terrylyns_title_42

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UNITED STATES DISTRICT COURT

For the _______________ DISTRICT OF _______________

___________; [_____________]c/o 4719 Quail Lakes Dr., Ste G #352Stockton, California [95207] CASE No. __________________

Judge ______________________ Plaintiff

Date _______________________Vs

__________________________ ,Employee of CORPORATION

STOCKTON POLICE DEPARTMENT,CITY OF, STOCKTON,22 E. Market Street VERIFIED COMPLAINT FORStockton, CA. 95202 MONEY DAMAGES, CIVIL RIGHTS VIOLATIONS, And U.S.C. Title 42, Section 1983, 1985

1986, 1988

Defendant

______________________________,Employee of CORPORATION

STOCKTON POLICE DEPARTMENT,CITY OF, STOCKTON22 E. Market StreetStockton, CA 95202

And

Defendant

_______________________________,Employee of CORPORATION

STOCKTON POLICE DEPARTMENT,CITY O, STOCKTON22 E. Market StreetStockton, CA 95202

And

Defendant

COMPLAINT FOR DAMAGES CIVIL RIGHTS VIOLATIONSPage 1 of 13


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_______________________________,Employee of CORPORATIONSTOCKTON POLICE DEPARTMENT,CITY OF, STOCKTON22 E. Market Street

Stockton, CA 95202

And

Defendant

OWNER BROWNIES TOWING,????????????????????????????????????

And

Defendant

BROWNIES TOWING,40 S. UNION ST.STOCKTON, CA 95205

AndJURY DEMAND HEREIN

Defendant

JOHN DOE #1Employee for BROWNIES TOWING,40 S. UNION ST.STOCKTON, CA 95205

I. INTRODUCTION AND OPENING STATEMENT

1. This action is brought by Plaintiff, _____________, hereinafter, Plaintiff, against State

Officials acting under color of State law, for civil rights violations involving non-compliance,

wrongful arrest, wrongful detention, domestic terrorism, threats of physical damage,

permanent mental damage, emotional distress, defamation, embarrassment, humiliation,

impairment of reputation, excessive extortion fees, theft of property, trespass, and denied

Plaintiff her Right to Liberty on a public right of way in which to provide life essentials



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III PARTIES

4. All allegations set forth in paragraph 1 and 3 are incorporated herein in its entirety by

reference.

5. Plaintiff ,_____________, hereinafter, Plaintiff, at all times relevant herein, lives

on San Joaquin County, California Republic. Plaintiff, has lived on California since birth.

6. Defendant, SERGEANT ________________, hereinafter, ___________________, at all

times relevant, to this complaint, is a sergeant for the STOCKTON, CITY OF, POLICE

DEPARTMENT, STOCKTON, CALIFORNIA, and a resident of SAN JOAQUIN COUNTY, acting

in such capacity as agent, servant, and/or, employee of, STOCKTON, CITY OF, POLICE

DEPARTMENT, _____________________ is being sued in his individual capacity.

7. Defendant, OFFICER ________________, hereinafter, ______________, at all times relevant,

to this complaint, is an officer for the STOCKTON, CITY OF, POLICE DEPARTMENT,

STOCKTON, CALIFORNIA, and a resident of SAN JOAQUIN COUNTY, acting in such capacity as

agent, servant, and/or, employee of, STOCKTON, CITY OF, POLICE DEPARTMENT, OFFICER

__________________ is being sued in his individual capacity.

8. Defendant, OFFICER _________________, hereinafter, _______________, at all times

relevant, to this complaint, is an officer for the STOCKTON, CITY OF, POLICE DEPARTMENT,

STOCKTON, CALIFORNIA, and a resident of SAN JOAQUIN COUNTY, acting in such capacity as

agent, servant, and/or, employee of, STOCKTON, CITY OF, POLICE DEPARTMENT, OFFICER

____________ is being sued in his individual capacity.

9. Defendant, OFFICER _________________, hereinafter, OFFICER ______________, at all

times relevant, to this complaint, is an officer for the STOCKTON, CITY OF, POLICE

DEPARTMENT, STOCKTON, and a resident of SAN JOAQUIN COUNTY,



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acting in such capacity as agent, servant, and/or, employee of, STOCKTON, CITY OF,

POLICE DEPARTMENT, OFFICER ___________ is being sued in his individual capacity.

10. JOHN DOE #1 hereinafter, JOHN DOE #1, at all times relevant, to this complaint, is an

employee, agent, servant, tow truck driver, for the BROWNIES TOWING, residence unknown, acting

in such capacity, and in concert, as agent, servant, assigns, and/or employee of Defendant,

BROWNIES TOWING. JOHN DOE #1 is being sued in his individual.

