09-4136-cv-c-nkl Tromotionnow

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MISSOURI CENTRAL DIVISION

ROBERT GIPSON, Individually

) ) ) Case No, 09-4136-CV-C-NKL ) ) ) ) ) ) ) ) )

AND ROBERT GIPSON As Next of Friend Casey Gipson, a minor child Plaintiffs, vs. Defendants, Governor Jay Nixon, et al

FIRST MOTION TO AMEND T.R.O AND EMERGENCY HEARING

COMES NOW, Robert Gipson, pro se, and for his cause of action to amend his TRO filed on July 20, 2009 and to clarify his request for such cause. Part one and part two of complaint and all exhibits are the foundation for his motion. Part one consist of thirty four pages and part two consist of eighty five pages. Plaintiff therefore states the following. 1. Plaintiff filed his complaint on Friday July 18, 2009. 2. On Monday, July 20, Plaintiff filed his first motion for a T.R.O. 3. Plaintiff observed the minor child with a broken arm on Saturday July 19. 4. On Tuesday, July 21, Plaintiff was informed that a phone conference hearing was scheduled in seven days by Honorable Judge Nanette Laughrey. 5. Plaintiff began sending out e-mails to Defendants advising them of the same.

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6. Plaintiff is slightly restricted. He does not have access to the E.C.F. and is attempting to notify the parties in a timely manner. 7. Plaintiff is asking that a Temporary Restraining Order be placed against the case workers And supervisors assigned to the Missouri Children’s Services. As indicated in part one and part two of Plaintiffs complaint, case workers and supervisors conducted themselves in such a manner that brought harm to the Plaintiffs. 8. Defendants, James Johns, Brandy Wilkenson and Jason Warren have conspired to violate the Plaintiffs civil and constitutional rights to have a father and son relationship.

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COMPLAINT PART #1 COMES NOW, Robert Gipson, pro se, and for his cause of action for the removal of Casey Ryan Gipson’s picture from a Porn sex site on MYSPACE. Brandy Wilkenson, mother of Casey Gipson exploits sex on the MYSPACE web site. Pictures, video, and advertisement as a sex coach are her marketing profile. This brings discredit to the minor child when his picture is also on this web site. Defendants have had ample opportunity to investigate the pictures and video of the Porn site on Brandy Wilkenson’s MYSPACE web site. This is a Porn site and the minor child’s picture is posted for view by visiting customers. Robert Gipson presented evidence to the Missouri Children’s Division, Benton County Sheriff’s Department and Honorable Judge Michael Hendrickson. Defendants have protected Brandy Wilkenson and her husband Jason Warren at the expense of the minor child. It is a Federal Violation to have pictures of children on a MYSPACE Porn site. The owners and operators of MYSPACE have failed to monitor their Web site and have jeopardized the health and welfare of the minor child Casey Ryan Gipson. Retaliation by the Benton County Sheriffs Department resulted in harassment by means of arrest and civil rights violations against Robert Gipson. During the last court hearing Judge Michael Hendrickson refused to remove the minor child’s picture from the MYSPACE PORN WEB SITE. The GAL MR Lutman was also aware of this web site and did nothing. Mr. Lutman is presently the GAL for the minor child. Mr. Lumens’ failure to protect the minor child is cause for dismissal. The Plaintiff was subjected to excessive harassment during the June 2009 court hearing. Plaintiff was held by force and threat of physical and mental abuse by Judge Hendrickson and the court Baliffs. The first court hearing consisted of five Baliffs, two Prosecuting Attorneys and one person from the Missouri crime victim’s office who worked with

