Recall that police officers had presented the Cassidy's with documentation and stated that they were acting under the authority of a search warrant. Also recall how police officers had written in the words "if any" in regards to firearms. Armed with these documents, the officers embarked on their own "fishing expedition"- searching throughout the Cassidy home and a variety of secured containers therein- seeking to catch some fish. Their own written words, "if any", indicate that officers did not know if the fish would be biting in the middle of the night of March 14, 1996. The officers actions were identical to what the Framers had painstakingly sought to prohibit from happening to United States citizens. Despite what the Framers had intended, the Sussex County Justice system has engaged in a conspiratorial pattern of abuse to ensure that these fishing expeditions can continue. Because each separate governmental body within Sussex County became complicit in the cover up, they were able to ensure that their actions would not be scrutinized by the federal courts.

On March 9, 1998, Tom had the law firm of Needleman & Schocket file a $2 million dollar federal civil rights lawsuit against the Town of Newton Police Department, et. al. and the Stillwater Township Police Department, et. al. in an attempt to redress the wrongs that have been committed against him. We encourage you read this lawsuit carefully in that it has been the only document thus far presented in the case record that has accurately and chronologically depicted the conspiratorial conduct that the Sussex County Justice officials have engaged in order to deprive Tom of his federal civil rights. It explains why the initial police misconduct had rapidly expanded to include members of the Sussex County Prosecutor's Office, the Sussex County Judiciary and others.

Yet because the Sussex County Justice system had chosen to become complicit in depriving one of federal civil rights rather than admonish it's own local police officers, it became that much more difficult for Tom to have the federal courts look into things.

Indeed, on November 6, 1998 Town of Newton and Stillwater Township attorney Richard P. Cushing had even threatened Tom that he would pursue Rule 11 sanctions for seeking to have his federal civil rights redressed. In this faxed letter, Cushing states that the federal courts would side with Superior Court Judge Gerald B. Hanifan, J.S.C. in that he had already ruled on this very same issue. Cushing also states that Newton Municipal Court Judge John Mulhern, J.M.C. had also approved of the illegal search and seizure. Yet there is no evidence that Judge Mulhern had ever been contacted on March 13-14, 1996!

In laymen's terms, this means that because the Sussex County Justice system had become complicit in the conspiracy to deprive Tom of federal civil rights, the federal courts would defer to the state judicial officials- i.e. Judge Gerald B. Hanifan, J.S.C. and his reliance on the wrongful conviction that police and prosecutorial and judicial misconduct had facilitated!

Because of these threats, Tom was forced to dismiss his suit that had sought to have his civil rights redressed!

The courts have defined civil rights conspiracies in the case of Hampton v. Hanrahan^[N.3]. The court found that a civil conspiracy is a "combination of two or more persons acting in concert to commit an individual act, or to commit a lawful act by unlawful means, the principle element of which is an agreement between the parties "to inflict a wrong against or injury upon another," and "an overt act that results in damage." The question of whether an agreement exists should not be taken from the jury so long as there is a possibility that the jury can "infer from the circumstances [that the alleged conspirators] had a 'meeting of the minds' and thus reached an understanding" to achieve the conspiracy's objectives. To demonstrate the existence of a conspiratorial agreement, it simply must be shown that there was "a single plan, the essential nature and general scope of which [was] known to each person who is to be held responsible for its consequences."

As you read throughout this site it will become readily apparent that a meeting of the minds had occurred since the very inception of the case of State v. Cassidy. Clearly, the conspiratorial conduct began shortly after March 14-15, 1996. The police officers knew that they had lied and did not have a valid search warrant as they had claimed. So they met with officials the Sussex County Prosecutor's Office to plan a way to cover up their own illegal conduct. They filed cover charges against Tom almost two weeks later in an effort to create the previously non-existent probable cause.

An effort which was successful once Assistant Prosecutor Vincent J. Connors, Jr. made his decision to become a co-conspirator in the cover up. Connors was so confident in the good-ol'-boy network of Sussex County that he had even dismissed the charges that Tom had filed against his assailant! And why wouldn't he be confident? For Judge N. Peter Conforti, J.S.C. too was complicit. Conforti had met secretly in chambers with Attorneys Laemers and McGovern and informed them that he believed the case was "nonsense" and not worth being on the court calendar. Yet despite his initial protests, Conforti agreed to proceed with the cover charges against Tom. Conforti permitted Assistant Prosecutor Connors, Jr. to move forward with a malicious prosecution and a dismissal of a complaint that Tom had filed.

So why did Judge Conforti proceed with a case he believed was "nonsense"? Because Conforti knew that Attorney George Daggett had filed a brief for a motion to suppress illegally obtained evidence. He knew that the Sussex County Prosecutor's Office needed to create the probable cause that was non-existent. Remember when John Tomasula, the Captain of the Newton Police Department, stated that they were going to lose the Cassidy case and all of those guns? Remember how Newton Police Detective Anthony Virga faxed Assistant Prosecutor Reed stating that "no one seems to be interested in changing anything"? This was the same Tony Virga who months earlier faxed confidential documentation to the New Jersey Department of Corrections in order to destroy Tom's career.

After Judge N. Peter Conforti, J.S.C. dismissed Tom's disorderly person complaint and wrongfully convicted Tom, the Sussex County Prosecutor's Office sought to capitalize on this and file additional arguments in opposition to the motion to suppress evidence.

On April 3, 1997 Judge Gerald B. Hanifan then latches on to the wrongful conviction in support of his denial of the motion to suppress evidence. He created the previously non-existent probable cause and used this to justify a warrantless search and seizure that was conducted in a private home in the middle of the night!

It was during this time period that the Sussex County Prosecutor's Office had faxed false documentation to the New Jersey Department of Corrections which indicated that Tom had pled guilty to the charge of simple assault! No doubt, the Sussex County Prosecutor's knew that Tom would have to incur the additional expense of retaining counsel to represent him in defense of these charges too!

Then, at a time when Tom was encountering much difficulty from a Sussex County Official Court Reporter in obtaining a transcript of the April 3, 1997 motion to suppress hearing, Tom is informed that his appeal to the wrongful simple assault conviction is dismissed! Once again, the record indicates that this event occurred as a result of the unrelenting malicious efforts of Sussex County Justice officials!