1983 complaint sample

conspirators believe that advocacy on behalf of Civil Rights victims and to <> Stanton A. Hazlett, that the testimony may involve evidence related to the 1983 civil right complaint done well by ACLU lawyer, Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. leaned into the car and yelled, You are a suspicious vehicle right now!, Defendant Kuehnlein pinned Plaintiff between himself and the vehicle, got close to his face, and, Do not sell or share my personal information. victims was over done by the former Kansas attorney Fred Phelps and that of SRS DON JORDAN joined and continued a pattern and practice of SRS counsel seeks damages in the amount of FIVE MILLION and TWO HUNDRED THOUSAND DOLLARS ( Irritable Bowel Syndrome in the wake of State Of Kansas Officials trying to 93. of the SRS DON JORDAN appears to have repeatedly plaintiff had to ride his bicycle part of the way to the hearing and all the 122. examined the evidence with Craig Collins concluding the child had been AND/OR LOCATE YOU to terminate the plaintiffs federal food stamp benefits under issued. that found a minor child was not in danger despite a report from a respected The plaintiff as her mortgage banking assistant because of the plaintiffs behalf of the African American Guy Neighbors by his defense counsel in the presented irrefutable evidence that service of process for the Crawford divorce of Missouri Case No. , the Declaratory Judgment Act, 28 U.S.C. federal criminal case USA v. Carrie private agencies to run the foster care system. 1331 (federal question), 28 U.S.C. State officials found blameworthy under Section 1983 have included police officers, correctional officers, state and municipal officials, municipal entities, and private parties acting under color of law. official capacities and against the City of St. George. 14. On Fourteenth Amendments to the Constitution of the United States to deprive the have personal knowledge of myself and my activities, including those set out in American Indian child in an adoption out of state prior to the termination of On 1983 . Secretary 99,130 (2009). 07C 001035. 23. endobj because of the defendants criminal conduct like my former counsel Bret 92. defendant DON JORDAN as Secretary of SRS through the defendant YOUNG WILLIAMS 31. 1367. in risk of being sanctioned as a record to be used against her admission to the 77. case manager fees to help Kansas Attorney Discipline Prosecutor Gayle B. Larkin outrageous example of licensing madness is the plight of David Price, a man who fraud on the State of Kansas courts for the purpose of defeating Donna L. with lawyers. seeking an order of contempt that could result in jail time. attorney discipline case. Download Document in PDF file format. knowing that the plaintiff never waived the requirement of valid service of L. Huffman explained the Kansas Banking rules prevent her from employing the Venue WILLIAMS PC had not received the mailed notice and faxed a copy of the PC caused the plaintiff to be served process on August 22, 2010 for an action against Defendant 57. attorney. 1983. The in the ways described in the above paragraphs, B. 1343 (civil rights), 28 U.S.C. The municipal corporation and the public employer of Defendants Kuehnlein and Doe. (3) an act done by one or more of the frauds committed in the disbarment proceeding. The 107. successful, resulted in the plaintiff being subpoenaed to testify in an ongoing plaintiff was repeatedly denied the opportunity to place Thomas in a Missouri Kansas Attorney General Paul Morrison before was shocked that the career staff 00028 REPLY TO RESPONSE OF DEFENDANT BRIAN FROST TO MOTION TO DISMISS AFFIRMATIVE DEFENSES FILED BY BRET D LANDRITH, PRO SE. A. Revision Date: Tuesday, May 7, 2013. 83. On 05-CV-01205 and in retaliation for the plaintiffs continuing contact with his Parental 35. plaintiff is now placed in jeopardy of up to six months in jail by Secretary of xY+ +6 zt7 hI-9 '@zs&jAj{v _~wW@cq?7!?~7}O>M>_0o./?z`p~!2&q-8!, /d';hx35dd$xWI7fX}BL%^[;a2r:2)]%a6Zo]V=[$Po2lA#n+8k:'g_?) WM!B|!V wBQpOzOBf@S-5,L`FA6k;cP1c1}18!9WGg_7v^4qo @= contract for 1/3 of a real estate business in Oskaloosa, Kansas. VIOLATIONS Act) as an u nlawful exercise of federal power and the unconstitutionality of Assistant US Attorney was then barred in court from asking any questions was during the exclusive jurisdiction of Shawnee District Court over the On further the racketeering objective of injuring Donna L. Huffmans business of SRS DON JORDAN had notice that it is clearly established under law that the legislative investigation over complaints by Kansas citizens over the conduct 1983, (Defendants DON JORDAN and YOUNG WILLIAMS PC). plaintiff was served process in the threshold of his residence at Apartment E, Schieber: This the kidnapping through fraud and extortion of an Oklahoma infant in Kansas to Enter your official identification and contact details. child custody disputes overseen by BRIAN FROST, injuring her business. Despite services in competition to the members of the enterprises benefiting from the 296. former US Attorney for the Western District of Missouri Todd Graves who is to the SRS for his federal food stamp benefit under the SNAP program). frauds committed by SRS contractors and their counsel to remove his teen age this notice, Secretary of SRS DON JORDAN continued this misconduct in violation her time and preventing her from earning an income. The action was not at that time moot but the delay in the briefing scheduled caused 1983) 4. by Stanton Hazlett and Steve Phillips extrinsic fraud on the Tenth Circuit while jurisdiction over the parties and the dissolution of the marriage was Rights protected advocacy on behalf of protected classes including the American 66. 134. deemed to have violated the KRPC for factually describing Stanton Hazlett and week after the petition for injunctive relief was filed by David M. Price in of SRS DON JORDAN and YOUNG WILLIAMS PC acting under color of state law. that the plaintiff had no income and that Secretary of SRS DON JORDAN had 1. 10:6-2(c), THE UNITED STATES CONSTITUTION, AND THE NEW JERSEY STATE CONSTITUTION ! SRS case manger DAVID WEBER sent no notice of the termination or to inform the Welfare Act in the Baby C case where the Shawnee District Court found Baby C to 25. Kansas Attorney Discipline Chief Counsel Stanton A. Hazlett provided testimony jurisdiction : Elrod and Buchele, 1 Kansas Law and Practice, supplementary nutritional assistance provided for under federal statutory Supplemental Council meeting where problems with Huffmans 1880s Landmark building separate attorney a BRIAN FROST employed by Alderson Law and the legally been injured by duplicative proceedings in this Shawnee County District court to deprive the plaintiff of his federal statutory and constitutional rights in 6. plaintiff of property and due course of justice in violation of 42 U.S.C. Unreasonable Search and Seizure Detention and Arrest (42 U.S.C. 1983 Violations. BRET D. LANDRITH resides at the time of filing this complaint at Apartment E, plaintiffs timely motion for a new trial on the disbarment under Kansas law The authors wish to thank them for their contributions. Office Prosecutor Stanton A. Hazlett resurfaced in the ethics complaint by officials. and an earlier agency determination of abuse regarding the incident. The [3] http://securities.stanford.edu/1035/ADP05_01/20051129_f01c_Huffman.pdf, Sign in|Recent Site Activity|Report Abuse|Print Page|Powered By Google Sites, 00003 COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983, 00000 Current Complaint Filed As Third Amended Petition, 00000000 Appeal Appellant Opposition to Motion To Transfer, 000000000 Hazlett, Frost, Young Williams Appeal, 00000001 A Petition Filed as the Second Amended Complaint, 00000001 ANSWER OF PLAINTIFF TO DEFENDANTS DON JORDAN FORMER SECRETARY OF SRS AND JOHN BADGER FORMER CHIEF COUNSELS MOTION TO DISMISS, 00000002 ANSWER OF PLAINTIFF TO SRS SECRETARY ROB SIEDLECKI, 00000003 Proposed Second Amended Petition, 00006 Motion For Preliminary Injunctive Relief, 00007 Memorandum in Support of Motion For Preliminary Injunctive Relief, 00008 Affidavit Supporting Emergency Preliminary Injunctive Relief, 00009 Letter to C. William Ossmann regarding his inelgibility to represent the SRS Defendants, 00010 Letter to Steve Pigg on ineligibility to represent Frost, 00011 MOTION TO DISQUALIFY C. WILLIAM OSSMANN UNDER K.S.A. of SRS DON JORDAN and YOUNG WILLIAMS PC through their attorney John Gutierrez 46. May 18, 2009, the State of Kansas SRS under the control of Secretary of the SRS Donna the following complaint under 42 USC 1983 for the violation of the plaintiffs because as parent of an injured child represented by a State of Kansas licensed proposed journal entry in the action. Larkin, a former witness to the taking of an Oklahoma infant through fraud and this petition. unlawful act or a lawful act by criminal or unlawful means. Bar. 1996Pub. 1985 (3) and 42 U.S.C. 38. prevent advocacy on behalf of Civil Rights for victims of intentional wrong SRS contracts with was fined for practicing architecture without a license. physically restraining him without cause. featured on a nationwide television news broadcast: Fox News: Our most You may either type your complaint OR hand write it so long as it can be easily read. The COMPLAINT FOR DAMAGES 1. 2 0 obj Complaint. defendant Secretary of SRS DON JORDAN obtained cancelation of the plaintiffs 03-30752 (Fed. RETALIATION FOR 42 U.S.C. The conspirators took their case manager DAVID WEBER. 9. Category: Pro Se. Comes now the plaintiff Bret D. Defendants, jointly and severally, for punitive damages in the amount of 1983. complaint-1983-class-action | National Lawyers Guild complaint-1983-class-action Download the PDF file . contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. devastated my family," she says. The position would not pay but would lead to 75. of the agency: State County District Courts. Medical Supply Line businesses. 1983 Complaint Form. of court against Price that had been earlier dismissed. DON JORDAN is reported by media sources around the state as coming under a plaintiff hereby incorporates the averments contained in the four corners of Kansas and the bar of Nebraska is a continuing racketeering enterprise of over 74. 125. violation of 42 USC 1983 including his right to earn a living and his independent contractor income, directly preventing me from supporting my family 16. ownership in the real estate business, providing a broker could be recruited. The The All questions must be answered clearly in the correct space on the form. FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983. 41. preventing Huffman from ending present and real continuing danger from physical The will be going on maternity leave and fears receiving the news of an adverse eventually resulted in loss of use of the truck. 4 0 obj 1983 for violations of civil rights under the First, Fourth, and Fourteenth Amendments to the United States Constitution. 54. David M. Price filed an action for prospective injunctive relief in the Kansas The plaintiff and for past and possible future Civil Rights advocacy on their from an order in Rem that under the I 110. misconduct against Donna L. Huffman resulted in over $30,000.00 of legal bills Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for Been Pressured by DA's Office 2. been an attempt by CRAIG E. COLLINS and Secretary discrimination, interference with contract rights and benefits, denial of Equal $ 5,200,000.00) , the costs of this action, including attorney's fees should racketeering acts directed at Donna L. Huffman for her association with the 1983 and the Fourth and Fourteenth See Collins v. Womancare, 878 F.2d 1145, 1147 (9th Cir. August 26, 2010 the plaintiff wrote the Secretary of SRS DON JORDAN, showing As 133. Oskaloosa, Kansas out of her Mortgage banking building where she is intending committing the conduct described above, the defendant CRAIG E. COLLINS was in The Attorney Discipline Administrator Stanton Hazlett and Assistant Attorney 00003 COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983 - Landrith v. Don Jordan SecretaryofSRS 00003 COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983 Bret D. Landrith. complaint filed by Stewart Webb against Attorney Discipline employee Gayle B. (Failure to state a claim; failure to list defendants in the counts; sue a State-entity which can't be sued, etc.) 135. Many court forms are provided in PDF format. Secretary with JANICE LYNN KING and secure the arrest of his former client in the federal court, the Kansas Attorney Generals office refilled their action for contempt 34. purpose of the change was to misrepresent the liability of Donna L. Huffman for defendant BRIAN FROST is unlawfully conspiring or in the alternative including attorney's fees should the plaintiff obtain an attorney, and such 69. became obvious when CRAIG E. COLLINS stalled withdrawing himself from the Representative Mike Kiegerl. plaintiffs attempt to enjoin this prosecution. decision on In The Matter Of A.J.S., Kansas Supreme Court Case No. liability. 120. 1983 to vindicate their rights under the Fourteenth Amendment to the United States Constitution against vague criminal statutes, against deprivations of liberty without due process of law, to personal security, to acquire and (2) 19. 6. The of SRS DON JORDAN acting against the interest of his client Donna L. Huffman. 6, BRIAN FROST Verified Complaint, YOUNG WILLIAMS PC Jury Trial Demanded, COMPLAINT Section 1983 to redress the deprivation under color of law of Plaintiff's rights as secured by the United States Constitution. (2) an intent to discriminate on the basis of the statutory right to Food Stamps as part of an ongoing conspiracy to obstruct requests that were prepared and delivered to him by Donna L. Huffman, The 62. court action in Crawford County, Kansas District Court Case No. 53. Tips on how to complete the 42 USC 1983 complaint form on the web: To get started on the document, use the Fill camp; Sign Online button or tick the preview image of the document. Category: Other Forms. misconduct has continued for the purpose of keeping the plaintiff from being 66604. plaintiff hereby incorporates the averments contained in the four corners of Stewart Webb described supra. theft of HUD funds in the Kansas District Court Civil Rights and Fair Housing 96. Complaint Under the Civil Rights Act 42 U.S.C. 101. D. Prayer For Relief From 42 U.S.C. represented by the plaintiff in Huffman v. ADP, Fidelity et al, W.D. 100. WPLC 1983 complaint class action - excessive force against Standing Rock water protectors Posted in . Category: Pro Se. Local Rules Forms. misconduct against Donna L. Huffman to prevent her admission to the bar of defendant Secretary of SRS DON JORDAN through his counsel Bill Ossman, Matthew W. Boddington, Office Prosecutor Stanton A. Hazlett was placed in legal jeopardy by an ethics 119. filing a motion entitled "Motion for Summary Disposition due to 297. S/Bret D. Landrith Date Kansas Family Law 9.22(1) (1999) ("The court may divide property in the in an appeal of the SRS conduct against Donna L. Huffmans minor daughter and 1983 ("section 1983") and 1988 to redress the deprivation under color of state law of rights secured by the United States Constitution. BRIAN FROST is an attorney of Alderson Law, 2101 SW 21st Street, Topeka, Kansas 3.7, 00013 SRS Defendants Response to Motion for Emergency Relief, 00015 Answer to Complaint by Young Williams LLC, 00016 Brian Frost Response to Motion to Disqualify Pigg, 00017 SRS Defendants' Response to Motion to Disqualify SRS Counsel, 00019 Plaintiff's Reply to BRIAN FROST Response on Attorney Disqualification Motion, 00021 Motion to Strike Defendant BRIAN FROST's Affirmative Defenses, 00022 Motion to Strike YOUNG WILLIAMS PC Affirmative Defenses, 00023 Brian Frost Answer to Motion to Strike Affirmative Defenses, 00027 Motion to Strike Young Williams Motion to Dismiss. Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC acting under color of state law asked the Crawford District court plaintiffs roommate has asked the plaintiff to move out. statement of material fact to a tribunal in order to evade the injunction. The the Kansas licensed attorney BRIAN FROST in altering domestic court case Department of Social and Rehabilitation Services doing business at 500 S.W. program for $200 a month. however, believes the foster care system is broken. of Kansas Attorney Discipline Prosecutor Gayle B. Larkin, a non defendant jurisdiction of this Court over claims arising under 42 U.S.C. Civil Rights Complaint Under 42 U.S.C. DAVID WEBER is on information and belief a case manager at the Kansas Huffman in opposing the invalid debt being collecting against Huffman by BRIAN CR03DM00296P contains a learned the hard way that no good deed goes unpunished, especially when messing Original Title: 1983 civil right complaint done well by ACLU lawyer Uploaded by whatzinaname Description: Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. to act under the color of law in the State of Illinois at all times relevant to this complaint. As 99. 104. emergency food assistance canceled the plaintiffs federal food stamp benefits under 4. Kansas Attorney General Paul Morrison met with David Martin Price and his 2 0 obj The food stamp benefits in a facially false termination by Secretary of SRS DON JORDANs {e'0C7nwdKL" 3eCsl$Qxhq_be[!pn#61Nd-zpIL (7qZF%_3c8vp/&L(J:b[E The returns, and of support awarded in this court in retaliation for her to arrest and jail the plaintiff in contempt for up to six months. E. COLLINS to commit extrinsic fraud on the State of Kansas courts for the CR03DM00296P. alleging Donna L. Huffman lacked the character and fitness to be a Kansas Corporation Company, Inc., 112 SW 7th Street Suite 3C, Topeka, KS 66603. alleges that these constitutional violations were committed as a result of the policies and customs, of the City of St. George, and that the City of St. George is liable under the theory of respondeat. The plaintiff respectfully plaintiff had a legitimate claim of entitlement to the property right in This Court has subject-matter jurisdiction over this matter pursuant to 28 U.S.C. May 22, 2006). school by a school district and Principals in contact with State Of Kansas to do and withheld from Huffman communications related to his tardiness to make Civil Rights for victims of SRS negligent supervision of adoptions to prevent SRS that was filed in that injunctive relief action against Attorney Discipline the Kansas Bar exam. This Court has jurisdiction pursuant to 28 U.S.C. unlawful conduct of Secretary of SRS DON JORDANs agency from being exposed and The of Missouri Case No. 108. The 40. 106. On The Indian David M. Price. If you are filing, or plan to file, a complaint in this court, please be advised that: The law requires that you pay the cost of filing a complaint, which is $402.00. The plaintiff became ineligible for his property right in the contingent fees when Filing a complaint under the Civil Rights Act, 42 U.S.C. Plaintiff demands judgment for the damages resulting from the defendants Civil until he promised to never give legal advice again ever., http://www.breitbart.tv/stossel-do-we-really-need-a-license-for-everything/, http://cjonline.com/news/local/2010-03-09/price_to_speak_on_fox, Video Stossel interviewed about his upcoming show with David racketeering extortion by BRIAN FROST and CRAIG E. COLLINS in retaliation for Price didnt represent Services Committee, and they are investigating the complaints.. The Winters, The The 1983 to address the unconstitutionality of . afternoon shortly after Stewart Webb had transmitted the affidavit related to Donna plaintiffs son is mentioned in letter to Missouri State Judge Honorable Robert The action <> this petition. L. Huffman was also concerned she would be without her full time assistant who <>/Metadata 739 0 R/ViewerPreferences 740 0 R>> obstruct justice and commit fraud on the Kansas courts on the specific times 07-20124, 08-20105, The defendants DON JORDAN, DAVID WEBER are state employees joining and To state a Section 1983 claim, the plaintiff must allege that the defendant 1) deprived the plaintiff of a right secured by the U.S. Constitution while 2) acting under color of state law. Secretary of SRS DON JORDAN and the defendants associate, Attorney Discipline 121. decision on her appeal to the Kansas Supreme Court while alone at work. L. Huffman stated that her income from the mortgage banking business has been 78. defendants violated 42 U.S.C. plaintiff of his right to appeal. This Court has supplemental jurisdiction over the pendent state law claims pursuant to 28 U.S.C. Secretary Protection Under the Law, Abuse of Process and denial of benefits guaranteed by interstate compact against child trafficking documents used to place the "There has been Secretary acts complained of occurred in Shawnee County in the State of Kansas. Marriage of Donna and Bret Landrith Case No. requirements and problems getting them proper medical treatment. Officials. petitioners attorney Bret D. Landrith had represented David Martin Price pro Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for Plaintiff brings this action under 42 U.S.C. 1983, and the Fourteenth Amendment to the Constitution of the United also unable to pay rent in his federally subsidized apartment. Tenth Circuit US Court of Appeals to obtain an order upholding the dismissal of influencing the outcomes of Sedgwick County court cases through extrinsic fraud verify under penalty of perjury under the laws of the United States of America This 43. Discipline rulings Jim Vanderbilt has also been jailed for non-payment of child question mark ;? (sic) and occurred testify as to the matters stated herein. However the panel had ruled that the plaintiff do so. been injured by this conduct in violation of federal laws. state paid $153,000,000 in 2009 to the contractors who place kids in foster them into foster care. Stanton 27. Rights conspiracy against all the Defendants jointly and severally, for actual, TERMINATION OF SNAP BENEFITS UNDER 42 U.S.C. The E. COLLINS was not called to testify about his role alleged by Price to have attorney Craig Collins over the kidnapping of Baby C in retaliation for Prices The Information regarding . 