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Karen Woodley the Benton County Prosecutor. This was nothing more than an imminent threat against Plaintiff Robert Gipson. This threat infringed upon the integrity of the case and created a very hostile court environment. This threat by court officials against the Plaintiff Robert Gipson violated his civil rights to a fair trial and violated the Plaintiffs fourteenth amendment. This act of aggression against Plaintiff interrupted the normal course of justice. To this date July 15, 2009, Plaintiff continues to be oppressed by community corruption. Plaintiff will never get a fair trial in the Benton County Missouri court house, nor in the Western court of appeals. The attached documents also indicate a child and father who have endured excessive physical and mental abuse. This abuse has been covered up by the Missouri Children’s Division, case workers and supervisors. Mandated reporter, Psychologist and Defendant, Ms Erika Waller failed to report that the child Casey Gipson was beat in the face and eye by his mother Brandy Wilkenson. Psychiatrist and Defendant Dr Daniels from Columbia Missouri supervised Dr Waller. Both failed to report this abuse against the minor child. Both were presented with many documents describing prior neglect and abuse against the minor child. Part one and part two of Plaintiffs law suit identifies a consolidation of reports, pictures, video and CD to substantiate Plaintiffs accusations against the Defendants. The first course of action requested by Plaintiffs is to remove the minor child’s picture from the MYSAPCE porn site created and managed by Defendant Brandy Wilkenson and her husband Defendant Jason Warren. The Defendants listed in part one and part two of this law suit subjected the minor child to a life of hardship by ignoring obvious signs of neglect and abuse against the child. Defendants, in their official and individual capacity to protect the minor child from harm as directed by the United States Constitution, violated their oath of office. Defendants Brandy Wilkenson and Jason Warren have conducted criminal activities against the minor child and Plaintiff Robert Gipson as stated

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in part one and part two of this claim. Part one and part two of said claim relates to various Defendants who have violated the civil rights of Plaintiffs. Part one and part two has attached supplemental evidence to support said claim. Attached are photos, video, CD, medical documents, witness statements,and legal documents. Part one and part two describes the actions of each Defendant, relief sought for by Plaintiffs, supplemental evidence, and facts common to all counts.

PARTIES The Plaintiff, Robert Gipson is a resident of Benton County, State of Missouri and is the natural father of Casey Ryan Gipson. Plaintiff Robert Gipson brings this action as the parent of Casey Ryan Gipson and as the next friend of Casey Gipson, a minor child, who is currently legally unable to bring this cause to action himself.

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T.R.O. REQUESTED AGAINST THE FOLLOWING DEFENDANTS See: number 10 thru 27 in part one of complaint on pages 5 thru 15 9.

Defendant William Haefer,

10. Defendant William Haefer 12. Defendant Ron Levy, 13. Defendants Jim Harrison, Steve Morrow, Nancy Parks, Ms Hendrickson, Paula Neese, Ms Hartgrave, Ron Levy 14. Defendant Steve Morrow 16. Defendant, Jim Harrison 17. Defendant, Celesta Sue Hartgrave, 18. Defendant Steve Morrow, 1 19. Defendant, Bryan Kincaid, 20. Defendant, William Haefer, 21. Defendant, James Johns, 22. Defendant, Brandy Wilkenson, 23. Defendant, Jason Warren 24. Defendant, Honorable Judge,Michael Hendrickson 25. OWNER AND OPERATORS MYSPACE WEB SITE 26. ADMINISTRATORS MYSPACE WEB SITE Defendants, of MYSPACE have allowed Brandy Wilkenson to freely exploit sex on the internet. The owner and operators of this agency has violated the civil rights of the minor child Casey Gipson. They allowed pictures of minor children to be on the same web page where sex acts and exploiting sex were conducted and revealed 6

27. MR LUTMAN GAL FOR MINOR CHILD Defendant, Mr Lutman failed to properly represent the minor child.

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At all times relevant herein, Defendants listed above and below violated agency policies,

and regulations. They failed to properly investigate and interview parties of interest and ignored Plaintiffs pleas to help the minor child Casey Ryan Gipson. These policies, decisions officially adopted or promulgated by the State of Missouri were Maliciously ignored. which acts may fairly be said to represent official policy or were pursuant to the governmental custom of the State of Missouri. 29.

At all times relevant herein, Defendants have acted under the color of authority of the law of the State of Missouri.

FACTS COMMON TO ALL COUNTS See: number 30 thru 36 in part one of complaint on pages 16, 17 and 18

Count I – Denial of Substantive Due Process See: number 37 thru 41 in part one of complaint on page 18 and 19

WHEREFORE, Plaintiffs pray judgment against Defendants and issue a TRO against the defendants listed above.

