SUPREME JUDICIAL COURT OF THE STATE OF MAINE(sitting as the Law Court)

ELI A. BLACKHOUSEp lW a Benjamin W. Turner,

Plaintiff

LAUzuE CONNELLY

Respondent

V.

DOCKET NO. KEN.1O-58(Inj unctive Relief Requested)

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INTERLOCUTORY APPEAL FOR INJUNCTIVE RELIEF,A.ND REQUEST FOR PROCEDURAL ORDER

(FROM CRIME VICTIM \ITTH PFH COMPLAINTONAPPEAL TO THE LAW COURT)

The Plaintiff asserts criminal threatening - including harassment - by the alleged owner

of the building in which same o\ ner conspired to restrain him via organized Federal housing

fraud until his recent (February 6,2010) escape to Waterville, Maine. Irrespective of the ultimate

determination of the harassment definition - the matter now before the Law Court - the plaintiff

asserts that an upstanding Court would eventually find the Defendant to have participated in an

illegal eviction as described in 14 MRSA $ 6014. Additionally, the apartment's waranty of

habitability is being violated by housing fraud and criminal stalking, rendering it uninhabitable to

the Plaintiff as conditions have forced him to flee both its premises and the City of Gardiner.

I March 6,2010lMaine Supreme Judicial Court: DocketNo. KEN-10-5g

Despite said conditions, the Defendant continues to require the Plaintiffto pay excessive

"rent" (i.e., extortion), violating Federai housing code; if he does not pay such a monthly sum -which has heretofore kept him restrained at the scene of 235 Water Street - he will not be

permitted to maintain property rights or protect the contents of his apartment: police harassment

would entail during a forcible entry and detainer action during a period of time in which the

Plaintiff remains a victim of police sexual assault, a criminal act concealed by the Augusta police

Department in concert u,ith the Augusta Housing Authority (shockingly, the AHA is the same

agency conducting the embezzlement portion of the housing fraud in question). This financial

exploitation prevents him from successful participation in this action - Docket No. KEN-10-58 -as the ongoing embezzlement and extortion briefly cited in the Notice of Appeal obstructs the

particularly girzen a) the

limitations and additional expenses imposed by his iatrogenic disability, ancl b) the presence of

organized housinq fraud simultaneously conducted by various State-run agencies. A disabled

crime victim now in flight - as both Laurie Connelly and Cluis Vallee (of Vallee Real Estate)

insist upon engaging in on-site harassment of the Plaintiff in violation of both his Federal and

State disability rights - N4r. Blackhouse is now forced to rent two residences (for a total of

$875/mo.) while limited to an $852 monthly SSDI income. As a result of organized Federal

housing fraud, he cannot afford postage stamps or the basic means to participate in a pro se

protective action during a period of time in which criminal activity is going unaddressed by both

the District Attorney and the Office of the Maine Attorney General.

2 March 6,2010 | Maine Sdpreme Judicial Court: Docket No. KEN- l0-58

The Plaintiff now notes for the Court that the entire array of criminal activity is too

complex to elucidate in this appeal. However, the Court is advised that evidence of wrongdoing

is manifest upon simple examination of various records generated by both Laurie Connelly and

other entities attached to her organizatiofl, e.g., the Portland Housing Authority has consistently

refused to reinstate the Plaintiffs Section 8 housing choice subsidy despite its expiration having

occurred as a direct result of a violation of his disability rights; separately, Mr. Blackhouse has

been illegally denied transitional housing assistance via various agencies' faulty rendering of

Federal homelessness definitions; etc.

CURRENT DISPOSITION OF THIS ACTION

As Mr. Blackhouse has been required to file pro se, he now entreats the Court to

undertake any communication with the Defendants on his behalf. The Plaintiff is neither a

prosecutor nor a professional attomey and without such credentials, cannot evaluate any material

he distributes to the Defendants for its potential relevance to any criminal investisation now

necessary relative to the behaviors or business operations of the Connellys and their various

associates.

Additionally, the Plaintiff is a victim of sexual assault by an Augusta police officer and

notes that his status as such was mentioned in the PFH complaint he filed in District Court. The

docket listing generated by District Court in Augusta indicates that the lower court did not

distribute the full information to the Connellys, a decision which might have been informed by

the Plaintiffs safety and privacy relative to the assault. It is almost impossible to discem any

charges now before the Court to be entirely distinct from criminal activity conducted by the TLC

3 March 6,2010 | Maine Supreme Judicial Court: Docket No. KEN-10-5g

Properties, Vallee Property Management, and the various successive o\\mers of the building

participating in the human traffrcking ring already suffrciently described to the Maine Human

Rights Commission by Mr. Blackhouse.

As stated in the original Notice of Appeal - in which the Plaintiffincluded material more

appropriate for a formal brief - Mr. Blackhouse was kidnapped and permanently disabled in

2002. Prior to this, he was the witness to - and victim of - large-scale filancial crimes which

cuiminated in a series of criminal hospitalizations. The Plaintiff adds that he is presently the

target of a reprisal kidnapping conspiracy organized between a medical crime syndicate and the

Augusta Police Department. The Gardiner Police Department refused to assist Mr. Blackhouse in

this matter, and a GA administrator conspired to deprive him of necessary, State-mandated

benefits to make him more vulnerable to confinement and abuse.

