UNITED STATED DISTRICT COURTDISTRICT OF RHODE ISLAND

Plaintiff

Melinda Laucks 2D Bonniecrest GardensNewport RI 02840401 846 1898

v. COMPLAINT

Defendants:

Mark McVayc/o Adult Correctional Institution, 40 Howard Street, Cranston RI 02920

John Deacon Jr. Esq. 72 Pine Street, Providence RI 02903 W. Mark Russo, as individual and in his capacity as RI Superior Court Special Master55 Pine Street, Providence RI 02903

John A. Dorsey, as individual and in his capacity as RI Superior Court Special Master55 Pine Street, Providence RI 02903

Seth Schalowc/o 55 Pine Street, Providence RI 02903

Michael A. Silverstein, as individual and in his capacity as RI Superior Court Judge250 Benefit Street, Courtroom Room 17, Providence, RI 02903

Benjamin Cutchshaw, Esq.695 Town Center Drive 17th Floor Costa Mesa, CA 92626. Phone: +1 714 668 6200

1 At all times mentioned hereafter, except as noted, the Plaintiff is and remains a resident of the State of Rhode Island.

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2 Defendant Mark McVay is a resident of the State of Rhode Island currently incarcerated at the Adult Correctional Institute in Cranston, RI

3 Defendant John Deacon Jr. Esq. resides and practices law in the State of Rhode Island

4 Defendant W. Mark Russo Esq. resides and practices law in the State of Rhode Island and

acts as Court Appointed Special Master to the business US Textile Inc.

5 Defendant John A. Dorsey Esq. practices law in the State of Rhode Island and acts as

Court Appointed Special Master to the business US Textile Inc.

6 Defendant Seth Schalow resides in the State of Rhode Island and maintains operations of

US Textile Inc. under the direction of the Special Master.

7 Defendant Michael A. Silverstein resides and acts in the capacity of Rhode Island

Superior Court Associate Justice, Providence County

8 Defendant Benjamin Cutchshaw Esq. resides and practices law in the State of California

and is attorney for Kolon Industries, the client of US Textile Inc.

9 The Jurisdiction of this Court is invoked pursuant to: RICO Act 91-452, Foreign and

Interstate Commerce Clause, Antitrust, violations of civil rights 42 U.S.C. § 1983

Diversity of Citizenship 28 U.S.C. § 1332,

SUMMARY OF CASE

10 Comes Now, the Plaintiff having been wrongfully denied rightful ownership and access

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to her business, US Textile Inc. in conjunction to crimes of physical violence upon her on two

occasions within a ten year period, first in 2005 for a period of nearly one year, and again in

2013 by Mr. Mark McVay, her former business partner, who pleaded no lo contendere to crimes

of vandalism, domestic disturbance and also committed assault with a deadly weapon upon her,

and issued other threats of bodily harm, extortion, embezzlement, conversion and used business

funds for the purchase and reckless consumption of improperly acquired controlled substances

including cocaine, marijuana, and adderall; and other personal items beyond a reasonable

allowance.

11 Mr. McVay has been aided and abetted wholly or in part by the remaining Defendants

who have, through abuse of authority, color of office, extortion, intimidation or other means of

collaboration have wrongfully converted the business US Textile Inc. to their own control with

the intention to manipulate the Judicial System to retain ownership permanently.

12 The collective activities of the Defendants have cause the wrongful and permanent denial

of Melinda Laucks to her rightful ownership of US Textile Inc. a business that she spent 13 years

building from nothing. The Defendants have also interfered with her Federally protected

activities including her First Amendment right to petition and participate in a public concern;

they have interfered with her right to associate with persons in her industry, gain rightful

employment in her industry, and have caused permanent defamation of her professional

reputation. Their actions have caused financial devastation and such severe emotional trauma as

to require two instances of hospitalization for anxiety, panic attacks and despair.

