IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
PEOPLE ex rel, JANICE LYNN KING,
Plaintiff,
v. Civil Case No: 06-4001-SAC
SHERRI KELLER, in her individual and official JURY DEMAND
capacity of Shawnee County District Court
Case Management Supervisor;
AMANDA SMITH-WILSON, in her individual and official
capacity of Shawnee County District Court
Case Manager;
SUSANNA VAN GELDER COXE, in her
individual and official capacity as an officer
of the court and a Kansas Bar Member;
STEVE PHILLIPS, in his individual and
Official capacity as the Assistance Attorney
General of the State of Kansas.
JOHN DOE #1 et al.,
Defendants,
COMPLAINT WITH JURY DEMAND
COUNT I
False Claims Act 31 U.S.C. §3729 (a)(1) & (2)
COMES NOW, the Plaintiff, the People of the United States of America, by the Relator,
Janice Lynn King, Pro Se, and for Count I of its Complaint against Sherri Keller, Amanda
Smith-Wilson, Susanna van Gelder Coxe, Steve Phillips, and John Doe #1 (hereinafter
Defendant) and alleges as follows;
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1). This is an action for damages and civil penalties on behalf of the People of the United
States of America arising from false statements and records made or caused to be made by
Defendant to the United States of America in violation of the False Claims Act, 31 U.S.C. §3729
(a)(1) & (2), et seq., as amended (hereinafter “FCA”). This Court has jurisdiction over the
subject matter of this action pursuant to 31 U.S.C. § 3730 (b) AND 28 U.S.C. § 1331 (1998).
2). Defendants are officers of the Shawnee County, and Kansas courts sworn to uphold the
laws of Kansas by occupational title.
3). Defendants contract indirectly with the United States of America (hereinafter
“Government”) through Federally allocated funding for the purpose of family reunification,
foster care, adoption, child services and family services.
4). The U.S. District Court has personal jurisdiction over Defendant and this matter
pursuant to 31 U.S.C. § 1391 and 31 U.S.C. § 3732 (a), the Sixth Amendment, the Thirteenth
Amendment, the Fourteenth Amendment, 18 USC § 2, 18 USC § 4, 18 USC § 241, 18 USC
1091, 18 USC § 1581, 18 USC §1583, 18 USC § 1584, 42 USC § 1981, 42 USC § 1982, 42 USC
§ 1983, and 42 USC § 1985.
5). King is a citizen of the United States of America and a resident of the State of Kansas.
6). King has first hand, direct, and independent knowledge, within the meaning of 31
U.S.C. § 3730(e)(4)(B), derived through her participation in Shawnee County District Court
Case No: 99D2559; 05-94703-A; 03 MC 2013; State v. Paul J. Ziegler; 00D1475 and
OOCR2826 and first hand knowledge of, In the Matter of Bret Landrith, Kansas Supreme
Court case no. 05-94333, Hunt v. Hunt 94D1144; 00 2193 GTV; 01 A 48; 01MC 01325; 02 C
000072; 03 90035 A; 03 TR 003740; 01 MC 1325; A 91252; 03 90035 A; 04 A 03; Smith v.
Smith 00D2011; on which the allegations set forth in this complaint are based.
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7). King is the original source of the allegations as defined in 31 U.S.C. § 3730 (e)(4)(B).
King has knowledge of the false statements and / or claims that Defendant submitted, or caused
to be submitted, to the government as alleged herein.
8). To the extent, if any, that this case is deemed to be a related action that facts set for the
herein are deemed to be the same as facts underlying an existing qui tam False Claims Act action
pending at the time of filing of this action, as prohibited by 31 U.S.C. § 3730(e), said factual
allegations in common with either pending action, which would cause this to be a related cause
of action, are hereby expressly excluded from this action, but only to the limited extent necessary
to exclude such preemption.
9). Furthermore, to extend that the Court finds that the allegations or transactions set forth
herein are based upon allegations or transactions which are the subject of a civil suit or an
administrative civil money penalty proceeding in which the United States is already a part, if any
such proceeding exists, then the allegations or transactions referred to herein that the Court
deems are based upon allegations or transactions which are the subject of any such civil suit or
administrative civil money penalty proceeding are expressly excluded here from, but only for the
specific time periods, and specific allegations or transactions as necessary.
10). Overall responsibility for the defendants of this action is the State of Kansas, by its
own Constitution, and that of the United States of America.
11). Defendants participate in the control the State of Kansas’s ability to renew its existing
contracts is to maintain its proposed plan of action as submitted to the Secretary of State of the
United States of America.
