New Court Filing

    Last time I filed an action (my petition for writ of habeas), I was arrested the next day and incarcerated for six weeks while the powers-that-be tried to retun me to prison. That may well happen again, but I am being left with little choice - in order to try to get past the obstructions by the local court, obstructions that have barred me proceeding in a simple suit to recover my property, I am being forced to take steps to further that claim - and in this instance, the only thing left for me to do is to try to move the claims, pursuant to RICO, to federal court.
        I expect that I will simply be arrested again, but I need to take these steps to try to preserve my civil rights... Anyone reading this, wish me luck...
        Attached is the action as I am filing it tomorrow. Hopefully I will be able to get it served before I am once again arrested...

----

Ron Glick
24 1st Avenue West #106B
Kalispell, MT 59901.
ron_glick@yahoo.com

IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF MONTANA
MISSOULA DIVISION
_______

Ron Glick,    ) Cause No.
     )
    Plaintiff,    ) Complaint
     )
v.     )
     )
Eleventh Judicial District Court of )
Montana, Peg Allison, Stuart )
Stadler, Katherine Curtis, Ted )
Lympus, [*], aka [*], Tim Harris, Ray Evert, )
Estate of Earl Evert, aka Earl Evert, )
Wayne Evert, Gregory Paskell, )
Montana Supreme Court, Montana )
Office of Disciplinary Counsel, )
Dave Edwards, Heidi Ulbricht, and )
Does One through Twenty, )
     )
    Defendants.    )
_____________________________ )


STATEMENT

        Since in or around 2003, Plaintiff has been repeatedly deprived of substantial civil liberties through the coordinated efforts of Defendants who, acting as a racketeering enterprise and under color of State law, have sought to oppress and persecute Plaintiff in retaliation for pursuing a civil liberties complaint against local authorities. Plaintiff has been subjected to everything from vexatious litigation to deprivation of due process and constitutional protections to outright theft of his personal and business assets as a means by which to penalize him for protesting his mistreatment and deprive him of financial capacity to challenge said deprivations. Though some Defendants have acted under duress and coercion, and others have acted solely to preserve the status quo of corrupt authorities, the end result of a coordinated effort as part of a racketeering enterprise designed to deprive Plaintiff of his civil liberties and property remains the same, and Plaintiff is entitled to redress.
JURISDICTION

    This action is brought pursuant to 42 USCS Sections 1983 and 1443, in that this Court has authority over deprivation of civil liberties under color of State law, 28 USCS Sections 1343 and 1443, in that this Court has authority to assume jurisdiction over State causes wherein a defendant is deprived, under color of State law, of any right secured by the United States Constitution, 18 USCS Section 1961, et seq., in that this Court has authority to prevent and restrain the misconduct of individuals and agencies who act as a criminal racketeering enterprise, and the First, Fourth and Fourteenth Amendments to the United States Constitution. Jurisdiction is founded under 28 USCS Sections 1331 and 1343(3) and (4) and the aforesaid Constitutional provisions.
BACKGROUND
    Plaintiff has had officers of Defendant Eleventh District Court, in and for Flathead County, State of Montana, obstruct his legal actions and, in coordination with and under the protection of other Defendants and other City of Kalispell officials, deprive Plaintiff of his civil liberties since in or around July, 2003. Such actions have been part of an ongoing vendetta against Plaintiff for pursuing civil liberty violation claims against City of Kalispell and County of Flathead officials, in direct violation of Plaintiff's First Amendment right to seek redress against government without reprisal nor molestation. Over the course of this longstanding crusade against Plaintiff, other non-official parties have been coerced and manipulated into supporting the actions of said officials, as well.
     Plaintiff established a nonprofit youth recreations program in or around October, 1996, originally named The Flipside CCG, though later changed to The Outpost CCG. Through years of solicited donations, Plaintiff acquired an inventory that well exceeded one million dollars. In or around April, 2002, Plaintiff and Defendant [*], then [*], who was also then Plaintiff's girlfriend, established a for-profit business, Arcadia, and parent corporation, Multiverse Enterprises, Incorporated, to work in partnership with the youth program. Though Plaintiff and Defendant [*] shared equal ownership of the for-profit business, Ms. [*] had no ownership claim over any of the youth program assets.
     Plaintiff's initial conflict with local authorities occurred on or about July 9, 2003, when a false allegation of sexual assault was made against him and an officer of the Kalispell Police Department, Myron Wilson, tampered with witnesses in order to secure a false report against Plaintiff. Plaintiff initiated a claim against said officer, only to be subsequently beset upon by officials of Kalispell and Flathead government agencies. Though the initial complaint against Plaintiff was dismissed and the original complainant recanted her allegation following closer of official investigations, harassments from said agencies continued and Plaintiff initiated legal action against City of Kalispell officials on or about October 30, 2003, and advanced his cause to full complaint against such parties on or about November 18, 2003 (Cause No. DV 03-572, Glick v. City of Kalispell, et al., Eleventh District Court of Montana). In response, Plaintiff's step-daughters were abducted on or about November 20, 2003, and held by the Flathead County Office of Child Protective Services, detained without contact with friends or family for weeks until the eldest step-daughter could be coerced to reassert her allegation against Plaintiff, said reassertment occurring on or about December 8, 2003.
