suit against co judges

8/2/2019 Suit Against CO Judges

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IN THE UNITED STATES DISTRICT C O U K ~ i s . r ; · ' , ' c ; , , I C ~ ~ ? ~ 1 gFOR THE DISTRICT OF COLORADO !.ll ..\ ; · I 1

·. I .••• J

Civil Action No. ll·CV- 1777-R.EB·CBS

TRRNTON H. PARII..'ER,

Plaintiff,v.,

DANIEL S. MAUS, Individual and in his official capacity;ELIZABETH B. STROBEL, individually and in her official capacity;

BRUCE T . .BARKER, individually and in his official capacity;STEPHANIE L. ARRIES, individually and her official capacity;

JOHN COOK, individually and in his official capacity;BOARD OF COUNTY COMMISSIONERS OJ? THECOUNTY OF WELD, STATE OF COLORADO; ANDln. Rc. Case No. 07-CV-189; and Case No ll·CV-19,

IN WELD COUNTY, STATE OF COLORADO.

Defendants.

AMENDED COMPLAINT

4: 24

DEP.ClKtJ .y--- __ _____...-

Comes the Plaintiff, Trenton H. Parker, prose, and alleges for his Complaint, as follows:

.JURISDICTION

l. This action arises under the Constitution and laws of the United States, including Article III,Section l, of the United States Constitution; Article IV, Section 4; Article XIV, Sections 1 and 2,and Title 42 U.S.C. § 1983. Jurisdiction is conferred on this Court pursuant to Title 28 U.S.C. §§1331, 1343 and 2201. The "Supplemental Jurisdiction'' of the District Court is hereby, invoked.

2. Venue is proper In the District of Colorado pursuant to Title 28 U.S.C. § 1391(b). All ofthe

events alleged herein, occurred within the state of Colorado, County of Weld. All of the partieshereto, are residents of the state of Colorado.



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PARTlF:S

3. Standing; Plaintiff Parl•er (Pa••ke•·) has standing to bring this action before this Federal District

Court because the Plaintiff is a citizen of the United S t a t ~ : ~ and has resided in the state of Colorado

at all times relevant he•·eto, and is a registered voter in the state of Colorado.

4. Defendant DanielS. Maus (Maus) is a District Court Judge of Weld County, Colorado; EliznbethB. Strobel (Strobel) is a District Court Judge in Weld County, Colorado; Bruce T. Barker (Barker)is the Weld County Attorney; Stephanie L. Arries (Arries) is an Assistant Weld County Attorney;John Cook (Cook) is the Sheriff of Weld County, Colorado; The Board Of County CommissionersOf The County Of Weld, State Of Colorado is the governing political hndy of Weld CountyColorado; Case No. 07-CV-189 and 11-CV-19 are civil cases involving alleged Weld County zoning

code violations which .PlaintiffPatker has a direct and personal interest in, and which is the subjectof t h i ~ lawsuit, and which are described in detail, hereinnftel',

5. At all pertinent times mentioned herein, Defendants M a u ~ and Strobel were employed by thesf:lte of Colorado and was acting as a Colorado state jud.ges without lawful or constitutional

authority to do so and lacked any jurisdictional authority to proceed as a judge or to have deniedthe Plaintiff a jury trial (Mans and Strobel), or sentenced the Plaintiff to jail (Maus).

6. At all pertinent times mentioned herein, Barker and Arries were employed by the Commissionersof Weld County, Colorado. At all pertinent times mentioned herein, John Cook was employed by

Weld County, Colorado as the Sheriff of said county.

7. This is an action for damages against Defendants Maus, Strobel, Barker, Arries, Cook; and theBoard Of County Commissioners of Weld County, Colorado for violating the .Piaintifrsconstitutional and civil rights under the Fourth, Fifth, Sixth, Seventh, Eighth, and FourteenthAmendments as protected under the Constitution of the United States.

8. Plaintiff Parker alleges that, for a period covering twelve (12) years, he has been sub.iected to andmade to suffer an ongoine and continuous loss and abuse of his constitutional rights at the hands ofthe Weld County Commissioners and various Weld county employees. That Defendants Mans,Strobel, Baker, and Arries have intentionally, kllowingly, l'ecklessly, and with deliberateindifference to Plaintifrs constitutional rights, violated the Plaintiff's Fourth, Fifth, Seventh, Eighth,and Fourteenth Amendment Rights when, the Defendants subjected Plaintiff Parker to numerousillegal acts, wrongs, torts and imprisonment prior to , during nnd following a two day contempt ofcourt hearing in Weld County, Colorado in Case No. 07-CV-189, which took place on June l4'h and25'" of 2009.

9. The l'Iaintiffwas sentenced to jail for 90 days. Tbe. Final Court Order and determination ofsaid trial and 90 day sentence was executed and issued by Defendant Mans on July 9, 2009. ThePlaintiff is not time-barred from bringing this act ion and constitutional c h a i i ~ J n g e s to the FinalOtdcrs aforementioned. The ~ v r o n g s and abridgments' of the rights of Plaintiff Parker have beenand are continuing in and nature at the bands of tbe Defendants name herein, as more fullydescribed



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CASE BACKGROUND AND IJME LINE

10. In 1997, Plaintiff Parker joined together with a number of individuals and companies in order

to pool various assets consisting of land, horses, construction equipment, tools, mobile homes,

construction offices and other various resou•·ces in order to develop a series of equestriancampgrounds which were to be located in the San Luis Valley in Costilla County, Colorado.

I I , On October 3, 1997, a Colorado corporation named West World U.S.A. Inc. (West World) w a ~ formed to proceed with the equestrian campground project. The primary staging area for the West

World venture was located on a twenty·five acre storage facility located 10701 E. l04'h Avenue,Commerce City, Colorado. Said facility was leased by lntermounta in Mobile Home Services which

was owned by Mrs. Marjore A. Kcssling (Kessling).

12. Kcssling had purchased Intermountain in early 1997, and had assumed a short term lease.Intermountain manufactured, stored, repaired, moved, removed and set up mobile homes,construction offices and portable farm and ranch barns and storage units.

13. In November of 1999, due to unforeseen circumstances, Kcssling became i ll and was unable locarry on with Intermountain's business. At the same time, Intermountain's property, which was

owned by a Chicago investment company, was sold and Intermountain's lease was terminated,requiring Intermountain's liquidation and relocation and the relocation of West World's horses and

facilities.

