Allan Cronshaw Jr.

480 Maitland St

East Meadow, NY 11554


June 21st, 2004




To The Clerk Of The Court

Nassau County Traffic Court

16 Cooper Street

Hempstead, NY 11550


Re: Notice of Motion for summons # LM 761596-3 and LM 761597-4

Dear Clerk Of The Court:

In view of the Constitutional issues raised in the above Summons, it is necessary to present my case in the form of a Motion to dismiss the cause of action against me.  In addition to the Original and two copies of the Motion, one of which you can pass on to the prosecuting attorney and the other for a file copy, enclosed is a copy of the Notice to appear for a scheduled CONFERENCE which is returnable on July 31st, 2004.   The Motion itself has a return date of July 16th, 2004.

In the Motion and Affidavit I provide parallel case law to demonstrate that the New York State seatbelt law is unconstitutional because it fails to contain a religious exemption.   The seat belt law, which is founded upon an Atheist Secular-Humanist mindset, and is erected on an outdated model based upon a Darwinist perspective of life that modern science has proven to be a “fossilized… and mechanical computer-like functioning that it is in real danger of self-extermination”, represents a denial of my Constitutionally protected First Amendment practice of my religion.     In my enclosed Affidavit, I therefore present my arguments from (1) a case-law perspective; (2) a religious perspective; (3) a modern scientific perspective; (4) and from a spiritual perspective; which is of my primary concern in the rejection of the Atheistic mindset that the seat belt law is founded upon.

If the court affirms my First Amendment rights, and dismisses the matter, then the issue is ended right there.   If, on the other hand, my Motion for dismissal is opposed, then there is a requirement that the NYS Attorney General be given notice in the event he desires to intervene in defense of the law.   And since Traffic Court is not the environment for Constitutional arguments, I would not object to the County Attorney’s petition of the Appellate Court as having Original Jurisdiction in this matter, and subsequent removal to the higher court.   In the event that I feel that I am being denied a proper hearing in this matter, I will myself remove the action to US District Court.   And as the world-wide leader of the Ebionite Nazirene Restoration Movement, all documents in this case will be uploaded to .   In any event, so long as the matter remains active, I will appeal it all the way to the US Supreme Court if necessary.







Allan Cronshaw Jr.