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Senator Edward Kennedy — Part 20
Page 84
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CA
COMPLAINT JURY DEMAND
COUNT I s
1) The Jurisdiction of this Court is invoked under Tittle 28 5
uscs, 1343 (1) (2) (3) and (4), 1331, and that this action arises
out of/under 42 SS USCS 1981, 1983, 1985 (2), (3)—--1986.
2) At all times the Plaintiff John J. Staradumsky, was and is
a citizen of the State of Rhode Island, and this Judicial District.
3) That all the defendants, were/ are citizens of the State of
Rhode Island, and this Judicial District.
4) That the defendants, Et Al, did conspire, on or about the
15th, and 16th, of September, 1984, to have the Plaintiff evicted
from his rented apartment, at 1688 Main Street West Warwick R.I.
thru no fault whatso-ever, and thru the use of frauduluent charges
at the West Warwick Police Station, by and thru Chief Danny
Patrarca, and with use of same by owner of the Building, William
Field, to serve netice for the Plaintiff John J. Staradumsky.
5) That this conspiracy did arise, out of and due to the plain-
tiff, havina filed Civil Action-- 83-841, Rhode Island Superior
Court, Kent County,conspiracy being between as mentioned owner
William Field, West Warwick Police et al, Chief of Police W.
Warwick Danny Patrarca, and with use of resident John Does Town
of West Warwick, by the W.Warwick Police et al, Defendants, to
harass and intimidate the plaintiff, with no action taken by the
W.Warwick police dept., when approached, or complained to by the
Plaintiz£. Thus inveking violations under 42 5 1981, 1983, 1985.
6) That this conspiracy was also with intent to deprive the
Plaintiff of any and all other Civil Rights, and to deprive him
of his 7th Amendment rights, and 14th Amendment rights, by use
of She capacity of acting under " Color Of the Law ", use of
West Warwick Police officers, and Office of the Chief to achieve
intimidation and harassment, in further retaliation, and abuse of
power. With purpose of driving the plaintifi out of town, West
Warwick, to deprive him of possible witnesses in his civil action,
and use of relatives and friends of police officers and officials
of the Town of West Warwick R.I. ( These defendants to be named
thru discovery ). With same action, to intimidate any and all
possible witnesses, who mav have come forward, who did witness
what happened to the plaintiff, and therefore become fearfull that
the same could happen to them , thus intimidation by implied actions.
Thus invoking civil rights violations of the plaintifi. under 42
OSscs 5 1983, 1985 (2) (3) and by same actions, 1986.
7) That this act, of forced eviction of the plainviic, thru the
use of ialse complaints, and miss use and abuse of same cn and after
vuly 22nd, 1984, was with sole malicious intent, and with the
Js
conspiracy of the owner William Field, who did have relations on
Same West Warwick Police Department. ( Defendant son-in-law, to
be named later thru discovery.) (R)
177-2 [8
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