Louis N. Rainone, Esq.
(Attorney ID#: 021791980)
RAINONE COUGHLIN MINCHELLO, LLC
555 U.S. Highway One South, Suite 440
Iselin, New Jersey 08830
Tel.: 732-709-4182
Fax: 732-791-1555
Attorneys for Plaintiff, City of Long Branch
CITY OF LONG BRANCH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MONMOUTH COUNTY
Plaintiff,
DOCKET NO.:
v.
Civil Action
WAVELL THOMPSON dba/aka
@PERCC30_DICKK dba/aka VERIFIED COMPLAINT
@PERCC30DICK,
KEVIN J. SMALL dba/aka
@_YOUNG_BISHOP, JAYSON S.
GLASPER dba/aka @JAY.DUHGOAT,
AKEIL T. ANDERSON dba/aka
KILSOSOUTH dba/aka KILSOSOUTH2X,
SEMYA GILL dba/aka @MYAAIMANI2.0,
JAYLEN COURTEN dba/aka
@SOSAACTIVATED, JOHN DOES 1-
5000, and ABC COMPANIES 1-5000
Defendants.
Plaintiff, City of Long Branch (the “City”), a body politic of the State of New Jersey with
principal offices located at 344 Broadway, Long Branch, New Jersey 07740, by way of verified
complaint against defendants hereby says:
FACTUAL BACKGROUND
1. Defendant, Wavell Thompson, dba/aka “@percc30_dickk” and “@percc30dick”,
with a last known address of 164 South Harrison Street, Unit 1D, East Orange, New Jersey, is an
individual who, upon information and belief, has worked in concert with other individuals and
utilized various social media accounts to promote non-permitted and illegal events within the City
of Long Branch in violation of the City ordinances requiring a permit for any such event. This
individual has utilized multiple accounts on different social media networks including Instagram,
TikTok, Twitter and Facebook to promote these events and encourage the destruction of property,
fighting, public consumption of drugs and alcohol, and other illegal activities for their own
commercial benefit and in violation of local ordinances and laws. Attached as Exhibit “A” to this
complaint is a collection of social media posts Mr. Thompson has published promoting and
celebrating these events. Based on various postings from these accounts, it appears that Mr.
Thompson is one of the individuals responsible for a previous similar event in the City of Long
Branch.
2. Defendant, Kevin J. Small, dba/aka “@_young_bishop”, currently believed to reside
at 204 Stephenson Avenue, Middlesex, New Jersey, is an individual who, upon information and
belief, has worked in concert with other individuals and utilized various social media accounts to
promote non-permitted and illegal events within the City of Long Branch in violation of the City
ordinances requiring a permit for any such event. This individual has utilized multiple accounts
on different social media networks including Instagram, TikTok, Twitter and Facebook to promote
these events and encourage the destruction of property, fighting, public consumption of drugs and
alcohol, and other illegal activities for their own commercial benefit and in violation of local
ordinances and laws. Attached as Exhibit “B” to this complaint is a video posted to social media
of Mr. Small participating in these events.
3. Defendant, Jayson S. Glasper, dba/aka “@jay.duhgoat”, currently believed to reside
at 66 Midway Road South, Tinton Falls, New Jersey, is an individual who, upon information and
belief, has worked in concert with other individuals and utilized various social media accounts to
promote non-permitted and illegal events within the City of Long Branch in violation of the City
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ordinances requiring a permit for any such event. This individual has utilized multiple accounts
on different social media networks including Instagram, TikTok, Twitter and Facebook to promote
these events and encourage the destruction of property, fighting, public consumption of drugs and
alcohol, and other illegal activities for their own commercial benefit and in violation of local
ordinances and laws. Attached as Exhibit “C” to this complaint is a collection of social media
posts Mr. Glasper has published promoting these events.
4. Defendant, Akeil T. Anderson, dba/aka “kilsosouth” and “kilsosouth2x”, currently
believed to reside at 131 Leslie St., Newark New Jersey, is an individual who, upon information
and belief, has worked in concert with other individuals and utilized various social media accounts
to originate non-permitted and illegal events within the City of Long Branch in violation of the
City ordinances requiring a permit for any such event. This individual has utilized multiple
accounts on different social media networks including Instagram, TikTok, Twitter and Facebook
to promote these events and encourage the destruction of property, fighting, public consumption
of drugs and alcohol, and other illegal activities for their own commercial benefit and in violation
of local ordinances and laws. Attached as Exhibit “D” to this complaint is a collection of social
media posts Mr. Anderson has published promoting these events.
