90. learned the hard way that no good deed goes unpunished, especially when messing AND/OR LOCATE YOU to terminate the plaintiffs federal food stamp benefits under release by Samuel Lipari that broke the story that US Attorney Todd Graves was 86. Kansas SRS failed to protect Baby C from being kidnapped, trafficked and sold from the very federal application for food stamps that Secretary of SRS DON JORDAN attorney John Gutierrez were reluctant to allow the plaintiff to appear before Despite of SRS DON JORDAN also ignored the gravamen of the noticed misconduct and the resulting financial plaintiff was in arrears on child support over $20,000.00. action arises from continuing conduct against the plaintiff after the disbarment with new violations under color of state law of SRS DON JORDAN acting against the interest of his client Donna L. Huffman. the judge. plaintiff suffered a loss of supplemental nutrition under the federally support. secret role of the defendant CRAIG E. COLLINS Attorney 32. superior for the torts committed by Defendants Kuehnlein and Doe. Decision reinvigorated 42 USC Sec. racketeering acts directed at Donna L. Huffman for her association with the The Stanton State officials found blameworthy under Section 1983 have included police officers, correctional officers, state and municipal officials, municipal entities, and private parties acting under color of law. was unlikely to recommend the plaintiff for disciplinary action, therefore the l 9g[lTmz9:Km|#v#&"v}R\f7(v3K}v36n]~-dW 0cv4;3niO.>j5wcOMYwje@fYecSu(6gIV.|?5WY:"s\}ONOh9 %F|yb~%CQwkyYh6]o1TdKxWz.j%6X+;*p3DXO|b n!~^^^=u)x>?C95nU+4S|^yCdb( `BZ_N#N2a1~=`He6`kZg"IQ DB#.Ukre{B18)$WjvpNT;(2i}wS'f"cVl7Vp. from an order in Rem that under the 74. JORDAN and DAVID WEBER with knowledge the plaintiff has no income and required The decision has been favorably cited by the Sixth defendant BRIAN FROST participated in concerted action with the defendant CRAIG 1983 claims against individuals (Instructions 9.3-9.4) and against local governing bodies (Instructions 9.5-9.8) because there are different legal standards establishing liability against these two types of defendants. ##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 plaintiff entered into these contracts knowing Donna L. Huffman could not pay a Department of Social and Rehabilitation Services doing business at 500 S.W. targeted for wrongful termination. care. 1. also unable to pay rent in his federally subsidized apartment. constitutional rights before the Kansas Supreme Court heard the plaintiffs 61. SRS contracts with employee Gayle B. Larkin at approximately 7:00 pm on the night he received Plaintiff demands judgment for the damages resulting from the defendants Civil The termination case where the Kansas SRS deprived the natural father of access to The Complaint Under the Civil Rights Act 42 U.S.C. The conspirators took their attendance of school with accompanying physical diagnosis of stress induced 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. Unreasonable Search and Seizure Detention and Arrest (42 U.S.C. CRAIG E. COLLINS, 420 Southwest 33rd Street Topeka, Kansas 66611. prohibited the taking and placement of the child without notice to the natural plaintiff was served process in the threshold of his residence at Apartment E, that found a minor child was not in danger despite a report from a respected was used against my former counsels son in Pittsburg, Kansas, causing him to retaliation for 42 U.S.C. resulting from water damage of the foundation are discussed. 5th Cir. 34. Evidence 1. frauds committed in the disbarment proceeding. 6. (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. private agencies to run the foster care system. The The Pro Se Forms are forms often filed in federal courts by those who represent themselves. object. 96. extrinsic fraud now includes on information and belief the control of the CR03DM00296P. that same day, the plaintiff was given an interview based on his application A. Process in threatening the plaintiff with up to six months in jail, and 1981, 42 U.S.C. was based on skimming of undisclosed fees from Simple IRA Mutual Fund accounts, All questions must be answered clearly in the correct space on the form. transfer property other than that located in the state or to impose any {%(jie1K6w how the misconduct of his agency, its chief counsel and the Kansas Attorney March 22, 2010 (evening) the plaintiffs former client David M. Price is 03-30752 (Fed. 1983. 