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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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Exhibit MN-620

Criminal misconduct in Minnesota by Jeffco-CSE* and Jane.

Many of the crimes are proven by the evidence in Exhibits MN-600 to MN-617.

*If Jeffco-CSE / Jefferson County Colorado fail to settle this action, subsequent civil and criminal complaints will be filed against Debbie Moss, Casie Stokes, Sue Palmer, Alvin Tafoya, and others involved in the Interstate Title IV-D case.


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CRIMES #1-7, by Jeffco-CSE: Seven of Jeffco-CSE's frauds upon the Minnesota courts rise to the level of perjury under Minn. Stat. § 609.48*; see Frauds # 1, 2, 5, 7, 8, 10, and 12.

     ELEMENTS of Jeffco-CSE's Perjuries:

  1.    In all instances, Jeffco-CSE made statements under oath in the Minnesota judicial proceedings.

  2.    In each instance, Jeffco-CSE knew or should have known at the time that its statement was false.

  3.    In each instance, Jeffco-CSE's statements were, in fact, false.

  4.    In each instance, Jeffco-CSE's false statements regarded material facts in the Minnesota cases.

     * See also 18 U.S.C. § 1621 - Perjury; and 18 U.S.C. § 1001 - False Statements.

CRIMES #8-10, by Jane: Three of Jane's frauds upon the Minnesota courts rise to the level of perjury under Minn. Stat. § 609.48*; see Frauds # 6, 9, and 11.

     ELEMENTS of Jane's Perjuries:

  1.    In all instances, Jane made statements under oath in the Minnesota judicial proceedings.

  2.    In each instance, Jane knew or should have known at the time that her statement was false.

  3.    In each instance, Jane's statements were, in fact, false.

  4.    In each instance, Jane's false statements regarded material facts in the Minnesota cases.

     * See also 18 U.S.C. § 1621 - Perjury; and 18 U.S.C. § 1001 - False Statements.

CRIMES #11-35, by Jeffco-CSE: In addition to their frauds upon the courts and perjuries, Jeffco-CSE committed at least 25 other crimes in Le Sueur County, as follows:

     ELEMENTS of Jeffco-CSE's Other Crimes in Le Sueur County:

  1.    Jeffco-CSE took part in my four false imprisonments in Le Sueur County, which constitute four separate crimes under Minn. Stat. § 609.255; the false imprisonments are also offenses against the United States because injury was caused to all American taxpayers, see 18 U.S.C. § 2.

  2.    Jeffco-CSE presented fraudulent arrears balances for filing in the Minnesota cases on several occasions, each of which constitutes a crime under Minn. Stat. § 609.7475.

  3.    Jeffco-CSE filed falsified arrears balance statements on the record in the Minnesota cases on several occasions, each of which is a crime pursuant to Minn. Stat. § 609.63, subd. 1.

  4.    Jeffco-CSE offered falsified arrears balance statements in evidence in the Minnesota trial of a felony, which is a crime under Minn. Stat. § 609.63, subd. 2.

  5.    Jeffco-CSE took part in the embezzlement of public funds through the Interstate Title IV-D Child Support case, which is a crime under Minn. Stat. § 609.54; see also 18 U.S.C. § 666.

  6.    On numerous occasions, Jeffco-CSE failed to report Jane's denials of visitation and contact, her frauds upon the courts and upon me and upon the people of both states, her thefts of public funds, or any of her other crimes, which constitutes misprision of felony under 18 U.S.C. § 4.

  7.    On numerous occasions, Jeffco-CSE failed to report Jane's child abuses, which is another count of misprision of felony under 18 U.S.C. § 4.

  8.    On numerous occasions, Jeffco-CSE failed to report the criminal misconduct by its employees in the Interstate Title IV-D case, which is another count of misprision of felony under 18 U.S.C. § 4.

  9.    Jeffco-CSE possesses false writings used to defraud the United States for their own gain and for Jane's gain, both of which are crimes under 18 U.S.C. § 1002 and 18 U.S.C. § 371 respectively.

  10.    Jeffco-CSE made and delivered their fraudulent motion to withdraw my motion to modify in 2008, and their fraudulent results of five reviews of my Title IV-D account, with the intent to defraud the Colorado and Minnesota courts in their respective judicial proceedings, which, in addition to the frauds upon the courts alleged previously, are crimes under 18 U.S.C. § 1018.

  11.    Jeffco-CSE corruptly influenced the federal Title IV-D proceedings in both states, which are crimes under 18 U.S.C. § 1505.