14. In March of 2000, West World joined together with a land development group which had

acquired a lease-option to purchase 90 acres of open ranch land (The Ranch) located south of WeldCounty Road 8 and Weld County Road 35, in Weld County, Colorado, with the closest residencebeing 1/4 mile away.

15 The 90-acre ranch property was part of an unsettled estate consisting of 120 acres owned by twowarring sisters. Before moving onto The Ranch property, the development group retained attorneyJohn Ringinberg to review Weld's zoning codes. After' reviewing said codes, it was determined that

there were no problems with West World moving its h ~ ; ~ r s e s and supporting equipment onto TheRanch property • which it did.

16. At the same time, the development group moved their construction equipment and portablebuildings onto The Ranch property. Likewise, some of the investors moved some of their personal

items on to The Ranch property, such as motor homes, horse trailers, portable horse tack and haytrailers, and farm, ranch and construction equipment . Ranch policy required all items to be onwheels and mobile.

17. The first year on The Ranch was spent building and establishing a functional infrastructureconsisting of fenced pastures, horses pens, windbreaks and hay sheds. At that time, West World

owned 40 horses, which were show quality registered Russian and .Polish Arabians (l 0 stallions and30 mares). During the year 2000, West World was operating on income derived from the repairand sale off excess equipment and materials, and show horses.



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18. On .January 1, 2001, Weld County passed a new zoning code which was reviewed by thedevelopment group's attorney, .John L. Ringenberg. Based on the reading of Weld's new code, itwas concluded that there was nothing on The Ranch property which was in violation of either the

old or new Weld county zoning codes.

19. On Oecember 14,2001 the development group formed Land Home l)evelopment

Company, Inc. (Land Home) and thereafter, on December 15, 2001 Land Home entered into aLand Sale Contract and stuck purchase agreement with Amanda M. Witt, one of the two wart•ing

sisters, who jointly owned the 120 acre ranch property.

20. In March of 2002, a dispute broke out between Weld's code enforcement agent,Bethany Salzman, the warring sisters, Land Home, West World, Intermountain and a landlordwho bad leased 10 acres In the town of Roggen, in Weld County, Colorado to Intermountain. Atthat time, Attorney Max Minnig, .Jr. (Minnig) was hired to represent the Defendants.

21. On April R, 2002, Weld County filed a law suit against all of the parties that had anything to do

with The Ranch property and the Roggen's/Intermountah1 storage facility (Board of County

Commissioners v. Trenton H. Parker et.al. Case No. 02-CV-558. This civil action took place morethan two years after the Ranch property had been occupied and more than a year after Weld'szoning codes had been enacted. Weld County ignored the fact that Colorado's Statutes ofLimitation harred this action, CRS-30-15-409.

22. On April16, 2002, Minnig accepted service in 02-CV-558 on behalf of Land Home, WestWorld, Intermountain, and Parker. However, for whatever reason, Minnig never filed an Answer

in that case, while advising all concerned that be was working to have the case dismissed.

23. On August 12, 2002, the Weld County District Court entered a written "Order ofDismissal" in the 02-CV-558 case, liS tn L11nd Home, West World, Intermountain and

Parker. After the Dismissal, Minnig took a mediealleave and moved from his law offices.

24. On September 27,2002, Weld County moved to reinstate the 02-CV-558 case. On8/28/02 the District Court granted Weld's motion for reinstatement. Bnt Minnig never received the

notke of reinstatement, as he bad moved and was .not practicing law at that time. Additionally,neither the Weld County Attorney or the District Court ever sent a copy of the Notice Of

Reinstatement of 02-CV-558 to Land Home, West World, Intermountain or Parker, who stillbelieved that the 02-CV-558 c:ase had been dismissed.

25. On October 23, 2002, a Default .Judgment was entered in 02-CV-558 by the District Courtagainst Land Home, West "World, Intermountain and Parker, who were stillnnder the impressionthat said case had been dismissed.

26. On May 5, 2003, Parker found out from Minnig that n Contempt Citation was entered againstParker in 02-CV-558. The Weld County Attorney mailed a copy ofthe Contempt Citation to Landllome's business address in Brighton, Colorado. On May 16, 2003, Parker filed a scant prose

response to the "Contempt Citation" in 02-CV-558, having no information as to what hadtJ·anspired since the "Dismissal.'' Following Parker's prose contempt response, Minnig wasrehired to represent Parker, Land Home and West World in the 02-CV-558 case.



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27. On May 14, 2003, Land Home Development Company was finally able to arrange financingand entered into a contract to purchase Witt's undivided interest in The Ranch, as The Ranch wasstill not officially divided. At about the same time, the second sister sold her undivided interest in

the 120 acre property to a next door neighbor. Since the sisters were no longer the owners of theproperty, Land Home working with the neighbor, proceeded to work to obtain a legal division of

The Ranch property in the District Court in Case No. 02-CV-300.

28. On October 23, 2003, a hearing was held in the Weld County District Court in 02-CV-558. Butdue to illness, Minnig could not attend. Parker attended, but was not sure what the hearing was

about. Weld was represented by Assistant County Attorney, Lee Morrison (Morrison). Saidhearing was continued with the understanding that if there was to be another hearing, Parkerwould be notified. Another hearing was scheduled and held on 2/17/04, but Parker never receivedany notice of the hearing, which resulting in aFTA Warrant being issued for Parker 's arrest.

29. On April IS, 2004, Parker was arrested on the February 17, 2004, FIA warrant. Parker

bonded out of jail and was ordered to appear In court for a "Show Cause" hearing on May 4, 2004.

30. On May 4, 2004 Parker appearQd pro se in the District Court, to answer the April 29, 2003contempt citation. When the dust cleared, Weld's nttol'ney, Mon·ison, moved to dismiss thecontempt citation against Parker for lack of evidence. Parker had been jailed and harassed by

Weld County for more than two years over matters which Parker was either not responsible for orhad no control over. For all intents and purposes, the 02-CV-558 case came to an end.

31. The issues in contention in 02-CV-558 was that Weld's new International Code Enforcement(ICE) Agent, Bethany Salzman (Salzman), was treating Land Home's portable buildings as mobilehomes and wanted Land Home to obtain building permits fo•· them, which is not required forconstruction trailers. Second, Salzman had decided that every type oftruck or piece ofconstruction llquipment was a "commQrciaJ vehicle" and that only one "commercial vehicle" was

to be allowed on a farm or ranch, regardless of the size of the farm or ranch. Additionally,Salzman had decided that no one was to have a "recreational vehicle'' stored or repaired on TheRanch property, as they should be placed in commercial storage yards and garages.

