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___________; [_____________]
c/o 4719 Quail Lakes Dr., Ste G #352
Stockton, California [95207] CASE No. __________________
Judge ______________________
Plaintiff
Date _______________________
Vs
__________________________ ,
Employee of CORPORATION
STOCKTON POLICE DEPARTMENT,
CITY OF, STOCKTON,
22 E. Market Street VERIFIED COMPLAINT FOR
Stockton, CA. 95202 MONEY DAMAGES,
CIVIL RIGHTS VIOLATIONS,
And U.S.C. Title 42, Section 1983, 1985
1986, 1988
Defendant
______________________________,
Employee of CORPORATION
STOCKTON POLICE DEPARTMENT,
CITY OF, STOCKTON
22 E. Market Street
Stockton, CA 95202
And
Defendant
_______________________________,
Employee of CORPORATION
STOCKTON POLICE DEPARTMENT,
CITY O, STOCKTON
22 E. Market Street
Stockton, CA 95202
And
Defendant
And
Defendant
And
Defendant
BROWNIES TOWING,
40 S. UNION ST.
STOCKTON, CA 95205
And
JURY DEMAND HEREIN
Defendant
JOHN DOE #1
Employee for BROWNIES TOWING,
40 S. UNION ST.
STOCKTON, CA 95205
Officials acting under color of State law, for civil rights violations involving non-compliance,
impairment of reputation, excessive extortion fees, theft of property, trespass, and denied
“Plaintiff ” her “Right to Liberty” on a public right of way in which to provide life essentials
COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS
Page 2 of 13
for her family. At all times relevant herein, the Defendants, all City “State” Officials,
employees and their agents acting under color of State law and outside their jurisdiction and
scope of authority, willfully caused “Plaintiff” a damage, deprivation of rights, physical, and
mental injury, and in so doing, violated clearly established law as those laws apply to
“Plaintiff’s” rights protected under the Bill of Rights, particularly under the 1st, 4th, 5th, 6th, 8th,
Article of the Bill of Rights (Amendments) and pertinent to the 14th Amendment to the
Constitution of the united states of America. Be it known, each of the City “State” Officials
herein have sworn an “Oath of Office” in regards to their duties, and therefore, each of their
acts under “Color of State Law,” equates to criminal conspiracy under Section 1985, working
activity.
2. All allegations set forth in paragraph 1 are incorporated herein its entirety by reference.
3. “Plaintiff” brings this action pursuant to Title 42 USC Section 1983, 1985, 1986, 1988,
and invokes the jurisdiction of this court pursuant to Title 28 USC Section 1343 (A), (3), (4),
and Title 28 USC Section 1331, and pertinent to the 14th amendment, Title 42 USC Section
1983, and the Civil Rights Act of 1870, Section 6, “rights protected under the Constitution”
particularly under the 1st, 4th, 5th, 6th, 8th, and pertinent to the 14th Amendment to the
Constitution of the united states of America, and Title 18 USC Chapter 13 Section 241 –
Conspiracy against rights, Title 18, Chapter 13 Section 242 – Deprivation of rights under the
color of law, Title 18 USC Chapter 4 – Misprision of Felony, Title 42 USC Section 20000d-
7.
4. All allegations set forth in paragraph 1 and 3 are incorporated herein in its entirety by
reference.
on San Joaquin County, California Republic. “Plaintiff,” has lived on California since birth.
times relevant, to this complaint, is a sergeant for the STOCKTON, CITY OF, POLICE
in such capacity as agent, servant, and/or, employee of, STOCKTON, CITY OF, POLICE
to this complaint, is an officer for the STOCKTON, CITY OF, POLICE DEPARTMENT,
STOCKTON, CALIFORNIA, and a resident of SAN JOAQUIN COUNTY, acting in such capacity as
agent, servant, and/or, employee of, STOCKTON, CITY OF, POLICE DEPARTMENT, OFFICER
relevant, to this complaint, is an officer for the STOCKTON, CITY OF, POLICE DEPARTMENT,
STOCKTON, CALIFORNIA, and a resident of SAN JOAQUIN COUNTY, acting in such capacity as
agent, servant, and/or, employee of, STOCKTON, CITY OF, POLICE DEPARTMENT, OFFICER
times relevant, to this complaint, is an officer for the STOCKTON, CITY OF, POLICE
10. JOHN DOE #1 hereinafter, JOHN DOE #1, at all times relevant, to this complaint, is an
employee, agent, servant, tow truck driver, for the BROWNIES TOWING, residence unknown, acting
in such capacity, and in concert, as agent, servant, assigns, and/or employee of Defendant,
IV STATEMENT OF FACTS
11. All allegations set forth in paragraph 1 through 14 are incorporated herein by reference.
12. All factual allegations herein this complaint began on November 03, 2010 on or about 3:45 pm
13. All allegations, injury and damage alleged in this complaint are on going and continue unless
otherwise stated.
