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The City of Asbury Park NJ fraudulently induced Title 59 Immunity to Evade Judicial Accountability (Evasion of Justice) for the ultra vires acts of L. Louis Jordan, which were ratified by City Officials, in defiance of a Judicial Mandate and Superior Court Order. Mr Jordan was stripped of command powers and prohibited from exercising police powers by way of a Superior Court Order, successfully obtained by the NJ State Attorney General's Office. These material facts were fraudulently concealed, while the City represented to the Superior Court that Mr Jordan was directed to cease ALL law enforcement duties (Fraud Upon the Court).

The City of Asbury Park used the language in their null and void ordinance 2362 to invoke an inapplicable permit process to hide behind Title 59 Immunity by trying to make this business dealing a government function. Under the City's 99 year lease, Redevelopment and Easement agreements, Title 59 Immunity is an IMPOSSIBILTY under the NJ Supreme Court's B. W. Standard and the Tort Claims Act they hid behind--NJSA 59:1-4.

The City's initiative to Evade Justice for Contempt of Court and to avoid Sanctions, removal from Office and loss of pensions their actions destroyed a local entrepreneur and by doing such they committed Fraud Upon the Court, Common Law Fraud, Insurance Fraud, Civil Rights and Constitutional Rights Violations, Tampering, Official Misconduct and more...

It was easier to deceive the local entrepreneur than it was to face the consequences for violating Judge Feinberg's Judicial Mandate and Superior Court Order! The motion to vacate the IMPOSSIBLE dismissal has been filed to vacate for Fraud Upon the Court (Rule 4:50-3) and Clerical Error (Rule 1:13-1) which both have zero-time restrictions.

All surprise(s), trick(s), cunning(s), dissembling and other unfair ways that is used to cheat anyone is considered as fraud. Kerr, Fraud and Mistake, 1 (7th ed. (1952)). See also 37 Am. Jur.2d, Fraud and Deceit § 1, pp. 17-20 (1968); Riverside Trust Co. v. Collin, 114 N.J. Eq. 157 (E. & A. 1933).

The City of Asbury Park NJ, Mr Louis Jordan (Long Branch NJ--NAACP) and the Attorneys reserve the right to file a lawsuit for Defamation, Slander and Libel within one year of the 7/15/2026 motion to vacate filing date for the void dismissal, if these undisputed Material Facts are incorrect.

Evidence shows the City of Asbury Park NJ Weaponized the Court System to commit fraudulent acts that are logged on the Court's Registry to Evade Judicial Accountability!

By doing such the City is in violation of NJLAD, the Monell Doctrine, Due Process, Breach of Contract, Tortious Interference, Equal Protection, Fraudulent Concealment and more. The non hearsay documents speak for themselves!

Under the landmark New Jersey Supreme Court standard established in B.W. King, Inc. v. Town of West New York, 49 N.J. 318 (1967), a public entity is entirely stripped of all governmental sovereign immunities, public safety protections, and licensing shields the exact instant it enters the open market to operate a commercial real estate venture under a 99-year master commercial leasehold for the Paramount Theatre.

In the regulatory and ethical jurisprudence of New Jersey, a licensed Attorney cannot present one version of reality in a pleading logged on Court Record and then deliver the diametrically opposite factual layout to a State Administrative Agency to process a compliance file. These facts are locked in on record.

This Fraudulently Invoking of Title 59 Immunity and maintaining such on-Court Record is not only Fraud Upon the Court but is a Constitutional Violation of the Plaintiff's Procedural Due Process Rights.

FRAUDULENT CONCEALMENT OF MATERIAL FACTS

Under the Imputed Knowledge Doctrine, when entities contractually coordinate their field operations under a master 99-year commercial leasehold network, their independent buckets of notice are poured into a single, legally unified enterprise memory. "We work in conjunction with the City and Police (Jordan)" -- Box Office Manager Asbury Park Press.

The NJ Supreme Court recognizes Fraudulent Concealment as a separate tort action. Tartaglia v. UBS PaineWebber, Inc., et al., 2008 WL 5274869 (N.J. Supreme Court, December 16, 2008).

In a PRECEDENTIAL DECISION, the Superior Court, Appellate Division, in Catena v. Raytheon Company, et al.,(August 18, 2016), held that the Discovery Rule applied to common law fraud claims (Fraudulent Concealment) as well as fraud claims under New Jersey's Consumer Fraud Act (CFA) even if discovered 17 years afterwards and filed 20 years later.

The Catena Court emphasized that the discovery rule "is designed to avoid harsh results that otherwise would flow from mechanical application of a statute of limitations." A party may not benefit from its own fraudulent conduct. Joe D'Egidio Landscaping, Inc. v. Apicella, 337 N.J. Super. 252, 257 (App. Div. 2001).

The Inescapable Proprietary Landlord Capacity Bar (B.W. King): Under the landmark New Jersey Supreme Court standard established in B.W. King, Inc. v. Town of West New York, 49 N.J. 318 (1967), a public entity is entirely stripped of all governmental sovereign immunities, public safety protections, and licensing shields the exact instant it enters the open market to operate a commercial real estate venture under a 99-year master commercial leasehold.

The B. W. King Standard wipes out ALL IMMUNITY including the public safety PRETEX -- under a contract dispute Court Docket!

The unmasked scheme shows City Executives and their Legal Branch used Title 59 Immunity to Evade Judicial Accountability for ultra vires acts in defiance of the March 2004 Judicial Mandate and July 2004 Court Order!

In the case Platinum Links Ent v Atlantic City Surf Pro Baseball Club 2002. 3rd Circuit United States District Court, the Hon Judge Joseph E. Irenas noted that the City's attempt to block the show was based on a "dislike of the message" and an unfair stereotype of rap fans. The ruling emphasized that Officials could not single out rap music for cancellation while allowing other genres.

NJLAD; Using "public safety" as a justification to cancel or restrict a specific genre of music (like rap) after the police and venue has already approved security measures for the event is discriminatory. It is a pretext for bias against the artists, promoter(s) and the audience.

Equitable Estoppel - Equitable Tolling

In the Catena appeal, the Appellate Division's decision reinforces the equitable nature of the Discovery Rule in New Jersey. The Court emphasized that the Discovery Rule "is designed to avoid harsh results that otherwise would flow from mechanical application of a statute of limitations."

In the context of FRAUD ESPECIALLY, "the victim's lack of awareness of the fraud is the wrongdoer's very object. The rule thus prevents the Defendant(s) from benefiting from his own deceit."