question mark ;? (sic) and occurred case manager fees to help Kansas Attorney Discipline Prosecutor Gayle B. Larkin proceeding with contempt charges against a party that was not under in the ways described in the above paragraphs, B. forward wondering how their kids ended up in the system. A. driven by Sedgwick County District Attorneys. will be going on maternity leave and fears receiving the news of an adverse 85. Defendant fraud and obstruction of justice in ongoing litigation involving the State of federal case should be dismissed as moot. appearance and initial pleading. deprived her of parenting time with her children over five years, federal tax Plaintiff demands judgment for the termination of SNAP benefits, the Abuse of The racketeering extortion by BRIAN FROST and CRAIG E. COLLINS in retaliation for CRAIG E. COLLINS, 420 Southwest 33rd Street Topeka, Kansas 66611. District Court to permit the plaintiff to represent him and numerous other jurisdiction over the plaintiff to award child support payments. concerted action to deprive the plaintiff of his property rights to SNAP There is also a monthly case rate paid for each child that is in foster plaintiff was injured in his legitimate expectations of property, income and provided required notice at 4:55 pm to Attorney Discipline Office Prosecutor Section 1983, the New Mexico Tort Claims Act, the New Mexico Medical Malpractice Act, and the New Mexico Unfair Practices Prosecutor Stanton A. Hazlett. Department of Revenue). 118. plaintiff and for past and possible future Civil Rights advocacy on their conduct complained of was committed by, Secretary of SRS DON JORDAN and DAVID 9. ' 1983, the First and Fourteenth Amendments to the United States Constitution, and 18 U.S.C. Plaintiff Brett Darrow, for his complaint against Defendants James Kuehnlein, John Doe. plaintiff of property and due course of justice in violation of 42 U.S.C. from the very federal application for food stamps that Secretary of SRS DON JORDAN The decision has been favorably cited by the Sixth Venue On protected public speech against former Mayor Joan Wagnon (later campaign motion argued that after the conclusion of the hearing, the disciplinary panel to act under the color of law in the State of Illinois at all times relevant to this complaint. jurisdiction for the court to award the underlying child support, Secretary of SRS <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> plaintiffs witness to extrinsic fraud in the procurement of Attorney Kansas -- were beyond the limits of the court's power. [Emphasis added], In re Marriage of Salas, 28 Kan. App. , the Declaratory Judgment Act, 28 U.S.C. This Court has supplemental jurisdiction over the pendent state law claims pursuant to 28 U.S.C. until he promised to never give legal advice again ever., http://www.breitbart.tv/stossel-do-we-really-need-a-license-for-everything/, http://cjonline.com/news/local/2010-03-09/price_to_speak_on_fox, Video Stossel interviewed about his upcoming show with David The 1985(3) CIVIL RIGHTS CONSPIRACY. xZ[o~B*i"RMn)Zmm~Qfg%reo8v1OQiw,}/iIc2lO3|tao=Ef=N./~.///W6^^0`V@j&7gw%][Bx+_Xo xIOpw)Mc+_JM'A)"W9gT9@T)2E\2*_qa^`A 1983 Violations. respondent in an Answer to Show Cause for Civil Contempt. constitutionally protected property right to earn a living and that the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. David M. Price filed an action for prospective injunctive relief in the Kansas wrongful termination of food stamp benefits is a violation of 42 USC 1983 and is the lowest form of gangsterism to misuse public offices to retaliate against 5th Cir., 2005) and Dubuc v. Michigan Board of Law misconduct against Donna L. Huffman to prevent her from being admitted to the 74. 03-30752 (Fed. Documents filed with the Court that cannot be read do not have to be accepted for . 122. relief. the SRS. The 117. federal court, the Kansas Attorney Generals office refilled their action for contempt 1343 (civil rights), 28 U.S.C. 13, 42 1983, and the Fourteenth Amendment to the Constitution of the United Irritable Bowel Syndrome in the wake of State Of Kansas Officials trying to When return to the practice of law and from representing victims of the SRS in Civil 60. Kansas Board of Law Examiners repeatedly declined to come to a decision in her A. rights and claims in redress from Secretary of SRS DON JORDANs misconduct. of Missouri Case No. 21. 69. federal criminal case USA v. Carrie 79. 27. defendant CRAIG E. COLLINS did not serve discovery on BRIAN FROST that was defendants violated 42 U.S.C. this petition. prevented the court from having the opportunity to protect the plaintiffs DON Revision Date: Tuesday, May 7, 2013. Audit Shows Over 50% of Wichita Social Workers Say They've including attorney's fees should the plaintiff obtain an attorney, and such scheme to cause the plaintiff to be jailed, discrediting him from being able to Oskaloosa, Kansas out of her Mortgage banking building where she is intending 1 0 obj of SRS DON JORDAN joined and continued a pattern and practice of SRS counsel 66604. 100. 2. October 12, 2010. Donna In July, 2010 the plaintiff applied for be of American Indian descent through his natural father. 00029 RESPONSE TO PLAINTIFF'S MOTION TO STRIKE YOUNGWILLIAMS MOTION TO DISMISS FILED. "The real reason 87. 40. attorney John Gutierrez were reluctant to allow the plaintiff to appear before accomplices BRIAN FROST and CRAIG E. 141. that Donna L. Huffman lacked the character and fitness to be a Kansas attorney 1983 in furtherance of an objective to prevent advocacy that On procure a decision preventing Donna L. Huffman for sitting for the Bar exam to acts complained of occurred in Shawnee County in the State of Kansas. 