Saturday, February 26, 2011

NOTICE AND CALL FOR POSSIBLE CLASS ACTION LAWSUIT AGAINST THE MINNESOTA JUDICIARY ET. AL.

Our Founding Fathers recognized that all people are fallen creatures.  We are all susceptible to the temptations of evil. The Founding Fathers sought to minimize the temptations of evil for elected officials in 3 ways:

1) They recognized that all persons are less susceptible to the temptations of evil when we are observed by others.  They recognized the recipe for minimizing the temptation of evil among our politicians to be transparency and Accountability;

2) The Founding Fathers recognized that the temptation of evil increased when too much power was concentrated in one or too few persons.  For that reason, our Founding Fathers created three branches of Government;

3) The Founding Fathers empowered each of the three branches with checks and balances on the others

Unfortunately, over time, the transparency, accountability, checks and balances that our Founding Fathers instituted to keep our Government in Check, have been eroded and/or eliminated.  As a result, corruption runs rampant in the Government and Judiciary of the State of Minnesota.

To the Point, the attached lawsuit may be used as the basis for a class action lawsuit damaged and aggrieved under the following theories and causes of action:

1) That the State of Minnesota and its various agencies have unlawfully retaliated and punished and/or threatened to retaliate and punish Persons who exercised or attempted to exercise their Constitutional 1st Amendment Right to Petition the Government for Redress of Grievances;

2) That the State of Minnesota and the Minnesota Supreme Court failed to adequately Supervise their various employees, agents and Departments and that this resulted in damages to innocent Persons at the hands of the employees, agents and Departments that the State failed to adequately supervise. The MN Board of Judicial Standards and the MN Lawyers Professional Responsibility Board have been so restricted in their authority as to be at best, ineffective and at worst, instruments in complicity in the corruption of the Minnesota Legislature;

3) That the Minnesota Legislature unconstitutionally delegated its constitutional duty to oversee and discipline the Minnesota Judiciary to the Minnesota Supreme Court.  The Minnesota Supreme Court has become a Corrupt Organization.  That the Minnesota House and Senate Judiciary Committees have acted negligently and/or maliciously in denying Minnesota Citizens their Right to Petition the Government for redress of grievances by refusing to take evidence and hear testimony of corruption in the Minnesota Judiciary for at least 5 years;

4) That Minnesota Lawyers, by coercion or quid pro quo arrangement, have betrayed their obligation to put the interests of clients first.  That as a result of the Minnesota Legislature having Minnesota Judges control the discipline and licensing of attorneys, Minnesota Attorneys are more loyal to Judges than they are their own paying, trusting clients (Perhaps this issue is best illustrated by the common reference to "Public Defenders" as "Public Pretenters").;

5)That Minnesota Blatantly Fix cases by telegraphing to attorneys the result they desire in the case at hand.  Because most persons who hire an attorney to represent them are ignorant of the law, effectively the lawyers use "smoke and mirrors" to allow the judge to make the ruling they indicated they wanted.
Because the MN Board of Judicial Standards is so constricted in its authority, criminal acts of Judges and lawyers are allowed to pass as Judicial Discretion;

6) Because the MN Board of Judicial Standards and the MN Lawyers Professional Responsibility Board do not publish the numbers and dispositions of complaints against judges and lawyers, there is no transparency and accountability.  Especially for Judges, this lack of transparency results in an uninformed electorate who cannot express themselves in meaningful, contested Judicial Elections. Because there is no transparency and accountability of lawyers and judges, the public is injured by the resultant systemic corruption of the Minnesota Judiciary;

 If you believe you have been injured or have causes of action related to any of these six theories of Law and/or causes action, Please assess your evidence carefully.

Please read my article,"This is how the Minnesota Judiciary System Fixes Court Cases" for an idea of the thought process and evidence required to prove up your claim.

If you believe you have a good case and want us to consider including as part of a possible class action, please send me a concise, maximum 1 page summary and up to 2 "smoking gun" pieces of evidence to substantiate your position.

Next, be forewarned i am not an attorney.  Hopefully some ambitious, true patriot attorney will volunteer to assist us.

Finally, if you want to get involved in addressing the epidemic of Government Corruption in our Country, may I suggest you participate in this online event this weekend:

Government Corruption Crisis Conference February 27, 2011 (Online)

Freedom isn't Free

Those were my thoughts.

Don Mashak
The Cynical Patriot
http://twitter.com/dmashak


United States District Court
District of Minnesota

                                                                                   
Don Mashak and First National Repossessors, Inc               
                                            Plaintiff(s),                     
                                                                                   
vs.                                                                                            Case No. 11 CV 00473
                                                                                                 
State of Minnesota, Minnesota Supreme Court,
Mary Yunker, Timothy R. Bloomquist, 
Diana Longrie, Lee Wolfgram, Dannette Meeks-Hull,
Michael Hull, John and Jane Doe(s)              
    Defendant(s).
                       
COMPLAINT
________________________________________ _________ ____________________________ 

Plaintiffs, as and for their Summons and Complaint in this matter, state and allege as follows:
1.       Plaintiffs’ will seek “Class Action Status” for this litigation for all persons injured by the unlawful and/or prohibited acts of the State of Minnesota in giving insufficient oversight of its Judiciary and/or specifically for those persons who have petitioned for the redress of grievances and been unlawfully retaliated against by the State of Minnesota and any of the other Defendants in this action;

2.       The State of Minnesota is represented by in Attorney General, Lori Swanson;

3.       The Supreme Court of Minnesota has delegated the duty of overseeing itself by the Minnesota Legislature in violation of the Minnesota Constitution and the principal of checks and balances amongst the various branch of  Government envisioned by the Founding Fathers;

4.       Judge Mary Yunker sits on the Bench of Sherburne County Minnesota in the City of Elk River;

5.       Judge Timothy Bloomquist sits on the Bench of Kanabec  County Minnesota in the City of Mora;
6.       Dianna Longrie is a former Attorney of Plaintiffs with offices located at 1321 Frost Ave. Maplewood, MN 55109

7.       Lee Wolfgram is a former Attorney of Plaintiffs  with offices located at 100 North 6th St #445A Minneapolis MN 55403;

8.       Dannette Meeks-Hull and Michael hull, were an employee and part-time subcontractor, respectively,  of 1st National Repossessors, inc.

9.       Dannete Meeks-Hull and Michael Hull residing  at 27015 BAYSHORE DRIVE, ISANTI MN 55040;
10.   Don Mashak is the sole owner of 1st National Repossessors, Inc, a Minnesota Corporation.

