> I was targetted again, stalked and pulled over.
>
> Dawn likely is hte motivator of this entire thing.
>
> at 1:20 AM when plenty of drunks are on the road, Greenwood Village
> pulled me over on my bike cuz I didn't have a light - but they used
> this to see if I'd be violent and they also had me being filmed they
> told me.
>
> I lied and gave them a fake name to see what they'd do. They continued
> to dick around and asked if htey could search my backpack or my fanny
> pack because at night people on a bike are known to be theives with
> those two items. So to play games with them I said no. Then they ran
> my fake name and asked me for a social security number and I told them
> I didn't know it because I haven't used it for years because I haven't
> worked.
>
> So then they continued to try fear tactics to make me think I was
> going to jail if I didn't give them some verifiable evidence that I
> was "Mike Jorgensen", so I told them that's who I am nothing else I
> can do.
>
> It sounded like Dawn Newbon was the police dispatcher, thus she was
> the motivator of htis entire violation of my space, this preying on my
> sovereignty and interferring with my life again. I could be wrong but
> it sounded just like her and her having a police dispatch background
> it'd make sense.
>
> Eventually I decided to play them a little and said "Ok if you want to
> check my backpack out you can", to see what they'd do. I had my IDs in
> my fanny pack. SO after they didn't find anything in my backpack (and
> they knew they wouldn't, they clearly were sent to pull me over and
> were waiting for me all night), he asked if he could see inside my
> fanny pack. I waited and said "no I figure I gave you enough". Then I
> 2 minutes later said ok you can see in here if you want.
>
> Clearly witchcraft is running GreenWOod Village Police Department, and
> the majority of what this police department does is illegal, selective
> enforcement for religion is illegal, no matter how undetectable it is.
> I was cited for no light on my bike and giving false information to a
> police officer.
>
> This whole ordeal I believe was motivated by Dawn Newbon because DAwn
> is sick, she believes that when police are being abused and
> tyrannically against me, I shouldn't be violent, she proved this by
> askign Alex to do his Florida skit with his assault charade. Because
> Dawn Newbon doesn't encourage me to be violetn when police are being
> corrupt, she is screwed up - relative to the independence or
> 'self-determination' reality and aspirations.
>
> She is so obsessed with her witchcraft and control of others and being
> vindictive behind the scenes, she can't understand what it is to be
> defensive of private sovereign boundaries like I am. They keep
> violating them and abusing law-enforcement to do it.
>
> If they tried to arrest me lastnight I would have fought them or just
> took off. I could have easily gotten away next time I probably will do
> that. BUt i wanted to see what they'd do when I gave them the fake
> name.
>
> The corruption is abusive and steep in GreenWood Village, Colorado
> government.
Is this true, chas?
Which part?
Greenwood Village is very wealthy; they have a very insular attitude. You
either live there, have legitimate business, or need a lift out of town.
Zahn is a hobo, and they'd want to know why he was there at all.
Our situation was a bit different. USWest (Elizabeth Kiovsky, Bill Stephens,
Markus Merritt, Tamara Gartin) thought it would be useful to have us slapped
around by the police, as a demonstration of power and to gain advantage in a
civil matter (divorce). On the basis of manufactured evidence, they
construed a non-crime by Gartin- and even that fell through, and they had to
drop the charges as unfounded at all.
Of course it took a couple of years of fucking with him first. They crapped
out on the day they had to prove any of it.
With me, they sent two GV cops (Carr and Stadterman) and one Aurora Swatzi
(Pete Page) to intimidate me into not allowing Gartin to use my fax-machine,
or witness for him in court. I said 'Witness Intimidation', Page split
instantly and the two cops just dug it deeper. It's all documented.
I had been warned by attorneys, warned by cops- and sure enough, got false
charges lodged against me, arrested and detained for days.
All for being a witness in court, and allowing a man to file legal process
through a fax machine.
I never played any games with them though, and wasn't in GV at all. They had
to cross jurisdictional lines to come fuck with me.
Chas
Is that the whole "Gartin was in Jail" thing I rememeber a while back? The
whole thing was about a divorce gone bad? Geez...
It was a tax/customs thing that started it; the divorce only exacerbated it.
Yeah; hell of a thing, hunh?
This was in the badolddays of the IRS- when they didn't even go by their own
regs, much less the law.
Chas
_____________
F a x S e r v i c e
To: Officer Souse From: Steve Douglas, Gartin
Fax: Relay: 739-9824 Pages: 11
Phone: Message: 364-0403 Date: August 22, 1996
Re: Markus Bernard Merritt lies again! CC: See Certificate of sending via
FAX page 11
l Comments: Hello Officer Scouse,
Hope all is well with you today. I have read the complaint that Markus
Bernard Merritt has filed with you. There is no truth in any part of it.
In order that you have a more realistic view of the situation, one of the
latest filings with Jefferson County District Court is included. If you need
further information please don't hesitate to leave a message for me with
Chas Clements @ 364-0403 or just FAX back. As a result of these problems, I'
m a bit down and out at this moment and have to rely on friends to relay
messages. Just a temporary setback, praise God.
The Greenwood Village Police Department has always been very gracious to me
as a specialty instructor and I have enjoyed my associations with you folks.
I want to clear the air on this fraudulent issue before we get too much
older, so I would be pleased to drop by at your convenience to discuss the
matter, or if you would like me to call at a specific time, please leave a
message and plan for a call the next day.
What Mr. Merritt is complaining about is upfront Litigation in the proper
venue and in all manner, legal. What follows is an example of what Mr.
Merritt claims is harrassing. If you would like copies of everything that
has been sent to Mr. Merritt's boss, who I'm also suing, please let me know.
I don't want to burden you with more legaleze paperwork than you care to
deal with, but it is important to me that you understand the truth in this
matter.
Thank you for your time, interest and effort in my behalf.
Sincerely,
Steve Douglas, Gartin
District Court, Jefferson County, state of Colorado
Case # 95-DR-2718 & 96C7386 - 96C7387 - 96C7388
Motion to Render Void Chief Judge Nieto's Order
April Rose, Gartin
Elijah Rock, Gartin
Steve Douglas, Gartin a Colorado Citizen
v.
Tamara Ann Zehnder, alias TAMARA A. GARTIN (a nom de guerre)
Markus Bernard Merritt, a.k.a. Michael Thomas
Pastor Robert Victor Zehnder & Dolores Jean Zehnder
and as agents for the Lutheran Church, Missouri Synod
Karsh & Fulton, P.C. "Legal Team" in the persons of:
Alan E. Karsh
Seymour Joseph
Fred Gabler
Valerie Krogman
Larry Fulton
A. Troy Ciccarelli
J. Terry Wiggins
1.. I, Steve Douglas, Gartin, the moving party and the Party Injured
inform the court that Chief Judge Henry Nieto has made a mistake in
judgment.
2.. Chief Judge Henry Nieto states in the first paragraph of his Order
dated August 15th, 1996 "The Court has read and reviewed the Motion, has
read and reviewed the documents on file with this Court, and being fully
advised in the premises,. . . "
3.. The Honorable Henry Nieto received my Motion for Summary Judgment in
case # 96-CV-1478 on August 15th, 1996 which was filed by FAX direct to Mr.
Nieto's office and is contained within the Court's record.
4.. Mr. Nieto either did NOT read my motion, or he ignored it when making
his decision to grant this Prevaricator, A. Troy Ciccarelli, Esquire his
fraudulent and perjurious motion. Either scenario is unacceptable
performance for a man in such an exalted position.
5.. A. Troy Ciccarelli, Esquire lied to the Court intentionally! He said
that I did not return his phone message. His secretary and my witnesses will
testify to the contrary.
6.. I very directly spoke with Mr. Ciccarelli that day, but his agenda was
to molest, slander, libel and harass me, and deny me my Rights as a Father.
This action is in criminal contempt of the order of the Court and in
conspiracy with listed defendants and others unknown at this moment.
7.. Karsh & Fulton, P.C., a.k.a. "Legal Team" has committed perjurous
instruments and documents to the court. This Legal Team has encouraged it's
clients to commit perjury in direct defiance of all law. This Legal Team has
encouraged and suborned its clients to defy the Court's Orders.
8.. This Legal Team has conspired and colluded with Magistrate Russell
Stuska and Judge William DuMoulin to defy and defile every Constitutional
Guarantee and Due Process and in conspiracy to deprive me of my Rights and
the Rights of my Children.
9.. My ONLY concern is for my Children. They are now in an environment
that encourages deceit, larceny, adultery, drunkenness, arrogance, violence,
ignorance of Biblical principles, and all of the evils I do not want my
Children exposed to. It is my Right as Father to protect my Children from
what I perceive to be an extremely volatile and dangerous situation.
45.. The Plaintiffs have recently became aware pursuant to F.R.C.P. 26,
(e) of the Law; aware of the requirements of a professional's Oath of
responsibility, and have become aware of a progress of:
a.. fraud, F.R.C.P. 9 (b)
b.. collusion, U.S.C.A. Title 18, section 1621
c.. extortion U.S.C.A. Title 18, section 1621, 1622
d.. perjury, U.S.C.A. Title 42, section 1986, 1985, 1983
e.. in conspiracy. U.S.C.A. Title 18 , section 1985
by the Defendants, Pastor Robert V. Zehnder & Delores Jean Zehnder, and
legal counsel; A. Troy Ciccarelli, J. Terry Wiggins, Markus Bernard Merritt,
Valerie Krogman, Alan Karsh, Fred Gabler, Larry Fulton, Seymour Joseph, and
other parties unknown to the Plaintiffs at this moment in time.
11.. Now we have become aware of the contempt of Karsh & Fulton, P.C. for
the order and direction in order of the Honorable Court as defined in
Magistrate Norton's Order of January 19th, 1996 to facilitate equal shared
parenting.
1.. The Honorable Court has had official notice of several fraudulent
documents submitted and perjuries made by A. Troy Ciccarelli. These are now
within the Court's Record and a matter of prima facie evidence of gross
perjury in all of Mr. Ciccarelli's dealings with the Court in which
Plaintiff is a Party.
45.. Presently the parties at Karsh & Fulton, P.C.; J. Terry Wiggins, A.
Troy Ciccarelli and such others and their clients, Tamara Ann Zehnder (alias
Tamara A. Gartin), Robert & Dolores Zehnder and Markus Bernard Merritt, are
all in conspiracy, in malicious contempt of the orders of the Court in Cases
95-DR-2718, #96CO3788, #96CO3787, #96CO3786.
46.. To allow such brazen prevarication and flagrant contempt for all that
is righteous and proper and lawful and truthful cannot be rewarded by
constant approval. I have observed this Court, in the person's of Magistrate
Stuska, Judge DuMoulin, and Chief Judge Henry Nieto operate in conspiracy
and collusion with this legal team of Karsh & Fulton, P. C. for over a year
now.
47.. I have observed outright lies and perjuries, in conspiracy, go
unpunished and even rewarded.
48.. I demand to know if this Jefferson County District Court is operating
in Conspiracy with Karsh & Fulton P. C. to deprive me and my Children of our
God-Given Rights to Life, Liberty, and the Pursuit of Happiness in direct
violation of the Constitution of the state of Colorado and the united States
of America.
WHEREFORE, the Plaintiffs, and them all, move this Honorable Court to Render
Void and of no effect the Order of Chief Judge Henry Nieto of August 15th,
1996 granting Karsh & Fulton, P.C. on the face of perjurous testimony to
receive and extra 20 days to reply and to issue an Order of Contempt against
each and every of the Defendants Legal Team and further relief as the court
deems just and proper in the premises.
Steve Douglas, Gartin, in his True Name and as the Proper Party Injured,
avails himself of all the provisions of the laws and statutes of the state
of Colorado and of the united States of America, which have been made and
provided for relief and restoration of tortious actions by Defendants, and
them all, and for cause, and other such statutes, made and provided, in
protection of the unalienable rights of the Citizens.
I claim all Rights and Privileges under the Constitutions of the state of
Colorado and the united States of America and at no time waive any right or
privilege of my free will.
Dated this 21st day of August, 1996.
Steve Douglas, Gartin
PO Box 114 Message Phone: 364-0403
Golden, Colorado Zip Exempt Message FAX: 739-9824
Plaintiff is Homeless and Indigent
Allow an extra 10 Days for delivery to PO Box and subsequent pickup
Please FAX for quicker response.
CC: VIA FAX Numbers Listed___________________________________
Jefferson County Court Chief Judge Henry Nieto FAX: 303-271-6270
Karsh & Fulton, P.C. Alan Karsh FAX: 303-782-0902
Bethlehem Lutheran, Inc. David Langewisch FAX: 303-238-7691
Timothy & Francisca Zehnder FAX: 303-932-2465
Federal District Court Judge Lewis T. Babcock FAX: 303-861-2233
U.S. Attorney FAX: 303-844-0098
u.. S. Supreme Court Grievance Committee FAX: 303-893-2443
U S West, Inc. Elizabeth Kiovsky FAX: 303-295-7046
Hard Copy available upon Request.
District Court for Jefferson County, state of Colorado
Case # 95-DR-2718 & 96C7386 - 96C7387 - 96C7388
Verified Motion for Contempt Citation
April Rose, Gartin
Elijah Rock, Gartin
Steve Douglas, Gartin a Colorado Citizen
v.
Tamara Ann Zehnder, alias TAMARA A. GARTIN (a nom de guerre)
Markus Bernard Merritt, a.k.a. Michael Thomas
Pastor Robert Victor Zehnder & Dolores Jean Zehnder
and as agents for the Lutheran Church, Missouri Synod
Karsh & Fulton, P.C. "Legal Team" in the persons of:
Alan E. Karsh
Seymour Joseph
Fred Gabler
Valerie Krogman
Larry Fulton
A. Troy Ciccarelli
J. Terry Wiggins
I, Steve Douglas, Gartin, the moving party and the Party Injured inform the
court that the restraining orders previously issued by the court in this
case have been violated. I ask the court to issue a contempt citations
against the defendant and set the matter for hearing. As grounds for this
request, I state as follows:
1.. This court issued the three above enumerated restraining orders on
July 2, 1996.
2.. The restraining orders were all served on the defendant without
attached affidavits, with all wrong names, and supported by perjured
testimony.
a.. A certificate of service is not attached.
a.. The Defendant violated the restraining order by doing the following
acts: Markus Bernard Merritt applied for and was granted a restraining order
against Steven Douglas Gartin. There is no such party or person.
3.. The restraining order was violated on July 22, 1996 at 5:45 - 6:15 PM
in the presence of many witnesses at my place of employment, which job has
subsequently been lost by Mr. Merritt's continued menacing harassment and
stalking.
4.. From the 8th of July until the 22nd of July, Markus Bernard Merritt
stalked my employment in a gold Saturn with license GAX7331.
5.. On the 22nd of July, 1996, Markus Bernard Merritt, falsely presenting
as Michael Thomas, deliberately entered at my employment place slightly
prior to my expected arrival. He asked about me by name, presented my two
children as his own, and included his illegitimate child of a former girl
friend and not of his wife of record Teri L. Merritt as the third of three
potential students for my particular children's class. All of these
statements were false, misleading, and designed by Mr. Merritt to get me
fired from this, the second job that Mr. Merritt and Tamara A. Zehnder,
alias TAMARA A. GARTIN, in conspiracy, have attempted and accomplished with
exactly the same modus operandi as the Golden Community Center Case.
f.. Mr. Merritt arrived and departed driving a motor vehicle in defiant
contempt of the deferred sentencing, probation and jail sentence as an
habitual offender and another probation of Arapahoe County District Court.
g.. Markus Bernard Merritt filed false information with Agent Scouse of
the Greenwood Police Department reporting of an inordinate 'fear' of me. I
am not responsible for Mr. Merritt's pathology. His unfounded fears and
paranoia is possibly a Delayed Stress Syndrome engendered by his years as a
violent thug for the National Football League.
h.. Markus Bernard Merritt gave false and misleading information to his
titular employer, U S West, to suggest a state of pathological fear
engendered by 'faxes'. He has them increasing their security at great cost
for a frivolous fear. In point of fact he seeks to conceal the liability he
has exposed them to in full knowledge of his actions. He has never been
touched, threatened, molested, stalked or otherwise improperly infringed
upon by myself, any other representation is a fiction and fantasy from a
mind reckless of the truth and reality. ALL of Mr. Merritt's statements are
IN FACT outright perjuries!
9.. The Defendants and them all, Tamara Ann Gartin, Markus Bernard
Merritt, Robert & Delores Jean Zehnder and their Legal Team, Karsh & Fulton,
P,C, and in appearance by A. Troy Ciccarelli, were ordered by Honorable
Judge Charles Hoppin to facilitate my custody of my children without
interference from the order of restraint. He further said that the
restraining order was mutual to all parties, an accommodation to my
simultaneous and prior application for order of restraint of Markus Bernard
Merritt for his prior assault, threats, menacing and molestation of myself
and my children. He further said that Karsh & Fulton, P.C., by their own
application, would provide services of facilitation for each and every
specific of the order of the Court. He specifically directed Karsh & Fulton
that the Order of Restraint was reluctantly given and only at the promise of
compliance with each specific. Each of them and them all have been
contemptuous of Judge Hoppin's order and its' specific directions.
j.. Judge Hoppin's proper concern for the shared custody of the children
was in compliance with the jurisdiction of Magistrate Babette Norton's order
for shared custody and generous interaction with my children. The Defendants
and them each and all of them have acted in direct arrogant contempt and
disregard and maliciously and after proper notice of non-compliance with the
order of Magistrate Babette Norton.
k.. The Defendants, Tamara Ann Gartin and Markus Bernard Merritt are in
common law marriage. They have colluded and conspired with their 'legal
team,' self identified by Tamara Zehnder as Karsh & Fulton, P.C. to harass,
molest and disturb myself, Steve Douglas, Gartin, with frivolous and
fraudulent actions before the Court and accomplished by perjury.
l.. Tamara Ann Gartin and Markus Merritt have conspired together to get me
fired from two places of employment by improper actions and by perjury. This
action in aid of their common law marriage, the contemplated probate of the
terminally ill Pastor Zehnder and its' distribution, their social position
before their church, their employment and the liability exposure they have
caused for their commercial associations, both the Lutheran Church and U S
West, Inc.
14.. Defendants and them all and each of them has presented to the Court a
description in evidence of myself Steve Douglas, Gartin in testimony and by
document and by acceptance, the perjury of '8th degree Black Belt', a
malicious and fearful fiction and fraud of Markus Bernard Merritt. Markus
Bernard Merritt has an irrational fear of me expressed as fantasies. I am
not an 8th degree Black Belt. I am not a man of violence of any description.
I have no record of violence. I have no presentation nor threat of violence
to any person at any time of record.
o.. This fantasy and perjury of Markus Bernard Merritt is used as a libel
and slander and to promote an unwarranted fear of me in order to coherce the
elderly Zehnders and Tamara A. Zehnder into his nefarious activities in
support of his intent to convert the elderly Zehnders assets into his own in
conspiracy with Tamara A. Zehnder, and with foul intent.
p.. Markus Bernard Merritt has threatened and menaced me in the presence
of witnesses. Markus Bernard Merritt has put his hands on me in an
intimidating manner and threatening me in the presence of my children on two
occasions. Markus Bernard Merritt is a previously convicted assaulter, under
present Restraining Order, a trained Professional Athlete in the National
Football League, a convicted Habitual Offender in dangerous and reckless
driving situations, a scofflaw in constant and arrogant contempt of deferred
sentencing, probation and direct Order of the Court. His filings and
applications of record to authority are a fraud and a fiction built of his
own record of offenses. He perjures without remorse for his own malicious
reasons.
q.. The Restraining Order and all its' applications have been a malicious
fiction and a frivolous contempt of the proper use of the Honorable Courts
valuable time. I have never sought the Courts time except to respond to the
malicious applications of Defendants, each of them and them all.
r.. The contempt of the Defendants, Tamara Ann Gartin, Markus Bernard
Merritt, their compliant parent, Robert V. Zehnder & Delores Jean Zehnder,
their self described legal team Karsh & Fulton, P.C. and in its persons all,
for a restraining order against my proper legal action taken in full view of
the Honorable Court and notification by FAX, a proper legal method, pursuant
to C.R.S. 125 is contemptuous of the time and notice of the Court and an
effort to deceive, conceal, and misdirect the Court's proper attention from
their own nefarious activities.
19.. The person Steve Douglas, Gartin is an indigent man by the very
direct and premeditated actions of Markus Bernard Merritt and Tamara Ann
Gartin, in conspiracy and in maliciously and with aforethought attacking
every employment opportunity presented to me. They continue to attack me in
Court for being in Forma Pauperis as if that were a condition of my own
choosing, it is IN FACT, the direct result of the knowledgeable acts of
Tamara A. Zehnder, alias TAMARA A. GARTIN and Markus Bernard Merritt in
conspiracy and collusion and in DIRECT CONTEMPT of the Court's Order that
they applied for, and the elderly Zehnders financed.
20.. The person Steve Douglas, Gartin is homeless and without other than a
mailing address in the government U S Postal Service, a legal reception
point for documents. The Defendants and them all refuse to comply with that
condition in contempt for the law and the direct order of Judge Charles
Hoppin to facilitate the custody and shared parenting of the minor children,
April Rose Gartin and Elijah Rock Gartin as required by the order of
Magistrate Babette Norton.
21.. The person Steve Douglas, Gartin has no phone service except by
charity and philanthropy. The sole message phone available through friends
of my family has not been used by Defendants to make appointment to confer
on motions submitted to the Court or to contact me to facilitate the Order
of the Court of Magistrate Babette Norton and Judge Charles Hoppin on shared
parenting, joint custody, facilitated time and transportation. A. Troy
Ciccarelli proffered and solicited volunteer accommodation Pro Bono Publico
by Karsh & Fulton, PC and in every person on the legal team. Perjuries by
Karsh & Fulton, PC in the Courts own record and as compared with their
messages and logs are an affront to the Court and the entire legal process
and tortious to the Parties Injured, et al.
v.. The proper service of legal information by FAX is a matter of law.