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12). Defendants participate in the control the State of Kansas’s ability to renew its plan of
action rest solely upon the citizens of the State of Kansas to, in any fashion, become an assigned
number by and through any of its agencies, ie, DFS, Courts, etc.
13). Defendants participate in the control the State of Kansas fraudulently inducing the
Government to pay Defendant for administrative services in accordance with its contracts from
at least 1999 to the present by submitting payment requests for services rendered, as they permit
the initiation and aggravation of family matters to induce participation.
14). That 31 U.S.C. § 3729 of the FCA states as follows: (a) Liability for certain acts. --
Any person who—
(1) Knowingly presents, or causes to be presented, to an officer or employee of the United States
Government or a member of the Armed Forces of the United States a false or fraudulent claim
for payment or approval;
(2) Knowingly makes, uses, or causes to be made or used, a false record or statement to get a
false or fraudulent claim paid or approved by the Government;
(3) Conspires to defraud the Government by getting a false or fraudulent claim allowed or paid;
(4) Has possession, custody, or control of property or money used, or to be used, by the
Government and, intending to defraud the Government or willfully to conceal the property,
delivers, or causes to be delivered, less property than the amount for which the person receives a
certificate or receipt;
(5) Authorized to make or deliver a document certifying receipt of property used, or to be used,
by the Government and, intending to defraud the Government, makes or delivers the receipt
without completely knowing that the information on the receipt is true;
(6) Knowingly buys, or receives as a pledge of an obligation or debt, public property from an
officer or employee of the Government, or a member of the Armed Forces, who lawfully may
not sell or pledge the property; or
(7) Knowingly makes, uses, or causes to be made or used, a false record or statement to conceal,
avoid, or decrease an obligation to pay or transmit money or property to the Government, is
liable to the United States Government for a civil penalty of not less than $5,000 and not more
than $10,000, plus 3 times the amount of damages which the Government…
15). That in addition to treble the actual damages suffered by the Government, Defendant is
liable to the United States Government for civil penalty of not less than:
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a). $5,00.00 and not more than $10,000.00, for any false claims it submitted to the
Government on or before 1999, in violation of 31 U.S.C. § 3729; and
b). $5,500 and not more than $11,000.00, for any false claims it submitted to the
Government on or after 1999, in violation of 31 U.S.C. § 3729. 28 U.S.C. § 85.
16). Defendant has not notified the Government of its violations of the FCA.
17). The Government was damaged do to Defendant’s deliberate improper use of its
judicial branch located in Shawnee County, Kansas and Government paid out claims that should
not have been paid out, and Defendant was paid its cost when not in compliance with local, state,
and Federal, rule, statute, law, charter ordinance, and ordinance, of Shawnee County, Kansas,
nor the United States of America, causing harm to the United States of America.
WHEREFORE, the People of the United States of America by Relator King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
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E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
COUNT II
(OBSTRUCTION OF JUSTICE)
(Pursuant to 42 U.S.C. § 1985)
COMES NOW, the People of the United States of America, by the Relator, King, Pro Se,
and for Count II of its Complaint against Sherri Keller, Amanda Smith-Wilson, Susanna van
Gelder Coxe, Steve Phillips, and John Doe #1, et al. (hereinafter Defendants), alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-17 of Count I as its
paragraphs 1-17 of this Count II.
18). When a 15 year old DMZ, in the residential custody of [Plaintiff] his mother, was
denied the ability to run amuck in the streets, engage in endless chat lines on the computer, and
not permitted to leave his television on past 9:30 p.m. on mom’s work days, DMZ devised a plan
to ignite the displaced anger of his father against his mother, and regardless of consequence,
accomplish the receipt of privileges that he sought on a daily basis.
19). DMZ conspired with his father who bargained that he would attend to a Summer
Camp, that the mother could not financially afford on her own, nor would the father offer to help
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pay, if DMZ would provide the testimony sought by the father in the Shawnee County District
Court.
20). On or about June 28th, 2003, Defendants conspired with the father, Respondent of
Shawnee County Court Case No: 99D2559, to protect him from kidnapping charges pertaining to
the parties oldest minor child, DMZ, as well as, attempted dissolution of two (2) years of child
support obligation arrearage.
21). On July 5th, 2003 Defendant Keller phoned the Plaintiff of this action (King) from her
home phone (as the courthouse was closed for the holiday) advising her that the scheduled case
management meeting for July 6th, 2003, had been cancelled, when in fact it had not been.
22). Defendant Keller continued to advise King that the minor child “would never return to
your residential custody, as no 15 year old should have to go to bed at 9:30 p.m., for any reason”.