11.   That Plaintiff Don Mashak has pursued reform of the Minnesota Judiciary as is his Constitutional 1st Amendment Right to “Petition the government for Redress of Grievances” for some 24 years;

12.   That in the past approximate 6 years,  a group of Minnesota Citizens and organizations have repeatedly demanded the opportunity to “Petition the Government for redress of grievances” with regard to the Judiciary by seeking to give testimony and evidence to the Minnesota House and Senate Judiciary Committees;

13.   Plaintiff Don Mashak has sought to give said testimony to various Minnesota Governmental bodies for the past 24 years, but most recently and more assertively in the past approximate 4 years, as member of this loose coalition of Minnesota Citizens and Organizations aggressively demanding the opportunity to give testimony and evidence of corruption in the Minnesota Judiciary to the Minnesota House and Senate Judiciary Committees;

14.   Plaintiff Don Mashak has also exercised his Constitutionally guaranteed 1ST Amendment Right to Petition the Government for Redress of Grievances by demanding financial information from various governmental Bodies to determine was his property and other taxes are increasing so dramatically;

15.   The State of Minnesota and the Minnesota Supreme court have unlawfully and illegally  retaliated against Don Mashak in various ways for exercising his constitutionally guaranteed 1st Amendment Right to Petition the Government for Redress of Grievances;

16.   Amongst the ways this retaliation has manifest itself is in the improper handling of unrelated litigation by Plaintiff Mashak and his Company against Defendants Dannette Meeks-Hull and Michael Hull;
17.   As retaliation for Plaintiff Mashak’s Constitutional Right to Petition the Government for redress of Grievances, Defendants have Conspired to Obstruct Justice in the matter of Plaintiff Mashak and 1st National Repossessors, Inc. (hereafter “FNR”) vs Dannette Meeks-Hull and Michael Hull;

18.   Defendants Meeks-Hull and Hull did steal property, embezzle money and otherwise cause loss and damage to Plaintiffs’ while Plaintiff Mashak was out of the Country on vacation;

19.   Upon hearing she was about to be served papers, Defendant Meeks-Hull concocted a wild story of false sexual allegations against Plaintiff Don Mashak;

20.   Plaintiff Mashak took and passed a polygraph refuting the allegations;

21.   Defendants Meeks-Hull and Hull false allegations regarding Plaintiff Mashak have been promoted and used by State of Minnesota and the Minnesota Court to demonize and discredit Plaintiff Mashak;

22.   Demonization and Discrediting of Leaders of Political Dissent is a common practice of Government in the United States (see COINTEL, FBI, Reverend Dr. Martin Luther King Jr.)

23.   This Demonizing and discrediting of Plaintiff Mashak was both unlawful punishment of Plaintiff Mashak for seeking Minnesota Judicial Reform by exercising his Constitutional 1st Amendment Right to Petition the Government for redress of Grievances and to make Plaintiff Mashak’s future attempts to reform the Minnesota Judiciary less credible and less effective;

24.   All retaliation against United States Citizens for exercising their Constitutionally guaranteed 1st Amendment Rights to petition the government for redress of grievances are unlawful and illegal;

25.   Such retaliation stifles the public discourse necessary for the proper functioning of our Representative Constitutional Republic;

