InfoTelesys Lawsuit: I. CLAIMS UPON WHICH RELIEF CAN BE GRANTED /
CONSTITUTIONAL RIGHTS VIOLATED
Thirteenth Claim For Relief Liable / Defamation of Character
PLAINTIFFS:
All PLAINTIFFS
DEFENDANTS:
IRWIN JOSEPH, Irwin Joseph
SAMUEL S. STEVENS, Samuel S. Stevens
MICHAEL E. BARTON, Michael E.
Barton
ANAMARIA BOUSTRED/TICHATSCHKE, Anamaria
Boustred/Tichatschke
STEFAN TICHATSCHKE, Stefan Tichatschke
VICKI J. PARRY, Vicki J. Parry
JOHN A. CHRISTERSON (CA State Bar 889096), John A.
Christerson
DENNIS J. KEHOE (State Bar 34687), Dennis J. Kehoe
LEONARD DUECK (VP Twin Lakes Baptist Church, Inc.),
Leonard Dueck
Twin Lakes Baptist Church, Inc.
MARK SPURLOCK, Mark Spurlock
JAMES WARE, James Ware
TRILLA E. BAHRKE, Trilla E. Bahrke
CHRISTOPHER M. CATTRAN, Christopher M. Cattran
PHYLLIS J. HAMILTON, Phyllis J. Hamilton
COUNTY OF SANTA CRUZ, County of Santa Cruz
STATE OF CALIFORNIA, State of California
UNITED STATES OF AMERICA, United States of America
BILL LOCKYER, Bill Lockyer (Former California State
Attorney General)
PAUL T HAMMERNESS, Paul T Hammerness (Deputy
Attorney General)
TROY B. OVERTON, Troy B. Overton (Deputy Attorney
General)
JASON M. HEATH, Jason M. Heath (Assistant County
Counsel, Santa Cruz)
DANA MCRAE, Dana McRae (County Counsel, Santa Cruz)
MARK TRACY, Mark Tracy (Former Sheriff)
MICHAEL MACDONALD, Michael Macdonald (Deputy
Sheriff)
M POOL, M Pool (Deputy Sheriff)
HEMMINGWAY, Hemmingway (deceased)
AMY CHRISTY, Amy Christy
BROZOZOWSKI, Brozozowski
BOB LEE, Bob Lee (Santa Cruz District Attorney)
STEVE DROTTAR, Steve Drottar
ANGELA GLASS, Angela Glass
RAVEN HARRIS, Raven Harris,
Santa Cruz Board of Directors
Jon Doe’s, 1 to n.
VIOLATION OF CIVIL RIGHTS & ULTIMATE FACTS
On multiple occasions far to numerous to mention
starting on March 10, 2003 during almost every hearing, pleading or
communiqué, in the above named Judicial District, the crime of LIABLE
and DEFAMATION, in violation of Common Law and the Constitution of the
United States of America, was committed by DEFENDANTS, who did willfully
and unlawfully commit LIABLE, DEFENDANTS having knowledge that their
actions were LIBELOUS and would cause PLAINTIFFS damage.
Further evidence relating to said LIBEL is
incorporated in each of the other Claims for Relief’s “VIOLATION OF
CIVIL RIGHTS & ULTIMATE FACTS” section and Exhibits and incorporated
herein by reference.
DAMAGES
As a proximate consequence of the willful and
malicious actions of DEFENDANTS, PLAINTIFF’S have sustained
extraordinary damage in a sum to be determined per proof, including
severe and extreme emotional stress and anguish, parental alienation,
lost time, lost business investments, lost business and prosperity,
damaged reputation including both slander and libel, interference with
the pursuit of happiness, loss of domestic tranquility, loss of general
welfare, and the loss of basic liberties such as enjoying life with
one’s own children!
Damages incurred by Plaintiffs as a direct or
indirect consequence to the above mentioned and referenced actions by
DEFENDANTS are also incorporated herein as listed in the “K DAMAGES”
section of this Complaint.
