InfoTelesys Lawsuit: I. CLAIMS UPON WHICH RELIEF CAN BE GRANTED / CONSTITUTIONAL RIGHTS VIOLATED
Claims 13 & 14 Libel & Slander
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.