ANGELO J. ONOFRI
`MERCER COUNTY PROSECUTOR
`By: John M. Jingoli Jr., Assistant Mercer County Prosecutor
`Attorney I.D. No. 009351975
`209 South Broad Street
`Trenton, New Jersey 08650-0068
`Telephone: (609) 989-6350
`
`STATE OF NEW JERSEY,
`
`Plaintiff,
`
`go
`
`$5,880.00 U.S. CURRENCY
`
`Defendant, In Rem.
`
`SUPERIOR COURT OF NEW JERSEY
`MERCER COUNTY
`LAW DIVISION - SPECIAL CIVIL PART
`
`Docket No. MER-DC- O~’i/O 75-220
`Prosecutor Forfeiture File No. F20-0200
`
`In Rem Civil Action
`
`Verified Complaint for Forfeiture of
`ContrabandPursuant to N.J.S.A. 2C:64-1
`through 2C:64-9
`
`Interrogatories
`
`Demand for Production of Documents
`
`Requests for Admissions
`
`Plaintiff, State of New Jersey, by and through the Office of the Mercer County
`
`Prosecutor, with its principal place of business located at 209 South Broad Street, Trenton, New
`
`Jersey 08650, says:
`
`1.
`
`This is a civil action for the forfeiture of contraband pursuant to N.J.S.A. 2C:64-1
`
`through N.J.S.A. 2C:64-9.
`
`The in rein Defendant is within the County of Mercer.
`
`On July 23, 2020, the City of Trenton Police Department seized the in rem
`
`2.
`
`3.
`
`Defendant.
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 1 of 24 Trans ID: SCP20201887555
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`MER DC 004075-20 10/28/2020 Pg 1 of 24 Trans ID: SCP20201887555
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`

`

`4.
`
`Javon T. Banks-Dawson is the owner of the in rem Defendant $5,880.00 U.S.
`
`Currency, and his principal place of residence is 65 South Walter Avenue, Trenton, New Jersey
`
`08609.
`
`5.
`
`One copy of the United States Currency Seizure Report (Control No. 200183)
`
`related to the in rem Defendant $5,880.00 is attached hereto.
`
`6.
`
`One copy of the Affidavit of Probable Cause is attached hereto. The facts set forth
`
`in same are incorporated as if set forth at length herein and set forth the basis for the criminal
`
`activity from which the seizure of the in rem Defendant arose.
`
`7.
`
`The circumstances related to the seizure of the in rem Defendant also resulted in
`
`Javon T. Banks-Dawson being charged with indictable crimes. One copy of Complaint No.
`
`1111-W-2020-002550 and Complaint No. 1111-W-2020-002619 which documents the
`
`aforementioned charges are attached hereto.
`
`8.
`
`The in rein Defendant was used in furtherance of criminal activity, or was
`
`intended to be used in furtherance of criminal activity, or was the proceeds of criminal activity.
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 2 of 24 Trans ID: SCP20201887555
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`

`

`WHEREFORE, Plaintiff demands judgment:
`
`1.
`
`Extinguishing any and all property interests of claimants in the in rem Defendant
`
`pursuant to N.J.S.A. 2C:64-1 through N.J.S.A. 2C:64-9, as of the date of the seizure;
`
`2.
`
`Forfeiting the in rem Defendant, to the State of New Jersey with title vesting in
`
`the County of Mercer as of the date of the seizure;
`
`3.
`
`4.
`
`Ordering attorney’s fees and costs of this suit; and
`
`Such other relief as the Court deems equitable and just.
`
`Date: Oct. i ~,, 2020
`
`ANGELO J. ONOFRI
`MERCER COUNTY PROSECUTOR
`
`By:/s/John M. Jingoli Jr.
`John M. Jingoli Jr.
`Assistant Mercer County Prosecutor
`(Attorney I.D. No. 009351975)
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 3 of 24 Trans ID: SCP20201887555
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`MER DC 004075-20 10/28/2020 Pg 3 of 24 Trans ID: SCP20201887555
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`

`

`Mercer County Treasurer’s Office Only:
`
`Control Number:
`
`1 ) Name:
`
`2) Address:
`(Street)
`
`(Last)
`
`(First)
`
`(City)
`
`4) Social Security #:
`
`(Zip)
`
`2 ~ SO 6) Work Telephone #:
`5) Home Telephone #: <-’~ " ~ ~’~"
`
`7) Seizing Agency:.
`
`8) ORI #:
`
`(Last)
`
`(First)
`
`(!VII)
`
`(Badge Number)
`
`11 ) Bureau/Section/Unit:
`
`12) Date of Seizure:
`
`"l
`
`(Street)
`
`$100(s) x ]~
`
`$ 50(s) x ti~
`
`$ 20(s)x /q q
`
`$ I O(s) x ~’
`
`$ 5(s) x ~
`
`$ l(s) x ~
`
`$ other(including coins)
`
`Total Seized: ~
`
`13) Time’of Seizure:
`
`(Municipality)
`
`(County)
`
`Claimant:
`
`( \
`Submitting Officer"-;
`
`-
`
`.-
`~--i "7
`Badge Number Date
`
`-
`
`Review: (Initials & Date)
`
`WHITE Treasurer’s Office YELLOW Treasurer’s Office PINK Prosecutor’s Office GOLD Arresting Agency
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 4 of 24 Trans ID: SCP20201887555
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`MER DC 004075-20 10/28/2020 Pg 4 of 24 Trans ID: SCP20201887555
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`

