Razzana V County of Nassau Et Al.

Case 2:07-cv-03983-ADS-AKT Document 17 Filed 11/27/2007 Page 1 of 17
La Reddola, Lester & Associates, LLP

Robert J. La Reddola (RJL 6501)
Attorneys for Plaintiff
Gabriel Razzano
600 Old Country Road, Suite 224
Garden City, New York 11530
(516) 745-1951
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
--------------------------------------------------------------x
GABRIEL RAZZANO,
Plaintiff,
Civil Case No. 07-CV-3983
-against-
AMENDED
COUNTY OF NASSAU, NASSAU COUNTY COMPLAINT
POLICE DEPARTMENT, POLICE
COMMISSIONER LAWRENCE W. MULVEY,
DETECTIVE SAMANAGO, POLICE OFFICER
MISTROTTA, POLICE OFFICER LIMEAUX, and
REPRESENTATIVE CAROLYN McCARTHY,
Defendants.
--------------------------------------------------------------x
Plaintiff, GABRIEL RAZZANO, by his attorneys, La Reddola, Lester &
Associates, LLP, as and for his complaint against the Defendants respectfully sets forth:
PRELIMINARY STATEMENT
1. This is a civil rights action for monetary damages brought under 42 U.S.C
§1983 and other pendant state causes of action against Defendants COUNTY OF
NASSAU (“NASSAU COUNTY”), NASSAU COUNTY POLICE DEPARTMENT,
POLICE COMMISSIONER LAWRENCE W. MULVEY DETECTIVE SAMANAGO,
POLICE OFFICER MISTROTTA, POLICE OFFICER LIMEAUX (the “Police
Defendants”), and others for committing acts under color of law and depriving Plaintiff
of rights secured by the Constitution and laws of the United States and the State of New
1
York. Plaintiff further alleges that Defendant U.S. Representative CAROLYN
McCARTHY (“Rep. McCARTHY”) and the Police Defendants, their agents, servants
and employees, conspired to violate his Constitutional First Amendment right to petition
the government.
JURISDICTION AND VENUE
2. This Court has jurisdiction of this action under 28 U.S.C. §§1331 and
1343 in that Defendants’ conduct violated rights guaranteed to Plaintiff under the First
and Fourteenth Amendments of the United States Constitution. This Court has
supplemental jurisdiction over Plaintiff’s state law claim under 28 U.S.C. §1367(a).
3. Venue in this District is proper under 28 U.S.C. §1391(b), since
Plaintiff’s claims arose in the Eastern District of New York and upon information and
belief, all parties currently reside or maintain offices in Nassau County.
PARTIES
4. Plaintiff, GABRIEL RAZZANO is a citizen of the State of New York and
a resident of Nassau County who resides at 135 Gordon Place, Freeport, New York
11520.
5. Defendant, NASSAU COUNTY is a duly constituted municipal
corporation of the State of New York existing and operating under and by the virtue of
the laws of the State of New York.
6. Defendant, NASSAU COUNTY POLICE DEPARTMENT (herein after
“N.C.P.D.”) was and is an agency of the COUNTY and is headquartered at 1490 Franklin
Avenue, Mineola, New York 11501.
2
7. Defendant LAWRENCE W. MULVEY is the Police Commissioner for
the N.C.P.D. (“COMMISSIONER MULVEY”).
8. Defendant, DETECTIVE SAMANAGO (“DET. SAMANAGO”) is an
officer of the N.C.P.D., and at all times relevant to this action, acted in his capacity as an
officer of the N.C.P.D.
9. Defendants, POLICE OFFICER MISTROTTA (“P.O.MISTROTTA”) and
POLICE OFFICER LIMEAUX (“P.O. LIMEAUX”) are officers of the N.C.P.D. and at
all times relevant to this action, acted in their capacity as officers of the N.C.P.D.
10. Defendant U.S. Representative CAROLYN McCARTHY is the
Representative for the Fourth Congressional District of New York in the United States
House of Representatives and has offices at 200 Garden City Plaza, Garden City, New
York 11530 (the “Long Island Office”).
FACTUAL ALLEGATIONS
11. Plaintiff is a member of the Minuteman Civil Defense Corp., a group
organized under the First Amendment, which campaigns for the security of the “borders
and coastal boundaries of the United States . . . against the unlawful and unauthorized
entry of all individuals, contraband, and foreign military.”1
12. Plaintiff is also the owner of several firearms, which include pistols,
handguns and long arms.
13. At the time in question, Plaintiff was a constituent of Rep.
McCARTHY’s congressional district. Therefore, Plaintiff had a constitutionally protected
State and Federal right to petition Rep. McCARTHY.
1
Mission Statement of the Minuteman Civil Defense Corps., found at www.minutemanhq.com
3
14. Rep. McCARTHY is a well known and outspoken advocate of gun
control, and an advocate for the illegal alien population.
