grifcom3-15-11.doc - Thirst For Justice

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grifcom3-15-11.doc - Thirst For Justice Powered By Docstoc (GrifCCSDd/l3-11-11)
9/1/10, b.30, c. m.   n. 105 p2
Time and resources consumed on amended complaint of 9/9/09
9/5/09 – 1 hour, 9/8/09 – 14:00 –
… …. … … … … … …
12/17/09 12:45 p.m. .. …., …. 12/23/09 – 14:00 - …, …, …, 12/28/09 -12:00-14:00, 12/29/09 19:15 -
, 8/6/10, 8/15/10, 8/25/10, 9/1/10 - 8:00-18:00
3/8/11 – 3/15/11 –
Document List of 3/11/11
   1. D/L of 3/11/11
   2. Il Sup. Ct. R. 298 Petition
   3. Amended Complaint of 3/11/11
  4. Motion to examine court upop with audio recording device if 298 is not granted w/n 7 days of 3/15/11

                       CHANCERY DIVISION

Robert More, Estate of   Robert J. More, ISMA Campaign to Make the World Safe for Innocence Once
Again, Mrs. W.R. More, Co-plaintiffs, Elizabeth, Luke, Henry, Vincent, Blaise, Lonigro – Assignee
v                       Circuit Court Case       No.
(all individual Defendants named herein are sued in their official and individual capacities &
all Municipal Government Entities named herein are sued as Monell v Dept. of Social Services of
the City of New York, Defendants)
Cook County, IL, Sheriff‘s Department      (―CCSD‖) Sergeant   (―SGT‖) Jennifer Griffith,    Cook
County, IL Sheriff Thomas Dart, CCSD SGT Quimque, CCSD SGT Bergfalk, CCSD Deputy D. Danatulo,
CCSD Deputy Koppe, in individual and Official Capacities, CCS T. Dart and Cook County, IL in
Monell Capacity as Well, CCSD Chief Counsel Mr. Peter Kramer, CCSD Lieutenant Prescott, CCSD
Chief of Court Security at the R. Daley Center Mr. Nolan,    Cook County Board of Commissioners
(―CCBC‖) President Mr. T. Stroger, CCBC, CCBC Commissioners #1-15 (all Commissioners other than
the alleged two who endeavored to prevent the elimination of the public speakers component of
CCBC Board Meetings) in individual and official capacities, CCBC and CCBC President Stroger in
Monell Capacity as Well, CCBC President‘s Counsel Mr. R. Velasquez, Clerk of        the CCCC, IL
Dorothy Brown, CCCC Deputy Clerk Who Threw RJM‘s Papers onto the Floor of the Courtroom in Room
304 of the Courthouse at 555 W. Harrison St. in Chicago, IL, in October of 2008, Circuit Court
of Cook County, IL (―CCCC‖) Judge Marvin Luckman, CCCC Judge Kuriakos Ceisel, CCCC Judge T. M.
Donnelly, Cook County State‘s Attorney (―CCSA‖) R. Devine, CCSA,      A. Alvarez, Asst. CCSA and
Supervisor, Charis Valente, Asst. CCSA and Supervisors – John and Jane Does #1-8, Asst. CCSA John
and Jane Does #1-6, Cook County Public Defender (―CCPD‖) Edwin Burrell, Asst. CCPD J. Stachler,
Asst. CCPD Mr. Theodore Green, Cook County, IL Forensic Services Clinic (―FSC‖) , CC, IL FSC
Director M. Markos, CCSD Deputies John Does #1&2 who informed RJM that if RJM did not leave the
Floor of the FSC on ____, that RJM would ―be arrested‖, Cook County Jail (―CCJ‖) Intake Person
John Doe, CCJ, Cook County Health And Hospital Services Director, Mr. T. Foley, Isaac Ray Center
Director Dr. Cavanaugh, Cermak Health Services (―CHS‖) Director, Dr. D. Carrington, CHS Dr.
Matthews, CHS – Registered Nurse (―RN‖)Mr. Augusta Alabi, CHS RN Manuel Manalastas, CHS Dr. John
Doe, CHS, CHS Clerks John Does #1-3, CCSD‘s Esposito And John Does #1-4 Involved In Haldol
Injections Of RJM As Restrainers In Regard TheretoCHS, CHS Clerks John Does #1-3, CCSD‘s Esposito
and John Does #1-4 Involved in Haldol Injections of RJM, CCSD Lieutenant J. Doe, CCSD Chief at
555 W. Harrison St. Chicago, IL Courthouse, Jane Doe, CCSD Sgt‘s Renkas & Kush, CCSD Wilson,
Hennessey, O‘Niell, Simpson, Mr. N. Albuquerque, CCSD IAD Director Raymond Zene, CCSD Employees
John and Jane Does #1-8, CCCC Chief Judge T. Evans, CCCC First Municipal Presiding Judge K.
Wright,   Official Court Reporters,    Mr. Jean Kiriazes, CCHS Risk Management Supervisor – As
Conditional Defendant, Asst. CCSA's Nenye Uche and Bret Franco, Defendants

Complaint of 3/11/11 Which is Edited Version of Complaint of 9/1/10 Submitted as Amended Version
of   Complaint Presented on 6/30/10 to this Court Along with IL. S.Ct. 298 Petition, to be
Superceded by 3/21/11 and Bi-weekly Thereafter Until Court Will have Provided Confirmation that
it Would Be Its Position that "Compliance Will Have Been Adequately Accomplished", if at Any
Given Juncture, It Would be Its Position that it Still Would Not Have Been

This is the second proposed amended complaint regarding the complaint presented to this Court
("Court") on 6/30/10, which was a refiling of Case # 09 CH 18934 ("09 CH18934"), which case was
nonsuited shortly before such date, which RJM has had to compose in "Word Pad" as RJM cannot get
any other software to adequately function for such composition. Numerous "trespass on the case"
Defendants and/or Defendants whose alleged and/or actual torts in regard to which RJM was
complaining in the complaint presented on 6/30/10, were committed either after 1/1/2009 or have
been ongoing, have been removed from this amended version of the complaint of 6/30/10 in order
to procure the approval of the S. Ct. Rule 298 petition (―298‖) regarding any and all counts
which are time sensitive, as RJM understands himself to be subject to an obligation to continue
to consider the time element of the prosecution of any and all claims in regard to which RJM is
committed to procure relief which have come into being from the false arrest to which RJM was
subjected on 6/13/08 in the R. Daley Center and all of the loss, affliction, grief and travail
which resulted therefrom. It is the intent of the Plaintiff -"RJM" to present to this Court, in
seriatum, a series of    components of a proposed order regarding the adjudication of the 298
petition which is being resubmitted alongherewith, in a form analagous to a presentation of
special interrogatories, regarding each of the Defendants and each of the counts included in this
complaint, so that the problems referenced in the Order issued on 8/2/10 regarding the Complaint
presented on 6/30/10 can be eliminated. Unless there would be some reason that this Court could
not grant the 298 Defendant by Defendant and Count by Count, this method will hopefully enable
RJM to cover the entirety of what RJM understands to constitute the liability to which RJM is
subject in all of its aspects regarding the demonstration of adequate diligence in the continue
prosecution of this case in order to prevent any Defendant named herein from evading liability on
any type of "excessive passage of time" type argument. As of 3/11/11 – having considered Law
Clerk Adam‘s recently (Feb of ‘11) provided observations and instructions regarding the alleged
deficiencies by which the Amended Complaint of 9/2/10 was allegedly plagued, and after having
begun repeatedly to continue to revise this complaint, RJM herein submits it as is, and will file
superceding components weekly until the Il Sup Ct. 298 Petition is granted. RJM is convinced that
there has never been any basis upon which such petition could ever have been justifiably denied
in this case, but in any event, will respectfully demand an opportunity to examine this Court if
the petition which accompanies this complaint is not granted by 3/22/11.