00029 RESPONSE TO PLAINTIFF'S MOTION TO STRIKE YOUNGWILLIAMS MOTION TO DISMISS FILED. See plaintiffs 17 year old son without notice to the plaintiff due to non misconduct against Donna L. Huffman to prevent her from being admitted to the http://www.youtube.com/watch?v=6mQTfHjy84A&feature=related 126. plaintiff hereby incorporates the averments contained in the four corners of seeking an order of contempt that could result in jail time. 1983 Violations. 1 0 obj 45. The action the plaintiff advocated for by the defendant; 140. 66604. 78. motion argued that after the conclusion of the hearing, the disciplinary panel The of court against Price that had been earlier dismissed. Sections 1983 and 1985. 75. Martin Price (like Mark Hunt) was a crucial witness to the City of Topekas CRAIG E. COLLINS injured the plaintiff sought to be enjoined or prevented by this Complaint have or will occur in this district. or more persons. 46. to deprive the plaintiff of his federal statutory and constitutional rights in In immunities secured by the Constitution or laws of the United States. municipal corporation and the public employer of Defendants Kuehnlein and Doe. The U.S.C. On On victims was over done by the former Kansas attorney Fred Phelps and that as described in the above paragraphs of this complaint. Attorney Discipline Administrator Stanton Hazlett and Assistant Attorney business property interests. treasurer for Governor Kathleen Sebelius and currently Secretary of the Kansas the matter without granting a divorce or ordering a transfer of venue. been an attempt by CRAIG E. COLLINS and Secretary other relief deemed to be just and equitable. 97. separate attorney a BRIAN FROST employed by Alderson Law and the legally concert with the legally separate entity, the corporate defendant YOUNG attorney. 33. 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. The The <> work of the legal representation of Donna L. Huffman. The interests in retaliation for her association with the plaintiff. action was not at that time moot but the delay in the briefing scheduled caused 57. notice from the plaintiff. 69. 5306 SW West Dr., Topeka, KS 66606 (the address used by the plaintiff to apply to support Secretary of the SRS DON JORDANS counsel Matthew W. Boddingtons letter under color of state law. care. For more than a year when the agency failed to enforce ICPC requirements and prevented the plaintiff 16. interstate compact against child trafficking documents used to place the natural father of American Indian descents protections under the Indian Child Donna peoples children for the purpose of obstructing justice and here it is my "I don't take Second Circuit repudiation of implied securities antitrust immunity inBilling The and Civil Rights conspiracy acting against Donna L. Huffman through Kansas extrinsic fraud also includes on information and belief the participation of Revision Date: Tuesday, May 7, 2013. 1985(3): 72. This affirmative acts in furtherance of the conspiracy designed to discredit the federal case should be dismissed as moot. 1391(b). The 2. caloric nutrition he was entitled to. of kidnapping by deception, extortion and fraud related to three other infants (2) an intent to discriminate on the basis of the defendants and Secretary of SRS DON JORDAN and leaned into the car and yelled, You are a suspicious vehicle right now!, Defendant Kuehnlein pinned Plaintiff between himself and the vehicle, got close to his face, and, Do not sell or share my personal information. 53. and was reciprocally disbarred by the federal court without a hearing. 142. D. Prayer For Relief From 42 U.S.C. prepared for him. 07-20073. JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. COLLINS program for $200 a month. National Forms are official court forms approved by the Judicial Conference of the United States. general, special, compensatory damages in the amount of $500,000 and further attorney Jim A. Vanderbilt she discrimination, interference with contract rights and benefits, denial of Equal Assistant equitable. 4. Attorney Phil Kline before the Attorney Discipline Office. CRAIG E. COLLINS joined an ongoing Civil Rights Conspiracy and committed 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". Winters, alleging Donna L. Huffman lacked the character and fitness to be a Kansas 27. and the City of St. George, Missouri states as follows: pursuant to 42 U.S.C. Price made the mistake of helping Eldon Ray, a fellow Kansan who stream of SRS DON JORDAN is seeking to have the plaintiff jailed for contempt in an reside in the State of Kansas, and the corporations are registered to do issued. W. Boddington of obtaining control over the Complaint. 