15. Upon information and belief, NASSAU COUNTY and the Police
Defendants have instituted a procedure under which they wrongfully confiscate registered
long arms, and then fail to formally notify the gun owners of the reasons why the
government is holding the property or of the steps that can be taken to challenge the
government’s actions.
16. Pursuant to Penal Law §400.00(2) licenses may be obtained for pistols
and revolvers, however, this statute is silent on the licensing of long arms. Likewise,
Penal Law §400.00(11) provides the procedure for the revocation of licenses, which do
not include long arms.
17. Thus, the laws of the State of New York do not delineate a procedure
under which long arms may be confiscated and later retrieved.
18. Upon information and believe, Rep. McCARTHY knew or had reason to
know about the Police Defendants’ new policy on confiscation of long arms along with
pistols when conducting an inquiry about pistol license matters.
Plaintiff’s Correspondence with Rep. McCARTHY
19. Beginning in early 2003, Plaintiff began writing to Rep. McCARTHY
about the increasing number of persons he believed to be illegal aliens in and around his
neighborhood. Plaintiff sent to Rep. McCARTHY no fewer then approximately 15
letters over the period of time from March 28, 2002 to March 2007.
20. Rep. McCARTHY responded to a few of Plaintiff’s letters and has
forwarded to his attention several letters she had written to the U.S. Department of
4
Homeland Security and the Bureau of Immigration and Customs Enforcement, explaining
to these governmental entities Plaintiff’s concerns.
21. Plaintiff had also, on several occasions, communicated with Jim Hart,
Rep. McCARTHY’s former chief of Staff, about the issues plaguing his community.
22. In early March 2007, plaintiff called Rep. McCARTHY’s office and
asked to speak with Jim Hart. Plaintiff was advised that Jim Hart no longer worked with
Rep. McCARTHY. Plaintiff then asked that Rep. McCARTHY’s new chief of staff
return his call. Plaintiff never received a call back.
Plaintiff is Advised he is not a Constituent of Rep. McCarthy’s District
23. On March 12, 2007, Plaintiff went to Rep. McCARTHY’s Long Island
Office to request an appointment with Rep. McCARTHY. Plaintiff was told that he was
not a member of Rep. McCARTHY’s Congressional district and that he should cease
communications with her office. Rep. McCARTHY’s assured Plaintiff that they would
straighten out the situation.
24. On March 19, 2007, having not heard back from Rep. McCARTHY’s
office, Plaintiff again went to Rep. McCARTHY’s Long Island Office and again
requested an appointment. Plaintiff was again advised that he was not a constituent of
Rep. McCARTHY’s district and instructed him to visit the Nassau County Board of
Elections to clarify any possible confusion.
25. Immediately thereafter, Plaintiff waited on line at the Nassau County
Board of Elections to obtain a stamped official copy of his Certificate of Registration
along with a Voter Registration Printout, copies of which are annexed as Exhibit A,
5
which showed Plaintiff as registered to vote and a constituent of Rep. McCARTHY’s
Fourth Congressional District.
26. Plaintiff traveled to David Denenberg’s office and spoke to his
Legislative Assistant, Kyle, about the issue of illegal aliens in our local jail system and
then went immediately back to Rep. McCARTHY’s Long Island Office, with his proof
that he was indeed a constituent of Rep. McCARTHY with the intention of again
requesting an appointment with the Congresswoman to discuss illegal immigration
issues.
Nassau County Police Department Infringe Plaintiff’s First Amendment Rights
27. While waiting in the reception area, Plaintiff was approached by DET.
SAMANAGO, a detective with the Nassau County Police Department., who informed
Plaintiff that he was not in Rep. McCARTHY’s district and that he should leave Rep.
McCARTHY’s office alone. DET. SAMANAGO then told Plaintiff to stop “annoying”
Rep. McCARTHY and not to contact Rep. McCARTHY on any issue until he
straightened this “entire situation out.”
28. By acting in this manner, DET. SAMANAGO, as a representative of the
Police Defendants and under the color of state law, has caused Plaintiff’s state and
federal right to petition the government and to free speech to be infringed.
29. Plaintiff was then escorted out of Rep. McCARTHY’s office and into an