Karsh & Fulton, PC a service business of legal services provision in the
state of Colorado, sought application before the Court for "harassment by
FAX" and after refusing my proper notification to them by FAX transmission
in contempt of the Court and its time and its knowledge of the Law.
w.. Karsh & Fulton, P.C. has threatened and intimidated Chas Clements, my
Families' friend of many years and a kind provider of desperately needed
'message services' as required by Karsh & Fulton, PC, with vaguely worded
threats of contemplated legal action by Karsh & Fulton, PC on its' own
commercial behalf, not that of its commercial clients, and self defined by
J. Terry Wiggins, Esq. as payment for "Billable Hours" and being an 'agent'
for Steve Douglas, Gartin. These actions are in contempt of the District
Courts orders and those judges, a malfeasance of their proper conduct as
Attorneys, a misfeasance of duty to their clients April Rose, Gartin &
Elijah Rock,Gartin. These are fraudulent actions before the Court and an
improper, immoral, and illegal abuse of the power of Officers of the Court.
24.. Karsh & Fulton, P.C., a.k.a. "Legal Team" has committed perjurous
instruments and documents to the court. This Legal Team has encouraged it's
clients to commit perjury in direct defiance of all law. This Legal Team has
encouraged and suborned its clients to defy the Court's Orders. This Legal
Team has conspired and colluded with Magistrate Russell Stuska, Judge
William DuMoulin and Judge Olsen to defy and defile every Constitutional
Guarantee and Due Process and in conspiracy to deprive me of my Rights and
the Rights of my Children.
25.. These Officers of the Court, with a high knowledge of the Law have
effectively kept me from my Children since my illegal arrest based on
fraudulent testimony by Mr. Merritt and Ms. Zehnder on June 18, 1996. This
is not only unconscionable, it is illegal, immoral, and tortious in every
regard.
26.. My ONLY concern is for my Children. They are now in an environment
that encourages deceit, larceny, adultery, drunkenness, arrogance, ignorance
of Biblical principles, and all of the evils I do not want my Children
exposed to. It is my Right as Father to protect my Children from what I
perceive to be an extremely volatile and dangerous situation.
aa.. Tamara Zehnder is well documented to be a "verbal abuser." This fact
is confirmed by Audio Tape Recordings and testimony by first-hand witnesses.
Markus Bernard Merritt is a violent and habitual offender with a record of
violence and flagrant disregard for law and order. It is just a matter of
time before Tamara's abusive language finds Markus in a foul mood. His
potentially violent reaction to her abusive verbal attacks could result in
serious injury or death to my Children if they are present when Mr. Merritt
goes berserk. Mr. Merritt's Wife of Record, Teri L. Merritt obtained a
Restraining Order against Mr. Merritt because of his violent, aggressive,
and abusive actions. It is only a matter of time before the volatile
combination of Tamara's verbal abuse and Markus' violent persona erupts into
mayhem in the Elderly Zehnder's domicile. There would be no one capable of
protecting my Children in such a situation. I am in extreme and well-founded
fear for the safety of my Children in the presence of Mr. Merritt.
For the convenience of the Honorable Court, I have included a brief history
of Markus Bernard Merritt, alias "Michael Thomas." The N.C.I.C. record will
provide additional information about Mr. Merritt's criminal activity in
Texas and elsewhere in addition to his criminal history in Colorado.
Markus Bernard Merritt poses a serious threat to the safety of my minor
Children.
Markus Bernard Merritt
Black Male
DOB 1-16-63
6'2" 220 Black Hair/Brown Eyes
SSN: 524-15-1300
DL #: F683885
FBI #: 506910CA9
SID: CO370994
Local Arrest #: A4155
Home of Record: c/o Bernard Merritt
1738 Granby Court
Aurora, Colorado 360-9225
Colorado Arrest Record:
1987: FTA - Possession 88C3916
Probation: 88-89 & 89-90 92-93 current
92C4313: Wife's Restraining Order
92T4602
1993: Aurora NVOL - NPOI -
DWAI - DWAI - DWAI
#95-9040 Greenwood Village
95F1665: Habitual Offender
95CR2146:
Warrant issued 4-16-96 FTA
95T3795 A-3 DUS
45.. The Plaintiffs have recently became aware pursuant to F.R.C.P. 26,
(e) of the Law; aware of the requirements of a professional's Oath of
responsibility, and have become aware of a progress of:
a.. fraud, F.R.C.P. 9 (b)
b.. collusion, U.S.C.A. Title 18, section 1621
c.. extortion U.S.C.A. Title 18, section 1621, 1622
d.. perjury, U.S.C.A. Title 42, section 1986, 1985, 1983
e.. in conspiracy. U.S.C.A. Title 18 , section 1985
by the Defendants, Pastor Robert V. Zehnder & Delores Jean Zehnder, and
legal counsel; A. Troy Ciccarelli, J. Terry Wiggins, Markus Bernard Merritt,
Valerie Krogman, Alan Karsh, Fred Gabler, Larry Fulton, Seymour Joseph, and
other parties unknown to the Plaintiffs at this moment in time.
as.. Now we have become aware of the contempt of Karsh & Fulton, P.C. for
the order and direction in order of the Honorable Court as defined in
Magistrate Norton's Order of January 19th, 1996 to facilitate equal shared
parenting.
at.. Now we have become aware of the contempt of Karsh & Fulton, P.C. for
the order and direction in order of the Honorable Court as directed in Judge
Hoppin's Order of Restraint wherein his genuine concern was expressed "on
record" for the conservation of the Rights of the herein designated
Plaintiffs April Rose, Gartin & Elijah Rock, Gartin & Steve Douglas, Gartin
in their family relationship.
47.. Karsh & Fulton, P.C. has made no attempt to hide their arrogant
contempt of any order of the Honorable Court that does not directly result
in their 'billable hours' as defined by Senior Partner J. Terry Wiggins,
Esquire a.k.a. Terry Wiggins in his true name and by any fiction d.b.a.
Karsh & Fulton, P.C.
48.. The Honorable Court has had official notice of several fraudulent
documents submitted and perjuries made by A. Troy Ciccarelli. These are now
within the Court's Record in Case # 95-DR-2718 and a matter of prima facie
evidence of gross perjury in all of Mr. Ciccarelli's dealings with the Court
in which Plaintiff is a Party.
49.. Presently the parties at Karsh & Fulton, P.C.; J. Terry Wiggins, A.
Troy Ciccarelli and such others and their clients, Tamara Ann Zehnder (alias
Tamara A. Gartin), Robert & Dolores Zehnder and Markus Bernard Merritt, are
all in conspiracy, in malicious contempt of the orders of the Court in Cases
95-DR-2718, #96CO3788, #96CO3787, #96CO3786.
THEREFORE, Plaintiffs and them all; April Rose, Gartin & Elijah Rock, Gartin
& Steve Douglas, Gartin, move the Honorable Court for Summary Judgment
pursuant to Rule 56.
WHEREFORE, the Plaintiffs, and them all, move this Honorable Court to render
a Summary Judgment for such other and further relief as the court deems just
and proper in the premises.
Steve Douglas, Gartin, in his True Name and as the Proper Party Injured,
avails himself of all the provisions of the laws and statutes of the state
of Colorado and of the united States of America, which have been made and
provided for relief and restoration of tortious actions by Defendants, and
them all, and for cause, and other such statutes, made and provided, in
protection of the unalienable rights of the Citizens.
I claim all Rights and Privileges under the Constitutions of the state of
Colorado and the united States of America and at no time waive any right or
privilege of my free will.
Dated this 21st day of August, 1996.
_____________________________________
Steve Douglas, Gartin
PO Box 114 Message Phone: 364-0403
Golden, Colorado Zip Exempt Message FAX: 739-9824
Plaintiff is Homeless and Indigent
Allow an extra 10 Days for delivery to PO Box and subsequent pickup
Please FAX for quicker response.
Law Note Index
[Note #1]
TITLE XII
Section 8. Oath of civil officers. Every civil officer, except members of
the general assembly and such inferior officers as may be by law exempted,
shall, before he enters upon the duties of his office, take and subscribe an
oath or affirmation to support the constitution of the united States and of
the state of Colorado, and to faithfully perform the duties of the office
upon which he shall be about to enter.
Section 9. Oaths - where filed. Officers of the executive department and
judges of the supreme and district courts, and district attorneys, shall
file their oaths of office with the secretary of state; every other officer
shall file his oath of office with the county clerk of the county wherein he
shall have been elected.
_________________________________________________________________
UNITED STATES CODE TITLE 18 - CRIMES AND CRIMINAL PROCEDURE
PART I - CRIMES CHAPTER 79 - PERJURY § 1621. Perjury generally
Whoever - (1) having taken an oath before a competent tribunal, officer, or
person, in any case in which a law of the United States authorizes an oath
to be administered, that he will testify, declare, depose, or certify truly,
or that any written testimony, declaration, deposition, or certificate by
him subscribed, is true, willfully and contrary to such oath states or
subscribes any material matter which he does not believe to be true; or (2)
in any declaration, certificate, verification, or statement under penalty of
perjury as permitted under section 1746 of title 28, United States Code,
willfully subscribes a true any material matter which he does not believe to
be true; is guilty of perjury and shall, except as otherwise expressly
provided by law, be fined not more than $2,000 or imprisoned not more than
five years, or both. This section is applicable whether the statement or
subscription is made within or without the United States.
[Note #2]
Colorado Revised Statutes 14-10-129.5. Disputes concerning parenting time.
Upon a verified motion by either parent or upon the court's own motion
alleging that a parent is not complying with a parenting time order or
schedule and setting forth the possible sanctions that may be imposed by the
court, the court shall determine from the verified motion, and response to
the motion, if any, whether there has been or is likely to be a substantial
and continuing noncompliance with the parenting time order or schedule
and either:
(b) Set the matter for hearing with notice to the parents of the time and
place of the hearing;
After the hearing, if a court finds that a parent has not complied with the
parenting time order or schedule and has violated the court order, the
court, in the best interests of the child, may issue orders which may
include but need not be limited to: the court shall separate the issues of
child support and parenting time and
shall not condition child support upon parenting time;
(b) Modifying the previous order to meet the best interests of the child;
(c) Requiring the violator to post bond or security to insure future
compliance;
Requiring that makeup parenting time be provided for the aggrieved parent
and
children under the following conditions:
(II) That such parenting time is made up within one year after the
noncompliance occurs;
That such parenting time is in the manner chosen by the aggrieved parent if
it is in the
best interests of the child;
(e) Finding the parent who did not comply with the parenting time schedule
in contempt of
court and imposing a fine or jail sentence;
(f) Scheduling a hearing for modification of custody with respect to a
motion filed pursuant
to section 14-10-131 or 14-10-131.5;
(g) Awarding to the aggrieved party, where appropriate, actual expenses,
including
attorney fees, court costs, and expenses incurred by a parent because of the
other parent's
failure to provide or exercise court-ordered parenting time. Nothing in this
section shall
preclude a party's right to a separate & independent legal action in tort.
[Note #3]
UNITED STATES CODE TITLE 18 - CRIMES AND CRIMINAL PROCEDURE
PART I - CRIMES CHAPTER 79 - PERJURY § 1622. Subornation of perjury
Whoever procures another to commit any perjury is guilty of subornation of
perjury,
and shall be fined not more than $2,000 or imprisoned not more than five
years, or both.
[Note #4]
UNITED STATES CODE TITLE 18 - CRIMES AND CRIMINAL PROCEDURE
PART I - CRIMES CHAPTER 13 - CIVIL RIGHTS
§ 241. Conspiracy against rights
If two or more persons conspire to injure, oppress, threaten, or intimidate
any inhabitant of
any State, Territory, or District in the free exercise or enjoyment of any
right or privilege secured to
him by the Constitution or laws of the united States, or because of his
having so exercised the
same; or
If two or more persons go in disguise on the highway, or on the premises of
another, with
intent to prevent or hinder his free exercise or enjoyment of any right or
privilege so secured -
They shall be fined not more than $10,000 or imprisoned not more than ten
years, or both; and if
death results, they shall be subject to imprisonment for any term of years
or for life.
a.. [Note #5]
The general assembly finds and declares that it is in the best interest of
all parties to encourage frequent and continuing contact between each parent
and the minor children of the marriage after the parents have separated or
dissolved their marriage. In order to effectuate this goal, the general
assembly urges parents to share the rights and responsibilities of
child-rearing and to encourage the love, affection, and contact between the
children and the parents.
The court shall determine custody in accordance with the best interests of
the child. The court, upon the motion of either party or upon its own
motion, may order joint or sole custody after making a finding that joint or
sole custody would be advantageous to the child and in his best interests.
In determining the best interests of the child, the court shall consider all
relevant factors, including:
a.. The wishes of the child's parents as to his custody;
b.. The wishes of the child as to his custodian;
c.. The interaction and interrelationship of the child with his parents,
his siblings,
d.. and any other person who may significantly affect the child's best
interests;
e.. The child's adjustment to his home, school, and community;
f.. The mental and physical health of all individuals involved;
g.. The ability of the custodian to encourage the sharing of love,
affection, and contact
h.. between the child and the noncustodial party;
i.. Credible evidence of the ability of the parties to cooperate and to
make decisions jointly; Credible evidence of the ability of the parties to
encourage the sharing of love, affection, and contact between the child and
the other party; Whether the past pattern of involvement of the parties with
the child reflects a system of values, time commitment, and mutual support
which would indicate an ability as joint custodians to provide a positive
and nourishing relationship with the child;
j.. The physical proximity of the parties to each other as this relates to
the practical considerations of awarding joint custody; Whether an award of
joint custody will promote more frequent or continuing contact between the
child and each of the parties; Whether one of the parties has been a
perpetrator of child abuse or neglect under section 18-6-401, C.R.S., or
under the law of any state, which factor shall be supported by credible
evidence. If the court makes a finding of fact that one of the parties has
been a perpetrator of child abuse or neglect, then it shall not be in the
best interests of the child to award joint custody over the objection of the
other party or the guardian ad litem of the child.
k.. Whether one of the parties has been a perpetrator of spouse abuse as
defined in subsection (4) of this section, which factor shall be supported
by credible evidence. If the court makes a finding of fact that one of the
parents has been a perpetrator of spouse abuse, then it shall not be in the
best interests of the child to award joint custody over the objection of the
other party or the guardian ad litem of the child, unless the court finds
that the parties are able to make shared decisions about their children
without physical confrontation and in a place and manner which is not a
danger to the abused spouse or the child.
l.. The court shall not consider conduct of a proposed custodian that does
not affect his relationship to the child.
m.. In considering a proposed custodian, the court shall not presume that
any person is better able to serve the best interests of the child because
of that person's sex.
n.. If a parent is absent or leaves home because of spouse abuse by the
other parent, such absence or leaving shall not be a factor in determining
the best interests of the child. For the purpose of this subsection (4),
"spouse abuse" means the proven threat of or infliction of physical pain or
injury by a spouse on the other parent.
[Note #6]
C.R.C.P. 121, 1-15-8
Duty to Confer. When appropriate to do so, moving counsel should confer with
opposing counsel before filing a motion. The motion shall, at the beginning,
contain a certification that the movant in good faith has conferred with
opposing counsel about the motion. If no conference has occurred, the reason
why shall be stated. If the relief sought by the motion has been agreed to
by the parties or will not be opposed, the court shall be so advised in the
motion.
[Note #7]
6.. R.C.P. IX. SPECIAL PROCEEDINGS Rule 73. Magistrate Judges;
Trial by Consent and Appeal Options
(a) Powers; Procedure.
When specially designated to exercise such jurisdiction by local rule or
order of the district court and when all parties consent thereto, a
magistrate judge may exercise the authority provided by Title 28, U.S.C.
§ 636(c) and may conduct any or all proceedings, including a jury or
nonjury trial, in a civil case. A record of the proceedings shall be made in
accordance with the requirements of Title 28, U.S.C. § 636(c)(7).
(b) Consent.
When a magistrate judge has been designated to exercise civil trial
jurisdiction, the clerk shall give written notice to the parties of their
opportunity to consent to the exercise by a magistrate judge of civil
jurisdiction over the case, as authorized by Title 28, U.S.C. § 636(c).
If, within the period specified by local rule, the parties agree to a
magistrate judge's exercise of such authority, they shall execute and file a
joint form of consent or separate forms of consent setting forth such
election.
A district judge, magistrate judge, or other court official may again advise
the parties of the availability of the magistrate judge, but, in so doing,
shall also advise the parties that they are free to withhold consent without
adverse substantive consequences. A district judge or magistrate judge shall
not be informed of a party's response to the clerk's notification, unless
all parties have consented to the referral of the matter to a magistrate
judge.
The district judge, for good cause shown on the judge's own initiative, or
under extraordinary circumstances shown by a party, may vacate a reference
of a civil matter to a magistrate judge under this subdivision.
I hereby certify that a true and correct copy of the forgoing
Motion for Summary Judgment was placed into que
for delivery via FAX on August 22nd, 1996
to the following Parties at the listed FAX number.
CC: VIA FAX Numbers Listed_________________________________________
Jefferson County Court Chief Judge Henry Nieto FAX: 303-271-6270
Karsh & Fulton, P.C. Alan Karsh FAX: 303-782-0902
Bethlehem Lutheran, Inc. David Langewisch FAX: 303-238-7691
Timothy & Francisca Zehnder FAX: 303-932-2465
American Civil Liberties Union FAX: 303-777-1773
Federal District Court Judge Lewis T. Babcock FAX: 303-861-2233
Commission on Judicial Discipline FAX: 303-837-3601
U.S. Attorney FAX: 303-844-0098
u.. S. Supreme Court Grievance Committee FAX: 303-893-2443
U S West, Inc. Elizabeth Kiovsky FAX: 303-295-7046
Hard Copy available upon Request.
Interested readers should know that the D.A.'s office dropped charges at
their own petition. Antonio Troy Ciccarelli, the lawyer, was let go from
Karsh & Fulton and his censure by the State Supreme Court sealed after
making false submission to the Federal Court.
The whole thing, by Greenwood Village, on behalf of the many defendants-
was a sham.
Chas
Intelligence Unit
Jefferson County Sheriffs' Department
February 11, 1997
Mr. Estep:
It has come to my attention that you would like to interview me regarding a
number of arrest warrants (so-called) for a Mr. 'Steve Gartin'. As you have
not answered your phone, I take the opportunity to send you some background
information about my involvement (so-called) in this matter.
As I understand it, Mr. Gartins' only 'threats' have been to seek an
investigation from an objective authority and to seek redress of damages
from these criminals. He has been forthcoming, has provided documentation,
has responded to all interrogatories. In return, he has been subject to
false arrest, illegal imprisonment, harassment and threats, Star Chamber
proceedings from the judiciary, obstruction of justice, intimidation of his
Witnesses by individuals under Color of Authority and more.
The actions of the Jefferson County Judicial/Law Enforcement community have
not been objective, professional or responsible. The negligence of your
community in the investigation of these matters is inexcusable and appalling
to anyone who depends on an independent view of a given situation. The
continuing gullibility of the police, sheriffs' department and city
attorneys' office is amazing. The inattention to detail, to reading, to
investigation and other due diligence is irresponsible and negligent.
It is certain that a proper investigation will now be done by the FBI and
the other Federal agencies. The Title 42 Action has been filed, the
preliminary reports made and the documentation provided to law enforcement
agencies. The grievance committee of the state supreme court and its'
judicial conduct review, the state Attorney Generals' office and the
Governors office are all proceeding with actions appropriate to their
responsibilities. These are not the actions of a man escaping his
responsibilities or evading punishment for his actions. These are the
actions of a man wronged by irresponsible negligence and malicious conduct.
Very Truly,
Charles H.
Clements
City Manager Charlie Richardson
City of Aurora, state of Colorado
February 10. 1997
Dear Mr. Richardson:
Yesterday, Sunday February 9. 1997, at approximately 9 AM, I was
again stopped and interrogated by the Aurora Police Department (Officer
Saitz) concerning information given to the APD by Greenwood Village Police
Department.
While the Officer involved was courteous, professional and civil
to both myself and my employer, the basic information given to APD is, at
worst, FALSE and at best, misleading. Accosting my employer was not
acceptable.
The Greenwood Village City Government is pursuing a course of
Obstructing Justice and Harrassment under the Color of Authority, the
unlawful intimidation of witnesses against them and other abrogations of
Civil and Constitutional Rights. This condition is the subject of reports
to the Federal Law Enforcement Authorities and Civil Actions in both State
and Federal Court under Title 42, Title 18 and etc.
My involvement (?) has consisted of allowing a poor man to use my
electronic facilities to send his legal documents. The Greenwood Village
City Government has found the allegations made by the FAXmodem information
to be embarrassing and possibly indicating of their criminal culpability and
liability.
My relationship with the APD and the Aurora City Government has
been positive and forthcoming. I would hate to think that the false and
misleading information given to the APD about me would change that posture.
I am more than willing to discuss the matter with you and to participate in
any investigation of this situation.
I include previous correspondence with the GVPD for your
background information.
Very Truly Yours,
Charles H. Clements
1741 Dallas Street
364-0403
cc: APD, GVPD, US Atty's Office, Fed. Dist. Court (Judge P. Cohen)
copy to City Manager Richardson, Aurora: February 10, l997
City Manager Crowell
City of Greenwood Village
January 17, 1997
Dear Sir:
I enclose the following letter sent by FAXmodem to your Police
Chief Waugh as dated. I have received no answers to the most simple of the
questions.