5. Defendant, Semya Gill, dba/aka “@myaaimani2.0”, whose address is unknown, is an
individual who, upon information and belief, has worked in concert with other individuals and
utilized various social media accounts to promote non-permitted and illegal events within the City
of Long Branch in violation of the City ordinances requiring a permit for any such event. This
individual has utilized multiple accounts on different social media networks including Instagram,
TikTok, Twitter and Facebook to promote these events and encourage the destruction of property,
fighting, public consumption of drugs and alcohol, and other illegal activities for their own
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commercial benefit and in violation of local ordinances and laws. Attached as Exhibit “E” to this
complaint is a collection of social media posts Ms. Gill has published promoting these events.
6. Defendant, Jaylen Courten, dba/aka “@sosactivated”, a minor, is an individual who,
upon information and belief, has worked in concert with other individuals and utilized various
social media accounts to promote non-permitted and illegal events within the City of Long Branch
in violation of the City ordinances requiring a permit for any such event. This individual has
utilized multiple accounts on different social media networks including Instagram, TikTok, Twitter
and Facebook to promote these events and encourage the destruction of property, fighting, public
consumption of drugs and alcohol, and other illegal activities for their own commercial benefit
and in violation of local ordinances and laws. Attached as Exhibit “F” to this complaint is a
collection of social media posts Mr. Courten has published promoting these events.
7. John Does 1-5000 are unknown individuals who were active participants in and upon
information and belief aided, encouraged and/or conspired with the named Defendants for their
own personal or commercial gain, to engage in and assist with the promotion, organizing or
planning of the non-permitted events that have taken place in Long Branch on June 19, 2021, May
22, 2022, and all future events planned by these individuals, including June 19, 2022.
8. ABC Corporations 1-5000 are unknown corporate entities who were active
participants in and upon information and belief aided, encouraged and/or conspired with the named
Defendants for personal, financial or otherwise commercial gain. These defendants engaged in
and assisted with the promotion and planning of the non-permitted events that have taken place in
Long Branch on June 19, 2021, May 22, 2022, and all future events planned, including June 19,
2022.
9.
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10. Upon information and belief, Defendants have worked in concert to maintain these
and other accounts under various names and aliases in order to promote these illegal activities and
in order to generate social media followers for the purposes of self-promotion. commercial gain
and the potential for monetary compensation.
11. Following in the footsteps of and hoping to capitalize on the notoriety of “Adrian’s
Kickback,” a “Project X” 1 style party that took place in California on May 23, 2021, these
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individuals and others working in concert with them advertised a similar unpermitted event on
June 19, 2021 in the City of Long Branch. Attached as Exhibit “G” is a copy of the original flyers
advertising the June 19, 2021 event. Mr. Thompson (@percc30dick) clearly added his username
to at least one of last year’s flyers prior to posting it.
12. Using social media to spread flyers advertising the event and generate word-of-mouth
awareness, these individuals, in particular Mr. Thompson, organized and encouraged as many
attendees as possible to come to the City of Long Branch to drink, use drugs, fight and generally
behave in a disorderly manner.
13. As a result, at least a thousand unidentified individuals utilized private transportation
and the New Jersey Transit system to travel to the beaches in Long Branch on June 19, 2021. They
then forced their way past the badge checkers to take over the beaches and the boardwalk area
known as Pier Village. Attached as Exhibit “H” to this complaint is the Long Branch Police
Department Shift Briefing for June 19, 2021 which details what followed.
14. Beginning at approximately 5:30 p.m. the Long Branch Police Department began to
receive reports of large crowds arriving at the train station and beginning to harass cars and
1
“Project X” is the name of a 2012 film in which a group of teenagers throw a party in an attempt to make a name for
themselves. The party grows exponentially larger and results in thousands of people engaging in wild and illegal
activities. Similar pop-up parties have embraced this as the sole purpose of these parties rather than an unintended
consequence.
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pedestrians in the area. Although initially dismissed as nothing, the situation at the beach quickly
escalated.
15. By 6:55 p.m. the City of Long Branch issued a call for mutual aid as the swelling
crowds became too much for them to handle on their own. Beginning on page 7 of Exhibit “H”,
the Shift Briefing details that units from Oceanport, Monmouth Beach and West Long Branch are
all en route to the area to provide crowd control.