elevator by DET. SAMANAGO. When the elevator reached the lobby and the doors
opened, Plaintiff came face to face with Rep. McCARTHY who had been waiting for an
elevator. Plaintiff, over the protest of DET. SAMANAGO, told Rep. McCARTHY “Ms.
Mc Carthy, I have been trying to meet with you”. Rep. McCARTHY ignored Plaintiff
6
and his comment and proceeded into the elevator. Plaintiff was then escorted out of the
building by DET. SAMANAGO.
30. Later that day, Plaintiff received a call from DET. SAMANAGO who
told him that there had been an error in the Board of Election’s placement of Plaintiff in
Rep. McCARTHY’s district and that Plaintiff was not in fact a member of her district and
he must cease communications with her office on illegal immigration issues and all other
issues.
Plaintiff’s Firearms and Longarms Are Wrongfully Confiscated
31. The very next day, on March 20, 2007, Plaintiff received a call from his
mother who informed him that P. O. MISTROTTA & P. O. LIMEAUX from the
N.C.P.D. were at her residence at located at 171 Gordon Place, Freeport, New York, on
the same block as Plaintiff’s residence, to seize his handguns and longarms. Plaintiff
immediately called a friend of his to possibly put the guns on his license. He and his son
witnessed the seizure.
32. Plaintiff peacefully surrendered all of his legally registered guns,
including nine rifles and fifteen hand guns. The N.C.P.D. also seized Plaintiff’s fiancée’s
handgun.
33. The Police Defendants informed Plaintiff that his guns were being seized
after they received a 911 call in which Plaintiff’s name was mentioned. The Police
Defendants explained that it was their policy to seize all firearms for a ninety-day period
“cooling” period. The Police Defendants do not have the statutory authority for the
implementation or utilization of such a procedure.
7
34. Upon information and belief, this 911 call, if it truly occurred, originated
from Rep. McCARTHY’s office.
35. Plaintiff was not arrested and the N.C.P.D. did not elaborate on the
details of the 911 call.
36. It was not until a week after this seizure and after Plaintiff requested a
receipt that he received a receipt for his seized handguns, pistols and longarms.
37. In a letter dated April 2, 2007, a copy of which is annexed as Exhibit B,
Plaintiff received notification that his address had been assigned to an incorrect election
district and that he was constituent of the Third, not Fourth, Congressional District of
New York.
38. Thereafter, in a letter dated April 24, 2007, a copy of which is annexed
as Exhibit C, the N.C.P.D. notified Plaintiff that his pistol license had been revoked based
upon a review of the events at Rep. McCARTHY’s office on March 19, 2007. The letter
also stated that plaintiff had become “increasingly obsessed with the day laborer
situation” and that plaintiff’s “actions have cause[d] great concern over your suitability to
possess a pistol license.”
39. No reference was made in the letter to a 911 call.
40. The Police Defendants’ stated reason for confiscating Plaintiff’s pistols
and longarms infringe on Plaintiff’s state and federally protected Constitutional rights to
petition the government and to freedom of speech.
41. The Police Defendants confiscation of long arms also violates Plaintiff’s
Due Process Rights since no mechanism exists for the return of his long arms.
8
42. As a result of the Defendants unlawful conduct, Plaintiff’s involvement
in daily activities he previously engaged in, and enjoyed Constitutional protection for,
have been chilled.
43. Plaintiff now lives in a constant state of fear that exercising his
Constitutionally protected rights will result in his arrest, since the Defendants have
already displayed a blatant disregard for the Plaintiff’s constitutionally protected rights.
44. Activities Plaintiff previously enjoyed, but which he now does not take
part in out of fear, include, but are not limited to: protesting illegal immigration issues,
partaking in activities and demonstrations at the Town Hall of Freeport, writing of
articles, and collecting signatures for petitions on issues relating to illegal immigration,
activities which Plaintiff no longer participates in due to the Defendants’ wrongful
conduct.
45. The Police Defendants still remains wrongfully in possession of
Plaintiff’s firearms and longarms without any mechanism for their return.
AS AND FOR A FIRST CAUSE OF ACTION

