Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895...

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1 2 3 Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 [email protected] 4 Plaintiff 5 6 7 UNITED STATES DISTRICT COURT 8 MISSOULA, MONTANA . 9 MISSOULA COUNTY DIVISION 10 Jason Christ, Pro Se, 11 Plaintiff. l2 vs. 13 City of Missoula Police 14 Department, Colin Rose, ) ) Case No. : ) ) Department: ) ) PLAINTIFF'S APPLICATION FOF ) TEMPORARY RESTRAINING ) ORDER, PRELIMINARY AND ) PERMANENT INJUNCTION, AND ) ORIGINAL VERIFIED COMPLAINT 15 Stacy Lear, Missoula county) FOR DAMAGES ) 16 Attorneys Office, Andrew ) ) 17 Paul, Paul Van Valkenberg, ) ) 18 Missoula County 911, ) ) 19 Officers John Does l-12; ) ) 20 Defendants ) ) 21 VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 1 Case 9:12-cv-00106-DLC-JCL Document 2 Filed 06/20/12 Page 1 of 49

Transcript of Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895...

Page 1: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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Jason Christ Pro Se PO Box 8282 Missoula MT 59807 (602) 481-3895 jasonmtmjorg

4 Plaintiff

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7 UNITED STATES DISTRICT COURT

8 MISSOULA MONTANA

9 MISSOULA COUNTY DIVISION

10 Jason Christ Pro Se

11 Plaintiff

l2 vs

13 City of Missoula Police

14 Department Colin Rose

) ) Case No )

) Department )

) PLAINTIFFS APPLICATION FOF ) TEMPORARY RESTRAINING ) ORDER PRELIMINARY AND ) PERMANENT INJUNCTION AND ) ORIGINAL VERIFIED COMPLAINT

15 Stacy Lear Missoula county) FOR DAMAGES )

16 Attorneys Office Andrew ) )

17 Paul Paul Van Valkenberg ) )

18 Missoula County 911 ) )

19 Officers John Does l-12 ) )

20 Defendants ) )

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VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 1

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2 COMES NOW Jason Christ pro se and files this

3 complaint against the defendants listed above and woul

4 show the court as follows

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6 THE PARTIES

7 1 Plaintiff Jason Christ is a resident of Missoul

8 County and had a business in Missoula with it I

9 primary place of business in Missoula

10 2 Defendant City of Missoula Police Department is

11 located in and its primary location for business

12 is in Missoula County Montana

13 3Defendant Colin Rose is a resident of Missoul

14 County

15 4Defendant Stacy Lear is a resident of Missoul

16 County

17 5 Defendant Missoula County Attorneys Office is

18 located in and it I S primary location for business

19 is in Missoula County Montana

20 6 Defendant Andrew Paul is a resident of Missoul

21 County

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7 Defendant Paul Van Valkenberg is a resident of

Missoula County

8Defendants Officers 1-12 are various Missoula Cit

Police and Missoula County Law Enforcement

employees

JURISDICTION AND VENUE

9Subject matter jurisdiction over this cause is

conferred upon and vested in this court under the

laws of the United States

10 Personal Jurisdiction over the Defendants is

vest in this Court under the laws of the Unite

States

11 All relevant conduct between the plaintiff an

the defendants occurred in the United States i

general venue is proper in this court

INTRADISTRICT ASSIGNMENT

12 This cause of action should be assigned to the

Missoula County Division of this Court because

substantial part of the events or omissions whic

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gives rise to this lawsuit occurred in Missoul

County

INTRODUCTION

13 In 2003 the citizens of Montana passed b

voter initiative the legalization of marijuana

for medical use It passed by 63 in 2003 and b

2009 850 patients were signed up as patients wit

the Montana department of public health and huma

services (DPHHS)

14 Plaintiff began his business in 2009 in whic

he provided a doctor to patients organized classes

about the law and medical cannabis and participate

in the political arena with lobbying efforts

15 By 2010 plaintiff I s business had served ove

15000 patients Montana State Court experience

its first jury nullificationmutiny with regards

to criminal marijuana possession causing th

proseuction to lose cases

16 In early 2010 plaintiff challenged the

validity of an ordinance that was put into effect

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by an anti-medical marijuana city attorney Ji

Nugent This law was never passed by any du

process of passing laws In other words Nugent i

his official capacity prohibited patients an

caregivers from lawfully growing their own marijan

within Missoula County No law existed to this

effect and plaintiff filmed Nugents verbal attempt

to excuse his mistake It was put on the internet

and the law was redacted

17 This kind of action by cities occurred on

state-wide scale as municipalities chose to enac

practices with the same weight and effect as laws

that prohibited patients from being able to access

and use medical marijuana lawfully under stat

law Part of plaintiffs business during outreac

seminars included educating the public about thes

unlawful practices and how government is suppose

to operate and how to participate

18 Law enforcement provided misinformation

heavy lobbying efforts in 2010 and 2011 t

eliminate the medical marijuana act As a result

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in 2010 the Montana Legislature passed a repeal

bill the governor vetoed the legislatures bill

and the legislature enacted a new medical marijuan

act that eliminated 75 of registered patients 98

of the business involved and frightened all but tw

doctors from exercising their free speech rights shy

to counsel freely a patient without fear of the

governments intrusion

19 But the results were clear patients wer

getting off of the many dangerous narcotic pills

that had been causing physical ailments whic

affected the overall economy in part due to th

use of medical cannabis

FACTS

20 Beginning in 2009 the Defendants named abov

initiated a stream of actions that led to this case

being filed This included the denial o

plaintiffs rights without due process denial of

equal protection under the law and malicious

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 2: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

1

2 COMES NOW Jason Christ pro se and files this

3 complaint against the defendants listed above and woul

4 show the court as follows

5

6 THE PARTIES

7 1 Plaintiff Jason Christ is a resident of Missoul

8 County and had a business in Missoula with it I

9 primary place of business in Missoula

10 2 Defendant City of Missoula Police Department is

11 located in and its primary location for business

12 is in Missoula County Montana

13 3Defendant Colin Rose is a resident of Missoul

14 County

15 4Defendant Stacy Lear is a resident of Missoul

16 County

17 5 Defendant Missoula County Attorneys Office is

18 located in and it I S primary location for business

19 is in Missoula County Montana

20 6 Defendant Andrew Paul is a resident of Missoul

21 County

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7 Defendant Paul Van Valkenberg is a resident of