16. By 7:15 p.m., the City had notified the State Police of the need for aid and had begun
issuing calls to other shifts to come in early and provide additional manpower and support. All
units from Shift One responded to the call for additional manpower and were in route to the
situation at the beach. Over the course of approximately the 90 minutes, units from the New Jersey
State Police, Middletown, Highlands, Atlantic Highlands , Freehold Township, Ocean Township,
Keyport, the Monmouth County Rapid Deployment Force (RDF), and the Monmouth Ocean
County Emergency Response Team (MOCERT) had all either arrived or were in route to the City
of Long Branch in response to the crowds. Attached as Exhibit “I” is a brief video compilation of
the June 19, 2021 crowd as it grew out of control.
17. In the ensuing chaos, a number of arrests were made while the focus shifted to
attempting to disperse the crowds of young and intoxicated participants. Businesses in the area
were closed, the streets were shut down, and at some point during the evening individuals began
vandalizing the area resulting in thousands of dollars of damages and store windows in Pier Village
being smashed.
18. Although this was thought to be a one-time occurrence, the above scenario repeated
itself this year. In May 2022 the same organizers - but most prominently Mr. Anderson (kilsosouth)
and Mr. Thompson (percc30dick) - began to once again advertise an event that they dubbed the
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“Beach Link Up” for May 21, 2022, once again in Long Branch. Utilizing the same flyer as the
previous year’s event, but with a new date, the defendants once again encouraged as many people
as possible 2 to come to the City of Long Branch to drink, use drugs, fight and compete in dance
1F
contests for cash prizes. Of note is that this event marked the one-year anniversary of the original
“Adrian’s Kickback” party that was the inspiration for the first Long Branch mass gathering.
Attached hereto as Exhibit “J” are copies of the flyers posted for the May 21, 2022 event.
19. The flyers, as posted and reposted by the various defendants, either do not have
names or include usernames and pseudonyms such as “Kilsosouth Presents” or “Dareeq Smith the
3rd Presents,” indicating a clear attempt by the organizers to partially conceal their identities and
provide deniability while still benefiting from the notoriety of advertising the event on their
personal social media accounts. Also of note is that while “Dareeq Smith the 3rd” appears to be a
fictitious name, Mr. Anderson on his “kilsosouth” Instagram account recently posted a video in
which he adopts the name of “Dariq Smith” as part of a video that he created with others.
20. As a result of the actions of the defendants in promoting and encouraging people to
attend this non-permitted event, approximately 5,000 people arrived in Long Branch on May 21,
2022 to participate in the “Beach Linkup.” Many once again utilized the New Jersey Transit
Railways to arrive and refused to pay the appropriate fare before exiting the train at Long Branch
station. New Jersey Transit workers were vastly outnumbered by the crowds and could do nothing
to prevent them from exiting without payment.
21. Based upon their prior experience having promoted a similar event, the Defendants
knew, or should have known, that the sheer volume of attendees would be overwhelming for the
residents, businesses and police services available. Attached as Exhibit “K” is a social media post
2
Flyers from last year and this year clearly indicate “Tell a friend to tell a friend…,” in a transparent attempt to
generate as much word of mouth as possible.
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confirming that attendees are aware that the crowds have the potential to overwhelm the area. As
a result, the area around Pier Village was once again shut down to normal vehicular traffic and the
businesses in the area were forced to close due to the sheer size and unruliness of the crowds.
22. These attendees began arriving at approximately 5:00 p.m. and engaged in public
fighting, use of alcohol and use of drugs in violation of local ordinances and state laws. Attached
as Exhibit “L” is a sample of the police reports generated during the event which demonstrate the
conditions created by the large number of attendees.
23. The organizers of this event encouraged the taking of videos during the event for
posting on social media to generate additional likes and page views. Many of the flyers and social
media posts advertising the event specifically include camera “emojis” to encourage recording and
reposting by the attendees. In so doing, the organizers encouraged increasingly dangerous and
destructive behavior from the attendees. By way of a specific example, Defendant Glasper was
detained while recording a group of individuals vandalizing a police vehicle. He was observed
encouraging the individuals to stomp on and break the rear windshield of that vehicle while he
recorded. The unknown individual did then, in fact, stomp on and smash the rear windshield of
the vehicle. Attached as Exhibit “M” is a copy of the police incident report documenting this
occurrence.
24. In addition to the drinking, drugs, fights, dance contests and vandalism, the promoters
of this event have generated additional attention by advertising, inviting and encouraging
“YouTube stars” and “influencers” 3 to attend the event so that they can use the footage on their
2F
own channels to generate additional page views. At least one youtube artist, “BandManRill,” used
3
Individuals that earn some or all of their income by posting content online and often use their popularity to promote
specific brands in exchange for payments.