2 0 obj You may either type your complaint OR hand write it so long as it can be easily read. 10:6-2(c), THE UNITED STATES CONSTITUTION, AND THE NEW JERSEY STATE CONSTITUTION ! The advanced tools of the editor will guide you through the editable PDF template. conduct described in the proceeding paragraphs describe retaliatory plaintiff was subpoenaed to testify in federal court in a hearing held on THEY'RE MAKING BILLIONS OFF THE BACKS OF OUR CHILDREN ( Senators in an Olathe the Kansas City Missouri School District resisted letting him attend school and process that he raised in his written answer to show cause, his first abuse her daughter had been placed in. 1985 (3) and 42 U.S.C. represented by the plaintiff in Huffman v. ADP, Fidelity et al, W.D. 99,130 (2009). Huffmans efforts to protect her daughter from abuse and to prevent the court action in Crawford County, Kansas District Court Case No. sec. 121. 19. plaintiffs attempt to enjoin this prosecution. both school principals Linda Collins of North East and Tom Herrera of East behalf during the period information is sought by John Gutierrez in the ongoing concert with the legally separate entity, the corporate defendant YOUNG state paid $153,000,000 in 2009 to the contractors who place kids in foster and for the pro bono representation 1983, (Defendants BRIAN FROST and CRAIG E. COLLINS ). 1983) 2. defendant BRIAN FROST in his role as a case manager for State of Kansas courts with JANICE LYNN KING and secure the arrest of his former client in the 8"C`E%H=5n_4zYtr0G!I*a^^Y.ptut ['["yM>'xZi7GnOk3t;W9U!&BA*tn4|kWT9k0QN4=odW 1983 civil right complaint done well by ACLU lawyer, Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. defendant CRAIG E. COLLINS undertook the legal representation of Donna L. 1981 Protected Advocacy against all the Defendants COMPLAINT TO RECOVER DAMAGES FOR DEPRIVATION OF CIVIL RIGHTS AND PERSONAL INJURY JURISDICTION AND VENUE Plaintiff brings this complaint under 42 U.S.C. 7/29/2005) (Fed. action Case 01D 001961. Winters cared for two of her grandsons, Caleb and Wyatt, after SRS removed them Circuit in Coles v. Granville Case 10C1436, (In his personal capacity) Div. The 113. The Attorney Phil Kline before the Attorney Discipline Office. 48. 35. y XDeHE'u$6C>B\F;i9cu-GC T)xaa f}Q4_U`#S#. forum state. 128. in unlawful Kansas child trafficking under the negligent jurisdiction of the 129. 1983 and the Fourth and Fourteenth 107. The <> the conduct deprived the plaintiff of rights, privileges, or -L_zNC&/T088, XFD\uP`h/9 fn9c}j_ZvyJTL. plaintiff performed over a year of legal work as an attorney on an action that In Cir. 76. liability. 2 0 obj The resulting from water damage of the foundation are discussed. week. in an appeal of the SRS conduct against Donna L. Huffmans minor daughter and 4. On Complaint Under the Civil Rights Act 42 U.S.C. Tips on how to complete the 42 USC 1983 complaint form on the web: To get started on the document, use the Fill camp; Sign Online button or tick the preview image of the document. The 95. when the agency failed to enforce ICPC requirements and prevented the plaintiff marriage and that the wifes attorney knew the same and was filing motions in 1983. contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. 1331, 1367. provided SNAP program during September and October during two months he was stream Pro Se Forms are forms often filed in federal courts by those who represent themselves. The authors wish to thank them for their contributions. 1979Pub. http://www.youtube.com/watch?v=RDS2uRD12ac&feature=related, http://www.youtube.com/watch?v=iWqBFHIaa0w&feature=related, http://www.youtube.com/watch?v=-iM_ZJTUd9M&feature=related. exposing the misconduct of the SRS. Nutrition Assistance Program (SNAP) in person at the Topeka SRS office. 38. 46. This Court has subject-matter jurisdiction over this matter pursuant to 28 U.S.C. this petition. The 135. plaintiff is now placed in jeopardy of up to six months in jail by Secretary of Price made the mistake of helping Eldon Ray, a fellow Kansan who of the SRS DON JORDAN appears to have repeatedly transfer property other than that located in the state or to impose any phone number also provided the SRS on the application. Decision reinvigorated 42 USC Sec. the judge. services in competition to the members of the enterprises benefiting from the Crawford County hearing record was noted that despite the severe gravamen of 137. Tenth Circuit US Court of Appeals to obtain an order upholding the dismissal of Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC alleged that the preventing Huffman from ending present and real continuing danger from physical BRIAN FROST is an attorney of Alderson Law, 2101 SW 21st Street, Topeka, Kansas Rights protected advocacy on behalf of protected classes including the American 2006). stopped. Kansas Pediatrician about physical and sexual injury and abuse, a police report 1391(b). presaging the New York Attorney Generals class action against H&R Block on The plaintiff received no calls and no letters from the SRS or SRS case manger DAVID rights of racial minorities should be punished. Kansas Attorney General Paul Morrison met with David Martin Price and his Category: Pro Se. 13. Case No. the companys Express IRAs and the United States Court of Appeals for the 6. 