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Count II - 42 U.S.C. §1983 CONSPIRACY

See items 42 thru 47 as listed in Part #1 of complaint on pages 19 and 20. WHEREFORE, Plaintiffs pray judgment against Defendants; for Plaintiffs’ costs of this action, including reasonable attorney fees; and such other relief as may be granted by the Court. Count III – Missouri State Law Claim - Torturous Interference

See items 48 thru 58 of Part one in complaint on pages 20 and 21. 58

Plaintiffs are entitled to a recovery of their reasonable attorney fees and

Punitive damages under Missouri Common Law for tortuous interference with their constitutionally protected relationship. It was and continues to be the actions of said Defendants that forced the Plaintiffs to take action and seek relief in this court.

WHEREFORE, Defendants listed as individuals and those acting under the color of law should be sanctioned and fined accordingly as required by law. Temporary Restraining Orders should be granted to protect Plaintiffs from any chance of further harm to them physically or mentally. Plaintiff has exhausted his resources in the circuit court and the appellate court. Plaintiff Robert Gipson has been bullied long enough. Plaintiff Robert Gipson states that the mental anguish caused by the Defendants and government agencies has caused PTSD. Plaintiff, Robert Gipson has endured seven years of an all out assault against his family. This has and could forever devastate his future life. Plaintiffs Bank account has been garnished. Funds that were exempt from garnishment were frauduantley obtained by James Johns, Brandy Wilkenson’s lawyer. The second garnishment was executed without a court order. Bank of America allowed this 8

transaction. Plaintiff was injured in Iraq. His Social Security Disability check was re routed to Brandy Wilkenson without Plaintiffs knowledge. Brandy Wilkenosn with the help from Mr. Brown and staff workers from the Sedalia Missouri Social Security Office conspired to make Brandy Wilkenson the payee of Plaintiffs Disability check. Plaintiff was injured in Iraq and receives money for his injuries. Brandy Wilkenson and her lawyer James Johns have conspired to bring false accusations against Plaintiff in order to obtain Plaintiffs money that was once used to support his child. Prior to such garnishment, Plaintiff provided financial support for the minor child in excess of the money now being paid out. Garnishment was just another reason for Brandy Wilkenson to file false accusations against Plaintiff and file to modify the previous court orders. The garnishment of the Plaintiff’s SSI, and savings account was nothing short of a criminal act. Plaintiff asks relief in the following.

1. This Federal law suit is the direct result of the Defendants Malicious attacks. 2.

Plaintiffs have suffered and have endured excessive mental anguish as a result of the actions and non actions of Defendants.

3. Plaintiff Robert Gipson, father of Casey Ryan Gipson has gone through extensive mental therapy as a direct result of Defendants failure to protect the minor child from neglect and abuse.

4. The Department of Veterans Affairs Psychologist and Civilian Psychologists have documented testimony from Plaintiff Robert Gipson on the abuse and neglect against the minor child Casey Ryan Gipson and the civil rights violations against both Plaintiffs.

5. The Defendants and Government agencies listed have violated their oath of office.

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SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS BEGINNING WITH LETTER A THRU Z See A thru Z in part one of complaint on pages 25 thru 27 of complaint

SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS MYSPACE PORN SITE WITH PICTURES OF THE MINOR CHILD CASEY RYAN GIPSON AGE SIX See: Page 28 in complaint . MYSPACE PORN SITE of Brandy Wilkenson dated August 15, 2008 as Exhibit #1 presented by Robert Gipson and witness dated on Feb 14, 2009. Presented as evidence on June 2009 in a hearing held in Benton County Missouri with Honorable Judge Michael Hendrickson presiding. Consisting of twelve pages. . MYSPACE PORN SITE, Exhibit #2, dated 2008. Eleven pages starting with Page 2 of 5 and last page 8 of 8. MYSPACE Calendar of Brandy Wilkenson dated Aug 22. 2008

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MYSPACE PICTURES EXHIBT #1, 2 AND 3 See: A thru J in part one of complaint on pages 28 and 29