14. On November 03, 2010, on or about 3:45 pm, “Plaintiff,” was going east on _____________,
17. Plaintiff has in her possession a Lawful Bill of Sale, as proof of her sole ownership of her
20. On November 03, 2010, on or about 3:45 pm, Plaintiff was not operating her conveyance in
Commerce,
21. On November 03, 2010, on or about 3:45 pm, Plaintiff was not Hauling Passengers or Cargo
for Hire,
COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS
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22. On November 03, 2010, on or about 3:45 pm, SERGEANT _____________, perpetrated a
fraud when he, deceived Plaintiff into Believing there was an emergency,
24. DRIVING his CITY, patrol car close behind Plaintiff’s conveyance and
26. Plaintiff pulled off the right of way and stopped, giving right of way to the emergency vehicle.
39. Plaintiff, or her property, was not involved in any criminal activity before, during or after
40. SERGEANT ____________ ordered Plaintiff’s private property to be taken from Her
possession,
41. and removed from where She had placed it, into His and Other’s control, and their use.,
42. with intent to damage, injure, and deprive Plaintiff of her property,
COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS
Page 6 of 13
43. absent a Fourth Amendment Warrant, or privilege to do so,
44. OFFICER’S _____________ and ____________ arrived and all officers were armed and
dangerous,
52. OFFICER ____________ took Plaintiff’s private property, fingerprint, without Her consent,
53. OFFICER ________________ took Plaintiff’s private property, photograph, without Her
55. over Plaintiff’s, objection, against Plaintiff’s will, and without Plaintiff’s consent,
56. Plaintiff was forced, by the armed Highway Men, impersonating lawful Officers, to remove
57. Absent any (fourth,) 4th, amendment warrant, or privilege to do so, the Highway man,
employee JOHN DOE #1, searched, and seized Plaintiff’s conveyance, property, and removed
Plaintiff’s property from where she parked it, without Her consent, over Her objection, and against
Her will.
58. and into Highway Man JOHN DOE’S #1 private possession on his tow truck,
59. therefore depriving Plaintiff of her private property without privilege to do so,
COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS
Page 7 of 13
60. under “color of State law”, Highway man JOHN DOE #1, acted in concert with the other
Highway men, who were impersonating lawful officers, and caused Plaintiff the damage alleged
herein,
62. Complainant does not have a Contract with the Corporation State of CALIFORNIA for a
63. Complainant’s property is not registered as a motor vehicle with the Corporation,
V CONCLUSION
36. All allegations set forth in paragraph 1 through 67 are incorporated herein its entirety by
reference.
37. According to the 1st, 4th, 5th, 6th, 8th, pursuant to the 14th Amendment of the United States
38. Complainant has the right to use the public right of ways, in which to provide life’s essentials for
her family, without being terrorized by corporate employees acting as “Tort Feasors.”
V RIGHT OF ACTION
39. All paragraphs set forth in paragraph 1 through 38 are incorporated herein, by reference.
40. On November 03, 2010, Plaintiff was stopped on a public right of way, compelled to vacate her
property, terrorized, in fear of her life, held captive, not free to leave, had her property searched
and seized, charged with numerous administrative traffic infractions; when Plaintiff has “NO”
right of ways in her private conveyance, 2006 Ford 4X4, when she was stopped by SERGEANT
42. Complainant property was seized and removed by a third party, JOHN DOE #1.
43. All allegations set forth in paragraphs 1 through 42 are incorporated herein by reference.
44. Federal Causes of Action, on November 03, 2010 on or about 3:45 pm, the herein described
actions, engaged in under color of state law, and working in concert while in non-compliance
with rules of agency and non-compliance with fiduciary duties to the public and responsible
deceptive trade practices and ratification thereof, for the acts by the Defendants, SERGEANT
____________________, JOHN DOE #1 are being sued in their individual and capacity.
45. FIRST CAUSE OF ACTION, as officers, employees, servants, assigns, and agents, who
deprived the Plaintiff of her rights secured to her by the Constitution of the United States of
America including the right to use the public right of ways, but not limited to her First (1st)
Amendment right to freedom of expression and redress of grievance, which was denied by
Defendants, when the Defendants go in disguise upon the highway, acting under the color of
State law, falsely created an illusion of emergency, took control and possession of Plaintiff,
searched and seized property without redress of grievance operating outside their jurisdiction and
scope of authority.