`

`VS.
`JAVON T BANKS-DAWSON
`ADDRESS :
`65 SOUTH WALTER AVENUE
`
`NJ 08609-0000
`
`TRENTON MUNICIPAL COURT
`225 N CLINTON AVE
`TRENTON NJ 08607-0000
`609 - 98 9 - 3 7 00 COUNTY OF: MERCER
`#ofCHARGES
`CO-DEFTS
`POLICE CASE#:
`3 20-007681
`COMPLAINANT HARRISON STEIMLE
`NAME: 225 NO CLINTON AVE
`ATTN: WARRANTS
`TRENTON
`
`TRENTON
`DEFENDANT INFORMATION
`SEX: M EYE COLOR: HAZEL
`DRIVER’S LIC.#. B04403908312965
`SOCIAL SECURITY #: xxx-xx-x543
`TELEPHONE #:
`( )
`LIVESCAN PCN #: 111106037916
`Purpose: This AffidavitJCertification is to more fully describe the facts of the alleged offense so that a judge or authorized judicial officer may determine
`probable cause.
`
`NJ 08607
`
`DOB: 12/10/1996
`DLSTATE: NJ
`
`SBI#: 436696G
`
`i. Description of relevant facts and circumstances which support probable cause
`that (i) the offense(s) was committed and (2) the defendant is the one who
`committed it:
`On Thursday, July 23, 2020 at approximately 1812 hours, we Unit 514 (Detective J.
`Vetter and I, Detective H. Steimle) along with Unit 513 (Detective R. Balestrieri and
`Detective N. Hogan) responded to the 400 block of Garfield Avenue on the report of
`suspicious persons engaging in the distribution of illegal narcotics. Trenton Police
`Communications notated in the CAD Event Report Notes, the suspicious persons were
`located near a red van and black Lexus. This area is known for quality of life
`violations, the open-air sales of illegal narcotics and gun violence. We were attired
`in the Patrol Uniform of the day with protective vests prominently displaying police
`identifiers and operating marked police vehicles. The time of day was evening
`during daylight hours with clear visibility.
`While traveling on Garfield Avenue from Farragut Avenue toward Hobart Avenue, I
`observed two males located in front of 440 Garfield Avenue near the red van which was
`parked behind the black Lexus facing the same direction. I immediately recognized one
`of the two males to be Defendant Javon Banks-Dawson standing in the street between
`the red van and a white Toyota Highlander parked directly behind it. On Wednesday
`July 22, 2020 I was contacted by a law enforcement officer from Falls Township Police
`Department in reference to Javon’s brother, Eric Dawson, who was wanted in reference
`to a shooting which occurred in Middletown Township, PA on that date. As we
`approached his location, I detected the odor of burnt CDS Marijuana in the i=~ediate
`area through the lowered front windows of our police vehicle. Javon appeared startled
`as he observed our approaching police vehicle, widened his eyes and bladed the right
`side of his body from my view as he began walking toward the sidewalk between the red
`van and white Toyota Highlander. I observed Javon clenching a crudely hand rolled
`brown cigar in his left hand. I exited and gave loud, clear and lawful commands for
`Javon and a Juvenile Offender (RJ) to stop. Simultaneously, Javon continued to walk a
`few steps and peered to his right along the sidewalk as if looking for an avenue of
`escape. I quickly closed the distance to Javon and observed a bulge in the front of
`his waistband which appeared to be weighted down. Waistbands are commonly used to
`conceal weapons and holster handguns. I conducted a pat-frisk. Javon awkwardly arched
`his lower back and stiffened his body as he nervously stared with widened eyes
`directly at me. ***SEE 2ND BOX***
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 5 of 24 Trans ID: SCP20201887555
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`
`

