05/04/2012:Formatted with active links to court stamped filings of public record. Plaintiff Michael Nazario’s
04/24/12 Itemized Objections formatted for open text web case study publish to optimize search engine distribution, court
and law community scholar docket analysis, presidential administration(s), States legislatures and funding decision makers,
U.S. Senate Federal and State of Minnesota Law Enforcement Awareness. Authorized by Roxanne Grinage, Legal Assistant Marketing
Careers Project Manager, HireLyrics Administrative Services posted as a verified public incident report to a demonstrated
administrative solutions tool for measuring individual accountability, U.S. Citizens (controlled) Public Docket Database;
Case Study page:http://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.html
05/01/12 U.S. District Judge Assigned Since
Case Opening 03/02/2012 Richard H Kyle Self Recusal Title 28 Section 455 Order for Disqualification and Reassignment 6 days
after 04/30/12 entered Plaintiff Michael Nazario on behalf of Nazario Family and Minnesotans Who May Be Unable to Sue Itemized
Objections: BURDEN OF PROOF; RESERVATION OF RIGHTS WITHOUT PREJUDICE; CONFLICT OF INTEREST; TAX PAYER FRAUD; DEFICIENCIES
IN DUE PROCESS; HEARING ON DEFENDANTS’ MOTIONS TO DISMISS IS PREMATURE ABSENT COURT’S RULING ON PLAINTIFF’S
THREE MOTIONS - United States District Judge Kyle Recuses himself 1 day after Hennepin County Family Division CPS DHS Sheriff
Dept Defendants file Affidavits and Memorandum of law in support of Motions To Dismiss in accordance with Local Rule 7.1 TEXT-ONLY
ENTRY. CLERK'S NOTICE OF REASSIGNMENT. This case is reassigned to Judge John R. Tunheim. Judge Richard H. Kyle no longer assigned
to the case. NOTE: the new case number is 12cv554 JRT/AJB. Please use this case number for all subsequent pleadings. (JME)
(Entered: 05/01/2012) ORDER for Disqualification and for Reassignment. (Written Opinion). Signed by Judge Richard H. Kyle
on 05/01/12. (kll) (Entered: 05/01/2012).pdfhttps://docs.google.com/open?id=0B-34Z89xij26MXNBZGJnRFhGRWs
05/01/12 Notice of Electronic 012-cv-00554-JRT-AJB
Clerk Notice Reassignment to Judge John R Tunheim. Judge Richard H. Kyle no longer assigned to the case Nazario v Quaintance
et al.pdf.https://docs.google.com/open?id=0B-34Z89xij26M091a1NmX2p3Q28
05/02/2012 Order of United States District
Judge John R. Tunheim Order of Reference Pursuant to the provisions of Title 2, U.S.C. Section 636(b)(1(B), Defendants Motions
to Dismiss Docket No. 17 and Docket No. 19 are referred to U.S. Magistrate Judge Arthur J. Boylan, who will submitt to the
undersigned [ Honorable John R. Tunheim] proposed findings of fact and a recommendation for the disposition of the motion
upon completion of a hearing Dated: May 2, 2012 at Minneapolis, Minnesota.pdfhttps://docs.google.com/open?id=0B-34Z89xij26dURmZXV1ekwyY00
05/04/12 Docket Report html pasted to Word
Deadlines/Hearing Schedule; Case Summary; Document Filers History, Docket Events Entered - USDC Court District of Minnesota
Michael Nazario and Minnesotans v Family Division Judge Katherine Quaintance CPS DHS Sheriff Dept Corruption Personal Injuries
5 RICO Causes of Action et al 012cv00554-JRT-AJB.docxhttps://docs.google.com/document/d/1Rko2krLKM-WFLd379EBCb3bJLsfA9ZxpQhT_FmhI7D4/edit
Michael Nazario on behalf of Nazario Family and similarly situated Minnesotans Minneapolis
MN 55418 nazariominnesotanfamilies@yahoo.com Federal Crime Witness Plaintiffs Pro Se
United States District Court District of Minnesota
MICHAEL NAZARIO ON BEHALF OF NAZARIO FAMILY, AND SIMILARLY SITUATED MINNESOTANS,
Plaintiffs Pro Se
JUDGE KATHERINE QUAINTANCE Fourth Judicial District Family Division,
in her individual capacity, having no immunity for Legal Malpractice inflicted personal injuries, irreparable harms in
re FAM ID NO. 323598 CASE NO. 27-JV-11-7365 Defendant, and
KARIN L CHEDISTER, Assistant Hennepin County Attorney in her individual capacity
having no immunity and largest degree of criminal culpability 18 USC § 241 - Conspiracy Against Rights, 18 USC §
242 - Deprivation Of Rights Under Color Of Law, Kidnap For Profit in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365
Defendant and
DIANE KASSLER and DEBORAH SILVERSTEIN, Hennepin County Department of
Health and Public Services, Child Protection Services (“DHS/CPS”) in their individual and joint capacities
for falsifying case reports, slander, libel, terror threats made to Plaintiff Joy Nazario and Lying in Official Court Documents
about having had meetings and conversations with Plaintiff Michael Nazario to kidnap for profit injure and disable Nazario
Family persons.
Defendants and
HENNEPIN COUNTY SHERIFF DEPARTMENT, In the County’s and Department’s
official capacity for accountability for their sheriff deputies’ and police officers’ having inflicted several
acts of Police Brutality, Trauma and Risk of Death Suffered by Michael Nazario Age 35 and his wife Joy Nazario Age 33, Daughter
in Law Marie Evans 18, Grandson Terrian Smith 6 months, Son Isaiah Smith, Father in Law James Dixon Age 54, Michael Nazario
Jr., Son Age 18 including pointing loaded firearms at a six month old baby and senior citizens, while acting on the Malpractice
False Arrest Unlawful Imprisonment Order of Judge Katherine Quaintance. Defendants
Case 0:12-cv-00554-RHK-AJB Nazario v. Quaintance et al PLAINTIFF MICHAEL NAZARIO’S ITEMIZED OBJECTIONS: BURDEN OF PROOF; RESERVATION OF RIGHTS WITHOUT PREJUDICE; CONFLICT OF INTEREST; TAX PAYER FRAUD; DEFICIENCIES
IN DUE PROCESS; HEARING ON DEFENDANTS’ MOTIONS TO DISMISS IS PREMATURE ABSENT COURT’S RULING ON PLAINTIFF’S
THREE MOTIONS
Minnesota General Rules of Practice for the District Courts:Rule
111.04 and Rule 112.01; and Federal Practice Manual.6.3 Motions Practice.6.3.B.4.
Rule 23.Docket analysis of the noticed events and un-noticed events in this case demonstrate prejudicial
treatment towards Defendants.Defendants are favored by the Court who has withheld for more than 28
days Ruling on Plaintiff’s Motions.
BACKGROUND
The above captioned matter
was opened in U.S. District Court for the District of Minnesota on March 2, 2012, by non-lawyer represented main plaintiff
attempting to bring to the Court’s attention similarly situated crime victims of Hennepin County Family Division, Children’s
Protective Services, Department of Health and Human Services and Sheriff’s Department corruption; MICHAEL NAZARIO on
behalf of Nazario Family and Minnesotans Who May Be Unable to Sue.
Main Plaintiff’s Case Initiation Documents including Civil
Cover Sheet and Complaint and Exhibits set forth “NATURE OF SUIT:Public Safety Emergency Caused
by Hennepin County Fourth Judicial District Family Division Deliberate Continuing and Worsening Legal Malpractice of Minnesota
Constitution Article I Bill of Rights and FIVE CAUSES OF ACTION: i.18 USC Chapter 96
- Racketeer Influenced Corrupt Organizations; ii.18 USC § 1968 - Civil investigative
demand; iii.18 USC § 3771 – Federal Crime Victims’ Rights; iv.18
USC § 241 - Conspiracy Against Rights; v.18 USC § 242 - Deprivation Of Rights Under Color Of
Law.”
Commencement
of Federal Lawsuit was Assigned by U.S. District of Minnesota Clerk of Court as follows: Date:03/02/2012; Case: 0:12-cv-00554; Assigned to:Kyle, Richard H.; Referral Judge: Leung, Tony N.
On March 5, 2012, Tony
N. Leung recused herself pursuant to the provisions of 28 U.S.C. § 455(a), which are “(a) Any justice, judge, or
magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably
be questioned.”
On
March 26, 2012, Hennepin County lawyers and State of Minnesota Attorney General’s Office entered their appearances for
all five Hennepin County Defendants, who are also their colleagues.
On March 26, 2012, all five Hennepin County Defendants entered
Motions To Dismiss pursuant to Federal Rules of Civil Procedure “Rule 12(b)(1) lack of subject matter jurisdiction and
Rule 12(b)(6) failure to state a claim upon which relief can be granted.
On March 26, 2012, upon noting all Hennepin County Defendants
and their Minnesota State and Hennepin County employed lawyers had all entered appearance and motions to dismiss on the same
day and in less than half the time allowed on U.S. District Court Clerk’ Summons in a Civil Action (sixty (60) days),
Plaintiff’s secretary, Roxanne Grinage, decided to perform a docket query of Deadlines/Hearings.
For reasons unknown, all
five Hennepin County defendants and their colleague lawyer representatives were aware the Court had assigned an “Answer
Due” Deadline of March 26, 2012 for each defendant on the same day the case was opened and in less than half the time
allowed on U.S. District Court Clerk’ Summons in a Civil Action, although no Deadlines/Hearing or Case Scheduling Notice
was issued by either paper or electronic notice.
On March 27, 2012, Plaintiff Michael Nazario filed three Motions titled as follows:
March 27, 2012, Plaintiff
Motion One:Plaintiff Michael Nazario’s Motion Continue June 11, 2012, Hearing
On Defendants March 26, 2012 Motions To Dismiss At Least Ninety (90) Days;
March 27, 2012, Plaintiff Motion Two:Federal
Crime Witness Plaintiff Michael Nazario’s Motion Appoint Counsel Or, In The Alternative, Continue Scheduled Hearing
On Defendants’ Motions To Dismiss At Least Ninety (90) Days To Give Non Attorney Represented Plaintiffs Time To Retain
Qualified Legal Malpractice Personal Injury Attorney Representation, To Fairly Match The Legal Expertise Of Judge, Lawyers
And State Employees Who Are, In Fact, Defendants And Whose “Heavy Weight” Hennepin County And Minnesota Governments-Employed
Litigators Have Entered Their Appearance On Behalf Of All Defendants; and
March 27, 2012, Plaintiff Motion Three:Plaintiff
Michael Nazario’s Motion To Compel Defendants Admit Or Deny Each Numbered Averment Set Forth In Amended Complaint Timely
Filed, Pursuant to Minnesota U.S. Courts Local Rule 7.1 Civil Motion Practice, Rule 7.1(b) Dispositive Motions, L.R. 7.1(b)(2)(A)(B)
and Federal Rules of Civil Procedure Rule 15(a)(1)(A)(B), and Rule 12(b), and Pursuant to Minnesota Court Local Rule 8 General
Rules For Pleading”, 8.05 “Pleadings To Be Concise and Direct; Consistency” and Plaintiffs’ “More
Definite Statements as to Federal Rule of Civil Procedure 12(b)(6) “Failure to State a Claim for which Relief can be
Granted.”
On
March 30, 2012, Michael Nazario entered Amended Complaint:one hundred and eight (108) numbered paragraph
averments, irrefutable facts and evidence marked Exhibits A, B, C, D, E, F, G, H, and I, which decisively refuted Defendants’
Motions to Dismiss (F.R.C.P. 12(b)(1) 12(b)(6)) and clarified the most fundamental Constitutional requirements for standing,
“Subject Matter” and “More Definite Statements” as to why similarly situated Minnesotans having experienced
personal injuries caused by Racketeering Corruption Organization Influenced Legal Malpractice caused by Hennepin County corruption,
have every right to petition U.S. District Court for the District of Minnesota and to expect that this Court will Grant Relief
unavoidable should fair due process, jury trial demand by Plaintiffs and Case Scheduling rules be applied fairly.
On
March 30, 2012, Plaintiff Michael Nazario filed, PLAINTIFF MICHAEL NAZARIO’S AMENDED COMPLAINT SETS FORTH PROPERLY FORMATTED
NUMBERED AVERMENTS TIMELY FILED, Pursuant to Federal Rules of Civil Procedure Rule 15(a)(1)(A)(B), and Rule 12(b), and Pursuant
to Minnesota Court Local Rule 8 General Rules For Pleading”, 8.05 “Pleadings To Be Concise and Direct; Consistency”
and Plaintiffs’; and “More Definite Statements as to Federal Rule of Civil Procedure 12(b)(6) “Failure to
State a Claim for which Relief can be Granted.”
See Exhibit A, Exhibit B, Exhibit C, Exhibit D, Exhibit E, Exhibit F, Exhibit
G, Exhibit H, and Exhibit I, Plaintiff Michael Nazario’s Marked Exhibit Index, Plaintiff Michael Nazario’s Amended
Complaint Sets Forth Properly Formatted Numbered Averments Timely Filed incorporated by reference as if fully set forth herein.
ITEMIZED
OBJECTIONS
1.BURDEN OF PROOFNormally, the Plaintiff has to
prove each legal element of a claim by a measure referred to by the Court as a “preponderance of the evidence.”The Plaintiff does not have to prove the evidence beyond a reasonable doubt (as does a prosecutor in a criminal trial),
but just by something more than 50%.Judges know these terms and Plaintiffs should not have to explain
them to a Judge who is acting fairly.Michael Nazario on behalf of Nazario Family and similarly situated
Minnesotans recognize that we have the burden of proof in this case.But given all the evidence as to each
of the legal elements put forward by non-lawyers Michael Nazario and his hired legal administrative assistant Roxanne Grinage,
despite the disadvantages posed by being “outsiders” in a forum which favors it’s bar association admitted
colleagues; it seems Plaintiffs have clearly met burden of proof.
2.ALL
RIGHTS RESERVED WITHOUT PREJUDICE.I, Michael Nazario, reserve my right without prejudice to petition Federal or Supreme Courts for
redress of grievances and/or to re-present my claims individually or jointly with other claimants who have been injured by
Hennepin County Corruption in all venues which present lawful recourse.Under no circumstance is my reservation
of rights without prejudice declaration to be misconstrued as withdrawal of claims or agreement with deprivation of rights
under color of law.
It is necessary to record for the records of this Court and future venues where these claims are likely to manifestthatdocket analysis of the noticed events and un-noticed events in this case demonstrate prejudicial
treatment towards Defendants who have been allowed to ignore Plaintiff’s March 27, 2012 Motion Compel Defendants Admit
or Deny Each Numbered Averment of Plaintiff Michael Nazario’s Amended Complaint.
3.Defendants are favored by the Court who has withheld for more than 28 days [at
time of web posting on May 4, 2012, 38 days] Ruling on Plaintiff’s Motion to Continue Hearing on Defendants’
Motions To Dismiss ninety days to give non-lawyer represented plaintiffs time to find and hire qualified counsel to balance
the “heavy weight” litigator expertise of the defendants and their colleague attorney representation.
4.Court has permitted Defendants to glean unfair advantage to the detriment of
Plaintiff who suffers continuing worsening personal injuries, fraud, threat of unlawful attachments, threat of disability
and death.High powered litigator defendants and their colleague legal representatives are permitted to
simply file one page motions to dismiss on March 26th and amended motions to dismiss on April 13, 2012, noticing twice a hearing
on Defendants Motions to Dismiss, smugly confident that this U.S. District Court for the District of Minnesota is not the
venue which will hold corrupt Hennepin County Defendants accountable for their Racketeering Influenced Corrupt Organization
Legal Malpractice caused personal injuries and fraud crimes against the People of Minnesota.
