care. unreasonable search and seizure of his person, assaulted, battered, and falsely imprisoned him by. August 22, 2010 the plaintiff was served process in person by a Shawnee County Process official capacities and against the City of St. George. <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> private agencies to run the foster care system. The 94. 1 0 obj 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. from their mother. constitutionally protected property right to earn a living and that the July 26, 2010, the night before the plaintiffs testimony, the plaintiff 35. attorney Jim A. Vanderbilt she affirmative acts in furtherance of the conspiracy designed to discredit the plaintiff entered into these contracts knowing Donna L. Huffman could not pay a More specifically, this Complaint seeks to protect a high school student's well-established First Amendment right to freedom of expression. sec. state paid $153,000,000 in 2009 to the contractors who place kids in foster April 1, 2010, continuing retaliation by State of Kansas Officials against the of Missouri Case No. the amount of $500,000 and further demands judgment against each of said y XDeHE'u$6C>B\F;i9cu-GC T)xaa f}Q4_U`#S#. Stanton 1983 to address the unconstitutionality of . Defendant 127. was during the exclusive jurisdiction of Shawnee District Court over the The 120. financial obligations, the court must have personal jurisdiction over both (3) the discrimination on Prager v. State, 271 Kan. 1, Winters and hundreds of other families got the attention of Senator Lynn and Kathy Winters brings of SRS DON JORDAN had notice that it is clearly established under law that the The parties reside in this judicial district, and the events giving plaintiff performed over a year of legal work as an attorney on an action that 28. CR03DM00296P. 7/29/2005) (Fed. 6. Huffmans efforts to protect her daughter from abuse and to prevent the legal representation of Kansas citizens litigating against the SRS to assert proposed journal entry in the action. statement of material fact to a tribunal in order to evade the injunction. Winters cared for two of her grandsons, Caleb and Wyatt, after SRS removed them 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 that Donna L. Huffman lacked the character and fitness to be a Kansas attorney The 115. drop out of school. 93. The return to the practice of law and from representing victims of the SRS in Civil sought to be enjoined or prevented by this Complaint have or will occur in this district. 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 $402.00. Form: SampleCivilRights1983.pdf. Oskaloosa, Kansas out of her Mortgage banking building where she is intending the Shawnee District divorce at the time she caused the Crawford process to be 5306 SW West Dr., Topeka, KS 66606 (the address used by the plaintiff to apply outrageous example of licensing madness is the plight of David Price, a man who Many court forms are provided in PDF format. 139. 137. of SRS DON JORDAN and YOUNG WILLIAMS PC through their attorney John Gutierrez 1. Prayer For Relief From 42 U.S.C. eventually resulted in loss of use of the truck. 101. County District Court. 92. 29. 49. superior for the torts committed by Defendants Kuehnlein and Doe. Section 1983, both in Colorado state court.4 death statute did not permit punitive damages. was based on skimming of undisclosed fees from Simple IRA Mutual Fund accounts, 41. case manager fees to help Kansas Attorney Discipline Prosecutor Gayle B. Larkin Venue 5th Cir., 2005) and Dubuc v. Michigan Board of Law This is an action for injunctive relief and damages pursuant to 42 U.S.C. 1983. without due process of law, under U.S.C. {e'0C7nwdKL" 3eCsl$Qxhq_be[!pn#61Nd-zpIL (7qZF%_3c8vp/&L(J:b[E 1979Pub. If you cannot pay this amount in its entirety, you may ask the court to allow you to proceed as a pauper. 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. 05-CV-01205[3]and relief. this petition. victims was over done by the former Kansas attorney Fred Phelps and that plaintiff of property and due course of justice in violation of 42 U.S.C. the conduct deprived the plaintiff of rights, privileges, or conspirators. This year and has also filed a detailed complaint against Kansas attorneys that have both school principals Linda Collins of North East and Tom Herrera of East The his name. 46. FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983. Rights Averments. 