I was subjected to public embarrassment, unwarranted intimidation
and an arrogance that was even apparent and distasteful to the Aurora Police
Dept. Captain that accompanied Dets. Carr and Stadterman during the
incident. I have been helpful, forthcoming and courteous to your officers
on all occasions of our interactions and there was no reason for this
conduct.
I am the Neighborhood Watch Block Captain in my neighborhood, well
known and, I hope, respected. I have been very active in the business, arts
and civic communities in Aurora since 1960. When the so-called 'crime' is
FAXing legal documents to the principal parties to the actions, there is no
reason to disturb my family to apprehend the 'fugitive'. If you want to
talk to him, call him on the phone and make arrangements- I have nothing to
do with it.
There are some very consequential Civil Rights questions inherent
in this situation that are already before the Federal District Court. As
well, there is the matter of the professional demeanor of your officers
while in another county, apparently without the requisite paperwork or
authority. The threats and intimidation from your Det. Carr on behalf of
Defendants; US West, jailbird Merritt, the other proven perjurers (ask Tech.
Scouse), and his failure to diligently and objectively investigate this
situation reflects poorly on your department.
I understand that my associates in Lakewood were the recipients of
an apology from Det. Carr for his actions at our club. I have not received
so much as an acknowledgement of my questions, much less an apology, much
less answers to my questions.
(Letter follows)
Copy to City Manager Richardson: February 10, 1997
Chief of Police Rich Waugh
Greenwood Village Police Department
January 7, 1997
Ref: Detective John Carr, GWPD
Subj: Interrogatory by Federal Witness
Sir:
Please provide for me the incident report 3 JAN 97 filed by
Detective John Carr of his attempt to serve Arrest Warrants on Steve
Douglas, Gartin at my home in Adams County. Also a copy of each Warrant as
signed by a judge and upon the oath of an affiant.
My chief concerns are with Det. Carrs' seeming obstruction of
justice, witness intimidation, failure to perform to the minimum standards
as a law enforcement professional.
1. Who was the Aurora Police Officer who accompanied Carr and Stadterman?
2. Was he shown a copy of the Warrant?
3. Did he make a photocopy (or other copy) of the Warrant or note the
identifying numbers in the presence of Det. Carr or Det. Stadterman?
4. Upon whose oath was the information stating my address as a possible site
for Mr. Gartin? On the record: Mr. Gartin has never spent a night at my
property. He has visited the property perhaps ten times in the twenty years
I've known him. He has never delivered documents to me for faxing. I do
not own a teleFAX machine, nor do I 'format' telefaxes, nor do I advise Mr.
Gartin about legal matters. I have no legal education, I have never filed a
case, I have never entered a Court as a principal without an attorney.
5. Why has Detective Carr threatened me to Mr. Gartin? Have I committed a
crime? If so, what crime might that be? Is the act of Witnessing a crime?
6. I have identified myself to Det. Carr as a Witness in a Federal District
Court Case. Why does he continue to 'warn' me of some sort of 'bad trouble'
from my testimony? I feel that my testimony will bring retribution of some
sort from him. Why is he taking sides in a situation he is being paid to
investigate objectively?
7. The complainant, Markus Bernard Merritt, has been caught in several lies
by your own police department,(I specifically think of Technician Scouse).
He just got out of your own jail for similar charges as he now makes from
the whole cloth. Why have the charges as made by Mr. Gartin, and
corroborated by others, not been investigated by Det. Carr?
8. He characterized the premises as 'not a labor dispute' when a casual
reading of the material shows that the situation derives from three labor
disputes; Spyderco, USWest, Golden Recreation Center. Why has he failed to
give this situation the slightest diligence of reading the background?
9. USWest is a Defendant in actions to which Mr. Gartin is Plaintiff. Why
has that information been unknown to Det. Carr? It is a matter of Public
Record. Their 'security concerns' are a fantasy to serve their own ends.
Why has Det. Carr failed to investigate their self interest in the
incarceration of Mr. Gartin?
10. Markus Merritt is Defendant to cases in which the Gartin Children are
Plaintiff, including applications for restraining orders from physical
abuse. He is responsible for bruises made in abuse that were videotaped.
He sleeps in the same bed with the six year old boy to keep him from running
away from the abuse. Your Det. Carrs' actions are in aid of sequestering
two Federal Witnesses/Plaintiffs from giving information in Court. The
children were detained from Court in the Golden incident because their
testimony would be exculpatory. Why is that situation not investigated?
Merritts' credibility is in serious question.
11. Det. Carr has found it necessary to speak of Mr. Gartin using some very
inflammatory rhetoric; 'coward', 'afraid to face his responsibilities',
'hiding behind FAXes', 'crazy', 'whacko', etc. Mr. Gartin is well known to
your Lt. Fisher as a man of great integrity, great honour, deep spirituality
and of unquestioned courage and sense of responsibility. He has that
reputation internationally. When did Det. Carr do enough background
research to come to those ugly conclusions? Does the color of his authority
cover malicious statements like that? Is it a professional demeanor?
12. Why did Det. Carr not have Mr. Gartins' pager number? Tamara and
Markus and the children and the Zehnders and the extended Family Zehnder and
the Lawfirm all had it. Why were they keeping material information from
Det. Carr?
13. A casual reading of the official record of the Court in the various
actions shows gross material perjury by the Complainants and their Lawfirm.
Why has Det. Carr failed to familiarize himself with this material? Why has
he failed to compare their perjury to the Court with the perjury to the
Greenwood Police Dept.
A Title 42 action, the KKK law, has been filed in Federal District
Court before Hon. Patricia Cohen, it is being investigated by Dep U. S. Att'
y James R. Allison. The information has been filed with the Grievance
Committee of the Colorado state Supreme Court. As I understand it, your
officer, John Carr, has been added to that criminal information as a
Defendant for the obstruction of justice, denial of Civil Rights under Color
of Authority, aiding a criminal conspiracy under color of authority, etc
The question before the U.S. Supreme Court today (US v. Lanier) is
a newstory that Det. Carr would do well to research in my humble opinion as
a layman. Infractions of Title 42 have very real consequences. All Steve
Gartin is asking for is an investigation by competant law enforcement
authorities. He has never been interviewed by police, never charged without
proving innocence, never had chance at legal counsel, never had a chance to
confront accusers.
I would respectfully remind you of an old Texas Ranger credo;
"You can't stop a man who knows he's right and just keeps on coming." Mr.
Gartin is, in my non-professional but considered opinion; not crazy, not
obsessed, not culpable, not lying. I have been witness to much of this
history by eye as well as constructivly; he is telling you the truth.
Very Respectfully,
Charles H. Clements
1741 Dallas Street
Aurora, Colorado
US 303-364-0403 Voice
US 303-739-9824
FAXmodem/data
District Court Case # 95-B-1747
F a x S e r v i c e
To: JAMES R. ALLISON
From: Steve Douglas, Gartin
Fax: Relay: 739-9824
Pages: 3
Phone: Message: 364-0403
Date: January 3, 1997
Re: ACTS OF WAR in color of Authority CC: Legal
List.
Notice of Natural/Civil Rights Violations and Criminal Complaint
l Comments:
Following is Plaintiff's Verified Complaint of ACTS of WAR. This notice is
filed VIA FAX, pursuant to and in compliance with, Colorado law.
Colorado Court Rules Section 1-25 FACSIMILE COPIES
2. Facsimile copies which conform with the quality requirements specified
in C.R.C.P. 10(d)(1) may be filed with the court in lieu of the original
document. Once filed with the court, the facsimile copy shall be treated as
an original for all court purposes. If a facsimile copy is filed in lieu of
the original document, the attorney or party filing the facsimile shall
retain the original document for production to the court, if requested to do
so.
4. Any facsimile copy transmitted directly to the court shall be
accompanied by a cover sheet which states the title of the document, case
number, number of pages, identity and voice telephone number of transmitter
and any instructions.
Colorado Court Rules Rule 10. Form and Quality of Pleadings, Motions and
Other Papers
(d) General Rule Regarding Paper Size, Format, and Spacing.
All documents originated after the effective date of this rule shall meet
the following criteria:
(1) Paper Size and Quality: Only documents which are clear and legible
and are on permanent plain 8 1/2 by 11 inch paper shall be filed.
(38) "Send" in connection with any writing or notice means to deposit in the
mail or deliver for transmission by any other usual means of communication
with postage or cost of transmission provided for and properly addressed and
in the case of an instrument to an address specified thereon or otherwise
agreed, or if there be none to any address reasonable under the
circumstances. The receipt of any writing or notice within the time at which
it would have arrived if properly sent has the effect of a proper sending.
Note: This Document is addressed to the above Party, if this document has
been received in error, please return or call 364-0403
Attention: James R. Allison, Assistant U.S. Attorney
U.S. Department of Justice
U.S. Attorneys Office, Colorado state
Criminal Division
BYRON G. ROGERS FEDERAL BUILDING
1961 STOUT STREET
DENVER, COLO. 80294
Date: 3 January 1997
Reference: ACTS OF WAR against Colorado Sovereigns
Subject: Appropriate Federal Charges for criminal acts in color of authority
Dear Mr. Allison:
Please be advised that the Homestead of the Clements Family was attacked
today by armed criminals in disguise as "police" detectives for the
corporate municipality of Greenwood Village, Inc.
I, Steve Douglas, Gartin am temporarily an indigent and homeless
man, before the Court in forma pauperis seeking relief from injustice and
damages in Federal District Court. This temporary condition is the direct
and tortious result of the illegal, seditious, and treasonous actions of the
Defendants and subject of legal action in several cases:
· Incorporated CASE #Federal District Court Case # 95-B-1747
Regarding Jefferson County Cases:
· Incorporated 95-CV-1634
· 95-DR-2718 - Fraud (F.R.C.P. 9 (b)
· Incorporated 96CO7019
· 96CO7388 - Fraud (F.R.C.P. 9 (b)
· 96CO7387 - Fraud (F.R.C.P. 9 (b)
· 96CO7386 - Fraud (F.R.C.P. 9 (b)
The present information has to do with the continuing criminal CONSPIRACY to
DEFRAUD the People of Colorado by the Lawfirm:
Karsh & Fulton, Professional Corporation Suite 710 Cherry Tower Office
Building
950 South Cherry Street Denver, Colorado 80222-2665
1. Alan E. Karsh
2. Larry C. Fulton
3. Fred Gabler
4. Terry Wiggins
5. Seymour Joseph
6. Antonio Troy Ciccarelli
7. Valerie M. Krogman
8. Markus Bernard Merritt
and has now been joined, in conspiracy, by
1. Defendant - John Carr and
2. Mark Stadterman and
3. Other "john does" unknown at this time d.b.a.
a. Greenwood Village Police Department,
Inc.
and associated cronies,
b. Arapahoe County, Inc. and
c. Greenwood City, Inc. by any and all
fictions created with the
intent to deceive by trickery and to usurp/convert/deprive
the Rights of the Sovereign People of the organic state of Colorado under
the Common Law of The Everliving.
by the direct actions of Detective John Carr as he and Mark Stadterman
proceeded in reckless disregard for the law by unlawfully crossing multiple
county lines in order to execute a Felonious BenchWarrant, having been
apprised of that fact by this Sovereign on January 2nd, 1997.
These citizens in disguise, known professionally as John Carr
and Mark Standterman did knowingly and with intent to deceive and,
· without a license to practice or enforce law,
· without any Legal Authority,
· without a legal warrant,
· without proper authorization, and
· in direct and knowing violation of the Civil Rights section 21 of
the United States Codes,
· the First, Fourth, Fifth, Sixth, Seventh, Tenth, and Fourteenth
Amendments to the Constitution of the United States and in violation of
all moral laws
attempt to assault the Sovereign Steve Douglas, Gartin with armed force.
And did in the commission of that Crime - with direct and malicious contempt
physically and verbally menace with deadly force, intimidate, threaten,
molest and disturb the Peace and Safety of the People of Colorado to be
secure in their homes, when they did attack the Clements Homestead at
mailing location Seventeen Forty One Dallas Street in the City of Aurora in
Adams County in the organic state of Colorado, which is expressly "without"
the United States and the Corporate Government Incorporated to do commerce
"within" the United States, Inc.
Yet, these officers of the court, with high knowledge and standards of law
proceeded forward without jurisdiction,
· in perjury,
· in conspiracy, and
· in collusion to extort rights by color of authority from the Family
Gartin and any and all Sovereigns who may stand in the way of their criminal
intent.
This is my Bona Fide Complaint and Demand for Arrest Warrant to be issued
upon probable cause for ACTS of WAR perpetrated upon the Sovereign People of
Colorado by the above listed criminals by FRAUD, DECEIT, PERJURY, UNLAWFUL
FORCE OF ARMS and under COLOR OF LAW upon the above named legal team,
operating without a license and the above named corporate police operating
without authority, and without Oath of Office on file with the county clerk
of Arapahoe County.
When these criminals should be pursuing REAL complaints, they are instead
expending TAXPAYERS money to persecute a Colorado Sovereign for FAXing legal
documents and making bonfire Complaints, which NONE of these Criminals have
bothered to investigate. These actions constitute prima facie Betrayal of
the Public Trust.
Steve Douglas, Gartin hereby makes DEMAND to be provided the proper
credentials and authorization from the People of Colorado for these above
listed "military police" Criminals in disguise to operate in the organic
state of Colorado.
Following is the first response to the criminal assault and ACTS of WAR
committed by the Greenwood Village Police Department, Inc. in the persons of
Mark Stadterman and John Car, directly to them and now to you.
I will confidently expect you to proceed in an honorable manner.
Very Truly,
Steve Douglas, Gartin
attn: Scott Tuttle, Special Agent (charge 16 applies)
Concerning Federal District Court
Case #96-CV-1478
____________________________________________________________________________
_______
Verified Emergency Notice and Charges of Obstruction of Justice and Civil
Rights Denials and Human Rights Abuses by Agents of Jefferson County and
Arapahoe County of Colorado under color of their authority and named
Defendants in complicity
____________________________________________________________________________
_______
Steve Douglas, Gartin as Head of Family
April Rose, Gartin - Heir
Elijah Rock, Gartin - Heir
Petitioners
against
Pastor Robert Victor Zehnder
Dolores Jean Zehnder
Tamara Ann Gartin, nee Zehnder
Markus Bernard Merritt
Pastor Michael Zehnder
Asst. Pastor Thomas Zehnder
Office Space Saving Concepts, Inc.
Timothy Zehnder
Francisca Zehnder
Karsh & Fulton, P.C.
Alan Karsh
Fred Gabler
Larry Fulton
Seymour Joseph
J. Terry Wiggins
Antonio Troy Ciccarelli
Valerie Krogman
Bethlehem Lutheran School,
Bethlehem Lutheran Church, of the Missouri Synod
David Langewisch
Peter Woodward
Chet Shoaf
Jefferson County Court
Henry Nieto
Russell A. Stuska
William DuMoulin
Babette Norton
Roy Olsen
Charles Hoppin
such "John Doe" Staff, Service Providers and Officers of the Court
Colorado state Attorneys' Office
Maury Knaizer, Esq.
Markus Bernard Merritt
John Openheimer
Linda Doughty
Greenwood Village, Inc.
John Carr
Mark Stadterman
Golden Community Center, Inc.
Bev Koenig
Theresa Reilly
Mike Bestor
Golden Police Department, Inc.
Michael Moler
Ted Schnack
Lewis Shellenberger
Glenn Moore
Bill Killpatrick
Russell Cook
Jefferson County Sheriffs Department, Inc.
Ronald Beckham
Don Estep
Frank Lastoczy
U S West, Inc.
Barbara Byers
Paula Anderson
Elizabeth Kiovsky
Roger McCormick
Bill Stevens
Lakewood Police Department
Michael Harris
Susan Hines
Mary Sutton
____________Defendants_____
____________________________________________________________________________
_
1. Plaintiff, Steve Douglas, Gartin is of proper age, of sound mind, tells
the Truth and has first hand knowledge of events and actions contained
herein.
2. Defendant list has been updated and 'John Does' have been assigned to
specific perpetrators as per information.
3. Jurisdiction of the Federal District Court is confirmed by prior service
to Defendant's and their attornies, by hand delivery, via U S Mail, Inc. and
Via Facsimile (Electronic Transmission) pursuant to C.R.S. 1-25.
4. All Defendants are joined in conspiracy and collusion by each and every
other Defendant amended to title in an interState criminal organization and
have benefitted from such organization and conspiracy.
5. The Defendants, and each of them and all of them, have joined in an
interState conspiracy to Obstruct Justice and to deny Equal Protection under
the Law to the Plaintiffs because of Plaintiffs' charges in Federal District
Court in the above named case Case #96-CV-1478 as well as cases 96C7386 -
96C7387 - 96C7388 and Incorporated Case # 96CO7019, 96CO1478, 96CO1439,
96CO140.
6. The Defendants, and through agents and co-conspirators, have repeatedly
given false and perjurious testimony or other affadavit in order to
wrongfully charge, wrongfully arrest and wrongfully imprison Steve Douglas,
Gartin in cases 96C7386 - 96C7387 - 96C7388 and Incorporated Case #
96CO7019, 96CO1478, 96CO1439, 96CO140 and such others to which they are
party.
7. The Defendants, and through agents and co-conspirators, have repeatedly
given false and perjurious testimony or other affadavit in order to
wrongfully imprison and to detain Steve Douglas, Gartins' heirs and
offspring April Rose, Gartin and Elijah Rock, Gartin from giving proper
testimony or appearing in Golden Municipal Court, Jefferson County District
Court and Federal District Court, Colorado in cases 96C7386 - 96C7387 -
96C7388 and Incorporated Case # 96CO7019, 96CO1478, 96CO1439, 96CO140 and
such others to which they are party.
.
8. The Defendants, and through agents and co-conspirators, have used, or
caused to be used, the color of their authority to obstruct justice and to
deny equal protection under the law to Plaintiffs' case before the Federal
District Court Case #96-CV-1478 by falsely arresting, torturing and
imprisoning Steve Douglas, Gartin using the law enforcement resources and
judicial system of Jefferson County and Arapahoe County, Colorado Republic
to escape the consequences of a Federal Law Enforcement investigation
concerning cases; 96C7386 - 96C7387 - 96C7388 and Incorporated Case #
96CO7019, 96CO1478, 96CO1439, 96CO140 to which they are party.
9. The Judges, so named above, have failed to secure the due process of the
Law or its equal protection to Steve Douglas, Gartin, deliberately and
maliciously and in a high knowledge of the Law, without judicial objectivity
and in knowing and deliberate abrogation of Steve Douglas, Gartins' Civil
Rights as guaranteed by the Constitutions of both the State of Colorado and
the United States of America in violation of their Oaths of Office in cases;
96C7386 - 96C7387 - 96C7388 and Incorporated Case # 96CO7019, 96CO1478,
96CO1439, 96CO140 and such others, in conspiracy with other Defendants.
10. Law Enforcement Officers, so named above, have perjured their Oaths of
Office by failing to provide equal enforcement of the law to Steve Douglas,
Gartin and his co-Plaintiffs, April Rose, Gartin and Elijah Rock, Gartin by
failing to accept Verified Criminal Charges of misdemeanors and felonies
against their co-Defendants, so named above, in an interState Organized
Criminal Conspiracy to escape prosecution in cases 96C7386 - 96C7387 -
96C7388 and Incorporated Case # 96CO7019, 96CO1478, 96CO1439, 96CO140 and
Case #96-CV-1478.
11. Plaintiffs April Rose, Gartin and Elijah Rock, Gartin were not
permitted the counsel of their Father or his assurances of the circumstances
of these events and actions in their domestic environment. The deep scars
and permanent damage generated by these Defendants perjury and enumerated
actions on these children has been exacerbated by the sequestration from the
love, nurturing and protection of their Father. These tortious actions are
in contempt of the Court's Order of equal shared parenting and solely and
only for the commercial gain of several incorporate entities high in
knowledge of the Law. Relief is sought under C.R.S. 14-10-129.5, I (b), and
II (a), (e), & (g).
12. The Plaintiffs have recently became aware pursuant to F.R.C.P. 26, (e)
of the Law; aware of the requirements of a professional's Oath of
responsibility, and have become aware of a progress of:
& fraud, F.R.C.P. 9 (b) U.S.C.A.
Title 18, section 3483
& collusion, U.S.C.A. Title 18, sec. 1621
& Title 28, sec. 85,
note 1359
& extortion U.S.C.A. Title 18, section
1621, 1622
& perjury, U.S.C.A. Title 42, section
1986, 1985, 1983
& in conspiracy. U.S.C.A. Title 18 , section 1985
by the Defendant, Tamara Ann Zehnder, alias TAMARA GARTIN, the parties;
Pastor Robert V. Zehnder & Delores Jean Zehnder, agents of the Bethlehem
Lutheran Church and School, Inc. of the Missouri Synod,and legal counsel; A.
Troy Ciccarelli, J. Terry Wiggins, Markus Bernard Merritt, Valerie Krogman,
Alan Karsh, Fred Gabler, Larry Fulton, Seymour Joseph, Magistrate Russell A.
Stuska, Chief Judge William DuMoulin, Judge Charles Hoppin, Judge Roy Olsen,
Chief Judge Henry Nieto, agents of U S West, Inc.and other parties, both
named above and presently unknown to the Plaintiffs without Discovery in
cases 96C7386 - 96C7387 - 96C7388 and Incorporated Case # 96CO7019,
96CO1478, 96CO1439, 96CO140.
.
13. Presently the parties at Karsh & Fulton, P.C.; J. Terry Wiggins, A.
Troy Ciccarelli and Valerie Krogman, and such others and their
co-Defendants, Tamara Ann Zehnder (alias Tamara A. Gartin),Robert & Dolores
Zehnder and Markus Bernard Merritt, are all in conspiracy, in malicious
contempt of the orders of the Court in Cases 95-DR-2718, #96CO3788,
#96CO3787, #96CO3786 to which they are party and seek to deny the Plaintiffs
any proper recourse in Federal District Court Case #96-CV-1478 by
consciously and deliberately giving false and misleading testimony to law
enforcement and judicial authorities in order to falsely imprison and
continue to imprison Plaintiffs.