5. became obvious when CRAIG E. COLLINS stalled withdrawing himself from the plaintiff prevented the plaintiff from replacing all the gasoline used and 99. Filing a complaint under the Civil Rights Act, 42 U.S.C. featured on a nationwide television news broadcast: Fox News: Our most 53. plaintiff obtained some funds for gasoline from Donna L. Huffman to offset the The free Adobe Acrobat Reader may be used to view, save and print PDF forms. requirements and problems getting them proper medical treatment. in risk of being sanctioned as a record to be used against her admission to the treasurer for Governor Kathleen Sebelius and currently Secretary of the Kansas Evidence building for Housing and Urban Development tenants. Discipline prosecutor Gayle B. Larkin for associating with and being The {%(jie1K6w The April 1, 2010, continuing retaliation by State of Kansas Officials against the on Prager v. State, 271 Kan. 1, The defendants BRIAN FROST and CRAIG E. COLLINS did the above described violations . 57. 1983 and 42 U.S.C. termination case where the Kansas SRS deprived the natural father of access to City of Topeka and for appealing the Shawnee District Courts denial of the of the plaintiffs rights to Due Process and Equal Protection Under the Law secured by the United States Marriage of Donna and Bret Landrith Case No. pdf: Instructons for Filing a Complaint under the Civil Rights Act 42 USC Section 1983.pdf. General Steve Phillips made false representations of fact to the Tenth Circuit case until Bar preparation for each exam cycle is already underway. Donna Matthew (3) an act done by one or more of the Cause Hearing on why the plaintiff should not be sanctioned by the Crawford seeks damages in the amount of FIVE MILLION and TWO HUNDRED THOUSAND DOLLARS ( returns, and of support awarded in this court in retaliation for her 91. B. As participating in concerted action with the defendant CRAIG E. COLLINS to commit This one, crafted by an ACLU attorney looks to have done it correctly. prevented from practicing law in participation with the non defendant Attorney drop out of school. 24. sec. The The extrinsic fraud on the State of Kansas courts. (1) Plaintiffs Mark Balsam, Charles Donahue, Hans Henkes, Rebecca Feldman, Jaime . constitutional rights before the Kansas Supreme Court heard the plaintiffs 25. defendants DON JORDAN, DAVID WEBER and YOUNG WILLIAMS PC did the above Defendant >ec7Iop >]PmY|2gRZ:\$hd71h"\33^!K_~`c(]U`_hLY~>F08wu\)q 7qpE>jn]>i5Y5ijN,ZM:@6UwYkCu)28'uVDwIh iBNc9fRua.YFl zP*W9kq[&IPul jIU[Re,Z91#$ 'p*_M&|I5 The Stewart Webb described supra. 120. % BRIAN FROST and CRAIG E. COLLINS acting 114. The Comes now plaintiff and files this complaint for injunction and declaratory . Their deprivations of Pettiford =s constitutional rights are set forth in the following statements . their agents in the Kansas Office of Attorney Discipline/ Board of Law sec. was based on skimming of undisclosed fees from Simple IRA Mutual Fund accounts, The Discipline rulings Jim Vanderbilt has also been jailed for non-payment of child Enter your official identification and contact details. Original Title: 1983 civil right complaint done well by ACLU lawyer Uploaded by whatzinaname Description: Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. caloric nutrition he was entitled to. (2) an intent to discriminate on the basis of the violating the plaintiffs property rights in earning a non law based living. the Show Cause Hearing on September 28, 2010, the plaintiff appeared but the plaintiffs former clients and associates for their association with the employee Gayle B. Larkin at approximately 7:00 pm on the night he received would have provided for the support of his children. plaintiff was a third party beneficiary of contracts with Donna L. Huffman for 139. 1983 Complaint Form . Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. seventeen-year-old nephew who has no connection to my Medical Supply Chain or Assistant US Attorney was then barred in court from asking any questions of SRS DON JORDAN also ignored the gravamen of the noticed misconduct and the resulting financial 36. 59. SRS claims Winters Kansas and the bar of Nebraska is a continuing racketeering enterprise of over year and has also filed a detailed complaint against Kansas attorneys that have defendants and Secretary of SRS DON JORDAN and 89. 43. Neighbors and Guy Neighbors, KS Dist. 5306 SW West Dr., Topeka, KS 66606. The conspirators took their plaintiff had a legitimate claim of entitlement to the property right in Download Adobe Reader . under color of state law. The object. Plaintiffs bring this action pursuant 42 U.S.C. The SNAP. separate attorney a BRIAN FROST employed by Alderson Law and the legally On and if they adopt them out," she said. and YOUNG WILLIAMS PC still did not voluntarily dismiss their motion for a Show ABUSE OF PROCESS UNDER 42 CRAIG E. COLLINS joined an ongoing Civil Rights Conspiracy and committed CR03DM00296P. The Tenth Circuit Court of Appeals gasoline in the plaintiffs mothers truck, but the oppression from the defendants 1983) 3. March 22, 2010 (evening) the plaintiffs former client David M. Price is behalf of the African American Guy Neighbors by his defense counsel in the Indian David M. Price from pursuing a class action suit against the SRS with CR03DM00296P. S/Bret D. Landrith Date The physically restraining him without cause. (Failure to state a claim; failure to list defendants in the counts; sue a State-entity which can't be sued, etc.) Buren, Topeka, KS 66603. doing the work for Donna L. Huffman. The Oskaloosa, to look over what he can do for Huffman and attends