UNITED STATES DISTRICT COURT

DISTRICT OF COLUMBIA

PASTOR DANIEL L. MEIER

Plaintiff, Case No.

Hon.

v.

WILLIAM M. MEGGS STATE ATTORNEY, FL.

JUDGE GEORGE S. REYNOLDS, LEON CO. FL.

LARRY CAMPBELL LEON COUNTY SHERIFF, FL.

DAVID KOTEL, FBI

JUDGE ROBERT H. CLELAND, MI.

DEPARTMENT OF CHILDREN AND FAMILIES, FL.

GUISEPPE A. BETTA, FL.

JUDGE DAWN COLOCA-JOHNSON, FL.

VICTOR LAURIA NOVI POLICE DEPARTMENT, MI.

FLORIDA DEPARTMENT OF REVENUE

ROBERT MCNEELY, ESQ., FL.

MARILYN K. MORRIS ESQ., FL.

PAUL SHAPIRO ESQ., FL.

CHARLES McCLURE, ESQ., FL.

ELLEN HAMILTON, FL.

MANDY LUTTENTON, GA.

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AMY OLK, FL.

DEPUTY JOHN MEEKS, FL.

PRICILLA QUIONNES ESQ., FL.

JUDGE JOHN C. COOPER, FL.

JUDGE JOHN SJOSTROM, FL.

EDWARD HORAN ESQ., FL.

TALLAHASSEE POLICE DEPARTMENT, FL.

SOUTHFIELD POLICE DEPARTMENT, MI.

JUDGE KATHLEEN DEKKER, FL.

JUDGE TERRY P. LEWIS, FL.

DEPARTMENT OF HOMELAND SECURITY

DETROIT DIESEL CORPORATION, MI.

WILLIAM ALTMAN, ESQ. MI.

JUDGE WENDY BAXTER, MI.

ROBERT L. GREEN, MI.

VERACRUSE MURRAY AND CALZONE P.L.C., MI.

FEDERAL BUREAU OF INVESTIGATIONS

JUDGE E. THOMAS FITZGERALD CT. APP. MI

JUDGE HENRY WILLIAM SAAD CT. APP. MI

JUDGE JESSICA R. COOPER CT. APP. MI

DR. ROLLA BAKARI-PANZA, MI.

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RICHARD BERNSTEIN ESQ., MI.

BERNSTEIN LAW FIRM, MI.

DR. ELIAS MICHAELIDES, GA.

DR. NABIL WHEBE, MI.

DR. CHRISTINA LEPOUDRE, MI.

WXYZ CHANNEL 7, MI.

DR. DONALD ROCHEN, MI.

SHARON WOODSIDE ESQ., MI

PAUL SHOENBECK ESQ., MI

DR. WARREN BRANDES, MI

LARRY BUTLER, MI.

Defendant(S).

_________________________________/

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, Pastor Daniel L. Meier, complaining against the above

named defendant(s) states as follows:

NATURE OF THE ACTION

Plaintiff is an ordained Pastor, award winning author of the book

"Hell Makers and War Makers in America" sold at Barned and Noble,

Amazon, and world wide, has a legal certification (CLA), and graduated with

honors with degrees from Florida State University. All documents and filings in

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this case are being provided immediately to the United Nations (HRC) and will

be posted world wide on web sites due to previous and continuing malicious acts

to obstruct the guaranteed right to due process and harm the plaintiff by

retaliatory actions of the defendants. For example, case# 08-43959 the unlawful

attack by the Police on the plaintiff immediately after the initial filing of this similar

obstructed complaint in September of 2007 in which the plaintiff was nearly

killed when illegally and arbitrarily attacked, beaten, choked, tasered, and

imprisoned by the Southfield, MI Police; Illegal bond was set at 150,000.00 and

plaintiff was charged with 3 trumped up felonies all of which the jury found

not guilty. End of trial, the prosecutor yells at the jury, "but he 's suing the

FBI" showing true basis for the attack. Also, in conflict of interest, obstruction,

the D.C. jurisdiction failed to timely provide a case number and then transferred

the case back to Michigan although they had jurisdiction and the plaintiff drove

to Washington D.C. from Michigan personally to file it to prevent obstruction

and fraud upon the court. Then, Judge Robert H. Cleland, who is named in the suit,

illegally takes the case from the judge assigned to it and arbitrarily and illegally

dismisses it using the illegal detention as a pretext for failure to proceed in a

timely manner. Grand Jury indictments are also being looked into by other

concerned citizens and copies will be provided to members of clergy and other

Christian organizations being victimized by this wide spread persecution. Another

book is being written containing detailed accounts of these proceedings by a third

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party and there is also a press release. This time, the whole world can watch.

This is a civil/criminal action seeking compensatory, punitive, and

exemplary damages by the plaintiff alleging: conspiracy to overthrow the U.S.

government by violent means, civil war, domestic terrorism, attempted murder,

false imprisonment, kidnapping, abduction, extortion, grand theft, obstruction

of justice, fraud upon the court, abuse of process, defamation, assault and

battery, child endangerment, malpractice, color of law violations, conspiracy

to violate civil rights, public corruption, denial of due process rights,

intentional infliction of emotional distress, negligence, entrapment, invasion

of privacy, sexual harassment and discrimination, violations of the 4th, 7th,

8th, and 14th amendments to the U.S. Constitution, violation of the freedom

of information act, interference with business relationships, malicious

prosecution, religious persecution and victimization by the illegal FBI Cointelpro

program and any other claims that may be considered and included as a matter

of law based on the unrefuted facts. Other joinders will be added as litigation

proceeds and is deemed necessary. Every and all components required and

or supporting a claim of each claim stated herein are all stated to be included

somewhere in this complaint; where additional support is necessary, findings of

fact in discovery procedures and at jury trial will provide evidence for each claim

to be fully supported as a matter of law.

SUMMARY OF CLAIM

1. On April 18, 1997 the plaintiff and his ex- wife entered into a marital

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settlement agreement finalizing their divorce. This agreement was drafted by

the former wife's attorney counseling her and ratified on April 30, 1997 by

Judge Reynolds, witnessed and signed by four witnesses and was notarized.

(exhibit #1 and #2) There was also a guardian ad litem appointed by the court

on October 31, 1996 to whom the former wife confided she was considering

giving "sole custody" to the father long before the ratification.

2. The agreement included the plaintiff, father (Daniel Meier) being

awarded "sole parental responsibility" MSA p.4 and that all matters of

personal property were "settled determined in all respects" and for purposes

of their respective present and future property rights, claims, and demands

and obligations past, present and future were "finally and conclusively

settled" and determined by the agreement. MSA p.2. Pursuant to her

attorney's own hand notes, " Personal prop.-already divided-each keep

what they already have." (exhibit #3)

3. There was no restrictive covenants as to moving out of the state and

it was in the plans for years that moving to Michigan was in the works and

being prepared for even as the agreement was being drafted. The agreement

also included a separation and non interference clause where "each shall be

free of any interference, authority, and control whether direct or indirect by

the other party to the same extent as if they were unmarried". MSA p.3

4. Moving to Michigan was agreed upon by both parties, and due to

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the former wife's propensity to violence, the former wife agreed to try to make

things work as an unmarried couple in Michigan, where job prospects were

better for both the parents. There was never any question as to where the

destination in Michigan was and each had separate vehicles for the trip.

5. On the evening of April 30, 1997 after the agreement was ratified

by Judge George S. Reynolds and the father had "sole custody", the former

wife refused to go to Michigan. The truck was loaded and ready to move and

lease expired that day, they had to leave that night. The former wife could

have easily caught up to the father on the highway with her own car, the

truck moving at only 50 mph and pulling a trailer carrying a car.

6. Incidentally, the former wife having contact with the father on the

night of April 30 while he was loading the moving van was a violation of her

probation for domestic violence and contempt of court, establishing violations

of law on her part not the fathers. The additional fraudulent affidavits filed by

the former wife add to the violations of her probation. (exhibit #4)

7. The former wife never intended to go to Michigan and rather used the

situation to conspire with Marilyn K. Morris esq., local, and out of state law

enforcement and federal agencies to fabricate and file fraudulent grand theft

charges, kidnap the father and his child from Michigan, falsely imprison the

father in state and federal penitentiaries for a month and extradite the father

to Florida in leg chains and hand cuffs on a con-air flight with murders and

rapists to Florida, deny the father his due process rights, and extort tens of

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thousands of dollars form him in the process. This is a father who had never

committed any crime and had graduated Deans List from Florida State

University 19 months earlier.

8. The father had "sole custody" and was never informed, as required by

law, of any actions in violation of the agreement and did not do any actions

in violation of the Marital Settlement Agreement constituting a significant change

in circumstances and the father and the daughter were illegally denied their

constitutional, civil, and basic human rights. The former wife was also on

probation at the time for domestic violence and it was specified for the

father to kept free from additional illegal criminal acts of the former wife.

9. The parties fully binding original Marital Settlement Agreement

was illegally ignored constituting fraud upon the court and additional denial

of due process and constitutional rights. The fabricated charges were also a

suggestion by the Novi, MI. police department that the former wife's attorney

attempt to secure "some type of felony warrant... to avoid any problems

when we attempted the pick up of the child" (exhibit#5) demonstrating the

father had sole custody and the charges a pretext to abducting the child and

kidnapping the father without any legal basis, hence all charges were dropped.

(exhibit #6) Reports were fabricated by Sgt. Conquest, Sgt. Hundersmarck,

Sgt. Harvin June 12,1997 Novi Police Department. Others may be added as

fact finding progresses as there is also a federal number allocated to this

illegal chain of events. This demonstrates cooperation between state and

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federal agencies conspiring to commit the illegal acts and extradition. An

FBI number was also given to the case, demonstrating blatant illegal cooperation.

10. The fraudulent offense reporting forms, probable cause affidavit, sworn

complaint, ex parte order, cooperative prisoner transportation agreement and

order enforcing judgment to support this act were signed and processed

primarily by officer Terry Brown (501) with officer Duncan (728), Lt. West (152)

of Tallahassee Police Department and signed by his supervisor Phil Kiracofe

(244) and notarized by officer Hoover (743) and facilitated by Judge George S.

Reynolds, State attorney Willie Meggs, assistant attorney Dana Plummer the

former wife's attorney(s) Marilyn K. Morris, Tann H. Hunt, private investigator

Danny Johnson and signed by Judge Lewis and enforced by Judge Steven N.

Andrews Sixth Judicial Circuit, Oakland County Michigan. Copies were also

sent to Leon County Sheriff Larry Campbell and Sergeant Laurel J. Allie who

prepared the cooperative prisoner transportation agreement. All conspired to

commit fraud, kidnap, assault, abduct, extradite and falsely imprison an

innocent citizen(s) of the United States by committing intentional acts in

violation of federal and state laws, due process requirements and civil rights

guaranteed under the Constitution of the United States. (exhibit #7)

11. On June 17,1997 The Novi, police department arrived at the fathers

residence in Farmington Hills, Det. Lauria informed the father he was under

arrest, the father asked what it was all about he was told they were taking

his daughter. The father informed them that he had "sole custody" and could

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show them the papers and he was not notified of any modification hearing,

detective Lauria stated to the father that he no longer had custody and stated

to the father, "if you say anything more, I will rip your eyeball out and shove it

up your ass". As several officers came in to the apartment and handcuffed the

father in front of his daughter. Detective Lauria made this comment loudly in

front of the daughter and being four years old caused her extreme distress

persecuting the father without providing legal notice and arbitrarily denying

the father with the opportunity to legally respond at any hearing prior to

arrest and never informing the plaintiff of his rights and never confiscating

the items allegedly "stolen", items that the warrant was based upon or even

noting their location or searching for them in the residence.

12. The father's daughter was taken from him and the father transported

between several state county and federal institutions for a period of one

month while being restrained in handcuffs and leg chains on transport flights

extraditing the father by force to Florida illegally in an acts of pure corruption

and false imprisonment.

13. The criminal attorney for the father, Dave Moye', in an effort to

establish merits with the State Attorneys Office, failed to take all steps that

could have been taken in representing the father intentionally taking

excessive time and extorting money from the father and his parents and

denying proper legal representation and due process and shortly after,

taking an employment position with the State of Florida Attorney Generals

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office who he was defending against thereby clearly establishing, obstruction

of justice, extortion, malpractice, fraud and conflict of interest.

14. Although the charges of grand theft were thrown out, Mr. Moye had

communications later with other perspective attorneys for the father, coercing

them not to pursue the case any further and interfering with other potential

legitimate legal options in so further obstructing justice. The plaintiff was also

forced to pay monies for items never shown to be in the moving truck and

forced to pay court costs and the department of corrections in acts of pure

extortion even though all charges were nolle processed. (exhibit#8)

15. The family law attorney Mr. McNeely was also in contact with Mr. Moye

and also failed to provide adequate legal representation and also attempted to

charge the plaintiff for services not provided and never submitted a guidelines

sheet for child support at the request of Mr. Moye and the State Attorney

Willie Meggs and his assistant Dana H. Plummer. The plaintiff was required

to pay support beyond that of and inconsistent with the guidelines also a

basis for continuing acts of extortion of the father and fraud upon the court.

16. In direct violation of the original, legal and binding Marital Settlement

Agreement, signed and witnessed April 18, 1997 and ratified in open court

by a judge with attorney present April 30, 1997, the court Aug 6, 1998 under

Judge Kevin Davey handed down a new order, illegally throwing out the

entire prior agreement, forcing the father to pay child support and give up

sole custody of his daughter further establishing the intent to kidnap and

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imprison the daughter in Leon County and continue to use the governmental

positions in extortionist acts against the father. This demonstrates no matter

what the facts were, the father would never be provided a full and fair

opportunity to litigate there, any hearings after the kidnapping and abduction

were a fraud and a mockery simply to establish a conspired and preconceived

means to an end and deny civil, constitutional, and human rights. Although

there were minor concessions in a couple hearings they were intertwined

and overshadowed by adversity. (exhibit#9) Judge Davies stated, “There was nothing

you could have done that would have changed what we were going to do to you or

your daughter, so don’t fight it”. He said, “As long as Hillary is in office you will

never get her back”, referring to Hillary Clinton of course. It was a clear implication,

and plaintiff did find that the Clintons were very close with Lawton Chiles who was

the Democrat Governor at that time and Tallahassee does have a massive feminist

base and the grandmother is a radical feminist lesbian. That comment establishes

some calls were likely made and illegal favors done to support such a statement.

There must be a very strong connection if they are so arrogant that they would also

risk tampering with the 2000 presidential election, which is precisely what the State

Attorney Willie Meggs said he did, as you will soon read.

17. The family law attorney, Mr. McNeely, then sued the father for an

outrageous 30,000.00 more than the approx.10,000.00 already paid even though

he filed not a single appeal, or submitted any guidelines affidavits to the court.

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Then, he and attempted to have it brought before the same Judge Lewis that

was responsible for the original fraudulent Grand Theft Warrant the year before,

June 17, 1997. The suit was dropped due to father filing bankruptcy. (exhibit #10)

In addition, the Florida bar tried to cover up the extortion but then persecuted,

in retaliation in another case, an innocent attorney the same year for overcharging

clients for protecting a client from being extorted by the same people. Judge Davies

also told McNeely that he could illegally manipulate the case in the future, if he

did not collect what he wanted. It was all part of the scam to feed the attorneys

supporting corruption while persecuting good attorneys who attempt to protect their

clients from it by actually attempting to enforce the law and client rights. McNeely

allowed the ex wife to tell the court how much she wanted for child support,

regardless of the guidelines, and they, not surprisingly, gave it to her illegally.

In reality, Mr. McNeely never worked for the plaintiff, it was just a pretext for fraud

and extortion to accomplish an illegal preconceived means to an end.

18. There was, by the father, a motion for modification of child support

filed June 14, 1999 due to the excessive amount that restricted visitation. The

hearing was set for October 4, 1999 at 2:00 the department of revenue then

intervened and it was cancelled and reset for February 23, 2000, eight months

after the motion was filed. The recommended order was not provided until

April 26, 2000 more than two months later and did not represent what was

stated or ruled upon in the hearing.

19. The prior order, and at the hearing for modification filed by the

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father, there was never an income deduction order, arrearage amount, or

payments due during summer when the daughter was with her father. These

were conspired to by the Department of Revenue in violation of judicial and rules

of procedure to extort additional monies from the father in violation of guidelines

and intended to illegally and additionally restrict visitation and entrap the

father financially; again without due process of law in further acts of extortion

and fraud upon the court. They knew it would be impossible for plaintiff to care for

his child properly when he had no money because he was paying support while

having her for summer. It became so that plaintiff could not take his daughter

anywhere to have fun or even pay for day care. Every penny would be spent to pick

her up and bring her back. There was barely enough to buy food, it was illegal and

barbaric. The intent was to make her wonderful summers with her father become

a test for survival just to see each other. Judge Dawn Coloca-Johnson is a sick

filthy minded wicked woman who needs to go to jail and that is what a Grand

Jury can accomplish. The process has already begun, and any Judges or persons

who want to continue with similar illegal behavior as is in this complaint, can

easily be pulled into the indictment. There is plenty of time to monitor how

everything transpires so everyone can watch and everything can be seen.

20. When the father requested a copy of the tape of that hearing to review

and proceed with corrective action the father found that the tape had been

checked out by the hearing officer Dawn Coloca-Johnson and erased by

her in another blatant criminal act of obstruction of justice and fraud upon

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the court by the hearing officer and the Florida Department of Revenue to

circumvent the judicial system, in so committing yet another extortionist act

denying the father his due process rights and civil rights and further falsely

imprisoning the father in debt and with evil intent to further restrict contact

with his daughter when as a matter of law and fact, the father still had sole

custody because the later meritless arbitrary decision brought about through

a conspiracy to commit criminal and illegal acts is void, unenforceable and

holds no precedence as a matter of law. A decision cannot be held to be legal

if supported by illegal acts in violation of federal state and local laws and the

Constitution of the United States and is considered void.

21. The following month, and for the next two years, for harassment, there

were continued malicious hearings, every month , for contempt for non payment

of support even though the full amount (although extorted) was being paid

every month, these were being conducted by the Department of Revenue

in violation of procedure and without cause. May 24, 2000 a letter unjustly

was sent to the father notifying him that his license was being suspended.

Payments made were not removed from total due, income tax intercepts

were not posted, letters were sent to the father every month, and a

collection company (GC Services) was then sent after the father for amounts

already paid. Thousands were being extorted without verification or

recognition and letters sent as recently as January 23, 2006 (exhibit #11)

and more illegally in 2012 from the Florida Department of Revenue.