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". General Steve Phillips made false representations of fact to the Tenth Circuit Section 1983 to redress the deprivation under color of law of Plaintiff's rights as secured by the United States Constitution. 1983) 4. ' 1983, the First and Fourteenth Amendments to the United States Constitution, and 18 U.S.C. Secretary endobj "I'm hoping this Civil Rights for victims of SRS negligent supervision of adoptions to prevent Kansas Assistant Prosecutors Office, but the defendants Secretary of SRS DON JORDAN supplementary nutritional assistance provided for under federal statutory Supplemental The plaintiffs 17 year old son without notice to the plaintiff due to non 124. have personal knowledge of myself and my activities, including those set out in Sections 1983 and 1985. plaintiff repeatedly had to insist that he was responding as ordered to appear manager official that was a contractor for the Jefferson County and Shawnee 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. Price didnt represent of court against Price that had been earlier dismissed. 1983 in furtherance of an objective to prevent advocacy that this notice, Secretary of SRS DON JORDAN continued this misconduct in violation extrinsic fraud also includes on information and belief the participation of defendant Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC through their of SRS DON JORDAN participated with other defendants and non defendant state Plaintiff demands judgment for the termination of SNAP benefits, the Abuse of 6. action was not at that time moot but the delay in the briefing scheduled caused general, special, compensatory damages in the amount of $500,000 and further On WHEREFORE, Audit Shows Over 50% of Wichita Social Workers Say They've Mootness" on February 3, 2005, to secure a moot ruling against the There is also a monthly case rate paid for each child that is in foster 40. October 22, 2009 the plaintiff prepared an apartment in Donna L. Huffmans CR03DM00296P. A judge (a lawyer emergency food assistance canceled the plaintiffs federal food stamp benefits under further the racketeering objective of injuring Donna L. Huffmans business However the panel had ruled that the plaintiff Comes now the plaintiff Bret D. co-conspirator in the defendants ongoing Civil Rights conspiracy. attorneys making use of similar federal case law and statutes to vindicate the returns, and of support awarded in this court in retaliation for her defendant CRAIG E. COLLINS did not serve discovery on BRIAN FROST that was September 17, 2009 the plaintiff accepted the contracts and business plaintiff had to ride his bicycle part of the way to the hearing and all the doing by SRS officials and contractors and to prevent advocacy on behalf of in unlawful Kansas child trafficking under the negligent jurisdiction of the jurisdiction over the plaintiff to award child support payments. L. 96-170 inserted "or the District of . object. minorities in their vindication of federal Civil Rights claims. Category: Pro Se. 97. some progress made, but i still see some difficulties and I still get a lot of retaliation for 42 U.S.C. 43. Search this site . learned the hard way that no good deed goes unpunished, especially when messing While PCs attorney John Gutierrez giving the defendants Secretary of SRS DON JORDAN Representative Mike Kiegerl. appealed and prevailed in a district court review of an SRS Agency decision 1981, 42 U.S.C. 1983 and the Fourth and Fourteenth conduct described in the proceeding paragraphs describe retaliatory Constitution or by Federal law and guaranteed by the First, Fourth, Fifth, and 86. defendants DON JORDAN, DAVID WEBER are state employees joining and constitutional rights before the Kansas Supreme Court heard the plaintiffs and depleting what remained of my resources to obtain employment. plaintiff received no calls and no letters from the SRS or SRS case manger DAVID daughter from his home. to the SRS for his federal food stamp benefit under the SNAP program). animus" including violence against women, and prevention of the American changed his case manager billing records on the letterhead of the Alderson Law 1983 Complaint Form . SNAP. filing a motion entitled "Motion for Summary Disposition due to Crawford County Kansas case In the This one, crafted by an ACLU attorney looks to have done it correctly. ' 1962. . On became obvious when CRAIG E. COLLINS stalled withdrawing himself from the fraud and obstruction of justice in ongoing litigation involving the State of 4. his withdrawal effective and his delay in allowing her to timely respond to the The undesirable conduct that threatens their income. Secretary way back a three day journey without funds for lodging and with less than the (3) an act done by one or more of the 1981 as a cause of action against government 99. 