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this opportunity to record footage to be used in a music video that was later posted online and
directly referenced the Long Branch “Beach Linkup.” 4 3F
25. The crowds, fighting and dangerous behavior resulted in numerous injuries to
attendees which were treated by emergency services on scene. While the majority of the injuries
sustained were by willing participants in this event, damage to the public areas and beaches, clean-
up costs for trash removal, and overtime costs for the extraordinary police response and city
services required to restore and keep order has resulted in tens of thousands of dollars in costs and
damages to the City of Long Branch. These damages do not take into account the losses to local
businesses due to the event, nor do they factor in the damage that such an event has done to the
reputation of the City of Long Branch as a family-friendly destination.
26. Emergency overtime expenditures alone account for $24,501.53 of the costs to the
City as a direct result of the illegal non-permitted event. Attached as Exhibit “N” is a spreadsheet
report prepared by the City totaling those overtime expenditures. This does not factor in the costs
to the other agencies including the State of New Jersey, municipalities that provided mutual aid,
the County responsive task forces, or the New Jersey Transit Authority.
27. As intended by the organizers, the recordings of this event have been posted online
by attendees, news media outlets, influencers and others. Mr. Thompson, in fact, has posted
additional content to his Instagram accounts both mocking the police investigation (attached as
Exhibit “O”) and bragging about the results of his promotional efforts (attached as Exhibit “P”).
28. As a follow-up to the May 21, 2022 event, the organizers have begun posting new
flyers to promote the “Beach Linkup Pt. 2,” set to take place in Long Branch on June 19, 2022.
Attached as Exhibit “Q” is a copy of the flyer advertising the second event.
4
https://www.youtube.com/watch?v=H8qqgQwgfC4 “Long Branch Beach Link Up Riottt and Bandmanrill and
more!”
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29. The June 19, 2022 event is scheduled to begin at 12:00 p.m. and end “whenever.”
This would significantly extend the time during which new arrivals can make their way to the
event and could potentially result in even more participants than the previous event.
30. The flyers encourage and entice viewers of the flyer to invite other people who are
not aware of the illegal event by again requesting that viewers “tell a friend to tell a friend.” Using
viral marketing like this ensures that the flyers are distributed to the widest range of potential
attendees possible. The organizers of the event, having utilized this tactic previously, are well
aware of the effectiveness of such tactics.
31. These flyers promote, encourage, and entice individuals to be a part of these events
so that they too can share in the media hype surrounding the incidents and can engage in illegal
activity, including fighting and dancing for prize money and the consumption of alcohol and
marijuana in public areas.
32. The flyer also advertises music, food, fun, dance battles, and a $1,000.00 (One-
Thousand Dollar) twerk contest. Other flyers have also advertised boxing matches and similar
dangerous activities.
33. It is clear from the flyers and continued social media posts that the organizers of these
events have no concern for the safety of their attendees and seek solely to capitalize on the chaos
and disorder for their own commercial, personal and financial gain.
34. This disregard for the City of Long Branch and its residents has resulted in additional
participants that seek to profit from the promotional activities of these individuals. The YouTube
channels “AT TV” and “PWAYY” created videos and posted them to their channels to generate
additional views. AT TV documented the event by compiling videos of the event from social
media and publishing it on their channel. PWAYY documented the event by interviewing
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individuals who attended the event. Submitted as Exhibit “R” is a video compiling the various
social media posts related to the event by those hoping to generate additional views for their
personal social media accounts. This video also provides a general overview of the dangerous
progression of the event throughout the day and evening.
35. Recording and publishing videos of the event and content adjacent to the event allows
"AT TV" and "PWAYY" and other content creators to monetize the occurrence of an illegal event.
This incentivizes the defendants to promote additional events for commercial gain and encourages
other individuals to promote their own events in an attempt to copy the success of these prior
events for financial gain regardless of the consequences.
36. In promoting, organizing and encouraging attendees to come to this event,
Defendants did not apply for or secure a special event permit from the City of Long Branch in
violation of City of Long Branch Ordinance 247-4 Permits for Special Events, for any area of the
public street, the public beach, or Pier Village for any event to take place on either May 21, 2021
or June 19, 2022. Attached as Exhibit “S” is a copy of the Long Branch ordinances violated by
the organizers and their attendees.