VIOLATIONS OF RIGHT TO PETITION
(AS AGAINST ALL DEFENDANTS )
46. Plaintiff repeats and realleges the allegations set forth in paragraphs “1”
through “45” above as if fully set forth herein.
47. Plaintiff has a right to petition the government, as secured by the First
Amendment to the United States Constitution, §9 of the New York State Constitution,
and other rights, privileges and immunities secured by the United States Constitution.
48. Defendants COUNTY OF NASSAU, NASSAU COUNTY POLICE
DEPARTMENT, POLICE COMMISSIONER LAWRENCE W. MULVEY,
9
DETECTIVE SAMANAGO, POLICE OFFICER MISTROTTA, POLICE OFFICER
LIMEAUX, and REPRESENTATIVE CAROLYN McCARTHY, actions, as outlined
above, were motivated by the Plaintiff’s petitioning his governmental representative
about social and political issues.
49. As a direct and proximate result of said acts, Defendants have violated
Plaintiff’s constitutional right to petition the government for redress.
AS AND FOR A SECOND CAUSE OF ACTION

VIOLATIONS OF PLAINTIFF’S RIGHT TO FREE SPEECH
(AS AGAINST ALL DEFENDANTS )
51. Plaintiff has a right to engage in free speech, as secured by the First
Amendment to the United States Constitution, §8 of the New York State Constitution,
and other rights, privileges and immunities secured by the United States Constitution.
LIMEAUX, and REPRESENTATIVE CAROLYN McCARTHY, actions, as outlined
above, were motivated by the Plaintiff’s practice of speaking freely on many social and
political issues.
53. That Defendants actions have chilled Plaintiff’s right to free speech as he
now lives in fear that his every day actions may result in arrest.
54. As a direct and proximate result of said acts, Defendants have violated
Plaintiff’s state and federal rights to freedom of speech.
10
AS AND FOR A THIRD CAUSE OF ACTION

FOR VIOLATION OF PLAINTIFF’S
14th AMENDMENT DUE PROCESS RIGHTS
(AS AGAINST NASSAU COUNTY AND THE POLICE DEFENDANTS)
56. An individual is afforded Due Process protection under the 14th
Amendment of the United States Constitution in regard to governmental confiscation of
property.
57. Plaintiff’s firearms and longarms are property to which he is afforded 14th
Amendment Due Process protection.
DETECTIVE SAMANAGO, POLICE OFFICER MISTROTTA and POLICE OFFICER
LIMEAUX, have enacted a policy under which they routinely and wrongfully confiscate
firearms, including long arms, without providing a mechanism under which one could
reclaim his property.
59. Pursuant to New York State law, there is no licensing requirement for the
possession of long arms, and the Police Defendants seizure of these weapons when there
is no claim that such weapons are contraband per se or that they were used in a crime is a
violation of Plaintiff’s Due Process Rights.
60. Failing to provide Plaintiff with proper notice and an opportunity for a
hearing subsequent to the seizure of Plaintiff’s longarms is a violation of his Due Process
Rights.
11
61. NASSAU COUNTY and the Police Defendants have further violated
Plaintiff’s 14th Amendment Due Process Rights by failing to have a procedure in place
under which Plaintiff could challenge this illegal conduct.
62. By requiring Plaintiff to take affirmative steps, including, inter alia, the
preparation of formal legal pleadings, the payment of a filing fee, the hiring of an
attorney, and the subsequent participation in all formal procedural devises of a trial court
action, to challenge this unlawful seizure of Plaintiff’s property, NASSAU COUNTY and
the Police Defendants have acted unreasonably and unconstitutionally under the Due
Process Clause of the 14th Amendment.
AS AND FOR A FOURTH CAUSE OF ACTION