26.   Judge Yunker has presided over this case and has demonstrated insurmountable bias against Plaintiffs;

27.   Judge Yunker has frustrated and prevented Plaintiffs Mashak and FNR from depositions, discovery and leave to amend their complaint to encompass more causes of action;
28.  Even though Defendants did not show up at the 7/9/2010 Pre-Trial hearing, Judge Yunker did not find in Plaintiffs’ favor;
29.  Judge Yunker did not get the amended scheduling order out from the 7/9/2010 for months;
30.  As a result, for months Defense argued that they did not know the Discovery deadline had been extended and therefore did not have to answer Plaintiffs’ Discovery;
31.  From July 9, 2010 to early September 2010, Judge Yunker did not return Plaintiffs’ attorney Marl Olson’s calls and written communications for weeks concerning the amended scheduling order and motions to compel Discovery;
32.  Judge Yunker cancelled the 9/16/2010 hearing that would have allowed Plaintiff to amend their complaint, compel discovery Discovery, received Plaintiff’s unanswered Request for Admissions to Plaintiffs’ as admitted;
33.  Judge Yunker would not allow any hearing to be heard, whether by teleconference or physical hearing from 9/30/2011 to 12/29/2010;
34.  Judge Yunker made up a term “suspensed motions” in an attempt to prevent Plaintiffs from bringing forth motions and to prevent Plaintiffs’ from getting evidence on the record.
35.  Judge Yunker hid all the Court file containing all the worst evidence against Defendants Meeks/Hull and Hull in her Chambers, so that demonization and discrediting of Plaintiff Mashak would continue unabated (and to prevent Plaintiffs’ from having access to the file when the file needed to be consulted or referenced)
36.  Judge Yunker refused to hear any discovery related matters from 9/30/2010 to past the 12/17/2010 deadline.
37.  Yet somehow, Judge Yunker, in the approximate 10 days from 1/25/2011 to 2/4/2011, has found time to have a hearing twice, once her attempts to fix the case were successful.
38.  Judge Yunker and Sherburne failed to provide Plaintiff Mashak the Accomodations he is entitled to under the Americans with Disabilities Act resulting from Legal Abuse System and subset of Post Traumatic Stress Syndrome;
39.   Judge Timothy Bloomquist aided and abetted the conspiracy to obstruct justice by refusing to intervene in judge Yunker’s refusal to put out a timely Scheduling order agreed to in the 7/9/2010 hearing that Defendant’s Meeks Hull and Hull did not attend in any way, shape or form;
40.   Judge Bloomquist said he had no authority to discuss the timeliness of providing the amended scheduling order to the parties;
41.   The Minnesota Supreme Court is in charge of the Discipline and licenses of Minnesota Attorneys;
42.   As a result, Minnesota Attorneys are more loyal to Judges they appear before than they are to the Clients they represent;
43.   Therefore, when an Minnesota Judge Telegraphs to Minnesota Attorneys the desired result they want in any particular litigation,  the attorneys are obliged to deliver;
44.   The predetermined “desired result” his known commonly as the “fix” or “the fix being in”;
45.   Over time, the practice and tradition has developed whereby Minnesota Attorneys “fact shape” cases to give Judges the ability to rule in manner the Judge wants the cased fixed;
46.   One common way of these fixes being effected is  by keeping evidence off the official record;
47.   Another common way is by one of the attorneys “accidently” not following the rules. For Example forgetting to file a motion or filing it in an untimely manner;
48.   Both of these previous two practices are calculated to allow the judge to rule on the case to rule in the manner the Judge predetermined by making sure the “official facts admitted on the record” allow the Judge to make the “fixed” determination;
49.   Don Mashak’s first attorney in the Meeks-Hull/Hull matter, Diana Longrie, aided and abetted the conspiracy to obstruct justice in a variety of ways;
50.   Dianna Longrie did not enter evidence, such as Don Mashak’s polygraph on the record;
51.   Dianna Longrie did not correctly cross examine Defendants Meeks-Hull and Hull regarding their outrageous sexual allegations about Plaintiff Mashak;
52.   Dianna Longrie, the day before the actual hearing on the claims that Plaintiffs brought was to occur, informed Plaintiff she could not attend and that Don Mashak could not ask for a continuance;
53.   Dianna Longrie intentionally misinformed Plaintiff Mashak of the documents necessary to meet the requirements for the collection of a deficiency,
54.   Dianna Longrie did not deposition Meeks/Hull nor Hull;
55.   Dianna Longrie and Plaintiff Mashak agreed on fifty requests for admissions and related interrogatories to send to Defendants, but Dianna Longrie never sent this discoverty;
56.   Dianna Longrie stopped returning Don Mashak’s Calls;
57.   Dianna Longrie failed to inform Plaintiffs of a Rule 11 Motion brought by the Defense;
58.   Plaintiffs were forced to fire Defendant Longrie because she stopped communicating and working on the case;
59.   The next Plaintiff Attorney was Joe O’Brien;
60.   Joe O’Brien represented Plaintiffs from approximately November 2010 to June 2011;
61.   Attorney O’Brien missed various deadlines set by the Court;
62.   Attorney O’Brien stopped communicating with Plaintiffs and actively avoided Plaintiffs;
63.   Attorney O’Brien for 3 months would not return Plaintiffs Case file;
64.   Attorney O’Brien did not return the file for 2 months after the Lawyers Board of Professional Responsibility was contacted;
65.   Plaintiff Mashak was informed by text message on or about June 15, 2010 that the file was left in an open car on his property;
66.   The file was missing many documents;
67.   The Minnesota Supreme Court specifically wrote the rules to allow things like this to occur when the Courts want to inconvenience litigants and drain litigants financially;
68.   Common Citizens can have their Driver’s License revoked for refusing to submit to alcohol tests but the Minnesota Supreme Court does not believe Lawyers should be subject to a similar loss of their Lawyers License for refusing to return client case files for months;
69.   Plaintiff Mashak was then forced to submit Requests for Admissions, interrogatories and Document Production requests and Appellate Briefs Pro Se because deadlines were imminently expiring;
70.   Shortly before the July 9, 2010 hearing, Plaintiff Mashak retained Attorney Mark Olson;
71.   Defendants did not appear in person or by Counsel at the 07/09/2010 hearing;
72.   Defendants retained counsel after the 07/09/2010 at the urging of the Court;
73.   Defendants refused to answer discovery claiming they were unaware the Discovery deadline had been extended;
74.   For almost two months, Judge Yunker refused to contact Plaintiffs’ attorney;
75.   On or about September 2, 2010 Defense serve a motion for a rule 11 summary Judgment on Plaintiffs;
76.   Attorney Mark Olson was attempting to get the Judge to send out the amended scheduling order, to set a hearing for a motion to compel discovery requests, request the Court enter Plaintiffs unanswered Admissions as having been admitted,   and to submit the amended complaint;
77.   A September 16, 2010 hearing was cancelled by Judge Yunker to prevent Plaintiffs from compelling Discovery, amending their complaint and having Plaintiffs unanswered Requests for Admissions Admitted.
78.   The effect and intent of Judge Yunker was to prevent Plaintiffs from entering evidence on the record and otherwise make it more difficult for Plaintiffs to prevail;
79.   During this period of time, third parties were telling Plaintiff Mashak that Attorney Olson was “getting it from the front and the back” which Plaintiff understood to mean that while Plaintiff Mashak was demanding Attorney Olson push harder with the litigation; the Minnesota Judiciary was demanding Attorney Olson “fix” the case;
80.   Defendant Judge Yunker insists that Attorney Olson cancelled the hearing, though that is not what Attorney Olson has stated in writing as the matter was occurring nor in answering a complaint submitted by Plaintiff Don Mashak to the Minnesota Lawyers Professional Responsibility Board;
81.   Attorney Olson insisted in answering Defendants Motion for Summary Judgment primarily by saying it was served untimely by 3 days and Attorney Olson refused to submit a more extensive responsive answer to Defendants Motion for Summary Judgment that included evidence and exhibits;
82.   The notes on the Court Computer says approximately that the September 16, 2010 hearing date was changed to allow defenses Motion for Summary Judgment to be timely; (Plaintiff has a photo of the computer screen that will be made available later)
83.   Plaintiff Mashak believes Judge Yunker cancelled the hearing date despite her assertions otherwise;
84.   Attorney Olson did not ask my permission to change the date as required and, if done unilaterally, cancelling a hearing date to compel discovery etc, just before a hearing to hear a Defense Motion for Summary Judgment would not be in Plaintiffs’ best interest and would be an ethical violation by attorney Olson;
85.   Attorney Olson quit shortly before the September 30, 2010 hearing, over the controversies just previously mentioned in this complaint;
86.   At the September 30, 2010 hearing Judge Yunker set the deadline for Dispositive Motions and Discovery for December 17, 2010;
87.   On or about October 28, 2010, Plaintiff Mashak hired Defendant Lee Wolfgram as an attorney in this matter;
88.   Plaintiff Mashak early and often strongly advised Attorney Wolfgram that Defendant Judge Yunker would not extend the December 17, 2010 deadlines;
89.   Plaintiff Mashak told Defendant Wolfgram to Notice the Depositions of the Defendants and other parties of interest immediately;
90.   Plaintiff Mashak told Defendant Wolfgram to subpoena sources of derogatory information on the internet;
91.   Plaintiff Mashak told Defendant Wolfgram to submit the Amended Complaint and Attorney Wolfgram indicates the Judge is refusing to set a hearing anytime soon;
92.   Defendant Wolfgram never executes a subpoena for the source of derogatory information on the internet;
93.   Defendant Wolfgram later tells Plaintiff Mashak that he is just mailing the Amended Complaint to Judge Yunker because the amended complaint is a simple matter that the judge will rule on favorably without a hearing; 
94.   Defendant Wolfgram then later says their must be a hearing for the Amended Complaint but the Judge won’t set a hearing until December 29, 2010 after the December 17, 2010 deadline;
95.   Defendant Wolfgram Notices the Depositions of Defendants Meeks-Hull and Hull about 10 days before the Discovery deadline of December 17, 2010;
96.   Defendants Attorney claims they never go the faxed notice and are not available before the December 17, 2010 deadline and refuse any deposition before the December 17, 2010 deadline;
97.   Judge Yunker refuses a teleconference to resolve the impasse;
98.   Defendant Wolfgram assures Plaintiff Mashak that the Court has to extend the deadline for Discovery because refusing to set any hearings before the December 17, 2010 prevented Discovery and would be a violation of the rules;
99.   At the December 29, 2010 hearing Judge Yunker denies the depositions, denies compelling discovery, denies the amended complaint and refuses to extend the discovery deadline even though Judge Yunker refused to set any hearing before the December 17, 2010 hearing so the Discovery issues could be resolved;
100.         The remainder of the numbered paragraphs from here until the “Causes of Action” are from the Amended Complaint Judge Yunker refused to allow;
101.         On or about January 23, 2006 Defendant Dannette Meeks-Krenzlok (hereafter "Meeks" or "Ms Hull") terminated her employment with I st National Repossessors, Inc. (hereinafter "FNR");