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13 The Defendants used extortion, blackmail and intimidation by public official, color of

office and abuse of the RI Judiciary System to their own financial gain and for the sole intention

of permanent conversion of the business to their own property. Their wrongful expulsion of the

Plaintiff was in complete disregard to the abundant evidence filed by the Plaintiff of Mr. McVay's

breach of fiduciary duty, his attempted embezzlement, and pleadings of no lo contendere to

multiple crimes of physical violence.

14 The business US Textile Inc. is incorporated in the State of Rhode Island but its only

client, Kolon Industries is located in South Korea and all of its customers are located outside of

the State of Rhode Island, thus the Defendants interfered with the Plaintiff's activities and rights

in respect to foreign and interstate commerce.

Factual Background

15 From summer of 2001, Ms. Laucks and Mr. McVay started, as an un-incorporated

partnership, concurrently to their full time jobs, a part-time company, US Textile, as a textile

sales agent in New York City.

16 In January of 2002, Mr. McVay and Ms. Laucks met Kolon Industries, and became

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Kolon's textile agent in North America. Kolon became the business's only client.

17 In September 2002, the business relocated to Newport, RI, and business partners shared

an apartment as roommates. US Textile's contract with Kolon did not provide reimbursement for

expenses and Ms. Laucks financed the business expenses and both partner's living expenses with

credit cards and loans from family members and friends.

18 In 2004, US Textile brokered an MOU creating 10-year supply agreement between Kolon

Industries and Milliken of South Carolina. Both Ms. Laucks and Mr. McVay travelled often to

bring this deal together. Mr. McVay was using cocaine in addition to drinking heavily during this

time and the two stopped sharing an apartment when a vacant one became available in the same

building. The business started to become profitable for the first time.

19 In April of 2005, Ms. Laucks discovered that Mr. McVay, with attorney Mark Bardorf,

incorporated himself as sole shareholder of US Textile Inc. two months earlier, in February of

2005. Mr. McVay's drug and alcohol use increased.

20 In May of 2005, Mr. McVay ransacked Ms. Laucks’s apartment rendering it

uninhabitable, including destroying her computer. Mr. McVay was arrested and required to pay

restitution for vandalism of $1,983.75 and the Newport District Court placed a No Contact order

upon him. Ms Laucks was compelled to move as Mr. McVay lived in an apartment directly

above. Mr McVay, when confronted by Ms Laucks for her share of proceeds from the business,

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he said “Get a lawyer, bitch”.

21 Ms. Laucks was shut off the access to the business and its assets were redirected to a

client account held by Bardorf & Bardorf, attorneys in Newport RI. Ms. Laucks was compelled

to seek relief in Federal Bankruptcy Court. The Federal Court discharged her debt of

approximately $56,000 in October of 2005.

22 During the period, May 2005 through approximately February or March 2006, Ms.

Laucks was completely shut out from operations and access to the business and all profits. An

attempt to settle between Ms. Laucks and Mr. McVay was brokered through lawyers and Ms.

Laucks accepted Mr. McVay's offer of $16,000 but he never paid it.

23 In 2006, following the loss of his driver's license due to a drug related arrest, Mr. McVay

sought out Ms. Laucks and entreated her to return to US Textile as a full 50% partner claiming

that he could not run it without her. Mr. McVay indicated his intention to change the

Incorporation to reflect this partnership but never did, instead the Incorporation become revoked

in 2007 due to lack of filing with the Secretary of State.

24 In December 2006, while Ms. Laucks was away for holidays, Mr. McVay was arrested for

video voyeurism of Ms. Laucks's roommate, breaking and entering, and possession of crack

cocaine. After Ms. Laucks' return in January 2007, she was obliged to vacate this apartment due

to his arrest there. In 2009, Mr. McVay was found guilty by judge of Breaking and Entering and

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Possession.

