meier v. meggs | federal lawsuit against crooked leon county and tallahassee officials
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Meier V. Meggs | Federal Lawsuit Against Crooked Leon County And Tallahassee OfficialsTRANSCRIPT
UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
PASTOR DANIEL L. MEIER
Plaintiff, Case No.
Hon.
v.
WILLIAM M. MEGGS STATE ATTORNEY, FL.
JUDGE GEORGE S. REYNOLDS, LEON CO. FL.
LARRY CAMPBELL LEON COUNTY SHERIFF, FL.
DAVID KOTEL, FBI
JUDGE ROBERT H. CLELAND, MI.
DEPARTMENT OF CHILDREN AND FAMILIES, FL.
GUISEPPE A. BETTA, FL.
JUDGE DAWN COLOCA-JOHNSON, FL.
VICTOR LAURIA NOVI POLICE DEPARTMENT, MI.
FLORIDA DEPARTMENT OF REVENUE
ROBERT MCNEELY, ESQ., FL.
MARILYN K. MORRIS ESQ., FL.
PAUL SHAPIRO ESQ., FL.
CHARLES McCLURE, ESQ., FL.
ELLEN HAMILTON, FL.
MANDY LUTTENTON, GA.
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AMY OLK, FL.
DEPUTY JOHN MEEKS, FL.
PRICILLA QUIONNES ESQ., FL.
JUDGE JOHN C. COOPER, FL.
JUDGE JOHN SJOSTROM, FL.
EDWARD HORAN ESQ., FL.
TALLAHASSEE POLICE DEPARTMENT, FL.
SOUTHFIELD POLICE DEPARTMENT, MI.
JUDGE KATHLEEN DEKKER, FL.
JUDGE TERRY P. LEWIS, FL.
DEPARTMENT OF HOMELAND SECURITY
DETROIT DIESEL CORPORATION, MI.
WILLIAM ALTMAN, ESQ. MI.
JUDGE WENDY BAXTER, MI.
ROBERT L. GREEN, MI.
VERACRUSE MURRAY AND CALZONE P.L.C., MI.
FEDERAL BUREAU OF INVESTIGATIONS
JUDGE E. THOMAS FITZGERALD CT. APP. MI
JUDGE HENRY WILLIAM SAAD CT. APP. MI
JUDGE JESSICA R. COOPER CT. APP. MI
DR. ROLLA BAKARI-PANZA, MI.
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RICHARD BERNSTEIN ESQ., MI.
BERNSTEIN LAW FIRM, MI.
DR. ELIAS MICHAELIDES, GA.
DR. NABIL WHEBE, MI.
DR. CHRISTINA LEPOUDRE, MI.
WXYZ CHANNEL 7, MI.
DR. DONALD ROCHEN, MI.
SHARON WOODSIDE ESQ., MI
PAUL SHOENBECK ESQ., MI
DR. WARREN BRANDES, MI
LARRY BUTLER, MI.
Defendant(S).
_________________________________/
COMPLAINT AND DEMAND FOR JURY TRIAL
Plaintiff, Pastor Daniel L. Meier, complaining against the above
named defendant(s) states as follows:
NATURE OF THE ACTION
Plaintiff is an ordained Pastor, award winning author of the book
"Hell Makers and War Makers in America" sold at Barned and Noble,
Amazon, and world wide, has a legal certification (CLA), and graduated with
honors with degrees from Florida State University. All documents and filings in
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this case are being provided immediately to the United Nations (HRC) and will
be posted world wide on web sites due to previous and continuing malicious acts
to obstruct the guaranteed right to due process and harm the plaintiff by
retaliatory actions of the defendants. For example, case# 08-43959 the unlawful
attack by the Police on the plaintiff immediately after the initial filing of this similar
obstructed complaint in September of 2007 in which the plaintiff was nearly
killed when illegally and arbitrarily attacked, beaten, choked, tasered, and
imprisoned by the Southfield, MI Police; Illegal bond was set at 150,000.00 and
plaintiff was charged with 3 trumped up felonies all of which the jury found
not guilty. End of trial, the prosecutor yells at the jury, "but he 's suing the
FBI" showing true basis for the attack. Also, in conflict of interest, obstruction,
the D.C. jurisdiction failed to timely provide a case number and then transferred
the case back to Michigan although they had jurisdiction and the plaintiff drove
to Washington D.C. from Michigan personally to file it to prevent obstruction
and fraud upon the court. Then, Judge Robert H. Cleland, who is named in the suit,
illegally takes the case from the judge assigned to it and arbitrarily and illegally
dismisses it using the illegal detention as a pretext for failure to proceed in a
timely manner. Grand Jury indictments are also being looked into by other
concerned citizens and copies will be provided to members of clergy and other
Christian organizations being victimized by this wide spread persecution. Another
book is being written containing detailed accounts of these proceedings by a third
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party and there is also a press release. This time, the whole world can watch.
This is a civil/criminal action seeking compensatory, punitive, and
exemplary damages by the plaintiff alleging: conspiracy to overthrow the U.S.
government by violent means, civil war, domestic terrorism, attempted murder,
false imprisonment, kidnapping, abduction, extortion, grand theft, obstruction
of justice, fraud upon the court, abuse of process, defamation, assault and
battery, child endangerment, malpractice, color of law violations, conspiracy
to violate civil rights, public corruption, denial of due process rights,
intentional infliction of emotional distress, negligence, entrapment, invasion
of privacy, sexual harassment and discrimination, violations of the 4th, 7th,
8th, and 14th amendments to the U.S. Constitution, violation of the freedom
of information act, interference with business relationships, malicious
prosecution, religious persecution and victimization by the illegal FBI Cointelpro
program and any other claims that may be considered and included as a matter
of law based on the unrefuted facts. Other joinders will be added as litigation
proceeds and is deemed necessary. Every and all components required and
or supporting a claim of each claim stated herein are all stated to be included
somewhere in this complaint; where additional support is necessary, findings of
fact in discovery procedures and at jury trial will provide evidence for each claim
to be fully supported as a matter of law.
SUMMARY OF CLAIM
1. On April 18, 1997 the plaintiff and his ex- wife entered into a marital
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settlement agreement finalizing their divorce. This agreement was drafted by
the former wife's attorney counseling her and ratified on April 30, 1997 by
Judge Reynolds, witnessed and signed by four witnesses and was notarized.
(exhibit #1 and #2) There was also a guardian ad litem appointed by the court
on October 31, 1996 to whom the former wife confided she was considering
giving "sole custody" to the father long before the ratification.
2. The agreement included the plaintiff, father (Daniel Meier) being
awarded "sole parental responsibility" MSA p.4 and that all matters of
personal property were "settled determined in all respects" and for purposes
of their respective present and future property rights, claims, and demands
and obligations past, present and future were "finally and conclusively
settled" and determined by the agreement. MSA p.2. Pursuant to her
attorney's own hand notes, " Personal prop.-already divided-each keep
what they already have." (exhibit #3)
3. There was no restrictive covenants as to moving out of the state and
it was in the plans for years that moving to Michigan was in the works and
being prepared for even as the agreement was being drafted. The agreement
also included a separation and non interference clause where "each shall be
free of any interference, authority, and control whether direct or indirect by
the other party to the same extent as if they were unmarried". MSA p.3
4. Moving to Michigan was agreed upon by both parties, and due to
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the former wife's propensity to violence, the former wife agreed to try to make
things work as an unmarried couple in Michigan, where job prospects were
better for both the parents. There was never any question as to where the
destination in Michigan was and each had separate vehicles for the trip.
5. On the evening of April 30, 1997 after the agreement was ratified
by Judge George S. Reynolds and the father had "sole custody", the former
wife refused to go to Michigan. The truck was loaded and ready to move and
lease expired that day, they had to leave that night. The former wife could
have easily caught up to the father on the highway with her own car, the
truck moving at only 50 mph and pulling a trailer carrying a car.
6. Incidentally, the former wife having contact with the father on the
night of April 30 while he was loading the moving van was a violation of her
probation for domestic violence and contempt of court, establishing violations
of law on her part not the fathers. The additional fraudulent affidavits filed by
the former wife add to the violations of her probation. (exhibit #4)
7. The former wife never intended to go to Michigan and rather used the
situation to conspire with Marilyn K. Morris esq., local, and out of state law
enforcement and federal agencies to fabricate and file fraudulent grand theft
charges, kidnap the father and his child from Michigan, falsely imprison the
father in state and federal penitentiaries for a month and extradite the father
to Florida in leg chains and hand cuffs on a con-air flight with murders and
rapists to Florida, deny the father his due process rights, and extort tens of
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thousands of dollars form him in the process. This is a father who had never
committed any crime and had graduated Deans List from Florida State
University 19 months earlier.
8. The father had "sole custody" and was never informed, as required by
law, of any actions in violation of the agreement and did not do any actions
in violation of the Marital Settlement Agreement constituting a significant change
in circumstances and the father and the daughter were illegally denied their
constitutional, civil, and basic human rights. The former wife was also on
probation at the time for domestic violence and it was specified for the
father to kept free from additional illegal criminal acts of the former wife.
9. The parties fully binding original Marital Settlement Agreement
was illegally ignored constituting fraud upon the court and additional denial
of due process and constitutional rights. The fabricated charges were also a
suggestion by the Novi, MI. police department that the former wife's attorney
attempt to secure "some type of felony warrant... to avoid any problems
when we attempted the pick up of the child" (exhibit#5) demonstrating the
father had sole custody and the charges a pretext to abducting the child and
kidnapping the father without any legal basis, hence all charges were dropped.
(exhibit #6) Reports were fabricated by Sgt. Conquest, Sgt. Hundersmarck,
Sgt. Harvin June 12,1997 Novi Police Department. Others may be added as
fact finding progresses as there is also a federal number allocated to this
illegal chain of events. This demonstrates cooperation between state and
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federal agencies conspiring to commit the illegal acts and extradition. An
FBI number was also given to the case, demonstrating blatant illegal cooperation.
10. The fraudulent offense reporting forms, probable cause affidavit, sworn
complaint, ex parte order, cooperative prisoner transportation agreement and
order enforcing judgment to support this act were signed and processed
primarily by officer Terry Brown (501) with officer Duncan (728), Lt. West (152)
of Tallahassee Police Department and signed by his supervisor Phil Kiracofe
(244) and notarized by officer Hoover (743) and facilitated by Judge George S.
Reynolds, State attorney Willie Meggs, assistant attorney Dana Plummer the
former wife's attorney(s) Marilyn K. Morris, Tann H. Hunt, private investigator
Danny Johnson and signed by Judge Lewis and enforced by Judge Steven N.
Andrews Sixth Judicial Circuit, Oakland County Michigan. Copies were also
sent to Leon County Sheriff Larry Campbell and Sergeant Laurel J. Allie who
prepared the cooperative prisoner transportation agreement. All conspired to
commit fraud, kidnap, assault, abduct, extradite and falsely imprison an
innocent citizen(s) of the United States by committing intentional acts in
violation of federal and state laws, due process requirements and civil rights
guaranteed under the Constitution of the United States. (exhibit #7)
11. On June 17,1997 The Novi, police department arrived at the fathers
residence in Farmington Hills, Det. Lauria informed the father he was under
arrest, the father asked what it was all about he was told they were taking
his daughter. The father informed them that he had "sole custody" and could
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show them the papers and he was not notified of any modification hearing,
detective Lauria stated to the father that he no longer had custody and stated
to the father, "if you say anything more, I will rip your eyeball out and shove it
up your ass". As several officers came in to the apartment and handcuffed the
father in front of his daughter. Detective Lauria made this comment loudly in
front of the daughter and being four years old caused her extreme distress
persecuting the father without providing legal notice and arbitrarily denying
the father with the opportunity to legally respond at any hearing prior to
arrest and never informing the plaintiff of his rights and never confiscating
the items allegedly "stolen", items that the warrant was based upon or even
noting their location or searching for them in the residence.
12. The father's daughter was taken from him and the father transported
between several state county and federal institutions for a period of one
month while being restrained in handcuffs and leg chains on transport flights
extraditing the father by force to Florida illegally in an acts of pure corruption
and false imprisonment.
13. The criminal attorney for the father, Dave Moye', in an effort to
establish merits with the State Attorneys Office, failed to take all steps that
could have been taken in representing the father intentionally taking
excessive time and extorting money from the father and his parents and
denying proper legal representation and due process and shortly after,
taking an employment position with the State of Florida Attorney Generals
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office who he was defending against thereby clearly establishing, obstruction
of justice, extortion, malpractice, fraud and conflict of interest.
14. Although the charges of grand theft were thrown out, Mr. Moye had
communications later with other perspective attorneys for the father, coercing
them not to pursue the case any further and interfering with other potential
legitimate legal options in so further obstructing justice. The plaintiff was also
forced to pay monies for items never shown to be in the moving truck and
forced to pay court costs and the department of corrections in acts of pure
extortion even though all charges were nolle processed. (exhibit#8)
15. The family law attorney Mr. McNeely was also in contact with Mr. Moye
and also failed to provide adequate legal representation and also attempted to
charge the plaintiff for services not provided and never submitted a guidelines
sheet for child support at the request of Mr. Moye and the State Attorney
Willie Meggs and his assistant Dana H. Plummer. The plaintiff was required
to pay support beyond that of and inconsistent with the guidelines also a
basis for continuing acts of extortion of the father and fraud upon the court.
16. In direct violation of the original, legal and binding Marital Settlement
Agreement, signed and witnessed April 18, 1997 and ratified in open court
by a judge with attorney present April 30, 1997, the court Aug 6, 1998 under
Judge Kevin Davey handed down a new order, illegally throwing out the
entire prior agreement, forcing the father to pay child support and give up
sole custody of his daughter further establishing the intent to kidnap and
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imprison the daughter in Leon County and continue to use the governmental
positions in extortionist acts against the father. This demonstrates no matter
what the facts were, the father would never be provided a full and fair
opportunity to litigate there, any hearings after the kidnapping and abduction
were a fraud and a mockery simply to establish a conspired and preconceived
means to an end and deny civil, constitutional, and human rights. Although
there were minor concessions in a couple hearings they were intertwined
and overshadowed by adversity. (exhibit#9) Judge Davies stated, “There was nothing
you could have done that would have changed what we were going to do to you or
your daughter, so don’t fight it”. He said, “As long as Hillary is in office you will
never get her back”, referring to Hillary Clinton of course. It was a clear implication,
and plaintiff did find that the Clintons were very close with Lawton Chiles who was
the Democrat Governor at that time and Tallahassee does have a massive feminist
base and the grandmother is a radical feminist lesbian. That comment establishes
some calls were likely made and illegal favors done to support such a statement.
There must be a very strong connection if they are so arrogant that they would also
risk tampering with the 2000 presidential election, which is precisely what the State
Attorney Willie Meggs said he did, as you will soon read.
17. The family law attorney, Mr. McNeely, then sued the father for an
outrageous 30,000.00 more than the approx.10,000.00 already paid even though
he filed not a single appeal, or submitted any guidelines affidavits to the court.
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Then, he and attempted to have it brought before the same Judge Lewis that
was responsible for the original fraudulent Grand Theft Warrant the year before,
June 17, 1997. The suit was dropped due to father filing bankruptcy. (exhibit #10)
In addition, the Florida bar tried to cover up the extortion but then persecuted,
in retaliation in another case, an innocent attorney the same year for overcharging
clients for protecting a client from being extorted by the same people. Judge Davies
also told McNeely that he could illegally manipulate the case in the future, if he
did not collect what he wanted. It was all part of the scam to feed the attorneys
supporting corruption while persecuting good attorneys who attempt to protect their
clients from it by actually attempting to enforce the law and client rights. McNeely
allowed the ex wife to tell the court how much she wanted for child support,
regardless of the guidelines, and they, not surprisingly, gave it to her illegally.
In reality, Mr. McNeely never worked for the plaintiff, it was just a pretext for fraud
and extortion to accomplish an illegal preconceived means to an end.
18. There was, by the father, a motion for modification of child support
filed June 14, 1999 due to the excessive amount that restricted visitation. The
hearing was set for October 4, 1999 at 2:00 the department of revenue then
intervened and it was cancelled and reset for February 23, 2000, eight months
after the motion was filed. The recommended order was not provided until
April 26, 2000 more than two months later and did not represent what was
stated or ruled upon in the hearing.
19. The prior order, and at the hearing for modification filed by the
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father, there was never an income deduction order, arrearage amount, or
payments due during summer when the daughter was with her father. These
were conspired to by the Department of Revenue in violation of judicial and rules
of procedure to extort additional monies from the father in violation of guidelines
and intended to illegally and additionally restrict visitation and entrap the
father financially; again without due process of law in further acts of extortion
and fraud upon the court. They knew it would be impossible for plaintiff to care for
his child properly when he had no money because he was paying support while
having her for summer. It became so that plaintiff could not take his daughter
anywhere to have fun or even pay for day care. Every penny would be spent to pick
her up and bring her back. There was barely enough to buy food, it was illegal and
barbaric. The intent was to make her wonderful summers with her father become
a test for survival just to see each other. Judge Dawn Coloca-Johnson is a sick
filthy minded wicked woman who needs to go to jail and that is what a Grand
Jury can accomplish. The process has already begun, and any Judges or persons
who want to continue with similar illegal behavior as is in this complaint, can
easily be pulled into the indictment. There is plenty of time to monitor how
everything transpires so everyone can watch and everything can be seen.
20. When the father requested a copy of the tape of that hearing to review
and proceed with corrective action the father found that the tape had been
checked out by the hearing officer Dawn Coloca-Johnson and erased by
her in another blatant criminal act of obstruction of justice and fraud upon
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the court by the hearing officer and the Florida Department of Revenue to
circumvent the judicial system, in so committing yet another extortionist act
denying the father his due process rights and civil rights and further falsely
imprisoning the father in debt and with evil intent to further restrict contact
with his daughter when as a matter of law and fact, the father still had sole
custody because the later meritless arbitrary decision brought about through
a conspiracy to commit criminal and illegal acts is void, unenforceable and
holds no precedence as a matter of law. A decision cannot be held to be legal
if supported by illegal acts in violation of federal state and local laws and the
Constitution of the United States and is considered void.
21. The following month, and for the next two years, for harassment, there
were continued malicious hearings, every month , for contempt for non payment
of support even though the full amount (although extorted) was being paid
every month, these were being conducted by the Department of Revenue
in violation of procedure and without cause. May 24, 2000 a letter unjustly
was sent to the father notifying him that his license was being suspended.
Payments made were not removed from total due, income tax intercepts
were not posted, letters were sent to the father every month, and a
collection company (GC Services) was then sent after the father for amounts
already paid. Thousands were being extorted without verification or
recognition and letters sent as recently as January 23, 2006 (exhibit #11)
and more illegally in 2012 from the Florida Department of Revenue.
