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First Subsequent Civil Complaint to Federal MASTER CIVIL COMPLAINT

First Subsequent Civil Complaint to Federal MASTER CIVIL COMPLAINT

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FIRST JUDICIAL DISTRICT OF MINNESOTA
LE SUEUR COUNTY

JOHN DOE, individually, and
       in behalf of my five children and the Citizens of Le Sueur County
               Plaintiffs,
    vs.
JANE DOE, individually
JEFFERSON COUNTY CHILD SUPPORT SERVICES,
JEFFERSON COUNTY COLORADO,
               Defendants.
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VERIFIED COMPLAINT
--------------------------------------------------------------

I, plaintiff John Doe, individually, and in behalf of my five children and the citizens of Le Sueur County Minnesota, seek certain declaratory relief to rectify a child support controversy in Minnesota, and sue the defendants for money damages in amounts greater than $50,000 caused by defendants' frauds upon the court and other offenses in Le Sueur County, and state:

DEMAND FOR JURY TRIAL

1.      Unless settled[1] (see first cause of action herein), plaintiffs demand two jury trials.

PARTIES

2.      I, plaintiff JOHN DOE, am presently a homeless indigent citizen of Le Sueur County Minnesota, but can receive mail at 1 Zippedy Do Da Lane, Le Sueur, MN 56058.

3.      The DOE TRUST is the Doe family's trust set up to receive settlements and jury awards for the benefit of my five children and myself.

4.      The CITIZENS OF LE SUEUR COUNTY MINNESOTA are also victims of the defendants' frauds upon the Minnesota courts and other offenses in Le Sueur County; a local bank account will be set up to receive settlements and jury awards for the citizens.

5.      Defendant JANE DOE is my ex-wife, is a citizen of Jefferson County Colorado, and presently resides at  U.S. Highway 40, Golden, CO 80439.

6.      Defendant JEFFERSON COUNTY CHILD SUPPORT SERVICES is represented by Assistant County Attorney Casie Stokes, 3500 Illinois Street, Suite 1300, Golden, CO 80401.

7.      Defendant JEFFERSON COUNTY COLORADO is currently represented by County Attorney Ellen G. Wakeman, 100 Jefferson County Parkway, Suite 5500, Golden, CO 80419.

JURISDICTION AND VENUE

8.      The events alleged herein occurred or caused injury in Le Sueur County Minnesota.

9.      This action seeks relief for plaintiffs' injuries caused by the defendants' frauds upon the court and other offenses in Le Sueur County cases 40-FA-07-0000 and 40-CR-09-0000.

10.    This district has original subject matter jurisdiction and this district court is the proper venue pursuant to Minn. Const. art. VI, § 3 and Minn. Stat. § 480.04.

11.    Because the defendants committed acts both inside and outside Minnesota that caused injury to the Le Sueur County plaintiffs, this district has personal jurisdiction over the nonresident defendants pursuant to Minnesota's long-arm statute: Minn. Stat. § 543.19, subd. 1, (3) and (4).

BACKGROUND

[NOTE: This section contains detailed factual allegations that will be adjudicated mainly in

Colorado, but that are also needed for the declaratory relief and damages sought herein.]

12.    Defendant JANE DOE (“Jane”) and I grew up in Minnesota, have known each other for over 40 years, were in a relationship for 22 years, and were married for 15 years.

13.    Jane and I moved to Colorado at different times in the early 1980s.

14.    Jane and I have six children, five of which are living.

15.    Jane became pregnant with our first child in the summer of 1983.

16.    While I was making arrangements in the fall of 1983 to transfer from Northeastern University in Boston to a college in Colorado so that I could support Jane and our first child, Jane called me to tell me that she had miscarried our baby.

17.    Unbeknownst to me until after she filed for divorce in 2005, Jane had secretly aborted our first child in 1983, as part of a very sordid plan to entrap me into a relationship, to marry me, to steal from me, and to divorce me when I had accumulated substantial assets.

18.    Jane and I were married on October 6, 1990.

19.    Pursuant to my vows, I married Jane for life.

20.    Pursuant to her written plan, Jane married me for profit.

     PERTINENT FACTS REGARDING CHILD SUPPORT:

21.    Early in our marriage, in what we referred to as our “Grand Plan,” Jane and I agreed that she would take care of the domestic chores and I would run my small construction business for everyday expenses, invest in real estate, build our family’s homes, and strive to payoff all debts; and, if accomplished, I would semi-retire and we would reverse roles.

22.    I worked double-time hours (over 80 hours/week) for much of my 25-year career, essentially cramming two careers into one to reach our goals, so that I could spend the maximum amount of time possible with our kids while they were growing up, as I had a lot to teach them.

23.    I accomplished our Grand Plan in April 2000 when I finished building our 3rd home on 27 acres in the foothills just up from Denver.

24.    Shortly thereafter I paid off all our debts.

25.    In addition, I had ample savings and equity at the time to pay any other financial obligations for my children’s entire upbringing.

26.    In 2002, after a one year stint in a fluke job in which I earned the highest income of my career, I began semi-retiring and role reversing with Jane as agreed.

27.    For about two years prior to Jane’s divorce, I was our children’s primary caregiver.

28.    During this time, I attended the parent/teacher conferences and other school events, most of our 4 boys’ soccer games, most of our kids' other activities, and most religious events, up until Jane’s assassination of my character in our Church and all around our community.

29.    All through our marriage, I was the sole decision maker for our family.

30.    Between 2002 and 2005, I improved our property in preparation for my home-based part-time business of making log structures, such as gazebos, decks, bridges, and furniture.

31.    Between 2002 and 2005, I harvested, draw-knifed, and stockpiled hundreds of full-length logs for my business.

32.    My semi-retirement business was headquartered on our property.

33.    The 27 acres has thousands of trees, which would have provided a lifetime supply of wood for my projects.

34.    My semi-retirement income was less than $20,000.00 per year, which paid all the bills since our mortgage and other debts were paid-off and we heated our house with wood.

35.    After refusing since 2002 to restart her career as agreed, in the fall of 2004 Jane began working for a tax preparation firm.

36.    In late-2004, Jane reneged on all our agreements in our Grand Plan.

37.    Just prior to filing for divorce, Jane agreed to move in the best interests of our children, but then reneged on that agreement too a few weeks later.

38.    Regardless of our Grand Plan, though, because “child support” is defined as the parents' responsibility to provide for the basic needs of their minor children, which are shelter, food, clothing, and education, and because I had paid my financial obligations for my children's entire upbringing, in full, until adulthood, prior to Jane's divorce, my child support obligations are paid-in-full; see evidence and additional information in Exhibit MN-500 of EXHIBIT BOOK.

     JANE'S FRAUDS UPON THE COLORADO COURTS AND ME:

39.    On January 25, 2005, Jane filed her divorce[2] against the wishes of our kids and me.

40.    While doing my mandatory inventory of our things, I found Jane's secret written plan to take advantage of me in life.

41.    Later that year, I began to realize that, as part of her gold-digger plan, Jane:

     a.    Had murdered our first child;

     b.    Had been defrauding me for over 22-years;

     c.    Had defrauded my family and friends and the priest at the alter in our wedding;

     d.    Had married me with her divorce in mind;

     e.    Had been brainwashing our children against me since they were little;

     f.     Had been turning our mutual friends against me throughout our marriage;

     g.    Had defamed me for years in the schools, in our church and all around our community;

     h.    Had systematically skimmed tens-of-thousands of dollars from our marital bank accounts;

     i.     Had opened her own secret bank accounts to conceal her thefts;

     j.     Had stockpiled thousands of valuable “collectibles” for her future life without me;

     k.    Had called numerous attorneys while I was working to get ideas for her divorce;

     l.      Had planned to defraud the courts and law enforcement during her divorce;

     m.    Intended to “call 911” despite the fact that I had never touched her in a mean way;

     n.    Intended to steal as much from me as she could in her divorce;

     o.    Intended to do and say whatever necessary to maximize the child support order; and

     p.    Intended to do and say whatever necessary to get rid of me from our family.

42.    On March 18, 2005, Jane called 911 to take the upper hand in her divorce, as she had planned in 1996, setting in motion a “domestic violence scam,” the “911 Scam,” that she still uses to this day to influence the judicial and administrative proceedings in Colorado and Minnesota.

43.    To maximize her thefts during her divorce, Jane committed at least 26 material frauds upon the Colorado courts; see Exhibits MN-501 to MN-508.

44.    In March 2006, Jane and I were officially divorced.

45.    In May 2006, “Permanent Orders” were issued in Jane's divorce.

46.    As alleged and evidenced herein, by massive fraud, Jane obtained near-full custody of our five minor children, sole decision-making ability, over 95% of the $2 million estate I built including the paid-off real estate where my business was headquartered, a grossly inflated child support order, and other miscellaneous orders designed to wipe me out financially.

     THE COLORADO DIVORCE ORDERS ARE VOID:

47.    For any one of the 26 frauds upon the Colorado courts in the previous section, Permanent Orders in Jane's divorce, including the child support order, were automatically rendered null and void and unenforceable by operation of law.

48.    In addition, the Colorado child support order is void for several other reasons, including but not limited to the divorce judge's failure to find and declare the fact that my child support obligations are paid-in-full, his failure to follow Colorado's Child Support Guidelines, his failure to be equitable with parenting time, and for any one of his materially false statements in his Permanent Orders that are contrary to the facts and law; see Exhibit MN-507.

     POST-DIVORCE CRIMES IN COLORADO:

49.    In May 2006, Jane fraudulently applied for child support enforcement services with Jefferson County Child Support Services (“Jeffco-CSE”).

50.    In May 2006, Jeffco-CSE unlawfully opened a “Title IV-D” Child Support Enforcement case[3] for Jane knowing she was ineligible.

51.    In the post-divorce, a conspiracy developed between Carol, Jeffco-CSE, and the officers of the court who had “fixed” the divorce against me in all regards, to deny my efforts to rectify the injustices, to impoverish me and to completely get rid of me from my family.

52.    Over the next year, Jane and Jeffco-CSE and the other conspirators:

     a.    Increased the denials of my parenting time and contact with our children;

     b.    Continued to hold my things hostage, including my tools and work equipment, knowing I was involuntarily unemployed as a result, see Exhibit MN-630;

     c.    Unlawfully seized my share, $9,973.50, of the “MSE Settlement” money awarded in permanent orders, see Exhibit MN-508, pages 1-2;

     d.    Deprived my right to verification of the facts, see Exhibit MN-508, page 3;

     e.    Committed state and federal crimes to obtain public assistance in the Child Support Enforcement Program, see Exhibit MN-508, page 3;

     f.    Altered the Title IV-D case, see Exhibit MN-508, page 4;

     g.    Harassed me for undue payment, see Exhibit MN-508, pages 4-5;

     h.    Refused credit for payments made, see Exhibit MN-508, page 5;

     i.     Stole another $750.00 in the “MSE Settlement” scam, see Exhibit MN-508, pages 6-7;

     j.     Suspended my driver’s license without due process, see Exhibit MN-508, page 7-9;

     k.    Ruined my good credit without due process, see Exhibit MN-508, pages 9-10;

     l.     Levied my bank accounts without due process, see Exhibit MN-508, pages 10-11;

     m.   Continued their “Contempt Scams” in pursuit of the 3 miscellaneous orders Carol and Hugger had obtained by fraud totaling $30,801.50, see Exhibit MN-508, pages 12-20;

[Caused injury to the plaintiffs in this action:]

     n.    Stole $5,500.51 from my children’s trust account, see Exhibit MN-508, page 12;

     o.    Deprived me of my due process rights to review and adjustment of the child support order, see Exhibit MN-508, pages 21-22;

     p.    Deprived me of my due process right to modification of the child support order, see Exhibit MN-508, pages 22-29;

     q.    Denied my repeated requests to use discretion regarding suspension of my driver's license;

     r.     Deprived me of my right to services in Jeffco-CSE's “Fatherhood Initiative Program”; and

     s.    Devastated my relationships with each of my five children.

53.    For any one of the foregoing denials of due process or other crimes by Jeffco-CSE, jurisdiction was lost in the Title IV-D case by operation of law.