AUTHORITIES
AUTHORITIES in section “K. COMMON AUTHORITIES” are
incorporated herein by reference in addition to the following
AUTHORITIES:
Fourteenth Claim For Relief Slander
PLAINTIFFS:
All PLAINTIFFS
DEFENDANTS:
IRWIN JOSEPH, Irwin Joseph
SAMUEL S. STEVENS, Samuel S. Stevens
MICHAEL E. BARTON, Michael E.
Barton
ANAMARIA BOUSTRED/TICHATSCHKE, Anamaria
Boustred/Tichatschke
STEFAN TICHATSCHKE, Stefan Tichatschke
VICKI J. PARRY, Vicki J. Parry
JOHN A. CHRISTERSON (CA State Bar 889096), John A.
Christerson
DENNIS J. KEHOE (State Bar 34687), Dennis J. Kehoe
LEONARD DUECK (VP Twin Lakes Baptist Church, Inc.),
Leonard Dueck
Twin Lakes Baptist Church, Inc.
MARK SPURLOCK, Mark Spurlock
JAMES WARE, James Ware
TRILLA E. BAHRKE, Trilla E. Bahrke
CHRISTOPHER M. CATTRAN, Christopher M. Cattran
PHYLLIS J. HAMILTON, Phyllis J. Hamilton
COUNTY OF SANTA CRUZ, County of Santa Cruz
STATE OF CALIFORNIA, State of California
UNITED STATES OF AMERICA, United States of America
BILL LOCKYER, Bill Lockyer (Former California State
Attorney General)
PAUL T HAMMERNESS, Paul T Hammerness (Deputy
Attorney General)
TROY B. OVERTON, Troy B. Overton (Deputy Attorney
General)
JASON M. HEATH, Jason M. Heath (Assistant County
Counsel, Santa Cruz)
DANA MCRAE, Dana McRae (County Counsel, Santa Cruz)
MARK TRACY, Mark Tracy (Former Sheriff)
MICHAEL MACDONALD, Michael Macdonald (Deputy
Sheriff)
M POOL, M Pool (Deputy Sheriff)
HEMMINGWAY, Hemmingway (deceased)
AMY CHRISTY, Amy Christy
BROZOZOWSKI, Brozozowski
BOB LEE, Bob Lee (Santa Cruz District Attorney)
STEVE DROTTAR, Steve Drottar
ANGELA GLASS, Angela Glass
RAVEN HARRIS, Raven Harris,
Santa Cruz Board of Directors
Jon Doe’s, 1 to n.
VIOLATION OF CIVIL RIGHTS & ULTIMATE FACTS
On multiple occasions, far to numerous to mention
during almost every hearing, pleading or communiqué, in the above named
Judicial District, the crime of LIABLE, in violation of Common Law, was
committed by DEFENDANTS, who did willfully and unlawfully commit LIABLE,
DEFENDANTS having knowledge that their actions were LIBELOUS and would
cause PLAINTIFFS damage.
Further evidence relating to said SLANDER is
incorporated in each of the other Claims for Relief’s “VIOLATION OF
CIVIL RIGHTS & ULTIMATE FACTS” section and Exhibits and incorporated
herein by reference.
DAMAGES
As a proximate consequence of the willful and
malicious actions of DEFENDANTS, PLAINTIFF’S have sustained
extraordinary damage in a sum to be determined per proof, including
severe and extreme emotional stress and anguish, parental alienation,
lost time, lost business investments, lost business and prosperity,
damaged reputation including both slander and libel, interference with
the pursuit of happiness, loss of domestic tranquility, loss of general
welfare, and the loss of basic liberties such as enjoying life with
one’s own children!
Damages incurred by Plaintiffs as a direct or
indirect consequence to the above mentioned and referenced actions by
DEFENDANTS are also incorporated herein as listed in the “K DAMAGES”
section of this Complaint.
AUTHORITIES
AUTHORITIES in section “K. COMMON AUTHORITIES” are
incorporated herein by reference. |