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22. The plaintiff's daughter was regularly and grossly neglected, frequently ill,

physically and mentally abused including a gash over the eye and numerous

bruises inflicted by the mother (witnessed by the grandmother), taken to

adult parties till very late hours on school nights causing black circles under

her eyes and ear infections that caused a split in the back of her ear down to

the cartilage also witnessed several times. The former wife repeatedly refused

to medicate the child or take her to the doctor and her clothes were frequently

filthy and the only new ones she would get would be from her father, her

teeth were not brushed and there would be so much plaque on them the

spaces would be filled flat and the father would have to chip it off in chunks

with dental tools. A video of the torn skin behind laurens ear from the mothers

neglect and abuse was provided to the court and ignored by judge Davies.

23. The grandmother, Ellen Hamilton is a neo witch (wiccan), lesbian,

and a psychologist a very dangerous combination for a young child, much

less a young girl to be around. She has the child help her out in her

"witches worm farm". The grandmother would send self made cards with

pictures of witches drawn by the grandmother to the child during the

summer when she was with her father to scare the child into doing what

they told her to do and stated that their "god" was "better than Jesus" because

they "took all the money" and the father lost everything. Her intent is to

make the child a lesbian and witch also. (exhibit #12 witch drawing)

24. The grandmother (Ellen Hamilton) has utilized brainwashing

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techniques to alienate the child from her father by stating repeatedly

"Lauren doesn't talk to daddy" and "daddy is bad" over and over to his

daughter and other methods to mentally and physically abuse the child

and has stated that the father "loves Jesus too much" as the reason. In

the interest of humanity as a whole, whatever licenses to practice Ellen

Hamilton holds should be immediately revoked.

25. December 28, 2000 the father was informed by his daughter, during

a visit, that the former wife and her sister (Amy Olk) had tried to take naked

pictures of his 7 year old daughter. The Father called the police and filed a

report that same night. The evidence was overwhelming and items were found

supporting the facts, including nude pictures of other people displayed to the

child to coerce her that it was okay and desensitize. One specific picture known

to have been shown to the child was a picture of Amy's friend "Michelle" naked

lying on her back with her legs spread displaying her virgina. Lauren stated it was

"gross", and that Amy wanted her to look at it and take one of the child while the

mother said, "it's okay". Father had no choice but to take action and met with State

Attorney Willie Meggs and inspectors Gandy and Goodwin February 16, 2001,

some of the same people responsible for the kidnapping and abduction, which

forced the child to be thrust into that sick, insane, situation with people who

didn't want her, except to coerce and pervert. Tallahassee Police Department

and Leon County Sheriff's Department conspired to cover up what had occurred

and cause further child endangerment, they being an accessory after the

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fact by refusing to take appropriate action. The Department of Children and

Families also conspired to cover up what had occurred by intentionally filing

fraudulent reports and endangering the child even more. At the hearing with

the Florida State Attorney, Willie Meggs, he stated he wasn't going to do

anything and he was "the only game in town "and "we do things differently

down here". Apparently, The Florida State Attorney Willie Meggs

considers his jurisdiction divisible from the rest of the country without

liberty and justice for all especially people from another state and or children.

(See exhibit #13 1.30 letter from Meggs/Goodwin, off rep. conflicting forms)

26. Although at the meeting the State Attorney, Chief Investigator and

Assistant State Attorney refused to properly uphold the law, they actually

apologized for doing what they did to the father (false imprisonment, abduction

kidnapping) in 97 and stated that if "we knew what you were like we wouldn't

have done it". "You want us to do for you what we did for her". But, the father

noted the difference is the father did nothing wrong or illegal. The statement

was also made "good for her if she can get away with doing something illegal".

Mr. Meggs, Mr. Gandy, and Mr. Goodwin display the kind of tyranny this

country was founded to be free from and is likely the reason why they were

all wearing guns at that meeting. Their statements alone are enough to

constitute relief from judgment and recovery of damages. (exhibit #14 letters

William M. Meggs State Attorney, Warren Goodwin the assistant State

Attorney, Al Gandy chief investigator) They also bragged about being responsible

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for the 2000 election ballot fraud and stated, "We did that".

27. The father, when arriving to visit his daughter in April 14, 2001, was

then physically attacked by the former wife and filed charges. Again,

Tallahassee police did not arrest, even with an admission of the attack from

the former wife. The report was again forwarded to the state attorney's office

because probable cause was established. Again, the State Attorney declined

to prosecute regardless of the fact these real charges were not like their

fraudulent charges in the past. The assault was an attempt at entrapment

initiated by the State Attorney and would not be the last because as

he stated they do things "differently" (illegally would be more accurate)

down there and the former wife stated she communicated with him

"personally" as recently as August 2007. There was also a group of people

waiting nearby, 4 or 5 in one car watching the incident. The plan was for

the plaintiff/father not to leave the scene and call the police from there,

where upon arrival the people in the car would say the father did the assault

and he would again be falsely arrested and imprisoned. Notice the issue

in the report that the father/plaintiff left to go file the report. (exhibit #15)

However, on the next trip they would try again at entrapment with another

beating, assault and battery on the plaintiff/father and his daughter, set up

by Willie Meggs, Leon County Sheriff Larry Campbell, former wife and

others in continuing acts of illegal agendas and in retaliation for contacting

other authorities about the child abuse and other incidents. Willie Meggs and

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Larry Campbell gave the ex wife permission and immunity from prosecution and

allowed her and others to attack the father in retaliation, repeatedly, initiating

an intentional small scale civil war. This is simply relaliation for being a good father.

28. October 18, 2001 the father again went to visit his daughter after

driving over 1000 miles was again denied visitation and this time again was

attacked in another and entrapment scheme. The school employees were instructed

by the defendants to invoke a physical confrontation with the father where he

and his daughter were actually physically attacked by employees Tonya Smith and

Mona Vonk and denied checking the child out of school for no reason. The

father had picked her up from that school several times prior to that visit

without any problems. Tanya Smith actually grabbed the father while just standing

there and outragously attempted to subdue him, absolutely insane. The father just

simply pulled away in shock and asked what they thought they were doing.

29. The Leon County Sheriffs Deputy by named John Meeks arrived and

attempted to persuade the employees that the father hit them back and he could

take the father to jail if they would "just say he did ". The deputy fabricated a no

trespassing warrant, contrary to the principal Johnson's wishes, and forced

the father by threat to let his daughter go when he had physical and legal

custody, again abducting her, defaming the father, traumatizing the child,

causing severe emotional distress to father and daughter and forcing the

father to "leave town" after threatening several times to put the father in jail

and refusing as before to press charges against those who committed illegal

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acts. Judge Kathleen Dekker also contributed to the abduction on October

18th 2001, similar to the 1997 incident of kidnapping and abduction also

involving Leon County Sheriff's Department by refusing to enforce any

visitation for the child on an emergency motion. (exhibit#16 Dekker refusing

to allow father to see daughter after 18 hour drive stating "this matter is over")

Well, apparently this matter is not over because she is now a defendant in being

an accessory to another illegal abduction and obstruction of justice.

30. Father sent a letter to Leon County Sheriff Larry Campbell, October

25, 2001, about the incident. The father also spoke with officer Meeks October

25, 2001 then later, October 25, 2001 spoke with Major Keith Daws who

stated," I don't care what happened" showing his malicious intent to obstruct

justice and proceeded to, under color of law, threaten the father further with

baseless arrest & harassment charges. (exhibit #17,10.25 e-letter to Campbell)

31. The father again wrote Sheriff Larry Campbell November 21,2001,

who then stated that instructions were given by him (exhibit#18 e-mail11.21

response from Sheriff Campbell to plaintiff). He then proceeded to continue

to harass the father with threats of charges and arrest, just as the other Leon

County officers who abducted the fathers daughter did just 4 weeks before,

clearly establishing a deeply rooted chain of command for the numerous

premeditated acts of fraud, abduction, harassment, intentional infliction of

emotional distress, entrapment, and assault and battery on father and child

and more on a continuing basis.

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32. Letters were sent to Governor Bush January 15, 2002 in regards to

the corrupt acts and cover ups. The same day the father also sent another

letter to Sheriff Campbell, again, in regards to another incident this time by

Leon County Officer Allie and the Tallahassee Police Department refusing

to enforce a court order to enforce visitation and denying the father the right

to see his daughter for Christmas even though written notice was provided

weeks ahead of time, December 8, 2001 to Judge Dekker, clerk of court,

and former wife. (exhibit #19 letter to Gov. Jeb Bush, Sheriff Campbell)

33. The father filed complaints with the Florida bar in regards to hearing

officer Johnson November 4, 2001 in regards to their intentional acts,

February 1, 2002 the hearing officer recused herself, notice the department

of revenue (Pricilla Quionnes) is continuing their involvement and are listed

as petitioners with the former wife. (exhibit #20 Fl bar complaint, Johnson

recusal)

34. On February 7, 2002 the father received a letter from the Florida

Department of Law Enforcement Commissioner, James Moore, in reference

to the child abuse case being forwarded to Chief Inspector General for

Department of Children and Families. The FDLE request was originally sent

from the Executive Office of the Governor. The Inspector General for

Department of Children and Families the refused to address the issues and

sent a letter further denying to follow through with a proper investigation on

February 26, 2002 with attachments. The father sent a responsive letter

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March 15, 2002 detailing the inadequacy of review. March 25, 2002 Mr.

Betta sent back another frivolous response. Father responded with yet more

specific detail April 7, 2002 expressing his dissatisfaction with the

carelessness which Mr. Betta was displaying in regards to the case. Mr. Betta

again sent a denial to properly investigate on April 18,2002. (exhibits for

#21 correspondence, FDLE, Betta and plaintiff)

35. The plaintiff later found that the former wife's boyfriend, Will, worked

at the Department of Children and Family and assisted in blocking any

investigations. This perverted boyfriend, Will, would also frequently walk in on

Lauren when she was taking a shower and stare at her; terrorizing the child.

36. On March 8, 2002 the father also filed a complaint against Judge

Dekker with the judicial qualifications commission due to the outrageous

actions and denial of the father's visitation rights. (exhibit #22)

37. On March 26, 2002 the father was found, by hearing officer Williams,

to be in compliance with the support order , the same order which had been

on continuance for repeated hearings by Judge Dekker and Hearing officer

Johnson purely for harassment purposes nearly every month for the two

years prior the same one in which Paul Shapiro esq. neglected his duty to

represent . April 29, 2002 hearing officer had to restate to Office of Attorney

General that the father was in compliance when Attorney General again

attempted to continue hearings purely for harassment, and the arrearage

is to extort payments already made and not posted which continues to

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to this day by D.O.R.( exhibit #23 letters 3.26, 4.29 on compliance)

38. When denied hearings, the Department of Revenue rather than

filing a new motion (because there would be no basis), illegally proceeded to

send more threatening letters August 28,2002 even after they had been

specifically instructed the father was in compliance, instead they fabricated

additional amounts to extort from the father without evidence. Even with the

father in full compliance the Department of Revenue was in contact with

Detroit Diesel Corporation, where the father was employed at the time, and

used those contacts to further their objectives. Additionally the Attorney

General utilized all female assistant attorneys Joy Aukema, Dana Plummer,

Pricilla Quionnes, Denise Johnson, intentionally as a form of sexual

harassment and discrimination.

39. This was an opportunity for the plaintiff's supervisor Bob Green,

also involved in illegal acts, to use the Florida circumstances as an excuse

to support his own mob mentality acts of terrorism. Out of the blue the

comment was even made by Ed Crawford (a director) "so we hear you're

having problems with your ex-wife". The federal government provided Bob

Green with access to agents and stated to Mr. Green he could do anything

he wanted to do the plaintiff, short of hitting the plaintiff. Mr. Green stated

he was considered an "officer" and used homeland security to label the

plaintiff a "terrorist" and using agents to further their corrupt, illegal plans.

40. To verify the fact that Mr. Green had access to agents, the plaintiff

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informed Mr. Green that he runs at a track but did not say which one and

that the plaintiff was pretty fast for his age. The next day a young man shows

up at the Stevenson track, after the plaintiff had done several laps, he stops

ahead of the plaintiff on the track and when the plaintiff gets just behind

him sprints in front of the plaintiff in an all out run racing the plaintiff. The

plaintiff stays on his left shoulder just behind him making sure not to pass.

The young man then immediately leaves after the 1/4 track run. This was

prior to the plaintiff's nerve problems. This never happened before.

41. The very next day when the plaintiff arrived at work Mr. Green

stated, first thing in the morning, "your not so fast". plaintiff explained

he was holding back to that person on the track and that next time the

plaintiff would give him 1/2 track head start and would pass him within

precisely 4 laps. Two days later the plaintiff is at a different track (the

Holmes track) several miles away and the same young man shows up;

plaintiff gives him 1/2 track and begins to run. He runs all out for

precisely 4 laps then stops exhausted with the plaintiff still behind, but

only less than a quarter of the track. The obscurity of the rules, different

track location, same suspect, and precise time, establish correlation

and causation with intimate communication on specifics and tracking

of plaintiff's location to offensively invade the plaintiff's privacy by

Homeland Security and others at a time reserved for private freedoms

and liberties.

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42. Later when the plaintiff had an injury and nervous system disorders

and was home on vacation time for rest. Mr. Green and DDC hired a private

investigator to harass the plaintiff and park his van in front of the plaintiff's

house for 3 days to prevent any rest and recovery the plaintiff may be

provided on his vacation time. (exhibit#24 investigator van staking out

plaintiffs house hired by DDC verified by FBI and Southfield police).

43. The Detroit Diesel legal department had contact with Florida

authorities and having knowledge of the family law case back ground felt

that they could get away with doing most anything employment related.

Knowing the federal government was involved in imprisoning the father

for no reason, there was no limit to what they felt they could get away

with. They used these contacts along with the FBI and Homeland security

to conspire and continue their efforts with the Florida authorities to

corruptly use law enforcement, judicial system, and federal agencies in

furtherance and continuance of illegal acts against the plaintiff. Detroit

Diesel counsel, Josh Yaker, even threatened the plaintiff that he would

not get Bob Green to "back off" and that it would be "difficult to get your

work done" in retaliation after the plaintiff filed suit. (exhibit # 25

unrefuted timeline and evidence first DDC case in support of plaintiff's

2.116 ( C ) (10) motion, won as a matter of law by plaintiff). The Job at

Detroit Diesel was expected by Judge Davies and he stated that plaintiff

would get a job there and do okay but the ex wife would get the child after

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the kidnapping. So clearly there is a relationship between certain

corporations (especially with government contracts) and the Government

to provide employment in certain circumstances. Judge Davies even told

plaintiff what employment agency to go through to get it.

44. In October of 2000 Daimler Chrysler purchased Detroit Diesel,

during the transition period the plaintiff played a very pivotal role

in the integration of the financial systems between the two companies

and developed a program with EDS "EO task entry system" which saved

the company millions of dollars, the plaintiff gave presentations in the

auditorium in front of the company to introduce the new program with

the logic he developed and program he supervised and developed with

with the assistance of EDS software engineers.

45. As an administrative tool and complement to the program, the

plaintiff created and programmed and developed himself the "automated

upload system" which provided data uploads for the program monthly and

allowed quick and seamless mass data transfer from specialized spreadsheets

and allowed for quick resolution and correction of errors.

46. For the integration the plaintiff was responsible for creating the

massive spreadsheet that linked the like accounting functions with foreign

functions to allow interactions and data loads into systems to maintain

financial reporting across national accounting barriers to feed the operations

of the financial reporting and controlling groups.

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47. The plaintiff's systems were extremely successful and implemented

corporate wide and the plaintiffs supervisor Mr. Green was transferred to

another department because of his failure to properly implement a system

that he purchased earlier to do the same thing which failed miserably and

as a result cost the company millions of dollars.

48. Before the acquisition of DDC by DCX, DDC was plagued by poor

management. Regardless of the need to help the company's to function,

many in management and lower level positions, rather than supporting

the integration, were moving to sabotage most anything they were given

to hamper the company success as a whole and the Germans. This seemed

irrational to some because the ultimate outcome would be negative for

everyone. Some would call those who did a decent job "traitors" and began

causing problems with their work. The plaintiff was the focus of some of

this, but at the time didn't see a reason.

49. Naturally, the ones who didn't care about their work chose to begin

to sabotage the work of others including the plaintiff's. The plaintiff wasn't

aware of any actual "war "and the term war was never elaborated upon until

years later. Initially, it appeared at most like a takeover "war" complicated

by foolishness and careless attitudes on the DDC side.

50. As the plaintiff's work (spreadsheets, data loads) were being

continually tampered with the plaintiff had one of several meetings with

one of the directors, Edward Crawford. At this meeting in 2000 Crawford

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stated that "this is a war" but still did not specify what it meant. plaintiff

told him that they own the company and we have to do the work.

Crawford later stated to the plaintiff that "everyone will be against you",

this turned out to be a much broader statement than originally taken

and it sounded crazy to the plaintiff none the less. Mr. Crawford was

also known for being one of the primary factors in the huge turnover

the company had even prior to the takeover. Up to this point, the

plaintiff had not seen any reason to suspect the Daimler people of

anything other than making the company productive once again.

51. The plaintiff ,while working out in the attached gym, spoke with

one of the young managers whose father also had worked for Detroit Diesel.

While working out he informed the plaintiff that being a manager or

a director for that matter in Detroit Diesel was not an impressive feat

there were many who were incompetent and that was the reason for most

of the problems in the first place and now again. He found that many were

promoted just because they stayed there a long enough time. He was

known for being a good manager. He, shortly thereafter, left to go to

another company to the surprise of many (not the plaintiff). There was

another manager who was held back, because he was brilliant, he was

there nearly 12 years and was not even a director. He later got an

engineering award of the year, left the company and went right into

being a Vice President of engineering at Ford and then to even more

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later at GM. Detroit Diesel is known for poor decision making.

52. Later, when there was poor management and widespread discontent

due to the behavior of the Daimler people, the plaintiff became concerned

and voiced his concerns and was told that there is a saying in German

that goes something to the effect "either your with us or we will take your

head off". The plaintiff considered leaving but that was not an option,

DDC was denying a positive reference and blacklisting the plaintiff and

getting vested for the pension disbursement was not that far off. As

mentioned Homeland Security and others were doing their own illegal

acts to interfere with and eliminate any and all options, just as is the

case at the present time, it would have to be addressed in court.

53. After the plaintiff expressed his concern over the circumstances

the Daimler people put Mr. Green back in position over the plaintiff. This

is when Mr. Green took advantage of the situation to seek vengeance against

the plaintiff for the implementation of his successful program and prior

dismissal and transfer of Mr. Green due to his incompetence.

54. There was also a man by the name of Gary Paja who it

was stated was having "problems" with the Germans. The plaintiff was told

by John Eriksen that "they found out he was Jewish" Mr. Paja then began

to have the plaintiff's supervisor force his work onto the plaintiff, just after

the Germans stated to the "war" was going to be against the plaintiff.