`

`Affidavit of Probable Cause
`THE STATE OF NEW JERSEY
`COMPLAINT NUMBER
`1111 I W 2020 1002550
`VS.
`JAVON T BANKS-DAWSON
`
`COURT CODE PREFIX
`YEAR
`SEQUENCE NO.
`2. I am aware of the facts above because: (Included, but not limited to: your observations,statements
`of eyewitnesses, defendant’s admission, etc.)
`
`I felt a hard object in the front of his pants below his waistband, which I
`immediately suspected to be a handgun, and ordered Javon to place his hands
`on the fence line for my safety and to negate his ability to flee. I felt the
`hard object again which I immediately recognized and confirmed to be a
`handgun and placed Javon in handcuffs behind his back. Further investigation
`revealed the handgun to be a loaded black Taurus model PT-24/7 PRO DS .40
`caliber semi-automatic handgun bearing serial number SCV96763 containing a 15
`round high capacity magazine. Further investigation of the hand rolled cigar
`revealed it to be burnt at one end and contained approximately 2 grams of
`greenish-brown vegetation suspected to be CDS Marijuana.
`
`3. If victim was injured, provide the extent of the injury:
`
`Certification:
`I certify that the foregoing statements made by me are true. I am aware that if
`any of the foregoing statements made by me are willfully false, I am subject to
`punishment.
`
`Signed: HARRISON STEIMLE LAW ENFORCEMENT OFFICER
`
`Date:
`
`07/23/2020
`
`Affidavit of Probable Cause
`Page 9 of 10 "~m2o,17
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 6 of 24 Trans ID: SCP20201887555
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`MER DC 004075-20 10/28/2020 Pg 6 of 24 Trans ID: SCP20201887555
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`

`

`COMP T -
`COMPLAINT NUMBER ........
`
`THE STATE OF NEW JERSEY
`
`SEQUENCE NO~
`
`COURT CODE PREFIX YEAR
`TRENTON MUNICIPAL COURT
`225 N CLINTON AVE
`TRENTON NJ 08607 - 0000
`609 - 989 - 3700 COUNTY OF: MERCER
`# of CHARGES
`CO-DEFTS
`POLICE CASE #:
`3
`1
`20-007681
`COMPLAINANT HARRISON STEIMLE
`NAME: 225 NO CLINTON AVE
`ATTN : WARRANTS
`TRENTON
`
`NJ 08607
`
`JAVON T BANKS-DAWSON
`
`ADDRESS :
`65 SOUTH WALTER AVENUE
`
`TRENTON
`DEFENDANT INFORMATION
`SEX: M EYE COLOR: HAZEL
`DRIVER’S LIC. #. B04403908312965
`SOCIAL SECURITY #: xxx-xx-x543
`TELEPHONE #:
`(
`LIVESCAN PCN #: 11110603"7916
`
`NJ 08609-0000
`
`DOB: 12/10/1996
`DLSTATE:
`SBI#: 436696G
`
`NJ
`
`defendantonorabout07/23/2020in TRENTON CITY MERCER Coun~,NJdid:
`WITHIN THE JURISDICTION OF THIS COURT, WHILE IN FRONT OF ~40 GARFIELD AVENUE THE
`DEFENDANT DID KNOWINGLY AND PURPOSELY VIOLATE THE FOLLOWING:
`
`CHARGE #I: DID POSSESS A CONTROLLED DANGEROUS SUBSTANCE TO WIT CDS MARIJUANA
`UNDER 50 GRAMS IN VIOLATION OF NJSA 2C:35-IOA(4)
`
`***DP***
`
`CHARGE #2: DID UNLAWFULLY POSSESS A BLACK TAURUS MODEL PT 24/7 PRO DS .40
`CALIBER SEMI-AUTOMATIC HANDGUN BEARING SERIAL NUMBER SCV96763 WITHOUT LICENCE OR
`PERMIT TO DO SO IN VIOLATION OF NJSA 2C:39-5B(I)
`
`***2ND DEGREE***
`
`in violation of:
`Original Charge
`
`1) 2C : 35-10A(4)
`
`2) 2C: 39-5B (1)
`
`3) 2C: 39-3J
`
`AmendedCharge
`CERTIFICATION: I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject
`to punishment.
`Signed: HARRISON STEIMLE
`You will be notified of your Central First Appearance/CJP date to be held at the Superior Court
`at the following address: MERCER COUNTY SUPERIOR CT
`400 SOUTH WARREN ST.
`TRENTON NJ 08650-0000
`Pho.e: 609-571-4000
`Date of Arrest: 0 7 / 2 3 / 2 0 2 0 Appearance Date: Time:
`PROBABLE CAUSE DETERMINATION AND ISSUANCE OF WARRANT
`Probable cause IS NOT found for the issuance of this complaint,
`
`in the county of MERCER
`
`Date: 07/23/2020
`
`Signature of Court AdminJs~’ator or Deput}, Court Administrator
`
`Date
`
`Signature of Judge
`
`Date
`
`I~ Probable cause IS found for the issuance of this complaint. SHEILA TAYLOR JUDICIAL OFFICER 07/:23/2020
`Signature and Title of Judicial Officer Issuing Warrant Date
`TO ANY PEACE OFFICER OR OTHER AUTHORIZED PERSON: PURSUANT TO THIS WARRANT YOU ARE HEREBY COMMANDED TO ARREST THE
`NAMED DEFENDANT AND BRING THAT PERSON FORTHWITH BEFORE THE COURT TO ANSWER THE COMPLAINT.
`Bail Amount Set: by:,
`
`[] Domestic Violence- Confidential
`Special conditions of release:
`~] No phone, mail or other personal contact w/victim
`[] No possession firearms/weapons
`[] Other (specify):
`
`/if different from iudicial officer that issued warrantt
`Related Traffic Tickets I [] Serious Personal Injury/Death
`or Other ComplaintsI Involved
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 7 of 24 Trans ID: SCP20201887555
`
`MER DC 004075-20 10/28/2020 Pg 7 of 24 Trans ID: SCP20201887555
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`