32. Furthermore, West World's hay and feed storage trailers, along with Land Home'sconstruction office were considered illegal because they bad similar types of frames, wheels anduxles which some mobile homes have and therefore, they must he "mobile homes" and thus wereillegal. A Tuft' Shed mounted on a small trailer frame was declared a "mobile home" by Salzman

because it was "mobile" and someone might put a bed and a heater in it and live in it. Salzman hadalready determinl.ld that everything on The Rancb property was illegal for one reason or another.

33. A key key legal issue involving The Ranch property was that until it was divided up by the

District Court, no one could legally apply for or receive any permits from the Weld Countybuilding department; and Salzman was the one who decided who could get a permit. Salzman hadalready decided, without ever conducting an on-site inspection, that everything on The Ranch

property was illegal, so no permits were going to be given to Land Home, West World or Parker,anyway. It was Salzman who had instigation the legal actions against Land Home, West Worldand Parker which has to date, lasted for nearly twelve (12) years. When 02-CV-558 ended, LandHome,West World and Parker returned to hudneu.



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34. On March 18, 2005, the Weld County District Court entered a Order approving a "StipulatedSettlement Agreement" regarding the division of The Ranch property; 02-CV-300. And on July 14,2005 mutual deeds were issued between Land Home and Mr. Gerry Bowman. Howeve.r, the timeand money spent on fighting Salzman and Weld County had left Land Home and its investors lowon financial resources and spirit which resulted In some of the investors simply walking away fromthe deal and leaving their various buildings, trailers, equipment and materials behind since they

had no other place to take them. Parker had to stay at The Ranch because he was the only one leftto take care of West World's horses, which had to be taken care of24 hours a day.

35. Land Home finally sold its interest In The Ranch property on July 14, 2006 to a another realestate company, Rio Grande Canyon Properties, Inc. (Rio Grande). However, since .Land Homehad a mortgage on the property with a "due on sale" clause, Rio Grande did not record its deeduntil after said loan was paid off. July 2, 2008.

36. On or about February 23, 2007 Weld County filed another Jaw suit against Land Home andTrenton Parker; Weld County Commissioners v. Land Home and Trenton H. Parker, Case No. 07·CV-189 in violation of CRS-30-15·409. This action took place nearly three years after the May 4'\

2004 contempt hearing was held in the 02-CV-558. Weld was represented by Assistant WeldCounty Attorney, Stephanie L. Arrics (Arries) assisted by Salzman. Even though Land Home no

longer owned The Ranch property, the last investor, Robert K. Karpe (Karpe) thought an answershould be filed. Karpe and Parker quickly fixed up one of the trucks which was left on The Ranchproperty and sold it for $3,000. Attorney Frederick J. Scheafer was paid $3,000.00 to file anA n ~ w e r , while Parker filed a prose Answer to Weld's new 07-CV-189 Zoning Code Complaint.

37. When Scheafer wanted more money, Karpe disappeared, Land Home died and Scbeaferwithdrew from the case. That left Parker holding the bag again. Richard Foreman (Foreman),who was a mortgage broker, had taken over the management of Rio Grande. Forman decided thatsince Rio Grande was not named in Weld's lawsuit, that there was no reason for him or RioGrande to get involved in it. Likewise, Foreman was in the middle of a divorce and was havingfinancial problems and did not wish to become envolved. in any additional litigation.

38. On October ll , 2007, Parker met with attorney J. Bryan Larson (Larson# 31822)at his offices located 730 E. Bridge Street, Brighton, Colorado 80601 and retained Larson torepresent Patkllr regarding the zoning code violation matter in the Weld County Distril;t CourtCase No. 07-CV-189. At that time Parker paid Larson a $500.00 cash retainer to appear at an upcoming hearing which was later rescheduled by the District Court to be held on December 20, 2007,before Judge Donald Maus (Mans).

39. In early December of 2007, Parker contacted Larson by phone to make sure that Larsonwould be ready for the 12/20/07, hearing and to confirm that Larson bad made a formal entry of

appearance. Larson told Parker that he had made a formal entry of appearance and that he wouldbe ready for the hearing. Parker told Larson that he wanted to stop by Larson's office and pick upcopies of whatever Larson bad filed with the Weld County District Court. That same afternoon,Parker stopped by Lorson's office, at which time Larson gave Parker a copy of an "Entr·y ofAppearance" wbich Larson said he bad c-mailed to the Clerk of District Court in Greely,regarding the 07-CV-189 case.



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40. On Monday, December 17, 2007, Parker called Larson at his office to find out when they we1·e

going to get together and prepare for the 12/20/07 bearing. At that time, Larson told Parker thatbe had been in contact with the Weld County Attorney's office and bad gotten a continuance due to

the up-coming Christmas Holidays, and that a bearing date would be rescheduled after the first of

the year - 2008. With that information, Parker let the matter rest.

41. Thereafter, about mid May of 2008, Parker was served with n copy of a motion for an "Orderof Possession" by the Weld County Sberifrs Department, regarding the alleged zoning code

violations. After being served, Pm·ker called Larson at his oftice and asked him what was going on,and why was Parker being served with an "Order for Possession." At that time, Larson toldParker that it w : ~ s all just 11 big mistake- and that he (Larson) would c : ~ l l the District Court nnd the

Weld County Attorney and get everything straightened out. Parker told Larson, at that time, thathe (Pa•·ker) wonted to know exactly what was going on In the Weld County case. Larson assuredJ>arkcr that he (Larson) would let Parker know just as soon as he (Larson) got the whole matte1'resolved.

42. Several day passed following the conversation with Larson, yet Parker had not received any

word from Larsou. Additionally, none of Parker' s phone calls were returned, At that time, Parkerc : ~ l l e d the Clerk of the .District Court and was informed that there was no record showing that Mr.J. Bryan Larson had ever made an entry of appearance in the 07-CV-189 case.

43. Additionally, the scheduled hearing of lZ/20/07 bad not been set aside, as Larson hadrepresented to .Parker. Furthermore, the 12/20/07 hearing had been held and no one hadappeared for any of the Respondents in the case. This whole matter had turned into an absolute

critical legal disaster, along with other legal matters involving Mr. Larson.

44. After finding out that Larson had lied to Parker about a number of matters, Parker went to

L : ~ r s o n ' s office to confront him on the matters covered above- as well as other matters. Parker

found Larson at hisof11ces

and asked Larson to return all of the paperworkin

the case and forLarson to tell the truth about the 07-CV-189 case, as wcl111s several other matters which Larsonhad been retained to work on.