In a letter to the Consurner Affails Division of the Public Utilities Commission, the

Plaintiffprovided the following synopsis of his victimization:

"I am the victim of multiple violent crimes that remain unprosecuted because of

racketeering between area police departments, the Augusta Housing Authority,

and medical facilities against which I have repeatedly attempted to file criminal

charges. I was kidnapped from private property in 2A02 and criminally restrained

within an unlicensed mental hospital by a group of private citizens acting entirely

outside of the necessary purview of the courts. The same group of people

conspired to cut my Section 8 housing subsidy in 2005, which radically increased

my rent-to-income ratio. Indeed, the amount of rent I have been forced to pay to

successive "owners" of the building through which I have been trafficked both

4 March 6,2010 | Maine S'upreme Judicial Court: Docket No. KEN- 10-5g

constitutes extortion and directly violates a number of HUD regulations. My SSDI

check is literally being drained to keep me out of reach of the court system.,, -January 6, 2010 letter to PUC (Consumer Assistance Division)

INJUNCTIVE REMEDY SOUGHT

As Mr. Blackhouse is currently a crime victim in flight from harassment - and as such

cannot file the brief for Docket No. Ken-10-58 (Maine Supreme Court) pro se without fixed

housing, adequate personal transportation, and rights afforded other citizens, he entreats the

Court to:

ENFORCEMENT

A) Order the appropriate State or Federal agency or judicial body to bring court

actions against the parties named in his initial MHRC complaint (Case No. H09-

0545), erroneously dismissed by the Commission but emergently actionable

according to Maine statute;

B) Assist Mr. Blackhouse's harassment lawsuit against Laurie Connelly, Docket No.

Ken-10-58 (now at Maine Supreme Judicial Court [sitting as the Law Court], i.e.,

this action);

C) Order a proxy to serve as the settlement intermediary between Ms. Connelly and

the Plaintifl as Mr. Blackhouse can have no direct contact with the Defendant

5 March 6,2010 | Maine S'upreme Judicial Court Docket No. KEN- t 0-5g

without risking the faiiure of his health, and as he has been required to proceed

with this actionpro se,.

D) lntervene immediately to determine Mr. Blackhouse's Gardiner property rights

pending the adjudication of the harassment charge against Laurie Connelly by

Maine Supreme Judicial Court (sitting as the Law Court);

E) Refer any Federal criminal activity discovered by the court _ such Mr.

Blackhouse's 2002 kidnapping, torture, and criminal restraint within the unlawful

premises of "P-6" at Maine Medical Center in Portland, Maine - to the portland

field office of the FBI, and to instruct the Bureau to open a formal investigation

with Mr. Blackhouse's participation, and for the agency to coordinate their efforts

with the US Attorney's offtce to whatever extent is usual and necessary;

F) Refer rampant, longstanding com:ption in the administration of the City of

Gardiner - and its police department - to the FBI for immediate investigation and

receivership;

COMPENSATORY

G) Direct the appropriate agencies, any of the MHRC-listed defendants, or Ms.

Connelly to provide monetary and other forms of compensation that will assist

Mr. Blackhouse in attending to the exigencies created by the conditions

caused by Ms. Connelly and other MHRC defendants;

6 March 6,2010 | Maine Supreme Judicial court: Docket No. KEN-10-5g

H) Direct the MHRC to deliver to the Plaintiff victim's assistance pursuant to 5 $

3360, et seq ("Victims'Compensation Fund,,);

D Provide the discrimination-related compensation ($20,000 - $100,000)

pursuant to 5 MRSA $ 4613 (2) (B) (7);

J) Provide the compensation described in 14 MRSA $ 5014 (2) as a rernedy to the

illegal eviction;

K) Enjoin Vallee Property Management from attempting to sell the property on

behalf of Tim and Laurie Connelly - pursuant to 5 MRSA $ 4613 - and to cease

and desist all efforts to enter Apartment 8 of 235 Water Street, for any reason

whatsoever, including alleged showings of the apartment to prospective buyers or

any other form of alleged assessment;

L) Order the Connellys not to attempt to enter the premises ofApt. 8 for any reason

whatsoever, including any reasons - ostensible or otherwise - relating to

"showing" the property (e.g., to prospective buyers of the building, now for sale),

asserting property rights, maintenance, and otherwise to treat the premises ofApt.

8 as entirely separate from their ownership;

7 March 6,2010 | Maine Si,rpreme Judicial Court: Docket No. KEN-10-58

M) Sell the property to Mr. Blackhouse pursuant to 5 MRSA $ 4613 (2) (B) (4),

and in a manner affordable to the Plaintiff, or to convey 235 Water Street

into the Plaintiff's ownership without compensation to the connellys;

REPI. CEMENT HOUSING

N) Direct the responsible defending party to purchase a permanent residence for Mr.

Blackhouse in the City of Waterville, and to furnish this residence;

O) Direct the responsible defending party to purchase a permanent residence for I\{r.