102.         On OR ABOUT January 23, 2006 Defendant Michael Hull, Defendant Meeks’ husband, terminated his sub-contractor relationship with FNR.

103.          1 st National Repossessors, Inc. is wholly owned by Don Mashak (hereinafter "Mashak");

104.          At the time Meeks quit, Mashak was out of the country and due to return the next day;

105.         For a few weeks Michael Hull and Meeks had planned to quit FNR. In other words, both defendants knew they were going to quit their employment with FNR about the time Mashak left for vacation on December 31,2005;

106.         5) At various times during Meeks' employment (that commenced in 2004), Mashak overheard various comments by other company employees and agents that he felt were not ;

107.          In the spring of 2005, Mashak paid for Meeks, and his sister Deanna Mashak, to fly to Houston Texas to visit another repossession company for training;

108.         In the fall of2005 Mashak allowed Defendant Michael Hull to take Meeks for an unscheduled surprise vacation to celebrate their recent marriage;

109.         In September of 2004 Mashak cosigned for, took a 2nd lien in and executed a contract with "Right of Offset" so that Meeks could buy the 2000 Ford Excursion VIN IFMNU41S4YEC17692 (hereafter "2000 Ford Excursion"), as evidenced by a loan contract and 2nd lien contract;

110.         Various issues caused Plaintiff Mashak to question the competence of Defendant Meeks in late fall of 2005;

111.         Mashak decided he was going to try to squeeze in the vacation before he either motivated Meeks to improve her productivity or fire her because it would be a long time before someone else could be trained so Don Mashak could once again go on vacation;

112.         Mashak left on vacation December 31, 2005;

113.         While Mashak was out of town, Meeks was required to refer all issues of importance and urgency that came up to his sister, Deanna Mashak;

114.         Payroll was to be delivered to Deanna Mashak's house five days in advance of pay day so funds could be transferred. This was not a big issue because Meeks passed within a couple ofblocks Deanna Mashak's house coming to and from home and the office;

115.         Defendant Meeks laid down an ultimatum that she would quit if the payroll was not on time for the January 16, 2006 payday; and then she failed to deliver the payroll to Deanna Mashak before Deanna Mashak had to leave for work on the 16th• This contrivance would later be her basis for quitting;

116.         While Mashak was on vacation, James Hocket was directed to pick up the company mail from the post office box a few days a week and deliver it to the office;

117.         On a number of occasions while Mashak was on vacation, Tom Corder (the owner ofthe business across the hall from FNR) told Mashak that the FNR office was closed several times for long periods oftimes during normal business hours;

118.         Plaintiff Mashak expressed his concerns to Meeks via phone and she became hostile and belligerent;

119.         Mashak backed off on the confrontation and questioning, feeling helpless and powerless to do anything thousands of miles away;

120.         Thereafter, Meeks corrected her observable behavior as was relayed to Mashak by persons sent to check up on the office found Meeks there;

121.         Mashak then decided that there would be no grace period for Meeks to improve her performance; and, she would no longer be able to charge the company when she was not ;

122.         At some point in time while Mashak was gone) Meeks erased the last approximately 3 months of email communications off her company owned computer after making written and electronic copies for herself;

123.         Meeks erased the three or four months of email in the general email box to her; and, between herself and Mashak and others to cover up her theft of company proprietary information and communications that might demonstrate that she was stealing proprietary information;

124.         This was done by Meeks to start her own company and/or go to work for a competitor;

125.         Meeks also erased payroll and other records off the computer system before Mashak returned;

126.          Meeks also stole her personnel files, her husband)s records and any other of her relatives who had been FNR employees and/or agents before Mashak returned from vacation;

127.         Meeks stole the files to destroy her the contract that included non-compete and non-disclosure provisions; and, to destroy any other incriminating information pertaining to her husband and relatives;

128.         Meeks also stole the file containing the loan documents for the 2000 Ford Excursion;

129.         While Mashak was on vacation, Meeks purposely and maliciously failed to deposit checks in Plaintiffs’ Business Account;

130.         Meeks and Defendant Hull also stole company property, files and documents from Plaintiff Mashak' s business;

131.         Some of the stolen property included a cell phone, a camera, keys to the office and keys to Mashak’s personal car among other items;

132.         Tom Corder, the owner of a business across the hall from FNR, told Mashak that he saw Meeks transporting computer equipment (that belonged to Mashak and/or FNR) in her vehicle;

133.          Shortly before Plaintiff Mashak’s return, Meeks then informed Mashak that she was quitting;

134.          Mashak's flight was delayed due to a snow storm and as a result the office was going to be unmanned without the keys from Meeks;

135.         Meeks told Plaintiff she had none of Plaintiffs’ property until Plaintiff Mashak asked her about the office keys, which Meeks admitted to having and needing to return;

136.         Meeks assured Mashak she would take and had no other property belonging to Plaintiffs.

137.         Mashak asked Meeks to make arrangements to allow Deanna Mashak to pick up the keys or to bring her the keys to her residence;

138.         When Meeks showed up, she refused to leave the keys with Deanna Mashak's daughters, despite instructions to do so, in yet another attempt to harass, annoy and cause immeasurable problem for Don Mashak. This is another display of the contempt for, and lack of fear Defendant Meeks now alleges she had of Mashak;

139.         Mashak returned on or about January 24, 2006;

140.         When Mashak returned, he first noticed the keys to his personal car missing. As the days went by, Mashak found several other items such as files, cell phone, camera, personal property and data missing. Mashak also found data deleted from the computers, especially payroll data;