54.    The known void Colorado child support order has been illegally enforced ever since.

55.    In addition to the facts that my child support obligations are paid-in-full and that the arrears balance is zero, Jeffco-CSE Manager Debbie Moss, who was also the Title IV-D Administrator for Jefferson County at the time, has known since at least early 2007 that permanent orders, including the child support order, are void for several reasons.

STATEMENT OF THE CASE

[NOTE: This section contains detailed factual allegations to be adjudicated in Minnesota.]

56.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

57.    To protect my children and myself from further harm following my 4th false arrest and imprisonment in Colorado, I moved to Minnesota on May 19, 2007.

58.    Jane has denied all my parenting time with our children, including summer vacations and holidays, since May 2007.

59.    Jane has denied all my contact with our kids since August 2008.

60.    Jane has worked tirelessly since I moved to Minnesota to prevent me from seeing or talking to our children, see Exhibit MN-600, and to brainwash each of our kids against me.

61.    Jane and Jeffco-CSE have relentlessly stalked me in Minnesota since I moved here with the intent to influence judicial proceedings against me.

62.    During the summer of 2007, Jeffco-CSE refused to review and adjust the child support order, which I had initiated on March 29, 2007.

63.    On June 28, 2007, my 90-day probationary driver's license expired.

64.    Since then, Jeffco-CSE has ignored numerous verbal and written requests from me to reinstate my suspended driver's license despite their ability to use discretion.

65.    Between late-June and late-October 2007, my employer (my brother Paul) drove approximately 50 miles each day to pick me up for work and drop me off at the end of the day.

66.    In late-October, Paul laid me off until I could obtain a driver's license.

67.    I have been involuntarily unemployed since October 2007.

68.    I have been forced to work 60-80 hours per week since October 2007 to defend myself against Jeffco-CSE's and Jane's never-ending pursuit of undue child support.

69.    When Jane or Jeffco-CSE found out where I was working in 2007, someone contacted the Nicollet County Sheriff's Office to visit my workplace.

70.    When Jane or Jeffco-CSE found out where I was living, Jeffco-CSE contacted the Le Sueur County Child Support Enforcement office (“LeSueur-CSE”) to register the Colorado child support order and arrears balance in Minnesota for enforcement.

71.    In November 2007, Jeffco-CSE transmitted their first false arrears balance to LeSueur-CSE[4] in a sworn “REGISTRATION STATEMENT” with the intent to influence a judicial proceeding in Minnesota.

72.    On information and belief, Jeffco-CSE persuaded LeSueur-CSE to skip a required administrative due process prior to registration of the Colorado child support order.

73.    In December 2007, LeSueur-CSE registered the Colorado child support order and arrears balance in Minnesota for enforcement, starting Le Sueur County case 40-FA-07-1253.

74.    In February 2008, a Minnesota judge vacated the first registration.

75.    In February 2008, I initiated the second “review and adjustment” of my child support by Jeffco-CSE through LeSueur-CSE.

76.    Along with my application and supporting documents during the second review, I provided Jeffco-CSE and other Colorado authorities ample information and evidence proving that my child support obligations are paid-in-full, that the child support order was obtained by fraud (and is therefore void), and that the arrears balance is zero.

77.    On April 30, 2008, Jeffco-CSE transmitted another known false – and still uncorrected – arrears balance to LeSueur-CSE for registration, see Exhibit MN-601, along with a copy of the AMENDED ORDER RE: PERMANENT ORDERS HEARING of June 22, 2006 (which included the known void child support order) and 87 pages of prejudicial and irrelevant documents, see Exhibit MN-602, with the intent to influence the second registration.

78.    On May 20, 2008, relying on the accuracy of Jeffco-CSE's transmittal under the full faith and credit laws, LeSueur-CSE registered the void Colorado child support order and false arrears balance in Minnesota for enforcement; see Exhibit MN-603.

79.    Also on May 20, 2008, a Jeffco-CSE caseworker recommended – in the Colorado review/adjustment process – a reduction in my monthly child support obligation from $1717.92 to $521.00, which was still incorrect but better than nothing; see Exhibit MN-604.

80.    On July 7, 2008, Jeffco-CSE's attorney Casie Shorey (now Casie Stokes) moved the Colorado court to modify my child support from $1717.92 to $521.00.

81.    On September 22, 2008, Stokes defrauded the Colorado court to withdraw my motion to modify the child support.

82.    Because of the continued crime spree against my family in Colorado by the officers of the court and Jeffco-CSE and their emerging effort to corrupt the Minnesota court and LeSueur-CSE, I wrote to Jane on June 27, 2008, and asked her to settle the child support matter between us in the best interests of our children; see Exhibit MN-605.

83.    But instead of thinking about our kids, in early-July 2008, Jane emailed one of my witnesses to influence his testimony in the second registration proceeding.

84.    By then, Jane was fully committed to join Jeffco-CSE in their oppression of me under color of Minnesota law.

85.    In answer to my discovery requests in the second registration, Jane committed multiple perjuries with the intent to influence the judicial proceeding; see Exhibit MN-606.

86.    On September 29, 2008 – the same day Stokes' motion to withdraw my motion to modify was granted in Colorado – the Minnesota judge approved the registration of the Colorado child support order and arrears balance for enforcement “[b]ased upon the testimony and exhibits,” which included Jane's fraudulent answers to my discovery requests, “and the filings from Colorado,” which included Jeffco-CSE's fraudulent REGISTRATION STATEMENTs and 87 pages of prejudicial and irrelevant documents; see Exhibit MN-607.

87.    In the fall of 2008, I discovered that one of Jane's sisters in St. Peter Minnesota is related to the Le Sueur County Attorney, who later disqualified himself.

88.    In January 2009, I formally objected – to Jefferson County officials, and others – to the continued enforcement services, on the grounds that my children are not “needy” as defined by state and federal law, see Exhibit MN-608, but Jeffco-CSE failed to cease and desist from their enforcement actions or close the Title IV-D case or even respond, as required by law.

89.    In March 2009, I wrote to Jefferson County Attorney Ellen Wakeman in follow up to my formal objection and requested that she oversee the reconciliation of my Title IV-D account, but she failed to even respond.

90.    On information and belief, it was around this time that Wakeman, Stokes, and Moss ordered their offices to ignore my requests to reconcile my child support account, to stonewall my requests for information, to ignore my complaints, and to blacklist me to prevent me from obtaining any services in Jefferson County.

91.    In June 2009, I again formally objected to all involved, this time providing 18 “further reasons that Colorado must cease and desist enforcement of the orders,” but again, all involved continued to enforce the known void Colorado child support order and false arrears balance in violation of state law and federal law and of my children's rights and my rights.

92.    In July 2009, LeSueur-CSE filed a criminal complaint against me in Minnesota for nonsupport of my children, based on false arrears balance figures provided by Jeffco-CSE, starting Le Sueur County case 40-CR-09-786.

93.    In June and July 2009, I tried to arrange my court-ordered summer vacation with my kids, but to prevent it Jane instructed the kids to ignore my repeated calls.

94.    On August 13, 2009, I applied for all services in Jefferson County's “Fatherhood Initiative Program,” which is administered by Jeffco-CSE, see Exhibit MN-609.

95.    My advocate in the program repeatedly contacted Jane to restore my visitation and contact with our children.

96.    On August 31, 2009, Jane told my advocate that she would call the sheriff if I ever came to Colorado to see our kids.

97.    On September 3, 2009, Moss ordered my advocate in the program to deny me services in the Fatherhood Initiative Program.

98.    Also on August 13, 2009, I moved the Colorado courts for orders requiring Jane to provide our children's contact information to me and to have our kids contact me at set times.

99.    On October 19, 2009, the Colorado court ordered Jane “[p]romptly to provide updated information and to continue to update it if phone numbers, email addresses or mailing addresses change. To encourage the children to contact their father and to respond to any reasonable message that he leaves for them. Such encouragement should be provided in a manner that is meaningful to them and that constitutes a good faith best effort to accomplish the objective of establishing a line of communication with him”; see Exhibit MN-610.

100.    Like all other orders and laws protecting the welfare and best interests of our children, Jane ignored this order and has continued her felony denials of my contact and visitation to this day.

101.    On June 16, 2010, I was falsely arrested and imprisoned for the 5th time – this time for nonsupport of my children – in Le Sueur County case 09-786.

102.    My brother paid $5,000.00 to bail me out 3-days later.

103.    In the months leading up to the jury trial in February 2011, I attempted several times to obtain exculpatory evidence for my defense from Jane, Jeffco-CSE's Moss and Jessica Delgadillo (who committed perjury in the REGISTRATION STATEMENTs), and several others, see Exhibit MN-611, but no one responded or produced any documents.

104.    In contempt of the Minnesota courts, Jane ignored three Subpoenas for her testimony, two Notices for Witness Testimony, and four Requests for Production of documents.

105.    In contempt of the Minnesota courts, Moss and Delgadillo ignored three Subpoenas for their testimony, a Notice [to each] for Witness Testimony, and four Requests for Production of documents.

106.    According to the court administrator, neither Jane nor Jeffco-CSE contacted the court at any time to inquire about their subpoenas, or sent any of the documents I requested.

107.    On or around February 28, 2011, Jeffco-CSE conspired with LeSueur-CSE supervisor Tammy Morgan and Minnesota prosecutor Michelle Zehnder Fischer to enter the false – and still uncorrected – arrears balance figures as evidence in the jury trial, and to falsely testify about the arrears balance and my payments toward child support, with the intent to influence the jury; see Exhibit MN-612.

108.    On March 1, 2011, the jury found me guilty of felony nonsupport of my children.

109.    In August 2011, Zehnder Fischer caused the illegal forfeiture of my $5,000.00 bail to Jeffco-CSE for Jane.

110.    On December 16, 2011, I was falsely arrested and imprisoned for the 6th time.

111.    While I was in jail, with the intent to influence the sentence, Jane conspired with Zehnder Fischer to obtain a “No Contact Order” preventing me from contacting our five children, including our adult children, as a condition of my probation.

112.    While I was in jail, with the intent to influence the sentence, Jeffco-CSE conspired with LeSueur-CSE and Zehnder Fischer to obtain an order requiring me to pay further child support, as a condition of my probation.

113.    On February 7, 2012, the Minnesota judge sentenced me to six months in jail and five years probation, which included the requested No Contact Order and an order to pay further child support, as conditions of my probation; see Exhibit MN-613.

114.    On information and belief, Jane and Jeffco-CSE began conspiring with my probation agent Julia Kraemer shortly after sentencing, with the intent to cause as many false arrests and false imprisonments as possible and with the hope that the oppression would cause my suicide.

115.    I was released from the Le Sueur County Jail on April 8, 2012.

116.    Kraemer immediately violated me for not signing some paperwork while in jail, setting in motion the post-sentencing oppression; see Exhibit MN-614.

117.    On July 1, 2012, unbeknownst to me, Jane made another false report to the Jefferson County Sheriff's Department in Colorado, this time claiming that I had left messages on, and had sent texts to, my daughter's cellphone, in violation of the No Contact Order.

118.    On July 2, 2012, I was tasered, falsely arrested and imprisoned for the 7th time, but, after signing Kraemer's paperwork, I was released that day without bail.

119.    To keep the oppression going for Jane and Jeffco-CSE, Kraemer immediately filed another Violation Report accusing me of violating the No Contact Order.

120.    While in Kraemer's office on July 23, 2012, I was falsely arrested for the 8th time and transported to the Nicollet County Jail to face false charges in case 52-CR-12-278, but was released the next day without bail.

121.    In January 2013, after hundreds of attempts to reach my children by phone, text, email and Facebook, I decided to stop and wait for God's timing to restore my family.

122.    In November 2013, I served my family's federal MASTER CIVIL COMPLAINT (“MCC”) upon the nine government defendants, including Jefferson County Colorado.

123.    In addition to monetary damages, our federal MCC seeks other relief to completely resolve the child support controversy; see Exhibit MN-615.

124.    On April 2, 2014, in my direct appeal of the jury verdict (see Appeal A12-794), the Minnesota Supreme Court wrongly ordered me to turn myself in for violating the No Contact Order, or my appeal would be dismissed.

