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

Seventeenth Claim For Relief    Violation of U.S. Const. 1st Amendment Freedom of Speech

U.S. Constitution, Amendment II: “A well regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear arms, shall not be infringed.”

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

Paula Simmons

County of Santa Cruz

State of California

Judge Paul R. Burdick

Jon Doe’s, 1 to n.

VIOLATION OF CIVIL RIGHTS & ULTIMATE FACTS

On or about October 18, 2007, John A. Christerson (CA State Bar 889096), Dennis J. Kehoe (State Bar 34687), Leonard Dueck (VP Twin Lakes Baptist Church, Inc.) filed a “CH-100 Request for Order to Stop Harassment” seeking the following: That “Clive Boustred is not allowed to contact or communicate with any students and/or families and/or employees of Twin Lakes Christian School or Twin Lakes Church by telephone, letter, electronic communication or otherwise.”.  Said lawsuit was filed in violation of Petitioner Clive Boustred, RCB and WFB’s First Amendment rights.  On October 18, 2007, Judge Paul R. Burdick issued an order restricting Petitioner Clive Boustred from communicating with four thousand members of the Church where Clive Boustred is a member or from entering the property of said Church.  Twin Lakes Baptist Church, Inc. filed to have the case heard on Halloween.  The Case was brought before the Honorable Judge Robert Atack.  The court found insufficient evidence to support the issuance of any restraining order and the order restraining Clive Boustred was dissolved.

In January of 2008 Paula Simmons instructed RCB that he may not exercise free speech and ordered RCB to not talk about the government and associated current events.  Paula Simmons not only violated RCB’s right to free speech, she set such a poor example for a child of learning age oppressing an eleven year old child is hardly admirable, especially when the adult is incompetent of answering the child’s legitimate and well constructed questions regarding facts and issues relating to current government.  Teaching children about the tremendous Constitution of the United States of America is something teachers should aspire to and not silence.

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.

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