14.The Family Zehnder sought in perjury,and were granted, fraudulent
Restraining Orders based upon misinformation and misleading information
concerning proper legal notification by FAX and all their applications have
been a malicious fiction and a frivolous contempt of the proper use of the
Honorable Court's valuable time in cases 96C7386 - 96C7387 - 96C7388 and
Incorporated Case # 96CO7019, 96CO1478, 96CO1439, 96CO140.
.
15. The Family Zehnder sought and were granted fraudulent Restraining Orders
based upon some gratuitous fantasy concerning imagined or constructed 'fears
of violence','religious fanaticism' and all their applications have been a
malicious fiction and a frivolous contempt of the proper use of the
Honorable Court's valuable time in cases 96C7386 - 96C7387 - 96C7388 and
Incorporated Case # 96CO7019, 96CO1478, 96CO1439, 96CO140.
.
16. The Family Zehnder deliberately gave false information to Law
Enforcement Authorities of Greenwood Village, Lakewood, Jefferson County and
the Federal (anti-terrorist) Law Enforcement Authority in intent of perjury
and murder to cause a SWAT team to view Steve Douglas, Gartin in a
'terrorist' profile which would cause his death at the hands of Authorities
for the purposes of murder, as threatened repeatedly by Tamara Ann Gartin
and in Jefferson County District Court per transcript. This was an
Attempted Murder by the use of the Police. This and all their applications
have been a malicious fiction and a frivolous contempt of the proper use of
the Honorable Court's valuable time in cases 96C7386 - 96C7387 - 96C7388 and
Incorporated Case # 96CO7019, 96CO1478, 96CO1439, 96CO140.
16. The contempt of the Defendants, Tamara Ann Zehnder, Markus Bernard
Merritt, their compliant accomplices, Robert V. Zehnder & Delores Jean
Zehnder, Timothy & Francisca Zehnder, Thomas Zehnder and Michael Zehnder and
their self described legal team Karsh & Fulton, P.C. and in its persons all,
for a restraining order against my proper legal action taken in full view of
the Honorable Court and notification by FAX, a proper legal method, pursuant
to C.R.S. 125, is an obstruction of justice contemptuous of the time and
notice of the Court and an effort to deceive, conceal, and misdirect the
Court's proper attention from their own criminal activities and to falsely
arrest and imprison Plaintiffs.
17. The proper service of legal and other information by FAX(modem), and
other electronic evidence, is a matter of law. It is and has been the only
means of communication that I could afford. This information is, in fact,
electronic in nature and proper service is demonstrated by reception
signals. Additionally, all FAX numbers were provided by recipients in the
course of their business. Karsh & Fulton, PC a business of legal services
provision in the state of Colorado, was the first to FAX and such
communication was common until they were named also as Defendants, sought
application before the Court for "harassment by FAX" and after refusing my
proper notification to them by FAX transmission in contempt of the Court and
its time and its knowledge of the Law and to maliciously obstruct justice
and deny Civil Rights to Plaintiffs in violation of law and the Ethical
Canons and such codices of conduct.
18. Presently the parties at Karsh & Fulton, P.C.; J. Terry Wiggins, A.
Troy Ciccarelli and such others and their clients, Tamara Ann Zehnder (alias
Tamara A. Gartin), Robert & Dolores Zehnder and Markus Bernard Merritt,
Timothy, Thomas, Michael, and Francisca Zehnder, and Bethlehem Lutheran
School, Inc., in the person of Peter Woodward, are all in conspiracy, in
knowingly malicious contempt of the orders of the Court in Cases 95-DR-2718,
#96CO3788, #96CO3787, #96CO3786 and seek to hide that fact from the Federal
District Court Case #96-CV-1478 by giving false testimony in support of
fraud and to obstruct justice.
19. The Judges, as named above, have deliberately and maliciously held
Plaintiffs to a high standard of form and failed to give judicial attention
to substance in all my applications in spite of the Plaintiffs posture as an
Indigent and without councel, standing in the Proper Party Injured in cases
96C7386 - 96C7387 - 96C7388 and Incorporated Case # 96CO7019, 96CO1478,
96CO1439, 96CO140 and such others, in order to obstruct justice in Case
#96-CV-1478 to which they are Defendants and failing to secure Plaintiffs'
rights to due process and equal protection of the law and in perjury of
their Ethical Canons, Codices of Conduct and Responsibility and their
several Oaths of Office.
20. The Law Enforcement Authorities, as named above and by agents, have
sought to improperly intimidate and interfere with my Witnesses against
Defendants by threatening unwarranted prosecution and other malicious
harassment against such Witnesses in cases 96C7386 - 96C7387 - 96C7388 and
Incorporated Case # 96CO7019, 96CO1478, 96CO1439, 96CO140, Case #96-CV-1478
and such others.
21. Karsh & Fulton, PC, in the persons of J. Terry Wiggins and Antonio Troy
Ciccarelli, has sought to improperly interfere with and intimidate my
Witnesses and to falsely detain co-Plaintiffs and Witnesses to prevent their
proper testimony in Golden Municipal Court, Jefferson County District Court
and the Federal District Court, Colorado Case #96-CV-1478 in cases 96C7386 -
96C7387 - 96C7388 and Incorporated Case # 96CO7019, 96CO1478, 96CO1439,
96CO140 and such others.
Steve Douglas, Gartin
PO Box 114 Message
Phone: 364-0403
Golden, Colorado Zip Exempt Message FAX: 739-9824
(File created on: Monday, March 03, 1997 11:52:00 AM)
1741 Dallas Street
Aurora, Colorado
80010-2018
303.364.0403 (vox)
303.739.9824 (fax)
e-mail: gryp...@home.com
Intake Department
Colorado Civil Rights Division
Denver, Colorado
15 Feb 02
Subj: Civil Rights abuses
I hope that your agency is the right one to approach. If I am wrong, please
forward my complaint to the appropriate administrative or legal agency.
I tried to prefer charges with the Attorney General's Office, the Denver
District Attorney's Office, the Denver Police Department, the Jefferson
County District Attorney's Office and with the presiding judge, Hon. Leland
P. Anderson, to no avail. While those I spoke with agreed with me that I had
been victimized, none would take jurisdiction over any of the persons
involved or the events that have transpired.
I have consulted with three attorneys, each of whom agrees that I have a
significant cause of action, but that their Firms didn't have the resources
necessary to mount such a prosecution.
My situation and history are as follows:
I have been subjected by officers of the law and prosecutors, to
a deliberate and malicious attempt to improperly coerce, intimidate and
influence me, as a Witness, through actions, threats, intimidation and
defamation. They have constructed a character of pure fantasy, assigned that
fantasy to me and investigated, indicted, arrested, detained me, required
surety bond, compelled my taking counsel for representation, and to defend
myself against vigorous prosecution with no cause whatsoever, none.
Their motivation stems from my position before the Court as a
3rd Party Witness for a Plaintiff in Federal Complaints, Mr. Steve Douglas
Gartin. He is complaining of various abuses of his civil rights in the
Federal Court. Whether Mr. Gartin is right or wrong in his complaints is of
little or no relevance to the abuses against me. My witness on his behalf
consists solely of observing meetings with administrators and investigators,
witnessing the service of legal process and documents and, by now, being
privy to the process as it has proceeded. I am not a principal in any of the
disputes; neither gain nor lose by any decision on either side of the
question.
Over some good period of time, four years or more, I have been
threatened by lawyers, a police officer, Sheriff's Deputy, and an FBI agent,
that my witness (presumably against them) for Mr. Gartin would 'lead to
trouble'. They have uniformly been individuals that are Respondent to Mr.
Gartin's complaints in Federal Court, or representatives of agencies or
other group interests. I have been investigated by: the Federal Protective
Service (Threat Assessment Division; Scott Tuttle), the U.S. Marshall's
Office (Dep. US Marshall Randy Martin), the Federal Bureau of Investigation
(an unknown agent, Special Agent Kurt Maleri, Spl. Agent Mark Hostlaw), the
Intelligence Unit of the Jefferson County Sheriff's Department (Dep. Sheriff
Don Estep), the Colorado State Attorney General's Office (Senior
Investigator Gary Clyman), the Greenwood Village Police Department (Det's.
Carr, Stadterman, Lt. Fisher) and have been thoroughly vetted for any
criminal involvement or 'political incorrectness'. All of those people are
either respondents to Mr. Gartin's complaints or represent the interests of
such other respondents as have organizational associations.
On February 19th, 2001, I was surprised to be arrested at my
home in Adams County by the Fugitive Felon Apprehension Team from Jefferson
County on a, previously unknown to me, Fugitive Felony Arrest Warrant
issuing from a Sealed Grand Jury Indictment (00CR001) issued 60 days prior
(23 Dec 00). There were sixteen charges; fifteen Felonies and one
Misdemeanor of violence; Attempt to Influence a Public Official, Filing
False Instruments (multiple counts), Computer Crime, Criminal Extortion
(multiple counts) and Carrying a Concealed Weapon on a Jefferson County
School Ground. (Ref. Jefferson County Case number 00CR3373) The arresting
officer read a number of the charges to me; I recognized nothing that would
have anything to do with me. I was bleeding from the wrists by the time we
reached the Detention Center due to the handcuffs. I was confined in
solitary, in the 'Cold Cell' for a number of hours dressed in light jail
clothing until I was shaking uncontrollably. They transferred me to a jail
cell with one blanket on a floor 'bed' where I froze all night.
On the third day, they took me to 'video arraignment' where I was told that
I was a 'special case' and would be arraigned under different circumstances
at a later date.
On my third day in jail, I was shown, very quickly, but not
given, a list of the charges, and was told that the Indictment was 'sealed'.
Arraignment was delayed for four days whilst they threatened me with the
contents of the 'sealed' Indictment, in order to extort a 'proffer' of
testimony and assistance, and while they abused my health and mental state.
The prosecutor for that Indictment was Attorney General Ken Salazar and
Senior Deputy Attorney General Marlene M. Langfield, Esq. of the Colorado
State Attorney's Office. The fifteen felony charges and the misdemeanor were
carried forward by the Jefferson County District Attorney's Office with
Marleen M. Langfield prosecuting under the rubric of 'Special Deputy
District Attorney of Jefferson County Colorado'.
Her investigative team; Senior Investigator Gary Clyman of the Attorney
General's Office, Senior Intelligence Investigator Don Estep of the
Jefferson County Sheriff's Department and Special Agents Kurt Maleri and
Mark Hostlaw of the Federal Bureau of Investigation, were operating under
the rubric of the 'MultiJurisdictional Domestic Terrorism TaskForce'..
I applied for a Public Defender, and was assigned Cynthia
Sheehan, Esq. of Cynthia Sheehan Law Practice.
Immediately upon Attorney Sheehan's appearances in the first
months after my arrest, the first fifteen felony charges were dropped; as
was the misdemeanor CCW. The charges were utterly unfounded, they comprised
a hazard of some one hundred and thirty years in prison. Nothing in the
indictment reflected any testimony against me by any complainant. The
charges were groundless, abusive of the process and done under the color of
their authority for personal, as well as professional reasons.
The surviving felony indictment, Criminal Extortion, was carried
by Special Deputy State Attorney General Marlene Langfield for several
months until a petition was made by the District Attorney's office to
dismiss. The charging was inappropriate by any measure- even if events had
transpired as was alleged- which they had not.
I was thoroughly cooperative throughout the experience.
One night in jail, the two lead investigators, Gary Clyman and
Don Estep, took me to my home in Aurora to get computer information from me.
They told me about all the felony charges in the sealed Indictment, how they
presently could charge me with 'aiding and abetting a Federal fugitive', and
would proceed with all the personal power they could bring to prosecution if
I did not give them my security passwords, remote access to my computer,
Gartin's possible passwords, e-mail addresses, website addresses and other
data. I complied with their threats because I knew already that they were
capable of falsely charging me with felonies, arresting me, holding me in a
'cold cell', leaving me without a blanket and engaging other custodial abuse
based for the jailers, I believe, on the charge of 'Carrying a Concealed
Weapon on a Jefferson County Schoolground'. They returned me to the Jail in
the early evening, spoke to the Jailers, and I was held in the Intake Tank
for the rest of the night, taken late to Court the following morning;
without sleep, opportunity to wash, relieve myself, or be presentable,
mentally distraught from the hours of craziness and aggressive activity.
Sometime after the first part of March, I began to realize that
all my business webpresence had been destroyed. My webspaces were no longer
available to me because the passwords had been changed. This included my two
webaddresses that were very desirable and valuable. At the same time, all of
Mr. Gartin's webpresence was destroyed; business, personal, legal
evidence/documentation, political and social commentary, religious
information, archival storage and so on.
Only the Attorney General's Office's MultiJurisdictional
Domestic Terrorism TaskForce Investigators Clyman and Estep had the
requisite four separate and distinct passwords (constructions of alphabet
and type ornament, case sensitive) and credit card number that were
necessary to raze both sets of sites or access my computer and Internet
Service Provider from a remote station. Nothing whatsoever on any of the
sites was of any relevance to their investigation and destroying them was
not only simple malice, but the crushing of any financial means to aid any
meaningful defense against their false charges, or pay simple living
expenses, as well as obstructing the recovery of evidence and documentation
that was in data storage.
Further, they released to the media and on the World Wide Web
Internet, that I am a 'Patriot', with ties to the Christian Identity group.
That media release was parroted by the ADL and SPLC types of groups,
newspapers, FBI special interest releases all across the world- all sorts of
individuals and institutions have deliberately been led to infer by this
defamation and false information, that I am a racist, a bigot, a religious
zealot; armed, violent supporter of bombers and robbers with a religious
justification and fervor.
In fact, I am a longtime civil rights observer, trained by the
Government as a GS-15 during the 'Model Cities' years, on subjects ranging
from race questions, anti-war, the environment; community involvement,
gender equality and parity. I am a professional artist and craftsman for
many years, long in residence at my home. I have never known any of those
kinds of people, never been to any sort of meeting or gathering, never read
their literature except at the most superficial level of the popular press,
never donated to any of them; never anything to do with them whatsoever.
I have been falsely and maliciously charged by Marleen M. Langfield,
recklessly and contemptuous of the law, and the those charged dropped when
sustenance to them was required in Court. I have been arrested on these
false charges, detained, and bond required of me on charges that were
knowingly and deliberately proffered by Senior Deputy Attorney General
Langfield. They have destroyed my businesses on the Internet, defamed my
reputation by accusing me of crimes and of heinous social views, knowing
that it was wrong in every manner.
Please help me.
Thank you for your kind consideration; I am at your convenience.
Charles H. Clements
Charles H. Clements
1741 Dallas Street
Aurora, Colorado
80010-2018
303.364.0403 (vox)
303.739.9824 (fax)
e-mail: gryp...@attbi.com
Deepak Patel, Director
American Civil Liberties Union
Denver, Colorado
15 Feb 02
Director Patel:
Sir:
Lisa Culpepper, Esq. of the Culpepper Law Firm has indicated
that you are receptive to a bit more information about these circumstances
of my application to the Union for help in proceeding with a civil case. I
need legal assistance to recover what the government has taken from me, but
I have no means to pay for a civil prosecution. I tried to prefer charges
Opportunity knocks! Obviously, someone has viewed my video productions and
perceived some sort of a threat. Perhaps it is because they contain too
much *real* information. Maybe there are too many secrets revealed. It
could even be that some folks think I must be making money and want part of
the pie - or all of it. Whatever motivates these spineless worms of
humanity, I have to give them a nod for persistence. If they worked this
hard on their own projects, their own lives, their own jobs they too may
have some work product to market. Instead, their stock in trade is slander,
libel and public defamation; Roger Brockman's mother must be proud that he
has actually done something. . . albeit not attaining to the standards of a
slug in terms of productivity nor a buzzard in terms of creativity - it may
be the most industrious he has been in his life. Imagine how hard he and
Victoria de Thouars-Tollman must have worked to type out all this slander,
libel and defamation and then to post it through anonymous re-mailers! I'm
impressed! In the twenty years I have known the pair of them, I've never
seen them complete a project of any sort. Kudos kidz! Willem may not be so
pleased however when he returns from Mexico to find that they have put
everything he owns at risk - first being his reputation and integrity. . .
not my job any longer.
But thankfully, Roger and Vicki have opened the litigational floodgates and
connected the dots to the deep pockets - how endearing. By inference they
have provided WAY more information than any rational person would care to be
liable for - but mouthing off is what Roger is most famed for. Sort of
surprises me coming from Vickie though.
Were their research skills commensurate with their flatulence they would
have found that they have, once again, made some absolutely false and
misleading statements that will return to haunt everyone they are connected
to. If any of you really care to know Chas' background, it is very clearly
stated in our first video together, entitled Heartless Monkey Knife, and is
available for order from 1-800-USA-TAPES or from our website:
www.kuntaosilat.com - you could even call Chas for a copy 303-364-0403.
My life is an open book, most of it in the courts records and easily
accessible on my personal website: www.gartin.homepage.com and
www.sheriffsteve.homepage.com
Since the criminal John Stone is being recalled and I'm back in the running
for Jefferson County Sheriff, you can rest assured that if anyone has any
legitimate complaint against me, it will be common knowledge if it's not
already.
At the risk of being accused of pride fullness, I think that the new videos:
Heartless Monkey Knife, Cane Combat for Cripples and Secrets of Silat are
much better than the two series I produced for Willem. And I continue to
improve both the quality of the presentation and the production with each
new video I produce. Several kind souls have emailed me with ideas for
productions and improvements that I have taken to heart and am acting upon
with dispatch. I expect to have at least six new videos produced before the
Recall Stone election begins on June 5th, whereupon I will have to divert
much of my attention upon my Mission for Election.
Speaking of the Election; one of the most dis-heartening discoveries I have
made in recent years is the rampant corruption in government that is
prevalent in our Country. When I became the First Registered Candidate for
Jefferson County Sheriff in 1997, all manner of evil was unleashed upon me.
That story has yet to be told in its entirety, but it involves Spyderco,
First Interstate Bank, NorWest, the City of Golden, the I.O.F., Douglas
County Government, Jefferson County Government, Greenwood Village Police
Department, Arapahoe County Government, the I.R.S., Roberto Torres, H.
Arthur Gitlin, Bob Orlando, Sam Edwards, Don Ethan Miller, the Federal
Protection Agency, the Lutherans for Profit, Inc. and copious quantities of
Liarz, Esquires, Judges and cops of all descriptions. Now that I think of
it, I may turn that into a video too - fiction can't hold a candle to this
story.
So, in a perverse sort of way, I guess these tortfeasors and slanderers have
aided in the promotion of Chas and I in our new careers as promoters of
ourselves rather than our Teachers. Thanks would probably be stretching it
though - so I'll jest bid a fond "see you in court" to those who *think*
they can hide behind anonymous mail servers. There is more than enough
truth to go around.
And one more thing; I have absolutely nothing to hide and I don't think Chas
does either - so if anyone has any questions, please fire away and let's get
the air cleared so we can get rich selling our own videos.
By the way, I truly appreciate those individuals to have supported us in the
past and present. . . I don't forget that either! God bless you all.
Have a most enjoyable day,
Steve
why do I get the impression I asked a bigger question than intended. I just
asked because I remembered I think, Chas posted something about this a
while back and was just curious. I didnt realize it was this involved.
> > So, in a perverse sort of way, I guess these tortfeasors and slanderers
> > have aided in the promotion of Chas and I in our new careers as
promoters
> > of
> > ourselves rather than our Teachers. Thanks would probably be stretching
> > it though - so I'll jest bid a fond "see you in court" to those who
> > *think*
> > they can hide behind anonymous mail servers. There is more than enough
> > truth to go around.
> >
> > And one more thing; I have absolutely nothing to hide and I don't think
> > Chas does either - so if anyone has any questions, please fire away and
> > let's get the air cleared so we can get rich selling our own videos.
> >
> > By the way, I truly appreciate those individuals to have supported us in
> > the
> > past and present. . . I don't forget that either! God bless you all.
> >
> > Have a most enjoyable day,
> >
> > Steve
> why do I get the impression I asked a bigger question than intended. I
just
> asked because I remembered I think, Chas posted something about this a
> while back and was just curious. I didnt realize it was this involved.
Hey, I'm just a full disclosure sort of guy. All the minions of government
tyranny have spent 13 years trying, with unlimited funding, to find a
crime - any crime - that I may have thought of committing . . . and have
miserably FAILED. Now, it is all going to come out for the public to view.
Let's see how it all turns out.
Steve :-)>>>>>>>>>>>>>
www.stevegartin.com
because it's still going on.
The Greenwood Village stuff was just an overture to what they were prepared
to do, and did, to stop the complaints in Federal Court- where they had
dragged Gartin in the first place.
Trav was talking about us/me picking fights- bullshit. We've been the
subject of harrassment for a decade, and it's always threatened with
criminal sanctions- going to fucking jail for petitioning the government for
redress of grievance.
That's the Bill of Rights; Amendment Number One- first pop out of the box is
being able to go to the Government. Right after that comes 'Due Process of
the Law'.
The sanctity of the Witness is a cornerstone of the Rule of Law.
Intimidating a Witness is a very serious crime, and having it done by police
officers is unconscionable.
It's not some looneytune, black helicopter, tax protest, militia, Patriot,
white-supremist bullshit.
It's a claim on our guarantees and the sole hope for justice.
It's funny until they come for you.
