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Senator Edward Kennedy — Part 20
Page 215
215 / 249
COMPLAINT
COUNT I
1), THE JURISDICTION OF THIS COURT IS INVOKED UNDER SECTION l,
OF THE 14th AMENDMENT, THE 1ST AMENDMENT, 4th AMENDMENT, 7Th
AMENDMENT, AND THE 6th AMENDMENT TO THE CONSTITUTION OF THE
UNITED STATES. AND UNDER TITTLE 28 USCS &1331, &1332 (a) (1), ec),
&1343 (1) (2) (3) (4), &(1346) (a) (2), AND &1361 AND THAT THESE
ACTIONS ARISE OUT OF AND UNDER VIOLATIONS, (CONSTITUTIONAL) OF
THE FEDERALLY PROTECTED RIGHTS OF THE PLAINTIFF, TITTLE 42 USCS
&1981,&1983, £1985 (2)(3), AND 1986.
2) That the amount in question exceeds $10,000, exclusive of
costs and/or interest.and Jurisdictional Actions Under 28UScs
1331, 1343 (1) (2 3 4)7-Civil Rights? E 1 Ri iti .
3) During alt fred hentionsd. and aoe ef na eg up gate ns Ss sizens
the Plaintiff, John J. Staradumsky, was and is a citizen/resident
of the United States, and the State of Rhode Island.
4) That the plaintiff claims Diversity of Citizenship in this
civil action, &1332 (a)(1), and (c), invoking Original Jurisdiction
in this Federal District Court. That these issues are between
Citizens of Different States, and Corporations deemed citizens
of any State that it has been incorporated and of the State where
it has its principal office. (All 28 USCS, Tittle)
5) That the plaintiff, is filing this complaint, under 28 USCS-¢é-
1346, and his complaint is against the United States, and its
Officers, as Defendants, arising out of Civil Rights violations
under 42 USCS,&1981,&1983,&1985 (2) (3), and 1986.
6) That the plaintiff, is filing this complaint, under 28 USCS,
&1361, ACTION TO COMPEL AN OFFICER OF THE UNITED STATES TO
PERFORM HIS/THEIR DUTIES. Plaintiff is seeking as stated this
complaint, seeking Writs of Mandumus, to force defendants as
isted these following counts, having exhausted all administrative
remedies available to him by law to have an investigation into
all violations of his Constitutional Rights, Protected under the
Constitutionof the United States, and under 42 USCS, &1981, &1983
1985 (2) (3), and 1986. and of which Plaintiff states all of
these actions/complaints this Civil Action arise out of. And
therefore Plaintiff claims Jurisdiction in this Federal District
Court, under this Same 28 USCS, &1361, this Complaint.
7) That all other defendants, this complaint, are to the best
of the Plaintiffs knowledge, Citizens of the United States, and
residents of the State of Rhode Island.
8) That on February 26th, 1987, the Providence Police, Sgt. Owen§$
with other"John Doe " Providence police Officers, and acting
on and with the advice of the Juvénile Division, Pravigenee
Police Department, Sgt. Giblin, forcefully removed ’.the :twin
infants, Christopher Lee, and Crystal Lynn Staradumskyv, from
the residence of the Plaintiff, John J. Staradumsky. The Plain-
tiff, did and does reside at 31 Kenyon Street Providence RI.
The Plaintiff was at all times, obeying the law, and did have
(1)
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