who deprived the Plaintiff of her rights secured to her by the Constitution of the united states of
America including the right to use the public right of ways, but not limited to her Fourth (4th)
Amendment right to be free from unlawful search, seizure, detention of her person, secure in her
conveyance, papers, and effects from unreasonable searches, terrorized and unprovoked attacks,
absent a Fourth Amendment Warrant signed by a judge, and absent an Affidavit of Complaint
signed under penalty of perjury by a competent witness; by the above Defendants acting under
the color of State law held Plaintiff against her will, over her objection, without her consent and
47. THIRD CAUSE OF ACTION, officers, deputies, employees, servants, assigns, and agents,
who deprived the Plaintiff of her rights secured to her by the Constitution of the united states of
America including the “Right to Travel” on the public highways, but not limited to her Fifth (5th)
crime absent an indictment from a Grand Jury, nor be deprived of life, liberty, or property,
without due process of law, nor shall Plaintiff’s private property be taken without just
compensation. Plaintiff is denied equal protection of the law, and her right to be free from terror
and fear of unjustified arrest, searches and seizure by the above Defendants acting under the
48. FOURTH CAUSE OF ACTION, officers, deputies, employees, servants, assigns, and agents,
who deprived the Plaintiff of Her rights secured to Her by the Constitution of the united states of
America including the right to use the public right of ways, but no limited to her Sixth (6th)
Amendment right to be informed of the nature and cause of the charges against Plaintiff, be
confronted with the witness against her, a crime shall have been committed. Plaintiff did not
commit a crime on November 03, 2010 on or about 3:45 pm, when stopped by SERGEANT
COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS
Page 10 of 13
____________________, OFFICER ________________, OFFICER ____________, OFFICER
___________________, and JOHN DOE #1. Plaintiff did not commit a crime before November
03, 2010.
49. FIFTH CAUSE OF ACTION, officers, deputies, employees, servants, assigns, and agents, who
deprived the Plaintif of her rights secured to her by the Constitution of the united states of
America including the right to use the public right of ways, but not limited to her Eighth (8th)
Amendment Right against cruel and unusual punishments inflicted, includes excessive bail.
Plaintiff suffered physical and emotional, cruel and unusual punishment at the hand of
OFFICER _________________, and JOHN DOE #1. Plaintiff will be charged extortion fees by
a third party, for recovery of her property unlawfully removed by JOHN DOE #1, on November
03, 2010.
WHEREFORE: The Complainant demands judgment against Defendants, jointly and severally as
Defendants violated the united states Constitution, First (1st), Fourth (4th), Fifth (5th), Sixth (6th), Eighth
(8th), pertinent to the (14th) Amendment; Defendants denied Plaintiff’s right to travel upon the public
(a) Ten Million Dollars for violation of my rights guaranteed by the Constitution of the United States
of America;
(b) Declaratory judgment for compensation, search, impound and rental fees from third party
Defendant for deprivation of property, 2006 White Ford 4X4 Diesel Truck seized from
Complainant;
COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONS
Page 11 of 13
(c) Declaratory judgment for cost of disbursement, research, and time incurred for this action;
(e) All attorney fees in processing this action pursuant to Title 42 U.S.C. Section 1988;
(f) All rights reserved and the right to amend complaint as needed;
(g) Complainant reserves the right to correct or update list of Defendants reflecting injuries due to
Non-Compliance.
(h) Declaratory judgment for Complainant’s record to be totally expunged; A151303 on November 03,
2010, 3:45 pm, all fingerprints, photos, and report expunged from the INLET system.
(i) Such other and further relief as to the court deems proper.
Dated: _____________________________
_____________________________
__________________r., Ste G, #352
Stockton, California (95207)
I have read the COMPLAINT FOR DAMAGES, CIVIL RIGHTS VIOLATIONS, U.S.C. Title
42, Section 1983, 1985, 1986, 1988, & Civil Rico and know the contents thereof to be true; and the
same is true of my own knowledge, except to the matters, which are therein stated on my information
and belief, and as to those matters, I believe them to be true. The foregoing is true, correct, complete
________________________________________
________________________________________
________________________________________
STATE OF,_______________________________________________
seal