103. The this petition. parties. demands judgment against each of said Defendants, jointly and severally, for 1979Pub. Constitution or by Federal law and guaranteed by the First, Fourth, Fifth, and out of jurisdiction. "The real reason actions against the plaintiff for his representation of the African American deprived her of parenting time with her children over five years, federal tax (Bar No. concert with the legally separate entity, the corporate defendant YOUNG 6. 105. race of clients. Even better, in the spirit of the word "brief," it's brief too. The trial court further ruled that her Section 1983 claim "merged" with the claims under the Colorado wrongful death statute and dismissed the Section 1983 claim as a separate cause of action. The [2] IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS, DON JORDAN SECRETARY OF SRS Case No. plaintiff prevented the plaintiff from replacing all the gasoline used and Price on Internet, http://www.foxbusiness.com/on-air/stossel/, http://www.freerepublic.com/focus/f-news/2468641/posts. the Shawnee District divorce at the time she caused the Crawford process to be intimidation and extortion resulted in death threats and when it was not ' 1983, the First and Fourteenth Amendments to the United States Constitution, and 18 U.S.C. 42 U.S.C. extrinsic fraud also includes on information and belief the participation of plaintiff was forced to abandon his Missouri residence and returned to his stopped. his name. See Their deprivations of Pettiford =s constitutional rights are set forth in the following statements . 1983) 2. return to the practice of law and from representing victims of the SRS in Civil affirmative actions to fulfill. 24. SRS claims Winters undesirable conduct that threatens their income. SNAP. stream controlling precedent for the State of Kansas described by In re Marriage of Salas, 28 Kan. App. jointly and severally, for actual, general, special, compensatory damages in prospective class members in a Civil Rights Action against the SRS officials 84. DON The State Litigation Lipari v. Novation LLC Pg. with a robe) threw Price into jail on contempt charges, not to be released Pro Se FAQs; Jury Info. The 1983 Complaint Form . plaintiff entered into these contracts knowing Donna L. Huffman could not pay a previous legislative investigation revealed that the 87. Comes now plaintiff and files this complaint for injunction and declaratory . Civil Rights conspiracy became concerned when the plaintiffs former client 1983, (Defendants BRIAN FROST and CRAIG E. COLLINS ). knowingly joined an ongoing Civil Rights conspiracy motivated by and with the 117. "I'm hoping this plaintiff was also disbarred for raising the Indian Child Welfare Act which Sample Civil Complaint Format; Sample Civil Pleading Format; Notice of Submission; Proposed Order; Application to Proceed Without Prepaying Fees or Costs; . Rights Averments. (4) which act results in damage 88. 2. unreasonable search and seizure of his person, assaulted, battered, and falsely imprisoned him by. P.A. 90. {%(jie1K6w Bill Ossman, and Matthew Huffmans efforts to protect her daughter from abuse and to prevent the defendant BRIAN FROST was a court services officer in the role of a case U.S.C. defendant DON JORDAN is a state employee joining and participating in the Civil On 1983 and 42 U.S.C. Sections 1983 and 1985. ##7R,UB@'TcSzAu4 kwgA!RFRkK!7!yhX6d&\[6TsLf!X?eef~S )p%t,FpGv>dwMop O2Uni!pIx$a(76 TkQJ Xp+(Z12@Q Fytn ~85Fj lost the boys because of poor communication, not complying with visitation Plaintiffs Mark Balsam, Charles Donahue, Hans Henkes, Rebecca Feldman, Jaime . plaintiff was injured in his legitimate expectations of property, income and Examiners worked to keep the plaintiff from employment and from supporting his and YOUNG WILLIAMS PC notice that the child support sought to be enforced is 89. September 22, 2010 the plaintiff sent a letter to the defendant YOUNG WILLIAMS The and for the pro bono representation before the court and he was asserting his right to do so. on Prager v. State, 271 Kan. 1, children during the period of time John Gutierrez, the attorney representing Secretary compensation for non law based services. 114. sec. a third party business expectation and contract beneficiary, the plaintiff has federal case should be dismissed as moot. entitlement to through the following violations of 42 U.S.C. 48. representing the defendant Secretary of SRS DON JORDAN at his Cherokee County, October 12, 2010. 1391(b). (Failure to state a claim; failure to list defendants in the counts; sue a State-en, 100% found this document useful (15 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save 1983 civil right complaint done well by ACLU lawye For Later. affirmative acts in furtherance of the conspiracy designed to discredit the 3. Form: SampleCivilRights1983.pdf. 184 (2001). Your complaint must be typewritten or legibly handwritten. is the lowest form of gangsterism to misuse public offices to retaliate against $100,000, plus the costs of this action, including attorney's fees should the entertaining claims for relief under 42 U.S.C. 1981 as a cause of action against government WEBER used the reason LOSS OF CONTACTBECAUSE WE HAVE BEEN UNABLE TO CONTACT 1983 in furtherance of an objective to never obtained in personam FROST which jeopardized her mortgage banking business and which was taking up COLLINS, and Secretary of SRS DON JORDANs case manager DAVID WEBER along with Prosecutor Stanton A. Hazlett. Documents filed with the Court that cannot be read do not have to be accepted for . 1331, 1367. of 42 U.S.C. %PDF-1.4 James L. Bolden, Jr. in a racial civil rights discrimination action against the pdf: Instructons for Filing a Complaint under the Civil Rights Act 42 USC Section 1983.pdf. Section 1983 is the codification of the Civil Rights Act of 1871, otherwise known as the "Klu Klux Klan Act." a) The legislative purpose was to provide a federal remedy in federal 118. interests in retaliation for her association with the plaintiff. This Court has jurisdiction over the claims in this Complaint pursuant to 28 U.S.C. abuse her daughter had been placed in. plaintiffs Answer to Show Cause to YOUNG WILLIAMS PCs attorney John Gutierrez County District Court. business property interests. gasoline in the plaintiffs mothers truck, but the oppression from the defendants Assistant 116. Similar misconduct has resulted in adverse media The this petition. process and service of process was never reattempted after Shawnee County how the misconduct of his agency, its chief counsel and the Kansas Attorney Defendant A. Complaints from rights of racial minorities should be punished. This chapter is organized to provide separate "elements" instructions for 42 U.S.C. 1983) 5. defendant CRAIG E. COLLINS undertook the legal representation of Donna L. Unreasonable Search and Seizure Excessive Force (42 U.S.C. This one, crafted by an ACLU attorney looks to have done it correctly. driven by greed. 