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22. The plaintiff's daughter was regularly and grossly neglected, frequently ill,
physically and mentally abused including a gash over the eye and numerous
bruises inflicted by the mother (witnessed by the grandmother), taken to
adult parties till very late hours on school nights causing black circles under
her eyes and ear infections that caused a split in the back of her ear down to
the cartilage also witnessed several times. The former wife repeatedly refused
to medicate the child or take her to the doctor and her clothes were frequently
filthy and the only new ones she would get would be from her father, her
teeth were not brushed and there would be so much plaque on them the
spaces would be filled flat and the father would have to chip it off in chunks
with dental tools. A video of the torn skin behind laurens ear from the mothers
neglect and abuse was provided to the court and ignored by judge Davies.
23. The grandmother, Ellen Hamilton is a neo witch (wiccan), lesbian,
and a psychologist a very dangerous combination for a young child, much
less a young girl to be around. She has the child help her out in her
"witches worm farm". The grandmother would send self made cards with
pictures of witches drawn by the grandmother to the child during the
summer when she was with her father to scare the child into doing what
they told her to do and stated that their "god" was "better than Jesus" because
they "took all the money" and the father lost everything. Her intent is to
make the child a lesbian and witch also. (exhibit #12 witch drawing)
24. The grandmother (Ellen Hamilton) has utilized brainwashing
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techniques to alienate the child from her father by stating repeatedly
"Lauren doesn't talk to daddy" and "daddy is bad" over and over to his
daughter and other methods to mentally and physically abuse the child
and has stated that the father "loves Jesus too much" as the reason. In
the interest of humanity as a whole, whatever licenses to practice Ellen
Hamilton holds should be immediately revoked.
25. December 28, 2000 the father was informed by his daughter, during
a visit, that the former wife and her sister (Amy Olk) had tried to take naked
pictures of his 7 year old daughter. The Father called the police and filed a
report that same night. The evidence was overwhelming and items were found
supporting the facts, including nude pictures of other people displayed to the
child to coerce her that it was okay and desensitize. One specific picture known
to have been shown to the child was a picture of Amy's friend "Michelle" naked
lying on her back with her legs spread displaying her virgina. Lauren stated it was
"gross", and that Amy wanted her to look at it and take one of the child while the
mother said, "it's okay". Father had no choice but to take action and met with State
Attorney Willie Meggs and inspectors Gandy and Goodwin February 16, 2001,
some of the same people responsible for the kidnapping and abduction, which
forced the child to be thrust into that sick, insane, situation with people who
didn't want her, except to coerce and pervert. Tallahassee Police Department
and Leon County Sheriff's Department conspired to cover up what had occurred
and cause further child endangerment, they being an accessory after the
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fact by refusing to take appropriate action. The Department of Children and
Families also conspired to cover up what had occurred by intentionally filing
fraudulent reports and endangering the child even more. At the hearing with
the Florida State Attorney, Willie Meggs, he stated he wasn't going to do
anything and he was "the only game in town "and "we do things differently
down here". Apparently, The Florida State Attorney Willie Meggs
considers his jurisdiction divisible from the rest of the country without
liberty and justice for all especially people from another state and or children.
(See exhibit #13 1.30 letter from Meggs/Goodwin, off rep. conflicting forms)
26. Although at the meeting the State Attorney, Chief Investigator and
Assistant State Attorney refused to properly uphold the law, they actually
apologized for doing what they did to the father (false imprisonment, abduction
kidnapping) in 97 and stated that if "we knew what you were like we wouldn't
have done it". "You want us to do for you what we did for her". But, the father
noted the difference is the father did nothing wrong or illegal. The statement
was also made "good for her if she can get away with doing something illegal".
Mr. Meggs, Mr. Gandy, and Mr. Goodwin display the kind of tyranny this
country was founded to be free from and is likely the reason why they were
all wearing guns at that meeting. Their statements alone are enough to
constitute relief from judgment and recovery of damages. (exhibit #14 letters
William M. Meggs State Attorney, Warren Goodwin the assistant State
Attorney, Al Gandy chief investigator) They also bragged about being responsible
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for the 2000 election ballot fraud and stated, "We did that".
27. The father, when arriving to visit his daughter in April 14, 2001, was
then physically attacked by the former wife and filed charges. Again,
Tallahassee police did not arrest, even with an admission of the attack from
the former wife. The report was again forwarded to the state attorney's office
because probable cause was established. Again, the State Attorney declined
to prosecute regardless of the fact these real charges were not like their
fraudulent charges in the past. The assault was an attempt at entrapment
initiated by the State Attorney and would not be the last because as
he stated they do things "differently" (illegally would be more accurate)
down there and the former wife stated she communicated with him
"personally" as recently as August 2007. There was also a group of people
waiting nearby, 4 or 5 in one car watching the incident. The plan was for
the plaintiff/father not to leave the scene and call the police from there,
where upon arrival the people in the car would say the father did the assault
and he would again be falsely arrested and imprisoned. Notice the issue
in the report that the father/plaintiff left to go file the report. (exhibit #15)
However, on the next trip they would try again at entrapment with another
beating, assault and battery on the plaintiff/father and his daughter, set up
by Willie Meggs, Leon County Sheriff Larry Campbell, former wife and
others in continuing acts of illegal agendas and in retaliation for contacting
other authorities about the child abuse and other incidents. Willie Meggs and
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Larry Campbell gave the ex wife permission and immunity from prosecution and
allowed her and others to attack the father in retaliation, repeatedly, initiating
an intentional small scale civil war. This is simply relaliation for being a good father.
28. October 18, 2001 the father again went to visit his daughter after
driving over 1000 miles was again denied visitation and this time again was
attacked in another and entrapment scheme. The school employees were instructed
by the defendants to invoke a physical confrontation with the father where he
and his daughter were actually physically attacked by employees Tonya Smith and
Mona Vonk and denied checking the child out of school for no reason. The
father had picked her up from that school several times prior to that visit
without any problems. Tanya Smith actually grabbed the father while just standing
there and outragously attempted to subdue him, absolutely insane. The father just
simply pulled away in shock and asked what they thought they were doing.
29. The Leon County Sheriffs Deputy by named John Meeks arrived and
attempted to persuade the employees that the father hit them back and he could
take the father to jail if they would "just say he did ". The deputy fabricated a no
trespassing warrant, contrary to the principal Johnson's wishes, and forced
the father by threat to let his daughter go when he had physical and legal
custody, again abducting her, defaming the father, traumatizing the child,
causing severe emotional distress to father and daughter and forcing the
father to "leave town" after threatening several times to put the father in jail
and refusing as before to press charges against those who committed illegal
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acts. Judge Kathleen Dekker also contributed to the abduction on October
18th 2001, similar to the 1997 incident of kidnapping and abduction also
involving Leon County Sheriff's Department by refusing to enforce any
visitation for the child on an emergency motion. (exhibit#16 Dekker refusing
to allow father to see daughter after 18 hour drive stating "this matter is over")
Well, apparently this matter is not over because she is now a defendant in being
an accessory to another illegal abduction and obstruction of justice.
30. Father sent a letter to Leon County Sheriff Larry Campbell, October
25, 2001, about the incident. The father also spoke with officer Meeks October
25, 2001 then later, October 25, 2001 spoke with Major Keith Daws who
stated," I don't care what happened" showing his malicious intent to obstruct
justice and proceeded to, under color of law, threaten the father further with
baseless arrest & harassment charges. (exhibit #17,10.25 e-letter to Campbell)
31. The father again wrote Sheriff Larry Campbell November 21,2001,
who then stated that instructions were given by him (exhibit#18 e-mail11.21
response from Sheriff Campbell to plaintiff). He then proceeded to continue
to harass the father with threats of charges and arrest, just as the other Leon
County officers who abducted the fathers daughter did just 4 weeks before,
clearly establishing a deeply rooted chain of command for the numerous
premeditated acts of fraud, abduction, harassment, intentional infliction of
emotional distress, entrapment, and assault and battery on father and child
and more on a continuing basis.
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32. Letters were sent to Governor Bush January 15, 2002 in regards to
the corrupt acts and cover ups. The same day the father also sent another
letter to Sheriff Campbell, again, in regards to another incident this time by
Leon County Officer Allie and the Tallahassee Police Department refusing
to enforce a court order to enforce visitation and denying the father the right
to see his daughter for Christmas even though written notice was provided
weeks ahead of time, December 8, 2001 to Judge Dekker, clerk of court,
and former wife. (exhibit #19 letter to Gov. Jeb Bush, Sheriff Campbell)
33. The father filed complaints with the Florida bar in regards to hearing
officer Johnson November 4, 2001 in regards to their intentional acts,
February 1, 2002 the hearing officer recused herself, notice the department
of revenue (Pricilla Quionnes) is continuing their involvement and are listed
as petitioners with the former wife. (exhibit #20 Fl bar complaint, Johnson
recusal)
34. On February 7, 2002 the father received a letter from the Florida
Department of Law Enforcement Commissioner, James Moore, in reference
to the child abuse case being forwarded to Chief Inspector General for
Department of Children and Families. The FDLE request was originally sent
from the Executive Office of the Governor. The Inspector General for
Department of Children and Families the refused to address the issues and
sent a letter further denying to follow through with a proper investigation on
February 26, 2002 with attachments. The father sent a responsive letter
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March 15, 2002 detailing the inadequacy of review. March 25, 2002 Mr.
Betta sent back another frivolous response. Father responded with yet more
specific detail April 7, 2002 expressing his dissatisfaction with the
carelessness which Mr. Betta was displaying in regards to the case. Mr. Betta
again sent a denial to properly investigate on April 18,2002. (exhibits for
#21 correspondence, FDLE, Betta and plaintiff)
35. The plaintiff later found that the former wife's boyfriend, Will, worked
at the Department of Children and Family and assisted in blocking any
investigations. This perverted boyfriend, Will, would also frequently walk in on
Lauren when she was taking a shower and stare at her; terrorizing the child.
36. On March 8, 2002 the father also filed a complaint against Judge
Dekker with the judicial qualifications commission due to the outrageous
actions and denial of the father's visitation rights. (exhibit #22)
37. On March 26, 2002 the father was found, by hearing officer Williams,
to be in compliance with the support order , the same order which had been
on continuance for repeated hearings by Judge Dekker and Hearing officer
Johnson purely for harassment purposes nearly every month for the two
years prior the same one in which Paul Shapiro esq. neglected his duty to
represent . April 29, 2002 hearing officer had to restate to Office of Attorney
General that the father was in compliance when Attorney General again
attempted to continue hearings purely for harassment, and the arrearage
is to extort payments already made and not posted which continues to
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to this day by D.O.R.( exhibit #23 letters 3.26, 4.29 on compliance)
38. When denied hearings, the Department of Revenue rather than
filing a new motion (because there would be no basis), illegally proceeded to
send more threatening letters August 28,2002 even after they had been
specifically instructed the father was in compliance, instead they fabricated
additional amounts to extort from the father without evidence. Even with the
father in full compliance the Department of Revenue was in contact with
Detroit Diesel Corporation, where the father was employed at the time, and
used those contacts to further their objectives. Additionally the Attorney
General utilized all female assistant attorneys Joy Aukema, Dana Plummer,
Pricilla Quionnes, Denise Johnson, intentionally as a form of sexual
harassment and discrimination.
39. This was an opportunity for the plaintiff's supervisor Bob Green,
also involved in illegal acts, to use the Florida circumstances as an excuse
to support his own mob mentality acts of terrorism. Out of the blue the
comment was even made by Ed Crawford (a director) "so we hear you're
having problems with your ex-wife". The federal government provided Bob
Green with access to agents and stated to Mr. Green he could do anything
he wanted to do the plaintiff, short of hitting the plaintiff. Mr. Green stated
he was considered an "officer" and used homeland security to label the
plaintiff a "terrorist" and using agents to further their corrupt, illegal plans.
40. To verify the fact that Mr. Green had access to agents, the plaintiff
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informed Mr. Green that he runs at a track but did not say which one and
that the plaintiff was pretty fast for his age. The next day a young man shows
up at the Stevenson track, after the plaintiff had done several laps, he stops
ahead of the plaintiff on the track and when the plaintiff gets just behind
him sprints in front of the plaintiff in an all out run racing the plaintiff. The
plaintiff stays on his left shoulder just behind him making sure not to pass.
The young man then immediately leaves after the 1/4 track run. This was
prior to the plaintiff's nerve problems. This never happened before.
41. The very next day when the plaintiff arrived at work Mr. Green
stated, first thing in the morning, "your not so fast". plaintiff explained
he was holding back to that person on the track and that next time the
plaintiff would give him 1/2 track head start and would pass him within
precisely 4 laps. Two days later the plaintiff is at a different track (the
Holmes track) several miles away and the same young man shows up;
plaintiff gives him 1/2 track and begins to run. He runs all out for
precisely 4 laps then stops exhausted with the plaintiff still behind, but
only less than a quarter of the track. The obscurity of the rules, different
track location, same suspect, and precise time, establish correlation
and causation with intimate communication on specifics and tracking
of plaintiff's location to offensively invade the plaintiff's privacy by
Homeland Security and others at a time reserved for private freedoms
and liberties.
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42. Later when the plaintiff had an injury and nervous system disorders
and was home on vacation time for rest. Mr. Green and DDC hired a private
investigator to harass the plaintiff and park his van in front of the plaintiff's
house for 3 days to prevent any rest and recovery the plaintiff may be
provided on his vacation time. (exhibit#24 investigator van staking out
plaintiffs house hired by DDC verified by FBI and Southfield police).
43. The Detroit Diesel legal department had contact with Florida
authorities and having knowledge of the family law case back ground felt
that they could get away with doing most anything employment related.
Knowing the federal government was involved in imprisoning the father
for no reason, there was no limit to what they felt they could get away
with. They used these contacts along with the FBI and Homeland security
to conspire and continue their efforts with the Florida authorities to
corruptly use law enforcement, judicial system, and federal agencies in
furtherance and continuance of illegal acts against the plaintiff. Detroit
Diesel counsel, Josh Yaker, even threatened the plaintiff that he would
not get Bob Green to "back off" and that it would be "difficult to get your
work done" in retaliation after the plaintiff filed suit. (exhibit # 25
unrefuted timeline and evidence first DDC case in support of plaintiff's
2.116 ( C ) (10) motion, won as a matter of law by plaintiff). The Job at
Detroit Diesel was expected by Judge Davies and he stated that plaintiff
would get a job there and do okay but the ex wife would get the child after
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the kidnapping. So clearly there is a relationship between certain
corporations (especially with government contracts) and the Government
to provide employment in certain circumstances. Judge Davies even told
plaintiff what employment agency to go through to get it.
44. In October of 2000 Daimler Chrysler purchased Detroit Diesel,
during the transition period the plaintiff played a very pivotal role
in the integration of the financial systems between the two companies
and developed a program with EDS "EO task entry system" which saved
the company millions of dollars, the plaintiff gave presentations in the
auditorium in front of the company to introduce the new program with
the logic he developed and program he supervised and developed with
with the assistance of EDS software engineers.
45. As an administrative tool and complement to the program, the
plaintiff created and programmed and developed himself the "automated
upload system" which provided data uploads for the program monthly and
allowed quick and seamless mass data transfer from specialized spreadsheets
and allowed for quick resolution and correction of errors.
46. For the integration the plaintiff was responsible for creating the
massive spreadsheet that linked the like accounting functions with foreign
functions to allow interactions and data loads into systems to maintain
financial reporting across national accounting barriers to feed the operations
of the financial reporting and controlling groups.
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47. The plaintiff's systems were extremely successful and implemented
corporate wide and the plaintiffs supervisor Mr. Green was transferred to
another department because of his failure to properly implement a system
that he purchased earlier to do the same thing which failed miserably and
as a result cost the company millions of dollars.
48. Before the acquisition of DDC by DCX, DDC was plagued by poor
management. Regardless of the need to help the company's to function,
many in management and lower level positions, rather than supporting
the integration, were moving to sabotage most anything they were given
to hamper the company success as a whole and the Germans. This seemed
irrational to some because the ultimate outcome would be negative for
everyone. Some would call those who did a decent job "traitors" and began
causing problems with their work. The plaintiff was the focus of some of
this, but at the time didn't see a reason.
49. Naturally, the ones who didn't care about their work chose to begin
to sabotage the work of others including the plaintiff's. The plaintiff wasn't
aware of any actual "war "and the term war was never elaborated upon until
years later. Initially, it appeared at most like a takeover "war" complicated
by foolishness and careless attitudes on the DDC side.
50. As the plaintiff's work (spreadsheets, data loads) were being
continually tampered with the plaintiff had one of several meetings with
one of the directors, Edward Crawford. At this meeting in 2000 Crawford
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stated that "this is a war" but still did not specify what it meant. plaintiff
told him that they own the company and we have to do the work.
Crawford later stated to the plaintiff that "everyone will be against you",
this turned out to be a much broader statement than originally taken
and it sounded crazy to the plaintiff none the less. Mr. Crawford was
also known for being one of the primary factors in the huge turnover
the company had even prior to the takeover. Up to this point, the
plaintiff had not seen any reason to suspect the Daimler people of
anything other than making the company productive once again.
51. The plaintiff ,while working out in the attached gym, spoke with
one of the young managers whose father also had worked for Detroit Diesel.
While working out he informed the plaintiff that being a manager or
a director for that matter in Detroit Diesel was not an impressive feat
there were many who were incompetent and that was the reason for most
of the problems in the first place and now again. He found that many were
promoted just because they stayed there a long enough time. He was
known for being a good manager. He, shortly thereafter, left to go to
another company to the surprise of many (not the plaintiff). There was
another manager who was held back, because he was brilliant, he was
there nearly 12 years and was not even a director. He later got an
engineering award of the year, left the company and went right into
being a Vice President of engineering at Ford and then to even more
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later at GM. Detroit Diesel is known for poor decision making.
52. Later, when there was poor management and widespread discontent
due to the behavior of the Daimler people, the plaintiff became concerned
and voiced his concerns and was told that there is a saying in German
that goes something to the effect "either your with us or we will take your
head off". The plaintiff considered leaving but that was not an option,
DDC was denying a positive reference and blacklisting the plaintiff and
getting vested for the pension disbursement was not that far off. As
mentioned Homeland Security and others were doing their own illegal
acts to interfere with and eliminate any and all options, just as is the
case at the present time, it would have to be addressed in court.
53. After the plaintiff expressed his concern over the circumstances
the Daimler people put Mr. Green back in position over the plaintiff. This
is when Mr. Green took advantage of the situation to seek vengeance against
the plaintiff for the implementation of his successful program and prior
dismissal and transfer of Mr. Green due to his incompetence.
54. There was also a man by the name of Gary Paja who it
was stated was having "problems" with the Germans. The plaintiff was told
by John Eriksen that "they found out he was Jewish" Mr. Paja then began
to have the plaintiff's supervisor force his work onto the plaintiff, just after
the Germans stated to the "war" was going to be against the plaintiff.
