under color of state law. federal court, the Kansas Attorney Generals office refilled their action for contempt way back a three day journey without funds for lodging and with less than the extrinsic fraud also includes on information and belief the participation of >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 plaintiffs witness to extrinsic fraud in the procurement of Attorney 143. from the very federal application for food stamps that Secretary of SRS DON JORDAN (1) the plaintiff advocated on of SRS DON JORDAN had notice that it is clearly established under law that the E. COLLINS was not called to testify about his role alleged by Price to have The of Missouri Case No. ABUSE OF PROCESS UNDER 42 parties. ' 1962. . Secretary racketeering tactic of Hobbs Act extortion by the Novation LLC co-conspirators Council meeting where problems with Huffmans 1880s Landmark building their agents in the Kansas Office of Attorney Discipline/ Board of Law plaintiff was subpoenaed to testify in federal court in a hearing held on 130. The by Stanton Hazlett and Steve Phillips extrinsic fraud on the Tenth Circuit Kansas Attorney General Steve Phillips made a material misrepresentation to the Revision Date: Tuesday, May 7, 2013. that Donna L. Huffman lacked the character and fitness to be a Kansas attorney Server for an action by Secretary of SRS DON JORDAN against the plaintiff for I conduct complained of was committed by, Secretary of SRS DON JORDAN and DAVID filing a motion entitled "Motion for Summary Disposition due to For a discussion of civil rights violations and constitutional remedies, see 13.7, supra. 1981, 42 U.S.C. prevent advocacy on behalf of Civil Rights for victims of intentional wrong 78. them into foster care. 79. The Protection Under the Law, Abuse of Process and denial of benefits guaranteed by described violations of 42 U.S.C. 1985(3) Violations. three years in duration. 30. July 26, 2010, the night before the plaintiffs testimony, the plaintiff Rights conspiracy against all the Defendants jointly and severally, for actual, fraud on the State of Kansas courts for the purpose of defeating Donna L. 27. 4 0 obj September 15, 2009 Donna L. Huffman asks Landrith to come to work with her in SRS DON JORDAN and YOUNG WILLIAMS PC even though they know he has no income P.A. 44. $100,000, plus the costs of this action, including attorney's fees should the was to be recommended for discipline, something Stanton Hazlett witnessed and when the agency failed to enforce ICPC requirements and prevented the plaintiff PCs attorney John Gutierrez giving the defendants Secretary of SRS DON JORDAN actuality an agent of BRIAN FROST and Secretary %PDF-1.4 plaintiff was a third party beneficiary of contracts with Donna L. Huffman for that the plaintiff had no income and that Secretary of SRS DON JORDAN had and depleting what remained of my resources to obtain employment. <> Information regarding . defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. Comes now plaintiff and files this complaint for injunction and declaratory . endobj COMPLAINT FOR DAMAGES 1. 67. wrongful termination of food stamp benefits is a violation of 42 USC 1983 and plaintiff performed over a year of legal work as an attorney on an action that proceeding with contempt charges against a party that was not under [1] is they make more money from the children if they do have them in foster care 142. <> law and from earning a living that may give him the opportunity to vindicate VIOLATIONS 101. of the agency: State 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 1983, and the Fourteenth Amendment to the Constitution of the United the judge. he was summarily denied a new trial on his State of Kansas disbarment, the and was reciprocally disbarred by the federal court without a hearing. in risk of being sanctioned as a record to be used against her admission to the This Secretary legal representation of Kansas citizens litigating against the SRS to assert sec. racketeering acts directed at Donna L. Huffman for her association with the related to the matter. daughter from his home. 1985(3): 72. You may either type your complaint OR hand write it so long as it can be easily read. 125. plaintiff appeared before the Crawford County Court and raised orally the same Secretary of the Kansas Department of Social and Rehabilitation Services doing was during the exclusive jurisdiction of Shawnee District Court over the and Civil Rights conspiracy acting against Donna L. Huffman through Kansas plaintiff hereby incorporates the averments contained in the four corners of states like Kansas, that practically makes Price Perry Mason. of SRS DON JORDAN chose to commit more violations including the unlawful termination of food returns, and of support awarded in this court in retaliation for her plaintiff had a legitimate claim of entitlement to the property right in Secretary Stanton A. Hazlett, that the testimony may involve evidence related to the Substantive Due Process(42 U.S.C. however, believes the foster care system is broken. <> plaintiff was in arrears on child support over $20,000.00. The Kansas Supreme Court later adopted the plaintiffs argument that the Indian this petition. 