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Old November 9th 09, 05:23 AM posted to rec.games.chess.politics
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Default lawsuit final version

UNITED STATES DISTRICT COURT
WESTERN DISTRCIT of TEXAS
EL PASO DIVISON

Marcus Wayne Roberts, a citizen of the United States of America and
Ambassador of the Federation of Saint Christopher and Nevis

V. CASE NO _________________________

Rio Grand Electric Cooperative, Inc., a Texas Corporation
Dan Laws, General Manager/CEO, Rio Grande Electric Cooperative, Inc.
Darlene Laws, wife of Dan Laws,
Gregg Gardner, employee of Rio Grand Electric Cooperative, Inc.
Cerro Alto Development, Inc., a Texas Corporation
John E. Turner, President, Cerro Alton Development, Inc. and Constable
Of Hudspeth County, Texas, District 3

COMPLAINT

PARITIES TO LAWSUIT
1 Plaintiff, Marcus Wayne Roberts, physical address 19308 France Silva
Avenue, El Paso, Texas 79996 mailing address PO BOX 961029, El Paso,
Texas 79996.
2. Rio Grande Electric Cooperative, Inc., Highway 90 & SH 131,
Brackettville, Texas 78832
3. Dan Laws, Highway 90 & SH 131, Brackettville, Texas, 78832
4. Darlene Laws, Hwy. 90 & SH 131, Brackettville, Texas 78832
5. Gregg Gardner, 501 South Main, Dell City, Texas 79837
6. Cerro Alto Development, Inc.11900 Montana Avenue, El Paso, Texas,
79936
7. John E. Turner, 11900 Montana Avenue, El Paso, Texas, 79936
JURISDICTION
8. This action is a federal question primarily for three reasons:
9. Rio Grande Electric Cooperative, Inc. is the recipient of Federal
financial assistance from the U.S. Department of Agriculture (USDA).
The USDA prohibits discrimination in all its programs and activities
on the basis of race, color, national origin, age, disability, and
where applicable, sex, marital status, familial status, parental
status, religion, sexual orientation, genetic information, political
beliefs, reprisal, or because all or part of an individual’s income is
derived from any public assistance program.
10. United States Constitution, Amendment V (1791)
No person shall be held to answer for a capital, or otherwise infamous
crime, unless on a presentment or indictment of a grand jury, except
in cases arising in the land or naval forces, or in the militia, when
in actual service in time of war or public danger; nor shall any
person be subject for the same offense to be twice put in jeopardy of
life or limb; nor shall be compelled in any criminal case to be a
witness against himself, nor be deprived of life, liberty, or
property, without due process of law; nor shall private property be
taken for public use, without just compensation.
11. United States Constitution, Amendment XIV (1868) Section 1
All persons born or naturalized in the United States, and subject to
the jurisdiction thereof, are citizens of the United States and of the
state wherein they reside. No state shall make or enforce any law
which shall abridge the privileges or immunities of citizens of the
United States; nor shall any state deprive any person of life,
liberty, or property, without due process of law; nor deny to any
person within its jurisdiction the equal protection of the laws.
VENUE
12. Property owned by the Plaintiff sits in Hudspeth County, Texas, in
the Western Federal District of Texas. Defendants with Rio Grande
Electric, Inc. do business in the western district of Texas, and
signed a PEACE bond before Justice of the Peace Juanita Callier, in
Hudspeth County, Texas. Defendant Cerro Alto Development, Inc., and
Constable John Turner sold property to plaintiff in Hudspeth County,
Texas. (See exhibit “A”).

COUNT 1: REFUSAL TO CONNECT POWER
13. Dan Laws, CEO of Rio Grand Electric Cooperative, refuses to
connect power to my homestead. In a letter dated October 27, 2009, and
October 28, 200i, Mr. Laws writes “I have asked for a notarized letter
from you…” “”I am also requiring you to include a statement assuring
Rio Grand that employees will not be harmed or molested in any way as
they carry out their duties. Until I have such a letter, Rio Grand
will not make connection.” Plaintiff requests a court order
establishing power. Plaintiff seeks unspecified damages for hotel
bills.
COUNT II: EXTORTION
14. Plaintiff has been charged with a class “B” misdemeanor relating
to the power hookup request. Said notarized statement requested by CEO
Laws will tend to incriminate the plaintiff at trial. Plaintiff
invokes Fifth Amendment to refuse to provide notarized confession.
Plaintiff seeks unspecified damages (see exhibit “J” and “K”)
COUNT III: LIBEL
15. Defendant Laws implied that Plaintiff would sexually molest power
company workers with the Public Utility Commission of Texas. Plaintiff
is on heart medication and unable to molest workers. Plaintiff is a
candidate for county judge. Plaintiffs’ reputation has been harmed.
Plaintiff seeks unspecified damages. (see exhibit “J” and “K”)
COUNT IV: FALSE ARREST
16. Defendants signed a PEACE BOND and complained to Constable John E.
Turner that Plaintiff was going to assault workers. Plantiff was
jailed for over 24 hours. Plaintiff seeks unspecified damages.
Plantiff seeks an order vacating peace bond. (see exhibit “L”)
COUNT V: BREECH OF CONTRACT
17. Constable Turner guaranteed by contract power was readily
available. Plaintiff seeks unspecified damages.
COUNT VI: DECEPTIVE TRADE PRATICES
18. Plaintiff seeks depictive seeks TRIPLE damages against defendant
Turner and Cerro Alto Development Company, Inc for hotel costs.
Plaintiff seeks TRIPLE damages because Rio Grand Power company charged
Plaintiff approximately 2,500 dollars cash on his VISA credit card for
access to electricity. Costs of electric connection are supposed to be
FREE for home connection, due to board policy.
19. Plaintiff seeks any PUNITIVE damages and all other remedies at law
from this HONORABLE COURT.

__________________________________________________ __
Marcus Wayne Roberts mailing address: PO BOX 961029
PRO SE El Paso, Texas 79996
Sunday November 8, 2009
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