125.    I turned myself in according to the rules, but my appeal was dismissed anyway.

126.    To maximize my 9th false imprisonment, Jeffco-CSE continued to transmit falsified arrears balances in the case and ignored my discovery requests.

127.    In preparation for the probation revocation hearing scheduled on August 28, 2014, I wrote to Jeffco-CSE caseworker Griffen Korosec to obtain documents for my defense, sent her the pertinent facts alleging that my child support obligations are paid-in-full, and again requested reconciliation and closure of the Title IV-D case; see Exhibit MN-616.

128.    On July 31, 2014, I initiated Jeffco-CSE's fifth administrative review and adjustment of my child support account; see Exhibit MN-617.

129.    As is typical with all my letters and complaints, Jeffco-CSE ignored my discovery request and review request to further influence the judicial proceedings in Minnesota.

130.    I was released from the Le Sueur County Jail on August 4, 2014, and transported to the Nicollet County Jail, which began my 10th false arrest and imprisonment.

131.    I borrowed another $600.00, posted bail, and was released on August 6, 2014.

132.    On August 14, 2014, the sentence in the Le Sueur County case was vacated; and on September 16, my probation was discharged and I was re-sentenced to time served.

133.    On October 20, 2014, I was forced to take a plea deal in the Nicollet County case.

134.    During Jeffco-CSE's fifth review of the Title IV-D case, I wrote 2 detailed letters to Jeffco-CSE's paralegal Sue Palmer, see Exhibit MN-617, and talked with her several times on the telephone to make sure that she understood that I was requesting an administrative review, not a judicial modification, and to make sure that she had the pertinent facts and evidence proving that my child support obligations are paid-in-full and the arrears balance is zero.

135.    But Palmer, as directed by Stokes, refused to do a proper review, insisted on imputing a false income for me into their child support worksheets in preparation for a judicial modification, and made ridiculous statements during our phone conversations including:

     a.    “I have to impute earning ability...” (for my income).

     b.    “I can't cite statutes...” (when asked for her legal authority for her actions).

     c.    “We do our review on the guidance of the department's attorney” (referring to Casie Stokes, who fixed the modification action against me in 2008, see Exhibit MN-604).

     d.    “What we can do and what we will do are two different things.

     e.    (Regarding reconciliation of my Title IV-D account): “I've heard this many times already, John. I already know the issue. I know what you want. I've already told you that I'll talk to the department attorney, I'll talk to my supervisor, and then I'll get back to you if the answer is different than what I've already told you.

     f.      “I'm telling you what we're going to do and I'm telling you what your options are.

     g.    “We don't agree with you … we don't agree that we should calculate your income as zero.

136.    On October 22, I began calling and leaving messages for Jeffco-CSE Manager/Title IV-D Administrator Alvin Tafoya to take full control of my case, but we never talked.

137.    On October 23, Jeffco-CSE caseworker Korosec, who never responded to my discovery request in July, finally called me to tell me that she would allow me to have a 90-day probationary driver's license, but ignored my request for reconciliation of the arrears balance and refused to look into reimbursement of the $5,500.51 stolen from my children's trust account.

138.    Over my repeated objections, on the 28th of October, Palmer imputed a false monthly income of $7,000.00 for me into the child support worksheet and filed with the Colorado court a motion to modify the child support order from $1,717.92 to $1,361.00 per month, to support my two youngest children who are still considered minors; but withdrew it a few days later when I complained.

139.    I left eleven detailed messages for Tafoya requesting:

     a.    That he take full control of the review;

     b.    That he open a case for me in the “Responsible Fatherhood Program” and help me reestablish contact and visitation with my children;

     c.    That he take whatever action necessary to lift the suspension of my driver's license;

     d.    That he obtain my letters from Palmer and Korosec, and fulfill my requests;

     e.    That he contact me if he had any trouble locating the evidence proving that my child support obligations are paid-in-full;

     f.    That he verify the facts and evidence, and administratively find and declare the facts in the Title IV-D case that my child support obligations are paid-in-full and the arrears balance is zero;

     g.    That he close the Title IV-D case; and

     h.    That he report his office's knowledge of Carol's crimes and child abuses to the Jefferson County Sheriff's Department and Jefferson County Child Protective Services.

140.    On November 5, 2014, Tafoya left me a message essentially denying me all services by Jeffco-CSE, turning my case over to Stokes, and advising that, unless I can provide a court order showing that my child support obligations are satisfied, his office cannot help me.

141.    On November 6, 2014, I wrote a final letter to, see Exhibit MN-617, and left a final telephone message for Tafoya, but, as of the date of this complaint, he has failed to respond.

142.    For the fifth time, Jeffco-CSE refused to do a proper administrative review of the Title IV-D case.

143.    Jeffco-CSE refused to open a case for me in their Responsible Fatherhood Program.

144.    Jeffco-CSE refused to report their knowledge of Carol's crimes and child abuses.

145.    Jeffco-CSE again deprived me of my rights to their services under color of law.

146.    Jeffco-CSE again deprived me of my right to honest services.

147.    And the conspiracy between Jane and Jeffco-CSE to deprive my five children and me of our rights to “frequent and continuing contact,” to defraud the courts in Colorado and Minnesota, and to stalk me and oppress me in both states, continues to this day.

148.    To date, in dealing with Jane's and Jeffco-CSE's never-ending pursuit to force me to pay my child support obligations again for their further amusement and profit, I have written 723 letters, I have made 806 telephone calls, and I have submitted 649 court documents, but have never received even a sliver of justice or protection for my family.

149.    To date, as one result of the massive effort by Jane and Jeffco officials and others to deny all my visitation and contact with my kids and leave the child support matters unresolved, I have not seen my oldest son B. Doe since May 6, 2007, and have not talked to him since August 25, 2008; I have not seen or talked to my son T. Doe since September 2006; I have not seen and have only talked once to my son N. Doe since April 21, 2007; I have not seen my son C. Doe since May 6, 2007, and have not talked to him since August 6, 2008; and I have not seen my daughter A. Doe since May 6, 2007, and have not talked to her since August 7, 2008.

FIRST CAUSE OF ACTION: SETTLEMENT

150.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

151.    This cause of action seeks quick settlement of this lawsuit, or preliminary relief.

152.    In full and final settlement of all civil and criminal claims against her, in both states*, within 20 calendar days following service of process of this complaint, Jane Doe shall:

    a.    Take whatever action necessary to immediately restore contact between our children and me;

    b.    Take whatever action necessary to assist Jeffco-CSE in arranging for my Christmas Holiday with our children in Colorado (see below);

    c.    Stipulate to the facts that my child support obligations are paid-in-full and the arrears balance is zero, and fulfill the other terms of the STIPULATION WITH RESPECT TO CHILD SUPPORT dated December 1, 2014 (delivered by the process server with this complaint); and

     d.    Agree to and fulfill the terms of the SETTLEMENT AGREEMENT dated December 1, 2014; (delivered by the process server with this complaint).

     *NOTE TO JANE: If you fulfill the above terms of settlement, you are done. And I will ensure that our children can contact you as often as they wish and will also help you recover damages from the States if you wish (always remember, our government ruined your family too). As an added bonus, if you will complete the terms of this settlement offer and the terms of the STIPULATION and the terms of the SETTLEMENT AGREEMENT by no later than 5:00pm on Friday, December 19, 2014, so that I can spend the Christmas Holiday with our children, I will also release your two sisters from any and all claims. If not, you and your sisters will be named in multiple civil and criminal complaints in both states, including actions for the wrongful death of our first child.

153.    In full and final settlement of all civil and criminal claims against them in Minnesota (except their civil liability for my false arrests and imprisonments), within 20 calendar days following service of process of this complaint, Jeffco-CSE / Jefferson County Colorado shall:

     a.    Declare – administratively in the Title IV-D case – that my child support obligations are paid-in-full and the arrears balance is zero;

     b.    Reconcile and close Title IV-D case #xx-xxxxxx-xx-xx;

     c.    Take whatever action necessary to withdraw or terminate the registration of the Colorado orders and arrears balance in Minnesota;

     d.    Take whatever action necessary so that I can permanently reinstate my driver's license;

     e.    Immediately pay $5,000.00 to me for travel, lodging, gifts for my children, and other expenses, so that I can arrange and pay for a trip to Colorado during the 2014 Christmas Holiday;

     f.     Pay $880,601.00 ($7,000.00 per month + interest) to me for lost income while in Minnesota, as calculated in Exhibit MN-650;

     g.    Pay $188,988.00 ($62,996.00, tripled (because your 8-year crime spree against my family should have never happened)) to me for my expenses in Minnesota, as itemized in Exhibit MN-650;

     h.    Pay $30,747.00 ($10,249.00, tripled) to the Doe Trust for the money stolen from my children's trust account by Jeffco-CSE, as calculated in Exhibit MN-650;

     i.     Pay $34,923.00 ($11,641.00, tripled) to me for the money stolen from me by Jeffco-CSE, as calculated in Exhibit MN-650;

     j.     Pay 3% of Jeffco-CSE's total funding in 2014 from all sources – including it's funding for the Responsible Fatherhood Program, Title IV-D administration and all other programs administered by Jeffco-CSE – to the Doe Trust by December 31, 2014, and then each year on the 1st of January, until Jefferson County has paid all damages demanded in my family's federal MCC, as summarized in Exhibit MN-651;

     k.    Pay $50,000.00 to the Citizens of Le Sueur County Minnesota;

     l.     In the event that Carol fails to settle this action, arrange and pay for suitable accommodations for my family (1 adult + 5 children) in Evergreen Colorado, our living expenses, and my travel back and forth at least every other week, during this action; and

     m.   Arrange and pay for housing, living expenses and mental health services for Carol until she is fully treated for her mental illnesses and released by a qualified psychiatrist.

154.    The defendants who fulfill their respective terms of settlement by the deadline will be dismissed from this action, and I will forgive and forget their crimes.

155.    No extensions of time will be granted because the non-monetary terms of settlement should have been done in 2006 when first requested, and the monetary terms of settlement are very low as compared to precedence in other extremely egregious cases and when considering the record-setting awards I will request if this case goes to trial; see PRAYER FOR RELIEF.

DEMANDS FOR PRELIMINARY RELIEF

WHEREFORE, because none of this should have happened in the first place and there is absolutely no excuse for the defendants' actions, in the event that either Jane or Jeffco-CSE / Jefferson County Colorado fails to fulfill all of their respective terms of settlement as specified above (hereinafter the “failing defendants”), I hereby make demand for preliminary relief by the court and for a preliminary jury trial to award plaintiffs preliminary damages, as follows:

     i.      A preliminary order by the court to the failing defendants to fulfill their respective non-monetary terms of settlement within 20-days;

     ii.     A preliminary order by the court to the failing defendants to pay me $7,000.00 per month during this action starting on January 1, 2015;

     iii.    A preliminary order by the court to the failing defendants to pay all filing fees, service of process fees, court costs, jury costs, and other expenses of this action;

     iv.    A preliminary order by the court to the failing defendants to pay all filing fees, service of process fees, court costs, jury costs, and other expenses of every subsequent action filed in Le Sueur County to fully rectify all claims brought about by Jane and Jeffco-CSE in this jurisdiction;

     v.     A preliminary order by the court to the failing defendants to prepay monthly the estimated costs of suitable accommodations for my five children and myself in Jefferson County Colorado and in Le Sueur County Minnesota, our living expenses, our travel back and forth for court proceedings, and my travel back and forth at least every other week, during this action;

     vi.    A preliminary order by the court to the failing defendants to pay plaintiffs' attorney's fees during this action and all subsequent actions;

     vii.   A preliminary order by the court to the failing defendants to pay a forensic accountant in Minnesota to determine the actual damages suffered by the citizens of Le Sueur County;

     viii.  A preliminary order by the court setting an immediate hearing on the replevin matter in the eighth cause of action herein;

     ix.     Such other and further relief the court deems reasonable and appropriate under the circumstances;

     x.      A preliminary verdict by a jury of joint and several liability against the failing defendants for my lost income at the rate of $7,000.00 per month plus interest, for my actual expenses, and for the actual money stolen from my children and me plus interest;

     xi.     A preliminary award by the jury against the failing defendants in the amount of $965,487.00 ($880,601.00 + 62,996.00 + 10,249.00 + 11,641.00; see Affidavits in Exhibit MN-650) for my lost income at the rate of $7,000.00 per month plus interest, for my actual expenses, and for the actual money stolen from my children and me plus interest; and

     xii.    Such other and further relief the jury deems reasonable and appropriate under the circumstances.