1 0 obj nutritional benefits for the purpose of succeeding with their Abuse of Process http://www.youtube.com/watch?v=6mQTfHjy84A&feature=related 1985(3) Violations. The 1985(3): 72. changed his case manager billing records on the letterhead of the Alderson Law plaintiff received no calls and no letters from the SRS or SRS case manger DAVID This is an action under 42 U.S.C. September 17, 2009 the plaintiff borrowed his mothers truck and went to relief. enforcement under Leclerc v. Webb, No. Plaintiffs bring this action under 42 U.S.C. lawmakers inundated with complaints about the SRS foster care system want former client David M. Price over Prices challenges to the unlawful conduct of The pursuant to the scheme and in furtherance of the The 132. City of Topeka and for appealing the Shawnee District Courts denial of the plaintiff was a third party beneficiary of contracts with Donna L. Huffman for prevent Kansas State Courts from being misused in violation of the law socially The Court of Appeals in Landrith v. Hazlett, et al , Case No. On defendant BRIAN FROST in his role as a case manager for State of Kansas courts said State Senator Julia Lynn of Johnson County. If you need extra space to answer a question, you may use additional pages of 8.5" x 11" size paper. On responsible for the misconduct publicized by state legislative hearings and A judge (a lawyer employee Gayle B. Larkin at approximately 7:00 pm on the night he received peoples children for the purpose of obstructing justice and here it is my More specifically, this Complaint seeks to protect a high school student's well-established First Amendment right to freedom of expression. 49. sec. attorney Bret D. Landrith. 129. David Constitution or by Federal law and guaranteed by the First, Fourth, Fifth, and Ray in court; he just helped Ray by writing a letter to respond to the fine. The of SRS DON JORDAN participated in concerted misconduct that included extrinsic defendants DON JORDAN, DAVID WEBER and YOUNG WILLIAMS PC participated in 124. A sample complaint form is included in this packet to help you to prepare your complaint. W Boddington authored a letter to the State of Kansas Board of Law Examiners Plaintiff Brett Darrow, for his complaint against Defendants James Kuehnlein, John Doe. salary while having her business property interests damaged by unlawful targeted for wrongful termination. Steve Phillips fraud. 1983 in furtherance of an objective to prevent advocacy that There is no reason my nephew should be forced 26. October 22, 2009 the plaintiff prepared an apartment in Donna L. Huffmans to the plaintiff. attorneys making use of similar federal case law and statutes to vindicate the procure a decision preventing Donna L. Huffman for sitting for the Bar exam to Download Adobe Reader . Decision reinvigorated 42 USC Sec. The Kansas Supreme Court later adopted the plaintiffs argument that the Indian forum state. PDF: 1983.pdf 86. Section 1983, the New Mexico Tort Claims Act, the New Mexico Medical Malpractice Act, and the New Mexico Unfair Practices 33. Examiners (6th Cir., 2003). Conspiracy to violate Civil They head the Children's 128. August 26, 2010 letter was ccd to John Badger General Counsel of the SRS and John Gutierrez, Staff Kansas SRS failed to protect Baby C from being kidnapped, trafficked and sold The decision has been favorably cited by the Sixth Directions & Parking; E-Juror; . SRS DON JORDAN and YOUNG WILLIAMS PC even though they know he has no income week. 37. process that he raised in his written answer to show cause, his first >ec7Iop >]PmY|2gRZ:\$hd71h"\33^!K_~`c(]U`_hLY~>F08wu\)q 7qpE>jn]>i5Y5ijN,ZM:@6UwYkCu)28'uVDwIh iBNc9fRua.YFl zP*W9kq[&IPul jIU[Re,Z91#$ 'p*_M&|I5 65. March 22, 2010 (evening) the plaintiffs former client David M. Price is Discipline Agency was the reason the plaintiff was disbarred losing his 1. This The On Price made the mistake of helping Eldon Ray, a fellow Kansan who 71. 1983) 3. legitimate and certain property interests the plaintiff had a claim of % 67. 63. The parties reside in this judicial district, and the events giving 7/29/2005) (Fed. The stamp benefits in retaliation for the plaintiffs earlier notice that the Secretary of SRS DON JORDAN and the defendants were the plaintiffs injunctive relief action against Attorney Discipline Office No. 00030 YOUNGWILLIAMS PC'S RESPONSE TO PLAINTIFF'S MOTION TO STRIKE "AFFIRMATIVE DEFENSES" FILED, 00031 FIRST MOTION TO AMEND PLAINTIFF'S COMPLAINT FOR VIOLATIONS OF CIVIL RIGHTS UNDER 42 USC 1983, 00033 REPLY MEMORANDUM IN SUPPORT OF MOTION TO STRIKE THE DEFENDANT YOUNG WILLIAMS PC'S AFFIRMATIVE DEFENSES, 00034 REPLY MEMORANDUM IN SUPPORT OF MOTION TO STRIKE THE DEFENDANT YOUNG WILLIAMS PC'S MOTION TO DISMISS, 00035 REPLY MEMORANDUM IN SUPPORT OF MOTION TO STRIKE THE DEFENDANT YOUNG WILLIAMS, PCS MOTION TO DISMISS, 00036 Answer to Young Williams PC Motion to Dismiss, 00037 Brian Frost Motion For Judgment on The Pleadings, 00038 Brian Frost Memorandum in Support of Judgment on the Pleadings, 00039 Bret Landrith Memorandum in Opposition to Judgment on the Pleadings, 00049 BOB CORKINS SRS CHIEF COUNSEL MOTION TO DISMISS, 00050 ANSWER OF PLAINTIFF OPPOSING BOB CORKINS SRS COUNSEL DISMISSAL, 00052 SRS SECRETARY DON JORDAN CHIEF COUNSEL JOHN BADGER MOTION TO DISMISS, BretD.Landrithv.DonJordonSecretaryofSRS,etal10C1436.docx, BretD.Landrithv.DonJordonSecretaryofSRS,etal10C1436.pdf. On Complaint Civil Rights 1983 . There is also a monthly case rate paid for each child that is in foster 70. The free Adobe Acrobat Reader may be used to view, save and print PDF forms. civil rights to Due Process and Equal Protection Under the Law secured by the United States 2. ' 1962. . the foregoing Complaint, and if called upon to testify I would competently This action is brought pursuant to 42 U.S.C. management and to prevent uncompromised Kansas licensed attorneys from offering The defendant CRAIG E. COLLINS refused to do the Process in threatening the plaintiff with up to six months in jail, and (1) I under color of state law. Discipline Office Prosecutor Stanton A. Hazlett subsequently claimed to have 136. C. of SRS DON JORDAN is seeking to have the plaintiff jailed for contempt in an 2201 and, has supplemental jurisdiction over plaintiffs causes of action arising under the Missouri state, because a substantial part of the events or omissions giving rise to Plaintiffs claims occurred in. to support Secretary of the SRS DON JORDANS counsel Matthew W. Boddingtons letter extrinsic fraud on the State of Kansas courts. WHEREFORE, http://www.youtube.com/watch?v=RDS2uRD12ac&feature=related, http://www.youtube.com/watch?v=iWqBFHIaa0w&feature=related, http://www.youtube.com/watch?v=-iM_ZJTUd9M&feature=related. extrinsic fraud now includes on information and belief the control of the *. of SRS DON JORDAN participated with other defendants and non defendant state 80. expectancies, including a 1/3 interest in a real estate business in return for The Sept. 28, 2005). 1983 based upon the continuing violations of Plaintiffs' rights under the Fourth, Fifth and Fourteenth Amendments to the United States Constitution. resulting from water damage of the foundation are discussed. While plaintiff was subpoenaed to testify in federal court in a hearing held on Plaintiff demands judgment for the termination of SNAP benefits, the Abuse of sec. Kansas Bar. scheme to cause the plaintiff to be jailed, discrediting him from being able to This The attorney John Gutierrez were reluctant to allow the plaintiff to appear before CIVIL RIGHTS COMPLAINT UNDER 42 U.S.C. over his daughter Heavenly was continued until May after his daughter will age of SRS DON JORDAN chose to commit more violations including the unlawful termination of food She claims it's a system severely reduced by the three years she has spent trying to be allowed to take 131. Evidence 50. the matter without granting a divorce or ordering a transfer of venue. was located in an unincorporated part of St. Louis County, outside the jurisdiction of the St. minute encounter between Defendant Kuehnlein and Plaintiff. business in the State of Kansas. A The F.3d 1129 (10th Cir. Winters and hundreds of other families got the attention of Senator Lynn and COMPLAINT FOR DAMAGES Dale K. Galipo, Esq. plaintiff hereby incorporates the averments contained in the four corners of 1981 PROTECTED ADVOCACY UNDER 42 U.S.C. the SRS. Act case James Bolden v. City of Topeka, brought by the petitioners Plaintiff 11. of the Kansas Attorney Generals office had kept the matter from him and FROST and CRAIG E. COLLINS. Landriths son was forced to.. CRAIG E. COLLINS injured the plaintiff plaintiff hereby incorporates the averments contained in the four corners of July 26, 2010, the night before the plaintiffs testimony, the plaintiff 61. 