RICHARD LEWIS, in PROPRIA PERSONA and EX REL as a Private Attorney General For the Citizens of Tennessee and the People of the United States of America P. O. Box 365 Maynardville, TN 37807
UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TENNESSEE
RICHARD LEWIS, an individual in propria persona and ex rel; Private Attorney General; NELLE PAEGEL, Esq. a licensed California attorney and an individual; THOMAS W. PAEGEL, an individual; THOMAS W.V. PAEGEL, an individual; LORRAINE LEWIS, individual; RICHARD L. LEWIS III, an individual; MINOR CHILD 1, age 6 an individual; MINOR CHILD 2, age 8 an individual; MINOR CHILD 3, age 3 an individual; MINORCHILD 4, age 7 an individual; THE BODY COMPANY SPORTS, INC, a Nevada corporation; and DOES 1-300 INCLUSIVE, Plaintiffs
LYDIA KORNILOFF aka LYDIA CORNELL, an individual; LYDIA CORNELL ENTERPRISES, a non-entity business; GODSHOTS (TM, L.L.C.), a non-organized internet website claiming to be an L.L.C., a charitable organization with a trademark; PAUL HAYELAND, aka PAUL HAYLAND, aka PAUL AYELAND, aka, PAUL AYLAND, aka, PAUL CORNELL, an individual; SPORTS ICON ENTERTAINMENT, a non-entity business; GSAXE, a non-entity internet retail business owned by Gene Simmons of the band known as KISS; AMERICAN EXPRESS TRAVEL RELATED SERVICES COMPANY, INC., a New York corporation and their agents and affiliates; WILLIAM BEATY, an individual; GEORGE DEL JUNCO, an individual, ELIDA DEL TORO, an individual; DAVID FLEMING, an individual; THE GREEN NETWORK, an entity of unknown derivation; eSTARHD.TV, an by Text-Enhance">internet business of unknown derivation; HITMAN PR, an internet website; STEPHANIE M. KING, an individual; MERITUS by Text-Enhance">PAYMENT SOLUTIONS, a credit card processor of unknown by Text-Enhance">registration; ALLEN S. MILLER, an individual; THE MILNER GROUP, LLC, a California limited liability company; DAVID M. ROBINSON, an individual; STAROPOLY, LLC, a revoked Nevada limited liability company; TSOFTNET, INC, a Nevada corporation; IVAN JACKSON, director, treasurer, and secretary of TSOFTNET, INC; PHILLIP MULLIGAN, president and director of TSOFTNET, INC.; TODHD, a subsidiary of TSOFTNET, INC, or other company; VIEWPARTNER CORPORATION, a Nevada corporation; ALEX VARONOS, aka ALEX VARONAS, aka ALEX ZARONOS, aka ALEX ZAMBONI, (aka UNKNOWN) an individual; WELLS FARGO N.A., a California corporation and their agents and Affiliates; CRAIG T. WORMLEY, an individual; (ALLEN) KELSEY GRAMMER, an individual; GRAMMNET, INC., a California corporation; GRAMMNET PRODUCTIONS, a California corporation; GRAMMNET NH PRODUCTIONS, a California corporation; GRAMMNET NH PRODUCTIONS, California corporation; GRAMNET GLOBAL, LLC, a California limited liability company; INNOVATIONS SUPPORT, a California limited liability company; SOLSTICE PROPERTIES, a California limited liability company; WORLD CUP COMEDY, LLC, a California limited liability company; ASTERISK, LLC, a California limited liability company; C2 CHANNEL CHANNEL, LLC, a California limited liability company; G3 MEDIA, LLC, a California limited liability; L A THEATRE SPORTS, a California corporation; NELSON PAGE ENTERTAINMENT, INC., a California corporation; SOLSTICE, LTD, a California limited liability company (suspended); KELSEY GRAMMER CHARITABLE FOUNDATION a California corporation GRAMMNET NH, INC.
A California corporation; MARTHA KEHOE, an individual; JAN A. PLUIM, an individual; KEITH G. WILEMAN, an individual;
XIAOYI YAO, an individual; ROBERT NEWELL, JR., an individual; LYRIX ENTERPRISES, a non-organized consulting and marketing internet business; MEKI COX, an individual aka (Meki L. Cox, Meki Lynn Cox, Meri Lynn Cox, Meki Cox, Meki C. Jaklitsch, Meki Jaklitsch, Meki L. Coxjaklitsch, Meki Selman, (aka UNKNOWN other identities); eSTARHD.TV, an online operation of unknown origin; ZURICH INSURANCE, N.A., an insurance company; FARMERS INSURANCE GROUP, an insurance company; MASTERCARD WORLDWIDE, a New York corporation; CINDY THOMAS, an individual; PETE E. ALMEIDA, an individual; S. MARTIN KELETI, and individual; EDWARD WALSH, an individual; JAMES HILLIS FORD, an individual; MARTHA KEHOE, an individual; ARTHUR HADDOCK, an individual; BARBARA NIVEN, an an individual; CORBIN BLEU, an individual; AV COMPUTER DOCTOR/CASEY KEITH a non-organized business; JAMES D. ROBERTS, an individual and DOES 1-300 INCLUSIVE, Defendants
) CASE NO: 3:13-CV-93) ) DATE OF FILING: Feb 20th 2013
) COURT DATE OF TRIAL:
) PLAINTIFFS DEMAND FOR
) JURY TRIAL; UNLIMITED CIVIL CASE;
) REQUEST FOR GAG ORDER
) JUDGE: HON. Bertelsman/Guyton
) HRG. DATE:
) COMPLAINT FOR DAMAGES FOR:
) 1) OBSTRUCTION OF JUSTICE (INCLUDING, BUT NOT LIMITED TO: COLLUSION, CONSPIRACY, PERJURY, BRIBERY DEFAMATION, FALSE REPORTING, ASSAULT& TECHNOLOGY HACKING)
) 2) GRAND THEFT BY FALSE PRETENSES
) 3) FEDERAL CONSPIRACY