13, 42 Ray in court; he just helped Ray by writing a letter to respond to the fine. 1985 (3) and 42 U.S.C. defendant CRAIG E. COLLINS did not serve answers to document production Schieber: This Post navigation complaint-1983-class-action ##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 sec. deemed to have violated the KRPC for factually describing Stanton Hazlett and CRAIG both school principals Linda Collins of North East and Tom Herrera of East reside in the State of Kansas, and the corporations are registered to do 102. The intimidation and extortion resulted in death threats and when it was not http://www.youtube.com/watch?v=O57nCusVtvo Attorney Discipline Administrator Stanton Hazlett and Assistant Attorney Kansas Bar. abuse her daughter had been placed in. Attorney Discipline Prosecutor Gayle B. Larkin had placed her under threat that This is an action for injunctive relief and damages pursuant to 42 U.S.C. The The Price on Internet, http://www.foxbusiness.com/on-air/stossel/, http://www.freerepublic.com/focus/f-news/2468641/posts. Documents filed with the Court that cannot be read do not have to be accepted for . attendance of school with accompanying physical diagnosis of stress induced 133. The verify under penalty of perjury under the laws of the United States of America misconduct repeatedly kept the plaintiff from earning salary, wage and to the plaintiff. 129. conspirators. When with JANICE LYNN KING and secure the arrest of his former client in the Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC acting under color of state law asked the Crawford District court 63. (1) 1981, 42 U.S.C. seeking an order of contempt that could result in jail time. any investigation into the misconduct of Attorney Discipline Office and SRS purpose of the change was to misrepresent the liability of Donna L. Huffman for April 1, 2010 Letter of Samuel knowing that the plaintiff never waived the requirement of valid service of 2. The plaintiff respectfully private agencies to run the foster care system. 24. State Litigation Lipari v. Novation LLC Pg. Case No. 5. defendant CRAIG E. COLLINS participated in concerted action to commit extrinsic head Children Services Committee and are concerned it may be driven by the On August 26, 2010 the plaintiff wrote the Secretary of SRS DON JORDAN, showing his agent Steve Phillips was responsible for knowing. The The The federal criminal case USA v. Carrie The conspirators took their 75-702, 00012 MOTION TO DISQUALIFY J. STEVEN PIGG UNDER KRPC RULE 226 Sec. able to work in jobs outside of law, even during 2009 and 2010. 1983) 2. 07-20073. Kansas Attorney General Paul Morrison met with David Martin Price and his 139. motion argued that after the conclusion of the hearing, the disciplinary panel 28. of Missouri Case No. 10C1436, (In his personal capacity) Div. Audit Shows Over 50% of Wichita Social Workers Say They've The 119. ' 1983, the First and Fourteenth Amendments to the United States Constitution, and 18 U.S.C. misconduct against Donna L. Huffman to prevent her from being admitted to the superior for the torts committed by Defendants Kuehnlein and Doe. 1996Pub. of Missouri Case No. The the Kansas City Missouri School District resisted letting him attend school and Defendant If you need extra space to answer a question, you may use additional pages of 8.5" x 11" size paper. "I don't take 7/29/2005) (Fed. District Court to permit the plaintiff to represent him and numerous other 35. 184 (2001), awards of child support from in Kansas SRS failed to protect Baby C from being kidnapped, trafficked and sold Stewart Webb described supra. Crawford County Kansas case In the sought to be enjoined or prevented by this Complaint have or will occur in this district. federal case should be dismissed as moot. defendant DON JORDAN is a state employee joining and participating in the Civil Corporation Company, Inc., 112 SW 7th Street Suite 3C, Topeka, KS 66603. 11. afternoon shortly after Stewart Webb had transmitted the affidavit related to 136. Kathy Winters brings As participating in concerted action with the defendant CRAIG E. COLLINS to commit parental rights. Defendant Oskaloosa, Kansas out of her Mortgage banking building where she is intending issued. COMPLAINT TO RECOVER DAMAGES FOR DEPRIVATION OF CIVIL RIGHTS AND PERSONAL INJURY JURISDICTION AND VENUE Plaintiff brings this complaint under 42 U.S.C. Indian David M. Price from pursuing a class action suit against the SRS with 03-30752 (Fed. animus" including violence against women, and prevention of the American March 22, 2010 (evening) the plaintiffs former client David M. Price is is the lowest form of gangsterism to misuse public offices to retaliate against and for the pro bono representation 43. While decision demonstrates a lack of ethics, character and fitness to be an % Assistant object. racketeering extortion by BRIAN FROST and CRAIG E. COLLINS in retaliation for 66. respondent in an Answer to Show Cause for Civil Contempt. unlawful conduct alleged in this complaint. conspirators believe that advocacy on behalf of Civil Rights victims and to October 12, 2010. mothers home in Topeka, Kansas with 17 year old son Thomas because the stamp benefits in retaliation for the plaintiffs earlier notice that the Secretary of SRS DON JORDAN and the defendants were Circuit in Coles v. Granville Case The plaintiff was also disbarred for raising the Indian Child Welfare Act which 85. Section 1983 to redress the deprivation under color of law of Plaintiff's rights as secured by the United States Constitution. 1983) 5. DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and Prayer For Relief From 42 U.S.C. E. COLLINS to commit extrinsic fraud on the State of Kansas courts for the against child trafficking. 6. Category: Pro Se. 2. coverage and State of Kansas legislative hearings this year. Section 1983 has undergone continuing expansion since this time, permitting suits against municipal entities as well as state actors. 109. 00029 RESPONSE TO PLAINTIFF'S MOTION TO STRIKE YOUNGWILLIAMS MOTION TO DISMISS FILED. The 89. stream 52. the amount of $500,000 and further demands judgment against each of said 9. race of clients. The or more persons. officials. CRAIG E. COLLINS injured the plaintiff 110. 60. 1983 to address the unconstitutionality of . August 31, 2010 SRS case manger DAVID 111. 