23). On July 6th, 2003, Defendant Keller allowed her personal bias and hatred of the parties
court appointed case manager of that time, Ginger K. Napue, to obstruct her from the facts of the
allegations of the matter, and intervened unnecessarily in this matter, deliberately causing kaos
and continued litigation of this matter. Ginger K. Napue was eventually terminated due to her
unbias involvement in this matter, and clear knowledge of the facts. To include the works by
DMZ that abled him to reside with his mother (plaintiff) initially.
24).On August 18th, 2003, Defendants failed to comply with enforce state laws pertaining
to parental abduction of a minor child, in which the respondent of 99D2559 (Paul Joseph
Ziegler) had committed;
a). Administrative hearing officer Lori L. Yockers postponed all issues that did not pertain
to child support issues.
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b). “Case Rotation” conveniently gave cause for the presiding judge, Honorable David E.
Bruns, from intervening.
c). Dual representation, though with direct conflict of interest [and failure to give an entry
of appearance of such], by defendant Coxe gave the defendant ample opportunity to submit
‘statements by a minor child’ into an open record [without request for seal], all the while
Defendants asserting that these works were indeed that of the child, “not her client’s” creations.
All the while conspiring with the other two (2) named defendants, at least, to cover up and /
destroy any evidence of the previous works of DMZ, that brought cause for him to be in the
residential custody of the mother in the first place.
25). On Augusts 18th, 2003, Defendants and their accomplices failed to enforce the laws
pertaining to the willful act of refusal to pay child support obligation payments in which the
respondent of 99D2559 (Paul Joseph Ziegler) had committed.
a). Administrative hearing officer Lori L. Yockers postponed all that did not pertain to
child support issues.
b). “Case Rotation” conveniently gave cause for the Honorable David E. Bruns from
intervening.
c). Dual representation, though direct conflict of interest and failure to give an entry of
appearance of such, by defendant Coxe gave the defendant ample opportunity to submit
‘statements by a minor child’ into an open record, all the while Defendant asserting that these
works were indeed the child, not her client’s creations. All the while conspiring with the other
two (2) named defendants, at least, to cover up and / destroy any evidence of the previous works
of DMZ, that brought cause for him to be in the residential custody of the mother in the first
place.
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26). On August 18th, 2003, Defendants and their accomplices made or caused to be made
the transcripts of the proceedings held on that day to be altered by and through defendant
Keller’s instruction and / or assistance.
27). On August 18th, 2003, Defendants and their accomplices made or caused to be made
the promotion of parental alienation in which the respondent of 99D2559 (Paul Joseph Ziegler)
had committed, see Smith v. Smith 00D2011; involving the same [court] personnel with the
same actions having been committed just to aggravate the situation between the parties.
a). Administrative hearing officer Lori L. Yockers postponed all that did not pertain to
child support issues.
b). “Case Rotation” conveniently gave cause for the Honorable David E. Bruns from
intervening.
c). Dual representation, though direct conflict of interest [and failure to give an entry of
appearance of such], by defendant Coxe gave the defendant ample opportunity to submit
‘statements by a minor child’ into an open record, all the while Defendant asserting that these
works were indeed the child, not her client’s creations. All the while conspiring with the other
two (2) named defendants, at least, to cover up and / destroy any evidence of the previous works
of DMZ, that brought cause for him to be in the residential custody of the mother in the first
place.
28). On August 18th, 2003, Defendants and their accomplices made or caused to be made
the promotion of hate crimes within the Capital City of the state of Kansas in which the
respondent of 99D2559 (Paul Joseph Ziegler) had committed.
a). Administrative hearing officer Lori L. Yockers postponed all that did not pertain to
child support issues.
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b). “Case Rotation” conveniently gave cause for the Honorable David E. Bruns from
intervening.
c). Dual representation, though direct conflict of interest and failure to give an entry of
appearance of such, by defendant Coxe gave the defendant ample opportunity to submit
‘statements by a minor child’ into an open record, all the while defendant asserting that these
works were indeed the child, not her client’s creations. All the while conspiring with the other
two (2) named defendants, at least, to cover up and / destroy any evidence of the previous works
of DMZ, that brought cause for him to be in the residential custody of the mother in the first
place.
29). After continuous litigation against a bias court due to ex parte communications and
pre-planned conspiracy, on April 14, 2005, a pre-trial hearing was attended in response to
address the ‘Motion to Quash’ the subpoenas King issued as to the court personnel that had been
participating in this matter, de novo, to attempt to gain the facts of the matter at that time. The
Honorable Ronald D. Innes (assigned by the Kansas Supreme Court) presided over this
‘hearing’.