Missoula County

8Defendants Officers 1-12 are various Missoula Cit

Police and Missoula County Law Enforcement

employees

JURISDICTION AND VENUE

9Subject matter jurisdiction over this cause is

conferred upon and vested in this court under the

laws of the United States

10 Personal Jurisdiction over the Defendants is

vest in this Court under the laws of the Unite

States

11 All relevant conduct between the plaintiff an

the defendants occurred in the United States i

general venue is proper in this court

INTRADISTRICT ASSIGNMENT

12 This cause of action should be assigned to the

Missoula County Division of this Court because

substantial part of the events or omissions whic

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gives rise to this lawsuit occurred in Missoul

County

INTRODUCTION

13 In 2003 the citizens of Montana passed b

voter initiative the legalization of marijuana

for medical use It passed by 63 in 2003 and b

2009 850 patients were signed up as patients wit

the Montana department of public health and huma

services (DPHHS)

14 Plaintiff began his business in 2009 in whic

he provided a doctor to patients organized classes

about the law and medical cannabis and participate

in the political arena with lobbying efforts

15 By 2010 plaintiff I s business had served ove

15000 patients Montana State Court experience

its first jury nullificationmutiny with regards

to criminal marijuana possession causing th

proseuction to lose cases

16 In early 2010 plaintiff challenged the

validity of an ordinance that was put into effect

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by an anti-medical marijuana city attorney Ji

Nugent This law was never passed by any du

process of passing laws In other words Nugent i

his official capacity prohibited patients an

caregivers from lawfully growing their own marijan

within Missoula County No law existed to this

effect and plaintiff filmed Nugents verbal attempt

to excuse his mistake It was put on the internet

and the law was redacted

17 This kind of action by cities occurred on

state-wide scale as municipalities chose to enac

practices with the same weight and effect as laws

that prohibited patients from being able to access

and use medical marijuana lawfully under stat

law Part of plaintiffs business during outreac

seminars included educating the public about thes

unlawful practices and how government is suppose

to operate and how to participate

18 Law enforcement provided misinformation

heavy lobbying efforts in 2010 and 2011 t

eliminate the medical marijuana act As a result

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in 2010 the Montana Legislature passed a repeal

bill the governor vetoed the legislatures bill

and the legislature enacted a new medical marijuan

act that eliminated 75 of registered patients 98

of the business involved and frightened all but tw

doctors from exercising their free speech rights shy

to counsel freely a patient without fear of the

governments intrusion

19 But the results were clear patients wer

getting off of the many dangerous narcotic pills

that had been causing physical ailments whic

affected the overall economy in part due to th

use of medical cannabis

FACTS

20 Beginning in 2009 the Defendants named abov

initiated a stream of actions that led to this case

being filed This included the denial o

plaintiffs rights without due process denial of

equal protection under the law and malicious

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 3: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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7 Defendant Paul Van Valkenberg is a resident of

Missoula County

8Defendants Officers 1-12 are various Missoula Cit

Police and Missoula County Law Enforcement

employees

JURISDICTION AND VENUE

9Subject matter jurisdiction over this cause is

conferred upon and vested in this court under the

laws of the United States

10 Personal Jurisdiction over the Defendants is

vest in this Court under the laws of the Unite

States

11 All relevant conduct between the plaintiff an

the defendants occurred in the United States i

general venue is proper in this court

INTRADISTRICT ASSIGNMENT

12 This cause of action should be assigned to the

Missoula County Division of this Court because

substantial part of the events or omissions whic

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gives rise to this lawsuit occurred in Missoul

County

INTRODUCTION

13 In 2003 the citizens of Montana passed b

voter initiative the legalization of marijuana

for medical use It passed by 63 in 2003 and b

2009 850 patients were signed up as patients wit

the Montana department of public health and huma

services (DPHHS)

14 Plaintiff began his business in 2009 in whic

he provided a doctor to patients organized classes

about the law and medical cannabis and participate

in the political arena with lobbying efforts

15 By 2010 plaintiff I s business had served ove

15000 patients Montana State Court experience

its first jury nullificationmutiny with regards

to criminal marijuana possession causing th

proseuction to lose cases

16 In early 2010 plaintiff challenged the

validity of an ordinance that was put into effect

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by an anti-medical marijuana city attorney Ji

Nugent This law was never passed by any du

process of passing laws In other words Nugent i

his official capacity prohibited patients an

caregivers from lawfully growing their own marijan

within Missoula County No law existed to this

effect and plaintiff filmed Nugents verbal attempt

to excuse his mistake It was put on the internet

and the law was redacted

17 This kind of action by cities occurred on

state-wide scale as municipalities chose to enac

practices with the same weight and effect as laws

that prohibited patients from being able to access

and use medical marijuana lawfully under stat

law Part of plaintiffs business during outreac

seminars included educating the public about thes

unlawful practices and how government is suppose

to operate and how to participate

18 Law enforcement provided misinformation

heavy lobbying efforts in 2010 and 2011 t

eliminate the medical marijuana act As a result

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in 2010 the Montana Legislature passed a repeal

bill the governor vetoed the legislatures bill

and the legislature enacted a new medical marijuan

act that eliminated 75 of registered patients 98

of the business involved and frightened all but tw

doctors from exercising their free speech rights shy

to counsel freely a patient without fear of the

governments intrusion

19 But the results were clear patients wer

getting off of the many dangerous narcotic pills

that had been causing physical ailments whic

affected the overall economy in part due to th

use of medical cannabis

FACTS

20 Beginning in 2009 the Defendants named abov

initiated a stream of actions that led to this case

being filed This included the denial o

plaintiffs rights without due process denial of

equal protection under the law and malicious

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 4: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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gives rise to this lawsuit occurred in Missoul

