InfoTelesys Lawsuit: I. CLAIMS UPON WHICH RELIEF CAN BE GRANTED /
CONSTITUTIONAL RIGHTS VIOLATED
Forth Claim For Relief Aggravated Battery and Aggravated Assault
PLAINTIFFS:
Clive Boustred, RCB, WEB
DEFENDANTS:
MICHAEL MACDONALD, Michael Macdonald (Santa Cruz
Deputy Sheriff)
VIOLATION OF CIVIL RIGHTS & ULTIMATE FACTS
On or about March 10, 2003, in the above named
Judicial District, the crime of AGGRAVATED BATTERY and AGGRAVATED
ASSAULT, in violation of Common Law and the Constitution of the United
States of America and the 4th, 5th and 14th
Amendments there to and PC § 34 and 37, a felony and misdemeanor
respectively, was committed by MICHAEL MACDONALD, who did willfully and
unlawfully under the color of law commit said crimes against PLAINTIFFS
by discharging his firearm by shooting at PLAINTIFFS with a deadly
weapon.
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!
On March 10, 2003 Santa Cruz Shooting Instructor
Deputy Sheriff Michael Macdonald ran up to Plaintiff Clive Boustred’s
vehicle on Mr. Boustred private property and from a range of five to
seven feet shot at Mr. Boustred. The bullet missed and slammed into the
door of Mr. Boustred’s vehicle. WFB, Mr. Boustred’ son aged three was
in the direct line of fire just behind Mr. Boustred, his seven year old
son RCB was about two feet off the line of fire.
Mr. Boustred was returning home from the Santa Cruz
Superior Court house where he had just filed a Temporary Restraining
Order and Verified Criminal Complaint against his ex wife Anamaria
Tichatschke (Formerly Anamaria Boustred) and former Personal Assistant,
STEFAN TICHATSCHKE for endangering WFB by abandoning WFB in the middle
of a learner ski run and for resuming false 911 calls.
Before the Deputy Sheriff shot at Mr. Boustred, the
Santa Cruz Sheriffs were aware Mr. Boustred was returning home from the
Santa Cruz Court house. The Sheriffs were also aware that Mr.
Boustred’s ex wife Anamaria made false 911 calls and was ordered out of
the family home eight months earlier. The Sheriffs were also aware that
Anamaria had a stolen million dollar life insurance policy on Mr.
Boustred’s life, as Mr. Boustred had formerly filed a complaint
detailing the stolen insurance policy with that very same Sheriffs
office. And the sheriffs were in possession of the Stipulated Custody
Agreement and Order that showed the Mr. Boustred was not violating any
court order.
Deputy Macdonald was prevented from taking a second
shot by Sgt. Amy Christy.
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:
§ 34 Aggravated Battery
Aggravated Battery is a battery committed with a
dangerous weapon - A FELONY
§ 37 Aggravated Assault
Aggravated assault is an assault committed with a
dangerous weapon - A MISDEMEANOR
Fifth Claim For Relief Battery and Assault
PLAINTIFFS:
Clive Boustred
DEFENDANTS:
BROZOZOWSKI, Brozozowski (Santa Cruz Deputy
Sheriff)
VIOLATION OF CIVIL RIGHTS & ULTIMATE FACTS
On or about March 10, 2003, in the above named
Judicial District, the crime of AGGRAVATED BATTERY and AGGRAVATED
ASSAULT, in violation of Common Law and the Constitution of the United
States of America and the 4th, 5th and 14th
Amendments there to and PC § 33, a felony, was committed by BROZOZOWSKI,
who did willfully and unlawfully under the color of law commit said
crimes against PLAINTIFF by cutting PLAINTIFFS wrist with handcuffs and
by drilling the knuckle of his fist into the nape of PLAINTIFFS neck.
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:
§ 33 Battery Defined
Battery is the intentional use of force or violence
upon the person of another;
§ 38 Simple Assault
Simple assault is an assault committed without a
dangerous weapon.
A MISDEMEANOR. |