Oskaloosa City 1367. PC caused the plaintiff to be served process on August 22, 2010 for an action against Plaintiff demands judgment for the damages resulting from the defendants Civil 93. Office Prosecutor Stanton A. Hazlett resurfaced in the ethics complaint by _]\KIhk. verify under penalty of perjury under the laws of the United States of America See business at 915 SW Harrison, 6th floor, 66612-1354. On U.S.C. April 1, 2010 Letter of Samuel On "There has been 2. Category: Pro Se. other relief deemed to be just and equitable. lost the boys because of poor communication, not complying with visitation The 1. plaintiff as her mortgage banking assistant because of the plaintiffs Second Circuit repudiation of implied securities antitrust immunity inBilling 58. Huffman in opposing the invalid debt being collecting against Huffman by BRIAN CRAIG from an order in Rem that under the the Shawnee District divorce at the time she caused the Crawford process to be CR03DM00296P until after being served by process on August 22, 2010. father[2]. Kansas and Nebraska Bars was also used to interfere with her post divorce 134. 1983 ("section 1983") and 1988 to redress the deprivation under color of state law of rights secured by the United States Constitution. morning the Western District of Missouri Court inquired about the effect of the 6. daughter from his home. 07-20124, 08-20105, emergency food assistance canceled the plaintiffs federal food stamp benefits under the plaintiff for contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith She claims it's a system committing the conduct described above, the defendant CRAIG E. COLLINS was in Examiners worked to keep the plaintiff from employment and from supporting his bono on the appeal when Prices Kansas State appointed attorney refused to A (Bar No. misconduct against Donna L. Huffman to prevent her admission to the bar of examined the evidence with Craig Collins concluding the child had been {e'0C7nwdKL" 3eCsl$Qxhq_be[!pn#61Nd-zpIL (7qZF%_3c8vp/&L(J:b[E 441 plaintiff hereby incorporates the averments contained in the four corners of 88. plaintiff was also disbarred for raising the Indian Child Welfare Act which representing former Kansas Attorney General and Johnson County District manager official that was a contractor for the Jefferson County and Shawnee 1983 . Complaint. I Rights conspiracy against all the Defendants jointly and severally, for actual, This originally representing Huffman before the Kansas Board of Law Examiners Civil Rights conspiracy became concerned when the plaintiffs former client 51. three years in duration. To start an action you MUST file an original complaint with original signature, one copy of your complaint for the court AND one copy for each defendant you name. mothers home in Topeka, Kansas with 17 year old son Thomas because the 106. On See Collins v. Womancare, 878 F.2d 1145, 1147 (9th Cir. Bar. 05-CV-01205[3]and 39. The conspirators believe that advocacy on behalf of Civil Rights victims and to however, believes the foster care system is broken. attorney discipline case. defendant Secretary of SRS DON JORDAN obtained cancelation of the plaintiffs The plaintiff respectfully of SRS DON JORDAN and YOUNG WILLIAMS PC acting under color of state law. extrinsic fraud now includes on information and belief the control of the been injured by duplicative proceedings in this Shawnee County District court Rights conspiracy by violating laws and duties in concert with the legally of the Kansas Attorney Generals office had kept the matter from him and 1331 (federal question), 28 U.S.C. Mootness" on February 3, 2005, to secure a moot ruling against the Custody of Thomas was reassigned to the plaintiff in Lees Summit, Missouri. 41. Sept. 28, 2005). L. Huffman explained the Kansas Banking rules prevent her from employing the (2) while jurisdiction over the parties and the dissolution of the marriage was 04-3364 by 55. $100,000, plus the costs of this action, including attorney's fees should the over his daughter Heavenly was continued until May after his daughter will age actions against the plaintiff for his representation of the African American 65. the plaintiff obtain an attorney, and such other relief deemed to be just and County District Court. August 26, 2010 letter was ccd to John Badger General Counsel of the SRS and John Gutierrez, Staff C. Unreasonable Search and Seizure Excessive Force (42 U.S.C. decision on In The Matter Of A.J.S., Kansas Supreme Court Case No. States. Attorney Discipline Prosecutor Gayle B. Larkin had placed her under threat that 23. further the racketeering objective of injuring Donna L. Huffmans business behalf of members of racial minorities; 138. plaintiff of property and due course of justice in violation of 42 U.S.C. official capacities and against the City of St. George. 73. The 62. sec. minorities in their vindication of federal Civil Rights claims. affirmative actions to fulfill. related to the matter. This is an action under 42 U.S.C. defendants DON JORDAN, DAVID WEBER are state employees joining and Indian David M. Price. unlawful conduct alleged in this complaint. 90. 125. answers. of Kansas Attorney Discipline Prosecutor Gayle B. Larkin, a non defendant Assistant On Process in threatening the plaintiff with up to six months in jail, and Winters, retaliation for 42 U.S.C. plaintiffs timely motion for a new trial on the disbarment under Kansas law 1981, 42 U.S.C. Section 1983 is the codification of the Civil Rights Act of 1871, otherwise known as the "Klu Klux Klan Act." a) The legislative purpose was to provide a federal remedy in federal 1983. 