County

INTRODUCTION

13 In 2003 the citizens of Montana passed b

voter initiative the legalization of marijuana

for medical use It passed by 63 in 2003 and b

2009 850 patients were signed up as patients wit

the Montana department of public health and huma

services (DPHHS)

14 Plaintiff began his business in 2009 in whic

he provided a doctor to patients organized classes

about the law and medical cannabis and participate

in the political arena with lobbying efforts

15 By 2010 plaintiff I s business had served ove

15000 patients Montana State Court experience

its first jury nullificationmutiny with regards

to criminal marijuana possession causing th

proseuction to lose cases

16 In early 2010 plaintiff challenged the

validity of an ordinance that was put into effect

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by an anti-medical marijuana city attorney Ji

Nugent This law was never passed by any du

process of passing laws In other words Nugent i

his official capacity prohibited patients an

caregivers from lawfully growing their own marijan

within Missoula County No law existed to this

effect and plaintiff filmed Nugents verbal attempt

to excuse his mistake It was put on the internet

and the law was redacted

17 This kind of action by cities occurred on

state-wide scale as municipalities chose to enac

practices with the same weight and effect as laws

that prohibited patients from being able to access

and use medical marijuana lawfully under stat

law Part of plaintiffs business during outreac

seminars included educating the public about thes

unlawful practices and how government is suppose

to operate and how to participate

18 Law enforcement provided misinformation

heavy lobbying efforts in 2010 and 2011 t

eliminate the medical marijuana act As a result

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in 2010 the Montana Legislature passed a repeal

bill the governor vetoed the legislatures bill

and the legislature enacted a new medical marijuan

act that eliminated 75 of registered patients 98

of the business involved and frightened all but tw

doctors from exercising their free speech rights shy

to counsel freely a patient without fear of the

governments intrusion

19 But the results were clear patients wer

getting off of the many dangerous narcotic pills

that had been causing physical ailments whic

affected the overall economy in part due to th

use of medical cannabis

FACTS

20 Beginning in 2009 the Defendants named abov

initiated a stream of actions that led to this case

being filed This included the denial o

plaintiffs rights without due process denial of

equal protection under the law and malicious

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

11

12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 5: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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by an anti-medical marijuana city attorney Ji

Nugent This law was never passed by any du

process of passing laws In other words Nugent i

his official capacity prohibited patients an

caregivers from lawfully growing their own marijan

within Missoula County No law existed to this

effect and plaintiff filmed Nugents verbal attempt

to excuse his mistake It was put on the internet

and the law was redacted

17 This kind of action by cities occurred on

state-wide scale as municipalities chose to enac

practices with the same weight and effect as laws

that prohibited patients from being able to access

and use medical marijuana lawfully under stat

law Part of plaintiffs business during outreac

seminars included educating the public about thes

unlawful practices and how government is suppose

to operate and how to participate

18 Law enforcement provided misinformation

heavy lobbying efforts in 2010 and 2011 t

eliminate the medical marijuana act As a result

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in 2010 the Montana Legislature passed a repeal

bill the governor vetoed the legislatures bill

and the legislature enacted a new medical marijuan

act that eliminated 75 of registered patients 98

of the business involved and frightened all but tw

doctors from exercising their free speech rights shy

to counsel freely a patient without fear of the

governments intrusion

19 But the results were clear patients wer

getting off of the many dangerous narcotic pills

that had been causing physical ailments whic

affected the overall economy in part due to th

use of medical cannabis

FACTS

20 Beginning in 2009 the Defendants named abov

initiated a stream of actions that led to this case

being filed This included the denial o

plaintiffs rights without due process denial of

equal protection under the law and malicious

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 6: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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in 2010 the Montana Legislature passed a repeal

bill the governor vetoed the legislatures bill

and the legislature enacted a new medical marijuan

act that eliminated 75 of registered patients 98

of the business involved and frightened all but tw

doctors from exercising their free speech rights shy

to counsel freely a patient without fear of the

governments intrusion

19 But the results were clear patients wer

getting off of the many dangerous narcotic pills

that had been causing physical ailments whic

affected the overall economy in part due to th

use of medical cannabis

FACTS

20 Beginning in 2009 the Defendants named abov

initiated a stream of actions that led to this case

being filed This included the denial o

plaintiffs rights without due process denial of

equal protection under the law and malicious

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 15

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

VERIFIED COMPLAINT and DEMAND FOR JURy TRIAL - 16

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

11

12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 7: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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prosecution of criminal charges that wereare

frivilous and arbitrarily enforced

21 The defendants instituted a frivilious charges

against the plaintiff - misdemeanors and felonies

some based on a single phone call where th

plaintiff used the word fuck These calls wer

charged against the plaintiff in various forms

including an alleged bomb threat

22 In the alleged bomb threat case the plaintiff

was not in the jurisdiction of the trial court whe

the offense was alleged to have occurred

violation of the Montana State Constitution

Article II sect24 Missoula county does not

jurisdiction yet the defendants have continued t

press charges against the plaintiff The trial

court has refused to dismiss the case proceedin

under mistake of law and the plaintiff has

appealed for writ of supervisory control and has

been denied multiple times

23 The plaintiff the defendant in that underlyin

case interviewed the prosecution witnesses

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 12

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 15

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

VERIFIED COMPLAINT and DEMAND FOR JURy TRIAL - 16

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 8: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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examined under oath The investigating officers

interviewed the prosecution witnesses In th

underlying case the prosecution is aware that th

testimony that will be given by the witness will b

purjured and the trial court has been made awar

of the same yet the case is continuing t

proceed The only way that the prosecution can wit

its case is if witnesses lie Indeed all of th

allegations by the prosecution have already bee

controverted several times by the plaintiff

24 The defendants are proceeding in that criminal

case knowing that the witness will have to continu

to commit perjury

25 The intended use of the justice system by th

defendants has been perverted in a design fo

prosecution of non-crimes such as complaining ove

the phone to police to customer service

representatives etc While the underlying reaso

for the defendants prosecution of the criminal

cases are in retaliation for plaintiffs political

involvement and exercise of free speech

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 9: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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26 Every other criminal case in the same district

where the charges are the same (felon

intimidation) has so much more of a story of

outrageous behavior that as one lawyer said it

are you serious The case against the plaintiff

by the defendant in these multiple criminal cases

are wholly unfounded no proof exists the

witnesses testimony has been perjured several

times and they have been brought solely for th

purpose to intimidate harrass and annoy th

plaintiff - to remove his ability to participate i

the political arena to have a business that hires

doctors who counsel patients to use marijuana The

actions are designed to also stop his ability t

conduct seminars throughout Montana

people about their rights beyond medical cannabis

27 For over three years the defendants have

engaged in denying equal protection to th

plaintiff in various forms and levels

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 15

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

VERIFIED COMPLAINT and DEMAND FOR JURy TRIAL - 16

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

11

12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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i