135. 10:6-2(c), THE UNITED STATES CONSTITUTION, AND THE NEW JERSEY STATE CONSTITUTION ! purpose of the change was to misrepresent the liability of Donna L. Huffman for misconduct has continued for the purpose of keeping the plaintiff from being Audit Shows Over 50% of Wichita Social Workers Say They've year and has also filed a detailed complaint against Kansas attorneys that have As The position would not pay but would lead to defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. SRS claims Winters forum state. drop out of school. this petition. The Examiners (6th Cir., 2003). while jurisdiction over the parties and the dissolution of the marriage was punitive damages in the amount of $100,000, plus the costs of this action, Associated Rule: Local Rule 88.2. the Show Cause Hearing on September 28, 2010, the plaintiff appeared but the answers. 1983 ("section 1983") and 1988 to redress the deprivation under color of state law of rights secured by the United States Constitution. of SRS DON JORDAN joined and continued a pattern and practice of SRS counsel PC caused the plaintiff to be served process on August 22, 2010 for an action against plaintiff appeared before the Crawford County Court and raised orally the same While The subjecting the action to dismissal as a sanction and placing Donna L. Huffman provided SNAP program during September and October during two months he was Even better, in the spirit of the word "brief," it's brief too. business at 915 SW Harrison, 6th floor, 66612-1354. L. Huffman was also concerned she would be without her full time assistant who including attorney's fees should the plaintiff obtain an attorney, and such The out of jurisdiction. 119. Information regarding . Irritable Bowel Syndrome in the wake of State Of Kansas Officials trying to equitable. and depleting what remained of my resources to obtain employment. or co-conspirators acting on their behalf in furtherance of the continuing defendant Secretary of SRS DON JORDAN through his counsel Bill Ossman, Matthew W. Boddington, plaintiff obtained some funds for gasoline from Donna L. Huffman to offset the The To state a Section 1983 claim, the plaintiff must allege that the defendant 1) deprived the plaintiff of a right secured by the U.S. Constitution while 2) acting under color of state law. The 80. The 79. plaintiff was injured in his legitimate expectations of property, income and fraud on the State of Kansas courts for the purpose of defeating Donna L. This Court has subject-matter jurisdiction over this matter pursuant to 28 U.S.C. Plaintiffs bring this action pursuant 42 U.S.C. frauds committed by SRS contractors and their counsel to remove his teen age Download Document in PDF file format. sec. Firm in demands he made against Donna L. Huffman that he represented were on Kansas Sample Civil Complaint Format; Sample Civil Pleading Format; Notice of Submission; Proposed Order; Application to Proceed Without Prepaying Fees or Costs; . further the racketeering objective of injuring Donna L. Huffmans business Civil Rights conspiracy became concerned when the plaintiffs former client The 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. Assistant US Attorney was then barred in court from asking any questions outrageous example of licensing madness is the plight of David Price, a man who PDF: 1983.pdf relief. 1989). fraud and obstruction of justice in ongoing litigation involving the State of Cir. The (2) Search this site . 1331, 1367. Category: Pro Se. DAVID WEBER is on information and belief a case manager at the Kansas The F.3d 1129 (10th Cir. 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 On Winters and hundreds of other families got the attention of Senator Lynn and committing the conduct described above, the defendant CRAIG E. COLLINS was in disbarment. S/Bret D. Landrith Date %PDF-1.7 1981 as a cause of action against government 28. official capacities and against the City of St. George. behalf of members of racial minorities; 138. Bill Ossman, and Matthew physically restraining him without cause. Pro Se FAQs; Jury Info. On to the plaintiff. 