MYSPACE EXHIBIT #2 See: page 30 in part one of complaint. A. Dated Aug 15, 2008, shows the flow of traffic coming to the web site and Brandy Wilkinson’s communication with her clients to market her business. B. Exhibit consists of eleven pages. MYSPACE EXHIBIT #3 See: page 30 in part one of complaint Exhibit #3 shows the schedule of Brandy Wilkinson’s nightly activities when she was a sex coach and exploiting sex. These schedules and the reckless life of Brandy Wilkenson subjected the minor child to a high risk environment. The minor child was left with Jason Warren during these late night parties and in one incident the minor child was locked outside his house and burned his hand on a stick from a fire with Jason Warren present. The minor child informed Plaintiff that his ears were cold and there were no keys to get into the house and his mommy was gone. . Plaintiff has been alienated from his child and can no longer protect his child from neglect and abuse.

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PICTURES OF CASEY RYAN GIPSON WHICH DISPLAY ABNORMAL AND EXCESSIVE INJURIES OF NEGLECT AND ABUSE See: number 15 thru 21 in part one of complaint on pages 31 and 32

STATEMENTS FROM PLAINTIFF ROBERT GIPSON See number 18 thru 23 in part one of complaint on page 33

MOTION FOR TRO CONTINUED WITH PART TWO OF PLAINTIFFS COMPLAINT Part two of Plaintiffs complaint consists of eighty four pages. 1.

Plaintiff request that a T.R.O. be issued to the Defendants listed below.

2. That every doctor listed be prevented from treating Casey Gipson 3. That every school teacher from the minor child’s pre-school and kinder garden be issued a T.R.O. 4.

That Ms Peterson be issues a TRO

5. That every police officer listed be issued a TRO 6. That the Bank of America be issued a TRO and reframe from allowing identity fraud 7. That Bank of America be issued a P.R.O. Permanent Restraining Order from allowing James Johns or any other person or agency from garnishing exempt funds 8. That every Psychologist listed as Defendant be issued a TRO and have no contact with Plaintiffs unless in a court hearing. 9. That Jason Warren be issued a TRO and be prevented from any contact with the minor child unless in the presence of another adult. 10. That Jason Warren not be allowed to drive a car with Casey Gipson as a passenger 11. That Jason Warren not be within one mile from Plaintiffs during any visitation changes. 12

12. That Jason Warren not be left alone with Casey Gipson for any reason. 13. That no one at any time smoke in the presence of the minor child if in doors or in a car. 14. That no police officer listed as Defendants come within one mile of Plaintiffs 15. That Judge Hendrickson be issued a TRO and be prevented from ruling on any court issues that involve Plaintiffs 16. That all rulings made by Judge Hendrickson be TRO and the 2005 custody order be restored. 17. That all Defendants listed be issued a TRO and have no contact with Plaintiffs unless in a court setting 18. That a new Pediatrician be assigned for the minor child 19. That the GAL Mr Lutman recues himself from his duties 20. That CASA Court Appointed Special Advocate be appointed for the minor child 21. That Ms Peterson be issued a TRO and not be in the presence of the minor child 22. That James Johns, attorney for Defendant Brandy Wilkenson, TRO and recues himself from any contact with Plaintiffs and reframe from any communication with Brandy Wilkenson about the minor child or Plaintiff Robert Gipson. 23. That Sheryl Schultz be issued a TRO and make no entries on any of the Plaintiffs court files.

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COMPLAINT PART#2

COMES NOW, Robert Gipson, pro se, and for his cause of action for the wrongful taking and unlawful deprivation of Plaintiff’s rights to parent his minor child, and for the minor child’s right to be in the custody of his father, against the above named defendants, and for his unlawful detention, arrest and incarceration by actions of government employees Plaintiffs mental health and well being has been affected by government workers to the extend Plaintiff has PTSD from being alienated from his child. Plaintiff states the following: Suit is being brought against all Defendants in their official capacity and individual capacity. Plaintiff states that qualified immunity does not exist here for government workers nor does any other immunity. Defendants violated Plaintiffs Civil Rights at various times from 2002 to most recent in 2009. Government workers mentioned maliciously and with malice and while under the color of law, restricted Plaintiffs having their freedom and right to happiness. Malicious Prosecution and Malicious Arrest have caused enormous harm against Plaintiff Robert Gipson. For over six years the unjustifiable and unreasonable excessive civil and criminal litigation against Plaintiff Robert Gipson has caused in the excess of $250,000 dollars. Some Defendants listed were often under government contract and violated state and federal laws by bringing fraud upon the court, perverting the course of justice and violating the civil rights of the Plaintiffs. Some Defendants listed were mandated reporters and purposely neglected to report neglect and abuse that was reported by the minor child Casey Ryan Gipson and Plaintiff Robert Gipson father of minor child. Some Defendants listed knowingly conspired with each other to prosper politically and financially at the expense of the minor child. Some Defendants listed abused their judicial 14