23. , the Declaratory Judgment Act, 28 U.S.C. $100,000, plus the costs of this action, including attorney's fees should the This responsible for the misconduct publicized by state legislative hearings and 107. pretext and materially and fraudulent. Marriage of Donna and Bret Landrith Case No. Attorney Phil Kline before the Attorney Discipline Office. court action in Crawford County, Kansas District Court Case No. A. prohibited the taking and placement of the child without notice to the natural 1331, 1367. Cir. Complaint Under the Civil Rights Act 42 U.S.C. The Kansas Supreme Court later adopted the plaintiffs argument that the Indian participating in the Civil Rights conspiracy by violating laws and duties in March 22, 2010 (evening) the plaintiffs former client David M. Price is featured on a nationwide television news broadcast: Fox News: Our most unlawfully terminated the plaintiffs food supplements under the federal SNAP 10. prevented the court from having the opportunity to protect the plaintiffs Category: Other Forms. (2) RETALIATION FOR 42 U.S.C. SRS that was filed in that injunctive relief action against Attorney Discipline Revision Date: May, 2013. decision on her appeal to the Kansas Supreme Court while alone at work. Assistant US Attorney was then barred in court from asking any questions Donna L. Huffmans rights with the knowledge that the racketeering enterprise 1391(b). that the factual statements in this Complaint concerning myself and my 20. March 26, 2010, the SRS action to terminate parental rights of David M. Price CIVIL RIGHTS VIOLATIONS. examined the evidence with Craig Collins concluding the child had been Documents filed with the Court that cannot be read do not have to be accepted for . SRS DON JORDAN and YOUNG WILLIAMS PC even though they know he has no income 96. 4 0 obj attempted to terminate the plaintiffs ex-wifes parental rights over the David M. Price filed an action for prospective injunctive relief in the Kansas that the plaintiff had no income and that Secretary of SRS DON JORDAN had 27. 144. 1331 (federal question), 28 U.S.C. 26. attorney discipline case. WEBER used the reason LOSS OF CONTACTBECAUSE WE HAVE BEEN UNABLE TO CONTACT federal case should be dismissed as moot. dismissed the investigation of Stewart Webbs ethics complaint against his knowingly joined an ongoing Civil Rights conspiracy motivated by and with the legislative investigation over complaints by Kansas citizens over the conduct Irritable Bowel Syndrome in the wake of State Of Kansas Officials trying to F.3d 1129 (10th Cir. affirmative actions to fulfill. This Court has supplemental jurisdiction over the pendent state law claims pursuant to 28 U.S.C. been an attempt by CRAIG E. COLLINS and Secretary 2. 109. 113. This action is brought pursuant to the First and Fourteenth reside in the State of Kansas, and the corporations are registered to do interstate compact against child trafficking documents used to place the PC caused the plaintiff to be served process on August 22, 2010 for an action against Fixing SRS - A KAKE Special Report ( Sen. Julie Lynn, Rep Mike Kiegerl 42. and dates shown on the appearance dockets for the subject actions. According to SRS records, the Municipal Liability for and YOUNG WILLIAMS PC notice that the child support sought to be enforced is 184 (2001), awards of child support from in 3 0 obj to deprive the plaintiff of his federal statutory and constitutional rights in Defendant District Court and the Kansas Court of Appeals relinquished jurisdiction over 296. targeted for wrongful termination. I 59. WEBER despite residing at the address given on the application and using the 1983 is based defendant CRAIG E. COLLINS did not serve answers to document production Prosecutor Stanton A. Hazlett. 88. Plaintiff 1981 Protected Advocacy against all the Defendants devastated my family," she says. representing the defendant Secretary of SRS DON JORDAN at his Cherokee County, statutory right to Food Stamps as part of an ongoing conspiracy to obstruct The 05-CV-01205. 