5.Michael Nazario has medical bills within the last two weeks of this filing which
show the chronic public defamation of himself and his son(s); the home invasion and police brutality experienced January 20,
2012; the trauma injuries to Michael Nazario’s daughters and wife; the outspoken threats and tyranny of Family Division
Defendant Judge Katherine Quaintance, DHS/CPS Diane Kassler, Deborah Silverstein and their co-worker Guardian Ad Litem Denise
Graves with Hennepin County lawyers Karin Chidester and Christa Groshek; continue to threaten fraud billing, unlawful attachments,
job loss, poverty, hate-crime and post traumatic stress caused personal injury disability and death to Michael Nazario and
other Minnesotan victims of Hennepin County corruption.
6.Michael Nazario
has within the last month suffered frequent chest pains, numbing in both arms, and his doctors and medical tests confirm he
is at high risk for suffering disability or death from heart attack or stroke.
7.CONFLICT OF INTEREST.The self recusal of first Clerk of Court assigned magistrate
judge validates the reasonable expectation that Hennepin County and State of Minnesota employed law practicing defendants
and their Hennepin County and State of Minnesota employed lawyer representatives are likely to have conflicts of interest
with regard to partiality and fairness.
8.TAX
PAYER FRAUDHennepin
County Defendants are brought into U.S.D.C. for the District of Minnesota by main plaintiff Michael Nazario on behalf of Nazario
Family and Minnesotans Who May Be Unable to Sue, because the Hennepin County Defendants are officials who are perpetrating
Racketeering Influenced Corrupt Organization legal malpractice caused personal injuries against the People of Minnesota.The victims of the Hennepin County Defendants are also the tax payers that not only pay the salaries of the RICO indictable
Defendants, but also are paying for the Minnesota State and Hennepin County funded competitively operating legal expertise
of Thomas C Vasaly, Minnesota Attorney General's Office and Beth A Stack and Toni A. Beitz Hennepin County Attorney's Office.
9.DEFICIENCIES IN DUE PROCESSIn addition to all prior Federal and
Local Rules cited by Plaintiff in previous filings to date incorporated as if fully set forth herein, following are additional
deficiencies in due process specific to Plaintiffs Michael Nazario on behalf of Nazario Family and Minnesotans Who May Be
Unable To Sue direct first‑hand experience in the matter captioned Nazario v. Quaintance, et al, U.S. District Court
District of Minnesota (DMN) Civil Docket For Case #: 0:12-cv-00554-RHK-AJB:
a.Plaintiffs Demanded a Jury Trial.Due Process, the public interest and Minnesota General Rules of Practice for the District Courts are best served if
a Pretrial Conference and at least one Case Management Scheduling Order takes precedence over accommodation of official corruption
Defendants’ motion to dismiss evasive tactics.
b.Plaintiffs disclosed
existence of official corruption fraud civil rights legal malpractice personal injuries and theft class claims and the public
interest, public safety need for qualified attorney representation and certification of class.
c.Minnesota General
Rules of Practice for the District Courts:Rule 111.04 Amendment:A scheduling order
pursuant to this rule may be amended at a pretrial conference or upon motion for good cause shown.Except
in unusual circumstances, a motion to extend deadlines under a scheduling order shall be made before the expiration of the
deadline.The court may issue more than one scheduling order.Cross Reference:Minn. R. Civ. P. 16, 26.06, 35, 36, 38; Minn. Civ. Trial book, section.
d.Minnesota General Rules of Practice for
the District Courts:Rule 112.01 When Required.As a case progresses, the court may
find it advisable to implement the scheduling order and procedures of Minn. Gen. R. Prac. 111 by requiring parties to report
on the status of the case.This report shall be made in the form entitled Joint Statement of the Case,
(see Form 112.01) not accessible to the public or the other party. Such an action by the Court will pin down Defendants who continue to coerce plaintiffs abusing their official access
to plaintiffs claiming everything from “we
are moving towards dismissal”; to “let
him dig a hole for himself, his complaint will be thrown out because it is poorly written and then we will end his parental
rights”; to Michael Nazario’s
daughters’ telling their therapist Hennepin County Guardian Ad Litem Denise Graves and her CPS/DHS defendant coworkers
tell the adolescent girls to rehears scripted comments of DHS/CPS “wait for us to turn on the recorder and then say
exactly what we told you to say” to “the lawyer Christa Groshek hired by Michael Nazario’s family to represent his wife Joy Nazario in false
arrest criminal matter; has yet to file anything in the criminal case and is conspicuously active in representing adverse
party, Defendant Karen Chedister’s DHS interest and instructions to Joy Nazario; and DHS/CPS extending their innuendo and defamation of “he didn’t believe his sister” to cause Joy and
Michael Nazario’s son to be ejected from his mother’s home to live with his father who Hennepin County DHS/CPS
Defendants are “hell-bent” on causing to be arrested, homeless, disabled or killed; Michael Nazario has experienced on March 6, 2012 upon arriving at Defendant Judge Katherine Quaintance’s court,
a completely empty lobby; never seen before ─ absolutely no person, staff or litigants in the lobby of the courthouse
building.While in Defendant Katherine Quaintance’s court Michael Nazario witnessed Katherine Quaintance
entertain arguments of CPS and DHS defendants who wanted to cause the arrest of Michael Nazario by bringing his daughters
into the proceedings so that Michael Nazario would technically be in violation of Defendant Katherine Quaintance’s coerced
by threats to Joy Nazario restraining order. Hennepin County DHS/CPS Defendants tell Joy Nazario, “That’s right Joy just keep your husband out of the
picture and we are moving to dismissal.” On March 6, 2012 while still in Defendant Katherine Quaintance’s court Michael Nazario was told by his wife that
the same CPS workers gave her permission to talk with her husband, “If you have any influence with Michael, get him
to drop the federal case.”It should be noted here that Defendant Katherine Quaintance reinstated
with no justification an order of protection barring Michael Nazario from his family that two prior Fourth Judicial District
Family Division Judges saw fit to nullify.
e.Federal Practice
Manual.6.3 Motions Practice.6.3.B.4. Rule 23.In class actions,
the complaint should contain allegations concerning the class drafted in light of Rule 23.It should allege
facts to support the requirements of numerosity, commonality, typicality, and representativeness.When
practical, a motion for class certification can and should be filed with the complaint. Main Plaintiff, Michael Nazario on behalf
of Nazario Family and similarly situated Minnesotans did not have to be knowledgeable in the practice of law to suffer the
legal malpractice personal injuries inflicted by Hennepin County Defendants official corruption fraud civil rights crimes. Fair access to justice, public
interest, U.S. economy and public safety require this Court ensure due process is afforded to the Plaintiffs as Plaintiffs
await Court’s rulings on Plaintiff’s motions.In the event Plaintiff’s Motion to Appoint
Counsel is denied; Due process dictates June 11, 2012 hearing on Defendants’ Motions to Dismiss should be canceled and
Enter Case Management Scheduling Order while class plaintiffs gather the money to retain qualified counsel who has quoted
a reasonable retainer fee of $20,000.
f.Defendants would
have U.S. District Court of Minnesota believe this case is about a Family Court matter.This case is about
the tragic discovery by first-hand experience, evidence gathering depositions and witness testimony of Defendants Fourth Judicial
District Family Division Judge Katherine Quaintance, Hennepin County DHS lawyer Karen Chedister, Hennepin County Children’s
Protective Services employees Deborah Silverstein Diane Kassler abusing federal and tax payer funding and public trust to
deliberately commit malpractice of Minnesota statutes which cause fraud billing, police brutality and personal injuries to
the People of Minnesota entrapped in a RICO Act indictable Kidnap for Profit Scheme.Defendants should
stand trial.
Respectfully
submitted,
Dated this 24th
Day of April, 2012.s/ Michael Nazario
Michael Nazario on behalf of Nazario Family and similarly situated Minnesotans Minneapolis MN 55418 nazariominnesotanfamilies@yahoo.com Federal Crime Witness Plaintiffs Pro Se
Michael Nazario on behalf of Nazario Family and similarly situated Minnesotans Minneapolis MN 55418 Tel:(952)Fax: (215) 405-2939 nazariominnesotanfamilies@yahoo.com Federal Crime Witness Plaintiffs Pro Se
United States District Court District of Minnesota
MICHAEL NAZARIO ON BEHALF OF NAZARIO FAMILY, AND SIMILARLY SITUATED MINNESOTANS,
Plaintiffs Pro Se
JUDGE KATHERINE QUAINTANCE Fourth Judicial District Family Division, in her individual capacity, having no immunity for Legal Malpractice inflicted
personal injuries, irreparable harms in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365
Defendant, and
KARIN L CHEDISTER, Assistant Hennepin
County Attorney in her individual capacity having no immunity and largest degree of criminal culpability 18 USC §
241 - Conspiracy Against Rights, 18 USC § 242 - Deprivation Of Rights Under Color Of Law, Kidnap For Profit in re
FAM ID NO. 323598 CASE NO. 27-JV-11-7365
Defendant and
DIANE KASSLER and DEBORAH
SILVERSTEIN, Hennepin County Department of Health and Public Services, Child Protection Services (“DHS/CPS”)
in their individual and joint capacities for falsifying case reports, slander, libel, terror threats made to Plaintiff Joy
Nazario and Lying in Official Court Documents about having had meetings and conversations with Plaintiff Michael Nazario
to kidnap for profit injure and disable Nazario Family persons.
Defendants
and
HENNEPIN COUNTY SHERIFF DEPARTMENT, In the County’s and Department’s official capacity for
accountability for their sheriff deputies’ and police officers’ having inflicted several acts of Police Brutality,
Trauma and Risk of Death Suffered by Michael Nazario Age 35 and his wife Joy Nazario Age 33, Daughter in Law Marie Evans
18, Grandson Terrian Smith 6 months, Son Isaiah Smith, Father in Law James Dixon Age 54, Michael Nazario Jr., Son Age
18 including pointing loaded firearms at a six month old baby and senior citizens, while acting on the Malpractice False
Arrest Unlawful Imprisonment Order of Judge Katherine Quaintance.
Defendants
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Case 0:12-cv-00554-RHK-AJB Nazario v. Quaintance
et al
Pursuant to Federal Rules of Civil Procedure Rule 15(a)(1)(A)(B), and Rule
12(b), and Pursuant to Minnesota Court Local Rule 8 General Rules For Pleading”, 8.05 “Pleadings To Be Concise
and Direct; Consistency” and Plaintiffs’; and “More Definite Statements as to Federal Rule of Civil Procedure
12(b)(6) “Failure to State a Claim for which Relief can be Granted.”
COMES
NOW, PLAINTIFF MICHAEL NAZARIO, a non-attorney represented Federal Crime Victim Witness, and sets forth only those allegations of facts and claims
(averments) for which Michael Nazario has first-hand knowledge, document, audio or witness evidence in support of in accordance
with “Federal Rules of Civil Procedure Rule 15, Amended and Supplemental Pleadings (a) Amendments Before Trial, (1)
Amending as a Matter of Course, a party may amend its pleading once as a matter of course within:(A)
21 days after serving it, or (B) if the pleading is one to which a responsive pleading is required, 21 days after service
of a responsive pleading or 21 days after service of a motion under Rule 12(b), (e), or (f), whichever is earlier,”
and respectfully enters
PLAINTIFF
MICHAEL NAZARIO’S AMENDED COMPLAINT SETS FORTH PROPERLY FORMATTED NUMBERED AVERMENTS TIMELY FILED, (See Cover Letter explanation of technical difficulties
and lack ecf training and of legal knowledge with regard to understanding whether to link amended complaint to March 2, 2012),
Pursuant to Federal Rules of Civil Procedure Rule 15(a)(1)(A)(B), and Rule 12(b), and Pursuant to Minnesota
Court Local Rule 8 General Rules For Pleading”, 8.05 “Pleadings To Be Concise and Direct; Consistency” and
Plaintiffs’; and “More Definite Statements as to Federal Rule of Civil Procedure 12(b)(6) “Failure to State
a Claim for which Relief can be Granted.”
I, Michael Nazario have marked my March 2, 2012 Complaint “Exhibit F”, have attached Exhibit
F hereto and do hereby incorporate it by reference as if fully set forth herein.
JURISDICTION and
WHY IT IS NECESSARY TO SUE IN THIS VENUE
As stated in sworn Affidavit of Facts in my
March 2, 2012 Complaint and restated herein in properly formatted Amended Complaint, timely filed; this Court has Jurisdiction
under 28 U.S.C. § 1331 because of Federal Questions which arise as a result of a Public Safety emergency caused
by Hennepin County Fourth Judicial District Family Division Defendant Judge Katherine Quaintance’s; Defendant
Hennepin County Attorney’s Office and DHS lawyer Karin Chedister’s;Defendants Hennepin County
Children Protective Services (CPS) employees Diane Kassler’s and Deborah Silverstein’s deliberate continuing and
worsening legal malpractice of Minnesota statutes and Minnesota Constitution Article I Bill of Rights, which have caused Defendant
Hennepin County Sheriff’s Department and Minnesotan taxpayers to be defrauded, abused to inflict judicial tyranny retaliation,
police brutality, unlawful imprisonment, reckless endangerment fraud billing, trauma injuries and maximum risk of injuries
during January 20, 2012 legal malpractice ordered arrest and the subsequent “throwing” of Michael and Joy Nazario’s
teenage daughters into a Minneapolis shelter system.
I, Michael Nazario, experienced first-hand federal crime victim witness, document, audio and expert
witness testimony evidence proving that Defendants Judge Katherine Quaintance, Karen Chedister, Diane Kassler, Deborah Silverstein
and Hennepin County Sheriff Department have committed grave and serious acts of official corruption, fraud civil rights crimes
to force commerce and contracts, injure/endanger, and disable my family’s health, finances, reputations, education,
and careers;
Set forth are
numbered averments whose answers impact Public Safety Emergency for which United States Federal Judge and a District Court
Jury Trial could grant relief through fair and accurate discernment of Federal Questions raised by Defendants conducts in
Fourth Judicial District Hennepin County Family Division Matter captioned “In the Matter of the Welfare of the Children
of Joy Nazario, Mother and Michael Nazario, Father, FAM ID NO. 323598 CASE NO. 27-JV-11-7365.
I, Michael Nazario, set forth the following
properly numbered averments which Defendants are obligated to admit or deny and for which U.S.D.C. District
of Minnesota has exclusive Jurisdiction and a duty to public interest to adjudicate via Trial and/or Jury Trial
demanded by Plaintiffs.See Plaintiff Michael Nazario Marked Exhibit Index, Exhibit
A. Civil Cover Sheet.
Averment
No. 2.Federal Question jurisdiction arises pursuant to 18 USC Chapter 96 - Racketeer Influenced
Corrupt Organizations(particularlySECTION 1028 (RELATING TO FRAUD AND RELATED ACTIVITY IN CONNECTION WITH IDENTIFICATION DOCUMENTS);
Averment No. 4.Federal
Question jurisdiction arises pursuant to 18 USC Chapter 96 - Racketeer Influenced Corrupt Organizations(particularlySECTION 1503 (RELATING TO OBSTRUCTION OF JUSTICE);
Averment No. 5.Federal
Question jurisdiction arises pursuant to 18 USC Chapter 96 - Racketeer Influenced Corrupt Organizations(particularlySECTION 1511 (RELATING TO THE OBSTRUCTION OF STATE OR LOCAL LAW ENFORCEMENT);
Averment No. 6.Federal Question jurisdiction arises pursuant to 18 USC Chapter 96 - Racketeer
Influenced Corrupt Organizations(particularlySECTION 1513 (RELATING TO RETALIATING AGAINST A WITNESS, VICTIM, OR AN INFORMANT);
Averment
No. 7.Federal Question jurisdiction arises pursuant to 18 USC Chapter 96
- Racketeer Influenced Corrupt Organizations(particularlySECTIONS 1581–1592 (RELATING TO PEONAGE, SLAVERY, AND TRAFFICKING IN PERSONS);
Averment
No. 8.Federal Question jurisdiction arises pursuant to 18 USC Chapter 96
- Racketeer Influenced Corrupt Organizations(particularly SECTION 1951 (RELATING TO INTERFERENCE WITH COMMERCE, ROBBERY, OR EXTORTION);
Averment No. 10.Federal Question jurisdiction
arises pursuant to 18 USC Chapter 96 - Racketeer Influenced Corrupt Organizations(particularlySECTION 1957 (RELATING TO ENGAGING IN MONETARY TRANSACTIONS IN PROPERTY DERIVED FROM SPECIFIED UNLAWFUL ACTIVITY);
Averment
No. 11.Federal Question jurisdiction
arises pursuant to 18 USC Chapter 96 - Racketeer Influenced Corrupt Organizations(particularly SECTION2260 (RELATING TO SEXUAL EXPLOITATION OF CHILDREN);
Averment No. 12.Federal Question jurisdiction
arises pursuant to 18 USC Chapter 96 - Racketeer Influenced Corrupt Organizations(particularlySECTIONS 2421–24 (RELATING TO WHITE SLAVE
TRAFFIC).