`

`THE STATE OF NEW JERSEY
`VS.
`JAVON T BANKS-DAWSON
`ADDRESS :
`65 SOUTH WALTER AVENUE
`
`NJ 08609-0000
`
`TRENTON MUNICIPAL COURT
`225 N CLINTON AVE
`TRENTON NJ 08607-0000
`6 0 9 - 9 8 9 - 3 7 0 0 COUNTY OF: MERCER
`#ofCHARGES
`CO-DEFTS
`POLICECASE#:
`4 20-007681
`COMPLAINANT HARRISON STEIMLE
`NAME: 225 NO CLINTON A~/E
`ATTN: WARRANTS
`TRENTON
`
`TRENTON
`DEFENDANT INFORMATION
`SEX: M EYE COLOR: HAZEL
`DRIVER’S LIC. #. B04403908312965
`SOCIAL SECURITY #: xxx-xx-x543
`TELEPHONE#:
`( )
`LIVESCAN PCN #:
`Purpose: This Affidavit!Certification is to more fully describe the facts of the alleged offense so that a judge or authorized judicial officer may determine
`probable cause.
`
`NJ 08607
`
`DOB: 12/10/1996
`DLSTATE: NJ
`
`SBI #:
`
`i. Description of relevant facts and circumstances which support probable cause
`that (i) the offense(s) was committed and (2) the defendant is the one who
`committed it:
`On July 23, 2020 at approximately 1812 hours I, Detective H. Steimle, arrested and
`signed Complaint Warrant W 2020 002550 against Javon Banks-Dawson. I applied for a
`search warrant of Javon’s vehicle (white 2019 Toyota Highlander bearing New Jersey
`registration VRB90G VIN 5TDJZRFHXKS726900). The Honorable Darlene J. Pereksta
`approved and signed the search warrant (DP-MER-2176-SW-20). On July 28, 2020 at
`approximately 2102 hours I executed the search warrant of the Toyota. A search of the
`Toyota revealed a clear plastic sandwich style bag tied in knot at one end containing
`greenish-brown vegetation, suspected to be CDS Marijuana (Under 50 grams) and a
`ripped piece of black plastic recovered from a pocket below the radio. Further
`investigation revealed the ripped piece of black plastic to contain fifteen (15)
`white oval prescription pills stamped "10/325 M523", suspected to be Oxycodone. This
`incident occurred within 1000 feet of the Hedgepeth-Williams Elementary School.
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 8 of 24 Trans ID: SCP20201887555
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`

