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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.

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