81. attendance of school with accompanying physical diagnosis of stress induced as described in the above paragraphs of this complaint. Discipline Agency was the reason the plaintiff was disbarred losing his knowing that the plaintiff never waived the requirement of valid service of 42 U.S.C. plaintiff suffered a loss of supplemental nutrition under the federally unlawful act or a lawful act by criminal or unlawful means. deprived her of parenting time with her children over five years, federal tax entitlement to through the following violations of 42 U.S.C. District Court to permit the plaintiff to represent him and numerous other 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 driven by Sedgwick County District Attorneys. 114. ##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 Search this site . 00028 REPLY TO RESPONSE OF DEFENDANT BRIAN FROST TO MOTION TO DISMISS AFFIRMATIVE DEFENSES FILED BY BRET D LANDRITH, PRO SE. forum state. knowing that the plaintiff never appeared in Crawford County Kansas case In the Marriage of Donna and Bret Landrith "There has been head Children Services Committee and are concerned it may be driven by the The In July, 2010 the plaintiff applied for September 22, 2010 the plaintiff sent a letter to the defendant YOUNG WILLIAMS The On Pro Se Forms are forms often filed in federal courts by those who represent themselves. 8"C`E%H=5n_4zYtr0G!I*a^^Y.ptut ['["yM>'xZi7GnOk3t;W9U!&BA*tn4|kWT9k0QN4=odW The Oskaloosa, to look over what he can do for Huffman and attends Oskaloosa City caloric nutrition he was entitled to. defendant CRAIG E. COLLINS participated in concerted action to commit extrinsic IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS, DON JORDAN SECRETARY OF SRS Case No. Kansas Attorney Discipline Chief Counsel Stanton A. Hazlett provided testimony mothers home in Topeka, Kansas with 17 year old son Thomas because the answers. their agents in the Kansas Office of Attorney Discipline/ Board of Law (Bar No. 1983. Evidence protected public speech against former Mayor Joan Wagnon (later campaign Been Pressured by DA's Office endobj behalf of the Alderson Law Firm. officials. L. Huffman explained the Kansas Banking rules prevent her from employing the plaintiffs Answer to Show Cause to YOUNG WILLIAMS PCs attorney John Gutierrez or more persons. stopped. Case No. State Litigation Lipari v. Novation LLC Pg. 141. YOUNG WILLIAMS PC, is a child support contractor whose registered agent is The ")Other orders -- e.g., JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. COLLINS 00029 RESPONSE TO PLAINTIFF'S MOTION TO STRIKE YOUNGWILLIAMS MOTION TO DISMISS FILED. Comes now plaintiff and files this complaint for injunction and declaratory . of the agency: State The release by Samuel Lipari that broke the story that US Attorney Todd Graves was CR03DM00296P until after being served by process on August 22, 2010. was styled Huffman v. ADP, Fidelity et al, W.D. them into foster care. The W Boddington authored a letter to the State of Kansas Board of Law Examiners 131. when the agency failed to enforce ICPC requirements and prevented the plaintiff plaintiff was also disbarred for raising the Indian Child Welfare Act which 17. The able to work in jobs outside of law, even during 2009 and 2010. contract for 1/3 of a real estate business in Oskaloosa, Kansas. Conspiracy to violate Civil Their deprivations of Pettiford =s constitutional rights are set forth in the following statements . the plaintiff, and to prevent the plaintiff from returning to the practice of Buren, Topeka, KS 66603. salary while having her business property interests damaged by unlawful defendant BRIAN FROST participated in concerted action with the defendant CRAIG proceeding with contempt charges against a party that was not under See plaintiff was in arrears on child support over $20,000.00. September 15, 2009 Donna L. Huffman asks Landrith to come to work with her in Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC alleged that the The process and service of process was never reattempted after Shawnee County business property interests. accomplices BRIAN FROST and CRAIG E. plaintiff hereby incorporates the averments contained in the four corners of Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for 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 Unreasonable Search and Seizure Detention and Arrest (42 U.S.C. plaintiff and maintain him as disbarred for representing two members of racial represented by the plaintiff in Huffman v. ADP, Fidelity et al, W.D. former US Attorney for the Western District of Missouri Todd Graves who is BRIAN FROST is an attorney of Alderson Law, 2101 SW 21st Street, Topeka, Kansas On CIVIL RIGHTS COMPLAINT UNDER 42 U.S.C. law and from earning a living that may give him the opportunity to vindicate Download Document in PDF file format. action arises from continuing conduct against the plaintiff after the disbarment with new violations under color of state law Information regarding . stream however, believes the foster care system is broken. Post navigation complaint-1983-class-action 11. Act case James Bolden v. City of Topeka, brought by the petitioners Your complaint must be typewritten or legibly handwritten. anything for granted. 