45. At that time, Larson told Parker that he could not return Parker's paperwork because thepolice had raided his offices and bad taken all of his paperwork and his computers as a result of his

involvement with some real estate and mortgage scams that Larson had become involved inthrough the title company which Larson owned. Additionally, Larson admitted that be was bllingsuspended from the practice of law by the Colorado Attorney Regulation Council and apologized

for not showing np in court, which resulted in a default judgment against Laud Home and Parker.Thereafter, Parker filed 3 different complaints against Larson with the Colorado AttorneyRegulation Council. Larson entered a plea agreement regarding his actions and was suspendedfrom the practice of law for n short time (Case No. 08-PDJ-046) ·entered on March 27, 2009.

46. l'arker filed a C.R.S.- Rule 60(b) Motion wltb the District Court, to set aside the entry ofdefault judgment because of Larson's unethical and fraudulent conduct. However, Judge Manssummarily dismissed the motion without allowing Parker to present any proof or testimony.



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47. Parker was issued an order by Judge Mans in 07-CV-189 to show cause why Parker and LandHome should not be held in contempt of court for some alleged zoning code violations. By thistime, Rio Grande had filed its deed from Land Home, and Foreman had taken over Rio Grandeunder a stock purchase and option agreement. Arries was informed of these matters with copies of

the Land Home· Rio Grande Deed, affidavits and sworn testimony. However, Arries refused todrop the case against Parker, who was attempting to liquidate West World's assets and move the

remaining horses and equipment to the San Luis Valley. On August 19, 2008, Foreman died (bysuicide) from an overdose of drugs and alcohol without paying the money due under his stockoption purchase agreement, which left Parker, WestWorld and its investors in a bind again.

48. Additionally, Arries kept an open-ended Lis Pendens on The Ranch property with no stated

amount, thereby making it impossible to obtain financing in order to begin developing saidproperty or to sell The Ranch to anyone. Thus, Parker had to seck a court nppointed attorney toI'epresent him in the Contempt of Court matter. Judge Mans appointed an attorney by the name ofChristopher G. CollhJs (Collins) of Greely, Colorado, to represent Parker. Collins callt:!d Parker by

phone at The Ranch (303-654·1048), with an established mailing address of 111 E. Bridge Street,

Brighton, Colorado 80601, which Parker gave to Collins over the phone.

49. When Collins called Parker, Collins explained thnt he had been appointed to represent Parker

by .Judge Maus, but that no date had been sat for the contempt of court hearing and that Collinswould contact Parker as soon as there was a firm date established. ln the meantime, Collins toldParker that he was behind on a lot of work and that Parker was not to call him about Parker's caseuntil Collins called Parker. Parker told Collins that he was busy taking care of the horses andrepairing equipment to be sold or removed. Collins told Porker to just keep doing what he wos

doing and that he (Collins) would contact Parker when the time came. Parker told Collins to tryand buy as much time as he could, as Parker was alone and out of money and working to keep thehorses fed. Collins said he would do whatever he could to buy time, and then bung up.

50. Parker did not hear from or meet Collins until the morning of June 24, 2009 when Parker

appeared in Weld County Court on an unrelated matter. As Parker was In the process ofleavlngthe court, deputy sheriffs arrested Parker for a failure to appear at a contempt of court hearing iu

the 07-CV-189 matter. When Parker, who was surprised, asked the deputies, "What ContemptHearing'l", Parker was told to talk to his attorney, and pointed to a man standing next to Parker.At that point, a man turned to Porker and said thnt he was Christopher G. Collins. That he couldnot talk to Parker at that time; that Parker was under arrest for a failure to appear; that Parkerwas going to be "booked" but that he would try to get Parker brought up to Judge Mans' court·room as soon as possible, as there was to be a forthwith trial regarding the contempt matter.

51. Thereafter, Parker was booked into Jail and then taken in handcuffs to Mans's court to meetCollins for the first time. Collins said there had been a contempt of court hearing scheduled for

May 19, 2009, and that he tried to contact Parker, but Parker's phone was disconnected and theaddress he sent a letter to was returned. As it turned out, Collins had written down Parker's phonenumber as 970-654-1084 not 303-654-1048. And Collins had sent the notice letter to 837 S. KunerRd., Brighton, Colorado 80601. This was an old address that Collins got off of an old pleading in

the 02-CV-558, case which had been a UPS Store that had closed down and moved two yearsbefore.



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52. Collins never bothered to call information or to ask Arries where The Ranch was or have~ o m e o n e go to The Ranch where Parker was working every day. Parker had about two minutes totalk to Collins before Judge Maus came into the courtroom to start Parker's contempt of courttrial. Parker asked Collins to request a continuance, as Parker had no way to contact witnesses orto obtain any exhibits. And Parker had never spoken to Collins regarding any affirmativedefenses. As court opened, Collins advised the court of the mistakes that he had made. Collins

lived in the 970 area code and assumed that Parker did too. And Collins also acknowledged that hehad ~ e n t notice of the contempt hearing to the wrong address and asked for a continuance. Mausdenied C o l l i n ~ request and st:n·ted Parker's contempt of court trial forthwith.

53. Par•kcr asked Collins if he (Parker) could get two or three h o u r ~ in order to get somedocuments together. At that time, Collins informed Parker thnt he was to go back to ,inilund thatMaus had put a $15,000 b ~ ; ~ n d on him. The trial was a judicial farce. Collins knew nothing aboutThe Ranch; or the history of the property; or the zoning codes that were alleged to be in violation,or any of Parker's affirmative defenses; or who owned The Ranch property; or where The Ranchwas; or who owned the items on The Ranch; or who a.ny ofthe investors were. Nor had Collinsever spoken to Parker or anyone else about Case No. 07-CV.189. C ~ ; ~ l l i n s told Parker that nothing

really would make any difference anyway because Judge Mans had already decided th11t Pnrkerwas going to get 90 days In jail.