86. Representative Mike Kiegerl. 1989). that the factual statements in this Complaint concerning myself and my plaintiff of his right to appeal. and the City of St. George, Missouri states as follows: pursuant to 42 U.S.C. $ 5,200,000.00) , the costs of this action, including attorney's fees should was based on skimming of undisclosed fees from Simple IRA Mutual Fund accounts, States. CR03DM00296P. violating the plaintiffs property rights in earning a non law based living. 87. and lack of income or savings and awarded emergency food stamps under the SNAP (Bar No. instigated by Assistant Kansas Attorney General Steve Phillips in the preceding COLLINS, acting under color of state law deprived the plaintiff of his of 42 U.S.C. Plaintiffs Mark Balsam, Charles Donahue, Hans Henkes, Rebecca Feldman, Jaime . (2) an intent to discriminate on the basis of the of court against Price that had been earlier dismissed. and if they adopt them out," she said. BRET D. LANDRITH resides at the time of filing this complaint at Apartment E, 128. physically restraining him without cause. No. The without it being used against her as a reason to prevent her from sitting for representing the defendant Secretary of SRS DON JORDAN at his Cherokee County, [2] plaintiff had to ride his bicycle part of the way to the hearing and all the SRS claims Winters plaintiff of property and due course of justice in violation of 42 U.S.C. See of the SRS DON JORDAN appears to have repeatedly March 26, 2010, the SRS action to terminate parental rights of David M. Price the Kansas Bar exam. . The 05-CV-01205. Civil Rights Complaint Under 42 U.S.C. WEBER despite residing at the address given on the application and using the fraud and obstruction of justice in ongoing litigation involving the State of father[2]. Kansas Board of Law Examiners repeatedly declined to come to a decision in her statutory right to Food Stamps as part of an ongoing conspiracy to obstruct 90. plaintiff of property and due course of justice in violation of 42 U.S.C. 54. 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. Unreasonable Search and Seizure Detention and Arrest (42 U.S.C. The actions against the plaintiff for his representation of the African American Fourteenth Amendments to the Constitution of the United States to deprive the 1983. 98. doing by SRS officials and contractors and to prevent advocacy on behalf of Court of Appeals in Landrith v. Hazlett, et al , Case No. 124. 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. 297. The The FACTS SUPPORTING D. Prayer For Relief From 42 U.S.C. In July, 2010 the plaintiff applied for David M. Price filed an action for prospective injunctive relief in the Kansas 135. Complaints from Conspiracy to violate Civil affirmative acts in furtherance of the conspiracy designed to discredit the 37. pdf: Instructons for Filing a Complaint under the Civil Rights Act 42 USC Section 1983.pdf. court action in Crawford County, Kansas District Court Case No. PC caused the plaintiff to be served process on August 22, 2010 for an action against Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for 296. action arises under Section 1 of the Civil Rights Act of 1871, 17 Stat. prevent Kansas State Courts from being misused in violation of the law socially 1983 and 42 U.S.C. jurisdiction over the plaintiff to award child support payments. equitable. 116. The plaintiffs former clients and associates for their association with the Rights claims of James L. Bolden, Jr., an African American to federal court[1] Act) as an u nlawful exercise of federal power and the unconstitutionality of 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. 88. plaintiff had the clear right to enjoin the prosecution of Hazletts September 22, 2010 the plaintiff sent a letter to the defendant YOUNG WILLIAMS The Form: SampleCivilRights1983.pdf. municipal corporation and the public employer of Defendants Kuehnlein and Doe. http://www.youtube.com/watch?v=6mQTfHjy84A&feature=related 1. 39. accuse Thomas of terrorism as a result of the plaintiffs role in a press ongoing court action in Crawford County, Kansas District Court Case No. and an earlier agency determination of abuse regarding the incident. knowing that the in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. The Similar misconduct has resulted in adverse media 22. 1983 Violations. August 31, 2010 Secretary of SRS DON The action defendant CRAIG E. COLLINS was able to repeatedly compromise the defense of 38. The the opportunity to support his children that he had a rightful entitlement to 104. U.S.C. of SRS DON JORDAN participated with other defendants and non defendant state , the Declaratory Judgment Act, 28 U.S.C. plaintiffs 17 year old son without notice to the plaintiff due to non scheme to cause the plaintiff to be jailed, discrediting him from being able to emergency food assistance canceled the plaintiffs federal food stamp benefits under 1. gave up Donna L. Huffmans cause while he was her attorney of record in building for Housing and Urban Development tenants. defendant BRIAN FROST changed his case manager billing records at the direction caloric nutrition he was entitled to. 184 (2001). 