     Following the abduction of his step-daughters, Plaintiff continued to pursue his complaint against City of Kalispell officials and, in absence of any appearance in the cause by the defendants, filed for default judgment on or about December 23, 2003, which Defendant Peg Allison blocked, alleging service had not properly been performed. Upon inquiry, said Defendant first insisted that no proof of service had been filed, but when challenged upon this point, said Defendant changed her reason for denying default judgment to be that allegedly no summons had ever been issued, even though Plaintiff had personally retrieved issued summons on the cause. When Plaintiff offered the testimony of Defendant [*], then [*], to attest to service of the summons, Defendant Allison insisted on speaking to her personally, and thereafter made direct threat against Defendant [*] that if she attested to service of summons, she would be prosecuted for perjury since Defendant [*] allegedly could not lawfully attest to service of lawfully issued summons, which Defendant Allison insisted had not been issued. In response to this intimidation, Defendant [*] called Plaintiff, literally terrified and in tears, refusing to file subpoena attesting to her service of the summons.
     Notably, Plaintiff has made numerous requests to Defendants Eleventh District Court and Allison for production of the court docket for Cause No. DV 03-572 to confirm or deny whether the summons had been removed from the court file, but said Defendants have refused to comply or even respond to such requests.
    Upon conclusion that Defendant Allison had tampered with a witness and was unconstitutionally barring Plaintiff's right of access to the courts and due process, and that Plaintiff could not possibly proceed within such jurisdiction, Plaintiff sent directly to Defendant Allison a notice of intent to remove the cause then filed to this Court's jurisdiction within thirty (30) days on or about January 28, 2004.
    Prior to the expiration of said deadline on or about February 27, 2004, Plaintiff was charged and arrested for the alleged sexual assault and witness tampering on or about February 20, 2004, and was thereafter continuously detained and deprived all access to court to pursue his complaint until after he was transferred into prison population in or around June, 2006. Since Plaintiff had only three years to have his legal service acknowledged, his suit was dismissed within Defendant Eleventh District Court.
    Upon arrest, Plaintiff sought support from Defendant [*], who possessed exculpatory evidence for Plaintiff's defense as well as fiscal support through their mutual business, and she was subsequently charged and arrested for alleged witness tampering on or about February 27, 2004, though was released upon her own recognizance after only a few days upon the stipulation that she would have no contact with and provide no support to Plaintiff, said directive issued by Defendant Ted Lympus. The charge of witness tampering was maintained against both Plaintiff and Defendant [*] until on or about July 7, 2005, dismissed without prejudice only four days prior to Plaintiff's trial, so that the charge could not be mentioned at trial (or so Plaintiff's trial counsel Eduardo Gurtierez Falla insisted), though it was clear that the charge could be brought again should Defendant [*] not conform to her prior restrictions of support of and contact with Plaintiff. Plaintiff thereafter was convicted and sentenced to twenty (20) years with fifteen (15) suspended through a mockery of trial, said conviction still being challenged within the State court system (Cause No. DC 04-066, State v Glick, Eleventh District Court of Montana).
     It should be noted that Defendant sought intervention against misconduct from Defendants Eleventh District Court and Katherine Curtis from Defendant Montana Supreme Court through application for writ of supervisory control in or around April, 2005 (Glick v. Curtis, Cause No. 05-261), but said Defendant refused to grant relief in spite of over forty independent reported violations, many of which involved blatant deprivation of due process by Defendant Curtis.
    This Court has previously ruled, after Plaintiff was finally able to file for relief in this Court in or around July, 2006, that Plaintiff is unable to challenge the specific issues of official misconduct heretofore cites since a civil action cannot be used to undermine a criminal conviction, and the initial suit had become intimately entwined into the criminal conviction as cause for vexatious prosecution (Glick v. [*], et al., Cause No. CV 06-112-M-DWM). Though Plaintiff does not seek of this Court a specific rescindment of that order, he does however believe that the specific circumstances of the civil suit that preceded the criminal cause, as well as circumstances that occurred during the course thereof, are relevant to this cause for establishment of a pattern of racketeering activity that extends well beyond the scope of the criminal cause. As such, Plaintiff references it herein as part of this cause. Additionally, since part of the relief sought in this cause is removal of said criminal cause to this Court's jurisdiction, it is appropriate to summarize said proceeding herein.
    In or around October, 2004, Plaintiff was contacted by Defendant Tim Harris, a patron of Plaintiff's and Defendant [*]'s business, who informed Plaintiff that Defendant [*] had closed said business and had left a sizable percentage of the youth program assets with him in trust until such time as Plaintiff could retrieve the property himself, though reportedly the contents of such deposit consisted of little of the for-profit business assets and only part of the youth program assets. Defendant [*] had at no time consulted with Plaintiff over this action and this action had allegedly been done because said Defendant was not permitted to have contact with Plaintiff pursuant to Defendant Lympus' order.
    Plaintiff has since learned that Defendant [*] maintained a storage unit wherein she stored the physical assets which she had retained, with the declared intent to reopen a new business, though said Defendant had also been selling off portions of said property piecemeal for personal gain. Additionally, it has been discovered by Plaintiff that said Defendant has retained numerous boxes of assets which belonged solely to Plaintiff's youth program of which said Defendant has been using to sell off for personal gain, as well.
     Defendant Harris later proved duplicitous and the majority of the property he held was left, without notice or agreement, with a nonprofit organization, Special Friends Advocacy Program, who notified Plaintiff that he had a limited time to have the property retrieved or forfeit claim thereof. Defendant Harris, by self-admission, retained some of the assets for himself and destroyed parts of the property out of spite rather than relinquish it.
    Plaintiff thereafter contracted with Defendant Ray Evert to have the property stored by his father, Defendant Earl Evert, in exchange for legal and clerical work Plaintiff performed for Defendant Ray Evert. Ultimately, Defendants Ray and Earl Evert also proved untrustworthy, as Defendant Ray Evert expended efforts to seize the property for himself and Defendant Earl Evert would not respond to efforts to bypass Defendant Ray Evert's duplicity.