SECOND CAUSE OF ACTION: FRAUD UPON THE MINNESOTA COURTS

156.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

157.    This cause of action seeks compensatory and punitive damages for the defendants' frauds upon the Minnesota courts since May 2007.

158.    FRAUD #1, by Jeffco-CSE: In November 2007, Jeffco-CSE transmitted a known false arrears balance to LeSueur-CSE for registration with the intent to influence the first registration.

     ELEMENTS of Fraud #1:

     a.    Jeffco-CSE's false arrears balance statement was made in writing, under oath, in a sworn “REGISTRATION STATEMENT” (and was transmitted by mail, fax or online).

     b.    The false statement was made regarding a material fact: the arrears balance.

     c.    Jeffco-CSE knew at the time that:

           1.    My child support obligations are paid-in-full;

           2.    The Colorado child support order is null and void and unenforceable for several reasons;

           3.    The arrears balance was, and still is, zero; and

           4.    They would be committing further serious crimes against my family in Minnesota.

     d.    Jeffco-CSE intended to influence the judicial registration process in Minnesota.

     e.    Although the first registration was vacated, the Minnesota judicial officials continued to enforce, and otherwise act in reliance upon, Jeffco-CSE's false arrears balance statement until the second registration was filed in May 2008.

     f.     My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jeffco-CSE's first false REGISTRATION STATEMENT.

159.    FRAUD #2, by Jeffco-CSE: On April 30, 2008, Jeffco-CSE transmitted another known false arrears balance to LeSueur-CSE for registration; see Exhibit MN-601.

     ELEMENTS of Fraud #2:

     a.    Jeffco-CSE's false arrears balance statement was made in writing, under oath, in a sworn “REGISTRATION STATEMENT” (and was transmitted by mail, fax or online).

     b.    The false statement was made regarding a material fact: the arrears balance.

     c.    Jeffco-CSE knew at the time that:

            1.    My child support obligations are paid-in-full;

            2.    The Colorado child support order is null and void and unenforceable for several reasons;

            3.    The arrears balance was, and still is, zero; and

            4.    They would be committing further serious crimes against my family in Minnesota.

     d.    Jeffco-CSE intended to influence the judicial registration process in Minnesota.

     e.    On September 29, 2008, the Minnesota judge acted in reliance upon Jeffco-CSE's false arrears balance statements, see Exhibit MN-603, and registered it for enforcement.

     f.     My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jeffco-CSE's second false REGISTRATION STATEMENT.

160.    FRAUD #3, by Jeffco-CSE: Also on April 30, 2008, along with the REGISTRATION STATEMENT, Jeffco-CSE transmitted 87 pages of prejudicial and irrelevant documents, see Exhibit MN-602, with the intent to influence not only the second registration, but also future law enforcement and child support enforcement actions against me in Le Sueur County.

     ELEMENTS of Fraud #3:

     a.    Jeffco-CSE's prejudicial and irrelevant documents were sent to defraud the Minnesota courts and officials into believing that Jane is a victim of domestic abuse by me so that they could continue their oppression of me in Minnesota (and were transmitted by mail, fax or online).

     b.    The fraud upon the Minnesota court regarded material facts being considered.

     c.    Jeffco-CSE knew at the time that:

            1.    Jane had repeatedly orchestrated “domestic violence scams” in Colorado to influence the judicial proceedings in her divorce;

            2.    Although I was found “not guilty” by a Colorado jury, Jane's “911 Scam” during her divorce had a profound effect on “permanent orders,” especially the child support order;

            3.    Jane is an inveterate liar; and

            4.    Whereas I am a passive person, Jane is a violent and evil person as evidenced by her “Phone Script,” in which Jane admits to secretly killing our first child.

     d.    Jeffco-CSE intended to influence not only the second judicial registration process in Minnesota, but also future law enforcement and child support enforcement actions in Le Sueur County.

     e.    Many Le Sueur County, Nicollet County, and Minnesota officials have acted in reliance upon Jeffco-CSE's prejudicial and irrelevant documents and notions that I am a violent man.

     f.     My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jeffco-CSE's false pretenses, and will continue to suffer until the prejudicial and irrelevant documents are stricken from the record in Minnesota.

161.    FRAUDS #4-5, by Jeffco-CSE: On September 22, 2008, Jeffco-CSE's attorney Casie Stokes, who had previously moved the Colorado court to modify my child support from $1717.92 to $521.00, defrauded the Colorado court to withdraw my motion to modify the child support; see Exhibit MN-604. [Although this crime took place in Colorado, because it caused injury to me and all other citizens of Le Sueur County, the crime can be prosecuted, both civilly and criminally, in Minnesota under Minn. Stat. § 543.19, subd. 1, (3) and (4). In fact, this crime caused the most damage in Minnesota. Had the child support order been modified to $521.00 per month, I would have moved back to Colorado in 2008 and found a way to pay it, and no further damages would have occurred.]

     ELEMENTS of Frauds #4-5:

     a.    Stokes committed this fraud upon both the Colorado and Minnesota courts.

     b.    Stokes' false statements in Colorado modification proceeding were made under oath in a sworn court document, which constitutes perjury in both Colorado and Minnesota.

     c.    Jeffco-CSE transmitted the results of Stokes' actions to the Minnesota court with the intent to influence the second registration case, which constitutes mail fraud under federal law.

     d.    Stokes' false statements were made regarding material facts in the Colorado and Minnesota cases.

     e.    Stokes and Jeffco-CSE knew at the time that:

            1.    The Colorado child support order should have been modified to zero;

            2.    I was indigent, involuntarily unemployed, without a driver's license, without my tools and work equipment, and could not pay $1,717.92 per month for child support;

            3.    I missed my children terribly;

            4.    I would have found a way to pay $521.00 per month so I could return to Colorado; and

            5.    The case in Minnesota would have been dismissed.

     f.     Stokes and Jeffco-CSE intended to influence the judicial proceedings in both states so that they and Jane could continue stalking me, and so that they could keep me, and my evidence of their crime spree against my family, out of Colorado.

     g.    Many local, state and federal officials in both states and in Washington DC have acted in reliance upon this fraud upon the courts.

     h.    My five children and I and the citizens of Le Sueur County have suffered enormous damages as a direct and proximate result of this fraud upon the courts, and will continue to suffer until Jeffco-CSE finds and declares the fact that my child support obligations are paid-in-full and takes whatever action necessary to correct the judicial and administrative records in both states.

161.    FRAUD #6, by Jane: In answer to my discovery requests during the second registration, Jane committed multiple perjuries with the intent to influence the judicial proceeding; see Exhibit MN-604. A few of the most notable are as follows:

     ELEMENTS of Fraud #6:

     a.    Jane denied my request for her admission that she stated under oath in her divorce that I was not semi-retired.

     b.    Jane denied my request for her admission that she stated under oath in her divorce that I was “voluntarily unemployed.”

     c.    Jane denied my request for her admission that I was able to pay all our bills on my semi-retirement income.

     d.    Jane denied my request for her admission that she stated under oath in her divorce that her monthly expenses were $8,800.56.

     e.    Jane denied my request for her admission that she stated under oath in her divorce that I could easily earn over $100,000.00 per year like I did in 2001.

     f.     Jane denied my request for her admission that the divorce judge relied on her false testimony and based the child support order on an imputed income for me of $84,000.00 per year.

     g.    Jane denied my request for her admission that throughout the divorce and post-divorce (and to this day), she continued to hold many of my most important tools and work equipment, all of my office equipment, all of my bidding and accounting software, and my work vehicles, in contempt of a court order.

     h.    Jane's false statements in regards to my work status, my semi-retirement income, her expenses, my earning ability, the Colorado divorce judge's reliance on her false statements in establishing the child support order, and her continued hold on my tools and work equipment, were made in writing, under oath, in a sworn court document in Minnesota, all of which constitute perjuries.

     i.     The false statements were made regarding material facts in the registration proceeding.

     j.     Jane knew at the time she made these false statements that:

             1.    I was semi-retired;

             2.    I was comfortably paying all the bills on my semi-retirement income because I had paid-off our home, our autos and our credit cards, and we heated our home with wood;

             3.    Because all debts were paid-off, her expenses were around $1,000.00 per month.

             4.    My semi-retirement income was about $20,000.00 per year; and

             5.    Her hold on my tools and business assets directly affected my ability to work.

     k.    Jane intended to influence not only the second registration in Minnesota, but also the review, adjustment and modification processes taking place in Colorado at the time.

     l.     The Minnesota judge acted in reliance upon Jane's false statements in granting the registration of the Colorado child support order and arrears balance for enforcement in Minnesota.

     m.   Our five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jane's false answers to my discovery requests during the second registration.

163.    FRAUD #7, by Jeffco-CSE: In July 2009, LeSueur-CSE filed a criminal complaint against me in Minnesota for nonsupport of my children, based on false arrears balance figures provided by Jeffco-CSE, starting Le Sueur County case 40-CR-09-786.

     ELEMENTS of Fraud #7:

     a.    Jeffco-CSE's false arrears balance statement at the time was made in writing, under oath, in a sworn court document (and was transmitted by mail, fax or online).

     b.    The false statement was made regarding a material fact: the arrears balance.

     c.    Jeffco-CSE knew at the time that the arrears balance statement was false.

     d.    Jeffco-CSE intended to influence the criminal justice proceedings in Minnesota.

     e.    The Minnesota officers of the court, and the appellate courts, acted in reliance upon the falsified criminal complaint throughout the case. (In addition, at least two newspapers have printed defamatory articles based on Jeffco-CSE's false arrears balance statement at the time.)

     f.     My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of the Le Sueur County criminal complaint falsified by Jeffco-CSE.

164.    FRAUD #8, by Jeffco-CSE: In February 2011, Jeffco-CSE conspired with LeSueur-CSE and the Minnesota prosecutor to enter the false – and still uncorrected – arrears balance figures as evidence in the jury trial, and to falsely testify about the arrears balance and my payments toward child support, with the intent to influence the jury; see Exhibit MN-612.

     ELEMENTS of Fraud #8:

     a.    Jeffco-CSE's false arrears balance numbers at the time were entered, under oath, on the record in the jury trial by documentary evidence and by testimony (which constitutes another count of perjury in Minnesota, another count of mail fraud under federal law, and a Class B federal felony for further processing a known fictitious obligation).

     b.    The fraud upon the Minnesota jury was made regarding material facts.

     c.    Jeffco-CSE knew at the time that:

            1.    My child support obligations are paid-in-full;

            2.    The arrears balance is zero;

            3.    I was being wrongly prosecuted for felony nonsupport of my children; and

            4.    All involved were committing several very serious state and federal crimes, including a federal felony that can result in a 25-year prison sentence.

     d.    Jeffco-CSE intended to influence the jury trial in Minnesota.

     e.    The jury acted in reliance upon the false arrears balance and found me guilty.

     f.     My five children and I and the citizens of Le Sueur County have suffered enormous damages as a direct and proximate result of the guilty verdict, and will continue to suffer until it is overturned.

165.    FRAUD #9, by Jane: While I was in jail in 2012, Jane conspired with the Minnesota prosecutor to defraud the record during the sentencing hearing to obtain a “No Contact Order” preventing me from contacting our five children, including our adult children, as a condition of my probation; see Exhibit MN-613.

     ELEMENTS of Fraud #9:

     a.    Jane's false statements regarding harassment were entered, under oath (attorney's are under oath 24 hours per day, 7 day per week), on the record at the sentencing hearing.

     b.    The fraud upon the court was made regarding a material fact.

     c.    Jane and the prosecutor knew at the time that:

            1.    I have never harassed Jane in my life;

            2.    There is no evidence on the record in Minnesota of my harassment of Jane;

            3.    Jane's harassment of me has been relentless for over a decade;

            4.    There is evidence on the record in Minnesota to prove Jane's felony harassment of me, which constitutes a pattern of stalking conduct; and

            5.    There is no legal authority or precedence for a no contact order preventing contact of one's children in child support cases.

     d.    Jane intended to influence the Minnesota judge's sentence and obtain the No Contact Order to justify her felony denials of my contact and visitation with our children.

     e.    The Minnesota judge acted in reliance upon Jane's false statements about harassment, as relayed by the prosecutor, and ordered me to have no contact with Jane or “her” children for 5 years.

     f.     My five children and I suffered enormous damages as a direct and proximate result of the No Contact Order and its enforcement for over 2-½ years.