They then had dozens of Jewish people come into the department, after
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that comment, wearing their signature apparel and Gary Paja's wife Pat,
who also worked at Detroit Diesel, who the plaintiff saw infrequently
began to show up every day while the plaintiff was walking down the
hall and she would lock an angry stare directly at the plaintiff several
seconds every time passing by. Clearly religious harassment.
55. From the time the plaintiff filed his original DDC lawsuit and was
frequenting the law library in Pontiac, MI there was a Jewish man wearing
a yamaca who would show up nearly every day after the plaintiff would
arrive and make sure to walk in front of the plaintiff regardless of the
time of plaintiff's arrival, when the plaintiff began attending another law
library in Farmington MI 30 miles from the one in Pontiac but closer to
the plaintiff's house, that same man would show up, adding another
facet to the campaign of harassment by the defendants.
56. Mr. Green would speak to Gary Paja in the hall speaking quietly
and when the plaintiff would walk by they would both stare at the plaintiff
at the same time and cease talking. The plaintiff never had any issues
with Gary Paja personally and worked well with him on many occasions
demonstrating this was clearly agenda driven component of the "everyone
will be against you" comment by Ed Crawford, since the plaintiff used to
work at a Jewish Community Center and bias was not an issue. Mr. Green
also made the comment that "we're all fighting terrorists" to another
employee while turning to look at the plaintiff. The plaintiff considered these
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comments to be a sign of Mr. Greens mental illness and perversion.
57. The Daimler people had an agenda, and took issue with some people
and offended many others. The plaintiff had no knowledge of their intentions,
but after voicing concern over some of their actions, it was communicated by
Walter Puetz to DDC management, some of the actions they took was a favor
or suggested by the plaintiff and this was to take the load off them and make
good on their threats to make the war so it was against the plaintiff and
demonstrate their intent. They also knew about the Florida case and
interpreted taking adverse action and blaming the plaintiff would make them
seem as though they were with everyone else. The perceptive people knew
that the same thing was happening at Chrysler and the plaintiff didn't work
over there. There was no employment options then as there is none now
based on continuing acts of the defendants.
58. Mr. Green's focus now, supported by the Daimler people and others,
was vengeance with malicious purposeful intent to destroy the plaintiff's
health, financial situation, future job prospects, interfere with visits
the plaintiff had with his daughter, inaccurate unfair and continually
reduced evaluations (devoid of detail), physical and verbal threats, reduced
and ultimately eliminated pay raises with no basis, sexual harassment and
discrimination, a fraudulent performance improvement program (to
harass), and eventually a retaliatory discharge within 2 weeks of the
plaintiff filing his original law suit when the evaluation period was not over.
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59. During the period when Mr. Green was again in position over the
plaintiff, the plaintiff was also the focus of lewd, perverted and ever more
obscene behavior and touching by Mr. Green to sexually harass the plaintiff.
60. The defendant also had contact with Homeland Security, FBI,
Banks, retail establishments, neighbors, employment agencies. There were
additional comments about the plaintiff's marital status, having to "leave the
country to get a job", having to "kill your parents" or "rob a bank' to have
enough money to see daughter again, stating "nothing is going to be easy"
Daimler people stating the "war will be against you". There was also contact
by defendants with doctors who were treating the plaintiff and the comment
by Bob Babridge that he plaintiff would be "getting it from both sides". It
must be noted that Bob green is a very bizarre individual and extremely disturbed.
61. The plaintiff had a meeting with Dave Kotel of the FBI on November
6, 2006 about the situations and what happened at DDC and what was
occurring with others and the day after the meeting there were additional
people following the plaintiff and taking pictures of him in the evening with
a flash, other cars following the plaintiff, the plaintiff's cell phone was
accessed and family members were contacted. Mr. Kotel stated that he would
only use the phone numbers the plaintiff gave him if he could not get in contact
with the plaintiff and needed to get a hold of him for some reason. However,
Kotel used them to harass and call the plaintiffs parents.
62. The defendants utilized their connections in the FBI and Homeland
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Security to contact people in the neighborhood and interfere with business
relationships and contact doctors and others with knowledge of the plaintiff's
suseptability to mistreat, poison, or refuse treatment of the plaintiff to
bring about continued illness and death to the plaintiff. There were also
people directed by Homeland Security to interfere with the plaintiff's most
recent filing of a federal lawsuit against Mr. Green in which the plaintiff's
sworn documents were removed from the copy machine when he turned
his back and files erased from his flash drive by a lady wearing all black
who sat at the plaintiffs computer. Both occurred while at the Farmington
library on March 30, 2007. Both women left before their deeds were fully
recognized. The documents were actually mailed back, more than a month
later with no letter, of course the files deleted the same day were still gone.
(exhibit #26 envelope postmarked May 10, 2007 with stolen items)
63. Since 1997, the federal government is violating the plaintiff's rights
continually, Mr. Kotel even asked for phone numbers of friends or contacts
plaintiff may stay with if things "got worse" then called parents and slandered
the plaintiff in an attempt to prevent them from helping if the need arises.
Additionally, Mr. Kotel tells plaintiff to see a psychologist because what the
plaintiff thinks he is seeing is "not really happening", a jury trial will provide
a cure for that problem. The following day the plaintiff was followed and
had flash pictures taken of him, while running in the evening, by two young
men wearing black hooded sweaters, was followed by a red Durango, had
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a comment made by a store clerk that "it shouldn't be that hard to drive him
crazy". All initiated by the FBI and Homeland security and others to harm
the plaintiff. Mr. Kotel also requested the name of the federal judge
overseeing that case to contact the courthouse and further interfere with
the plaintiff's Constitutional rights.
64. The plaintiff filed freedom of information act requests in regards
to the Kotel incidents and earlier matters involving the federal government
and was denied any records pertaining to the case and the administrative
appeal was later not responded to in the allotted time frame as required
by law.
65. The FBI, Homeland Security, DDC, Florida State Attorney and
other defendants to this day are continually moving to violate the plaintiff's
civil rights and deny the plaintiff any mode of survival in making a living.
The only reason is blatant terrorist mentality and corruption in violation
of basic Constitutional and human rights and conspiring to overthrow the
United States government by utilizing hostile acts as a means to further
their illegal interests and agendas.
66. The plaintiff has filed a series of lawsuits, the first in Sept. 21, 2005
against DDC where the plaintiff was denied his due process rights although
he won as a matter of law, court of appeals affirmed in violation of rights,
leave to appeal to Michigan Supreme court was denied. plaintiff filed first
suit against Mr.Green in July 2006. plaintiff was again denied his due
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process and constitutional rights and appeal of right by lack of service of
final order and violations by defendants counsel. Third suit was again
against DDC filed in Lansing (capitol) and was forwarded to wrong district
(western) and was thrown out for lack of jurisdiction. Plaintiff filed his second
suit against his supervisor in federal court in eastern district of Michigan and
was again illegally denied his due process rights when judge and defendant's
attorney conspired to illegal sanctions and block a legitimate federal action
consistent with prior federal denial of rights with the Florida State Attorney
and other defendants, the supervisor outrage case was on appeal.
STATEMENT OF JURISDICTION
67. This complaint is jurisdictional as it contains complaints covered
under federal labor laws, statutes, denial of civil rights, diversity of citizenship
and rights guaranteed under the U.S. Constitution and issues of National
Security. Damages are in excess of 75,000.00, there is also federal jurisdiction
to review the sufficiency of state procedures for which the court may
mandamus the lower court for duties. The plaintiff was denied his right to
jury trial(s) and due process rights under the 7th and 14th amendments to
the Constitution respectively, harassed in violation of title VII of the Civil
Rights Act of 1964, and denied information in violation of the Freedom of
Information act.
VENUE
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68. Venue is proper in this action in that all times relevant to this action
the plaintiff worked in Michigan or Florida , and other circumstances related
to defendants herein transpired in the Continental United States.
Plaintiff is a resident of the state of Michigan
The suit is being filed in the United States District Court in
the District of Columbia due to intentional illegal obstruction in Michigan and
Florida by Federal Judge Cleland who was named in the suit and Florida
State Attorney Willie Meggs also named in the suit.
FIRST COUNTCONSPIRACY TO OVERTHROW THE U.S.
GOVERNMENT THROUGH VIOLENT MEANS
69. All paragraphs are realleged and reaffirmed as if set forth herein.
70. Many of the defendants involved in this complaint are employed by
state, federal and county agencies. There have been numerous illegal violent
acts to manipulate the operations of agencies against the citizens of the
United States and in violation of the principles and doctrines they were
founded under. These corporal acts of kidnapping, assault, false imprisonment
and violations of due process, obstruction of justice, extortion and others are
nothing less than acts of civil war on the plaintiff and citizens of the United
States and a conspiracy to overthrow the government by violent means and
restrict or eliminate the civil rights, freedom and liberties of it's citizens.
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71. After the kidnapping, abduction and other crimes the plaintiff was
forced to return items to the former wife's residence where a friend of the
family by the name of Dick Morrow was present and stated "they used to
call us Commie pinky fagots "this was to present the beliefs of some
committing the prior and continuing illegal acts . These statements
are consistent with the Florida State Attorney, Willie Meggs, comments that
"we do things differently down here" in regards to the fraudulent charges
and the mass of illegal and violent acts continuing to this day supported
by Homeland security, DDC (Detroit Diesel Corporation), FBI and others.
SECOND COUNT
DOMESTIC TERRORISM
72. All paragraphs are realleged and reaffirmed as if set forth herein.
73. The FBI and Homeland Security initiated contact with friends and
family under false pretences, and in a continuation used a meeting with FBI
investigator Dave Kotel to further the campaign of harassment on plaintiff and
have additional contact with neighbors, friends, and parents. There was contact
with automotive facilities which the plaintiff was doing business with and on
several occasions instructed those facilities to intentionally damage to the
plaintiff's items or to do poor workmanship which would cause the plaintiff to
repeatedly return to have the work done properly, in so destroying productivity
parts, and or vehicles in the process and causing extreme and repeated
emotional distress intending to cause illness to the plaintiff. The following
is a list if companies who through their representatives displayed like behavior
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intentionally and repeatedly ruining materials and or items belonging to the
plaintiff or his company or other adverse actions. Bob Green at DDC would
ask the plaintiff where work was being done and then the service provider
would be contacted shortly thereafter in regards to the plaintiff and what
steps to take by Homeland Security or other federal agents utilizing color
of law to impose their will in with and create public corruption in violation
of law. Reference Wikipedia: FBI Cointelpro program
Activities:
Gales Body shop: ruined paint job, repaint contaminatedwith dirt particles, car outside without paint large areas bare with no paint,told how to rub out the dirt which wasin paint when done second time Mr.Green comment ruining paintexcessive time to do work
request plaintiff to bring back again
and again after damage
D&S engine specialists: Ruine gas tank, strange "not afraid of you" statement never properly rebuild engine after paid for full rebuild, ruined engine, harass, engine knock, admit ruining alternator, intentionally hide other problems, wrong push rods(exhibit#27 letters) Mr. Green Comment
excessive time to do work
request plaintiff to bring back again
and again after damage
Chuck's engines: German receipt in bag, return several times repeated improper machining, sign of "united we stand" posted on front of building only after improper work doneexcessive time to do work
request plaintiff to bring back again
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and again after damage
Murray's Discount auto store: Ruine brake rotor, admitting thenrefusing to give after ordered, cops in parking lot follow around, harass, provoke discontent, calls someone before finally giving items, tries to get plaintiff take parts and run (exhibit#28 pictures parts on table, manager call before giving parts,livonia cops following in parking lot)excessive time to do work
offer to come back again after damage
Livernois Motorsports: increase price then destroy cylinder head surface then try to make pay for new cylinder heads, misleading BBB, failure to do procedures, harass, BBBrecommended not to do business with them (exhibit #29 BBB correspondence)excessive time to do work
request plaintiff to bring back again
and again after damage
Olson Kawasaki: keep motorcycle and never repairthen damage to gas tank, ruined paintjob failure to do any repair correctlyexcessive time to do work
request plaintiff to bring back again
and again after damage
E-bay e-mails, blocking corvette salesblocking e-mails, harassmentnot posting all pictures changingprimary picture, DCX unrelated emails (dozens) immediately after auction, interfere with sale not forwarding offers to buyers (exhibit# 30 DODGE (DDC) e-mails all at once after auction close)
Midwest auto auction damage corvette, force hood out of alignment, chunk of paint out of drivers door of new paint job, credits to come in
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again admit damage, offer pay to repair then deny, offer to bring back in againafter damage (exhibit#31 corvette door damage, vouchers to come back )
Budget Rent-A-Car steal items from car, lease badlydamaged truck to plaintiff andattempt to charge plaintiff for priordamage, Mr. Green comment about
budget will stick it to you before acts(exhibit#32 attempts to charge)
*Fact finding will assist in determining correlation or causationalleging a connection due to repeated far out of ordinary actsand statements supporting Textbook use of the illegal Cointelproprogram by the FBI's Toni Charbot and Dave Kotel as wellas Homeland Security (another name for Cointelpro). Contact was admitted by the FBI and parents, plain and simple.
ENCYCLOPEDIA COINTELPRO DEFINITION
Cointelpro or (Counter intelligence Program) is a series of covertand often illegal projects conducted by the FBI. They targeted studentdemonstrators, Islam, antiwar community, Christian leadershipconference, (PETA) People for the ethical treatment of animals (whooppose the kosher slaughter of cows) and they put people fromGreenpeace on a terrorist watch list. The inspector General found2001-2006 “troubling” FBI practices consistent with the ChurchSenate Committee. The FBI would discredit, disrupt, undermine trust,plant false media stories, make anonymous phone calls, spreadmisinformation,create pseudo movement groups, manipulate or strong
arm parents, employers, landlords, school officials and others to causetrouble. The FBI conspires with police and abuses the legal system toharass, make people appear to be criminals, police officers would giveperjured testimony, fabricate evidence to use as a pretext for falsearrests, wrongful imprisonment, and use conspicuous surveillance tointimidate. They use local police departments to threaten, conductillegal break-ins, commit vandalism, assaults, beatings, andassassinations. Their declared purpose for illegal acts was ”nationalsecurity” even from 1956-1976. They use unsavory and vicious tacticsto break up marriages, disrupt meetings, and ostracize persons fromtheir profession. Sound familiar? The committee concluded that“Government officials, including those whose principal duty is toenforce the law, have violated or ignored the law over long periods of
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time and have advocated and defended their right to break the law”.They investigated people for “factually weak” reasons and withoutadequate basis”. They use secret informants and other intrusivetechniques and a myriad of other “dirty tricks” to undermine people
with no just cause. Wikipedia encyclopedia FBI search Cointelpro
74. Certain behaviors are consistent with most situations cordial
beginning followed by promises not kept, followed by overcharging and or
damage, promises to correct problem and to keep calling back, followed
complete denial to do anything or job never done correctly and taking
excessive time or requirement to keep coming back only to do more
and more damage or take even more time. The "united we stand" sign posted
in front of Chuck's, only after damage, takes on a dubious theme in this context.
Although things like this may happen on an infrequent basis from time to
time, there was and extreme increase in repeated acts far out of the norm.
75. Additionally there were contacts with employment agencies to
prevent the plaintiff from ever gaining meaningful employment after
leaving DDC. The temp agency acts support the all inclusive intent on the
part of the defendants. Remember, Judge Davies oddly told the Plaintiff what
agencies to use in the first place, so there is an admitted connection here.
Dixon Allen: Do things to "forge relationship"with DDC. DDC calls plaintiff "high roller" after meeting
Accountants Connection: Call plaintiff at work ask how things are going, send items to plaintiffout of the blue admits DDC contact
76. City services and utilities and their employees also were used as a
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tool to harass the plaintiff and intentionally damage or deface private
property, trespass, extort money, and or not provide service. Notice
City of Southfield admission of being instructed by the "Feds" for
acts purely consistent with Cointelpro without question.
Water and Sewer Department: Extort money from plaintiff by applyingto taxes the small amount due and large100.00 service fee amount after call to resolve (exhibit#33 intent to lien)
Waste Management: Dumping trash on lawn day of Stephens hearing, later refusing to pick up likeothers on the same street (exhibit#34trash on lawn and neighbors cans placed in front to obstruct driveway)
City of Southfield: Trespassing on property and cutting offlarge tree limb causing no interference with any city interest, no prior notice, giving chips to neighbor to humiliate while tearing up lawn. No trespassing sign in clear view this was after comment a few days before that plaintiff likes to maintain his lawn. (exhibit #35 tree cut, torn up lawn, give chips from tree to neighbor) flags only pretext to do damage. Employee stated: "If the feds say so you have to do it"
Detroit Edison: Accelerate payments on utilities whenno plan was requested, intentional non posting, service worker stated she had never seen that before, plaintiff had 3rd party intervene twice.(exhibit#36 billsand shutoff notice after full payment)
Sprint: Tampering with cell phone information
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gathering private information through phone access illegally day after FBI Kotelmeeting invading privacy and harassing
U.S. postal service Tampering with mail box, moving mail box without any notification, failure to deliverrepeatedly and continually to harass.
77. Although the Germans at Detroit diesel did do many things,
the defendants utilized props (see Cointelpro) and circumstances to make it
seem as though the German's were doing what was done by Homeland Security
and FBI.
Raced up to while on foot or day after FBI meeting with tailgated by German cars: Kotel complaint, BMW drive
up dangerously fast right in front of plaintiff while walking across street
German receipts in plastic bag: Chuck's Engines
4 Black German cars together cars together in bizarre semi circle in road aimed towards house same time: in violation of parking laws
78. Additionally, one of the main focuses is to make the plaintiff appear
as if he is in conflict with women in general, purely due to the opportunity
to focus on the perspectives, views or situations the plaintiff had with his
ex-wife and magnify any divisions to constitute and all inclusive, untrue and
defamatory position. This objective was made clear when Director Ed
Crawford stated that "everybody will be against you" after declaring "So we
hear you're having problems with your ex-wife " The fact that an intent
like that would even enter the mind of an anti- American fraud like Ed
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Crawford is in violation of the constitution and laws of this country and is a
criminal act. This tyrannical, terrorist, agenda is a menace to all who value
their freedom in this country and violates and threatens our unity under
freedom and liberty with justice for all citizens, without discrimination. Even
more obscure is the comment from Larry Butler at DDC stating that they
know that the ex-wife doesn't want plaintiff to see his daughter anymore. He
said, "We know your ex- wife doesn’t want you to see Lauren anymore".
Again, consistent with Cointelpro breaking up families and contacting employers.
79. This presents an issue of the defendants to defame the plaintiff
before all people with the assistance of Homeland Security, FBI and State
and local authorities in Florida and Michigan. There is simply no basis
for any of their positions and it constitutes evidence of criminal acts and
political imprisonment. Since what the defendants are doing is not supported
by any statute, law, or regulation, it is patently illegal and unconstitutional.