This is a suit in law and equity filed against Defendants in their official and/or individual
capacities for-- without legal authority or just cause-- violating Plaintiff‘s (―JH‖‘s)
unalienable rights, which at all times relevant to the matters in regard to which RJM herein
complains   were protected    by the provisions of     the common law, state administrative and
statutory and federal statutory laws, and/or provisions of the state and federal constitutions
applicable at the time of the developments described herein, inter alia, by falsely imprisoning
and arresting Plaintiff in the Richard J. Daley Center in Chicago, Illinois (henceforth ―the
Daley Center‖ (―RDC‖) and for falsely prosecuting Him without probably cause, and especially for
doing so as part of a pattern of retaliation against many citizens, including Plaintiff, who have
and has exercised their and his constitutionally protected rights to expose the misdeeds of Their
and His public servants, including some of the employees of one of the most powerful occupants
of the Daley Center-- the Sheriff of Cook Country (henceforth ―the Sheriff‖), Whose Office is a
component entity of a political subdivision of the State of Illinois.     Plaintiff thus alleges
illegal actions committed by Defendants that exceeded the scope of Their authority, constituting
an exception to the normal policy that claims against municipal actors in the performance of
their duties are precluded by qualified immunity. Plaintiff seeks declaratory relief in this
suit which RJM is convinced will protect RJM from the types of predations this complaint concerns
and also a preliminary and then a permanent injunction ordering the Sheriff to cease and desist
from the application of any policy, promulgated or de facto, and or practice the effect of which
would be the prevention of Plaintiff‘s using the various courthouses in Cook County as He
hitherto has done and has a right and/or privilege to do in any and all lawful ways.
Secondarily, Plaintiff seeks all other relief to which He is entitled, including compensatory,
and punitive damages.
RJM admits that some of what is contained herein constitutes editorializing,          and/or the
expression of opinion(s)never solicited which do not directly subject any party to liability,
but in RJM's concern to ensure that no predatory activity end up being apprehended as actually
being    contra-predatory or otherwise benign, and in order to otherwise succeed in the
accomplishment of     the objective of       ensuring that no arrogation(s), encroachment(s),
usurpation(s) and/or transgressions ever cause any unjustifiable damage to the interests RJM
is prosecuting this complaint to vindicate, RJM did not see how he could justifiably leave such
out of this complaint (see NAACP v Burton (_U.S._)).
No later than 3/14/11, RJM will have served a copy of       the ―‘More et al   v Griffith et al‘
Settlement Proposal of 3/14/11‖, (see URL herein supra ―(grisetprpo3-14-11)‖)upon the President
of the Cook County Board of Commissioners and upon each of the Commissioners whereof, as well as
upon the Office of the CCSD and CCSA, so that this case can be settled as soon as possible at the
lowest morally acceptable cost to the County Treasury.
According to the principles present in the axiom having its origin in what was once known as
―Christendom‖ Qui nocentibus parcit, innocentibus punit (―He who spares the guilty, punishes the
innocent‖), RJM has not understood that he possessed any morally legitimate choice in regard to
the filing of this complaint except to name each of the Defendants listed in the caption of this
complaint as Defendants in this case, as Defendants named in a case can always be dismissed
therefrom whereas Defendants not originally named in a case cannot always be added thereto.
3. So that inter alia, the appearance of a disposition of ingratitude could never be justifiably
attributed to RJM, RJM herein explains that RJM is not at all oblivious to the fact that there
have been no small number of instances in which RJM has been spared grief and/or shielded from
the types of harms - from which although it is the duty of persons such as RJM to protect His
Majesty‘s little ones (Jn. 21:15 et al) and not to seek to avoid themselves, there is no small
evident net benefit to the Interests of the Noncounterfeit Roman Catholic Church (‖NRCC‖) (as
distinct from the nominally Catholic, de facto Protestant Religion of the Second Vatican Council)
in RJM (and affiliates) avoiding– by the activity of some D‘s listed herein supra and/or by
individuals conducting activity in various positions which necessitates such persons cooperating
to some extent with various     Defendants listed herein supra.   The activity of    a number of
members of   the various entities listed herein as Defendants,        in regard to which RJM is
cognizant, has    no doubt been providing more benefit to the interests of the R.C. Church than
would be provided thereto, were such individuals to be replaced by non-contradegenerates in a
given case. RJM cannot comment upon the information he possesses regarding the activity of      a
number of such type actors whose activity has produced at least some evident benefits for the
interests in regard to which RJM understands that RJM will have to provide an accounting, lest,
in so doing, RJM were to     risk compromising various important interests,…but for purposes of
demonstrating a commitment to the protection of     those same  interests, and to    engender the
confidence of those who might ever find themselves in a position in which the assistance of any
member of   the Institute of St. Michael the Archangel (―ISMA‖) might be of benefit to such
persons, that the assistance of ISMA might be something not to be foregone, RJM herein explains
that at various junctures between the hours of 10:45 a.m. on 6/12/08 and 16:00 p.m. on 12/18/08,
CCSD Sgts. Garrett, Boyd, and Poachie, and CCSD Deputies A. Thomas, Morrissey, Mendoza and P.
Martin, CCSD employees Carol McFadden, Megan Keating and Matthew Burke provided RJM assistance in
one form or another, for which RJM is not at all ungrateful. RJM also notes that CCSD Defendants
listed herein supra Mr. P. Kramer, Sgt. Renkas, Kush and Lt. _________, and CCCC Clerks Cecelia
Jenkins, C. Bolland, F. Healy and Sheryl Holloway (who were not named as D‘s herein) , at various
junctures provided assistance to RJM in RJM‘s endeavors to defeat Lucifer‘s endeavors to injure
that component of what Pope Pius XI referenced as the ―Catholic Cause‖ (Ad Sacerdoti Catholici,
1935) in regard to which RJM understands that RJM will have to provide an accounting, via the
affliction and oppression of RJM in the matters this complaint concerns to an extent such that
were RJM to leave such contributions unacknowledged, RJM would fear accruing a moral arrearage
in regard thereto. So that if it would be the case that if RJM would still be in the theatre of
earthly existence at some future juncture attributable to the fact that at such juncture there
would be some not-adequately reciprocated benefit which RJM would have received and that thus
RJM would be in a state of moral arrearages because of such, that it would not be the case that
such not adequately reciprocated benefit at such juncture could possibly be attributed to RJM‘s
knowingly, and therefore demonstrably culpably, having left any arrangement in place in which a
not-adequately reciprocated benefit would be the only reason which if RJM were to possess the
entity referenced in moral theology texts as ―sanctifying grace‖ at such juncture, His Majesty
Christus Rex would not have granted RJM some type of individual ―reprieve‖ along the lines
referenced collectively in      Mt. 24:22, RJM has included the averments contained herein
immediately supra, whatever their legal significance. RJM has come to understand in the marrow of
his bones – at least for a lightweight, wretched, Non-Isaac Jogues/John de Brebauf, the reasons
St. Teresa referred to the tour of duty in the theatre of earthly existence as a ‗bad night in a
bad inn‖, and why when hearing the ringing of the church bell each hour, she would say a prayer
of gratitude (and sometimes demonstrably rejoice) that at such juncture(s) there would be one
less hour in which she could ever commit a mortal sin than there had been        at the previous
ringing of such church bell (acknowledging that the condition of not subjectively apprehending
the presence of any culpability for any sin in one‘s record of activity at a given juncture
cannot ever, by itself,    constitute a basis upon which one might conclude that he possesses
sanctifying grace (1 Cor. 4:4)      and why Padre Pio too, so often prayed that the problem of
conditional salvation for him, be forever ―put into the rearview mirror‖ and out of the devil‘s
reach. If RJM knew more clearly what RJM would have to now do to protect his record of conduct
from any culpability rising to the level of a fully deliberate venial sin, or even a voluntary
fault, RJM would do whatever RJM would have to do to protect such record and procure the
condition of certainty, that if RJM were to end up in hell or to be left in this vale of tears
one minute more than would have been unavoidable, that such condition could not be attributed to
any culpable disposition of RJM, if this postulation even makes any sense (admitting that if it
does not, that RJM has incurred a moral arrearage in inserting it herein and leaving those
obliged to read this complaint having to read it - which demonstrates why RJM is so committed to
get out of here asap - to eliminate the possibility of diminishing his own prospects of
eventually procuring, howsoever undeservedly, a happy ending to that component of the entirety
of the travail, affliction and grief of the fallen human condition in the vale of tears, which
has been RJM‘s ―portion whereof to be voluntarily borne‖ (Matt.11:30)).
4. If RJM is not going to succeed in procuring a place in purgatory prior to the time at which
RJM will have to accomplish something in the prosecution of this case subsequent to the filing
of this complaint, RJM herein explains that RJM has sought a nihil obstat from the ISMA CLT in
regard to the defeat of     the predations and the rectification of the injustices this case
concerns and that it is only because RJM cannot procure such nihil obstat without the filing of
this complaint that RJM is burdened with filing it and all others concerned are burdened with
having to deal with it.
5. Accompanying this complaint is a ―Declaration …Unconstitutionality…RJM‖ (Doc. #_______), (see
also: URL at top LHC of this document ―Dec… of Unconst….RJM‖ .
6. Were a copy of such document or something similar to now be signed by a judge of      any Court
in the State of IL possessing jurisdiction over the matters this case concerns, regarding the
contents of the criminal code presently operative in the State of IL, as such might be applied
to RJM et al‘s endeavors to rectify the injustices this complaint concerns in the absence of the
issuance of such order or something similar, neither RJM nor anyone conducting activity in the IL
Court System would be burdened by any adjudication of this case in the future.
7. Had RJM possessed a signed copy of such type document on 10/21/04, RJM could, even with his
left arm in a full length cast,      have endeavored to subdue and arrest the Obama supporting
miscreant who blew out RJM‘s eardrum       on that date with his megaphone and none of         the
afflictions, grief, travails, burdens and expenses incurred by all who have incurred such
regarding the matters this case concerns would have ever transpired, or, even better, RJM could
have   even just taken the municipal code violating-megaphone from the batterer prior to the
battery in the first place.
8. In a world as close to having evidently been completely abandoned by God as is that in which
this document is being composed, afflictions, travail, grief and burdens other than those this
complaint concerns would no doubt have been encountered     by RJM   in the period from 10/21/04
until today but the ones this case concerns would not have been.
9. In case RJM would procure a place in purgatory, or just end up in hell,           prior to the
vindication of the rights of    His Majesty, Christus Rex,   which this complaint concerns; as a
matter of record which those entitled to consideration from RJM might consider, RJM herein
declares   that beyond RJM‘s commitment to procure declaratory relief which will prevent the
perpetration of the types of crimes this complaint concerns in the future and monetary damages to
make RJM and those entitled to consideration from RJM, whole for the injuries unjustifiably
incurred by us, RJM also herein proclaims RJM‘s commitment to get all of those responsible for
the perpetration of crimes in such matters, adequately prosecuted and punished and removed from
the government offices in which the perpetrators of such crimes were conducting activity in the
perpetration of such crimes. The piles of paperwork generated in the last weeks of May of 2010
regarding the probable cause hearing/appt of special prosecutor projects in which RJM was the
protagonist, attest to the efforts of RJM in such regard
10. In this vein, RJM herein invites Mr. T. Dart to resign from the Office of Cook County Sheriff
immediately, and if there is even the slightest sense of shame in him to do public penance for
the appalling priorities according to which he has conducted the activity which he has conducted
over the past several years, most notably his atrocious participation in whatever         sodomite
parades he has been a participant. This invitation is likewise extended to any other Defendant
included in this case who has participated in any such type abomination, which would include
Dorothy Brown, and whomever else it would include (CCBC Members who supported the ―Gay Games‖)
and all of    those herein listed who have supported any other type of      grave sin such as the
abortions perpetrated at Stroger Hospital. RJM proposes that either Deputy Wallach or Pettigrew
be appointed as interm Sheriff.
11. The egregious disrespect for the rights of His Majesty demonstrated by those referenced
herein supra, has indisputably created a climate in which the types of crimes, predations and
torts this complaint concerns are the natural product of dispositions of Chief Policy Makers
which demonstrate an extreme indifference to the     requirements of    the natural law, which in
turn causes the proliferation of sin and its effects, causing incalculable destruction to the
social order.
11a., RJM does not consent to participate in any proceedings which would be conducted in       the
adjudication of this case except in the Courtrooms of whatever Contra-degenerates are presently
conducting activity in the Chancery Division of the CCCC.