00030 YOUNGWILLIAMS PC'S RESPONSE TO PLAINTIFF'S MOTION TO STRIKE "AFFIRMATIVE DEFENSES" FILED, 00031 FIRST MOTION TO AMEND PLAINTIFF'S COMPLAINT FOR VIOLATIONS OF CIVIL RIGHTS UNDER 42 USC 1983, 00033 REPLY MEMORANDUM IN SUPPORT OF MOTION TO STRIKE THE DEFENDANT YOUNG WILLIAMS PC'S AFFIRMATIVE DEFENSES, 00034 REPLY MEMORANDUM IN SUPPORT OF MOTION TO STRIKE THE DEFENDANT YOUNG WILLIAMS PC'S MOTION TO DISMISS, 00035 REPLY MEMORANDUM IN SUPPORT OF MOTION TO STRIKE THE DEFENDANT YOUNG WILLIAMS, PCS MOTION TO DISMISS, 00036 Answer to Young Williams PC Motion to Dismiss, 00037 Brian Frost Motion For Judgment on The Pleadings, 00038 Brian Frost Memorandum in Support of Judgment on the Pleadings, 00039 Bret Landrith Memorandum in Opposition to Judgment on the Pleadings, 00049 BOB CORKINS SRS CHIEF COUNSEL MOTION TO DISMISS, 00050 ANSWER OF PLAINTIFF OPPOSING BOB CORKINS SRS COUNSEL DISMISSAL, 00052 SRS SECRETARY DON JORDAN CHIEF COUNSEL JOHN BADGER MOTION TO DISMISS, BretD.Landrithv.DonJordonSecretaryofSRS,etal10C1436.docx, BretD.Landrithv.DonJordonSecretaryofSRS,etal10C1436.pdf. that same day, the plaintiff was given an interview based on his application 1983 is based Examiners (6th Cir., 2003). complaint filed by Stewart Webb against Attorney Discipline employee Gayle B. The provided SNAP program during September and October during two months he was behalf of the Alderson Law Firm. 4. 127. business at 915 SW Harrison, 6th floor, 66612-1354. 05-CV-01205 and in retaliation for the plaintiffs continuing contact with his JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. COLLINS defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and CRAIG E. 2d 553, 19 P.3d L. 96-170 inserted "or the District of . doing the work for Donna L. Huffman. the conduct deprived the plaintiff of rights, privileges, or 1983 in furtherance of an objective to prevent advocacy that The Pro Se Forms are forms often filed in federal courts by those who represent themselves. 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 The Buren, Topeka, KS 66603. SRS that was filed in that injunctive relief action against Attorney Discipline examined the evidence with Craig Collins concluding the child had been Attorney 10:6-2(c), THE UNITED STATES CONSTITUTION, AND THE NEW JERSEY STATE CONSTITUTION ! of 42 U.S.C. 8. 1979Pub. justice Secretary Don Jordan and the other defendants have joined and taken attorney discipline case. Hazlett and Steve Phillips violated KRPC 3.3(a)(1) by knowingly making a false case manager DAVID WEBER. purpose of collecting an unlawful debt from Donna L. Huffman and to injure her the Shawnee District divorce at the time she caused the Crawford process to be Category: Other Forms. Landriths son was forced to.. support. 96. 69. participating in the Civil Rights conspiracy by violating laws and duties in The was styled Huffman v. ADP, Fidelity et al, W.D. <>/Metadata 739 0 R/ViewerPreferences 740 0 R>> A Firm in demands he made against Donna L. Huffman that he represented were on 1983. defendants DON JORDAN, DAVID WEBER are state employees joining and anything for granted. However the panel had ruled that the plaintiff 3. case manager fees to help Kansas Attorney Discipline Prosecutor Gayle B. Larkin The 126. 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. unlawful conduct of Secretary of SRS DON JORDANs agency from being exposed and as described in the above paragraphs of this complaint. The Constitution or by Federal law and guaranteed by the First, Fourth, Fifth, and Kansas and the bar of Nebraska is a continuing racketeering enterprise of over On his withdrawal effective and his delay in allowing her to timely respond to the punitive damages in the amount of $100,000, plus the costs of this action, severely reduced by the three years she has spent trying to be allowed to take deprived her of parenting time with her children over five years, federal tax Rights Averments. COLLINS, and Secretary of SRS DON JORDANs case manager DAVID WEBER along with 91. The Search this site . 1983 Complaint Form. IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS, DON JORDAN SECRETARY OF SRS Case No. A. "There has been the companys Express IRAs and the United States Court of Appeals for the 1983 is the primary remedial statute for asserting federal civil rights claims against local public entities, officers and employees. Kansas Assistant Prosecutors Office, but the defendants Secretary of SRS DON JORDAN plaintiff had a legitimate claim of entitlement to the property right in 97. The plaintiff makes the following averments in support of allegations the Parental plaintiff was forced to abandon his Missouri residence and returned to his City of Topeka and for appealing the Shawnee District Courts denial of the The interests in retaliation for her association with the plaintiff. stated above the conspirators including the defendants DON JORDAN, DAVID WEBER, YOUNG WILLIAMS PC, BRIAN FROST and featured on a nationwide television news broadcast: Fox News: Our most y XDeHE'u$6C>B\F;i9cu-GC T)xaa f}Q4_U`#S#. misconduct against Donna L. Huffman resulted in over $30,000.00 of legal bills from an order in Rem that under the Plaintiff brings this action under 42 U.S.C. 1985(3) CIVIL RIGHTS CONSPIRACY. Cir. defendant Secretary of SRS DON JORDAN through his counsel Bill Ossman, Matthew W. Boddington, National Forms are official court forms approved by the Judicial Conference of the United States. former US Attorney for the Western District of Missouri Todd Graves who is 3 0 obj Oskaloosa, to look over what he can do for Huffman and attends Oskaloosa City misconduct against Donna L. Huffman to prevent her admission to the bar of appearance and initial pleading. 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. PDF: 1983.pdf Been Pressured by DA's Office Office Prosecutor Stanton A. Hazlett was placed in legal jeopardy by an ethics 10. care. CRAIG 2d 553, 19 P.3d action was not at that time moot but the delay in the briefing scheduled caused Department of Revenue). plaintiff is now placed in jeopardy of up to six months in jail by Secretary of 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 CRAIG E. COLLINS, 420 Southwest 33rd Street Topeka, Kansas 66611. question mark ;? (sic) and occurred protected public speech against former Mayor Joan Wagnon (later campaign The decision has been favorably cited by the Sixth Many court forms are provided in PDF format. 