They then had dozens of Jewish people come into the department, after

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that comment, wearing their signature apparel and Gary Paja's wife Pat,

who also worked at Detroit Diesel, who the plaintiff saw infrequently

began to show up every day while the plaintiff was walking down the

hall and she would lock an angry stare directly at the plaintiff several

seconds every time passing by. Clearly religious harassment.

55. From the time the plaintiff filed his original DDC lawsuit and was

frequenting the law library in Pontiac, MI there was a Jewish man wearing

a yamaca who would show up nearly every day after the plaintiff would

arrive and make sure to walk in front of the plaintiff regardless of the

time of plaintiff's arrival, when the plaintiff began attending another law

library in Farmington MI 30 miles from the one in Pontiac but closer to

the plaintiff's house, that same man would show up, adding another

facet to the campaign of harassment by the defendants.

56. Mr. Green would speak to Gary Paja in the hall speaking quietly

and when the plaintiff would walk by they would both stare at the plaintiff

at the same time and cease talking. The plaintiff never had any issues

with Gary Paja personally and worked well with him on many occasions

demonstrating this was clearly agenda driven component of the "everyone

will be against you" comment by Ed Crawford, since the plaintiff used to

work at a Jewish Community Center and bias was not an issue. Mr. Green

also made the comment that "we're all fighting terrorists" to another

employee while turning to look at the plaintiff. The plaintiff considered these

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comments to be a sign of Mr. Greens mental illness and perversion.

57. The Daimler people had an agenda, and took issue with some people

and offended many others. The plaintiff had no knowledge of their intentions,

but after voicing concern over some of their actions, it was communicated by

Walter Puetz to DDC management, some of the actions they took was a favor

or suggested by the plaintiff and this was to take the load off them and make

good on their threats to make the war so it was against the plaintiff and

demonstrate their intent. They also knew about the Florida case and

interpreted taking adverse action and blaming the plaintiff would make them

seem as though they were with everyone else. The perceptive people knew

that the same thing was happening at Chrysler and the plaintiff didn't work

over there. There was no employment options then as there is none now

based on continuing acts of the defendants.

58. Mr. Green's focus now, supported by the Daimler people and others,

was vengeance with malicious purposeful intent to destroy the plaintiff's

health, financial situation, future job prospects, interfere with visits

the plaintiff had with his daughter, inaccurate unfair and continually

reduced evaluations (devoid of detail), physical and verbal threats, reduced

and ultimately eliminated pay raises with no basis, sexual harassment and

discrimination, a fraudulent performance improvement program (to

harass), and eventually a retaliatory discharge within 2 weeks of the

plaintiff filing his original law suit when the evaluation period was not over.

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59. During the period when Mr. Green was again in position over the

plaintiff, the plaintiff was also the focus of lewd, perverted and ever more

obscene behavior and touching by Mr. Green to sexually harass the plaintiff.

60. The defendant also had contact with Homeland Security, FBI,

Banks, retail establishments, neighbors, employment agencies. There were

additional comments about the plaintiff's marital status, having to "leave the

country to get a job", having to "kill your parents" or "rob a bank' to have

enough money to see daughter again, stating "nothing is going to be easy"

Daimler people stating the "war will be against you". There was also contact

by defendants with doctors who were treating the plaintiff and the comment

by Bob Babridge that he plaintiff would be "getting it from both sides". It

must be noted that Bob green is a very bizarre individual and extremely disturbed.

61. The plaintiff had a meeting with Dave Kotel of the FBI on November

6, 2006 about the situations and what happened at DDC and what was

occurring with others and the day after the meeting there were additional

people following the plaintiff and taking pictures of him in the evening with

a flash, other cars following the plaintiff, the plaintiff's cell phone was

accessed and family members were contacted. Mr. Kotel stated that he would

only use the phone numbers the plaintiff gave him if he could not get in contact

with the plaintiff and needed to get a hold of him for some reason. However,

Kotel used them to harass and call the plaintiffs parents.

62. The defendants utilized their connections in the FBI and Homeland

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Security to contact people in the neighborhood and interfere with business

relationships and contact doctors and others with knowledge of the plaintiff's

suseptability to mistreat, poison, or refuse treatment of the plaintiff to

bring about continued illness and death to the plaintiff. There were also

people directed by Homeland Security to interfere with the plaintiff's most

recent filing of a federal lawsuit against Mr. Green in which the plaintiff's

sworn documents were removed from the copy machine when he turned

his back and files erased from his flash drive by a lady wearing all black

who sat at the plaintiffs computer. Both occurred while at the Farmington

library on March 30, 2007. Both women left before their deeds were fully

recognized. The documents were actually mailed back, more than a month

later with no letter, of course the files deleted the same day were still gone.

(exhibit #26 envelope postmarked May 10, 2007 with stolen items)

63. Since 1997, the federal government is violating the plaintiff's rights

continually, Mr. Kotel even asked for phone numbers of friends or contacts

plaintiff may stay with if things "got worse" then called parents and slandered

the plaintiff in an attempt to prevent them from helping if the need arises.

Additionally, Mr. Kotel tells plaintiff to see a psychologist because what the

plaintiff thinks he is seeing is "not really happening", a jury trial will provide

a cure for that problem. The following day the plaintiff was followed and

had flash pictures taken of him, while running in the evening, by two young

men wearing black hooded sweaters, was followed by a red Durango, had

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a comment made by a store clerk that "it shouldn't be that hard to drive him

crazy". All initiated by the FBI and Homeland security and others to harm

the plaintiff. Mr. Kotel also requested the name of the federal judge

overseeing that case to contact the courthouse and further interfere with

the plaintiff's Constitutional rights.

64. The plaintiff filed freedom of information act requests in regards

to the Kotel incidents and earlier matters involving the federal government

and was denied any records pertaining to the case and the administrative

appeal was later not responded to in the allotted time frame as required

by law.

65. The FBI, Homeland Security, DDC, Florida State Attorney and

other defendants to this day are continually moving to violate the plaintiff's

civil rights and deny the plaintiff any mode of survival in making a living.

The only reason is blatant terrorist mentality and corruption in violation

of basic Constitutional and human rights and conspiring to overthrow the

United States government by utilizing hostile acts as a means to further

their illegal interests and agendas.

66. The plaintiff has filed a series of lawsuits, the first in Sept. 21, 2005

against DDC where the plaintiff was denied his due process rights although

he won as a matter of law, court of appeals affirmed in violation of rights,

leave to appeal to Michigan Supreme court was denied. plaintiff filed first

suit against Mr.Green in July 2006. plaintiff was again denied his due

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process and constitutional rights and appeal of right by lack of service of

final order and violations by defendants counsel. Third suit was again

against DDC filed in Lansing (capitol) and was forwarded to wrong district

(western) and was thrown out for lack of jurisdiction. Plaintiff filed his second

suit against his supervisor in federal court in eastern district of Michigan and

was again illegally denied his due process rights when judge and defendant's

attorney conspired to illegal sanctions and block a legitimate federal action

consistent with prior federal denial of rights with the Florida State Attorney

and other defendants, the supervisor outrage case was on appeal.

STATEMENT OF JURISDICTION

67. This complaint is jurisdictional as it contains complaints covered

under federal labor laws, statutes, denial of civil rights, diversity of citizenship

and rights guaranteed under the U.S. Constitution and issues of National

Security. Damages are in excess of 75,000.00, there is also federal jurisdiction

to review the sufficiency of state procedures for which the court may

mandamus the lower court for duties. The plaintiff was denied his right to

jury trial(s) and due process rights under the 7th and 14th amendments to

the Constitution respectively, harassed in violation of title VII of the Civil

Rights Act of 1964, and denied information in violation of the Freedom of

Information act.

VENUE

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68. Venue is proper in this action in that all times relevant to this action

the plaintiff worked in Michigan or Florida , and other circumstances related

to defendants herein transpired in the Continental United States.

Plaintiff is a resident of the state of Michigan

The suit is being filed in the United States District Court in

the District of Columbia due to intentional illegal obstruction in Michigan and

Florida by Federal Judge Cleland who was named in the suit and Florida

State Attorney Willie Meggs also named in the suit.

FIRST COUNTCONSPIRACY TO OVERTHROW THE U.S.

GOVERNMENT THROUGH VIOLENT MEANS

69. All paragraphs are realleged and reaffirmed as if set forth herein.

70. Many of the defendants involved in this complaint are employed by

state, federal and county agencies. There have been numerous illegal violent

acts to manipulate the operations of agencies against the citizens of the

United States and in violation of the principles and doctrines they were

founded under. These corporal acts of kidnapping, assault, false imprisonment

and violations of due process, obstruction of justice, extortion and others are

nothing less than acts of civil war on the plaintiff and citizens of the United

States and a conspiracy to overthrow the government by violent means and

restrict or eliminate the civil rights, freedom and liberties of it's citizens.

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71. After the kidnapping, abduction and other crimes the plaintiff was

forced to return items to the former wife's residence where a friend of the

family by the name of Dick Morrow was present and stated "they used to

call us Commie pinky fagots "this was to present the beliefs of some

committing the prior and continuing illegal acts . These statements

are consistent with the Florida State Attorney, Willie Meggs, comments that

"we do things differently down here" in regards to the fraudulent charges

and the mass of illegal and violent acts continuing to this day supported

by Homeland security, DDC (Detroit Diesel Corporation), FBI and others.

SECOND COUNT

DOMESTIC TERRORISM

72. All paragraphs are realleged and reaffirmed as if set forth herein.

73. The FBI and Homeland Security initiated contact with friends and

family under false pretences, and in a continuation used a meeting with FBI

investigator Dave Kotel to further the campaign of harassment on plaintiff and

have additional contact with neighbors, friends, and parents. There was contact

with automotive facilities which the plaintiff was doing business with and on

several occasions instructed those facilities to intentionally damage to the

plaintiff's items or to do poor workmanship which would cause the plaintiff to

repeatedly return to have the work done properly, in so destroying productivity

parts, and or vehicles in the process and causing extreme and repeated

emotional distress intending to cause illness to the plaintiff. The following

is a list if companies who through their representatives displayed like behavior

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intentionally and repeatedly ruining materials and or items belonging to the

plaintiff or his company or other adverse actions. Bob Green at DDC would

ask the plaintiff where work was being done and then the service provider

would be contacted shortly thereafter in regards to the plaintiff and what

steps to take by Homeland Security or other federal agents utilizing color

of law to impose their will in with and create public corruption in violation

of law. Reference Wikipedia: FBI Cointelpro program

Activities:

Gales Body shop: ruined paint job, repaint contaminatedwith dirt particles, car outside without paint large areas bare with no paint,told how to rub out the dirt which wasin paint when done second time Mr.Green comment ruining paintexcessive time to do work

request plaintiff to bring back again

and again after damage

D&S engine specialists: Ruine gas tank, strange "not afraid of you" statement never properly rebuild engine after paid for full rebuild, ruined engine, harass, engine knock, admit ruining alternator, intentionally hide other problems, wrong push rods(exhibit#27 letters) Mr. Green Comment

excessive time to do work

request plaintiff to bring back again

and again after damage

Chuck's engines: German receipt in bag, return several times repeated improper machining, sign of "united we stand" posted on front of building only after improper work doneexcessive time to do work

request plaintiff to bring back again

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and again after damage

Murray's Discount auto store: Ruine brake rotor, admitting thenrefusing to give after ordered, cops in parking lot follow around, harass, provoke discontent, calls someone before finally giving items, tries to get plaintiff take parts and run (exhibit#28 pictures parts on table, manager call before giving parts,livonia cops following in parking lot)excessive time to do work

offer to come back again after damage

Livernois Motorsports: increase price then destroy cylinder head surface then try to make pay for new cylinder heads, misleading BBB, failure to do procedures, harass, BBBrecommended not to do business with them (exhibit #29 BBB correspondence)excessive time to do work

request plaintiff to bring back again

and again after damage

Olson Kawasaki: keep motorcycle and never repairthen damage to gas tank, ruined paintjob failure to do any repair correctlyexcessive time to do work

request plaintiff to bring back again

and again after damage

E-bay e-mails, blocking corvette salesblocking e-mails, harassmentnot posting all pictures changingprimary picture, DCX unrelated emails (dozens) immediately after auction, interfere with sale not forwarding offers to buyers (exhibit# 30 DODGE (DDC) e-mails all at once after auction close)

Midwest auto auction damage corvette, force hood out of alignment, chunk of paint out of drivers door of new paint job, credits to come in

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again admit damage, offer pay to repair then deny, offer to bring back in againafter damage (exhibit#31 corvette door damage, vouchers to come back )

Budget Rent-A-Car steal items from car, lease badlydamaged truck to plaintiff andattempt to charge plaintiff for priordamage, Mr. Green comment about

budget will stick it to you before acts(exhibit#32 attempts to charge)

*Fact finding will assist in determining correlation or causationalleging a connection due to repeated far out of ordinary actsand statements supporting Textbook use of the illegal Cointelproprogram by the FBI's Toni Charbot and Dave Kotel as wellas Homeland Security (another name for Cointelpro). Contact was admitted by the FBI and parents, plain and simple.

ENCYCLOPEDIA COINTELPRO DEFINITION

Cointelpro or (Counter intelligence Program) is a series of covertand often illegal projects conducted by the FBI. They targeted studentdemonstrators, Islam, antiwar community, Christian leadershipconference, (PETA) People for the ethical treatment of animals (whooppose the kosher slaughter of cows) and they put people fromGreenpeace on a terrorist watch list. The inspector General found2001-2006 “troubling” FBI practices consistent with the ChurchSenate Committee. The FBI would discredit, disrupt, undermine trust,plant false media stories, make anonymous phone calls, spreadmisinformation,create pseudo movement groups, manipulate or strong

arm parents, employers, landlords, school officials and others to causetrouble. The FBI conspires with police and abuses the legal system toharass, make people appear to be criminals, police officers would giveperjured testimony, fabricate evidence to use as a pretext for falsearrests, wrongful imprisonment, and use conspicuous surveillance tointimidate. They use local police departments to threaten, conductillegal break-ins, commit vandalism, assaults, beatings, andassassinations. Their declared purpose for illegal acts was ”nationalsecurity” even from 1956-1976. They use unsavory and vicious tacticsto break up marriages, disrupt meetings, and ostracize persons fromtheir profession. Sound familiar? The committee concluded that“Government officials, including those whose principal duty is toenforce the law, have violated or ignored the law over long periods of

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time and have advocated and defended their right to break the law”.They investigated people for “factually weak” reasons and withoutadequate basis”. They use secret informants and other intrusivetechniques and a myriad of other “dirty tricks” to undermine people

with no just cause. Wikipedia encyclopedia FBI search Cointelpro

74. Certain behaviors are consistent with most situations cordial

beginning followed by promises not kept, followed by overcharging and or

damage, promises to correct problem and to keep calling back, followed

complete denial to do anything or job never done correctly and taking

excessive time or requirement to keep coming back only to do more

and more damage or take even more time. The "united we stand" sign posted

in front of Chuck's, only after damage, takes on a dubious theme in this context.

Although things like this may happen on an infrequent basis from time to

time, there was and extreme increase in repeated acts far out of the norm.

75. Additionally there were contacts with employment agencies to

prevent the plaintiff from ever gaining meaningful employment after

leaving DDC. The temp agency acts support the all inclusive intent on the

part of the defendants. Remember, Judge Davies oddly told the Plaintiff what

agencies to use in the first place, so there is an admitted connection here.

Dixon Allen: Do things to "forge relationship"with DDC. DDC calls plaintiff "high roller" after meeting

Accountants Connection: Call plaintiff at work ask how things are going, send items to plaintiffout of the blue admits DDC contact

76. City services and utilities and their employees also were used as a

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tool to harass the plaintiff and intentionally damage or deface private

property, trespass, extort money, and or not provide service. Notice

City of Southfield admission of being instructed by the "Feds" for

acts purely consistent with Cointelpro without question.

Water and Sewer Department: Extort money from plaintiff by applyingto taxes the small amount due and large100.00 service fee amount after call to resolve (exhibit#33 intent to lien)

Waste Management: Dumping trash on lawn day of Stephens hearing, later refusing to pick up likeothers on the same street (exhibit#34trash on lawn and neighbors cans placed in front to obstruct driveway)

City of Southfield: Trespassing on property and cutting offlarge tree limb causing no interference with any city interest, no prior notice, giving chips to neighbor to humiliate while tearing up lawn. No trespassing sign in clear view this was after comment a few days before that plaintiff likes to maintain his lawn. (exhibit #35 tree cut, torn up lawn, give chips from tree to neighbor) flags only pretext to do damage. Employee stated: "If the feds say so you have to do it"

Detroit Edison: Accelerate payments on utilities whenno plan was requested, intentional non posting, service worker stated she had never seen that before, plaintiff had 3rd party intervene twice.(exhibit#36 billsand shutoff notice after full payment)

Sprint: Tampering with cell phone information

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gathering private information through phone access illegally day after FBI Kotelmeeting invading privacy and harassing

U.S. postal service Tampering with mail box, moving mail box without any notification, failure to deliverrepeatedly and continually to harass.

77. Although the Germans at Detroit diesel did do many things,

the defendants utilized props (see Cointelpro) and circumstances to make it

seem as though the German's were doing what was done by Homeland Security

and FBI.

Raced up to while on foot or day after FBI meeting with tailgated by German cars: Kotel complaint, BMW drive

up dangerously fast right in front of plaintiff while walking across street

German receipts in plastic bag: Chuck's Engines

4 Black German cars together cars together in bizarre semi circle in road aimed towards house same time: in violation of parking laws

78. Additionally, one of the main focuses is to make the plaintiff appear

as if he is in conflict with women in general, purely due to the opportunity

to focus on the perspectives, views or situations the plaintiff had with his

ex-wife and magnify any divisions to constitute and all inclusive, untrue and

defamatory position. This objective was made clear when Director Ed

Crawford stated that "everybody will be against you" after declaring "So we

hear you're having problems with your ex-wife " The fact that an intent

like that would even enter the mind of an anti- American fraud like Ed

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Crawford is in violation of the constitution and laws of this country and is a

criminal act. This tyrannical, terrorist, agenda is a menace to all who value

their freedom in this country and violates and threatens our unity under

freedom and liberty with justice for all citizens, without discrimination. Even

more obscure is the comment from Larry Butler at DDC stating that they

know that the ex-wife doesn't want plaintiff to see his daughter anymore. He

said, "We know your ex- wife doesn’t want you to see Lauren anymore".

Again, consistent with Cointelpro breaking up families and contacting employers.

79. This presents an issue of the defendants to defame the plaintiff

before all people with the assistance of Homeland Security, FBI and State

and local authorities in Florida and Michigan. There is simply no basis

for any of their positions and it constitutes evidence of criminal acts and

political imprisonment. Since what the defendants are doing is not supported

by any statute, law, or regulation, it is patently illegal and unconstitutional.