Jurisdiction And Venue

12. This Court, being a state court of general jurisdiction, possesses—pursuant to    § 9 of Art.
VI of the Illinois Constitution and the Declaratory Action Act 735 ILCS 5/2-701, subject matter
jurisdiction to entertain and to decide Plaintiff‘s justiciable claims of a common law, statutory
law,   and equitable nature, as the State Courts of the State of IL are courts of general and
unlimited jurisdiction. Herb v Pitcairn (_U.S._).      The claims of a federal     constitutional
dimension included herein are subject to this Court‘s jurisdiction pursuant to the authority
postulated in among other SCOTUS opinions those of Herb supra, Claflin v Houseman, (_U.S._) and
Lockerty v Phillips (_U.S._) which point the Supreme Court of the State of IL had to explain to
the IL App. Ct, First District in the opinion recently postulated in Blount v Stroud ( _ Ill. 3d
B) All Parties include in this complaint are located in or reside in, or were conducting the
activity in regard to which the claims herein addressed concern, in      Cook County, IL, so this
Court possesses personal jurisdiction over all Defendants listed herein.

Barest minimum of    factual predicates necessary to sustain claims concerned until Defendants
answer complaint:
On 6/13/08 ("RJM mistakenly pled the date of "6/12/09" in Case # 09 CH 18934, Robert J. More
proceeded to the Courtroom of the Hon. P. Flynn in room 2408 of the R. Daley Center in regard
to Case # 08CH 9978 (More v Obama for Senate Campaign, et al), as RJM had filed a motion to be
addressed on such date at 9:45 a.m. in such case.
RJM proceeded to go to Courtroom 2601 on another matter at 10:00 a.m.
RJM returned to Courtroom 2408 (―2408‖) shortly thereafter.
At about 10:45 a.m 2408 Case Management Coordinator, Barbara _________ (―CMCB‖) informed RJM that
case # 08 CH 9978 had been dismissed and that an order declaring such had been placed in the
―orders bin‖ outside of 2408, a copy of which RJM confirmed that he had received by that time.
RJM then informed CMCB that RJM would compose and submit a motion to have the case recalled on
6/13/08, which would include petitions for other relief as well, within minutes of that time.
The great majority of the details regarding what transpired next need not be detailed herein on
this occasion, according to RJM‘s understanding of       the compliance-accomplishment threshold
according to which RJM must plead the causes of action herein pled in order to get a S.C.R. 298
petition granted in regard to this complaint on 9/1/10.
Based upon the plethora of lies CCSD Sgt Griffith and Deputy Danatulo told on the witness stand
on 12/17/08, under penalty of perjury, in the criminal case adjudicated regarding the matters
this complaint concerns, RJM would not see how RJM could possibly justify pleading this case more
thoroughly than it is herein being pled, prior to RJM‘s being permitted to depose everyone who
was in 2408 at the time of    the arrest perpetrated on 6/13/08 in this case, and everyone who
conducted activity in regard to such matter prior to 12/17/08 and indeed prior to the date upon
which RJM would conduct such depositions, as there is every reason to believe that the problem of
the tailoring of witness testimony to the contents of a complaint in order to evade liability
will be a serious one in the adjudication of this case (―testilying‖ as the phenomena is
{Parenthetically, RJM herein explains that if the 298 is not granted in regard to this case,
RJM will challenge the constitutionality as applied of the provisions of      whatever statute or
IL. Supreme Court Rule would allegedly have been utilized to deny such petition.
Beyond that, if it were not to be granted and no explanation were to accompany any conjectural
denial whereof, which would demonstrate that any such type conjectural denial would      not lack
legitimacy, a “Proposal to Demonstrate Cause” why criminal charges ought not be instituted
against whomever would have been responsible for any denial of     the 298 ever issued, would be
presented to this Court in regard to this complaint. Likewise in the type of scenario described
herein, a “Proposal to Demonstrate Cause” why a claim for civil damages ought not be filed, would
be presented to this Court.
RJM would have filed this case in the local federal court, except that there are two filing
restrictions still - entirely unjustifiably imposed – in place     upon RJM in such court which
would prevent the filing of   anything RJM would endeavor to file therein.
RJM has never discontinued his endeavors to get such restrictions removed, but as of 3/9/11, RJM
has not succeeded in accomplishing the removal thereof.
Should any attorney representing any Defendant named herein supra endeavor to claim that RJM has
not succeeded in getting some objective or other accomplished “soon enough” or prior to some date
or other, RJM will with great reluctance because of the many redeeming qualities Judge Kinnaird
has demonstrated, have to add Judge Kinnaird as a Defendant to this case, as the complaints she
received on 6/30 and 9/2 of ’10 were according to RJM’s understanding of all of the legal
authority that was applicable to the      adjudication of the 298’s presented along with such
complaints, adequate for purposes of the issuance and correlative      procurement by RJM   of an
order directing the    Court Clerk to file the complaints presented on such dates without any
payment of any fee(s). Indeed, it is most lamentably the fact that a condemnation of various
courses of conducted according to which activity conducted by Judge Kinnaird in various instances
has been conducted has had to have been posted in the website of the ISMA Br. #4, in which an SST
has for her has also been posted, but this is in fact the case.
It is RJMs’ position that the fact that RJM has filed this amended complaint in this case in no
way constitutes any type of affirmation, or approval of, any claim ever made by any government
official that either of the complaints submitted on 6/30 or 9/2 of 2010 in regard to this case,
were in any way substantially deficient to a level of deficiency sufficient to justify the non-
granting of the 298’s submitted to this Court along with such complaints in the first instance.
RJM herein simply explains that a number of individuals in 2408 advised RJM to proceed to room
802 and file a motion there.
RJM explained that he was filing a ―Motion to Recall the Case on 6/12/08, Instanter‖ (or 6/13/08)
in 2408 on 6/12/08 (or 6/13/08), as RJM possessed a constitutionally protected right to do so.
 At this time CCSD Deputies Dattulo and Koppe were in 2408.
Deputy Koppe (―DK‖) clasped RJM‘s right arm and proceeded to endeavor to pull RJM away from the
RJM demanded that DK release RJM‘s arm.
DK released RJM‘s arm.
RJM proposed that some supervisor other than Sgts. Quimque or Bergfalk be summonsed to 2408, and
proposed that it be Sgt Garrett or Boyd who would be so summonsed.
Deputy Dattulo or Koppe, at RJM‘s insistence, summonsed a supervisor.
Minutes later, CCSD Sgts. Griffith, Bergfalk and Quimque entered 2408.
RJM explained what had occurred, as did Dattulo and Koppe.
Griffith informed RJM that RJM had to leave the courtroom.
In a voice of conversational tone, speaking with his head in the direction of Griffith, with no
background noise then presently rendering communication difficult, RJM informed all concerned
that RJM would leave the 2408 as soon as RJM received a confirmation that either the Court had
ordered RJM to leave, that the courtroom was closed for the morning or that RJM would be arrested
if RJM refused to leave without any of the types of confirmations described herein supra.
No such type confirmation was provided.
Bergfalk and Griffith both addressed RJM.
RJM again explained that all RJM understood that RJM needed to procure in order to possess the
authority to leave 2408 at what was then very shortly after 11:00 a.m. was           the type of
confirmation described herein supra, emphasizing that RJM     would leave without delay    if the
consequences of RJM‘s not leaving would be that RJM would be arrested for not leaving
The purpose of RJM‘s engaging in the colloquy described herein supra, is the principle volenti
non fit injuria (―he who consents has no injury‖), as an individual who would find him or her
self in the position in which RJM found himself as described herein supra, cannot voluntarily
accede to the mandate contained in an unjust order from a member of    a policing entity (―MPE‖)
without risking jeopardizing any claim to relief     which might be due him or her in a given
situation upon the shoals of a claim from a given (collection of ) MPE(‘s) that the addressee of
a given illegitimate order would have voluntarily acceded thereto or that according to some other
argument, no act    constituting any utilization of     any   coercive aspect of an exercise of
government authority would have ever been executed as a proximate cause of any injury alleged to
have been unjustifiably inflicted.
RJM then opined that he was calling ―the Office of Legal Counsel‖
As RJM dialed 603-3396, Griffith moved into RJM‘s person space (the area within RJM‘s reach in an
arrangement in which such positioning would not be unavoidable and would not be due to RJM‘s
having provided at least tacit approval of such positioning).
As RJM heard Mr. M. Burke answer the phone, Griffith grabbed RJM‘s hand causing RJM to drop the
phone onto the ground and informed RJM that RJM was under arrest.
RJM rose from the pew in which RJM had been seated and was escorted by Griffith et al out of
RJM inquired as to the basis for the arrest and Griffith stated: ―Criminal Trespass to State
Supported Land.‖ (―CTSSL‖)
Quimque informed RJM that he had to ―search your bag‖ referring to the waist pack RJM customarily
Quimque made physical contact with RJM‘s body in an insulting and provoking         manner as he
removed such pack from RJM‘s person.
RJM was escorted to the lock-up in the basement of the R. Daley Center.
On 12/17/08, Judge T. M. Donnelly granted a directed verdict for the Defendant Robert J. More and
against the State of IL, in Criminal Case # 08 MC 123741901, which was the case in which a
conviction was sought for the CTSSL Griffith alleged RJM perpetrated, explaining that the trial
testimony of both Griffith and Dattulo had been thoroughly impeached by the Defense and that the
contents of   a  statement of Griffith which the State produced at trial – a copy of a report
Griffith submitted to her supervisors on 6/13/08, that stated that ―More said he would leave if
he would be arrested‖, exonerated Defendant Robert J. More of any criminal culpability.
Notwithstanding that Asst. CCSA's Franco and Uche transmitted to RJM's counsel on the scheduled
day of trial a copy of such statement, Franco and Uche still proceeded to endeavor to procure a
conviction of   RJM regarding the activity which the Court ultimately decided was completely
protected via RJM's notification of his intent to depart from courtroom 2408, were he to be
subject to arrest for refusing to depart such room at the time immediately before RJM was in fact
arrested in regard to the matters this complaint concerns (―these matters‖).