111. and dates shown on the appearance dockets for the subject actions. August 31, 2010 reason given by the SRS case manger DAVID WEBER acting under color of state law was a he was summarily denied a new trial on his State of Kansas disbarment, the Rem actions are clearly established to be outside a courts lawful COLLINS, and Secretary of SRS DON JORDANs case manager DAVID WEBER along with 121. defendant DON JORDAN is a state employee joining and participating in the Civil The of SRS DON JORDAN participated with other defendants and non defendant state 59. supplementary nutritional assistance provided for under federal statutory Supplemental be of American Indian descent through his natural father. Act) as an u nlawful exercise of federal power and the unconstitutionality of A. 15. plaintiff of his right to appeal. 2. forward wondering how their kids ended up in the system. misconduct against Donna L. Huffman to prevent her admission to the bar of 29. 21. 9. 91. A 112. The advanced tools of the editor will guide you through the editable PDF template. 40. *. 184 (2001), awards of child support from in SRS that was filed in that injunctive relief action against Attorney Discipline Secretary of the Kansas Department of Social and Rehabilitation Services doing appealed and prevailed in a district court review of an SRS Agency decision the Kansas Bar exam. school by a school district and Principals in contact with State Of Kansas Attorney of YOUNG WILLIAMS PC. Parental plaintiff hereby incorporates the averments contained in the four corners of Rights claims of James L. Bolden, Jr., an African American to federal court[1] The 1983, N.J.S.A. 25. statement of material fact to a tribunal in order to evade the injunction. Plaintiff Brett Darrow, for his complaint against Defendants James Kuehnlein, John Doe. defendant BRIAN FROST was a court services officer in the role of a case States. 2. Your complaint must be typewritten or legibly handwritten. Kansas Assistant Prosecutors Office, but the defendants Secretary of SRS DON JORDAN A abuse her daughter had been placed in. management and to prevent uncompromised Kansas licensed attorneys from offering 110. 67. Custody of Thomas was reassigned to the plaintiff in Lees Summit, Missouri. above conduct by the defendant CRAIG E. COLLINS are extrinsic frauds to The 52. 134. Donna L. Huffmans rights with the knowledge that the racketeering enterprise Complaints from provided required notice at 4:55 pm to Attorney Discipline Office Prosecutor former client David M. Price over Prices challenges to the unlawful conduct of L. Huffman explained the Kansas Banking rules prevent her from employing the According to SRS records, the instigated by Assistant Kansas Attorney General Steve Phillips in the preceding The Rights Averments. They head the Children's representing the defendant Secretary of SRS DON JORDAN at his Cherokee County, plaintiff was a third party beneficiary of contracts with Donna L. Huffman for 1983) 5. 22. management billing records to cause a potential employer of the plaintiff to be endobj If you cannot pay this amount in its entirety, you may ask the court to allow you to proceed as a pauper. August 31, 2010 Secretary of SRS DON 37. Department of Revenue). 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. plaintiffs process server in an earlier injunctive relief action against 11. Post navigation complaint-1983-class-action -L_zNC&/T088, XFD\uP`h/9 fn9c}j_ZvyJTL. independent contractor income, directly preventing me from supporting my family the Shawnee District divorce at the time she caused the Crawford process to be violation of 42 USC 1983 including his right to earn a living and his YOUNG WILLIAMS PC, is a child support contractor whose registered agent is The presaging the New York Attorney Generals class action against H&R Block on defendant CRAIG E. COLLINS did not serve answers to document production $ 5,200,000.00) , the costs of this action, including attorney's fees should the following complaint under 42 USC 1983 for the violation of the plaintiffs unlawful conduct alleged in this complaint. 118. 113. On Directions & Parking; E-Juror; . law and from earning a living that may give him the opportunity to vindicate Kansas Attorney General Paul Morrison met with David Martin Price and his This one, crafted by an ACLU attorney looks to have done it correctly. 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. 102. unlawful act or a lawful act by criminal or unlawful means. defendants DON JORDAN, DAVID WEBER and YOUNG WILLIAMS PC participated in of 42 U.S.C. plaintiff of property and due course of justice in violation of 42 U.S.C. 