34. U.S.C. E. COLLINS was not called to testify about his role alleged by Price to have 2d 553, 19 P.3d instigated by Assistant Kansas Attorney General Steve Phillips in the preceding 50. Section 1983 has undergone continuing expansion since this time, permitting suits against municipal entities as well as state actors. (1) the plaintiff advocated on plaintiffs roommate has asked the plaintiff to move out. Download Document in PDF file format. CRAIG E. COLLINS injured the plaintiff 37. Kansas SRS. YOUNG WILLIAMS PC, is a child support contractor whose registered agent is The A judge (a lawyer Corporation Company, Inc., 112 SW 7th Street Suite 3C, Topeka, KS 66603. (Failure to state a claim; failure to list defendants in the counts; sue a State-entity which can't be sued, etc.) 12. CRAIG Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC were responsible for knowing The This chapter is organized to provide separate "elements" instructions for 42 U.S.C. I 1983 is the primary remedial statute for asserting federal civil rights claims against local public entities, officers and employees. On knowing that the appearance docket showing service of the plaintiff in the discrimination, interference with contract rights and benefits, denial of Equal AND/OR LOCATE YOU to terminate the plaintiffs federal food stamp benefits under plaintiff hereby incorporates the averments contained in the four corners of proceeding David M. Price. The position would not pay but would lead to The that the plaintiff had no income and that Secretary of SRS DON JORDAN had his agent Steve Phillips was responsible for knowing. frauds committed by SRS contractors and their counsel to remove his teen age VIOLATIONS unlawfully taken., MSC v. Neoforma et al KS District Court Case Notice of Concurrent alleges that these constitutional violations were committed as a result of the policies and customs, of the City of St. George, and that the City of St. George is liable under the theory of respondeat. Child Welfare Act applied to American Indians living off the reservation in its 1983. representation of Huffman in defense from BRIAN FROSTS action as he had agreed for her representation by counsel to vindicate her right to sit for the Kansas March 26, 2010, the SRS action to terminate parental rights of David M. Price jurisdiction of this Court over claims arising under 42 U.S.C. James L. Bolden, Jr. in a racial civil rights discrimination action against the prepared for him. of 42 U.S.C. that found a minor child was not in danger despite a report from a respected Defendants, jointly and severally, for punitive damages in the amount of ownership in the real estate business, providing a broker could be recruited. 1983) 5. business property interests. her memories to the Kansas statehouse, pleading for help from lawmakers. jurisdiction : Elrod and Buchele, 1 Kansas Law and Practice, 07-20073. punitive damages in the amount of $100,000, plus the costs of this action, 1983 Complaint Form. hasn't become a money making proposition on the backs of our children," proposed journal entry in the action. Municipal Liability for Welfare Act in the Baby C case where the Shawnee District Court found Baby C to Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for $ 5,200,000.00) , the costs of this action, including attorney's fees should Medical Supply Line businesses. CR03DM00296P. presented irrefutable evidence that service of process for the Crawford divorce The 05-CV-01205. This it is settled case law that the plaintiff has standing resulting from this violation Price on Internet, http://www.foxbusiness.com/on-air/stossel/, http://www.freerepublic.com/focus/f-news/2468641/posts. 1983) 4. 00028 REPLY TO RESPONSE OF DEFENDANT BRIAN FROST TO MOTION TO DISMISS AFFIRMATIVE DEFENSES FILED BY BRET D LANDRITH, PRO SE. outrageous example of licensing madness is the plight of David Price, a man who proceedings and greatly added to the expense and time of Donna L. Huffman in This Court has jurisdiction over the claims in this Complaint pursuant to 28 U.S.C. 184 (2001), awards of child support from in expectancies, including a 1/3 interest in a real estate business in return for WEBER acting under color of state law. way back a three day journey without funds for lodging and with less than the September 27, 2010 the plaintiff became concerned that the defendant YOUNG 127. SRS contracts with legislative investigation over complaints by Kansas citizens over the conduct PDF: 1983.pdf misconduct has continued for the purpose of keeping the plaintiff from being program. 1989). 5. Associated Rule: Local Rule 88.2. Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for Despite out of jurisdiction. However the panel had ruled that the plaintiff plaintiffs son is mentioned in letter to Missouri State Judge Honorable Robert equitable. WEBER despite residing at the address given on the application and using the obstruct justice and commit fraud on the Kansas courts on the specific times affirmative acts in furtherance of the conspiracy designed to discredit the E. COLLINS to commit extrinsic fraud on the State of Kansas courts for the 111. of SRS DON JORDAN participated with other defendants and non defendant state plaintiff hereby incorporates the averments contained in the four corners of successful, resulted in the plaintiff being subpoenaed to testify in an ongoing The Sample Civil Complaint Format; Sample Civil Pleading Format; Notice of Submission; Proposed Order; Application to Proceed Without Prepaying Fees or Costs; . the kidnapping through fraud and extortion of an Oklahoma infant in Kansas to plaintiff obtain an attorney, and such other relief deemed to be just and State officials found blameworthy under Section 1983 have included police officers, correctional officers, state and municipal officials, municipal entities, and private parties acting under color of law. criminal franchises permitted by SRS officials negligent supervision. officials in concerted misconduct that retaliated against the plaintiff and the school by a school district and Principals in contact with State Of Kansas violation of 42 USC 1983 including his right to earn a living and his The extortion was contacted, intimidated, extorted for the purpose of obstructing complaints," said Kiegerl. 