69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 10: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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28 When the plaintiff contacted the defendants fo

police protection due to a theft at his residenc

in 2010 for several thefts and assaults in 2011

and thefts assault battery and police misconduct

in 2012 the defendants did not respond properly

29 Instead the defendants 1) ignored th

plaintiffs requests 2) declined to prosecute 100

of every complaint 3) threatened the plaintiff

with arrest if he continued to complain about the

complete lack of equal police protection and 4)

filed criminal charge after criminal charge against

the plaintiff - for using the word fuck over the

phone 1

30 Plaintiff has been forced to file civil actions

against those who have harmed him rather tha

1 The context of which was l what the fuck or thia is fucking shitty as

opposed to an insult such as Vlfk you The allegations of every criminal

charge are the same - they donlt allege insults they are charges solely

based on the use of the word ~tuck or another similar word like it And

neither a stream of them - a single act forms the basis of multiple felonys

and misdemeanor charges against the plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 15

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

11

12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 11: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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prosecution being a part of the right of th

plaintiff to police protection After all it is

the tax-payers - the citizens who pay for police

and it is their duty to provide those services

equally to all

31 So the Court because of the many pleadings

filed by the plaintiff has labeled the plaintiff

difficult litigant and hard to deal kith Which

if true would not be agreed upon by the clerks of

that same court - those who do the actual dealing

with the plaintiff

32 In early 2012 as a result of the ongoin

harrassment by the police and their affirmative

actions to deprive the plaintiff from equal

protection the plaintiff was forced to leav

Missoula county

33 Plaintiff moved out of his home Over a course

of several evenings after many thefts had alread

occurred and no police protection or prosecution

plaintiff called the police because at nigh

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 15

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

VERIFIED COMPLAINT and DEMAND FOR JURy TRIAL - 16

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-------------

1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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i

69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 12: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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someone was pointing a red laser into his kitchen

living room and dining room This occurred fo

several weeks the police did not investigate but

they wrote a silly report designed to make th

plaintiff look bad so that they would not take hi

serious

34 Within two weeks plaintiffs car windows an

tires were shot out items were stolen and othe

things occurred that caused plaintiff to fear fo

this life

35 The police refused to investigate an

allegations by the plaintiff dismissing every call

to 911 as frivilous

36 The plaintiff moved from his home and did not

notify the lower trial courts in the criminal cases

because the defendants would use that against hi

to lock him in jail not because plaintiff was

violating any court orders or state laws but

because thats how things are done in Missoul

County District State Court

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1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

11

12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 13: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

1 37 Plaintiff moved out to camp ln the woods

2 38 Plaintiff was camping near Lolo Hot Springs

3 about 20 miles into Mineral county down a vas

4 network of random unimproved dirt roads near the

5 end of one of them in the middle of nowhere

6 39 On May 2nd 2012 the plaintiff was supposed t

7 interview a prosecution witness at 9AM

8 40 Plaintiff did not appear to interview he

9 because he thought it was scheduled for two days

10 later and indeed had set it as such in his

11 calendar

12 41 One of many strangest and most frightenin

13 interactions with law enforcement occurred

14 42 At 5PM on that day Missoula County sheriffs

15 deputys without warrant or permission entere

16 Mineral county and went directly to plaintiffs

17 vehicle in which he was sitting working on

18 legal paper

19 43 The plaintiff heard a knock on his window h

20 looked out of his car saw guns pointed at him an

21 was instantly frightened

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 15

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 14: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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44 The deputies had their guns drawn and pointe

at the plaintiff as they made the plainti exit

his car talk to them They requested hi

identification and while he was retrieving it fro

his car another officer pointed his gun at the

plaintiff

45 When plaintiff was asked why he was there h

responeded that he liked camping was working

some legal stuff I and had a US field

manual

46 The plaintiff asked if he had done somethin

wrong (to find out why they were there) and the

deputies responded that someone had called about

person camping This call somehow prompted the

Missoula county sheriffs department to cross

county lines point their guns at plainti an

harass him about his personal business

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 14

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

VERIFIED COMPLAINT and DEMAND FOR JURy TRIAL - 16

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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i

69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 15: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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47 There exists no laws for the actions taken b

the defendants and there are no laws prohibit in

what the plaintiff was doing - camping 2

48 There was no probable cause or court order fo

the intrusion on plaintiffs peace and quiet

49 In May and June of 2012 the defendants

threatened the plaintiff with arrest an

prosecution for asserting his request to speak wit

a supervisor regarding why the plaintiff was denie

equal protection when assaulted The plaintiff ha

caught the incident on camera and was threated b

the police with criminal prosecution if he

complained to supervisors

50 The plaintiff was charged with violating th

Privacy in Communcations Act (45-8-213 MCA) fa

questioning why the desk officer did not forwarde

plaintiffs many requests to speak with

Incidently plaintiff is vegan (vegetarian) and does not hunt does not own

any weapons but is not allowed to have any to protect himself in the woods

- from bears and such

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

VERIFIED COMPLAINT and DEMAND FOR JURy TRIAL - 16

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 16: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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supervisor There was no probable cause for the

charges against the plaintiff and the defendants

intentionally did not record the phone call and

most importantly the plaintiff was charged with

crime for using the word fuck over the phone 3

51 The defendants attempted to subvert justice

attempting to acquire a warrant for plaintiffs

arrest without due process of law

52 The defendants sent a copy of a ticket to th

plaintiffs PO Box unregistered They did not

attempt any kind of proper service Defendants

charged plaintiff with the crime of using the f

word over the phone

53 The defendants have not investigated the lead

or information provided by the plaintiff

3 Again the context of which was ~what the fuck1 or ~this is fucking

shitty as opposed to an insult such as fk you Regardless it was to ar

trained police officer specially educated to tolerate such expressions of

dissatisfaction with the governments actions

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

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12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 17: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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1 criminal charges or in complaints made to the

