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ON THE JOB/AND OFF THE JOB CRIMINALLY CONSPIRED , PRE-MEDIATATED "ANIMUS INTENT", SLANDER OF A NATURE, OF AND BY THE MANAGEMENT PERSONEL, to deprive the plaintiff of his job. Plaintiff charges that this discharge, was in the form of a charge of petty theft. That this charge was a charge completely without foundation, and solely due to this "Animus Intent", campaign, and job stress, and lack of competent Counsel, plaintiff did allow on May 10th 1978, through counsel, a plea of"NOLO". Plaintiff charges that this plea of "NOLO",waszazreversal of his original plea of"Not Guilty" entered on March 30th,1978, after UPS, did file a criminal complaint against the plaintiff, resulting in his being booked by the Warwick Police Department. Plaintiff charges that this complaint was filed by Ups Management, after attempting to coerce from the plaintiff, his signature on a paper of voluntary termination, of which the plaintiff refused. Plaintiff charges that the defendant Robert Dwyer, (to be served later,after discovery of location) Manager at the RI,UPS terminal at the time of this alledged, charge against the plaintiff, had forced the plaintiff off his regular, seniority job, of Tractor Trailer Driver, and had on trumped up charges forced him into this inside job. Plaintiff charges that he was forced from his regular position As a tractor trailer driver, onto this night time shift, and that his seniority rights, were being violated, and that he was seeking to return to his regular job, and was pushing the issue with this manager Robert Dwyer, and Teamsters Business Agent-- Local 251, Gerry Blinkhorn. Plaintiff charges that this denial of his right to seek the job of his choice, was a gross violation of his previously negotiated Teamsters--Ups Contract, which did hold provisions for the bidding on/of jobs of workers choice, according to seniority, and that he had been forced, in February 1978, by Robert Dwyer, in complete violation of this contract/ agreement, to accept this inside position. Plaintiff charges that this forced involuntary servitude, was uncalled for,contrived, and that when the plaintiff did strongly protest the continuation of this violation of his contract, he was set-up and fired. Plaintiff fwyrther charges that while forced to work on this inside night time shift, he was harassed, and intimidated, which had been the pattern, on a continuing scale, growing in intensity since 1964. Plaintiff Charges that in 1964, he was struck from behind by a supervisor, while working, andtehat UPS,had built this charge, out of proportion, did attempt to place blame on the plaintiff, and did as stated single the plaintiff out as an example at this terminal, to harass and intimidate, and attempt to set a precédent for others, of an example, to attempt to break, in form of, Union attitudes. Plaintiff charges duettotth¢s incident at which time he was assaulted by one supervisor,by no fault of his own, and do solely to job pressure on this super- visor,he did become a means/example for this company, a takget For others to see, of what they could/would do i@ challenged in there attempts of total control and authority of employee's, in any way shape or manner. Plaintiff charges that up to this point he had,;had no on the job problems, that this supervisor was newly appointed, did not have the job skills required to fill (73) i : t