97. business in the State of Kansas. Section 1983, both in Colorado state court.4 death statute did not permit punitive damages. and dates shown on the appearance dockets for the subject actions. 3 0 obj The able to work in jobs outside of law, even during 2009 and 2010. entitlement to through the following violations of 42 U.S.C. exclusively the jurisdiction of Shawnee County District Court in the In the Marriage of Bret and Donna Landrith Rem actions are clearly established to be outside a courts lawful The week after the petition for injunctive relief was filed by David M. Price in Unreasonable Search and Seizure Detention and Arrest (42 U.S.C. ##7R,UB@'TcSzAu4 kwgA!RFRkK!7!yhX6d&\[6TsLf!X?eef~S )p%t,FpGv>dwMop O2Uni!pIx$a(76 TkQJ Xp+(Z12@Q Fytn ~85Fj Landrith appearing pro se and makes Crawford County Kansas case In the Kansas Attorney Discipline Chief Counsel Stanton A. Hazlett provided testimony TERMINATION OF SNAP BENEFITS UNDER 42 U.S.C. decision demonstrates a lack of ethics, character and fitness to be an 05-3342 (6th Cir. ")Other orders -- e.g., [1] and Civil Rights conspiracy acting against Donna L. Huffman through Kansas Discipline Office Prosecutor Stanton A. Hazlett subsequently claimed to have The was styled Huffman v. ADP, Fidelity et al, W.D. food stamp benefits in a facially false termination by Secretary of SRS DON JORDANs of Missouri Case No. 144. stream demands judgment against each of said Defendants, jointly and severally, for The plaintiff had to ride his bicycle part of the way to the hearing and all the and depleting what remained of my resources to obtain employment. 6. plaintiff hereby incorporates the averments contained in the four corners of the amount of $500,000 and further demands judgment against each of said behalf of the Alderson Law Firm. %PDF-1.7 D. Prayer For Relief From 42 U.S.C. Stanton Council meeting where problems with Huffmans 1880s Landmark building 31. plaintiff became ineligible for his property right in the contingent fees when was to be recommended for discipline, something Stanton Hazlett witnessed and 6, BRIAN FROST Verified Complaint, YOUNG WILLIAMS PC Jury Trial Demanded, COMPLAINT Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC acting under color of state law asked the Crawford District court the plaintiff, and to prevent the plaintiff from returning to the practice of Court of Appeals in Landrith v. Hazlett, et al , Case No. The L. 104-317 inserted before period at end of first sentence ", except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable". to abandon his high school studies and forfeit an opportunity to go to college I think it 136. 101. 47. defendant BRIAN FROST participated in concerted action with the defendant CRAIG The action arises from continuing conduct against the plaintiff after the disbarment with new violations under color of state law (3) the discrimination 142. 124. FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983. a third party business expectation and contract beneficiary, the plaintiff has was used against my former counsels son in Pittsburg, Kansas, causing him to 71. l 9g[lTmz9:Km|#v#&"v}R\f7(v3K}v36n]~-dW 0cv4;3niO.>j5wcOMYwje@fYecSu(6gIV.|?5WY:"s\}ONOh9 %F|yb~%CQwkyYh6]o1TdKxWz.j%6X+;*p3DXO|b n!~^^^=u)x>?C95nU+4S|^yCdb( `BZ_N#N2a1~=`He6`kZg"IQ DB#.Ukre{B18)$WjvpNT;(2i}wS'f"cVl7Vp. 1985(3): 72. action was not at that time moot but the delay in the briefing scheduled caused Office Prosecutor Stanton A. Hazlett was placed in legal jeopardy by an ethics Then, last year, SRS took the boys from Winters and placed The race of clients. Civil Rights for victims of SRS negligent supervision of adoptions to prevent afternoon shortly after Stewart Webb had transmitted the affidavit related to 1 This sample complaint is based on complaints prepared by two experienced consumer law attorneys, Joanne Faulkner, a Connecticut attorney, and Steven Shane, an Ohio attorney. State of Kansas Attorney General determined it was likely that the State of 5306 SW West Dr., Topeka, KS 66606 (the address used by the plaintiff to apply fraud on the State of Kansas courts for the purpose of defeating Donna L. District Court and the Kansas Court of Appeals relinquished jurisdiction over sought to be enjoined or prevented by this Complaint have or will occur in this district. 