Chas
This is what the 8 April, 2004 hearing is all about. Never raised a hand to
a copsucker before or since, yet Gary Clyman STATE AG) insists that the
CALL OUT THE SWATZis jacket he has placed upon me is necessary for *officer
safety.* I'm getting damn tired of copsuckers pointing fully automatic
laser sighted high capacity weapons at me everytime they want to check my
driver's license. Here is where the rubber meets the road. You're all
welcome to attend.
Steve Gartin
www.stevegartin.com
Some old notes that were converted into a Civil Rights Action - handwritten
from solitary confinement during my prison sentence for contempt of court,
so said.
____________________________________________________
SWATzies WarrantLess Assault
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
____________________________________________________________
Civil action No.97-D-1036 Inc. Cause of Action Date:
26 February and 5 May 1997
______________________________________________
Steve Douglas, Gartin ]
Plaintiff ]
]
v. ]
Charles T. Hoppin
]
Ronald L. Miller
]
James Demlow
]
Roy Olsen
]
Henry Nieto
]
Marilyn E. Leonard
]
Dorothy Cline
]
Judith Cherne
]
Antonio Troy Ciccarelli
]
J. Terry Wiggins
]
Alan Karsh
]
Larry Fulton
]
Seymour Joseph
]
Fred Gabler
]
William Hayashi
]
Maurice Knaizer
]
Lynda Donnelly
]
James Hollaway
]
Elizabeth Kiovsky
]
George Brauchler
]
David J. Thomas
]
Ted Maclinberg (sic)
]
James Peters
]
Darren Voss
]
Gale Norton
]
William Pharo
]
Jefferson County Sheriff
]
Arapahoe County Sheriff
]
City of Golden
]
City of Littleton
]
Golden Community Center, Inc.
]
City of Aurora
]
City of Greenwood Village
]
U S West, Inc.
]
Lutheran Church, M.S.
]
Bethlehem Lutheran, Inc.
]
Office Space Saving Concepts, Inc.
]
STATE OF COLORADO
]
Spyderco, Inc.
]
Jefferson County Board of Commissioners
]
Arapahoe County Board of Commissioners
]
Karsh & Fulton, P.C.
]
Robert V. Zehnder Estate
]
Dolores J. Zehnder
]
Michael Zehnder
]
Timothy Zehnder
]
Francisca Zehnder
]
Markus B. Merritt
]
David Langewisch
]
Peter Woodward
]
Chet Shoaf
]
Richard McCormick
]
Daniel Manson
]
Ernest L. Laseter
]
Bill Stevens
]
Rich Waugh
]
Mike Bestor
]
Roy Romer
]
Ronald Beckham
]
Donald Estep
]
James D. Johnson
]
Grant Whitus
]
Deputy Martin
]
Dennis Beery
]
Allen L. Simmons
]
Lieutenant Manwaring
]
Sgt. Williams
]
Kirk G. Beaulieu
]
Barry L. Williams
]
Raymond Fleer
]
Joseph McGuire
]
Frank Lastoczy
]
Jack Jackala
]
Sgt. Walcher
]
Lt. Shrader
]
Randall West
]
Daryl Hoffman
]
Mark Nazaryk
]
A.J. DeAndrea
]
Michael Moler
]
Bill Killpatrick
]
Russell Cook
]
Dave Farley
]
Robert Tortora
]
Glenn Moore
]
Lewis Shellenberger
]
Ted Schnack
]
Mike Hendershot
]
Mark Stadterman
]
John Carr
]
Jeff Mulqueen
]
Bruce Davis
]
Ewan Scouse
]
David Fisher
]
Steven Crowell
]
Michael Harris
]
Susan Hines
]
Mary Sutton
]
Pete Page
]
Patrick Sullivan
]
W.H. Fields
]
Vincent Landis
]
Ethan Feldman
]
Robert L. Allen
]
Chief of Police
]
Steve Zotos
]
Robert Wood
]
Robert McMahon ]
Kim Castellano
]
Corporal Reese
]
Defendants (see appendix)
Trial By Jury Demand Herein
Complaint of Civil Rights Violations pursuant to
Title 42 §§1986, 1985, 1983
Criminal Complaint pursuant to Title 18
§§ 241, 242, 872, 1001, 1621 & 1622
Comes now the Plaintiff, Steve Douglas, Gartin who is of proper age, of
sound
mind, tells the truth and has first hand knowledge of events and actions
contained herein, without an attorney and in full possession of all
inalienable
rights and states:
Ex Rel.
Know all men by these presents, I Steve Douglas, Gartin with standing to
bring
this case, being in possession of all unalienable rights and protected by
the
Constitution of the united States and Colorado state: for the People of the
united States of America, under the American Flag of Peace, without an
attorney,
Ex Rel. state:
1. Ex Rel: for the people of the united States defined: "But it is the
manner of
enforcement which gives 42 U.S.C.A. 1983 its unique importance, for the
enforcement is placed in the hands of the people." Each citizen, "acts as a
private attorney general who takes on the mantle of the sovereign, guarding
for
all of us the individual liberties enunciated in the constitution." Section
1983
represents a balancing feature in our governmental structure whereby
individual
citizens are encouraged to police those who are charged with policing us
all.
JUDICIAL CAPACITY
2. The Constitution of the united States, U.S.C.A. Article III, 1 Note 62. A
"controversy" in the constitutional sense must be one that is appropriate
for
judicial determination, be definite and concrete touching legal relations of
parties having adverse legal interests, and be a real and substantial
controversy admitting of specific relief through decree of conclusive
character.
3. The Constitution of the united States, U.S.C.A., Article III, 1 Note 64.
Exercise of judicial power under the Constitution depends on existence of
case
or controversy.
4. The Constitution of the united States, U.S.C.A., Article III, 1 Note 162.
Judicial power of the United States is vested in federal courts and extends
to
prosecutions for violations of criminal laws of United States.
CONSTITUTIONAL COURT
5. The Constitution of the united States, U.S.C.A., Article III, 1 Note 92.
Constitutional Courts. "Constitutional courts" are those recognized and
provided
for in this section and includes Supreme Court and inferior courts which
Congress may from time to time ordain and establish under authority
conferred
thereby.
6. The Constitution of the United States, U.S.C.A., Article III, 1 Note 114
"district court of the United States" without more, means solely courts
created
by Congress under this article and not territorial courts.
CASE LAW
7. The Constitution of the United States, U.S.C.A., Article III, 2 Note 131
This
clause embraces alike civil and criminal cases arising under the
Constitution
and law; both are equally within the dominion of the judicial powers of the
United States, and there is nothing in the grant to justify an assertion
that
whatever power may be exerted over a civil case may not be exerted as fully
over
a criminal one.
The following facts establish the rules to be used by the court. Notice that
the
Federal rules of Civil Procedure are written as limits for litigants in the
United States District Court. Also notice that while those rules are
intended
for use in law cases, they do not limit the litigant in law to using just
those
rules. Indeed those rules cannot limit the relief of litigants in law.
8. The Constitution of the United States, U.S.C.A., Article III 1 Note 54
Congress possesses the sole right to say what shall be the forms of
proceedings,
whether in equity or at law. Congress possesses the sole right to say what
shall
be the forms of proceedings, either in equity or at law, in the courts of
the
United States, and in what cases an appeal shall be allowed or not;
Congressional power to prescribe procedure to be employed by court created
pursuant to this article is limited by the Constitution and specifically by
Amendment Seven.
9. The Constitution of the United States, U.S.C.A., Article III 1 Note 23.
The
Constitution of the United States and Acts of Congress recognize and
establish
the distinction between law and equity; the remedies in the courts of the
United
States are, at common law or in equity, not according to the practice of
state
courts, but according to the principles of common law and equity, as
distinguished and defined in that country from which we derive our knowledge
of
those principles.
Distinction between law and equity must be preserved in federal courts under
constitutional provision defining judicial power of United States, . . .
Under the Federal Constitution, the distinction between law and equity must
be
observed. Though under Rule 2, Federal Rules of Civil Procedure, 28 U.S.C.A.
all
distinction as to form between actions at law and suits in equity have been
abolished the difference in substance in federal judicial power between law
and
equity is imbedded in the constitution and remains unaltered.
RULES
10. P.L. 675 Chapter 445, 54 Stat. 688, (1940) Congress makes rules for
court
procedure.
11. P.L. 415 Chapter 631, 48 State 1064, (1934) . . . Section 2 The court
may at
any time unite the general rules prescribed by it for cases in equity with
those
in actions at law so as to secure one form of civil action and procedure for
both; Provided, however, that in such union of rules the right of trial by
jury
as at common law and declared by the seventh amendment of the Constitution,
shall be preserved to the parties inviolate.
12. Prejudice means: aforejudgement; bias; partiality; preconceived opinion.
A
leaning toward one side of a cause for some reason other than conviction of
its
justice. Black's Law Dictionary 6th. Any and all presumptions and any and
all
associations in common.
CONTROVERSY
13. U.S.C.A., The Constitution of the United States, Article III, Case Note
62
SPECIFIC Charges
14. Defendant Judicial Officers, each of them and them all, hereinafter
referred
to as "Judges," et al, having superior knowledge of the law and a high
standard
of the law as confirmed by their oath of office, and witnessing the fraud
committed by Defendant Officers of the Court, hereinafter referred to as
"Attorneys," when those Attorneys brought false, fraudulent and unfounded
suits
against Plaintiff herein, in conspiracy with private Citizens, who was not
the
person named on the complaint; those Defendant Judges, Attorneys, and
Citizens,
and all of them in each and every cause of action herein indicated of this
action, KNOWINGLY caused damages and deprivation and neglected to correct or
prevent the wrongs pursuant to Title 42 U.S.C.A., 1986.
15. Defendant Judges, each and every one of them and et al, in court rooms
they
themselves knowingly colored with an Executive Flag, pursuant to Title 4
U.S.C.A. 1, Part II, in a "Federal Agency," 1994 Act to Reorganize the Govt.
63
Statutes at Large, Chapter 288, Sec. 3 (b), the term "Federal Agency" means
any
executive agency or establishment in the legislative or Judicial branch of
government, Title 5, p. 739 section 5721.
"Agency" means (C) a court of the United States; took rights from Plaintiffs
herein, Plaintiff's Rights and Liberty, by means of illegal compulsion and
oppressive exaction, compelling judgments on the Plaintiff, when Plaintiff
was
not named on legal process in cases enumerated above by Color of Defendant
Judge
s Office as Judicial Officer in conspiracy with Defendant Attorney 'a office
as
Officer of the Court in the same Bar Association shall be fined not more
than
$5,000 or imprisoned not more than three years, or both.
16. Defendant Quasi-Military Troops, hereinafter referred to as "Cops",
operating in Color of Authority, conferred by Color of Law, and each and
every
one of them above titled - and others yet to be discovered, knowingly and
willingly acted in concert and conspiracy with Defendant Judges, Attorneys,
Legal Assistants, Corporations, and private Citizens in behalf of Defendant
"Persons" to deprive constitutionally guaranteed Rights of this Proper Party
Injured. These acts were committed in high knowledge of the Law, evidenced
by
each and every "Cop's" Oath of Office and by threatened use of dangerous
weapons, intimidation, duress, fraud and mayhem; when each and every one of
the
above titled Defendant Cop's went in disguise upon the Highways and on the
premises of another with the expressed purpose and intent of depriving
Plaintiff
of constitutionally guaranteed rights at Amendment 1, 2, 4, 5, 6, 7, 8, 9,
10,
13, & 14 of the United States Constitution and corresponding Titles of the
Colorado Constitution.
17. Applicable Statutes and Codes
42 U.S.C.A. 1986: Defendants each had knowledge of the law and did or
witnessed
wrongs committed in their presence and neglected to correct and prevent.
42 U.S.C.A. 1985: Defendants each acted in Concert under color of law to
deprive
Constitutionally guaranteed rights.
42 U.S.C.A. 1983: Defendants each caused damages.
The neglects or actions of each of the Defendants violated Statutes that
bind
officers under color of authority and under color of law.
18 U.S.C.A., 241: Conspiracy against Rights
18 U.S.C.A., 242: Deprivation of rights in color of authority
18 U.S.C.A., 872: Extortion in color of authority
18 U.S.C.A., 1621: Perjury of Oath of Office
The Rules of Court show that Defendant's actions granted no jurisdiction
over
the Plaintiff in the lower court case.
F.R.C.P. 19 and 12 (b) (7) No Joinder of parties
F.R.C.P. 12(b)(6) Failed to State a Claim upon which relief can be granted
F.R.C.P. 12(b)(1) and (2) Lack's personam and subject matter jurisdiction.
Background:
DEFENDANTS UNLAWFUL WARRANTLESS ARREST OF PLAINTIFF IN CONSPIRACY TO DEPRIVE
RIGHTS AS AN OBSTRUCTION OF JUSTICE
On or about February 26, 1997 the Jefferson County Special Weapons and
Tactics
Military Unit, standing and paid for over two years, in violation of the
Constitution of the United States of America, did unlawfully attack the Home
of
Ernest Lynn Laseter at the mailing location of 1400 Golden Circle #108 in
Golden, Colorado in full force of arms to include; Fully Automatic Weapons
with
Laser sights, full Riot Gear, S.W.A.T. "Shields" and Body Armor. These
Military
Troops, in disguise as Jefferson County Sheriff Deputies, clothed in Black
Uniforms, Ski Masks and bearing NO IDENTIFYING MARKINGS DID UNLAWFULLY go in
disguise upon the highways AND on the premises of another, in conspiracy, in
full knowledge of their actions, with the specific INTENT, the means, and
with
the motive to UNLAWFULLY ARREST Plaintiff, who had committed no crime,
within or
without the sight or knowledge of the Defendants herein referred to as
"Quasi-Military Troops" and hereinafter abbreviated by the notation, "Cops"
et
al.
Said "Cops" resorted to the use of a BATTERING RAM to break down the locked
Door
at the above noted home residence; without probable cause, without a lawful
warrant, and without any knowledge of; who was inside the private residence,
or
whom they intended to unlawfully arrest after smashing in the door.
Defendant
Jefferson County Deputy Sheriffs and other Defendant Law Enforcement
Officers
called out the name of a person who was not known or present in the
premises,
claimed to have an Arrest Warrant that they did not possess, aimed at least
six
Laser-sighted Automatic weapons on this Plaintiff and threatened him . . .
"If
you do ANYTHING -you WILL BE SHOT" . . . that, a direct quote from the audio
tape recording of the Assault and Criminal Trespass, Attempted Murder and
Unlawful Arrest, and all under Color of Law and Color of Authority, which
are
the subject of this Complaint. Said Audio Tape is included as sure evidence
of
the criminal actions of "Cops" known as Jefferson County Special Weapons and
Tactics team at 1400 Golden Circle #108 in Golden, Colorado on the 26th day
of
February in the year of our Lord, Jesus, Nineteen Hundred and Ninety Seven
in
the Colorado Republic.
After unlawfully arresting, assaulting, battering, and committing mayhem
upon
the person and property of Plaintiff and the resident of the property,
Defendant
Sheriff Deputies then HANDCUFFED this Totally Compliant and unresisting
Plaintiff with torturous bone-tight "Riot Cuffs, although regular steel
handcuffs were available and are preferred, and transferred Plaintiff to
another
Defendant Sheriff Deputy who unlawfully Forcibly Kidnapped Plaintiff, and
illegally transported Plaintiff to the Jefferson County Sheriff Department
Detention Center without knowledge of the Identity or the alleged crime
committed by the Plaintiff as there was no Arrest Warrant or other proper
order
of any court.
Plaintiff was tortured by riot handcuffs for over SIX HOURS while
"terrorists"
disguised as the Defendant Sheriffs Deputies attempted to extort information
from Plaintiff. Plaintiff knew that his Liberty and Freedom had been
trespassed
and Fully Informed each and every Defendant Deputy and Defendant Law
Enforcement
Officer within hearing of their Violations of Plaintiff's Civil Rights and
their
numerous CRIMES against the Plaintiff, and the Deprivation of Rights against
the
Plaintiff. Each and every Defendant "Cop" refused to Cease and Desist their
Criminal Actions even after being fully informed of the Law and failed and
neglected to prevent or correct wrongs and to do their Sworn Duty to Uphold
the
Constitution of the United States of America and the Colorado Constitution.
Rather than relenting, the Defendant "Cops" further engaged in torture and
torment of Plaintiff for the directly expressed purpose of Extorting a
Waiver of
Plaintiff's Rights in Color of Authority and under Color of Law, in
Conspiracy
and in full knowledge; each Actor having the ability to prevent or correct,
witnessing the Deprivations being committed against the Plaintiff and
REFUSING
and NEGLECTING and FAILING to Correct or Prevent the WRONGS being COMMITTED
in
each actor's direct presence, when each Actor, "COP," had a Duty to protect
and
defend Plaintiff's Rights.
Claim I: UNLAWFUL WARRANTLESS ARREST _ Denial of Due Process
Heavily Armed Military Troops, in disguise as Multi-Jurisdictional Jefferson
County Special Weapons and Tactics Team Division of the Jefferson County
Sheriff's Department did unlawfully ATTACK a private residence in order to
illegally arrest Plaintiff.
Supporting Facts: Through an elaborate Conspiracy and meeting of minds of;
Defendant Private Citizens who intended and stated with malice and
aforethought
to unlawfully murder Plaintiff by use of government financed quasi-military
troops or otherwise; Defendant Officers of the Court who instigated,
designed,
masterminded and implemented said conspiracy; compliant quasi-judicial and
de
facto Defendant Judicial Officers for hire, military troops in disguise as
the
Defendant Officers of the Law, and Defendant Corporate Officers with
specific
fiduciary and other interests to protect from the light of truth; ALL
conspired
and colluded with foul intent to develop a false-persona of Plaintiff
whereby
the "government" would view Plaintiff as a threat, and deploy Heavily Armed
Troops to NEUTRALIZE the DANGER.
Claim II: Criminal Trespass: Breaking and Entering - Denial of Due Process
Military Troops in disguise as Officers of the Law, termed Jefferson County
Sheriff's Department, and Special Weapons and Tactics Team "Made Entry"
unlawfully into private residence.
supporting Facts: On or about February 26, 1997 Jefferson County S.W.A.T.
Team
did apply the "Department Ram" to the private residence located at 1400
Golden
Circle #108 in Golden Colorado.
Sheriff Deputies did then unlawfully bash in the residence door and invaded
the
residence in an "overwhelming" force of arms and with numerous armed
military
troops. Defendant Sheriff Deputies did not have in their possession any
Warrant,
either lawful or unlawful. Defendant Sheriff Deputies did at that time
completely destroy the residence door, which was private property, with the
"Department Battering Ram." Sheriff Deputies did make open threats of direct
murder upon the person of Plaintiff. The audio tape of the Criminal Trespass
confirms the ultimate fact that Defendant Sheriff Deputies broke into this
private residence with the INTENT to commit murder upon the Plaintiff.
CLAIM III - ASSAULT & BATTERY UNDER COLOR OF AUTHORITY
Plaintiff incorporates foregoing as if completely reproduced herein.
Immediately
after Sheriff's Deputies Trespassed by Unlawful Breaking & Entering into a
private residence, Defendants did unlawfully Assault Plaintiff with fully
automatic weapons by jamming the muzzles of those automatic weapons into
Plaintiff's spine, ribs and head with unjustifiable force. Plaintiff offered
NO
resistance. Sheriff's Deputies then unlawfully HANDCUFFED Plaintiff, who was
NOT
charged with a felony, for NO VALID reason or purpose, other than to torture
and
humiliate Plaintiff. Said unlawful actions being committed under Color of
Law,
caused Plaintiff damages including but not limited to, Physical Trauma,
Psychological Trauma, Physical Pain, enduring physical injuries,
humiliation,
and deep emotional trauma.
CLAIM IV - Cruel and Unusual Punishment and Sadistic Treatment under color
of
authority
Deputies applied 'temporary' Riot Handcuffs with excessive force, thus
cutting
off the blood circulation to Plaintiff's arms and hands, a known method of
torture. The Riot Handcuffs were then also 'cranked up' in such a manner as
to
initiate intense pain in Plaintiffs arms, shoulders and spine. Plaintiff was
totally compliant, offered NO RESISTANCE and made NO effort to escape the
unlawful arrest. Said excessive force, being committed in color of authority
caused Plaintiff damages including' but not limited to; Physical Trauma,
Psychological Trauma, Physical pain, enduring physical injuries,
humiliation,
and deep emotional trauma.
CLAIM V - KIDNAPPING -
Deprivation of Plaintiffs Right to Due Process of Law
and Equal Protection of the Law
Defendant Sheriff's Deputies, forcibly removed Plaintiff from the private
residence in which they unlawfully arrested him - IN HANDCUFFS and placed
Plaintiff in another Deputies Automobile. Said Defendant Deputy Martin; did
not
have knowledge of Plaintiff's identity, had not witnessed a crime, did not
have
a valid warrant, and refused to loosen the 'temporary use' Riot Handcuffs
that
were, by then, causing Plaintiff even greater pain and suffering as
Plaintiff
was now forced to sit in the back seat with his arms and hands painfully
cranked
up behind his back. Defendant Sheriff Deputy Martin repeatedly refused to
loosen
or adjust the handcuffs.
Deputy Martin transported Plaintiff directly to the Jefferson County
Detention
Facility although Defendant was informed by Plaintiff that he is required by
Law
to take any arrested person DIRECTLY before the nearest magistrate of
competent
jurisdiction - which Magistrate, Plaintiff had reason to believe, was
directly
across the street from the Detention Facility. Defendant Martin did
knowingly
and willfully kidnap the Plaintiff in reckless and wanton disregard for the
Law
of the Land in furtherance of the 'Conspiracy'. Said acts, committed in
Color of
Authority, caused the Plaintiff damages, including, but not limited to,
Physical
Trauma, enduring physical injuries, psychological pain and suffering, loss
of
time, loss of income, loss of FREEDOM, deep emotional trauma, humiliation
and
distress.