  12.    Jeffco-CSE corruptly influenced the judicial proceedings in both states, which are crimes under 18 U.S.C. § 1512(c)(2).

  13.    Jeffco-CSE took part in the processing and enforcement of a fictitious obligation, which is a class B federal felony under 18 U.S.C. § 514.

  14.    Jeffco-CSE took part in the extortion of my bail money pursuant to 18 U.S.C. § 1951.

  15.    Jeffco-CSE repeatedly deprived me of my rights to verification, review, adjustment, modification, reconciliation, and other services in the Interstate Title IV-D Child Support Enforcement Program, committing several crimes under 18 U.S.C. § 242.

  16.    Jeffco-CSE deprived me of my rights in the Fatherhood Initiative Program and later in the Responsible Fatherhood Program, committing two more crimes under 18 U.S.C. § 242.

  17.    Jeffco-CSE deprived me of my right to frequent and continuing contact with my children, which is a crime under Minn. Stat. § 609.54 and under 18 U.S.C. § 242.

  18.    Jeffco-CSE covered up the fact that the No Contact Order violated Colorado law and my children's and my rights, which constitutes a crime under 18 U.S.C. § 1001.

  19.    Jeffco-CSE covered up the fact that Jane's fraudulent application, her felony denials of my contact and visitation with our children, and other actions had disqualified her from receiving child support enforcement services, which constitutes another crime under 18 U.S.C. § 1001.

  20.    Jeffco-CSE repeatedly concealed the fact that my child support obligations are paid-in-full, which constitutes additional crimes under 18 U.S.C. § 1001.

  21.    Jeffco-CSE repeatedly committed the crime of mail fraud pursuant to 18 U.S.C. § 1341.

  22.    Jeffco-CSE deprived me of my right to honest services in the Interstate Title IV-D Child Support Enforcement case, which is a crime under 18 U.S.C. § 1346.

  23.    Jeffco-CSE deprived me of my right to honest services in Minnesota's Criminal Justice System, which is another crime under 18 U.S.C. § 1346.

  24.    Jeffco-CSE aided Jane in her felony denials of my contact and visitation with our children, which is a crime under Minn. Stat. § 609.495.

  25.    By committing the 7-year crime spree alleged above, Jeffco-CSE committed several counts of felony harassment and several patterns of stalking conduct in Le Sueur County pursuant to Minn. Stat. § 609.749.

     [NOTE: Evidence exists to prove the elements of each of Jeffco-CSE's crimes, including the act or omission, intent, knowledge and injury. In the event that this lawsuit is not timely settled pursuant to the first cause of action herein, criminal complaints against Jeffco-CSE officials will be sent to investigators, grand juries and other appropriate authorities.]

CRIMES #36-53, by Jane: In addition to her frauds upon the courts and perjuries, Jane committed at least 18 other crimes in Le Sueur County, as follows:

     ELEMENTS of Jane's Other Crimes in Le Sueur County:

  1.    Jane took part in my four false imprisonments in Le Sueur County, which constitute four separate crimes under Minn. Stat. § 609.255; the false imprisonments are also offenses against the United States because injury was caused to all American taxpayers, see 18 U.S.C. § 2.

  2.    Jane tampered with one of my witnesses in the registration case, which is a crime under Minn. Stat. § 609.498 and is also a federal crime under 18 U.S.C. § 1512(b)(1).

  3.    Jane presented false information for filing in the Minnesota cases, which constitutes a crime under Minn. Stat. § 609.7475.

  4.    Jane presented a false police report for filing in the Minnesota cases, which constitutes another crime under Minn. Stat. § 609.7475.

  5.    Jane caused a false police report to be filed on the record in Minnesota, which is a crime pursuant to Minn. Stat. § 609.63, subd. 1.

  6.    Jane took part in the embezzlement of public funds through the Interstate Title IV-D Child Support case, which is a crime under Minn. Stat. § 609.54; see also 18 U.S.C. § 666.

  7.    Jane possesses false writings used to defraud the United States for monetary gain, which constitutes two crimes, one under 18 U.S.C. § 371 and the other under 18 U.S.C. § 1002.

  8.    Jane corruptly influenced the federal Title IV-D proceedings in both states, which are crimes under 18 U.S.C. § 1505.

  9.    Jane corruptly influenced the judicial proceedings in both states, which are crimes under 18 U.S.C. § 1512(c)(2).

  10.    Jane took part in the extortion of my bail money pursuant to 18 U.S.C. § 1951.

  11.    Jane received my stolen bail money, which is a crime under Minn. Stat. § 609.52.

  12.    Jane deprived me of my right to frequent and continuing contact with my children, which is a crime under Minn. Stat. § 609.54 and under 18 U.S.C. § 242.

