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Senator Edward Kennedy — Part 20
Page 91
91 / 249
27)
Complaint as an incorporation of this paragraph 26) and attwched
here-in, incorporated into this Count IV. -
PLAINTIFF further charges that on or about September 1Sth,
1984, he did relocate to the City of Providence RI, 31 KENYON
ST.PROVIDENCE RI. Plaintiff states as charged and charged tHat
this relocation, was of a forced/evicted--nature, having lived
in the West Warwick--Coventry--Towns, since 1969, and that at
all times was up to and including September 1984, a law abiding
and peacefull citizen. Plaintiff further charges that in this
relocation to Providence RI, he did also reside at all times as
a peacefull and law abiding citizen, and’ States.that he does to
this day,remain so.
Plaintiff charges, that prior to this forced relocation?
due to the Fire on July 9th,1983, and the alleged charge by~
West Warwick Rolidee, on October 1st,1981, that the plaintiff
denies, of assault to the Defendant Stephen Mowry-~agent UPS,
as charged, plaintiff did receive harassment and intimidation,
per incorporated, paragraph 26) CA 87-0473. Plaintiff charges that
this harassment was at the hands of the West Warwick police ‘dept.,
and was as a direct and proximate result of the booxing of same
Dlaintif£ on October lst,1981, and subsequent coerced "NOLO"
plea of the plaintiff on December 3rd,i981. Plaintiif repeats
charges that he was, entrapped, and coerced into this plea,
in the form of " medicated, denied sleep, spied on,harrassed
and intimidated, and otherwise denied peace of mind, and the’ right
to te mentally stable*-up to and including this "NOLO" Plea,
that he was also advised by the Defendant Donald Packer Esq.,
that he would be able to reverse this plea, if sued Civilly
in this matter,of alledged assault, of which was denied to him
later--and a new trial/trial was also denied.
Plaintiff charges conspiracy to deny "Equal Rights,Equad
Protection of the law", against the West Warwick police Dept.,
originating in atleast, 1970, and continuing to this day im the
form of conspiracy, being aided ana abetted with City of Cranston
Police Dept., City of Providence Police Dept., City of Coventry
police dept.--Defendants, in active acts of conspiracy, harrassing
and intimidating the plaintiff in acts of "Malicious prosecution-
Parking tickets, Motor vehicle violations, entrapment--telephone
bugging-apartment bugging--entrapping the plaintiff--with the
defendant Gloria Hartmann who was forced,/was enlisted to sp¥ on
plaintiff--perjury in testimony in courts, using "John and Jane
Does" to harass and intimidate the plaintiff, Malicious slander
campaign to incite this "Animus Intent", hate-+harrasment campaicn,
Arson to his business--ruination of his good name--ruination of
she lige of the plaintiff and his children-- and any and ail
other acts committed acainst the Dlaintiff,including acts of
omission, totally and with prior*knewWledce anc in conspiracy,
to deprive the oiaintiff of his rights to "Equal Protection
tinder the Laws#-To wit; Police protection, local ana State of
Rhode Island, as well as FBI/Sustice Dept. legal and constitutiona:
protected investigactions--prosecutions-- to protect the Civil
Constitutional rights of the Plaintiff. ~
*S1) ve
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