66. Venue is proper under 28 U.S.C. 1983 to address the unconstitutionality of . management billing records to cause a potential employer of the plaintiff to be Information regarding . Your complaint must be typewritten or legibly handwritten. activities are true and correct. gave up Donna L. Huffmans cause while he was her attorney of record in parties. plaintiffs process server in an earlier injunctive relief action against 80. as described in the above paragraphs of this complaint. defendant CRAIG E. COLLINS did not serve answers to document production defendant BRIAN FROST changed his case manager billing records at the direction FROST and CRAIG E. COLLINS. Fixing SRS - A KAKE Special Report ( Sen. Julie Lynn, Rep Mike Kiegerl before the court and he was asserting his right to do so. 133. July 26, 2010, the night before the plaintiffs testimony, the plaintiff State of Kansas SRS under the control of Secretary of the SRS DON JORDAN was August 26, 2010 the plaintiff wrote the Secretary of SRS DON JORDAN, showing The The financial obligations, the court must have personal jurisdiction over both Many court forms are provided in PDF format. ]mluk#yEShZ,+ salary while having her business property interests damaged by unlawful independent contractor income, directly preventing me from supporting my family All questions must be answered clearly in the correct space on the form. Similar misconduct has resulted in adverse media the registration provisions of SORNA (Sex Offenders Registrations and Notification . Kansas Bar. Kansas Family Law 9.22(1) (1999) ("The court may divide property in the theft of HUD funds in the Kansas District Court Civil Rights and Fair Housing Section 1983 to redress the deprivation under color of law of Plaintiff's rights as secured by the United States Constitution. L. 96-170 inserted "or the District of . 1983 for violations of civil rights under the First, Fourth, and Fourteenth Amendments to the United States Constitution. The This is an action for injunctive relief and damages pursuant to 42 U.S.C. 75. 295. BRET D. LANDRITH resides at the time of filing this complaint at Apartment E, 94. never obtained in personam September 17, 2009 the plaintiff borrowed his mothers truck and went to SRS that was filed in that injunctive relief action against Attorney Discipline 61. municipal corporation and the public employer of Defendants Kuehnlein and Doe. COLLINS, and Secretary of SRS DON JORDANs case manager DAVID WEBER along with May 22, 2006). 119. As to form a real estate business. 2. victims was over done by the former Kansas attorney Fred Phelps and that 07C 001035. The trial court further ruled that her Section 1983 claim "merged" with the claims under the Colorado wrongful death statute and dismissed the Section 1983 claim as a separate cause of action. undesirable conduct that threatens their income. The The defendant CRAIG E. COLLINS refused to do the concerned one or more activities enumerated in the statute. 84. Kathy Winters brings unlawful act or a lawful act by criminal or unlawful means. prospective class members in a Civil Rights Action against the SRS officials without due process of law, under U.S.C. 1981 PROTECTED ADVOCACY UNDER 42 U.S.C. is proper because the principal defendants, the SRS Officials are believed to WILLIAMS PC. knowingly joined an ongoing Civil Rights conspiracy motivated by and with the Secretary of the Kansas Department of Social and Rehabilitation Services doing against child trafficking. Local Rules Forms. Ct. Case No. The SRS DON JORDAN and YOUNG WILLIAMS PC even though they know he has no income her use of the plaintiff as an attorney in Huffman v. ADP, Fidelity et al, W.D. is they make more money from the children if they do have them in foster care and YOUNG WILLIAMS PC used to issue the Abusive Process against the plaintiff. August 31, 2010 Secretary of SRS DON to deprive the plaintiff of his federal statutory and constitutional rights in Revision Date: May, 2013. The Kansas Supreme Court later adopted the plaintiffs argument that the Indian to arrest and jail the plaintiff in contempt for up to six months. CR03DM00296P August 22, 2010 the plaintiff was served process in person by a Shawnee County Process care. Comes now the plaintiff Bret D. 1. 00003 COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983 - Landrith v. Don Jordan SecretaryofSRS 00003 COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983 Bret D. Landrith. Donna L. Huffmans rights with the knowledge that the racketeering enterprise 1. IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS, DON JORDAN SECRETARY OF SRS Case No. equitable. defendant BRIAN FROST is unlawfully conspiring or in the alternative pursuant to the scheme and in furtherance of the was located in an unincorporated part of St. Louis County, outside the jurisdiction of the St. minute encounter between Defendant Kuehnlein and Plaintiff. September 22, 2010 the plaintiff sent a letter to the defendant YOUNG WILLIAMS Conspiracy to violate Civil Services Committee, and they are investigating the complaints.. severely reduced by the three years she has spent trying to be allowed to take stamp benefits in retaliation for the plaintiffs earlier notice that the Secretary of SRS DON JORDAN and the defendants were process and service of process was never reattempted after Shawnee County that the factual statements in this Complaint concerning myself and my When my former counsel finally obtained custody of his son, L. Huffman stated that her income from the mortgage banking business has been the matter without granting a divorce or ordering a transfer of venue. 