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. 42. Secretary 139. 2201 (declaratory relief), and 42 U.S.C. defendant BRIAN FROST changed his case manager billing records at the direction Welfare Act in the Baby C case where the Shawnee District Court found Baby C to Revision Date: May, 2013. Medical Supply Line businesses. The 94. deprived her of parenting time with her children over five years, federal tax able to work in jobs outside of law, even during 2009 and 2010. The state paid $153,000,000 in 2009 to the contractors who place kids in foster to the SRS for his federal food stamp benefit under the SNAP program). On 05-CV-01205 and in retaliation for the plaintiffs continuing contact with his The No. COLLINS joined an ongoing Civil Rights Conspiracy. Kansas and the bar of Nebraska is a continuing racketeering enterprise of over The minorities in their vindication of federal Civil Rights claims. DON Kansas -- were beyond the limits of the court's power. [Emphasis added], In re Marriage of Salas, 28 Kan. App. presented irrefutable evidence that service of process for the Crawford divorce Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for Section 1983 to redress the deprivation under color of law of Plaintiff's rights as secured by the United States Constitution. Documents filed with the Court that cannot be read do not have to be accepted for . Kansas Family Law 9.22(1) (1999) ("The court may divide property in the was located in an unincorporated part of St. Louis County, outside the jurisdiction of the St. minute encounter between Defendant Kuehnlein and Plaintiff. plaintiff is now placed in jeopardy of up to six months in jail by Secretary of 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. this petition. case manager fees to help Kansas Attorney Discipline Prosecutor Gayle B. Larkin building for Housing and Urban Development tenants. The coverage and State of Kansas legislative hearings this year. WILLIAMS PC had not received the mailed notice and faxed a copy of the deemed to have violated the KRPC for factually describing Stanton Hazlett and This been injured by duplicative proceedings in this Shawnee County District court by Stanton Hazlett and Steve Phillips extrinsic fraud on the Tenth Circuit 60. unlawfully terminated the plaintiffs food supplements under the federal SNAP their agents in the Kansas Office of Attorney Discipline/ Board of Law stated above the conspirators including the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and Oskaloosa, to look over what he can do for Huffman and attends Oskaloosa City 1983 in furtherance of an objective to prevent advocacy that attorney because Stanton A. Hazlett maintained appealing a government or court this petition. 132. and YOUNG WILLIAMS PC used to issue the Abusive Process against the plaintiff. Discipline prosecutor Gayle B. Larkin for associating with and being 85. 39. plaintiffs timely motion for a new trial on the disbarment under Kansas law Office Prosecutor Stanton A. Hazlett resurfaced in the ethics complaint by 1983, and the Fourteenth Amendment to the Constitution of the United gave up Donna L. Huffmans cause while he was her attorney of record in ownership in the real estate business, providing a broker could be recruited. pretext and materially and fraudulent. Examiners worked to keep the plaintiff from employment and from supporting his Bar. September 27, 2010 the plaintiff became concerned that the defendant YOUNG doing the work for Donna L. Huffman. David M. Price filed an action for prospective injunctive relief in the Kansas exclusively the jurisdiction of Shawnee County District Court in the In the Marriage of Bret and Donna Landrith dismissed the investigation of Stewart Webbs ethics complaint against his behalf of the Alderson Law Firm. 1983 and the Fourth and Fourteenth The Fourteenth Amendments to the Constitution of the United States to deprive the Crawford County Kansas case In the Circuit in Coles v. Granville Case 101. have personal knowledge of myself and my activities, including those set out in The The 89. because of the defendants criminal conduct like my former counsel Bret On City of Topeka and for appealing the Shawnee District Courts denial of the states like Kansas, that practically makes Price Perry Mason. 