powers to oppress Plaintiffs. Some Defendants listed knowingly that a crime had occurred and had the Authority to act failed to do so. Some Defendants listed tampered with evidence and obstructed justice. Some Defendants listed knowingly perverted the course of justice by forging signatures on official court records. Some Defendants listed slandered Plaintiffs and created excessive litigation in order to embezzle money and Garnished Plaintiffs bank account. The funds Garnished were Exempt and executed without a court judgment. Bank of America conspired with James Johns, attorney for Brandy Wilkenson embezzled money from Plaintiffs account. Defendant Brandy Wilkenson, James Johns and members from the Missouri Children’s Division conspired and succeeded in garnishing Plaintiffs Social Security Disability Benefits. Defendant Mr. Brown from the Sedalia Missouri Social Security Office allowed Brandy Wilkenson to become the Payee for the money for Plaintiffs child without notifying Plaintiff. Plaintiff received money for his wounds which occurred in Iraq during his tour in 2003-2004. Once again in July 2009 Defendant Brandy Wilkenson and her lawyer, James Johns are attempting to embezzle money from Plaintiff and have accused Plaintiff of conducting a home Sleep Study and medical testing on his minor child Casey Gipson. Defendants have orchestrated yet another desperate approach to alienate the minor child from his father. Defendant Brandy Wilkenson will never stop until she completely and with malice destroys the bond between Plaintiffs Robert Gipson and son Casey Gipson. Unfounded court orders to restrict the Plaintiffs to the present visitation of five hours every other Saturday and Sunday has caused and will continue to destruct the family unity. Police officers from Lincoln Missouri, Cole Camp Missouri and Benton County Sherriffs office and case workers from the Missouri Children’s Division, conspired to bring physical and mental harm to plaintiffs. Plaintiff has been subjected to numerous interviews by police officers and case workers. The minor child has been subjected

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to safe house interviews as the direct result of the Defendant Brandy Wilkenson making false accusations that the Plaintiff Robert Gipson sexually molested his child Casey Gipson. The Missouri Children’s Division case workers did video these interviews and refuse to release the video to the Plaintiff even after Plaintiff has requested so in writing to Ron Levy the Director of the Missouri Family Services and Jim Harrison the former director of the Missouri Children’s Division. Medical Doctors and Psychologists failed to inform the court and Authorities about the adverse medical conditions which have stressed the minor child Casey Ryan Gipson. Psychologist and Psychiatrist who are mandated reporters failed to report when the minor child Casey Ryan Gipson stated to them that he was hit in the face by his mother Brandy Wilkenson. Psychologist failed to protect the minor child when his father and Plaintiff Robert Gipson presented written reports and documentation of neglect and abuse against the minor child by his mother Brandy Wilkenson and his step father Jason Warren. Psychologist conspired with case workers and to gain government contracts and favored case workers from the Missouri Department of Children Services. Psychologist violated the HEPPA laws by releasing personal information about Plaintiff Robert Gipson without consent from Plaintiff. Psychologist ignored witness statements from Plaintiff Robert Gipson about neglect and abuse against the minor child Casey Ryan Gipson. Directors from the Missouri Family Services and the Missouri Children’s Division ignored and failed to properly investigate written complaints and Hot Line reports about the neglect and abuse against Plaintiffs Robert Gipson and Casey Gipson. Video, pictures and CD which showed neglect and abuse against the child Casey Ryan Gipson was ignored by the Missouri Department of Family Services which showed the minor child having severe medical problems with Sleep Apnea, Burn Marks, Excessive bug bites, bruises and Obstructive airway. Reports of loaded guns, and a home environment that endangered the minor child were ignored

