"Plaintiff notes that Defendant Timothy does not enjoy absolute immunity (e.g. Imbler v. Pachtman, 424 U. S. 409, 428, 430 (1976) "lower courts have held that unconstitutional suppression of exculpatory evidence is beyond the scope of" duties constituting an integral part of the judicial process" and have refused to extend absolute immunity to suits based on such claims. Hilliard v. Williams, 465 F.2d 1212, 1218 (CA6), cert. denied, 409 U.S. 1029 (1972); Haaf v. Grams, 355 F. Supp. 542, 545 (Minn. 1973); Peterson v. Stanczak, 48 F R. D. 426 (ND Ill. I 969). Contra, Barnes v. Dorsey, 480 F.2d I 057 (CA8 1973)." (see also Doc. 44-1, ii 7 I (b )) (also, state judicial officers have been held liable in damages for abuse of process: Williams v. Kozak, 280 F. 373 (1922); Dean v. Kochendorfer, 237 N. Y. 384, 143 N. E. 29 (1924); Hoppe v. Klapperich, 224 Minn. 224, 28 N. W. 2d 780, (1947))"
Complaint
Plaintiff's Amended Complaint for: (1) Brady violations; (2) Abuse of Process; (3) Malicious Prosecution; (4) Intentional Infliction of Emotional Distress (IIED); (5) Civil Conspiracy
Sanctions
Plaintiff's In Limine Response to Court's Inquiry into Sanctions
9th Cir., 19-55954
Motion for Injunction
Plaintiff-Appellant's Motion for an Injunction against John Gregory Unruh, Leonard Nyugen Trinh and Timothy G. O'Connor
Motion-to-Dismiss
Defendant O'Connor's Motion to Dismiss (5/24/19)
Supreme Court Petition (18-1330)
Plaintiff's Petition to for a Writ of Certiorari to the Supreme Court of the United States, case no.: 18-1330
PORTAL to
Plaintiff-Appellant's Correspondence to the Court regarding the Issues to be Presented in this Appeal
Opp. to MTD
Plaintiff's Response in Opposition to Defendant O'Connor's Motion-to-Dismiss
Judicial Disqualification Motion
Plaintiff's Motion for Disqualification of Judge Cynthia Bashant, former Deputy Chief of Narcotics for the U.S. while defendant reached (unlawfully suppressed) plea bargains
Dismisssal
Judge Cynthia A. Bashant's FRCP 12(b) summary dismissal finding absolute immunity for Defendant O'Connor - or providing him a bona fide license to act in concert with a member of organized crime (Defendant Unruh) - without any due process in opposition to the clear violations of Plaintiff's Civil Rights (making an easy basis for conspiracy)
Petition for Mandamus
(9th Cir 19-71369)
Plaintiff's Petition for Mandamus for Disqualification of Judge Cynthia Bashant, former Deputy Chief of Narcotics for the U.S. while defendant reached (unlawfully suppressed) plea bargains
Imagine if a state actor (e.g. a prosecutor) could request a warrant for your arrest, for a misdemeanor charge carrying a maximum penalty of One Thousand Dollars, filing such charge latently (e.g. over four (4) months beyond the one (1) statue of limitations) and fraudulently - and - doing so on behalf of an actual criminal of dubious character and nefarious background providing false, partial and/or misleading information to various authorities for illicit motive(s) and purpose - while such state actor willfully suppresses the criminal background required for timely disclosure on such person - would a reasonable person view that as a state actor in partnership with a criminal? How can any other benign conclusion be drawn? Does it beg the obvious question, what are such persons actual motives in abusing power?