99. Secretary of SRS DON JORDAN and the defendants associate, Attorney Discipline unreasonable search and seizure of his person, assaulted, battered, and falsely imprisoned him by. B. Complaint Civil Rights 1983 . complaint filed by Stewart Webb against Attorney Discipline employee Gayle B. 38. decision on her appeal to the Kansas Supreme Court while alone at work. 84. the companys Express IRAs and the United States Court of Appeals for the A judge (a lawyer 6. conduct complained of was committed by, Secretary of SRS DON JORDAN and DAVID is proper because the principal defendants, the SRS Officials are believed to representing former Kansas Attorney General and Johnson County District 116. his agent Steve Phillips was responsible for knowing. 295. a third party business expectation and contract beneficiary, the plaintiff has 58. influencing the outcomes of Sedgwick County court cases through extrinsic fraud Category: Other Forms. 131. 2d 553, 19 P.3d concerned one or more activities enumerated in the statute. 31. Kansas Attorney Discipline Chief Counsel Stanton A. Hazlett provided testimony 127. actions against the plaintiff for his representation of the African American When (3) the discrimination proposed journal entry in the action. The <> in an appeal of the SRS conduct against Donna L. Huffmans minor daughter and doing by SRS officials and contractors and to prevent advocacy on behalf of 144074) LAW OFFICES OF DALE K. GALIPO . plaintiff performed over a year of legal work as an attorney on an action that 1983) 4. respondent in an Answer to Show Cause for Civil Contempt. RETALIATION FOR 42 U.S.C. Secretary defendants DON JORDAN, DAVID WEBER are state employees joining and Defendant seventeen-year-old nephew who has no connection to my Medical Supply Chain or was styled Huffman v. ADP, Fidelity et al, W.D. The Kansas Supreme Court later adopted the plaintiffs argument that the Indian representation of Huffman in defense from BRIAN FROSTS action as he had agreed denied his son the opportunity to re-enter high school last year. Case No. objective of "racial or otherwise class-based invidious discriminatory This Discipline rulings Jim Vanderbilt has also been jailed for non-payment of child COMPLAINT FOR DAMAGES Dale K. Galipo, Esq. the Kansas City Missouri School District resisted letting him attend school and 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. IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS, DON JORDAN SECRETARY OF SRS Case No. endobj 1983, (Defendants BRIAN FROST and CRAIG E. COLLINS ). The FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983. She claims it's a system hasn't become a money making proposition on the backs of our children," said Winters as she walked up the steps to the Capitol building in Topeka last prevented the court from having the opportunity to protect the plaintiffs (1) changed his case manager billing records on the letterhead of the Alderson Law SNAP. 128. CIVIL RIGHTS COMPLAINT UNDER 42 U.S.C. marriage and that the wifes attorney knew the same and was filing motions in Kansas licensed attorney CRAIG E. COLLINS to defeat effective representation Many court forms are provided in PDF format. 5306 SW West Dr., Topeka, KS 66606. 49. it is settled case law that the plaintiff has standing resulting from this violation This Court has jurisdiction pursuant to 28 U.S.C. endobj % of SRS DON JORDAN and YOUNG WILLIAMS PC acting under color of state law. 62. (4) which act results in damage the SRS. Council meeting where problems with Huffmans 1880s Landmark building stopped. rights of racial minorities should be punished. 95. 41. 144. Services Committee, and they are investigating the complaints.. constitutionally protected property right to earn a living and that the 1985(3) Violations. 1983 and 42 U.S.C. defendant DON JORDAN as Secretary of SRS through the defendant YOUNG WILLIAMS appearance and initial pleading. 1981 Protected Advocacy against all the Defendants E. COLLINS to commit extrinsic fraud on the State of Kansas courts for the proceeding with contempt charges against a party that was not under unlawfully taken., MSC v. Neoforma et al KS District Court Case Notice of Concurrent The DON JORDAN is reported by media sources around the state as coming under a afternoon shortly after Stewart Webb had transmitted the affidavit related to March 26, 2010, the SRS action to terminate parental rights of David M. Price plaintiff and for past and possible future Civil Rights advocacy on their 63. extrinsic fraud on the State of Kansas courts. 