`

`COMPLAINT -
`
`RRANT
`THE STATE OF NEW JERSEY
`
`TRENTON MUNICIPAL COURT
`225 N CLINTON AVE
`TRENTON NJ 08607 - 0000
`609 - 989 - 37 00 COUNTY OF: MERCER
`#ofCHARGES J CO-DEFTS I POUCE CASE #:
`4 20-007681
`COMPLAINANT HARRISON STEIMLE
`NAME: 225 NO CLINTON AVE
`ATTN : WARRANTS
`TRENTON
`
`NJ 08607
`
`JAVON T BANKS-DAWSON
`ADDRESS :
`65 SOUTH WALTER AVENUE
`
`TRENTON
`DEFENDANT INFORMATION
`SEX: M EYE COLOR: HAZEL
`DRIVER’S LIC. #. B04403908312965
`SOCIAL SECURITY #: xxx-xx-x543
`TELEPHONE #:
`( )
`LIVESCAN PCN #:
`
`NJ 08609-0000
`
`DOB: 12/10/1996
`DLSTATE:
`
`SBI#:
`
`NJ
`
`defendantonorabout07/23/2020in TRENTON CITY MERCER
`WITHIN THE JURISDICTION OF THIS COURT, WHILE AT 440 GARFIELD AVENUE
`DEFENDANT DID KNOWINGLY AND PURPOSELY VIOLATE THE FOLLOWING:
`
`County, NJ did:
`THE
`
`CHARGE #i: DID POSSESS A CONTROLLED DANGEROUS SUBSTANCE TO WIT CDS MARIJUANA
`LTNDER 50 GRAMS IN VIOLATION OF NJSA 2C:35-IOA(4)
`
`***DP***
`
`CHARGE #2: DID POSSESS A CONTROLLED DANGEROUS SUBSTANCE TO WIT OXYCODONE IN
`VIOLATION OF NJSA 2C:35-IOA(I)
`
`***3RD DEGREE***
`
`CHARGE #3 : DID
`in violation of:
`Original Charge
`
`POSSESS A CONTROLLED DANGEROUS SUBSTANCE TO WIT OXYCODONE WITH
`
`2) 2C:35-IOA(I)
`
`3) 2C:35-5A(I)
`
`11) 2C:35-IOA(4)
`I
`
`AmendedCharge
`CERTIFICATION: I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject
`to punishment
`Signed: HARRISON STEIMLE Date: 07/29/2020
`
`in the county of MERCER
`
`~’ou will be notified of your Central First Appearance/CJP date to be held at the Superior Court
`at the following address: MERCER COUNTY SUPERIOR CT
`400 SOUTH WARREN ST.
`Date of Arrest:
`
`Appearance Date:
`
`TR"*~TON *~’~ o8~so-oooo
`Time:
`Phone: 609-571-4000
`PROBABLE CAUSE DETERMINATION AND ISSUANCE OF WARRANT
`Probable cause IS NOT found for the issuance of this complaint.
`
`Signature of Court Administrator or Deput~ Court Administrator
`
`Date
`
`Signature of Judge
`
`Date
`
`[~ Probable cause IS found for the issuance of this complaint. LOURDES COSME J~J’DICIAL OFFICER 07/29/2020
`¯
`Signature and Title of Judicial Officer Issuing Warrant
`Date
`TO ANY PEACE OFFICER OR OTHER AUTHORIZED PERSON: PURSUANT TO THIS WARRANT YOU ARE HEREBY COMMANDED TO ARREST THE
`NAMED DEFENDANT AND BRING THAT PERSON FORTHWITH BEFORE THE COURT TO ANSWER THE COMPLAINT.
`Bail Amount Set: by:
`
`Domestic Violence - Confidential
`Special conditions of release:
`13 No phone, mail or other personal contact w/victim
`[3 No possession firearms/weapons
`13 Other (specify):
`
`/if different from iudicial officer that issued warrant/
`Related Traffic Tickets
`13 Serious Personal Injury/Death
`or Other Complaints
`Involved
`ORIGIN
`
`Page
`
`,tlt2o,7
`
`MER-DC-004075-20 10/28/2020 4:13:54 PM Pg 9 of 24 Trans ID: SCP20201887555
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`MER DC 004075-20 10/28/2020 Pg 9 of 24 Trans ID: SCP20201887555
`
`

`

`COMPLAINT - WARRANT
`COMPLAINT NUMBER
`1111 W 2020 002550 STATE V.
`COURT.DE
`PREFIX
`YEAR
`SEQUENCENO.
`CHARGE #3: DID POSSESS A PROHIBITED DEVICE MORE SPECIFICALLY A HIGH CAPACITY
`MAGAZINE CAPABLE OF CONTAINING 15 ROUNDS OF AMMUNITION IN VIOLATION OF NJSA
`2C:39-3J
`
`JAVON T BANKS-DAWSON
`
`***4TH DEGREE***
`
`Original Charge
`
`Amended Charge
`
`COMPLAINT - WARRANT
`Page 2 of 10
`NJ/CDR2 1/1/2017
`
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`
`