) 4) FEDERAL EXTORTION/ATTEMPTED EXTORTION AND BLACKMAIL
) 5) CREDIT/DEBIT CARD FRAUD AND PHISHING
) 6) CHILD ENDANGERMENT AND CHILD ABUSE
) 7) FEDERAL ILLEGAL PRACTICE OF BUSINESS AND FALSE ADVERTISING
) 8) FRAUD BY INTENTIONAL OR FRAUDULENT MISREPRESENTATION
) 9) FRAUD BY NEGLIGENT MISREPRESENTATION
) 10) FRAUD BY FRAUDULENT INDUCEMENT TO ENTER INTO CONTRACT
) 11) INDUCEMENT TO COMMIT FRAUD
) 12) CONVERSION
) 13) GRAND LARCENY THEFT OF PERSONAL PROPERTY
) 14) GRAND THEFT OF MATERIAL
) 15) UNFAIR COMPETITION BY TORTIOUS INTERFERENCE WITH EXISTING BUSINESS RELATIONSHIP; PROCUREMENT OF BREACH OF CONTRACT
) 16) UNAUTHORIZED PRACTICE OF LAW
) 17) BREACH OF CONTRACT
) 18) BREACH OF COVENANT OF GOOD FAITH AND FAIR DEALING
) 19) INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONSHIPS
) 20) FRAUD VIA INTERNET, COMPUTER FRAUD AND ABUSE
) 21) INTERNET PIRACY, PHISHING
) 22) NEGLIGENCE/GROSS NEGLIGENCE
) 23) GRAND THEFT BY EMBEZZLEMENT
) 24) INVASION OF PRIVACY, PHISHING
) 25) COMPUTER FRAUD AND ABUSE, INTERNET HACKING, PHISHING AND CYBER-CRIMES
) 26) VIOLATION OF THE AMERICANS WITH DISABILITIES ACT
) 27) HARASSMENT AND INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
) 28) FILING FALSE REPORTS WITH GOVERNMENT AGENCIES
) 29) INSURANCE BAD FAITH
) 30) BUSINESS INTERFERENCE
) 31) DEFAMATION
) 32) VIOLATIONS OF THE FEDERAL RULES OF DISCOVERY
) 33) FEDERAL AND STATE INCOME TAX EVASION AND FRAUD
) REQUEST FOR DECLARATORY
) RELIEFCONSTRUCTIVE TRUST,
) RESTITUTION, PERMANENT INJUNCTION,
) SUMMARY POSSESSION, PUNITIVE
) DAMAGES, ATTORNEY FEES AND COSTS
) 18 U.S.C. CH. 1961-1968, et seq.; HOBBS Act 18 U.S.C. 1951; 18 U.S.C. 201, 202-209; The Federal Extortion and/or Blackmail Act, 18 U.S.C. 872, 875-877; Grand Larceny; Stalking 18 U.S.C. 2261A et seq.; Mail Fraud 18 U.S.C. 1341; Wire Fraud 18 U.S.C. 1343; Extortion 18 U.S.C. 875; Full Faith and Credit 1738-1739; Americans with Disabilities Act of 1990, 42 U.S.C. 12131; U.S.A. Patriot Act of 2001, 42 U.S.C 5195; Homeland Security Act of 2002 6 U.S.C. 101; 12 U.S.C. 2605(e)(2)(A) and (e)(3), ABA Model Code of Judicial Conduct (CANONS); Racketeer Influenced and Corrupt Organizations Act of 1970; Tennessee Civil RICO Act of 1968; Tennessee RICO act 1968; Tennessee GANG BILL; the Tennessee Terrorism Prevention Act, and common law of the United States (collectively, The ACTS) and Tennessee, California, and Florida statutes and common law; The Adam Walsh Child Protection and Safety Act of 2006.
RICHARD LEWIS (LEWIS), P.O. Box 365, Maynardville, TN 37807.
NELLE PAEGEL (NELLE), 231 S. Glendora Ave, Glendora, CA 91741.
THOMAS W. PAEGEL(TOM), 231 S. Glendora Ave, Glendora, CA 91741.
THOMAS W. V. PAEGEL (TOMMY), 231 S. Glendora Ave, Glendora, CA 91741.
THE BODY COMPANY SPORTS, INC (TBCS), 231 S. Glendora Ave, Glendora, CA 91741.
LORRAINE LEWIS (LORRAINE), address placed under seal, contact RICHARD LEWIS at P.O. Box 365, Maynardville, TN 37807.
RICHARD L. LEWIS III (LEWIS III), address placed under seal, contact RICHARD LEWIS at P.O. Box 365, Maynardville, TN 37807.
MINOR CHILD 1 (MINOR), address placed under seal, contact RICHARD LEWIS at P.O. Box 365, Maynardville, TN 37807.
MINOR CHILD 2 (MINOR) , address placed under seal, contact RICHARD LEWIS at P.O. Box 365, Maynardville, TN 37807.
MINOR CHILD 3 (MINOR3), address placed under seal, contact RICHARD LEWIS at P.O. Box 365, Maynardville, TN 37807.
MINORCHILD 4(MINOR) , address placed under seal, contact RICHARD LEWIS at P.O. Box 365, Maynardville, TN 37807.
LYDIA KORNILOFF aka LYDIA CORNELL (CORNELL), 300 S.
Crescent St. Beverly Hills CA, 90212 and P.O. Box Address 269 S. Beverly
Drive, #1024, Beverly Hills, CA 90212.
GODSHOTS (TM, L.L.C.)(CORNELL) 269 S. Beverly Drive #1204, Beverly Hills, CA 90212.
PAUL HAYELAND (HAYELAND), and aliases, 269 S. Beverly Dr., # 608, Beverly Hills, CA 90212 and PCH.1111@YAHOO.COM.
SPORTS ICON ENTERTAINMENT (SIE), c/o PAUL HAYELAND and GSAXE.com.
GENE SIMMONS (SIMMONS), 2650 Benedict Canyon Drive, Los Angeles, CA.
AMERICAN EXPRESS TRAVEL RELATED SERVICES COMPANY, INC.
(EXP), c/o CT Corporation System, 111 Eighth Avenue, New York, New
WILLIAM BEATY (BEATY), 81 Newport Ave., Santa Ana, CA 92705.
GEORGE DEL JUNCO (JUNCO), 1643 Larkvane Road, Rowland Heights, CA 91748.
ELIDA DEL TORO (TORO), 1643 Larkvane Road, Rowland Heights, CA 91748.
THE GREEN NETWORK (GREEN), 1643 Larkvane Road, Rowland Heights, CA 91748.
DAVID FLEMING (FLEMING), 5016 Kester, Apt. 211, Sherman Oaks, CA 91703.
HITMAN PR/HITMAN PR.COM (HITMAN), 411 E. Huntington Dr., STE 107 PMB 285, Arcadia, CA 91006.
STEPHANIE M. KING (KING), 375 Huntington Drive, Ste. B, San
Marino, CA 91106 or 541 Linwood Avenue, Unit C, Monrovia, CA 91016.
MERITUS PAYMENT SOLUTIONS (MERITUS), 1901 E. Alton Parkway, Ste. 220, Santa Ana, CA 92705-5849.
ALLEN S. MILLER (MILLER), 541 Linwood Avenue, Unit C, Monrovia, CA 91016.
