the city's attorney confirmed the 99-YEAR lease!

TITLE 59 IMMUNITY WAS A TOTAL IMPOSSIBILITY UNDER THE LAW!

The City of Asbury Park’s reliance on local Ordinance 2362—regardless of its broad text targeting "any person," "any concerts," or "any public or private property"—is a total constitutional and statutory nullity because a local municipal ordinance can never legally supersede, dilute, or expand state contract and tort law structures.

In the hierarchy of New Jersey law, the doctrine of State preemption strips municipalities of any power to pass local codes that attempt to reshape courthouse dockets or manufacture public entity immunities out of thin air.

The City and its legal department possessed direct, actual notice of this legal boundary because Assignment Judge Linda Feinberg’s strict March 24, 2004 Injunction Mandate explicitly ruled that local codes cannot grant law enforcement authority to an unsworn civilian against state statute (N.J.S.A. 40A:14-118).

By using that identical void ordinance to enforce an extortionate 100-officer escrow lockout on September 17, 2004—four full days after the Police Captain had already legally bound the 50-Officer commercial contract baseline—the City fiduciaries engaged in an ultra vires act of civilian contract sabotage executed in direct criminal contempt of court (N.J.S.A. 2C:29-9) and Official Misconduct (N.J.S.A. 2C:30-2).

The City possessed absolute zero legal justification to invoke Title 59 notice-bars other than to actively Evade Judicial accountability for their defiance of Judge Feinberg's Mandates, rendering the August 2, 2005 default dismissal order an absolute subject-matter jurisdiction void that the Court must vacate under Rule 1:13-1 (Clerical Mistakes) and Rule 4:50-3 (Fraud Upon the Court).

The City's Legal branch holds absolute zero standing to assert that Ordinance 2362 authorized Jordan's venue shutdown, because local legislation cannot dilute un-capped marketplace liabilities. Pursuant to the explicit, non-discretionary command of N.J.S.A. 59:1-4, contract actions are completely and textually carved out from public entity immunities: "Nothing in this act shall affect the liability of the State or a public entity based upon contract."

Because the initial Case Information Statement (CIS) was formally processed and locked by the Court clerk strictly into the "Contract Dispute" track based on the Police Captain's bound security baseline, the Trial Court was entirely starved of subject-matter jurisdiction to apply a 90-day tort compliance notices barrier (N.J.S.A. 59:8-8).

Under the unyielding Supreme Court standard in B.W. King, Inc. v. Town of West New York, 49 N.J. 318 (1967), a public entity operating a 99-year master commercial leasehold track for the Paramount Theatre acts strictly as a private marketplace Landlord competitor, completely stripping the enterprise of all governmental shields.