Averment No. 13.Federal
Question jurisdiction arises pursuant to Plaintiff Michael Nazario on behalf of Nazario Family and Minnesotans similarly situated
Second Cause of Action set forth in March 2, 2012 Complaint:18 USC § 1968 - Civil investigative
demand:
Averment No. 14.I,
Michael Nazario, my wife, father in law, mother, sons, daughter in law and six month old grandson were all affected as a result
of decisions and orders issued by Defendant Judge Katherine Quaintance.
Averment No. 15.Decisions
made and orders issued by Defendant Judge Katherine Quaintance in Family Court impact Michael Nazario, Joy Nazario and all
of our children.
Averment No. 16.Neither
Michael Nazario, nor Joy Nazario, nor our children, nor my father in law, nor my daughter in law, nor my sons nor my now 8
month old grandson have any forum available to us as Federal Crime Victims created by official corruption fraud civil rights
crimes to ask for the assistance of the Attorney General or make an investigative demand for crimes committed under color
of law in Fourth Judicial District Hennepin
County Family Division Matter captioned “In the Matter of the Welfare of the Children of Joy Nazario, Mother and
Michael Nazario, Father, FAM ID NO. 323598 CASE NO. 27-JV-11-7365.
Averment
No. 17.A
United States District Court venue (Federal Court) is the only venue available to Michael Nazario on behalf of Nazario Family
and similarly situated Minnesotans Federal Crime Victims who seek the assistance of the Attorney General in accordance with
Federal Statute “18 USC § 1968 - Civil investigative demand (a) Whenever the Attorney General
has reason to believe that any person or enterprise may be in possession, custody, or control of any documentary materials
relevant to a racketeering investigation, he may, prior to the institution of a civil or criminal proceeding thereon, issue
in writing, and cause to be served upon such person, a civil investigative demand requiring such person to produce such material
for examination.”
Averment
No. 18.Personal
injuries sustained by litigants as a result of legal malpractice in a family court matter does not diminish the severity of
the injuries.
Averment No. 19.Fraud
billing, whether initiated due to an agency DHS/CPS employee’s criminal intent to embezzle federal funding sources,
or because of bureaucratic records mis-management forces contracts which cause the malpractice payee to become financially
devastated and unable to make U.S. Economy enriching contributions as a consumer or career contributor.
Averment
No. 20.Agencies’
Department of Human Services (DHS) and Children Protective Services (CPS) billing statements, whether legal or not, move from
invoice to demand notice to judgment to lien/levy and wage garnishee and seizure of property and assets.
PARTIES
March 26, 2012 Docket Report U.S. District Court District of Minnesota (DMN) Civil Docket For Case #:
02:12-cv-00554-RHK-AJB:Correctly records case details, short form and long form captions, parties, federal
question, cause of action, nature of suit; capacities as completely as Clerk of Court’s database fields would allow.See Plaintiff Michael Nazario’s Marked Exhibit Index – Amended Complaint, Exhibit B.
Averment No. 1.All of the legal representatives who have entered appearance on behalf of Defendant
officials are Hennepin County attorney’s office employed or Minnesota U.S. Courts government employed litigators (Beth
Stack and Toni Dietz, U.S. Attorney’s Office Thomas Vasaly).
Averment No. 2.Defendants
Diane Kassler and Deborah Silverstein are Hennepin County and/or Minnesota State agencies employees.Defendant,
Hennepin County Sheriff’s Department is represented by Hennepin County Attorney’s Office, Beth Stack and Toni
Beitz, co-workers and colleagues of Defendants Karin Chedister Diane Kassler and Deborah Silverstein.
Averment No. 3.Defendant Judge Katherine Quaintance is a State of Minnesota
judiciary official who is represented by Minnesotan taxpayers’ paid for official and Bar Association Attorney also having
prosecutorial powers, Thomas C. Vasaly, Minnesota Attorney General’s Office.
Averment No. 4.Defendant Fourth Judicial District Family Division Judge
Katherine Quaintance is a member of Minnesota Bar Association.
Averment
No. 5.Defendant Fourth Judicial District
Family Division Judge Katherine Quaintance is a member American Bar Association.
Averment No. 6.Defendant Fourth Judicial District
Family Division Judge Katherine Quaintance swore oaths of public office to uphold Minnesota Statutes, Minnesota Constitution
and U.S. Constitution.
Averment No. 7.By way of further averment plaintiff Michael Nazario and
similarly situated Minnesotans ask Defendant Fourth Judicial District Family Division Judge Katherine Quaintance to set forth
in written response exactly what the oath or oaths she vowed as a judicial authority trusted to make decisions that impact
the health economies careers of the families who come before her in domestic relations matters.
Averment No. 8.The capacities in which Defendant
Judge Katherine Quaintance is complained about in March 2, 2012 Complaint of Michael Nazario on behalf of Nazario Family and
Minnesotans similarly situated who may be unable to sue are recorded in the Case Summary and Docket Report of U.S.D.C. for
the District of Minnesota Case: 0:12-cv-00554-RHK-AJB; as set forth in Michael Nazario’s Complaint:“Defendant,
Judge Katherine Quaintance, Fourth Judicial District Family Division, in her individual capacity, having no immunity for Legal
Malpractice inflicted personal injuries, irreparable harms in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365.” See
Plaintiff Michael Nazario Marked Exhibit Index – Amended Complaint, Exhibit B.
Averment No. 9.Defendant Fourth Judicial District
Family Division Judge Katherine Quaintance is obligated by oath, public and fiduciary trust to exemplify Model Code of Judicial
Conduct framed in Judicial Canons Preamble, to the best of her ability:
“Our legal system is based on the principle that an independent, fair and competent judiciary
will interpret and apply the laws that govern us. The role of the judiciary is central to American concepts of justice and
the rule of law. Intrinsic to all sections of this Code are the precepts that judges, individually and collectively, must
respect and honor the judicial office as a public trust and strive to enhance and maintain confidence in our legal system.
The judge is an arbiter of facts and law for the resolution of disputes and a highly visible symbol of government under the
rule of law.
The
Code of Judicial Conduct establishes standards for ethical conduct of judges. It consists of broad statements called Canons,
specific rules set forth in Sections under each Canon, a Definitions Section, an Application Section and Commentary. The text
of the Canons and the Sections, including the Definitions and Application Sections, is authoritative. The Commentary, by explanation
and example, provides guidance with respect to the purpose and meaning of the Canons and Sections. The Commentary is not intended
as a statement of additional rules. When the text uses "shall" or "shall not," it is intended to impose
binding obligations the violation of which, if proven, can result in disciplinary action. When "should" or "should
not" is used, the text is intended as hortatory and as a statement of what is or is not appropriate conduct but not as
a binding rule under which a judge may be disciplined. When "may" is used, it denotes permissible discretion or,
depending on the context, it refers to action that is not covered by specific proscriptions.
The Canons and Sections are rules of
reason. They should be applied consistent with constitutional requirements, statutes, other court rules and decisional law
and in the context of all relevant circumstances. The Code is not to be construed to impinge on the essential independence
of judges in making judicial decisions.
The Code is designed to provide guidance to judges and candidates for judicial office and to provide
a structure for regulating conduct through disciplinary agencies. It is not designed or intended as a basis for civil liability
or criminal prosecution. Furthermore, the purpose of the Code would be subverted if the Code were invoked by lawyers for mere
tactical advantage in a proceeding.”
The text of the Canons and Sections is intended to govern conduct of judges and to be binding upon
them. It is not intended, however, that every transgression will result in disciplinary action. Whether disciplinary action
is appropriate, and the degree of discipline to be imposed, should be determined through a reasonable and reasoned application
of the text and should depend on such factors as the seriousness of the transgression, whether there is a pattern of improper
activity and the effect of the improper activity on others or on the judicial system.
The Code of Judicial Conduct is not intended
as an exhaustive guide for the conduct of judges. They should also be governed in their judicial and personal conduct by general
ethical standards. The Code is intended, however, to state basic standards which should govern the conduct of all judges and
to provide guidance to assist judges in establishing and maintaining high standards of judicial and personal conduct.
Statement of
Facts, Claims and More Definite Statements as
to F.R.C.P. 12(b)(6) “Failure to State a Claim for which Relief can be Granted.”
The following numbered averments set forth Statement of Facts, Claims and More Definite
Statements as to F.R.C.P. 12(b)(6) “Failure to State a Claim for which Relief can be Granted” as numbered averments
within properly formatted amended complaint of Michael Nazario filed timely herein.Exhibits E, D, and
F of Plaintiff Michael Nazario’s Marked Exhibit Index – Amended Complaint are supporting evidence of Statement
of Claims and More Definite Statements and are attached hereto and incorporated by reference as if fully set forth herein.
Averment No. 1.It is a fact and a claim and a more definite statement of
Michael Nazario that Judge Katherine Quaintance has censored and destroyed clerk of court stamped filed and certified service
of party testimony, evidence and lawful filings.
Averment No. 2.Defendants are respectfully
asked to please admit deny or qualify responses by further answer:Defendants Quaintance, her law clerk, Chedister, Kassler, Silverstein and Guardian
Ad Litem lawyer representation for Denise Graves and other Guardian Ad Litems were made aware of the grave and serious nature
of U.S.D.C. Plaintiff Michael Nazario’s claims presented in February 1, 2012 stamped Filed Hennepin County District Court Administrator; Michael David Nazario’s
Counter Claim Sworn Notarized Affidavit of Facts, Certified Service Notice Federal Civil Rights Claim For Damages $3,000,000.00
Nazario Marked Exhibits Index Pages 1 through 40, In Re the Matter of the Welfare of the Children of Joy
Adams Nazario, Mother and Michael Nazario, Father, Fam ID. 323598, HSPHD Case No. CP00356138, SSIS No. 267015086, Court File
No. 27-JV-117365. Certificate of Service of Michael Nazario and Proof of Service by Michael Nazario’s
legal administrative assistant, Roxanne Grinage of HireLyrics Administrative Services is attached and itemized in Plaintiff
Michael Nazario Marked Exhibit Index – Amended Complaint.
An Argument.Not an Averment.Marked
Exhibit D, excludes Exhibits 1-40 referred to pending U.S. District Court Honorable Richard H. Kyle ruling on Plaintiffs’
March 26, 2012 Motion Continue, Motion Appoint Counsel, Motion Compel Defendants Admit or Deny each numbered averment;
which will stop Defendants from circumventing Trial or Jury Trial discernment and force Defendants to undergo discovery, evidence
gathering depositions and expert witness testimony in support of their defenses for Plaintiffs’ claims against Defendants
in U.S.D.C. MN Case No. 0:12-cv-0054-RHK-AJB.See Plaintiff Michael Nazario Marked Exhibit Index
– Amended Complaint, Exhibit D.
Averment No. 3.Thereafter (See Exhibit D), Defendant Judge Katherine
Quaintance proceeded to commit fraud upon the Hennepin County Family Division Court, entering into the record of Hennepin
County Family Division Court March 6, 2012 Findings of Fact and Order which states she had considered all evidence and testimony
but only referred to the one-sided falsified case reports and by now “conspiracy kidnap for profit cover up” testimony
of Judge Katherine Quaintance’s co-defendants Karin Chedister, DHS/CPS employees and guardian ad litem employees.
Averment No. 4.Please admit or deny.Defendant Judge Katherine Quaintance,
her co-defendants Karin Chedister, DHS/CPS employees Diane Kassler and Deborah Silverstein were made aware of the following
evidence in support of the grave and serious claims made in Michael Nazario’s February 1, 2012 Counter claim Affidavit
of Facts, Notice of Civil Rights Damages $3Million:censored, destroyed ignored by Defendant Judge Katherine
Quaintance accused of continuing and worsening Legal Malpractice crimes committed in Fourth Judicial District Hennepin County
Family Division Matter captioned “In the Matter of the Welfare of the Children of Joy Nazario, Mother and Michael
Nazario, Father, FAM ID NO. 323598 CASE NO. 27-JV-11-7365.”
Averment No. 5.Defendants, please admit or deny
as to whether you have knowledge of receiving on February 1, 2012, Marked Nazario Exhibit Page 1:“Department
of Justice Form OM No. 1105-00008, Claim For Damage, Injury or Death caused by Federal Funded Agency employee(s), of Michael
David Nazario and Joy Regina Nazario, spouse, citing Date of Injury, January 20, 2012, $3 Million damages for personal injuries
incurred during Defendant Judge Katherine Quaintance tyrannical retaliation legal malpractice false arrest and imprisonment
order caused Hennepin County Sheriff Department employees to brandish firearms and point firearms toward the adult son and
daughter in law of Michael Nazario while they were holding Michael Nazario’s six month old grandson.
Averment No. 6.Please admit or deny or give qualified responses by way of
further answer.Defendant Judge Katherine Quaintance’s retaliation against Michael Nazario and Joy
Nazario is racially motivated.Michael Nazario Joy Nazario, their parents and their children embody an
example of America at its best, combining of Caucasian, African American and Latino heritages draped in lifelong (more than
twenty years) hard work, exemplary work ethic, commitment to family and community development.
Averment No. 7.Please admit or deny or give qualified responses by way of
further answer.Defendant Judge Katherine Quaintance and Defendant DHS lawyer Karen Chedister’s retaliation
January 20, 2012 false arrest unlawful imprisonment and illegal transfer of guardianship in violation of 18 USC Section 3771,
against Michael Nazario is financially motivated:both Michael Nazario and Joy Nazario are college educated,
real estate financial services and information technology professionals who met in high school at the ages of fourteen and
fifteen fell in love and raised two sons and two daughters while contributing to their children’s education, optimum
career paths in professional modeling whose professional portfolio and training paid for by Nazario Family won Michael Nazario’s
daughter American Girl Limited Edition Doll Model Commission.
Averment No. 8.Please admit or deny.Defendant Judge Katherine
Quaintance’s legal malpractice order did not protect subject children but rather placed at maximum risk of injury and
death the lives of un-armed civilians present during the January 20, 2012 Hennepin County Sheriff’s Department home
invasion, police brutality, of Michael Nazario, Joy Nazario the family including senior citizens, young adult children and
a baby while ransacking and destroying property and papers having to do with “running an Americanhousehold
and participating in Federal Lawsuit(s).