CLAIM VI - DENIAL OF DUE PROCESS - Unlawful Booking procedures
Defendant Deputy Sheriff Martin refused to take Plaintiff before the nearest
magistrate and instead took Plaintiff into the Jefferson County Detention
Facility for interrogation, booking, fingerprinting, photographing and
immediate, unjustified and unlawful incarceration. Defendant Deputy Sheriff
Martin did not know whom he had arrested, he was aware of NO CRIME committed
by
the unknown detainee, and yet he repeatedly refused to release Plaintiff or
loosen the HANDCUFFS to prevent additional pain and suffering to Plaintiff,
a
totally compliant Citizen whom NO ONE had seen commit ANY CRIME whatsoever.
Deputy Martin continued to attempt to Extort Plaintiff into telling him the
unlawfully detained Plaintiff's identity by threats, attempts to humiliate,
denial of and the failure to provide basic human necessities and the riot
handcuffs. Said extortion and deprivation of Plaintiff's Rights being in
Color
of Authority caused Plaintiff damages including but not limited to loss of
time,
damage to reputation, loss of income, intense pain and suffering, loss of
FREEDOM, deep emotional trauma, humiliation and distress.
Deputy Martin was fully informed by Plaintiff during the Kidnapping of the
trespass upon the Rights of the Plaintiff by the unlawful Arrest and above
stated deprivation of Plaintiff's Constitutionally guaranteed rights.
Defendant
Martin had NO EXCUSE!
Claim VII - Defendants denial of Due Process of Law - Denial of access to
the
courts- Denial of Equal protection of the Law.
Defendant Sheriffs Deputies' Reports, on file, confirm that the Plaintiff
was
unlawfully arrested at approximately 3 PM on a Wednesday. The Courts were
open
and Defendant Deputy Martin neglected and failed to take Plaintiff before
the
nearest Magistrate, and without unnecessary delay, as required by law;
depriving
Plaintiff of Due Process of law. Defendants deprivation of Plaintiff's
Constitutionally Guaranteed rights under color of state law caused Plaintiff
damages including but not limited to physical trauma, emotional distress,
psychological distress, pain and suffering, lost income, loss of Family,
loss of
career, damage to reputation and other collateral and related damages.
Claim VIII - Sadistic Treatment, Cruel and unusual punishment
for no crime and without due process of the law, failure to neglect or
prevent
wrongs or to provide equal protection of the law to Plaintiff and in
conspiracy.
Defendant Deputy Sheriff Martin witnessed no crime committed, and yet Deputy
Martin paraded Plaintiff around the Booking Rooms while Plaintiff was
tightly
restrained unnecessarily, still in riot handcuffs and for an extended period
of
time. Plaintiff politely and repeatedly informed Defendant Martin and all
the
other Defendant Cops present of the gross deprivation of Plaintiffs Rights;
delineated and described each Sworn Law Enforcement Officers' Duty to
Correct
and Prevent wrongs and Fully Informed each Defendant Officer of the Law
present
of his/her responsibility under the Constitution, USC. 42 1986, 1985 & 1983
as
well as 18 USC 241 & 242.
Defendant Martin became emotional and angry, resorting to excessive and
brutal
force to throw the already handcuffed and restrained Plaintiff into a "sound
proof" room to prevent and obstruct Plaintiff from informing all sworn Peace
Officers present of their Duty under the U.S.C., the Constitutions and the
Law
of the Land. Deputy Martin repeatedly refused to loosen the Riot Cuffs even
after Plaintiffs arms and hands had grown numb and purple from swelling.
Although Plaintiff cried out for relief from the Torture caused by the
"Bone-tight" riot-cuffs- all the sworn Sheriffs Deputies present refused and
neglected and failed to correct or prevent serious and permanent injury to
Plaintiff. Such willful and malicious torture being in Color of Authority
caused
Plaintiff Damages. Defendants deprivation of Plaintiff's Constitutionally
Guaranteed rights under color of state law caused Plaintiff damages
including
but not limited to physical trauma, emotional distress, psychological
distress,
pain and suffering, lost income, loss of Family, loss of career, damage to
reputation and other collateral and related damages.
Claim IX- Extortion by Torture, Denial of Human Rights and Necessities -
Assault and mayhem under color of authority-Denial of Plaintiffs Rights to
Due
Process of Law and Equal Protection of the Law by Defendants.
Defendant Martin had tried for several hours to Extort a Waiver of Fifth
Amendment Rights from Plaintiff by torture in "Bone tight" Riot cuffs. After
some six hours, Deputy Martin eventually gave up his efforts and shoved
Plaintiff into a "Booking Room" where a fresh set of Interrogators,
Defendant
Jefferson County Sheriffs Deputies, finally needed to cut the 'temporary use
'
Riot Cuffs off of Plaintiffs arms with heavy Wire Cutters.
Both Plaintiffs arms were purple and swollen, the left arm was immobile due
to
the trauma caused by the 5-6 Hours in Bone-tight Riot Cuffs.
Plaintiff repeatedly requested medical triage and treatment for his obvious
and
painful injuries and was repeatedly Denied by Defendants.
Plaintiff was then stripped, intrusively searched and further interrogated,
continuously threatened by Deputies to Extort a Waiver of Fifth Amendment
Rights
and thrown into the "rubber room" as further and continued torture in order
to
extort a Waiver or Joinder which Plaintiff would NOT concede.
Plaintiff was held for many hours in this punitive confinement; in an
injured
condition, without any food or any water, in deliberately frigid conditions,
without any bed or blanket, without any toilet and without access to a
telephone
or any Presentment to a Magistrate all night and into the next day in an
attempt
to extort by TORTURE a Waiver of Rights or a permissive joinder by speaking
Plaintiffs name. Plaintiff refused to waiver or joinder, but did fully
inform
each Defendant Deputy present of his/her Duty under the law and the
Constitutions.
All the Defendants present refused and neglected and failed to prevent or to
correct the wrongs they each witnessed; such wrongs committed in Color of
Authority caused Plaintiff damages. Defendants deprivation of Plaintiff's
Constitutionally Guaranteed rights under color of state law caused Plaintiff
damages including but not limited to physical trauma, emotional distress,
psychological distress, pain and suffering, lost income, loss of Family,
loss of
career, damage to Plaintiffs' reputation and other collateral and related
damages.
Claim X - Denial and deprivation of Due Process of Law and the Equal
Protection
of the Law by Fraud and Deception by the Defendants.
Late Thursday morning, an unknown Defendant Deputy Sheriff told Plaintiff
that
Defendant Judge Charles T. Hoppin 'had issued a Judicial Order' that
'required'
Plaintiff to relinquish a Fingerprint before the Court would 'allow any
appearance' by Plaintiff. Fearing not to comply, Plaintiff provided a
fingerprint "under duress" and "without prejudice" pursuant to U.C.C. 1-207
&
C.R.S. 4-1-207.
Upon the extorted and fraudulently obtained "compliance", Plaintiff was
moved to
"Classification", only then, after many hours in detention, was Plaintiff
allowed toilet, food, water and very restricted access to a "Gateway
Technology"
telephone pursuant to R.I.C.O. statutes 42 USC 1961. Plaintiff was never
presented this so-called "court order" in writing and further has good
reason to
believe said Deputy Lied and Perpetrated a FRAUD upon Plaintiff.
Said FRAUD by Defendant Sworn Law Enforcement Officer constituting a
deprivation
of Constitutionally protected Rights causing Plaintiff damages in Color of
Authority. Defendants deprivation of Plaintiff's Constitutionally Guaranteed
rights under color of state law caused Plaintiff damages.
Claim XI - Cruel & Unusual Punishment- Plaintiff was required under threat,
in
duress and by intimidation to "Force March" in shackles, chains & handcuffs.
Mid-Thursday afternoon Armed Military Troops in disguise as Defendant
Sheriffs'
Deputies came in force to Plaintiffs' jail cell; bound and shackled
Plaintiff,
hand, waist and ankles and forced him to march hundreds of yards from the
Jefferson County Jail to the Jefferson County Courthouse. Each and every
step
caused the ankle shackles to tear into Plaintiffs' Achilles tendon, causing
permanent scars and injuries. None of the shackles, chains or handcuffs was
removed upon entry to the courtroom or later in the holding area. Plaintiff
repeatedly informed each and every Defendant Deputy Sheriff of the injuries
and
each and every Defendant directly refused or failed or neglected to correct
or
to prevent further injuries. Said acts committed in Color of Authority
caused
Plaintiff injuries and damages. Defendants deprivation of Plaintiff's
Constitutionally Guaranteed rights under color of state law caused Plaintiff
damages including but not limited to physical trauma, emotional distress,
psychological distress, pain and suffering, lost income, loss of Family,
loss of
career, damage to reputation and other collateral and related damages.
Claim XII- Conspiracy to Deprive Plaintiffs' Right to Due Process on 2/27/97
in
Courtroom 3A by "Judicial Officer" Charles T. Hoppin,
Defendant Judicial Officer Charles T. Hoppin, hereinafter referred to as
"Judge," having superior knowledge of the law and a high standard of the law
as
confirmed by his oath of office, and witnessing the fraud committed by
Defendant
Officers of the Court, hereinafter referred to as "Attorneys," when those
Attorneys brought Fraudulent, false and frivolous suits against Plaintiff
herein, in conspiracy with Defendant Private Citizens, who was not the
person
named on the complaint.
Defendant Judges, Attorneys, Cops and Citizens, and all of them in each and
every cause of action enumerated herein this action, knowingly and
deliberately
caused damages and deprivation and neglected and failed to correct or to
prevent
the wrongs pursuant to Title 42 U.S.C.A., 1986.
Defendants deprivation of Plaintiff's Constitutionally Guaranteed rights
under
color of state law caused Plaintiff damages including but not limited to
physical trauma, emotional distress, psychological distress, pain and
suffering,
lost income, loss of Family, loss of career, damage to reputation and other
collateral and related damages.
Claim XIII- Deprivation of Due Process- the Presumption of Innocence
Defendant Judicial Officer Charles T. Hoppin, having a superior knowledge of
the
law and a high standard of the law as confirmed by his oath of office, under
arms, and witnessing the fraud committed by Defendant "Attorneys," when
those
Attorneys deprived Plaintiff of his Constitutionally Guaranteed right to be
provided an Indictment, a Summons/Complaint or Information of the
Accusation.
Plaintiff was forcibly taken to a "Courtroom" whilst standing in chains and
jail
clothes, without counsel, surprised; thus denying and removing the
Constitutionally guaranteed presumption of innocence and indicating 'guilt'.
Defendants provided No Indictment - No Summons/Complaint or Information in
deprivation of Plaintiff's Constitutionally Guaranteed rights under color of
state law. The deprivation of Constitutionally guaranteed rights caused
Plaintiff damages including but not limited to physical trauma, emotional
distress, psychological distress, pain and suffering, lost income, loss of
Family, loss of career, damage to reputation and other collateral and
related
damages.
Claim XIV- Excessive Bail required on 2/27/97-
Courtroom 3A by "Judicial Officer" Charles T. Hoppin
Defendant Judicial Officer Charles T. Hoppin, hereinafter referred to as
"Judge," having superior knowledge of the law and a high standard of the law
as
confirmed by his oath of office, and witnessing the fraud committed by
Defendant
"Attorneys," when those Attorneys deliberately and maliciously deprived the
un-represented and un-counseled and indigent Plaintiff of Plaintiff's
Constitutionally Guaranteed right to a reasonable Bail under color of state
law,
caused Plaintiff damages including but not limited to physical trauma,
emotional
distress, psychological distress, pain and suffering, lost income, loss of
Family, loss of career, damage to reputation and other collateral and
related
damages.
Claim XV- Charles T. Hoppin - Deprivation of Constitutional Right to Face
Witnesses
Defendant Judicial Officer Charles T. Hoppin, hereinafter referred to as
"Judge," having superior knowledge of the law and a high standard of the law
as
confirmed by his oath of office, under arms, and witnessing the Fraud
committed
by Defendant "Attorneys, in conspiracy with Defendant Private Citizens, to
deprive Plaintiff of the right to confront and examine witnesses against
him.
Defendant Judge, Attorneys, and Citizens, and all of them in each and every
cause of action enumerated herein this action, KNOWINGLY caused damages and
deprivation and neglected to correct or prevent the wrongs pursuant to Title
42
U.S.C.A., 1986.
Defendant 'Private Citizens' Tamara Ann Zehnder and Marcus Bernard Merritt
advanced on the court docket as Witnesses in Complaint. They deliberately
chose
not to be present at a proper time, obstructing justice and manipulating the
Court, depriving Plaintiff the opportunity to confront these 'Witnesses'
against
him, as guaranteed in the Constitutions. Defendants deprivation of Plaintiff
's
Constitutionally Guaranteed rights under color of state law caused Plaintiff
damages including but not limited to physical trauma, emotional distress,
psychological distress, pain and suffering, lost income, loss of Family,
loss of
career, damage to reputation and other collateral and related damages.
Claim XVI - Fraudulent ex parte hearing by Magistrate Marilyn Leonard
in conspiracy with Defendant Private Citizens Tamara Ann Zehnder and Marcus
Bernard Merritt
Defendant Judicial Officer Magistrate Marilyn Leonard, hereinafter referred
to
as "Judge," having superior knowledge of the law and a high standard of the
law
as confirmed by her oath of office; under arms, and Witnessing the Fraud
committed by Defendant Private Citizens; to deprive Plaintiff of the right
to be
present at any hearing and to confront and examine witnesses and evidence
against him; that Defendant Magistrate Marilyn Leonard, such Attorneys, and
Citizens, and all of them in each and every cause of action enumerated
herein
this action, knowingly and deliberately and maliciously caused damages and
deprivation and neglected and failed to correct or to prevent the wrongs
pursuant to Title 42 U.S.C.A., 1986.
Plaintiff was subjected to another fraudulent ex-parte hearing while
available
to the Courts requirements. Defendant 'Judge' Magistrate Marilyn Leonard in
conspiracy with Private Citizens Tamara Ann Zehnder and Marcus Bernard
Merritts'
deprivation of Plaintiff's Constitutionally Guaranteed rights to Due Process
under color of state law caused Plaintiff damages including but not limited
to
physical trauma, emotional distress, psychological distress, pain and
suffering,
lost income, loss of Family, loss of career, damage to reputation and other
collateral and related damages.
Claim XVII - Cruel and Unusual Punishment
Mid-Thursday afternoon Armed Military Troops in disguise as Sheriffs'
Deputies
forced Plaintiff to march hundreds of yards from the Jefferson County
Courthouse
to the Jefferson County Jail after having stood in the chains and shackles
for
hours. Each and every step caused the ankle shackles to tear into Plaintiffs
Achilles tendon, causing permanent scars and injury. Plaintiff informed each
and
every Deputy of the injuries and each and every Deputy refused or neglected
to
correct or prevent further injuries. Said acts committed in Color of
Authority
caused Plaintiff injuries. Defendants deprivation of Plaintiff's
Constitutionally Guaranteed rights under color of state law caused Plaintiff
damages including but not limited to physical trauma, emotional distress,
psychological distress, pain and suffering, lost income, loss of Family,
loss of
career, damage to reputation and other collateral and related damages.
Claim XVIII - Unlawful Service - Unlawful Complaint- 2/28/97-
Defendant Magistrate Marilyn Leonard in conspiracy with Deputy Sheriff Frank
Lastoczy
Defendant Judicial Officer Magistrate Marilyn Leonard, having superior
knowledge
of the law and a high standard of the law as confirmed by her oath of
office,
deprived Plaintiff of Plaintiff's Constitutionally Guaranteed right to due
process of law by subjecting Plaintiff to unlawful service by armed
Defendant
Deputy Sheriff Frank Lastoczy of an unlawful complaint. Defendants
deprivation
of Plaintiff's Constitutionally Guaranteed rights under color of state law
caused Plaintiff damages including but not limited to physical trauma,
emotional
distress, psychological distress, pain and suffering, lost income, loss of
Family, loss of career, damage to reputation and other collateral and
related
damages.
Claim XIX - Deprivation of Due Process- Fraudulent probation agreement
Defendant Judicial Officers, each of them and them all, having superior
knowledge of the law and a high standard of the law as confirmed by their
oath
of office, deprived Plaintiff of Plaintiff's Constitutionally Guaranteed
right
to due process of law by demanding, requiring and subjecting Plaintiff to a
'probation agreement/ pre-trial supervisory agreement' which contained
numerous
unconstitutional provisions, pejorative restrictions and requirements prior
to
any trial, any defense or any other 'due process of law'. Defendants
deprivation
of Plaintiff's Constitutionally Guaranteed rights under color of state law
caused Plaintiff damages including but not limited to physical trauma,
emotional
distress, psychological distress, pain and suffering, lost income, loss of
Family, loss of career, damage to reputation and other collateral and
related
damages.
Claim XX - Defendants Denial of Human Rights, Sadistic Treatment and Cruel
and
Unusual punishment and for no crime
Plaintiff was released on bail and discharged from the Jefferson County
Detention Center. Plaintiff was maliciously denied warmth or shelter or any
telephone access or any other necessities of life; at 3:00 A.M. in a dire
snow
blizzard and without a coat or any proper clothing. The 3:00 A.M. timing was
deliberate and malicious and at the order of the Shift Officer in conspiracy
and
a meeting of the minds with the other Defendant Detention Center staff; to
torture, discommode, inflict pain and perhaps cause the death by exposure of
Plaintiff, Steve Douglas, Gartin; in deprivation of Plaintiffs
constitutionally
guaranteed rights.
Defendant Jefferson County Sheriffs Department personnel's deliberate and
malicious deprivation of Plaintiff's Constitutionally Guaranteed rights
under
color of state law caused Plaintiff damages including but not limited to
physical trauma, emotional distress, psychological distress, pain and
suffering,
lost income, loss of Family, loss of career, damage to reputation and other
collateral and related damages.
Claim XXI - Defendants Failure and Neglect to Correct or to Prevent Wrongs
and
Deprivations of Rights to Plaintiff
Plaintiff incorporates Claim I through Claim XX inclusive as if fully
reproduced
herein. Defendant Law Enforcement Officers, Defendant Judges, Defendant
Officers
of the Court, each of them and them all; refused, neglected and failed to
provide equal protection of the law to Plaintiff and, neglected and failed
to
correct or to prevent wrongs done to Plaintiff or deprivation of Plaintiffs
Rights as they were notified by Plaintiff.
Plaintiff contacted Defendant Law Enforcement Administrative Officers and
Internal Affairs Departments, Defendant Administrative and Supervisory
Judges
and such Defendant Officers of the Court on or reporting to Disciplinary
Committees, Defendant Law Enforcement and Investigative Officers and
agencies.
All Defendants failed to investigate Plaintiffs charges, failed to charge or
discipline such named Defendants and failed or neglected to prevent such
wrongs
and deprivations as were in their immediate knowledge or those sworn and
verified by Plaintiff and Witnesses. Such failure by Defendants to secure
Plaintiffs Rights, failure to Protect Plaintiffs Rights, failure and neglect
to
correct or to prevent such wrongs and deprivations caused Plaintiff damage
including but not limited to physical trauma, emotional distress,
psychological
distress, pain and suffering, lost income, loss of Family, loss of career,
damage to reputation and other collateral and related damages.
DAMAGES
18. The facts enumerated in items one (1) through (17) are incorporated
herein
as if fully reproduced.
19. Plaintiff states with reasonable expectation, that Defendant's
unreasonable
and unconscionable actions as enumerated herein and certainly proven beyond
doubt by prima facie evidence filed in the Court record in this instant
matter,
have wrongfully deprived Plaintiff of 1st, 4th, 5th, 6th, 7th, 8th and 14th
Amendments rights as enumerated in the Bill of Rights to the Constitution
for
the United States of America.
Said deprivation, being under Color of Law, and in conspiracy, causing
damage to
Plaintiff.
20. Wherefore Plaintiff demands Compensatory Damages severally against all
Defendants herein in the amount of Fifty Million Dollars ($50,000,000.00),
per
Defendant, per cause of action.
21. Plaintiff herein demands exemplary damages as a deterrent to future
damages
in the amount of One Hundred Million Dollars ($100,000,000.00), per each
cause
of action as enumerated herein against All Defendants severally.
22. Plaintiff demands reparation for costs and reimbursement of all out of
pocket expenses incurred as a result of the filing of this action.
23. Plaintiff requests relief pursuant to the criminal allegations brought
herein.
24. Plaintiff further seeks any other relief that the court of proper
jurisdiction deems appropriate under the circumstances and the
Constitutional
controversy raised herein.
JURY DEMAND
25. Trial by Jury according to the Seventh Amendment known as the Bill of
Rights
DEMANDED HEREIN.
Right to Amend:
Plaintiff herein reserves the right to Amend Complaint as needed.
Criminal Oath
WITNESS BY JUDICIAL OFFICER
_______________________________________________________________________
Steve Douglas, Gartin - the Common Law copyrighted freeman character
Before me,_____________________ , A Judicial Officer for the United States
prescribed by law with authority to administer oaths, appeared Steve
Douglas,
Gartin, who making himself known to me, did affirm and subscribe to the
truth of
the facts in this Complaint on this ________day of_____________________ ,
1997.
___________________________________
Judge
Pursuant to 28 U.S.C.A. 1746
(1) and executed "without the United States," I affirm under penalty of
perjury
under the laws of the United States of America that the foregoing is true
and
correct, to the best of my belief and informed knowledge.
Subscribed, sealed and affirmed to this _______day of__________ 1997.
I hereby affix my own signature to all of the above affirmations with
explicit
reservation of ALL my unalienable rights and without prejudice to ANY of
those
rights pursuant to U.C.C. 1-207.