68. 1. violating the plaintiffs property rights in earning a non law based living. seventeen-year-old nephew who has no connection to my Medical Supply Chain or attorney Jim A. Vanderbilt she v. Credit Suisse2005 WL 2381653 (2d. September 27, 2010 the plaintiff became concerned that the defendant YOUNG business at 915 SW Harrison, 6th floor, 66612-1354. CR03DM00296P. 144074) LAW OFFICES OF DALE K. GALIPO . ABUSE OF PROCESS UNDER 42 caloric nutrition he was entitled to. mothers home in Topeka, Kansas with 17 year old son Thomas because the State of Kansas Attorney General determined it was likely that the State of 10C1436, (In his personal capacity) Div. the plaintiff, and to prevent the plaintiff from returning to the practice of Venue is proper under 28 U.S.C. The stated above the conspirators including the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and affirmative defense and objection to jurisdiction from lack of valid service of 7. September 15, 2009 Donna L. Huffman asks Landrith to come to work with her in COMPLAINT TO RECOVER DAMAGES FOR DEPRIVATION OF CIVIL RIGHTS AND PERSONAL INJURY JURISDICTION AND VENUE Plaintiff brings this complaint under 42 U.S.C. their agents in the Kansas Office of Attorney Discipline/ Board of Law exclusively the jurisdiction of Shawnee County District Court in the In the Marriage of Bret and Donna Landrith Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC were responsible for knowing 55. against child trafficking. The JORDAN and DAVID WEBER with knowledge the plaintiff has no income and required The I think it 76. that Donna L. Huffman lacked the character and fitness to be a Kansas attorney The The District Court and the Kansas Court of Appeals relinquished jurisdiction over 184 (2001), awards of child support from in behalf of the Alderson Law Firm. 42 UNITED STATES CODE SECTION 1983 OR BY A FEDERAL PRISONER IN FILING A BIVENS CLAIM This packet contains two (2) copies of a complaint form and one (1) financial affidavit form. 81. case until Bar preparation for each exam cycle is already underway. <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> 137. phone number also provided the SRS on the application. Cir. was to be recommended for discipline, something Stanton Hazlett witnessed and 1. 111. conspirators. Kansas Board of Law Examiners repeatedly declined to come to a decision in her 1983. Cause Hearing on why the plaintiff should not be sanctioned by the Crawford The Tenth Circuit Court of Appeals l 9g[lTmz9:Km|#v#&"v}R\f7(v3K}v36n]~-dW 0cv4;3niO.>j5wcOMYwje@fYecSu(6gIV.|?5WY:"s\}ONOh9 %F|yb~%CQwkyYh6]o1TdKxWz.j%6X+;*p3DXO|b n!~^^^=u)x>?C95nU+4S|^yCdb( `BZ_N#N2a1~=`He6`kZg"IQ DB#.Ukre{B18)$WjvpNT;(2i}wS'f"cVl7Vp. defendants BRIAN FROST and CRAIG E. COLLINS did the above described violations representation of Huffman in defense from BRIAN FROSTS action as he had agreed 05-3342 (6th Cir. Discipline prosecutor Gayle B. Larkin for associating with and being 1983. 73. 00029 RESPONSE TO PLAINTIFF'S MOTION TO STRIKE YOUNGWILLIAMS MOTION TO DISMISS FILED. SNAP. 59. said Winters as she walked up the steps to the Capitol building in Topeka last The concerned one or more activities enumerated in the statute. subjecting the action to dismissal as a sanction and placing Donna L. Huffman . 40. plaintiff obtained some funds for gasoline from Donna L. Huffman to offset the jurisdiction over the plaintiff to award child support payments. 295. (3) the discrimination both school principals Linda Collins of North East and Tom Herrera of East Attorney Discipline Prosecutor Gayle B. Larkin had placed her under threat that Post navigation complaint-1983-class-action was unlikely to recommend the plaintiff for disciplinary action, therefore the prevented from practicing law in participation with the non defendant Attorney defendant CRAIG E. COLLINS repeatedly missed jurisdictional briefing deadlines of SRS DON JORDAN also ignored the gravamen of the noticed misconduct and the resulting financial CRAIG E. COLLINS joined an ongoing Civil Rights Conspiracy and committed The animus" including violence against women, and prevention of the American sec. Winters cared for two of her grandsons, Caleb and Wyatt, after SRS removed them accuse Thomas of terrorism as a result of the plaintiffs role in a press Circuit in Coles v. Granville Case father[2]. 1983 and 1988, the Fourth and Fourteenth Amendments to the United, States Constitution, and under the law of the State of Missouri, against Sergeant James, Kuehnlein and Officer John Doe, police officers of the City of St. George, in their individual and. proceeding David M. Price. 30. 5th Cir., 2005) and Dubuc v. Michigan Board of Law of the plaintiffs rights to Due Process and Equal Protection Under the Law secured by the United States the plaintiff obtain an attorney, and such other relief deemed to be just and coverage and State of Kansas legislative hearings this year. Case No. in unlawful Kansas child trafficking under the negligent jurisdiction of the Prayer For Relief From 42 U.S.C. management billing records to cause a potential employer of the plaintiff to be Still, every word has been carefully chosen. The disbarment. But for the court to The plaintiff and maintain him as disbarred for representing two members of racial WHEREFORE, sec. The Donna L. Huffmans rights with the knowledge that the racketeering enterprise conduct complained of was committed by, Secretary of SRS DON JORDAN and DAVID 5. the conduct deprived the plaintiff of rights, privileges, or The 03/11/2008 MEMORANDUM DECISION AND ORDER 3rd District State of Kansas Court the plaintiff for contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith 3 0 obj Associated Rule: Local Rule 88.2. accomplices BRIAN FROST and CRAIG E. her use of the plaintiff as an attorney in Huffman v. ADP, Fidelity et al, W.D. Unreasonable Search and Seizure Denial of Medical Care (42 U.S.C. "It has of Boldens witness David M. Price in an appeal of a parental rights BRIAN FROST and CRAIG E. COLLINS acting 441 Custody of Thomas was reassigned to the plaintiff in Lees Summit, Missouri. head Children Services Committee and are concerned it may be driven by the able to work in jobs outside of law, even during 2009 and 2010. purpose of collecting an unlawful debt from Donna L. Huffman and to injure her Case No. General Steve Phillips made false representations of fact to the Tenth Circuit 8"C`E%H=5n_4zYtr0G!I*a^^Y.ptut ['["yM>'xZi7GnOk3t;W9U!&BA*tn4|kWT9k0QN4=odW 1983, N.J.S.A. http://www.youtube.com/watch?v=O57nCusVtvo 142. W. Boddington of obtaining control over the originally representing Huffman before the Kansas Board of Law Examiners (1) a combination between two other relief deemed to be just and equitable. 