`

`STATE V.
`
`Amount Bail Set: $.
`
`Committed
`w/o Bail
`
`Place Committed:
`Date of First
`[] Advised of Rights by.
`Appearance:
`Prosecuting Attorney Information
`
`[] Bail Recog. Attached
`
`Date Referred to
`County Prosecutor:
`
`Defendant Desires Counsel:
`[] Yes 13 No
`Defense Counsel Information
`
`Name:
`State County I MunicipalI
`Original Charge
`
`Other
`
`1) 2C: 35-10A(4)
`
`Name:
`N )ne J
`
`2)
`
`Retained
`
`I Public Def
`I
`2C: 39-5]~ (1)
`
`Assigned
`
`I Waived I
`
`3) 2C: 39-3,3"
`
`Other
`
`Amended Charge
`Waiver Indt/Jury
`Plea/Date of Plea
`
`Adjudication (* see code)
`
`Jail Term
`
`Probation Term
`Cond. Discharge Term
`
`Community Service
`
`D/L Suspension Term
`
`Fines/Costs
`VCCB/SNSF
`DEDR/Lab Fee
`CD Fee/Drug Ed Fnd
`DV Surch/Other Fees
`Restitution
`Beneficiary:
`
`Plea:
`
`Finding
`Code:
`
`Date:
`
`Date:
`
`Jail time credit
`
`ISusp. Imp
`
`Susp. Imp
`
`Plea:
`
`Finding
`Code:
`
`Date:
`
`Date:
`
`Plea:
`
`Finding
`Code:
`
`Date:
`
`Date:
`
`Jail time credit
`
`Susp. Imp
`
`I Jail
`
`time credit
`
`Susp. Imp
`
`Susp. Imp
`
`Susp, Imp
`
`Fines:
`
`VCCB:
`
`DEDR:
`
`CD:
`
`DV:
`
`Costs:
`
`SNSF:
`
`LAB:
`
`DAEF:
`
`Other:
`
`Fines:
`
`VCCB:
`
`DEDR:
`
`CD:
`
`DV:
`
`Costs:
`
`SNSF:
`
`LAB:
`
`DAEF:
`
`Other:
`
`Fines:
`
`VCCB:
`
`DEDR:
`
`CD:
`
`DV:
`
`Costs:
`
`SNSF:
`
`LAB:
`
`DAEF:
`
`Other:
`
`Miscellaneous Information, Adjournments, Companion Complaints, Co-Defendants, Case Notes:
`
`Related Traffic Tickets and Complaints:
`
`* Finding Codes
`
`1 - Guilty
`2 - Not Guilty
`3 - Dismissed - Other
`4 - Guilty but Merged
`5 - Dismissed-Rule
`6 - Dismissed Lack of Prosecution
`7 - Dismissed - Pros MotionNic Req
`8 - Conditional Discharge
`D - Dismissed- Prosecutor Discretion
`M - Dismissed- Mediation
`P - Dismissed-Plea Agreement
`S - Disposed at Supedor
`W- Dismissed-False ID
`
`JUDGE’S SIGNATURE
`
`DATE
`
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`
`

`

`COMPLAINT - WARRANT
`
`Action)
`
`COMPLAINT NUMBER
`
`STATE V.
`
`1111 W 2020 002550
`YEAR
`PREFIX
`COU~ CODE
`FTA Bail Information ~)ate Bail Set:
`Committed
`Released
`R.O.R.
`Committed
`on Bail
`Default
`w/o Bail
`
`SEQUENCE NO.
`
`Amount Bail Set: $.
`
`(q)
`Date of First
`Appearance:
`Prosecuting Attorney Information
`Name: Name:
`State
`None
`Other
`County Municipal
`
`Place Committed:
`[] Advised of Rights by.
`
`JAVON T BANKS-DAWSON
`
`by:.
`
`i-I Bail Recog. Attached
`Date Referred to
`County Prosecutor:
`Defendant Desires Counsel:
`[] No
`[] Yes
`Defense Counsel Information
`
`Public Def
`
`Assigned
`
`Waived
`
`Other
`
`II Retained
`
`Original Charge
`
`Amended Charge
`Waiver Indt/Jury
`
`Plea/Date of Plea
`
`Adjudication (* see code)
`
`Jail Term
`
`Probation Term
`Cond. Discharge Term
`
`Community Service
`
`D/L Suspension Term
`
`Plea:
`
`Finding
`Code:
`
`Date:
`
`Date:
`
`Plea:
`Finding
`Code:
`
`Date:
`
`Date:
`
`Plea:
`Finding
`Code:
`
`Date:
`
`Date:
`
`Jail time credit
`
`Susp. Imp
`
`Jail time credit
`
`Susp. Imp
`
`Jail time credit
`
`Susp. Imp
`
`Susp. Imp
`
`Susp. Imp
`
`Susp. Imp
`
`Fines:
`
`VCCB:
`
`DEDR:
`
`CD:
`
`DV:
`
`Costs:
`
`SNSF:
`
`LAB:
`
`DAEF:
`
`Other:
`
`Fines/Costs
`VCCB/SNSF
`DEDR/Lab Fee
`CD Fee/Drug Ed Fnd
`DV Surch/Other Fees
`Restitution
`Benefician/:
`Miscellaneous Information, Adjournments, Companion Complaints, Co-Defendants, Case Notes:
`
`Fines:
`
`VCCB:
`
`DEDR:
`
`CD:
`
`DV:
`
`Costs:
`
`SNSF:
`
`LAB:
`
`DAEF:
`
`Othe~
`
`Related Traffic Tickets and Complaints:
`
`Fines:
`
`VCCB:
`
`DEDR:
`
`CD:
`
`DV:
`
`Costs:
`
`SNSF:
`
`LAB:
`
`DAEF:
`
`Other:
`
`* Finding Codes
`
`1 - Guilty
`2 - Not Guilty
`3 - Dismissed - Other
`4 - Guilty but Merged
`5 - Dismissed-Rule
`6 - Dismissed Lack of Prosecution
`7 - Dismissed - Pros MotionNic Req
`8 - Conditional Discharge
`D - Dismissed- Prosecutor Discretion
`M - Dismissed- Mediation
`P - Dismissed-Plea Agreement
`S - Disposed at Supedor
`W- Dismissed-False ID
`
`JUDGE’S SIGNATURE
`
`DATE
`
`COMPLAINT - WARRANT(Court Action)
`Page 4 of 10
`NJ/CDR2 1/1/2017
`
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`