    Prompted by the successive abuses of his property and entitlements, Plaintiff filed suit against Defendants [*], Harris, Ray Evert and Earl Evert in or around November, 2007, in Dawson County where he was at the time detained. Plaintiff thereafter had Defendants Ray and Earl Evert served on or about December 22 and 26, 2007, respectively. When neither Defendant filed response to the complaint, Plaintiff sought default judgment against them on or about January 28, 2008. Though Defendant Earl Evert managed to avoid default through an eleventh-hour filing by his son, Defendant Wayne Evert, Defendant Ray Evert has never to date filed a response of any kind, and default judgment should properly have been entered against him, though to date never has.
     Defendant Earl Evert's eleventh hour pleading was actually filed by Defendant Wayne Evert, who had assumed power of attorney over Defendant Earl Evert to defend his father's cause. However, in addition to such filing, Defendant Wayne Evert also attempted to extort money from Plaintiff for the safety of his property and made threats to dispose of the property should the extortion not be paid. Further, Plaintiff has learned independently that, when Plaintiff refused to comply with said extortion, that said Defendant attempted to sell the property by piecemeal, of which Plaintiff has no way to at this time affirm as to what degree said Defendant may have been successful or not. Reportedly, at least part of Plaintiff's property still remains with said Defendant, though.
    On or about March 28, 2008, the Dawson County District Court, on motion of Defendant Earl Evert's later appointed counsel, Defendant Gregory Paskell, ordered venue transferred to Flathead County and the jurisdiction of Defendant Eleventh District Court without acting upon the motion for default judgment against Defendant Ray Evert and other outstanding issues. Plaintiff had objected to this transfer, citing hid federal claim against City of Kalispell and Flathead County officials, including many of the Defendants in this cause of action, stating specifically that Plaintiff “cannot receive a fair nor impartial hearing in Flathead County due to the bias and prejudice of officials therein” (Plaintiff's Response to Defendant Earl Evert's Motion For Change of Venue, et seq., Cause No. 07-128, Glick v. [*], et al. (Seventh District Court of Montana, transferred to Defendant Eleventh District Court as Cause No. DV 08-391)). This objection was clearly disregarded and Plaintiff's forewarning has come to pass.
    Prior to transfer, Plaintiff had filed to remove Defendant Paskell for conflict of interest, since he had previously represented Defendant [*] and had once before withdrawn for such conflict in the divorce proceedings between Ms. [*] and [*] for this exact reason and, by necessity, Defendant Paskell would need to work against the interests of Ms. [*] in pursuit of the rights of his current clients, Defendants Ray, Earl and Wayne Evert, such split of loyalty being impermissible. Defendant Stuart Stadler issued an order on or about April 15, 2008, denying said motion. This motion was noticeably filed well after the motion for default judgment against Defendant Ray Evert, but to date, no ruling has been issued pursuant to this preexisting motion.
    Since transfer to Defendant Eleventh District Court, Plaintiff has additionally sought issuance of new summonses for Defendants [*] and Harris, who remain unserved, but Defendant Allison has refused to issue such. Additionally, Plaintiff has filed numerous motions that have largely been obstructed and denied in absence of law and precedent, including acts of conspiracy between Defendants Eleventh District Court, Allison, Stadler and Paskell to conceal the death of Defendant Earl Evert, and Defendants Allison and Stadler to tamper with official records.
    Defendant Earl Evert died on or about May 31, 2008. Defendant Paskell had a duty to report such death to Plaintiff, but failed to do so, though did notify Defendant Eleventh District Court and, presumably Defendants Allison and Stadler. After Plaintiff learned of Defendant Earl Evert's death through an independent source in or around November, 2008, Plaintiff sought record of whether an official estate had been filed through both Defendants Allison and Paskell, yet both ignored his request for information. Plaintiff believes and thereon alleges that Defendant Earl Evert's death was kept from Plaintiff to aid in Defendant Wayne Evert's efforts to conceal his father's property, which Plaintiff has learned had been transferred to said Defendant's name immediately prior to Defendant Earl Evert's death, before a claim against Defendant Estate of Earl Evert could be lawfully made by Plaintiff.
    The delays caused by said Defendants effectively barred Plaintiff from making a claim pursuant to Montana estate law so that separate suit is necessitated to claim said assets. Additionally, Plaintiff has been informed by Defendant Paskell that no official estate was filed because Defendant Earl Evert died “penniless”, which is in direct opposition to the official records concerning property transferred from Defendant Earl Evert's name by Defendant Wayne Evert, which further implicates all of said Defendants in criminal fraud.
     Still further, as part of the machination to deprive Plaintiff of claim against Defendant Estate of Earl Evert, Defendant Allison, in collaboration with Defendant Stadler, tampered with official court records to assist in concealing said death, effectively depriving Plaintiff of any pretense of due process as consequence. On or about May 15, 2008, approximately two weeks prior to Defendant Earl Evert's death, Plaintiff filed two motions with Defendant Eleventh District Court: a motion for judgment on the pleadings against Defendant Earl Evert, upon the grounds that said Defendant's response admitted to all the necessary material elements necessary for judgment against him, ie, that he had taken possession of Plaintiff's property and continued to hold such pursuant to agreement, and a motion to amend the complaint to name Doe One in said complaint as Defendant Wayne Evert. No response was ever filed to either motion, and Plaintiff subsequently filed for default rulings in his favor on or about June 9, 2008. All motions were held in limbo until on or about August 1, 2008, when Defendant Stadler subsequently denied the motion for judgment on the pleadings, modified the motion to amend to require Plaintiff to refile his complaint, and denied the motion for default judgment upon the pretense that the issue was rendered moot by the rulings to the prior motions.