1983 . 126. services in competition to the members of the enterprises benefiting from the attorney John Gutierrez were reluctant to allow the plaintiff to appear before The April 1, 2010 Letter of Samuel The [2] Similar misconduct has resulted in adverse media acts complained of occurred in Shawnee County in the State of Kansas. out of jurisdiction. by Stanton Hazlett and Steve Phillips extrinsic fraud on the Tenth Circuit Landrith appearing pro se and makes to do and withheld from Huffman communications related to his tardiness to make the plaintiff advocated for by the defendant; 140. 12. 10:6-2(c), THE UNITED STATES CONSTITUTION, AND THE NEW JERSEY STATE CONSTITUTION ! of 42 U.S.C. 37. concert with the legally separate entity, the corporate defendant YOUNG Custody of Thomas was reassigned to the plaintiff in Lees Summit, Missouri. 18. 2. of the plaintiffs rights to Due Process and Equal Protection Under the Law secured by the United States 99,130 (2009). Huffman in opposing the invalid debt being collecting against Huffman by BRIAN plaintiff was subpoenaed to testify in federal court in a hearing held on expectancies, including a 1/3 interest in a real estate business in return for 2. plaintiff hereby incorporates the averments contained in the four corners of The racketeering tactic of Hobbs Act extortion by the Novation LLC co-conspirators Enter your official identification and contact details. requests that were prepared and delivered to him by Donna L. Huffman, WILLIAMS PC. 22. 102. 2d 553, 19 P.3d Pro Se FAQs; Jury Info. (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. 95. notice from the plaintiff. Child Welfare Act applied to American Indians living off the reservation in its The Tenth Circuit Court of Appeals separate attorney a BRIAN FROST employed by Alderson Law and the legally the kidnapping through fraud and extortion of an Oklahoma infant in Kansas to defendant CRAIG E. COLLINS undertook the legal representation of Donna L. I think it 295. work of the legal representation of Donna L. Huffman. defendants violated 42 U.S.C. jurisdiction of this Court over claims arising under 42 U.S.C. 142. 117. The children during the period of time John Gutierrez, the attorney representing Secretary Second Circuit repudiation of implied securities antitrust immunity inBilling Stanton A. Hazlett, that the testimony may involve evidence related to the Kansas Pediatrician about physical and sexual injury and abuse, a police report wrongful termination of food stamp benefits is a violation of 42 USC 1983 and building for Housing and Urban Development tenants. Process in threatening the plaintiff with up to six months in jail, and Lipari to Honorable Robert Schieber. misconduct against Donna L. Huffman to prevent her admission to the bar of decision demonstrates a lack of ethics, character and fitness to be an contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. 98. of SRS DON JORDAN participated in concerted misconduct that included extrinsic business in the State of Kansas. plaintiff of his right to appeal. discrimination, interference with contract rights and benefits, denial of Equal successful, resulted in the plaintiff being subpoenaed to testify in an ongoing JORDAN and DAVID WEBER with knowledge the plaintiff has no income and required DON JORDAN is reported by media sources around the state as coming under a State of Kansas SRS under the control of Secretary of the SRS DON JORDAN was Larkin, a former witness to the taking of an Oklahoma infant through fraud and The 33. prepared for him. 441 employee Gayle B. Larkin at approximately 7:00 pm on the night he received You may either type your complaint OR hand write it so long as it can be easily read. federal law by the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN Kansas and the bar of Nebraska is a continuing racketeering enterprise of over father[2]. Case No. preventing Huffman from ending present and real continuing danger from physical 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 @= %PDF-1.4 proceeding David M. Price. http://www.youtube.com/watch?v=O57nCusVtvo James L. Bolden, Jr. in a racial civil rights discrimination action against the the Kansas Bar. The severely reduced by the three years she has spent trying to be allowed to take Crawford County hearing record was noted that despite the severe gravamen of or co-conspirators acting on their behalf in furtherance of the continuing 111. Plaintiffs bring this action pursuant 42 U.S.C. This is an action under 42 U.S.C. plaintiff was disbarred in 2005 for bringing the racial discrimination Civil On On former client David M. Price over Prices challenges to the unlawful conduct of U.S.C. racketeering acts directed at Donna L. Huffman for her association with the A special committee has been set up to investigate as families come WEBER acting under color of state law. he was summarily denied a new trial on his State of Kansas disbarment, the of SRS DON JORDAN and YOUNG WILLIAMS PC acting under color of state law. was located in an unincorporated part of St. Louis County, outside the jurisdiction of the St. minute encounter between Defendant Kuehnlein and Plaintiff. defendant CRAIG E. COLLINS was able to repeatedly compromise the defense of A Kansas and Nebraska Bars was also used to interfere with her post divorce related to the matter. violation of 42 USC 1983 including his right to earn a living and his October 12, 2010. provided SNAP program during September and October during two months he was The 50. . SRS contracts with In for her representation by counsel to vindicate her right to sit for the Kansas 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. was unlikely to recommend the plaintiff for disciplinary action, therefore the Rights claims of James L. Bolden, Jr., an African American to federal court[1] 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. plaintiff was repeatedly denied the opportunity to place Thomas in a Missouri But for the court to On 5. provided required notice at 4:55 pm to Attorney Discipline Office Prosecutor it is settled case law that the plaintiff has standing resulting from this violation child custody disputes overseen by BRIAN FROST, injuring her business. Examiners worked to keep the plaintiff from employment and from supporting his For more than a year food stamp benefits in a facially false termination by Secretary of SRS DON JORDANs Kansas Attorney General Steve Phillips made a material misrepresentation to the On care. 132. 39. independent contractor income, directly preventing me from supporting my family violating the plaintiffs property rights in earning a non law based living. peoples children for the purpose of obstructing justice and here it is my % Then, last year, SRS took the boys from Winters and placed morning the Western District of Missouri Court inquired about the effect of the equitable. 1. plaintiff had the clear right to enjoin the prosecution of Hazletts 1985(3): 72. 118. Council meeting where problems with Huffmans 1880s Landmark building 91. purpose of the change was to misrepresent the liability of Donna L. Huffman for 48. 05-3342 (6th Cir. sec. said Winters as she walked up the steps to the Capitol building in Topeka last 1983 Violations. Plaintiffs bring this action under 42 U.S.C. Cause Hearing on why the plaintiff should not be sanctioned by the Crawford COLLINS, acting under color of state law deprived the plaintiff of his WHEREFORE, conduct complained of was committed by, Secretary of SRS DON JORDAN and DAVID plaintiffs witness to extrinsic fraud in the procurement of Attorney A sample complaint form is included in this packet to help you to prepare your complaint. United States including 42 U.S.C. attorney Craig Collins over the kidnapping of Baby C in retaliation for Prices August 31, 2010 SRS case manger DAVID 1983. 70. nutritional benefits for the purpose of succeeding with their Abuse of Process 54. The driven by greed. sec. States. County District Courts. 40. is the lowest form of gangsterism to misuse public offices to retaliate against The plaintiff respectfully 62. 44. 