Averment No. 9.Please Admit or Deny.Neither Defendant Judge Katherine Quaintance, nor Defendant DHS lawyer Karen Chedister, nor Hennepin County Child Protective
Services Defendants, Diane Kassler, Deborah Silverstein, or their colleague Guardian Ad Litem Denise Graves, (not named a
defendant but whose person records and things are intended to be subpoenaed as a witness should this court permit trial to
proceed), owned any individual or joint responsibility for what happened to the pre-teen and teenage daughters of Michael
and Joy Nazario after the children were “thrown” with no accountability whatsoever into the Minneapolis shelter
system because of Judge Quaintance’s tyrannical order to arrest people trying to protect their children from further
injury already suffered and billed for while in the so-called “care” of child protective services as administered
by quasi-involved legal malpractice Hennepin County DHS CPS and Family Division practitioners.
Averment No. 10.Please admit or deny.Defendant Judge Katherine Quaintance owns
largest degree of culpability (blame) for causing injuries and damages suffered by Michael Nazario’s whole family on
January 20, 2012.
Averment
No. 11.Please admit or deny.Defendant Judge Katherine
Quaintance’s Order to arrest Michael and Joy Nazario was devoid any children protective services or other family preservation
consideration and violated the Minnesota constitutional and U.S. constitutional rights of Michael Nazario’s whole family.
Averment No. 12.Please admit or deny.Defendant Judge Katherine Quaintance’s
Order to throw Michael and Joy Nazario’s pre-teen and teenage daughters into a DHS billing contractor Catholic Charities
Minneapolis shelter system trampled on Child Protective Services Family Preservation regulations seeking to preserve heritage
and minimize separation trauma.Instead of protecting children, legal malpractice Judge Katherine Quaintance
is guilty of deprivation of rights under color of law;assault, aggravated assaults; abuse of police officers
in Hennepin and Ramsey Counties; and willful reckless child endangerment.
Averment No. 13.Please admit or deny.By no stretch of the imagination was Defendant Judge Katherine Quaintance’s retaliatory and capricious decision
to thrown Michael and Joy Nazario’s children’s into Minneapolis shelter system an act which could be justified
by Children’ Protective Services.
Averment No. 14.Judge Katherine Quaintance should
have demanded to learn the family preservation placement opportunities from her co-Defendant DHS lawyer Defendant Karin Chedister,
and her co-Defendants Hennepin County DHS/CPS employees Diane Kassler, Deborah Silverstein and Hennepin County Family Division
practitioner guardian ad litem Denise Graves whose falsified case reports Judge Quaintance parrots prejudicially in written
findings of facts and orders.
Averment No. 15.Please admit or deny as to whether
Defendants are aware Defendants received certified service of Michael Nazario’s Hennepin Clerk stamped February 1, 2012
Counterclaim Affidavit of Facts and Notice of Federal Civil Rights Claim for Damages $3 Million, marked as Nazario Exhibits
Index, Pre-Hearing Report on Hearing Date 01/10/2012, of County Attorney Karin Chedister where it was shown that Karen Chedister
simply passed on to Judge Katherine Quaintance the falsified case reports of Hennepin County CPS employees Defendants Deborah
Silverstein and Diane Kassler, and that a permanency review hearing had already been set but not disclosed to Joy or Michael
Nazario who were being led to believe by CPS Defendants and DHS Lawyer Defendant Karin Chedister that “the
Department (DHS) wanted to move towards dismissal.”See Exhibit D. Marked Exhibit Page D-4.
Averment No. 16.Please admit deny or offer a defense as to Hennepin County Human Services (DHS)
December 22, 2011 correspondence Re Case Number: 0015202545 02, issued by Parent Fee Unit of DHS, inflicts libel, public humiliation,
defamation andfraud of identification documents upon Michael Nazario, Joy Nazario and their children by
referring to Michael Nazario and Joy Nazario’s twenty years marriage as “sexual relations she had around the time
she became pregnant”, and asking Michael Nazario to “volunteer” to be excluded as the parent of his naturally
conceived daughter born in wedlock who Michael Nazario and Joy Nazario has vested interest of heritage, love, provision, protection,
teaching, guidance, hopes, dreams, goals and aspirations about.See Exhibit D Page D-5 attached
to this amended complaint.
Averment No. 17.Please admit or deny or offer defenses
by way of further answer as to what legal justification Defendant Judge Katherine Quaintance had for acting in complete opposition
to Minnesota Statutes and Police and Expert Witness Reports detailed by Michael Nazario’s former criminal lawyer Allan
H. Caplan’s November 29, 2011 Findings of Fact and Conclusions of Law, which were Marked in Michael Nazario’s
February 1 2012 filed Affidavits of Facts “Nazario Exhibit Index Page 30, now included with Exhibit D of Michael
Nazario’s Counterclaim marked Exhibit D pages D-6, D-7 and D8.
Averment No. 18.Plaintiff alleges that Defendant
Judge Katherine Quaintance committed legal malpractice against all the Minnesota Statutes itemized in former criminal lawyer
Allan H. Caplan’s Conclusions of Law numbers 1 through 8; and all the Findings of Facts he numbers 1 through 14, on
November 29, 2011, Hearing in Fourth Judicial
District Hennepin County Family Division Matter captioned “In the Matter of the Welfare of the Children of Joy Nazario,
Mother and Michael Nazario, Father, FAM ID NO. 323598 CASE NO. 27-JV-11-7365:
Averment No. 19.November 29, 2011, Findings of
Fact number 25 is “Although ____ in-court direct testimony and her interview with CornerHouse as reflected by the videotape
admitted at trial were both credible standing along, in light of the evidence in the record, which includes the police reports,
the results of the police search, the results of the psychosexual examination, statements made to police officers by _____
Nazario, and the testimony of Joy Nazario, Michael Nazario, Jr. and Michael Nazario, Sr., Yasiah’s allegations against
her father are not credible.
Averment No. 20.November 29, 2011, Findings of Fact number 4 is “In Officer Swanson’s
report, dated September 7, 2011, she notes that father, Mr. Nazario, passed a polygraph examination conducted by Knefelkamp
and Associates.In that examination, Mr. Nazario answered “no” to having any type of sexual
contract with ______.He answered “no” to touching _______ for any type of sexual purpose.
Averment No. 21.November 29, 2011, Findings of
Fact number 5.“Mr. Nazario agreed to take a second polygraph if he were guaranteed not to be charged
if he passed.”
Averment No. 22.November 29, 2011, Findings of Fact number 6.“In
Officer Swanson’s report dated October 31, 2011, she noted that she spoke with Investigator Rain who took a statement
from Hannah Lucille Anderson, one of _______’s sleepover friends.Hannah told Investigator Rain that
_______ told her about the sexual assault at the sleepover.Hannah also said that _____ told, another friend
of hers, ____ Hartwig, about the incidents of sexual assault.
Averment
No. 23.November 29, 2011, Findings of Fact number 7.“Officer Swanson contacted ____ Hartwig who stated that _______ never disclosed anything to her and she never
had any indication that anything inappropriate was going on.____ and her mother told Officer Swanson that
____ lied all the time and that these lies eventually caused the friendship to end.
Averment No. 24.November 29, 2011, Findings of Fact number 9.“The results
of Dr. Alsdurf’s examination were not controverted in any way during the trial.”
Averment No. 25.November 29, 2011, Findings of Fact number 14.“Dr. Alsdurf
concluded that Mr. Nazario is not in need of sex offender treatment or monitoring in the future.
Averment No. 26.November 29, 2011, Findings of Fact number 27.“The evidence
in the record, including the police reports and psychosexual evaluation, as the testimony at trial, indicates that Mr. Nazario
is a credible witness.
Averment No. 27.November 29, 2011, Findings of
Fact number 28.“At trial, no testimony was ever adduced that manifested any of the characteristics
typically seen in a child who has been sexually abused by a parent over a protracted period of time.
Averment No. 28.November 29, 2011, criminal lawyer Alan Caplan’s November 29, 2011, Conclusions
of Law identify Minnesota statutes and Children’s Protective Services Regulations which Defendants Katherine Quaintance,
Karin Chedister, Diane Kassler and Deborah Silverstein are guilty of legal malpractice.
Averment No. 29.November 29, Conclusion of Law number 3.“At a CHIPS trial,
the Court must determine whether the statutory grounds set forth in the petition ware proved by are proved by clear and convincing
evidence.In Re Welfare of B.A.B. 572 N.W.2d 776, 778 (Minn. App. 1998); See also Minn. R. Juv. Prot. P.39.0,
Subd. 1.”
Averment
No. 30.November 29, 2011 Conclusion of Law number 4.In a child protection matter, Minn Stat. Sec 260C.007, subdivision 6, requires proof that one of the enumerated child-protection
grounds exists and that the subject child needs protection or services.In re Welfare of Child of S.S.W.,
767 N. W.2d 723 (Minn) App. 2009.”
Averment No. 31.November 29, 2011 Conclusion of
Law number 5.“The Minnesota Supreme Court has long recognized the substantial and fundamental rights
of parents to enjoy the custody and companionship of their children and that a parent should not be deprived of these rights
“except for grave and weighty reasons.”In re Welfare of Rosenbloom, 266 N.W.2d 888, 889 (Minn.
1978) citations omitted).”
Averment No. 32.November 29, 2011 Conclusion of
Law number 6.“Under Minn. Stat. Section 260C.001, subd. 2(b)(3), one of the purposes of the child-protection
laws is “to preserve and strengthen the child’s family ties whenever possible and in the child’s best interests,
removing the child from the custody of parents only when the child’s welfare or safety cannot be adequately safeguarded
without removal.”
Averment No. 33.November 29, 2011 Conclusion of
Law number 7.“The record does not contain clear and convincing evidence that grounds for child protection
exist on the basis of physical or sexual abuse under Section 260C.007, subdivision 6 (2)(i).
Averment No. 34.November 29, 2011 Conclusion of Law number 8.“The
record does not contain clear and convincing evidence that grounds for child protection exist on the basis of a dangerous
or injurious environment under Section 260C.007, subdivision 6(9).
Averment No. 35.Please admit or deny or provide
Defenses for as why Defendant Judge Katherine Quaintance and Defendants Karin Chedister and Defendants Diane Kassler and Deborah
Silverstein are able to force contracts with a DHS contractor Pathways which forced Michael Nazario to pay $6,000, to admit
to guilt of something he did not do, surely cause him to lose his job, and place him at highest risk of neighborhood vigilante
assault, injury disability and death because he would be seen by community going in and out of sex offender treatment building.
Averment No. 36.If Plaintiff Michael Nazario
is fired from his job or beat up and killed because the neighborhood thinks he’s a child molester, Defendant Judge Katherine
Katherine Quaintance, Karin Chedister, CPS Diane Kassler, Deborah Silverstein will simply go on about their work day as they
did when they caused Michael Nazario’s children to be thrown in a shelter system.
Averment No. 37.Excerpt criminal lawyer Alan
Caplan’s Findings of Fact, attached as Exhibit D, pages D-6, D-7 D-8 and D-9.
Averment No. 38.The welfare of the children entrusted
to the fair and impartial findings of facts and evidence by a domestic relations adjudicator, Defendant Judge Katherine Quaintance
were not protected at all when their parents, grandparents, older siblings and baby cousin suffered home invasion, threat
of injury or death by brandished loaded firearms, destruction of property, police brutality false arrest and imprisonment
on January 20, 2012.Please admit deny or give qualifying responses by way of further answer if a defense
exists as to why Defendants Judge Katherine Quaintance and Karin Chedister should escape jury trial discernment of damages
for the trauma, child endangerment, exposure to sexual predators, drug paraphernalia, abductors, infectious disease, degradation
of family values instilled by Michael and Joy Nazario due to the malicious legal malpractice conducts of
Judge Katherine Quaintance.
Averment No. 39.Please admit or deny or offer qualified
responses by way of further answer which defendant Defendants Judge Katherine Quaintance, Karin Chedister, Diane Kassler,
and Deborah Silverstein making the traumatic and child endangering decision to throw Michael and Joy Nazario’s pre-teen
and teenager into Minneapolis shelter system in violation of Department of Human Services and federal funded Children Protective
regulations, policies and procedures intended to preserve families.If Defendants have a defense for depriving
Michael and Joy Nazario’s daughters of strong nurturing support of a tightly bound family heritage on both the mother’s
side and the father’s side, then Plaintiff hereby requests Defendants provide said defenses.
Averment No. 40.Please admit or deny whether Defendants received certified service of Michael
Nazario’s certified served by Roxanne Grinage, Public Notice, “Legal Notice and Warning Denial of Rights Under
Color of Law Violation Warning – 18 U.S.C. §242; 18 U.S.C. §245; 42 U.S.C. §1983, Marked Nazario Exhibit
Index Page 3.
Averment No. 41.Additionally, Defendant Judge Quaintance
abused taxpayers civilians, public safety and sheriff deputies when she criminalized twenty-years demonstrated protector good
provider parents to assist place two minor adolescent daughters of Michael and Joy Nazario at highest risk for injury abduction,
rape, infectious disease by “throwing” children DHS contractor-run Catholic Charities Minneapolis Shelter System.
Averment
No. 42.Defendants, please admit or deny as to whether you have knowledge
of receiving on February 1, 2012, Marked Nazario Exhibit Page 2:HireLyrics Administrative Services stamped
verified Federal Crime Victim Disclosure signed by Michael Nazario.
Averment No. 43.Defendants, please admit or deny
as to whether you have knowledge of receiving on February 1, 2012, Marked Nazario Exhibit Page 2:Federal
Crime Victim Disclosure signed by Michael Nazario, “I certify I am a Federal Crime Victim as defined by United States
Department of Justice as set forth in 18 U.S.C. §3771.”
Averment No. 44.Additionally, Defendants please
admit deny or offer by way of further answers, I, Michael Nazario observed my case information as published in standard
claims intake assessment and HireLyrics Administrative Services Legal Administrative Assistant verifications, Trial Prep Exhibits,
case study page maintained as administrative solution tool, U.S. Citizens Public Docket Database at “Minnesota families
new civil rights heroes” sub-url at a domain owned by legal administrative assistant, Roxanne Grinage, printed distributed
and discussed at March 6, 2012 hearing before Judge Katherine Quaintance.
Averment No. 45.Michael Nazario filed Counter Plaintiff’s
Motion Stay Pending Judge Katherine Quaintance Recuse Herself for Legal Malpractice Conflicts of Interest and Deprivation
of Rights Under Color of Law.
Averment No. 46.The motion attached March 2, 2012
U.S.D.C. Federal Lawsuit Complaint of Michael Nazario on behalf of Nazario Family and similarly situated Minnesotans.
Averment No. 47.On March 6, I Michael Nazario experienced first-hand Defendant Judge Katherine
Quaintance try to hand back to me the Hennepin County Family Division stamped filed Motion to Stay pending Judge Quaintance
Recuse herself claiming she did not get served with the original.Attached here is Exhibit E, Clerk Stamped
Filed March 2, 2012 Motion, Michael Nazario’s Certificate of Service and Proof of electronic certified service performed
by legal admin Roxanne Grinage after I, Michael Nazario informed her that clerk called me after stamping original and after
I left the court on the way back to work and admitted the clerk had misplaced the original.See Exhibit
E.
Averment
No. 48.Katherine Quaintance stated in open court to me, “just
because you were never charged doesn’t mean you are not guilty!Go ahead and let him dig a hole for
himself.His Complaint is going to be thrown out because it is poorly written and then we will terminate
his parental rights.”
Averment No. 49.I stated respectfully to Judge
Katherine Quaintance witnessed by the attendees in her courtroom on March 6, 2012, “You are violating my Civil Rights.”
Averment No. 50.Judge Quaintance stated to me from the bench, “You have a choice to make
– your family or your civil rights.”
