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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.

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