FOR CONVERSION
64. On March 20, 2007, the N.C.P.D. unjustifiably, and without due process,
seized all of Plaintiffs firearms, including, handguns, which are subject to registration
under Penal Law §400, and longarms, which are not subject to registration.
65. The N.C.P.D. is the issuing agency for pistol licenses in Nassau County
66. The N.C.P.D. had no special authority for registration of longarms.
67. Plaintiff has not been arrested and is not the subject of a criminal
complaint.
68. The Police Defendants continues to retain possession of Plaintiff’s
longarms without cause, legal authority and without a remedy for Plaintiff.
69. The fair and reasonable value of Plaintiff’s longarms is $10,000.00.
12
70. By reason of the foregoing, Plaintiff has been damaged in the sum of
$10,000.00, the value of Plaintiff’s longarms.
AS AND FOR A FIFTH CAUSE OF ACTION

FOR REPLEVIN
72. Defendant NASSAU COUNTY and the Police Defendants took and
retained Plaintiff’s firearms, including, handguns, pistols and long arms.
73. The sole reason NASSAU COUNTY and the Police Defendant’s’ took
Plaintiff’s guns was Plaintiff’s valid exercise of his constitutional right to free speech and
to petition his representative.
74. Plaintiff demands compensation for his firearms that were taken and
retained by NASSAU COUNTY and the Police Defendants.
75. The detention by NASSAU COUNTY and the Police Defendants of
Plaintiff’s firearms, including, handguns, pistols and long arms, as described above, is
wrongful.
76. That Plaintiff has no adequate remedy at law.
77. That by reason of the foregoing, Plaintiff is entitled to an order and
judgment of replevin directing Defendants return to Plaintiff his pistol licenses, as well as
all of his firearms, including, handguns, pistols and long arms.
13
AS AND FOR A SIXTH CAUSE OF ACTION

42 U.S.C §1983 – 14th AMENDMENT
(AS AGAINST ALL DEFENDANTS)
79. Defendants, COUNTY OF NASSAU, NASSAU COUNTY POLICE
DETECTIVE SAMANAGO, POLICE OFFICER MISTROTTA POLICE OFFICER
LIMEAUX, and REPRESENTATIVE CAROLYN McCARTHY, acting under color of
state law, collectively and individually have engaged in actions and abuses which have
deprived Plaintiff of his rights, including, but not limited to, Plaintiff’s rights to free
speech and to petition the government for redress of grievances, as secured by the First
Amendment to the United States Constitution, privileges and immunities secured by the
United States Constitution, including the 14th Amendment in violation of 42 U.S.C.
§1983.
80. As a direct and proximate result of said acts, Plaintiff has suffered, and
continues to suffer, from the loss of his firearms, as well as distress, humiliation, great
expense, embarrassment, and damage to his reputation as a result of Defendants conduct.
Defendants actions also infringe upon Plaintiff’s First Amendment Rights.
AS AND FOR A SEVENTH CAUSE OF ACTION

FOR CONSTITUTIONAL TORT
(AS AGAINST ALL DEFENDANTS)
14
82. Defendants, COUNTY OF NASSAU, NASSAU COUNTY POLICE
LIMEAUX, and REPRESENTATIVE CAROLYN McCARTHY, acting under color of
law, violated plaintiff’s rights pursuant to the First Amendment of the United States
Constitution, §§8 and 9 of the New York State Constitution.
83. A damages remedy here is necessary to effectuate the purpose of the First
Amendment of the United States Constitution, §§8 and 9 of the New York State
Constitution, and appropriate to ensure full realization of plaintiff’s rights under those
sections.
PRAYERS FOR RELIEF
Plaintiff requests that he receive judgment as follows:
a. First Cause of Action: in excess of $1,000,000.00, in damages, punitive damages,
costs and attorneys fees;
b. Second Cause of Action: in excess of $1,000,000.00, in damages, punitive
damages, costs and attorneys fees;
c. Third Cause of Action: in excess of $1,000,000.00, in damages, punitive
damages, costs and attorneys fees
d. Fourth Cause of Action: in excess of $10,000.00, in damages, costs and attorneys
fees;
e. Fifth Cause of Action: an order and judgment of replevin directing Defendants
return to Plaintiff his pistol licenses, as well as all of his firearms, including,
handguns, pistols and long arms.
15
f. Sixth Cause of Action: in excess of $1,000,000.00, in damages, punitive
g. Seventh Cause of Action: in excess of $1,000,000.00, in damages, punitive
h. Punitive damages against Defendants in an amount the court deems fit;
i. Attorneys fees and costs pursuant to 42 U.S.C. 1988, or in an amount this court
deems proper and appropriate;
j. A declaratory judgment that Defendants willfully violated Plaintiff’s rights
secured by the federal and state constitution, as alleged herein; and
k. An order granting such other legal and equitable relief as the court deems just and
proper.
JURY TRIAL DEMANDED
In accordance with the provisions of Fed. R. Civ. Pro. Rule 39(b) and 39, Plaintiff hereby
demands a trial by jury of all issues so triable.
La Reddola, Lester & Associates, LLP
_________/s______________________
Robert J. La Reddola (RJL 6501)
Attorneys for Plaintiff
Gabriel Razzano
600 Old Country Road, Suite 224
Garden City, New York 11530
(516) 745-1951
16
17