Averment No. 51.I have further recorded my witness
testimony of Judge Katherine Quaintance’s judicial and Bar Association professional mis-conducts, yelling and screaming
and being rude to all litigants and parties and their representatives.I have witnessed Katherine Quaintance
yelling at CPS workers.
Averment No. 52.At the March 6, 2012 hearing, I
can’t prove that Judge Quaintance put her up to it or whether it was a combination of Defendant Chedister or CPS Kassler
and Denise Graves who the criminal lawyer we hired (Christine Groashek) for Joy Nazario broke away from a huddle with the
CHIPS hearing attendees and told Joy Nazario, “If you have any influence over your husband at all, get him to drop the
federal case.”
Averment No. 53.Prior to March 6, 2012 Family Division
Judge Katherine Quaintance presided hearing, Michael Nazario’s adolescent daughter told her therapist that Defendants
Diane Kassler, Deborah Silverstein and their colleague Guardian Ad Litem Denise Graves put the pre-teen and teenage daughters
of Michael and Joy Nazario in a room with a tape recorder, require them to rehearse scripted testimony and tell the girls,
“Now wait for us to turn on the recorder and make sure you say what we told you to say.”
Averment No. 54.Averment No. 2.Both my daughters
have, while sobbing, told CPS employees Diane Kassler and Guardian Ad Litem Program Denise Grave that“CPS
ruined our lives – I just wish you would get away from us – you have ruined our lives.”
Request
For Relief
18 USC § 1968 - Civil investigative demand
and “In no event shall the defendant be named as such guardian or representative” in accordance
with 18 USC § 3771 - Crime victims’ rights.
More Definite
Statements as to Claims of which I have first-hand
knowledge and evidence in support of are within above PLAINTIFF MICHAEL NAZARIO’S AMENDED COMPLAINT SETS FORTH PROPERLY
FORMATTED NUMBERED AVERMENTS TIMELY FILED; and below numbered averments which set forth in properly numbered averment paragraphs
itemized Relief(s) that can be Granted by a United States Federal Judge and U.S. District Court for the District of Minnesota
Jury Trial Demanded by Plaintiff Michael Nazario.
Claims are stated for which U.S. District of Minnesota can provide the following relief:
Averment
No. 1.A United
States District Court venue (Federal Court) is the only venue available to Michael Nazario on behalf of Nazario Family and
similarly situated Minnesotans Federal Crime Victims who seek the assistance of the Attorney General in accordance with Federal
Statute “18 USC § 1968 - Civil investigative demand (a) Whenever the Attorney General has reason to believe that
any person or enterprise may be in possession, custody, or control of any documentary materials relevant to a racketeering
investigation, he may, prior to the institution of a civil or criminal proceeding thereon, issue in writing, and cause to
be served upon such person, a civil investigative demand requiring such person to produce such material for examination.”
Averment No. 2.By
way of “More Definite Statements in regard to Federal Rule of Civil Procedure 12(b)(6)“Failure
to State a Claims for which Relief can be Granted,”Plaintiff Michael Nazario is the only party which
is not a judiciary official, or an American or Minnesota Bar Association official.
Averment No. 3.All of the legal representatives who
have entered appearance on behalf of Defendant officials are Hennepin County attorney’s office employed or Minnesota
U.S. Courts government employed litigators (Beth Stack and Toni Dietz, U.S. Attorney’s Office Thomas Vasaly) who are
not only in possession of legal expertise, staff, research and document production resources that out match non-attorney represented
Plaintiff Michael Nazario and his legal secretarial service, but said “heavy weight” litigators have professional
association advantage ofbeing members of the same corporate entity (Minnesota Bar Association).
Averment
No. 4.Defendant
officials have with theirlegal representatives who are also state and county officials and “high-powered”
litigators, enjoy unfair advantage having colleague camaraderie that allows them to pick up the phone and coordinate litigation
plan strategies tapping friendships and loyalties gleaned from having practiced together, not only in Hennepin County but
in the very same U.S.D.C. where Michael Nazario on behalf of Nazario Family and similarly situated Minnesotans’ grave
and serious RICO Act, Personal Injuries Legal Malpractice action is opened March 2, 2012.A pacer search
March 27th reveals Defendant Judge Katherine Quaintance and a likely relative, Charles Quaintance, Jr. are attorneys of record
in at least twenty (20) U.S.D.C. Court District Minnesota Civil Dockets.
Averment No. 5.Unfair advantage is evidenced in docket
analysis which reveals as un-noticed due date filing deadline of March 26, 2012 was issued by the Court for Defendants to
answer Michael Nazario’s 03/02/12 Complaint thirty days earlier than allowed by summons returned executed on all defendants
March 5, 2012.
Averment No. 6.Defendants
refer to Local Rule 7 which speaks to Civil Motion Practice; entered Notice Hearing June 11, 2012 which Local Rule 7 clarifies
skilled legal representation were able to get a Hearing scheduled on Defendants Motions to Dismiss, (a) attempting to circumvent
Jury Trial Demand of Plaintiff; (b) imposing hardship, scheduling the June 11, 2012 in the city of St. Paul at the convenience
of Defendant Judge Katherine Quaintance’s legal representative, Minnesota Office of Attorney General Thomas Vasaly,
and causing additional hardship in travel time, missed work and costs accrued for non-attorney represented Michael Nazario.
Averment No. 7.Respected litigator, Thomas Vasaly, who
has entered his appearance for Defendant judiciary official Defendant Judge Katherine Quaintance also has prosecutorial powers
which if wielded as Defendant Judge Katherine Quaintance has demonstrated unaccountability for child endangerment false arrest
and retaliation against litigants who seek to have their civil rights recognized in her Family Division court; threaten to
exacerbate injuries disability endangerment fraud billing and unlawful imprisonment of Michael Nazario on behalf of Nazario
Family and similarly situated Minnesotans who have already suffered irreparable and worsening harms by Defendant Judge Katherine
Quaintance’s legal malpractice conducts in Fourth
Judicial District Hennepin County Family Division Matter captioned “In the Matter of the Welfare of the Children of
Joy Nazario, Mother and Michael Nazario, Father, FAM ID NO. 323598 CASE NO. 27-JV-11-7365.
Averment No. 8.F.R.C.P.
12(b)(6) “Failure to State a Claim for which Relief can be Granted” is further satisfied by Plaintiff Michael
Nazario’s More Definite Statements.Claims of Michael Nazario are clearly stated which indicate United
States District Court Honorable Richard H. Kyle, has the necessary jurisdiction, venue and Federal Court judicial empowerments
to grant relief by Granting non-attorney represented Motions e-filed March 27, 2012:Motion Continue June
11, 2012 Hearing on Defendants’ Motions To Dismiss and correct Defendants errors in courtroom locations noticed and
Hennepin County Defendant’s lawyer Beth Stack’s errors in case caption capacities censored to alter meaning.”
Averment
No. 9.F.R.C.P.
12(b)(6) “Failure to State a Claim for which Relief can be Granted” is further satisfied by Plaintiff Michael
Nazario’s More Definite Statements.Claims of Michael Nazario are clearly stated which indicate United
States District Court Honorable Richard H. Kyle, has the necessary jurisdiction, venue and Federal Court judicial empowerments
to grant relief by Granting non-attorney represented Motions e-filed March 27, 2012:Federal Crime Witness
Plaintiff Michael Nazario’s Motion Appoint Counsel Or, In The Alternative, Continue Scheduled Hearing On Defendants’
Motions To Dismiss At Least Ninety (90) Days To Give Non Attorney Represented Plaintiffs Time To Retain Qualified Legal Malpractice
Personal Injury Attorney Representation, to fairly match the legal expertise of judge, lawyers and state employees who are,
in fact, Defendants and whose “heavy weight” Hennepin County and Minnesota governments-employed litigators have
entered their appearance on behalf of all Defendants.
Averment
No. 10.More Definite Statements clarify United
States District Court for the District of Minnesota, United States Federal Judge’s appointment of special prosecutors
is in the Public Interest and not just the sole interest of case initiated filer Michael Nazario.
Averment
No. 11.Michael Nazario on behalf of Nazario
Family and similarly situated Minnesotans are complaining about Defendants who are municipal law enforcement personnel and
District Attorney prosecutor who are unable to self police, self investigate or self-cure the extent of systematically practiced
legal malpractice to perpetrate official corruption fraud civil rights crimes practiced without accountability in furtherance
of out of control Fourth Judicial District Family Division with Hennepin County DHS and CPS Kidnap For Profit Schemes.
Averment No. 12.The
fact that the local district attorney will not prosecute his/her colleagues does not diminish the public safety emergency
posed by Defendants legal malpractice conducts.United States District Court for the District of Minnesota
and it’s judicially wise U.S. Federal Judge and referred Magistrate are the only recourse at this time for an American
family who are not skilled bar association attorneys to seek redress of real and dire grievances in a forum wherein Federal
Laws are reasonably applied to the rich and the poor fairly.
Averment No. 13.Defendants’ legal malpractice conducts create a public
safety emergency; also defraud Minnesotan taxpayers, several Whitehouse and Department of Justice court reform and judicial
accountability initiatives; U.S. Economy; the Federal and Minnesota Child Protective Services funding sources intended to
preserve families and not divide families by false statements and criminalization of domestic relations matters.
Averment
No. 14.There are many statements acts and deeds
of Defendants that are not attainable in the transcripts and records controlled by Defendants, Fourth Judicial District Hennepin
County Family Division “In the Matter of the Welfare of the Children of Joy Nazario, Mother and Michael Nazario, Father,
FAM ID NO. 323598 CASE NO. 27-JV-11-7365.
Averment No. 15.This
Court has the unique ability to Grant Relief:A United States Federal Judge has the authority to
invoke/order “18 USC § 1968 - Civil investigative demand, which will reveal those evidentiary items which exist
as audio, deposition, expert witness reports, crime scene witness testimony; deposition statements and cross-examination of
attendees of Defendant Judge Katherine Quaintance presided Fourth Judicial District Hennepin County Family
Division “In the Matter of the Welfare of the Children of Joy Nazario, Mother and Michael Nazario, Father, FAM ID NO.
323598 CASE NO. 27-JV-11-7365 heard observed experienced. Plaintiff Michael Nazario’s properly formatted numbered averments
referred to in Plaintiffs’ Motion to Compel Defendants admit or deny each numbered averment e-filed March 26, 2012,
are set forth below:
Averment No. 16.Defendant Karin Chedister is
employed by Hennepin County Attorney’s Office.
Averment No. 17.Defendant Karin Chedister is
a member of Minnesota Bar Association.
Averment No. 18.Defendant Karin Chedister is
a member of American Bar Association.
Averment No. 19.Defendant Karin Chedister is
the lawyer who represents the interests ofHennepin County Department of Human Services (“The Department
or DHS”) in the Fourth Judicial District Hennepin County Family Division Matter captioned “In the Matter of the
Welfare of the Children of Joy Nazario, Mother and Michael Nazario, Father, FAM ID NO. 323598 CASE NO. 27-JV-11-7365.
Averment No. 20.Hennepin County Department of Human Services receives federal funding for
Children Protective Services.
Averment No. 21.Hennepin County DHS employees
have various position descriptions all of which oblige state or municipal employees to dispense block grants and other federal
and taxpayer funds in accordance with their state and municipal employers’ DHS/CPS regulations, policies procedures,
guidebooks, training manuals and Minnesota State statutes.
Averment No. 22.The capacities in which Defendant
Karin Chedister is complained about in March 2, 2012 Complaint of Michael Nazario on behalf of Nazario Family and Minnesotans
similarly situated who may be unable to sue are recorded as completely as Clerk of Court’s database fields would allow;
in the Case Summary and Docket Report of U.S.D.C. for the District of Minnesota Case: 0:12-cv-00554-RHK-AJB; as set forth
in Michael Nazario’s Complaint:Assistant Hennepin County Attorney, in her individual capacity having
no immunity and largest degree of criminal culpability 18 USC 241 - Conspiracy Against Rights, 18 USC 242 - Deprivation Of
Rights Under Color Of Law, Kidnap For Profit in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365.”
Averment No. 23.By way of further More Definite Statements as to F.R.C.P. 12(b)(6) Failure
to State a claim for which Relief can be Granted”Michael Nazario’s Amended Complaint herein
sets forth properly formatted numbered averment which U.S.D.C. for the District of Minnesota is empowered to stop Defendants
from continuing censorship and destruction of evidence, false statements and tyranny they practice flagrantly in Fourth Judicial
District Hennepin Family Division; stop Defendants from seeking to side step Federal Court (which is a public record of a
court of law) adjudication of grave and serious public safety issues by attempting to Motion to Dismiss without a trial, discovery,
evidence gathering, discovery, interrogatories, jury, etc.
Averment No. 24.Michael Nazario’s More
Definite Statements as to F.R.C.P. 12(b)(6) “Failure to State a Claim for which Relief can be Granted and Exhibits
D, E, F, G, H, and I evidence U.S.D.C. of the District of Minnesota can Grant Relief by Granting Plaintiff
Michael Nazario’s Motion To Compel Defendants Admit Or Deny Each Numbered Averment Set Forth In Amended Complaint Timely
E-Filed, Pursuant to Minnesota U.S. Courts Local Rule 7.1 Civil Motion Practice, Rule 7.1(b) Dispositive Motions, L.R. 7.1(b)(2)(A)(B)
and Federal Rules of Civil Procedure Rule 15(a)(1)(A)(B), and Rule 12(b), and Pursuant to Minnesota Court Local Rule 8 General
Rules For Pleading”, 8.05 “Pleadings To Be Concise and Direct; Consistency” and Plaintiffs’ “More
Definite Statements as to Federal Rule of Civil Procedure 12(b)(6) “Failure to State a Claim for which Relief can be
Granted.”
Averment No. 25.Plaintiff has provided more definite
statements as to the Public Safety Emergency, Public Interest and heightened risk of retaliation posed by Defendants’
being officials which are complained about in accordance with 18 USC 3771 “Crime Victims’ Rights” and corrupt
official defendants having special prosecutor and litigator clout which out balances the non-attorney represented expertise
and resources of legal malpractice personal injuries devastated Federal Crime Victim Michael Nazario on behalf of Nazario
Family and Minnesotans similarly situated.
Claims are clearly
stated which indicate this Court is empowered to Grant Relief such that Federal Crime Victim Michael Nazario and my wife Joy
Nazario and my daughters are given protection from the accused and “In
no event shall the defendant be named as such guardian or representative” in accordance with 18 USC § 3771 - Crime
victims’ rights.
(e) Definitions. — For the purposes of this chapter,
the term “crime victim” means a person directly and proximately harmed as a result of the commission of a Federal
offense or an offense in the District of Columbia. In the case of a crime victim who is under 18 years of age, incompetent,
incapacitated, or deceased, the legal guardians of the crime victim or the representatives of the crime victim’s estate,
family members, or any other persons appointed as suitable by the court, may assume the crime victim’s rights under
this chapter, but in no event shall the defendant be named as such guardian or representative.
18 USC
§ 3771 - Crime victims’ rights, (a) Rights of Crime Victims. — A crime victim has the following rights:(1) The right to be reasonably protected from the accused.(2) The right to reasonable, accurate,
and timely notice of any public court proceeding, or any parole proceeding, involving the crime or of any release or escape
of the accused.(3) The right not to be excluded from any such public court proceeding, unless the court,
after receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if the
victim heard other testimony at that proceeding.(4) The right to be reasonably heard at any public proceeding
in the district court involving release, plea, sentencing, or any parole proceeding.(5) The reasonable
right to confer with the attorney for the Government in the case.(6) The right to full and timely restitution
as provided in law.(7) The right to proceedings free from unreasonable delay.(8) The
right to be treated with fairness and with respect for the victim’s dignity and privacy.(b)
Rights Afforded. — (1) In general. — In any court proceeding involving an offense against a crime victim, the
court shall ensure that the crime victim is afforded the rights described in subsection (a). Before making a determination
described in subsection (a)(3), the court shall make every effort to permit the fullest attendance possible by the victim
and shall consider reasonable alternatives to the exclusion of the victim from the criminal proceeding. The reasons for any
decision denying relief under this chapter shall be clearly stated on the record.
