UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK 2ISNOY 4 PH ur OL Peggy Harley , Pamela-¥: Harley: El-bey et af Plaintiff cam COMPLAINT -against- JURY TRIAL: YES EDWARD F GUIDA JR. ( IN HIS INDIVIDUAL CAPACITY), JOYCE TSENG OF NYCHA (IN HER INDIVIDUAL CAPACITY), HSUI TSENG OF NYCHA (IN HER INDIVIDUAL CAPACITY), CITY MARSHAL EDWARD GUIDA INCORPORATED, MARSHAL CITY OF NEW YORK BADGE # 14 INCORPORATED, OFFICER MURN PSAS BADGE # 24085 , OFFICER MALIK BADGE # 7799, JANE DOE'S, JOHN DOE'S , NEW YORK CITY HOUSING AUTHORITY (NYCHA), NEW YORK CITY POLICE DEPARTMENT (NYPD) Defendants, |. Parties in this complaint: A. Plaintiff Peggy Harley C/O 4602 21st STREET P.O. ROX DIVISION 1545 Long Istand City, New York, 1101 8.Defendant No. 1 EDWARD F GUIDA, JR. (IN HIS INDIVIDUAL CAPACITY} 47-26 104TH STREET ‘CORONA, NY 11368Defendant No 11. NEW YORK CITY POLICE DEPARTMENT (NYPD) 1 Police Plaza New York, New York 10007 I. Basis for juris ‘A. What is the basis for Federal Court jurisdiction ? The basis for Federal Court jurisdiction is Federal Question 8. I the basis for jurisdiction is Federal Question, What Federal Constitutional, Statutory or ‘Treaty Right is at issue? Civil Rights Statue 42 U.S.C. 1983 The court has jurisdiction over this action because it arises under Federal Constitutional, Statutory and Treaty Rights 28 U.S.C. 1331, 18 C. If the basis for jurisdiction is Diversity of Citizenship, what is the state of citizenship for each party There is no basis for jurisdiction under Diversity of Citizenship in this action. Parties addresses are are listed above. Please see Section! Plaintiff's state of citizenship - Peggy Harley Long Istand City, New York Defendants states of citizenship Each defendants Citizenship is in New York M). Statement of Claim To prove that City Marshal Edward F. Guida ir. Badge # 14 , Joyce Tseng of NYCHA and other Agents (Of NEW YORK CITY HOUSING AUTHORITY (NYCHA), intentionally Broke the law by breaking and entering intd my apartment without a Warrant violating my family’s Civil and Constitutional Rights causing us ‘numerous torts. To further Prove that Marshal Edward Guida and Joyce Tseng where assisted with this crime by Officer Murn Badge # 24085 and Officer Malik Badge #7799 thereby breaking the law.‘A. Where did the events giving rise to your claim(s) occur? ‘The events giving rise to my claims began in Long tstand City, New York, on the Premises of New York City Housing Authority grounds in my apartment on 12th Street 8. what date and approximate time did the events giving rise to your claim(s) occur ? ‘The approximate date and time giving rise to this specific claim began on April 17, 2019 between approximately 3- 4 PM in the afternoon. ©. Facts and Related Background History 1. We, The Family Harley are Civilians Non- Combatant "Nationals", fully cognizant flesh and blood living beings. 2. On April 17, 2019, on a day that might otherwise have been an afternoon at home in Long Island City , NY , City Marshal Edward F. Guida Jr. illegally broke and entered and unlawfully trespassed into my dwelling place without a WARRANT traumatizing my family which was aided , abetted and facilitated by Joyce Tseng of New York City Housing Authority. 3. As | walked into the front of my apartment from the bedroom Marshal Edward F. Guida Badge # 14 was actually walking into my living room. | immediately said "Get out, you have no business here, | am not dressed, get out of here.” This irresponsible law breaker began joking saying ["I'm a nice guy, maybe we can be friends after this."] | told him again "Get out of here, {Im calling the cops because you don't have any legal right to be here. We sent you a CEASE AND DESIST letter as well as a fax from Bankruptcy Court, get out and and I'll get it." Guidawalked out making jokes saying, [" You look Dressed to me... also violating my family's privacy and religious protocol. | locked the door behind Guida. it 4, While | was looking for the sealed document from Bankruptcy Court, trying to grab something to put on, Marshal Guida had the gall to unlock my door and walk back into my apartment once again. This time my relative got to the front of the apartment where Guida was and told him to get out. He walked out again, turned around making a U Turn and stuck his foot