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by case workers from the Missouri Children’s Division. Case workers investigated over fifteen legitimate reports from the Plaintiff Robert Gipson and also third party reports. These reports reflect back to the first oven burn which the child received when he was a baby. Reports sense 2003 to 2009 have been poorly investigated and found to be Un-substantiated time after time. The Investigations conducted were done so in a Haphazard and careless process. The minor child was observed with obvious bruises, cuts, excessive bug bites, smashed face, burnt arm, burnt ear by a cigarette. Reports of the child observing his mother getting beat by her husband Jason Warren were ignored by case workers and school principal Ms Peterson of the Cole Camp Elementary in Cole Camp Missouri. Head wounds received by the child were ignored by school teachers. The minor child was struck in the head by the rocks which came from an automobile that caused the wounds. Police reports, witness statements, video, pictures, CD and court testimony was presented as evidence and ignored by court judges, case workers, police, psychologist, doctors, lawyers, school teachers, school principal and church pastors. Third party witnesses were ignored when they reported by Hot Line calls and written statements to the Missouri Children’s Division and state officials of the neglect and abuse against the minor child Casey Ryan Gipson. Witness statements presented in court in person and in writing were ignored by judges. Judge Larry Burdett and Judge Michael Hendrickson’s Final Judgments and court rulings were unfounded. Their rulings were unsubstantiated and without merit. Their rulings were Bias against the Plaintiffs Robert Gipson and Casey Gipson. There was no substantial evidence, no preponderance of evidence to justify their rulings to modify and court judgments from 2005 to 2009. The Plaintiffs rights to due process was violated severely Judge Larry Burdett and Judge Michael Hendrickson allowed their court to be ruled by Brandy Wilkenson and her two lawyers James Johns and Jim Rice. Case workers manipulated the court

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proceedings by bringing fraud upon the court. Excessive litigation has caused Plaintiff Robert Gipson to lose over $250, 000, 00 dollars and has caused mental anguish that has affected every fiber of Plaintiffs life. Court orders and rulings by judge Burdett and Judge Michael Hendrickson have severed the bond between father and son. Judge Burdett and judge Hendrickson both have failed to up hold their oath of office and have failed to protect the Constitutional Rights of Plaintiffs. Both judges allowed expert witnesses to get away with bringing fraud upon the court and perverting the course of justice. Both judges prevented Plaintiff Robert Gipson from presenting his motions and restricted Plaintiff from presenting evidence that would be in the best interest of the minor child. Judge Burdett and Judge Michael Hendrickson violated the Plaintiffs fourth amendment and created an atmosphere of injustice in their court room. Judge Burdett held court hearings without the knowledge of Plaintiff. This allowed Brandy Wilkenson and her lawyer James Rice favor in their case against Plaintiff Robert Gipson. Judge Burdett along with his clerk of court ignored Plaintiffs request to have his motions heard. The Clerk failed to give Plaintiff court dates as requested in Plaintiffs motion. It was not until time was up that Plaintiff was given dates and it was at that time that the Benton County clerk stated to Plaintiff that she does not read my motions. Plaintiff’s motions requested that the Clerk provide a time to be heard. Judge Burdett informed the Benton County Clerk, Ms Schultz not to send Plaintiff a copy of the Final judgment even after Plaintiff put the court on notice that he was now a Pro-se litigant. Judge Burdett ignored Plaintiffs motion to request that Jim Rice return Plaintiffs exhibits that were taken from the bench. Plaintiff first entered pleadings in the Benton County court house in 2003. There has been nothing but injustice and conspiracy to drain the pockets of Plaintiff through excessive litigation and to deny Plaintiff his equal rights to be a father to his son.