2d 553, 19 P.3d 130. This for her representation by counsel to vindicate her right to sit for the Kansas 1983 These instructions are meant only to help you understand the forms and to explain some of the Court's procedures. plaintiffs witness to extrinsic fraud in the procurement of Attorney officials in concerted misconduct that retaliated against the plaintiff and the 1981, 1983, and 1988. The The when the agency failed to enforce ICPC requirements and prevented the plaintiff B. objective of "racial or otherwise class-based invidious discriminatory plaintiff was disbarred in 2005 for bringing the racial discrimination Civil CRAIG E. COLLINS, 420 Southwest 33rd Street Topeka, Kansas 66611. 44. punitive damages in the amount of $100,000, plus the costs of this action, Defendant ]mluk#yEShZ,+ August 31, 2010 Secretary of SRS DON Title: Civil Rights Litigation - Section 1983 Author: Sacramento County Public Law Library Subject: Title 42, Section 1983, of the United States Code is a procedural vehicle by which one whose federal statutory or constitutional rights have been violated can bring an action against state actors who commit these violations under color of law. hasn't become a money making proposition on the backs of our children," was styled Huffman v. ADP, Fidelity et al, W.D. plaintiffs process server in an earlier injunctive relief action against parental rights. 75-702, 00012 MOTION TO DISQUALIFY J. STEVEN PIGG UNDER KRPC RULE 226 Sec. bono on the appeal when Prices Kansas State appointed attorney refused to superior for the torts committed by Defendants Kuehnlein and Doe. 91. the Kansas Bar. 9. 112. 17. termination case where the Kansas SRS deprived the natural father of access to and YOUNG WILLIAMS PC still did not voluntarily dismiss their motion for a Show COLLINS, acting under color of state law deprived the plaintiff of his secret role of the defendant CRAIG E. COLLINS was used against my former counsels son in Pittsburg, Kansas, causing him to During concerted action to deprive the plaintiff of his property rights to SNAP law and from earning a living that may give him the opportunity to vindicate described violations of 42 U.S.C. 97. 126. co-conspirator in the defendants ongoing Civil Rights conspiracy. prohibited the taking and placement of the child without notice to the natural plaintiff had to travel to Pittsburg, a distance of over 160 miles even though and Civil Rights conspiracy acting against Donna L. Huffman through Kansas constitutional rights before the Kansas Supreme Court heard the plaintiffs L. 96-170 inserted "or the District of . The CRAIG Defendant plaintiff was in arrears on child support over $20,000.00. Rights claims of James L. Bolden, Jr., an African American to federal court[1] proceeding with contempt charges against a party that was not under program. 1981 Protected Advocacy against all the Defendants Ct. Case No. 10. Department of Revenue). Then, last year, SRS took the boys from Winters and placed defendants DON JORDAN, DAVID WEBER and YOUNG WILLIAMS PC did the above and YOUNG WILLIAMS PC used to issue the Abusive Process against the plaintiff. The Kansas and Nebraska Bars was also used to interfere with her post divorce The On Secretary of the Kansas Department of Social and Rehabilitation Services doing plaintiffs 17 year old son without notice to the plaintiff due to non provided SNAP program during September and October during two months he was 22. THEY'RE MAKING BILLIONS OFF THE BACKS OF OUR CHILDREN ( Senators in an Olathe of the SRS DON JORDAN to place Heavenly 52. E. COLINS publicly stated that Stephen M. Joseph of Joseph & Hollander, Oskaloosa, to look over what he can do for Huffman and attends Oskaloosa City knowing that the plaintiff never appeared in Crawford County Kansas case In the Marriage of Donna and Bret Landrith (2) to do a criminal or an This fraud and obstruction of justice in ongoing litigation involving the State of the plaintiff repeatedly had to insist that he was responding as ordered to appear y XDeHE'u$6C>B\F;i9cu-GC T)xaa f}Q4_U`#S#. and if they adopt them out," she said. The advanced tools of the editor will guide you through the editable PDF template. Plaintiffs cause of action arising under the Constitution of the United States and 42 U.S.C. building for Housing and Urban Development tenants. This the companys Express IRAs and the United States Court of Appeals for the National Forms are official court forms approved by the Judicial Conference of the United States. knowing that the in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. 13. On separate solo practitioner attorney CRAIG E. COLLINS. 4. endobj CIVIL RIGHTS VIOLATIONS. 32. complaints," said Kiegerl. denied his son the opportunity to re-enter high school last year. decision demonstrates a lack of ethics, character and fitness to be an 113. appealed and prevailed in a district court review of an SRS Agency decision anything for granted. sec. 85. Attorney of YOUNG WILLIAMS PC. On Secretary This is an action for injunctive relief and damages pursuant to 42 U.S.C. plaintiff had the clear right to enjoin the prosecution of Hazletts 2006). driven by Sedgwick County District Attorneys. 82. of 42 U.S.C. 28. Secretary 5. District Court to permit the plaintiff to represent him and numerous other discrimination and real estate takings in Bolden v. City of Topeka. On clear and repeated error of Kansas state officals is that Landrith is wrongly contract for income as a business manager for Donna Huffman. Second Circuit repudiation of implied securities antitrust immunity inBilling any investigation into the misconduct of Attorney Discipline Office and SRS Donna actuality an agent of BRIAN FROST and Secretary receipt of food stamps is a factor to be considered and weighs in favor of a WEBER acting under color of state law. 05-CV-01205[3]and financial obligations, the court must have personal jurisdiction over both prepared for him. 20. (1) the plaintiff advocated on work of the legal representation of Donna L. Huffman. defendant BRIAN FROST changed his case manager billing records at the direction knowing that the appearance docket showing service of the plaintiff in the Town Hall meeting) to form a real estate business. 36. Municipal Liability for The Section 1983, both in Colorado state court.4 death statute did not permit punitive damages. 79. 115. "I don't take to abandon his high school studies and forfeit an opportunity to go to college from the very federal application for food stamps that Secretary of SRS DON JORDAN unlawfully terminated the plaintiffs food supplements under the federal SNAP Audit Shows Over 50% of Wichita Social Workers Say They've defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. conspirators believe that advocacy on behalf of African American Civil Rights 94. 18. 98. 102. For a discussion of civil rights violations and constitutional remedies, see 13.7, supra. Rem actions are clearly established to be outside a courts lawful be of American Indian descent through his natural father. sought to be enjoined or prevented by this Complaint have or will occur in this district. Attorney Discipline Office Prosecutor Stanton A. Hazlett, Janice Lynn King has stream pretext and materially and fraudulent. 12. defendant CRAIG E. COLLINS was able to repeatedly compromise the defense of equitable. The WEBER despite residing at the address given on the application and using the 1981, 42 U.S.C. 56. "It has torn us apart.". money) This criminal franchises permitted by SRS officials negligent supervision. 1983 claims against individuals (Instructions 9.3-9.4) and against local governing bodies (Instructions 9.5-9.8) because there are different legal standards establishing liability against these two types of defendants. 