  13.    Jane covered up the fact that the No Contact Order violated Colorado law and our children's and my rights, which constitutes a crime under 18 U.S.C. § 1001.

  14.    Jane covered up the fact that her fraudulent application, her felony denials of my contact and visitation with our children, and other actions had disqualified her from receiving child support enforcement services, which constitutes another crime under 18 U.S.C. § 1001.

  15.    Jane repeatedly concealed the fact that my child support obligations are paid-in-full, which constitutes additional crimes under 18 U.S.C. § 1001.

  16.    During registration, Jane committed the crime of mail fraud pursuant to 18 U.S.C. § 1341.

  17.    Jane's felony denials of my contact and visitation with our children are not only crimes in Colorado, but also violate my parental rights in Minnesota – a crime under Minn. Stat. § 609.495.

  18.    By committing the 7-year crime spree alleged above, Jane committed several counts of felony harassment and a pattern of stalking conduct in Le Sueur County under Minn. Stat. § 609.749.

     [NOTE: Evidence exists to prove the elements of each of Jane's crimes, including the act or omission, intent, knowledge and injury. In the event that this lawsuit is not timely settled pursuant to the first cause of action herein, criminal complaints against Jane will be sent to investigators, grand juries and other appropriate authorities.]

CRIMES #54-57, by Jeffco-CSE: On at least four occasions in Le Sueur County, Jeffco-CSE conspired with Minnesota officials to cause my false arrest and prosecution, see Minn. Stat. § 609.175, subd. 1.*

     ELEMENTS of Jeffco-CSE's Conspiracies to cause arrest or prosecution:

  1.    In 2009, Jeffco-CSE conspired with Minnesota officials to have me falsely arrested for nonsupport of our children; In 2011, Jeffco-CSE conspired to have me falsely arrested on the false conviction of nonsupport of our children; In 2012, Jeffco-CSE conspired to have me falsely arrested for probation violations; and in 2014, Jeffco-CSE took part in the conspiracy to coerce me into turning myself in for prosecution on the false probation violation charges.

  2.    In 2009, Jeffco-CSE knew that the charge was false because my child support obligations are paid-in-full; In 2011, Jeffco-CSE knew that the conviction was false because my child support obligations are paid-in-full; In 2012, Jeffco-CSE knew that the probation violation was false and was just part of a grander conspiracy and plan to oppress me with the full police power of the State of Minnesota until I snapped or took my own life; and in 2014, Jeffco-CSE knew that the premise on which I was ordered to turn myself in, and the prosecution, were false because the sentencing order and probation were invalid, and more specifically on the charge pending at the time, the No Contact Order was illegal, violated Colorado and Minnesota law, violated two Colorado court orders, violated my right to “frequent and continuing contact” with my children, violated my children's rights to “frequent and continuing contact” with me, and was indecent and conscience shocking.

  3.    In 2010, Jeffco-CSE and other conspirators caused my 5th false arrest and false prosecution; In 2011, Jeffco-CSE and other conspirators caused my 6th false arrest and false sentencing; In 2012, Jeffco-CSE and other conspirators caused my 7th false arrest and false prosecution; and in 2014, Jeffco-CSE and other conspirators caused my 9th false arrest and false prosecution.

     *See also 18 U.S.C. § 241 – Conspiracy against rights.

CRIMES #58-61, by Jane: On at least four occasions in Le Sueur County, Jane conspired with officials to cause my false arrest and prosecution, see Minn. Stat. § 609.175, subd. 1.*

     ELEMENTS of Jane's Conspiracies to cause arrest or prosecution:

  1.    In 2009, Jane conspired with Minnesota officials to have me falsely arrested for nonsupport of our children; In 2011, Jane conspired to have me falsely arrested on the false conviction of nonsupport of our children; In 2012, Jane conspired to have me falsely arrested for probation violations; and in 2014, Jane took part in the conspiracy to coerce me into turning myself in for prosecution on the false charge of violating the void No Contact Order.

  2.    In 2009, Jane knew that the charge was false because my child support obligations are paid-in-full; In 2011, Jane knew that the conviction was false because my child support obligations are paid-in-full; In 2012, Jane knew that the probation violation was false and was just part of a grander conspiracy and plan to oppress me with the full police power of the State of Minnesota until I snapped or took my own life; and in 2014, Jane knew that the premise on which I was ordered to turn myself in and the prosecution were false because the No Contact Order was illegal, violated Colorado and Minnesota law, violated two Colorado court orders, violated my right to “frequent and continuing contact” with our children, violated our children's rights to “frequent and continuing contact” with me, and was indecent and conscience shocking.