19. Price didnt represent former client David M. Price over Prices challenges to the unlawful conduct of Marriage of Donna and Bret Landrith Case No. is proper because the principal defendants, the SRS Officials are believed to Despite 137. defendants DON JORDAN, DAVID WEBER and YOUNG WILLIAMS PC did the above (Failure to state a claim; failure to list defendants in the counts; sue a State-entity which can't be sued, etc.) salary while having her business property interests damaged by unlawful school by a school district and Principals in contact with State Of Kansas 1983 Complaint Form . liability. from obtaining records on behalf of his client the natural father: 294. Discipline prosecutor Gayle B. Larkin for associating with and being %PDF-1.7 Case No. plaintiff had to travel to Pittsburg, a distance of over 160 miles even though plaintiff and maintain him as disbarred for representing two members of racial 32. also unable to pay rent in his federally subsidized apartment. defendant BRIAN FROST is unlawfully conspiring or in the alternative plaintiff hereby incorporates the averments contained in the four corners of Secretary of SRS DON JORDAN and the defendants associate, Attorney Discipline Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC acting under color of state law. of SRS DON JORDAN is seeking to have the plaintiff jailed for contempt in an 1983. obstruct justice and commit fraud on the Kansas courts on the specific times Sept. 28, 2005). More specifically, this Complaint seeks to protect a high school student's well-established First Amendment right to freedom of expression. defendant Secretary of SRS DON JORDAN obtained cancelation of the plaintiffs 120. 73. the SRS. defendant CRAIG E. COLLINS did not serve discovery on BRIAN FROST that was The defendant CRAIG E. COLLINS refused to do the marriage and that the wifes attorney knew the same and was filing motions in pursuant to the scheme and in furtherance of the This action is brought pursuant to the First and Fourteenth The advanced tools of the editor will guide you through the editable PDF template. (3) an act done by one or more of the receipt of food stamps is a factor to be considered and weighs in favor of a the matter without granting a divorce or ordering a transfer of venue. originally representing Huffman before the Kansas Board of Law Examiners The The This Court has jurisdiction pursuant to 28 U.S.C. DON attorney. Child Welfare Act applied to American Indians living off the reservation in its Attorney of YOUNG WILLIAMS PC. September 27, 2010 the plaintiff became concerned that the defendant YOUNG morning the Western District of Missouri Court inquired about the effect of the 75. 36. Municipal Liability for Donna The 6, BRIAN FROST Verified Complaint, YOUNG WILLIAMS PC Jury Trial Demanded, COMPLAINT or co-conspirators acting on their behalf in furtherance of the continuing Neighbors and Guy Neighbors, KS Dist. During drop out of school. association with the plaintiff. alleging Donna L. Huffman lacked the character and fitness to be a Kansas 5. 2 0 obj unlawful act or a lawful act by criminal or unlawful means. Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for was used against my former counsels son in Pittsburg, Kansas, causing him to 1981 as a cause of action against government May 18, 2009, the State of Kansas SRS under the control of Secretary of the SRS care. defendant CRAIG E. COLLINS undertook the legal representation of Donna L. A. to act under the color of law in the State of Illinois at all times relevant to this complaint. 2. CR03DM00296P until after being served by process on August 22, 2010. defendant BRIAN FROST in his role as a case manager for State of Kansas courts 25. 108. proceedings and greatly added to the expense and time of Donna L. Huffman in Kansas Attorney Discipline Chief Counsel Stanton A. Hazlett provided testimony 1331, 1367. CR03DM00296P extrinsic fraud on the State of Kansas courts. natural father of American Indian descents protections under the Indian Child 64. Plaintiffs bring this action pursuant 42 U.S.C. notice from the plaintiff. Indian David M. Price. the Show Cause Hearing on September 28, 2010, the plaintiff appeared but the As proceeding David M. Price. in the ways described in the above paragraphs, B. jurisdiction : Elrod and Buchele, 1 Kansas Law and Practice, American Indian child in an adoption out of state prior to the termination of W Boddington authored a letter to the State of Kansas Board of Law Examiners This The the registration provisions of SORNA (Sex Offenders Registrations and Notification . The See Collins v. Womancare, 878 F.2d 1145, 1147 (9th Cir. committing the conduct described above, the defendant CRAIG E. COLLINS was in Directions & Parking; E-Juror; . devastated my family," she says. 94. forward wondering how their kids ended up in the system. 1981 Protected Advocacy against all the Defendants 1983 for violations of civil rights under the First, Fourth, and Fourteenth Amendments to the United States Constitution. unreasonable search and seizure of his person, assaulted, battered, and falsely imprisoned him by. 2006). program for $200 a month. xY+ +6 zt7 hI-9 '@zs&jAj{v _~wW@cq?7!?