THE MILNER GROUP, LLC (MILNER), c/o DAVID ROBINSON agent for
service of process, 715 S. Barrington Ave., Apt. D, Los Angeles, CA
DAVID M. ROBINSON (ROBINSON), 715 S. Barrington Ave., Apt. D, Los Angeles, CA 90049.
STAROPOLY, LLC (STAROPOLY also included as VARONOS), c/o
Laughlin Associates, Inc., 2533 N. Carson Street, Carson City, NV 89706.
TSOFTNET, INC. (TSOFTNET also included as VARONOS), c/o Davine Henderson, LLC, 2533 N. Carson St., Carson City, NV 89076.
IVAN JACKSON (JACKSON also VARONOS and STAROPOLY),
Director, Treasurer, and Secretary of TSOFTNET, INC. c/o Davine
Henderson, LLC, 2533 N. Carson St., Carson City, NV 89076.
PHILLIP MULLIGAN (MULLIGAN also VARONOS and STAROPOLY),
President and Director of TSOFTNET, INC. c/o Davine Henderson, LLC,
2533 N. Carson St., Carson City, NV 89076.
TODHD (TODHD also included as VARONOS), TSOFTNET, INC.,
manager, c/o Davine Henderson, LLC, 2533 N. Carson St., Carson City, NV
VIEWPARTNER CORP. (VIEWPARTNER also included as VARONOS),
c/o Laughlin Associates, Inc., 9120 Double Diamond Pkwy., Reno, NV,
ALEX VARONOS, President, Director, Secretary, Treasurer of
VIEWPARTNER CORPORATION, c/o Laughlin Associates, Inc., 9120 Double
Diamond Pkwy., Reno, NV, 89521.
ALEX VARONOS (aka ALEX ZARONOS, aka ALEX ZAMBONI)
(VARONOS), 11182 Lexington Dr., Los Alamitos, CA 90720; 1772 J. East
Avenida de Los Arboles #114, Thousand Oaks, CA 91362; or by publication
WELLS FARGO N.A. (FARGO), 1200 Montego Way, Walnut Creek, CA 94598.
CRAIG T. WORMLEY (WORMLEY), 1109 Englewild Dr., Glendora, CA 91741.
KELSEY GRAMMER (included as GRAMMER), 11 E. Walton St., Apt. 3002, Chicago, Ill. 60611-5405.
GRAMMNET, INC. (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
GRAMMNET NH, INC. PRODUCTIONS, (included as GRAMMER) c/o
Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
GRAMMNET NH PRODUCTIONS (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
GRAMMNET PRODUCTIONS (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
SOLSTICE, LTD (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
GRAMNET GLOBAL, LLC (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
INNOVATIONS SUPPORT, LLC (included as GRAMMER) , c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
SOLSTICE PROPERTIES, LLC included as (GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
WORLD CUP COMEDY, LLC (included as GRAMMER) , c/o Wayne Page, 1066 Charles St., Pasadena, CA 91103
ASTERISK, LLC (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
C2 CHANNEL CHANNEL, LLC (included as GRAMMER) , c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
G3 MEDIA, LLC (included as GRAMMER), c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
LA THEATRE SPORTS (included as GRAMMER) , c/o Dan OConnor, 2145 N. Gower St., Los Angeles, CA 90068.
NELSON PAGE ENTERTAINMENT, INC. (included as GRAMMER) , c/o Wayne Page, 1066 Charles St., Pasadena, CA 91103.
GRAMNET NH, INC. (included as GRAMMER) c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA 90064.
KELSEY GRAMMER CHARITABLE FOUNDATION included as (GRAMMER) ,
c/o Jeff W. Lane, 11400 W. Olympic Blvd., Ste. 200, Los Angeles, CA
JAN A. PLUIM, (PLUIM) Judge of the California Superior
Court, Pasadena Superior Court, department P, 300 E. Walnut, Pasadena,
KEITH G. WILEMAN (WILEMAN), 3226 Mills Ave. La Cresenta, Ca. 91214.
XIAOYI YAO (YAO), 49 Sycamore Lane, Buena Park, CA 90621.
S. MARTIN KELETI (KELETI), 8340 Melrose Avenue Los Angeles, CA, US 90069-5420
ROBERT NEWELL, JR.. (NEWELL), Biltmore Court, 520 S. Grand Avenue, Suite 390, Los Angeles, CA 90071.
MEKI COX SELMAN and all akas (COX), 44519 10TH STREET, WEST LANCASTER, CA 93534.
LYRIX ENTERPRISES, (included as COX) 44519 10TH STREET, WEST LANCASTER, CA 93534.
eSTARHD.TV, c/o David Fleming, 5016 Kester, Apt. 211, Sherman Oaks, CA 91703.
ZURICH INSURANCE, N.A. (ZURICH included as INS), 1400 American Lane, Schaumburg, IL 60196.
FARMERS INSURANCE GROUP (FARMERS included as INS),
Farmers National Document Center, P.O. Box 268994, Oklahoma City, OK
73126-1389 FAX 877-217-1389.
MASTERCARD WORLDWIDE (MC included as FIN. INST.), 2000 Purchase Street, Purchase, NY 10577 U.S.A.
CINDY THOMAS (THOMAS), clerk of the California Pasadena Superior Court, Dept. P, 300 E. Walnut, Pasadena, CA 91101.
BARBARA VARGAS (VARGAS), clerk of the California Pasadena Superior Court, Dept. P, 300 E. Walnut, Pasadena, CA 91101.
PETE E. ALMEIDA, (ALMEIDA) 700 S. Flower St., 22nd Fl., Los Angeles, CA 90017-4209.
EDWARD WALSH, (WALSH) 717 17th Street, Suite 1520, Denver, CO 80202.
JAMES HILLIS FORD (FORD) through publication Boston Globe 135 Morrissey Blvd. Boston, MA 02125.
MARTHA KEHOE (KEHOE) 6238 Berkeley St., Englewood, Florida, 34224
ARTHUR HADDOCK (HADDOCK) dedicated due to MINORS
BARBARA NIVEN AKA Barbara Lee Buholz. (NIVEN) c/o LEGALZOOM.COM, INC. 100 WEST BROADWAY SUITE 100 GLENDALE CA 91210.
CORBIN BLEU (BLEU) C/O Neil E. Meyer, Stone Meyer, & Genow 9665 Wilshire Boulevard
Suite 510 Beverly Hills, CA 90212.
JAMES D. ROBERTS, Esq. (ROBERTS), 20301 Ventura Blvd., Ste. 351, Woodland Hills, CA 91364.
CASEY KEITH/AV COMPUTER DOCTOR 44519 10th St West Lancaster, CA 93534
All defendants that cannot be reached through normal service will be served through publication in accordance to the rules.