141.          James Hockett stated that he had brought in several large deposits of money while Mashak was on vacation and they were not reflected in the bank deposit records;

142.         Most Notably, the day James Hocket startled Meeks by stating Mashak would be back in a day or two, Hocket verified he left approximately $3000.00 to be deposited; however, the deposit records for that day only showed about $600.00 was deposited;

143.         Following Plaintiff Mashak’s return, various company vendors and clients made vague references to Mashak about Meeks calling them up and bad-mouthing Mashak and FNR, but gave no specific details and were generally dismissive of the allegations;

144.         Mashak found a discrepancy in the payroll. While there was only one vehicle for a person whose last name was Erkilla-Witt, the payroll that Meeks submitted showed one half of a debtors hyphenated last name had been used on the payroll ledger to evidence $100.00 to be paid to Agent Lee Baldwin, and the other half of the debtors hyphenated last name was used to evidence $100 to be paid to Defendant Meeks' husband Defendant Michael Hull;

145.         Mashak contacted Lee Baldwin and asked if Defendant Hull had any involvement in the said repossession involving the debtor with the hyphenated last name. Lee Baldwin said Defendant Michael Hull had no involvement in the repossession whatsoever. Furthermore, while the notes on the Erkil1a-Witt computer records are initialed by Meeks, there is no note of her husband having anything to do with the vehicle;

146.         Mashak verily believes that any reasonable person would see the separating of the hyphenated name as the deliberate, duplicitous attempt to prevent Mashak from realizing the double payment;

147.         The fact that there are no notes in the computer record for that account that mention Defendant Michael Hull or mention the need to move the vehicle, speaks to the false nature of the defense that Mashak said he would pay anything to have Defendant Michael Hull do anything with the vehicle;

148.         Meeks did not inform Deanna Mashak that she was quitting, even though she was instructed to communicate all urgent and major issues to Deanna Mashak;

149.         Defendant Meeks and Defendant Michael Hull at first denied having and/or stealing any company property;

150.         Several more times, both Defendants denied having any property of Plaintiffs.

151.         Defendants did not return the company property that they had at their house before Mashak returned;

152.         Mashak asserts that the failure to return the property on or before Defendants' last day is much more consistent with Defendants having any company property in their possession with intent to steal it, than with the contention that it was items that Meeks had at home to work on after normal work hours and just forgot to return;

153.         At some point after Mashak returned, Tom Corder told Mashak about an incident in which Meeks' vehicle had a window broken out of it. In viewing the damage Tom Corder noticed the computer equipment in the vehicle;

154.         Plaintiff Mashak later  noticed computers and equipment missing from the back storage room;

155.         Mashak and his sister Deanna Mashak went to Defendants Meeks and Hulls' residence with the Anoka Sheriff's Department a few days after Mashak got back in town in January 2006 to recover whatever property they could, along with missing vehicles and a tow dolly;

156.         Law Enforcement required that Mashak and his sister wait at the curb;

157.         The deputy returned from their door with a few files and some keys;

158.         Mashak and Deanna Mashak left with the files, the tow dolly and a vehicle that Defendants had previously denied having;

159.         Plaintiff Mashak wrote Defendants a couple of letters in the weeks after he returned and had his attorneys write letters;

160.         Defendant Meeks has admitted she had psychological issues before she began employment with Mashak and FNR;

161.         Meeks told Mashak a story in December of2005 wherein she claimed that earlier in her life her ex-husband was a big time drug dealer and that their marriage ended when he allegedly held a gun to Defendant Meeks' head while snorting cocaine from a huge pile like a scene out ofthe movie "Scarface";

162.         Defendant Meeks, by her own admission, acknowledged that she had previously sought medical help for her psychological problems;

163.         Defendant Meeks also told Mashak she was in the witness protection program for testifYing against her ex-husband;

164.         Plaintiff Mashak alleges Defendant Meeks only sought psychiatric help after she received the notice that Plaintiffs were aware of her criminal activities;

165.         Plaintiff Mashak asserts that if Defendant Meeks had an alleged nervous breakdown, it is the result her of realizing her various frauds and thefts had been discovered;

166.         Defendant Meeks insisted to the Anoka County Sheriffs Department that the property that was returned via the Anoka Sheriffs Department was all the property they had;

167.         Plaintiff Mashak's attorneys sent Defendants more letters demanding the return ofstolen property, data and files. Finally, about a coule weeks later, after more denials of having company property, Defendant Hull returned yet more property, including the keys to Mashak's personal car to Plaintiffs’ attorneys’ office;

168.         Other agents and employees of FNR and Deanna Mashak began telling Mashak that Meeks and her husband Michael Hull were trying to start there own repossession business after they left FNR;

169.         In spring of 2006, Mashak learned that Meeks was working at another Twin Cities repossession company and called there to inform them ofthe non-compete agreement;

170.         In July or August of2006, Defendants tried to trade in the 2000 Ford Excursion, without disclosing the second lien held by Mashak;

171.         Defendants apparently believed that the theft of the loan file would successfully end Mashak' s proof of second lien on the vehicle which they attempted to trade it in violation ofMinn. Stat. §609.62;

172.         Plaintiff Mashak has other causes of action to recover monetary damages from Defendants, one as simply being the cosignor and two, because of the uninsured damages the car experienced while in the care, custody and control of Defendants Meeks and Hull and/or their agents and assigns;

173.         When Walzer Car sales called, Plaintiff Mashak asked for $2000.00 to release the lien. Walzer decided to undo the deal, rather than pay the payoff;

174.          In an attempt to damage Mashak's credit, Meeks insisted the vehicle had to be repossessed; and, Defendant Meeks said she would not allow Mashak to take possession directly;

175.         Further Defendant Meeks insisted the 2000 Ford Excursion be repossessed so Plaintiff Mashak would be forced to pay it off rather than continue to make payments on it;

176.         The credit union holding the loan repossessed the vehicle;

177.         Defendants insisted the vehicle was in great shape as did the credit union; however, they would not let Mashak see it before he paid for it;

178.         Mashak paid off the loan with the credit union in cash but was not allowed to pick it up that day;

179.         Steve Lolls, Mashak's business associate, said he was interested in buying the 2000 Ford Excursion for his wife for between $9000.00 and $10,000.00, if it was in good condition;

180.         When Mashak and Steve Lolls showed up to pick up the 2000 Ford Excursion from the credit union, it was severely damaged;

181.         Due to the condition of the vehicle Steve Lolls backed out of buying it;

182.         Neither the credit union nor Defendants would provide any explanation for what had happened to the vehicle nor the insurance information so that Mashak could make an insurance claim;