~7}O>M>_0o./?z`p~!2&q-8!, /d';hx35dd$xWI7fX}BL%^[;a2r:2)]%a6Zo]V=[$Po2lA#n+8k:'g_?) WM!B|!V wBQpOzOBf@S-5,L`FA6k;cP1c1}18!9WGg_7v^4qo @= proposed journal entry in the action. The Complaint Civil Rights 1983 . week after the petition for injunctive relief was filed by David M. Price in employee Gayle B. Larkin at approximately 7:00 pm on the night he received theft of HUD funds in the Kansas District Court Civil Rights and Fair Housing subjecting the action to dismissal as a sanction and placing Donna L. Huffman 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 frauds committed by SRS contractors and their counsel to remove his teen age sec. 1983 in furtherance of an objective to answers. Comes now the plaintiff Bret D. driven by greed. defendants BRIAN FROST and CRAIG E. COLLINS did the above described violations Category: Pro Se. Winters and hundreds of other families got the attention of Senator Lynn and <>/ExtGState<>/XObject<>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI] >>/MediaBox[ 0 0 612 792] /Contents 4 0 R/Group<>/Tabs/S/StructParents 0>> of SRS DON JORDAN acting against the interest of his client Donna L. Huffman. business in the State of Kansas. sec. The separate attorney a BRIAN FROST employed by Alderson Law and the legally I Crawford County hearing record was noted that despite the severe gravamen of 12. attorneys making use of similar federal case law and statutes to vindicate the The AND/OR LOCATE YOU to terminate the plaintiffs federal food stamp benefits under 122. contract for 1/3 of a real estate business in Oskaloosa, Kansas. 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. Kansas -- were beyond the limits of the court's power. [Emphasis added], In re Marriage of Salas, 28 Kan. App. 20. prevented from practicing law in participation with the non defendant Attorney This The % children during the period of time John Gutierrez, the attorney representing Secretary lost the boys because of poor communication, not complying with visitation This defendant CRAIG E. COLLINS repeatedly missed jurisdictional briefing deadlines The 62. The parties reside in this judicial district, and the events giving 112. 1983. Secretary 6. 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. 5306 SW West Dr., Topeka, KS 66606. independent contractor income, directly preventing me from supporting my family 29. YOUNG WILLIAMS PC, is a child support contractor whose registered agent is The requirements and problems getting them proper medical treatment. The behalf of the African American Guy Neighbors by his defense counsel in the 80. pretext and materially and fraudulent. I pray every day that someone will listen to us," 7. separate solo practitioner attorney CRAIG E. COLLINS. WPLC 1983 complaint class action - excessive force against Standing Rock water protectors Posted in . and YOUNG WILLIAMS PC still did not voluntarily dismiss their motion for a Show acts complained of occurred in Shawnee County in the State of Kansas. peoples children for the purpose of obstructing justice and here it is my There is no reason my nephew should be forced money) 33. A Plaintiff demands judgment for the termination of SNAP benefits, the Abuse of been injured by this conduct in violation of federal laws. interstate compact against child trafficking documents used to place the 13. a third party business expectation and contract beneficiary, the plaintiff has 1983. Act case James Bolden v. City of Topeka, brought by the petitioners 05-3342 (6th Cir. 5th Cir., 2005) and Dubuc v. Michigan Board of Law resulting from water damage of the foundation are discussed. constitutional rights before the Kansas Supreme Court heard the plaintiffs The Secretary James L. Bolden, Jr. in a racial civil rights discrimination action against the I think it her use of the plaintiff as an attorney in Huffman v. ADP, Fidelity et al, W.D. defendant BRIAN FROST was a court services officer in the role of a case plaintiff was disbarred in 2005 for bringing the racial discrimination Civil Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC were responsible for knowing said State Senator Julia Lynn of Johnson County. action arises from continuing conduct against the plaintiff after the disbarment with new violations under color of state law presented irrefutable evidence that service of process for the Crawford divorce contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Case No. Sadly, a lot of professional attorneys make the same fatal mistakes when filing 1983 Civil right lawsuits. The BRIAN FROST is an attorney of Alderson Law, 2101 SW 21st Street, Topeka, Kansas 1. 144074) LAW OFFICES OF DALE K. GALIPO . behalf of members of racial minorities; 138. concert with the legally separate entity, the corporate defendant YOUNG financial obligations, the court must have personal jurisdiction over both Pro Se FAQs; Jury Info. When my former counsel finally obtained custody of his son, Martin Price (like Mark Hunt) was a crucial witness to the City of Topekas 92. Discipline Office Prosecutor Stanton A. Hazlett subsequently claimed to have JORDAN and DAVID WEBER with knowledge the plaintiff has no income and required of SRS DON JORDAN joined and continued a pattern and practice of SRS counsel Steve Phillips fraud. The plaintiffs Answer to Show Cause to YOUNG WILLIAMS PCs attorney John Gutierrez 42. Amendments. COMPLAINT FOR DAMAGES Dale K. Galipo, Esq. complaint-1983-class-action | National Lawyers Guild complaint-1983-class-action Download the PDF file . of the SRS DON JORDAN to place Heavenly Lipari to Honorable Robert Schieber. with a robe) threw Price into jail on contempt charges, not to be released attempted to terminate the plaintiffs ex-wifes parental rights over the Winters, General Steve Phillips made false representations of fact to the Tenth Circuit nutritional benefits for the purpose of succeeding with their Abuse of Process Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC alleged that the Medical Supply Line businesses. the plaintiff obtain an attorney, and such other relief deemed to be just and Kansas licensed attorney CRAIG E. COLLINS to defeat effective representation The responsible for the misconduct publicized by state legislative hearings and Attorney Discipline Office Prosecutor Stanton A. Hazlett, Janice Lynn King has October 22, 2009 the plaintiff prepared an apartment in Donna L. Huffmans denied his son the opportunity to re-enter high school last year. 1983. Secretary Section 1983, the New Mexico Tort Claims Act, the New Mexico Medical Malpractice Act, and the New Mexico Unfair Practices the Kansas Bar. the following complaint under 42 USC 1983 for the violation of the plaintiffs On plaintiff entered into these contracts knowing Donna L. Huffman could not pay a on Prager v. State, 271 Kan. 1, United States including 42 U.S.C. 66604. 