80. After the comments at Detroit Diesel about the ex-wife there was a
concerted effort to have women, specifically, harass and create problems for
the plaintiff by Detroit Diesel and have female agents for Homeland Security
do some of the initial personal contacts and continuing communications with
other women the plaintiff may be in contact with on a business or personal
basis outside the company and continues to this very day. This effort is
also to ruin, prevent, or interfere any relationship the plaintiff will attempt
to develop in the future whether personal or professional. There were never
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any problems to this particular issue until after those specific comments,
it must be noted there is no guess work needed, Detroit Diesel and the FBI
made specific statements and dire predictions regarding these events and the
relationship of their contacts and the connections to marital or family status
to establish the correlation and causation. Additionally, FBI investigator Dave Kotel
stated to the plaintiff that they have FBI agents and contacts at Detroit Diesel.
81. Certain financial institutions provided confidential information to
the defendants in relation to private bank transactions in violation of federal
privacy laws:
Comerica Bank: Provided detailed informationabout specific transactions andlocations, dates, times.
Chase/Bank One: Provided detailed informationabout specific transactions andlocations, dates, times.
82. Except as for being a Christian, doing his job, or having a divorce
there has been no specific mention as to why these actions are, other than
a purely political and corrupt agenda originally simply to show that Florida
has power over and beyond the law. The former mother in law has made the
statement the father "loves Jesus too much", her group stated they were
"Communist", and the State Attorney's office and Willie Meggs stated he
was the "only game in town" and "good for her if she can get away with
breaking the law" and "we do things differently down here". Clearly the FBI
has issued discriminatory tactics against Christians, as Cointelpro targeted the
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Christian leadership conference and the plaintiff is a Pastor. Apparently, they
also use corrupt and disruptive individuals to undermine the Christian church
by inserting false leaders and corrupt immoral Pastors to distract and manipulate
people. Larry Butler would be one of them, by giving false testamony under oath
and seeking to corrupt Christianity, the plaintiff's daughter, and other young
girls. As the book "The End of America", by my fellow author Naomi Wolf explains,
it is American Patriots like us who are being arbitrarily targeted in this country,
not criminals, because the system is so deprave.
83. That kind of corrupt influence is used to coerce others in separate
jurisdictions and is precisely why the instant case is absolutely necessary
and imparitive and in the advent of 9.11, Homeland Security has added
another greater tool for public corruption ripe for the picking for those with
ulterior motives and terrorist agendas. These and other actions constitute
a serial abuse of government resources to commit illegal acts.
THIRD COUNT
FRAUD UPON THE COURT
84. All paragraphs are realleged and reaffirmed as if set forth herein.
85. Beginning in 1997 and to the present day Tallahassee Police,
Leon County Sheriff, Tann Hunt, Marilyn Morris, Mandy Luttenton, Ellen
Hamilton, Paul Shapiro, Florida Department of Children and Families
(Guiseppe A. Betta Inspector General), Florida Department of Revenue hearing
officer Dawn Coloca-Johson, Judge Kathleen Dekker, Judge George S.
Reynolds, Judge P. Kevin Davey, Warren Goodwin (assistant state attorney),
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Willie Meggs (Florida State Attorney ), Al Gandy (chief inspector State
Attorney's office), Charles McClure, Bill Altman, Judge Robert H. Cleland, and
others committed fraud upon the court including fraudulent sworn affidavits
fraudulent theft reports, including one of the plaintiff stealing his (own car)
supposedly witnessed by Ellen Hamilton, destroying court documents,
violating guidelines to extort money, conflict of interest, fraudulent
misrepresentation of facts, denial of due process rights, mock hearings, denial
of right to be served, extraditing under false pretences, child abuse, child
endangerment, kidnapping, abduction, assault, battery, false imprisonment,
public corruption, illegal sanctions, illegal threats, and more.
86. Apparently, Judge George S. Reynolds has received awards for this
kind of illegal behavior by his legal association or group in which he is a
member; one attorney even went as far to call Judge Reynolds a "dangerous
man" to our country because his acts are known not to be limited to the
actions taken in the instant case and he has a record of corrupting the
system and peoples lives irrespective of the law.
87. The defendant's attorney for all DDC suits was Bill Altman who
took steps in each case to misrepresent rules, statutes, facts and
requirements, all in an effort to corrupt the judicial system and deny
the plaintiff his civil rights. Mr. Altman additionally repeatedly failed to
show up for depositions and ignored subpoenas and failed to show with
or without his client also denying the plaintiff his due process rights. This
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was done with a motion for protective order being filed and not granted.
88. Mr. Altman also attempted to convince Judge Cleland to deny
the plaintiff's his first amendment rights and filed vexatious unwarranted
responsive motions to deny waiving of fees, he also mislead the court in
denying true facts and moving for a 2.116 (C) (8) without asking for a more
definite statement and admitting he understood the plaintiff's filings and
the plaintiff alleged "exactly" what he intended.
89. The original complaint in the case was filed in Wayne county circuit
court on September 21, 2005 before Judge Baxter. The plaintiff filed the
complaint with a demand for jury trial. The plaintiff filed a motion for
summary judgment pursuant to 2.116(C)(10) and won as a matter of law,
but was denied a decision in his favor. The defendant's attorney even
stipulated that the plaintiff "won" the retaliation suit and that they would
"probably give you that one" if it was appealed. The plaintiff was also denied
a jury trial and the defendant was given a summary judgment pursuant
to 2.116 (C) (8) without justification or reasoned opinion and the decision
additionally was infirm as it was not supported by law and is barred by
collateral estoppel.
90. Portions of the Detroit Diesel component of the instant case was
appealed as a matter of right on January 30, 2006 the court of appeals also
denied the plaintiff a decision in his favor in violation of the plaintiff's
constitutional rights when as a matter of law the plaintiff won and the
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plaintiff and defending counsel had already stipulated on that fact. There
is no disagreement, only erroneous decisions. The plaintiff was also sexually
harassed by the security guards threatening to have him strip all his
clothes when his shoes caused the sensor to beep at the court of appeals
and a complaint was filed regarding that and other incidents. A simple
motion for clarification was denied and filings repeatedly returned with
no consideration as was provided for the defendant. (exhibit#37 Ct. of
Appeals response to complaint)
91. Plaintiff filed a leave to appeal to the Michigan Supreme Court
but leave was denied and the decision was never affirmed by the highest
state court leaving denial of substantive due process rights open as a
constitutional question for federal review of sufficiency of state procedures.
92. The plaintiffs first suit against Bob Green was also denied to
proceed in a violation of the plaintiffs due process rights and Judge Stephens
actually blocked the plaintiff from making his argument after arriving at
the courthouse. When the plaintiff arrived home, Waste Management had
dumped garbage on the plaintiff's lawn. (see exhibit #34)
93. The illegal acts of federal and state agencies is also present in the
the attempts of the plaintiff to address any issues in court, where the state
attorneys offices in Michigan and Florida have interfered with and violated
the plaintiff's constitutional rights by obstructing justice and other illegal
acts of fraud upon the court.
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94. On March 30, 2007 plaintiff filed his second action against Mr.
Green, plaintiff's former supervisor at Detroit Diesel Corporation ("DDC")
due to the denial of due process rights, constitutional rights, right to jury
trial, and failure to serve orders, denying the plaintiff his appeal of right
by Judge Cynthia Stephens in Wayne County Circuit Court.
Federal Judge, Robert H. Cleland, conspired with the defendant’s attorneys,
William Altman and Gregory V. Murray, to deny due process rights, right
to Jury trial, failed follow federal rules of procedure in the normal mode,
and illegally discriminated against a person in minority status as a pro-se
and a plaintiff in pauper status. He intentionally misapplied doctrines, blocked
depositions, and conspired to extort tens of thousands of dollars in illegal and
unmerited sanctions, with malice. There are, in the Judges order dated September
6, 2007, specific"threats" if plaintiff choose to further exercise constitutional rights
to a full and fair opportunity to litigate. This is the reason for the chapter: "Federal
Judge Cleland is an idiot" in the book, "Hell Makers and War Makers in America"
His sanctions were so outrageous, the court of appeals could not even tolerate such
corruption on that count and overruled him on the sanctions.
FOURTH COUNT
KIDNAPPING AND ABDUCTION
95. All paragraphs are realleged and reaffirmed as if set forth herein.
96. The kidnapping and abduction the father and his daughter were
and are subjected to, flies completely in the face of the Parental Kidnapping
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Prevention Act of 1980. All jurisdictions involved in the kidnapping were
obligated to review the circumstances and the violation of this act, again
father always had "sole custody" sole legal custody. There has never been found
to be any basis, even at the later illegal hearings, to restrict the fathers
contact with his daughter, yet on a recent visit the father was threatened to
stay in Michigan by Leon County Sheriff Department, again under the threat
of additional acts of force and false arrest and imprisonment regardless of
any court order. Family law court orders have had no impact on the behavior
of the Tallahassee Police Department or Leon County Sheriff; plaintiff has
exhausted those remedies and travel to that jurisdiction is no longer safe and
the comments made by the Florida State Attorney Willie Meggs show the
full and fair opportunity to litigate in that jurisdiction will not exist, even
if the plaintiff brought a retired judge down there they stated "go ahead and
bring him down here he'll be like a fish out of water". The plaintiff has not
been allowed to see his daughter at all since summer of 2005 and used to
see her every 6 to 8 weeks on a consistent basis in addition to 3 phone calls
per week to make sure she was safe which they also stopped illegally.
97. The father could not live in that jurisdiction for obvious reasons due
to the complete disregard for the law and continued criminal acts of the
Florida State Attorney and other authorities to entrap the plaintiff, the father
would have no way to help the child if he was incarcerated. A web site called
"thetallahasseeo" documents case upon case of illegal activity in Tallahassee.
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There are other sites documenting it as well, with many of the defendants listed
in this complaint showing their illegal activity and antics time an time again.
98. The real reason the ex wife wanted the child was to take pornographic
lesbian pictures of her and sell them to make money, while extorting child
support and other monies to further her perverted and abusive lifestyle. The
child was repeatedly abused both physically and mentally severely neglected
and tormented over a extended period of time. The child stated several times
to the father that she would "probably be dead" if it wasn't for the fathers
constant contact and to make sure she was okay; that is how bad it was.
FIFTH COUNT
FALSE IMPRISONMENT
99. All paragraphs are realleged and reaffirmed as if set forth herein.
100. Agents of the federal government working with state and local
authorities have repeatedly and maliciously committed illegal acts against
the plaintiff and other citizens of the United States entirely against the
interests of the country and in direct violation of the constitution. An illegal
act against any citizen of the United States is an act against the country
and its people and the legitimate, legally functioning remaining components
of the government.
101. The plaintiff and daughter were illegally taken by kidnapping and
abduction and falsely imprisoned June 17, 1997 and father and daughter
thereafter have been the focus of a never ending campaign of false
imprisonment and extortion to this very day. The daughter is still being
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illegally held in Florida in violation of the only valid court order and father
forced to pay support when he has had sole legal custody.
102. The plaintiff, due to the illegal steps taken in Florida, would not
even able to secure a passport to visit Niagara falls restricting the plaintiffs
movement with no just cause and limiting many kinds of activities or trips
with friends or family.
103. The Department of Revenue and Leon County Court illegally,
years after the order, and without a hearing, initiated an income tax intercept
so any refund would be taken to further financially restrain the plaintiff. What
was intercepted was never posted or removed from the total just stolen
and simply extorted without any recognition or balance adjustment.This was done
in addition to illegally adding the months of June and July to pay support,
without a hearing, while the plaintiff tried to care for his daughter and had
her in Michigan for the summer. This was to inflict additional and intentional
distress. These illegal intercepts are continuing acts which are still in place to
this day even though the daughter is 19 years old and Florida DOR never
has had jurisdiction. In all actuality, this was intended to financially imprison
and restrain the plaintiff arbitrarily and illegally.
104. The plaintiff's perfect credit was intentionally and with malice
ruined by the Illegal acts of defendants severely restricting the ability of
the plaintiff to acquire transportation, move about freely or establish
a company and hinder employment or residence options; freedoms and
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liberties intentionally taken away by the illegal Florida and other proceedings.
105. Detroit Diesel has had contact with the FBI and Homeland Security
before and after the plaintiff filed suit against the company. They have used
these contacts in attempts to harass and terrorize the plaintiff into dropping
the law suits and preventing the plaintiff any means of support in addition to
blacklisting the plaintiff to any perspective employers.
106. As recently as July 27, 2007 the department of Homeland Security
had agents hide behind vehicles at Plymouth Rd. and Telegraph Rd. in
Redford Mich. and repeatedly peek around and above the cars holding a
camera with an unusually large lens apparently taking pictures, or at least
the impression of agents taking pictures, attempting to scare the plaintiff into
dropping his federal lawsuit. The camera has an unusual lens almost looking
like a prop. A few weeks earlier a Detroit Police Officer (parking enforcement)
also used what seemed to be the same camera with the unusually large lens
pointing it several times at the plaintiff out his widow while stopped in his
car at the intersection they both would put it down, then lift the camera
back up and point it when the plaintiff looked or turned in that direction.
Again, see Cointelpro definition and exact examples. Update, in federal court
the defendants actually submitted these pictures to the court, and plaintiff has
copies which can be also supplied as evidence in this complaint.
107. Homeland Security is taking actions to interfere and obstruct business
relationships that the plaintiff may establish, they have spoken with neighbors
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in efforts to provoke the plaintiff by harassment and restrict his freedom of
movement by having people run out from behind buildings yelling "bang",
creating pyrotechnic explosions in front of the plaintiff's house at night,
dumping trash on the plaintiff's lawn, taking flash pictures of plaintiff at
night, tampering with e-mail communications or sales, accessing cell phone
communications, interfering with filing of federal lawsuits from denying due
process, deleting flash drive files, agents physically removing notarized
documents from copiers at the library, tampering with utilities, theft and
destruction of private property, tampering with the plaintiff's mail box,
attempts to run the plaintiff off the road or give the appearance or evoke
fear of the imminent act of being run off the road, contact with rental car
companies threatening gestures and unwelcome physical contact after
court hearings, walking large black dogs never in area before repeatedly
by the plaintiffs house several times in a row, one was clearly trained
to attack and attempted to do so but was on leash, all intended to instill fear.
108. The actions of the defendant(s) and their agents have caused
the plaintiff to have no options in which to sustain himself the defendant
made statements such as, "you will have to go to another country to get a job"
and "everyone will be against you", and while the plaintiff was looking
out the window "kind of like being in a prison, isn't it". The situation has
caused the plaintiff to no longer have any career path at all and even in the
effort to start a new company, an (LLC), the plaintiffs attempts to establish
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relationships with companies or suppliers is constantly interfered with
as they are instructed to do inadequate work as to provoke the plaintiff,
and or require the plaintiff to come back repeatedly to have work corrected
in so wasting the plaintiff's money and time and any chance to establish
a company and secure a living. If they do not go along with the requests
of the Department of Homeland Security, the company is then targeted. They
have also interfered and attempted to block the plaintiff's filing of previous
federal lawsuits by various means including blocking access to Pacer. Not to
mention the illegal, outragous, sanctions, bonds and beatings and trumped up
felonies used as a club or threat to prevent exercise of simple constitutional rights.
109. They have intentionally vandalized cars owned by the plaintiff or his
company such as taking a large chunk of paint off the door of a newly painted
and restored corvette and ruining the hood alignment, preventing the
immediate sale of the vehicle which also had the engine repeatedly improperly
machined by the contacted machine shop. Homeland Security has shown
pictures to people also to assist in the targeting the plaintiff . There are also
police officers who have followed the plaintiff repeatedly, after plaintiff
picketing at Detroit Diesel, looking for any slight reason to provide a ticket
being directed to the plaintiff to ticket him to increase financial difficulties
the plaintiff is experiencing is due to repeated violations of the plaintiff's
civil rights, due process rights, and liberties which originally began in Florida
through the illegal acts of Florida State Attorney's office and Leon County
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Courts and continued through extortion and communications to agencies
and employers in Michigan.
110. The plaintiff was informed by one of the contacts that the Michigan
Attorney General Mike Cox is involved and has detailed knowledge, personal
knowledge and/or input with Homeland Security and what is happening and
has had contact with the Florida State Attorney Willie Meggs.
111. Clearly there has been a concerted effort to hide these acts from ever
being addressed and the intent was and is for the plaintiff to never have the
opportunity to defend himself and to be oppressed, imprisoned, humiliated
and destitute, without contact with his child or having shelter, and without
any constitutional rights to prevent all of the parties involved from being held
accountable not to mention the attacks and beatings intended to knock the plaintiff
off . The plaintiff is at this time a political prisoner in the United States by people
acting in violation of the laws of the United States.
112. As a one day props example, on August 17, 2007 Homeland security
and agents followed plaintiff into a parking lot with a Hurst beeping repeatedly,
parked a with an electric mobility chair across from him while he was
protesting outside Detroit Diesel, had a handicap lady with a walker out
of nowhere traverse slowly across the median to inquire about the sign,
parked a Chrysler vehicle the same color as clothes plaintiff was wearing
in the place of the truck when it left (where there is no parking spot but
is in plain view of plaintiff), had Redford police officers with flashing lights
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show up in the parking lot as plaintiff arrived . The handicap focus is from
the neurosis problems and suseptiblities the plaintiff suffered earlier. When
the FBI contacted parents earlier they made a point to the plaintiffs father to
comment about nerve problems. Clearly these actions are to cause injury
and stress with intent to cause disability or death and is further and
continuing acts of illegal retaliation for the lawsuits from Detroit Diesel with
State Attorney's Office, FBI, Homeland security and local law enforcement.
Adding additional validation, the day before this a woman game up to the plaintiff,
while protesting in front of DDC, and after conversing with the plaintiff and developing
a liking for the plaintiff stated that she was on SSI and that Homeland Security
is using people on SSI to do things for them because as she said, they "don't have
anything better to do". Then she said, who was your boss? Plaintiff told her it was
Bob Green and she stated that is who they were "getting their instructions from"
which was a huge link in how all of this was transpiring. Plaintiff thanked her
dearly for the visit. It appears some would testify in a trial and she even called
plaintiff their "pied piper" for the real America..
113. On August 30, 2007, after paying his ticket for expired plate,
Redford police were waiting outside when the plaintiff left and followed
him with a gray Dodge Charger police unit which raced up behind
the plaintiff, turned on its lights beeped its pull over siren then turned
around and headed the other way simply to harass the plaintiff.
114. Due to the extensive history of many of the defendants in this suit
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using law enforcement for their corrupt motives and furtherance of their
illegal acts, the plaintiff is notifying members of the U.N. Human Right Commission
and other concerned parties of this suit so as make people known and aware.