`

`F20-0200
`
`Verification
`
`I, Harrison Steimle, of full age, hereby certify as follows:
`
`1.
`
`2.
`
`3.
`
`I am an officer with the City of Trenton Police Department.
`
`I am personally familiar with the factual allegations contained herein.
`
`The factual allegations in the foregoing Verified Complaint are true.
`
`I certify that the foregoing statements made by me are true. I am aware that if any of the
`foregoing statements made by me are willfully false, I am subject to punishment.
`
`Dated:
`
`Harr~n S~in~le~
`Officer’ Cit~, of Trenton Police Department.
`
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`

`

`Certification Pursuant to R. 4:5-1
`
`I, John M. Jingoli Jr., of full age, hereby certify as follows:
`
`The matter in controversy is not the subject of any other civil action pending in
`any court or of a pending civil arbitration proceeding, no such action or arbitration
`proceeding is contemplated at this time.
`
`At present, there are no non-parties, other than the claimant(s) identified in the
`Verified Complaint, who should be joined in this action pursuant to R__~. 4:28, or
`who is subject to joinder pursuant to R___~. 4:29-1(b) because of potential liability to
`any party on the basis of the same transactional facts.
`
`The cause of action that forms the basis for the within litigation is the subject of a
`criminal action brought before the Mercer County Superior Court, Law Division -
`Criminal Part under Prosecutor File No. 20-2024.
`
`Confidential personal identifiers have been redacted from documents now
`submitted to the court and will be redacted from all documents submitted in the
`future in accordance with R__~. 1:38-7(b).
`
`I certify that the foregoing statements made by me are true. I am aware that if any of the
`foregoing statements made by me are willfully false, I am subject to punishment.
`
`Date: Oct. ]b , 2020
`
`/s/John M. Jin~oli Jr.
`John M. Jingoli Jr.
`Assistant Mercer County Prosecutor
`
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`

`

`****FOR CLAIMANTS IN CIVIL FORFEITURE ACTIONS****
`
`NOTICE TO CLAIMANTS: THE STATE MAY NOT USE ANY STATEMENTS MADE BY
`YOU IN YOUR ANSWER TO THIS FORFEITURE COMPLAINT IN ITS CASE IN CHIEF IN A RELATED
`CRIMINAL CASE.
`
`You MUST file an answer to the complaint within thirty-five days of receipt of the
`complaint to avoid losing the forfeiture case by default. However, you may then ask the Court
`to stay (delay) the forfeiture case until any criminal prosecution is concluded pursuant to 2C:64-
`3(f).
`
`You may wish to consult with a lawyer before deciding whether to file an answer, a
`motion for a stay, or any other pleading in the forfeiture case. If a criminal case is pending, you
`should contact the attorney who represents you in the criminal case. Even if your criminal
`attorney cannot represent you in the forfeiture action, your criminal attorney may be able to
`provide you with some important advice about this matter.
`
`A courtesy copy of this notice has been served on your currently known criminal
`defense attorney.
`
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`

`

`Initial Interrogatories to Claimants
`
`Pursuant to R___~. 6:4-3 and R._~. 4:17, Plaintiff hereby demands individually from each
`claimant answers in writing and under oath to the following initial interrogatories within thirty
`(30) days of the date of service of these interrogatories and the Verified Complaint in this action.
`
`Date: October ]~ , 2020
`
`By:
`
`ANGELO J. ONOFRI
`MERCER COUNTY PROSECUTOR
`
`/s/John M. Jingoli Jr.
`John M. Jingoli Jr.
`Assistant Mercer County Prosecutor
`(Attorney I.D. No. 009351975)
`
`Definitions
`
`"Currency" refers to and means each in rem defendant Currency in this action.
`
`"Motor Vehicle" refers to and means each in rem defendant motor vehicle in his action.
`
`Interrogatories
`
`1. What is your full name, current address, social security number, date of birth, and all
`other names by which you have ever been known?
`
`2. What was your primary residential address on July 23, 2020?
`
`3. What other addresses did you reside at, on more than one occasion, during the six months
`preceding July 23, 2020?
`
`4. What is the name, date of birth, and relation to you of each person that resided with you
`on July 23, 2020?
`
`5. As to each item identified as an in rem defendant in this action, who are the owners, and
`what is your relationship to the owner? Please provide the address of each owner.
`
`6. As to each in rem defendant in this action that you claim to have an ownership interest in:
`
`a. How did you first obtain it?
`
`b. Where did you first obtain it?
`
`c. When did you first obtain it?
`
`d. From whom did you first obtain it?
`
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`