  3.    In 2010, Jane and other conspirators caused my 5th false arrest and false prosecution; In 2011, Jane and other conspirators caused my 6th false arrest and false sentencing; In 2012, Jane and other conspirators caused my 7th false arrest and false prosecution; and in 2014, Jane and other conspirators caused my 9th false arrest and false prosecution.

     *See also 18 U.S.C. § 241 – Conspiracy against rights.

CRIMES #62-83, by Jeffco-CSE: Jeffco-CSE conspired to commit at least 22 crimes in Le Sueur County, see Minn. Stat. § 609.175, subd. 2.*

     ELEMENTS of Jeffco-CSE's Conspiracies to commit crime:

  1.    Jeffco-CSE conspired with Minnesota officials to have me falsely imprisoned four times in Le Sueur County (see Minn. Stat. § 609.255).

  2.    Jeffco-CSE conspired with Minnesota officials to present fraudulent arrears balances for filing in the Minnesota cases (see Minn. Stat. § 609.7475).

  3.    Jeffco-CSE conspired with Minnesota officials to file falsified arrears balance statements on the record in the Minnesota cases (see Minn. Stat. § 609.63, subd. 1).

  4.    Jeffco-CSE conspired with Minnesota officials to offer falsified arrears balance statements in evidence in a trial of a felony (see Minn. Stat. § 609.63, subd. 2).

  5.    Jeffco-CSE conspired with Minnesota officials to embezzle public funds (see Minn. Stat. § 609.54; see also 18 U.S.C. § 666).

  6.    Jeffco-CSE conspired with Minnesota officials to defraud the United States for their own gain and for Carol's gain (see 18 U.S.C. § 371 and 18 U.S.C. § 1002 respectively).

  7.    Jeffco-CSE's Title IV-D Administrators and attorneys conspired in-house to make and deliver their fraudulent motion to withdraw my motion to modify in 2008 and their fraudulent results of five reviews of my Title IV-D account with the intent to defraud the Colorado and Minnesota courts in their respective judicial proceedings (see 18 U.S.C. § 1018).

  8.    Jeffco-CSE conspired with Minnesota officials to corruptly influence the federal Title IV-D proceedings in both states (see 18 U.S.C. § 1505).

  9.    Jeffco-CSE conspired with Minnesota officials to corruptly influence the judicial proceedings in both states (see 18 U.S.C. § 1512(c)(2)).

  10.    Jeffco-CSE conspired with Minnesota officials to process and enforce a fictitious obligation (a class B federal felony under 18 U.S.C. § 514).

  11.    Jeffco-CSE conspired with Minnesota officials to extort my bail money from me for Jane (see 18 U.S.C. § 1951).

  12.    Jeffco-CSE conspired with Minnesota officials to deprive me of my rights to verification, review, adjustment, modification, reconciliation, and other services in the Child Support Enforcement Program (see 18 U.S.C. § 242).

  13.    Jeffco-CSE conspired with Jane and Minnesota officials to deprive me of my rights in their Fatherhood Programs (see 18 U.S.C. § 242).

  14.    Jeffco-CSE conspired with Jane and Minnesota officials to deprive me of my right to frequent and continuing contact with my children (see 18 U.S.C. § 242).

  15.    Jeffco-CSE conspired with Jane and Minnesota officials to cover up the fact that the No Contact Order violated Colorado law and my children's and my rights (see 18 U.S.C. § 1001).

  16.    Jeffco-CSE conspired with Jane and Minnesota officials to cover up the fact that Jane's fraudulent application, her felony denials of my contact and visitation with our children, and other actions had disqualified Jane from receiving child support enforcement services (see 18 U.S.C. § 1001).

  17.    Jeffco-CSE conspired with Jane and Minnesota officials to conceal the fact that my child support obligations are paid-in-full (see 18 U.S.C. § 1001).

  18.    Jeffco-CSE conspired with Minnesota officials to commit mail fraud (see 18 U.S.C. § 1341).

  19.    Jeffco-CSE conspired with Minnesota officials to deprive me of my right to honest services in the Interstate Title IV-D Child Support Enforcement case (see 18 U.S.C. § 1346).

  20.    Jeffco-CSE conspired with Minnesota officials to deprive me of my right to honest services in Minnesota's Criminal Justice System (see 18 U.S.C. § 1346).