     A subsequent acquisition of the court docket and records established that Defendant Allison, in collaberation with Defendant Stadler, had actually tampered with records and manipulated the proceedings to assure Plaintiff would not prevail and to conceal the fact of Defendant Earl Evert's death. Said court docket, supported by a separate letter from Defendant Allison, prove that Defendant Allison removed the motions for judgment on the pleadings and to amend from their date of receipt on or about May 19, 2008, until on or about July 29, 2008, and presumably reported to Defendant Paskell that he had no need to file responses since said motions would not be docketed. Defendant Allison acknowledged in a separate letter that she had kept the summons sent for issuance that had accompanied said motions on her desk, and presumably kept the motions there as well.
    Additionally, said letter also affirmed that the motion for default rulings had arrived while said Defendant was out of town, and as such said motion was entered on the docket without Defendant Allison's knowledge. This motion was only docketed and scheduled for hearing because Defendant Allison was not present to remove it from the court file, as well. The records demonstrate thereafter that the motion to dismiss was reviewed by Defendant Stadler on or about July 3, 2008, but was returned to Defendant Allison without being ruled upon. Clearly, it was returned to Defendant Allison with instructions to handle it in the same manner as the prior two motions, but said Defendant was unable to delete an entry made into the computerized docket records.
    Since entry onto the docket was not deletable, Defendant Allison and Stadler conspired to assure that the two motions referenced in the motion to dismiss would be re-entered in the docket on or about July 29, 2008, so that Defendant Stadler could summarily deny them on or about August 1, 2009.
     However, Defendant Stadler's order defied all pretense of jurisprudence. He altered the motion to amend to be a motion to file an amended complaint, an act needless to simply amend the identity of a defendant, and which would have effectively removed Plaintiff's default judgment claim against Defendant Ray Evert and any potential claim against Defendant Earl Evert, since said Defendant had since died (of which Plaintiff had willfully been kept ignorant) and Plaintiff could not serve a deceased party. Further, Defendant Stadler denied the motion for judgment on the pleadings by omitting critical language in Defendant Earl Evert's response. Still further, Defendant Stadler denied the motion for default rulings upon the pretense that the motions in question had now been ruled upon, ignoring that the motion for default rulings had been filed well in advance of such rulings and that Plaintiff was entitled to relief automatically in any claim that was undisputed by defense. Essentially, Defendant Stadler, who was supposed to act as impartial magistrate, acted as co-counsel to the defendants in the cause by asserting legal defense and manipulating due process to assure that Plaintiff's relief would not be granted, to further keep Plaintiff ignorant of the status of Defendant Earl Evert and to further obstruct the cause of action from speedy resolution.
     To implicate Defendants further, said ruling by Defendant Stadler was actually kept out of the docket as well, and was only returned to the docket on or about August 15, 2008, upon receipt by Defendant Eleventh District Court of an application for writ of supervisory control filed with Defendant Montana Supreme Court, to which a copy of said ruling was attached.
     The records clearly establish a timeline in this instance. Plaintiff's motions were received by Defendant Eleventh District Court on or about May 19, 2008, and were subsequently removed from the docket. Defendant Allison acknowledged keeping documents properly contained in the court's docket on her desk during this time. Said docket further establishes that Plaintiff's motion for default rulings was received by Defendant Eleventh District Court on June 12, 2008, and was docketed and scheduled for hearing on or about June 17, 2008. Court records further establish that said motion was forwarded to Defendant Stadler on or about July 3, 2008, and that the motion was returned to the court clerk's office without being ruled upon. The court docket thereafter demonstrates that the motions previously removed were returned to the court docket on or about July 29, 2008, in time to be ruled upon by Defendant Stadler on or about August 1, 2008. Further, the complete and total absence of any response being filed by Defendant Paskell clearly indicates a preexisting knowledge that the motions had not been docketed, since otherwise he would dutifully have filed responses in defense of his clients.
     Plaintiff filed two separate applications for writ of supervisory control with Defendant Montana Supreme Court over these issues, but in each instance said Defendant acted in defense of the other Defendants in this cause. In spite of blatant violations of standards of conduct and criminal misconduct by said Defendants, Defendant Montana Supreme Court acted in conspiracy to shelter said Defendants from the consequences of their criminal misconduct. Collectively, Plaintiff has filed three separate applications for writ of supervisory control over Defendants, and in each instance, Defendant Montana Supreme Court has acted to defend and shelter the misconduct of Defendant Eleventh District Court officials.
     Further, Plaintiff filed a complaint against Defendant Paskell with Defendant Office of Discliplinary Counsel, to which Defendant Paskell blatantly perjured himself by attesting to multiple issues that were readily impeachable by official records, yet Defendant Office of Disciplinary Counsel defended the misconduct of Defendant Paskell. Plaintiff had previously filed numerous complaints against other attorneys involved in his criminal prosecution, and had innumerable issues of misconduct also dismissed by Defendant Office of Disciplinary Counsel. Collectively, Plaintiff has filed five separate complaints of misconduct against attorneys acting in conspiracy with Defendant Eleventh District Court officials, and in each instance, Defendant Office of Disciplinary Counsel has acted to defend and shelter the misconduct of said attorneys, just as they have in the case of Defendant Paskell.