Count One: Common Law False Imprisonment & False Arrest Against Griffith, Bergfalk, Quimque,
48. Paragraphs # 13- 46 of this Complaint are incorporated herein in their entirety, as though
fully set forth herein.
49.     False Imprisonment has traditionally been defined as any unlawful, intentional show of
force by which a person is compelled to remain in a place in which he or she does not wish to
remain and is subject to no duty to remain, thus depriving him or her of liberty and property
interests and the tort of False Arrest has traditionally been defined as the assertion of lawful
authority to arrest with intention to effect an arrest that restrains (whether tangibly or
intangibly) the person arrested, who reasonably believes that he or she has been arrested and
who, therefore, does not attempt to escape from the restraint exerted for fear of being found
guilty of resisting arrest.
50. At all times relevant to the matters this complaint concerns (―At all times relevant‖),
Plaintiff possessed    a common law right to be free from being falsely imprisoned by anyone,
including the herein named Defendants.
51. At all times relevant, Defendants and unknown others were subject to a common law, and
Official Misconduct 720 ILCS 5/33-3 duty, to refrain from falsely imprisoning Plaintiff, as well
as a duty to avoid battering, kidnapping or depriving RJM of any measure of consideration
guaranteed him by the Constitution and laws of   the U.S and/or of the State of IL.
52. At all times relevant, the Defendants named in this Count were subject to the above said
duties, notwithstanding the fact that they may not be ―amenable to justice,‖ according to the
general principle of law articulated in 720 ILCS 5/8-2.1(b)(3) - that is, "not amendable to any
type of justice not requiring the utilization of vigilante methods in no way lacking morally
53. On 6/13/08, in the R. Daley Center, without lawful authority or just cause, the Defendants
named in this Count breached said duties and deprived Plaintiff of His protected liberty and
property interests to be free from false imprisonment when They compelled Him-- both before and
after His arrest—to stay put and later to go with them into the Daley Center Lock-up Facility
for allegedly ―interfer[ing] with another person‘s lawful use or enjoyment of such building or
       54. Plaintiff was injured by the actions of the Defendants named in this Count in that He
was prevented from remaining in a public area – namely a public courtroom – that of 2408 of the
R. Daley Center, by said Defendants, who committed said deeds without lawful authority or just
cause, thus preventing RJM from exercising his right to petition the government for the redress
of grievances in the form of accessing a civil court in regard to a civil case (Chambers v
Baltimore and Ohio Railroad (_U.S._)) , and Plaintiff was injured in that Plaintiff lost time -
in regard to which loss He will eventually have to provide an accounting, when He was forced into
custody and when He was then compelled to spend money (thru a loan from his elderly mother)
unnecessarily in order to defend Himself in criminal court as well as incurring the enormous
costs of    the subsequent court appearances, BCX exam excursions, incarceration, research and
composition     ventures, meetings with the Attorneys who represented him, detentions for
subsequent contempts which were entirely unjustified, and the     dispersion of   his belongings.
Finally, Plaintiff was and is injured in that He was and is compelled to endure the on-going
private humiliation and emotional distress of the previously mentioned indignities.
55. The Defendants named in this Count were the proximate causes of Plaintiff‘s injuries, because
those injuries were a direct result of Their personal words and/or deeds.
       56. Plaintiff prays for a jury trial on all matters triable by jury, declaratory judgment
against the above named Defendants in this Count for the causes brought herein, compensatory
damages of over $50,000.00 from each Defendant, punitive damages, injunctions as requested herein
infra, and any other relief that whatever jury decides this case would find just and equitable.

 Equitable Relief Requested
If this Court will not now simply provide a signature on RJM‘s ―Declaration of
Unconstitutionality …RJM‖ (RJM C:6/11b19 n46 p/9) (see also:
(DecofUncon), at this juncture, then RJM must continue and herein adds:
57. Paragraphs 13-46 of this Complaint are incorporated herein in their entirety, as if fully
set forth herein.
58. RJM respectfully moves this Court to issue an order in regard to the case this complaint
concerns (―this case‖) prior to the conducting of any activity in regard to it other than the
adjudication of the matter of   the audio(-video) recording of    any and all proceedings which
might ever be conducted in it, that absolutely no proceedings may be conducted in this case
except in an arrangement in which no such type proceeding would ever be conducted herein unless
and until a confirmation in writing would have been received by this Court      from all parties
having a direct and legally cognizable interest    in the adjudication hereof, and entered into
whatever trial court record would be created in regard to it, that each and every such party
would understand that none of such parties would ever have to participate in any proceeding ever
conducted in regard hereto, except and unless either it would have been the case that no
interference would have been posited with any endeavors which would ever have been undertaken for
purposes of   the creation of    an audio-recording of any such proceeding(s) as might ever be
conducted herein and that no such type proceeding(s) could likewise be conducted unless and until
an order would be in place and operative which would prevent any interference with the audio-
video recording of any and all activity of any individual which would ever be conducted in any
government building containing any court of the State of IL, or quasi-court thereof, other than
activity which would be conducted in any courtroom, lockerroom and or washroom thereof.
In other words, RJM does not consent to ever participate in any activity in which anyone who
would be conducting activity as a representative official of any government entity would be
conducting activity which would not be monitored by an audio (in the courtroom) or audio-
video(everywhere and place other than those areas referenced herein supra) recording device, the
product of which in regard to a given proceeding would be available to any party involved in
any activity ever conducted therein in regard to this case or any other activity in regard to
which RJM would find it necessary to access any government building (while there are number of
individuals conducting activity in the court system presently operative in the state of       IL,
without whose activity conditions therein would no doubt be far worse than they are presently
found to be, it is the understanding of the matter this conveyance concerns in regard to which
RJM understands that he    will have to provide an accounting, that the combination of morally
bankrupt individuals    conducting activity as government officials, a disparity of weaponry
between predation perpetrators and their victims, conditions which provide the capacity       and
opportunity   for the    perpetration of    predations under the color of law and pretext of
legitimacy upon unarmed victims thereof, and a lack of monitoring in a form which enables all of
those victimized by the types of predations perpetrated in
courtrooms in which activity is not adequately monitored    on a continual basis    [to possess a
record of   what [occurs] [would have occurred] in the adjudication of      a given case– is an
arrangement devastatingly destructive to the interests of the Roman Catholic Church in regard
to which RJM understands that RJM will have to provide an accounting, and it is RJM‘s
understanding that no such type arrangement can be permitted to remain in place without those
possessing the means to eliminate such conditions incurring sinful culpability, not excluding
gravely sinful culpability (1 Tim. 5:22, Eph. 5:8, et al) for any and all culpable neglect in
not effecting the elimination of such conditions or at least having adequately endeavored to
accomplish the elimination thereof. Even the presence in a given case, of a tribunal presider of
the probity of St. Alphonsus Liguori would not be enough to deter many of      the predators who
frequent IL Courts from endeavoring to use the presently operative court system to defraud their
 59. RJM herein respectfully moves this Honorable Court to grant the relief described herein
infra in the version of the Proposed Statute whose contents are explicated herein in:

725 ILCS 5/103-10. A/V Evidence Disclosure to Certain Suspects at Time of Release
or Decision to Hold, Mandatory.

(a) Every law enforcement officer in Illinois or in any political subdivision thereof who
has an encounter with a private citizen in a governmental building that results in a governmental
decision to arrest said citizen as a criminal suspect, shall make such arrest only
in the good faith belief that three conditions do and shall exist:
(1) that there was an audio-visual (hereinafter ―a-v‖) recording made of the encounter
that allegedly provides prima facie justification for the arrest,
(2) that said a-v recording shall be automatically preserved for 6 months without
a special notice or motion being necessary for said preservation,
(3) (i) that the arresting or supervising officer in charge of a given arrest shall, at the time
of said
suspect‘s release on personal recognizance or on bail, present to said suspect an intelligibly
high quality DVD reproduction of the audio-visual recording of said encounter that
allegedly justified the arrest together with the written notice of the specific offense for
which the suspect was arrested, which notice is already required on the bond form.
(ii) that in the event that said suspect is not released within the customary 48
(or if on a weekend 72) hours but is held without bail pending trial, said a-v DVD together
with a copy of said written notice of the charge shall, within 48 (or if on a weekend
72) hours of said suspect‘s arrest, as authorized by the suspect, be given to a public
defender, a private attorney, or one of one or more designated relative(s) or friend(s) of a
given arrestee as
soon thereafter as     any of    such type actors    arrives to receive same, according to the
incarcerated suspect‘s
expressed intent in such regard.
(b) In the event that all three of the above conditions are not met, the arrest of any private
citizen in a governmental building or place shall be deemed to be null and void ab initio.
(c) In the event of any arrest effected in violation of Sections (a) and/or (b) of this Statute
such that said arrest as described therein is automatically without legal force and effect, a
private right of civil action shall be deemed to exist against those responsible for said arrest
and for said violation(s).
(Nothing in this document--neither the number nor the content of this proposed statute--is
intended to be construed by anyone as
a duly enacted Statute of the General Assembly of the State of Illinois; it is strictly a
proposed statute)

60. Plaintiff stands to     suffer irreparable harm without      the procurement of preliminary
injunctions, ordering the relief sought in the previous paragraphs without delay.
61.   There is no adequate remedy at law for those of Plaintiff‘s injuries that would now cause
Plaintiff to abstain from entering and using Cook County courthouses in order to accomplish His
legitimate and lawful purposes, which he often cannot accomplish without the type of monitoring
described herein supra.
62. Plaintiff is likely to be successful on the merits of this action, since this Court is
lawfully bound to uphold Plaintiff‘s due process and other constitutionally protected rights and
to hold as void all orders that do not conform thereto.
63. There is urgency about Plaintiff‘s petition for injunctive relief, as He has immediate and
on-going needs, as alluded to above.
64. Therefore, Plaintiff requests that this Court issue a preliminary injunction granting the
relief sought supra.
65. Should Plaintiff prevail on some or all of His claims, He also requests a permanent
injunction similar to the preliminary injunction requested above.
66. By way of additional relief Plaintiff seeks:
An order of the Court, after Defendants would have filed any response to this complaint which
would be filed by any of them, explaining wherein this Complaint might justifiably be claimed to
be deficient and leave to amend same.
Trial by jury on all issues triable by jury.
Exemplary damages in an amount that a jury would find just and equitable.
Any and all other relief that this Court would consider to be just and equitable.