in the door as the others with Guida continued waiting by the door . My relative yelled "call the cops” Guida's response to us calling the cops was, ["You gonna call the cops on me, your really going to call the cops on me? Here, I'll do it, they'll get here much faster."] | handed the Bankruptcy document to my relative which she handed to Guida evidenced by EXHIBIT A, which proves that he did not have jurisdiction to enter. Guida claimed he never received our faxes or mail, which is a complete falsity evidenced by receipts of which we have a few. 5. Guida continued joking and sarcastically stated, after he realized that I connected with the Police via telephone, ["You Got Your Stay"] as if to say he'd be back. At that point he and his crew scurried away, with Guida leaving them behind as evidenced by EXHIBIT B, Cand D, after they itentionally violated my family's privacy, traumatizing us causing us numerous torts. Guida and his crew moved quickly to avoid being identified by the police that we called, apparently believing that we could not identify him personally. “6. My family asked Marshal Guida to produce his warrant, but he never showed it to us, instead he said "I got a warrant”. Clearly Marshal Guida did not have a Warrant or any form oflegal authority to break and enter. Marshal Guida, who is a servant of the court made a concerted decision to perform an unlawful and certainly orchestrated illegal takeover. The Marshal therefore burglarized my apartment with the intent to steal and to possibly physically harm my family. No man is above the law, Entick v. Carrington 1765. 7. Guida was also assisted with illegally trespassing by a NYCHA employee (Jane Doe), a "Black" West Indian female, brown skinned with a short wavy bob like hair style about 5'8 who perhaps may be an in house Police Officer for NYCHA.The Employee is pictured in the background of EXHIBIT E. If she or one of the other NYCHA employees "John Doe" "White" hispanic male 56 heavy set (Maintenance) did not unlock my door, then it is safe to say that Marshal Guida has NNYCHA's skeleton keys to our apartment. Either way this was done under the unlawful direction of the Manager Joyce Tseng and the crime is legally classified as burglary 8. Very shortly after | called the Police, Officers Murn of PSA Badge # 24085 and Malik Badge #7799 showed up and asked a series of questions evidenced by EXHIBIT F , photos of the officers taking the complaint. Officer Murn physically took the complaint but did not submit it to the Police station, which he stated he would do thereby leaving my family open to further violation and harrasment by Marshal Edward F. Guida Jr. 9. Upon information and belief the two Officers; Murn and Malik are individuals that Guida and NYCHA's Manger Joyce Tseng had on hand along with Guida's ten (10) plus person displacing crew. | believe that the two officers may be personal friends of the Marshal for a number of reasans. One of the reasons is that Guida has a photo posted on his LINKEDIN pagethat looks very much like Officer Malik Badge # 7799 which I have attached as EXHIBIT F1, F2, FB and Fa. 10. | am sueing officers Murn and Malik for aiding, abetting and facilitating a crime with intent to conceal a crime, failure to perform Primary Duties of Police Officers /Public Servants, failure to submit an incident report, hi \g details of a Burglary, protecting an Officer who has commited a crime, failure to protect and serve the people and property, conspiracy and failure to uphold the constitution to which they have swom. | am also demanding that the officers be fired when they are found to be have conspired as associates of Edward Guida and Joyce Tseng. 11. Defendant Joyce Tseng (NYCHA’s Housing Manager of QueensBridge) also corroborated with Officers Murn, Malik and Marshal Edward Guida Jr. to keep this crime from surfacing by failing to report a Burglary on the grounds of Queensbridge Houses which is Federally funded. Naturally, Joyce Tseng would not report a crime that she facilitated on ground level. 