54. At lunch break, Collins had a meeting that he had to go to, so there was no time to confer withPar•ker. At the end of the day, Parker was taken to the Weld County jail without any time to talltto Collins. Parker, using all of West Wol"ld's horse feed.ing money ($1500), managed to bonded outof jail and get back to his car and back to The Ranch. Parker spent the whole night feeding andwatering the horses and trying to get ready for the next day's contempt of court hearing. Uponlll'riving at court the following day, Parker notified Collins that he was fired and that Parker wasgoing to proceed pro se. When Judge Maus reopened the trial, Parker went on record firingCollins and objecting to the proceedings. Parker testified in his own behalf, though U was never

clear· as to what exactly Parker was on trial for. Parker was found guilty of some unspecifiedzoning code violations and sentenced to 90 days in .iail to start 45 days later. Judge Maus neveractually made any record of exactly what is was that Parker was guilty of. However, Maus did goon the record and said he did not know who the owner of The Ranch property was, but he did notthink it was Parker.

55. What transpired over the next 45 days was covered in a "Status Report" to Judge Maus andthe District Court and ended in the seizure of West World's remaining 24 horses.

56. On September 3, 2009, Judge Maus granted Color·ado's motion to seize Parker's and WestWorld's hones in Case Nu, 09-CV-881, and on the morning of September 4, 2009, the WeldCounty Sheriffseized 24 horses valuede at $500,000 and took them to an undisclosed place.

57.0n September 8, 2009, Plaintiff Parker committed himself to the Weld County .Jail pursuant toMans's executed order of July 9, 2009, to begin serving a 90 day contempt of cuurt jail sentence.



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58. On Septembe•· ll , 2009, Plaintiff Parker was taken from the Weld County Jail, in prison garb,with no notice, and taken before Judge Mans, and forced to attend a TRO hearing in Case No. 09-

CV-881, with no chance to consult with any attorney, talk with any witnesses, make any phonecalls, obtain any defense materials or documentation, or be informed u to what happened to thesci11.:ed 24 horses valued at more than $500,000. Later, Judge Maus secretly helped to arrange forsell West Worlds 24 hurses to his friend Nick Meagher for $7,500, without any notice to any of thehorse owners.

59. On ____ , 2009, Plaintiff Parker was released from the Weld County Jail.

60. On Aprill, 2010, upon motion from Arries, Judge Mans dismissed Laud Home DevelopmentCompany from the 07-CV-189 civil action, but kept Parker as a Defendant in the zoning code lawsuit.

6). On September 23,2010, Judge Maus disqualified himself as a. judge in 07-CV-189 and the casewas moved to Division 3, Judge Elizabeth B. Strobel.

62. On November 26, 2010, the District Court Uudge Strobel) entered an order dismissing the

contempt citation against Parker in 07-CV-189.

63. On December 21, 2010, Judge Strobel entered an order releasing the Lis Pendens against Land.Home Development Company and The Ranch property, even though said property had not been in

the name of"Land Home" for almost three years.

64. On January 5, 2011, Weld County, via Defendants Barker and Arrics filed another zoning codeviolation law suit, but this time it was against Rio Grande Canyon Properties, Inc., Case No. 2011-CV-19. Additionally, Arries filed another Lis Pendens against The Ranch property even thoughtruo Grande's deed had been recorded on July 2, 2008,- past Colorado's two year statute oflimitations to bring a civil action.

CLAIMS FQR RELIEF

65. Plaintiff Parker her·eby incorporates paragraphs 1 through 64 of this Complaint, as part ofthe facts relating to and in support of his !'laims fo r relief, and furthermore states as follows;

66. LACK OF JURISDICTION NO. 1: Plaintiff Parker hereby alleges that Colorado's judges in

general and Defendants Mans and Strobel in particular, have no jurisdiction to hear any legalmatter regarding the Plaintiff, pursuant to Article VI, Section 9, of the Colorado Constitutionbecause said statute is in violation of the United States Constitution, Article IV, Section 2,"Equality of Privileges" and Section 4, requiring a "Republican form of government", and Article

XIV, Section 1, "Equal protection ofthe Jaw", and Section 2, which requires all state JudicialOfficers to be popularly elected in free and open elections, and requires the Joss of congressionalrepresentation for any state that fails to allow for the free and open elections of its state judges(Judicial Officers).



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67. .Piaintitl' Parker hereby alleges that he (along with all other Colorado voters) have and arecurrently being denied the right to vote in any free and open election for any state judge "JudicialOfficer" inasmuch as Colorado passed a constitutional amendment in 1966, which became law on

January 17, 1967, requiring state judges (Judicial Officers) to be appointed by a politicalcommittee rather than elected by popular vote (Colorado Constitution, Article VJ-1 OS, 106).

68. Plaintiff Parker further alleges that ''Article TV, Section 4" requires the federal government(Federalism) to guarantee the citizens of every state in the Union, a republican form of governmentLikewise, "AJ•ticle XIV, Section 2" J'eads as follows; "Representatives (congressional) shall beapportioned among the several States according to their respective numbers, counting the wholenumber of persons in each State, excluding Indians not taxed. But when the right to vote at anyelection for the choice of" ..... " the Executive and Judicial Officers (state judges) of a State, or themembers of the Legislature thereof, is denied to any of the male inhabitants of such State, beingtwenty-one years of age, and citizens of the United States, 01· in any other way abridged, except forparticipation in rebellion, or other crime, the basis of (congressional) representation therein shallbe reduced in the proportion which the number of such male citizens shall bear to the wholenumber of male citizens twenty-one years of age in such State." Parker claims that even if the

citizens of a state wanted to give up their rights to elect theh· own .iudges, for what ever reasons,The Constitution OfThe United States prohibits such actions.

69. In 1!:170, Congress enfranchised the Indians (Native Amcricau) under Article XIV. In 1920,"Article XIV, Section 2" was expanded as to persons authorized to vote with the passage of"Article XIX", whieh granted women the right to vote. Thereafter, in 1924, Congress passed the''Indian Citizenship Act" which granted United States Citizenship to the Indians (NativeAmericans) and then in 1968 Congress passed the Indian Civil Rights Act. Thereafter , Congresspassed "Al'ticle X.XVT" thereby changing the national voting age from 21 to 18 years of age.

70, The Plaintiff' is claiming that the "Fourteenth Amendment, Paragraph No. 2" requires the freeand open elections of all state Executive, Legislative and "Judicial Officers" of a state and to thedegree that dtizcns, eighteen years of age or older, are denied the right to vote for their "JudicialOfficers" in free and open elections, a state loses its right to congressional representation inproportion to the ratio of qualified electors denied the right to vote for said state Judicial Officersor in this case, Colorado judges. Sinee no qualified person can openly run for a Coloradojudgeship, and since Colorado voters cannot vote for the judges of their choice, Plaintiff Parkercontends that Judge Mans has exercised jurisdiction by a fiction and that all Colorado judges arcillegal and that Colorado is not entitled to have any representation in the United States Congress.