Amendment of 9/5/09
67. Sometime in September of 2008, RJM appeared before Judge Kuriakos-Ciesel (―JKC‖)           in
Courtroom 304 of the 555 W. Harrison St. Chicago, IL CCCC Courthouse. JKC held RJM in contempt
for RJM‘s refusing to concede the issue of the capitalization of     RJM‘s name before RJM would
have received any confirmation from JKC      that no claim to relief would have been waived,
relinquished nor otherwise forfeited due to RJM‘s not having adequately presented and preserved
such in any trial court proceedings ever conducted in       the underlying criminal   case   this
document concerns (―UCC‖) (on need to accomplish such objective - see Webb v Webb (_U.S._) and
Illinois v Gates (_U.s._). RJM was prevented from even explicating the basis of his response to
her question before being taken into custody and kept there until something like 16:00 p.m. when
RJM was finally released.
67.a. CCSD Deputy Wilson battered RJM via an unconsented physical contact in escorting RJM to the
67.b. RJM was prevented from the preserving the legal issue of the detention and escort any
better than what was accomplished in this regard inspite of the conduct of JKC and Wilson.
67c. RJM repeatedly demanded paper and a writing utensil to complete and get filed a 28 USC 2241
habeas corpus petition to a federal judge and also to have various books in his book bag provided
to him as well as to have a meal, but RJM was denied all of these measures of consideration.
68.   RJM was repeatedly sent to behavior clinic exams at the Forensic Clinic Service of      the
CCCC, howsoever unjustified were the orders requiring such.
69. As will be detailed in much greater particularization in the future, RJM appeared at each of
such appointments, informed Dr. Markos that RJM in good faith did not see how RJM could
participate in any such proceeding without either a witness, an audio-recording or an opportunity
to record every question, every answer    in any examination which would ever be conducted and
procure a signature confirming the accuracy of such    record as would have been the product of
such procedure from whatever examiner would conduct such, of such examination(s) , based upon
the consequences to RJM and all those entitled to consideration from RJM (RJM et al) of the BCX
exams to which RJM has been subjected over the past ten years.
70. Markos confirmed RJM‘s appearance in each instance, and informed RJM that he would not
conduct any examination under such circumstances and that neither would he provide any
explanation in support of his position.
71. On one occasion RJM inquired of the receptionist regarding some matter RJM then considered
important and was informed by two CCSD Deputies that if RJM did not immediately then depart the
floor on which the FCS Clinic is operative that RJM would be arrested. RJM departed under protest
– explicitly postulated and after receiving a confirmation that he had been understood by such
72. In an October of 2008 pretrial audience, RJM was endeavoring to record on RJM‘s computer the
proceedings being conducted by the attorney he had appointed against his most vociferous
opposition to represent him – Mr. J. Stachler before the Court       by typing into the computer
keyboard as much as RJM could gleen of what was being said by the Court and the attorneys then
interacting with the Court, and to provide such attorney the list of the things RJM demanded be
addressed on that court date, when CCSD Sgt Renkas who was on RJM‘s right side, ordered RJM to
close the computer, notwithstanding that the Judge could obviously see what RJM was doing. When
RJM proposed that Renkas identify the legal basis for the demand, a CCSD Deputy whom RJM now
knows as Deputy Simpson came running up from the back courtroom pew and got into RJM‘s person
space on RJM‘s left and exclaimed that, ―You give her any lip, and I will lock you up!!!!!!!!!!‖
73. This entirely unauthorized endeavor which would      foreseeably cause a person of ordinary
firmness to concede claims to consideration to which he would have been obliged to make claim,
in order by so conceding to avoid the affliction and grief of the lock-up and further
incarceration ordeal, with all of its attendant search inventories, interrogations, inavailabilty
to honor any legitimate reliance interests others might have accrued from contracts and/or non-
contractual associations and affiliations in which one might ever find oneself in the ordinary
context of   the lives of those who have not committed themselves to the complete anchorite
vocation at a given juncture,        demonstrated a reckless and wanton unconcern for RJM‘s
constitutionally protected right to assist in his defense, to petition the government for redress
of grievances, to due process of law, to be free from the threat of false arrest and to other
measures of consideration.
74. Mr. J. Stachler (―JS‖) was appointed as RJM‘s Counsel over RJM‘s vociferous objection.
75. To his great credit, JS summonsed Fr. J. Perluzzi to the Court on 9/25/09 as RJM was
preparing for a trip to the Cook County Jail – which for so many has been a death sentence or a
sentence to conditions which would leave one‘s life forever worsened (cf. Mayoral v Sheehan,
(_F.3d, _ ) (permanent paralysis from subjection to a gang beating in the CCJ which CCA 7, Judge
K. Ripple attributed to the conscious avoidance of the Sheriff and subordinates of the evidence
of the unreasonably dangerous conditions prevailing in the CCJ in the period in which Mayoral
was being detained there) so that RJM could get what RJM at that time understood might very well
constitute a ―last confession‖ heard, which is something Catholics have always sought in life-
threatening situations and/or situations in which one might have to participate, howsoever
reluctantly, in the shedding of blood in order to contribute to the prevention of an evil
demonstrably worse than the participation in activity the foreseeable unintended consequence of
which might include the shedding of human blood, or even worse, the shedding of innocent human
blood (for example in a given scenario an escapee from an illegitimate incarceration arrangement
might have to use a vehicle or a firearm in such a manner that an altogether innocent child might
be injured or killed as a foreseeable unintended consequence of a given endeavor to escape an
unjust detention or    to evade what would constitute an unjustified endeavor       to capture a
fugitive   in a given instance, which might include efforts to accomplish such objective made by
individuals who would not possess the information necessary in a given instance to know that a
given capture/endeavor would not be morally justified, due to a lack of access to information of
the sort needed to make such a determination in a given case.
76. Beyond that he continually informed RJM that he did not have time to do anything in the case.
77. He permitted himself to be used as a muzzle on RJM as will be detailed in the future.
78. Every time RJM went to Court, RJM was made to wait for extremely long periods to confer with
him and to procure an audience with the Court.
79. On or about 11/25/09, RJM was ordered into the custody of the CCJ by Judge T. M. Donnelly,
for refusing to answer BCX questions except according to the formula provided herein supra on the
basis that RJM had violated a condition of his bond.
79.a RJM explained to Deputy Wilson and CCSD Lt. Burns that there was no legal justification for
their transporting RJM out of the courtroom, to the lock-up and to the holding area to be sent
to the CCJ to the extent RJM could accomplish    and was not prevented from accomplishing, such
provision of notice objective.
80. The law regarding this type matter clearly states that no defendant who appears for such type
examination but refuses to answer any questions can be sanctioned for anything.
81. JS made no objection to the Court‘s ordering RJM into the custody of the CCJ on 11/25/08 and
explained to RJM that he could do nothing for RJM on 11/25/08, even as RJM was demanding an
opportunity to address the Court regarding the alleged legal basis of the sentence to the CCJ.
82. The supervisor of JS, Mr. T. Green (―TG‖) never did anything when RJM repeatedly complained
about the culpable negligence and reckless and wanton disregard of     the duties of    a defense
counsel demonstrated by JS regarding the UCC.
83. On or about 11/25/08, RJM was strip searched in the CCJ Cermak Facility in a situation in
which females could see the video conducted of the matter, as RJM understands the parameters of
the Cermak operation.
84. On 11/25/08, RJM was denied a medical exam upon entering the CCJ, notwithstanding that he
repeatedly demanded such.
85. On 11/25, 11/26, and 11/27 RJM continued to demand a writing utensil and some paper in order
to complete and get filed a habeas corpus petition to a federal judge pursuant to the provisions
of 28 USC 2241 but RJM was repeatedly denied such consideration.
86. RJM repeatedly demanded that he be permitted to speak to a CCSD supervisor re this issue and
several others on such dates, but RJM was never provided any opportunity to accomplish such
87. On 11/26, RJM was injected with Haldol over his most vociferous objection by R.N.         Mr.
Augusta Alabi ("AA") .
88. On 11/27/08, RJM was injected with Haldol twice over his most vociferous objections, first by
R.N. Manuel Manuelastas in the a.m. and then by R.N. AA in the p.m. .
89. The food in the jail was acidic garbage, which RJM surmises must have come out of cans with
BPA resin coating the inside thereof, and there was a total deprivation of       any physical or
intellectual stimulation which caused RJM to atrophy.
90. On 11/28/09, RJM experienced the symptoms of    withdrawal from the Haldol known as tardive
dykinesia when RJM could not keep his tongue in his mouth, could not think straight and could not
control his bodily operations.
91. This occurred to RJM while RJM was at his storage locker and RJM was terrified that he would
never recover from this horrid condition but would be taken into custody if he sought treatment
92. Dr. L. Shelton was apprised of RJM's predicament in this regard and took RJM to her father‘s
home and let RJM take Benedryll until such symptoms resided.
93. RJM then spent the next 2 days helping her clean that home in gratitude for the assistance
94. JTMD held RJM in contempt with the assistance of the CCSA and its subordinates for filing an
amicus curiae brief on behalf of Mr. J. Hernandez, which he later had to dismiss.
95. A Mr. N. Albuquerque    (―NA‖) ended up as RJM‘s counsel due to RJM‘s mother being induced
through Dr. Shelton to pay him $1200.00 to replace JS.
96. The activity of JTMD, NA and the prosecutors from the Office of the CCSA resulted in RJM‘s
not getting any of the pretrial or trial issues which RJM endeavored to raise, addressed, which
prevented the dismissal of the case on a pretrial basis and also denied the public the evidence
of the priorities according to which the UCC was instigated, prosecuted, defended and
97. On 12/17/08, RJM was again, without any justification, held in contempt of court, and Sgt
Kush and CCSD Deputy Wilson battered RJM via an unconsented physical contact in taking RJM to the
97a. JTMD prevented RJM from finishing his presentation to such actors regarding RJM‘s claims as
to their liability in enforcing the contempt order issued, before RJM was escorted out of the
97b. There was no response to any of the subpoenas RJM issued on various Cook County officials.
97c. RJM is not cognizant that any Cook County Official ever      lifted so much as a finger to
prevent or remedy any of the injuries RJM has incurred as described herein.
98. On 12/17/08, the prosecutor made an opening statement in RJM‘s trial during which RJM
endeavored to make the sign of the cross for each sin against the Eighth Commandment committed
by him and RJM ended up continuously making such sacramental sign as the statement was simply a
series of    fabrications, an enumeration of     which will be provided once RJM can get the
transcripts created from the conducting of such proceedings scanned into a form which will enable
RJM to print them.
99. The Court directed a verdict against the prosecution based upon the contents of a memo
written by Sgt Griffith to her supervisors on 6/13/09 which was entirely incompatible with the
perjured testimony Griffith and Dattulo provided under oath.
100. CC Sheriff Dart is alleged to have participated in the ―Gay Pride Parade‖ in June of 2008.
101. He went to the District of Criminals (Washingto D.C.) in January 2009 to testify regarding
102. On 1/19/09, his quotes were in the Chicago Sun Times about courtroom security, threats to
judges and suchlike political bounty accumulating matters.
103. He has time for everything but the matters to which a County Sheriff is gravely obliged to
attend, which matters he leaves unattended to the calamnitous injury of all Contra-degenerates
and everything His Majesty can still justify not hating.      He must resign or be removed from
office without delay, as his manifest lack of      the poverty of spirit (Matt. 5:4)     and  the
demonstratively adequately adjusted priorities and moral    fiber   which would correlate to the
minimal component of poverty of spirit which a person demonstrably would have to possess to
discharge the duties of the office of a county sheriff, according to a standard of accountability
which would be minimally enough to ensure that the moral liability corresponding to           the
exercise(s) of the authority of such office would not be left "less than demonstrably adequately
covered" renders him evidently to be patently unfit to continue to conduct activity in such
104. Throughout 2006, RJM spoke at the public speakers component of     the Cook County Board of
Commissioners meetings, complaining about the types of matters which resulted in the dreadful
ordeal described herein supra.
105. In December of 2006, such component was eliminated from the meetings.
106. Richard Velasquez, the counsel to the President of the CC B of Commissioners has received
and/or participated in no fewer than 7 or 8 conversations/phone messages with/from RJM regarding
the issue of the County's enabling RJM to access such videos so that the matters addressed
therein can be recorded and entered into this complaint and other documents.
107. To this day, RJM still has never been permitted to access such tapes.
Counts #_ to _ .
108. From August of 2008 through May of 2009, RJM was continually escorted at all times that RJM
was in the RDC by a member of the CCSD, which may have caused observers to conclude that RJM
has a history of violence, is mentally ill, is under investigation and/or has been leading a
"double life" of some sort or other.
109. Sometime over the past 5 years, a Robert Dgonchak – a licensed attorney responded to RJM‘s
proposal that he consider taking a case of       RJM‘s by declining to even read the documents
presented and never provided any explanation for such conduct, notwithstanding that he had been a
hockey player teammate of RJM‘s brother JWM.
RJM demands the sum of over $1,000,000.00 for all of the torts listed herein and the declaratory
and injunctive relief described herein.
Amendment of 9/17/09
109. In late October of 2005, RJM had a supervisor summonsed to Courtroom 2005 of       the Daley
Center and CCSD Sgt‘s Bergfalk and Quimque responded.
110. The developments of the incident that such response caused have been detailed in a separate
111. Such developments were presented to the FBI in December of 2005.
112. Subsequent to such juncture, RJM repeatedly made demands to deputies attending to matters
in various courtrooms, to the Supervisory Personnel in CL 132 and to the Legal Department in Room
704 of the R Daley Center that when RJM would summons a supervisor (almost an every time
occurrence in matters in which RJM has been involved in Room 1501 over the period in which
Lawrence O‘Gara and Moira Johnson have been presiding there) that only Sgt Garret or Boyd, or
someone of similar priorities and moral fiber be sent to attend to the matter.
113. Ms. Carol McFadden, Ms. Megan Keating and Mr. Matthew Burke can all attest to the number of
phone calls which the Office of the Legal Counsel in Room 704 received explicitly proposing that
no member of the CCSD who is a supervisor be sent to any call concerning RJM in the R. Daley
Center but such type supervisors.
114. In fact, on repeated occasions, RJM explicitly informed that Office that sending Bergfalk
and/or Quimque   to attend to any matter concerning RJM would most certainly only exacerbate a
given bad situation and likely result in the incurrment of liability by the County and to such
individuals, both civil and criminal.
115. To her great credit Ms. McFadden (Ms Keating and Mr. Burke have also contributed
conspicuously to the prevention of the incurrment of liability for the County in various
instances) demonstrated conspicuous concern to get Sgt. Garret or Boyd to attend to such matters.
116. On 6/13/08, RJM was endeavoring to get one of such two Sgts or Lt Prescott or Peter Kramer
or Mr. Burke himself to come up to Room 2408 when RJM was arrested while speaking on the phone to
Mr. Burke.
117. Notwithstanding the noteworthy and beneficial activity of        a number of employees and
officials in Cook County, IL Government, such government is in RJM‘s understanding, indisputably
a predatory and not a beneficent entity, but such predatory character of such activity is
evidently not as easily detected by those in contact with it on a daily basis as it would be for
someone considering such matter from afar.
118. From T. Stroger‘s appalling tax hike project, to Roberta Steele‘s taking a full pension for
the   holding of   the President‘s position for the short period for which she held it, to the
funding of    egregiously immoral co-habitation arrangements put on the same level as that of
sacramental marriage, to the adoption by degenerates of innocent infants and toddlers, to the
subsidization at the County Hospital of the murder of the preborn, to the lack of any adequate
investigation of the murder of Donald Young and two other members of Trinity…Church w/n 40 days
in late 2007 and 2008, and in so many other areas, there is a predilection towards iniquity that
reeks of the devil‘s presence and activity.
119. The poison to which RJM makes reference herein supra is the flousilicic acid poured into the
municipal water supply.
120. RJM also herein includes notice that he will include in a proposed future amendment to this
complaint a petition to have the statutory promulgations according to which the United States
Court of Appeals for the Seventh Circuit, and each judgeship therein except that presently
occupied by the Honorable Diane Sykes declared to be unconstitutional according to an argument
which will be presented in the future, as RJM understands that he cannot afford to not get the
298 petition which accompanies this document signed asap.
121.   RJM also    will in the future include a petition to have the statutory promulgations
according to which the United States District Court for the Northern District of IL, and each
judgeship of the judges before whom RJM has ever appeared in such Court, except that presently
occupied by the Honorable John Nordberg, or Judges Marovich and Bucklo, declared to be
unconstitutional according to an argument which will be presented in the future, for the same
reason included in para #120 herein supra.
122. The condition of such Courts induces in the many predators conducting activity in this
society at this juncture in its continued descent into an ever deeper barbarity in the area over
which such courts possess jurisdiction, a confidence that they can perpetrate felonies on the
members of   -   what is obviously considered by the     non-atypical Judges of   such Courts to
constitute    - the      ―slave class‖ who are unwilling to risk offending His Majesty by
participating in the transgression of    His laws, with impunity, as such predators continue to
exploit the forbearance of Contra-degenerates in a most appalling manner.
123. This condition evidently contributed to the perpetration of the felonies and torts this case
concerns and such condition must be eliminated and the abolition of such Courts, none of which is
mandated by Article III of the Constitution of the u.S. of A., is of the highest priority in
such regard.