183.          Defendants thereafter claimed that they bought the vehicle in that poor condition; however, their claims are refuted by the person they bought the vehicle from who stated there was only one dent on the comer and some superficial scratches; and, there was nothing close to the terrible condition the unit was in when Mashak redeemed the vehicle;

184.         Mashak sent a notice of Right to Redeem and Sale to Defendants;

185.         Due to the poor condition of the vehicle, and increasing gas prices, Mashak initially didn't get any good bids for the vehicle;

186.         Mashak sent Defendants a notice and accounting of deficiency in a timely manner in June of 2007;

187.         Defendants failed to pay the deficiency;

188.         Thereafter, Mashak offered to give the vehicle back and let Defendants out of all costs directly involving it if they paid the original $6,900.00 Mashak paid the credit Union;

189.         Defendants did not accept that offer;

190.         The 2000 Ford Excursion was sold in June of2007 for $5,500.00;

191.         In January of2008, Mashak filed a small claims court claim against Defendants;

192.         Defendants avoided service of process for several months and moved to Isanti County;

193.         Defendants' new address was discovered by a in late November or early December 2008;

194.         The day after Mashak gave notice to the courts of the need to change venue, Meeks served a harassment restraining order on Mashak, claiming the entire small claim was baseless.;

195.         The trial court granted the order, which was based upon false evidence, testimony and motive. [Court File No. 30-CV -08-1298] Plaintiff Mashak asserts that Defendant Meeks made the claim of harassment in bad faith, when it became apparent she could no longer avoid service of process and would be held accountable for her criminal acts;

196.         Plaintiff Mashak alleges that all of said false statements were made with malice, with the express intention of Defendants furthering their own interests and/or  causing Plaintiff Mashak severe mental and financial duress.

197.         Mashak has taken and passed a polygraph with regards to the most egregious of Defendant Meeks’ allegation;

198.         Plaintiffs’ have obtained the affidavits of several employees and agent in the relevant time period who dispute Defendants allegation in this regard;

199.         Defendant Meeks is known to not be credible, as evidenced by affidavits of various employees, agents and clientsl. When Meeks sought employment with Plaintiffs, she represented she previously was a Hennepin Country Sheriffs Deputy, which was false.  Some ofFNR's clients stated that Meeks also told them she had been a Hennepin County sheriff Deputy;

200.         Defendant Meeks had a power struggle with one of FNR's agents and that agent investigated and demonstrated that Defendant Meeks had lied about being a sheriffs deputy; and, was a actually a staff-worker in the child protection unit;

201.         Meeks now denies ever saying she was a Hennepin County Sheriffs Deputy. In fact, she apparently stole her personnel file to prevent discovery of her lie;

202.         Plaintiffs reserve right to transform to a class action suit for all persons who have been injured by for petitioning the State of Minnesota for Redress of Grievances and/or injured by the failure of the State of Minnesota to properly oversee its employees and agencies, primarily those in the Minnesota Judiciary;

COUNT ONE – Unlawful Punishment and Retaliation for Plaintiff Mashak exercising his Constitutional 1st Amendment Right to Petition the Government for Redress of Grievances

203.         Plaintiff’s reallege paragraphs 1-202;

204.         The State of Minnesota and the Minnesota Courts have retaliated and punished Plaintiff Mashak for exercising his 1st Amendment Right to petition the Government for Redress of Grievances by conspiring to demonize and discredit him through there various acts;

205.         Amongst these acts were aiding and abetting Defendants Meeks-Hull and Hull in perpetrating their false allegations against Mashak by denying Plaintiffs the opportunity to clear Plaintiff Mashak’s name through litigation by unlawfully thwarting and stifling Plaintiffs’ legitimate Litigation;

206.         Plaintiffs were denied Depositions, Subpoenas, Discovery and the opportunity to amend their complaint;

207.         Among the punishments the Defendants exacted on Plaintiff Mashak were increased the price of litigation, damage to Plaintiffs Mashak’s health, destruction of Plaintiff Mashak financial condition and damage to Plaintiff Mashak’s business interests;

208.         Mashak reallege paragraphs 1 -202 above; ) Defendants actions herein are extreme and outrageous and have passed the boundaries of decency to the extent that the actions are utterly intolerable to the civilized community;

209.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $10,000,000.00 which Plaintiffs are entitled to recover;

COUNT TWO – RACKETEERING, INFLUENCE AND CORRUPT ORGANIZATIONS

210.         Plaintiffs reallege paragraphs 1-209;

211.         The Minnesota Legislature unconstitutionally delegated its responsibility for the oversight of the Minnesota Judiciary to the Minnesota Judiciary;

212.         The Minnesota Supreme Court has written the rules to allow Court Cases to be “fixed” with great protections to all those involved in fixing the case;

213.         The Minnesota Supreme Court has written Laws making it lawful for Judges to takes “Tips” otherwise known as bribes;

214.         There is no limit to the number of bribes that Judge can take in a day save that individual bribes over $150.00 must be reported.  (eg 100 bribes of $149.00 would not have to be reported)

215.         That the Minnesota Supreme Court has oversight of the discipline and licenses of Minnesota Attorneys;

216.         As a result, Attorneys in Minnesota are more loyal to the Judges they appear before than the Clients they represent;

217.         The Minnesota Supreme Court and Minnesota Legislature have written the rules for the Minnesota Board of Judicial Standards such that the Board cannot speak to most issues of misconduct of a Judge that rise to a criminal level except for transgressions involving trust funds;

218.         The Rules of the Board of Judicial Standards generally do not allow the Board to address issues of how a Judge conducts themselves except for such things as repeated tardiness, untimely filing of various legal filings and being openly drunk on the bench;

219.         For most matters, The Supreme Court has written the rules such that the only recourse for litigants is to Appeal,  and the Supreme Court has written the rules that way knowing that most persons do not have the knowledge to appeal themselves nor the money to pay an attorney to do so, thus insuring that most “fixed” cases will never be subject to scrutiny;

220.         That it is these Rules written with the intent to be duplicitous that have allowed the Corruption in the Minnesota Judiciary to become Systemic;

221.         That the Defendants have violated the Judicial Rules understood to the General Public to wrongfully punish, demonize and discredit Plaintiff Mashak;

222.         That the Defendants in this matter have unlawfully retaliated against me for petitioning the Government for Redress of Grievances in a Systemic criminal manner fully consistent with the types of criminal actions the RICO act intended should be prosecuted;

223.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $10,000,000.00 which Plaintiffs are entitled to recover;