71. Plaintiff Parker further alleges that "Article IV, Section 4" and "Artiele XIV, Section 2"forbid any state of the United States from becoming a totalitarian dictatorship run by a dictator oran oligarchy that appoints state executive, legislative and or Judicial Officers and thereafter, every

six years or ten years graciously grants the citizens of the state the right to confirm or not confirmthe various politically appointed officials .... which was the way elections were conducted in theformer Soviet Union under the Communist Party, and which is the way many current dictatorshipsconduct their own phony national elections.



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72. .Plaintiff Parker also alleges that Colorado's current "judicial political appointment andconfirmation system" does not constitute the free and open election of Colorado's Judicial Officers(state judges) as required by The Constitution Of The United States by any standard of judicial

review. Currently, no qualified person is presently at liberty to run for any Colorado judgeship onbehalf of himself, nor may anyone be drafted to run for any judicial (lffice by any group of personsof any form of persuasion because, all Colorado judges must first be appointed by a political

appointment committees to automatically serve from six (6) to ten (10) year terms in office beforeever haviog to face a public "reconfirmation" vote, and without any type of formal opposition.

73. Furthermore, the Plaintiff alleges that no Colorado judge can be recalled under Colorado'scurrent election laws regardless of how incompetent, rude, or corrupt they may be, because

Colorado .iudges are not considered to be elected officials under the current elections laws andtherefore, a Colorado judge eannot be recalled.

74. The Plaintiff further alleges that no Colorado judge is ever required to make any form offinancial disclosure pursuant to Colorado's "Sunshine Law" because Colorado judges are notconsidered to be publicly elected officials. There is nothing to prevent a Colorado judge fromestablishing a reconfirmation campaign fund and accepting financial contributions (hribe.s) forsome future reconfirmation campaign- even though Colorado judges seldom ever spend anymoney on their own reconfirmation, Defendant Maus, at all times relevant hereto, has been and is

an illegal judge without lawful jurisdiction.

75. Additionally, Colorado judges are not required to file any finaneial reports regarding their

campaign funds and those funds can be invested in anything from real estate to stocl>s and bonds.Likewise, said funds can be gathered up at the time of retirement and used by the ex-judge at willand in most cases, tax-free. There arc no Colorado laws in place to prevent such financial dealingson the part of Colorado judges bec:ause Colorado judges are not considered publicly electedofficials. And no Colorado judge is subject to any Colorado law governing term limitationsbecause Colorado judges are not considered elected officials under the Colorado Constitution,

Article VI, Sections 24 and 25.

76. Plaintiff Parker hereby claims that Colorado's judicial system has become corrupt because noColol'ado judge is currently required to make any kind of public disclosure regarding any personalbac.kground information suc.h as: information regarding bank accounts, financial records, realestate holdings, trust accounts or tax records; or any information regarding past educationalbackground such as the schools attended, years graduated or GPA; or any information regardingpast employment history or military service or any marital information; or any driving history,citizenship history, or any disclosures regarding memberships in any clubs, fraternities, soda!organizations, or societies . . . because Colorado's Judicial Officers (state judges) are notconsidered publicly elected officials; and, any information pertaining to a license to pntctice law is

also, more or less, kept confidential.

77. Twelve additional states have chosen, in one way or another, to deny their citizens the right toelect their own state "Judicial Officers" by way of open populnr elections. The general thinking fordoing away with the open popular electious of state judges revolves around the belief on the part ofthe legal community, supported by the judicial elite, that the general public is simply not smartenough (too stupid) to be put in charge of electing even the lowest of their own state judges.



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78. .But if the voting public is not smart enough to elect their own state judges, what would causeanyone to believe that the voting public should ever be allowed to select a Congressman, or a U.S.Senator or the President or Vice President of the United States? Surely these jobs are far moreimportant and require a great deal more aptitude than that of some city court judge

79) Plaintiff Parker hereby alleges that when "Article XIV" was passed and became part of theConstitution Of The United States, it was done with the clear intent to initiate a clearly defined lawwith serious consequences fm· the failure of any state to comport or comply with said Article, andthat it was NOT the intent of Congress to pass some vaguely written series of mild "politicalsuggestions" which could be casually disregarded or liberally construed. Defendant Mans actedagainst the Plaintiff by putting him in jail without any lawful jurisdiction and all in violation of the

Defendant's due process l'ights.

80. Plaintiff Parker hereby alleges that "Article 4, Section 4" is the constitutional safeguard whichprohibits foolish citizens from giving up their rights to vote in free and open elections for theirExecutive, Legislative and Judicial Officers - rights which were won only after many years oflighting- at a cost of millions of lives. I f 113 of Colorado's government (,Judicial Officers) can beappointed by a committee, why not have a second committee appoint all state "Legislative"ofticers'? And while we are at it, why not have a third committee appoint all "Executive" officers?And of course, we should also appoint a committee to "oversee" the conduct of the other three (3)

committees. And why not call this new "oversight" committee the "State Central Committee"

Comrades!'! ("It is not who votes that counts- but who counts the votes, that matters"- Stalin)

81. LACK OF JURISDICTION NO.2: The Colorado Constitution gives District Courts generaljurisdiction pursuant to Article VI, Section 9. in civil cases .... "except as otherwise provided for.".Plaintiff P<trker admits that Colorado district courts and county courts have concurrentjurisdiction with respects to matters which fall within the jurisdiction of both courts. However,Plaintiff Parker hereby alleges that, the District Court does not have legal jurisdiction in Case No,07-CV-189 or ll-CV-19, for the following good and sufficient reasons set forth below.

82. C.R.S. §30-15-410 specifically confers jurisdiction in the prosecution of violations of countyordinances on the County Court and not the Dist rict Courts. Furthermore, in her Weld CountyComplaints, Arries cites C.R.S. §30·28·124 for jurisdiction -said jurisdiction is clearly vested, persaid Colorado statute, in the County Court and not the District Court. Furthermore, nowhere in

Weld's Complaints does Weld motion the District Court to hear or decide any case. PlaintiffParker alleges that Defendant Maus never had lawful jurisdiction to rule on any alleged county

zoning code violations and to put Plaintiff Parker in jail. Aud furthermore, that Barker and An·icsknew or should have known that the statute of limitations barred the filing of cases 07-CV-189 andll·CV-19.