30). Defendant Phillips was served, via USPS on March 18, 2005, a copy of King’s Pretrial
Questionnaire, outlining the issues being sought for review. [Attachment 1]
31). On May 23, 2005, King’s attempts were quashed and the requested trial to address the
matter was handed to the respondent and his counselor, defendant Coxe, at which time turned the
following pleadings into a 3-ring circus. Accomplishing the following;
a). Failing to enforce existing law on any of the violations already stated in this
complaint.
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b). Failing to uphold his judiciary duty to uphold the laws and protect the innocent in his
courtroom, due to ex parte communications and political favor, in retaliation to the plaintiff’s
affiliations with Bret D. Landrith (formerly Esquire) and David Martin Price.
c). Deliberate uninvited micro-management to this matter just to aggravate the situation
and bring cause for additional Federal Funding to Kansas to accommodate the family court’s
industry’s hunger.
32). On July 23, 2005, Defendants and their accomplices made and / or caused to be made
the promotion of child abuse when the court ordered the parties youngest minor child to reside
with the respondent of 99D2559 after more than a month of refusing to have ‘parenting time’
with him due to his verbal and emotional abuse. Therefore, creating judicial kidnapping.
33). On July 23, 2005, Defendants and their accomplices made and caused to be made the
involuntary servitude of a minor child when the court ordered the parties youngest minor child to
reside with the respondent of 99D2559 after more than a month of refusing to have ‘parenting
time’ with him due to his verbal and emotional abuse. Therefore, creating judicial kidnapping.
34). On July 23, 2005, Defendants and their accomplices made and caused to be made
involuntary servitude of Plaintiff, when the court ordered the parties youngest minor child to
reside with the respondent of 99D2559 after more than a month of refusing to have ‘parenting
time’ with him due to his verbal and emotional abuse, while the plaintiff of this matter continues
to litigate over the order of restraining the minor children to the perimeters of Shawnee County,
Kansas until they are of age. Therefore, enforcing judicial kidnapping.
35). On July 23, 2005, Defendants made or caused to be made direct violations of the laws
of the state of Kansas, specifically the Protection From Abuse Act laws. KS.A. 60-2331 et seq.
when the court allowed the parties’ oldest minor child to remain in the residential custody of the
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respondent and ordered the parties youngest minor child to reside with the respondent of
99D2559 after more than a month of refusing to have ‘parenting time’ with him due to his verbal
and emotional abuse, while the plaintiff of this matter continues to overturn the order of
restraining the minor children to the perimeters of Shawnee County, Kansas until they are of age.
36). On July 23, 2005, Defendants made and / or caused to be made direct violations of
Plaintiff’s 6th Amendment Rights to Due Process when Plaintiff was not permitted to present
evidence nor speak during the “Show Cause Hearing” of this date.
37). On July 23, 2005, Defendants and their accomplices failed to uniformly apply the laws
of the state of Kansas when the presiding judge declared that the docketed appeal of the matter
‘did not stay’ the order rendered, nor future order of this court, though appeal was not yet
complete. Therefore, enforcing coerced control by the abuser (Paul Joseph Ziegler) towards the
plaintiff and minor children of this matter.
38). On July 23, 2005, Defendants and their accomplices failed to uniformly apply the laws
of the state of Kansas when ‘hearsay information’ was presented to the court with all objections
to such was over-ruled. Therefore, enforcing coerced control by the abuser (Paul Joseph
Ziegler) towards the plaintiff and minor children of this matter.
39). On July 23, 2005, Defendants participated in ex parte communications and be
witnessed by plaintiff and her witnesses just minutes prior to the hearing.
40). On July 23, 2005, Defendants and their accomplices retaliated upon a process server of
matters before the U.S. District Court for the District of Kansas, by and through matters for
David Martin Price and Bret D. Landrith (formerly Esquire), with their preplanned actions
against the plaintiff and minor children of 99D2559.
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41). Defendants conspired to place a minor child in eminent danger on July 23, 2005 when
the court ordered the parties youngest minor child to reside with the respondent of 99D2559 after
more than a month of refusing to have ‘parenting time’ with him due to his verbal and emotional
abuse, while the plaintiff of this matter continues to overturn the order of restraining the minor
children to the perimeters of Shawnee County, Kansas until they are of age. Therefore, enforcing
coerced control by the abuser (Paul Joseph Ziegler) towards the plaintiff and minor children of
this matter.
42). On July 23, 2005, Defendants and their accomplices deliberately disregarded all laws
and rules of the court to accomplish their missions when the court ordered the parties youngest
minor child to reside with the respondent of 99D2559 after more than a month of refusing to
have ‘parenting time’ with him due to his verbal and emotional abuse, while the plaintiff of this
matter continues to overturn the order of restraining the minor children to the perimeters of
Shawnee County, Kansas until they are of age. Therefore, enforcing coerced control by the
abuser (Paul Joseph Ziegler) towards the plaintiff and minor children of this matter.