     Upon release from prison, Plaintiff was remanded to the custody of the Montana Department of Adult Probation and Parole for a fifteen (15) year probation sentence, that was not specifically imposed by his sentencing court, and placed under the authority of Defendant Dave Edwards. From the time of Plaintiff's release, said Defendant acted to provoke and harass Plaintiff, attempting to obstruct his rights to pursue his legal claims and his capacity to support himself, as well as manipulating circumstances of that said Defendant could violate Plaintiff's release and return him to prison.
    Upon learning of Plaintiff's suit against Defendant [*], Defendant Edwards contacted her and provoked in her an irrational fear of Plaintiff, convincing Defendant [*] that Plaintiff was seeking her out to harm her. Defendant Edwards later claimed that Defendant [*] had contacted him because she had learned of Plaintiff's efforts to contact her and ordered Plaintiff to cease all attempts to contact her. When Plaintiff filed a complaint against Defendant Edwards for exceeding his authority, said Defendant instructed Defendant [*] to file a restraining order to further obstruct Plaintiff from pursuing or settling his claim against Defendant [*], which was served upon Plaintiff on or about April 15, 2009 ([*] v. Glick, Cause No. CV 2009-19-OP, Kalispell Municipal Court).
     Defendant [*]'s application for order of protection included numerous perjured statements, and Plaintiff filed a response to Defendant [*]'s petition on or about April 20, 2009, as well as having subpoenas issued against Defendant Edwards and others.
     Following these blatant obstructions and clear intent to attempt to violate him, Plaintiff filed a petition for writ of habeas corpus on or about April 22, 2009, challenging the legality of his commitment to probation amongst other issues. Learning of this petition, Defendant Edwards filed to revoke Plaintiff's probation and had a warrant issued for his arrest on or about April 23, 2009, upon the pretense that Plaintiff had not successfully obtained employment in two months after release, ignoring Plaintiff's ninety (90) day application period for Supplemental Security Income (SSI) that was still pending, his application for assistance through Vocational Rehabilitation for retraining and a recessed economy where people in the region had been out of work six months to a year, and had not enrolled in allegedly court appointed treatment, despite absence of the court ordered prerequisite of a counselor's recommendation. Subsequently, Defendant Edwards called Social Security instructing them to cancel his application because he had been arrested and contacted Vocational Rehabilitation claiming that I was no longer eligible for services because Plaintiff had been denied SSI.
    Incidentally, Defendant Edward's contact with Social Security did not cancel Plaintiff's claim and he was accepted for SSI benefits on or about May 15, 2009, though his efforts to attempt to sabotage such application cannot be overlooked. As a direct result of this approval, the efforts to revoke Plaintiff were undermined and he was released from custody after approximately six weeks of detention on or about June 2, 2009, with the condition that Plaintiff was now required to enroll in and pay for sex offender treatment.
     During the course of Plaintiff's incarceration, he was permitted only a video conference appearance at the hearing on Defendant [*]'s order of protection, which occurred over two hearing dates. Defendant Edwards defied his subpoena and did not appear at either, and Defendant Heidi Ulbricht, who oversaw the proceedings, would not enforce his appearance. Further, Defendant Ulbricht acted completely contrary to law by having ex parte communications with Defendant [*] prior to the commencement of the second hearing in which she offered assurances to Defendant [*] that her restraining order would be granted, as witnessed by one of Plaintiff's witnesses present in the courtroom. Still further, Defendant Ulbricht quashed two other subpoenas, one for production of records and another for the appearance of Melvin Williams, both of which, coupled with the subpoena for Defendant Edwards, would have impeached the testimony of Defendant [*] at the hearing.
    It was made abundantly clear during the course of the proceedings that Defendant [*] was acting under direction from someone else, yet would not reveal the identity of such when asked, and Defendant Ulbricht would not compel the identity, and that her only real reason is seeking the order of protection was to obstruct the lawsuit Plaintiff had pending against her. Further, not only did Defendant Ulbricht bar introduction of evidence that would impeach Defendant [*], Defendant Ulbricht also suppressed any evidence or cross-examination that would demonstrate that Defendant [*]'s fears had been engendered by others, not by Plaintiff.
    It was effectively clear that Defendant Ulbricht had a prejudicial predisposition to decide in favor of Defendant [*]. This was made even more abundantly clear when Defendant Ulbricht, in issuing her ruling, could not summarize any actual reason for granting the order of protection, and even stumbled upon reading the law when required to state that there was a reasonable apprehension of harm. In spite of this, Defendant Ulbricht granted the order of protection, though could not compel Plaintiff to not continue his lawsuit. This cause is presently being appealed before Defendant Curtis ([*] v. Glick, Cause No. DR-09-396B, Eleventh District Court).
    As it presently stands, Defendant is unable to pursue even the simplest of civil actions. Defendant Eleventh District Court officials are actively obstructing service of unserved defendants by refusing to issue summons, and otherwise obstructing the cause of action from proceeding. Said Defendants have demonstrated that they have no intention of providing Plaintiff with even a modicum of fair hearing, and remain actively in pursuit of finding cause to return Plaintiff to prison in order to further obstruct his legal access and civil liberties. Further, said Defendants have demonstrated a capacity for manipulating others into furthering their objectives, through both coercion and duplicity. Still further, considering that Defendants have retaliated to previous legal filings by having Plaintiff arrested, he anticipates that he will yet again be deprived of his liberty as consequence for filing this action, which will likely impede his constitutional right of access to the courts.