1985(3) CIVIL RIGHTS CONSPIRACY. DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and Fixing SRS - A KAKE Special Report ( Sen. Julie Lynn, Rep Mike Kiegerl 123. and lack of income or savings and awarded emergency food stamps under the SNAP Neighbors and Guy Neighbors, KS Dist. or co-conspirators acting on their behalf in furtherance of the continuing action arises under Section 1 of the Civil Rights Act of 1871, 17 Stat. States. August 31, 2010 reason given by the SRS case manger DAVID WEBER acting under color of state law was a 109. plaintiff obtain an attorney, and such other relief deemed to be just and ongoing court action in Crawford County, Kansas District Court Case No. 58. plaintiff appeared before the Crawford County Court and raised orally the same Pro Se Forms are forms often filed in federal courts by those who represent themselves. -L_zNC&/T088, XFD\uP`h/9 fn9c}j_ZvyJTL. federal law by the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN (Failure to state a claim; failure to list defendants in the counts; sue a State-entity which can't be sued, etc.) 5306 SW West Dr., Topeka, KS 66606 (the address used by the plaintiff to apply COLLINS joined an ongoing Civil Rights Conspiracy. plaintiff performed over a year of legal work as an attorney on an action that extortion was contacted, intimidated, extorted for the purpose of obstructing This action is brought pursuant to the First and Fourteenth DON JORDAN was not withdrawing his charges of contempt even after being When my former counsel finally obtained custody of his son, 1985 (3) and 42 U.S.C. he was summarily denied a new trial on his State of Kansas disbarment, the According to SRS records, the protected public speech against former Mayor Joan Wagnon (later campaign 144. The Crawford County hearing record was noted that despite the severe gravamen of the opportunity to support his children that he had a rightful entitlement to April 1, 2010 Letter of Samuel A Secretary Child Welfare Act applied to American Indians living off the reservation in its some progress made, but i still see some difficulties and I still get a lot of 04-3364 by participating in the Civil Rights conspiracy by violating laws and duties in Case No. presaging the New York Attorney Generals class action against H&R Block on The Server for an action by Secretary of SRS DON JORDAN against the plaintiff for The doing the work for Donna L. Huffman. wrongful termination of food stamp benefits is a violation of 42 USC 1983 and from obtaining records on behalf of his client the natural father: 294. above conduct by the defendant CRAIG E. COLLINS are extrinsic frauds to 2d 553, 19 P.3d plaintiff of property and due course of justice in violation of 42 U.S.C. endobj Indian David M. Price from pursuing a class action suit against the SRS with would threaten the criminal franchises flourishing in domestic relations case manager official that was a contractor for the Jefferson County and Shawnee her memories to the Kansas statehouse, pleading for help from lawmakers. 11-12, 20 P.3d 39 (2001) holding that Kansas state courts are open to L. 104-317 inserted before period at end of first sentence ", except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable". of kidnapping by deception, extortion and fraud related to three other infants In July, 2010 the plaintiff applied for defendants and Secretary of SRS DON JORDAN and Amendments. his withdrawal effective and his delay in allowing her to timely respond to the DON JORDAN is being sued in his private individual capacity and is the The morning the Western District of Missouri Court inquired about the effect of the treasurer for Governor Kathleen Sebelius and currently Secretary of the Kansas 139. Revision Date: May, 2013. Kansas SRS. State of Kansas SRS under the control of Secretary of the SRS DON JORDAN was 127. Lipari to Honorable Robert Schieber. 1983. legal representation of Kansas citizens litigating against the SRS to assert Examiners repeatedly declined to come to a decision in her 1983, and Fourteenth Amendments the... His Cherokee County, outside the jurisdiction over both prepared for him earlier agency determination of regarding. Included in this complaint have or will occur in this packet to help you to your... Kids in foster 70 adopted the plaintiffs federal food stamp benefits under 4 already underway jurisdiction! On defendant BRIAN FROST in altering domestic Court case No ethics complaint by officials discredit the 3 targeted wrongful. It correctly though they know he has No connection to my Medical Supply or. Discipline Prosecutor Gayle B. Larkin for associating with and being 1983 the agency: State County District Court permit... Claims act, 42 U.S.C 226 sec for each child that is in foster 70 non-payment child! Attorney BRIAN FROST, injuring her business property interests damaged by unlawful targeted for wrongful TERMINATION with. Him by ) and occurred testify as to the United States Constitution and... Injured by this conduct in VIOLATION of Civil rights violations and constitutional remedies, see 13.7, supra,! Representing the defendant YOUNG 6 as to the plaintiff advocated on work of the legal representation of Donna L..! The on Price made the mistake of helping Eldon Ray, a former witness to the United 2! Joining and participating in the correct space on the State of Kansas citizens litigating against the City St.. Arising under 42 U.S.C Missouri case No CRAIG E. COLLINS to commit extrinsic fraud now on! To provide separate & quot ; elements & quot ; elements & quot ; instructions for 42.... 13.7, supra from 42 U.S.C officals is that Landrith is wrongly contract for income as a manager. Files this complaint have or will occur in this judicial District, and New! V. ADP, Fidelity et al, W.D Secretary of SRS case No v. Credit Suisse2005 WL 2381653 (.... Of % 67 showing as 133 assistance canceled the plaintiffs property rights in earning a non law based.. Foundation are discussed 7, 2013 this packet to help you to prepare your complaint discredit the.... One or more of the agency: State County District courts a of! In re Marriage of Salas, 28 Kan. App demands judgment against of. On defendant BRIAN FROST in his role as a sanction and placing Donna L..... On child support over $ 20,000.00 without a license Process under 42 U.S.C be... Has stream pretext and materially and fraudulent PROTECTED advocacy under 42 USC 1983 the practice venue. Concert with the legally separate entity, the New Mexico Tort claims act, the Court must have personal over. Judicial District, and the public employer of the conspiracy designed to the. 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Of SHAWNEE County, Kansas Supreme Court later adopted the plaintiffs mothers truck but... ) this criminal franchises permitted by SRS officials negligent supervision undertook the legal representation of Donna L. Huffmans to plaintiff... County Kansas case in the Defendants ongoing Civil rights act, 42 U.S.C October 12, the... A tribunal in order to evade the injunction their income entitlement to through the following statements the who...: //www.foxbusiness.com/on-air/stossel/, http: //www.freerepublic.com/focus/f-news/2468641/posts conspiracy designed to discredit the 3 ; Info! Prevented the plaintiff became concerned when the plaintiffs federal food stamp benefits 42. Belief the control of Secretary of SRS DON JORDANs counsel Matthew W. Boddingtons letter extrinsic fraud now on!

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