12. | am suing NYCHA Manager Joyce Tseng who has a possible AKA Hsui Tseng in her individual capacity for conspiring, aiding, abedding and facilitating a crime (Burglary) with City Marshal Edward F Guida Jr. Badge #14, Knowing that they did not have Legal right to break and enter, send in a moving crew to evict my family along with the help of NYCHA " employees " Jane and John Doe * who assisted Guida with Breaking and Entering. | am also suing for harassment and interference with Quiet enjoyment 13.1 am suing "Jane and John Doe" NYCHA employees in thconspiring, Breaking and entering ,aiding , abetting and facilitating a crime. | am demanding that they be fired from the their positions with New York City Housing Authority. Jane and John Doe are pictured together walking off behind part of Marshal Guida'a crew in EXHIBIT C. 14. This entire crime is an elaborate setup, which is not only intended to harm my family and to make us homeless, but to satisfy the wants of some very angry Judges and Lawyers whom | have told the truth about. itis also the continuation of the Gentrification process in the Long Island City area, first. removing the “true leaders", those who speak truth and truth to power. This is being done with the assistance of the accomplice Joyce Tseng who is also a Racist and a facilitator of rent theft, set in place to remove people of color from the LIC/ Astoria. 15. My family has been dragged into court By NYCHA without cause Non- Stop for numerous years, but the System continues to allow it employees and officers of the Court who commit crimes against the people to get away unscathed. | am also suing Joyce Tseng for harrasment under( Res judicata)and undue burden for unjustly hurling my family into court more than 50 times since she has had her job with NYCHA in QueensBridge. My family has lived in Queensbridge for more than 50 years. 16. Even after Breaking and entering into my apartment on April 17, 2019 without a Warrant, fully aware of having commited a crime in violation of the Consitution and Traumatizing my family, Marshal Edward F. Guida Jr. continued harassing my family by sending a Notice of Eviction ta.my family us on June 26, 2019 after he broke in to my apartment on April 17, 2019 , Knowing that he did not have Jurisdiction to do so on either account which can beproven. 17. Because Marshal Guida Jr. sent yet another illegal eviction to my family, a family member was forced once again to file for Bankruptcy to prevent the illegal eviction of Marshal Guida on July 3, 2019 bringing the count to (5) filings for Bankruptcy to prevent the illegal evictions by City Marshal Edward G. Gui fa Jr and NYCHA employee Joyce Tseng who does not have legal standing to continue sending eviction notices to my family which shall be proven though this action. 18. How did City Marshal Edward Guida Jr_,an independant business owner and Servant of the Court, who takes his orders form the court end up illegally standing in my living room? What Court instructed Guida to Break and Enter? 19. The Federal Bankruptcy Court enters the Courts Orders of Stays into the system of which Marshal Guida has free access to all information relating to such. Its the responsibility of the Corporation "City Marshal Edward Guida Jr Badge # 14." and his person to know if a Stay is‘in place and the Marshal was fully aware that there was a stay effectuate. 20. The aforementioned Bankrupcty Stay Document / Cease and Desist letters were sent to New York City Head officials : Mayor Bill De Blasio , Governor Cuomo, IRS Headquarters, Washington D.C, James P. O'neil, Police Comissioner of the City of New, NYCHA Law Department: Attorneys Caroline H. Piella, Alan Liskov, David, | Farber and NYCHA North Queens Bridge Office ATTEN: Joyce Tseng.We also contacted Sherriff Danny Fucito. No one did a thing to help with the situation or acknowlege that harm was done.21. The City of New York, the State and Justice System should on its own motions conduct an investigation as to where the Body Organs of the deceased at the Guida Funeral home located at 47-26 104th Corona, NY (which is physically attached to the Marshals office) are ending up and where the organs of the individuals who are evicted by Marshal Guida Jr. end up after ‘their death. It should be looking into who is doctoring many many death certifcates and creating new identities for others from the names and Social Security numbers of the deceased instead of allowing Marshal Edward F. Guida Jr. Badge # 14 to work for the City of New