2 police such as when the plaintiff was assaulted

3 54 Instead the defendants filed complaints

4 against the plaintiff For over three years the

5 defendants have continued improper proceedings

6 against the plaintiff Some of the proceedings hav

7 been dismissed because there has been no probable

8 cause or for improper venue or because the

9 victims testimony has been been found to be made

10 up

11

12 55 In the course of making false claims 1

13 affidavits to magistrates the defendants engage

14 in a pattern of illegal searches and seizures of

15 the plaintiff his person places and effects

16 56 Defendants made an illegal search and seizure

17 of an unauthenticated recorded phone call

18 allegedly the plaintiff cussing out a custome

19 service representative

20 57 The plaintiff was charged with the crime of

21 cussing over the phone by Information outlining

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 18: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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phone call a bomb threat and two (or three 4 )

counts of felony intimidation

58 The plaintiff was another county at the time

the plaintiff was alleged to have committed th

crime of intimidation based on an unrecorded

alleged bomb threat

59 No jurisdiction in Missoula county was proper

yet the defendants maintained an illegal actio

against the plaintiff the defendants sought an

seized evidence without warrants whil

similtaneously lawfully obtaining evidence from the

same party

60 The plaintiff was entitled to and expected

privacy of his persons places and effects Yet th

defendants ignored his rights and affirmativel

violated plaintiffs right to be secure in his

person places and effects

The State (prosecution) has been threatening to add more felony charges for

the same act of the plaintiff for two years in retaliation for the

plaintiffs filing of motions in the underlying case

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 19: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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61 The defendants engaged in a series of

defamatory actions that caused others to have

negative view of the plaintiff causing the

material denial of plaintiffs rights

62 The defamatory remarks were written some b

hand some in email and some verbally

63 The defendants contacted the news media jus

before several situations in which the plaintiff

was searched or arrested the defendants used th

media to embarrass the plaintiff

64 Those remarks were untrue the defendants di

not have a privilege to dissemenate tha

information

65 The Montana Fourth Judicial District Court has

been presiding over a case for the last 2

which the plaintiff in the instant case

charged with two (or three) counts of

intimidation for complaining about his

service

66 The State Court is proceeding under several

mistakes of fact (stipulated by the prosecution)

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 20: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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and law that are clearly shown to be incorrect b

documented evidence in the form of database

records but the lower State Court has proceede

under a number of procedural errors that if

allowed to continue will deprive the plaintiff 1

the instant case the right to a fair trial

67 In the State criminal case against the

plaintiff the Court has ordered the production of

evidence exculpatory and inculpatory in nature fo

the plaintiffs defense yet it has refused t

enforce any of its orders

68 Additionly the State Court has not dismisse

the charges even though the defendant was i

another county at the time of the alleged offense

the State stipulates to this fact and the

Constitution states that the accussed shall hav

the right to a jury trial by his or her peers I

the Montana Constitution (Art II sect24) the

accussed shall have the right to a trial in the

county in which the offense is alleged to have

occurred

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 21: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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69 The State District Court has independentl

sought and found case law that weakly supports th

States position in order to keep the case

Missoula County which is not the definition of

impartial judge and does not lead to a fai

trial

70 The State court has ordered that the plaintiff

gets only one lawyer - Katie Green Esq who is s

busy that in the last month she has not had an

time to meet with the plaintiff and help with his

criminal charges In fact she was told by he

director not to participate or help the plaintiff

as a defendant in the pending State criminal

charges against him

71 The State Court being briefed on this issue

has ignored the plaintiffs plea for legal

assistence These criminal charges against him have

cost him his business reputation freedom right

to medical help ability to get a job or rent

home and position in the medical industry

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 22: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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72 The Montana Supreme Court has refused th

plaintiffs repeated requests for writs of

supervisory control

73 The plaintiff has been frightened away fro

living in Missoula county or in the surroundin

counties based on the stream of continuou

harrassment from local iaw enforcement in Missoul

city and county It has affected his bodil

functions

74 The defendants have refused to allow the

plaintiff to make complaints through th

administrative process of the Missoula Police

Department

75 The governor of the State of Montana has

refused to hear any complaints and the attorne

general for the State of Montana was a defendant i

a case against the State because the plaintiff

sued the State for not allowing the plaintiff

access to his medicine The AG has never returne

the plaintiffs calls

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 23: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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76 Due to the multiple criminal charges against

the plaintiff in the State criminal charge th

plaintiff has been detained in Montana unable t

travel visit family or manage his business

affairs It has cost him relationships bot

business and personal and has cost him well over 7

million dollars in lost profits and costs H

cannot respond to family emergencies

77 Plaintiff is detained in Montana without bein

convicted of any crimes and without Constitutional

due process of law

78 Plaintiff has been denied many rights durin

the pendency of the criminal charges against him

He is not allowed to have alcohol to own a weapon

to use drugs to travel to enter bars no contact

with Verizon and requred to hire an attorney But

there has never been any hearing on a restrainin

order any hearing whatsoever to determine if

denial of the plaintiffs rights are lawful

even necessary

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 24: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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79 The plaintiff has no criminal record ha

appeared at every hearing and cannot get a cell

phone in Montana due to the denial of his rights

80 The Missoulian a Montana state newspaper wit

strong political ties has defamed the plaintiff i

its many front page stories about the plaintiff

and his criminal charges has labelled the

plaintiffa jerk and the biggest grower of

marijuana in Montana But the plaintiff never grew

did not sell or distribute marijuana The plaintiff

did not have any ties financial or otherwise wit

caregivers - those who legally grew marijuana Th

plaintiff owned a medical clinic that provide

outreach seminars and arranged doctor-patient

visits

81 As a result of the newspapers untrue

statements statements that have not been verified

the plaintiff has suffered law enforcement

retailiation everywhere in Montana - it is Stateshy

wide

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 25: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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82 In May of 2012 the plaintiff was in Arlee MT

