District Court

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District Court - Nassau County, State Of New York

The People Of The State Of New York

MOTION

PLEASE TAKE NOTICE, that on the within affidavit of ALLAN CRONSHAW JR., affirmed and witnessed to on the 25^th day of March, 2004, and upon all the proceedings heretofore had herein, the undersigned Motion to Dismiss will move this court at the courthouse located at 99 Nichols Ct., Hempstead, New York, on the 25^th day of April, 2004, at 9:30 o’clock in the forenoon of that day or as soon thereafter as can be heard for an Order of Dismissal of the within Summons of improper plates (Liberty).

The vehicle in question being properly registered in the State of New York under the plate number REABA; and the plates in question being of the variety that was properly issued by the State of New York; and it being UNEQUAL PROTECTION UNDER THE LAW as the use of older plates is a commonly accepted practice among vintage and classic car enthusiasts which is accepted at least in practice by the various police departments across the state; that the current issued plates bearing the slogan THE EMPIRE STATE had previously been banned by the courts; and that the defendant, Allan Cronshaw, does not use THE EMPIRE STATE plates by reason of a Constitutionally protected RELIGIOUS OBJECTION!

PLEASE TAKE NOTICE, that defendant Allan Cronshaw is an Ordained Clergy of the World Wide Nazirene and Ebionite Restoration Movement (see http://Ebionite.com ), and thus lives in strict accord with Spiritual rather than philosophical religious beliefs and convictions.

PLEASE TAKE FUTHER NOTICE, that answering affidavits by the County Attorney are to be properly served upon the defendant at least 12 days prior to any hearings in this matter.

The People Of The State Of New York

COUNTY OF NASSAU

ALLAN CRONSHAW JR., duly affirms, deposes and states, that I am the defendant in the above captioned action; I am fully familiar with the events and circumstances; and I make this affidavit in support of my Motion to Dismiss the above summons.

1. That on March 23, 2004, I was detained by Officer Dixon, badge #197, of the Hempstead Police Department, who then issued the above summons # LR 996665 5 (see attached), alleging improper plates (Liberty).

2. That plates in question were issued by the State of New York and bared the proper custom plate number of REABA, and said plates contain no expiration date whatsoever.

3. UNEQUAL PROTECTION OF THE LAW: It being a commonly accepted practice by owners of vintage and classic cars, to acquire, use and display a plate that was issued by the State of New York in the year the vehicle was manufactured.

4. That it has been explained to me by various law enforcement officials, that so long as the plate number is in accord with the registration of the vehicle in question, and was issued by the State of New York, that this practice is acceptable and proper.

5. And this can be observed at most weekend car meets where owners of vintage and classic cars converge to show their vehicles – often in parades with local police being present – and it being the case that many of these vehicles exhibit plates which correspond to the year of manufacture. As an example: Many 1932 Fords are legally driven on the road with plates that were issued in 1932, with which the owner and registrar of the vehicle has purchased a custom plate number which corresponds to the plate from 1932 which he displays on the vehicle.

6. That my vehicle and registration has been examined by law enforcement on a number of occasions, and the Liberty plates bearing the proper number were never an issue; the last being when I was recently hit from behind and the Nassau County Police were present on the scene, confirms this point.

7. It has been further explained to me that in the event that the plates were lost, the vehicle can be legally driven by affixing a cardboard license plate bearing the proper number said vehicle is registered under, and state of issuance (New York State).

8. I also understand that plates are recalled and reissued periodically in order to reinitiate the numbering system that would exceed the digits if new plates were not issued; but that is not the case with respect to custom plate numbers as in this situation.

9. THE EMPIRE STATE LOGO: In the mid 1960’s, the state was barred from using the logo The Empire State by the courts; and this practice was only recently continued with the issuance against previous court rulings of the current variety of non-custom plates.

10. CONSTITUTIONAL RELIGIOUS OBJECTION: The defendant Allan Cronshaw has a religious objection to displaying plates with the words: The Empire State, by virtue of the fact that the concept of a being a part of a worldly empire is against his religious convictions. And this being further within his rights in view of the fact that the State of New York was in the past barred by the courts from forcing residents to display this logo.

11. In the same way that American society and culture has revised many of their older ways that were at one time taken for granted, and we observe this in the fact that Native Americans have protested the use of their names, the concept of a worldly empire is not only contrary to the Constitution which maintains that sovereignty remain with the people, and the concept of empires are in accord with places such as ancient Rome; the idea of being a part of the Empire of New York is religiously sacrilegious.

12. In view of the above, the defendant Allan Cronshaw moves this court to dismiss all charges against him forthwith.

The below signed individuals personally know the above signed Allan Cronshaw, and witness that he affixed his signature to the within affidavit in their presence.

In view of the Constitutional issues raised in the within motion and affidavit, I prefer to present my case in writing to the Court in the event of appeal, or even a removal of the matter to US District Court. Enclosed is the original copy of the summons with a not guilty plea, the original motion for dismissal intended for the judges of the court who are to rule on the matter, a copy for the county prosecuting attorney for him to answer from, and an extra file copy.