The plaintiff demands trial by a twelve man jury.
I Robert More certify that I am the plaintiff in the above entitled action. The allegations in
this amended complaint are true.
Robert J. More
R.   More,      P.O.   Box   6926,   Chicago,    IL, 60680,   (312)  545-1890,   _   HYPERLINK
"" __anselm45@gmail.com_

Amendment of   11/25/09

cc://                   (Griffithccsd)
11/25/09, b.30, c. m.   n. 114 p1
Time and resources consumed on composition of amended complaint of 11/25/09
9/5/09 – 1 hour, 9/8/09 – 14:00 – , 11/1, 11/4, 11/12, 11/13, 11/17, 11/21, 11/25/09
15:15 – 16:25 and filing time – 16:40

                     CHANCERY DIVISION
(same caption as that included herein supra)(the caption included herein simply demonstrates what
such caption constituted prior to the modification thereof of 9/1/10)

[Robert More, Estate of   Robert J. More, ISMA Campaign to Make the World Safe for Innocence Once
v                                         Circuit Court Case      No.
(all individual Defendants named herein are sued in their official and individual capacities &
all Municipal Government Entities named herein are sued as Monell v Dept. of Social Services of
the City of New York, Defendants)
Cook County, IL, Sheriff‘s Department     (―CCSD‖) Sergeant    (―SGT‖) Jennifer Griffith,    Cook
County, IL Sheriff Thomas Dart, CCSD SGT Quimque, CCSD SGT Bergfalk, CCSD Deputy D. Danatulo,
CCSD Deputy Koppe, In Individual And Official Capacities, CCS T. Dart And Cook County, IL In
Monell Capacity As Well, CCSD Chief Counsel Mr. Peter Kramer, CCSD Lieutenant Prescott, CCSD
Chief Of Court Security At The R. Daley Center Mr. Nolan,    Cook County Board Of Commissioners
(―CCBC‖) President Mr. T. Stroger, CCBC, CCBC Commissioners #1-15 (All Commissioners Other Than
The Alleged Two Who Endeavored To Prevent The Elimination Of The Public Speakers Component Of
CCBC Board Meetings) In Individual And Official Capacities, CCBC And CCBC President Stroger In
Monell Capacity As Well, CCBC President‘s Counsel Mr. R. Velasquez, Clerk Of        The CCCC, IL
Dorothy Brown, CCCC Deputy Clerk Who Threw RJM‘s Papers Onto The Floor Of The Courtroom In Room
304 Of The Courthouse At 555 W. Harrison St. In Chicago, IL, In October Of 2008, Circuit Court
Of Cook County, IL (―CCCC‖) Judge Marvin Luckman, CCCC Judge Kuriakos Ceisel, CCCC Judge T. M.
Donnelly, Cook County State‘s Attorney (―CCSA‖) R. Devine, CCSA,      A. Alvarez, Asst. CCSA And
Supervisor, Charis Valente, Asst. CCSA And Supervisors – John And Jane Does #1-8, Asst. CCSA John
And Jane Does #1-6, Cook County Public Defender (―CCPD‖) Edwin Burrell, Asst. CCPD J. Stachler,
Asst. CCPD Mr. Theodore Green, Cook County, IL Forensic Services Clinic (―FSC‖) , CC, IL FSC
Director M. Markos, CCSD Deputies John Does #1&2 Who Informed RJM That If RJM Did Not Leave The
Floor Of The FSC On ____, That RJM Would ―Be Arrested‖, Cook County Jail (―CCJ‖) Intake Person
John Doe, CCJ, Cook County Health And Hospital Services Director, Mr. T. Foley, Isaac Ray Center
Director Dr. Cavanaugh, Cermak Health Services (―CHS‖) Director, Dr. D. Carrington, CHS Dr.
Matthews, CHS – Registered Nurse Mr. Augusta Alabi, CHS Dr. John Doe, CHS, CHS Clerks John Does
#1-3, CCSD‘s Esposito And John Does #1-4 Involved In Haldol Injections Of RJM As Restrainers In
Regard Thereto – Including Entirety Of       Persons Listed In Any Form In Exhibit #1 Which
Accompanies This Document, All CCSD Representatives Who Refused To Provide RJM Writing Utensil
And Paper At Any Juncture In The     History Of Developments This Complaint Concerns,     All CHS
Representatives Who Refused To Provide RJM Writing Utensil And Paper At Any Juncture In The
History Of Developments This Complaint Concerns, CCSD Lieutenant J. Doe, CCSD Chief At 555 W.
Harrison St. Chicago, IL Courthouse, Jane Doe, CCSD Sgt‘s Renkas & Kush, CCSD Wilson, Hennessey,
O‘Niell, Simpson, Mr. N. Albuquerque, Juror Who Made The Claim In Jury Selection ―The Problem
Ought To Be Dealt With By A Means Other Than A Criminal Prosecution‖ Demonstrating A Complete
Disregard Of The Presumption Of Innocence And A Reckless Indifference To The Consequences Of His
Activity In Regard To The Interests Of The Roman Catholic Church And The Prospects Of Eternal
Salvation Of Those Effected By It, State Of IL, U.S. Of A. U.S. Attorney For The N.D. Of IL,
Patrick Fitzgerald, CCSD IAD Director Raymond Zene, CCSD Employees John And Jane Does #1-8, CCCC
Chief Judge T. Evans, CCCC Office Of Chief Judge Receptionist Rosemary Dotson, CCCC First
Municipal Presiding Judge K. Wright, All Of The Present Members Of      The Supreme Court Of The
State Of IL Who     Were Responsible For The Recent Denial Of      RJM‘s Endeavor To Permanently
Eliminate The Condition Of Unmonitored Activity In The Adjudication Of Cook County IL Case # 08
CH 9977 Which Was A Precursor To       The Filing Of A Petition The Granting Of Which Would
Permanently Eliminate Any Prohibition On RJM‘s Use Of An Audio Recoding Device In Any Court
Proceeding In The State Of IL, In Which RJM Would Ever Be Involved
Proposed Amendment     Component Of 11/25/09 of Complaint Of 6/12/09….
This amendment was filed as a bet-hedging measure on 11/25/09 in order to get various parties,
previously not named in the Complaint to which this amendment was a proposed addition      and/or
parties who were named as John and Jane Does therein, but in regard to which parties, no tort
liability was incurred prior to 11/25/08 added to the Complaint pending in Case # 09 CH18934 by
The Guardianship and Advocacy Report Issued sustaining the allegations of      misfeasance and/or
malfeasance by CHS in the matters 09 CH 18934 and this complaint concerns is attached to the
amendments added in 09 CH 18934 subsequent to its original filing and is accessible in the court
file stored in Room 802 of the R. Daley Center.
RJM incorporates by reference herein the entirety of such report as if fully set forth herein
and will present a copy of such to this Court such document, if the incorporation by reference
herein would not be considered adequate for the purpose of getting the 298 petition granted.
That report contains factual claims according to which recovery can be procured for the torts of
willful and wanton disregard of duty, battery, deprivation of a right guaranteed by the
Constitution of the U.S. (right to privacy, right to free exercise of religion, and right to be
free from pretrial intrusion except in an arrangement in which due process of law would have been
provided, as applicable to the activity of actors of a political subdivision of a state via the
incorporation provisions of the due process clause of the Fourteenth Amendment of             such
Constitution and substantive due process).
A copy of the documents which the Cook County Sheriff‘s Department provided RJM in response to
RJM‘s FOIA in which RJM sought the names of all members of such Department who participated in
any Haldol injection of RJM, is contained in the court file of Case # 09 CH 18934 and RJM
incorporates the entirety of such document into this document by reference as if fully set forth
herein according to the same principle utilized regarding the report referenced herein supra.
The plaintiff demands trial by a twelve man jury.
I Robert More certify that I am the plaintiff in the above entitled action. The allegations in
this amended complaint are true.
Robert J. More
R.   More,      P.O.    Box   6926,  Chicago,    IL,   60680,   (312)   545-1890,   _   HYPERLINK
"" __anselm45@gmail.com_

RJM did not receive the      name of Manuel Manalastas      (―MM‖) until 12/11/09 and so has to
conditionally include Ms.    Jean Kiriazes as a Defendant to this case in order to cover a scenario
in which Cook County, IL     would endeavor to evade liability by claiming that RJM was somehow
responsible for not having   procured the name of MM prior to such date.