and had pulled over to the side of the road in

sparcely populated area to use his computer He wa

on the side of the road parked legally and n

visible signs stated otherwise

83 A Montana law enforcement officer came out of

a residential house wearing plain clothes without

a badge or gun approached plaintiffs car windows

and attempted to enter and search the plaintiffs

vehicle

84 Plaintiff moved his vehicle down the street

and the officer went back into the house put on

black vest and gun got into an unmarked vehicle

and pulled behind the plaintiffs car with polic

lights and siren blazing

85 The officer got out of his car went up

plaintiffs driver door opened the door and pulle

plaintiff from his car Plaintiff attempted to put

on his bag (it has a shoulder strap) and th

officer said you wont need that where you r

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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going and put handcuffs on him The officer bega

to search the plaintiffs person bag and car

86 Plaintiff objected to the search and asked the

officer what he was doing and why Office

responded that he knew the plaintiff I and stated

so you like to be on the front cover of th

Missoulian do ya The officer put the plaintiff

in the back of his unmarked police vehicle an

began searching quicking and sporatically fo

something This caused plaintiff to fear that h

would be murdered because of what the officer said

that the officer was looking for a potential

weapon and that the officer did not follow an

kind of protocol commonly used by law enforcement

87 The officer did not display any show of

authority to arrest the plaintiff nor did th

officer follow procedure instead the officer

unlawfully detained the plaintiff without probable

cause made statements designed to terrify the

plaintiff and make him feel like he was going to be

killed

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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88 After 20 minutes a supervising officer showe

up and the first officer let the plaintiff g

without mention of any crimes committed or why th

plaintiff was detained in the first place

89 No charges were filed the officer did not

inquire as to the plaintiffs status what he was

doing and was verbally and physically abusive wit

the plaintiff The officer never told the plaintiff

why he had arrested and detained him for 30

minutes without probable cause for any crime

90 The officer did not ask for the plaintiffs

drivers license

91 In 2010 after allegations by former employees

alleging fraud by the plaintiff the defendants

engaged in a search and seizure highly publicized

of plaintiffs business As filmed and pictured i

the local state and national news they too

computers contracts bank information ta

paperwork medical records and 28000 patient

records and more

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

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Page 28: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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92 The Missoula county detectives contacted an

threatened plaintiffs doctors patients several

caregivers and other affiliates

93 The detectives followed up with patients about

their medical conditions and why the doctors ha

written certain things in the medical records

94 Then the detectives cross referenced this

information with the DPH~S in Helena provide

information to Federal DEA and FBI agents whic

resulted in many of the raids and federal criminal

charges against many law abiding citizens of

Montana and the United States

95 The case in Missoula State District Court was

opened so that the State would be able to acquire

that which could otherwise never have bee

acquired patient medical records and contacts of

the plaintiff and his doctors and affiliates

96 The case was closed in Missoula State District

Court without any charges against the plaintiff

97 The plaintiff had to envoke court action to get

the defendants to return his items but they did not

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 28

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 29

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 30

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 32

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 33

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

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8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

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Page 29: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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return all of the items Some of the items were

destroyed or otherwise lost

REQUEST FOR INJUNCTIVE RELIEF AND PROTECTIVE ORDER

98 The actions by the defendants are not legal

99 The plaintiff needs protection from Missoul

county sheriffs the city of Missoula police an

law enforcement in the State of Montana becEiUs

they are breaking the law violating the US

Montana Constitutions and the State Courts ar

denying the plaintiff due process and equal access

to the courts They have dismissed cases solely 0

the basis of his pro se status in court

100 Between 2011 and 2012 a Missoula Court ordere

that the plaintiff be prohibited from

only law library in Montana (Actually there is

one other in Helena about 7i the size of the

Law Library)

101 For over two months the plaintiff was denie

access to any legal resources whatsoever

decisions were appealed to the appellate court

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 35

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 30: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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all of the cases with all of the judges in all of

the State courts denied the plaintiffs 14 motions

for stay of proceedings and denied his requests fo

extensions and continuances

102 In 2012 the State Court dismissed civil

complaints against others where the plaintiff wa

pro se solely because he was pro se The judge i

that case told the plaintiff that he would have t

hire a lawyer if he wanted justice

plaintiffs equal access to the courts a

Constitutional guarantee

103 In 2012 the judge in another case announce

that the Missoula Fourth Judicial District State

Court was having problems with the plaintiff

because he filed many pleadings The court calle

plaintiff a difficult litigant based solely 0

the number of pleadings not on the merits of thos

papers

104 The plaintiff requests protection from Missoul

city and county public officials including but not

limited to mayor city attorney county attorney

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

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Page 31: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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city police and county sheriff from state polic

from retaliation and revenge against the plaintiff

due to this complaint against the defendants

105 Their actions if not halted will cause

irreparable harm to the plaintiff

106 No remedy exists for the harm to the plaintiff

by the defendants

107 The plaintiff requests that this court issue

protective order against the defendants to sto

them from harassing and any malicious prosecutio

against the plaintiff

108 If the plaintiff uses unclean words over th

phone he is charged wi th a crime by the State of

Montana and this is unlawful because it is

directly against the freedom of speech

109 The defendants have filed another complaint

a state court against the defendant but

prosecution has not begun The compliant is

on an unconstitutional law 45-8-213 MCA

allows law enforcement the arbitrary ability

arrest anyone for using the word fuck over

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 31

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 32

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 35

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 36

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

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1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 32: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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phone internet or text message The