Plaintiffs, RICHARD LEWIS in pro per and ex rel,
LORRAINE K. LEWIS, RICHARD L. LEWIS III, NELLE PAEGEL, THOMAS W. PAEGEL,
THOMAS W.V. PAEGEL, ALL PAEGELS COLLECTIVELY (PAEGELS), THE BODY
COMPANY SPORTS, INC. (TBCS), MINOR CHILD 1, MINOR CHILD 2, MINOR
CHILD 3, and MINOR CHILD 4 (collectively MINORS) file this Complaint
and alleges against Defendants as follows:
Defendants, LYDIA CORNELL KORNILOFF; GODSHOTS,; WILLIAM
BEATY, GEORGE DEL JUNCO, ELIDA DEL TORO, DAVID FLEMING, THE GREEN
NETWORK, HITMAN PR/HITMAN PR.COM (HITMAN), STEPHANIE M. KING (KING),
MERITUS PAYMENT SOLUTIONS (MERITUS), ALLEN S. MILLER (MILLER), THE
MILNER GROUP LLC (MILNER), DAVID M. ROBINSON (ROBINSON), STAROPOLY
LLC (STAROPOLY), TSOFTNET, INC (TSOFTNET), TODHD (TODHD), a
subsidiary of TSOFTNET, INC, STAROPOLY AND/OR VIEWPARTNER CORPORATION,
VIEWPARTNER CORPORATION (VIEWPARTNER), ALEX VARONOS, aka ALEX ZARONOS,
aka ALEX ZAMBONI (VARONOS), IVAN JACKSON, an individual, PHILLIP
MULLIGAN, an individual, WELLS FARGO N.A. (FARGO or FIN. INST.),
CRAIG T.WORMLEY (WORMLEY). KELSEY GRAMMER, an individual and his
known companies organized in California: GRAMMNET, INC., GRAMMNET NH,
INC. PRODUCTIONS, GRAMMNET NH PRODUCTIONS, GRAMMNET PRODUCTIONS,
SOLSTICE, LTD, GRAMNET GLOBAL, LLC, INNOVATIONS SUPPORT, LLC, SOLSTICE
PROPERTIES, WORLD CUP COMEDY, LLC, ASTERISK, LLC, C2 CHANNEL CHANNEL,
LLC, G3 MEDIA, LLC, LA THEATRE SPORTS, NELSON PAGE ENTERTAINMENT, INC.,
GRAMMNET NH, INC., KELSEY GRAMMER CHARITABLE FOUNDATION, COLLECTIVELY
(GRAMMER),. AMERICAN EXPRESS TRAVEL RELATED SERVICES, INC (EXP and
FIN. INST.), HON. JAN A. PLUIM, an individual; KEITH G. WILEMAN, ESQ.,
an individual; S. MARTIN KELETI, ESQ., an individual; XIAOYI YAO, ESQ.,
an individual; ROBERT NEWELL, JR., ESQ., an individual; MEKI COX, an
individual aka (Meki L Cox, Meki Lynn Cox, Meri Lynn Cox, Meki Cox, Meki
L Coxjaklitsch, Meki C Jaklitsch, Meki Jaklitsch, Meki L Coxjaklitsch,
and Meki Selman); ALEX VARONOS, an individual; ALLEN S. MILLER, an
individual; DAVID FLEMING, an individual; eSTARHD.TV, an online internet
operation of unknown origin; ZURICH INSURANCE, N.A. (ZURICH or
INS.), an insurance company; FARMERS INSURANCE GROUP (FARMERS or
INS.), an insurance company; MASTERCARD credit card company, CINDY
THOMAS, an individual; PETE E. ALMEIDA, an individual; EDWARD WALSH, an
individual; JAMES HILLIS FORD an individual; MARTHA KEHOE an individual;
and ARTHUR HADDOCK, an individual, BARBARA NIVEN, an individual and
CORBIN BLEU, an individual. CASEY KEITH an individual, AV COMPUTER
DOCTOR fraudulent business LYRIX ENTERPRISES, a fraudulent non-organized
consulting and marketing internet business; BARBARA VARGAS, an
individual; JAMES D. ROBERTS, Esq., an individual.
LEWIS REQUESTS AN ORDER OF THE FEDERAL COURT
to have all Defendant individuals AND their counsel present themselves in person no later than one week before answering this complaint for the purpose of being fingerprinted by United States Marshals. This case involves individuals who have committed child endangerment (as required by The Adam Walsh Child Protection and Safety Act of 2006), internet fraud and other frauds, including identity theft. The Court and the plaintiffs need to be assured of defendants and counsel true identities. Each individual must bring a valid State or Federal form ofphoto identification.
LEWIS FEARS for the safety of all PLAINTIFFS, and does so for the forgoing reasons. As soon as this Federal complaint is filed, and the defendants are notified and aware that they are being brought to the Tennessee Federal court under the Federal CIVIL RICO ACT, and knowing that information has been collected and continuing to be collected about their activities, LEWIS FEARS that retribution reprisal and possible injury to and against the PLAINTIFFS including the MINORS.
For instance, MILLER has a pattern of threating people and also threating people with a firearm; MILLER has been known to keep a pistol in his belt. MILLER does not have a carry permit and has admitted to having unregistered firearms. See EXHIBIT No. 9, Pg 60. MILLER is known to have a personal friend who owns a firing range. MILLER has a
webpage called HITMAN which is tongue in cheek for his duties in the GANG.
VARONOS has already has made death threats upon LEWISS life in open court; WILEMAN has bragged about owning a $4,000.00 shotgun; WALSH, FORD and COX have made open threats to LEWIS and his family. LEWIS speaks for all the Plaintiffs in notifying and pleading to this court and law enforcement to offer protection. Defendants and any of them are the most likely candidates for further crime. LEWIS knows that a piece of paper will not stop a bullet and as such places this plea for protection for all PLAINTIFFS.
LEWISS complaint and allegations against Defendants are as follows:
STATEMENT OF ACTION
The Federal Rule of Civil Procedure for complex litigation requires that the court hearing a complex litigation case initiates and implements efficient supervision and control of the litigation proceedings from the beginning of the process to ensure a fair resolution of the complex litigation issue before it. The procedure expects all parties and representing counsel to collaborate in a professional manner and work together for the free exchange of basic and essential information within the allotted time to allow for proper initial pre-discovery and planning as well as case preparation. The rule presumes the court and all representing counsel will cooperate for the evolution of the case and the progression of
settlement negotiations in a fair manner. The Federal Rule of Civil Procedure grants the presiding judge special procedures for managing potentially difficult or protracted actions that may involve complex matters, multiple parties, difficult legal situations, or extraordinary proof issues.