Any attempts at further retaliatory acts under the guise of law these parties may
chose to take considering their extreme propensity for violence, terrorism, tyranny,
and obstruction of justice will be watched by every nation all over the world.
115. The count of false imprisonment and the intentions of the defendants
was clearly called out in very specific terms by the statements "kind of like
being in a prison isn't it?" and Mr. Green stating the plaintiff would have to
"leave the country to get a job". These are plain and clear statements of intent
to falsely imprison and deny constitutional rights.
116. The plaintiff is being treated illegally as a political prisoner by the
federal government and other defendants.
SIXTH COUNT
VIOLATION OF SEVENTH AMENDMENT (TRIAL BY JURY)
117. All paragraphs are realleged and reaffirmed as if set forth herein.
118. The original filing on September 21, 2005 was filed in Wayne
County Circuit Court and included a demand for jury trial. The plaintiff
was denied his right to a jury trial even though there were several complaints
under which relief could be granted establishing grounds more than sufficient
to state a claims on which relief could be granted. The defendant didn't
request a more specific statement, and there were issues of material fact
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sufficient to go to jury trial. The plaintiff also won his MCR 2.116( C )(10)
motion as a matter of law at the same hearing, rendering a summary
in favor of the defendant with no reasoned opinion factually and legally
impossible and without merit and a violation of the plaintiff's constitutional
rights by Judge Baxter. The amended complaint of retaliation was won by
default as it was never responded to at all as required by law and all
allegations and reasoning are admitted. It can't get any more clear than that.
Prior to her judicial appointment, she was a private practice lawyer, working for
General Motors Baxter was accused of falsifying documents and was also guilty
of tampering with a criminal murder case. Detroit Diesel was a division of General
Motors and she knew full well that she should have never presided over a case
concerning her former employer. There was clearly extreme prejudice and a clear
conflict of interest behind the obstruction of justice, denial of due process and
illegal fraud upon the court. On September 11, 2001, the Judicial Tenure
Commission voted to censure Baxter concerning another separate case showing
she is no stranger to using the court to do illegal activity and deny a jury trial.
119. The second suit against the plaintiff's supervisor was also to be
a jury trial was also a denial of the plaintiff's due process and constitutional
rights by Judge Stephens. This has been verified with attorneys with 30 plus
years of experience but aware of the consequences to their careers of they
make an issue of what is regularly and illegally done to pro se filers. It is
not only pro se filers who are being denied their rights, it is any good attorney
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attempting to actually stand up against the corrupt courts and being targeted
and their law practices and lives being destroyed illegally on a regular basis.
120. In the more recent federal suit against Mr. Green the plaintiff is again
being denied his right to jury trial by Judge Robert H. Cleland of the
Eastern District of Michigan in violation of his constitutional rights. This is
done even as outrageously none of the alligations are specifically denied
and are admitted as such.
SEVENTH COUNT
OBSTRUCTION OF JUSTICE
EIGHTH COUNT
ABUSE OF PROCESS
121. All paragraphs are realleged and facts reapplied and reaffirmed as if herein:
A. "Abuse of process" can be defined as the use of a legal process , whether
criminal or civil, against another primarily to accomplish a purpose for which
the process was not designed Am Jur 2d 1 Abuse of Process
B. "Process" as used in the tort of abuse of process, is interpreted broadly and
it encompasses the entire range of activites and procedures incident to the
litigation process, including discovery proceedings, noticing of depositions,
and issuing of subpoenas General Refractories Co. v. Fireman's Fund Ins.
Co. 337 F. 3d 297 (3d Cir 2003)
C. It has also been stated that for purposes of abuse of process"process refers to
the papers issued by a court to bring a party or property within its jurisdiction,
such as a writ of attachment, the process used to initiate a civil action, or the
process related to bringing of criminal charges. American Jurisprudence 2d
Abuse of process 2 p.458
D. The Ulterior motive or purpose generally required in an abuse of process
action may take the form of coersion to obtain a collateral advantage not
properly involved in the proceeding itself, such as the surrender of
property or the payment of money, by the use of the process as a threat
or club; there is in otherwords a form of extortion. Baker v. Bank of California
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N.A. 282 Cal.Rptr. 22 (App 4th Dist. 1991)
E. Use of the legal process in the seizure of property in order to harass
or injure the owner or person in posession constitutes an actionable
abuse of process, as does the use of process in an attempt to enforce
payment of a judgement known to be false,fraudulent, or nonexistent.
Shipe v. Schenk, 158 A.2d 910(Mun. Ct. App. D.C. 1960)
F. However, where the criminal process or civil or criminal arrest, is
used to effect an object not within its scope, there is an abuse of
process for which an action will lie, as for example where a warrant
of arrest is used to extort money or other property, or to compel the
signing of a paper, the giving up of a claim or the doing of some other
act in accordance with the wishes of those who have control of the
prosecution.Wood v. Palmer Ford, Inc. 47 Md. App. 692,425 A. 2d
671 (1981)
G. Where criminal proceedings are used as a ruse or pretext, or in bad
faith, for the purpose of getting a non-resident into the jurisdiction
in order to serve him or her with civil process, the process will be set
aside as an abuse, and damages may be recovered.
Wood v Baily, 144 Mass. 365, 11 N.E. 567 (1887)
H. An officer acting under legal process, if guilty of the improper
illegal exercise of authority under it as to warrant the conclusion
that the officer intended to use legal authority as a cover for illegal
conduct, is liable as a tresspasser as though he or she had acted without
process. Hence an officer who inproperly seizes property, uses excessive
force in serving a writ, or makes oppressive use of legally issued
processes forfeits the protection that would be available had the
officer exicuted the process for the purpose for which it was intended;
for such abuse the officer becomes liable in damages like any other
private individual.
Giddings v. Freedley, 128 F. 355 (C.C.A. 2d Cir. 1904)
Stern v. Riches, 111 Wis. 591, 87 N.W. 555 (1901)
Barrett v. White, 3 N.H. 210 1825 WL 476 (1825)
I. Liability for the abuse of process tort generally extends to all who
knowingly procure, participate in, aid, ar abet the abuse, and those
who advise, or consent to the abusive acts, or subsequently adopt
or ratify them, are liable as joint tortfeasors. Thus the injured person
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has a remedy, not only agianst the officer serving the process, but
also against all others who may unite with the officer inflicting the
injury American Jurisprudence 2d 19 p. 481 Encyclopedia
J. Where abuse of prcess is accompanied by malice, exemplary or punitive
damages may be awarded. Steele v. Morris 608 F. Supp. 274, 1 Fed R. Serv. 3d 956
(S.D. W. Va. 1985)
K. Malice may be established by showing the defendants conduct reflected
spite, ill will, and reckless disregard of its possible consequences to
the opposing party.
L. The fact that a plaintiff acted under the advice of counsel is not generally
considered to be a defense. The existence of probable cause also is not
a defense to an abuse of process claim Mc Carthy v. Kleindherst, 741 F. 2d
1406,39 Fed. R. Serv. 2d 1165 (D.C. Cir. 1984)
NINTH COUNT
COLOR OF LAW VIOLATIONS
TENTH COUNT
EXTORTION
ELEVENTH COUNT
MALICIOUS PROSECUTION
122. All paragraphs are realleged and reaffirmed as if set forth herein.
123 Some information below also contains components of entrapment,
additional fraud upon the court, false imprisonment and other illegal acts.
124. During to the June 97 kidnapping, abduction, and false imprisonment
the former wife was on probation. She was never held accountable for her
numerous violations of probation, the Leon County Sheriff's department
and Tallahassee police and State Attorneys Office conspired to commit illegal
acts with her while the former wife was on probation. These acts were in
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violation of court ratified and legally binding marital settlement agreement
as well as criminal law. Ellen Hamilton conspired and also illegally signed
sworn documents stating the plaintiff stole his own car from her residence.
The father had an established residence and belongings not easily transported
and had a legal right to be served with a notice of hearing since he had sole
legal custody, therefore the ex-parte hearing which occurred was an
unjustified intentional illegal act to deny the father due process rights and
full and fair opportunity to litigate and further obstruct justice. This denial
of substantive due process rights renders any judgments and later mock
hearings void as a matter of law. Furthermore, the plaintiff was being
restrained in violation of his rights by the conflict of interest of his counsel
and the Florida State Attorney's Office.
125. The seizure of property and grand theft charges was to harass and
injure the father in addition to the violent abduction of his daughter. This
process was used as a weapon to accomplish a purpose for which it was
not intended. The grand theft charges are an unwarranted, unauthorized
illegal and perverted use of the process. The defendant clearly had an ulterior
motive which was to kidnap the child from her legal guardian. The father
illegally suffered the loss of his child, financial stability, civil liberties and
each year thereafter the abuse continued and slowly chipped away at any
remaining rights the father had left. Even though the father prevailed in the
criminal action, and the charge was ultimately dropped, the illegal bar to
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any full and fair recovery was already predetermined by the perpetrators
and covered the entire range of activities related to the litigation process
and current unwarranted denial of contact is simply to harass and injure
the father and satisfy the wishes of those who had control of the prosecution.
126. The Judge George S. Reynolds acted wholly without jurisdiction and
acted under pretences of official capacity. Other officers involved in the acts
did not have facts to establish probable cause as required by law. The legal
authority was simply used as a pretext for illegal conduct. The criminal
proceedings, as shown by the dropped charges, were used as a ruse or a
pretext in bad faith to prevent any legal defense and force the plaintiff back
to their jurisdiction and the entire and continually escalating process to
this day is an abuse intended to cause additional damages. There was also
procured the improper initiation of proceedings by third parties to use
criminal proceedings to collect a fraudulently alleged civil debt and acted
upon jointly and constitutes the oppressive use of legally issued processes.
127. The father offered to Novi, and Farmington Hills Police Department
legally binding proof of custody to provide them with a legitimate legal
document establishing issue of material fact and allowing them ample time to
question the actions they were taking and validate the documents with their
respective departments and exercise good investigative instincts rather than
contributing to further illegal acts. Detective Lauria denied the opportunity,
and rather chose to escalate the situation with vulgar violent threats in front
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of a 4 year old child expressing his sick and corrupt mentality and striking
fear into a four year old child establishing that officer Lauria, Novi police
department, and Farmington Hills police among other things used excessive
force in serving the writ of attachment and trespassed while kidnapping and
falsely arresting, and committing an illegal child abduction while defaming
the father in front of his child as well as false imprisonment and failure to
read the plaintiff his rights.
128. When plaintiff asked detective Victor Lauria about if he would be read
rights Lauria stated, "you don't have any", a denial of rights and admission
clearly stated with malice. This idiot is now the assistant Chief of Police.
129. Oakland county jail refused to allow the father a phone call within
24 hours of incarceration. The father was then forced under duress to sign
a release or was told that he would never leave the cell, where men were
molesting other men, or get a phone call if he did not sign. If he did sign, he
was promised to be transferred to a different cell and would get a phone call
The father immediately after signing was put into the same cell until the
extradition process began days later. The plaintiff, at times, still has flashbacks
because of the illegal incarceration.
130. David Moye', the father's criminal attorney, intentionally overcharged
the father and parents and did not take the proper steps to resolve the case
by interfering with and withholding other possible options and not informing
the father of the details of the factual findings. It was clearly the intent
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of Mr. Moye to do this as a favor for his future employer, who he was to be
defending the father against for illegal and outrageous acts. Mr. Moye
intentionally kept the criminal case open as to prevent any decision in
the father's favor from being used in the family law case by the request of
the State Attorney Willie Meggs and to cover up illegal acts on their part
and to further extort money from the father and his parents the hearings
were simply a mockery set up by those planning the illegal acts.
131. Mr. Moye by intentionally dragging out the criminal case used
it as a form of coercion, threat or a club in an ulterior motive, to establish
a collateral advantage for opposing party in the family law case and
for his future employer in a form of extortion to force the plaintiff to
surrender property and extort money from him in the form of higher
attorneys fees, payment of court costs, surrender of property not in
the proceedings, and extort payment for services of other officers, higher
fees for the family law attorney, and adverse family law outcome. It
was also used extort payments that were false, fraudulent or nonexistent
in the context of the ultimate determination.
132. Mr. Moye later also persuaded other attorneys not to pursue the case
clearly in an effort to cover his own interests and prevent any of the egregious
acts from being addressed in court, obstructing the plaintiff's rights.
133. The Family Law attorney, Robert McNeely, also proceeded in similar
fashion and was in contact with Mr. Moye while he also neglected his duties
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to provide adequate representation and also aggressively moved to extort.
McNeely's ploy was to file repeated motions, and when denied, would fail to
appeal and allow the time to run out on consideration of the motion; but
attempt to get another judge whereby wasting time and eliminating all
appellate options on such a clear and simple case that should have been
appealed immediately from the beginning. The scam was to run up hours and
extort money from the father without merit as later did Paul Shapiro. (ex #38)
Shapiro's blatant malpractice, obstruction of justice, fraud and harassment
of the plaintiff). Note: extortion of court costs required by "Attorney General"
and additional hearings and court costs continue for two years of malicious
prosecution, fraud upon the court, extortion, denial of due process rights,
abuse of process, harassment, fraud and more while plaintiff is in compliance
the whole time. (see exhibit#23 on compliance 2 years later)
134. The father was, as mentioned, the focus of more than one assault and
battery instigated by Leon County Sheriff and Tallahassee Police in conjunction
with repeated refusal to enforce visitation orders and attempts to provoke the
father to defend himself and entrap the father to being unjustly arrested
again. There was also a complete denial of the fathers rights to any legal
recourse for being assaulted or in filing child abuse charges. defendants
conspired to withhold facts in a child abuse investigation, further abductions
of the child, deny legal custody of the child, additional efforts of Leon County
to fabricate charges, refusal to provide legal assistance as provided to
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residents of Leon County, forcing the father to leave town, abducting and
withholding visitation with his daughter simply for political reasons, causing
the child extreme distress and additional physical and mental abuse.
135. The inaction on the part of The Department of Children and Families
in not properly addressing the child abuse and working with Leon County
Sheriff's Department and Tallahassee Police Department in conspiring to
cover up and not properly proceed as legally required to protect the child also
constitutes further acts in obstruction of justice.
136. In further proceedings in Leon County Court and with the most recent
opposing counsel Charles McClure (who corruptly, but not surprisingly, was
a prior judge privy and subject to conflict of interest with this case), filed
frivolous motions without merit, requesting denial of all visitation of the father
as recently as June 2006, the father was denied his due process rights, tapes
of hearings were erased, Department of Revenue has continued their
harassment and extortion and refused to adhere to child support guidelines,
instructing Florida State Disbursement Unit not to post payments made and
not to post thousands more in income tax intercepts as further blatant
extortion knowingly demanding other or greater sums than are authorized
by law willfully oppressing the father under color of law by the malicious acts
of Attorney General for the Department of Revenue Priscilla Quionnes who
initiated the illegal acts. State Attorney's office has sent copies of scheduling
orders and has represented the former wife on additional hearings continuing
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their involvement and solidifying the facts that the obstruction of justice and
fraud has never ceased. The former wife stated on August 21, 2007 she was
going to talk to the Attorney General "personally", demonstrating a willful
and malicious intent to forever continue illegal acts with the support of
the Florida State Attorney Willie Meggs and others. There was another
illegal exparte hearing in 2012 in which the Florida Department of Revenue
decided to continue to stalk the father for illegal support payments even though
the daughter is 19 years old, she is no longer a child, they no longer have
jurisdiction anyway, and all prior and future payments were illegal.
137. From 2005 to present, under the counsel of Charles McClure, the
former wife has refused visitation entirely between the father and the
daughter. Even though Charles McClure's motions to deny visitation were
not granted, the former wife and her counsel have taken it upon themselves,
with no legal basis, to completely deny the child her relationship with her
father. When the father would schedule to visit; the child would be illegally
abducted to another location, or the father forced to leave town, this had
been used with extensive brainwashing of the child to defame the father
both by the former wife and former mother-in-law (Ellen Hamilton) and
significant other or "lesbian girlfriend" who hold any fathers position in low
regard and the aunt who has taken "porno pictures" of other women and also
tried to take explicit nude pictures of the child while "urged on" by the
mother (former wife) to do the act. This psychopathic behavior is partially
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why the father filed for divorce in the first place and why that environment is
dangerous for a young person clearly each of these people advised and
consented to the illegal, perverted acts. (exhibit #39 '04 complaint form)
138. When Charles McClure filed a his motions he never even filed
the UJCC affidavit, which is required by law, or establish a significant
change in circumstances, also required. There is simply no excuse for a
judge that recently retired from family law to file a frivilous motion
lacking the basic requirements of the motion. The motion was simply
and intentionally harass and was completely baseless and meritless
and again was a ruse or a pretext to interfere with summer vacation
and force the plaintiff to again to go down to Florida to defend a
meritless act when plaintiff should have been allowed to attend by
phone. The intent was that the plaintiff would not be able to make it
to Florida for the hearing and then be held in contempt of court
allowing the Florida authorities to take the child from Michigan and
again falsely imprison the plaintiff this time for contempt in another
entrapment scheme. It cannot be overstated that Charles McClure had
intimate knowledge that the motion was patently frivilous and lacked
the basic requirements to sustain it. (exhibit #40 letter McClure, Letter
Lauren (daughter) sent to Judge done in 10 minutes June 2004)
139. When Charles McClure's plan didn't work he became very
upset and stated to the plaintiff "you're a horses ass" and this was
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coming from a recently retired Leon County Judge! This demonstrates
State Attorney Willie Meggs statement that "we do things differently
down here". This lunatic was actually angry that his corrupt illegal act
fell through. At the hearing he even tried to allege the plaintiff made
statement "catch me if you can". If the plaintiff would have not shown
up for the hearing, that act of fraud upon the court would have been
again used to take the child and put the plaintiff in jail, just as the
former wife stated if the plaintiff's parents would not have got him out
the first time he would "still be in there". (exhibit#41 McClure letters May
- June 2006 "horses ass" comment ). The fact is, that Judge Cooper should
have never allowed a hearing on Charles McClure's improper motion in the first
place or forced Lauren to have excessive phone contact every single day during
the summer with her mother when calls were supposed to be three times a week
and the every day calls were simply to harass, torment, brainwash and ruin
the child's summer even further strangling her liberties again with oppressive
and hate filled lies. The hearing forced the father to go all the way back to Florida
during the child's summer vacation simply to harass and interfere with visitation.
He refused to have the hearing by phone. She is haunted and followed around
constantly by the mother even to this day. If the purpose was moral or protective
that would be a different issue; but, it is simply to alienate and terrorize a child
by a mother that wants to prevent her from reading the bible or having a father.
It is religious persecution using the family law system as a pretext for illegal
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discrimination.