statute states that use of a profane word using an

kind of electronic communication is evidence of

defendants intent to harrass annoy offend etc

another person which is a misdemeanor crime

1l0 The plaintiff tried to make a formal complaint

to the police about the police and they did not

allow him to make a complaint Plaintiff complaine

about it making the statement what the fuck

and as a result was charged with violating 45-8shy

213 MCA a misdemeanor

111 The defendants did not serve the plaintiff wit

the ticket It was mailed to him unregistered t

his PO Box

CLAIM I - ABUSE OF PROCESS

112 The defendants had an ulterior purpose fo

using legal processes

113 The defendants committed willful acts in th

use of processes

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 32

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 33

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 34

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 35

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 36

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 37

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 33: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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0 114 The defendants willful acts misused

perverted the intended use of the process and

115 The plaintiff was damaged and harmed as

result of the defendants actions

CLAIM II - DENIAL OF EQUAL PROTECTION UNDER THE LAW

116 The plaintiff was entitled to equal protectio

under thelaw from the defendants

117 The plaintiffs involvement with the medical

marijuana program in Montana precluded and was th

cause of the class designation of the plaintiff b

the defendants

118 The defendants were obligated to provide equal

protection to the plaintiff

119 The defendants intentionally and maliciousl

denied equal protection to the plaintiff

120 The plaintiff suffered damages as a direct

result of the defendants actions

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 33

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 35

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 36

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 37

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 38 of 49

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

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5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 34: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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CLAIM III - MALICIOUS PROSECUTION

121 The defendants instituted and continued man

judicial proceedings against the plaintiff

122 The proceedings were instigated and abetted b

defendants

123 The proceedings terminated favorably for the

plaintiff

124 The proceedings against the plaintiff lacke

probable cause

125 The defendants instituted the proceedings wit

malice and reckless disregard for the truth

126 The actions by the defendants injured th

plaintiff

127 The actions by the defendants caused damage t

the plaintiff

CLAIM IV INVASION OF PRIVACY

128 The plaintiff had a right to the privacy of

plaintiffs person places and effects and to b

free from unreasonable searches and seizure

without a compelling state interest However the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 34

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 35

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 36

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 37

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

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14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 35: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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defendants were unreasonable in their search an

seizure of the plaintiffs persons and effects

because without a search warrant it was per s

unreasonable

129 The defendants did not have a compelling State

interest and the unlawfully seized evidence was

not going anywhere it had been preserved by th

victims defendants were aware of the

preservation

130 The access to the plaintiffs privat

information was unlawful

131 The plaintiff suffered harm as a result of th

defendants invasion of privacy because th

transcript of that phone call was put into the

public charging documents accusing the plaintiff of

cussing out customer service

132 The plaintiff suffered harm to his reputatio

and right to an impartial trial by his peers

because of the massive publicity that the

transcript produced

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 35

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 35 of 49

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 36

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 36 of 49

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 37

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 37 of 49

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 38 of 49

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

19

20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 36: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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CLAIM V - SLANDER

133 The defendants engaged in making statements

that were not true about the plaintiff to othe

persons in written form in the charging documents

and other pleadings to the court and in wri tte

communication to the press public and electe

officials and departments entrusted in public

administration and order

134 Others relied on that information

135 The defendants knew or should have known that

the information was false

136 The defendants accused the plaintiff of crimes

falsely and without legal justification

137 The information that the defendants provided t

others was false and the defendants did not hav

any privilege to disseminate that information

138 The plaintiff was damaged as a result of th

defendants slander

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 36

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 36 of 49

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 37

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 37 of 49

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 38 of 49

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

19

20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 37: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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CLAIM VI - LIBEL

139 The defendants engaged in making statement

that were not true about the plaintiff to othe

persons verbally including but not limited t

the media and other departments engaged in la

enforcement and public administration

140 Others relied on that information

141 The defendants knew or should have known that

the information was false

142 The information that the defendants provided t

others was false and the defendants did not have

any privilege to disseminate that information

143 The plaintiff was harmed as a result of th

defendants libel

CLAIM VII - NEGLIGENCE

144 The defendants owed a duty to the plaintiff t

investigate the plaintiffs assertions of assault

and false testimony by witnesses and allege

victims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 37

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145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 38 of 49

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

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20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 38: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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i

145 The defendants owed a duty to the plaintiff t

dismiss the claims against the plaintiff when the

learned that the victim I witnesses were biased an

providing false information to the defendants

order to get the plaintiff in trouble

146 The defendants owed a duty to the plaintiff t

provide equal protection under the laws

147 The defendants owed a duty to the plaintiff t

follow the rules of criminal procedure and

Montana and US Constitution having made an oath t

support and defend the same

148 The defendants engaged in prosecuting the

plaintiff in a court that was not the correct

venue even after being notified of the issue th

defendants brought more frivolous charges against

the plaintiff instead of dismissing those charges

149 The defendants owed a duty to the plaintiff t

investigate allegations of police misconduct an

for supervisor contact regarding complaints about

law enforcement response

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 38

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 38 of 49

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

19

20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 39: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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150 The defendants owed a duty to the plaintiff t

provide accurate information to the courts

lSI The defendants breached that duty of care

152 The defendants actions were the proximate

cause of the harm to the plaintiff

153 The plaintiff suffered damages as a result

having to defend allegations brought in an imprope

venue and against charges that were brought withou

probable cause

154 The plaintiff has suffered reputation

emotional and economic damages

CLAIM VIII - INTENTIONAL INFLICTION OF EMOTIONAL

DISTRESS

155 The defendants conduct was extreme an

outrageous

156 The defendants acted intentionally an

recklessly

157 The plaintiff suffered severe emotional

distress and

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 39

i

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 39 of 49

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

19

20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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l

167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 40: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

1 158 The defendants conduct was the proximate caus

2 of the emotional distress suffered by th

3 plaintiff

4

5 CLAIM IX - FALSE IMPRISIONMENT

6 159 The defendants deprived the plaintiff of hi

7 liberty by bringing charges that could not be

8 brought in this jurisdiction and venue wer

9 brought without probable cause and deprived the

10 plaintiff of his liberty by denying him the abilit

11 to travel freely to be free from court obligation

12 and to be free from the social and financial

13 burdens placed upon the accused if criminal charges

14 are brought

15 160 The deprivation of liberty was done without th

16 plaintiffs consent

17 161 The deprivation was done without legal

18 justification

19

20

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 40

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 40 of 49

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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l