25 In 2008, Milliken withdrew from the sales agreement causing an immediate and drastic

financial hardship to US Textile. Ms. Laucks and Mr. McVay moved to and shared the two

bedroom apartment at 2D Bonniecrest Gardens where they resided as business partners and

worked at other jobs to support the business. Due to being on probation, Mr. McVay refrained

from cocaine use but continued to consume marijuana and alcohol profusely.

26 Mr. McVay and Ms. Laucks worked together to re-establish Kolon in the automotive

market going directly to the OEMs, ultimately landing a meeting with GM in 2010 that proved

productive and began bringing in profit to US Textile in the Spring of 2012. Due to Mr. McVay's

lack of credit card and driver's license, Ms. Laucks facilitated all travel and meetings to

customers with and, more often, without, Mr. McVay.

27 From 2006 until 2013 the partners used the US Textile Inc business account nearly

exclusively for both personal and business transactions. Mr. McVay converted a larger than 50%

of the profits of US Textile for personal items including past child support and attorney fees for

his various criminal charges. He purchased an outboard 14' dinghy; and a ride on an America's

Cup series catamaran for $4,900. He used funds from US Textile to travel for his pleasure to San

Francisco to volunteer for the America's Cup and intended to travel to Italy as well, paying for

ten days of hotel rooms in Naples that were never used or refunded. Mr. McVay and Ms. Laucks

had an agreement that in exchange for “reasonable” personal items, the business would buy her

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an automobile and it did provide down-payment and monthly payments starting in October of

2012. However, Mr McVay also used business funds for unreasonable personal use (bar bills,

entertainment and cash for marijuana) causing Ms. Laucks and Mr. McVay to argue constantly.

28 In early January of 2013, Mr. McVay began abusing the prescription drug Adderall (a

stimulant) which he obtained without prescription. His behavior became increasingly erratic and

irascible.

29 In February 2013 Melinda Laucks was asked by three separate customers why Mr.

McVay was not responding to their emails and phone calls; she discovered that Mr McVay was

not visiting friends but had absconded, checked into a hotel with all of the business's operating

capital of about $3,200 and caused overdraft fees of $390. Mr. McVay had set up a secret email

address "ustextile@rocketmail.com" with which he asked Kolon Industries to transfer

commission payments to a new personal bank account. He wrote an email, on February 17, and

stated “Be sure not to copy my ustextile.us address because if Melinda finds out she will be even

more ballistic than she already is”. (Ms Laucks having been angered by the bank withdrawals

and overdraft fees). Mr McVay also stated his intention to end the partnership by writing “The

money I save by switching Melinda from partner to employee will allow me to hire 3 more

people.” He told Kolon that he had an Incorporation with himself as sole shareholder allowing

him to do this. Mr. Ryan Im at Kolon responded by writing “Regarding the bank account,

Melinda is following up all of your business now. So I can imagine how people think about

changing account to another one with you out of the loop. You really should speak to her and fix

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things first.” Kolon Industries showed this email to Ms. Laucks, and both Ms. Laucks and Kolon

Industries interpreted Mr. McVay's email as intention of embezzlement as well as an intention to

end the partnership.

30 On February 21, 2013, Mr. McVay took, without approval, Ms. Laucks' car with her

wallet in it. Ms. Laucks required the Newport Police to intervene to prevent damage to the

vehicle and to keep Mr. McVay from using her cash and credit card. The Newport Police arrested

Mr. McVay and returned the car Ms Laucks. (The charge of driving a motor vehicle without

permission was dropped by Ms. Laucks several weeks later.)

31 On February 23, Mr. McVay sent an email to Ms. Laucks' stepfather stating that he was

sole shareholder of US Textile. That evening, Mr. McVay's lawyer, Mr. Kevin Hagan called Ms.

Laucks and told her that Mr. McVay was sole shareholder of US Textile and that she had no

rights to the business. Ms Laucks agreed to that the partnership to be was over.