COUNT THREE – OBSTRUCTION OF JUSTICE

224.         Plaintiffs reallege paragraphs 1-223;

225.         The Defendants all worked to unlawfully obstruct justice;

226.         Defendants’ Meeks-Hull and Hull falsely interposed an outrageous sexual allegation when they were caught embezzling money and stealing property from Plaintiffs’

227.         The remainder of the Defendants seized upon this false allegation as a way to unlawfully punish Plaintiff Mashak for exercising his constitutional right to petition the Government for redress of Grievances;

228.         The State of Minnesota and the Minnesota Supreme Court through Defendants Yunker, Bloomquist, Wolfgram and Longrie each acted to deny Plaintiffs full, fair, equitable, unbiased and just adjudication of the original matter which denied and obstructed Justice for Plaintiffs;

229.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $10,000,000.00 which Plaintiffs are entitled to recover;

COUNT FOUR – CONSPIRACY TO OBSTRUCT JUSTICE

230.         Plaintiffs reallege  paragraphs 1-229;

231.         All of the Defendants acted to deny Plaintiffs full, fair, equitable, unbiased and just adjudication of the original matter which denied and obstructed Justice for Plaintiffs;

232.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $10,000,000.00 which Plaintiffs are entitled to recover;

COUNT FIVE – CRUEL AND UNUSUAL PUNISHMENT

233.         Plaintiffs reallege  paragraphs 1-232;

234.         Allowing Plaintiffs to believe Justice was being fairly administered, when in fact, the entire process was being manipulated and “fixed” was cruel and unusual punishment;

235.         And this concept of law applies to this situation, because it was the intent of the Defendants to Punish Plaintiff Mashak by demonizing and discrediting him for the “undeclared yet true reality” that Political Dissent is punished by our Government;

236.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $10,000,000.00 which Plaintiffs are entitled to recover;

COUNT SIX – THEFT BY SWINDLE

237.         Plaintiffs reallege  paragraphs 1-236;

238.         Attorney Defendants Wolfgram and Longrie induced Plaintiffs to pay them money by falsely stating that they would represent Plaintiff Mashak to the best of their ability;

239.         Attorney Defendants Wolgram and Longrie instead participated in fixing Plaintiffs case against the best interests of Plaintiffs;

240.         In the same way, The Courts wrongfully induced Plaintiffs to give them money on the representation that Plaintiffs would receive full, fair, equitable, unbiased and just adjudication of their litigation;

241.         From the facts in evidence, it is clear that the Minnesota Courts fraudulently induced Plaintiffs to pay them certain fees when the Court had no intent to provide Plaintiffs with impartial Justice;

242.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $10,000,000.00 which Plaintiffs are entitled to recover;

COUNT SEVEN – MEDICAL EXPENSES

243.         Plaintiffs reallege  paragraphs 1-242;

244.         The unlawful acts of the Defendants have caused Defendant Great psychological and physical distress;

245.         Plaintiff Mashak has succumbed to LEGAL ABUSE SYNDROME a subset of Post Traumatic Stress Syndrome as a result of the false allegations of Defendants Meeks-Hull and Hull and as a result of the unlawful  acts of the remainder of the Defendants in attempting to prevent these false allegations from being exposed;

246.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $100,000.00 which Plaintiffs are entitled to recover;

COUNT EIGHT – EXTORTION

247.         Plaintiffs reallege  paragraphs 1-246;

248.         Attorney Wolfgram, on two or more occasions, demanded Plaintiff Mashak sign a document stating Plaintiff Mashak was satisfied with his representation, or Defendant Wolfgram would quit as Plaintiffs’ attorney;

249.         This constitutes extortion as Defendant knew that Plaintiff Mashak would have to pay another attorney the cost of familiarizing them with the case;

250.         As such, Defendant Wolfgram was extorting Plaintiff Mashak for an “alibi” and for the money Plaintiffs would otherwise have to pay to another attorney to once again familiarize themselves with the case;

251.         As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $100,000.00 which Plaintiffs are entitled to recover;
COUNT NINE - Intentional Infliction of Emotional Distress
252.         Mashak reallege paragraphs 1 -251 ;

253.         Defendants Meeks-Hull and Hull made statements to third parties alleging that Mashak had sexually harassed  them and/or had made improper sexual advances and/or had told them he had sex with minors in the Philippines;

254.         Defendants' Meeks-Hull and Hull’s statements were false;

255.         The Remainder of the Defendants terrorized Plaintiff Mashak by their actions to punish, demonize and discredit him by depriving him of the right to clear his name through the legal process;

256.         Defendants actions herein are extreme and outrageous and have passed the boundaries of decency to the extent that the actions are utterly intolerable to the civilized community;

257.         Defendants' actions were intentional and/or reckless;

258.         Defendants actions have caused emotional distress to Mashak;

259.         The emotional distress suffered by Mashak has been severe in nature to the extent that no reasonable person could be expected to endure it;

260.         As a direct and proximate result of Defendants' actions, Mashak has been injured and harm to an extent greater than $50,000 which Mashak is entitled to recover;

COUNT TEN – BREACH OF FIDUCIARY DUTY

261.         Mashak realleges paragraphs 1 -260 above;

262.         Defendants owed a fiduciary duty to Plaintiffs in the capacity of employees who were entrusted with confidential and proprietary information and who were required to act in the Plaintiffs' interests, not their own;

263.         Defendants breached their fiduciary duty to the Plaintiffs by their actions, as enumerated above;

264.          As a direct and proximate cause of Defendants' wrongful actions Plaintiffs have been damaged in an amount in excess of $50,000 which Plaintiffs are entitled to recover;
COUNT ELEVEN  - TORTIOUS INTERFERENCE WITH BUSINESS ADVANDAGE
265.         Plaintiffs reallege paragraphs 1 -264 above;

266.         Plaintiffs had the reasonable expectation of economic advantage or economic benefit through the continued operation of FNR;

267.         Defendant had knowledge of the expectation since they were privy to it as employees;

268.          Defendants wrongfully and unjustifiably interfered with that expectation by stealing customer lists, client files and/or proprietary business information;

269.         Defendants' actions have prevented Plaintiffs from obtaining an economic advantage in Plaintiffs' line of work that Plaintiffs would have obtained but-for Defendants' interference;

270.         Defendants' actions were intentional;

271.         As a direct and proximate result Plaintiffs have been damaged to an extent greater than $50,000 which Plaintiffs are entitled to recover;
COUNT TWELVE – ABUSE OF PROCESS
272.         Plaintiffs reallege paragraphs 1 -271;

273.         Defendants alleged in said action that Mashak was stalking them and engaging in harassing behavior toward them;

274.         Mashak had engaged in no such activity against the Defendants and in fact was merely attempting to lawfully utilize the court system to seek lawful redress against said Defendants;