`

`e. Why did you first obtain it?
`
`f. Does any other person or company have a property interest in it?
`
`g. To what use did you put it?
`
`h. Do you have a receipt documenting how you obtained it?
`
`i. Who did you allow to use it and for what purpose and when?
`
`j.
`
`If you believe that it should not be forfeited, explain why and set forth each and
`every fact supporting your belief.
`
`7. What is the name, address, and telephone number of each employer who has employed
`you during the last five years?
`
`8. What are the sources of your income for the thirty-six months preceding July 23, 2020?
`As to each source, set forth the amount of income you received.
`
`9. Please identify:
`
`a. Each person you intend to call as a witness at any trial or arbitration of this
`matter, including their name, address, and telephone number; and
`
`b. Describe in detail the substance of each potential witness’ testimony.
`
`10. What witnesses do you plan to call as experts to give opinion testimony in the trial of this
`matter? Provide their name, address, and telephone number. Please also supply all
`reports drafted and prepared by each expert witness. As to each expert witness:
`
`a. What are the expert’s qualifications and area of expertise?
`
`b. As to what facts will they testify?
`
`c. On what facts is their expert opinion based?
`
`d. What is their opinion as to which they will testify?
`
`11. What are the names, addresses, and telephone numbers of each and every individual
`whom you believe has knowledge of any relevant facts relating to this civil action?
`
`12. Please disclose the existence, description, nature, custody, condition, location, and
`contents of any and all documents (including papers, books, accounts, drawings, graphs,
`charts, videotapes, movies, and photographs) and any other data compilations from which
`information may be obtained and any other tangible things which constitute or contain
`
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`

`

`matters relevant to the subject matter in this action; and please describe same with
`sufficient particularity so that they can be described in a request for production.
`
`13. Please identify any statement you have obtained from any person regarding this incident.
`
`14. On what dates, if any, have you been found guilty of an offense in any jurisdiction?
`
`15. On what dates, if any, have you been convicted of a crime in any jurisdiction?
`
`16. Identify all documents that may relate to this action and attach a copy of each. Please
`also identify the document’s author, the date of the document, and the number of pages.
`
`17. If there is an in rem defendant in this action that is a Motor Vehicle, as to each such
`Motor Vehicle:
`
`a. What is the name, address, and relationship to you of each person who operated
`the Motor Vehicle during the week before its seizure on July 23, 2020?
`
`b. Who was the last person to operate the Motor Vehicle prior to its seizure by the
`City of Trenton Police Department on July 23, 2020?
`
`c.
`
`Identify all persons with an ownership interest in the Motor Vehicle by providing
`their name, address, and the nature of their ownership interest.
`
`do During the twelve months prior to the seizure of the Motor Vehicle on July 23,
`2020, how many times did you drive the Motor Vehicle, and as to each such
`occasion, what was the purpose, distance, and time driven?
`
`eo During the twelve months prior to the seizure of the Motor Vehicle on July 23,
`2020, how many times did someone other than you drive the Motor Vehicle, and
`as to each such occasion, what was the purpose, distance, and time driven?
`
`Identify every insurance policy (by number, name of the insuring company, and
`name and address of the insurance agent) that has insured the Motor Vehicle since
`it came into the possession of the person to whom it was registered on July 23,
`2020.
`
`g. What are the dates and locations of each accident the Motor Vehicle has been
`involved in, and who were the driver and passengers in the Motor Vehicle at the
`time of each accident?
`
`ho
`
`If the Motor Vehicle has been involved in any incident where a summons for a
`violation of the Motor Vehicle Code of New Jersey - or that of any other
`jurisdiction - was issued, what is the date, location, summons number, and
`violation for each such incident and who were the driver and passengers in the
`Motor Vehicle at the time?
`
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`

`

`During the twelve months prior to July 23, 2020, how many times did a mechanic
`work on the Motor Vehicle, what was the purpose of each such instance, what
`work was performed, and who paid for the work?
`
`jo
`
`What was the make, model, year, ovemight location, registered owner, and lessor
`of each motor vehicle other than the Motor Vehicle that you had access to drive
`during the twelve months prior to July 23, 2020?
`
`k. As to each motor vehicle listed in the response to (j.), above:
`
`i. What is the policy number, name, and address of the company insuring it?
`
`ii. What is the name of the person who paid the insurance premiums to it?
`
`iii. What is the name, address, and telephone number of each person or
`business that serviced the motor vehicle?
`
`iv. What is the name of each person who drove the motor vehicle in the
`twelve months prior to July 23, 2020?
`
`v. How many times was the motor vehicle driven by someone other than
`yourself in the twelve months prior to July 23, 2020?
`
`vi. Under what conditions was the mo