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Case 2:07-cv-03983-ADS-AKT Document 17 Filed 11/27/2007 Page 1 of 17

La Reddola, Lester & Associates, LLP

UNITED STATES DISTRICT COURT

Plaintiff, GABRIEL RAZZANO, by his attorneys, La Reddola, Lester &

NASSAU (“NASSAU COUNTY”), NASSAU COUNTY POLICE DEPARTMENT,

POLICE COMMISSIONER LAWRENCE W. MULVEY DETECTIVE SAMANAGO,

POLICE OFFICER MISTROTTA, POLICE OFFICER LIMEAUX (the “Police

York. Plaintiff further alleges that Defendant U.S. Representative CAROLYN

JURISDICTION AND VENUE

3. Venue in this District is proper under 28 U.S.C. §1391(b), since

belief, all parties currently reside or maintain offices in Nassau County.

4. Plaintiff, GABRIEL RAZZANO is a citizen of the State of New York and

5. Defendant, NASSAU COUNTY is a duly constituted municipal

the laws of the State of New York.

6. Defendant, NASSAU COUNTY POLICE DEPARTMENT (herein after

Avenue, Mineola, New York 11501.

7. Defendant LAWRENCE W. MULVEY is the Police Commissioner for

the N.C.P.D. (“COMMISSIONER MULVEY”).

8. Defendant, DETECTIVE SAMANAGO (“DET. SAMANAGO”) is an

officer of the N.C.P.D.

9. Defendants, POLICE OFFICER MISTROTTA (“P.O.MISTROTTA”) and

10. Defendant U.S. Representative CAROLYN McCARTHY is the

York 11530 (the “Long Island Office”).

11. Plaintiff is a member of the Minuteman Civil Defense Corp., a group

entry of all individuals, contraband, and foreign military.”1

handguns and long arms.

13. At the time in question, Plaintiff was a constituent of Rep.

McCARTHY’s congressional district. Therefore, Plaintiff had a constitutionally protected

State and Federal right to petition Rep. McCARTHY.

14. Rep. McCARTHY is a well known and outspoken advocate of gun

control, and an advocate for the illegal alien population.

not include long arms.

under which long arms may be confiscated and later retrieved.

pistols when conducting an inquiry about pistol license matters.

Plaintiff’s Correspondence with Rep. McCARTHY

19. Beginning in early 2003, Plaintiff began writing to Rep. McCARTHY

neighborhood. Plaintiff sent to Rep. McCARTHY no fewer then approximately 15

20. Rep. McCARTHY responded to a few of Plaintiff’s letters and has

to these governmental entities Plaintiff’s concerns.

return his call. Plaintiff never received a call back.

Plaintiff is Advised he is not a Constituent of Rep. McCarthy’s District

straighten out the situation.

Elections to clarify any possible confusion.

25. Immediately thereafter, Plaintiff waited on line at the Nassau County

Board of Elections to obtain a stamped official copy of his Certificate of Registration

which showed Plaintiff as registered to vote and a constituent of Rep. McCARTHY’s

Fourth Congressional District.

26. Plaintiff traveled to David Denenberg’s office and spoke to his

requesting an appointment with the Congresswoman to discuss illegal immigration

Nassau County Police Department Infringe Plaintiff’s First Amendment Rights

straightened this “entire situation out.”

28. By acting in this manner, DET. SAMANAGO, as a representative of the

federal right to petition the government and to free speech to be infringed.

building by DET. SAMANAGO.

Plaintiff’s Firearms and Longarms Are Wrongfully Confiscated

witnessed the seizure.

32. Plaintiff peacefully surrendered all of his legally registered guns,

implementation or utilization of such a procedure.