80. After the comments at Detroit Diesel about the ex-wife there was a

concerted effort to have women, specifically, harass and create problems for

the plaintiff by Detroit Diesel and have female agents for Homeland Security

do some of the initial personal contacts and continuing communications with

other women the plaintiff may be in contact with on a business or personal

basis outside the company and continues to this very day. This effort is

also to ruin, prevent, or interfere any relationship the plaintiff will attempt

to develop in the future whether personal or professional. There were never

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any problems to this particular issue until after those specific comments,

it must be noted there is no guess work needed, Detroit Diesel and the FBI

made specific statements and dire predictions regarding these events and the

relationship of their contacts and the connections to marital or family status

to establish the correlation and causation. Additionally, FBI investigator Dave Kotel

stated to the plaintiff that they have FBI agents and contacts at Detroit Diesel.

81. Certain financial institutions provided confidential information to

the defendants in relation to private bank transactions in violation of federal

privacy laws:

Comerica Bank: Provided detailed informationabout specific transactions andlocations, dates, times.

Chase/Bank One: Provided detailed informationabout specific transactions andlocations, dates, times.

82. Except as for being a Christian, doing his job, or having a divorce

there has been no specific mention as to why these actions are, other than

a purely political and corrupt agenda originally simply to show that Florida

has power over and beyond the law. The former mother in law has made the

statement the father "loves Jesus too much", her group stated they were

"Communist", and the State Attorney's office and Willie Meggs stated he

was the "only game in town" and "good for her if she can get away with

breaking the law" and "we do things differently down here". Clearly the FBI

has issued discriminatory tactics against Christians, as Cointelpro targeted the

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Christian leadership conference and the plaintiff is a Pastor. Apparently, they

also use corrupt and disruptive individuals to undermine the Christian church

by inserting false leaders and corrupt immoral Pastors to distract and manipulate

people. Larry Butler would be one of them, by giving false testamony under oath

and seeking to corrupt Christianity, the plaintiff's daughter, and other young

girls. As the book "The End of America", by my fellow author Naomi Wolf explains,

it is American Patriots like us who are being arbitrarily targeted in this country,

not criminals, because the system is so deprave.

83. That kind of corrupt influence is used to coerce others in separate

jurisdictions and is precisely why the instant case is absolutely necessary

and imparitive and in the advent of 9.11, Homeland Security has added

another greater tool for public corruption ripe for the picking for those with

ulterior motives and terrorist agendas. These and other actions constitute

a serial abuse of government resources to commit illegal acts.

THIRD COUNT

FRAUD UPON THE COURT

84. All paragraphs are realleged and reaffirmed as if set forth herein.

85. Beginning in 1997 and to the present day Tallahassee Police,

Leon County Sheriff, Tann Hunt, Marilyn Morris, Mandy Luttenton, Ellen

Hamilton, Paul Shapiro, Florida Department of Children and Families

(Guiseppe A. Betta Inspector General), Florida Department of Revenue hearing

officer Dawn Coloca-Johson, Judge Kathleen Dekker, Judge George S.

Reynolds, Judge P. Kevin Davey, Warren Goodwin (assistant state attorney),

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Willie Meggs (Florida State Attorney ), Al Gandy (chief inspector State

Attorney's office), Charles McClure, Bill Altman, Judge Robert H. Cleland, and

others committed fraud upon the court including fraudulent sworn affidavits

fraudulent theft reports, including one of the plaintiff stealing his (own car)

supposedly witnessed by Ellen Hamilton, destroying court documents,

violating guidelines to extort money, conflict of interest, fraudulent

misrepresentation of facts, denial of due process rights, mock hearings, denial

of right to be served, extraditing under false pretences, child abuse, child

endangerment, kidnapping, abduction, assault, battery, false imprisonment,

public corruption, illegal sanctions, illegal threats, and more.

86. Apparently, Judge George S. Reynolds has received awards for this

kind of illegal behavior by his legal association or group in which he is a

member; one attorney even went as far to call Judge Reynolds a "dangerous

man" to our country because his acts are known not to be limited to the

actions taken in the instant case and he has a record of corrupting the

system and peoples lives irrespective of the law.

87. The defendant's attorney for all DDC suits was Bill Altman who

took steps in each case to misrepresent rules, statutes, facts and

requirements, all in an effort to corrupt the judicial system and deny

the plaintiff his civil rights. Mr. Altman additionally repeatedly failed to

show up for depositions and ignored subpoenas and failed to show with

or without his client also denying the plaintiff his due process rights. This

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was done with a motion for protective order being filed and not granted.

88. Mr. Altman also attempted to convince Judge Cleland to deny

the plaintiff's his first amendment rights and filed vexatious unwarranted

responsive motions to deny waiving of fees, he also mislead the court in

denying true facts and moving for a 2.116 (C) (8) without asking for a more

definite statement and admitting he understood the plaintiff's filings and

the plaintiff alleged "exactly" what he intended.

89. The original complaint in the case was filed in Wayne county circuit

court on September 21, 2005 before Judge Baxter. The plaintiff filed the

complaint with a demand for jury trial. The plaintiff filed a motion for

summary judgment pursuant to 2.116(C)(10) and won as a matter of law,

but was denied a decision in his favor. The defendant's attorney even

stipulated that the plaintiff "won" the retaliation suit and that they would

"probably give you that one" if it was appealed. The plaintiff was also denied

a jury trial and the defendant was given a summary judgment pursuant

to 2.116 (C) (8) without justification or reasoned opinion and the decision

additionally was infirm as it was not supported by law and is barred by

collateral estoppel.

90. Portions of the Detroit Diesel component of the instant case was

appealed as a matter of right on January 30, 2006 the court of appeals also

denied the plaintiff a decision in his favor in violation of the plaintiff's

constitutional rights when as a matter of law the plaintiff won and the

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plaintiff and defending counsel had already stipulated on that fact. There

is no disagreement, only erroneous decisions. The plaintiff was also sexually

harassed by the security guards threatening to have him strip all his

clothes when his shoes caused the sensor to beep at the court of appeals

and a complaint was filed regarding that and other incidents. A simple

motion for clarification was denied and filings repeatedly returned with

no consideration as was provided for the defendant. (exhibit#37 Ct. of

Appeals response to complaint)

91. Plaintiff filed a leave to appeal to the Michigan Supreme Court

but leave was denied and the decision was never affirmed by the highest

state court leaving denial of substantive due process rights open as a

constitutional question for federal review of sufficiency of state procedures.

92. The plaintiffs first suit against Bob Green was also denied to

proceed in a violation of the plaintiffs due process rights and Judge Stephens

actually blocked the plaintiff from making his argument after arriving at

the courthouse. When the plaintiff arrived home, Waste Management had

dumped garbage on the plaintiff's lawn. (see exhibit #34)

93. The illegal acts of federal and state agencies is also present in the

the attempts of the plaintiff to address any issues in court, where the state

attorneys offices in Michigan and Florida have interfered with and violated

the plaintiff's constitutional rights by obstructing justice and other illegal

acts of fraud upon the court.

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94. On March 30, 2007 plaintiff filed his second action against Mr.

Green, plaintiff's former supervisor at Detroit Diesel Corporation ("DDC")

due to the denial of due process rights, constitutional rights, right to jury

trial, and failure to serve orders, denying the plaintiff his appeal of right

by Judge Cynthia Stephens in Wayne County Circuit Court.

Federal Judge, Robert H. Cleland, conspired with the defendant’s attorneys,

William Altman and Gregory V. Murray, to deny due process rights, right

to Jury trial, failed follow federal rules of procedure in the normal mode,

and illegally discriminated against a person in minority status as a pro-se

and a plaintiff in pauper status. He intentionally misapplied doctrines, blocked

depositions, and conspired to extort tens of thousands of dollars in illegal and

unmerited sanctions, with malice. There are, in the Judges order dated September

6, 2007, specific"threats" if plaintiff choose to further exercise constitutional rights

to a full and fair opportunity to litigate. This is the reason for the chapter: "Federal

Judge Cleland is an idiot" in the book, "Hell Makers and War Makers in America"

His sanctions were so outrageous, the court of appeals could not even tolerate such

corruption on that count and overruled him on the sanctions.

FOURTH COUNT

KIDNAPPING AND ABDUCTION

95. All paragraphs are realleged and reaffirmed as if set forth herein.

96. The kidnapping and abduction the father and his daughter were

and are subjected to, flies completely in the face of the Parental Kidnapping

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Prevention Act of 1980. All jurisdictions involved in the kidnapping were

obligated to review the circumstances and the violation of this act, again

father always had "sole custody" sole legal custody. There has never been found

to be any basis, even at the later illegal hearings, to restrict the fathers

contact with his daughter, yet on a recent visit the father was threatened to

stay in Michigan by Leon County Sheriff Department, again under the threat

of additional acts of force and false arrest and imprisonment regardless of

any court order. Family law court orders have had no impact on the behavior

of the Tallahassee Police Department or Leon County Sheriff; plaintiff has

exhausted those remedies and travel to that jurisdiction is no longer safe and

the comments made by the Florida State Attorney Willie Meggs show the

full and fair opportunity to litigate in that jurisdiction will not exist, even

if the plaintiff brought a retired judge down there they stated "go ahead and

bring him down here he'll be like a fish out of water". The plaintiff has not

been allowed to see his daughter at all since summer of 2005 and used to

see her every 6 to 8 weeks on a consistent basis in addition to 3 phone calls

per week to make sure she was safe which they also stopped illegally.

97. The father could not live in that jurisdiction for obvious reasons due

to the complete disregard for the law and continued criminal acts of the

Florida State Attorney and other authorities to entrap the plaintiff, the father

would have no way to help the child if he was incarcerated. A web site called

"thetallahasseeo" documents case upon case of illegal activity in Tallahassee.

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There are other sites documenting it as well, with many of the defendants listed

in this complaint showing their illegal activity and antics time an time again.

98. The real reason the ex wife wanted the child was to take pornographic

lesbian pictures of her and sell them to make money, while extorting child

support and other monies to further her perverted and abusive lifestyle. The

child was repeatedly abused both physically and mentally severely neglected

and tormented over a extended period of time. The child stated several times

to the father that she would "probably be dead" if it wasn't for the fathers

constant contact and to make sure she was okay; that is how bad it was.

FIFTH COUNT

FALSE IMPRISONMENT

99. All paragraphs are realleged and reaffirmed as if set forth herein.

100. Agents of the federal government working with state and local

authorities have repeatedly and maliciously committed illegal acts against

the plaintiff and other citizens of the United States entirely against the

interests of the country and in direct violation of the constitution. An illegal

act against any citizen of the United States is an act against the country

and its people and the legitimate, legally functioning remaining components

of the government.

101. The plaintiff and daughter were illegally taken by kidnapping and

abduction and falsely imprisoned June 17, 1997 and father and daughter

thereafter have been the focus of a never ending campaign of false

imprisonment and extortion to this very day. The daughter is still being

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illegally held in Florida in violation of the only valid court order and father

forced to pay support when he has had sole legal custody.

102. The plaintiff, due to the illegal steps taken in Florida, would not

even able to secure a passport to visit Niagara falls restricting the plaintiffs

movement with no just cause and limiting many kinds of activities or trips

with friends or family.

103. The Department of Revenue and Leon County Court illegally,

years after the order, and without a hearing, initiated an income tax intercept

so any refund would be taken to further financially restrain the plaintiff. What

was intercepted was never posted or removed from the total just stolen

and simply extorted without any recognition or balance adjustment.This was done

in addition to illegally adding the months of June and July to pay support,

without a hearing, while the plaintiff tried to care for his daughter and had

her in Michigan for the summer. This was to inflict additional and intentional

distress. These illegal intercepts are continuing acts which are still in place to

this day even though the daughter is 19 years old and Florida DOR never

has had jurisdiction. In all actuality, this was intended to financially imprison

and restrain the plaintiff arbitrarily and illegally.

104. The plaintiff's perfect credit was intentionally and with malice

ruined by the Illegal acts of defendants severely restricting the ability of

the plaintiff to acquire transportation, move about freely or establish

a company and hinder employment or residence options; freedoms and

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liberties intentionally taken away by the illegal Florida and other proceedings.

105. Detroit Diesel has had contact with the FBI and Homeland Security

before and after the plaintiff filed suit against the company. They have used

these contacts in attempts to harass and terrorize the plaintiff into dropping

the law suits and preventing the plaintiff any means of support in addition to

blacklisting the plaintiff to any perspective employers.

106. As recently as July 27, 2007 the department of Homeland Security

had agents hide behind vehicles at Plymouth Rd. and Telegraph Rd. in

Redford Mich. and repeatedly peek around and above the cars holding a

camera with an unusually large lens apparently taking pictures, or at least

the impression of agents taking pictures, attempting to scare the plaintiff into

dropping his federal lawsuit. The camera has an unusual lens almost looking

like a prop. A few weeks earlier a Detroit Police Officer (parking enforcement)

also used what seemed to be the same camera with the unusually large lens

pointing it several times at the plaintiff out his widow while stopped in his

car at the intersection they both would put it down, then lift the camera

back up and point it when the plaintiff looked or turned in that direction.

Again, see Cointelpro definition and exact examples. Update, in federal court

the defendants actually submitted these pictures to the court, and plaintiff has

copies which can be also supplied as evidence in this complaint.

107. Homeland Security is taking actions to interfere and obstruct business

relationships that the plaintiff may establish, they have spoken with neighbors

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in efforts to provoke the plaintiff by harassment and restrict his freedom of

movement by having people run out from behind buildings yelling "bang",

creating pyrotechnic explosions in front of the plaintiff's house at night,

dumping trash on the plaintiff's lawn, taking flash pictures of plaintiff at

night, tampering with e-mail communications or sales, accessing cell phone

communications, interfering with filing of federal lawsuits from denying due

process, deleting flash drive files, agents physically removing notarized

documents from copiers at the library, tampering with utilities, theft and

destruction of private property, tampering with the plaintiff's mail box,

attempts to run the plaintiff off the road or give the appearance or evoke

fear of the imminent act of being run off the road, contact with rental car

companies threatening gestures and unwelcome physical contact after

court hearings, walking large black dogs never in area before repeatedly

by the plaintiffs house several times in a row, one was clearly trained

to attack and attempted to do so but was on leash, all intended to instill fear.

108. The actions of the defendant(s) and their agents have caused

the plaintiff to have no options in which to sustain himself the defendant

made statements such as, "you will have to go to another country to get a job"

and "everyone will be against you", and while the plaintiff was looking

out the window "kind of like being in a prison, isn't it". The situation has

caused the plaintiff to no longer have any career path at all and even in the

effort to start a new company, an (LLC), the plaintiffs attempts to establish

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relationships with companies or suppliers is constantly interfered with

as they are instructed to do inadequate work as to provoke the plaintiff,

and or require the plaintiff to come back repeatedly to have work corrected

in so wasting the plaintiff's money and time and any chance to establish

a company and secure a living. If they do not go along with the requests

of the Department of Homeland Security, the company is then targeted. They

have also interfered and attempted to block the plaintiff's filing of previous

federal lawsuits by various means including blocking access to Pacer. Not to

mention the illegal, outragous, sanctions, bonds and beatings and trumped up

felonies used as a club or threat to prevent exercise of simple constitutional rights.

109. They have intentionally vandalized cars owned by the plaintiff or his

company such as taking a large chunk of paint off the door of a newly painted

and restored corvette and ruining the hood alignment, preventing the

immediate sale of the vehicle which also had the engine repeatedly improperly

machined by the contacted machine shop. Homeland Security has shown

pictures to people also to assist in the targeting the plaintiff . There are also

police officers who have followed the plaintiff repeatedly, after plaintiff

picketing at Detroit Diesel, looking for any slight reason to provide a ticket

being directed to the plaintiff to ticket him to increase financial difficulties

the plaintiff is experiencing is due to repeated violations of the plaintiff's

civil rights, due process rights, and liberties which originally began in Florida

through the illegal acts of Florida State Attorney's office and Leon County

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Courts and continued through extortion and communications to agencies

and employers in Michigan.

110. The plaintiff was informed by one of the contacts that the Michigan

Attorney General Mike Cox is involved and has detailed knowledge, personal

knowledge and/or input with Homeland Security and what is happening and

has had contact with the Florida State Attorney Willie Meggs.

111. Clearly there has been a concerted effort to hide these acts from ever

being addressed and the intent was and is for the plaintiff to never have the

opportunity to defend himself and to be oppressed, imprisoned, humiliated

and destitute, without contact with his child or having shelter, and without

any constitutional rights to prevent all of the parties involved from being held

accountable not to mention the attacks and beatings intended to knock the plaintiff

off . The plaintiff is at this time a political prisoner in the United States by people

acting in violation of the laws of the United States.

112. As a one day props example, on August 17, 2007 Homeland security

and agents followed plaintiff into a parking lot with a Hurst beeping repeatedly,

parked a with an electric mobility chair across from him while he was

protesting outside Detroit Diesel, had a handicap lady with a walker out

of nowhere traverse slowly across the median to inquire about the sign,

parked a Chrysler vehicle the same color as clothes plaintiff was wearing

in the place of the truck when it left (where there is no parking spot but

is in plain view of plaintiff), had Redford police officers with flashing lights

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show up in the parking lot as plaintiff arrived . The handicap focus is from

the neurosis problems and suseptiblities the plaintiff suffered earlier. When

the FBI contacted parents earlier they made a point to the plaintiffs father to

comment about nerve problems. Clearly these actions are to cause injury

and stress with intent to cause disability or death and is further and

continuing acts of illegal retaliation for the lawsuits from Detroit Diesel with

State Attorney's Office, FBI, Homeland security and local law enforcement.

Adding additional validation, the day before this a woman game up to the plaintiff,

while protesting in front of DDC, and after conversing with the plaintiff and developing

a liking for the plaintiff stated that she was on SSI and that Homeland Security

is using people on SSI to do things for them because as she said, they "don't have

anything better to do". Then she said, who was your boss? Plaintiff told her it was

Bob Green and she stated that is who they were "getting their instructions from"

which was a huge link in how all of this was transpiring. Plaintiff thanked her

dearly for the visit. It appears some would testify in a trial and she even called

plaintiff their "pied piper" for the real America..

113. On August 30, 2007, after paying his ticket for expired plate,

Redford police were waiting outside when the plaintiff left and followed

him with a gray Dodge Charger police unit which raced up behind

the plaintiff, turned on its lights beeped its pull over siren then turned

around and headed the other way simply to harass the plaintiff.

114. Due to the extensive history of many of the defendants in this suit

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using law enforcement for their corrupt motives and furtherance of their

illegal acts, the plaintiff is notifying members of the U.N. Human Right Commission

and other concerned parties of this suit so as make people known and aware.