140. Fifteen years of these illegal acts demonstrates there is an unrelenting
malicious purposeful intent for the defendants to create an environment
so the plaintiff will never be safe in his own country and have to live in
constant fear and be denied all rights to his child and any mode of survival.
There is no reason for this insanity and acts of civil war and terrorism against
the plaintiff and the constitution itself. If there is a reason for their acts, this
is their opportunity to tell it to the jury and explain it in depositions.
141. In acts as recently as Aug 9, 2007 the former wife again stated her
intent to make it so the plaintiff would never be a father to his daughter and
again threatened unjustified legal action and stated that the plaintiff "never
will be" her father. The father clearly has exhausted his legal options in that
jurisdiction and there is no law abiding law enforcement authorities, as the
instant case clearly demonstrates, to uphold the law in that area. The former
wife also stated that if the plaintiff's parents didn't help to get him out of
the illegal incarceration she caused he would " still be in there". This can
only cause one to question how many other people are being imprisoned
illegally in violation of their rights by these sickening, clearly retarded, mentally
ill terrorists employed by, but working against the U.S. government and its
people and how many children are being abused and neglected by and as
a result of their blatant malicious illegal acts. Former wife also sent a letter to
the court stating in her own words that she was "fighting this man" and sent
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an e-mail stating the nothing that the plaintiff says, feels, or does matters and
that he was just a "sperm donor" and never will be Laurens father. These may
also be presented to the court. This also demonstrates why she was on probation
for domestic violence and why the plaintiff filed to divorce her in the first place.
142. Mr. Green at Detroit Diesel also stated that the plaintiff would have to
"rob a bank" or "kill your parents" to have enough money to see his daughter
again. This is not for any lack of parenting skills or abilities, simply a group of
corrupt people with a fraudulent intent using contacts to illegally interfere
someone's life and family and commit illegal acts utilizing communications
with incompetent employers to further their goals.
143. Mr. Larry Butler, a former employee of DDC, in a deposition
on September 25, 2006, made intentional false statements under oath to
obstruct justice in order to play on the grand theft theme by stating that the
plaintiff wanted Mr. Butler to "give" him his car rather than purchasing it
from him however, he cannot defend that statement as inconsistencies
develop in his story as the deposition goes on . This is also consistent with
specific activities of defamation listed in the instant complaint. Prior to the
deposition, in a phone call with the plaintiff, Mr. Butler stated that he may
attempt to "ruin" the plaintiff's case in so committing purjury and obstructing
justice.
144. On November 6, 2006 the plaintiff traveled to Lansing to file
a complaint with the FBI. The plaintiff was initially given a complaint form
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and scheduled to see an agent to discuss the complaint. However, shortly
thereafter the complaint form was taken back and the plaintiff was instructed
that there was no one there to discuss the case, and that the plaintiff would
need to go to the Oakland county location to file the complaint. The plaintiff
called the location in Troy and spoke with Dave Kotel, who stated he would
fill out a complaint for the plaintiff. The plaintiff met with Mr. Kotel and
apparently no report was ever filled out by Mr. Kotel in reference to the
plaintiff's complaint although he was led to believe there was. The plaintiff
also offered several pictures to Mr. Kotel in support of his allegations and
Mr. Kotel stated that he did not need them. Mr. Kotel stated that he forwarded
the complaint to a different group, however on February 16, 2007, the
plaintiff filed a freedom of information act request to get a copy of the report
Mr. Kotel was to have prepared; plaintiff was told there was no report.
145. Mr. Kotel also attempted to obstruct contact with the plaintiff and
Kotel's supervisor after Mr. Kotel displayed unethical behavior and made
outrageous comments on January 8, 2007 and got combative when asked
about his knowledge of the adverse actions the day after the November 6
meeting such as phone calls, picture taking, contact with neighbors and
family, cell phone being remotely accessed, being followed, etc.
146. While Mr. Kotel's comments were that the things that the plaintiff
was seeing weren’t "really happening" and that the plaintiff should see a
doctor for psychological issues. His supervisor, Charabot, did not deny the activity
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but stated that the FBI were not the ones doing the following but she could
not say that it was not being done by another department such as Homeland
Security. The other alleged actions, such as phone calls, phone access, picture
taking and neighbor contacts were not denied like the issue of following.
Mr. Kotel personally contacted the plaintiffs Father and Mother and told them
that it would be in their "best interest" not to help the plaintiff. This act
struck such fear into the family that there has been no contact ever since,
which in itself is terrorism and malicious defamation per se. Again, see Cointelpro.
After plaintiff found out who he called, Plainitff called Kotel back and asked if he had
contact with anyone and he initially denied it. Then, when plaintiff proved to him
he was lying and gave him specific details of his calls to plaintiff's parents he became
combative and said, “So what!?”, and admitted contact, and that is when plaintiff
asked to speak with his supervisor Toni Charabot but Kotel tried to deny contact.
147. Homeland Security and FBI interfered with the filing of a federal law suit
where the plaintiff's files were erased, originals of affidavits stolen, papers
removed from copier and plaintiff was queried about his emotional condition
after papers were taken, all within 1 hour while preparing his federal case
against Green at the Farmington, MI library the same day: March 30, 2007.
The stolen items were later returned in the mail over a month later.
148. PBS had a special on homeland security and the serious attacks
on the constitutional rights of our citizens and violation of privacy rights at
libraries. The special was called America at a Crossroads and was aired May 11,
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2006 so the plaintiff is not the only one.
149. Homeland security has had contact with people in the plaintiff's
neighborhood, has had contact with companies the plaintiff has business
relationships and conspired with many of them to do damage to items
belonging to the plaintiff, improperly or inadequately do jobs which would
cause the plaintiff to return repeatedly to have done right or completed,
wasting the plaintiff's time and financial resources and intending to cause
plaintiff's company to fail and restrict any and all efforts at productivity.
150. In prior cases, as with the prior federal suit against Mr. Green, the
plaintiff has had monies extorted from him by the courts in filing fees motion
fees and illegal sanctions in the tens of thousands of dollars while denying
the plaintiff his due process rights when the plaintiff has won as a matter
of law and stated claims with identical circumstances found to have won jury
verdicts or decisions as a matter of precedent anyway even if not defaulted.
151. The week after the plaintiff had contact with a realtor about selling
his house, Judge Cleland conspired with Bill Altman and Gregory V. Murray
to extort any proceeds from the sale by illegally sanctioning the plaintiff
$18, 242.38, when sanctions should have been against the defendant for
their numerous rule violations and illegal acts. Even in the courts own
standard of review, sanctions are not merited against plaintiff, however it
does support sanctions against the defendant. The fact that attempted
murder and extortion is now supported by Judge Robert H. Cleland as
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acceptable is utterly shocking. (exhibit#42 plaintiff's response and
counter motion for sanctions w/ transcript of plaintiff winning 2.116
( C ) (10) as matter of law Dec. 16, 2005, opinion and order granting
defendants motion for sanctions Sept. 6, 2007, list of extorted fees
and costs) In addition, they were informed about the sale of the house in the
first place by the FBI, admittedly. Obviously they would have never known
such a private transaction was taking place any other way and Kotel asked
who the Judge was for the federal suit and later illegally contacted Cleland.
TWELFTH COUNT
NEGLIGENCE
152. All paragraphs are realleged and reaffirmed as if set forth herein
153. Leon County Sheriff, Tallahassee Police department, Department
of Children and Families, State Attorney Willie Meggs, agents Gandy and
Goodwin and others acted negligently in not properly investigating and
failing to take appropriate legal action to protect the child against the former
wife, aunt, and lesbian grandmother from trying to persuade the child to
pose for pornographic pictures which also explains why the child had
mosquito and ant bites all over her body after visiting the grandmother a
few years before because the grandmother was taking nude pictures of
the child outside and desensitizing her to filthy lesbian whoring.
154. The plaintiff hired John C. Kenny to take legal action to seek a
modification of parental responsibility to protect the child from additional
acts of child abuse, neglect, and endangerment. Rather than address the
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issues, he used it as a social opportunity to have contact with the Willie
Meggs and made agreements with Willie Meggs to take no action at
all, causing and contributing to her additional suffering and abuse and
he even made the statement that "the legal system is hell".
155. The FBI, Novi police, Farmington Hills police and others displayed
negligence in not properly investigating the extradition order which they
should have denied in the '97 incident for the utterly fraudulent and illegal
basis on which it was founded upon and complete lack of evidence to sustain
such an order and lack of jurisdiction.
156. The FBI displayed negligence in not following through with
complaints made to them concerning people in the plaintiff's neighborhood
being contacted by individuals originally thought to be posing as agents
from the FBI or Homeland Security. The plaintiff was not called back on
the several requests to Mr. Kotel by messages left concerning the complaint
the plaintiff believed and was led to believe he filed with Dave Kotel.
157. The FBI was negligent in not following through with standard
procedures and intentionally misleading the plaintiff when he was presenting
issues related to national security, possible impersonating a federal officials
(which actually was them), civil rights, fraud, and rights guaranteed by the
constitution of the United States and equal access under the law.
158. The FBI and Homeland security were also negligent in not providing
and withholding information concerning the plaintiff, in violation of the
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Freedom of Information Act.
THIRTEENTH COUNT
VIOLATION OF 14TH AMENDMENT (DUE PROCESS)
159. All paragraphs are realleged and reaffirmed as if set forth herein.
160. ..No state shall make or enforce any law which shall abridge the
privelage or immunities of citizens of the United States; nor shall any
state deprive any person of life, liberty, or property without due process
of law; nor deny any person within its jurisdiction the equal protection
of the laws .
161. All violations listed in all paragraphs are reaffirmed and asserted
as if herein.
162. The father was denied his due process right to being served, to attend
the ex parte hearing before Judge George S. Reynolds. There was no legal
cause and the father had legal "sole custody" details of which were witnessed
and the former wife fired the prior attorney for refusing to make the agreement
giving the father sole custody. The conspiracy was to "take" the child with the
specific intent to deny due process, hence the fraudulent charges, criminal
attorney not resolving case quickly (and later working for Attorney General)
denial of the father and his daughter equal protection under the law, further
abductions and assaults set up by Leon county Sheriff and other related
illegal continuing activity including continuing federal violations to this day.
163. It was made very clear that the law wasn't the issue when at the
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meeting the plaintiff/father had with Attorney General Willie Meggs, Mr.
Gandy and Mr. Goodwin February 16, 2001, the State Attorney stated
that he was the "only game in town" and the facts didn't matter. The father
/plaintiff mentioned that he had some recent opinions on the matter by a
retired judge. The statement was made" go ahead and bring him down
here, he'll be like a fish out of water" and "we do things differently down
here", and "good for her if she can get away with breaking the law".
(see exhibit #19 letter to Gov. Jeb Bush)
164. The plaintiff was denied his 7th amendment right to a jury trial
in the first DDC case, the plaintiff was denied equal protection of the law
against retaliatory action as provided under the Whistleblowers Protection Act.
Defendants evaded depositions by leaving town in order to obstruct the
judicial process and violated other court rules.
165. Although it is not clear or reasoned in the judge's order, there
was a summary decision without basis in law or fact and the decision was
made without due process and the "ordinary mode prescribed by law" and
was not based on the merits of the case and was clearly premature as
discovery was not even completed. Jury trial was denied illegally.
166. The order was not sufficiently firm to establish a basis for the
decision and the plaintiff was "arbitrarily restrained" from proceeding to
a jury trial. There was no suitable protection provided to the plaintiff
in his employment from the defendant taking further adverse action
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in violation the plaintiff's civil liberties and equal protection under the
law as provided by the Whistleblowers Protection Act after filing the
original suit.
167. The Michigan court of appeals went right along with the denial
of due process and violations of constitutional rights in affirming the
grossly erroneous decision(s). Even to go so far as to attempt to make a
malicious fraudulent reasoned opinion devoid of logic while intentionally
ignoring the facts and law and not once showing how there was a failure
to state a claim while also ignoring the facts that there was a default and all
allegations were admitted to as well as application of law; they are a sick,
pathetic insult to the judicial system and human rights.
168. The plaintiff was clearly in a position to suffer grievous loss to
health, future, career and as a result of being denied his rights has in fact
suffered additional grievous loss as would be expected when a citizens' civil
liberties and rights are denied arbitrarily. That is part of the reason these cases
were proceeded with pro se was to intentionally test the integrity of the system
and document the outcome, as is now the case again.
169. Through actions to interfere with business relationships and deny
employment opportunities the FBI and Homeland Security has taken steps
to intentionally remove the plaintiff from his home and deny him his
property rights and any liberties he may have by arbitrarily restraining any
and interfering with all financial pursuits and or endeavors the plaintiff may
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attempt. The FBI even asked for numbers of where the plaintiff would stay
if "things got worse" rather than offering any kind of support of addressing
issues, the day after that comment incidents and harassment increased
dramatically and when that fact was mentioned to Dave Kotel of the FBI
he became defensive and rude as he essentially admitted guilt in taking
part in initiating the acts then denied contact with his supervisor.
170. The only reason the plaintiff was in that past financial situation
and has lost his house is due to the governments denial of the plaintiffs
due process rights, this is not the sole cause of everything financial because
they also destroyed the plaintiffs company and career prospects, but the
inability to make payments and retain his house would not be an issue if
plaintiff was granted decisions which he won and is entitled to as a matter
of fact and law. Because of the actions of the government ( or those acting
illegally in governmental positions) the plaintiff's credit has been completely
destroyed also. It should also be noted the defendant's attorney admitted the
plaintiff won his retaliation claim and the amended complaint was never
responded to and plaintiff won his 2.116 ( C ) (10) as a matter of law at the
hearing. If the plaintiff and defendant agree as to the facts, they are settled
and are in agreement with the law. A adverse decision is void, arbitrary,
without merit and a denial of substantive due process and constitutional
rights in repeated adverse acts which shock the conscience.
171. The plaintiff is being denied equal protection under the law from
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illegal acts of Detroit Diesel, federal and state governments and other
defendants in violation of the Constitution of the United States by
arbitrarily restraining him from exercising his civil rights in the ordinary
mode and intentionally causing plaintiff to suffer grievous loss by denying
equality in due process when state courts and others have repeatedly,
intentionally, and with malice denied the plaintiff his individual rights.
A. When process is due:" The extent to which due process must be afforded the recipientis influenced by the extent to which he may be 'condemned tosuffer grievous loss ', and depends on whether the recipientsinterest in avoiding that loss outweighs the governmental interestin summary adjudication." The very nature of the concept negatesany concept of inflexible procedures universally applicable toevery imaginable situation."
B. Federal constitutional law provides a floor for individual rightsthat state courts may not go below.
C. Liberty: Includes personal, political and social rights and privelagesand implies the absence of arbitrary restraint . With the relation ofthe employer and employed there is to be "suitable protectionof health and safety and that peace and good order may be promotedthrough regulations designed to insure wholesome conditionsof work and freedom from oppression:
D. Procedural due process--civil:It must be pursued in the ordinary mode prescribed by law; itmust be adapted to the end to be attained; and whenever necessaryto the protection of the parties.
E. Equality in due process:Rights are measured not by laws made to affect him individually,but by general provisions of law applicable to all those in like condition.
F. Denial of the full rights of a pro se, as provided by the Constitutionis no different than discriminating against any other minorityon the basis of some arbitrary factor. Pro se in the judicial
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system are minorities by definition and should be afforded allrights and protections under the law as any other citizen.
STANDARD OF REVIEW
172. " The touchtone of due process is to protect the individual
against the arbitrary action of government." U.S. ex rel. Myers v. Sielaf
381 F. Supp. 840 D.C. Pa (1974). Our system of law has always endeavored
to prevent even the probability of unfairness" In re Murchison , 349 U.S.
133, 136,75 S. Ct 623,625,99 L. Ed. 942. "Justice must satisfy the
appearance of justice". The appearance of impropriety is sufficient to
survive the limited requirements of Federal rule of Civil Procedure 8.
Church of Scientology Intern v. Kolts 846 F. Supp. 873 C.D. Cal., 1994
What is being claimed is a violation of substantive due process because
the acts "so shock the conscience" as to constitute a depravation of the
plaintiff's federally protected rights. A violation of a constitutional right
to substantive due process because the conduct was inherently
impermissible Schiller v. Strangis , 540 F. Supp. 605,614. Thus federal
court subject matter jurisdiction in cases adequately alleging violations
of substantive due process is not affected by the adequacy of state
remedies. Id Manuel , 767 F. 2d 174,177. It in effect violates the very
fabric of our system. If the process is so egregious as to "shock the
conscience "it also constitutes a depravation of substantive due process.
(" A judgment, whether in civil or criminal case, reached without
due process of law is without jurisdiction and void and attackable collaterally..
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by resistance to its enforcement if a civil judgment"). 1B Moore's Federal
Practice p. 406 (2),p.905;7id.at p 60.25 (2), p. 309-11. A judgment rendered
in violation of due process is indeed void and therefore need not be enforced
under 28 U.S.C. s 1738 or the full faith and credit clause of the constitution.
"A departure from established modes of procedure (can) render the judgment
void." Windsor , supra, 93 U.S. at 283 where the procedural defects are of
sufficient magnitude to constitute a violation of due process, or…"so unfair as
to deprive the proceedings of validity", Eagles v. U.S. 329 U.S. 304,314,67 S.
Ct 313,319,91 L. Ed. 308 (1946).
FOURTEENTH COUNT
VIOLATION OF FREEDOM OF INFORMATION ACT
173. All paragraphs are realleged and reaffirmed as if set forth herein.
174. A request for information pertaining to the kidnapping of the
plaintiffs daughter, false arrest, false imprisonment, extortion, and records
and circumstances relating to the FBI and Homeland Security related to
the illegal activity at Detroit Diesel and attempted murder by plaintiff's
supervisor and other defendants was made. Additionally, the violations that
occurred by Dave Kotel and the refusal of that department to provide
information as requested was made by the plaintiff.
175. A freedom of information act request was sent to U.S. Department
of Justice (FBI) February 16, 2007, additional information was requested
from the plaintiff by FBI on February 27, 2007 and reply was sent March 4,
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2007, notice of FBI referral was made March 13, 2007. A notice of no
information in regards to the FOIPA was sent March 14,2007. March 28,
2007 letter was sent in regards to information pertaining to another
individual. An administrative appeal with legal citings and detailed
circumstances was filed April 8, 2007 by the plaintiff, April 26, 2007
notice of receipt of the appeal was made. Appeal was not answered until
June 19, 2007.
176. The lack of findings is clearly not valid as there was actual
documented contact that the FBI had with people, specific statements
made by Dave Kotel, and personal meetings and phone calls. The FBI is
clearly withholding information in violation of the freedom of information
act. If the request was more properly addressed by another office the
Freedom of information act and or Privacy Act would allow for a notice
of specific findings at another location and what they may have in
reference to the request, instead each office pointed to the other.