83. LACK OF J U R I S D I ~ T I O N NO. 3; The District Court- Judge Maus lacked jurisdiction tohear this matter in the first place because Land Home a.nd Parker began "RENTJNG" and"USING" The Ranch property in the spring of2000 and therefore, said usage pre-dates thecodification of the Weld County Zoning Code whi.ch, according to Weld's Complaint (11-CV-19)

paragraph 2., did not become effective until January 2, 2001. This fact was made known toattorney Arries and Weld iu Land Home's Answer to Weld's original Complaint's (07-CV-189) SeeLand Home's "General Allegations, Paragraph 2. ~ • , which was filed with the Distl'ict Court on



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April 25, 2007. However, Judge Strobel along with Defendants Maus, Barker and Arries, have allignored this fact, and have refused to allow the Plaintiff to ever have a hearing on an ex post factolaw. Furthermore, Plaintiff Parker was and is protected against Defendants B a r k e r ' ~ and Arries

claims for injunctive relief pursuant to an existing and non-conforming use in accord with CRS

·30·28-UO(l), which reads:

"The lawful use of a building or structure or the lawful use of anyland, as existing and lawful at the time of the adoption of a zoningt·esolution or, in the case of an amendment of a resolution, utthe time of such amendment, may be continued, although such uscdoes not conform with the provisions of such resolution or amendment,and such use may be extended throughout the same building if nostructurnlnltcration of such building is proposed or made for thepurpose of such extension."

84. Defendants Mans, Barker and Arries knew or should have Known that the aforesaidDefendants had no right or jurisdiction to prosecute either Land Borne Development Company orPlaintiff Parker in the 07-CV-189 case pursuant to CRS-30-:28-120(1).

85. LACK OF JURISDICTION NO.4: Plaintiff Parker further alleges that, CRS-30·15·409establishes a one year statute of limitation which bars the recovery of any fine or the prosecutionfor the commission of any offense made punishable under any ordinance of any county. Byattorney Arries' own admission, pursuant to Paragraph 6. of the 11-CV-19 Complaint, condructivenotice as to tbc ownership of The Runch property, wus given by Rio Grande Canyon Properties,Inc. by the filing of its deed with the o.ffice of the Weld County Recorder on July 2,2008. Therehave been no facts or allegations presented by Defendants Hal'k.er and Arries that any of thealleged zoning code violations complained of, started within the one year statutory time periodprior to the filing of the 11-CV-19 Complaint.

86. Furthermore, CRS-30·15·409 does not make any distinction between one type of entity overanother, such as individuals, corporations, or county governments, etc. Plaintiff Parker allegesthat whatever zoning code violation(s) Weld, Barker and Arries are claiming have occurred onThe Ranch property, said violations would have originally taken place in the early part of 2000.thus, Weld, Barker and Arrles filed 11-CV-19, eleven (11) years after the fact. Thus, the statute oflimitations has long s i n ~ e run its legal course. Plaintiff Parker alleges thut the doctrine of "laches"clearly applies in this case and that Defendants Weld, Barker and Arries knew or should haveknown that the District Court had no Jurisdiction to hear this case nor was Weld County entitled toany equitable relief against West World or its stockholders/investors by statutory limitation.

87. LACK OF JUIUSDJCTION NO 5: Plaintiff Parker hereby alleges that Defendants Weld,

Barker and Arries were barred from bringing the action against Parker in 07-CV-189 or ll·CV·l9and that Defendants Maus and Strobel lacked jurisdiction to hear the cases under the doctrines ofCollateral Estoppel and Res .Judicata in that the Weld had already had its day in Court under 02-

CV-558. There was not a single issue raised in the 07-CV-189 or 11-CV19 which was not raised inthe 02-CV·SSS case. During the May 5, 2004 con 'tempt hearing regurding 0:2-CV·SSS, the DistrictCourt granted the Weld County Attomey's "Motion To Dismiss" the case against Parker due to

"lack of evidence". This was not a "settlement agreement".



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88. Plaintiff Parker alleges that after the contempt hearing in 02-CV-558, Weld waited three (3)

years before it filed its 07-CV·189 case, which covered the very same issue that were addressed in

the OZCVSSS. The current case (11-CV-19) covens the same claims and the same ranch propertywhich was addressed in the two previous cases. Additionally, public notice regarding the purchaseof said ranch property by Rio Grande, was made known to attorney Arries in the early part of

2007. Attorney Arries waited for 4 years before filing the ll·CV·l9 case which covers the verysame issues that were addressed in the two previous cases, and all in violation of Colorado's statuteof limitations, pursuant C.R.S.§ 30-15-409. Weld, Barker and A•·ries know or should have knownthat they had now lawful right or jurisdiction to bring the aforementioned actions thereby resultingin an absolute abuse of process against the Plaintiff.

89. The Defendants Mans, Weld, Barker and Arries caused the Plaintiff to be arrested on June 24'\

2009, for alleged violations of unspecified "Weld County Zoning Codes" on r a n ~ : h property whkh

the Plaintiff did not own, and which was located in Weld County, Colorado, in violation of thel'laintift's Fifth Amendment rights.

90. Defendant Maus, supported by Baker and Arrics , caused the Plaintiff to be held on an excessivebond of $15,000, in violation of the Plaintifrs Eighth Amendment rights, "Excessive Bail".

91. 'fhe Defendants Maus, Weld, Barker and Arries caused the Plaintiff to undergo a QUICK "trial

by the court" forty-five (45) minutes after the Plaintiff was arrested, for said alleged zoning codeviolations, which took place in the Weld County Oistrict Court on the morning of June 24, 2009 in

violation of the .Plaintifrs Fifth Amendment rights (Oue Process of Law), Sixth Amendment rights(right to a jury trial and competent attorney) and bis Fourteenth Amendment rights, Section 1,

denial of due process of law and equal protection.

92. The Plaintiff was provided with a court appointed attorney by the name of Christopher G.

Collins (Collins) of Greeley, Colorado, whom the Plaintiff had never met or spoken to regarding the

case at hand (Case No. 07-CV-189) before said trial began. Likewise, Collins knew virtually nothingabout: I. The alleged zoning code violation; 2. The subject ranch property, or 3. Any of thePlaintiff's affirmative defenses regarding said zoning code violations; and all in violation of thePlaintiff's Fifth, Sixth, and Fourteenth Amendmcn t rights- denial of Due .Process and Assistance of

competent legnl Counsel.

