Click through for the complaint, filed in Pierce Superior Court, September 13.
Douglas L. Tooley, Washington Voter, in Propria Persona
P.O. Box 3135
Durango, CO 81302
doug@motleytools.com
SUPERIOR COURT OF PIERCE COUNTY
STATE OF WASHINGTON
Douglas L. Tooley,
Plaintiff,
vs.
Cascade Land Conservancy, Green Tacoma Partnership, Washington Native Plant Society, Tahoma Audubon Society, City of Tacoma, METRO Parks Tacoma, Ruth Anna Thurston, Catherine Hovanic, Alisa O’Hanlon, Christopher Ott, Ryan Mello, Marilyn Strickland, Jake Fey, Bill Baarsma, Victoria Woodards, Marty Cambell, Lauren Walker, Eric Anderson, Christopher T. Gilliand, Gene Duvernoy, Nick Harper, Carol Sanders (WSBA#605), Aimee Welch (WSBA #40642) Craig Benjamin, Krystal Keyer, Bryan Flint, Dan Fear, Edwina Magrum, et al,
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COMPLAINT
This Complaint alleges specific instances of a conspiracy to control the land use and public capital expenditures of the Central Puget Sound Region, in the City of Tacoma, Pierce County via an educationally institutionalized malicious strategy of abuse of process, harassment, defamation, and extortion rising at the most culpable level to attempted murder. Petitioner is not under current or immediate threat from the individuals listed here, however that is not the fact from the larger conspiracy of which this set of chronological events is related. The full extent of this relation to matters external is unknown at this time, however complaints have been filed for some of them at the Federal level and more are anticipated.
Though a current and immediate threat is not alleged, it is however alleged that given the joint conspiratorial nature of this larger pattern of conspiracy damages are continuing to accrue against the petitioner as a direct and indirect result of this cause of action.
The most salient date of action is August 18, 2009, the Court date for three ‘anti-harassment’ restraining order hearings held in the District Court of Presiding Judge Jack Nevin by Thurston, the Cascade Land Conservancy (CLC), and Tahoma Audubon. The record submitted by these defendants and their associates above shall likely constitute the bulk of the evidence in this case.
Most of the defendants above were either parties to those actions or documented in the pleadings, (9Y600364A, 9Y600371A, 9Y600374A) incorporated here by reference.
The apparent ‘ringleader’ is the Cascade Land Conservancy (CLC) somewhere unknown above the level of employee Christopher Gilliand. Pierce County CLC Director Ryan Mello is completely culpable and his appointment to the Tacoma Council by the other five current Councilmembers is alleged to be in support of this practice of conspiracy, former Mayor Bill Baarsma is included as Executive at the time of the beginning of these incidents. CLC Attorney Nick Harper is included to investigate connections between the CLC and the larger patterns of alleged conspiracy, most notably through his election to the Washington State Legislature by criminal actions, not all parties identified at this date.
The core events arose from an incident in a meeting related to a native plant stewardship course project where the petitioner objected to an apparent attempt by the City of Tacoma’s Federal Endangered Species designated official to fraudulently avoid project responsibility under Washington State Wetlands rules. In response Edwina Magrum, chair of the Tacoma Federal Community Development Block Grant citizen review committee made a malicious allegation of harassment against the petitioner, an event sparking and possibly continuing a large number of attacks against the petitioner and manipulations of public decision making processes with financial and land use ramifications. The most notable of these other issues is in the Transportation arena, which includes a small second project of the Cascade Land Conservancy, ‘Community Stewards’, under the direction of Craig Benjamin.
The full set of relations among the various known and unknown conspirators is not yet determined, however much is known. The Native Plant Stewardship Course was taught by Anna Thurston, under contract to the Washington Native Plant Society (WNPS), an organization she also served as County director. The WNPS was working as part of the Green Tacoma Partnership funded by the City of Tacoma and METRO Parks Tacoma and led by the Cascade Land Conservancy who staffed the agency (Gilliand).
The Green Tacoma Partnership includes a number of local and regional environmental organizations of varying sizes, first of which may be the Tahoma Audubon Society. Audubon Staff Member Kyer attended native plant stewardship training classes on multiple occasions and was the first to continue the defamation of Magrum, as a member of a committee relating to the course project of the petitioner (First Creek Restoration on Tacoma’s Eastside near the HUD Salishan project.). Of the other larger organizations in the Green Tacoma Partnership the Puget Creek Restoration Society and Citizens For a Healthy Bay are NOT alleged to have any culpability.
Also included by reference is a Commission on Judicial Conduct complaint against District Court Presiding Judge Nevin of February 19, 2011.
As a result of these conspiratorial actions petitioner has become permanently disabled (also documented in the enclosed GR33 Submission) and our system of local and state government undermined seditious. The petitioner has no objection to the community treatment of malicious individuals documented here, solely in the misapplication of those correct standards – specifically recreating the cycle of abuse. Petitioner alleges that the most senior of defendants are not victims in any regard and are in fact intentionally pandering to hate for political and financial benefit, and as such rise to, or exceed, level 3 sexual predators and possibly attempted murder under civil law. Pursuant to the legal terminology of the George Washington Bush Department of Justice these individuals are, in fact, corporate ‘enemy combatants’ against America and the forfeiture of rights as a US citizen.
The use of institutionalized educational strategies by some of these senior defendants adds another layer to this conspiracy, what petitioner terms as ‘uber-predators’, those who use their legal authority to train others to create conspiracies of this sort. The culpability of these individuals exceeds that of a level 3 sexual predator and may designate genetic deficiency to a level designating a lack of membership in the human race.
WHEREFORE, Plaintiff prays for punitive financial judgment against Defendants for medical costs, lost earnings, and pain and suffering, in amounts proportional to their responsibility; and for declaratory and injunctive relief proportional to their own standards.
Dated this 13th day of September
Douglas Tooley,
in Propria Persona