Any attempts at further retaliatory acts under the guise of law these parties may

chose to take considering their extreme propensity for violence, terrorism, tyranny,

and obstruction of justice will be watched by every nation all over the world.

115. The count of false imprisonment and the intentions of the defendants

was clearly called out in very specific terms by the statements "kind of like

being in a prison isn't it?" and Mr. Green stating the plaintiff would have to

"leave the country to get a job". These are plain and clear statements of intent

to falsely imprison and deny constitutional rights.

116. The plaintiff is being treated illegally as a political prisoner by the

federal government and other defendants.

SIXTH COUNT

VIOLATION OF SEVENTH AMENDMENT (TRIAL BY JURY)

117. All paragraphs are realleged and reaffirmed as if set forth herein.

118. The original filing on September 21, 2005 was filed in Wayne

County Circuit Court and included a demand for jury trial. The plaintiff

was denied his right to a jury trial even though there were several complaints

under which relief could be granted establishing grounds more than sufficient

to state a claims on which relief could be granted. The defendant didn't

request a more specific statement, and there were issues of material fact

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sufficient to go to jury trial. The plaintiff also won his MCR 2.116( C )(10)

motion as a matter of law at the same hearing, rendering a summary

in favor of the defendant with no reasoned opinion factually and legally

impossible and without merit and a violation of the plaintiff's constitutional

rights by Judge Baxter. The amended complaint of retaliation was won by

default as it was never responded to at all as required by law and all

allegations and reasoning are admitted. It can't get any more clear than that.

Prior to her judicial appointment, she was a private practice lawyer, working for

General Motors Baxter was accused of falsifying documents and was also guilty

of tampering with a criminal murder case. Detroit Diesel was a division of General

Motors and she knew full well that she should have never presided over a case

concerning her former employer. There was clearly extreme prejudice and a clear

conflict of interest behind the obstruction of justice, denial of due process and

illegal fraud upon the court. On September 11, 2001, the Judicial Tenure

Commission voted to censure Baxter concerning another separate case showing

she is no stranger to using the court to do illegal activity and deny a jury trial.

119. The second suit against the plaintiff's supervisor was also to be

a jury trial was also a denial of the plaintiff's due process and constitutional

rights by Judge Stephens. This has been verified with attorneys with 30 plus

years of experience but aware of the consequences to their careers of they

make an issue of what is regularly and illegally done to pro se filers. It is

not only pro se filers who are being denied their rights, it is any good attorney

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attempting to actually stand up against the corrupt courts and being targeted

and their law practices and lives being destroyed illegally on a regular basis.

120. In the more recent federal suit against Mr. Green the plaintiff is again

being denied his right to jury trial by Judge Robert H. Cleland of the

Eastern District of Michigan in violation of his constitutional rights. This is

done even as outrageously none of the alligations are specifically denied

and are admitted as such.

SEVENTH COUNT

OBSTRUCTION OF JUSTICE

EIGHTH COUNT

ABUSE OF PROCESS

121. All paragraphs are realleged and facts reapplied and reaffirmed as if herein:

A. "Abuse of process" can be defined as the use of a legal process , whether

criminal or civil, against another primarily to accomplish a purpose for which

the process was not designed Am Jur 2d 1 Abuse of Process

B. "Process" as used in the tort of abuse of process, is interpreted broadly and

it encompasses the entire range of activites and procedures incident to the

litigation process, including discovery proceedings, noticing of depositions,

and issuing of subpoenas General Refractories Co. v. Fireman's Fund Ins.

Co. 337 F. 3d 297 (3d Cir 2003)

C. It has also been stated that for purposes of abuse of process"process refers to

the papers issued by a court to bring a party or property within its jurisdiction,

such as a writ of attachment, the process used to initiate a civil action, or the

process related to bringing of criminal charges. American Jurisprudence 2d

Abuse of process 2 p.458

D. The Ulterior motive or purpose generally required in an abuse of process

action may take the form of coersion to obtain a collateral advantage not

properly involved in the proceeding itself, such as the surrender of

property or the payment of money, by the use of the process as a threat

or club; there is in otherwords a form of extortion. Baker v. Bank of California

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N.A. 282 Cal.Rptr. 22 (App 4th Dist. 1991)

E. Use of the legal process in the seizure of property in order to harass

or injure the owner or person in posession constitutes an actionable

abuse of process, as does the use of process in an attempt to enforce

payment of a judgement known to be false,fraudulent, or nonexistent.

Shipe v. Schenk, 158 A.2d 910(Mun. Ct. App. D.C. 1960)

F. However, where the criminal process or civil or criminal arrest, is

used to effect an object not within its scope, there is an abuse of

process for which an action will lie, as for example where a warrant

of arrest is used to extort money or other property, or to compel the

signing of a paper, the giving up of a claim or the doing of some other

act in accordance with the wishes of those who have control of the

prosecution.Wood v. Palmer Ford, Inc. 47 Md. App. 692,425 A. 2d

671 (1981)

G. Where criminal proceedings are used as a ruse or pretext, or in bad

faith, for the purpose of getting a non-resident into the jurisdiction

in order to serve him or her with civil process, the process will be set

aside as an abuse, and damages may be recovered.

Wood v Baily, 144 Mass. 365, 11 N.E. 567 (1887)

H. An officer acting under legal process, if guilty of the improper

illegal exercise of authority under it as to warrant the conclusion

that the officer intended to use legal authority as a cover for illegal

conduct, is liable as a tresspasser as though he or she had acted without

process. Hence an officer who inproperly seizes property, uses excessive

force in serving a writ, or makes oppressive use of legally issued

processes forfeits the protection that would be available had the

officer exicuted the process for the purpose for which it was intended;

for such abuse the officer becomes liable in damages like any other

private individual.

Giddings v. Freedley, 128 F. 355 (C.C.A. 2d Cir. 1904)

Stern v. Riches, 111 Wis. 591, 87 N.W. 555 (1901)

Barrett v. White, 3 N.H. 210 1825 WL 476 (1825)

I. Liability for the abuse of process tort generally extends to all who

knowingly procure, participate in, aid, ar abet the abuse, and those

who advise, or consent to the abusive acts, or subsequently adopt

or ratify them, are liable as joint tortfeasors. Thus the injured person

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has a remedy, not only agianst the officer serving the process, but

also against all others who may unite with the officer inflicting the

injury American Jurisprudence 2d 19 p. 481 Encyclopedia

J. Where abuse of prcess is accompanied by malice, exemplary or punitive

damages may be awarded. Steele v. Morris 608 F. Supp. 274, 1 Fed R. Serv. 3d 956

(S.D. W. Va. 1985)

K. Malice may be established by showing the defendants conduct reflected

spite, ill will, and reckless disregard of its possible consequences to

the opposing party.

L. The fact that a plaintiff acted under the advice of counsel is not generally

considered to be a defense. The existence of probable cause also is not

a defense to an abuse of process claim Mc Carthy v. Kleindherst, 741 F. 2d

1406,39 Fed. R. Serv. 2d 1165 (D.C. Cir. 1984)

NINTH COUNT

COLOR OF LAW VIOLATIONS

TENTH COUNT

EXTORTION

ELEVENTH COUNT

MALICIOUS PROSECUTION

122. All paragraphs are realleged and reaffirmed as if set forth herein.

123 Some information below also contains components of entrapment,

additional fraud upon the court, false imprisonment and other illegal acts.

124. During to the June 97 kidnapping, abduction, and false imprisonment

the former wife was on probation. She was never held accountable for her

numerous violations of probation, the Leon County Sheriff's department

and Tallahassee police and State Attorneys Office conspired to commit illegal

acts with her while the former wife was on probation. These acts were in

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violation of court ratified and legally binding marital settlement agreement

as well as criminal law. Ellen Hamilton conspired and also illegally signed

sworn documents stating the plaintiff stole his own car from her residence.

The father had an established residence and belongings not easily transported

and had a legal right to be served with a notice of hearing since he had sole

legal custody, therefore the ex-parte hearing which occurred was an

unjustified intentional illegal act to deny the father due process rights and

full and fair opportunity to litigate and further obstruct justice. This denial

of substantive due process rights renders any judgments and later mock

hearings void as a matter of law. Furthermore, the plaintiff was being

restrained in violation of his rights by the conflict of interest of his counsel

and the Florida State Attorney's Office.

125. The seizure of property and grand theft charges was to harass and

injure the father in addition to the violent abduction of his daughter. This

process was used as a weapon to accomplish a purpose for which it was

not intended. The grand theft charges are an unwarranted, unauthorized

illegal and perverted use of the process. The defendant clearly had an ulterior

motive which was to kidnap the child from her legal guardian. The father

illegally suffered the loss of his child, financial stability, civil liberties and

each year thereafter the abuse continued and slowly chipped away at any

remaining rights the father had left. Even though the father prevailed in the

criminal action, and the charge was ultimately dropped, the illegal bar to

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any full and fair recovery was already predetermined by the perpetrators

and covered the entire range of activities related to the litigation process

and current unwarranted denial of contact is simply to harass and injure

the father and satisfy the wishes of those who had control of the prosecution.

126. The Judge George S. Reynolds acted wholly without jurisdiction and

acted under pretences of official capacity. Other officers involved in the acts

did not have facts to establish probable cause as required by law. The legal

authority was simply used as a pretext for illegal conduct. The criminal

proceedings, as shown by the dropped charges, were used as a ruse or a

pretext in bad faith to prevent any legal defense and force the plaintiff back

to their jurisdiction and the entire and continually escalating process to

this day is an abuse intended to cause additional damages. There was also

procured the improper initiation of proceedings by third parties to use

criminal proceedings to collect a fraudulently alleged civil debt and acted

upon jointly and constitutes the oppressive use of legally issued processes.

127. The father offered to Novi, and Farmington Hills Police Department

legally binding proof of custody to provide them with a legitimate legal

document establishing issue of material fact and allowing them ample time to

question the actions they were taking and validate the documents with their

respective departments and exercise good investigative instincts rather than

contributing to further illegal acts. Detective Lauria denied the opportunity,

and rather chose to escalate the situation with vulgar violent threats in front

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of a 4 year old child expressing his sick and corrupt mentality and striking

fear into a four year old child establishing that officer Lauria, Novi police

department, and Farmington Hills police among other things used excessive

force in serving the writ of attachment and trespassed while kidnapping and

falsely arresting, and committing an illegal child abduction while defaming

the father in front of his child as well as false imprisonment and failure to

read the plaintiff his rights.

128. When plaintiff asked detective Victor Lauria about if he would be read

rights Lauria stated, "you don't have any", a denial of rights and admission

clearly stated with malice. This idiot is now the assistant Chief of Police.

129. Oakland county jail refused to allow the father a phone call within

24 hours of incarceration. The father was then forced under duress to sign

a release or was told that he would never leave the cell, where men were

molesting other men, or get a phone call if he did not sign. If he did sign, he

was promised to be transferred to a different cell and would get a phone call

The father immediately after signing was put into the same cell until the

extradition process began days later. The plaintiff, at times, still has flashbacks

because of the illegal incarceration.

130. David Moye', the father's criminal attorney, intentionally overcharged

the father and parents and did not take the proper steps to resolve the case

by interfering with and withholding other possible options and not informing

the father of the details of the factual findings. It was clearly the intent

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of Mr. Moye to do this as a favor for his future employer, who he was to be

defending the father against for illegal and outrageous acts. Mr. Moye

intentionally kept the criminal case open as to prevent any decision in

the father's favor from being used in the family law case by the request of

the State Attorney Willie Meggs and to cover up illegal acts on their part

and to further extort money from the father and his parents the hearings

were simply a mockery set up by those planning the illegal acts.

131. Mr. Moye by intentionally dragging out the criminal case used

it as a form of coercion, threat or a club in an ulterior motive, to establish

a collateral advantage for opposing party in the family law case and

for his future employer in a form of extortion to force the plaintiff to

surrender property and extort money from him in the form of higher

attorneys fees, payment of court costs, surrender of property not in

the proceedings, and extort payment for services of other officers, higher

fees for the family law attorney, and adverse family law outcome. It

was also used extort payments that were false, fraudulent or nonexistent

in the context of the ultimate determination.

132. Mr. Moye later also persuaded other attorneys not to pursue the case

clearly in an effort to cover his own interests and prevent any of the egregious

acts from being addressed in court, obstructing the plaintiff's rights.

133. The Family Law attorney, Robert McNeely, also proceeded in similar

fashion and was in contact with Mr. Moye while he also neglected his duties

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to provide adequate representation and also aggressively moved to extort.

McNeely's ploy was to file repeated motions, and when denied, would fail to

appeal and allow the time to run out on consideration of the motion; but

attempt to get another judge whereby wasting time and eliminating all

appellate options on such a clear and simple case that should have been

appealed immediately from the beginning. The scam was to run up hours and

extort money from the father without merit as later did Paul Shapiro. (ex #38)

Shapiro's blatant malpractice, obstruction of justice, fraud and harassment

of the plaintiff). Note: extortion of court costs required by "Attorney General"

and additional hearings and court costs continue for two years of malicious

prosecution, fraud upon the court, extortion, denial of due process rights,

abuse of process, harassment, fraud and more while plaintiff is in compliance

the whole time. (see exhibit#23 on compliance 2 years later)

134. The father was, as mentioned, the focus of more than one assault and

battery instigated by Leon County Sheriff and Tallahassee Police in conjunction

with repeated refusal to enforce visitation orders and attempts to provoke the

father to defend himself and entrap the father to being unjustly arrested

again. There was also a complete denial of the fathers rights to any legal

recourse for being assaulted or in filing child abuse charges. defendants

conspired to withhold facts in a child abuse investigation, further abductions

of the child, deny legal custody of the child, additional efforts of Leon County

to fabricate charges, refusal to provide legal assistance as provided to

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residents of Leon County, forcing the father to leave town, abducting and

withholding visitation with his daughter simply for political reasons, causing

the child extreme distress and additional physical and mental abuse.

135. The inaction on the part of The Department of Children and Families

in not properly addressing the child abuse and working with Leon County

Sheriff's Department and Tallahassee Police Department in conspiring to

cover up and not properly proceed as legally required to protect the child also

constitutes further acts in obstruction of justice.

136. In further proceedings in Leon County Court and with the most recent

opposing counsel Charles McClure (who corruptly, but not surprisingly, was

a prior judge privy and subject to conflict of interest with this case), filed

frivolous motions without merit, requesting denial of all visitation of the father

as recently as June 2006, the father was denied his due process rights, tapes

of hearings were erased, Department of Revenue has continued their

harassment and extortion and refused to adhere to child support guidelines,

instructing Florida State Disbursement Unit not to post payments made and

not to post thousands more in income tax intercepts as further blatant

extortion knowingly demanding other or greater sums than are authorized

by law willfully oppressing the father under color of law by the malicious acts

of Attorney General for the Department of Revenue Priscilla Quionnes who

initiated the illegal acts. State Attorney's office has sent copies of scheduling

orders and has represented the former wife on additional hearings continuing

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their involvement and solidifying the facts that the obstruction of justice and

fraud has never ceased. The former wife stated on August 21, 2007 she was

going to talk to the Attorney General "personally", demonstrating a willful

and malicious intent to forever continue illegal acts with the support of

the Florida State Attorney Willie Meggs and others. There was another

illegal exparte hearing in 2012 in which the Florida Department of Revenue

decided to continue to stalk the father for illegal support payments even though

the daughter is 19 years old, she is no longer a child, they no longer have

jurisdiction anyway, and all prior and future payments were illegal.

137. From 2005 to present, under the counsel of Charles McClure, the

former wife has refused visitation entirely between the father and the

daughter. Even though Charles McClure's motions to deny visitation were

not granted, the former wife and her counsel have taken it upon themselves,

with no legal basis, to completely deny the child her relationship with her

father. When the father would schedule to visit; the child would be illegally

abducted to another location, or the father forced to leave town, this had

been used with extensive brainwashing of the child to defame the father

both by the former wife and former mother-in-law (Ellen Hamilton) and

significant other or "lesbian girlfriend" who hold any fathers position in low

regard and the aunt who has taken "porno pictures" of other women and also

tried to take explicit nude pictures of the child while "urged on" by the

mother (former wife) to do the act. This psychopathic behavior is partially

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why the father filed for divorce in the first place and why that environment is

dangerous for a young person clearly each of these people advised and

consented to the illegal, perverted acts. (exhibit #39 '04 complaint form)

138. When Charles McClure filed a his motions he never even filed

the UJCC affidavit, which is required by law, or establish a significant

change in circumstances, also required. There is simply no excuse for a

judge that recently retired from family law to file a frivilous motion

lacking the basic requirements of the motion. The motion was simply

and intentionally harass and was completely baseless and meritless

and again was a ruse or a pretext to interfere with summer vacation

and force the plaintiff to again to go down to Florida to defend a

meritless act when plaintiff should have been allowed to attend by

phone. The intent was that the plaintiff would not be able to make it

to Florida for the hearing and then be held in contempt of court

allowing the Florida authorities to take the child from Michigan and

again falsely imprison the plaintiff this time for contempt in another

entrapment scheme. It cannot be overstated that Charles McClure had

intimate knowledge that the motion was patently frivilous and lacked

the basic requirements to sustain it. (exhibit #40 letter McClure, Letter

Lauren (daughter) sent to Judge done in 10 minutes June 2004)

139. When Charles McClure's plan didn't work he became very

upset and stated to the plaintiff "you're a horses ass" and this was

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coming from a recently retired Leon County Judge! This demonstrates

State Attorney Willie Meggs statement that "we do things differently

down here". This lunatic was actually angry that his corrupt illegal act

fell through. At the hearing he even tried to allege the plaintiff made

statement "catch me if you can". If the plaintiff would have not shown

up for the hearing, that act of fraud upon the court would have been

again used to take the child and put the plaintiff in jail, just as the

former wife stated if the plaintiff's parents would not have got him out

the first time he would "still be in there". (exhibit#41 McClure letters May

- June 2006 "horses ass" comment ). The fact is, that Judge Cooper should

have never allowed a hearing on Charles McClure's improper motion in the first

place or forced Lauren to have excessive phone contact every single day during

the summer with her mother when calls were supposed to be three times a week

and the every day calls were simply to harass, torment, brainwash and ruin

the child's summer even further strangling her liberties again with oppressive

and hate filled lies. The hearing forced the father to go all the way back to Florida

during the child's summer vacation simply to harass and interfere with visitation.

He refused to have the hearing by phone. She is haunted and followed around

constantly by the mother even to this day. If the purpose was moral or protective

that would be a different issue; but, it is simply to alienate and terrorize a child

by a mother that wants to prevent her from reading the bible or having a father.

It is religious persecution using the family law system as a pretext for illegal

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discrimination.

140. Fifteen years of these illegal acts demonstrates there is an unrelenting

malicious purposeful intent for the defendants to create an environment

so the plaintiff will never be safe in his own country and have to live in

constant fear and be denied all rights to his child and any mode of survival.