32 By examining the Rhode Island Secretary of State website, Ms. Laucks determined that

the Incorporation for US Textile Inc. had in fact been revoked since 2007. On February 23, 2013,

Ms. Laucks paid $235 and incorporated her half of the now dissolved partnership as US Textile

Inc. Ms. Laucks notified by email Mr. McVay of her Incorporation on February 25, 2013.

33 In March of 2013, Mr. McVay agreed to stop abusing prescription drugs and return the

business money. With acknowledgement of the Incorporation, Mr. McVay returned to US Textile

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and the residence at 2D Bonniecrest Gardens but with no official or written agreement to the

status or nature of the business relationship.

34 From March to June of 2013, Mark McVay attended counseling with a psychiatrist but

also continued drug abuse. Ms Laucks attended two counseling sessions with Mr. McVay and Dr.

Gollinger in the attempt to improve the situation. In spite of this, Mr. McVay's behavior became

increasingly erratic, contentious, irascible, and delusional. He engaged in frequent manic rages

wherein he would rant uncontrollably for prolonged periods shouting obscenities and abusive

language. His behavior included prolonged sexual perversion. During this time period the

Newport Police were called to the apartment to intervene in domestic conflicts on at least three

separate occasions. On the last occasion, the police threatened to arrest both parties if they were

called another time.

35 Mr McVay resumed excessive and reckless spending, intentionally overdrawing the

business bank account. He made numerous bank transfers to his personal account, and the

accounts of his family members and excessive cash withdrawals and charges via his debit card.

His behavior caused overdraft charges of $1,3678.82. Mr. McVay willfully created conditions in

incur cause for charges of Fraud/Writing Bad Checks upon Ms Laucks. Mr McVay's egregious

spending prevented Ms Laucks from mailing normal bank checks and during this time she was

compelled, upon notification of a deposit, to rush to the bank and buy cashiers checks in order to

keep the business running and to prevent insufficient funds on mailed checks. When Mr. McVay

found out about Ms. Laucks issuing cashier's checks to creditors including to the landlord, Mr.

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McVay became irate.

36 Mr. McVay's destructive behavior was not limited to Ms. Laucks and the US Textile bank

account. Mr McVay's behavior as volunteer for SailNewport Youth regatta was so extreme that

three other volunteers requested to never be on a boat with Mr. McVay again. He was terminated

from his volunteer position with the Clagett Regatta when the director discovered empty rum

bottles on her personal boat after Mr. McVay used it without her permission.

37 Mr. McVay, by his own volition, destroyed his interest in US Textile business by using

abusive and threatening language to US Textile's only client, Kolon Industries in both emails and

phone calls. Mr McVay entirely alienated, threatened to sue directly, and threatened to provide

“evidence” against Kolon in their litigation with DuPont. By June 23, 2013 Kolon Industries

refused communicate or work with Mr McVay entirely. Ms. Laucks was the sole communicator

between US Textile and Kolon.

38 In the morning of June 26, 2013, Plaintiff McVay assaulted Ms. Laucks as she sat in her

bedroom emailing business customers. Initially Mr. McVay attempted to barricade and nail shut

her bedroom door which she managed to undo and then retrieve her laptop, she retreated to her

bedroom and locked the door. Mr. McVay then removed the door from its hinges, wrested her

laptop computer and her wallet from her arms. In doing so he ripped her clothing and smashed

her hip with a large hammer. He caused bruising on her arms and hip. He destroyed the laptop by

hurling it from a second-story deck into the driveway. Ms. Laucks, in shock, drove, barefoot and

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in a ripped dress, to a safer location and parked behind a nearby school. There, she called the

personal cell number of an officer of Newport Police, whom she hoped could help her get Mr.

McVay in a rehab facility. While Ms. Laucks waited to hear back from the officer she saw the

Plaintiff ride away on his bicycle. Ms. Laucks returned to the apartment to dress and secure her

things. While Ms. Laucks was preparing to leave, Mr. McVay returned to the property and

continued his assault on Ms. Laucks. Ms. Laucks had locked the front door to prevent his entry

and Mr McVay climbed the fire escape and forced his way in. When Ms Laucks ran to her car,

Mr. McVay chased her and positioned himself in front of the car, preventing her from driving.