37. Failing to apply for or receive a permit denies the City the opportunity to ensure that
proper measures are taken to ensure the safety of attendees and the residents of Long Branch. For
a large-scale event such as this, adequate restrooms must be arranged, adequate sanitation must be
accounted for, and there must be adequate police, fire and EMS services present during the event.
Subverting this rule allows the promoters and organizers to avoid responsibility for the behavior
or actions of their attendees. Under normal circumstances - if such an event were to receive a
permit - the organizers would be required to pay certain fees, make certain arrangements with the
City for the aforementioned services and would be required to provide insurance in the event that
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damages occur. By sidestepping those requirements, the promoters of this event are able to
privatize any commercial gains while shifting the cost and consequences of their activities onto
the residents and taxpayers of the City of Long Branch.
38. As a result of these flyers and the activities that have occurred, these Defendants and
other, related individuals, have begun advertising additional "Beach Linkups" for other weekends.
On June 18, 2022, a new flyer promotes a party in the shore town of Point Pleasant Beach and
seeks to draw a similar crowd to that location. That flyer also promotes bring your own liquor,
bring your own weed, dance battles, twerk contests, and boxing matches. Over Memorial Day
Weekend, rumors of a similarly organized event in Asbury Park, New Jersey, diverted police
resources to identifying and preparing for such an occurrence.
39. While the City of Long Branch has been fortunate in that no one has been seriously
injured or killed as a result of these unsanctioned events, it is only a matter of time before one of
the uncontrollable nature of these non-permitted gatherings leads to significant tragedy.
40. It is clear that without the intervention of the Courts, Defendants and other individuals
with the same goals will not cease to promote and share this or other flyers. Without the requested
Court Order, events like this will continue in Long Branch and have already begun to spread to
other municipalities such as Point Pleasant and Asbury Park.
VENUE
41. Venue is appropriate in Monmouth County as the event has been advertised to take
place at the Long Branch Beach, which is located in the City of Long Branch. In addition, the
same event that took place on May 21, 2022, took place at the Long Branch Beach and at Pier
Village, located in the City of Long Branch.
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COUNT I
FAILURE TO OBTAIN A PERMIT IN VIOLATION OF LONG BRANCH SPECIAL
EVENTS ORDINANCE
42. Plaintiff repeats and realleges each and every allegation contained in each of the
preceding paragraphs and incorporates them herein by reference.
43. Section 247-4 of the Long Branch Municipal Code pertains to permits for special
events.
44. Section 247-4 of the Long Branch Municipal Code requires a person, organization,
or entity to apply for and obtain a special event permit when an event may impact public safety or
services.
45. Section 247-1 describes a special event as including, but not limited to, a
performance, show or entertainment, labor strikes, road closings, large gatherings requiring other
City permits, protests or demonstrations.
46. Section 247-1 provides that all events must comply with applicable state statutes and
City ordinances.
47. Some of the factors considered for the issuance of a special permit are "That the
proposed activity or use of the park or requested area will not unreasonably interfere with or detract
from the general public enjoyment of the park or said area”; "that the proposed activity and use
will not unreasonably interfere with or detract from the promotion of public health, welfare, safety
and recreation"; "that the proposed activity and use will not unreasonably restrict, obstruct,
interfere with or impede pedestrian right-of-way, a vehicle's right-of-way or ingress or egress from
the requested or abutting property"; "that the proposed activity or uses that are reasonably
anticipated will not include violence, crime, or disorderly conduct, nor create a nuisance."
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48. Defendant illegally planned, promoted, and encouraged an event without applying
for or obtaining a special event permit.
49. Defendant's event interfered with the promotion of public health, welfare, safety and
recreation by encouraging individuals to bring marijuana and alcohol to the event. The event
scheduled for June 19, 2022 will do the same.
50. Defendant's event proposed activity that unreasonably restricted, obstructed,
interfered with, and impeded pedestrian's and vehicle's right of way. It is reasonable to believe
that the event scheduled for June 19, 2022 will do the same.
51. Defendant's event included violence, crime, disorderly conduct, and created a
nuisance. After two similar events, it would be reasonable to anticipate that violence and
vandalism will occur for the event scheduled for June 19, 2022.
52. As a result of Defendant’s violations of Long Branch Municipal Code 247-4, Plaintiff
has suffered damages and has no adequate or equitable remedy at law to alleviate the hazardous
conditions to the public health, welfare, safety, and quality of life imposed upon the City of
Long Branch and its residents by Defendants.