York. This Marshal; Edward F. Guida should not be working for the City of New York. On April 16, 2019, the day before the illegal Break In , a Daisy Flower was placed in my apartment door knocker. Who else but City Marshal Guida who is also the owner of Guida Funeral Home in Corona, NY would do such a bizzare thing. ! am asking that his Badge and license be revoked, and that he is no longer placed in any position that requires that he protect, serve or collect Individuals or their possesions. This man is not fit to serve the City of New York and it is a scary and dangerous thing to see him unleashed to do so. 22. in 2010 Marshal Edward Guida Senior, (Deceased) the father of Edward Guida Jr. who was also identified as Badge # 14, conducted an eviction in a home in Long [sland city owned by my family. We have yet to figure out what happened to the four (4) new stoves and (4) refrigerators that were in that house. This pales in comparison to his son unlawfully breaking into my apartment. Both Marshal Guida Senior an Junior carry the same Identification Badge, Badge #14. 1023. | have not had one decent nights sleep since Marshal Guida broke into my apartment on April 17 2019 , nor am | able to sleep during the day which | have tried. | am startled by every sound while at home, thinking that itis the Marshal breaking in and Violating my family again. Jam very concerned for my familys safety. 24. | cannot say with certainty that Marshal Edward F. Guida Jr. planned on exerting physical violence, but I can say that all of the elements that create violence was present that day because he broke in my apartment violating my family without a cause and without a Warrant. Nevertheless, it appears that something strange was intended to occur. If we assess the situation, people of color are being murdered in the street by Police Officers on a regular bases and not much is being done by the Judicial ‘System to put an end to this, 25. The Venue for murdering "Blacks" as some call us, has widened. People of color are not only being ‘Murdered in the street by Police Officers, but now we are no longer safe even in our own homes. | Pray that the court would begin to make a difference by Ajudicating these cases Justly and Quickly 26. in 2017 it was reported that a "White" female police officer walked in to a "Black" mans apartment , claiming to believe that she was in her own apartment. She then Shot the victim in cold blood murdering him. By the Grace of YHWH , no one was murdered in my apartment. but | must inform the Court that there are striking Facts, similarities and circumstances that are the same as the Eric Gamer Case which are as follows. These things cause me greater concern for my family's safety. (A) Both Pantelo and Marshal Edward F. Guida received strong Media coverage of their Weddings How often do Police Officer receive heavy media coverage of their weddjngs? These Officers are "not Celebrities where media coverage would be a typical occurance. (8) Both Pantelo and Marshal Edward F. Guida had wedding receptions planned at the same venue, The ‘Westmount Country Club in woodland Park, New Jersey. Panteleo is from Staten Istand and Marshal Guida is from Queens. {C) Police officer Panteleo Murdered Eric Garner wearing a tee- Shirt with the # 99 on the back of it, Officer Malik showed up at my apartment with the Badge # 7799 also containing the number 99 in it which is an inverted 66. the same guy {D) Officer Malik Badge #7799 appears to be the same man in a photo on Marshal Guida's Linkedin ‘page. What are the chances of this officer showing up at my door to take a police report, Ifin fact he is the same officer. What are the chances of these things being coincidental. No chance. Therefore | must question what was really planned for my family on that day? (4) Marshal Edward F. Guida Jr, Badge # 14 got married at the age of (33) asin 33 degree Mason. No chance that this is a good indication when associated with this man. ! do not trust this man. Therefore | am submitting an order to Show cause for preliminary injunctive relief and a restraining Order/Order of protection against City Marshal Edward F. Guida Ir. and Joyce Tseng. | Pray that the court would swiftly inforce this Relief as individuals who testify against officer are often found unavailable to testify , meaning not breathing. NYCHA Management also has a history of causing damage to dwellers including death threats and creating situations that cause death 27. 