NOTE: AUTOMATIC NUMBERING FOR THIS SECTION LOST IT'S SEQUENTIAL ORDER BUT IS IN FACT NUMBERED
NUMBERED IN SEQUENCE IN COURT STAMPED FILED 03/30/2012 AMENDED COMPLAINT OF MICHAEL NAZARIO ON BEHALF OF NAZARIO FAMILY AND
SIMILARLY SITUATED MINNESOTANS.
EXHIBITS
Plaintiff Michael Nazario’s Marked Exhibit Index – Amended Complaint,
complies with “IMPORTANT NOTICE OF REDACTION
RESPONSIBILITY:All filers must redact: Social Security or taxpayer-identification numbers;
dates of birth; names of minor children; financial account numbers Fed. R. Civ. P. 5.2,This requirement applies to all documents, including attachments.”
Exhibit
A
Civil Cover Sheet. Clerk of Court Stamped Scanned March 2,
2012, Case 0:12-cv-00554-RHK-AJB Document 1-3 Filed 03/02/12 Page 1 of 1:Basis of Jurisdiction:Federal Question; Nature of Suit: Other Statutes 470 Racketeer Influenced and Corrupt Organizations; Cause of Action:18 USC Chapter 96-Racketeer Influenced Corrupt Organizations, 18 USC § 3771 – Crime victim’s rights,
18 USC § 242 – Deprivation of Rights Under Color Of Law.Brief description of cause: “Public
Safety Emergency Caused by Hennepin County Fourth Judicial District Family Division Deliberate Continuing and Worsening
Legal Malpractice of Minnesota Constitution Article I Bill of Rights, U.S. Economy Fraud, Kidnap For Profit.”
Exhibit
B
March 26, 2012 Docket Report U.S. District Court District of Minnesota (DMN) Civil
Docket For Case #: 02:12-cv-00554-RHK-AJB:Correctly records case details, short form and long form
captions, parties, federal question, cause of action, nature of suit; capacities as accurately as Clerk of Court’s
database fields would allow.
Plaintiff
Michael David Nazario On Behalf of Nazario Family and Minnesotans Similarly Situated Who May Be Unable To Sue
represented by
Michael David Nazario Minneapolis, MN 55418 nazariominnesotanfamilies@yahoo.com
PRO SE
V.
Defendant
Judge
Katherine Quaintance Fourth Judicial District
Family Division, in her individual capacity, having no immunity for Legal Malpractice inflicted personal injuries,
irreparable harms in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365
represented by
Thomas C Vasaly Minnesota Attorney General's Office - St Paul, MN 55101-2128 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
Karin
L Chedister Assistant Hennepin County
Attorney, in her individual capacity having no immunity and largest degree of criminal culpability 18 USC 241 - Conspiracy
Against Rights, 18 USC 242 - Deprivation Of Rights Under Color Of Law, Kidnap For Profit in re FAM ID NO.
represented by
Beth A Stack Hennepin County Attorney's Office 300 S 6th St Ste C-2000
Mpls, MN 55487 LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
Diane Kassler in
their individual and joint capacities for falsifying case reports, slander, libel, terror threats made to Plaintiff Joy
Nazario and Lying in Official Court Documents about having had meetings and conversations with Plaintiff Michael Nazario
to kidnap
represented by
Beth A Stack (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
Deborah
Silverstein in their individual and joint
capacities for falsifying case reports, slander, libel, terror threats made to Plaintiff Joy Nazario and Lying in
Official Court Documents about having had meetings and conversations with Plaintiff Michael Nazario to kidnap
represented by
Beth A Stack (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant
Hennepin
County Sheriff Department In the County's
and Department's official capacity for accountability for their sheriff deputies' and police officers' having inflicted
several acts of Police Brutality, Trauma and Risk of Death Suffered by Michael Nazario Age 35 and h
represented by
Beth A Stack (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
Exhibit
C
March 5, 2012 Summons Returned Executed Upon All Defendants.Clerk
of Court Stamped Scanned March 5, 2012, Case 0:12-cv-00554-RHK-AJB Document 2 Filed 03/05/12/12 Pages 1, 2, 3, 4, and
5.
Exhibit D
February 1 stamped Filed
Hennepin County District Court Administrator; Michael David Nazario’s Counter Claim Sworn Notarized Affidavit of Facts,
Certified Service Notice Federal Civil Rights Claim For Damages $3,000,000.00 Nazario Marked Exhibits Index Pages 1 through
40. In Re the Matter of the Welfare of the Children of Joy Adams Nazario, Mother and Michael Nazario, Father, Fam Id.
323598, HSPHD Case No. CP00356138, SSIS No. 267015086, Court File No. 27-JV-117365; Certificate of Service of Michael Nazario
and Proof of Service by Michael Nazario’s legal administrative assistant who is not a party to case and not a lawyer,
Roxanne Grinage of HireLyrics Administrative Services.
Exhibit
E
March 2, 2012 Stamped Filed in Hennepin County Family Division Counter Plaintiff
Michael Nazario’s Motion To Stay Pending Judge Quaintance Recuse Herself for Legal Malpractice Conflicts of Interest
and Deprivation of Rights Under Color of Law, and Proof of Certified Service.
Exhibit
F
Michael Nazario’s March 2, Complaint stamped Case No. 0:12-cv-00554-RHK-AJB
accurately opened and docketed by U.S.D.C. District of Minnesota incorporated into Plaintiff Michael Nazario’s Amended
Complaint by attachments Marked Exhibit F as if fully set forth herein.
United States District
Court District of Minnesota
MICHAEL NAZARIO ON BEHALF OF NAZARIO FAMILY and MINNESOTANS
SIMILARLY SITUATED WHO MAY BE UNABLE TO SUE
Federal Crime Victim Plaintiffs Pro Se,
vs.
Case No. 0:12-cv-00554
JUDGE KATHERINE QUAINTANCE Fourth Judicial District Family Division in her individual capacity, having no immunity for Legal
Malpractice inflicted personal injuries, irreparable harms in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365 Family Court, Family Justice Center
(FJC) 110 South 4th Street, Room 600 Minneapolis, MN 55401Defendant,
and
KARIN L CHEDISTER Assistant
Hennepin County Attorney in her
individual capacity having no immunity and largest degree of criminal culpability 18 USC § 241 - Conspiracy Against
Rights18 USC § 242 - Deprivation Of Rights Under Color Of Law, Kidnap For Profit in re FAM ID NO. 323598 CASE NO. 27-JV-11-7365 525
Portland AvenueSouth, Suite 1200 Minneapolis MN 55415Defendant
and
DIANE KASSLER and
DEBORAH SILVERSTEIN in
their individual and joint capacities for falsifying case reports, slander, libel, terror threats made to Plaintiff
Joy Nazario and Lying in Official Court Documents about having had meetings and conversations with Plaintiff Michael Nazario
to kidnap for profit injure and disable Nazario Family persons.
Hennepin
County Department of Health and Public Services Child Protection Services Health Services Building
– 10 L960 525 Portland Avenue South Minneapolis, MN55415Defendants
and
HENNEPIN COUNTY SHERIFF DEPARTMENT In the County’s and Department’s official capacity for accountability for their
sheriff deputies’ and police officers’ having inflicted several acts of Police Brutality, Trauma and Risk
of Death Suffered by Michael Nazario Age 35 and his wife Joy Nazario Age 33, Daughter in Law Marie Evans 18, Grandson
Terrian Smith 6 months, Son Isaiah Smith, Father in Law James Dixon Age 54, Michael Nazario Jr., Son Age 18 including
pointing loaded firearms at a six month old baby and senior citizens, while acting on the Malpractice False Arrest Unlawful
Imprisonment Order of Judge Katherine Quaintance.
Hennepin County Sheriff's Office 350 South
Fifth Street, Room 6 Minneapolis,MN55415Defendant
DEMAND FOR JURY TRIAL YES XNO ___
COMMENCEMENT OF FEDERAL LAWSUIT U.S. District of Minnesota
Clerk of Court Assigned Date:03/02/2012 Case: 0:12-cv-00554 Assigned to: Kyle, Richard H. Referral Judge: Leung, Tony N. (self recused) Description:NazarioQuaintance et al
NATURE OF SUIT:
Public Safety Emergency Caused by Hennepin County Fourth Judicial
District Family Division Deliberate Continuing and Worsening Legal Malpractice of Minnesota Constitution Article I
Bill of Rights.
FIVE CAUSES OF ACTION i.18 USC Chapter 96 - Racketeer Influenced Corrupt Organizations ii.18 USC § 1968 - Civil investigative demand iii.18 USC § 3771 – Federal
Crime Victims’ Rights iv.18 USC § 241 - Conspiracy Against Rights v.18 USC § 242 - Deprivation Of Rights Under Color Of Law
.
Exhibit G
Formerly EXHIBIT A of Michael Nazario on behalf of Minnesotan Families and similarly situated Minnesotans Complaint
opened 03/02/2012.Excerpt
Quote from Beloved Former Senator Nancy Schaefer, Deceased, From the legislative desk of Senator Nancy Schaefer 50th District
of Georgia, November 16, 2007, THE CORRUPT BUSINESS OF CHILD PROTECTIVE SERVICES, by: Nancy Schaefer Senator, 50th District;
Exhibit H
Formerly EXHIBIT B of Michael Nazario
on behalf of Minnesotan Families and similarly situated Minnesotans Complaint opened 03/02/2012.Hennepin County District Court Administrator Stamped filed
February 1, 2012,MICHAEL DAVID NAZARIO’S Counter Claim Plaintiff Pro Se COUNTER CLAIM AFFIDAVIT
OF FACTS, CERTIFIED SERVICE NOTICE FEDERAL CIVIL RIGHTS CLAIM FOR DAMAGES $3,000,000.00, NAZARIO MARKED EXHIBITS INDEX PAGES
1 THROUGH 40.
Exhibit I
Clerk Stamped CASE 0:12-cv-00554-RHK-AJB Document 16-9 Filed 03/30/12
Formerly EXHIBIT C of Michael Nazario on behalf of
Minnesotan Families and similarly situated Minnesotans Complaint opened 03/02/2012.EXHIBIT C.January 20, 2012, How 2,000 Federal Crime Victim Class Action Case Studies Innovate Champions of Patriotism 11
New Federal Laws enrich U.S. Economy Careers Education Judicial Accountability Prison and Public Safety Reform by Roxanne
Grinage HireLyrics Administrative Services.
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
American Federal Crime Victims Voter Clout
HireLyrics Jobs Creation 2012 Standard Access Pro Se Litigation Law Enforcement Intervention Audit
Legal Administrative Assistant Verification Merits
of Claim, Document Review, Docket Analysis Trial Prep Binder, Exhibits Marked Litigation Referral, Federal U.S.
Department of Justice, Minnesota State Special Prosecutors, U.S. Senate and U.S. GAO Intervention and Audit Referrals
AFFIDAVIT OF FACTS January 31, 2012
Certified Service Notice
State of Minnesota County of Hennepin Juvenile Fourth Judicial
District, Certain Bar Association Practitoners Fam No. 323598 Case 27-JV-117365 CONFLICT OF INTEREST PROFESSIONAL MALPRACTICE
ETHICS.
Hennepin County Human Service Public Health Department Children Protective
Services Field; Guardian Ad Litem Program, Parental Fee Unit, Case No. 001520254502; CPS case worker, MN State Employee
FALSIFICATION OF CASE REPORTS.
Hennepin and Ramsey Counties Sheriff Employees ILLEGAL
ENTRY BRUTALITY POINTING FIREARMS AT CIVILIANS NAZARIO FAMILY CHILDREN SENIOR CITIZENS AND A SIX MONTH OLD BABY while
in the commission of false arrest home invasion unlawful imprisonment on 01/20/12 MNCIS 27CR12-1850 / 201200373.
Federal Crime Victim Claims Verified Nazario Marked Exhibits Index 1 - 40.
MICHAEL DAVID NAZARIO Pro Se Plaintiff Counter Plaintiff
Pro Se
U.S. Economy Recovery Act Fraud and Waste, U.S.
Dept of Justice Investigation U.S. GAO Audit Requested;
Official Corruption Fraud Civil Rights, Illegal Transfer of Parental Rights via Racketeering Corrupt Organization
Act ("RICO") Kidnap For Profit Schemes;
Michael
Nazario telephoned Roxanne Grinage requesting information about HireLyrics Administrative Services. Michael Nazario
and Roxanne Grinage spoke for one hour and ½ - the call was not recorded. Michael Nazario said his wife Joy Nazario
suggested he contact HireLyrics after watching HireLyrics Youtube Channel. Michael and Joy Nazario, their children
and their family who experienced police brutality were registered as HireLyrics 1091, 1092, 1093, 1094, 1095, 1096, 1097,
1098, 1099 and 2000th Federal Crime Victims having verifiable claims of Official Corruption Fraud Civil Rights
http://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.html
01/02/2012
Michael Nazario telephoned Roxanne Grinage requesting
urgent legal administrative services to document Minnesota State Court Juvenile Division Malpractice illegally transferred
parental rights Court Ordered Child Abuse/Child Endangerment, Kidnap Trauma Injuries, False Arrest Unlawful imprisonment,
abuse of False Statements made to abuse Hennepin and Ramsey County Sheriff deputies to cause three unlawful home invasions,
sheriff deputies guns drawn and pointed toward Nazario family children, senior citizens and six month old baby and other
acts of police brutality. Michael Nazario explained that DHS was forcing Michael Nazario and his wife Joy Nazario
to sign case plan contracts which were contrary to Minnetoka Police investigation a passed polygraph test, an expert witness
report of Minnesota Licensed sexual psychological evaluation and a former private retained qualified Minnesota criminal
practice lawyer's Summation of case law violated by the State of Minnesota Fourth Judicial District Juvenile Division in
this case to date. This call is 55min is recorded and posted to U.S. Citizens controlled public docket database
standard claims intake assessment summarized as follows: http://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.html
01/22/2012 Roxanne Grinage Standard Claims Intake Assessment verifies Michael Nazario his
wife Joy Regina Nazario Adams their children Michael D. Nazario Jr, Yasiah Nazario, Veonna Nazario, Michael's Father in
Law James Dixon Age 55, Michael Rosario's Son and Son's Fiance Isaia D Smith and Marie their 6 month old baby are Federal
Crime Victims created by Measurable through Docket Analysis Official Corruption Fraud Civil Rights Crimes Judicial Tyranny
in Retaliation for American Family Rosario demand their Civil Rights to Due Process - Hennepin County Minnesota and Ramsey
County Sheriffs Deputies and Local Law Enforcement were abused by the Threat of False Arrest and Unlawful Imprisonment
declared by a corrupt Domestic Relations Judge Kathryn L. Quaintance who is documented for spearheading what the evidence
gathering depositions and expert witness testimony are standard modus operandi of a Racketeering Corruption Influenced
Organization (RICO) Indictable Kidnap For Profit Scheme where the following officially positioned people are culpable
for measureable degrees of criminal malpractice culpability which resulted in Hennepin and Ramsey Counties Minnesota Law
Enforcement being abused to cause the multiple breaking and entering home invasion guns drawn and actually pointed to
a six month old baby: This audio file is available for free download and posted as a case study and a teaching segments
as to how Federal Crime Victims can utilize the Collaborative powers of internet technologies to organize voter clout,
gather evidence and report verified claims in Federal Pro Se Lawsuits and Dept of Justice Claim Forms and Damages Claims
with the growing recognition American U.S. Economy Education and Public Safety Jobs Expansion 2012 recognize Law Enforcement
are Working Class People Too and Federal Crime Victims are not complaining about amorphous unaccountable government as
much as we have verified evidence reported as due diligence to highest levels of law enforcement and U.S. Senate, special
prosecutors lawmakers and funding source decision makers U.S. government accountability office as to why there is a Public
Safety Intervention need in local jurisdictions where the conflict of interest nepotism and malpractice becomes the acceptable
standard unable to cure or correct the corruption poisoned jurisdiction: State of Minnesota County of Hennepin District
Court Juvenile Court Fourth Judicial District In the Matter of the Welfare of the Children of Joy Adams aka Nazario, Parent
Michael Nazario, Parent Children: Michael D Nazario Jr dob 1994, Yasiah Nazario dob 1996, Veonna Nazario dob 2000 Order
For CHIPS Adjudication and Protective Supervision Fam No. 323598 Case No. 27-JV-11-7365 Presided: Kathryn L. Quaintance,
Appearances (for examining and measuring conflict of interest professional misconduct malpractice or negligence) Karin
L. Chedister, assistant Hennepin County Attorney, Diane Kassler, Social Worker Hennepin County Human Services and Public
Health Department, Charles Clippert, attorney for mother, Allan Caplan, attorney for the father, Carrie Prentice, Assistant
Hennepin County Public Defender, appeared for the child Yasiah, Colin Nelson, Alternate Public Defender, appeared for
child Veonna, Todd Kenyon, Attorney for Guardian ad Litem, Denise Graves, Guardian ad Litem. This audio file is 55 minutes
is an mp3 and free download. Strongest Prayers for the rescue of Kidnap For Profit injured Children of All Ages, Respectfully
Roxanne Grinage, Legal Administrative Assistant Project Manager, HireLyrics Administrative Services "Prayer and a U.S.