Ms Laucks backed up to avoid him and the neighbor came outside of her home. Mr. McVay

climbed up onto the hood of Ms Laucks's vehicle gouged a deep 40” scratch in the hood of her

car with a key. The neighbor called the police. Ms. Laucks drove straight to the Newport Police

department. Mr. McVay was arrested for Domestic Disturbance, and Vandalism of personal and

business property, and Assault with a Deadly Weapon. Newport District Court imposed a No

Contact order placed upon Plaintiff McVay. This Court Order made all communication, for

business and otherwise, unlawful between Mr. McVay and Ms. Laucks.

39 On June 27, 2013, Melinda Laucks terminated Mr. McVay from his association with US

Textile Inc. due to this specific incident, his reckless use of business funds, illicit drug use and

unprofessional conduct; and removed him from the US Textile Citizen's Bank Account under the

guidelines established by Citizens Bank's corporate policy and Rhode Island Law.

40 Ms. Laucks discovered that Mr. McVay had ordered a gun safe and spy cameras in the

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shape of coat hooks that he had shipped in care of the neighbor to, presumably, conduct video

voyeurism as he had done in 2006.

41 After the termination of Mr. McVay, Defendant Ms. Laucks frequently traveled to

maintain the operation of US Textile, improve relationships with customers and the client Kolon

Industries. She increased the business's operations and its profitability significantly. Ms. Laucks

successfully guided the business through many serious color and quality issues at GM and GM's

suppliers. Ms Laucks paid back the business loans to family members and friends they had given

ten years prior. Kolon wrote emails stating that they were impressed with how things were going

without Mark.

42 During the summer and fall of 2013,Mark McVay, in violation of his No Contact Order

continued to send emails to Ms. Laucks alternating from apologetic to very threatening. In

August of 2013, Mr. McVay threatened a manager at Citizen's Bank.

43 In September of 2013, Mr John Deacon, Jr., attorney for Mr. McVay sent a demanding

and harassing letter to Ms. Laucks, insisting that she resume a business relationship with Mr.

McVay. Ms. Laucks responded with a letter describing the assault and that a No Contact Order

prevented any communication; and that Kolon no longer wanted Mark with US Textile either, a

sentiment that Kolon had made very clear. Mr. Deacon immediately issued a Subpoena and

Summons with Verified Complaint. Kolon Industries requested that Ms. Laucks shut down the

business and re-incorporate under a different name but Kolon's counsel, Mr. Ben Cutchshaw later

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advised against that.

44 In December 2013 Ms. Laucks provided as discovery thousands of documents and emails

relating to the operations of the business.

45 In February, while Ms. Laucks was attending business meetings in Michigan with Kolon

and GM, the Court placed the business in Mastership. On February 21, Special Master, Mr. w.

Mark Russo proceeded to seize the business's bank account with no notice or advance warning.

Ms. Laucks had gone to Texas briefly for a family obligation and was stranded in there with only

$47 in cash and a single credit card with a very low limit (as result of the prior bankruptcy). The

lawyer representing Ms. Laucks immediately quit.

46 On February 27, 2014, the Plaintiff Mark McVay pleaded guilty (no lo contendere) to

Vandalism and Domestic Disturbance, was sentenced to No Contact, Probation, Restitution and

Domestic Violence Classes. Ms Laucks discovered that the Newport police mishandled the

evidence causing the Assault with a Deadly Weapon charge to be dismissed. The evidence

incorrectly labeled the neighbor who called the police as the victim in this charge.

47 In February 2014, Mr. McVay wrote an email to a business supplier, Mr. Kurt Con cannon

in which he made false allegations and defamed her character, instead of reprimanding Mr.