Blackhouse in the State of Florida;

P) Order the Connellys not to require the $4751mo. extortion they describe as "rent"

in advance of the decision by the Court, which - according to the briefing

schedule - cannot be made until after June 9, 20IA1:

PROCEDURAL

O Adjust any additional Maine Supreme Court procedures to accommodate Mr.

Blackhouse's disability, including off-site accommodations (e.g., any oral

arguments potentially required by the Court, such as the one anticipated in the

briefing schedule, to be handled via altemative comrnunication);

I The extorted SSDI gleanings that IvIr. Blackhouse was forced to pay during a period of time in which he waswrongfully confined to the City of Gardiner - and out of reach of the court system - were laundered through theprevious owner's restaurant and bar (the Mad Dog Pub).

8 March 6,2010lMaine Supreme Judicial Court: DocketNo. KEN-10-58

R-) Alter Court procedures in light of Mr. Blackhouse's allegation that the activity by

successive landlords - conducted by Vallee Property Management tluough a

money-laundering and human trafficking racket - is criminal, and not simply

civil, in origin, and to undertake to convey/communicate any information

to the Defendants as presently required by the civil appellate rules regarding

copying opposing parties on the various motions germane to the appeal;

S) Provide the Plaintiffwith an exact copy of any and all material delivered by the

Court to the Connellys relative to Docket No. Ken-10-58 or the District Court

docket preceding it, and to provide such copies on an ongoing basis;

T) Order that the Plaintiffis permitted to proceed with anonymity regarding his

current residence in Waterville, protecting the rights and interests of the

homeowner providing him with transitional shelter;

U) Order the City of Waterville to provide emergency assistance, if such assistance is

not provided by another entity - such as the FBI - and in the amount and form

deemed necessary by the Court, including rental assistance distributed to the

Plaintiffin cash so that he can maintain his current waterville-based

transitionauemergency residence, which is a privately-owned house, with

protective anonymity;

9 March 6,2010 | Maine Sirpreme Judicial court: Docket No. KEN-10-5g

TRANSPORTATION

V) Order the reinstatement of Mr. Blackhouse's Maine driver's license, fraudulently

suspended by the Maine Department of Motor vehicles \n2005;

W) Order the responsible party to provide Mr. Blackhouse with a new automobile for

his personal and Court-related use, which will also help prevent additional

stranding and victimization(the State's GA auditor - Ellen Heath - refused to

acknowledgethatrequiring Waterville to pay rent for the Gardiner residence

durine the property dispute would be both a reasonable accorlmodation of a

disability and a deductible, disability+-elated expense2);

X) Provide Mr. Blackhouse with a private transportation fund enabling him

unfettered, unexamined access to US travel via airline, rental car, or any other

mode of transportation;

OTHER

Y) Award any other civil, penal, or compensatory monetary damages it deems

appropriate, and to make any other judgment pursuant to its statutory or judicial

powers to advance the protection of Mr. Blackhouse, independently of any

specific action by the MHRC or otherwise (e.g., for the court - or the

2 It is also unlikely that any specific regulation prohibits municipal emergency GA programs from paying for tworesidences simultaneously. State laws provide GA adminisfators the ability to tailor emergency assistance toindividual need, the nature ofthe emergency, andthe availability ofresources.

l0 March 6,2010 | Maine Sirpreme Judicial courr Docket No. KEN-10-5g

commission - to order the city of Gardiner to provide immediate cash

assistance to the Plaintiff; etc.).

Multiple other necessary injunctive measures are emergently necessary but the details are

not listed herein because of time and filing restraints (the immediate. permanent closure of

Maine Medical Center, the Augusta Housing Authority, etc.).

The Plaintiff requests that any compensatory and recuperative awards and orders that arc

not immediately distributed by the Court after examination of this interlocutory appeal are

administered instead through the FBI and/or the US Attorney (e.g., by the US Attorney's

victim/witness coordinator). He notes again that some forms of compensation are more readily

distributable than others and, if compensation is not immediately available from the

Defendant(s), he entreats the Court to order money and other forms of support to be delivered by

the various State or municipal agencies who have colluded to prevent him from receiving

sufftcient crime-related assistance.

He further notes that while Adult Protective Services has the mandate to order the various

violating agencies to provide restitution (e.g., the immediate restoration of his housing subsidy)

via direct intervention in such matters through the Courts, the Plaintiff has not been able to

access APS services because of the "easy-commitment" policies promoted by its operations,

including a) excessive "incapacitation" review procedures for victims of neglect and

exploitation, b) widespread ignorance or criminal misrepresentation - on the part of persormel -of the qualifying criteria for receiving APS services, and c) the agency's racketeering and

unconstitutional proximity to the criminal orgarization dlbla Riverview (formerly AMHI - APS

is located on the AMHVRiverview campus in Augusta).

l1 March 6,2010 | Maine Supreme Judicial Court: Docket No. KEN-10-58

Respectfully submitted byMWOn:

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Filingpro se

12 March 6,2010lMaine supreme Judicial court: DocketNo. KEN-10-5g