IV STATEMENT OF FACTS

11. All allegations set forth in paragraph 1 through 14 are incorporated herein by reference.

12. All factual allegations herein this complaint began on November 03, 2010 on or about 3:45 pm

and continues until present,

13. All allegations, injury and damage alleged in this complaint are on going and continue unless

otherwise stated.

14. On November 03, 2010, on or about 3:45 pm, Plaintiff, was going east on _____________,

15. Plaintiffs conveyance is a 2006 White Ford Diesel 4X4,

16. Plaintiff had not relinquished ownership of her private property,

17. Plaintiff has in her possession a Lawful Bill of Sale, as proof of her sole ownership of her

private property (conveyance),

18. Plaintiff has a lawful title for her property,

19. Plaintiff private property was paid for with silver,

20. On November 03, 2010, on or about 3:45 pm, Plaintiff was not operating her conveyance in

Commerce,

21. On November 03, 2010, on or about 3:45 pm, Plaintiff was not Hauling Passengers or Cargo

for Hire,



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22. On November 03, 2010, on or about 3:45 pm, SERGEANT _____________, perpetrated a

fraud when he, deceived Plaintiff into Believing there was an emergency,

23. he falsely created the illusion of an emergency, by

24. DRIVING his CITY, patrol car close behind Plaintiffs conveyance and

25. activated his Emergency Red lights, therefore

26. Plaintiff pulled off the right of way and stopped, giving right of way to the emergency vehicle.

27. SERGEANT ______________ exited his (emergency vehicle), petrol car,

28. SERGEANT_________________ was armed and dangerous,

29. and Plaintiff feared for her life,

30. Complainant was not free to leave,

31. SERGEANT __________________ ordered Plaintiff, give evidence against Herself,

32. out of fear, Plaintiff complied,

33. OFFICER ______________ arrived,

34. OFFICER _____________ was armed and dangerous,


36. Plaintiff was not free to leave,

37. SERGEANT _______________ did not witness a crime,

38. OFFICER _______________ did not witness a crime,

39. Plaintiff, or her property, was not involved in any criminal activity before, during or after

November 03, 2010,

40. SERGEANT ____________ ordered Plaintiffs private property to be taken from Her

possession,

41. and removed from where She had placed it, into His and Others control, and their use.,

42. with intent to damage, injure, and deprive Plaintiff of her property,



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43. absent a Fourth Amendment Warrant, or privilege to do so,

44. OFFICERS _____________ and ____________ arrived and all officers were armed and

dangerous,


46. Plaintiffs friend Patty arrived,

47. Plaintiff was not free to leave,

48. OFFICERS _______________ ordered Plaintiff, produce evidence against Herself,

49. out of fear, Plaintiff complied,

50. Plaintiff demanded to be taken before a Magistrate, immediately,

51. OFFICER _______________ said its too late for a Magistrate,

52. OFFICER ____________ took Plaintiffs private property, fingerprint, without Her consent,

over Her objection, and against Her will.

53. OFFICER ________________ took Plaintiffs private property, photograph, without Her

consent, over Her objection, and against Her will.

54. The Thief with a tow truck arrived,

55. over Plaintiffs, objection, against Plaintiffs will, and without Plaintiffs consent,

56. Plaintiff was forced, by the armed Highway Men, impersonating lawful Officers, to remove

her two dogs from her property,

57. Absent any (fourth,) 4th, amendment warrant, or privilege to do so, the Highway man,

employee JOHN DOE #1, searched, and seized Plaintiffs conveyance, property, and removed

Plaintiffs property from where she parked it, without Her consent, over Her objection, and against

Her will.

58. and into Highway Man JOHN DOES #1 private possession on his tow truck,

59. therefore depriving Plaintiff of her private property without privilege to do so,



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60. under color of State law, Highway man JOHN DOE #1, acted in concert with the other

Highway men, who were impersonating lawful officers, and caused Plaintiff the damage alleged

herein,

61. Complainants property is valued at about $34,000.00,

62. Complainant does not have a Contract with the Corporation State of CALIFORNIA for a

known document called a Drivers License,

63. Complainants property is not registered as a motor vehicle with the Corporation,

CALIFORNIA STATE OF,

V CONCLUSION

36. All allegations set forth in paragraph 1 through 67 are incorporated herein its entirety by

reference.

37. According to the 1st, 4th, 5th, 6th, 8th, pursuant to the 14th Amendment of the United States

Constitution the Complainant has a right to Life, Liberty and Property,

38. Complainant has the right to use the public right of ways, in which to provide lifes essentials for

her family, without being terrorized by corporate employees acting as Tort Feasors.