The complex litigation handbook addresses certain types of cases including: Antitrust, Securities, Employment Discrimination, Intellectual Property, CERCLA (Superfund) and Civil RICO. Complex litigation regularly involves two or more separate cases that have some relation or link between them. This may include all pending associated cases or cases that may filed later in the same court even if the cases are filed in separate division of the court. All related
cases should be assigned to the same judge even if the judge divides them up later. The Federal Rule of Civil Procedure permits the consolidation of related case for the purpose of coordination and planning.
Consolidation of related cases and pretrial proceedings is possible even when related cases are filed in different courts by having the related cases transferred to the consolidation court if personal jurisdiction and venue lie in the transferee forum. The Judicial Panel on Multidistrict Litigation may also consolidate the related cases under a single district court.
In cases of complex litigation, it is important to assess if there are clear and acceptable guidelines for compensation and reimbursement as well as whether the arrangements for coordination among participating counsel are fair, reasonable, and efficient.
THE BURDEN OF PROOF A series of United States Supreme Court decisions in diversity cases leaves no doubt of the relevance of Erie Railroad Co. v. Tompkins, 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188 (1938), to questions of burden of proof. These decisions are: Cities Service Oil Co. v. Dunlap, 308 U.S. 208, 60 S.Ct. 201, 84 L.Ed. 196 (1939), Palmer v. Hoffman, 318 U.S. 109, 63 S.Ct. 477, 87 L.Ed. 645 (1943), and d**k v. New York Life Ins. Co., 359 U.S. 437, 79 S.Ct. 921, 3 L.Ed.2d 935 (1959). (Involving burden of proof, respectively, as to status as bona fide purchasers, contributory
negligence, and non-accidental death (suicide) of an insured.) In each instance the state rule was held to be applicable. It does not follow, however, that all presumptions in diversity cases are governed by state law. In each case cited, the burden of proof question had to do with a substantive element of the claim or defense. Application of the state
law is called for only when the presumption operates upon such an element. Accordingly the rule does not apply state law when the presumption operates upon a lesser aspect of the case, i.e. tactical presumptions. The situations in which the state law is applied have been tagged for convenience in the preceding discussion as diversity cases. The designation is not a completely accurate one since Erie applies to any claim or issue having its source in state law, regardless of the basis of federal jurisdiction, and does not apply to a federal claim or issue, even though jurisdiction is based on diversity. Vestal, Erie R.R. v. Tompkins: A Projection, 48 Iowa L.Rev. 248, 257 (1963); Hart and Wechsler, The Federal Courts and the Federal System, 697 (1953); 1A Moore, Federal Practice 0.305 (2d ed. 1965); Wright, Federal Courts, 217218 (1963). Hence the rule employs, as appropriately descriptive, the phrase as to which state law supplies the rule of decision. See A.L.I. Study of the Division of Jurisdiction Between State and Federal Courts.
One critical aspect of litigation is the threshold one has to establish in order to prove a case, otherwise known as the burden of proof. There is a major distinction between criminal and civil burdens of proof. In criminal courts, the beyond a reasonable doubt burden of proof is a very high burden, which is often described as having to prove your case to a very high degree of moral certainty. If a member of the jury has any reasonable doubt, which essentially means doubt that
is formulated well enough that it can be expressed and supported by reason, that person should vote for acquittal of the defendant.
The burden of proof is much lower in a civil trial. The civil justice system uses the mere preponderance of the evidence burden, which is sometimes expressed as 51 percent level of proof. Civil jury instructions, which are given to jurors by the judge prior to their deliberations on a case, often describe this as the scales of justice tipping ever so slightly in the direction of one party versus another, meaning that the jury must find for the party who is supported by the weight of the evidence, even if this is only slightly so. This difference in burdens of proof can often result in a defendant being acquitted (found not guilty) of criminal charges, yet having a judgment rendered against him or her in a corresponding civil action. Here, Plaintiffs will show that there is not only a preponderance of evidence, but often evidence beyond a reasonable doubt as well. The criminal aspects will be handled by the other agencies such as the United States and District Attorneys; the civil and civil RICO ACT matter of showing the mere preponderance of the evidence burden shall be shown in this jurisdiction and court.
TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Now comes Richard Lewis, in propria persona and ex rel., Private Attorney General for the people of the United States of America and the Citizens of Tennessee under the Civil RICO Act 18 USC Ch. 96 1961-1968 et seq.; HOBBS Act 1951; Bribery, Graft, and
Conflicts of Interest 18 USC Chapter 11 201, 202-209; U.S.A. Patriot Act 2001 42 U.S.C 5195; Homeland Security Act of 2002 6 U.S.C. 101; The Federal Extortion and/or Blackmail Act, 18 U.S.C. 872, 875-877; Grand Larceny; Stalking 18 U.S.C. 2261A et seq.; Mail Fraud 18 U.S.C. 1341; Wire Fraud 18 U.S.C. 1343; Extortion 18 U.S.C. 875; Full Faith and Credit 1738-1739; Americans with Disabilities Act of 1990, 42 U.S.C. 12102; ABA Model Code of Judicial Conduct (CANONS); Racketeer Influenced and Corrupt Organizations Act of 1970; Tennessee Civil RICO
Act of 1968; Tennessee RICO act 1968; Tennessee GANG BILL; The Adam Walsh Child Protection and Safety Act of 2006; the Tennessee Terrorism Prevention Act, and common law of the United States (collectively, The ACTS) and Tennessee, California, and Florida statutes and common law.
This case properly falls under the jurisdiction of the Eastern District of Tennessee of the United States District Court and supported by the federal statutes, state statutes and common law. This Court shall have original jurisdiction to prevent and restrain violations of The ACTS by issuing appropriate orders, including, but not limited to: 1) Ordering any person to divest himself of any interest, direct or indirect, in any enterprise, 2) Imposing reasonable restrictions on the future activities or investments of any person, including, but not limited to, prohibiting any person from engaging in the same type of endeavor as the enterprise engaged in, the activities of which affect interstate or foreign commerce, and/or 3) Ordering dissolution or reorganization of any enterprise, making due provision for the rights of innocent persons.