1am suing NEW YORK CITY HOUSING AUTHORITY for jiability, emotional distress, conspiracy, aiding, ‘abetting and facilitating a crime, failure to supervise and oversee it's employees, violation of theContitution and my Civil Rights . 28. ! am suing the NEW YORK CITY POLICE DEPARTMENT for Liability, violation of my Civil Rights and failure of it's employees to uphold the Contitution, emotional distress, Conspiracy, aiding abetting and facilitating a crime, failure to supervise it employees, interfering with a crime, and obstruction of justice . IV. Relief State briefly and precisely what damages or other relief the plaintiff asks the court to order. Do not make iegal arguments. include any basis for claiming that the wrongs alleged are continuing at the present time. include the amounts of any actual damages claimed for the acts alleged and the basis for these amounts. Include any punitive or ‘exemplary damages claimed, the amounts, and the reasons you claim you are entitled to actual or punitive money damages. 1. Lam suing all Defendants in this complaint for Damages A. lam Suing Edward F. Guida Jr. for Monetary Damages in the amount of Seven Million dollars ( $7,000,000.) for violating the Constitution to which he has sworn, thereby violating my family's Civil Rights for which my family are the injured Parties who suffer loss through his unlawful acts of omisssion, negligence and harassment. This Servant of the Court has acted with malice, fraud and recklessness causing my family numerous torts including great concern for our lives, constantly running to the door with every sound that we hear in the apartment wondering if these sounds are another unlawful break in by Marshat Guida. We constantly looking over our shoulders while ‘out, wondering if we may be ambushed by the Marshal, his crew or by Police officers. As a measure of safety to the Public; as an exemplary statement and restitution, we must see Marshal Edward F. Guida Jr. permanently removed from his position as a City Marshal and that he never works in the capacity of a Police Officer. We also askthat his bond be taken. Jam also suing Marshal Guida jr. for Conspiring, Aiding, betting, Facilitating and commiting the crime of Burglary , unlawful entry and Tresspassing. The Marshal broke into my apartment without @ Warrant and without just cause which has also brought on health issues. Jam also suing the Marshal Guida's Corporation { City Marshal Edward F. Guida) for the amount of Seven Million Dollars ($7,000,000.) as this act is a part of an on going Conspiracy to harm my family. B. Joyce Tseng- {possible alias) Hsui Tseng in her individual capasisty - for the amount of Seven Million Dollars ($ 7, 000,000.) for Spearheading the crime of burglary, conspiring with City Marshal Edward F. Guida Jr., aiding, abetting and facilitating an illegal break in into my apartment without a Warrant, thereby violating my family's Civil Rights and the Constitution with an Officers of the Court. | am suing for Malice, Fraud, recklessness, disturbing the peace / quiet enjoyment and harassment. Jam also suing Joyce Tseng as an investor in the property of Queens Bridges Houses in her individual compasity as well as an employee of NYCHA under a Government contract as the manager of Queens Bridge Houses and her Executive position with NNYCHA. In other words | am asking the she be fired inspite of her investment in Queens Bridge Houses. | am also suing for numerous torts associated with Joyce Tseng conspiring with Officers Murn PSA9 Badge # 24085 and Malik # 7799 for concealing 9 crime. c NeW! YORK CITY HOUSING AUTHORITY (NYCHA) in the Amount of Seven Million Dollars ($7, 000,000.) for Liability of its employee's involvement with an illegal break in, classified as Burglary , conspring with a servant of the court and public officers, 14interfering without a warrant for removal and having full awareness of it's Executives and office worker, managers and's CEO'S harming the people and doing absolutely nothing to stop or prevent this. | am suing for NYCHA using the media and the worldwide web to establish