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Senator Edward Kennedy — Part 20

249 pages · May 11, 2026 · Document date: Jun 22, 1987 · Broad topic: Politics & Activism · Topic: Senator Edward Kennedy · 249 pages OCR'd
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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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