CIVIL RICO (Racketeering and Organized Crime)
UNDER THE CIVIL RICO ACT, THE STATUTE OF LIMITATIONS IS EXTENDED TO 10 YEARS; LEWIS FULLY INTENDS TO INVESTIGATE GANG ACTIVITIES FOR THAT PERIOD OF TIME. THE STATUTES REQUIRE LEWIS TO ENGAGE IN AGGRESSIVE DISCOVERY AND REPORT TO VARIOUS AUTHORITIES ENDOWED WITH THE RESPONSIBILITY OF FILING CRIMINAL CHARGES WHERE JUSTIFIED. AT THE OUTSET, THE EVIDENCE AGAINST EVERY DEFENDANT, BEING SUBMITTED HEREIN, WARRANTS THAT EACH DEFENDANT COULD EASILY BE CHARGED WITH PERJURY AND/OR FRAUD THIS CASE IS A PERFECT EXAMPLE OF HOW ORIGINATED CRIME WORKS.The Private Attorney General is authorized under the Civil RICO Act to investigate under this section and report his findings to the proper authorities for any and all criminal actions they may take. Pending final determination thereof, the court may at any time enter such restraining orders or prohibitions, or take such other actions, including the acceptance of satisfactory performance bonds, as it shall deem proper.
Any person injured in his business or property by reason of a violation of section 1962 of this chapter may sue therefore in any appropriate United States district court or the State of Tennessee the State of Tennessee which has original jurisdiction thereofand shall recover threefold the damages he/she sustains and the cost of the suit, including a reasonable attorneys fee, except that no person may rely upon any conduct that would have been actionable as fraud in the purchase or sale of securities to establish a violation of section 1962. The exception contained in the preceding sentence does not apply to an action against any person that is criminally convicted in connection with the fraud, in
which case the statute of limitations shall start to run on the date on which the conviction becomes final. Tennessee RICO Statute 1989; Applied to TN Gangs Act Jan. 23, 2012; Ch. 3917, 1981; 18 U.S.C.1962 et seq.
A final judgment or decree rendered in favor of the United States and
the State of Tennessee in any criminal or civil proceeding brought by
the Private Attorney General shall estop the defendant from denying
the essential allegations of the criminal or civil offense in any
subsequent proceeding brought by the United States.
Civil RICO statutes are supplemented by 2 Human Rights Treatiesthe
Universal Declaration of Human Rights and the International Covenant on
Civil and Political Rightsboth of which are rendered supreme law by
virtue of the Supremacy Clause (just like the Bill of Rights).
The latter Covenants Reservations enacted by Congress expressly
reserve original jurisdiction to State and local governments, to the end
that their competent authorities may take appropriate measures for the
fulfillment of the Covenant.
Under 18 USC 1964(C), a Private Attorney General may appear in
court without the license to practice law that is required of all State
Civil RICO specifically has a further purpose of encouraging potential private plaintiffs to investigate diligently. Rotella v. Wood, 528 U.S. 549 (2000).
RICO, 18 U. S. C. 1961-1968 (1994 ed. and Supp. III), makes it
criminal to conduct an enterprises affairs through a pattern of racketeering activity,
18 U. S. C. 1962(c), defined as behavior that violates certain other
laws, either enumerated federal statutes or state laws addressing
specified topics and bearing specified penalties, 18 U. S. C. 1961(1)
(Supp. III). Pattern is also a defined term requiring at least two acts of racketeering activity . . . , the last of which occurred within ten years
after the commission of a prior act of racketeering activity. 18
U. S. C. 1961(5). Given Civil RICOs want of any express limitations
provision for civil enforcement actions, Clayton Act analogy, 4b, as
added, 69 Stat. 283, 15 U. S. C. 15b, See, e.g., Grimmett v. Brown , 75 F. 3d 506, 511 (CA9 1996); McCool v. Strata Oil Co. , 972 F. 2d 1452, 1464-1465 (CA7 1992); Rodriguez v. Banco Central Corp. , 917 F. 2d 664, 665-666 (CA1 1990); Bankers Trust Co. v. Rhoades , 859 F. 2d 1096, 1102 (CA2 1988); Pocahontas Supreme Coal Co. v. Bethlehem Steel Corp.
, 828 F. 2d 211, 220 (CA4 1987). The administrative director of the
courts is authorized to establish any policies and procedures that may
be necessary to assist courts with compliance with the Americans with
Disabilities Act, 42 U.S.C. 12131 et. seq. The Supreme Court shall
approve any such policies and procedures prior to implementation.
Participants in the judicial system shall comply with any policies and
procedures that may be implemented. This rule shall apply to all courts
in this state, including without limitation, municipal courts, general
sessions courts, juvenile courts, circuit courts, chancery courts,
criminal courts, and the respective appellate courts. 18 USC 195,
Interference with commerce by threats or violence. 18 U.S.C. Sec. 1951, a
provision commonly known as the Hobbs Act, and described in RICO
itself, Sec. 1961(1)(A).
FEDERAL EXTORTION AND OR BLACKMAIL 18 U.S.C. 871
Blacks Law Dictionary defines blackmail as follows: Unlawful
demand of money or property under threat to do bodily harm, to injure
property, to accuse of crime, or to expose disgraceful defects. This
crime is commonly included under extortion statutes. Blacks defines
extortion as follows: The obtaining of property from another induced
by wrongful use of actual or threatened force, violence, or fear, or
under color of official right. FEDERAL EXTORTION AND OR BLACKMAIL 18
U.S.C. 871 both fall under the Tennessee and Federal Civil RICO
ACT. Extortion by an officer or employee of
the United States includes: Threatening to inform (or not to inform) on
the violation of a federal law coupled with a demand for money or
anything of value (blackmail). Using the mails to extort money or
anything of value.is when the offender threatens to reveal information
about a victim or his family members that is potentially embarrassing,
socially damaging, or incriminating unless a demand for money, property,
or services is met. Even if the information is true or actually
incriminating, you can still be charged with blackmail if you threaten
to reveal it unless the victim meets your demand.
In this case, the Defendants demanded money, threatened, and revealed
personal information about the Plaintiff LEWIS, LEWIS III, LORRAINE the
MINORS and other family members.
The USA PATRIOT Act
Congress enacted the Patriot Act by overwhelming, bipartisan margins,
arming law enforcement with new tools to detect and prevent terrorism:
The USA Patriot Act was passed nearly unanimously by the Senate 98-1,
and 357-66 in the House, with the support of members from across the
The Act Improves Our Counter-Terrorism Efforts in Several Significant Ways:
The Patriot Act allows investigators to use the tools that were
already available to investigate organized crime and drug trafficking.Allows law enforcement to use surveillance against more crimes of
terror. Before the Patriot Act, courts could permit law enforcement to
conduct electronic surveillance to investigate many ordinary,
non-terrorism crimes, such as drug crimes, mail fraud, and passport
fraud. Agents also could obtain wiretaps to investigate some, but not
all, of the crimes that terrorists often commit. The Act enabled
investigators to gather information when looking into the full range of
terrorism-related crimes, including: chemical-weapons offenses, the use
of weapons of mass destruction, killing Americans abroad, and terrorism
financing.Allows federal agents to follow sophisticated terrorists trained to evade detection.Allows law enforcement to conduct investigations without tipping off
terrorists. Allows federal agents to ask a court for an order to obtain
business records in national security terrorism cases.Prosecutors and investigators used information shared pursuant to
section 218 in investigating the defendants in the so-called Virginia
The Patriot Act updated the law to reflect new technologies and new
threats. It allows law enforcement officials to obtain a search warrant
anywhere a terrorist-related activity occurred Allows victims of computer hacking to request law enforcement assistance in monitoring the trespassers on their computers.