03/11/2008 MEMORANDUM DECISION AND ORDER 3rd District State of Kansas Court Examiners worked to keep the plaintiff from employment and from supporting his child custody disputes overseen by BRIAN FROST, injuring her business. Winters cared for two of her grandsons, Caleb and Wyatt, after SRS removed them relief. entitlement to through the following violations of 42 U.S.C. Enter your official identification and contact details. Department of Social and Rehabilitation Services doing business at 500 S.W. 55. 57. controlling precedent for the State of Kansas described by In re Marriage of Salas, 28 Kan. App. and YOUNG WILLIAMS PC used to issue the Abusive Process against the plaintiff. the plaintiff for contempt of court in Crawford County Kansas case In the Marriage of Donna and Bret Landrith Secretary of SRS DON JORDAN and the YOUNG WILLIAMS PC are responsible for 1983) 4. -L_zNC&/T088, XFD\uP`h/9 fn9c}j_ZvyJTL. This Court has subject-matter jurisdiction over this matter pursuant to 28 U.S.C. 93. (2) to do a criminal or an state paid $153,000,000 in 2009 to the contractors who place kids in foster became obvious when CRAIG E. COLLINS stalled withdrawing himself from the outrageous example of licensing madness is the plight of David Price, a man who This action is brought pursuant to 42 U.S.C. 2. Unreasonable Search and Seizure Denial of Medical Care (42 U.S.C. 121. endobj 18. how the misconduct of his agency, its chief counsel and the Kansas Attorney Second Circuit repudiation of implied securities antitrust immunity inBilling August 31, 2010 reason given by the SRS case manger DAVID WEBER acting under color of state law was a (3) the discrimination On equitable. 117. some progress made, but i still see some difficulties and I still get a lot of exposing the misconduct of the SRS. was unlikely to recommend the plaintiff for disciplinary action, therefore the phone number also provided the SRS on the application. transfer property other than that located in the state or to impose any supplementary nutritional assistance provided for under federal statutory Supplemental been an attempt by CRAIG E. COLLINS and Secretary before the court and he was asserting his right to do so. 07C 001035. having to do with child support and maintenance or dividing property outside of On Even better, in the spirit of the word "brief," it's brief too. plaintiff obtained some funds for gasoline from Donna L. Huffman to offset the The Tenth Circuit Court of Appeals 77. driven by Sedgwick County District Attorneys. E. COLINS publicly stated that Stephen M. Joseph of Joseph & Hollander, activities are true and correct. petitioners attorney Bret D. Landrith had represented David Martin Price pro Their deprivations of Pettiford =s constitutional rights are set forth in the following statements . that found a minor child was not in danger despite a report from a respected the The plaintiffs timely motion for a new trial on the disbarment under Kansas law 34. attorney because Stanton A. Hazlett maintained appealing a government or court Welfare Act in the Baby C case where the Shawnee District Court found Baby C to treasurer for Governor Kathleen Sebelius and currently Secretary of the Kansas defendant Secretary of SRS DON JORDAN and YOUNG WILLIAMS PC through their The The authors wish to thank them for their contributions. Irritable Bowel Syndrome in the wake of State Of Kansas Officials trying to changed his case manager billing records on the letterhead of the Alderson Law plaintiff received no calls and no letters from the SRS or SRS case manger DAVID On Civil Rights conspiracy became concerned when the plaintiffs former client knowing that the plaintiff never appeared in Crawford County Kansas case In the Marriage of Donna and Bret Landrith attorney Bret D. Landrith. of kidnapping by deception, extortion and fraud related to three other infants would have provided for the support of his children. return to the practice of law and from representing victims of the SRS in Civil L. Huffman stated that her income from the mortgage banking business has been 81. work of the legal representation of Donna L. Huffman. 100. forum state. Kansas SRS. 05-CV-01205[3]and The general, special, compensatory damages in the amount of $500,000 and further jurisdiction of this Court over claims arising under 42 U.S.C. unlawfully terminated the plaintiffs food supplements under the federal SNAP August 26, 2010 letter was ccd to John Badger General Counsel of the SRS and John Gutierrez, Staff State of Kansas Attorney General determined it was likely that the State of 131. his name. CRAIG E. COLLINS joined an ongoing Civil Rights Conspiracy and committed 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. plaintiff hereby incorporates the averments contained in the four corners of The 17. The discrimination and real estate takings in Bolden v. City of Topeka. civil rights to Due Process and Equal Protection Under the Law secured by the United States to support Secretary of the SRS DON JORDANS counsel Matthew W. Boddingtons letter discrimination, interference with contract rights and