McVay, Mr. Russo was hostile and derogatory to Ms. Laucks for defending herself from this

egregious libel and did this with Mr. Concannon cc:d in the email thus Mr. Russo began to

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willfully and maliciously defame the Defendant's professional reputation.

48 In March of 2014, the Special Master (consisting of W. Mark Russo and John Dorsey)

refused to allow Ms. Laucks to operate her business even though it was her wish to do so, the

wishes of Kolon and the wishes of the customers. Mr. Benjamin Cutchshaw, Kolon's counsel,

explicitly told Ms. Laucks that Kolon would absolutely insist that she be maintained in the

running of the business.

49 However, Mr. Russo refused to provide any type of payment for her work or

reimbursement of business travel expenses and was upset because she sent an email to his office

after business hours. Mr. Russo demanded that Ms. Laucks return to Rhode Island even though

she did not feel safe there and he would not pay her travel expenses to do so.

50 Ms. Laucks was told by her attorney, before he quit, that the Mastership was appointed

for the purpose of "Finding of Fact" and reducing litigation, yet Mr Russo and Mr. Dorsey

refused to acknowledge the evidence submitted to them by Ms. Laucks, refused to acknowledge

Mr. McVay's guilty pleading on criminal charges and refused to acknowledge evidence that was

available to them through Kolon Industries (who immediately demanded to NOT work with Mr.

McVay) or evidence obtainable in the bank statements for the account that they seized two weeks

prior. The Mastership willfully ignored the evidence and proceeded with the case in an

extraordinarily hostile manner toward Ms. Laucks, including having her harassed in her home on

multiple occasions.

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49 Immediately upon being appointed Permanent Special Master, in March 2014, Mr. Russo

and Mr. Dorsey caused Mr. Seth Schalow to run the day to day operations of the business. Mr.

Seth Schalow has a Linked-in Page online that indicates that he has been involved with the

business from as early as December 2013, coinciding to when discovery was presented, thus

providing evidence of collusion, conspiracy and intend to defraud by the Mastership.

50 Mr. McVay continued to harass Ms. Laucks by email, and through contact with her

family, in violation of the No Contact Order. Mr McVay was arrested for this on April 7, 2014.

51 During the course of this litigation, the Mastership, as assisted by Attorney John Deacon

Jr and Superior Court Judge Michael A. Stern destroyed Ms. Laucks's relationships with her

clients and customers causing defamation to her professional reputation and her esteem in her

industry. The Court ordered to forbid Ms. Laucks contact with all persons and associations in her

industry; she has been unlawfully prevented from seeking employment in her industry, taking a

job offered in her industry, and maintaining her personal relationships.

52 The restraining order denied Ms. Laucks her right to participate in interstate and foreign

commerce, and violated Strategic Litigation against Public Participation by prohibiting her from

contacting her associated for materials, statements and witnesses for her legal defense.

53 The activity of the Mastership, by wrongfully denying any income to Ms. Laucks, and

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refusing the return of personal funds in the account, has prevented her from obtaining counsel

which abridges her ability to properly petition and present her legal defense.

54 In April 2014, Judge Silverstein made false allegations of a felony against Ms. Laucks,

that she embezzled $13,000 from a customer. Neither the client nor the customer supported this

accusation. This act of extortion by public official was attested, while under oath, by Mr. Russo

in Kent County Courtroom 4e in the presence of Judge Brian Stern.

54 The loss of income has caused severe hardship to Ms. Laucks, she is getting government

assistance (SNAPS) and despite a low-paying hourly rate job, she is depleting a small IRA

simply for living expenses.

55 During the course of the litigation Mr. Deacon, Mr. Russo and Mr. Dorsey filed and

threatened multiple charges of contempt of court on very flimsy and exaggerated circumstances,

circumstances that they used entrapment tactics to obtain. These contempt accusations were used

to intimidate and threaten Ms. Laucks from appearing in Court. Judge Silverstein threatened to

have the bailiff "lock her up."