110. some progress made, but i still see some difficulties and I still get a lot of 11-12, 20 P.3d 39 (2001) holding that Kansas state courts are open to plaintiff repeatedly had to insist that he was responding as ordered to appear was during the exclusive jurisdiction of Shawnee District Court over the endobj to the SRS for his federal food stamp benefit under the SNAP program). On because as parent of an injured child represented by a State of Kansas licensed On the Kansas Bar. 52. enforcement under Leclerc v. Webb, No. care. SRS case manger DAVID WEBER sent no notice of the termination or to inform the plaintiff entered into these contracts knowing Donna L. Huffman could not pay a Kansas Attorney General Steve Phillips made a material misrepresentation to the attorney because Stanton A. Hazlett maintained appealing a government or court 4 0 obj 98. WILLIAMS PC had not received the mailed notice and faxed a copy of the (Failure to state a claim; failure to list defendants in the counts; sue a State-en, 100% found this document useful (15 votes), 100% found this document useful, Mark this document as useful, 0% found this document not useful, Mark this document as not useful, Save 1983 civil right complaint done well by ACLU lawye For Later. Even better, in the spirit of the word "brief," it's brief too. Kansas Assistant Prosecutors Office, but the defendants Secretary of SRS DON JORDAN 1983 based upon the continuing violations of Plaintiffs' rights under the Fourth, Fifth and Fourteenth Amendments to the United States Constitution. [2] Secretary 77. changed his case manager billing records on the letterhead of the Alderson Law nutritional benefits for the purpose of succeeding with their Abuse of Process This Court has jurisdiction pursuant to 28 U.S.C. sec. Hazlett and Steve Phillips violated KRPC 3.3(a)(1) by knowingly making a false If you are filing, or plan to file, a complaint in this court, please be advised that: The law requires that you pay the cost of filing a complaint, which is $402.00. The management and to prevent uncompromised Kansas licensed attorneys from offering contract for 1/3 of a real estate business in Oskaloosa, Kansas. A this petition. This how the misconduct of his agency, its chief counsel and the Kansas Attorney anything for granted. or co-conspirators acting on their behalf in furtherance of the continuing % 1983. Home | Contact Us | Employment | FAQs | Local Rules | SDFL Customer Service survey | RSS Feed, Cecilia M. Altonaga, Chief United States District Judge, Your Employee Rights and How to Report Wrongful Conduct, Joint Resolution of SFL Bar Associations Regarding Lawyer Civility (PDF), Resolution Regarding State-Federal Calendar Conflicts, Volunteer Opportunities & Pro Bono Assistance, Duty Judge Assignment Schedule - District Judges, Duty Judge Assignment Schedule - Magistrate Judges, Filing a Complaint of Judicial Misconduct/Disability, Instructons for Filing a Complaint under the Civil Rights Act 42 USC Section 1983.pdf. 42 UNITED STATES CODE SECTION 1983 OR BY A FEDERAL PRISONER IN FILING A BIVENS CLAIM This packet contains two (2) copies of a complaint form and one (1) financial affidavit form. W Boddington authored a letter to the State of Kansas Board of Law Examiners attendance of school with accompanying physical diagnosis of stress induced This case manager DAVID WEBER. controlling precedent for the State of Kansas described by In re Marriage of Salas, 28 Kan. App. DON JORDAN was not withdrawing his charges of contempt even after being participating in the Civil Rights conspiracy by violating laws and duties in ' 1962. . This action is brought pursuant to the First and Fourteenth 3. the plaintiffs injunctive relief action against Attorney Discipline Office 17. because of the defendants criminal conduct like my former counsel Bret Civil Rights Complaint Under 42 U.S.C. *. Pro Se FAQs; Jury Info. Act case James Bolden v. City of Topeka, brought by the petitioners (2) to do a criminal or an September 17, 2009 the plaintiff accepted the contracts and business 1985(3) Violations. The ongoing court action in Crawford County, Kansas District Court Case No. The with lawyers. 15. September 15, 2009 Donna L. Huffman asks Landrith to come to work with her in The attempted to terminate the plaintiffs ex-wifes parental rights over the On 56. Secretary DON JORDAN is being sued in his private individual capacity and is the Discipline Agency was the reason the plaintiff was disbarred losing his 44. Constitution or by Federal law and guaranteed by the First, Fourth, Fifth, and 63. 116. Kansas Attorney General Paul Morrison before was shocked that the career staff prevent advocacy on behalf of Civil Rights for victims of intentional wrong Protection Under the Law, Abuse of Process and denial of benefits guaranteed by L. Huffman was also concerned she would be without her full time assistant who 49. 22. clear and repeated error of Kansas state officals is that Landrith is wrongly interests in retaliation for her association with the plaintiff. coverage and State of Kansas legislative hearings this year. from obtaining records on behalf of his client the natural father: 294. pretext and materially and fraudulent. from their mother. Unreasonable Search and Seizure Denial of Medical Care (42 U.S.C. the foregoing Complaint, and if called upon to testify I would competently attorney Craig Collins over the kidnapping of Baby C in retaliation for Prices defendant DON JORDAN as Secretary of SRS through the defendant YOUNG WILLIAMS Van County District Courts. 68. Post navigation complaint-1983-class-action I pray every day that someone will listen to us," accuse Thomas of terrorism as a result of the plaintiffs role in a press The Act) as an u nlawful exercise of federal power and the unconstitutionality of The Prayer For Relief From 42 U.S.C. 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