43). On July 23, 2005, Defendants and their accomplices committed libal, slander, fraud,
and perjury upon and within a court of the state of Kansas to achieve the court ordering the
parties youngest minor child to reside with the respondent of 99D2559 after more than a month
of refusing to have ‘parenting time’ with him due to his verbal and emotional abuse, while the
plaintiff of this matter continues to overturn the order of restraining the minor children to the
perimeters of Shawnee County, Kansas until they are of age. See Hunt v Hunt 94D1144, in
which plaintiff witnessed defendant Smith-Wilson perjure herself pertaining to the placement of
the minor children of that matter, as well.
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a). Participants unknown at his time that knew or should have known are therefore
subject to be ammended in as John Doe Defendants.
b). The Public Officials that participated, yet refused to uniformly apply Kansas state law,
and attempt to defuse this matter for what it actually is are in clear violation of abuse of authority
and office to permit this matter to have escalted to Federal Jurisdiction.
44). As the Defendants conspired with Ziegler, the agreed parenting plan tossed out, and
the holiday schedule had all but been abolished. Thanksgiving fell to where it was not only
plaintiff’s holiday but weekend as well. Having the four (4) days of holiday in a row was not
uncommon for Ziegler to have parenting time of the minor children over the past five (5) years,
though this time it was plaintiff’s turn. Plaintiff enjoyed the Topeka Police Department being
dispatched on the Friday after Thanksgiving, only for Ziegler to be more than three (3) hours late
picking up minor Child MEZ on Sunday, without prior notice of any kind. Only to have
defendant Smith-Wilson issue a new set of rules by and through recommendation to deny
plaintiff all but three (3) days of the winter break [December 24, 2005, though January 5, 2006].
Plaintiff arrived at Ziegler’s with the last court Order in hand granting her the ability to retreive
MEZ Christmas morning at 10:00 a.m. Only to be advised by Topeka Police Officers that a case
managers recommendation without judges signature superceded the judges order, no differently
than Ziegler denying plaintiff access to DMZ since 2003.
WHEREFORE, the People of the United States of America by Relator King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
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A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
COUNT III
( KNOWLEDGE OF AND FAILURE TO ACT –
CONSPIRACY TO COVER UP CRIMES )
(Pursuant to 18 USC § 4)
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COMES NOW, the People of the United States of America, by the Relator, King, Pro Se,
and for Count II of its Complaint against Sherri Keller, Amanda Smith-Wilson, Susanna van
Gelder Coxe, Steve Phillips, and John Doe #1, et al. (hereinafter Defendants), alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-44 of Count II as its
paragraphs 1-44 of this Count III.
45). King has made or caused to be made the information of this matter to the offices of
Kansas Attorney General, Phil Kline, the Kansas of Department of SRS, and Battered Women’s
Task Force of Topeka, Kansas, who have failed to address this matter in accordance with the
law. Though each of these departments receive Federally allocated grants to protect the abused
each year as described in Appellant’s Brief in 05-94703-A, Kansas Court of Appeals.
46). King made or caused to be made the information of this matter to the Shawnee County
District Attorney’s Office. With no results, after very little response State v. Paul J. Ziegler;
00D1475 and OOCR2826 When victum’s witness, David Martin Price, was put on trial and
under iterrogation by defendant’s counsel and the court, in this politically motivated sharade of
an unlawful entry charge against defendant.
a). Participants from #42 and #43 are therefore subject to be ammended in as John Doe
Defendants.
b). The Public Officials that participated, continued to refuse to uniformly apply Kansas
state law, and attempt to defuse this matter for what it actually is are in clear violation of abuse
of authority and office to permit this matter to have escalted to Federal Jurisdiction pursuant to
18 USC §§ 2 and 4.
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47). M.E.Z. is now in the residential custody of Paul J. Ziegler, therefore placing the minor
child in eminent danger of her perpetrator, in direct violation of the Kansas Protection From
Abuse Act laws.