There is no reason for this insanity and acts of civil war and terrorism against

the plaintiff and the constitution itself. If there is a reason for their acts, this

is their opportunity to tell it to the jury and explain it in depositions.

141. In acts as recently as Aug 9, 2007 the former wife again stated her

intent to make it so the plaintiff would never be a father to his daughter and

again threatened unjustified legal action and stated that the plaintiff "never

will be" her father. The father clearly has exhausted his legal options in that

jurisdiction and there is no law abiding law enforcement authorities, as the

instant case clearly demonstrates, to uphold the law in that area. The former

wife also stated that if the plaintiff's parents didn't help to get him out of

the illegal incarceration she caused he would " still be in there". This can

only cause one to question how many other people are being imprisoned

illegally in violation of their rights by these sickening, clearly retarded, mentally

ill terrorists employed by, but working against the U.S. government and its

people and how many children are being abused and neglected by and as

a result of their blatant malicious illegal acts. Former wife also sent a letter to

the court stating in her own words that she was "fighting this man" and sent

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an e-mail stating the nothing that the plaintiff says, feels, or does matters and

that he was just a "sperm donor" and never will be Laurens father. These may

also be presented to the court. This also demonstrates why she was on probation

for domestic violence and why the plaintiff filed to divorce her in the first place.

142. Mr. Green at Detroit Diesel also stated that the plaintiff would have to

"rob a bank" or "kill your parents" to have enough money to see his daughter

again. This is not for any lack of parenting skills or abilities, simply a group of

corrupt people with a fraudulent intent using contacts to illegally interfere

someone's life and family and commit illegal acts utilizing communications

with incompetent employers to further their goals.

143. Mr. Larry Butler, a former employee of DDC, in a deposition

on September 25, 2006, made intentional false statements under oath to

obstruct justice in order to play on the grand theft theme by stating that the

plaintiff wanted Mr. Butler to "give" him his car rather than purchasing it

from him however, he cannot defend that statement as inconsistencies

develop in his story as the deposition goes on . This is also consistent with

specific activities of defamation listed in the instant complaint. Prior to the

deposition, in a phone call with the plaintiff, Mr. Butler stated that he may

attempt to "ruin" the plaintiff's case in so committing purjury and obstructing

justice.

144. On November 6, 2006 the plaintiff traveled to Lansing to file

a complaint with the FBI. The plaintiff was initially given a complaint form

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and scheduled to see an agent to discuss the complaint. However, shortly

thereafter the complaint form was taken back and the plaintiff was instructed

that there was no one there to discuss the case, and that the plaintiff would

need to go to the Oakland county location to file the complaint. The plaintiff

called the location in Troy and spoke with Dave Kotel, who stated he would

fill out a complaint for the plaintiff. The plaintiff met with Mr. Kotel and

apparently no report was ever filled out by Mr. Kotel in reference to the

plaintiff's complaint although he was led to believe there was. The plaintiff

also offered several pictures to Mr. Kotel in support of his allegations and

Mr. Kotel stated that he did not need them. Mr. Kotel stated that he forwarded

the complaint to a different group, however on February 16, 2007, the

plaintiff filed a freedom of information act request to get a copy of the report

Mr. Kotel was to have prepared; plaintiff was told there was no report.

145. Mr. Kotel also attempted to obstruct contact with the plaintiff and

Kotel's supervisor after Mr. Kotel displayed unethical behavior and made

outrageous comments on January 8, 2007 and got combative when asked

about his knowledge of the adverse actions the day after the November 6

meeting such as phone calls, picture taking, contact with neighbors and

family, cell phone being remotely accessed, being followed, etc.

146. While Mr. Kotel's comments were that the things that the plaintiff

was seeing weren’t "really happening" and that the plaintiff should see a

doctor for psychological issues. His supervisor, Charabot, did not deny the activity

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but stated that the FBI were not the ones doing the following but she could

not say that it was not being done by another department such as Homeland

Security. The other alleged actions, such as phone calls, phone access, picture

taking and neighbor contacts were not denied like the issue of following.

Mr. Kotel personally contacted the plaintiffs Father and Mother and told them

that it would be in their "best interest" not to help the plaintiff. This act

struck such fear into the family that there has been no contact ever since,

which in itself is terrorism and malicious defamation per se. Again, see Cointelpro.

After plaintiff found out who he called, Plainitff called Kotel back and asked if he had

contact with anyone and he initially denied it. Then, when plaintiff proved to him

he was lying and gave him specific details of his calls to plaintiff's parents he became

combative and said, “So what!?”, and admitted contact, and that is when plaintiff

asked to speak with his supervisor Toni Charabot but Kotel tried to deny contact.

147. Homeland Security and FBI interfered with the filing of a federal law suit

where the plaintiff's files were erased, originals of affidavits stolen, papers

removed from copier and plaintiff was queried about his emotional condition

after papers were taken, all within 1 hour while preparing his federal case

against Green at the Farmington, MI library the same day: March 30, 2007.

The stolen items were later returned in the mail over a month later.

148. PBS had a special on homeland security and the serious attacks

on the constitutional rights of our citizens and violation of privacy rights at

libraries. The special was called America at a Crossroads and was aired May 11,

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2006 so the plaintiff is not the only one.

149. Homeland security has had contact with people in the plaintiff's

neighborhood, has had contact with companies the plaintiff has business

relationships and conspired with many of them to do damage to items

belonging to the plaintiff, improperly or inadequately do jobs which would

cause the plaintiff to return repeatedly to have done right or completed,

wasting the plaintiff's time and financial resources and intending to cause

plaintiff's company to fail and restrict any and all efforts at productivity.

150. In prior cases, as with the prior federal suit against Mr. Green, the

plaintiff has had monies extorted from him by the courts in filing fees motion

fees and illegal sanctions in the tens of thousands of dollars while denying

the plaintiff his due process rights when the plaintiff has won as a matter

of law and stated claims with identical circumstances found to have won jury

verdicts or decisions as a matter of precedent anyway even if not defaulted.

151. The week after the plaintiff had contact with a realtor about selling

his house, Judge Cleland conspired with Bill Altman and Gregory V. Murray

to extort any proceeds from the sale by illegally sanctioning the plaintiff

$18, 242.38, when sanctions should have been against the defendant for

their numerous rule violations and illegal acts. Even in the courts own

standard of review, sanctions are not merited against plaintiff, however it

does support sanctions against the defendant. The fact that attempted

murder and extortion is now supported by Judge Robert H. Cleland as

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acceptable is utterly shocking. (exhibit#42 plaintiff's response and

counter motion for sanctions w/ transcript of plaintiff winning 2.116

( C ) (10) as matter of law Dec. 16, 2005, opinion and order granting

defendants motion for sanctions Sept. 6, 2007, list of extorted fees

and costs) In addition, they were informed about the sale of the house in the

first place by the FBI, admittedly. Obviously they would have never known

such a private transaction was taking place any other way and Kotel asked

who the Judge was for the federal suit and later illegally contacted Cleland.

TWELFTH COUNT

NEGLIGENCE

152. All paragraphs are realleged and reaffirmed as if set forth herein

153. Leon County Sheriff, Tallahassee Police department, Department

of Children and Families, State Attorney Willie Meggs, agents Gandy and

Goodwin and others acted negligently in not properly investigating and

failing to take appropriate legal action to protect the child against the former

wife, aunt, and lesbian grandmother from trying to persuade the child to

pose for pornographic pictures which also explains why the child had

mosquito and ant bites all over her body after visiting the grandmother a

few years before because the grandmother was taking nude pictures of

the child outside and desensitizing her to filthy lesbian whoring.

154. The plaintiff hired John C. Kenny to take legal action to seek a

modification of parental responsibility to protect the child from additional

acts of child abuse, neglect, and endangerment. Rather than address the

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issues, he used it as a social opportunity to have contact with the Willie

Meggs and made agreements with Willie Meggs to take no action at

all, causing and contributing to her additional suffering and abuse and

he even made the statement that "the legal system is hell".

155. The FBI, Novi police, Farmington Hills police and others displayed

negligence in not properly investigating the extradition order which they

should have denied in the '97 incident for the utterly fraudulent and illegal

basis on which it was founded upon and complete lack of evidence to sustain

such an order and lack of jurisdiction.

156. The FBI displayed negligence in not following through with

complaints made to them concerning people in the plaintiff's neighborhood

being contacted by individuals originally thought to be posing as agents

from the FBI or Homeland Security. The plaintiff was not called back on

the several requests to Mr. Kotel by messages left concerning the complaint

the plaintiff believed and was led to believe he filed with Dave Kotel.

157. The FBI was negligent in not following through with standard

procedures and intentionally misleading the plaintiff when he was presenting

issues related to national security, possible impersonating a federal officials

(which actually was them), civil rights, fraud, and rights guaranteed by the

constitution of the United States and equal access under the law.

158. The FBI and Homeland security were also negligent in not providing

and withholding information concerning the plaintiff, in violation of the

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Freedom of Information Act.

THIRTEENTH COUNT

VIOLATION OF 14TH AMENDMENT (DUE PROCESS)

159. All paragraphs are realleged and reaffirmed as if set forth herein.

160. ..No state shall make or enforce any law which shall abridge the

privelage or immunities of citizens of the United States; nor shall any

state deprive any person of life, liberty, or property without due process

of law; nor deny any person within its jurisdiction the equal protection

of the laws .

161. All violations listed in all paragraphs are reaffirmed and asserted

as if herein.

162. The father was denied his due process right to being served, to attend

the ex parte hearing before Judge George S. Reynolds. There was no legal

cause and the father had legal "sole custody" details of which were witnessed

and the former wife fired the prior attorney for refusing to make the agreement

giving the father sole custody. The conspiracy was to "take" the child with the

specific intent to deny due process, hence the fraudulent charges, criminal

attorney not resolving case quickly (and later working for Attorney General)

denial of the father and his daughter equal protection under the law, further

abductions and assaults set up by Leon county Sheriff and other related

illegal continuing activity including continuing federal violations to this day.

163. It was made very clear that the law wasn't the issue when at the

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meeting the plaintiff/father had with Attorney General Willie Meggs, Mr.

Gandy and Mr. Goodwin February 16, 2001, the State Attorney stated

that he was the "only game in town" and the facts didn't matter. The father

/plaintiff mentioned that he had some recent opinions on the matter by a

retired judge. The statement was made" go ahead and bring him down

here, he'll be like a fish out of water" and "we do things differently down

here", and "good for her if she can get away with breaking the law".

(see exhibit #19 letter to Gov. Jeb Bush)

164. The plaintiff was denied his 7th amendment right to a jury trial

in the first DDC case, the plaintiff was denied equal protection of the law

against retaliatory action as provided under the Whistleblowers Protection Act.

Defendants evaded depositions by leaving town in order to obstruct the

judicial process and violated other court rules.

165. Although it is not clear or reasoned in the judge's order, there

was a summary decision without basis in law or fact and the decision was

made without due process and the "ordinary mode prescribed by law" and

was not based on the merits of the case and was clearly premature as

discovery was not even completed. Jury trial was denied illegally.

166. The order was not sufficiently firm to establish a basis for the

decision and the plaintiff was "arbitrarily restrained" from proceeding to

a jury trial. There was no suitable protection provided to the plaintiff

in his employment from the defendant taking further adverse action

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in violation the plaintiff's civil liberties and equal protection under the

law as provided by the Whistleblowers Protection Act after filing the

original suit.

167. The Michigan court of appeals went right along with the denial

of due process and violations of constitutional rights in affirming the

grossly erroneous decision(s). Even to go so far as to attempt to make a

malicious fraudulent reasoned opinion devoid of logic while intentionally

ignoring the facts and law and not once showing how there was a failure

to state a claim while also ignoring the facts that there was a default and all

allegations were admitted to as well as application of law; they are a sick,

pathetic insult to the judicial system and human rights.

168. The plaintiff was clearly in a position to suffer grievous loss to

health, future, career and as a result of being denied his rights has in fact

suffered additional grievous loss as would be expected when a citizens' civil

liberties and rights are denied arbitrarily. That is part of the reason these cases

were proceeded with pro se was to intentionally test the integrity of the system

and document the outcome, as is now the case again.

169. Through actions to interfere with business relationships and deny

employment opportunities the FBI and Homeland Security has taken steps

to intentionally remove the plaintiff from his home and deny him his

property rights and any liberties he may have by arbitrarily restraining any

and interfering with all financial pursuits and or endeavors the plaintiff may

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attempt. The FBI even asked for numbers of where the plaintiff would stay

if "things got worse" rather than offering any kind of support of addressing

issues, the day after that comment incidents and harassment increased

dramatically and when that fact was mentioned to Dave Kotel of the FBI

he became defensive and rude as he essentially admitted guilt in taking

part in initiating the acts then denied contact with his supervisor.

170. The only reason the plaintiff was in that past financial situation

and has lost his house is due to the governments denial of the plaintiffs

due process rights, this is not the sole cause of everything financial because

they also destroyed the plaintiffs company and career prospects, but the

inability to make payments and retain his house would not be an issue if

plaintiff was granted decisions which he won and is entitled to as a matter

of fact and law. Because of the actions of the government ( or those acting

illegally in governmental positions) the plaintiff's credit has been completely

destroyed also. It should also be noted the defendant's attorney admitted the

plaintiff won his retaliation claim and the amended complaint was never

responded to and plaintiff won his 2.116 ( C ) (10) as a matter of law at the

hearing. If the plaintiff and defendant agree as to the facts, they are settled

and are in agreement with the law. A adverse decision is void, arbitrary,

without merit and a denial of substantive due process and constitutional

rights in repeated adverse acts which shock the conscience.

171. The plaintiff is being denied equal protection under the law from

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illegal acts of Detroit Diesel, federal and state governments and other

defendants in violation of the Constitution of the United States by

arbitrarily restraining him from exercising his civil rights in the ordinary

mode and intentionally causing plaintiff to suffer grievous loss by denying

equality in due process when state courts and others have repeatedly,

intentionally, and with malice denied the plaintiff his individual rights.

A. When process is due:" The extent to which due process must be afforded the recipientis influenced by the extent to which he may be 'condemned tosuffer grievous loss ', and depends on whether the recipientsinterest in avoiding that loss outweighs the governmental interestin summary adjudication." The very nature of the concept negatesany concept of inflexible procedures universally applicable toevery imaginable situation."

B. Federal constitutional law provides a floor for individual rightsthat state courts may not go below.

C. Liberty: Includes personal, political and social rights and privelagesand implies the absence of arbitrary restraint . With the relation ofthe employer and employed there is to be "suitable protectionof health and safety and that peace and good order may be promotedthrough regulations designed to insure wholesome conditionsof work and freedom from oppression:

D. Procedural due process--civil:It must be pursued in the ordinary mode prescribed by law; itmust be adapted to the end to be attained; and whenever necessaryto the protection of the parties.

E. Equality in due process:Rights are measured not by laws made to affect him individually,but by general provisions of law applicable to all those in like condition.

F. Denial of the full rights of a pro se, as provided by the Constitutionis no different than discriminating against any other minorityon the basis of some arbitrary factor. Pro se in the judicial

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system are minorities by definition and should be afforded allrights and protections under the law as any other citizen.

STANDARD OF REVIEW

172. " The touchtone of due process is to protect the individual

against the arbitrary action of government." U.S. ex rel. Myers v. Sielaf

381 F. Supp. 840 D.C. Pa (1974). Our system of law has always endeavored

to prevent even the probability of unfairness" In re Murchison , 349 U.S.

133, 136,75 S. Ct 623,625,99 L. Ed. 942. "Justice must satisfy the

appearance of justice". The appearance of impropriety is sufficient to

survive the limited requirements of Federal rule of Civil Procedure 8.

Church of Scientology Intern v. Kolts 846 F. Supp. 873 C.D. Cal., 1994

What is being claimed is a violation of substantive due process because

the acts "so shock the conscience" as to constitute a depravation of the

plaintiff's federally protected rights. A violation of a constitutional right

to substantive due process because the conduct was inherently

impermissible Schiller v. Strangis , 540 F. Supp. 605,614. Thus federal

court subject matter jurisdiction in cases adequately alleging violations

of substantive due process is not affected by the adequacy of state

remedies. Id Manuel , 767 F. 2d 174,177. It in effect violates the very

fabric of our system. If the process is so egregious as to "shock the

conscience "it also constitutes a depravation of substantive due process.

(" A judgment, whether in civil or criminal case, reached without

due process of law is without jurisdiction and void and attackable collaterally..

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by resistance to its enforcement if a civil judgment"). 1B Moore's Federal

Practice p. 406 (2),p.905;7id.at p 60.25 (2), p. 309-11. A judgment rendered

in violation of due process is indeed void and therefore need not be enforced

under 28 U.S.C. s 1738 or the full faith and credit clause of the constitution.

"A departure from established modes of procedure (can) render the judgment

void." Windsor , supra, 93 U.S. at 283 where the procedural defects are of

sufficient magnitude to constitute a violation of due process, or…"so unfair as

to deprive the proceedings of validity", Eagles v. U.S. 329 U.S. 304,314,67 S.

Ct 313,319,91 L. Ed. 308 (1946).

FOURTEENTH COUNT

VIOLATION OF FREEDOM OF INFORMATION ACT

173. All paragraphs are realleged and reaffirmed as if set forth herein.

174. A request for information pertaining to the kidnapping of the

plaintiffs daughter, false arrest, false imprisonment, extortion, and records

and circumstances relating to the FBI and Homeland Security related to

the illegal activity at Detroit Diesel and attempted murder by plaintiff's

supervisor and other defendants was made. Additionally, the violations that

occurred by Dave Kotel and the refusal of that department to provide

information as requested was made by the plaintiff.

175. A freedom of information act request was sent to U.S. Department

of Justice (FBI) February 16, 2007, additional information was requested

from the plaintiff by FBI on February 27, 2007 and reply was sent March 4,

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2007, notice of FBI referral was made March 13, 2007. A notice of no

information in regards to the FOIPA was sent March 14,2007. March 28,

2007 letter was sent in regards to information pertaining to another

individual. An administrative appeal with legal citings and detailed

circumstances was filed April 8, 2007 by the plaintiff, April 26, 2007

notice of receipt of the appeal was made. Appeal was not answered until

June 19, 2007.

176. The lack of findings is clearly not valid as there was actual

documented contact that the FBI had with people, specific statements

made by Dave Kotel, and personal meetings and phone calls. The FBI is

clearly withholding information in violation of the freedom of information

act. If the request was more properly addressed by another office the

Freedom of information act and or Privacy Act would allow for a notice

of specific findings at another location and what they may have in

reference to the request, instead each office pointed to the other.