177. A freedom of information act request was also made to the
department of Homeland Security for information related to the
circumstances, March 27, 2007 and the answer on May 30, 2007 was
that the secret service files contained nothing. Clearly an evasive answer
to withhold evidence of what was known to be occurring by responding
to the Secret Service question not the Homeland Security request.
FIFTEENTH COUNT
MALPRACTICE
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178. All paragraphs are realleged and reaffirmed as if set forth herein.
179. The initial grand theft charges, exparte hearing, denial of due
process rights that occurred in June of 97 was a blatant case of entrapment
but not pure entrapment because the plaintiff did not really break the law they
just set it up to look like it which gave the contributing authorities the confidence
arrogance, disrespect and disregard for any sort of adverse legal action to
make repeated further attempts at entrapment and threat upon threat of
unjustified imprisonment to the plaintiff almost sickening casual. In that
frame of mind the defendants have repeatedly and unrelentingly attempted
to do it all over again by conspiring to set up all manner circumstances in a
never ending cycle of corruption and illegal traps. This is especially true of the
retaliatory attack, beating, and attempted murder by the Southfield police
February 29, 2008 after the filing of the original Federal lawsuit. The plaintiff
stated to the arresting officer, "you arrested me for nothing" his response was "Yep"
a legally admissable per se admission of illegal arbitrary arrest by Southfield
police.
180. The father hired Paul Shapiro to correct the child support issues
and rather than show up for the hearing to correct the issues and have the
father attend by phone, the father waited on the phone and Mr. Shapiro
stated that he made a deal when there was no deal to make. He entrapped
the father into even more monthly hearings when there was no cause and
clearly conspired to take action not in the best interest of his client and
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extort fees from the father while representing the other side in a fraud to
appease and conspire with the Department of Revenue.
181. The employers ant attorney's at Detroit Diesel found out about the
plaintiff's prior circumstances in Florida and used it as an opportunity for corruption
and violation the plaintiffs human rights, liberties, and constitutional rights
by using the 9.11 attack and the discontent with the purchase by Daimler
Chrysler to contact governmental entities such as FBI and Homeland security
to create a gradual timetable which would end in the plaintiff losing everything
and being alienated by those in contact with the plaintiff, ignoring any laws
or rights that may have been violated in the process.
182. The timetable included a arbitrary decrease in pay, blacklisting of the
plaintiff to eliminate any employment options, homeland security contacting
neighbors, family, and business connections to destroy any chance the
plaintiff may have to establish a company, entrapping the plaintiff into financial
indigence and inability to make house payments, utility payments, insurance
payments, visit his daughter, or pay child support then ticketing the plaintiff
through the Redford Police who would follow the plaintiff home closely watching
for any reason to ticket the plaintiff . When the plaintiff was ticketed for
an expired motorcycle plate, the cause of the financial situation which
brought it about was the denial of due process rights by the Wayne County
court denying a decision in a law suit where the plaintiff won and was
entitled by law to relief. The city of Redford is located in Wayne County
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Michigan.
183. It was made very clear the intent that the FBI had when requesting
the phone numbers of anyone who the plaintiff may stay with if "things got
worse", then calling these people to frighten and alienate them by stating
that the plaintiff was high strung and had a nervous breakdown (which
incidentally is also a misrepresentation of neurosis and leg failure which is
what occurred) in an effort to prevent the plaintiff from having anywhere to
stay, when the intended outcome of complete financial destitution and
the plaintiff's loss of his house did occur.
184. The plaintiff's father made it a point to tell the FBI that the plaintiff
is not high strung and the issue of him being 40 and having his life and
career ruined is a cause for anyone to be concerned.
185. The plaintiff has been required to pursue public assistance to survive
due to denial of his constitutional rights and liberties of continuing with his
career due to the actions of Detroit Diesel, FBI and Homeland security to
interfere and destroy the plaintiffs prospects, even postings on e-bay were
tampered with and transactions ruined while plaintiff was listing items for
sale to establish his company.
186. After the appeal of the Green lawsuit the harassment had been
increasing to include repeated aggressive acts by young men to provoke
the plaintiff into confrontations as recently as August 13, 2007. The short
time frame, lack of historical incidents, volume, consistency of the age
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(teenagers), lack of situational cause for the behavior clearly demonstrates a
manipulation of the behavior of these young people to entrap the plaintiff
into a situation questionable on many fronts. It has also been noted that these
young men have multiple backup waiting very close to the location. This
has simply never occurred and now is becoming clearly repetitive by different
and multiple actors within several weeks consistent with the Kotel Comment.
187. Young people (teens or twenties) are used repeatedly by the FBI
and or Homeland Security. The hooded men taking pictures at night were
young men, almost running the plaintiff off the road was by young men,
stealing of the plaintiff's bike and riding by the plaintiff's house the same
week on the stolen bike was a young man, provoking the plaintiff to fight
at the library was a young man. perpetrators are in groups of 2 or more,
usually, and may be white or black. When the young men do their part
they are usually dressed all in black or black and white.
188. This entire prior paragraph was included in the Federal
suit in 2007 just before an attack (case 07-1940 filed in Washington D.C.)
The case was for several weeks illegally denied a case number then, although
D.C. did not deny jurisdiction, they refused to hear the case but remanded
it to Michigan in violation of due process. Then the plaintiffs house is attacked
by two men wearing black hooded sweatshirts, just as stated in the complaint.
When the plaintiff calls the police he is attacked, beaten, tasered, choked and
almost killed by the police. Bond is set illegally at 150,000.00, and the plaintiff
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is forced to undergo a government psychological evaluation to have him found
incompetent to stand trial and be put away forever and is charged with 3 felonies.
Then, when the plaintiff gets his own evaluation done first, they are outraged. After
that, when the plaintiff dumps 2 conspiring attorneys and wins the trial, the
prosecutor yells at the jury "but he's suing the FBI"! The intentional, malicious
retaliation here is obvious to anyone, is pure terrorism and attempted murder.
Plaintiff had to pretend he was dead and a local news crew to show for the the
beating, choking, and tasering to stop. It was broadcast on wxyz channel 7 news.
Channel 7 broadcast a report of the incident on the news with a video, and it was a
complete outrageous fraud and defamation. They cut and edited the tape to a point
it was nothing like what happened. They took out the whole first few minutes of
the police brutality and beating and one of the taser strikes and manipulated
the story in favor of the police as a form of deception and filthy propaganda.
189. Then when subpoenaed, WXYZ CHANNEL 7 refused to provide the full
length version and said they destroyed it, simply outrageous, not only that, but
the prior attorney Paul Shoenbeck also destroyed his copy of it after meeting with
prosecutor at the prosecutors house. Everyone was making deals to destroy the
evidence because what it really looked like was an attempted murder by the police.
Not only that, but in conspiring to present false testimony, channel 7 stated that
one of the news ladies from channel 7 was actually going to testify against the
plaintiff. But, after the conspiring federal court appointed attorney Sharon Woodside
was fired by the plaintiff, WXYZ channel 7 then decided not to provide their false
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testimony any longer. Plaintiff spoke with Richard Bernstein, and he showed
absolutely no concern for constitutional rights and his attitude was careless,
pompous, and negligent. He made the comment that he would go along with what
the other attorneys were doing and he would not help the plaintiff. Not surprisingly,
WXYZ channel 7 does most of their commercials, so this again is additional
obstruction, negligence, malpractice, and discrimination.
190 The denial of due process by the Wayne County courts is the primary
reason why the plaintiff is now in such a financial situation. The loss of his
house was caused by the illegal denial of a decision in his favor when he
won as a matter of law but denied his constitutional rights by Judge Baxter
and Judge Stephens of the Wayne County Courts and the Michigan Court
of Appeals and also denied a jury trial in conjunction with the blacklisting
for professional positions and the interfering of business relationships by
DDC, FBI, Homeland Security, State Attorney's offices and others.
191. The intent is to provide the plaintiff no way out, and it was inevitable
the plaintiff would lose everything. An attempt to find a roommate, rent the
house, or any other effort, just like the plaintiff's company, all options would
be made to be futile by the acts of the defendants, and the plaintiff took two
and a half years renovating his house. Certainly, the equity lost due to the
denial of due process rights is a consideration in the total losses.
192. January 8, 2008 plainitff again attempted to see his daughter and hired
attorney Ed Horan. Ed horan conspired with Judge Sjostrom to prevent any motions
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from being heard in court and denied visitation. Ed Horan took a deposit and signed
a contract to represent plaintiff then did nothing but conspire with the judge to
obstruct visitation in violation of the clear visitation orders. He even said, “another
attorney might file a motion for contempt and leave blood all over the court room
floor, but I am not going to do that”. That is how obviously in the right he knew the
plaintiff was. He mentioned that federal civil case was an issue that came up, so the
judges in Florida acted in retaliation and with knowledge of the federal civil case.
193. The plaintiffs efforts to sell his house have also been blocked in
efforts to deny a realtor. Just as they interfered with other business
relationships begin normally with a realtor and ends with a no show and
denial by the realtor, wasting time, obscure knowledge of plaintiff, denial
of completion while pending foreclosure. All to put the plaintiff "out on the
street" and waste his time in a sale by making it" break even" as the realtor
Bill Bury of Remax Partners stated making the effort futile and plaintiff pay
all costs in a unreasonable proposition given the equity, even in this market,
just as they blocked the sale and transactions of the plaintiff's Corvette.
194. The plaintiff called Remax, the call was handled by one realtor by
the name of Kathy, she handed it off to Bill Bury, after stating she needed
to check on some things, who called back and took a non specific walk through
and tried to talk plaintiff into filing for bankruptcy and "sticking it to the
mortgage company" and stringing out the foreclosure. He stated plaintiff
should call a bankruptcy attorney and maybe plaintiff do some of the work
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himself. plaintiff called Mr.Bury back the following day and stated he wanted
to list the house which seemed to annoy Mr. Bury.
195. An appointment was scheduled to take listing pictures on 10:00 a.m.
Saturday. September 2, 2007 Mr. Bury doesn't show, but calls at 10:00 after
the house is ready and states that he will give to another broker. Then calls
the plaintiff back a few minutes later and says nothing on the phone and
hangs up. The other broker by the name of Mary calls the plaintiff and states
she is too busy and would have to schedule at a later date and Bill told her
that the plaintiff was looking to "break even". Homeland security would make
nothing easy as they track every call like the FBI stated "if things got worse".
(exhibit#48 forclosure notice on plaintiff's house). Then the the federal Judge and
defendants attorney mention the transaction as well as work done to the house.
196. Mr. Green at DDC stated they would make it so "nothing was easy"
for the plaintiff and he would have to "go to another country" to get a job and
plaintiff would have to "kill his parents" or "rob a bank to have enough money
to see your daughter". Crawford stated "everyone will be against you". Just as
the State Attorney in Florida stated that bringing a retired Michigan Judge
down there he would be made to feel like a "fish out of water". The Willie
Meggs also stated to the plaintiff that he should get a law degree, surely for
him to also block any law practice the plaintiff would try to establish. These
and others, are blatant illegal acts of civil war and oppression on a citizen
of the United States. A restraining order will likely be required against some
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of the defendants. Green made the comment about the plaintiff never seeing
his daughter again in 2005; and since 2005 all contact the father had with his
daughter, including phone calls, has been blocked. Bob Green clearly had a
role in the continued illegal kidnapping and abduction just as Judge Davies
told the plaintiff he would work for Detroit Diesel before he even got the job. No
employer in their right mind would ever even consider making such outragous
disturbed comments about someones child. Obviously, there was prior knowledge
and malicious intent. Clearly this is an intimate and incriminating connection.
197. This behavior is consistent with the plaintiff being told by Leon
County Sheriff's Deputy Meeks that he should "stay up in Michigan" and that
the plaintiff is only making it harder on his daughter by trying to see her
and that "the more you come down the harder we will make it for her" just
as Bob Green stated "maybe you just wont be able to pick her up" and
mentioned plaintiff would have "rob a bank" or "kill your parents" to have
enough money to see his daughter again. It is all intertwined to take all the
plaintiff's money his child, health, dignity, home and future and make every
effort futile so as Mr. Green put it "nothing will be easy" and when Ed
Crawford stated "everyone will be against you" that meant everyone and
was not only entrapment but a declaration of civil war on a U.S. citizen.
198. Since the plaintiff will no longer have the protection of his own
property the defendants had intensified the harassment such has been
done after filing suit to retaliate. The plaintiff is offensively touched, or his
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personal items touched while shopping for food, or he is followed, every time
he leaves the house. People drive by laughing out loud at the plaintiff for
no reason, the plaintiff's windows are knocked on at night by kids, then
they run. Young men walk by the house talking out loud about how easy
it would be to steal the plaintiff's car. This is a component of the dire
predictions of illegal acts to accomplish and make good on the threats by
Detroit Diesel, Homeland Security, FBI, Florida and other law enforcement,
Florida and Michigan Attorney Generals, former wife, and others. Again,
reference Kotel comments and Cointelpro.
199. The former wife called Saturday Aug 11, 2007 to make a point of
asking where the plaintiff is going to be living. The plaintiff has not conversed
with her or anyone down there about anything concerning the foreclosure and
she does not usually call but to harass. Clearly the Florida authorities are
keeping tabs and other perpetrators informed on the progress of their plan.
SIXTEENTH COUNT
SEXUAL HARASSMENT AND DISCRIMINATION
SEVENTEENTH COUNT
VIOLATION TITLE VII OF CIVIL RIGHTS ACT OF 1964
200. All paragraphs are realleged and reaffirmed as if set forth herein.
201. The sexual harassment is composed of several perpetrators in an
extended period of time continuing to this day. The circumstances in
Florida, with Detroit Diesel, and the FBI and Homeland Security all include
related components of continuing sexual harassment and or discrimination.
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202. The daughter was abducted and father kidnapped and falsely
imprisoned based on sexual discrimination. Child abuse charges were
not filed against the former wife for attempting to coerce the child into
pornography. If two men had done the identical act they would have been
certainly immediately charged and jailed for such acts on a 7 year old.
In the meeting with the Florida State Attorney and agents the comment
was made "you want us to do for you what we did for her". The plaintiff
made it clear the difference was that the child is in danger and she actually
did something illegal as opposed to the baseless acts they did to the father.
203. When Detroit Diesel found out about the Florida case and the
Director Ed Crawford commented about the plaintiff having problems
with his former wife they immediately initiated a campaign of sexual
harassment against the plaintiff by Mary Cheeseman and Kim Gyenese,
co workers of the plaintiff who had previously posed no problems at
all. There were also extreme perverted acts by Bob Green.
204. Mary Cheeseman, who sat to the right of the plaintiff, had
extra cable added to her computer and her monitor was shifted from
inside the cubicle, to awkwardly facing directly toward the plaintiff
to stare over the monitor at the side of him constantly when they
used to be more or less back to back. She was the only one in the
department to have her computer position changed like this.
205. Mary and Kim Gyenese then began to tamper repeatedly with
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formulas on spreadsheets, that the plaintiff developed for specialized
purposes, they were instructed to do this act maliciously to cause
errors and distress. The plaintiff utilized a program in the system to
track which computer user and login ID made modifications to the
programs and they were traced to these two people.
206. The plaintiff had a conversation with Kim Gyenese a couple
of days later in the basement by the EDS offices. The plaintiff stated
that he knew what they were doing, Kim initially denied it but
when confronted with the facts of the tracking she stated "okay,
I did it, so what?" apparently confident she had been given permission
or instruction to do so and had no concern for the consequences and
even threatened to go to human resources for harassment although she was in fact the one harassing the plaintiff. She never did go to
H/R, the statement was just another baseless threat to harass the
plaintiff even further.
207. Plaintiff found shortly thereafter that agencies had been
contacted and he had been blacklisted, and if a position was
found the government agencies would interfere with other perspective
employers and the effort would be futile. The only option was to
stand by the constitution and his civil rights and hold them legally
accountable for the illegal behavior. Incidentally, the plaintiff was
proven correct when even business relationships were illegally
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interfered with when he later tried to build a company, only to be torn
apart by Homeland Security in acts having nothing to do with security
of the country at all, intent of the agency itself, and in violation of the
Constitution and Bill of Rights.
208. When Kim left the company, several months later, Mary began
harassing the plaintiff more than ever by intentionally changing spread
sheets nearly every time she would use them, requiring the plaintiff to fix
formula problems when she was simply to insert data. She would also miss
posting thousands of hours causing the government contracts to be
overcharged by increasing the labor and burden rate. The supervisor
Bob Green refused to address the contract issue and allowed the massive
errors to go unchecked intentionally inflating the rates for years.
209. While working on a separate project that Mary was to supply
personnel data, the information was not able tie and had to be reviewed
by the plaintiff several times. In a conversation with Mr. Green in regards
to the information Mr. Green stated, "she just doesn't like to do her
job" and "she's an asshole"
210. In effort to humiliate the plaintiff and discriminate on other counts
Mr. Green gave this so called "asshole" who "doesn't like to do her job" 10%
pay increases and promotions every year until she was making more than the
plaintiff; even though she had less education, responsibility, seniority,
abilities and had a difficult time doing operations. This was in conjunction
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with the plaintiff getting incrementally lower to no pay raise (10%,5%, 0%)
and being put on a fraudulent performance improvement plan with no basis
in fact while communicating this to other members in the group with less
seniority and no need for such information and even adding additional jobs
to the plaintiff's work load. Mary was also asked if she wanted to be a
manager which she turned down because it would have been more work,
this was also in violation of position requirements as company policy. The
intent is to give others what the plaintiff earns, has, or what they believe
he would want and is carried over to other like incidents.
211. This is just as happened with the City of Southfield when they
trespassed on the plaintiff's property cut off a huge branch from a
100 year old tree in the front of the house, dragged it across the lawn
tearing up the grass, ground it up and gave the chips to the lady across
the street and threw rocks from the truck on the plaintiff's lawn rather
than cleaning the area. The city never provided notice and a no
trespassing sign was clearly posted. One of the employees made the
comment that "If the feds say so, then you have to do it". (see exhibit
#35)
212. There were times churches were involved. When the plaintiff was
taking his daughter to Christ Our Savior church, things became increasingly
more harassing and difficult in the day care program. The plaintiff was
charged late fees on a small overdue balance when the mothers were not,
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and when plaintiff asked why he was paying late fees when the female
members were not, even when they were thousands in arrears, the plaintiff
was told "that is them". The plaintiff was later sued by the church for a
$347.25 balance in an outrageous act that other members said they had
never seen. This was additional acts of sexual discrimination and malicious
prosecution by the defendants. (exhibit# 49 summons and response) Larry
Butler at DDC asked where lauren was going for daycare before this happened.
213. Although Mary did take adverse action against the plaintiff by
direction of her superiors, she did make the statement, before the plaintiff
filed suit in September of 2005, that the plaintiff should "sue them after what
they have done to you" and "I'm sure what they have done has caused some
damage".