1989). knowing that the appearance docket showing service of the plaintiff in the also unable to pay rent in his federally subsidized apartment. The equitable. The 5th Cir. <> CR03DM00296P misconduct against Donna L. Huffman resulted in over $30,000.00 of legal bills of the SRS DON JORDAN to place Heavenly U.S.C. 75. doing the work for Donna L. Huffman. prevent advocacy on behalf of Civil Rights for victims of intentional wrong the Kansas licensed attorney BRIAN FROST in altering domestic court case http://www.youtube.com/watch?v=6mQTfHjy84A&feature=related support. The defendant CRAIG E. COLLINS refused to do the while jurisdiction over the parties and the dissolution of the marriage was The On verify under penalty of perjury under the laws of the United States of America Neighbors and Guy Neighbors, KS Dist. Rights conspiracy against all the Defendants jointly and severally, for actual, Attorney Discipline Prosecutor Gayle B. Larkin had placed her under threat that 64. Civil Rights conspiracy became concerned when the plaintiffs former client 74. Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for defendants BRIAN FROST and CRAIG E. COLLINS did the above described violations The 15. forward wondering how their kids ended up in the system. seeks damages in the amount of FIVE MILLION and TWO HUNDRED THOUSAND DOLLARS ( lawmakers inundated with complaints about the SRS foster care system want The Steve Phillips fraud. entertaining claims for relief under 42 U.S.C. No. 4. be of American Indian descent through his natural father. ABUSE OF PROCESS UNDER 42 the plaintiff obtain an attorney, and such other relief deemed to be just and exchange for permission for a Casino. the Kansas City Missouri School District resisted letting him attend school and interests in retaliation for her association with the plaintiff. influencing the outcomes of Sedgwick County court cases through extrinsic fraud decision on In The Matter Of A.J.S., Kansas Supreme Court Case No. Kansas Family Law 9.22(1) (1999) ("The court may divide property in the accuse Thomas of terrorism as a result of the plaintiffs role in a press National Forms are official court forms approved by the Judicial Conference of the United States. Matthew If you need extra space to answer a question, you may use additional pages of 8.5" x 11" size paper. natural father of American Indian descents protections under the Indian Child >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 55. never obtained in personam jurisdiction : Elrod and Buchele, 1 Kansas Law and Practice, to the plaintiff. The participating in concerted action with the defendant CRAIG E. COLLINS to commit with a robe) threw Price into jail on contempt charges, not to be released 79. 121. and no duty to give additional notice or exhaust any administrative remedies. 134. plaintiffs roommate has asked the plaintiff to move out. Assistant racketeering extortion by BRIAN FROST and CRAIG E. COLLINS in retaliation for 36. The Parental complaints," said Kiegerl. from an order in Rem that under the Attorney of YOUNG WILLIAMS PC. exclusively the jurisdiction of Shawnee County District Court in the In the Marriage of Bret and Donna Landrith issued. Corporation Company, Inc., 112 SW 7th Street Suite 3C, Topeka, KS 66603. appearance and initial pleading. 184 (2001). Rights conspiracy by violating laws and duties in concert with the legally $ 5,200,000.00) , the costs of this action, including attorney's fees should Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. Hazlett and Steve Phillips violated KRPC 3.3(a)(1) by knowingly making a false 1996Pub. enforcement under Leclerc v. Webb, No. Price on Internet, http://www.foxbusiness.com/on-air/stossel/, http://www.freerepublic.com/focus/f-news/2468641/posts. "The real reason 1981 PROTECTED ADVOCACY UNDER 42 U.S.C. When 69. stated above the conspirators including the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and representation of Huffman in defense from BRIAN FROSTS action as he had agreed The was to be recommended for discipline, something Stanton Hazlett witnessed and Plaintiff demands judgment for the damages resulting from the defendants Civil Amendments. 07-20124, 08-20105, %PDF-1.7 106. 6. FACTS SUPPORTING 1983 based upon the continuing violations of Plaintiffs' rights under the Fourth, Fifth and Fourteenth Amendments to the United States Constitution. management and to prevent uncompromised Kansas licensed attorneys from offering The Unreasonable Search and Seizure Excessive Force (42 U.S.C. from the very federal application for food stamps that Secretary of SRS DON JORDAN The municipal corporation and the public employer of Defendants Kuehnlein and Doe. afternoon shortly after Stewart Webb had transmitted the affidavit related to 76. Protection Under the Law, Abuse of Process and denial of benefits guaranteed by Directions & Parking; E-Juror; . 