166.    FRAUD #10, by Jeffco-CSE: While I was in jail in 2012, Jeffco-CSE conspired with LeSueur-CSE and the Minnesota prosecutor to defraud the record during the sentencing hearing to obtain an order requiring me to pay further child support, as a condition of my probation; see Exhibit MN-613.

     ELEMENTS of Fraud #10:

     a.    Jeffco-CSE's false statements regarding child support were entered, under oath (attorney's are under oath 24 hours per day, 7 day per week), on the record at the sentencing hearing.

     b.    The fraud upon the court was made regarding a material fact.

     c.    Jeffco-CSE and the prosecutor knew at the time that:

            1.    My child support obligations are paid-in-full; and

            2.    The Colorado child support order was rendered null and void and unenforceable, ab initio.

     d.    Jeffco-CSE intended to influence the Minnesota judge's sentence and obtain a further order in Minnesota requiring me to pay child support, so that they and LeSueur-CSE could further ripoff the American taxpayers through the Child Support Enforcement Program.

     e.    The Minnesota judge acted in reliance upon Jeffco-CSE's false statements about the “existing” child support order, as relayed by the prosecutor, and ordered me to pay further child support.

     f.     My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of the new child support order and its enforcement for over 2-½ years.

167.    FRAUD #11, by Jane: On July 1, 2012, with the intent to have me falsely arrested and falsely imprisoned in Minnesota for violation of the No Contact Order, Jane made a false report to the Jefferson County Sheriff's Department in Colorado claiming that I had left messages on, and had sent texts to, my daughter's cellphone, see Exhibit MN-614.

     ELEMENTS of Fraud #11:

     a.    Jane's false statements in the report regarding my calls and texts at the time to our kids were faxed to Minnesota the next day, attached to a Violation Report, and entered, under oath, on the record in the Minnesota case.

     b.    The fraud upon the court was made regarding a material fact.

     c.    Jane knew at the time that:

            1.    She lied to law enforcement about my messages being left on my daughter's phone;

            2.    The No Contact Order was illegal and therefore null and void and unenforceable, ab initio;

            3.    She had repeatedly violated Colorado law requiring “frequent and continuing contact” between our children and me;

            4.    She had repeatedly violated a court order requiring her to update me on our children's contact information;

            5.    She had repeatedly violated a court order requiring her to encourage our children to stay in touch with me; and

            6.    She would be committing further state and federal felonies.

     d.    Jane intended to aid in another false arrest and imprisonment in Minnesota.

     e.    Jane also intended to maximize my jail time.

     f.     The Minnesota appellate courts (in Appeal A12-794) acted in reliance upon Jane's false police report and ordered me to turn myself in on the resulting charge.

     g.    My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jane's false police report and its enforcement, including but not limited to my 9th false imprisonment for another 4 months.

168.    FRAUD #12, by Jeffco-CSE: To maximize my 9th false imprisonment and with the intent to influence the probation revocation proceeding, Jeffco-CSE continued to transmit falsified arrears balances in the case; see Exhibit MN-614.

     ELEMENTS of Fraud #12:

     a.    Jeffco-CSE's false statement regarding the arrears balance at the time was entered in a Violation Report, under oath, and submitted on the record during the probation revocation proceeding.

     b.    The fraud upon the court was made regarding a material fact.

     c.    Jeffco-CSE knew at the time that:

            1.    My child support obligations are paid-in-full; and

            2.    The arrears balance is zero.

     d.    Jeffco-CSE intended to maximize my 9th false imprisonment.

     e.    The Minnesota judge acted in reliance upon Jeffco-CSE's false arrears balance and kept me in jail for 4 months until I fully executed my jail time under the void sentence.

     f.     My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jeffco-CSE's continued fraud upon the courts regarding the arrears balance.

169.    FRAUD #13, by Jeffco-CSE: To maximize my 9th false imprisonment and with the intent to influence the probation revocation proceeding, Jeffco-CSE continued to ignore my discovery requests, see Exhibit MN-616.

     ELEMENTS of Fraud #13:

     a.    Jeffco-CSE's concealment of exculpatory facts and evidence proving that my child support obligations are paid-in-full and that there are no arrears is another fraud upon the court.

     b.    The fraud upon the court was made regarding a material fact.

     c.    Jeffco-CSE knew at the time that:

            1.    Because my child support obligations are paid-in-full, case 09-786 should not even exist;

            2.    The jury verdict was automatically rendered void by operation of law;

            3.    The sentence, in its entirety, was automatically rendered void by operation of law; and

            4.    The probation revocation proceeding was illegal.

     d.    By ignoring my discovery requests, Jeffco-CSE intended to influence the probation revocation proceeding and obtain another mark against me on my record.

     e.    Because of Jeffco-CSE's concealment of exculpatory facts and evidence, the Minnesota judge was unable to adjudicate the probation revocation proceeding and therefore vacated the sentence.

     f.     However, because Jeffco-CSE has never come forward with the truth, the concealment was another count of fraud upon the Minnesota courts, and Jeffco-CSE's false facts remained on the record, which were relied upon by another judge to re-sentence me.

     g.    My five children and I and the citizens of Le Sueur County suffered damages as a direct and proximate result of Jeffco-CSE's concealment of the truth in the probation revocation hearing.

170.    FRAUDS #14-18, by Jeffco-CSE: To cover up their crimes in both states, to keep the oppression going in Minnesota, and to keep me, and my evidence of their crimes, out of Colorado, Jeffco-CSE refused five times to do a proper administrative review and adjustment of my child support account, see Exhibit MN-617.

     ELEMENTS of Frauds #14-18:

     a.    Jeffco-CSE's refusals to administratively find and declare that my child support obligations are paid-in-full and that there are no arrears are frauds upon both the Colorado and Minnesota courts.

     b.    The frauds upon the courts were made regarding material facts being considered in the judicial proceedings in both states.

     c.    Jeffco-CSE has known all along that:

            1.    Neither Jane nor the government has ever refuted my facts or rebutted my evidence proving that my child support obligations are paid-in-full and the arrears balance is zero;

            2.    Their office is required by law to verify, find and declare the facts once established;

            3.    Permanent Orders in Jane's divorce, including the child support order, were automatically rendered void, for several different reasons, by operation of law; and

            4.    All of the Minnesota judicial decisions based on the Colorado orders, including the registration order, the jury verdict, and the sentencing order, were automatically rendered void, for several different reasons, by operation of law.

     d.    By refusing to do proper administrative reviews and their other duties, Jeffco-CSE intended to influence the Minnesota judicial proceedings for the purposes of covering up their crimes, keeping the oppression going in Minnesota, and keeping me, and my evidence, out of Colorado.

     e.    The Minnesota district courts and appellate courts, the jury, and LeSueur-CSE relied upon the results of Jeffco-CSE's reviews, under the full faith and credit laws, to render their decisions.

     f.     My five children and I and the citizens of Le Sueur County suffered enormous damages as a direct and proximate result of Jeffco-CSE's refusals to do proper administrative reviews over the past 7 years.

WHEREFORE, plaintiffs pray for jury awards of compensatory and punitive damages against the failing defendants - see PRAYER FOR RELIEF; together with such other and further relief the jury deems reasonable and just under the circumstances.

THIRD CAUSE OF ACTION: OTHER CRIMINAL MISCONDUCT

171.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

172.    This cause of action seeks compensatory and punitive damages for the defendants' other criminal misconduct and conspiracies in Minnesota; see Exhibit MN-620.

173.    As alleged in Exhibit MN-620 and as mostly proven in Exhibits MN-600 to MN-617:

     a.    Seven of Jeffco-CSE's frauds upon the Minnesota courts rise to the level of perjury under state and federal law; see Frauds # 1, 2, 5, 7, 8, 10, and 12 above.

     b.    Three of Jane's frauds upon the Minnesota courts rise to the level of perjury under state and federal law; see Frauds # 6, 9, and 11 above.

     c.    In addition to their frauds upon the courts and perjuries, Jeffco-CSE committed at least 25 other crimes in Le Sueur County.

     d.    In addition to her frauds upon the courts and perjuries, Jane committed at least 18 other crimes in Le Sueur County.

     e.    Jeffco-CSE repeatedly conspired to cause my false arrests and prosecution in Le Sueur County.

     f.     Jane repeatedly conspired to cause my false arrests and prosecution in Le Sueur County.

     g.    In addition, Jeffco-CSE conspired to commit at least 22 other crimes in Le Sueur County.

     h.    In addition, Jane conspired to commit at least 18 other crimes in Le Sueur County.

174.    On multiple occasions, Jane and Jeffco-CSE conspired together and with Minnesota officials to commit their respective frauds and other crimes and torts in Minnesota.

175.    In each instance, Jane and/or Jeffco-CSE performed some overt act to advance the conspiracy, which, in addition to the actual crimes and torts, makes them further criminally culpable and civilly liable to the plaintiffs.

176.    As a direct and proximate result of Jane's and Jeffco-CSE's criminal misconduct and conspiracies in Minnesota, my five children and I suffered enormous damages, and the citizens of Le Sueur County suffered substantial damages.

WHEREFORE, plaintiffs pray for jury awards of compensatory and punitive damages against the failing defendants - see PRAYER FOR RELIEF; together with such other and further relief the jury deems reasonable and just under the circumstances.

FOURTH CAUSE OF ACTION: INVASION OF PRIVACY

177.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

178.    This cause of action seeks compensatory and punitive damages for Jeffco-CSE's invasion of my family's privacy in the Minnesota registration case; see Exhibit MN-602.

179.    Along with their fraudulent REGISTRATION STATEMENT in April 2008, Jeffco-CSE transmitted 87 additional pages of private and irrelevant documents to LeSueur-CSE, who filed them on the public record, where they remain to this day; see FRAUD #3 in second cause of action and NEGLIGENCE #30 in fifth cause of action.

180.    Among the 87-pages are Jane's “Phone Script” evidencing her secret killing of our first child and Jane's VICTIM IMPACT STATEMENT evidencing one of her “domestic violence scams,” which is still being used in both states to manipulate the outcome of judicial proceedings and to turn law enforcement officials against me.

181.    Jane's outrageously fraudulent VICTIM IMPACT STATEMENT from her “911 Scam” was sent intending to con the Minnesota authorities about domestic violence like Jefferson County officials did in Colorado to help “fix” the divorce against me, with the intent to lower my parenting time and thus jack up the child support order. [I have since found out that leaking private information to paint ‘breadwinners’ as bad parents in family law matters is just one of many case fixing tactics employed by corrupt family law 'professionals' all across the U.S.]

182.    This fraud upon the Minnesota court prevented me from obtaining a harassment restraining order in 2008, and set in motion a series of other frauds including the false statements by the prosecutor in case 09-786 to obtain a No Contact Order in February 2012 preventing me from contacting my 5 children, including my 2 adult children at the time.

183.    Jeffco-CSE publicized these matters, and other highly offensive matters, to LeSueur-CSE, several officers of the Minnesota courts, and Le Sueur County law enforcement officials, with the intent to prejudice the officials and the Minnesota judicial proceedings against me.

184.    Jeffco-CSE is restricted by the Uniform Interstate Family Support Act (UIFSA) to transmit only the child support order and relevant documents relating to child support.

185.    Jeffco-CSE is also held to strict privacy rules under Colorado and Minnesota law.

186.    Jeffco-CSE knew that the Phone Script and VICTIM IMPACT STATEMENT and most of the other 87-pages are of no legitimate concern to the Minnesota courts or the public.

187.    Jeffco-CSE's invasion of our privacy jump-started their plan to stalk me in Minnesota.

188.    As a direct and proximate result of Jeffco-CSE's invasion of my family's right to privacy, my five children and I suffered enormous damages, and the citizens of Le Sueur County suffered substantial damages.