48). In this matter alone the following violations of existing Kansas state laws have
occurred in the efforts of the Defendants to maintain their federally allocated funding ‘to assist
families in need’ and ‘state aided foster and adoption programs’:
a). 3 Counts of involuntary servitude.
b). 1 Count of extortion.
c). An ongoing number of Counts of violations to King’s Fourteenth Amendment Rights to
parent her minor child(ren), as they continues to be held hostage to the defendants and their
accomplices within the Court, and not returned to their mother [plaintiff].
d). An ongoing number of Counts of Direct violations of Canon 1. A Judge Shall Uphold
the Integrity and Independence of the Judiciary, by the actions already stated above.
e). An ongoing number of Counts of Direct violations to Canon 2. A Judge Shall Avoid
Impropriety and the Appearance of Impropriety in All of the Judge's Activities, by the
actions already stated above.
f). An ongoing number of Counts of violating Compliance with the Code of Judicial
Conduct, for the actions already stated above.
g). An ongoing number of Counts of misuse of Federal and State Funds, as this Judge
continues to call ‘Hearings’ pertaining to this Matter, yet continues it to avoid resolving it
matters in the best interest of the parties and the law.
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h). In an ongoing number of violations of Article III, Sec. 1, "The Judicial Power of the
United States shall be vested in one supreme court, and in such inferior courts, shall hold their
offices during good behavior."
i). In an ongoing number of violations of ‘Code of Judicial Conduct’, as it provides “Our
legal system is based on the principle that an independent, fair and competent judiciary will
interpret and apply the laws that govern us. The role of the judiciary is central to American
concepts of justice and the rule of law. Intrinsic to all sections of this Rule 2 are the precepts that
judges, individually and collectively, must respect and honor the judicial office as a public trust
and strive to enhance and maintain confidence in our legal system. The judge is an arbiter of
facts and law for the resolution of disputes and a highly visible symbol of government under the
rule of law. Preamble of the Code of Judicial Conduct.”
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
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D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
COUNT IV
[ RACKETEERING ]
[Pursuant to 18 U.S.C. § 1961]
COMES NOW, the Plaintiff, the People of the United States of America, by the Relator,
King, Pro Se, and for Count III of its Complaint against Sherri Keller, Amanda Smith-Wilson,
Susanna van Gelder Coxe, Steve Phillips, and John Doe #1 et al. (hereinafter Defendants),
alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-48 of Count III as
its paragraphs 1-48 of this Count IV.
49). Defendants and their accomplices have created an equitable industry, known to any
reasonable person as ‘the family court division of the county court’.
50). Defendants has conspired with its accomplices, to include insurance companies,
physicians, and pharmacies to secure the natural resources mandated to maintain this industry,
19
known to any reasonable person as America’s children and families’, causing harm to the United
States of America.
51). Defendants have disguised their activities by a ‘numbers game’, as admitted on May
23rd, 2005 by defendant Coxe in 99D2559, to the United States of America, never admitting to
their involvement of the creation of the matters within the ‘family courts’, causing harm to the
United States of America.
52). Defendants have abused its discretion of the Suter v. Artist M., 503 U.S. 347 (1992)
decision to run ramped throughout its parameters in the name of federally allocated funds in
support of ‘programs’ designed to continue the circle and cycle of abuse towards the citizens of
the state of Kansas, and the United States of America, causing harm to the United States of
America.
53). Defendants have created the market for the monies of the United States of America
and the tax payers of this country to never be completely satisfied by its hunger for said funds,
causing harm to the United States of America.
54). Defendants protect its agents and accomplices through immunity and protections of the
state courts to continue its operations. Making or causing to be made, America’s families to
financial destitution in the battle to rescue the children from the industry created by the
Defendants and its accomplices, causing harm to the United States of America.
55). Defendants addresses any opposition to their industry by and through any means
necessary, to include extortion, kidnapping, force and / or court ordered instigation of minoot
incident, just to create a case file, and protect the natural resources of said industry, causing harm
to the United States of America.
20
56). Defendants has forcibly caused financial destruction upon the citizens of Kansas, to
continue its operations and subsidize its industry through the ‘family court system’, causing harm
to the United States of America.
57). Defendants has declared war upon the citizens of Kansas, and the United States of
America, to continue this unwarranted and unwelcome industry into the parameters of the state
of Kansas within the Continental United States of America, causing harm to the United States of
America, all in the name of Federally allocated funding.
58). Defendants have declared the citizens of the state of Kansas as expendable to provide
the industry with the natural resource required for its operations, the minor children of the state
of Kansas, causing harm to the United States of America.
59). Defendants have caused and contributed to the cause of breached their accomplices
contract with the United States of America, specifically “Among its requisite features, an
approved plan must provide that it "shall be in effect in all" of a State's political subdivisions and
"be mandatory upon them," 42 U.S.C. 671(a)(3), and that "reasonable efforts will be made" to
prevent removal of children from their homes and to facilitate reunification of families where
removal has occurred, 671(a)(15), of The Adoption Assistance and Child Welfare Act of 1980,
and therefore have forfeited its entitlements of allocation of Federal Funds under this contract,
and all affiliated contracts to this item, and should be made to reimburse the United States of
America, and the citizens of the Untied States of America for this breach of contract.
