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| @ Son Douglas Staradumsky, present, he was accosted and an attempt was made to assault him, BY Defendants William "Chico" Hartmann, William Hartmann, Jr., A PUGILIST, and Raymond arrity, (Boyfriend of defendant Gloria Hartmann) -Plaintiff Garrity, (Boyfriend of derene en ee Ft poudlas charges that he was lured there on legal advice of Douglas Smith,Esq.-, " That the Providence police would let you see the twins, if you call them, and the escort you to the apartment at 3 Curtis St." PLAINTIFF CHARGES—-CONSP IRACY-~DEFENDANT SMITH ,ESQO. Plaintiff charges that after receiving this advise from Douglas Smith Esq., on March 12th,1987, and after receiving many calls from the Mother defendant Gloria Hartmann, on March 9th, March llth, and finally on March 14th,1987, he did call the Providence Police Department, requesting that a police car be dispatched to 3 Curtis St. Providence, to see his twin infants, who from the Audio taped calls of the Plaintiff from the Défendant Glotia”Hartmann,Plaintiff not having the telephone number of the defendant Gloria Hartmann, had come down, as stated with, Colds, eye infections, ear infections, and chicken Pox, Providence Police, per audio taped calls by the plaintiff did state that a car would respond to Manton Ave., ‘and that the Plaintiff should await it there. Plaintiff did, catt of fear and concern for his twin infants, and with his son Douglas Staradumsky present, park his car, on Manton Ave., across from but not entering Curtis St. Providence, and await the Providence Police, to escort him if possible to see his infants, at the residency, second floor, where the defendant Gloria Hartmann was temporarily residing. He was at all times, other than, to call Providence police again, after no Police Car did respond, in his car, and peacefully awaiting arrival of police. plaintiff charges that at this point, appox. 1;20 Pm, Plaintiff was accosted, with verbal threats, to life and limb, his vehicle punched, and he was other- wise threatened by the Defendants, William "Chico" Hartmann, William Hartmann Jr., and Ray Garrity. That at appox. 1:36 PM, Providence police did respond to 3 Curtis St., Plaintiff did at this point, enter Curtis St., and park behind the police car. Plaintiff did relate the calls from defendant Gloria Hartmann, Legal advice from Douglas Smith Esq., and request with police present to see his twin Infants.Plaintiff£ states that the providence police, ( two cars, did respond, one after the other,) did find the deféfdants at the scene, and did Speak to William "Chico" Hartmann, William Hartmann Jr., and did after enter the dwelling at 3 Curtis St. However, defendant Ray Garrity was also in the building at this time, with his black car RI License DO0-606, parked in front of the house. Upon returning from the dwelling, Defendant " JOhn Doe. "" providence police, did inform the Plaintiff'that the Defendant Gloria Hartmann, had refused to allow Plaintiff to see his twins, However they were resting, sleeping in their cribs, and were covered with chicken Pox, but the mother/defendant had seen a doctor, and had medication". Plaintiff at this point, request that a report be made out, and that the name of his Son Douglas Staradumsky, be placed on this report as a witness. This report was made out, C.C.R. Bo. 87- 30668, dated 3/14/87. Plaintiff Charges that this report, and (11)