177. A freedom of information act request was also made to the

department of Homeland Security for information related to the

circumstances, March 27, 2007 and the answer on May 30, 2007 was

that the secret service files contained nothing. Clearly an evasive answer

to withhold evidence of what was known to be occurring by responding

to the Secret Service question not the Homeland Security request.

FIFTEENTH COUNT

MALPRACTICE

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178. All paragraphs are realleged and reaffirmed as if set forth herein.

179. The initial grand theft charges, exparte hearing, denial of due

process rights that occurred in June of 97 was a blatant case of entrapment

but not pure entrapment because the plaintiff did not really break the law they

just set it up to look like it which gave the contributing authorities the confidence

arrogance, disrespect and disregard for any sort of adverse legal action to

make repeated further attempts at entrapment and threat upon threat of

unjustified imprisonment to the plaintiff almost sickening casual. In that

frame of mind the defendants have repeatedly and unrelentingly attempted

to do it all over again by conspiring to set up all manner circumstances in a

never ending cycle of corruption and illegal traps. This is especially true of the

retaliatory attack, beating, and attempted murder by the Southfield police

February 29, 2008 after the filing of the original Federal lawsuit. The plaintiff

stated to the arresting officer, "you arrested me for nothing" his response was "Yep"

a legally admissable per se admission of illegal arbitrary arrest by Southfield

police.

180. The father hired Paul Shapiro to correct the child support issues

and rather than show up for the hearing to correct the issues and have the

father attend by phone, the father waited on the phone and Mr. Shapiro

stated that he made a deal when there was no deal to make. He entrapped

the father into even more monthly hearings when there was no cause and

clearly conspired to take action not in the best interest of his client and

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extort fees from the father while representing the other side in a fraud to

appease and conspire with the Department of Revenue.

181. The employers ant attorney's at Detroit Diesel found out about the

plaintiff's prior circumstances in Florida and used it as an opportunity for corruption

and violation the plaintiffs human rights, liberties, and constitutional rights

by using the 9.11 attack and the discontent with the purchase by Daimler

Chrysler to contact governmental entities such as FBI and Homeland security

to create a gradual timetable which would end in the plaintiff losing everything

and being alienated by those in contact with the plaintiff, ignoring any laws

or rights that may have been violated in the process.

182. The timetable included a arbitrary decrease in pay, blacklisting of the

plaintiff to eliminate any employment options, homeland security contacting

neighbors, family, and business connections to destroy any chance the

plaintiff may have to establish a company, entrapping the plaintiff into financial

indigence and inability to make house payments, utility payments, insurance

payments, visit his daughter, or pay child support then ticketing the plaintiff

through the Redford Police who would follow the plaintiff home closely watching

for any reason to ticket the plaintiff . When the plaintiff was ticketed for

an expired motorcycle plate, the cause of the financial situation which

brought it about was the denial of due process rights by the Wayne County

court denying a decision in a law suit where the plaintiff won and was

entitled by law to relief. The city of Redford is located in Wayne County

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Michigan.

183. It was made very clear the intent that the FBI had when requesting

the phone numbers of anyone who the plaintiff may stay with if "things got

worse", then calling these people to frighten and alienate them by stating

that the plaintiff was high strung and had a nervous breakdown (which

incidentally is also a misrepresentation of neurosis and leg failure which is

what occurred) in an effort to prevent the plaintiff from having anywhere to

stay, when the intended outcome of complete financial destitution and

the plaintiff's loss of his house did occur.

184. The plaintiff's father made it a point to tell the FBI that the plaintiff

is not high strung and the issue of him being 40 and having his life and

career ruined is a cause for anyone to be concerned.

185. The plaintiff has been required to pursue public assistance to survive

due to denial of his constitutional rights and liberties of continuing with his

career due to the actions of Detroit Diesel, FBI and Homeland security to

interfere and destroy the plaintiffs prospects, even postings on e-bay were

tampered with and transactions ruined while plaintiff was listing items for

sale to establish his company.

186. After the appeal of the Green lawsuit the harassment had been

increasing to include repeated aggressive acts by young men to provoke

the plaintiff into confrontations as recently as August 13, 2007. The short

time frame, lack of historical incidents, volume, consistency of the age

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(teenagers), lack of situational cause for the behavior clearly demonstrates a

manipulation of the behavior of these young people to entrap the plaintiff

into a situation questionable on many fronts. It has also been noted that these

young men have multiple backup waiting very close to the location. This

has simply never occurred and now is becoming clearly repetitive by different

and multiple actors within several weeks consistent with the Kotel Comment.

187. Young people (teens or twenties) are used repeatedly by the FBI

and or Homeland Security. The hooded men taking pictures at night were

young men, almost running the plaintiff off the road was by young men,

stealing of the plaintiff's bike and riding by the plaintiff's house the same

week on the stolen bike was a young man, provoking the plaintiff to fight

at the library was a young man. perpetrators are in groups of 2 or more,

usually, and may be white or black. When the young men do their part

they are usually dressed all in black or black and white.

188. This entire prior paragraph was included in the Federal

suit in 2007 just before an attack (case 07-1940 filed in Washington D.C.)

The case was for several weeks illegally denied a case number then, although

D.C. did not deny jurisdiction, they refused to hear the case but remanded

it to Michigan in violation of due process. Then the plaintiffs house is attacked

by two men wearing black hooded sweatshirts, just as stated in the complaint.

When the plaintiff calls the police he is attacked, beaten, tasered, choked and

almost killed by the police. Bond is set illegally at 150,000.00, and the plaintiff

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is forced to undergo a government psychological evaluation to have him found

incompetent to stand trial and be put away forever and is charged with 3 felonies.

Then, when the plaintiff gets his own evaluation done first, they are outraged. After

that, when the plaintiff dumps 2 conspiring attorneys and wins the trial, the

prosecutor yells at the jury "but he's suing the FBI"! The intentional, malicious

retaliation here is obvious to anyone, is pure terrorism and attempted murder.

Plaintiff had to pretend he was dead and a local news crew to show for the the

beating, choking, and tasering to stop. It was broadcast on wxyz channel 7 news.

Channel 7 broadcast a report of the incident on the news with a video, and it was a

complete outrageous fraud and defamation. They cut and edited the tape to a point

it was nothing like what happened. They took out the whole first few minutes of

the police brutality and beating and one of the taser strikes and manipulated

the story in favor of the police as a form of deception and filthy propaganda.

189. Then when subpoenaed, WXYZ CHANNEL 7 refused to provide the full

length version and said they destroyed it, simply outrageous, not only that, but

the prior attorney Paul Shoenbeck also destroyed his copy of it after meeting with

prosecutor at the prosecutors house. Everyone was making deals to destroy the

evidence because what it really looked like was an attempted murder by the police.

Not only that, but in conspiring to present false testimony, channel 7 stated that

one of the news ladies from channel 7 was actually going to testify against the

plaintiff. But, after the conspiring federal court appointed attorney Sharon Woodside

was fired by the plaintiff, WXYZ channel 7 then decided not to provide their false

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testimony any longer. Plaintiff spoke with Richard Bernstein, and he showed

absolutely no concern for constitutional rights and his attitude was careless,

pompous, and negligent. He made the comment that he would go along with what

the other attorneys were doing and he would not help the plaintiff. Not surprisingly,

WXYZ channel 7 does most of their commercials, so this again is additional

obstruction, negligence, malpractice, and discrimination.

190 The denial of due process by the Wayne County courts is the primary

reason why the plaintiff is now in such a financial situation. The loss of his

house was caused by the illegal denial of a decision in his favor when he

won as a matter of law but denied his constitutional rights by Judge Baxter

and Judge Stephens of the Wayne County Courts and the Michigan Court

of Appeals and also denied a jury trial in conjunction with the blacklisting

for professional positions and the interfering of business relationships by

DDC, FBI, Homeland Security, State Attorney's offices and others.

191. The intent is to provide the plaintiff no way out, and it was inevitable

the plaintiff would lose everything. An attempt to find a roommate, rent the

house, or any other effort, just like the plaintiff's company, all options would

be made to be futile by the acts of the defendants, and the plaintiff took two

and a half years renovating his house. Certainly, the equity lost due to the

denial of due process rights is a consideration in the total losses.

192. January 8, 2008 plainitff again attempted to see his daughter and hired

attorney Ed Horan. Ed horan conspired with Judge Sjostrom to prevent any motions

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from being heard in court and denied visitation. Ed Horan took a deposit and signed

a contract to represent plaintiff then did nothing but conspire with the judge to

obstruct visitation in violation of the clear visitation orders. He even said, “another

attorney might file a motion for contempt and leave blood all over the court room

floor, but I am not going to do that”. That is how obviously in the right he knew the

plaintiff was. He mentioned that federal civil case was an issue that came up, so the

judges in Florida acted in retaliation and with knowledge of the federal civil case.

193. The plaintiffs efforts to sell his house have also been blocked in

efforts to deny a realtor. Just as they interfered with other business

relationships begin normally with a realtor and ends with a no show and

denial by the realtor, wasting time, obscure knowledge of plaintiff, denial

of completion while pending foreclosure. All to put the plaintiff "out on the

street" and waste his time in a sale by making it" break even" as the realtor

Bill Bury of Remax Partners stated making the effort futile and plaintiff pay

all costs in a unreasonable proposition given the equity, even in this market,

just as they blocked the sale and transactions of the plaintiff's Corvette.

194. The plaintiff called Remax, the call was handled by one realtor by

the name of Kathy, she handed it off to Bill Bury, after stating she needed

to check on some things, who called back and took a non specific walk through

and tried to talk plaintiff into filing for bankruptcy and "sticking it to the

mortgage company" and stringing out the foreclosure. He stated plaintiff

should call a bankruptcy attorney and maybe plaintiff do some of the work

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himself. plaintiff called Mr.Bury back the following day and stated he wanted

to list the house which seemed to annoy Mr. Bury.

195. An appointment was scheduled to take listing pictures on 10:00 a.m.

Saturday. September 2, 2007 Mr. Bury doesn't show, but calls at 10:00 after

the house is ready and states that he will give to another broker. Then calls

the plaintiff back a few minutes later and says nothing on the phone and

hangs up. The other broker by the name of Mary calls the plaintiff and states

she is too busy and would have to schedule at a later date and Bill told her

that the plaintiff was looking to "break even". Homeland security would make

nothing easy as they track every call like the FBI stated "if things got worse".

(exhibit#48 forclosure notice on plaintiff's house). Then the the federal Judge and

defendants attorney mention the transaction as well as work done to the house.

196. Mr. Green at DDC stated they would make it so "nothing was easy"

for the plaintiff and he would have to "go to another country" to get a job and

plaintiff would have to "kill his parents" or "rob a bank to have enough money

to see your daughter". Crawford stated "everyone will be against you". Just as

the State Attorney in Florida stated that bringing a retired Michigan Judge

down there he would be made to feel like a "fish out of water". The Willie

Meggs also stated to the plaintiff that he should get a law degree, surely for

him to also block any law practice the plaintiff would try to establish. These

and others, are blatant illegal acts of civil war and oppression on a citizen

of the United States. A restraining order will likely be required against some

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of the defendants. Green made the comment about the plaintiff never seeing

his daughter again in 2005; and since 2005 all contact the father had with his

daughter, including phone calls, has been blocked. Bob Green clearly had a

role in the continued illegal kidnapping and abduction just as Judge Davies

told the plaintiff he would work for Detroit Diesel before he even got the job. No

employer in their right mind would ever even consider making such outragous

disturbed comments about someones child. Obviously, there was prior knowledge

and malicious intent. Clearly this is an intimate and incriminating connection.

197. This behavior is consistent with the plaintiff being told by Leon

County Sheriff's Deputy Meeks that he should "stay up in Michigan" and that

the plaintiff is only making it harder on his daughter by trying to see her

and that "the more you come down the harder we will make it for her" just

as Bob Green stated "maybe you just wont be able to pick her up" and

mentioned plaintiff would have "rob a bank" or "kill your parents" to have

enough money to see his daughter again. It is all intertwined to take all the

plaintiff's money his child, health, dignity, home and future and make every

effort futile so as Mr. Green put it "nothing will be easy" and when Ed

Crawford stated "everyone will be against you" that meant everyone and

was not only entrapment but a declaration of civil war on a U.S. citizen.

198. Since the plaintiff will no longer have the protection of his own

property the defendants had intensified the harassment such has been

done after filing suit to retaliate. The plaintiff is offensively touched, or his

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personal items touched while shopping for food, or he is followed, every time

he leaves the house. People drive by laughing out loud at the plaintiff for

no reason, the plaintiff's windows are knocked on at night by kids, then

they run. Young men walk by the house talking out loud about how easy

it would be to steal the plaintiff's car. This is a component of the dire

predictions of illegal acts to accomplish and make good on the threats by

Detroit Diesel, Homeland Security, FBI, Florida and other law enforcement,

Florida and Michigan Attorney Generals, former wife, and others. Again,

reference Kotel comments and Cointelpro.

199. The former wife called Saturday Aug 11, 2007 to make a point of

asking where the plaintiff is going to be living. The plaintiff has not conversed

with her or anyone down there about anything concerning the foreclosure and

she does not usually call but to harass. Clearly the Florida authorities are

keeping tabs and other perpetrators informed on the progress of their plan.

SIXTEENTH COUNT

SEXUAL HARASSMENT AND DISCRIMINATION

SEVENTEENTH COUNT

VIOLATION TITLE VII OF CIVIL RIGHTS ACT OF 1964

200. All paragraphs are realleged and reaffirmed as if set forth herein.

201. The sexual harassment is composed of several perpetrators in an

extended period of time continuing to this day. The circumstances in

Florida, with Detroit Diesel, and the FBI and Homeland Security all include

related components of continuing sexual harassment and or discrimination.

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202. The daughter was abducted and father kidnapped and falsely

imprisoned based on sexual discrimination. Child abuse charges were

not filed against the former wife for attempting to coerce the child into

pornography. If two men had done the identical act they would have been

certainly immediately charged and jailed for such acts on a 7 year old.

In the meeting with the Florida State Attorney and agents the comment

was made "you want us to do for you what we did for her". The plaintiff

made it clear the difference was that the child is in danger and she actually

did something illegal as opposed to the baseless acts they did to the father.

203. When Detroit Diesel found out about the Florida case and the

Director Ed Crawford commented about the plaintiff having problems

with his former wife they immediately initiated a campaign of sexual

harassment against the plaintiff by Mary Cheeseman and Kim Gyenese,

co workers of the plaintiff who had previously posed no problems at

all. There were also extreme perverted acts by Bob Green.

204. Mary Cheeseman, who sat to the right of the plaintiff, had

extra cable added to her computer and her monitor was shifted from

inside the cubicle, to awkwardly facing directly toward the plaintiff

to stare over the monitor at the side of him constantly when they

used to be more or less back to back. She was the only one in the

department to have her computer position changed like this.

205. Mary and Kim Gyenese then began to tamper repeatedly with

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formulas on spreadsheets, that the plaintiff developed for specialized

purposes, they were instructed to do this act maliciously to cause

errors and distress. The plaintiff utilized a program in the system to

track which computer user and login ID made modifications to the

programs and they were traced to these two people.

206. The plaintiff had a conversation with Kim Gyenese a couple

of days later in the basement by the EDS offices. The plaintiff stated

that he knew what they were doing, Kim initially denied it but

when confronted with the facts of the tracking she stated "okay,

I did it, so what?" apparently confident she had been given permission

or instruction to do so and had no concern for the consequences and

even threatened to go to human resources for harassment although she was in fact the one harassing the plaintiff. She never did go to

H/R, the statement was just another baseless threat to harass the

plaintiff even further.

207. Plaintiff found shortly thereafter that agencies had been

contacted and he had been blacklisted, and if a position was

found the government agencies would interfere with other perspective

employers and the effort would be futile. The only option was to

stand by the constitution and his civil rights and hold them legally

accountable for the illegal behavior. Incidentally, the plaintiff was

proven correct when even business relationships were illegally

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interfered with when he later tried to build a company, only to be torn

apart by Homeland Security in acts having nothing to do with security

of the country at all, intent of the agency itself, and in violation of the

Constitution and Bill of Rights.

208. When Kim left the company, several months later, Mary began

harassing the plaintiff more than ever by intentionally changing spread

sheets nearly every time she would use them, requiring the plaintiff to fix

formula problems when she was simply to insert data. She would also miss

posting thousands of hours causing the government contracts to be

overcharged by increasing the labor and burden rate. The supervisor

Bob Green refused to address the contract issue and allowed the massive

errors to go unchecked intentionally inflating the rates for years.

209. While working on a separate project that Mary was to supply

personnel data, the information was not able tie and had to be reviewed

by the plaintiff several times. In a conversation with Mr. Green in regards

to the information Mr. Green stated, "she just doesn't like to do her

job" and "she's an asshole"

210. In effort to humiliate the plaintiff and discriminate on other counts

Mr. Green gave this so called "asshole" who "doesn't like to do her job" 10%

pay increases and promotions every year until she was making more than the

plaintiff; even though she had less education, responsibility, seniority,

abilities and had a difficult time doing operations. This was in conjunction

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with the plaintiff getting incrementally lower to no pay raise (10%,5%, 0%)

and being put on a fraudulent performance improvement plan with no basis

in fact while communicating this to other members in the group with less

seniority and no need for such information and even adding additional jobs

to the plaintiff's work load. Mary was also asked if she wanted to be a

manager which she turned down because it would have been more work,

this was also in violation of position requirements as company policy. The

intent is to give others what the plaintiff earns, has, or what they believe

he would want and is carried over to other like incidents.

211. This is just as happened with the City of Southfield when they

trespassed on the plaintiff's property cut off a huge branch from a

100 year old tree in the front of the house, dragged it across the lawn

tearing up the grass, ground it up and gave the chips to the lady across

the street and threw rocks from the truck on the plaintiff's lawn rather

than cleaning the area. The city never provided notice and a no

trespassing sign was clearly posted. One of the employees made the

comment that "If the feds say so, then you have to do it". (see exhibit

#35)

212. There were times churches were involved. When the plaintiff was

taking his daughter to Christ Our Savior church, things became increasingly

more harassing and difficult in the day care program. The plaintiff was

charged late fees on a small overdue balance when the mothers were not,

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and when plaintiff asked why he was paying late fees when the female

members were not, even when they were thousands in arrears, the plaintiff

was told "that is them". The plaintiff was later sued by the church for a

$347.25 balance in an outrageous act that other members said they had

never seen. This was additional acts of sexual discrimination and malicious

prosecution by the defendants. (exhibit# 49 summons and response) Larry

Butler at DDC asked where lauren was going for daycare before this happened.

213. Although Mary did take adverse action against the plaintiff by

direction of her superiors, she did make the statement, before the plaintiff

filed suit in September of 2005, that the plaintiff should "sue them after what

they have done to you" and "I'm sure what they have done has caused some

damage".