Citizens (controlled) Public Docket Database will engage slow and heal a nationwide Child Slaughter U.S. Economy Fraud
Court and Education Reform Public Safety Emergency." https://docs.google.com/leaf?id=0B_UmvYpq4WCUNjM1MDY3MmYtNGI2My00MTlhLTg3ZGEtNDVkM2JjNDdlNjI2&hl=en_US
Nazario Marked Exhibit Index Page 2, Page
3, Page 4, Page 5. Michael Nazario notarized eighteen pages fax received: HireLyrics Form of Employment
Agreement Retain Roxanne Grinage Legal Administrative Assistant enclose (1) Federal Crime Victim Disclosure 18 U.S.C. §3771;
(2) Form COL Legal Notice and Violation Warning Denial of Rights Under Color of Law 18 U.S.C. §242 18 U.S.C. §245;
42 U.S.C. §1983; (3) Authorization For Release of Information (4) Revocation of Authorization For Release of Information.
01/26/12 Nazario Marked Exhibits Index HireLyrics Administrative Services Received Federal Crime Victim Disclosure Release
and Revocation of Release Legal Notice and Warning Violation Denial Rights Under Color of Law.pdf http://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.htmlhttps://docs.google.com/open?id=0B_UmvYpq4WCUOTI3ZTM3MzQtZWFhNS00MWE3LTg3MjYtODAxN2EwMzA4NGIw
Nazario Marked Exhibit Index Pages 6, 7,
8, 9 01/31/12 Nazario Marked Exhibit Index Education Real Estate Financial Services IT Tech
Attorneys Fees Psyche Evaluation James Alsdurf Ph.D. Receipt Polygraph expert David Knefelkamp Retainer Caplan Tamburino
MN, ENTER INTO THE RECORD of State of Minnesota County of Hennepin Juvenile Division Fourth Judicial District, In the
Matter of the Welfare of the Children of Joy R. Adams Nazario and Michael Nazario, Parents, Fam ID. 323598; HSPHD Case No.
CP00356138, SSIS No. 267015086, Case No. 27-JV-11-7365.pdfhttp://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.html
Michael Nazario 02/01/2012 Pro Se: WHEREFORE, STATE OF MINNESOTA FOURTH
JUDICIAL DISTRICT JUVENILE DIVISION JUDICIARY and/or Honorable Katherine Quaintance are compelled by Minnesota Law, CPS
Regulations and U.S. Constitution to invoke judicial wisdom and 28 USC 453 Solemn Oath of Justices and Judges:
"I do solemnly swear (or affirm) that I will administer justice without respect to persons, and do equal right to
the poor and to the rich, and that I will faithfully and impartially discharge and perform all the duties incumbent
upon me as under the Constitution and laws of the United States. So help me God", such that the Counter Plaintiff
Pro Se MICHAEL DAVID NAZARIO'S respectful pleading, this Court enter and enforce without further delay the following Orders
to end DHS corruption Court Ordered suffering of American Family Nazario: Order Hennepin County Human Services & Public
Health Department Child Protection Field Unit, Guardian Ad Litem Program and Parental Fee Unit to pay to Counter Plaintiff
Pro Se MICHAEL DAVID NAZARIO all demonstrable costs (not damages - costs) that Michael and Joy Nazario can demonstrate are
paid or still owed; extorted by way of DHS corruption forced contracts fraud billing non-applicable case plan(s); false
allegations; false arrest and unlawful imprisonment bail, interest, penalties, attorneys fees and expert witness reports
and legal administrative assistant professional consultant service retained, accumulated in an amount of no less than $20,000.00
to date and growing. Order DHS employees to say what their credentials are that qualify a case worker to contradict
thorough Police Criminal Investigation, qualified Written Summation of MICHAEL DAVID NAZARIO'S former lawyer Allan H.
Caplan, Esquire; qualified findings of expert, David E. Knefelkamp & Associates administered Polygraph Test, qualified
expert witness sexual psychological evaluation of James M. Alsdurf, Ph.D., L.P., my wife's testimony on November 29, 2011
wherein Joy Nazario asked our daughters time and time again if they knew they could come to her if anyone said something
or did something sexual or if anyone made them feel uncomfortable that they could come to her and she would protect them.
https://docs.google.com/viewer?a=v&pid=explorer&chrome=true&srcid=0B_UmvYpq4WCUNDViNTFjMzMtYWRiMi00MTY2LTg3NjMtZTNiNDFhN2UxMDY1&hl=en_US
01/31/2012
Nazario Marked Exhibit Index Page 1.
01/31/12 Michael Joy Nazario v State of Minnesota Hennepin Human Services CPS Field Unit Guardian Ad Litem Program Parental
Fee Unit signed Dept Justice Form 95 Claim For Damage Injury "State in detail the known facts and circumstances attending
the damage, injury, or death identifying persons and property involved, the place of occurrence and the cause thereof:
HENNEPIN COUNTY HUMAN SERVICES & PUBLIC HEALTH DEPARTMENT, CHILD PROTECTION UNIT and GUARDIAN AD LITEM PROGRAM and
PARENTAL FEE UNIT: Debbie M. Silverstein / HSPS / Hennepin MSW, LICSW Supervisor, Child Protection Field did censor
omit and falsify case reports submitted to Christine Spaulding and Karin Lynn Chedister, Hennepin County Attorney's Office
Child Protection Division who committed Fraud Upon The Court by Entering for adjudication Falsified Case Reports which
results in Honorable Kathryn Quaintance having illegally transferred parental rights in violation of rights under color
of law 18 U.S.C. §242, 18 U.S.C. § 245; 42 U.S.C. § 1983; in violation of U.S. Attorney General's definition
of Official Corruption Fraud Civil Rights, 18 U.S.C. §3771;. abuse of Hennepin and Ramsey counties Sheriff employees
who perpetrated three counts of unlawful entry police brutality pointed firearms on Nazario family children senior citizens
and a six month old baby to enforce the Fourth Judicial District Juvenile Division Court Ordered Abuse of Nazario children
thrown into Catholic Charities funded DHS contractor provider beneficiary St Joseph's Minneapolis Shelter System at highest
risk of exacerbated injuries and exposure to sexual predators. http://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.html $3,000,000.00.pdf https://docs.google.com/open?id=0B_UmvYpq4WCUOWUwNDNiYzUtNWExMS00ZjJlLWE1MDUtZTgzNmM1YzNjN2Ni
01/31/2012
01/31/12 Notarized Michael David Nazario's
Counter Plaintiff Pro Se Counter Claim Affidavit of Facts, Certified Service Notice Federal Civil Rights Claim For Damages
$3,000,000.00, Nazario Marked Exhibits Index Pages 1 through 40, ENTER INTO THE RECORD
of State of Minnesota County of Hennepin Juvenile Division Fourth Judicial District, In the Matter of the Welfare of the
Children of Joy R. Adams Nazario and Michael Nazario, Parents, Fam ID. 323598; HSPHD Case No. CP00356138, SSIS No. 267015086,
Case No. 27-JV-11-7365.
PROOF OF CERTIFIED SERVICEVIA ELECTRONIC (EMAIL) TRANSMISSION
MICHAEL DAVID
NAZARIO will present printed proof of certified service of enclosed true and correct copies via electronic (email) transmission
to Clerk of Court for ENTRY INTO THE RECORD of State of Minnesota County of Hennepin Juvenile Division Fourth Judicial
District, In the Matter of the Welfare of the Children of Joy R. Adams Nazario and Michael Nazario, Parents, Fam ID. 323598;
HSPHD Case No. CP00356138, SSIS No. 267015086, Case No. 27-JV-11-7365, today February 1, 2012.
On behalf of Pro Se litigant Michael Nazario, please find enclosed links to true and correct Certified
Service or Courtesy Copies which will be presented to Clerk of Court for filing today, Michael David Nazario's Counter
Claim Affidavit of Facts, Certified Service Notice Federal Civil Rights Claim For Damages $3,000,000.00, Nazario Marked
Exhibits Index Pages 1 through 40. These documents may be accessed as evidence is verified and authorized
posted to U.S. Citizens Public Docket Database litigation referral case study page maintained by HireLyrics Administrative
Service at http://hirelyrics.org/minnesotafamiliesnewcivilrightsheroes.html.
2 of 2 Nazario Exhibits Index Pages 18 - 40 and Correspondence Certified Service True Correct Service Copy Filed 02-01-12
Michael Nazario Pro Se Counter Claim Affidavit of Facts Notice Fed Civil rights claim Damages 3M Nazario Exhibits 1 thru
40.pdf https://docs.google.com/open?id=0B_UmvYpq4WCUMGNlOGU1MzItODUwMy00NGNkLWI1Y2ItY2I2ZmU3ZmY4NmRi Thank you, Roxanne Grinage Legal Administrative Assistant to Michael David Nazario, Fax: (215) 405-2939 mikenazariosr@gmail.com electronic service requested
02/01/2012
Counter Claim Plaintiff Pro Se Michael David Nazario Minneapolis MN 55418 Fax: (215) 405-2939 mikenazariosr@gmail.com electronic service requested
STATE OF MINNESOTA
DISTRICT COURT
COUNTY OF HENNEPIN
FOURTH JUDICIAL DISTRIC FAMILY COURT DIVISION
In Re the Matter of the Welfare of
the Children of:
Joy Adams Nazario, Mother
Michael Nazario,
Father
Children: Veonna
Nazario, Age 11 Yasiah Nazario, Age 15
MICHAEL
DAVID NAZARIO'S
Counter Claim Plaintiff Pro Se
COUNTER
CLAIM AFFIDAVIT OF FACTS,
CERTIFIED SERVICE NOTICE FEDERAL CIVIL RIGHTS CLAIM FOR DAMAGES
$3,000,000.00,
COMES NOW, MICHAEL DAVID NAZARIO, a
resident of Minnesota invoking State of Minnesota Constitutional right to petition Minnesota State Court on my own behalf,
in my own right, for redress of grievances, non-attorney represented counter plaintiff pro se, and hereby
1.
ENTER INTO THE RECORD of State of Minnesota County of Hennepin Juvenile Division Fourth Judicial District, In the
Matter of the Welfare of the Children of Joy R. Adams Nazario and Michael Nazario, Parents, Fam ID. 323598; HSPHD Case
No. CP00356138, SSIS No. 267015086, Case No. 27-JV-11-7365, the following
2.
Counter Claim Affidavit of Facts, Certified Service Notice Federal Civil Rights Claim For Damages $3,000,000.00,
Nazario Marked Exhibits Index Pages 1 through 40, which verify breached integrity of DHS case reports as passed
by DHS employee(s) to and entered by Attorney for DHS Karin Lynn Chedister, which have inflicted Fraud upon a Minnesota
State Court through falsification of case reports, lying in official court documents and destruction of evidence in
the best interest of children, and
3.
Inflict on-going DHS kidnap for profit injuries inflicted upon MICHAEL NAZARIO and JOY NAZARIO'S American
family.
4.
Counter Plaintiff Pro Se MICHAEL NAZARIO believes our particular working class family has been targeted
as an extortion victim by Racketeering Influenced Corrupt Organization Kidnap For Profit Schemes of a few State of Minnesota
DHS employees to perpetrate extortion, fraud billing, Recovery Act Fraud and Waste, because we are accomplished skilled
technicians making U.S. Economy enriching careers contributions to our children and our community, employed by a global
financial services bank.
6.
The initial reporter was a neighbor who Nazario Family lived near for three years, who our daughters visited from time
to time but after one of our daughters told us she witnessed drugs in baggies in the house, our former neighbor and abuse
reporter 54 years old caucasian Raven Straight forced my daughter to go to the police station with false allegations against
me COUNTER PLAINTIFF PRO SE MICHAEL NAZARIO, in retaliation for me and my wife not allowing our daughters
to go back to her home where her adult daughters' and their boyfriends' drug use and drug dealing activities had been
exposed by our daughters telling us what they witnessed in Raven Straight's home.
7.
I, MICHAEL DAVID NAZARIO, Counter Plaintiff Pro Se, have reported United States Department of Justice
Form Approved OMB No. 11105-0008 CLAIM FOR DAMAGES, INJURY OR DEATH caused by the actions of a federally
funded agency or state employee, having verified Counter Claim Affidavit of Facts, Certified Service Notice Federal
Civil Rights Claim For Damages $3,000,000.00, Nazario Marked Exhibits Index Pages 1 through 40, proving
facts and circumstances attending the damage, injury or death identifying persons and property involved, the place of
occurrence and the cause thereof, HENNEPIN COUNTY HUMAN SERVICES & PUBLIC HEALTH DEPARTMENT, CHILD PROTECTION
UNIT and GUARDIAN AD LITEM PROGRAM and PARENTAL FEE UNIT: Debbie M. Silverstein / HSPS / Hennepin MSW,
LICSW Supervisor, Child Protection Field did censor omit and falsify case reports submitted to Christine Spaulding and
Karin Lynn Chedister, Hennepin County Attorney's Office Child Protection Division who committed Fraud Upon The Court by
Entering for Your Honor's adjudication Falsified Case Reports which results in Honorable Kathryn Quaintance having illegally
transferred parental rights in violation of rights under color of law 18 U.S.C. §242, 18 U.S.C. § 245; 42 U.S.C.
§ 1983; in violation of U.S. Attorney General's definition of Official Corruption Fraud Civil Rights, 18 U.S.C. §3771.
8.
Also in violation of State of Minnesota Statutes Section 260C.001 Subdivision 2(b)(3); Section 260C.007, Subdivision
6(2)(i) sec 260C.007 Subdivision 6(9) dishonest malpractice DHS employee misconduct has resulted in HENNEPIN and
RAMSEY COUNTIES SHERIFF OFFICES suffering civil rights lawsuit liability: three (3) counts illegal entry,
police brutality, pointing firearms arms at American Family, children, senior citizens and a six month old baby, false arrest
and unlawful imprisonment, aiding and abetting DHS verified Racketeering Kidnap For Profit Schemes while inflicting personal
injuries and optimizing risk of injury or death.
