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Senator Edward Kennedy — Part 20
Page 232
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in a state of blackmail, extortion, an in an attempt to have
the Plaintiff, in a state of forced depression, commit suicide,
therefore, attempted murder, by induced, harassment, intimidation
of an extreme and un-relenting nature, day atter day, and as
in the remaining countS-~shall charge, continuing--in an un-
relenting pattern for many years. This miss-use and abuse of
the twins, being the in-human pinnacle, in years of in-humane
conspiracy perpetrated, in an un-relenting cover-up of years of
criminal acts against the plaintiff, and his heirs, to deprive him
and same heirs, of any and ali civil rights, in a concerted
violation of any and all Civil Rights, as Follows: Following
Counts This Complaint, and these Counts I and TI.
Plaintiff charges that this motion to modify is still pending,
and that he has in the interim been served, on January 9th,1988,
A Contempt Summons,and witness summons, with attached Motion to
Adjudge In Contempt. Plaintiff cnarges that he has since early
in this case, filed, had filed, obtained counsels who should
have filed, for a hearing to determine custody in this matter.
And that Plaintiff Charges all defendants thiS Count, and Count
I, in conspiring, under and against the plaintiff, and violating
his Civil Rights, Under 42 USCS&1986 -- Failing to act, to prevent
conspiracy, !985, (2) & (3), Conspiring with each other to deprive
Plaintiff and use this Family Court, the twins, and aiding and
abetting with the defendant Gloria Hartmann, to illegally stop,
deprive plaintiff of this hearing, illegally tampering with the
witness Gloria Hartmann, by not allowing her to testity, answer
interrogatories, or otherwise answer the initial complaint, as
filed. Plaintiff further charges that the défendants' have-acied
in concert and in omission, by using and miss-using offices to
obtain same conspiracy, therefere-. Acting " Under Color of the
Law,", in all violations under 42 USCS&1983 causes of action.
(deprivation of rights to a hearing,) and thus violating the
Civil Rights of the Plaintiff, under 42 USCS, 1981, gross denial
of Equal rights under the law.....To sue, be parties, give
evidence.....eeeceeeee- AS Plaintiff charges and does intend to
prove, that all defendants as charges these two counts have
conspired in concert, to deprive the plaintiff ot--A fair hearing
for the well being of the twin infants... Plaintiff charges that
all défendants as Listed shall be listed, this complaint, by
conspiracy, “Acting under Color of the Law", Conspiratory Omission
in their capacities to act to prevent further conspiracies, nave
all deprived the plaintiffs twins, of adequate care, and are
guilty in a voluntary/involuntary criminal manner of, physical
abuse, neglect and deprivation, of any committed acts against
same twins, including sicknesses inflicted by improper care, due
to removal to improper housing conditions and unstable /incomoetent
/vindictive defendants. Plaintift charges that the defendants
were foreworned per complaint, C.C.R. 87-23501, o.-sPlaintiff
"Mr. Staradumsky protested the mother taking the children as he
feels she is an unfit mother......."Plaintiff further charges
that he did also inform Sat. Owens, that the conditions at 3
Curtis street, were unfit, and it was a drug useage location,
(18)
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