55 July 2, 2014, Mr. McVay was arrested for video voyeurism of a minor which he

photographed under a table up a girls' skirt in a Barrington, RI church and for video voyeurism

in a fitness center women's locker room in Seakonk, MA. and remains incarcerated for violation

of probation.

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56 In August 2014, Mr. Deacon filed for civil and criminal charges of contempt for 60 days

in jail against the Defendant for simply missing a day in court when no hearings were scheduled

and Mr. McVay, who she is afraid of, was expected to attend. Ms. Laucks had already notified

the Court that this presented unreasonable financial hardship and would be absent. This extreme

and trumped up excessive use of contempt, malicious abuse of the judiciary system and caused

Ms. Laucks so much anxiety and duress that her neighbors worried about her safety and Ms.

Laucks was involuntarily hospitalized for six days under suicide watch. Ms. Laucks has since

been readmitted to the hospital for follow up treatment and has sought outpatient case for her

anxiety, distress and panic attacks caused directly by this litigation.

57 Mr. Deacon caused further harassment and malice by making a false allegation of

Practicing Law without a License upon an associate of Ms. Laucks. This allegation was found to

be entirely false and without merit yet caused a breach in the relationship and her support for Ms.

Laucks and forced the Defendant of the charge to hire a lawyer at her own expense.

58 Despite numerous subpoenas, the Mastership and Seth Schalow have failed to account for

and provide evidence of the alleged start date for Seth Schalow's invovlement. Mr. Schalow said

under oath that he had an email showing that he began on March 6, 2014 but he and the

Mastership have refused to provide this document or any other. This alleged start date of March 6

2014 conflicts with his Linked-in account and with verbal information Ms. Laucks received

from Kolon personnel later that spring.

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59 The Mastership fails to provide despite subpoena, actual bank statements from Citizens

Bank that would dispel suspicions of bribery and misappropriation of business funds.

60 The Mastership has sought use its influence with Judge Brian Stern to impose a

egregiously unfair settlement document that would enable the Mastership to retain the business

permanently, a document that was initially agreed to by Ms. Laucks under duress and with fouled

expectations and with numerous objectionable issues, including a later, superseding agreement

by the express wish of Mr. McVay, signed and notarized by both Mr. McVay and Ms. Laucks that

returns control of US Textile Inc. to Ms. Laucks.

COUNT IRACKETEERING INFLUENCED CORRUPT ORGANAZATIONS

COUNT IISTRATEGIC LITAGATION AGAINST PUBLIC PARTICIPATION

COUNT IIIVIOLATIONS OF FEDERAL AND CONSTITUTIONAL RIGHTS

TITLE 18, DUE PROCESS

COUNT IVVIOLATION OF COMMERCE CLAUSE

COUNT VCOLLUSION & CONSPIRACY

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COUNT VIFRAUD

COUNT VIIEXTORTION, BLACKMAIL, INTIMIDATION BY PUBLIC OFFICIAL

COLOR OF OFFICE

COUNT VIIICONVERSION

COUNT IXANTITRUST

COUNT XSLANDER, LIBEL, DEFAMATION

COUNT XIBREACH OF FIDUCIARY DUTY

COUNT XIIINTENTIONAL AFFLICTION OF EMOTIONAL DISTRESS

Wherefore the plaintiff seeks:

Criminal prosecution of the above mentioned Defendants;

the business and its assets and damages for pain and suffering of $2,500,000

or

money damages in the amount of $25,000,000 for loss of income and future income;

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any further relief the Honorable Court may deem appropriate.

WHEREFORE, Plaintiff demands judgment against Defendants for damages in a sum sufficient to invoke the jurisdiction of this Honorable Court; actual and consequential damages; punitive damages; attorney fees; and interest and costs of suit, together with all other and such relief that this Honorable Court may deem just and proper.

Melinda Laucks, pro se2D Bonniecrest GardensNewport, Rhode Island401 846 1898February 17, 2015

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