  21.    Jeffco-CSE conspired with Jane and Minnesota officials to aid Jane in avoiding the consequences of her crimes in Le Sueur County (see Minn. Stat. § 609.495).

  22.    Jeffco-CSE conspired with Jane and Minnesota officials to commit the above crimes in order to oppress me under color of Minnesota law and otherwise stalk me in Le Sueur County for seven years (see Minn. Stat. § 609.749).

     [NOTE: In furtherance of each conspiracy, Jeffco-CSE and/or Jane and/or one or more of the Minnesota officials involved, did one or more overt acts. These overt acts are alleged in my criminal complaints, which will be sent to investigators, grand juries and other appropriate authorities in the event that this lawsuit is not timely settled pursuant to the first cause of action herein.]

     *See also 18 U.S.C. § 241 – Conspiracy against rights.

CRIMES #84-102, by Jane: Jane conspired to commit at least 18 crimes in Le Sueur County, see Minn. Stat. § 609.175, subd. 2.*

     ELEMENTS of Jane's Conspiracies to commit crime:

  1.    Jane conspired with Jeffco-CSE and Minnesota officials to have me falsely imprisoned four times in Le Sueur County (see Minn. Stat. § 609.255).

  2.    Jane conspired with Minnesota officials to tamper with one of my witnesses in the registration case (see Minn. Stat. § 609.498; see also 18 U.S.C. § 1512(b)(1)).

  3.    Jane conspired with Jeffco-CSE to present false information for filing in the Minnesota cases (see Minn. Stat. § 609.7475).

  4.    Jane conspired with Minnesota officials to present a false police report for filing in a Minnesota case (see Minn. Stat. § 609.7475).

  5.    Jane conspired with Minnesota officials to file a false police report on the record in the Minnesota cases (see Minn. Stat. § 609.63, subd. 1).

  6.    Jane conspired with Jeffco-CSE and Minnesota officials to embezzle public funds (see Minn. Stat. § 609.54; see also 18 U.S.C. § 666).

  7.    Jane conspired with Jeffco-CSE and Minnesota officials to defraud the United States for her monetary gain (see 18 U.S.C. § 371 and 18 U.S.C. § 1002 respectively).

  8.    Jane conspired with Jeffco-CSE and Minnesota officials to corruptly influence the federal Title IV-D proceedings in both states (see 18 U.S.C. § 1505).

  9.    Jane conspired with Jeffco-CSE and Minnesota officials to corruptly influence the judicial proceedings in both states (see 18 U.S.C. § 1512(c)(2)).

  10.    Jane conspired with Jeffco-CSE and Minnesota officials to extort my bail money (see 18 U.S.C. § 1951).

  11.    Jane conspired with Jeffco-CSE and Minnesota officials to receive my stolen bail money (see Minn. Stat. § 609.52).

  12.    Jane conspired with Jeffco-CSE and Minnesota officials to deprive me of my right to frequent and continuing contact with our children (see 18 U.S.C. § 242).

  13.    Jane conspired with Jeffco-CSE and Minnesota officials to cover up the fact that the No Contact Order violated Colorado law and my children's and my rights (see 18 U.S.C. § 1001).

  14.    Jane conspired with Jeffco-CSE and Minnesota officials to cover up the fact that Jane's fraudulent application, her felony denials of my contact and visitation with our children, and other actions had disqualified Jane from receiving child support enforcement services (see 18 U.S.C. § 1001).

  15.    Jane conspired with Jeffco-CSE and Minnesota officials to conceal the fact that my child support obligations are paid-in-full (see 18 U.S.C. § 1001).

  16.    Jane conspired with Jeffco-CSE and Minnesota officials to commit mail fraud (see 18 U.S.C. § 1341).

  17.    Jane conspired with Jeffco-CSE and Minnesota officials to aid her in her felony denials of my contact and visitation with our children (see Minn. Stat. § 609.495).

  18.    Jane conspired with Jeffco-CSE and Minnesota officials to commit the above crimes in order to oppress me under color of Minnesota law and otherwise stalk me in Le Sueur County for seven years (see Minn. Stat. § 609.749).

     [NOTE: In furtherance of each conspiracy, Jane and/or Jeffco-CSE and/or one or more of the Minnesota officials involved, did one or more overt acts. These overt acts are alleged in my criminal complaints, which will be sent to investigators, grand juries and other appropriate authorities in the event that this lawsuit is not timely settled pursuant to the first cause of action herein.]

     *See also 18 U.S.C. § 241 – Conspiracy against rights.