InfoTelesys Lawsuit: I. CLAIMS UPON WHICH RELIEF CAN BE GRANTED /
CONSTITUTIONAL RIGHTS VIOLATED
Fifteenth Claim For
Relief Intentional/Negligent Infliction of Emotional
Distress, Fraud/Deceit, Wrongful Civil Proceedings / Abuse of Process
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 or about February 20, 2003 and other dates, in
the above named Judicial District, the crime of INTENTIONAL/NEGLIGENT
INFLICTION OF EMOTIONAL DISTRESS and or FRAUD/DECEIT and or WRONGFUL
CIVIL PROCEEDINGS / ABUSE OF PROCESS, in violation of Common Law and the
Constitution of The United States of America, was committed by
DEFENDANT/S listed above, who did willfully and unlawfully commit said
crimes.
On or about February 20, 2003, in violation of
Rules 7-103 and 7-108 of the Rules of Professional Responsibility and
Conduct of The State Bar of California and without any basis for an
urgency and without giving proper notice in violation of section § 240
of California’s Family Code and also without any legal basis, DEFENDANT
Vicki J. Parry called an unethical and unlawful ex parte hearing to
“clarify” an order prohibiting Petitioner Clive Boustred’s former
personal assistant and his wife’s lover, DEFENDANT Stefan Tichatschke,
from contact with RCB and WFB. Vicki J. Parry unlawfully secured a void
Order unlawfully granting Stefan Tichatschke the right to have contact
with Petitioner’s RCB and WFB.
On repeated occasions following sad abuse of
process on February 20, 2002, DEFENDANTS Samuel S. Stevens, Art Danner
(Deceased), Michael E. Barton, Trilla E. Bahrke, William M. Kelsay,
Irwin Joseph, Phyllis J. Hamilton, DEFENDANT, Michael Macdonald, Amy
Christy, M Pool, Mark Tracy, Hemmingway (Deceased), Brozozowski,
Griffin, Steven Drottar, Bob Lee, Bill Doyle, Christopher M. Cattran,
Anamaria Boustred, Steffan Tichatschke, Genworth Financial, Gregor Guy
Smith, Robert Frandeen, Paul Meltzer, Vicki J. Parry, Jason M. Heath,
Raven Harris, Angela Glass, and Jon Doe’s 1 to n. Intentionally and/or
Negligently Inflicted Emotional Distress and committed Fraud and engaged
in Racketeering and Wrongful Civil Proceedings / Abuse Of Process
against PLAINTIFFS. Including the filing of as many as seven false
cases against PLAINTIFF Clive Boustred, kidnapping RCB and WFB and
holding them hostage from their father Clive Boustred who they
repeatedly threw in jail on absurd charges.
DEFENDANTS' conduct as described herein was not
only outrageous it was intentional and malicious, or at the least
grossly negligent, exhibiting a reckless disregard for plaintiffs'
rights and conspiring against plaintiffs, causing plaintiffs to suffer
humiliation, mental anguish, financial burdens, excessive court hearings
and need to answer false charges, stress and emotional and physical
distress and plaintiffs were injured financially and in mind and body
all to their damage in amounts according to proof. DEFENDANTS owed a
duty to plaintiffs not to cause the harm as herein alleged. DEFENDANTS
breached said duty.
The aforementioned acts of DEFENDANTS were willful,
wanton, malicious and oppressive and justify the awarding of exemplary
and punitive damages in amounts according to proof.
Further evidence relating to said crimes are
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. |