167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 41: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

1 CLAIM X - UNLAWFUL ARREST AND DETENTION

2 162 The defendants deprived the plaintiff of

3 federally protected rights privileges an

4 immunities

5 163 The defendants took action under the color of

6 state law

7

8 CLAIM XI - USCA sect1983 VIOLATION

9 164 Deprivation of a federally protected right

10 privilege or immunity

11 165 Action by the defendant under color of state

12 law

l3

14 CLAIM XII - INTENTIONAL INTERFERENCE WITH A PROSPECTIVE

15 BUSINESS ADVANTAGE

16 166 The defendants were aware of and actuall

17 interfered with the plaintiffs existing 0

18 reasonable exptected relationship with a thir

19 party relationships which were likely to provide

20 future economic benefits to the plaintiff

21

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 41

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 41 of 49

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l

167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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21

CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 42: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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l

167 The defendants intended to interfere and acte

with the sole purpose of harming the plaintiff an

the defendants employed wrongful methods

effecting the interference

168 The defendants interfering conduct was not

justified or privileged

169 The plaintiff suffered actual damages that but

for the defendants interference would not have

occurred

170 The plaintiff suffered punitive damages an

attorneys fees

CLAIM XIII - OUTRAGE

171 The defendants conduct was so extreme an

outrageous that the plaintiff is entitled t

recovery

172 The emotional distress suffered by th

plaintiff is in such extreme degree that the la

must intervene because the distress inflicted is s

severe that no reasonable person should be expecte

to endure it

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 42

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 42 of 49

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 43: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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CLAIM XIV - FALSE LIGHT INVASION OF PRIVACY

173 The defendants engaged in a search of

plaintiffs business without probable cause too

all of the major tools used by his business and his

15+ employees held them for two months and the

would not release it without the plaintiffs havin

to petition the court and obtain court orders

174 On the way to the plaintiffs business th

defendants contacted the Missoulian and the entire

search was captured on TV and in the newspaper

because reporters showed up

175 There were no charges filed but the publicit

generated caused a drop in plaintiffs business

because it harmed his credibility

CLAIM XV - SEARCH AND SEIZURE VIOLATIONS

176 The plaintiff had the right to be secure in his

4 thperson places and effects according the

6th and 14th Amendments to the US Constitution

177 The defendants repeatedly violated the

plaintiffs right to privacy when they conducted

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 43

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 43 of 49

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 44: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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search at plaintiffs business obtaining 30000

patient medical records and database information

in violation of HIPPA The records were no

included in the search warrant because it waul

have been unlawful for any Court to order thei

disclosure

178 The harm to plaintiffs business because hi

patients could no longer be certain that thei

medical history would remain confidential ca

hardly be measured

179 The harm to the plaintiffs clients an

patients and to the reputation of the plaintiff

with his doctors cannot be measured The polic

took patient medical records without a searc

warrant outside of the law illegally and the

used it to conduct raids and searches on those

patients

180 The defendants continued to violate th

plaintiffs rights to privacy when the defendants

searched and seized his account information at hi

cell phone carrier without a warrant Nor was the

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 44

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 44 of 49

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 45: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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item seized in plain view it was private and hel

behind firewalls and highend technical barriers

Nor was the item mentioned in the return nor was

the item obtained by any other party lawfully

181 The State Court refuses to suppress this

illegally obtained evidence and the Appellate

Court has refused to grant the plaintiff a writ of

supervisory control

182 The plaintiff cannot exhaust any more remedies

he has filed over 1300 pleadings in the 25 civil

and 1 criminal case in which he is involved Not

one of his pleadings or causes have been deeme

frivilous in the 3 years he has been litigating

Even after filing multiple motions fo

reconsideration because the court is proceedin

under plain error the lower State Courts continue

to refuse to reverse their orders depriving the

plaintiff of due process equal access to the

courts and the general deprivation of his civil

rights in violation of sect1983 USC

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 45

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 45 of 49

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 46: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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WHEREFORE

Plaintiff demands a t al by jury injunctiv

relief in form of stay of proceedings in the State

Court pending this Federal action and that the court

finds judgment against the defendants as follows

1 Damages from time lost in pursuing this action t

make the plaintiff whole as the plaintiff is pr

se and entitled to be compensated for time spent i

the amount of $2685000

2Damages from the lost business from industr

relationships in the amount of $156800000

3Damages from having to hire legal counsel to defen

himself in the underlying frivilous lawsuits in the

amount of $3400000

4Punitive damages in the amount of $5000000000

for defendants willful and malicious actions i

misusing and perverting process for its

intentional infliction of emotional distress an

for punitive damages for the other claims

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL 46

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 46 of 49

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 47: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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5 Costs of the suit to be taxed to Defendantsj

6Interest to the date of the payment at the lawfull

allowable percentage rate per annumj and

7Such other and further relief as the cour

considers just and proper

Dated this 20 th day of June 2012

Pro Se

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 47

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 47 of 49

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 48 of 49

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My Commission Expires

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 49

Case 912-cv-00106-DLC-JCL Document 2 Filed 062012 Page 49 of 49

Page 48: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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VERIFICATION

State of Montana

)ss

county of Missoula

I Jason Christ after being first duly sworn on oat

do depose and say that I am the Jason Christ referre

to this foregoing Verified Complaint that I have rea

the foregoing know the contents thereof and

facts and matters therein contained are true accurat

and complete I further declare under penalty of

perjury that I am the plaintiff in this action I have

read this complaint and the informationi set fort

herein is true and correct (28 U sect1746 i 18 U S c

sect1621)

JASON CHRIS

SWORN to and subscribed before me this the 20 th day of

June 2012

NOTARY PUBLI

VERIFIED COMPLAINT and DEMAND FOR JURY TRIAL - 48

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Page 49: Jason Christ, Pro Se · Jason Christ, Pro Se PO Box 8282 Missoula, MT 59807 (602) 481-3895 jason@mtmj.org 4 ; Plaintiff

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