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Some Defendants listed conspired with Brandy Wilkenson Warren and Jason Warren to bring false accusations of sexual abuse against Plaintiff Robert Gipson. Conspiracy to bring a Child Protection Order, exparte hearings, child endangerment hearings, false arrest reports, false contempt actions, false criminal reports, physical threats, threats against Plaintiffs finances, threats against Plaintiffs home and alienating the minor child from Plaintiff Robert Gipson. The actions of Defendants have crippled the relationship between the father, Robert Gipson and his biological son Casey Ryan Gipson. These atrocities will forever burden the family foundation that was once enjoyed by a loving father and his precious seven year old child. The destruction and devastation brought against Plaintiffs may be irreversible and may cause a lasting effect of mental disorders upon Plaintiffs’. DEFENDANTS 13. Defendant, Mark Breshears,. 14. Defendant, Honorable Judge Larry Burdett, 15. Defendant, Honorable Judge Mark Pilley 16. Defendant, Karen Woodley, 17. Defendant Cheryl Schultz Defendants, Carlisle Walker, Officer Rick Fajen Mickey Mittlestadt, Chief Kinkinnon, Deputy Haun

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Chief Kinkinnon 19. Defendant, Sheriff Officer Rick Fajen 20. Defendant, Mickey Mittlestadt, .Defendant, Officer Haun Defendant, Honarable Judge,Michael Hendrickson Defendants, Missouri Crime Victims Office, CRIME VICTIMS ADVOCATE Defendant, Ron Levy, Defendant, Debra Scott, Defendants Jim Harrison, Steve Morrow, Nancy Parks, and Ms Hendrickson Defendant, Celesta Sue Hartgrave, Defendant, Dawn Long, Defendant, Beverly Chapman, Defendant, Paula Woolery, Defendant Alice Sharon Zidlicky, Defendant Steve Morrow, Defendant, Mr. Brown, Defendant, Sherriff Deputy officer Haun, Defendant, William Haefer, Defendant, Attorney, James Johns, Brandy Wilkenson’s Attorney in 2007 and 2009 Defendant, Brandy Wilkenson, Mother of minor child Casey Gipson Defendant, Former, Attorney James Rice, Attorney for Brandy Wilkenson in 2004, Defendant, Dr, Susan Waldo, minor child’s counselor. Defendant, Dr. Daniels, Psychiatrist

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Defendant, Dr. Tim Vuagniaux, court appointed psychologist. Defendant, DR. Erika Waller, psychologist for child and father. Defendant, DR. Salenger, psychologist for child. Defendant, Dr. Julie Cahill, physician for child. Bank of America,

Defendant, Ms. Peterson, School Principal for minor child. Defendant, MS, Defendant, MS, Wooleby, Pre-school teacher for minor child, Defendant, MS, kinder garden teacher for minor child,

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FACTS COMMON TO ALL COUNTS

See: number 14 thru 20 on part two of complaint. Count I – Denial of Substantive Due Process

See: Number 21 thru 25 of complaint

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and such other relief as may be granted by the Court.

Count II - 42 U.S.C. §1983 CONSPIRACY

See number 26 thru 34 of complaint. .

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages

in an amount that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and such other relief as may be granted by the Court. Plaintiff states that he has been forced to file such suit in order to protect the interest of his minor child. Plaintiff moves to Quash all Summery judgments against this suit by 22

any and all Defendants.

Count III – Missouri State Law Claim - Tortuous Interference

See: number 35 thru 46 in part two of complaint.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and such other relief as may be granted by the Court.

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COMPLAINT CONTINUED SIGNIFICANT EVENTS AND TIME FRAMES FROM MAY 26, 2002 – July 9, 2009 See: number 1 thru 29 in part two of complaint. Pages 66 thru 70.

2003 See: number 30 thru 32 in part two of complaint. Pages 71 and 72

2004 See: number 33 thru 43 in part two of complaint. Pages 73 and 74

2005 See: number 43 thru 44 in part two of complaint. Pages 75 and 76

2006 See: number 45 thru 48 in part two of complaint. Pages 77

2007 See: number 49 thru 52 in part two of complaint. Pages 78 and 79

2008 See: number 54 thru 57 in part two of complaint. Pages 81 thru 83

2009

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See: number 58 thru 60 in part two of complaint. Page 84 and 85

Plaintiff states that all the information provided is true to the best of his knowledge. Notice of Service is attached. This motion will be e-mailed, hand delivered and sent by U.S. certified mail to Defendants listed in this motion. Robert Gipson 105 South Center ST Lincoln Missouri 65338 660-723-4044 cell

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