WHEREFORE, Plaintiff demands judgment against Defendants for:
a) Permanently enjoining Defendants from advertising, promoting, or
encouraging, and events within the City of Long Branch without applying for
and obtaining a special event permit in violation of Long Branch Municipal
Code 247-4;
b) Requiring Defendants to remove any advertisements or postings promoting the
June 19, 2022 event or any future pop-up parties planned for the City of Long
Branch and requiring defendants to post notice as drafted by the Plaintiff that
any planned gathering has been cancelled attached as Exhibit T;
c) Awarding Plaintiff attorneys fees and costs; and
d) Awarding Plaintiff such other and further relief as this Court deems just and
proper in the circumstances.
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COUNT II
REPEATED VIOLATIONS OF MUNICIPAL ORDINANCES RESULTING IN
PUBLIC NUISANCE
53. Plaintiff repeats and realleges each and every allegation contained in each of the
preceding paragraphs and incorporates them herein by reference.
54. Defendants have promoted and advertised consumption of alcohol and marijuana on
the public beaches, Pier Village, and the surrounding public areas in violation of Long Branch
Municipal Code 116-5.
55. Defendants have advertised, enticed, and promoted the rough athletics, boxing and
other activities that can lead to injury on the public beaches, Pier Village and surrounding public
areas in violation of Long Branch Municipal Code 116-5.
56. Defendants have encouraged and enticed individuals to conduct themselves in a
disorderly manner on the public beaches, Pier Village, and surrounding public areas in violation
of Long Branch Municipal Code 116-5.
57. Defendants have illegally encouraged the consumption of cigarettes and tobacco
products at the public beaches, Pier Village, and surrounding public areas in violation of Long
Branch Municipal Code 116-5.
58. Defendants have engaged in activities which causes a significant interference with
the public health, safety, peace, comfort, or convenience and causes unreasonable interference with
the City’s property.
59. Defendants have engaged in activities prohibited by the City's ordinances in a manner
which created an injury and/or significant threat of injury to the interests of the Plaintiff in
maintaining and preserving the health and safety of the general public.
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60. As a result of Defendant’s activities, Defendant have caused an unreasonable
interference with a right common to the general public, thus causing a public nuisance.
WHEREFORE, Plaintiff demands judgment against Defendants jointly and severally for:
a) Permanently enjoining Defendants from advertising, promoting, or
encouraging, and events within the City of Long Branch without applying for
and obtaining a special event permit in violation of Long Branch Municipal
Code 247-4;
b) Requiring Defendants to remove any advertisements or postings promoting the
June 19, 2022 event or any future pop-up parties planned for the City of Long
Branch and requiring defendants to post notice as drafted by the Plaintiff that
any planned gathering has been cancelled attached as Exhibit T;
c) Awarding Plaintiff attorneys fees and costs; and
d) Awarding Plaintiff such other and further relief as this Court deems just and
proper in the circumstances.
COUNT III
NEGLIGENCE
55. Plaintiff repeats and realleges each and every allegation contained in each of the
preceding paragraphs and incorporates them herein by reference.
56. Defendants owe a duty of care to the Plaintiff in this matter to abide by the laws and
ordinances of City of Long Branch and to refrain from encourages others to violate those laws.
57. Defendants further owe a duty of care to the Plaintiff in this matter not to invite or
encourage a mass illegal gathering within the City of Long Branch when they know that or can be
reasonably certain that the consequences will cause damage to the Plaintiff.
58. Defendants breached this duty by creating, posting and intentionally spreading word
of the planned gathering through social media sites and forums with the express intention of
breaking the laws and ordinances of the City of Long Branch.
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59. This breach did, in fact, encourage and entice several thousand individuals to attend
the non-permitted event in the City of Long Branch for the purposes of drinking, using drugs,
engaging in fights and vandalism, which did in fact occur. Without the creation, planning and
promotion of this event, the attendees would not have been in Long Branch on that day.
60. Defendants’ negligent, reckless and willful conduct was the direct and proximate
cause of the illegal and unpermitted event which did, in fact, result in damages to Plaintiff.
61. Plaintiff suffered damages as a direct result of the actions of the Defendants in this
matter, including exceptional overtime costs, clean-up costs, damage to police equipment and
vehicles, injuries to police officers, and damage to its reputation and future prospects as a center
for family friendly tourism.