WHEREFORE, plaintiffs pray for jury awards of compensatory and punitive damages against Jeffco-CSE; see PRAYER FOR RELIEF; together with such other and further relief the jury deems reasonable and just under the circumstances.

FIFTH CAUSE OF ACTION: NEGLIGENCE and NEGLIGENCE PER SE

189.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

190.    This cause of action seeks compensatory and punitive damages for the defendants'

negligent acts and omissions that caused injury in Minnesota.

191.    NEGLIGENCE #1-5, by Jeffco-CSE: Pursuant to the Uniform Interstate Family Support Act (UIFSA) and other regulations, whenever requested by either parent, Jeffco-CSE is required to review child support orders and arrears balances, to verify actual income and other facts, to adjust child support orders (in Colorado, to move the court to modify), and/or to adjust the arrears balance if appropriate. Jeffco-CSE has known since they opened the Title IV-D case in 2006 that my child support obligations are paid-in-full, but repeatedly refused following their five reviews (see Exhibit MN-508, pages 20-22) to administratively find that fact so that the child support order could have been modified to zero by the Colorado court.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed me, as the noncustodial parent and the requester of their services, a legal duty to exercise reasonable care in the performance of their duties in each of the five review and adjustment processes, including but not limited to finding and declaring in the Interstate Title IV-D case that my child support obligations are paid-in-full and that the arrears balance is zero. In addition, Jeffco-CSE owed each of my five children a heightened duty of care during their work for our family. In addition, Jeffco-CSE owed the citizens of Le Sueur County a duty of care during their work in the Interstate Title IV-D case.

     b.    In each of the five reviews, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's refusals to do proper reviews, my five children and I and the citizens of Le Sueur County suffered substantial damages.

192.    NEGLIGENCE #6-10, by Jeffco-CSE: State and federal regulations also required Jeffco-CSE, following each review, to move the court to modify the child support order because circumstances showed that the order would be decreased by 10% or more (and because the order is inconsistent with the child support guidelines, and because the order is clearly unjust, and because the order is simply unfair, and because of my inability to pay, and because of other reasons). But, following each of their five reviews, Jeffco-CSE failed to bring about the required modification of the child support order to zero; see Exhibit MN-604 and MN-617.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to exercise reasonable care in the performance of their duties in moving the Colorado court to modify the child support order to zero following each of their five reviews.

     b.    In each of the five modifications, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failures to modify the child support order, my five children and I and the citizens of Le Sueur County suffered substantial damages.

193.    NEGLIGENCE #11-12, by Jeffco-CSE: Because the “Fatherhood Initiative Program” and “Responsible Fatherhood Program” are administered by Jeffco-CSE, my five children and I were entitled to Jeffco-CSE's help in restoring contact and visitation, in reporting Jane's felony denials of visitation and contact and other crimes to the courts and law enforcement, in reporting Jane's relentless parental alienation and other child abuses to the courts and Child Protective Services, and in recommending a reversal of custody to the courts. But instead of doing their jobs or watching out for the welfare of my children, Jeffco-CSE denied me services in both programs; see Exhibit MN-609.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me a legal duty to exercise reasonable care in the performance of their duties in the Fatherhood Initiative Program and the Responsible Fatherhood Program.

     b.    In both programs, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failures to do its duties in the fatherhood programs, my five children and I have suffered enormous damages, including but not limited to being separated from each other for over 7-½ years and cutoff from all communications with each other for nearly 6-½ years, and we will continue to suffer until our family is reunited.

194.    NEGLIGENCE #13-17, by Jeffco-CSE: On at least five occasions, Jeffco-CSE ignored my requests for reinstatement of my suspended driver's license, despite knowing all along of their illegal action to suspend it without due process in December 2006, see Exhibit MN-508, pages 7-8, and despite knowing that the suspension was harming my family.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to exercise reasonable care in the performance of their duties in the Child Support Enforcement Program – including using discretion under the circumstances in regards to my driver's license – to keep me working during the dispute and to protect my ability to work and pay child support.

     b.    On at least five occasions, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's repeated refusals to use discretion regarding my driver's license, I have been unable to work, my five children and I have suffered enormous damages, and the citizens of Le Sueur County suffered damages too, from my lost income.

195.    NEGLIGENCE #18, by Jeffco-CSE: Despite knowing for years that Carol was in contempt of 2 court orders requiring her to return my contractor tools and work equipment, work vehicles, bidding and estimating software, office equipment, and other business items, and despite knowing that my attorneys and I had written to Carol at least 26 times during and after her divorce requesting my work things, and despite knowing since December 2006 that my driver's license was suspended, and despite my repeated statements of my willingness to work if I could and pay child support if I could even if the facts showed that my financial obligations to raise my children to adulthood are already paid-in-full, and despite their responsibility under UIFSA to adjust child support orders pursuant to a party's ability to pay, Jeffco-CSE officials knowingly looked the other way for 8 years, repeatedly refused to find the fact that I had no income, repeatedly imputed an impossible income for me in the child support worksheets, and never once processed the fact that I had no ability to pay child support even if I wanted to.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to find the fact that I had no income and was unable to pay child support, and either suspend the Title IV-D case or stay the enforcement of the child support order in Colorado and Minnesota.

     b.    Once again, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failures to follow the law in this regard, my five children and I and the citizens of Le Sueur County suffered substantial damages.

196.    NEGLIGENCE #19-20, by Jeffco-CSE: Jeffco-CSE failed to answer my two Formal Objections in 2009 to the continued enforcement of the void child support order and false arrears balance, and, as has been typical for over 8 years, failed to even respond; see Exhibit MN-608.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to at least abate enforcement of the child support order and arrears balance in Colorado and in Minnesota until the matters raised in my objections were addressed.

     b.    Jeffco-CSE failed to address my Formal Objections and therefore breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failures to address my Formal Objections, my five children and I and the citizens of Le Sueur County suffered substantial damages.

197.    NEGLIGENCE #21-26, by Jeffco-CSE: On at least three separate occasions, two Jeffco-CSE officials failed to provide documents including exculpatory evidence, arrange for their testimony on the record, or even answer my Subpoena Duces Tecum and other discovery requests served upon them in preparation for the jury trial in February 2011; see Exhibit MN-611.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to cooperate and participate in the judicial processes they caused in Minnesota.

     b.    By ignoring my subpoenas, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failure to address my Subpoenas, my five children and I and the citizens of Le Sueur County suffered substantial damages.

198.    NEGLIGENCE #27, by Jeffco-CSE: While I was in jail during my 9th false imprison-ment in 2014, a Jeffco-CSE official failed to provide documents including exculpatory evidence, or even answer my discovery requests in preparation for the final hearing; see Exhibit MN-616.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to cooperate and participate in the judicial processes they caused in Minnesota.

     b.    By ignoring my discovery request, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failure to address my discovery requests, I was held in jail to fully execute the sentence, and my five children and I suffered substantial damages.

199.    NEGLIGENCE #28, by Jeffco-CSE: In spite of a federal mandate in UIFSA, Jeffco-CSE failed to suspend my child support account while I was jail or even answer my request.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me a legal duty to suspend my child support account while I was incarcerated.

     b.    By failing to suspend my child support account as required, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failure to suspend my child support account while I was in jail, my five children and I suffered substantial damages.

200.    NEGLIGENCE #29, by Jeffco-CSE: Despite knowing that the No Contact Order in Minnesota violated Colorado law and Minnesota law, violated 2 Colorado court orders, violated my children's rights, violated my rights, was unconscionable and cruel, and was causing further harm to my five children and me, Jeffco-CSE failed to notify the Minnesota authorities of the harm being done by enforcement of the No Contact Order.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owed my children and me and the citizens of Le Sueur County a legal duty to notify the Minnesota authorities about the illegal No Contact Order and act to have it set aside.

     b.    In regards to the No Contact Order, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failure to take action to prevent the harm being done by the No Contact Order, my five children and I suffered enormously for over 2-½ years, and the citizens of Le Sueur County suffered damages too.

201.    NEGLIGENCE #30, by Jeffco-CSE: In 2008, Jeffco-CSE transmitted 87 pages of prejudicial and irrelevant documents to LeSueur-CSE including Carol's “Phone Script” proving her murder of our first child and other sensitive documents, which remain on the public record to this day; see Exhibit MN-602.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Under UIFSA and other state and federal laws, Jeffco-CSE owes my children and me (and Carol) a legal duty to exercise reasonable care for our family's privacy.

     b.    By failing to protect our privacy, Jeffco-CSE breached its duties.

     c.    As a direct and proximate result of Jeffco-CSE's failure to protect our privacy, my five children and I suffered substantial damages, and will continue to suffer until the documents are stricken from the record.

202.    NEGLIGENCE #31, by Jeffco-CSE: For over 8 years now, Jeffco-CSE has refused to correct the arrears balance; not even their alteration of my account in the amount of $6,301.50, 22-days after the child support order was issued, before my first payment was even due. At the jury trial in 2011, through LeSueur-CSE, Jeffco-CSE admitted to the 'error' and promised – to me and to the jury apparently – that the arrears balance would be corrected; see Exhibit MN-612. But, after I was convicted of nonsupport of my children by the hoodwinked jury, Jeffco-CSE just blew it off again, and the arrears balance remains uncorrected to this day.

     ELEMENTS of Jeffco-CSE's Negligence:

     a.    Jeffco-CSE owes my children and me and the citizens of Le Sueur County a legal duty to provide honest services in the Interstate Title IV-D Child Support Enforcement case.

     b.    Jeffco-CSE has never been honest about my case, and therefore breached its duties to be honest.

     c.    As a direct and proximate result of Jeffco-CSE's failure to be honest with me or Minnesota officials, my children and I and the citizens of Le Sueur County suffered substantial damages.

203.    NEGLIGENCE #32, by Jane: In contempt of 2 court orders and despite at least 26 written requests during and after her divorce for the return of my contractor tools and work equipment, work vehicles, bidding and estimating software, office equipment, and other business items, Jane continued to hold my things hostage; see Exhibit MN-630. Following my move to Minnesota, I filed over 50 motions in Colorado to obtain my things, but Jane still felt the need to hold my things. Jane has not returned a single item of mine to this day. And, just like Jeffco-CSE, Jane expects me to pay child support with no income.

     ELEMENTS of Jane's Negligence:

     a.    Jane owes each of our children and me, and now also the citizens of Le Sueur County, a legal duty to exercise at least reasonable care for my property rights, especially in a situation such as this where my property could have been used to earn income and pay child support.

     b.    By holding my things, especially my work things, Jane breached her duties.

     c.    As a direct and proximate result of Jane's hold on my work things, I have been unable to work and our children and I and the citizens of Le Sueur County have suffered substantial damages.

204.    NEGLIGENCE #33-37, by Jane: In contempt of the divorce orders and in violation of Colorado and Minnesota law protecting my parental rights, Jane has denied all my attempts to see our children since I moved to Minnesota in May 2007, with the constant threat to contact law enforcement to cause another false arrest if I ever come to Colorado; see Exhibit MN-600.

     ELEMENTS of Jane's Negligence:

     a.    Jane owes each of our children and me a legal duty to exercise at least reasonable care in the performance of her parental responsibilities.

     b.    Jane breached her duties repeatedly to deny all of my parenting time over the past 7-½ years since I moved to Minnesota.

     c.    As a direct and proximate result of Jane's extensive effort to prevent me from seeing our children, our kids and I have suffered enormous damages.

205.    NEGLIGENCE #38-42, by Jane: In contempt of a post-divorce order requiring her to encourage and facilitate my contact with our children, see Exhibit MN-610, and in violation of Colorado, Minnesota and federal law and our children's and my rights, Jane orchestrated a massive effort in our children's schools and church and sports leagues and elsewhere around our community to prevent any contact with our children since August 2008.

     ELEMENTS of Jane's Negligence:

     a.    Jane owes each of our children and me a legal duty to exercise at least reasonable care in the performance of her parental responsibilities.

     b.    Jane breached her duties repeatedly to deny my contact with each of our children over the past 6-½ years.

     c.    As a direct and proximate result of Jane's extensive effort to prevent me from talking to our children, our kids and I have suffered enormous damages.