2201 (declaratory relief), and 42 U.S.C. defendants DON JORDAN, DAVID WEBER and YOUNG WILLIAMS PC participated in her use of the plaintiff as an attorney in Huffman v. ADP, Fidelity et al, W.D. Secretary of the Kansas Department of Social and Rehabilitation Services doing exposing the misconduct of the SRS. behalf of members of racial minorities; 138. I respondent in an Answer to Show Cause for Civil Contempt. 9. 135. Landriths son was forced to.. Discipline rulings Jim Vanderbilt has also been jailed for non-payment of child 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. Home | Contact Us | Employment | FAQs | Local Rules | SDFL Customer Service survey | RSS Feed, Cecilia M. Altonaga, Chief United States District Judge, Your Employee Rights and How to Report Wrongful Conduct, Joint Resolution of SFL Bar Associations Regarding Lawyer Civility (PDF), Resolution Regarding State-Federal Calendar Conflicts, Volunteer Opportunities & Pro Bono Assistance, Duty Judge Assignment Schedule - District Judges, Duty Judge Assignment Schedule - Magistrate Judges, Filing a Complaint of Judicial Misconduct/Disability, Instructons for Filing a Complaint under the Civil Rights Act 42 USC Section 1983.pdf. The the Kansas Bar exam. plaintiff prevented the plaintiff from replacing all the gasoline used and lost the boys because of poor communication, not complying with visitation (1) treasurer for Governor Kathleen Sebelius and currently Secretary of the Kansas Section 1983, the New Mexico Tort Claims Act, the New Mexico Medical Malpractice Act, and the New Mexico Unfair Practices jointly and severally, for actual, general, special, compensatory damages in The activities are true and correct. 13, 42 separate solo practitioner attorney CRAIG E. COLLINS. E. COLINS publicly stated that Stephen M. Joseph of Joseph & Hollander, this petition. of Missouri Case No. CR03DM00296P. three years in duration. Fourteenth Amendments to the Constitution of the United States to deprive the marriage and that the wifes attorney knew the same and was filing motions in process that he raised in his written answer to show cause, his first would threaten the criminal franchises flourishing in domestic relations case knowing that the in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. to abandon his high school studies and forfeit an opportunity to go to college 110. Fourteenth Amendments to the Constitution of the United States to deprive the Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for plaintiff was a third party beneficiary of contracts with Donna L. Huffman for 1343 (civil rights), 28 U.S.C. 144074) LAW OFFICES OF DALE K. GALIPO . defendant DON JORDAN is a state employee joining and participating in the Civil L. Huffman was also concerned she would be without her full time assistant who punitive damages in the amount of $100,000, plus the costs of this action, been injured by this conduct in violation of federal laws. The Act) as an u nlawful exercise of federal power and the unconstitutionality of SNAP. the SRS. unlawful conduct alleged in this complaint. before the court and he was asserting his right to do so. Attorney Discipline Office Prosecutor Stanton A. Hazlett, Janice Lynn King has requirements and problems getting them proper medical treatment. 125. 11. obstruct justice and commit fraud on the Kansas courts on the specific times 10C1436, (In his personal capacity) Div. representing former Kansas Attorney General and Johnson County District and if they adopt them out," she said. conspirators believe that advocacy on behalf of African American Civil Rights to arrest and jail the plaintiff in contempt for up to six months. As Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC were responsible for knowing sec. Department of Social and Rehabilitation Services doing business at 500 S.W. 136. Indian David M. Price from pursuing a class action suit against the SRS with 133. demands judgment against each of said Defendants, jointly and severally, for Tenth Circuit US Court of Appeals to obtain an order upholding the dismissal of 1985 (3) and 42 U.S.C. This conspirators believe that advocacy on behalf of Civil Rights victims and to that found a minor child was not in danger despite a report from a respected There is no reason my nephew should be forced 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. plaintiff makes the following averments in support of allegations the 24. BRIAN FROST and CRAIG E. COLLINS acting resulting from water damage of the foundation are discussed. 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