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
21
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
COUNT V
( AIDING AND ABETTING )
(Pursuant to 18 USC § 2)
COMES NOW, the Plaintiff, People of the United States of America, by the Relator, King,
Pro Se, and for Count V of its Complaint against Sherri Keller, Amanda Smith-Wilson, Susanna
22
van Gelder Coxe, Steve Philips, and John Doe #1, et al. (hereinafter Defendants), alleges as
follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-59 of Count IV as
its paragraphs 1-59 of this Count V.
60). Plaintiff alleges defendants willfully violated 18 USC § 2, which provides:
(a) Whoever commits an offense against the United States or aids, abets, counsels,
commands, induces or procures its commission, is punishable as a principal.
(b) Whoever willfully causes an act to be done which if directly performed by him or
another would be an offense against the United States, is punishable as a principal.
61). Plaintiff alleges that defendants engaged in activities by and through the fore stated
action to aid and abet Paul Joseph Ziegler, as defendants and their accomplices are rewarded
through monetary gains by and through federally allocated funding for the seizure of DMZ and
MEZ, causing harm to the United States of America.
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
23
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse Building in Topeka, Kansas, or any convenient forum as decided by the U.S. District
Court of the District of Kansas.
COUNT VI
( INVOLUNTARY SERVITUDE )
(Pursuant to the Thirteenth Amendment,
18 U.S.C. §§ 1581, 1583, and 1584, and under 18 U.S.C. § 241
[Criminalized Conspiracies To Interfere With The Exercise Of Constitutional Rights])
COMES NOW, the Plaintiff, the People of the United States of America, by the Relator,
King, Pro Se, and for Count VI of its Complaint against Sherri Keller, Amanda Smith-Wilson,
Susanna van Gelder Coxe, and John Doe #1, et al. (hereinafter Defendants), alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-61 of Count V as its
paragraphs 1-61 of this Count VI.
62). Plaintiff alleges defendants knowingly and willfully violated the Thirteenth
Amendment, 18 U.S.C. §§ 1581, 1583, and 1584, and under 18 U.S.C. § 241 therefore
24
committing Criminalized Conspiracies To Interfere With The Exercise Of Constitutional Rights
by and through;
a). court ordered retention of minor children, who have committed no crime, to the
county lines;
b). court ordered therapy, to profit the insurance companies, and counseling
‘professionals’;
c). court ordered placement of minor children to the residents of their abusers,
promoting the insurance companies when the minors are admitted to the states emergency rooms,
psychological hospitals and / or a life time of adult therapy to overcome the abuse they endured,
and state and federal prisons when the minor children mature and become criminally violent to
society. Willfully causing harm to the United States.
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
25
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
COUNT VII
(Specific Intent To Destroy)
(Pursuant to 18 USC § 1091)
COMES NOW, the Plaintiff, the People of the United States of America, by the Relator,
King, Pro Se, and for Count VII of its Complaint against Sherri Keller, Amanda Smith-Wilson,
Susanna van Gelder Coxe, Steve Phillips and John Doe #1, et al. (hereinafter Defendants),
alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-62 of Count VI as
its paragraphs 1-62 of this Count VII.
63). Plaintiff alleges the defendants willfully and intentionally violated 18 USC § 1091 to
supply their state industry its only required natural resource, the minor children of the state, by
and through ‘state family court’, as the lower financially funded families are irreparably harmed
26
in their attempts to protect their children while a bias court drains them of their financial and
emotional standings in their efforts. Willfully causing harm to the United States.
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
27
COUNT VIII
(Child Abuse Reporting)
(Pursuant to 42 USC § 13031)
COMES NOW, the Plaintiff, the People of the United States of America, by the Relator,
King, Pro Se, and for Count VIII of its Complaint against Sherri Keller, Amanda Smith-Wilson,
Susanna van Gelder Coxe, Steve Phillips, and John Doe #1, et al. (hereinafter Defendants),
alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-63 of Count VII as
its paragraphs 1-63 of this Count VIII.
64). Plaintiff alleges that defendant abused its authority of Child Abuse Reporting pursuant
to the provisions of 42 USC § 13031, specifically; §§ (d) and (e).
65). Plaintiff alleges that defendants use the provisions of 42 USC § 13031 (d) and (e) to
stalk lower income families and prey upon their lack of financial standing to seize their children
as the natural resource of the state created industry any reasonable person calls ‘state family
court’. Willfully causing harm to the United States.