My signature,_______________________________________________________
Citizen/Principal, by Special Appearance in Propria Persona, proceeding Sui
Juris, with Assistance, Special, " Without Prejudice" to any of my
unalienable
rights.
Parties: __________________________________________________________________
1st Judicial District
100 Jefferson County Parkway
Golden, Colorado 80401
Charles T. Hoppin
At all pertinent times herein, Defendant, Charles T. Hoppin, was employed as
a
Sworn Judicial Officer with the Jefferson County District Courts. Defendant
had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Charles T. Hoppin was operating under color of law
within the scope of his employment.
Golden Municipal Court
911 10th Street
Golden, Colorado 80401
Ronald L. Miller
At all pertinent times herein, Defendant, Ronald L. Miller, was employed as
a
Sworn Judicial Officer with the Golden Municipal Court. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages.. At
all
pertinent times herein, Ronald L. Miller, was operating under color of law
within the scope of his employment.
18th Judicial District
100 Jefferson County Parkway
Golden, Colorado 80401
James Demlow
At all pertinent times herein, Defendant, James C. Demlow, was employed as a
Sworn Judicial Officer with the 18th Judicial District. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, James C. Demlow was operating under color of law
within
the scope of his employment.
Roy Olsen
At all pertinent times herein, Defendant, Roy Olsen, was employed as a Sworn
Judicial Officer with the 18th Judicial District. Defendant had knowledge
that
the deprivations were in progress, conspired in and had the power and the
duty
to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Roy Olsen was operating under color of law within
the
scope of his employment.
Henry Nieto
At all pertinent times herein, Defendant, Henry Nieto, was employed as a
Sworn
Judicial Officer with the 18th Judicial District. Defendant had knowledge
that
the deprivations were in progress, conspired in and had the power and the
duty
to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Henry Nieto was operating under color of law within
the
scope of his employment.
Marilyn E. Leonard
At all pertinent times herein, Defendant, Marilyn Leonard, was employed as a
Sworn Judicial Officer with the 18th Judicial District. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Marilyn Leonard was operating under color of law
within
the scope of her employment.
Dorothy Cline
At all pertinent times herein, Defendant, Dorothy Cline, was employed as a
court
clerk for the 18th Judicial District. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Dorothy Cline was operating within the scope of her employment.
Golden Municipal Court
911 10th Street
Golden, Colorado 80401
Ronald L. Miller
At all pertinent times herein, Defendant, Ronald L. Miller, was employed as
a
Sworn Judicial Officer with the Golden Municipal Court. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Ronald L. Miller was operating under color of law
within
the scope of his employment.
Karsh & Fulton, P.C.
Cherry Tower Office Building- Suite 710
950 South Cherry Street
Denver, Colorado 80222-2665
Antonio Troy Ciccarelli
At all pertinent times herein, Defendant, Antonio Troy Ciccarelli, was
employed
as an Attorney at Law with Karsh & Fulton, P.C. Defendant had knowledge that
the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Antonio Troy Ciccarelli was operating under color of law within the
scope of his employment.
J. Terry Wiggins
At all pertinent times herein, Defendant, J. Terry Wiggins, was employed as
an
Attorney at Law with Karsh & Fulton, P.C. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, J. Terry Wiggins was operating under color of law within the scope
of
his employment.
Alan Karsh
At all pertinent times herein, Defendant, Alan Karsh, was employed as an
Attorney at Law with Karsh & Fulton, P.C. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Alan Karsh was operating under color of law within the scope of his
employment.
Larry Fulton
At all pertinent times herein, Defendant, Larry Fulton, was employed as an
Attorney at Law with Karsh & Fulton, P.C. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Larry Fulton was operating under color of law within the scope of
his
employment
Seymour Joseph
At all pertinent times herein, Defendant, Seymour Joseph, was employed as an
Attorney at Law with Karsh & Fulton, P.C. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Seymour Joseph was operating under color of law within the scope of
his
employment.
Fred Alexander Gabler Jr.
At all pertinent times herein, Defendant, Fred Alexander Gabler Jr. was
employed
as an Attorney at Law with Karsh & Fulton, P.C. Defendant had knowledge that
the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Fred Alexander Gabler Jr. was operating under color of law within
the
scope of his employment.
City Attorneys Office
City of Golden, Incorporated
911 10th Street
Golden, Colorado 80401
William Hayashi
At all pertinent times herein, Defendant, William Hayashi, was employed as
City
Attorney of Golden, Colorado. Defendant had knowledge that the deprivations
were
in progress, conspired in and had the power and the duty to prevent or
correct
the intentional deprivation of Plaintiffs' Constitutionally guaranteed
Rights,
causing Plaintiff grievous damages. At all pertinent times herein, William
Hayashi was operating under color of law within the scope of his employment.
Office of the Attorney General (Colorado)
1525 Sherman St.
Denver, Colorado 80203
Maurice Knaizer
At all pertinent times herein, Defendant, Maurice Knaizer, was employed as
an
Attorney at Law with the Colorado State Attorney Generals' Office. Defendant
had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Maurice Knaizer was operating under color of law
within
the scope of his employment.
Colorado Supreme Court Grievance Committee
600 Seventeenth Street
Suite 510
Denver, Colorado 80202-5435
Lynda Donnelly
At all pertinent times herein, Defendant, Lynda Donnelly, was employed as an
Attorney at Law with the Colorado State Supreme Court Grievance Committee.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Lynda Donnelly was operating under
color
of law within the scope of her employment.
James Hollaway
At all pertinent times herein, Defendant, James Hollaway, was employed as an
Attorney at Law with the Colorado State Supreme Court Grievance Committee .
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, James Hollaway was operating under
color
of law within the scope of his employment.
U S West, Incorporated
7800 East Orchard Road- Suite 190
Post Office Box 6508
Englewood, Colorado 80155-6508
Elizabeth Kiovsky.
At all pertinent times herein, Defendant, Elizabeth I. Kiovsky, was employed
as
Senior Attorney at Law with the U S West, Incorporated. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Elizabeth I. Kiovsky was operating under color of
law
within the scope of her employment.
18th Judicial District. Attorneys' Office
500 Jefferson County Parkway
Golden, Colorado 80401-6020
George Brauchler.
At all pertinent times herein, Defendant, George Brauchler, was employed as
Deputy District Attorney with the Jefferson County District Attorneys
Office.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, George Brauchler was operating under
color of law within the scope of his employment.
David J. Thomas
At all pertinent times herein, Defendant, David J. Thomas, was employed as
Jefferson County District Attorney, Jefferson County District Attorneys
Office.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, David J. Thomas, was operating under
color of law within the scope of his employment.
Ted Maclinberg (sic).
At all pertinent times herein, Defendant, Ted Maclinberg (sic) was employed
as
Jefferson County Deputy District Attorney, Jefferson County District
Attorneys
Office. Defendant had knowledge that the deprivations were in progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Ted
Maclinberg (sic) was operating under color of law within the scope of his
employment.
Arapahoe County District Attorneys Office
7305 South Potomac
Englewood, Colorado
James Peters.
At all pertinent times herein, Defendant, James Peters was employed as
Arapahoe
County Deputy District Attorney, Arapahoe County District Attorneys Office.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, James Peters was operating under
color
of law within the scope of his employment.
Darren Voss.
At all pertinent times herein, Defendant, Darren Voss was employed as
Arapahoe
County Deputy District Attorney, Arapahoe County District Attorneys Office.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Darren Voss was operating under
color of
law within the scope of his employment.
Office of the Attorney General (Colorado)
1525 Sherman St.
Denver, Colorado 80203
Gale Norton
At all pertinent times herein, Defendant, Gale Norton, was employed as an
Attorney at Law with the Colorado State Attorney Generals' Office. Defendant
had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Gale Norton was operating under color of law within
the
scope of her employment.
United States Attorneys Office
1961 Stout St., Suite. 1200
Denver, CO 80294
William Pharo
At all pertinent times herein, Defendant, William Pharo, was employed as an
Attorney at Law with the U.S. Attorneys' Office. Defendant had knowledge
that
the deprivations were in progress, conspired in and had the power and the
duty
to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, William Pharo was operating under color of law
within
the scope of his employment.
Jefferson County Sheriff
Jefferson County Sheriffs Department, Incorporated
200 Jefferson County Parkway- Suite 200
Golden, Colorado, 80401
Arapahoe County Sheriff
Arapahoe County Sheriffs Department
5686 South Court Place
Littleton, Colorado 80203
City of Golden, Incorporated
911 10th Street
Golden, Colorado 80401
City of Littleton
225 West Berry Avenue
Littleton, Colorado
City of Aurora
1470 South Havana
Aurora, Colorado
City of Greenwood Village
City Hall 6060 South Quebec Street
Greenwood Village, Colorado 80111-4591
U S West, Incorporated
7800 East Orchard Road- Suite 190
Post Office Box 6508
Englewood, Colorado 80155-6508
Missouri Synod Lutheran Church Incorporated
Quigley & Bruce
Neal A. Quigley
1010 Cherry Tower
950 South Cherry Street
Denver, Colorado 80222
Bethlehem Lutheran, Inc.
Office Space Saving Concepts, Incorporated
10060 West Grand Avenue
Littleton, Colorado 80137
STATE OF COLORADO
State Capitol Bldg.
Denver, Colorado
Spyderco, Incorporated
Louis S. Glesser:
P.O. Box 800
4565 North Highway 93
Golden, CO 80403
Spyderco, Inc. Louis S. Glesser.
At all pertinent times herein, Defendant, Louis S. Glesser, was employed as
Owner of Spyderco, Incorporated. Defendant had knowledge that the
deprivations
were in progress, conspired in and had the power and the duty to prevent or
correct the intentional deprivation of Plaintiffs' Constitutionally
guaranteed
Rights, causing Plaintiff grievous damages. At all pertinent times herein,
Louis
S. Glesser was operating within the scope of his employment.
44] Jefferson County Board of Commissioners
100 Jefferson County Parkway, Golden, Colorado
45] Arapahoe County Board of Commissioners
5334 South Prince, Littleton, Colorado
Karsh & Fulton, P.C.
Cherry Tower Office Building- Suite 710
950 South Cherry Street
Denver, Colorado 80222-2665
Family Zehnder
5587 South Urban Street
Littleton, Colorado 80127
TAMARA A. GARTIN.
At all pertinent times herein, Defendant, Tamara Ann Zehnder (Gartin), was
employed with the U S West, Incorporated. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Tamara Ann Zehnder (Gartin) was operating within the scope of her
employment.
Robert V. Zehnder Estate
At all pertinent times herein, Defendant, Pastor Robert V. Zehnder Estate,
was
employed as a Senior Pastor with the Bethlehem Lutheran Church & School,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Pastor
Robert
V. Zehnder Estate was operating within the scope of his employment.
Dolores J. Zehnder
At all pertinent times herein, Defendant, Dolores J. Zehnder, was employed
as a
Senior Agent with the Bethlehem Lutheran Church & School, Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Defendant, Dolores J. Zehnder was
operating within the scope of her employment.
Office Space Saving Concepts, Incorporated
10060 West Grand Avenue
Littleton, Colorado 80137
Timothy Zehnder
At all pertinent times herein, Defendant, Timothy Zehnder, was employed as
owner
of the Office Space Saving Concepts, Incorporated Defendant had knowledge
that
the deprivations were in progress, conspired in and had the power and the
duty
to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Timothy Zehnder was operating within the scope of
his
employment.
Francisca Zehnder
At all pertinent times herein, Defendant, Francisca Zehnder, was employed as
a
senior manager with the U S West, Incorporated and owner of Office Space
Saving
Concepts, Incorporated. Defendant had knowledge that the deprivations were
in
progress, conspired in and had the power and the duty to prevent or correct
the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Francisca
Zehnder was operating within the scope of her employment.
Markus Bernard Merritt
16656 East Mansfield Circle
Aurora, Colorado 80017
Markus B. Merritt
At all pertinent times herein, Defendant, Markus Bernard Merritt, was
employed
as the Legal Director/ Advisor by the Zehnder Family and by U S West, Inc.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Markus Bernard Merritt was operating
within the scope of his employment.
Missouri Synod Lutheran Church Incorporated
Quigley & Bruce
1010 Cherry Tower
950 South Cherry Street
Denver, Colorado 80222
David Langewisch
At all pertinent times herein, Defendant, David Langewisch, was employed as
a
Pastor with the Missouri Synod Lutheran Church Incorporated. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, David Langewisch was operating within the scope of
his
employment.
Peter Woodward
At all pertinent times herein, Defendant, Peter Woodward, was employed as a
Pastor with the Missouri Synod Lutheran Church Incorporated. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Peter Woodward was operating within the scope of his
employment.
Chet Shoaf
At all pertinent times herein, Defendant, Chet Shoaf, was employed as a
Pastor
with the Missouri Synod Lutheran Church Incorporated. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Chet Shoaf was operating within the scope of his
employment.
U S West, Incorporated
7800 East Orchard Road- Suite 190
Post Office Box 6508
Englewood, Colorado 80155-6508
Richard McCormick
At all pertinent times herein, Defendant, Richard McCormick, was employed as
an
Executive Officer with the U S West, Incorporated. Defendant had knowledge
that
the deprivations were in progress, conspired in and had the power and the
duty
to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages.. At
all
pertinent times herein, Richard McCormick, was operating under color of law
within the scope of his employment.
Karsh & Fulton, P.C.
Cherry Tower Office Building- Suite 710
950 South Cherry Street
Denver, Colorado 80222-2665
Daniel Manson
At all pertinent times herein, Defendant, Daniel Manson, was employed as a
process server with Karsh & Fulton, P.C. Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Daniel Manson was operating within the scope of his employment.
Ernest L. Laseter
1400 Golden Circle #108
Golden, Colorado 80401
Ernest L. Laseter
At all pertinent times herein, Defendant, Ernest Lynn Laseter, a
confidential
police informant, was employed as a consultant and agent sub-contractor.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages.. At all pertinent times herein, Ernest Lynn Laseter was operating
within the scope of his employment.
U S West, Incorporated
7800 East Orchard Road- Suite 190
Post Office Box 6508
Englewood, Colorado 80155-6508
Bill Stevens
At all pertinent times herein, Defendant, Bill Stevens, employed as a Senior
Security Agent with the U S West, Incorporated. Defendant had knowledge that
the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Bill Stevens was operating within the scope of his employment.
Greenwood Village, Incorporated
City Hall, 6060 South Quebec Street
Greenwood Village, Colorado 80111-4591
Rich Waugh
At all pertinent times herein, Rich Waugh, was employed as a Chief of
Police, a
sworn law enforcement officer for Greenwood Village, Incorporated. Defendant
had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Rich Waugh was operating under color of authority
within
the scope of his employment.
Roy Romer
400 East Eighth Avenue
Denver, Colorado
Roy Romer
At all pertinent times herein, Defendant, Roy Romer, was employed as
Governor of
the state of Colorado, a Sworn Administrative Officer with the state of
Colorado. Defendant had knowledge that the deprivations were in progress in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein Roy Romer was operating under color
of
authority within the scope of his employment.
Jefferson County Sheriffs Department, Incorporated
200 Jefferson County Parkway- Suite 200
Golden, Colorado, 80401
Ronald Beckham
At all pertinent times herein, Defendant, Ronald Beckham, was employed as
Jefferson County Sheriff, a Sworn Law Enforcement Officer with the Jefferson
County Sheriffs Department, Incorporated Defendant had knowledge that the
deprivations were in progress, conspired in and had the power and the duty
to
prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally
guaranteed Rights, causing Plaintiff grievous damages. At all pertinent
times
herein, Ronald Beckham was operating under color of authority within the
scope
of his employment.
Donald Estep
At all pertinent times herein, Defendant, Donald Estep, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Donald
Estep
was operating under color of authority within the scope of his employment.
James D. Johnson
At all pertinent times herein, Defendant, James D. Johnson, was employed as
a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, James D.
Johnson was operating under color of authority within the scope of his
employment.
Grant Whitus.
At all pertinent times herein, Defendant, Grant M. Whitus, was employed as a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Grant M.
Whitus was operating under color of authority within the scope of his
employment.
Deputy Martin
At all pertinent times herein, Defendant, Deputy Martin, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Deputy
Martin
was operating under color of authority within the scope of his employment.
Dennis Beery
At all pertinent times herein, Defendant, Dennis Beery, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages.. At all pertinent times herein, Dennis
Beery, was operating under color of authority within the scope of his
employment.
Allen L. Simmons
At all pertinent times herein, Defendant, Allen L. Simmons, was employed as
a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Allen L.
Simmons was operating under color of authority within the scope of his
employment.
Lieutenant Manwaring
At all pertinent times herein, Defendant, Lieutenant Manwaring, was employed
as
a Sworn Law Enforcement Officer with the Jefferson County Sheriffs
Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein,
Lieutenant
Manwaring was operating under color of authority within the scope of his
employment.
Sgt. Williams
At all pertinent times herein, Defendant, Sgt. Williams, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Sgt.
Williams
was operating under color of authority within the scope of his employment.
Kirk G. Beaulieu
At all pertinent times herein, Defendant, Kirk G. Beaulieu, was employed as
a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Kirk G.
Beaulieu, was operating under color of authority within the scope of his
employment.
Barry L. Williams
At all pertinent times herein, Defendant, Barry L. Williams, was employed as
a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated . Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Barry L.
Williams was operating under color of authority within the scope of his
employment.
Raymond Fleer
At all pertinent times herein, Defendant, Raymond Fleer, was employed as a
Sworn
Senior Law Enforcement Officer with the Jefferson County Sheriffs
Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Raymond
Fleer
was operating under color of authority within the scope of his employment.
Joseph McGuire
At all pertinent times herein, Defendant, Joseph McGuire, was employed as a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Joseph
McGuire was operating under color of authority within the scope of his
employment.
Frank Lastoczy
At all pertinent times herein, Defendant, Frank Lastoczy, was employed as a
Sworn Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated . Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Frank
Lastoczy was operating under color of authority within the scope of his
employment.
Jack Jackala
At all pertinent times herein, Defendant, Jack Jackala, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Jack
Jackala
was operating under color of authority within the scope of his employment.
Sgt. Walcher
At all pertinent times herein, Defendant, Sgt. Walcher , was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages.. At all pertinent times herein,Sgt.
Walcher
was operating under color of authority within the scope of his employment.
Lt. Shrader
At all pertinent times herein, Defendant, Lt. Shrader, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Lt.
Shrader
was operating under color of authority within the scope of his employment.
Randall West
At all pertinent times herein, Defendant, Randall West, was employed as a
Sworn
Law Enforcement Officer with the Jefferson County Sheriffs Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Randall
West
was operating under color of authority within the scope of his employment.
Arvada Police Department, Incorporated
8101 Ralston Road
Arvada, Colorado 80002
Daryl Hoffman
At all pertinent times herein, Defendant, Daryl Hoffman, was employed as a
Sworn
Law Enforcement Officer with the Arvada Police Department, Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Daryl Hoffman was operating under
color
of authority within the scope of his employment.
Mark Nazaryk
At all pertinent times herein, Defendant, Mark Nazaryk, was employed as a
Sworn
Law Enforcement Officer with the Arvada Police Department, Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Mark Nazaryk was operating under
color
of authority within the scope of his employment.
A.J. DeAndrea
At all pertinent times herein, Defendant, A.J. DeAndrea, was employed as a
Sworn
Law Enforcement Officer with the Arvada Police Department, Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, A.J. DeAndrea was operating under
color
of authority within the scope of his employment.
Golden Police Department, Incorporated
911 10th Street
Golden, Colorado 80401
Michael Moler
At all pertinent times herein, Defendant, Michael Moler 1465, was employed
as a
Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages.
Bill Killpatrick
At all pertinent times herein, Defendant, Bill Killpatrick, was employed as
a
Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Bill Killpatrick was operating under
color of authority within the scope of his employment.
Russell Cook
At all pertinent times herein, Defendant, Russell Cook, was employed as the
Chief of Police, a Sworn Law Enforcement Officer with the Golden Police
Department, Incorporated. Defendant had knowledge that the deprivations were
in
progress, conspired in and had the power and the duty to prevent or correct
the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Russell
Cook
was operating under color of authority within the scope of his employment.
Dave Farley
At all pertinent times herein, Defendant, Dave Farley, was employed as a
Sworn
Law Enforcement Officer with the Golden Police Department, Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Dave Farley was operating under
color of
authority within the scope of his employment.
Robert Tortora
At all pertinent times herein, Defendant, Robert Tortora, was employed as a
Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Robert Tortora was operating under
color
of authority within the scope of his employment.
Glenn Moore
At all pertinent times herein, Defendant, Glenn Moore 1470, was employed as
a
Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Glenn Moore 1470 was operating under
color of authority within the scope of his employment
Lewis Shellenberger
At all pertinent times herein, Defendant, Lewis Shellenberger 2031, was
employed
as a Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated. Defendant had knowledge that the deprivations were in
progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Lewis
Shellenberger 2031 was operating under color of authority within the scope
of
his employment.
Ted Schnack
At all pertinent times herein, Defendant, Ted Schnack 2011, was employed as
a
Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Ted Schnack 2011, was operating
under
color of authority within the scope of his employment.
Mike Hendershot
At all pertinent times herein, Defendant, Mike Hendershot, was employed as a
Sworn Law Enforcement Officer with the Golden Police Department,
Incorporated.
Defendant had knowledge that the deprivations were in progress, conspired in
and
had the power and the duty to prevent or correct the intentional deprivation
of
Plaintiffs' Constitutionally guaranteed Rights, causing Plaintiff grievous
damages. At all pertinent times herein, Mike Hendershot was operating under
color of authority within the scope of his employment.
Greenwood Village, Incorporated
City Hall 6060 South Quebec Street
Greenwood Village, Colorado 80111-4591
Mark Stadterman
At all pertinent times herein, Defendant, Mark Stadterman, was employed as a
Sworn Law Enforcement Officer for Greenwood Village, Incorporated. Defendant
had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Mark Stadterman was operating under color of
authority
within the scope of his employment.