This change made the law technology-neutral; it placed electronic
trespassers on the same footing as physical trespassers. Now, hacking
victims can seek law enforcement assistance to combat hackers, just as
burglary victims have been able to invite officers into their homes to
The Patriot Act increased the penalties for those who commit
terrorist crimes. Americans are threatened as much by the terrorist who
pays for a bomb as by the one who pushes the button. Thats why the
Patriot Act imposed tough new penalties on those who commit and support
terrorist operations, both at home and abroad.
The Civil RICO Act 18 U.S.C. 1961-1968 Racketeer Influenced and
Corrupt Organizations (RICO) Legislation (US Criminal Code, Chapter 96)
provides support for legal actions against individuals or organizations
involved in systematic illegal activities. The Office of Government
Ethics (OGE), a small agency within the executive branch, was
established by the Ethics in Government Act of 1978. Originally part of
the Office of Personnel Management, OGE became a separate agency on
October 1, 1989 as part of the Office of Government Ethics
Reauthorization Act of 1988. 18 U.S.C. 201 Bribery of Public Officials and Witnesses Bribery
Definition: The offering, giving, receiving, or soliciting of
something of value for the purpose of influencing the action of an
official in the discharge of his or her public or legal duties.
Bribery Modern Law Modern statutes, state and federal, have four
common characteristics. (1) They apply equally to receivers and givers.
(2) They are comprehensive, including as officials all employees of
government and those acting in a government capacity, such as jurors and
legislators. More recent statutes include party officials and even
party employees. (3) They treat bribery as a crime that can be committed
by the briber even though the bribee is not influenced. (4) They treat
bribery as a felony. Bribery is a criminal act, classified as white
collar crime. It refers to the improper acceptance, offering, giving,
receiving or solicitation of a gain or advantage for the Beneficiary,
with the intent of influencing the actions, views, opinions, or
decisions of a public official, juror, someone in a position of trust,
or someone bound by a duty to act impartially.
The gain or advantage may be a promise, money, property, goods,
services, information, commercial interests or anything else of value.
In most cases, both the person offering the bribe and the person
accepting the bribe can be charged with bribery. Bribery is usually
charged as a felony, punishable by a fine, imprisonment, or both. In
order to be considered bribery, there must be corrupt purpose, either
implied or proven. A gift is not a bribe unless it is given with the
intention of influencing the recipients behavior. There are
various types of bribery, which include: bribery by/of a public
official; bribery by/of a witness; bribery of a foreign official;
commercial bribery; bank bribery; and bribery in sporting contests.
Bribery is closely associated with extortion.
18 U.S.C. 201 proscribes bribery and the acceptance of certain gratuities. The U.S. Supreme Court in United States v. Sun-Diamond Growers of California, 526 U.S. 398, 404-405 (1999), describes the two crimes as follows:
The first crime, described in 201(b)(1) as to the giver, and
201(b)(2) as to the recipient, is bribery, which requires a showing
that something of value was corruptly given, offered, or promised to a
public official (as to the giver) or corruptly demanded, sought,
received, accepted, or agreed to be received or accepted by a public
official (as to the recipient) with intent, inter alia, to influence
any official act (giver) or in return for being influenced in the
performance of any official act (recipient). The second crime, defined
in 201(c)(1)(A) as to the giver, and 201(c)(1)(B) as to the recipient,
is illegal gratuity, which requires a showing that something of value
was given, offered, or promised to a public official (as to the giver),
or demanded, sought, received, accepted, or agreed to be received or
accepted by a public official (as to the recipient), for or because of
any official act performed or to be performed by such public official.
The distinguishing feature of each crime is its intent element.
Bribery requires intent to influence an official act or to be
influenced in an official act, while illegal gratuity requires only
that the gratuity be given or accepted for or because of an official
act. In other words, for bribery there must be a quid pro quo a
specific intent to give or receive something of value in exchange for an
official act. An illegal gratuity, on the other hand, may constitute
merely a reward for some future act that the public official will take
(and may already have determined to take), or for a past act that he has
Due to the pervasiveness of bribery
herein alleged during case nos. GC047909 and 11-cv-08810-GW, all
transcripts from those case numbers are herein incorporated in part or
full by reference.
The predicate acts, of which at least two are required, to establish a pattern of racketeering activity for RICO purposes, are:
violation of state statutes against gambling, murder, kidnapping,
arson, robbery, bribery, extortion, dealing in obscene matter, or
dealing in a controlled substance or listed chemical (as defined in the
Controlled Substances Act);
act of bribery, counterfeiting, theft, embezzlement, fraud, dealing in
obscene matter, obstruction of justice, slavery, racketeering, gambling,
money laundering, commission of murder-for-hire, and several other
offenses covered under the Federal criminal code *Title 18);
iii. Embezzlement of union funds;
iv. Bankruptcy or securities fraud;
v. Drug trafficking;
vi. Money laundering and related offenses;
vii. Bringing in, aiding or assisting
aliens in illegally entering the country (if the action was for
viii. Acts of terrorism.
PRIVATE ATTORNEY GENERAL
18 USC 1964(c), which was passed by Congress which enable any person
who has been injured by a Civil RICO Act violation to sue. That person
can request an order for damages and injunctions (such as a restraining
order). Under his authority as the Private Attorney General, Plaintiff LEWIS in propria persona and as ex rel is also requesting a restraining order against all defendants at this time, to prevent future violations. The ACTS provide that the plaintiff can recover treble damages, expenses, attorney fees, and costs.
Furthermore, The ACTS provide that the plaintiff must submit all
findings of fact and discovery to the appropriate legal authority(ies)
for prosecution. This case is a perfect example of how obstruction
of justice and other acts are perpetrated by and through organized crime
and protected by corruption within the judiciary. Appropriate
local and federal agencies are actively investigating certain
Defendants. The EXHIBITS include transcripts from a number of hearings
by PLUIM and federal Judge George Wu (Wu) in a similar, though
different, California case involving many of the plaintiffs and
All statements are being made under penalty of perjury according to my information and belief.
Richard Lewis, in propria persona and Private Attorney General, ex rel
Plaintiffs herein named and DOES 1-300 inclusive allege as follows:
1. LEWIS alleges: all the Defendants have impeded in an ongoing investigation as LEWIS is the PAG.
2. Plaintiff LEWIS is, and at all times mentioned herein, a resident of Union County, Tennessee.
3. Plaintiff TBCS is, and at all times mentioned
herein, a Nevada corporation with principle place of business in Los
Angeles County, California.