     Plaintiff has exhausted every reasonable measure to reach settlement on his property suit, but he has met with further obstructions from other Defendants in this, as well. Defendant Paskell has repeatedly caused delays in reaching settlement by many bad faith gestures of settlement, while his client, Defendant Wayne Evert, has met with Defendants Harris and [*] to provoke them into refusing to settle. In the instance of Defendant Harris, this occurred after a settlement had been reached and Plaintiff had simply been waiting for Defendant Harris to sign the settlement agreement. All of this collectively contributes to the long-standing effort to assure that Plaintiff will remain financially bereft, a state that has been the objective of Defendant Eleventh District Court officials and other local authorities for nearly six years now.
     Individually, each of the Defendants' actions as cited herein have been contrary to law. Collectively, they demonstrate a pattern of abuse that seeks one universal purpose: the oppression and harm of Plaintiff. Though not all Defendants have acted in full knowledge of the actions nor motivations of others, this is not necessary in a conspiracy, only that conspirators' conduct is in pursuit of a common cause. That this conduct was part of a larger criminal enterprise through a pattern of racketeering activity, including but not limited to witness tampering, coercion, obstruction of due process, and other crimes, that have caused injury to Plaintiff and his property is equally indisputable. Further, the actions of Defendants have grossly undermined the integrity of this country's judicial and legal system, and such infringements upon liberty entitle Plaintiff to redress.
PARTIES

    1. Plaintiff Ron Glick is and was at all times relevant a citizen of the United States and resident of the State of Montana.
    2. Defendant Eleventh Judicial District Court (hereafter “DC”) is a duly sanctioned court formed and operated under the laws of the State of Montana and is sued in its official capacity.
    3. Defendant Peg Allison (hereafter “Allison”), at all times referred to herein, is Court Clerk for Defendant DC and is sued in her individual and official capacities.
    4. Defendant Stuart Stadler (hereafter “Stadler”), at all times referred to herein, is and was a lawfully elected district court judge of Defendant DC, and is sued in his individual and official capacities.
    5.Defendant Katherine Curtis (hereafter “Curtis”), at all times referred to herein, is and was a lawfully elected district court judge of Defendant DC, and is sued in her individual and official capacities.
    6. Defendant Ted Lympus (hereafter “Lympus”), at all times referred to herein, is and was a lawfully elected district court judge of Defendant DC, and is sued in his individual and official capacities.
    7. Defendant [*], aka [*] (hereafter “[*]”), at all times referred to herein, is and was a resident of Flathead County, State of Montana.
    8. Defendant Tim Harris (hereafter “Harris”), at all times referred to herein, is and was a resident of Flathead County, State of Montana.
    9. Defendant Ray Evert (hereafter “Evert 1”), at all times referred to herein, is and was a resident of the State of Montana.
    10. Defendant Estate of Earl Evert (hereafter “Evert 2”) is the estate of the deceased Earl Evert, who prior to his death, was a resident of Flathead County, State of Montana.
    11. Defendant Wayne Evert (hereafter “Evert 3”), at all times referred to herein, is and was a resident of Flathead County, State of Montana.
    12. Defendant Gregory Paskell (hereafter “Paskell”) is a legally licensed attorney in the State of Montana who formerly practiced law in Flathead County, State of Montana.
    13. Defendant Montana Supreme Court (hereafter “SC) is a duly sanctioned court formed and operated under the laws of the State of Montana and is sued in its official capacity.
    14. Defendant Office of Disciplinary Counsel (hereafter “ODC”) is a legal office of the State of Montana, formed and operated under the laws of said State, and is sued in its official capacity.
    15. Defendant Heidi Ulbricht, at all times referred to herein, is and was a lawfully elected city court judge of the City of Kalispell, and is sued in her individual and official capacities.
    16. Defendant Dave Edwards, at all times referred to herein, is and was a probation and parole officer employed by the Montana Department of Probation and Parole, and is sued in his individual and official capacities.
    17. The true names and capacities of Does One through Twenty are presently unknown to Plaintiff. Plaintiff is informed and believes, and based upon such belief alleges, that each of said Doe Defendants is responsible for the damages suffered by Plaintiff. Leave of the Court will be sought to amend this complaint to include the true names and capacities of said Doe Defendants as soon as such information becomes known to Defendant.
GENERAL FACTUAL ALLEGATIONS
    18. Plaintiff has been subjected to innumerable violations of his civil liberty as a direct consequence of his seeking legal redress against local government authorities since in or around July, 2003, and Defendants named herein are both directly and indirectly responsible for such, as cited heretofore.
    19. Plaintiff has been deprived constitutional access to court on several occasions, including but not limited to detention in a Flathead County detention facility where he was deprived all contact with Defendant Eleventh District Court to pursue his civil claims between February, 2004, and December, 2005, and Defendants named herein are both directly and indirectly responsible for such, as cited heretofore.
    20. Plaintiff has been deprived of due process in innumerable instances, including but not limited to tampering with court records, obstruction of lawfully filed motions, and coordinated efforts to deprive Plaintiff of relief, and Defendants named herein are both directly and indirectly responsible for such, as cited heretofore.
    21. Plaintiff has been victimized by coordinated racketeering activity designed to oppress him and to deprive him of assets, property and support, and Defendants named herein are both directly and indirectly responsible for such, as cited heretofore.
    22. Plaintiff is entitled to the return of his property and/or reimbursement for its loss, yet has been consistently obstructed in this liberty interest, and Defendants named herein are both directly and indirectly responsible for such, as cited heretofore.
    23. Plaintiff has been subjected to innumerable instances of criminal fraud and misconduct which have deprived him of any hope of fair and impartial administration of justice within the State of Montana, and Defendants named herein are both directly and indirectly responsible for such, as cited heretofore.