John Carr
At all pertinent times herein, Defendant, John Carr, was employed as a Sworn
Law
Enforcement Officer for Greenwood Village, Incorporated. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, John Carr was operating under color of authority
within
the scope of his employment.
Jeff Mulqueen
At all pertinent times herein, Defendant, Jeff Mulqueen, was employed as a
Sworn
Law Enforcement Officer for Greenwood Village, Incorporated. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Jeff Mulqueen was operating under color of authority
within the scope of his employment.
Bruce Davis
At all pertinent times herein, Defendant, Bruce Davis, was employed as a
Sworn
Law Enforcement Officer for Greenwood Village, Incorporated. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Bruce Davis was operating under color of authority
within the scope of his employment.
Ewan Scouse
At all pertinent times herein, Defendant, Ewan Scouse, was employed as a
Sworn
Law Enforcement Officer for Greenwood Village, Incorporated. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Ewan Scouse was operating under color of authority
within the scope of his employment.
David Fisher
At all pertinent times herein, Defendant, David Fisher, was employed as a
Sworn
Law Enforcement Officer for Greenwood Village, Incorporated. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, David Fisher was operating under color of authority
within the scope of his employment.
Steven Crowell
At all pertinent times herein Steven S. Crowell, Jr. was employed as a City
Manager for the city of Greenwood Village, Incorporated Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Steven S. Crowell, Jr. was operating under color of
authority within the scope of his employment.
Lakewood Police Department
445 South Allison Parkway
Lakewood, Colorado 80226
Michael Harris
At all pertinent times herein, Defendant, Michael Harris, was employed as a
Sworn Law Enforcement Officer with the Lakewood Police Department. Defendant
had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Michael Harris was operating under color of
authority
within the scope of his employment.
Susan Hines
At all pertinent times herein, Defendant, Susan Hines, was employed as a
Sworn
Law Enforcement Officer with the Lakewood Police Department. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages.. At
all
pertinent times herein, Susan Hines was operating under color of authority
within the scope of her employment.
Mary Sutton
At all pertinent times herein, Defendant, Mary Sutton, was employed as a
Sworn
Law Enforcement Officer with the Lakewood Police Department. Defendant had
knowledge that the deprivations were in progress, conspired in and had the
power
and the duty to prevent or correct the intentional deprivation of Plaintiffs
'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Mary Sutton was operating under color of authority
within the scope of her employment.
Aurora Police Department
1470 South Havana
Aurora, Colorado 80012
Pete Page
At all pertinent times herein, Defendant, Pete Page, was employed as a Sworn
Law
Enforcement Officer with the Aurora Police Department. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Pete Page was operating under color of authority
within
the scope of his employment.
Arapahoe County Sheriffs Department
5686 South Court Place
Littleton, Colorado 80203
Patrick Sullivan
At all pertinent times herein, Defendant, Patrick Sullivan, was employed as
Arapahoe County Sheriff, a Sworn Law Enforcement Officer with the Arapahoe
County Sheriffs Department. Defendant had knowledge that the deprivations
were
in progress, conspired in and had the power and the duty to prevent or
correct
the intentional deprivation of Plaintiffs' Constitutionally guaranteed
Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Patrick
Sullivan was operating under color of authority within the scope of his
employment.
W.H. Fields
At all pertinent times herein, Defendant, W.H. Fields, was employed as
Arapahoe
County Deputy Sheriff, a Sworn Law Enforcement Officer with the Arapahoe
County
Sheriffs Department. Defendant had knowledge that the deprivations were in
progress, conspired in and had the power and the duty to prevent or correct
the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, W.H.
Fields.
was operating under color of authority within the scope of his employment.
Vincent Landis
At all pertinent times herein, Defendant, Vincent Landis, was employed as
Arapahoe County Sheriff, a Sworn Law Enforcement Officer with the Arapahoe
County Sheriffs Department. Defendant had knowledge that the deprivations
were
in progress, conspired in and had the power and the duty to prevent or
correct
the intentional deprivation of Plaintiffs' Constitutionally guaranteed
Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Vincent
Landis. was operating under color of authority within the scope of his
employment.
Ethan Feldman
At all pertinent times herein, Defendant, Ethan Feldman, was employed as
Arapahoe County Sheriff, a Sworn Law Enforcement Officer with the Arapahoe
County Sheriffs Department. Defendant had knowledge that the deprivations
were
in progress, conspired in and had the power and the duty to prevent or
correct
the intentional deprivation of Plaintiffs' Constitutionally guaranteed
Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Ethan
Feldman
was operating under color of authority within the scope of his employment.
City of Littleton
Police Department
225 West Berry Avenue
Littleton, Colorado
Robert L. Allen
At all pertinent times herein, Robert L. Allen, was employed as a sworn law
enforcement officer for City of Littleton, Incorporated. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, Robert L. Allen was operating under color of
authority
within the scope of his employment.
Chief of Police, Littleton Police Department
At all pertinent times herein, Chief of Police was employed as a sworn law
enforcement officer for City of Littleton, Incorporated. Defendant had
knowledge
that the deprivations were in progress, conspired in and had the power and
the
duty to prevent or correct the intentional deprivation of Plaintiffs'
Constitutionally guaranteed Rights, causing Plaintiff grievous damages. At
all
pertinent times herein, the Littleton Chief of Police was operating under
color
of authority within the scope of his employment.
Douglas County Sheriffs Department
355 South Wilcox Avenue
Castle Rock, Colorado 80104
Steve Zotos
At all pertinent times herein, Defendant, Steve Zotos, was employed as
Douglas
County Sheriff, a Sworn Law Enforcement Officer with the Douglas County
Sheriffs
Department. Defendant had knowledge that the deprivations were in progress,
conspired in and had the power and the duty to prevent or correct the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Steve
Zotos
was operating under color of authority within the scope of his employment.
Robert Wood
At all pertinent times herein, Defendant, Robert Wood, was employed as
Douglas
County Deputy Sheriff, a Sworn Law Enforcement Officer with the Douglas
County
Sheriffs Department. Defendant had knowledge that the deprivations were in
progress, conspired in and had the power and the duty to prevent or correct
the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Robert
Wood
was operating under color of authority within the scope of his employment.
Robert McMahon
At all pertinent times herein, Defendant, Robert McMahon, was employed as
Douglas County Deputy Sheriff, a Sworn Law Enforcement Officer with the
Douglas
County Sheriffs Department. Defendant had knowledge that the deprivations
were
in progress, conspired in and had the power and the duty to prevent or
correct
the intentional deprivation of Plaintiffs' Constitutionally guaranteed
Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Robert
McMahon was operating under color of authority within the scope of his
employment.
Kim Castellano
At all pertinent times herein, Defendant, Kim Castellano, was employed as
Douglas County Deputy Sheriff, a Sworn Law Enforcement Officer with the
Douglas
County Sheriffs Department. Defendant had knowledge that the deprivations
were
in progress, conspired in and had the power and the duty to prevent or
correct
the intentional deprivation of Plaintiffs' Constitutionally guaranteed
Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Kim
Castellano was operating under color of authority within the scope of his
employment.
Corporal Reese
At all pertinent times herein, Defendant, Corporal Reese, was employed as
Douglas County Sheriff, a Sworn Law Enforcement Officer with the Douglas
County
Sheriffs Department. Defendant had knowledge that the deprivations were in
progress, conspired in and had the power and the duty to prevent or correct
the
intentional deprivation of Plaintiffs' Constitutionally guaranteed Rights,
causing Plaintiff grievous damages. At all pertinent times herein, Corporal
Reese was operating under color of authority within the scope of his
employment.
________________________________________________________________
Attachment 1: Definitions
"person" defined.
In general usage, a human being, though by statute the term may include
labor
organizations, partnerships, associations, corporations, legal
representatives,
trustees, trustees in bankruptcy, or receivers. Scope and delineation of
term is
necessary for determining those to whom Fourteenth Amendment of the
Constitution
affords protection since this Amendment expressly applies to "person."
Black's
Law 6th
"Whoever" includes all persons, agents, and employees; and all officials,
public
or private. An unincorporated voluntary association does not come within the
meaning of the term, "whoever" in an ordinance providing that "whoever"
violates
certain provisions of the ordinance shall be deemed guilty of a misdemeanor;
and
such association cannot be convicted for offense- Bridgeport v. Eagles 97 O.
App. 245, 56 0033, 125 NE2d 202.
Defendant Judges, each and every one of them and et al, in court rooms they
themselves knowingly colored with an Executive Flag, pursuant to Title 4
U.S.C.A. 1, Part II, in a "Federal Agency", 1994 Act to Reorganize the Govt.
63
Statutes at Large, Chapter 288, Sec. 3(b), the term 'Federal Agency' means
any
executive agency or establishment in the legislative or Judicial branch of
government, Title 5, p.739 section 5721. "Agency" means (C) a court of the
United States;
took rights from Plaintiff herein, Plaintiff's rights and liberty, by means
of
illegal compulsion or oppressive exaction, compelling judgments on Plaintiff
when Plaintiff was not named on legal process, by color of Defendant's
office as
Judicial Officer in conspiracy with Defendant Attorney 'a office as Officer
of
the Court in the same Bar Association shall be fined not more than $5,000 or
imprisoned not more than three years, or both.
"Color of Authority" defined. That semblance or presumption of authority
sustaining the acts of a public officer which is derived from his apparent
title
to the office or from a writ or other process in his hands apparently valid
and
regular.
"Color" defined. An appearance, semblance, or simulacrum, as distinguished
from
that which is real. A prima facie or apparent right. Hence, a deceptive
appearance; a plausible, assumed exterior, concealing a lack of reality; a
disguise or pretext. Black's Law 6th
"Color of Office" defined. Pretense of official right to do act made by one
who
has no such right. An act under color of office is an act of an officer who
claims authority to do the act by reason of his office when the office does
not
confer on him any such authority.
Conspiracy-Title 42, §1983
Knowledge- Title 42, §1986
Random Facts for application of torts
_________________________________________________________________
Defendant Tamara Ann Zehnder's wish to be enriched by divorce is the genesis
of
this conspiracy. Her contacts to U S West, the Lutheran Church MS and her
intimate knowledge of Plaintiffs family and professional life allowed her to
formulate a plan of action in order:
To accompany Markus Bernard Merritt and supporting him with financial
substance
from the sale or use of Plaintiffs' personal goods and possessions. The plan
to
steal Plaintiffs' goods by fraud and deceit was the formulation of Antonio
Troy
Ciccarelli, J. Terry Wiggins of Karsh & Fulton, P.C., Markus Bernard Merritt
and
the Zehnder Family.
To consolidate her position at U S West Legal Department and to cover the
fact
that she lied on her professional resume` in claiming computer and other
skills
that she did not have.
To cover the fact that Defendant Francisca Zehnder, her sister in law and
supervisor at U S West and member of the Bethlehem Lutheran Church
congregation,
was fully knowledgeable about those lies, conspiring to defraud Plaintiff of
his
work and payment for same.
To escape further financial liability for the Spyderco/IRS action in Federal
Court
To prevent the exposure of Zehnder Family Secrets; theft, homosexuality,
adultery, child and spousal abuse. The posture of the Zehnder family as
professional and commercial Christians, in the employ of the Lutheran Church
MS,
would have been severely damaged with the exposure of the secrets.
Defendant U S West, Incorporated needed to sever its' relationship with
Plaintiff and conspired in the actions with these motives:
To make a theft of services, to wit; Invoiced and Unpaid-for computer skills
and
services for the U S West Legal Department Staff; Supervisor Francisca
Zehnder,
Paula Anderson, Barbara Byres, Tamara Ann Gartin, Markus Bernard Merritt,
Richard McCormick and others.
Unauthorized dissemination of confidential and privileged client and
corporate
information from the Staff of the Legal Department to Plaintiff by
Supervisor
Francisca Zehnder and Tamara Ann Zehnder and such others.
To keep secret the false resume` presented to U S West which continues to
serve
Tamara Ann Zehnder as a work credential.
Elizabeth Kiovsky, and in her position as Senior Counsel to U S West, has
actively instigated and participated in a Conspiracy with Legal Department
Staff
Supervisor Francesca Zehnder, Richard McCormick, Paula Anderson, Barbara
Byres,
Tamara Ann Gartin, Markus Bernard Merritt and Bill Stevens to present
perjury
and falsified documents to Greenwood Village Police Department Technician
Ewan
Scouse in order to falsely portray Plaintiff as a menace and to obstruct
justice.
To further the activities of Tamara Ann Gartin at the Bethlehem Church &
School,
Inc., and Francisca Zehnder, Paula Anderson, Beverly Byres; members of the
Lutheran Church MS at Bethlehem Lutheran Church.
Defendant Bethlehem Lutheran Church & School and Defendants David
Langewisch,
Peter Woodward and Chet Shoaf conspired and in a meeting of minds to conceal
the
personal life of the Zehnder Family. The Zehnder Family is of National
Prominence and any taint of scandal would affect the 'National Church' as
well
as Bethlehem Lutheran.
David Langewisch broke the confidentiality of the Marriage and Personal
Counseling with Plaintiff and needed to hide that breach of ethics;
conspiring
with U S West Legal Department Supervisor Francisca Zehnder, Paula Anderson,
Barbara Byres, Tamara Ann Gartin, Markus Bernard Merritt.
Senior Pastor Emeritus Robert V. Zehnder supported Tamara's position with
finances and to hide his own affairs and abuse of his family.
The Zehnder Family wanted to keep secret the adultery of Tamara Ann Gartin
with
Markus Bernard Merritt from the Congregation, Pastor Robert V. Zehnder,
Plaintiffs offspring and the National Church.
Karsh & Fulton, P.C.
Antonio Troy Ciccarelli is a member of the Bethlehem Lutheran Church
Congregation. His relationship with the Senior Pastor Robert Zehnder,
Delores
Jean Lynn Zehnder and Tamara Ann Zehnder, was as Counsel for 'Tamara Ann
Gartin'. He was assisting Markus Bernard Merritt in the unauthorized
practice of
law and to defraud the Zehnder Family of substance and goods.
J. Terry Wiggins was Antonio Troy Ciccarellis' leading Partner in Karsh &
Fulton, P.C. and took on Ciccarellis' caseload when absence or vacations
applied. J. Terry Wiggins was responsible for Ciccarellis' strategies and
the
conduct of his cases. Defendant Wiggins was intimately aware of the
communications between Steve and Troy because the FAX machine is in his
office.
Wiggins is a well known fixer and former prosecutor with broad connections
into
the County and Federal systems of Law Enforcement and the Judiciary. He has,
on
his own initiative; threatened a Witness on multiple occasions, stood in
knowing
contempt of the Courts orders, participated in the knowing submission of
false
and misleading documents and testimony to the Court, failed to supervise and
correct a subordinate lawyer, failed to conduct himself in the manner to
instill
confidence in the integrity of his firm or his profession, improperly
obstructed
justice by failing to properly receive or give due diligence to
communications
and filings on behalf of his minor clients; April Rose Gartin and Elijah
Rock
Gartin and failed to rise to minimal and slight standards of professional
conduct.
Alan Karsh has arrogated a personal participation by threatening to 'squash'
me
'like a bug...I have the power' in support of blatantly unethical and
improper
acts by his partner, J. Terry Wiggins and his junior associate, Antonio Troy
Ciccarelli, as well as the number of 'un-billable' hours required by
Ciccarelli's promises to the Jefferson County Court. He has failed and given
slight diligence to his responsibilities of supervision of subordinate
lawyers;
J. Terry Wiggins and Antonio Troy Ciccarelli.
Larry Fulton, Seymour Joseph and Fred Gabler have been contacted personally
and
repeatedly with notification of the active participation in the deprivation
of
my Rights by their Partner and Associate and Staff. They have failed and
neglected to correct or prevent wrongs and deprivations.
Valerie Krogman has failed and neglected to
Daniel Manson has submitted false documents to the Court on behalf of K&F to
further the Conspiracy and for money.
Golden Police Department Officer Michael D. Moler conspired with Antonio
Troy
Ciccarelli, Tamara Ann Gartin and Markus Bernard Merritt to:
Abduct and Kidnap two children
Establish a false persona of violence to counterattack my petition for a
restraining order against Markus Bernard Merritt.
Golden Municipal Court Attorney William Hayashi joined in the conspiracy to
limit the liability of the City of Golden and the Golden Recreation Center
and
the Golden Police Department and to conceal his own slight diligence to his
responsibilities as an Officer of the Court.
Magistrate Ronald L. Miller joined in the conspiracy in order to limit the
liability of the City of Golden and the Golden Recreation Center and the
Golden
Police Department and to conceal his own slight diligence to his
responsibilities to his sworn oath of office.
David J. Thomas, George Brauchler, Ted Maclenberg (sic) joined the
conspiracy to
limit the liability of the 18th Judicial District, Jefferson County, City of
Golden, Jefferson County Sheriffs Department, Golden Police Department and
to
cover its' own slight diligence.
Henry E. Nieto, James C. Demlow, Roy G. Olsen, Marilyn E. Leonard and
Charles T.
Hoppin have joined the conspiracy in order to limit the liability of the 1st
Judicial District, Jefferson County, Jefferson County Sheriffs' Department,
Golden Magistrate Ronald L. Miller, William Hayashi, Mike Bestor, the City
of
Golden, Theresa Reilly, the Golden Police Department, the Golden Recreation
Center and its staff and administration and their own slight diligence and
slight performance to their positions of public trust and integrity.
The various clerks of the court and such staff have knowingly and
maliciously
obstructed justice and refused documents, diverted and delayed documents,
and
furthered the conspiracy by direct actions on behalf of their Judges and for
commercial purposes.
Lynda Donnelly and James Hollaway have joined in the conspiracy and
obstructed
justice by failing to act or refusing to act or neglecting to act. They have
consciously and deliberately acted improperly on behalf of the lawyers
charged
to them as before the Disciplinary Committee of the Supreme Court of the
state
of Colorado. They have repeatedly refused to accept information and
evidence;
delayed, diverted and concealed information and evidence in Court
submissions,
and failed or neglected to correct or prevent wrongs and deprivations or to
provide equal protection of the law or of administrative relief to a
non-lawyer
citizen.
Maurice Knaizer joined the conspiracy on behalf of Chief Judge Henry E.
Nieto
and to conceal the slight diligence and slight performance and to limit the
liability of the state of Colorado, Jefferson County, et al.
Greg Peters and Darren Voss joined the conspiracy and the meeting of minds
to
curry favor with the Executives of U S West, Incorporated, the City of
Greenwood
Village, Lakewood Police Department, City of Littleton, Greenwood Village
Police
Department, Arapahoe County and the Arapahoe County Sheriffs Department and
to
attempt to limit the civil and criminal liability of same. Further, they
seek to
conceal and limit their own liability for frivolous and malicious actions
against Steve. They have failed and neglected to secure or to prevent or to
correct wrongs and deprivations of rights they were witness to. They have
given
slight diligence and slight performance to professional standards and
ethical
requirements of the legal profession.
The Administrative and Line Officers of the Internal Affairs Bureau (however
named) of the Golden Police Department, Lakewood Police Department,
Littleton
Police Department, Jefferson County Sheriffs' Department have joined in the
conspiracy and the meeting of minds to conceal the illegal actions or slight
performance of their fellow officers. They have conspired to conceal their
own
slight diligence and failure to secure and to protect, to prevent and
correct
wrongs and deprivations of Rights.
The Officers and Administration of the Colorado Bureau of Investigation, the
Douglas County Sheriffs Department, the Aurora Police Department, the Arvada
Police Department have conspired and in a meeting of minds to obstruct
justice,
conceal the slight diligence and slight performance to professional
standards of
their fellow police officers, such officers of the court and judicial
officers
from public exposure and opprobrium.
Oh? Why don't you explain to us how you know this. I believe you know
this by being a special op person for government. You're into
witchcraft and that's the trend assuming the governments all accross
the country now. Anyone in government positions usually is involved
with witchcraft and believe that using government positions to intrude
to role play others by their government position is proper. You
demonstrate this behavior as does Gartin.
> You either live there, have legitimate business, or need a lift out of town.
You're really not succeeding here in juicing the drama con artist.
> Zahn is a hobo, and they'd want to know why he was there at all.
A hobo you make sure you avoid.
> Our situation was a bit different. USWest (Elizabeth Kiovsky, Bill Stephens,
> Markus Merritt, Tamara Gartin) thought it would be useful to have us slapped
> around by the police, as a demonstration of power and to gain advantage in a
> civil matter (divorce).
Total fictional story, an attempt at a con by Gartin/Chas Fraud Co.
> On the basis of manufactured evidence, they construed a non-crime by Gartin- > and even that fell through, and they had to drop the charges as unfounded at > all.
Got any case numbers? Even if you did it was all made up and your
witchcraft friends in GWV were in on the skit with you.
> Of course it took a couple of years of fucking with him first. They crapped
> out on the day they had to prove any of it.
Sure. We don't believe you.
> With me, they sent two GV cops (Carr and Stadterman) and one Aurora Swatzi
> (Pete Page) to intimidate me into not allowing Gartin to use my fax-machine,
> or witness for him in court.
All a role-play game.
> I said 'Witness Intimidation', Page split instantly and the two cops just dug > it deeper. It's all documented.
Usually good cons are documented to give more convincing spark.
> I had been warned by attorneys, warned by cops- and sure enough, got false
> charges lodged against me, arrested and detained for days.
Sure you didn't.
> All for being a witness in court, and allowing a man to file legal process
> through a fax machine.
Don't believe you.
> I never played any games with them though, and wasn't in GV at all. They had
> to cross jurisdictional lines to come fuck with me.
Don't believe you Chas, sorry.
> Chas