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InfoTelesys Lawsuit: I. CLAIMS UPON WHICH RELIEF CAN BE GRANTED / CONSTITUTIONAL RIGHTS VIOLATED

Sixteenth Claim For Relief    Wrongful Civil Proceedings / Abuse of Process

PLAINTIFFS:

Clive Boustred, RCB and WFB

DEFENDANTS: 

DENNIS J. KEHOE (State Bar 34687), Dennis J. Kehoe

Dennis Kehoe Law Corp.

JOHN A. CHRISTERSON (CA State Bar 889096), John A. Christerson

LEONARD DUECK (VP Twin Lakes Baptist Church, Inc.), Leonard Dueck

Twin Lakes Baptist Church, Inc.

MARK SPURLOCK, Mark Spurlock

Jon Doe’s, 1 to n.

VIOLATION OF CIVIL RIGHTS & ULTIMATE FACTS

On or about October 18, 2007 and October 31, 2007 (Halloween) and on other occasions, in the above named Judicial District, the crime of WRONGFUL CIVIL PROCEEDINGS / ABUSE OF PROCESS, in violation of Common Law and the Constitution of the United States of America and the 1st, 2nd, 4th, 5th, 6th, 7th, 8th, 9th, 10th, 13th, 14th Amendments thereto, was committed by DEFENDANT/S listed above, who did willfully and unlawfully commit said crimes and civil violations.

DEFENDANTS engaged in the blatantly wrongful institution of civil proceedings by filing an absurd case against Respondent Clive Boustred where DEFENDANTS sought to prohibit Clive Boustred from communicating with his own children RCB and WFB and where DEFENDANTS did prohibit Clive Boustred from attending or communicating with approximately four thousand members of the Church where Clive Boustred is a member.  DEFENDANT’s actions were malicious and intentional, DEFENDANTS have also caused other significant damage to Clive Boustred, RCB and WFB, including SLANDER, LIBEL, GRAND THEFT AUTO, MALICIOUS PROSECUTION, PARENTAL ALIENATION and KIDNAP, which is also alleged and charged herein.

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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