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Senator Edward Kennedy — Part 21
Page 15
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STEPHEN MOWRY AGEWT UPS,JUDGE BERRETTA, EUGENE HIGGINS, JOHN
GARAN, DONALD BACKER,HOGAN & HOGAN LAW FIRM, JUDGE DARRIGAN,
JUDGE McOSKER, RELIANCE INSURANCE CO.S, JOHN TOMLINSON(TO BE
SERVED LATER AFTER DISCOVERY OF LOCATION, IF POSSIBLE) ,RAUL
LOVETT, JOHN HARNETT,JEFFREY PERLOW,DAVID MORETTI ,COMMISSIONER
ROTONDI, LOVETT,MORGERA,SCHEFRIN,GALLOGLY UTD., MORETTI & PERLOW
LAW OFFICES, FORMER MAYOR "BUDDY"CIANCI, SHEILA STARADUMSKY,
STATE OF RHODE ISLAND/FAMILY COURTS--DISTRICT COURTS--SUPERIOR
COURTS--WORKERS COMPENSATION COURT, ‘John and Jane Does""THAT
THIS DISCOVERY,THIS CASE MAY UNCOVER", JOINTLY AND SEVERALLY IN
Compensatory,PUNITIVE AND EXEMPLARY DAMAGES, IN THE AMOUNT OF
TEN MILLION DOLLARS, ($10,000,000) AND THE COSTS OF THIS ACTION,
SUIT, AND DEMANDS A TRIAL BY JURY ALL COUNTS.
COUNT IV
25) PLAINTIFF REPEATS AND REALLEDGES THE ALLEGATIONS CONTAINED
IN PARAGRAPHS 1-~-14, COUNT I, AND 15--20 COUNT II, AND 21--24
COUNT III, AND INCORPORATES SAME INTO THIS COUNT IV, AND CHARGES
THAT COUNTS I,II,AND IIZI,ARE A DIRECT AND PROXIMATE RESULT AND7OF
DEPRIVATION OF CONSTITUTIONAL AND CIVIL RIGHTS, AND THAT DAMAGES
OCCURRED IN COUNTS I,II, AND III, ARE AS A RESULT OF AND IN
CONCERT WITH CIVIL RIGHTS VIOLATIONS, AND CONSPIRACY, CONTAINED
IN THIS COUNT IV. PLAINTIFF FURTHER CHARGES THAT THESE CHARGES
THIS COUNT IV, ARE OF CIVIL RIGHTS VIOLATIONS, WHICH WERE ACTIONS,
COMMITTED TO CONCEAL ACTIONS,EARASSMENT AND INTIMIDATIONS BY
POLICE AND STATE BECAUSE OF PLAINTIFFS SEEKING REDRESS OF GRIEV-
ANCES IN STATE COURTS, TO DEPRIVE PLAINTIFF OF THESE STATE COURTS,
RETALIATION FOR FILINGS IN STATE COURTS, AND FOR FILING ACTIONS
IN THIS FEDERAL DISTRICT COURT.
26¥ That the Plaintiff Charges that on or about Septmber 15th,
1984, he was forced by the West WarwickPolice Department Et Al,
Defendants, going,in disguise, as defendant William Field, owner/
Landlord of the Building, 1686 Main St. West Warwick RI, who in’.
conspiraéy with same West Warwick police Department, and actine
on behalf of same, did evict Plaintiff, having given eviction
notice on or about July 22nd,1984. (Plaintiff having filed
complaint pertaining to these Civil Rights Violations, 87-0473,
Filed September 15th,1987, on appeal pending " In Forme Pauperis"
Costs of filing.) Plaintiff repeats and realledges all counts
this complaint, and does incorporate same complaint, ali counts
into this complaint, charging that all issues contained in this
complaint 87-0473, are contained in this complaint, and are of
a common issue; To Wit--State and police, entrapment. harassment,
intimidation, deprivation of civii rights--conspiracy-- Dental
of Equal Rights--Depriving Plaintifé of rights and privilégés,
ané Action for neglect to prevent Conspiracy~- all Causes of
Action Under 42 USCS&1981,1983,2935(2) (3),and &$&1986-—- and
Jurisdiction Claimed under Tittle 28 USCS1343 (1) (2) (3)8(4),anda
1331. Plaintiff further charces that the Defendants are all the
same defendants, and does further attach and make part of this
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