214. At Detroit Diesel, when the plaintiff asked Mr. Green if he could do

more than any other analyst he stated "definitely" and when requested for

detail of what constituted the poor evaluations no reason was ever provided

clearly demonstrating his own knowledge of the untruthfulness of his

own evaluations as having no basis in fact.

215. Mr. Green also proceeded to sexually harass the plaintiff by

coming up behind the plaintiff while he was seated at his computer and

reach over his shoulder rubbing the plaintiff's chest. Mr. Green also would

rub his crotch while looking at the plaintiff's genitals after pushing himself

out from behind his desk and spreading his legs. These sick, perverted acts

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would usually occur while working late in the evening, intended to effect

the plaintiff's ability to sleep. This has all been admitted to in prior cases.

216. The plaintiff was also sent perverted e-mails and sent a strange

e-mail which had a jpeg picture of a woman with horns holding a baby,

she was apparently intended to look like a version of Satan.

217. An engineer by the name of Larry Butler joined the controlling

group and was trained by the plaintiff. The plaintiff had car troubles and

Larry, having an extra car, offered to sell the car (a 1990 Grand Prix) to the

plaintiff on monthly payments if he could fix the mechanical problems

it had, he mentioned he had done it before (sold a spare car) to someone in

the company.

218. After the repairs were done, he said the car was his wife's and she

said she did not want to sell it and made the plaintiff speak with her

several times then afterwards required the plaintiff to return the car. After

the return Larry admitted he didn't need her permission to sell it. The

wife was simply in it for harassment purposes (which would become a

common theme with homeland security) to cause issues when the plaintiff

needed a vehicle, was previously promised, then again denied after several

dishonest fluctuations in the story.

219. As previously mentioned female operatives of Homeland Security

have been heavily involved in alienating the plaintiff to neighbors or contacts

especially to other women who the plaintiff may communicate with, even

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at churches, doctor's offices, or hospitals in efforts to do harm to the plaintiff

or deny him care.

220. The problems with health care would usually include the male

doctors denying service but usually the female doctors and nurses did the

overt specific acts infecting ear, injecting with allergens, rupturing vein with

needle causing hand to turn blue, excessive x rays in one position causing

poisoning. The illegal assaults from the former wife, failure to press charges,

attacks from women at the daughter's school and Meeks telling them that he

would arrest plainitff if they would just "say" that plaintiff hit them when

the plaintiff was the victim of the attack and provocation. The statement

from Willie Meggs "good for her if she can get away with breaking the law".

The retalitory police attack from Southfield Police was a female Police officer

doing the tasering shown to be enough to kill alone having been done twice

with full voltage. Not to mention the denial of jury trials and due process

rights by female Judges Coloca Johnson,Dekker, Baxter, Stephens, Attorney

General Quionnes (FDR), Attorney Marilyn Morris, Tann Hunt, Judge Robert

H. Cleland and other perpetrators.

EIGHTEENTH COUNT

ATTEMPTED MURDER

221. All paragraphs are realleged and reaffirmed as if set forth herein.

222. The defendants, with federal assistance, had contact with health

care providers and doctors to monitor the plaintiff's treatments and influence

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doctors to prevent proper care and or recovery and cause further illness and

death to the plaintiff. This was in conjunction with blacklisting, destroying

plaintiff's company, contacting neighbors and family, extortion, denial of due

process, interfering with contact with his daughter, retaliatory action,

increasing harassment directly after doctors visits and attempting to render

any treatment ineffective, kidnapping, false imprisonment, and others.

223. These illegal and criminal actions were taken with the assistance

knowledge and support of the FBI, Homeland Security and other state

and federal agencies in acts of terrorism and civil war.

224. The actions taken by the defendants with the direct and intimate

knowledge of the plaintiff's illness (s) and suseptablities constituted direct

and repeated attempts to kill the plaintiff. The plaintiff was on several

occasions denied treatment, improperly treated, or intentionally poisoned

by doctors and or nurses involved in his care. One such instance occurred

with Allergy associates on Orchard Lake road and the Doctor Rolla

Bakari-Panza in which the plaintiff rather than being given a cortisone

shot was injected with a massive dose of allergens which caused the

plaintiff to become very dizzy and bleed perfusely from the nose and

break out in hives. This act could have easily cause the plaintiff to go

into shock or have a heart attack.

225. The plaintiff approached doctor Panza with the findings and stated

that another doctor did a blood test and found there was no artificial

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cortisone in the blood tests and that she was trying to harm the plaintiff.

Dr. Panza did not deny that fact and was desperate to find out the name

of the other doctor was, as if she would go after him.

226. This is the same doctor that ran allergy tests on the plaintiff

and reported that every one of the tests came out negative to mislead the

plaintiff and deny him proper treatment. When the identical tests were

performed by another doctor the results were completely different from

the results from Dr. Panza. This was several identical tests which renders

incompatibility on all counts statistically nearly impossible having stopped

all medications before testing. (exhibit #43 allergy test comparisons)

227. Homeland Security and other defendants with knowledge of the

plaintiff's medical problems and allergies would instruct people to intentionally

attempt to provide food while illegally incarserated that would cause the plainitff

allergic reactions, create a never ending campaign of harassment to intensify

the effect, and instruct doctors not to provide the plaintiff proper medical attention

in attempts to cause further harm and eventual death of the plaintiff. Since

the plaintiff wrote his book and has found other who have been persecuted

nearly all the health problems have subsided and the plaintiff is ready to continue

with this case through all appeals if necessary and stay for the long haul.

228. The plaintiff went to ENT surgical associates Sept. 2002 to get help

for a severe allergic reaction and stress and was given several tests by Doctor

Rochen but was given nothing to reduce the severe swelling. plaintiff asked

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him for some sort of medication for a severe reaction and no cortisone shot

was provided. He stated he would take care of it the "natural way" while the

plaintiff was in severe pain. The plaintiff had to take his own doses of

Ibuprofen to reduce the swelling enough to even see clearly. The plaintiff

then went to see Dr. Brandes who provided no assistance and stated that

he could not help the plaintiff and was intentionally rude and forceful to

aggravate the condition, which also effected balance. He pushed the

plaintiff with force when the plaintiff was leaving the office, the condition

was known to get worse with stress and Dr. Brandes, with malice, provided

some personally, to intentionally aggravate the condition.

229. Later, when the plaintiff had to see another doctor for help, he

explained what happened and the doctor said "it was doctor Brandes wasn't

it?". The plaintiff never mentioned what doctor or where he had been seen.

Dr. Brandes evil tactics are apparently very well known in the medical

community. His name was the first name mentioned as an immediate

response by the other doctor.

230. The plaintiff was seeing Dr. Whebe at DMC health care center,

plaintiff was told to come in to a doctors office after complaining that

the medication was not working and caused a very sore throat and chest,

the doctor instructed the plaintiff to come in and the prescription would

be changed. When the plaintiff arrived he was asked if the plaintiff had a

family history of heart attacks at a young age and was not given a different

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medication, but more of the same which was making him ill.

231. When the plaintiff came back to work Mr. Green made comments

about the doctors visit and that he knows Dr. Whebe. Green was never

informed as to who the plaintiff was seeing for treatment. The doctor also

mentioned a trip being scheduled for the plaintiff that only employees

at DDC would have known demonstrating knowledge of specific private

facts shared by the perpetrators by using the company insurance card.

232. When the plaintiff went to Botsford hospital emergency room he

was put into a room where the nurse was to take blood. The nurse

inserted the needle several times on different angles without removing

it completely, stating she could not find a vein, which no one has ever

stated to the plaintiff, and caused the vein to bleed under the skin and

turn the plaintiffs hand blue then a pregnant woman wearing all black

walked in and the nurse said to her, "I blued him" and hung up a sodium

drip which plaintiff asked them not to attach after reading the label. The

woman in black stood there a few minutes not saying a word then left.

A security guard then came in and told the plaintiff he would have to

leave and they could not help him. (exhibit #44 Botsford receipt)

233. The plaintiff's supervisor, Mr. Green, would make comments about

a doctors visit and even mention the doctor by name when no information

as to the doctors name was ever mentioned to Mr. Green, he would then

harass the plaintiff and have him do jobs that would specifically aggravate

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the condition he had gone to the doctor to be treated for.

234. The plaintiff was also seeing Dr. Michaelides for ear infection,

he refused to medicate the plaintiff's bacterial infection, intentionally

mislead the plaintiff about the condition and severe pain and refused a

tube for the inner ear infection until the plaintiff told him that a

doctor in the emergency room said he should. After he put the tube in,

he did not prescribe any antibacterial ear drops for the infection, the

plaintiff finally got the drops from yet another doctor with pills and

it cleared the infection. This infection, if left alone, would likely have

caused a cancer, or tumor of the brain or inner ear. Dr. Michaelides

intentions were to cause permanent injury and or death to the plaintiff

by establishing a chronic condition and extort insurance money. After

the plaintiff informed Dr. Michaelides that another doctor completely

refuted his findings and cured the bacterial infection June 5, 2004, he

moved his practice to Atlanta a few months later in November of 2004.

(exhibit#45 10.19.04 Michaelides letter)

235. The plaintiff went to Oakwood emergency room on March 25, 2005

and had a cat scan done and some x rays. One radiologist was taking the

x rays and another one comes in and states that she needs to make some of

one certain neck area. She proceeded to take approximately 15 (additional )

x rays of the exact area without moving this caused radiation poisoning and

the plaintiff to become very ill and throw up when he got home. After she

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had taken the additional shots she stated to the other radiologist that the

ones that were originally taken were okay, and she didn't even need the several

she had just taken. (exhibit#46 Oakwood receipt)

236. The plaintiff saw Dr. Seel to have the tube removed once the

ear infection was clear and he was instructed to keep water out of the ear

to prevent infection. When the plaintiff went in for a check on the

ear, Dr. Seel was out and doctor LePoudre took his place. While

looking in the ear to inspect the paper over the wound she took small

plastic bottle and squirted hard, a large amount of "water" or liquid directly

into the healing ear onto the injury intending to cause an infection to the

complete shock of the plaintiff , this act did in fact cause a reinfection

due to her malicious act. (exhibit#47 ENT LePoudre receipt)

237. If the plaintiff did not use his principal insurance card, there was a

much better chance of receiving proper care. The insurance company

through Detroit Diesel supplied the defendants information on specific

visits. Clear connections can be drawn between this, and actions taken by

companies the plaintiff was dealing with and improper work performed

and defendants efforts to make good on their numerous threats and cover

other prior repeated illegal acts and commit new ones. Once the FBI is involved

in persecuting someone, as happened with the kidnapping in 97', they keep

tabs on that person indefinitely because they are paranoid of retaliation; and if

the victim does not submit to illegal oppression and fights it, the terrorism continues

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and if sued they try to make the person disappear by illegal incarceration,

fraudulent psychological evaluations, false testimony, trumped up charges or

assassination and planted in a cornfield somewhere. All of which is validated here

by circumstances happening to a completely innocent pastor and author. Again, a

textbook case of Cointelpro terrorism.

NINETEENTH COUNT

DEFAMATION (LIBEL AND SLANDER)

238. All paragraphs are realleged and reaffirmed as if set forth herein.

239. plaintiff was defamed when falsely imprisoned and friends and

relatives were made aware. There are also continuing acts in that the plaintiff

is illegally being denied visitation with his daughter as if he has done

something wrong, and the redicilious and fraudulent grand theft charges,

although dropped, still show up on the plaintiff's record as an entry.

240. The reason for the Grand Theft charges still showing on the plaintiff's

record, even though they were dropped, is to defame the plaintiff forever and

label the plaintiff a "crook" to make any entrapment scheme such as trying

to "stick it to the mortgage company" as the real-estate broker Bill Bury

suggested, look that much more believable or make getting a job nearly

impossible in the accounting field. The Willie Meggs chose Grand

Theft because it plays right into plaintiff's career as an auditor, analyst

and accountant. The 2nd Circuit Court of Appeals also posted a ridiculous and

intentionally fraudulent decision on the internet when all allegations were

admitted to and the amended claim was unopposed. This is posted online and would

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show up when the plaintiff would attempt to secure a job; falsely defaming

the plaintiff while also maliciously denying a decision won as a matter of law.

Again, refer to the Cointelpro findings and specific tools they use.

241. After the Willie Meggs Conspired with the plaintiff's defense

attorney(s) and convinced them to throw the case, not only was the fraudulent

and nolle processed grand theft charge put on his record to stay, but the

defamitory mug shot is posted online. Homeland Security uses this information

that the plaintiff has a grand theft and other made up charges on his record

when communicating with anyone they wish to convince to take adverse

action against the plaintiff. Both postings are by Florida authorities and

only Florida authorities and are intentionally to illegally label the plaintiff

a crook or a criminal for the rest of his life. There is also posted by The

State of Florida a mug shot of the plaintiff when he was kidnapped which also

shows up on a Google search.

242. Mr. Moye', the plaintiffs criminal attorney in the fraudulent grand

theft, prior to being hired stipulated that nothing would be allowed to show

up on the plaintiff's record so as not to adversely effect the plaintiff's career

or future, but instead initiated the defaming, illegal, nolle processed charges

to be listed violating his responsibilities to his client.

243. The Leon county Sheriffs Department defamed the plaintiff in front

of his daughters friends by denying his right to custody and visitation

also contributed by Desoto Trail Middle School staff and by the actions of

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officer Meeks. The plaintiff's daughter even said, "why are trying to make

you look like a bad daddy, why are they doing this?" (see exhibit#17)

244. Detroit Diesel manager Bob Green filed a report with the FBI and in

the complaint stated many slanderous accusations not founded in fact but

in an effort to destroy the plaintiff's life, liberty pursuit of happiness and

career and do irreparable harm to his entire future.

245. The plaintiff was fraudulently evaluated in his job performance

evaluations make specific reference to derogatory terms to untruthfully

describe the plaintiffs performance without detail to substantiate, the

plaintiff is left with 5 1/2 years of his employment which cannot be used

for a reference and makes a proper, marketable resume impossible.

Additionally, the evaluations to not elaborate on what accounts for the

substandard performance and in so gave the plaintiff nothing to correct

or act upon and is defamation per se. Lower level employees with no

relevant interest in the evaluations were provided notice of the adverse

evaluations given to the plaintiff.

246. The FBI contacted family members and made several false misleading

and defamatory statements about the plaintiff such as the plaintiff is "high

strung" and had "a nervous breakdown" to defame the plaintiff, cause doubt,

and interfere with family relations and contact.

247. As stated by Ed Crawford a director at Detroit Diesel, they were

going to make it so that "everyone" was against the plaintiff. This included

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staging incidents designed to parade a wide array of people around the

plaintiff at work and outside of work to be arbitrarily offensive or rude and

to create a wide ranging and oppressive environment to prevent the plaintiff

from functioning in a productive way in society with the malicious intent to

provoke extreme anxiety and a complete destruction of the plaintiff's freedoms

and liberties and any prospect of future success. All of the statements

made at Detroit Diesel also represent the activities still being pursued by

Detroit Diesel, Homeland Security and the FBI and other authorities against

the plaintiff in violation of the U.S. Constitution and basic internationally

recognized human rights.

248. Communications that the FBI and Homeland security had with

neighbors, business contacts and others constituted defaming the plaintiff

and conspiring with contacts in illegal acts of fraud and other torts in taking

adverse action against the plaintiff without any justification, basis in fact, or

legitimate legal reason but in an attempt to adversely label the plaintiff in

ways to make it appear that everyone was against the plaintiff. The game

plan was clearly stated by Leon County Sheriff Larry Campbell, Deputy John

Meeks, Mandy Luttenton, Florida Attorney General Willie Meggs, FBI agent

Dave Kotel, FBI supervisor Toni Charabot, Supervisor Bob Green, Director

Ed Crawford, Vice President DDC Walter Puetz and others. The statements

that the plaintiff would have to "go to another country to get a job" or "rob

a bank" or "kill your parents" to have money to see his daughter and that

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"everyone will be against you", "the war will be against you" and "kind of like

being in a prison, isn't it?" are so outrageous and extreme that the acts to

make good on them would also have to be outrageous and extreme and do

in fact include the illegal actions of people employed by the government as

evidenced by the signed documents, exhibits, actual statements and factual

occurrences and admissions in legal proceedings.

TWENTIETH COUNT

CHILD ENDANGERMENT

249. All paragraphs are realleged and reaffirmed as if stated herein.

TWENTY-FIRST COUNT

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

250. All paragraphs are realleged and reaffirmed as if stated herein.

TWENTY-SECOND COUNT

VIOLATION OF THE FOURTH AMENDMENT

ILLEGAL SEARCH AND SEIZURE

251. All paragraphs are realleged and reaffirmed as if stated herein.

TWENTY-THIRD COUNT

VIOLATION OF THE EIGHTH AMENDMENT

CRUEL AND UNUSUAL PUNISHMENT

EXCESSIVE FINES AND BAIL

252. All paragraphs are realleged and reaffirmed as if stated herein.

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TWENTY- FOURTH COUNT

POLICE BRUTALITY

253. All paragraphs are realleged and reaffirmed as if stated herein.

CONCLUSION

254. The plaintiff's entire life and future have been illegally , maliciously

and without cause destroyed. Everything he had, child, career, home, savings

retirement, freedom, liberty has been illegally continually and violently

ripped away by the illegal and criminal acts of federal government and

others. These acts have been intentional, and violently in opposition to the

Constitution of these United States and have included attempted murder

and continuing attempts to put the plaintiff in prison one way or another

and completely block his access to the judicial system, and in fact use it

illegally as a weapon. This is and represents a civil war and acts terrorism

against all citizens of the United States and warrants a detailed Senate

investigation as to what these criminals have done as a whole to our country

and innocent people. Surely these and other groups of tyrannical freaks have

already killed and imprisoned many other good innocent American citizens

before, just as they have done and are attempting to do to the plaintiff

right now; just as the Chruch Senate investigation on the illegal FBI Cointelpro

program verified. It is is still being used. Wikipedia search Cointelpro.

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PRAYER FOR RELIEF

255. WHEREFORE. The plaintiff, Pastor Daniel L. Meier, requests a trial

by jury and that the court adjudge and decree the defendant(s) are liable for

the torts and other conduct both civil and criminal asserted herein and enter

a judgment for Pastor Daniel L. Meier and against the defendants listed herein

and award Pastor Daniel L. Meier compensation for all damages in addition to:

A. Allocated monetary damages attributable to the defendant to

compensate Pastor Daniel L. Meier the costs that he bears as the result of the

defendants conduct, in excess of the jurisdictional requirements of the

court.

B. Punitive damages in an amount to reflect and compensate for

the fact the defendants conduct was malicious, willful and wanton such

as to demonstrate a reckless disregard for the rights of the plaintiff.

C. Exemplary damages to establish that this behavior is outrageous

and intolerable in a civilized society.

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