4. Plaintiffs, PAEGELS were, and at all times
mentioned herein, residents of Los Angeles County, California, and
incorporators of TBCS.
5. NELLE PAEGEL (NELLE) is a licensed
California attorney at law and was the attorney for herself, Thomas W.
Paegel, Thomas W.V. Paegel, The Body Company Sports, Inc., Lydia Cornell
and Brian Williams in California Los Angeles Superior Court Case No.
GC047909, known as case no. 11-cv-08810-GW, during the time of its
removal to federal jurisdiction. References to that/those case numbers
refers to that case, during the litigation of which, some of the herein
causes of action arose.
LORRAINE is, and at all times mentioned herein, a resident of Charlotte
County, Florida and visits with her family Union county Tennessee.
7. Plaintiff LEWIS III is, and at all times
mentioned herein, a resident of Charlotte County, Florida and visits
with her family Union county Tennessee.
8. Plaintiffs MINORS, and at all times mentioned
herein, reside in the United States, however their location is under
protection due to the invasion of their privacy and child endangerment
they have suffered. Contact can be made with them through LEWIS.
9. The true names and capacities, whether
individual, corporate, associate, representative or otherwise, of the
Plaintiffs identified herein as DOES 1-300, inclusive, are unknown to
Plaintiffs, who therefore represents these Plaintiffs by said fictitious
names. LEWIS will amend this complaint to allege the true names and
capacities of Defendant DOES 1-300 who will have same or similar
10. LEWIS is informed and believes, and thereon
allege, that at all times mentioned herein Defendant VARONOS is a
principle of VIEWPARTNER CORP., TSOFTNET, STAROPOLY, TODHD, and
eSTARHD.TV, all of which do business over the internet and or in
multiple states of the U.S.
11. LEWIS is informed and believes, and thereon
allege, that at all times mentioned herein Defendants TORO and JUNCO
portended to own and operate GREEN.
12. LEWIS is informed and believe, and thereon
allege, that at all times mentioned herein Defendant CORNELL is and at
all times mentioned herein individual living at 300 S. Crescent St.
Beverly Hills California 90212.
13. CORNELL/GODSHOTS misrepresents on her Facebook
site that GODSHOTS is a charity with a trademarked name and an L.L.C.
The site solicits donations under false pretenses.
14. CORNELL has endangered the MINORS and conspired
and colluded with MILLER, KEHOE, HADDOCK, COX, WALSH, FORD, and WILEMAN
to create a false persona of LEWIS in order to discourage him from his
15. CORNELL gave false statements on the record in
court, to the FBI to the Beverly Hills police, and the La. County
Sheriffs about LEWIS. She personally created a defamatory police
profile including a false mug shot and description of LEWIS and
presented same to the court as if it were true, to others and placed
such material on the internet.
16. CORNELL filed a false petition for a
restraining order against LEWIS containing the above self-created
17. CORNELL has harassed, threatened and stalked
LEWIS and continues to do so, and has impeded an ongoing investigation
to where LEWIS had to get a restraining oarder against CORNELL in
Tennessee state court, Maynardville.
18. CORNELL originally filed complaint GC047909 as
one of the seven plaintiffs in order to obtain information about that
case as an informant for those defendants. She regularly
reported information obtained in the case to the rest of the GANG.
LEWIS joined case no. GC047909 in March, 2012.
19. HAYELAND is CORNELLS former husband and
business partner. He is also a member of the GANG; they both have a
close connections and ties to FLEMING and SIMMONS. As such, he
regularly commits fraud on the internet via the fraudulent businesses
known as GSAXE and SPORTS ICON ENTERTAINMENT.
20. HAYELAND and CORNELL are known to receive and fence stolen property such as jewelry and paintings.
21. SIMMONS has/is allowing his likeness and image to be used by a fraudulent business entity to commit fraud.
22. FINANCIAL INSTITUTIONS (EXP, FARGO, MERITUS)
(FIN. INST.) failed to self-report that they were named in Case No.
GC047909, as required by regulators.
23. FIN INST., including MC intentionally and/or
negligently allowed the GANG to launder money by and through their
respective banking institutions.
24. FIN. INST. failed to adequately research the use the GANG was making of their bank services.
25. BEATTY knowingly enabled the GANG to misuse FIN. INST. services.
26. KEHOE is/has impeded in an ongoing
investigation; she has stalked, harassed, and invaded the privacy of
some of the Plaintiffs; hacked into Plaintiffs computers in order to
commit fraud and endanger MINORS; she has violated LEWISS restraining
order; and hacked into one or more Plaintiffs e-mail(s).
27. FORD stalked, harassed, threatened, and
interfered with an on-going investigation by PAG LEWIS, and used the
telephone to threaten LEWIS.
28. WALSH is a licensed attorney in Colorado who
interfered with and impeded an on-going case in California, GC047909.
29. WALSH practiced law in the state of California
without a license by giving legal advice to CORNELL in California,
30. WALSH made bodily injury threats to LEWIS.
31. WALSH defamed LEWIS via the internet on his and LEWISS Facebook pages.
32. ROBERTS is a licensed California attorney at
law who falsely told the court in GC047909 that VARONOS was not served
with process. In fact, VARONOS was served several times including in
33. HADDOCK has impeded an ongoing investigation;
colluded and conspired to endanger the health and welfare and life of
the MINORS; to defamed LORRAINE and MINORS by giving personal and
private information about them to other Defendants, namely CORNELL,
KEHOE, MILLER and COX who placed said information on the internet.
34. HADDOCK has threatened of bodily injury against LORRAINE, LEWIS, LEWIS III, and the MINORS.
35. MILLER, KING, CORNELL, KEHOE, COX, KEITH,
SIMMONS, HAYELAND, AXE, ISE have/are committing income tax evasion, both
state and federal, by engaging in fraudulent businesses.
36. NIVEN has impeded in an ongoing investigation
and is a partner of MILLER and KING. She has defrauded Plaintiffs
PAEGELS of $10,000.00 and 21 videotapes belonging to the PAEGELS and
37. LEWIS is informed and believes MILLER poses as a
public relations firm characterized as HITMAN/HITMANPR, which is a
false depiction as a public relations business; its true purpose is
to defraud businesses of money and property with false claims and
promises of success and use of threats.
38. MILLER has impeded in an ongoing investigation.
39. LEWIS is informed and believes, and thereon
alleges, that at all times mentioned herein Defendant MILLER was/is and
at all times mentioned herein, a resident in Los Angeles County,