V RIGHT OF ACTION

39. All paragraphs set forth in paragraph 1 through 38 are incorporated herein, by reference.

40. On November 03, 2010, Plaintiff was stopped on a public right of way, compelled to vacate her

property, terrorized, in fear of her life, held captive, not free to leave, had her property searched

and seized, charged with numerous administrative traffic infractions; when Plaintiff has NO

Contract with the CALIFORNIA, STATE OF, CORPORATION.



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46. SECOND CAUSE OF ACTION, officer, deputies, employees, servants, assigns, and agents,

who deprived the Plaintiff of her rights secured to her by the Constitution of the united states of

America including the right to use the public right of ways, but not limited to her Fourth (4th)

Amendment right to be free from unlawful search, seizure, detention of her person, secure in her

conveyance, papers, and effects from unreasonable searches, terrorized and unprovoked attacks,

absent a Fourth Amendment Warrant signed by a judge, and absent an Affidavit of Complaint

signed under penalty of perjury by a competent witness; by the above Defendants acting under

the color of State law held Plaintiff against her will, over her objection, without her consent and

deprived her of her conveyance without the privilege to do so.

47. THIRD CAUSE OF ACTION, officers, deputies, employees, servants, assigns, and agents,

who deprived the Plaintiff of her rights secured to her by the Constitution of the united states of

America including the Right to Travel on the public highways, but not limited to her Fifth (5th)

Amendment, pertinent to Fourteenth (14th) Amendment right to be subject to or answer to a

crime absent an indictment from a Grand Jury, nor be deprived of life, liberty, or property,

without due process of law, nor shall Plaintiffs private property be taken without just

compensation. Plaintiff is denied equal protection of the law, and her right to be free from terror

and fear of unjustified arrest, searches and seizure by the above Defendants acting under the

color of State law without the privilege to do so.

48. FOURTH CAUSE OF ACTION, officers, deputies, employees, servants, assigns, and agents,

who deprived the Plaintiff of Her rights secured to Her by the Constitution of the united states of

America including the right to use the public right of ways, but no limited to her Sixth (6th)

Amendment right to be informed of the nature and cause of the charges against Plaintiff, be

confronted with the witness against her, a crime shall have been committed. Plaintiff did not

commit a crime on November 03, 2010 on or about 3:45 pm, when stopped by SERGEANT



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____________________, OFFICER ________________, OFFICER ____________, OFFICER

___________________, and JOHN DOE #1. Plaintiff did not commit a crime before November

03, 2010.

49. FIFTH CAUSE OF ACTION, officers, deputies, employees, servants, assigns, and agents, who

deprived the Plaintif of her rights secured to her by the Constitution of the united states of

America including the right to use the public right of ways, but not limited to her Eighth (8th)

Amendment Right against cruel and unusual punishments inflicted, includes excessive bail.

Plaintiff suffered physical and emotional, cruel and unusual punishment at the hand of

Defendants, SERGEANT ____________, OFFICER ______________, OFFICER __________,

OFFICER _________________, and JOHN DOE #1. Plaintiff will be charged extortion fees by

a third party, for recovery of her property unlawfully removed by JOHN DOE #1, on November

03, 2010.

WHEREFORE: The Complainant demands judgment against Defendants, jointly and severally as

Defendants violated the united states Constitution, First (1st), Fourth (4th), Fifth (5th), Sixth (6th), Eighth

(8th), pertinent to the (14th) Amendment; Defendants denied Plaintiffs right to travel upon the public

rights of way, and denied Plaintiff Life, Liberty, and Property.

A DECLARATORY JUDGMENT FOR:

(a) Ten Million Dollars for violation of my rights guaranteed by the Constitution of the United States

of America;

(b) Declaratory judgment for compensation, search, impound and rental fees from third party

Defendant for deprivation of property, 2006 White Ford 4X4 Diesel Truck seized from

Complainant;



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(c) Declaratory judgment for cost of disbursement, research, and time incurred for this action;

(d) Declaratory judgment for false arrest;

(e) All attorney fees in processing this action pursuant to Title 42 U.S.C. Section 1988;

(f) All rights reserved and the right to amend complaint as needed;

(g) Complainant reserves the right to correct or update list of Defendants reflecting injuries due to

Non-Compliance.

(h) Declaratory judgment for Complainants record to be totally expunged; A151303 on November 03,

2010, 3:45 pm, all fingerprints, photos, and report expunged from the INLET system.

(i) Such other and further relief as to the court deems proper.

Dated: _____________________________

Trial by Jury is Hereby Demanded. _______________________________

_______________________________________________r., Ste G, #352Stockton, California (95207)



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