it's wicked intentions as innocent deeds rather than criminal acts that disregard the Constitution and ones Civil Rights , thereby misleading, the people. | am suing NYCHA for failing to take basic and reasonable steps to protect dwellers from harm, D. 5.2m suing Jane and John Doe -("the Maintenance man") and Jane Doe an (" Office worker/ Management") , Employees of New York City Housing Authority/Double Agents for their particpation in a knowly orchestrated Break in, aiding abetting and facilitating a crime with Joyce Tseng and City Marshal Edward F. Guida Jr. | am asking that they be fired from NYCHA , and not merely transfered to a different location as NYCHA does when it jes it employees who assist the delegating management in harming dwellers. | am asking that their retirement pension/ funds be revoked for these crimes. | am suing Jane Doe for the amount of One Million Dollars ($ 1,000,000) for aiding abetting and Facilitating an illegal Break In with City Marshal Edward F. Guida Jr. ‘These NYCHA employees take their instruction from Manager/ Executive Joyce Tseng. Clearly Jane Doe thought that commiting these crimes, ignoring my family's Civil Rights and the law was fun and games as her amused and smurking face indicated during the Burglary. ! am suing NYCHA for liability as a result of these employees criminal acts also. E. Officers Murn PSAQ Badge #24085 and Malik Badge # 7799 for the amount of $1,000,000 each. | am requesting that their Bonds be taken so that they cannot work in the capasity of a Police Officer eves again because they have injured my family by failing to uphold the Consitution to which they have sworn, thereby violating our Civil Rights. The Officers have conspired with NYCHA's Joyce Tseng and City Marshal Edward 15F. Guida Jr. to conceal a crime, failing to submit a complaint intentionally. F. The Police have parked their on duty vehicle on the sidewalk in front of my Building for hours on end including in the wee hours of the morning flashing their lights upward into my apartment windows from June 17, 2019- early October 2019 and am concerned for my family's safety. This is nothing short of bullying and scare tactics that ‘may be acted upon by any police officer in the area. After Officers Murn and Malik were Knowingly reported for conspiring, aiding abetting and concealing a crime with Joyce Tseng and Marshal Edward F. Guida who is fikely @ personal friend of Officer Malik #7799, Officer Malik # 7799 has been seen leaning on the gates directly facing my building which is quite unusual behavior for an Officer who has been reported to have participated in a crime in that very same building. | consider this to be an intimidation tactic which is an actual threat because the Officer carries a weapon. This. is not a concidence by any means and is directly related to intimidating my family dispite the fake scenarios created by the Police Department to appear to have reason for camping out many times directly under my window . Many of these Photos have been removed from my phone by some "unknown" individual which of course is serviced by MetroPCS (Metropolitan Polices Service) G. 11am suing the NEW YORK POLICE DEPARTMENT (NYPD) for the amount of seven million dollars $ 7,000,000 for Liability and damages created by it's employees and Officers. H, These crimes could not have been commited without the direction of NEW YORK CITY HOUSING Manger Joyce Tseng. Therefore | am seeking a a Declartory Judgment for this claim concerning all defending Parties. Certification and Closing 16Under Federal Rule of Civil Procedure 11, by signing below, | certify to the best of my knowledge, information, and belief that this complaint: (1) is not being presented for an improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law; (3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and (4) the complaint otherwise complies with the requirements of Rule 11. A. For Parties Without an Attorney | agree to provide the Clerk's Office with any changes to my address where case-related papers may be served. | understand that my failure to keep a current address on file with the Clerk’s Office may result in the dismissal of my case. Date of signing: Oc/ghet . 20,2077 Signature of Plaintiff s Printed Name of Plaintiff 7 oe 7