206.    NEGLIGENCE #43, by Jane: The stipulation that I sent Jane in 2008, see Exhibit MN-605, would have ended the controversy over child support.

     ELEMENTS of Jane's Negligence:

     a.    Jane owes each of our children and me a legal duty to act in the best interests of our family, and part of that is to step forward with the truth when known, in this instance, to affirm the fact that my child support obligations to raise our five children to adulthood are already paid-in-full.

     b.    Totally consumed with hatred for me, Jane repeatedly breached her duties to our family.

     c.    As a direct and proximate result of Jane's failure to stipulate to the truth about child support, our kids and I have suffered enormous damages.

207.    NEGLIGENCE #44-45, by Jane: Jane failed to answer my two Formal Objections in 2009, see Exhibit MN-608, which would have also ended the controversy over child support.

     ELEMENTS of Jane's Negligence:

     a.    Jane owed our children and me and the citizens of Le Sueur County a legal duty to at least abate enforcement of the child support order and arrears balance in Colorado and in Minnesota until the matters raised in my objections were addressed.

     b.    Jane failed to address my Formal Objections and therefore breached her duties.

     c.    As a direct and proximate result of Jane's failures to address my Formal Objections, our children and I and the citizens of Le Sueur County suffered substantial damages.

208.    NEGLIGENCE #46-50, by Jane: On at least three separate occasions, Jane failed to provide documents including exculpatory evidence, arrange for her testimony on the record, or even answer my Subpoena Duces Tecum and other discovery requests served upon her in preparation for the jury trial in February 2011; see Exhibit MN-611.

     ELEMENTS of Jane's Negligence:

     a.    Jane owed our children and me and the citizens of Le Sueur County a legal duty to cooperate and participate in the judicial processes she caused in Minnesota.

     b.    By ignoring my subpoenas, Jane breached her duties.

     c.    As a direct and proximate result of Jane's failure to address my Subpoenas, our children and I and the citizens of Le Sueur County suffered substantial damages.

209.    NEGLIGENCE #51, by Jane: Even knowing that she was just as responsible as anyone else involved for causing my 9th false imprisonment, for causing the dismissal of my appeal from the false conviction, and for causing an additional 2-½ years of pain and suffering for the other 6 members of her family, Jane remained silent while the illegal No Contact Order was enforced against me with the full police power of the state of Minnesota.

     ELEMENTS of Jane's Negligence:

     a.    Jane owed our children and me and the citizens of Le Sueur County a legal duty to notify the Minnesota authorities that the No Contact Order was illegal and was causing harm to our family.

     b.    Because she remained silent about No Contact Order, Jane breached her duties.

     c.    As a direct and proximate result of Jane's failure to take action to prevent the harm being done by the No Contact Order, our five children and I suffered enormously for over 2-½ years, and the citizens of Le Sueur County suffered damages too.

210.    NEGLIGENCE #51-123, by Jeffco-CSE: Each of Jeffco-CSE's frauds, see second cause of action, and other crimes, see third cause of action, is an act of “negligence per se.”

     ELEMENTS of Jeffco-CSE's Negligence Per Se:

     a.    Jeffco-CSE owes each of my children and me and the citizens of Le Sueur County a legal duty to abide by the law in the exercise of their authority.

     b.    During each of their acts of criminal misconduct, Jeffco-CSE breached their duties.

     c.    As a direct and proximate result of Jeffco-CSE's negligence per se in Minnesota, each of my five children and I suffered grievously for 7-½ years, and the citizens of Le Sueur County suffered substantial damages too.

211.    NEGLIGENCE #124-169, by Jane: Each of Jane's frauds, see second cause of action, and other crimes, see third cause of action, is an act of “negligence per se.”

     ELEMENTS of Jane's Negligence Per Se:

     a.    Jane owes each of our children and me and the citizens of Le Sueur County a legal duty to abide by the law in the exercise of her rights.

     b.    During each of her acts of criminal misconduct, Jane breached her duties.

     c.    As a direct and proximate result of Jane's negligence per se in Minnesota, each of our five children and I suffered grievously for 7-½ years, and the citizens of Le Sueur County suffered substantial damages too.

WHEREFORE, plaintiffs pray for jury awards of compensatory and punitive damages against the failing defendants - see PRAYER FOR RELIEF; together with such other and further relief the jury deems reasonable and just under the circumstances.

SIXTH CAUSE OF ACTION: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

212.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

213.    This cause of action seeks compensatory and punitive damages for the defendants' intentional infliction of emotional distress on me while in Minnesota.

214.    Since I moved to Minnesota in May 2007, all Jane’s acts and omissions to deprive me of contact and parenting time with our children, all Jane’s acts of child abuse to brainwash our children against me, all Jane's acts to sabotage my relationships with each of our 5 children, all Jane’s frauds upon the Minnesota courts, and all Jane's criminal misconduct in Minnesota, were performed intentionally to cause me emotional distress, and with reckless disregard for the well-being of every member of our family, for my relationships with each of our children, for our children's rights, for my rights, and for the futures of all 7 members of our family.

215.    Since I moved to Minnesota in May 2007, all Jeffco-CSE’s acts and omissions to deprive me of my rights to their child support services, all Jeffco-CSE’s acts and omissions to deprive me of my rights to their honest services, all Jeffco-CSE's acts and omissions to deprive me of my rights to Jefferson County's assistance in restoring my contact and parenting time with my children, all Jeffco-CSE’s acts and omissions to deprive me of my rights to reconciliation and closure of the Title IV-D Child Support case, all Jeffco-CSE’s frauds upon the Minnesota courts, and all Jeffco-CSE’s criminal misconduct in Minnesota, were performed intentionally to cause me emotional distress, and with reckless disregard for the well-being of every member of my family, including Jane, for my relationships with each of my children, for my children's rights, for my rights, and for the futures of all 7 members of my family.

216.    On information and belief, Jane and several Jeffco-CSE employees had the further intention of causing me so much grief that I would commit suicide like thousands of other fathers in the United States each year.

217.    Jane and all Jeffco-CSE employees intimately involved in the Interstate Title IV-D case knew full well that their actions would cause me severe emotional distress.

218.    Their conduct was outrageous, cruel, atrocious, odious, uncivilized, and intolerable.

219.    Jane's conduct, and that of Jeffco-CSE's Debbie Moss and Casie Stokes, constitutes felony harassment and a pattern stalking conduct in Minnesota; see Minn. Stat, § 609.749.

220.    As direct and proximate results of the intentional inflictions of emotional distress, I have experienced severe and ongoing emotional distresses for many years, including but not limited to suffering, fright, horror, nervousness, grief, worry, anguish, shock, and anxiety; I have also suffered from exhaustion and many sleepless nights; I continue to suffer damages to this day, and I will suffer from irreparable emotional harm for the rest of my life.

WHEREFORE, plaintiffs pray for jury awards of compensatory and punitive damages against the failing defendants - see PRAYER FOR RELIEF; together with such other and further relief the jury deems reasonable and just under the circumstances.

SEVENTH CAUSE OF ACTION: DECLARATORY AND OTHER RELIEF

221.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

222.    Unless the defendants settle this lawsuit pursuant to the first cause of action herein and cause the following to be accomplished, this cause of action seeks an injunction[5] and declaratory relief[6] by the Minnesota court to:

    a.    Suspend full faith and credit to Colorado in Title IV-D case #xx-xxxxxx-xx-xx and in Le Sueur County cases xx-xx-xx-xxxx and xx-xx-xx-xxxx:

         1.    LeSueur-CSE should have suspended full faith and credit to Colorado when I first brought Jeffco-CSE's criminal misconduct in the Interstate Title IV-D case and intent to defraud the Minnesota courts to LeSueur-CSE's attention in December 2007.

         2.    There is an imminent likelihood of continuing irreparable harm to the plaintiffs if this injunction is not issued.

         3.    Jury awards against the defendants alone will not abate or restore plaintiffs' losses suffered and to be suffered as a result of defendants' frauds upon the Minnesota courts.

         4.    Plaintiffs' losses far outweigh any possible harm to defendants.

         5.    The granting of this injunction will not contravene the public interest, but support it.

         6.    The facts on which plaintiffs seek this injunction are proven herein.

     b.    Find and declare[7] – for all purposes in Minnesota[8] – that my child support obligations are paid-in-full and the arrears balance is zero:

         1.    This declaration is needed to correct an egregious injustice in Minnesota caused by Jeffco-CSE that unjustly affects my rights in Minnesota.

         2.    My rights to a judgment of satisfaction of my child support obligations and my privilege to drive a motor vehicle are dependent upon these facts.

         3.    There is no controversy over these facts. The defendants have had numerous opportunities to challenge these facts over the past 7 years, but have repeatedly failed to refute these facts or rebut the evidence supporting these facts.

         4.    However, defendants may still have an adverse interest in either the facts or the law.

         5.    And therefore, defendants are hereby given notice and opportunity to have their adverse interest heard by this court in this action.

         6.    The relief sought is not merely the giving of legal advice by the court or an answer to questions founded merely in curiosity.

     c.    Find and declare – for all purposes in Minnesota – that the Colorado child support order was obtained by fraud[9] and is therefore invalid:

         1.    This declaration is needed to correct another egregious injustice in Minnesota caused by the defendants.

         2.    The declaration deals with the present state of the facts, which were misrepresented or concealed during registration in Minnesota of the void Colorado child support order in 2008.

         3.    My rights to correction of the record and the setting aside of the wrongful registration are dependent upon these facts and the proper application of Minnesota law to these facts.

         4.    Defendants may have an adverse interest in this subject.

         5.    Defendants are hereby given notice and opportunity to have their adverse interest heard by this court in this action.

         6.    The relief sought is not merely the giving of legal advice by the court or an answer to questions founded merely in curiosity.

     d.    Set aside the registration of the Colorado child support order and arrears balance in Minnesota:

         1.    Once the foregoing declarations are made, the registration can be set aside pursuant to Minnesota Rule of Civil Procedure 60.02(c)[10], (d)[11], (e)[12] and/or (f)[13].

     e.    Summon and convene a task force to take whatever action necessary to correct the judicial and administrative records in Minnesota that were falsified by Jane and Jeffco-CSE.

     f.    Summon and convene a special county grand jury in Le Sueur County to investigate the criminal misconduct by the defendants in Minnesota; and

     g.    Bill the defendants for all expenses incurred to accomplish the foregoing.

WHEREFORE, unless the defendants settle this lawsuit pursuant to the first cause of action and Jeffco-CSE takes whatever action necessary to withdraw or terminate the registration of the Colorado child support order and arrears balance in Minnesota, plaintiffs request the court issue orders accomplishing the foregoing, as requested; together with such other and further relief the court deems reasonable and just under the circumstances.

EIGHTH CAUSE OF ACTION: REPLEVIN

223.    I reallege all preceding paragraphs of this pleading as if fully incorporated herein.

224.    Unless Jane settles this lawsuit pursuant to the first cause of action herein, this cause of action seeks immediate replevin of my work things by the Minnesota court.

225.    As previously stated, Jane kept most of my personal property following her divorce, including my office equipment and many of my tools and work equipment; see Exhibit MN-630.

226.    I own the property listed and I am entitled to possession of all items listed.

227.    There was no tax, assessment, fine, or other encumbrance on any of my property.

228.    Jane is wrongfully in possession of my things, has repeatedly refused to return my things, and has indicated that she intends to keep my things permanently, which constitutes theft.

229.    If necessary, I will be filing actions against Jane in Colorado to recover my things.

230.    In the meantime, and in anticipation of the reinstatement of my driver's license, I would like my work things shipped to Minnesota so that I can get back to work.

231.    On page 3 of Exhibit MN-630, my work things are listed separately along with each item's estimated replacement value.

232.    A decision not to settle this suit pursuant to the first cause of action should prompt Jane to immediately ship my work things to me in Minnesota, and send me a cashier's check for the replacement value of any and all items she sold or otherwise got rid of, without waiting for a court order, as I will be documenting her performance for the Minnesota judge and jury.