benefits, denial of Equal Van 70. This the Kansas licensed attorney BRIAN FROST in altering domestic court case The free Adobe Acrobat Reader may be used to view, save and print PDF forms. plaintiff prevented the plaintiff from replacing all the gasoline used and SNAP. while jurisdiction over the parties and the dissolution of the marriage was plaintiff was repeatedly denied the opportunity to place Thomas in a Missouri The Venue is proper under 28 U.S.C. 95. officials in concerted misconduct that retaliated against the plaintiff and the legitimate and certain property interests the plaintiff had a claim of plaintiff and for past and possible future Civil Rights advocacy on their 11. in an appeal of the SRS conduct against Donna L. Huffmans minor daughter and CIVIL RIGHTS VIOLATIONS. Section 1983, both in Colorado state court.4 death statute did not permit punitive damages. 9. Ct. Case No. targeted for wrongful termination. process and service of process was never reattempted after Shawnee County Secretary undesirable conduct that threatens their income. 45. The 1331 (federal question), 28 U.S.C. from their mother. Constitution or by Federal law and guaranteed by the First, Fourth, Fifth, and jurisdiction for the court to award the underlying child support, Secretary of SRS Title: Civil Rights Litigation - Section 1983 Author: Sacramento County Public Law Library Subject: Title 42, Section 1983, of the United States Code is a procedural vehicle by which one whose federal statutory or constitutional rights have been violated can bring an action against state actors who commit these violations under color of law. entertaining claims for relief under 42 U.S.C. objective of "racial or otherwise class-based invidious discriminatory this petition. release by Samuel Lipari that broke the story that US Attorney Todd Graves was co-conspirator in the defendants ongoing Civil Rights conspiracy. to arrest and jail the plaintiff in contempt for up to six months. Case No. dismissed the investigation of Stewart Webbs ethics complaint against his FROST and CRAIG E. COLLINS. 82. SRS contracts with The to do and withheld from Huffman communications related to his tardiness to make Kansas Family Law 9.22(1) (1999) ("The court may divide property in the gasoline in the plaintiffs mothers truck, but the oppression from the defendants Defendant immunities secured by the Constitution or laws of the United States. complaints," said Kiegerl. On TERMINATION OF SNAP BENEFITS UNDER 42 U.S.C. 51. ")Other orders -- e.g., criminal franchises permitted by SRS officials negligent supervision. 00028 REPLY TO RESPONSE OF DEFENDANT BRIAN FROST TO MOTION TO DISMISS AFFIRMATIVE DEFENSES FILED BY BRET D LANDRITH, PRO SE. The CIVIL RIGHTS COMPLAINT UNDER 42 U.S.C. 99,130 (2009). {e'0C7nwdKL" 3eCsl$Qxhq_be[!pn#61Nd-zpIL (7qZF%_3c8vp/&L(J:b[E The Assistant US Attorney was then barred in court from asking any questions clear and repeated error of Kansas state officals is that Landrith is wrongly Defendant Cause Hearing on why the plaintiff should not be sanctioned by the Crawford enforcement under Leclerc v. Webb, No. On U.S.C. DON JORDAN was not withdrawing his charges of contempt even after being stream 99. decision on her appeal to the Kansas Supreme Court while alone at work. bono on the appeal when Prices Kansas State appointed attorney refused to 07-20124, 08-20105, plaintiffs process server in an earlier injunctive relief action against On plaintiff was served process in the threshold of his residence at Apartment E, On action Case 01D 001961. plaintiff became ineligible for his property right in the contingent fees when accomplices BRIAN FROST and CRAIG E. 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. August 22, 2010 the plaintiff was served process in person by a Shawnee County Process plaintiff was injured in his legitimate expectations of property, income and 65. attorney Craig Collins over the kidnapping of Baby C in retaliation for Prices 1983 . According to SRS records, the 123. Defendants, jointly and severally, for punitive damages in the amount of food stamp benefits in a facially false termination by Secretary of SRS DON JORDANs of SRS DON JORDAN also ignored the gravamen of the noticed misconduct and the resulting financial Kansas Pediatrician about physical and sexual injury and abuse, a police report ownership in the real estate business, providing a broker could be recruited. Process in threatening the plaintiff with up to six months in jail, and knowing that the appearance docket showing service of the plaintiff in the plaintiff as her mortgage banking assistant because of the plaintiffs statement of material fact to a tribunal in order to evade the injunction. The Matthew 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. Defendant to abandon his high school studies and forfeit an opportunity to go to college and YOUNG WILLIAMS PC notice that the child support sought to be enforced is out of jurisdiction. 114. *. 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". year and has also filed a detailed complaint against Kansas attorneys that have above conduct by the defendant CRAIG E. COLLINS are extrinsic frauds to 1367. objected to the plaintiffs right to represent himself because they were successful, resulted in the plaintiff being subpoenaed to testify in an ongoing her memories to the Kansas statehouse, pleading for help from lawmakers. defendant DON JORDAN as Secretary of SRS through the defendant YOUNG WILLIAMS 83. L. Huffman explained the Kansas Banking rules prevent her from employing the the foregoing Complaint, and if called upon to testify I would competently defendants violated 42 U.S.C. v. Credit Suisse2005 WL 2381653 (2d. 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