93. When the .June 24, 2009, trial started, Defendant Mans never provided the Plaintiff with anyform of advisements regarding the Plaintiff's rights or advised the Plaintiff of the specific chargesthat the Plaintiff was being put on trial for, and al l in violation of the Plaintiff's Fifth, Sixth andFourteenth Amendments rights to due process of law, right to competent legal counsel and the rightto proper advisement of the charges against the Plaintiff,

94. Defendant Maus, supported by Weld, Baker aiid Arries, denied the Plaintiff the right to a jury

trial, in violation of the Plaintifrs Sixth and Fourteenth Amendment rights.

95. Defendant Maus, supported by Baker and Arries, denied the Plaintiff any time in which tocontact and call witnesses in his defense, and all io violation of the Plaintiff's Sixth and FourteenthAmendment rights to due process of Jaw and the right to call witnesses on his own behalf.



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96. Defendant Mans, supported by Baker and Arrics, denied the Plaintiff a continuance of saidtrial, thus denying the Plaintifftime to consult with court-appointed attorney Collins, in viol.ation ofthe Plaintiffs Fifth, Sixth and Foul'teenth Amendment dghb to due p•·ocess of law, unjustifieddeprivation of liberty, right to legal counsel, and the right to call witnesses on Plaintiffs behalf.

97, Near the end of the Trial (.June 25, 2009), Defendant Mau§ went on the record and stated that he(Maus) did not know who owned the subject ranch pl'operty, and then, on the record, dated that he(Maus) did not believe that the Plaintiff (Parker) did, in violation of the Plaintiffs Fifth andFourteenth Amendment rights.

98. Defendant Ma.us, supported hy Weld, Raker and .Arries, found the Plaintiff guilty of someu n s p ~ c i f i e d zoning code violations and sentenced the Plaintiff to serve 90 days in the Weld County.Jail, in violation ofthe Plaintiffs Fifth, Sixth and Fourteenth Amendment l'ights to due process oflaw and false imprisonment.

99. Defendant Mans, supported by Baker and Arries, ordered Plaintiff to commit himself to tbcWeld County Jail to begin his 90 day sentence on June lS, 2009; and coerced the Plaintiff toundergo 45 days of involuntary servitude and hard labor, during which time the Plaintiff wasexpected to go on to the subject ranch property, which the Plaintiff did not own, and thereafter, toproceed to destroy, sell, demolish, haul off, steal, vandalize and engage in numerous criminal acts,which the Plaintiff documented and reported to Defendant Maus, and all in vinlation of thePlaintiffs Fifth, Sixth, Eighth, and Fourteenth Amendment rights- denial of due process of Jaw,cruel and unusual punishments and involuntary sel'vitude.

100. Defendant Mans, supported by Baker and Arries, denied the Plaintiff a stay of execution in

order for the Plaintiff to appeal his 90-day sentence and the outrageous conduct of the entire two-day trial proceedings to the Colorado Court of Appeals (Case No. ), in violation of thePlaintiffs Fifth and Fourteenth Amendment rights.

101. While the Plaintitiwas serving his 90-day sentence in the Weld County Jail, he wasconstitutionally handicapped from gaining access to the Colorado Court of Appeals and obtainingany aid from outside sources, due to fact that the Weld County Jail has no law library or anyFederal or Colorado law books and the Weld County Jail operates an inmate phone calling systl:mthat costs from $5.00 to $7.00 per minute- in advance- and bars inmates from making any outsidecollect calls, in violation of the .Plaintiffs Fifth and Fourteenth Amendment rights. As a direct resultof being deprived of any access to any Colorado law book, Plaintiff Parker was denied access to thecourt of appeals and was denied any reasonable abili ty to pursue his appeal of his contempt of courtsentence all in violation of his constitutional rights to due process of law. Plaintiff hereby allegesthat the Weld County Jail is willfully run by Defen_dant Cook with the intention of keeping

prisoners from having any reasonable or meaningful access to the courts and to cause any form oflegal communication with the courts or judicial system to be as costly for the prisoners as possible.

102. The Plaintiff alleges that while the Weld County Jail does have some kind of a computer innblack box that rolls around on a metal stand, which jail officials call a "Law Library". Saidcomputer comes with no operational manuals; and the .Plaintiff could not find any jail official whoknew how the black box computer worked. Additionally, the Weld County jail offered no form of



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instruction as to how the black box computer worked. The Plaintiff spent hours, without any- success, attempting to figure out how the Weld County Jail's black box computer worked. Plaintiff

Parker alleges that the clcnr mnnngcmcnt structural plan of the Weld County Jail is to make itvirtually impouible for any inmate to have any meaningful access to the c.ourts and the judicialsystem. Defendant Cook's jail management policy, had the clear net affect of depriving PlaintiffParker from havina any meaningful access to the courts, and all in violation of the Plaintifrs Fifth

and Fourteenth Amendment right have reasonable access to the courts and to due process of law.

CLAIMS FOR RELIEF

I03. The Plaintiff incorporates all of the paragraphs in this Complaint for purposes of his claimsfor relief.

WHEREFORE, Plaintiff Parker seeks ,judgment against Defendants Mans, Strobel, Weld,

Barker, Arries and Cook as follows;

A. Compensatory damages for each and every claim made in and fromParagraph 1 to t 03, as a jury may deem just, fi t and reasonable.

B. Punitive damaees as to all issues raised herein, as a jury may deem just,fit and reasonable.

C. All costs associated with this action.

D. Pre-judgment and post-judgment interest on anyaward of damages to the extent permitted hy law; and,

E• .For such other and further relief ns this court or jury may deem just, fit,reasonable and appropriate.

105. Plaintiff Parker hereby combines and incorporates allr laims for relief into this Complaintand seeks additional relief as follows;

106, Plaintiff Parker seeks relief in the form of a reversal of the finding of contempt in Case No.07-CV -189 due to the violations of his civil and constitutional rights claimed herein.

107. Plaintiffseeks: l) The reversal of the default judgment entered in Case No. 07-CV-189; 2)Appropriate declaratory and injunctive relief; 3) Compensatory and consequential damages,including damages for emotional distress, loss of reputation, humiliation and forfeiture of

enjoyment of life and 4) Compensation for all other pain and sufferine on all claims allowed by lawin an amount to be determined at trial; and 5) For all other economic damage and losses allowed bylaw.



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DEMAND FOR A JURY TRIAL

Plaintiff Parker hereby makes demand for a .iury trial on all issues so triable.

Dated this 9'" day of December 2011.Trenton H. Parker

111 R. Bridge Street,Brigbton, Colorado 80601

(303-654·1 048)

P.18

suit against co judges

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