233.    As a direct and proximate result of Jane's wrongful retention of my things, in addition to my lost income, I have also suffered other damages, which I will itemize for the juries in Minnesota and Colorado in the event that Jane decides not to settle this suit.

WHEREFORE, unless Jane settles this lawsuit pursuant to the first cause of action, I request the court issue an order requiring her to immediately ship my work things to me in Minnesota, and send me a cashier's check for the replacement value of any and all items she sold or otherwise got rid of; together with such other and further relief deemed appropriate under the circumstances.

OVERALL DAMAGES

234.    The following is a summary of the injuries my family has suffered during the never-ending pursuit of undue child support by Jane and our government:

     a.    My five children and I have been separated from each other since May 2007;

     b.    We have been cutoff from all communications with each other since August 2008;

     c.    We have missed out on: 1000s of hours of my parenting time; 9 Thanksgivings; 8 Christmases; 9 Spring Breaks; 8 summer vacations; 49 birthday parties; hundreds of school activities, hundreds of sporting events, numerous Girl Scout and Church events, many award ceremonies and celebrations; over 3000 family suppers and thousands of evening sports sessions; over 5000 homework sessions; hundreds of teaching opportunities to pass along my faith in God, my skills as a home-builder and contractor, and my abilities as a father; hundreds of “park-hopping” trips and other family outings; about 45 camping trips, 45 snowmobiling trips, 45 skiing trips, and 45 boating trips; our long-awaited once-in-a-childhood Disney trip; thousands of hugs, kisses, and high-fives; thousands of phone calls, texts, emails, and talks; and all other moments that are typically shared, in person or electronically, by parents and their children;

     d.    My 3 oldest sons and I have missed out their high school experiences and their graduations;

     e.    In 2005, my kids witnessed the intentional destruction of their family by our own government; and, for nearly 10 years now, they have been subjected to ongoing and relentless attacks on their family and an army of corrupt government officials; they have been subjected to intense and relentless government-sanctioned brainwashing, “Parental Alienation,” denials of visitation and contact, and other emotional child abuses by their mother and her sisters and friends; they have witnessed many things that would be traumatic for an adult and have been subjected to true domestic terror for many years; they have been totally brainwashed against me; they have had each of their relationships with me totally sabotaged; they have been forced by their mother and our government to grow up in a fatherless environment filled with greed, hatred, and crime; they each lost 10 years of childhood; and they do not know what reality is anymore;

     f.    In 2005, I witnessed the intentional destruction of my family by Colorado's case fixing criminals, everything I had from 25-years of backbreaking work was stolen from me with the stroke of a corrupt divorce judge's pen, and then, despite all involved knowing that my child support obligations are paid-in-full, I was strung up with a child support order that was more than I was earning at the time; and, for nearly 10 years now, I have been subjected to ongoing and relentless attacks on my family by an army of corrupt government officials in Colorado and Minnesota and Washington D.C. because of my evidence of their wrongdoing; I have been stripped of all my rights as if I was a Jew in Nazi Germany during WWII; I have been repeatedly denied access to our courts; I have been repeatedly denied protection by law enforcement; I have been repeatedly denied my rights to redress, due process, honest services, equal protection, answers to complaints, adjudication, and the administration of the law; I have been subjected to intense and relentless government-sanctioned harassment and stalking by my ex-wife and her new friends in child support enforcement and child protective services; I have had my relationships with each of my children totally sabotaged; I have been denied my right to be a parent; and I have lost 10 years of parenthood;

     g.    I have missed out on nearly 10 years of what is most precious to me in life: my family and my 5 relationships with my children; I lost my parental right to the care, custody, companionship, and love of my 5 children, and to all the fruits of the happy family I once had; and each of my children lost their right to my care, custody, companionship and love, and to all the fruits of the happy family they once had;

     h.    For nearly 10 years, my children and I have suffered from the intentional inflictions of emotional distress by our government and by my ex-wife and her accomplices; I, and likely each of my children, have experienced severe and ongoing emotional distresses, including but not limited to suffering, fright, horror, nervousness, grief, worry, anguish, shock, and anxiety;

     i.     For nearly 10 years, I, and likely each of my children, have suffered grievously from fatigue and helplessness; have suffered through hundreds of sleepless or restless nights; have suffered from many bouts of depression in varying degrees, have suffered from an indescribable longing or yearning or heartache that is a persistent dull but terrible pain; have suffered from lack of concentration and flashbacks to past good and bad times; have suffered from fear of my ex-wife’s next abuse or crime, fear of my ex-wife’s sisters’ next abuse or crime, and fear of my ex-wife’s friends’ next abuse or crime, have suffered from fear of the next abuse or crime by our government, fear of the next visit by police, fear of my next arrest, fear of the next false order by a judge, and fear of losing even more; and have suffered from fear of the future;

     j.     I have been falsely arrested 10 times and falsely imprisoned for over 9 months; I was tased during one of the arrests, suffered for months with recurring migraine headaches, and was diagnosed with high blood-pressure for the first time in my life; and I was hospitalized for several days with bleeding ulcers and was told that I would likely have to medicate my ulcers for the rest of my life;

     k.    I have been deprived for over 9 years of my right to educate my children and pass on my talents to them, as I had planned all through my career; and my children have been deprived of my knowledge and instruction through most of their adolescence;

     l.     My children and I have suffered for years from the stigma caused by my being falsely cast in public by my ex-wife and by our government as a “Deadbeat Dad” and other titles designed to portray me in public in a false light; I have suffered from defamation of my character in news articles; I have suffered greatly from the resulting humiliation and disgrace, and have lost a great amount of the respect and love of my children, my relatives, my friends and my supporters; and my children have lost the truth and have been forced to live in a web of deceit;

     m.    I have missed out on over 30 years of parent/child relationship with my first child, who was murdered by my ex-wife; each of my five children has missed out on a relationship with their older brother or sister all their lives; and collectively, we have missed out on all the good things that go along with the lost familial relationships.

     n.     For nearly 10 years, because neither my ex-wife nor the government would step forward with the truth, I have been separated from my home, my business headquarters and my tools and work equipment; have been without a driver’s license since December 2006; have been indigent and supported by relatives since January 2007; have been unemployed since October 2007; and have been forced to work double-time hours fighting against a never-ending pursuit in Colorado and Minnesota of my payment of child support for the second time so the states can profit from federal funding in the Child Support Enforcement Program; in addition, although my child support obligations are paid-in-full, I would have paid more if I could so my children would have had some extras, but because of the ongoing deceit, my children have suffered the loss of my extra support and I have suffered the disgrace of being supported by relatives;

     o.    My children and I continue to suffer substantial damages including great pain and emotional distress; and we will grievously suffer until our family is reunited;

     p.    We will suffer from irreparable injuries for the rest of our lives; and

     q.    We will never be the same.

235.    This action seeks damages resulting from Jane's and Jeffco-CSE's crime spree against me since I moved to Minnesota in May 2007.

236.    If this case goes to trial, because this is part of one of the most egregious cases against an American family in history, I will ask the jury to set precedence and award my children and me and the citizens of Le Sueur County record-setting amounts of damages based upon the highest jury awards in the history of the United States, especially in the case of Gilbert P. Hyatt v. Franchise Tax Board of the State of California (Nevada case number unknown; see 538 U.S. 488 (2003)), in which a Nevada jury awarded $388 million to a 70-year-old inventor, who was pursued by the California tax authority for years to pay taxes that were not owed.

237.    In my family's federal MASTER CIVIL COMPLAINT, dated October 11, 2013, see at www.federalmcc.webs.com, nine government defendants are named, including Jefferson County Colorado, against whom we seek damages in the amount of several billion dollars and against whom damages are increasing at a rate of $1.644 million per day; see Exhibit MN-651.

238.    It is in the best interests of the defendants to settle this action quickly.

239.    All the defendants have to do is follow the law and do what should have been done years ago, as outlined in the first cause of action.

PRAYER FOR RELIEF

WHEREFORE, plaintiffs pray for the following relief against the failing defendants:

     i.      A jury verdict adjudging the failing defendants jointly and severally liable for my lost income and my expenses since May 2007, plus punitive damages;

     ii.     A jury verdict adjudging the failing defendants jointly and severally liable for all thefts from my children and me since May 2007, plus punitive damages; and

     iii.    A jury verdict adjudging the failing defendants liable for their respective frauds upon the Minnesota courts, other criminal misconduct in Le Sueur County, invasion of privacy, negligence, intentional infliction of emotional distress, harassment, patterns of stalking conduct, oppression, denials of due process, denials of contact with my children, and destruction of my relationships with each of my children, plus punitive damages.

Money damages for the Doe Family:

     i.      For my lost income since May 2007: Compensatory damages in the amount of $250.00 per hour for my work in the capacity of an attorney, $146.00 per hour in the capacity of a paralegal and $42.00 per hour in any other capacity, plus interest, plus prospective income, plus punitive damages in an amount the jury deems just to deter other government entities and custodial parents from causing hardship to noncustodial parents;

     ii.     For my expenses since May 2007: Actual damages in the amount of $62,996.00, plus punitive damages in the amount of $1,826,884.00 or in an amount the jury deems just to deter other government entities and custodial parents from causing hardship to noncustodial parents;

     iii.    For the theft of my children's trust money: Actual damages in the amount of $10,249.00, plus punitive damages in the amount of $297,221.00 or in an amount the jury deems just to deter other child support enforcement officers and custodial parents from stealing money that belongs to children;

     iv.     For the theft of my money: Actual damages in the amount of $11,641.00, plus punitive damages in the amount of $337,589.00 or in an amount the jury deems just to deter other child support enforcement officers and custodial parents from stealing money from noncustodial parents;

     v.      Against Jane for her frauds upon the Minnesota courts, other criminal misconduct in Le Sueur County, and negligence: Aggregate compensatory and punitive damages in the amount of $600,000.00 (six hundred thousand dollars), or in amounts the jury deems just to compensate me for my injuries and deter other custodial parents from committing similar torts and crimes against the noncustodial parent and their children;

     vi.     Against Jeffco-CSE / Jefferson County Colorado[14] for Jeffco-CSE's frauds upon the Minnesota courts, other criminal misconduct in Le Sueur County, and negligence: Annual compensatory damages in an amount equivalent to 30% of Jeffco-CSE's total funding in 2014 from all sources, including it's funding for the Responsible Fatherhood Program, Title IV-D administration and all other programs administered by Jeffco-CSE, until Jefferson County has paid all damages demanded in my family's federal MASTER CIVIL COMPLAINT, plus punitive damages in an amount the jury deems just to deter other government entities from committing similar torts and crimes against noncustodial parents and their children;

     vii.    Against Jane for her intentional infliction of emotional distress, harassment, patterns of stalking conduct, oppression, denials of contact with our children, and destruction of my relationships with each of our children: Aggregate compensatory and punitive damages in the amount of $6,000,000.00 (six million dollars), or in amounts the jury deems just to compensate me for my injuries and deter other custodial parents from committing similar torts and crimes against the noncustodial parent and their children;

     viii.   Against Jeffco-CSE / Jefferson County Colorado for Jeffco-CSE's invasion of privacy, intentional infliction of emotional distress, harassment, patterns of stalking conduct, oppression, denials of services in the Responsible Fatherhood Program, and destruction of my relationships with each of my children: Aggregate compensatory and punitive damages in the amount of $600,000,000.00 (six hundred million dollars), or in amounts the jury deems just to compensate me for my injuries and deter other government entities from committing similar torts and crimes against noncustodial parents and their children; and

     ix.     Such other and further relief the jury deems appropriate under the circumstances.

For the Citizens of Le Sueur County:

     i.      For frauds upon the Minnesota courts, other criminal misconduct in Le Sueur County, negligence and other torts: Actual damages in an amount determined by a forensic accountant, plus punitive damages in an amount the jury deems just to deter similar misconduct in the Interstate Title IV-D Child Support Enforcement Program; and

     ii.     Such other and further relief the jury deems appropriate under the circumstances.

VERIFICATION

I, plaintiff John Doe, verify under penalty of perjury pursuant to 28 U.S.C. § 1746 that this complaint and all referenced exhibits are true and correct to the best of my knowledge.


DATED this 1st Day of December 2014. 


________________________________

By Plaintiff:                           John Doe