275.          Defendants on the other hand improperly abused the court system to wrongfully obtain harassment relief in an attempt to thwart Mashak's lawful attempt to seek legal redress;

276.         The harassment statutes were not intended to act as a shield against justified litigation; rather, they are intended to prevent a person or persons from engaging in harassing activities as defined by the statutes;

277.         In obtaining the harassment order in this matter Plaintiffs wrongfully engaged in perjury and misrepresentation;

278.         As a result of Plaintiffs ' abuse of process the harassment order issued, which has caused damages to Mashak in excess of $50,000;

279.         In addition to monetary damages incurred by Mashak, the findings in the harassment action and resultant order continue to inflict great harm and damage to the Plaintiffs' business and personal reputations;

280.         The only way to rectify the prior and continuing damage is to vacate the harassment order in its entirety and to expunge the proceeding;

281.         Statutory authority for the vacation and expungement of the harassment order is set forth in Minn. Stat. §548.14,
"Any judgment obtained in a court of record by means of perjury, subornation of perjury, or any fraudulent act, practice, or representation of the prevailing party, may be set aside in an action brought for that purpose by the aggrieved party in the same judicial district within three years after the discovery by the aggrieved party of such perjury or fraud. In such action the court may either enjoin the enforcement of the judgment or command the satisfaction thereof, may compel the party procuring the same to restore any property received by virtue thereof, and may make such other or further order or judgment as justice shall require; but no right or interest of a third party acquired under such judgment in good faith, and without knowledge of the wrong complained of, shall be affected by the action herein provided for; provided, if during the pendency of such action the enforcement of such judgment or an action thereon shall become barred by the statute of limitations, and such judgment is sustained, the same may be enforced, or an action commenced thereon, within one year after such action is finally determined. "
282.         Mashak seeks said vacation and expungement herein;
COUNT THIRTEEN  -  THEFT OF TRADE SECRETS
283.          Plaintiffs reallege paragraphs 1 -282 above;
284.         Defendants, in the scope oftheir employment, obtained information, devices, methods and techniques that had intrinsic economic value that was not generally known to competitors in the repossession business that the Plaintiffs are engaged in;
285.         Defendants were required to sign non-disclosure, non-compete and confidentiality agreements as part of their employment due to the need for secrecy to protect Plaintiffs' interests in said property;
286.          Plaintiffs unlawfully misappropriated said information, devices, methods and techniques;  That as a direct and proximate result of said misappropriation, Plaintiffs have been damaged in excess of $50,000 which they are entitled to recover;
287.         Plaintiffs have also incurred and will incur attorney's fees and costs as a direct and proximate result of said misappropriations which Plaintiffs are entitled to recover;
COUNT FOURTEEN - Intentional Interference With Contract
288.  Plaintiffs reallege paragraphs 1 -287 above;
289.  Defendants, through their employment with Plaintiffs, were aware of contractual relationships that Plaintiffs had with third parties;
290.  Defendants intentionally attempted to interfere with and/or convert those relationships for their own monetary benefit;
291 .As a direct and proximate result of Defendants' wrongful actions, Plaintiffs have been harmed to an extent greater than $50,000 which Plaintiffs are entitled to recover;
COUNT FIFTEEN  -  Breach of Contract
292. Mashak realleges paragraphs 1 -291 above;
293. Mashak and Meeks entered into a contractual agreement wherein Mashak signed and obligated himself for the purchase of a 2000 Ford Excursion;
294. Meeks on the other hand agreed to timely make the payments when due on said vehicle and to keep said vehicle in good  working order and condition;
295. Meeks breached her agreement by failing to timely make the payments and by failing to keep the vehicle in good working condition;
296. As a direct and proximate result of Meeks' breach, Mashak has been damaged in the amount of$3,000.00 which Mashak is entitled to recover against her;
COUNT SIXTEEN -  CONVERSION
297. Plaintiffs reallege paragraphs 1 -296 above;
298. During the course ofDefendants ' employment with Plaintiffs, Defendants were placed into a position to handle various business property, equipment and money;
299. As more fully described above, Defendants wrongfully stole, converted and/or absconded with monies and properties belonging to the Plaintiffs;
300. While the exact value of the monies and property is unknown at this time, it is likely greater than $50,000;
301. Plaintiffs are entitled to recover said amount from the Defendants;
302. Meeks wrongfully attempted to defeat Mashak's security interest in the 2000 Ford Excursion identified above by attempting to sell said vehicle without first satisfying Mashak's security interest therein;
303. As an alternative to Count Eight, Mashak is entitled to recover any losses he sustained as a direct and proximate result of Meeks ' failure to keep the subject vehicle in good working condition and appearance and her failure to timely make payments against said vehicle;

303A) Mashak is entitled to recover $3,000.00 from Meeks;
COUNT SEVENTEEN -  Breach of Non-compete Agreements
304.) Plaintiffs reallege paragraphs 1 - 303 above;

305. Defendants entered into non-compete and non-disclosure agreements with Plaintiffs;
306.  Said agreements called for liquidate damages of $25,000 for violations of said agreements;
307.  Defendants violated said agreements by obtaining employment contrary to said agreements and by disclosing information contrary to said agreements;
308. Plaintiffs are entitled to recover from Defendants the sum of$25,000 for said violations;
COUNT EIGHTEEN  – PUNITIVE DAMAGES
               309.  Plaintiffs reallege paragraphs 1 - 303 above;
               310. Whereas the trauma suffered by Plaintiff Mashak has been so outrageous and devastating;
               311. Whereas the necessity of protecting and reasserting the General Publics Constitutional 1st
Amendment Right to Petition the Government for Redress of grievances without threat of or actual retaliation is central to the functioning and preservation of the American Constitutional Representative Republic created by our Founding Fathers;
              312. Plaintiffs ask $10,000,000.00 in punitive damages from Defendants;
WHEREFORE, PLAINTIFFS REQUEST THE FOLLOWING RELIEF OF THIS COURT:
1.  The vacation and/or expungement  of the harassment order contained in Court File No. 30-CV-08-1298 and the permanent sealing of said file;
2. Granting the Plaintiffs damages against the Defendants, jointly and severally, in an amount in excess of $10,000,000.00;
3. Granting the Plaintiffs their attorney's fees, costs and disbursements herein; and
4. For such other and further relief as to the Court is fair and just.


Dated: February 24, 2011
Don Mashak
Pro Se                                                   
POB 231 Albertville MN 55301 612-723-7780
1st National Repossessors, inc. 950 Hwy 10 #4 Elk River MN  55330 612-723-7780

Minnesota Injustice: True Court Horror Cases - With Names

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