WHEREFORE, Plaintiff demands judgment against Defendants jointly and severally for:
a) Reimbursement of all extraordinary costs incurred as a result of the Plaintiffs
response to and clean up of the non-permitted event on May 21, 2022;
b) Compensatory and punitive damages in an amount to be proven at trial;
c) Awarding Plaintiff attorneys fees and costs;
d) Permanently enjoining Defendants from advertising, promoting, or
encouraging, and events within the City of Long Branch without applying for
and obtaining a special event permit in violation of Long Branch Municipal
Code 247-4;
e) Requiring Defendants to remove any advertisements or postings promoting the
June 19, 2022 event or any future pop-up parties planned for the City of Long
Branch and requiring defendants to post notice as drafted by the Plaintiff that
any planned gathering has been cancelled attached as Exhibit T; and
f) Awarding Plaintiff such other and further relief as this Court deems just and
proper in the circumstances.
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COUNT IV
CIVIL CONSPIRACY
62. Plaintiff repeats and realleges each and every allegation contained in each of the
preceding paragraphs and incorporates them herein by reference.
63. Defendants have acted in concert and under an agreement with a common design to
engage in illegal actions within the City of Long Branch – namely, to host an event without a
permit and to do so with knowledge that the event was in violation of local ordinances.
64. Defendants each engaged in overt acts in furtherance of this conspiracy. Defendants
posted informational flyers and advertisements, attended the gathering, recorded and posted videos
of the event, and encouraged others to attend and engage in dangerous and illegal conduct
including the vandalizing of a police vehicle.
65. The very nature of the event was for the illegal purpose of an non-permitted event
with the stated goals of engaging in illegal acts such as public intoxication, fighting and vandalism.
66. The Plaintiff’s suffered special damages due to the nature of the illegal gathering,
including overtime costs, cleanup costs and damage to the reputation and standing of the City.
WHEREFORE, Plaintiff demands judgment against Defendants jointly and severally for:
a) Permanently enjoining Defendants from advertising, promoting, or
encouraging, and events within the City of Long Branch without applying for
and obtaining a special event permit in violation of Long Branch Municipal
Code 247-4;
b) Requiring Defendants to remove any advertisements or postings promoting the
June 19, 2022 event or any future pop-up parties planned for the City of Long
Branch and requiring defendants to post notice as drafted by the Plaintiff that
any planned gathering has been cancelled attached as Exhibit T;
c) Reimbursement of all extraordinary costs incurred as a result of the Plaintiffs
response to and clean up of the mass gathering on May 21, 2022;
d) Compensatory and punitive damages in an amount to be proven at trial;
18
223007v1
e) Awarding Plaintiff attorneys fees and costs; and
f) Awarding Plaintiff such other and further relief as this Court deems just and
proper in the circumstances.
RAINONE COUGHLIN MINCHELLO, LLC
Attorneys for Plaintiff, City of Long Branch
By:_____________________________________
Louis N. Rainone, Esq.
Dated: June 7, 2022
19
223007v1
INDEX OF EXHIBITS
Exhibit A – Social media posts by Mr. Thompson
Exhibit B – Video of social media post of Mr. Small participating in events
Exhibit C – Social media posts by Mr. Glasper
Exhibit D – Social media posts by Mr. Anderson
Exhibit E – Social media posts by Ms. Gill
Exhibit F – Social media posts by Mr. Courten
Exhibit G – Flyers advertising the June 19, 2021 event
Exhibit H – Long Branch Police Department Shift Briefing for June 19, 2021
Exhibit I – Video compilation of the June 19, 2021 crowd
Exhibit J – Flyers posted for the May 21, 2022 event
Exhibit K – Social media post regarding the potential to overwhelm the area
Exhibit L – Sample of the police reports generated during the event on May 21, 2022
Exhibit M – Police incident report of May 21, 2022
Exhibit N – Spreadsheet report by the City totaling overtime expenditures
Exhibit O – Social media posts by Mr. Thompson regarding police investigation
Exhibit P – Social media posts by Mr. Thompson regarding his promotional efforts
Exhibit Q – Flyers advertising the June 19, 2022 event
Exhibit R – Video compilation of various social media posts related to the event
Exhibit S – Long Branch ordinances
Exhibit T – Long Branch Beach Linkup Event Cancellation
223808v1
Louis N. Rainone, Esq. (Attorney ID#: 021791980)
RAINONE COUGHLIN MINCHELLO, LLC
555 U.S. Highway One South, Suite 440
Iselin, New Jersey 08830
Tel.: 732-709-4182
Fax: 732-791-1555
Attorneys for Plaintiff, City of Long Branch
CITY OF LONG BRANCH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MONMOUTH COUNTY
Plaintiff,
DOCKET NO.:
v.