    24. Defendants have instigated injustices not only designed to oppress Plaintiff, but to additionally perpetuate the continued abuses of discretion and authority rampant in Flathead County, Montana, described by many as a “Good Ol' Boy” system, demonstrating that Defendants cannot maintain impartiality within their own jurisdiction.
FIRST CAUSE OF ACTION
    25. Plaintiff realleges and incorporates by reference all of the preceding above as though set forth herein in full.
    26. This cause of action is brought pursuant to the previously cited jurisdictions set forth heretofore.
    27. The above described acts and omissions of Defendants, and each of them, under color of state law, constitute collaboration in a common goal, the oppression and defamation of Plaintiff and the deprivation to Plaintiff of his property interests, and though each Defendant may have been motivated by separate reasons to participate and may not have been aware of either all the participants or actions thereof, they were all knowledged that their actions were in collusion with others for the same purpose, constituting a chain conspiracy, violating Plaintiff's rights guaranteed by the First, Fourth and Fourteenth Amendments to the United States Constitution.
    28. Defendants, in the commission of their acts and omissions, used invidious discrimination of Plaintiff's indigent social status, a condition created by the very deprivations at issue in depriving Plaintiff of his property, to perpetuate their misconduct without opposition.
    29. As a direct and proximate result of acts, omissions and constitutional violations alleged above, Plaintiff has suffered and is entitled to damages.
    30. In doing the acts and making the omissions alleged herein, Defendants acted maliciously and with wanton disregard for the rights, needs and feelings of Plaintiff and by reason thereof, Plaintiff requests punitive damages in the amount of one hundred thousand dollars ($100,000) per Defendant.
SECOND CAUSE OF ACTION
    31. Plaintiff realleges and incorporates by reference all of the preceding above as though set forth herein in full.
    32. This cause of action is brought pursuant to the previously cited jurisdictions set forth heretofore.
    33. The above described acts and omissions of Defendants, and each of them, under color of state law, constitute collaboration in a criminal enterprise, and though each Defendant may have been motivated by separate reasons to participate and may not have been aware of either all the participants or actions thereof, they were all knowledged that their actions were in collusion with others for the same purpose, constituting a racketeering organization, violating Plaintiff's rights guaranteed by the First, Fourth and Fourteenth Amendments to the United States Constitution.
    34. Defendants, in the commission of their acts and omissions, used invidious discrimination of Plaintiff's indigent social status, a condition created by the very deprivations at issue in depriving Plaintiff of his property, to perpetuate their misconduct without opposition.
    35. As a direct and proximate result of acts, omissions and constitutional violations alleged above, Plaintiff has suffered and is entitled to damages.
    36. In doing the acts and making the omissions alleged herein, Defendants acted maliciously and with wanton disregard for the rights, needs and feelings of Plaintiff and by reason thereof, Plaintiff requests punitive damages in the amount of one hundred thousand dollars ($100,000) per Defendant.
THIRD CAUSE OF ACTION
    37. Plaintiff realleges and incorporates by reference all of the preceding above as though set forth herein in full.
    38. This cause of action is brought pursuant to the previously cited jurisdictions set forth heretofore.
    39. The above described acts and omissions of Defendants, and each of them, under color of state law, constitute collaborated effort to deprive Plaintiff of his civil rights, violating Plaintiff's rights guaranteed by the First, Fourth and Fourteenth Amendments to the United States Constitution.
    40. Defendants, in the commission of their acts and omissions, used invidious discrimination of Plaintiff's indigent social status, a condition created by the very deprivations at issue in depriving Plaintiff of his property, to perpetuate their misconduct without opposition.
    41. As a direct and proximate result of acts, omissions and constitutional violations alleged above, Plaintiff has suffered and is entitled to damages.
    42. In doing the acts and making the omissions alleged herein, Defendants acted maliciously and with wanton disregard for the rights, needs and feelings of Plaintiff and by reason thereof, Plaintiff requests punitive damages in the amount of one hundred thousand dollars ($100,000) per Defendant.
FOURTH CAUSE OF ACTION
    43. Plaintiff realleges and incorporates by reference all of the preceding above as though set forth herein in full.
    44. This cause of action is brought pursuant to the previously cited jurisdictions set forth heretofore.
    45. The above described acts and omissions of Defendants, and each of them, under color of state law, constitute collaborated efforts to deprive Plaintiff of his rightful property, constituting deprivation of Plaintiff's liberty interest in owning property, violating Plaintiff's rights guaranteed by the United States Constitution.
    46. Defendants, in the commission of their acts and omissions, used invidious discrimination of Plaintiff's indigent social status, a condition created by the very deprivations at issue in depriving Plaintiff of his property, to perpetuate their misconduct without opposition.
    47. As a direct and proximate result of acts, omissions and constitutional violations alleged above, Plaintiff has suffered and is entitled to damages.
    48. In doing the acts and making the omissions alleged herein, Defendants acted maliciously and with wanton disregard for the rights, needs and feelings of Plaintiff and by reason thereof, Plaintiff requests punitive damages in the amount of one hundred thousand dollars ($100,000) per Defendant.
FIFTH CAUSE OF ACTION
    49. Plaintiff realleges and incorporates by reference all of the preceding above as though set forth herein in full.
    50. This cause of action is brought pursuant to the previously cited jurisdictions set forth heretofore.
    51. The above described acts and omissions of Defendants, and each of them, under color of state law, have demonstrated an intent and purpose in oppressing Plaintiff and denying him access to basic civil liberties, constituting a gross abuse of discretion and authority, violating Plaintiff's rights guaranteed by the First, Fourth and Fourteenth Amendments to the United States Constitution.