124.   On 11/26/08,   in the evening of that date, a Mr. Augusta Alabi, RN, injected RJM with
Haldol against RJM‘s will and over RJM‘s most vociferous,    but not in any way,    inappropriate
125. - on 11/27/08, in the morning of that date a Mr. Manuel Manalastas, RN, injected RJM with
Haldol against RJM‘s will and over RJM‘s most vociferous,    but not in any way,    inappropriate
126. - on 11/27/08,    in the evening of that date, a Mr. Augusta Alabi, RN, injected RJM with
Haldol against RJM‘s will and over RJM‘s most vociferous       but not in any way inappropriate
127. RJM herein complains that he was subject to inventory searches on five separate occasions,
all of which constitute separate torts as violations of the Fourth Amendment to the Constitution
of the u.S. of A.
128. RJM also complains that both Matthew Burke and Peter Kramer, licensed attorneys in the CCSD
Office of Legal Affairs, expressed surprise on 11/20/09 and 11/23/09, respectively, that RJM had
ever been criminally prosecuted in the matters this complaint concerns, indicating a total lack
of control over the CCSD by Thomas Dart – if the members of the Office of Legal Counsel did
not even ever receive notice that a criminal prosecution of the type herein described was being
conducted, especially since investigations and monitoring of RJM had been conducted by various
representatives of     the CCSD, over the     several years prior to and during the criminal
prosecution in regard to which RJM herein complains.
129. RJM herein complains that he is being injured because he still has not received copies of
the transcripts from the proceedings conducted in the trial court in Criminal Case #        08 MC
123741901, which has rendered him incapable of pleading various causes of action more
specifically than they have been pleaded herein and that the condition presently prevailing in
Cook County, IL in which innocent persons prosecuted for alleged crimes are dependent upon court
reporters to reconstruct a record of trial court proceedings is egregiously incompatible with
all of the measures of consideration guaranteed citizens of     the u.S. of A. in the Fifth and
Sixth Amendments to the Constitution of the u.S. of A. as such apply to the activity of state
actors and actors conducting activity in political subdivisions of states via the incorporation
provisions of the Due Process Clause of the Fourteenth Amendment to such Constitution.
Wherefore, RJM seeks the relief sought herein elsewhere in regard to the matters paragraphs # 125
– 129 concern.
Robert J. More

Amendment of   12/28/09 to Complaint of 6/13/08 in 09 CH 18934

130. RJM herein seeks to add his mother - Mrs. W.R. More (―TBM‖), as a plaintiff to this case,
as it is the understanding of RJM that she was caused severe emotional distress when she learned
that her firstborn male child was being injected with Haldol on 11/27/08, which distress
continued until the   reception of notice by her, of     the  granting of   the directed verdict
granted against the State of IL Predator/Prostitutes on 12/17/08.
131. ―We are grateful to the Washington Post, New York Times, Time Magazine…whose directors have
attended our meetings and respected their promise of discretion for almost forty years. It would
have been impossible for us to develop our plan for the world if we had been exposed to the
bright light of publicity during those years. The world is…prepared to march towards a world
government. The super-national sovereignty of an intellectual elite and world bankers is surely
superior to the national auto-determination practiced in past centuries. -      David Rockefeller
former CFR President at 1991 Bilderberger Mtg.
132. CC Sheriff Thomas Dart‘s listing as one of Time Magazine‘s 100 Most Influential Persons
of 2009 is another cause for concern compelling RJM to against insist he resign from the Office
133. The Constitution is an iron clad contract in writing which is to be liberally interpreted in
favor of the non-preparer – the citizen for the protection of rights and property – 2nd Amjur, 58
Const. Law – according to Carl Miller – this principle must be instilled into the minds of all of
those named as D‘s hererin.
134. On 12/2/09 – RJM was subject to the theft of combination lock, allegedly by a member of the
CCSD and demands restitution therefore in this case.
135. Two conspicuously considerate persons – 5‘ 10‖, heavy set black male – about 32-35 YO, CCSD
CO who provided two baloney sandwiches to the group of detainees of which RJM was a member on
11/26/08,   and the   5‖10‖ medium build Hispanic male CCSD CO who oversaw the unconstitutional
strip search of 11/26/08 are herein cited for the consideration demonstrated in the conducting of
activity conducted by them, respectively, even though the latter activity conductor could not
have not incurred moral, tort and criminal liability regarding his activity conducted in the
strip search referenced herein.
136. Patrick Fitzgerald and his subordinates have all been removed from this complaint in order
to get the 298 petition signed asap but RJM is fully committed to suing him and his subordinates
for interfering with RJM‘s access to the Federal Grand Jury presently seated at the Dirksen
Federal Building as is RJM committed regarding USMS Marshal John Clark and USMS Marshal for the
NDI, Kim Widup and his subordinates.
137. CC Clerk David Orr, notwithstanding the incalculable damage he has caused to the interests
of the Catholic Church, by his support of moral degeneracy has provided information to RJM in
regard to getting this complaint filed which has been of value.
138. RJM complains that the Chief Policy Makers of Cook County       are all according to RJM‘s
understanding,    active promoters of degeneracy, decay, depravity, deterioration, disease and
ultimately, death, and that they are all anti-innocence anti-innocence of childhood, anti-
chastity, anti-family, antinomianism, anti-righteousness, and anti-civilization.
139. By 9/29/10, RJM intends to present to the Cook County Board and its President and the
Attorney General of the State of IL, a settlement proposal including – provision for the
elimination of abortion, any arrangement which places any type of relationship on the same
footing as sacramental or natural law contractual marriage, the discontinuance of     withholding
of federal income tax from county and/or state employees compensation and benefit packages,
accompanied by the elimination of the acceptance/reception of federal funding ―assistance‖ of
whatever types there are in regard to which the County and/or State would possess the authority
to eliminate such which are not compatible with some express provision of the Constitution of
the u.S. of A., and to use Home Rule to eliminate any arrangement resulting in a disparity
of weaponry between the citizenry and the government at all levels.
140. RJM intends to require himself     to continue to conduct his activity such that there is
neither any lack of forcefulness, nor any type of concession to any type of predation on the one
hand, nor any lack of    consideration for the infirmity of the fallen human condition     on the
other, and if he should allegedly fail in this regard, complaints can be filed against him at:
see URL listed herein in the upper left hand corner of this document, supra (ISMA-Comp).
141. The time spent in a jail awaiting a trial has a detrimental impact on the individual. It
often means loss of a job; it disrupts family life; and it enforces idleness. Most jails offer
little or no recreational or rehabilitative programs. The time spent in jail is simply dead time.
Imposing those consequences on anyone who has not yet been convicted is serious. It is especially
unfortunate to impose them on persons who are ultimately found innocent. Finally, even if an
accused is not incarcerated prior to trial, he is still disadvantaged by restraints on his
liberty and by living under a cloud of anxiety, suspicion and often hostility. – Barker v Wingo,
407 U.S. 514, 92 S.Ct. 2182
142. RJM‘s Mother paid     1200.00 for attorney to defend RJM which was a totally preventable
143. RJM incurred severe mental and emotional distress,         upon being subjected to Haldol
injections and subsequent thereto until the directed verdict was issued as RJM had to deal with
the possibility of having to endeavor to escape and use force in any such type endeavor which
might foreseeably result in entirely unintended harm to persons of the moral caliber of Sgts.
Boyd or Garrett or Deputies Pettigrew, Wallach, Untaretti, Molnar, A. Thomas etc. etc..
 144. On 9/3/08, Judge TM Donnelly, stated, ―The State must retain a monopoly on use of force.‖.
145. Solzhenitsyn, Guy Fawkes, St. Thomas, Claus von Stauffenberg, Pope Pius XII, the Cristeros,
the Spanish in 1936, the Irish in 1918 and every Roman Catholic of all time cannot accept such a
patently morally unjustified statement.
146. The letter from U.S. Attorney‘ s Office of July of 2008 regarding the unconstitutional and
unacceptable conditions of the Cook County Jail evidently did not result in enough improvements
for RJM et al to have been spared the grief and harm described herein.
147.   RJM respectfully proposes that this Hon. Court consider eventually either providing her
signature on    a copy of    the Proposed Dec…RJM ( (Declaration
Unconstitionality...RJM) in regard to this or some similar case which RJM will almost invariably
have to file in the future, or     providing such on an amicus curiae to a higher court in such
regard and seeks feedback for what record of conduct RJM would have to demonstrate to procure
such at some future juncture.
148. Providence willing, RJM will add the material excised from the complaint dismissed in June
of 2010 (09 CH18934) to this complaint by 1/1/11, and all claims arising subsequent to 1/1/09
regarding the arrest et al of 6/13/08, in a form which would be in no way lacking in legitimacy.
Wherefore, RJM herein demands the sum of two million dollars and all equitable relief described
herein from the various Defendants named herein, subject to an upward augmentation twenty years
from today, should it be demonstrated that RJM incurred brain and/or eye damage form the Haldol
injections which would not have been adequately compensated by the sum of 2 million dollars at
this juncture in history, which sum can be dispersed in any of a number of forms to any of a
number of entities involved in the corporal and/or spiritual works of mercy of the Roman Catholic
Plaintiff demands trial by jury on all non-equitable counts and on all equitable counts contained
I aver that all factual averments contained herein are true.
Robert J. More

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