Civil Action
WAVELL THOMPSON dba/aka
@PERCC30_DICKK dba/aka ORDER TO SHOW CAUSE FOR
@PERCC30DICK, PRELIMINARY INJUNCTION WITH
KEVIN J. SMALL dba/aka TEMPORARY RESTRAINTS
@_YOUNG_BISHOP, JAYSON S.
GLASPER dba/aka @JAY.DUHGOAT,
AKEIL T. ANDERSON dba/aka
KILSOSOUTH dba/aka KILSOSOUTH2X,
SEMYA GILL dba/aka @MYAAIMANI2.0,
JAYLEN COURTEN dba/aka
@SOSAACTIVATED, JOHN DOES 1-
5000, and ABC COMPANIES 1-5000
Defendants.
THIS MATTER having been opened to the Court by Rainone, Coughlin, Minchello, LLC,
attorneys for Plaintiff, City of Long Branch, seeking relief by way emergent and preliminary
injunction pursuant to R. 4:52, based upon the facts set forth in the verified complaint filed
herewith; and the Court having reviewed the Verified Complaint, and the brief submitted herewith,
and it further appearing that Plaintiff will suffer immediate irreparable harm absent the relief
contained herein, and notice of this application being given to all parties, and for good cause
shown;
It is on this _______ day of _______________________, 2022;
ORDERED that pending the return date of this Order to Show Cause:
222809v1
Louis N. Rainone, Esq. (Attorney ID#: 021791980)
RAINONE COUGHLIN MINCHELLO, LLC
555 U.S. Highway One South, Suite 440
Iselin, New Jersey 08830
Tel.: 732-709-4182
Fax: 732-791-1555
Attorneys for Plaintiff, City of Long Branch
CITY OF LONG BRANCH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MONMOUTH COUNTY
Plaintiff,
DOCKET NO.:
v.
Civil Action
WAVELL THOMPSON dba/aka
@PERCC30_DICKK dba/aka CERTIFICATION OF
@PERCC30DICK, DOMINGOS A. SALDIDA
KEVIN J. SMALL dba/aka
@_YOUNG_BISHOP, JAYSON S.
GLASPER dba/aka @JAY.DUHGOAT,
AKEIL T. ANDERSON dba/aka
KILSOSOUTH dba/aka KILSOSOUTH2X,
SEMYA GILL dba/aka @MYAAIMANI2.0,
JAYLEN COURTEN dba/aka
@SOSAACTIVATED, JOHN DOES 1-
5000, and ABC COMPANIES 1-5000
I, Domingos A. Saldida, of full age, hereby certifies as follows:
1. I am the Public Safety Director with the City of Long Branch. In that capacity, I am
directly responsible for the day-to-day operations of the City of Long Branch Police
and Fire Departments and am fully familiar with the facts and circumstances of this
matter.
2. The individuals named in the Complaint have been investigated by the City of
Long Branch Police Department and are believed to have used their social media
223279v1
CITY OF LONG BRANCH, SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: MONMOUTH COUNTY
Plaintiff,
DOCKET NO.:
v. CIVIL ACTION
WAVELL THOMPSON dba/aka
@PERCC30_DICKK dba/aka
@PERCC30DICK,
KEVIN J. SMALL dba/aka
@_YOUNG_BISHOP, JAYSON S.
GLASPER dba/aka @JAY.DUHGOAT,
AKEIL T. ANDERSON dba/aka
KILSOSOUTH dba/aka KILSOSOUTH2X,
SEMYA GILL dba/aka @MYAAIMANI2.0,
JAYLEN COURTEN dba/aka
@SOSAACTIVATED, JOHN DOES 1-
5000, and ABC COMPANIES 1-5000
Defendants.
BRIEF IN SUPPORT OF ORDER TO SHOW CAUSE FOR PRELIMINARY
INJUNCTIVE RELIEF WITH TEMPORARY RESTRAINTS
RAINONE COUGHLIN MINCHELLO, LLC
Louis N. Rainone, Esq. (Attorney ID #021791980)
515 U.S. Highway One South, Suite 440
Iselin, New Jersey 08830
Tel.: 732-709-4182
Fax: 732-791-1555
E-mail:
[email protected] Attorneys for Plaintiff City of Long Branch
Louis N. Rainone, Esq. (Attorney ID #021791980)
On the Brief
Dated: June 7, 2022