9.
Also in violation of Child Protection Services funding guidelines DHS records mismanagement whether incompetently or
deliberately performed has resulted in Recovery Act Fraud and Waste as evidenced in Nazario Marked Exhibits Index
Pages 1 through 40.
WHEREFORE, STATE OF MINNESOTA FOURTH JUDICIAL DISTRICT JUVENILE DIVISION JUDICIARY and/or Honorable Katherine Quaintance
are compelled by Minnesota Law, CPS Regulations and U.S. Constitution to invoke judicial wisdom and 28 USC 453 Solemn
Oath of Justices and Judges: "I do solemnly swear (or affirm) that I will administer justice without respect
to persons, and do equal right to the poor and to the rich, and that I will faithfully and impartially discharge
and perform all the duties incumbent upon me as under the Constitution and laws of the United States. So help me
God", such that the Counter Plaintiff Pro Se MICHAEL DAVID NAZARIO'S respectful pleading, this Court
enter and enforce without further delay the following Orders to end DHS corruption Court Ordered suffering of American
Family Nazario:
Order DHS CEASE AND DESIST chronic ongoing infliction of separation trauma maximum risk of abuse
injury and exposure to sexual predators in St. Joe's Minneapolis Shelter System;
Order the immediate return of Yasiah and Veonna to the protective nurturing care of their mother Joy Nazario who with
her husband their father Michael Nazario have demonstrated a greater vested interest in providing best quality of life
for their children than has any corrupt or inept Child Protective Services employee of Hennepin County Health Department
now verified by docket analysis and evidence gathering to have falsified case reports to maximize fraud billing in the
best interest of DHS contractor providers and not Nazario children's safety;
Order DHS employees and Attorney for DHS Karin Lynn Chedister to produce evidence supporting allegations of sexual misconduct
of Michael Nazario other than the contrived case reports of a field social worker;
Order DHS employees to say what their credentials are that qualify a case worker to contradict thorough Police
Criminal Investigation, qualified Written Summation of MICHAEL DAVID NAZARIO'S
former lawyer Allan H. Caplan, Esquire; qualified findings of expert, David E. Knefelkamp
& Associatesadministered Polygraph Test, qualified expert witness sexual
psychological evaluation of James M. Alsdurf, Ph.D., L.P., my wife's testimony on November 29,
2011 wherein Joy Nazario asked our daughters time and time again if they knew they could come to her if anyone
said something or did something sexual or if anyone made them feel uncomfortable that they could come to her and she would
protect them;
Order Hennepin County Human Services and Public Health Department Child Protection Field Unit and Guardian Ad Litem Program
and Parental Fee Unit to CEASE AND DESIST all attempts to force Nazario family into unwanted non-applicable
case plans or other contracts with Minnesota State DHS contractor providers;
Order Hennepin County Employees to STAY AWAY FROM NAZARIO FAMILY UNTIL SUCH TIME AS THIS COURT makes RULING FINDINGS
OF FACT based on Honorable Court's qualified judicial examination of verified evidence gathered depositions claims assessment
expert and witness testimony submitted herewith. See Nazario Marked Exhibits Index Pages 1 through 40;
Order Hennepin County Human Services & Public Health Department Child Protection Field Unit, Guardian Ad Litem Program
and Parental Fee Unit to pay to Counter Plaintiff Pro Se MICHAEL DAVID NAZARIO all demonstrable costs (not
damages - costs) that Michael and Joy Nazario can demonstrate are paid or still owed; extorted by way of DHS corruption
forced contracts fraud billing non-applicable case plan(s); false allegations; false arrest and unlawful imprisonment
bail, interest, penalties, attorneys fees and expert witness reports and legal administrative assistant professional consultant
service retained, accumulated in an amount of no less than $20,000.00 to date and growing.
LASTLY, DHS Corruption victim MICHAEL DAVID NAZARIO, Counter Plaintiff Pro Se asks this Honorable Court
to Order DHS to issue written apology letter that Michael and Joy Nazario may present to their Financial Services Industry
Employer and our trauma parent alienation injured children. Counter Plaintiff Pro Se MICHAEL DAVID NAZARIO
and my wife JOY NAZARIO were irreparably harmed by the results of false allegations slander and defamation
of DHS employee misconduct malpractice. We are skilled law abiding community conscience U.S. Economy careers contributors,
making contributions to education, community development and a better way of life for our children until we were forced
to become Federal Crime Victim Witnesses due to egregious official corruption fraud civil rights crimes inflicted by Hennepin
County Human Services & Public Health Department Child Protection Field Unit, Guardian Ad Litem Program and Parental
Fee Unit destroyed Nazario Family's heritage, health, education, U.S. Economy enriching careers contribution, freedom and
future.
Respectfully submitted _______________________________________ Michael
David Nazario, Counter Claim Plaintiff Pro Se Minneapolis MN 55418 Tel: (952)
Fax: (215) 405-2939 electronic service requested
STATE OF ______________ ) COUNTY OR DISTRICT ) ________________________ )
Subscribed
and sworn to or affirmed before me at
(city),
(state) On (date).
(NOTARY SEAL)
Clerk of Court, Notary Public or other person authorized
to administer oaths. ________________________________ My commission expires:
CERITIFICATE OF SERVICE (Service Distribution List
Attached on Separate Sheet)
I certify that I caused the foregoing Counterclaim Affidavit of Fact Notice of Federal Civil Rights Damages Claim $3,000,000.00
to be transmitted to the official contact addresses as indicated by electronic mail (email) on January 31, 2012 in time
to be received by all parties by scheduled February 1, 2012 Court Hearing, or that I mailed courtesy copies as shown on
attached Certified Service Distribution List via first class mail postage prepaid on February 1, 2012.
January 31, 2012 __________________________MICHAEL DAVID NAZARIO
FOOTNOTE 1 FOOTNOTE
2
[1] See Nazario Marked Exhibit Index. U.S. Department of Health and Human
Services Administration for Children and Families; Administration on Children, Youth and Families Children's Bureau, Office
on Child Abuse and Neglect, Child Abuse and Neglect User Manual Series. Child Protective Services: A Guide For Caseworkers.
Reviewers, Technical Advisory Panel Page 4 Acknowledgements; Developed under the guidance and direction of Irene Bocella,
Federal Task Order Officer, and Catherine Nolan, Director, Office on Child Abuse and Neglect, Bob Scholle, Independent
Consultant Pittsburgh Pa, Brad Wilcox, Ph.D. University of Virginia, Department of Sociology Charlottesville, VA; Pages
25 - 27, Responsibility of Child Protective Services: Intake, Initial Assessment or Investigation, Family Assessment;
Case Planning; Service Provision; Family Progress; Case Closure.
2 See Nazario
Marked Exhibit Index. University of Minnesota College of Education and Human Development Center for Advanced Studies in
Child Welfare. Practice Notes. Supervision: The Key to Strengthening Practice in Child Welfare: How do you
encourage staff to be careful and clear on documentation? Ethical Considerations in Supervision: Two principles
underlie malpractice actions and parallel how a regulatory body such as the Board of Social Work might analyze a situation
regarding negligence in supervision: Vicarious Liability - The supervisor in child protection is assumed to direct
and review the work of a staff member. If an error in judgment harms the family or child, the supervisor may be
held responsible, simply because they are the supervisor (the legal theory of "respondeat superiori" - let the
master respond to the failure of the subordinate). Negligence - Specific errors and omissions of the supervisor such
as inattention to substandard work, failure to properly instruct staff, giving inadequate directions, etc. ("What would
a reasonable and prudent supervisor have done in the same or similar situation?"). Page 4 and 11. Adapted
from Schoener, G.R. (2008). Clinical Supervision: Ethics, boundaries, & practice issues. Walk-in
Counseling Center, 2421 Chicago Avenue S., Minneapolis, MN 55404.
02/01/12 Authorized Posted
to HireLyrics Administrative Services managed Litigation and Evidence Reporting Case Study Page: Minnesota
Families New Civil Rights Heroes: Please come back regularly to see itemized Exhibits Index and Pleading Open Text with
active links to each document official Department of Justice Claim for Damage Forms contacts to Minnesota Human
Rights Civil Rights organizations and a directory Father's and Men's Rights resources in Minnesota
and in the United States. All CPS corruption in government victim Americans can benefit by learning about
State Court and Federal Court compliance for pro se actions we can take on our own behalf and Federal Crimes Victims created
by official corruption fraud civil rights will be empowered when we learn law abiding Americans who love our nation too much
to fail can interface in our own right in Department of Justice Claims and State Treasurers Unclaimed Property Claims. "A
New Civil Rights Movement is underway in these United States...Families Fight Back, say NO MORE! DHS Demonic Horror Stories! HireLyrics
Administrative Solutions Series demonstrates we are well on the way to utilizing the shared learning afforded by
"free and low cost internet technologies" to creating virtual and brick and mortar "All Neighbors
Welcome Community Meeting Places, where anyone may present regardless of who you know or what you have, to act lawfully
but assertively to strategize and implement solutions for saving the soul of our cities, our states indeed for saving
the soul of our nation." "Docket Never Lies...Individual Accountability for Child Slaughter U.S. Economy Fraud
Court and Education Reform Public Safety Emergency is measurable in Docket Analysis!" Strongest prayers and always
remember there are more good people than bad people. There are more ethical qualified professionals lawmakers and law
enforcement who took their oaths to protect public safety and uphold our states and U.S. Constitutions. That is why
HireLyrics Administrative slogan which marks our Department of Justice and other grant funding applications to realize all
states chapter heads community development jobs creation 2012 recognizes "Law Enforcement are Working Class People Too."
No matter how financially devastated the federal crime victim claimant can utilize the collaborative powers of free and low
cost internet technologies to galvanize grassroots community based voter and lobby group endorsement and impeachment constituency
clout. Federal Crime Victim Voter Statement: If one of us should fall or ten of us should fall or a hundred
of us should fall, WE WILL HAVE A COMMUNITY NEEDS PERSONALITY INDEPENDENT MECHANISM IN PLACE TO AUTOMATICALLY TRIGGER THE
RESCUE OF KIDNAP FOR PROFIT INJURED CHILDREN OF ALL AGES. Strongest prayers, roxanne grinage.
AFFIDAVIT OF FACTS
January 31, 2012 Certified
Service Notice State of Minnesota County of Hennepin Juvenile 4th Judicial District; All Bar Assoc.
Practitioners, Fam. No. 323598 Case 27-JV-117365PROFESSIONAL MALPRACTICEHennepin County Human Service Public Health DepartmentCase No 001520254502FALSIFICATION
OF CASE REPORTS Hennepin and Yancey Counties Sheriffs3 COUNTS ILLEGAL ENTRY BRUTALITY POINTING FIREARMS AT NAZARIO FAMILY CHILDREN & BABY.
01/20/12 MNCIS 27CR12-1850 / 201200373
Nazario Exhibit Index Page 1.NOTICE DAMAGES CLAIM $3,000,000
Federal Crime Victim ClaimantMICHAEL DAVID NAZARIOPro Se Plaintiff Counter Plaintiff Pro Se
·U.S. Economy Recovery Act Fraud and Waste, U.S. Dept of Justice Investigation U.S.
GAO Audit Requested;·Official Corruption Fraud
Civil Rights, Illegal Transfer of Parental Rights via Racketeering Corrupt Organization Act (“RICO”) Kidnap For
Profit Schemes;·Malpractice Personal Injuries False
Arrest Unlawful Imprisonment Police Brutality Defamation, Trauma, Parent Alienation Trauma
Legal Malpractice Personal Injury Attorney Wanted Nazario v. Quaintance U.S.D.C. MN 0:12-cv-00554-RHK-AJB
Michael Nazario Family v Hennepin County CPS/DHS
HireLyrics 2000 Federal Crime Victim Voters Case Studies Propose 11 Laws Judicial Accountability
U.S.D.C. MN Nazario v Quaintance et al 012-cv-00554-RHK-AJB
Michael David
Nazario , Sr., Yasiah Olivia Mahaliya Nazario, Michael David Nazario, Jr., Veonna Veona Nazario, Joy Regina Adams-Nazario
and Russell Jay Gould
Defendants:
Karin Chedister, Dave Adney, Pete Dymit, Diane Kassler, Nadia Vostad, Alan H. Caplan, Charles Clippert, Carrie
Prestice, Colin T. Nelson, Denise Graves, Michael Eggers and Kathryn L. Quaintance
Who
has authentic interest in Heritage Health Education U.S. Economy Careers Freedom and Future of Michael and Joy Nazario's daughters,
examples of everything great about American Life and Liberty? Nazario, A White American African American Latino American Family
of College Graduates IT Technicians Real Estate/Financial Services professionals who gave their children and community the
best education and career opportunities until targeted for Kidnap For Profit, Forced Commerce Fraud Billing of certain State
of Minnesota DHS/CPS Employees whose official corruption fraud civil rights crimes personal injuries and $10,000,000 Damages
Irreparable Harms are exacerbated by Judicial Negligence and Bar Association Lawyers' Professional Misconduct in County of
Hennepin Fourth Judicial District FAMILY DIVISION Case No. 27-JV-11-736.
Veonna Nazario
is an American Girls Doll® model and Federal Crime Victim with her sister, Yasiah Nazario and Nazario Family.
PROOF OF CERTIFIED
SERVICE VIA ELECTRONIC (EMAIL) TRANSMISSION
MICHAEL DAVID NAZARIO will present printed proof of certified
service of enclosed true and correct copies via electronic (email) transmission to Clerk of Court for ENTRY INTO THE RECORD
of State of Minnesota County of Hennepin Juvenile Division Fourth Judicial District, In the Matter of the Welfare of the Children
of Joy R. Adams Nazario and Michael Nazario, Parents, Fam ID. 323598; HSPHD Case No. CP00356138, SSIS No. 267015086, Case
No. 27-JV-11-7365, today February 1, 2012.
Thank you, Roxanne Grinage Legal Administrative
Assistant to Michael David Nazario, Counter Claim Plaintiff Pro Se Michael David Nazario Minneapolis MN 55418 Fax:
(215) 405-2939 mikenazari @gmail.com electronic service requested Roxanne Grinage, Legal Administrative
Assistant HireLyrics Administrative Services U.S. Citizens Public Docket Database PO Box 22225 Philadelphia
Pa 19136 267-444-0594 Fax 215-405-2939 http://www.hirelyrics.org/ www.Twitter.com/HireLyrics
Internet Explorer 8.0 Mozilla/4.0 (compatible; MSIE 8.0; Windows NT 6.1; WOW64; Trident/4.0; SLCC2; .NET CLR
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From: Roxanne Grinage <roxannegrinage@yahoo.com> To:
"mikenazariosr@gmail.com" <mikenazariosr@gmail.com>; "jnazario6@aol.com" <jnazario6@aol.com>
Sent: Wednesday, February 1, 2012 11:04 AM Subject: 02/01/12 HireLyrics.org Tracker
Stats Show Minnesota US Government Servers Respond To Nazario Certified Service Notice of Federal Civil Rights Damages $3M
Seriously. Fw: In the Matter of the Welfare of the Children of Joy R. Adams Nazario and Michael Nazario, Parents, Fam ID.
323598; HSPHD Case No. CP00356138, SSIS No. 267015086, Case No. 27-JV-11-7365, today February 1, 2012.
Dear Michael and Joy, see tracker stats of this morning after forwarded proof of certified service true and correct
copies of Michael Nazario's intended filed today. Stand and Hold. Strongest Prayers, rox
