CAUSE OF ACTION
Violations of 42 U.S.C.§1983
The defendants have violated clearly established statutory and constitutional rights of which a reasonable person would have known.
Violations of Rights Under 42 U.S.C.§1981 Guaranteed by 42 U.S.C.§1983
The defendants have retaliated against the plaintiff repeatedly for protected speech on behalf of an African American and his witnesses in representing James Bolden’s claims for redress against misconduct by the City of Topeka that violates Mr. Bolden’s right to own and enjoy property, Mr. Bolden’s right to testify in court and to not be discriminated on the basis of race.
The defendant Honorable RICHARD D. ANDERSON encouraged, directed, and or deceived the Honorable G. JOESEPH PIERRON, JR., Honorable HENRY W. GREEN, Honorable LEE A. JOHNSON, and JONATHAN M. PARETSKY into creating an ethics complaint against the plaintiff for the purpose of causing the defendants STANTON A. HAZLETT and FRANK D. DIEHL to prosecute the plaintiff in a common enterprise to deprive James Bolden and his witness David Price of counsel for the purpose of protecting their common enterprise lead by the defendants Honorable RICHARD D. ANDERSON and Honorable MARLA J. LUCKERT that conducts the affairs of Shawnee District Court in a fashion that is vulnerable to criticism for subsidizing violating crime and fostering corruption in the adjudication of civil controversies to a degree that might cause the public disclosure of financial accounts.
The defendants through a letter drafted by STANTON A. HAZLETT declared their intent to prosecute the plaintiff on May 3rd because on the proceeding day he appeared in federal court where he had designated the witnesses James Bolden, Fred Sanders, David Price and Mark Hunt( all being of either African American or American Indian protected classes) to testify in a temporary restraining order hearing about the retaliations against them by the City of Topeka for protected speech under the color of law, often while under the jurisdiction of Shawnee District Court.
The appearance of Mark Hunt on the stand, called by the plaintiff because of retaliation for exercising his right to testify under 42 U.S.C.§ 1983 by both the State of Kansas and the City of Topeka caused an emergency for the defendants common enterprise. Unknown to the plaintiff, the defendant Honorable RICHARD D. ANDERSON had made a much earlier arrangement to cause Mark Hunt to lose custody of his children in a divorce which was frustrated when another Shawnee County judge, acting as a mediator then taking the stand as a witness testified falsely against Mark Hunt. The judge has also withheld the fact that he had an amorous relationship with Mark Hunt’s estranged wife while acting as a mediator. Because the Shawnee District judge believed Mark Hunt to be an inferior African American, the judge made false material statements contradicting the notes in his own hand, used by Hunt to impeach the judge’s testimony. As a consequence, the defendant Honorable RICHARD D. ANDERSON was unable to complete his plan to take away Mark Hunt’s children until City of Topeka officials assisted in reopening the divorce custody order by fabricating a false crime.
The plaintiff knew only that after years of harassment, City officials had caused Mark Hunt to be arrested without being read his rights or having access to a lawyer and to be held for three days then released without being charged. The arrest was then used in an ex parte hearing against Hunt while depriving him of discovery.
Rights To Not be Retaliated Against for Protected Speech
Guaranteed by the Fourteenth Amendment and 42 U.S.C.§1983
Rights To Practice Law Under Kansas Rules of Professional Conduct
Guaranteed by the Fourteenth Amendment and 42 U.S.C.§1983