For the purposes of this action ‘state family court’ actions are defined as any and all matter
pertaining to rights of parents to raise their children and children to be raised by their biological
families to include, but are not limited to, adoption cases, foster care placement cases, alleged
abusive spouse / former spouse cases, alleged negligent parent cases and other like matters that
would fall under the jurisdiction of the family courts of the state and federal monies are allocated
to any agency to address and / or partake in said matters, as well as, the state’s lack of
jurisdiction to ‘micro manage’ any household without just cause. Troxel, US No. 99—138.
28
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
COUNT IX
(Promotion of Hate Crimes)
29
(Violations of 42 U.S.C. §§ 1981, 1982, 1983, and 1985 (3))
COMES NOW, the Plaintiff, the People of the United States of America, by the Relator,
King, Pro Se, and for Count IX of its Complaint against Sherri Keller, Amanda Smith-Wilson,
Susanna van Gelder Coxe, Steve Phillips, and John Doe #1, et al. (hereinafter Defendants),
alleges as follows:
1). Plaintiff hereby adopts by this reference and realleges paragraphs 1-65 of Count VIII as
its paragraphs 1-65 of this Count IX.
66). Plaintiff alleges that defendants willfully promote hate crimes of former relationships
by and through their ‘state family court’ industry, by means of:
a). court ordered family counseling,
b). case management,
c). family services,
d). failure to make or cause to be made enforcement of court orders by the local law
enforcement agencies,
e). failure to address emotional, verbal, and mental abuse cases equally to physical
abuse cases, pursuant to the Federal and Kansas Protection From Abuse Act.
f). failure to reunite families of ‘state family court’ jurisdiction,
g). failure to provide equal application of law in ‘state family court’ actions.
67). Plaintiff alleges that defendants willfully violate the victims constitutionally protected
rights as provided by 42 U.S.C. §§ 1981, 1982, 1983, and 1985 (3)), as the state and their agents
shop for quality resources within its borders, namely the minor children of the state. Willfully
causing harm to the United States of America.
30
WHEREFORE, the People of the United States of America by Relator, King, prays that
this court give judgment in it favor against the Defendant, and issue orders in accordance with
the False Claims Act, 31 U.S.C. § 3732 (a), specifically:
A). Defendant cease and desist from violating the False Claims Act, 31 U.S.C. §
3729 et seq.;
B). Defendant pay a compensatory amount equal to three times the amount of
damages the United States of America has sustained for each false claim by Defendant, plus a
civil penalty of $10,000.00 submitted prior to April 26, 2000, for any false claim submitted on or
after submitted April 26, 2000, and the costs of this action pursuant to 31 U.S.C. § 3729(a);
C). Defendant pay the Relator’s reasonable costs and expenses, including reasonable
attorneys fees, pursuant to 31 U.S.C. § 3730(d)(1);
D). That Relator be awarded the statutory percentage of the amount received by the
government pursuant to 31 U.S.C. § 3730(d)(1); and
E). Such other and further relief as this Court deems just and proper.
F). King seeks that the Relator and minor child MEZ be granted a PFA and TRO
from the participants of this action in the manner of which that the Defendants are temporarily
restrained from the action of repeatedly and willfully violating the Kansas Protection From
Abuse Act, thereby placing the Relator and the minor child in imminent danger, with the minor
child in the sole care, control and custody of the Relator (King) as defined by Kansas statute.
REQUEST FOR TRIAL BY JURY
Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a
trial by jury.
31
DESIGNATION OF TRIAL
Designation of Trial shall be at U.S. District Court for the District of Kansas, 490 U.S.
Courthouse in Topeka, Kansas, or any convenient forum as decided by the U.S. District Court of
the District of Kansas.
Respectfully submitted,
___________________________________, .
Janice Lynn King
Plaintiff, Pro Se
3121 S.E. Fremont Street
Topeka, Kansas 66605
(785) 267-5132
32
CERTIFICATE OF SERVICE
[Pursuant to KSA 60-205]
The undersigned hereby certifies that a true and correct copy of the foregoing
document in the above-captioned matter was deposited in the United States mail, first-class
postage prepaid, addressed to:
Sherri Keller
SCDC Case Management Division
200 SE 7th
Topeka, Kansas 66601
Amanda Smith-Wilson
SCDC Case Management Division
200 SE 7th
Topeka, Kansas 66601
Susanna vanGelger Coxe
525 S.W. Topeka Blvd.
Topeka, Kansas 66603
Steve Phillips
Kansas Assistant Attorney General
120 SW 10th Avenue
Topeka, Kansas 66612
on the 3rd day of January, 2006.
Respectfully submitted
___________________________________, .
Janice Lynn King
Plaintiff, Pro Se
3121 S.E. Fremont Street
Topeka, Kansas 66605
(785) 267-5132
33