    52. Defendants' foregoing acts and omissions have demonstrated a clearly credible history of retaliation for Plaintiff's actions taken in defense of his civil liberties, and has effectively shown a pattern of behavior that is reasonably indicative that future abuses will occur.
    53. Thereupon, there is a real and immediate credible threat that Plaintiff will be wronged again and a sufficient likelihood of substantial and immediate irreparable injury should Defendants be permitted to retain jurisdiction, control or influence over Plaintiff.
    54. As a direct and proximate result of acts, omissions and constitutional violations alleged above, Plaintiff has suffered and is entitled to relief.
    55. In doing the acts and making the omissions alleged herein, Defendants acted maliciously and with wanton disregard for the rights, needs and feelings of Plaintiff and by reason thereof, Plaintiff requests injunctive relief through order of the Court prohibiting any Defendant or agent, associate, representative, employee or supervisory authority thereof from maintaining jurisdiction, control or influence over Plaintiff or any witness that Plaintiff may have cause to name, and to remand all active and future causes of action presently or in the future litigated in the State of Montana in which said Defendants or agent, associate, representative, employee or supervisory authority thereof is named or involved, to this Court's jurisdiction.
SIXTH CAUSE OF ACTION
    56. Plaintiff realleges and incorporates by reference all of the preceding above as though set forth herein in full.
    57. This cause of action is brought pursuant to the previously cited jurisdictions set forth heretofore.
    58. Plaintiff has sufficient cause to believe that many of Defendants' actions, under color of State law, remain unknown and undiscovered, though Plaintiff has expectation of learning of such acts and omissions that are believed to be in violation of Plaintiff's liberty interests protected by the Fourteenth Amendment to the United States Constitution.
    59. As a direct and proximate result of acts, omissions and constitutional violations alleged above, Plaintiff is expected to suffer and will be entitled to damages.
    61. In doing the acts and making the omissions alleged herein, Defendants will have acted maliciously and with wanton disregard for the rights, needs and feelings of Plaintiff and by reason thereof, Plaintiff would request appropriate damages.
CONCLUSION
     Plaintiff has continuously sought to defend his own civil liberties for nearly six years, yet in every instance that he has tried, Defendants have come forth to retaliate against him and further deprive him of his liberty interests. In spite of all he has endured and lost, Plaintiff continues to try to pursue legal remedies to these conflicts, yet in each instance, Defendants abuse their positions, authorities and opportunities to further the objective of invidiously persecuting Plaintiff. And despite Plaintiff's best efforts to seek intervention of proper authorities, repeatedly he has been denied any form of proper relief.
     Simply put, Plaintiff is a United States citizen entitled to constitutional protections and liberties that he has been repeatedly denied in order to perpetuate a corrupt authority entrenched in Montana. And when Plaintiff has sought assistance from supervisory authorities, those same authorities have acted to empower the corruption rather than to take the proper legal measures necessary to restore Plaintiff's constitutional rights. Effectively, Plaintiff is a political prisoner in his own country, where the rights and privileges of all other citizens do not apply to him.
     Plaintiff continues to fight against an unjust conviction wherein he was deprived all pretense of constitutional protections, just as he strives to regain the property that he was unlawfully stripped of by others intent upon their own gains. Plaintiff has at every measure acted within the confines of law, yet he is faced by authorities and those empowered thereby who are not required to follow the law. Essentially, there is a blanket immunity when it comes to violating the law and constitutional provisions of America for anyone who acts specifically against Plaintiff.
     The underlying purpose in all of this is to oppress Plaintiff and to assure that he remains oppressed and incapable of standing against the corruption that has oppressed him. And the corrupt powers-that-be, of which many of the Defendants herein are counted in their number, are willing to permit any atrocity so long as the end result perpetuates their end-game, which is the continuance of the status quo, regardless of who has to be harmed to maintain the corrupt system. Plaintiff remains an outspoken opponent of the corrupt authorities in Montana, and as such has been victimized in order to disempower his capacity to fight back. Plaintiff has been labled with the worst conceivable crime in order to blacklist him and to make him an undesirable. It matters little that it is all based upon falsehood and manipulated, coerced evidence. All that matters in the end is the result: the utter ruination of an innocent man in order to preserve the financial gains of a corrupt government.
     To accomplish this goal, Defendants have formed a criminal enterprise using racketeering activities for the sole purpose of causing harm to Plaintiff and his property. This is a clear and blatant violation of Federal RICO law, and Plaintiff is entitled to both protection from this abuse and to damages for the harm that has been caused him.

     WHEREFORE, Plaintiff respectfully requests relief as follows:
     A. Temporary, preliminary and permanent injunctive relief prohibiting Defendants, or agent, associate, representative, employee or supervisory authority thereof, from maintaining jurisdiction, control or influence over Plaintiff or any witness that Plaintiff may have cause to name, and to remand all active and future causes of action presently or in the future litigated in the State of Montana in which said Defendants, or agent, associate, representative, employee or supervisory authority thereof, is named or involved, to this Court's jurisdiction;
     B.    Punitive damages in the amount of four hundred thousand dollars ($400,000) per Defendant;
    C. Cost of suit herein, including any reasonable attorney fees which Plaintiff may accrue;
    D. Such other and further relief as the Court may deem proper.

     Plaintiff above named does hereby attest under penalty of perjury that the foregoing is true and correct to the best of his ability to present and that this is respectfully submitted on the 24th day of August, 2009.

        ___________________________________
         Ron Glick, Plaintiff