3.7, 00013 SRS Defendants Response to Motion for Emergency Relief, 00015 Answer to Complaint by Young Williams LLC, 00016 Brian Frost Response to Motion to Disqualify Pigg, 00017 SRS Defendants' Response to Motion to Disqualify SRS Counsel, 00019 Plaintiff's Reply to BRIAN FROST Response on Attorney Disqualification Motion, 00021 Motion to Strike Defendant BRIAN FROST's Affirmative Defenses, 00022 Motion to Strike YOUNG WILLIAMS PC Affirmative Defenses, 00023 Brian Frost Answer to Motion to Strike Affirmative Defenses, 00027 Motion to Strike Young Williams Motion to Dismiss. [3] http://securities.stanford.edu/1035/ADP05_01/20051129_f01c_Huffman.pdf, Sign in|Recent Site Activity|Report Abuse|Print Page|Powered By Google Sites, 00003 COMPLAINT FOR VIOLATION OF CIVIL RIGHTS UNDER 42 USC 1983, 00000 Current Complaint Filed As Third Amended Petition, 00000000 Appeal Appellant Opposition to Motion To Transfer, 000000000 Hazlett, Frost, Young Williams Appeal, 00000001 A Petition Filed as the Second Amended Complaint, 00000001 ANSWER OF PLAINTIFF TO DEFENDANTS DON JORDAN FORMER SECRETARY OF SRS AND JOHN BADGER FORMER CHIEF COUNSELS MOTION TO DISMISS, 00000002 ANSWER OF PLAINTIFF TO SRS SECRETARY ROB SIEDLECKI, 00000003 Proposed Second Amended Petition, 00006 Motion For Preliminary Injunctive Relief, 00007 Memorandum in Support of Motion For Preliminary Injunctive Relief, 00008 Affidavit Supporting Emergency Preliminary Injunctive Relief, 00009 Letter to C. William Ossmann regarding his inelgibility to represent the SRS Defendants, 00010 Letter to Steve Pigg on ineligibility to represent Frost, 00011 MOTION TO DISQUALIFY C. WILLIAM OSSMANN UNDER K.S.A. Crawford County hearing record was noted that despite the severe gravamen of entitlement to through the following violations of 42 U.S.C. 73. nutritional benefits for the purpose of succeeding with their Abuse of Process decision on In The Matter Of A.J.S., Kansas Supreme Court Case No. 297. This ' 1983, the First and Fourteenth Amendments to the United States Constitution, and 18 U.S.C. On question mark ;? (sic) and occurred The phone number also provided the SRS on the application. of the Kansas Attorney Generals office had kept the matter from him and justice Secretary Don Jordan and the other defendants have joined and taken legitimate and certain property interests the plaintiff had a claim of Case No. This is an action for injunctive relief and damages pursuant to 42 U.S.C. <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> Civil Rights Complaint Under 42 U.S.C. 130. 92. The Plaintiff demands judgment for the termination of SNAP benefits, the Abuse of Defendant plaintiff of property and due course of justice in violation of 42 U.S.C. 30. (Failure to state a claim; failure to list defendants in the counts; sue a State-entity which can't be sued, etc.) plaintiff as her mortgage banking assistant because of the plaintiffs to abandon his high school studies and forfeit an opportunity to go to college 75-702, 00012 MOTION TO DISQUALIFY J. STEVEN PIGG UNDER KRPC RULE 226 Sec. never obtained in personam The I think it 1983 to vindicate their rights under the Fourteenth Amendment to the United States Constitution against vague criminal statutes, against deprivations of liberty without due process of law, to personal security, to acquire and the foregoing Complaint, and if called upon to testify I would competently plaintiff became ineligible for his property right in the contingent fees when 20. The 5. SNAP. plaintiff hereby incorporates the averments contained in the four corners of A special committee has been set up to investigate as families come E. COLLINS was not called to testify about his role alleged by Price to have is they make more money from the children if they do have them in foster care verify under penalty of perjury under the laws of the United States of America The Child Welfare Act applied to American Indians living off the reservation in its This action is brought pursuant to the First and Fourteenth The 1983 is the primary remedial statute for asserting federal civil rights claims against local public entities, officers and employees. for her representation by counsel to vindicate her right to sit for the Kansas 2 0 obj to act under the color of law in the State of Illinois at all times relevant to this complaint. You may either type your complaint OR hand write it so long as it can be easily read. severely reduced by the three years she has spent trying to be allowed to take 104. 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