Download the complete Brief exactly as filed in the 




There are 19 Exhibits which are referenced in the Brief.

 These documents can be downloaded as well.

To obtain the 19 Exhibits please click



(We need your help!)

On Monday June 1, 2015 the SAPPA Group will be issuing a Press Release and will begin an effort to get the document to as many news outlets as possible.  The target is not just outlets here in New Jersey.   Media enterprises across this great land should be contacted and given the opportunity to pick up this news item and present it to their readers and viewers.

The Press Release is displayed below in JPG format for the convenience of our readers and supporters of this endeavor.  Mr. Purpura's contact information has been obscured for this open source web posting, but if you think you would like to present this Press Release to your favorite media outlet please contact me, Dwight Kehoe, at  Please tell us a bit about yourself and include a contact telephone number where we can reach you.  We will then send you a link where you can download the unobscured Press Release in a PDF format which you can then send to media outlets of your choice.

​The filing has been accepted by the court and issued Docket Number 15-03534 and has been assigned to the Honorable Judge Michael J. Shipp.


​​​​By TPATH Contributor Ms. RoseAnn Salanitri

January 10, 2015 ~TPATH~ The new year brought with it old concerns - especially regarding the vulnerability of American citizens, including a worldwide increase in Islamic terrorists’ activities.  As the Islamic terrorist movement grows, our vulnerability is increased not only by the terrorists but by lawmakers that have seriously infringed upon our Second Amendment right to defend ourselves and our families. The Second Amendment is short and clear.  It reads: A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms (sic), shall not be infringed.  (Emphasis added) While some dispute the meaning of what our Founders meant by the term “Militia”, the second half of the Amendment that is emphasized above is unambiguous. It simply means that the “people” - that’s you and me - have the right to purchase, keep, and carry firearms.   ​According to our Constitution, this is a civil right that is meant to be protected by government.  It bears repeating. This is not a privilege. It is a right. Therefore, it does not require a license and should not be regulated or infringed upon. This Amendment, which is part of our Constitution, is also legally binding upon all law makers and government officials who have taken and oath to uphold the Constitution.  By virtue of their office, no one - no, not one - has the right to infringe upon any of our civil rights, including this one.  As a matter of fact, the Supreme Court has ruled on numerous occasions that any law that is contrary to the Constitution is no law at all.  Therefore, all the well-meaning firearms regulations are unconstitutional, since they infringe upon a civil right that is guaranteed in the Constitution. ​Even the most notoriously liberal Ninth District Court recognized our civil right to defend ourselves against terrorists.  They stated: “The right to bear arms is the bulwark against external invasion. We should not be overconfident that oceans on the east and west coasts alone can preserve security. We recently saw in the case of the terrorists attack on Mumbai that terrorist may enter a country covertly by ocean routes, landing in small craft and then assembling to wreak havoc. That we have a lawfully armed populace adds a measure of security for all of us and makes less likely that a band of terrorist could make headway in an attack on any community before more professional forces arrived…” In Nordyke v. King, 364 F.3d 1025, 1037 (9th), Judge Gould stated: “As I have said previously, I do not think that individual rights under the Second Amendment are outmoded․ The Second Amendment was designed to provide national security not only when our country is strong but also if it were to become weakened or otherwise subject to attack. As the people bear the risk of loss of their freedom and the pain of any attack, our Constitution provides that the people have a right to participate in defense of the Nation. The Second Amendment protects that fundamental right.”  ​Although many of our lawmakers may believe that they are doing good by instituting gun control legislation, they are actually endangering this country and our citizens by infringing upon their civil right to defend themselves with firearms.  In the process, they are creating a situation where citizens, now increasingly at risk from terrorists’ attacks, lack the means of defending themselves.  This is not only ill-advised, it is reckless and it endangers our citizens -  and “reckless endangerment” is not only a distasteful term; it is a criminal violation. According to, reckless endangerment is defined as:…a crime consisting of acts that create a substantial risk of serious physical injury to another person. The accused person isn't required to intend the resulting or potential harm, but must have acted in a way that showed a disregard for the foreseeable consequences of the actions…It should be noted that according to the definition above, the person guilty of reckless endangerment did not have to intentionally place their victim in harm’s way - even those exercising good intentions can be guilty of reckless endangerment. Furthermore, the harm can also be interpreted to be “potential.”  For example, if a parent places a child in a hot locked car, the parent returns quickly and that child doesn’t die and the parent’s never intended that any harm should come to the child, they are still guilty of reckless endangerment. Given all of the above, especially in this day and age when terrorist threats abound, our legislators that have signed gun regulations into law that infringe upon our right to own and carry firearms, are guilty of reckless endangerment.  Additionally, such laws that have passed are not laws at all since they are in clear violation of our Second Amendment, which has clearly defined the right to carry as a civil right. What about our lawmakers who have endangered us - either intentionally or otherwise? They have committed a legally prosecutable crime - they have violated our civil rights and they have violated their oath of office.  They are guilty of crimes against the Constitution and crimes against our people at a most heinous level.  They should not be sitting comfortably in the offices taxpayers have paid for; they should be sitting uncomfortably behind bars.  You may be asking that if all of this is credible, why hasn’t anyone done anything about it yet?  The good news is that a couple of patriots in the Garden State have addressed the issue and have created a model for the rest of the country to emulate. It can be found at www.tpath.orgunder the Second Amendment Preservation and Protection Act tab on the right hand side of their home page.  There’s more good news.  Should these patriots be successful in this movement, We the People will have found a way to hold our legislators to their oaths of office and to protect our Constitution.  Since the recent vote for John Boehner proved that they will no longer listen to the voice of the people and their constituents, perhaps they will pay attention to the threat of legal prosecution.   Time and time again, most of us have acknowledged that we have been sold down the proverbial stream by our three branches of government and the media, well, my friends, it’s high time we stop relying on those who have proven untrustworthy and take matters into our own hands.   You see, the truth is that we don’t have a Constitution if we don’t stand up and insist that it is upheld.  All we have is the sweet memory of a government that was once instituted to protect the rights of its citizens.  Others have paid for this right in treasure and in blood.  It is now our time to pay with diligence and commitment or this Constitutional Republic has ceased to exist and has become nothing more than a well-preserved illusion.

Contact RosaeAnn HERE







                The Honorable Judge M. J. Shipp                                     Mr. Nicholas E. Purpura








​As of this date, Wednesday, May 27, 2015, Mr. Nicholas E. Purpura has filed his legal Brief with the Federal District Court in Trenton, New Jersey.  Also, as of this date, all the defendants have been served and issued a full copy of the Brief.  Those served include Governor Chris Christie, the State Attorney General, the Firearms Supervisor, several State and Federal Judges as well as over 30 New Jersey lawmakers.

Each of these defendants are required to prepare a defense for the civil rights  violations they are being charged with.  There is no legal argument that any of them can proffer that will hold up in the United States Supreme Court, the eventual destination of this legal action.

Many of the outrageous rulings and defenses used by these defendants and supported by unconstitutional edicts will not be able to withstand the focus which Nicholas E. Purpura v  Governor Chris Christie, et al. will direct at them.  For those Judges and lawmakers who do not wish to find themselves on the wrong side of the eventual Supreme Court ruling, we here at the SAPPA Group would like for each of them to know, it  may not be too late to mend your ways and begin honoring the oath you each have taken to support and defend our great Constitution.





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