214. At Detroit Diesel, when the plaintiff asked Mr. Green if he could do
more than any other analyst he stated "definitely" and when requested for
detail of what constituted the poor evaluations no reason was ever provided
clearly demonstrating his own knowledge of the untruthfulness of his
own evaluations as having no basis in fact.
215. Mr. Green also proceeded to sexually harass the plaintiff by
coming up behind the plaintiff while he was seated at his computer and
reach over his shoulder rubbing the plaintiff's chest. Mr. Green also would
rub his crotch while looking at the plaintiff's genitals after pushing himself
out from behind his desk and spreading his legs. These sick, perverted acts
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would usually occur while working late in the evening, intended to effect
the plaintiff's ability to sleep. This has all been admitted to in prior cases.
216. The plaintiff was also sent perverted e-mails and sent a strange
e-mail which had a jpeg picture of a woman with horns holding a baby,
she was apparently intended to look like a version of Satan.
217. An engineer by the name of Larry Butler joined the controlling
group and was trained by the plaintiff. The plaintiff had car troubles and
Larry, having an extra car, offered to sell the car (a 1990 Grand Prix) to the
plaintiff on monthly payments if he could fix the mechanical problems
it had, he mentioned he had done it before (sold a spare car) to someone in
the company.
218. After the repairs were done, he said the car was his wife's and she
said she did not want to sell it and made the plaintiff speak with her
several times then afterwards required the plaintiff to return the car. After
the return Larry admitted he didn't need her permission to sell it. The
wife was simply in it for harassment purposes (which would become a
common theme with homeland security) to cause issues when the plaintiff
needed a vehicle, was previously promised, then again denied after several
dishonest fluctuations in the story.
219. As previously mentioned female operatives of Homeland Security
have been heavily involved in alienating the plaintiff to neighbors or contacts
especially to other women who the plaintiff may communicate with, even
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at churches, doctor's offices, or hospitals in efforts to do harm to the plaintiff
or deny him care.
220. The problems with health care would usually include the male
doctors denying service but usually the female doctors and nurses did the
overt specific acts infecting ear, injecting with allergens, rupturing vein with
needle causing hand to turn blue, excessive x rays in one position causing
poisoning. The illegal assaults from the former wife, failure to press charges,
attacks from women at the daughter's school and Meeks telling them that he
would arrest plainitff if they would just "say" that plaintiff hit them when
the plaintiff was the victim of the attack and provocation. The statement
from Willie Meggs "good for her if she can get away with breaking the law".
The retalitory police attack from Southfield Police was a female Police officer
doing the tasering shown to be enough to kill alone having been done twice
with full voltage. Not to mention the denial of jury trials and due process
rights by female Judges Coloca Johnson,Dekker, Baxter, Stephens, Attorney
General Quionnes (FDR), Attorney Marilyn Morris, Tann Hunt, Judge Robert
H. Cleland and other perpetrators.
EIGHTEENTH COUNT
ATTEMPTED MURDER
221. All paragraphs are realleged and reaffirmed as if set forth herein.
222. The defendants, with federal assistance, had contact with health
care providers and doctors to monitor the plaintiff's treatments and influence
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doctors to prevent proper care and or recovery and cause further illness and
death to the plaintiff. This was in conjunction with blacklisting, destroying
plaintiff's company, contacting neighbors and family, extortion, denial of due
process, interfering with contact with his daughter, retaliatory action,
increasing harassment directly after doctors visits and attempting to render
any treatment ineffective, kidnapping, false imprisonment, and others.
223. These illegal and criminal actions were taken with the assistance
knowledge and support of the FBI, Homeland Security and other state
and federal agencies in acts of terrorism and civil war.
224. The actions taken by the defendants with the direct and intimate
knowledge of the plaintiff's illness (s) and suseptablities constituted direct
and repeated attempts to kill the plaintiff. The plaintiff was on several
occasions denied treatment, improperly treated, or intentionally poisoned
by doctors and or nurses involved in his care. One such instance occurred
with Allergy associates on Orchard Lake road and the Doctor Rolla
Bakari-Panza in which the plaintiff rather than being given a cortisone
shot was injected with a massive dose of allergens which caused the
plaintiff to become very dizzy and bleed perfusely from the nose and
break out in hives. This act could have easily cause the plaintiff to go
into shock or have a heart attack.
225. The plaintiff approached doctor Panza with the findings and stated
that another doctor did a blood test and found there was no artificial
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cortisone in the blood tests and that she was trying to harm the plaintiff.
Dr. Panza did not deny that fact and was desperate to find out the name
of the other doctor was, as if she would go after him.
226. This is the same doctor that ran allergy tests on the plaintiff
and reported that every one of the tests came out negative to mislead the
plaintiff and deny him proper treatment. When the identical tests were
performed by another doctor the results were completely different from
the results from Dr. Panza. This was several identical tests which renders
incompatibility on all counts statistically nearly impossible having stopped
all medications before testing. (exhibit #43 allergy test comparisons)
227. Homeland Security and other defendants with knowledge of the
plaintiff's medical problems and allergies would instruct people to intentionally
attempt to provide food while illegally incarserated that would cause the plainitff
allergic reactions, create a never ending campaign of harassment to intensify
the effect, and instruct doctors not to provide the plaintiff proper medical attention
in attempts to cause further harm and eventual death of the plaintiff. Since
the plaintiff wrote his book and has found other who have been persecuted
nearly all the health problems have subsided and the plaintiff is ready to continue
with this case through all appeals if necessary and stay for the long haul.
228. The plaintiff went to ENT surgical associates Sept. 2002 to get help
for a severe allergic reaction and stress and was given several tests by Doctor
Rochen but was given nothing to reduce the severe swelling. plaintiff asked
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him for some sort of medication for a severe reaction and no cortisone shot
was provided. He stated he would take care of it the "natural way" while the
plaintiff was in severe pain. The plaintiff had to take his own doses of
Ibuprofen to reduce the swelling enough to even see clearly. The plaintiff
then went to see Dr. Brandes who provided no assistance and stated that
he could not help the plaintiff and was intentionally rude and forceful to
aggravate the condition, which also effected balance. He pushed the
plaintiff with force when the plaintiff was leaving the office, the condition
was known to get worse with stress and Dr. Brandes, with malice, provided
some personally, to intentionally aggravate the condition.
229. Later, when the plaintiff had to see another doctor for help, he
explained what happened and the doctor said "it was doctor Brandes wasn't
it?". The plaintiff never mentioned what doctor or where he had been seen.
Dr. Brandes evil tactics are apparently very well known in the medical
community. His name was the first name mentioned as an immediate
response by the other doctor.
230. The plaintiff was seeing Dr. Whebe at DMC health care center,
plaintiff was told to come in to a doctors office after complaining that
the medication was not working and caused a very sore throat and chest,
the doctor instructed the plaintiff to come in and the prescription would
be changed. When the plaintiff arrived he was asked if the plaintiff had a
family history of heart attacks at a young age and was not given a different
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medication, but more of the same which was making him ill.
231. When the plaintiff came back to work Mr. Green made comments
about the doctors visit and that he knows Dr. Whebe. Green was never
informed as to who the plaintiff was seeing for treatment. The doctor also
mentioned a trip being scheduled for the plaintiff that only employees
at DDC would have known demonstrating knowledge of specific private
facts shared by the perpetrators by using the company insurance card.
232. When the plaintiff went to Botsford hospital emergency room he
was put into a room where the nurse was to take blood. The nurse
inserted the needle several times on different angles without removing
it completely, stating she could not find a vein, which no one has ever
stated to the plaintiff, and caused the vein to bleed under the skin and
turn the plaintiffs hand blue then a pregnant woman wearing all black
walked in and the nurse said to her, "I blued him" and hung up a sodium
drip which plaintiff asked them not to attach after reading the label. The
woman in black stood there a few minutes not saying a word then left.
A security guard then came in and told the plaintiff he would have to
leave and they could not help him. (exhibit #44 Botsford receipt)
233. The plaintiff's supervisor, Mr. Green, would make comments about
a doctors visit and even mention the doctor by name when no information
as to the doctors name was ever mentioned to Mr. Green, he would then
harass the plaintiff and have him do jobs that would specifically aggravate
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the condition he had gone to the doctor to be treated for.
234. The plaintiff was also seeing Dr. Michaelides for ear infection,
he refused to medicate the plaintiff's bacterial infection, intentionally
mislead the plaintiff about the condition and severe pain and refused a
tube for the inner ear infection until the plaintiff told him that a
doctor in the emergency room said he should. After he put the tube in,
he did not prescribe any antibacterial ear drops for the infection, the
plaintiff finally got the drops from yet another doctor with pills and
it cleared the infection. This infection, if left alone, would likely have
caused a cancer, or tumor of the brain or inner ear. Dr. Michaelides
intentions were to cause permanent injury and or death to the plaintiff
by establishing a chronic condition and extort insurance money. After
the plaintiff informed Dr. Michaelides that another doctor completely
refuted his findings and cured the bacterial infection June 5, 2004, he
moved his practice to Atlanta a few months later in November of 2004.
(exhibit#45 10.19.04 Michaelides letter)
235. The plaintiff went to Oakwood emergency room on March 25, 2005
and had a cat scan done and some x rays. One radiologist was taking the
x rays and another one comes in and states that she needs to make some of
one certain neck area. She proceeded to take approximately 15 (additional )
x rays of the exact area without moving this caused radiation poisoning and
the plaintiff to become very ill and throw up when he got home. After she
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had taken the additional shots she stated to the other radiologist that the
ones that were originally taken were okay, and she didn't even need the several
she had just taken. (exhibit#46 Oakwood receipt)
236. The plaintiff saw Dr. Seel to have the tube removed once the
ear infection was clear and he was instructed to keep water out of the ear
to prevent infection. When the plaintiff went in for a check on the
ear, Dr. Seel was out and doctor LePoudre took his place. While
looking in the ear to inspect the paper over the wound she took small
plastic bottle and squirted hard, a large amount of "water" or liquid directly
into the healing ear onto the injury intending to cause an infection to the
complete shock of the plaintiff , this act did in fact cause a reinfection
due to her malicious act. (exhibit#47 ENT LePoudre receipt)
237. If the plaintiff did not use his principal insurance card, there was a
much better chance of receiving proper care. The insurance company
through Detroit Diesel supplied the defendants information on specific
visits. Clear connections can be drawn between this, and actions taken by
companies the plaintiff was dealing with and improper work performed
and defendants efforts to make good on their numerous threats and cover
other prior repeated illegal acts and commit new ones. Once the FBI is involved
in persecuting someone, as happened with the kidnapping in 97', they keep
tabs on that person indefinitely because they are paranoid of retaliation; and if
the victim does not submit to illegal oppression and fights it, the terrorism continues
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and if sued they try to make the person disappear by illegal incarceration,
fraudulent psychological evaluations, false testimony, trumped up charges or
assassination and planted in a cornfield somewhere. All of which is validated here
by circumstances happening to a completely innocent pastor and author. Again, a
textbook case of Cointelpro terrorism.
NINETEENTH COUNT
DEFAMATION (LIBEL AND SLANDER)
238. All paragraphs are realleged and reaffirmed as if set forth herein.
239. plaintiff was defamed when falsely imprisoned and friends and
relatives were made aware. There are also continuing acts in that the plaintiff
is illegally being denied visitation with his daughter as if he has done
something wrong, and the redicilious and fraudulent grand theft charges,
although dropped, still show up on the plaintiff's record as an entry.
240. The reason for the Grand Theft charges still showing on the plaintiff's
record, even though they were dropped, is to defame the plaintiff forever and
label the plaintiff a "crook" to make any entrapment scheme such as trying
to "stick it to the mortgage company" as the real-estate broker Bill Bury
suggested, look that much more believable or make getting a job nearly
impossible in the accounting field. The Willie Meggs chose Grand
Theft because it plays right into plaintiff's career as an auditor, analyst
and accountant. The 2nd Circuit Court of Appeals also posted a ridiculous and
intentionally fraudulent decision on the internet when all allegations were
admitted to and the amended claim was unopposed. This is posted online and would
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show up when the plaintiff would attempt to secure a job; falsely defaming
the plaintiff while also maliciously denying a decision won as a matter of law.
Again, refer to the Cointelpro findings and specific tools they use.
241. After the Willie Meggs Conspired with the plaintiff's defense
attorney(s) and convinced them to throw the case, not only was the fraudulent
and nolle processed grand theft charge put on his record to stay, but the
defamitory mug shot is posted online. Homeland Security uses this information
that the plaintiff has a grand theft and other made up charges on his record
when communicating with anyone they wish to convince to take adverse
action against the plaintiff. Both postings are by Florida authorities and
only Florida authorities and are intentionally to illegally label the plaintiff
a crook or a criminal for the rest of his life. There is also posted by The
State of Florida a mug shot of the plaintiff when he was kidnapped which also
shows up on a Google search.
242. Mr. Moye', the plaintiffs criminal attorney in the fraudulent grand
theft, prior to being hired stipulated that nothing would be allowed to show
up on the plaintiff's record so as not to adversely effect the plaintiff's career
or future, but instead initiated the defaming, illegal, nolle processed charges
to be listed violating his responsibilities to his client.
243. The Leon county Sheriffs Department defamed the plaintiff in front
of his daughters friends by denying his right to custody and visitation
also contributed by Desoto Trail Middle School staff and by the actions of
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officer Meeks. The plaintiff's daughter even said, "why are trying to make
you look like a bad daddy, why are they doing this?" (see exhibit#17)
244. Detroit Diesel manager Bob Green filed a report with the FBI and in
the complaint stated many slanderous accusations not founded in fact but
in an effort to destroy the plaintiff's life, liberty pursuit of happiness and
career and do irreparable harm to his entire future.
245. The plaintiff was fraudulently evaluated in his job performance
evaluations make specific reference to derogatory terms to untruthfully
describe the plaintiffs performance without detail to substantiate, the
plaintiff is left with 5 1/2 years of his employment which cannot be used
for a reference and makes a proper, marketable resume impossible.
Additionally, the evaluations to not elaborate on what accounts for the
substandard performance and in so gave the plaintiff nothing to correct
or act upon and is defamation per se. Lower level employees with no
relevant interest in the evaluations were provided notice of the adverse
evaluations given to the plaintiff.
246. The FBI contacted family members and made several false misleading
and defamatory statements about the plaintiff such as the plaintiff is "high
strung" and had "a nervous breakdown" to defame the plaintiff, cause doubt,
and interfere with family relations and contact.
247. As stated by Ed Crawford a director at Detroit Diesel, they were
going to make it so that "everyone" was against the plaintiff. This included
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staging incidents designed to parade a wide array of people around the
plaintiff at work and outside of work to be arbitrarily offensive or rude and
to create a wide ranging and oppressive environment to prevent the plaintiff
from functioning in a productive way in society with the malicious intent to
provoke extreme anxiety and a complete destruction of the plaintiff's freedoms
and liberties and any prospect of future success. All of the statements
made at Detroit Diesel also represent the activities still being pursued by
Detroit Diesel, Homeland Security and the FBI and other authorities against
the plaintiff in violation of the U.S. Constitution and basic internationally
recognized human rights.
248. Communications that the FBI and Homeland security had with
neighbors, business contacts and others constituted defaming the plaintiff
and conspiring with contacts in illegal acts of fraud and other torts in taking
adverse action against the plaintiff without any justification, basis in fact, or
legitimate legal reason but in an attempt to adversely label the plaintiff in
ways to make it appear that everyone was against the plaintiff. The game
plan was clearly stated by Leon County Sheriff Larry Campbell, Deputy John
Meeks, Mandy Luttenton, Florida Attorney General Willie Meggs, FBI agent
Dave Kotel, FBI supervisor Toni Charabot, Supervisor Bob Green, Director
Ed Crawford, Vice President DDC Walter Puetz and others. The statements
that the plaintiff would have to "go to another country to get a job" or "rob
a bank" or "kill your parents" to have money to see his daughter and that
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"everyone will be against you", "the war will be against you" and "kind of like
being in a prison, isn't it?" are so outrageous and extreme that the acts to
make good on them would also have to be outrageous and extreme and do
in fact include the illegal actions of people employed by the government as
evidenced by the signed documents, exhibits, actual statements and factual
occurrences and admissions in legal proceedings.
TWENTIETH COUNT
CHILD ENDANGERMENT
249. All paragraphs are realleged and reaffirmed as if stated herein.
TWENTY-FIRST COUNT
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
250. All paragraphs are realleged and reaffirmed as if stated herein.
TWENTY-SECOND COUNT
VIOLATION OF THE FOURTH AMENDMENT
ILLEGAL SEARCH AND SEIZURE
251. All paragraphs are realleged and reaffirmed as if stated herein.
TWENTY-THIRD COUNT
VIOLATION OF THE EIGHTH AMENDMENT
CRUEL AND UNUSUAL PUNISHMENT
EXCESSIVE FINES AND BAIL
252. All paragraphs are realleged and reaffirmed as if stated herein.
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TWENTY- FOURTH COUNT
POLICE BRUTALITY
253. All paragraphs are realleged and reaffirmed as if stated herein.
CONCLUSION
254. The plaintiff's entire life and future have been illegally , maliciously
and without cause destroyed. Everything he had, child, career, home, savings
retirement, freedom, liberty has been illegally continually and violently
ripped away by the illegal and criminal acts of federal government and
others. These acts have been intentional, and violently in opposition to the
Constitution of these United States and have included attempted murder
and continuing attempts to put the plaintiff in prison one way or another
and completely block his access to the judicial system, and in fact use it
illegally as a weapon. This is and represents a civil war and acts terrorism
against all citizens of the United States and warrants a detailed Senate
investigation as to what these criminals have done as a whole to our country
and innocent people. Surely these and other groups of tyrannical freaks have
already killed and imprisoned many other good innocent American citizens
before, just as they have done and are attempting to do to the plaintiff
right now; just as the Chruch Senate investigation on the illegal FBI Cointelpro
program verified. It is is still being used. Wikipedia search Cointelpro.
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PRAYER FOR RELIEF
255. WHEREFORE. The plaintiff, Pastor Daniel L. Meier, requests a trial
by jury and that the court adjudge and decree the defendant(s) are liable for
the torts and other conduct both civil and criminal asserted herein and enter
a judgment for Pastor Daniel L. Meier and against the defendants listed herein
and award Pastor Daniel L. Meier compensation for all damages in addition to:
A. Allocated monetary damages attributable to the defendant to
compensate Pastor Daniel L. Meier the costs that he bears as the result of the
defendants conduct, in excess of the jurisdictional requirements of the
court.
B. Punitive damages in an amount to reflect and compensate for
the fact the defendants conduct was malicious, willful and wanton such
as to demonstrate a reckless disregard for the rights of the plaintiff.
C. Exemplary damages to establish that this behavior is outrageous
and intolerable in a civilized society.
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