WHEREFORE, by and through the United States of America, and all the foregoing reasons set forth herein, Plaintiff Manuel Arias, respectfully demands the following forms of relief:
1). Against Defendant Paul Voinovich, compensatory and punitive damages in the amount to be determined after full discovery has been afforded;
2). Against Defendant Paul Mifsud, compensatory and punitive damages in the amount to be determined after full discovery has been afforded;
3). Against Defendant Margaret Ghee, compensatory and punitive damages in the amount to be determined after full discovery has been afforded;
4). Against Defendant George Voinovich, compensatory and punitve damages in the amount to be determined after full discovery has been afforded;
5). Against Defendant Victor Voinovich, compensatory and punitive damages in the amount to be determined after full discovery has been afforded;
6). Against Defendant Betty Montgomery, compensatory and punitive damages in the amount to be determined after full discovery has been afforded;
7). Against Defendant Reginald Wilkinson, compensatory and punitive damages in the amount to be determined after full discovery has been afforded;
8). Against Defendant Raymond Capots, compensatory and punitive damages in the amount to be determined after full discovery has been afforded.
WHEREFORE, by and through the United States of America, Plaintiff Manuel Arias respectfully demands this Honorable Court
to:
i). DECLARE that each and every action as averred herein, as to each defendant; singly and collectively, clearly violated Federal Criminal Laws and Federal Civil Laws;
ii). DECLARE that each and every action as averred herein, as to each defendant; singly or collectively, violated Plaintiff's rights and privileges and the rights and privileges of the United States of America as guaranteed within the United States Constitution;
iii). DECLARE that each and every action averred to herein as to each defendant; singly or collectively, violated the State of Ohio's criminal and civil laws as applied to the genuine issues of material facts herein;
iv). DECLARE that Ohio Revised Code(s) 2967.03, et seq., and 5149.02, et seq., upon their respective face, and as applied to Plaintiff, violate the United States Supreme Court's Non Delegation and Unbridled Discretion Doctrines, and Federal Laws;
v). DECLARE that Ohio Revised Code(s) 2967.03, et seq., and 5149.02, et seq., singly and collectively, upon their respective face, and as applied to Plaintiff, violate his First, Fifth, Eighth and Fourteenth Amendments to the United States Constitution, and Federal Laws: FURTHERMORE TO DECLARE that said statute(s) violate Article I, Section I of the United States Constitution's "Checks and Balance" guarantee, upon their respective face, and, as respectively being applied to Plaintiff.
vi). DECLARE that the actions complained of herein regarding the total and specific conduct of Defendant Raymond Capots violated Plaintiff's right to be free from state permitted discrimination, and violated Federal Laws.
WHEREFORE, by and through the United States of America, Plaintiff Manuel Arias, respectfully demands that this Honorable Court immediately ENJOIN EACH DEFENDANT herein from exercising any type of state or non state related conduct that would be in violation of his rights and privileges as guaranteed to him by way of the United States Constitution and Federal Laws.
WHEREFORE, by and through the United States of America, Plaintiff Manuel Arias, respectfully demands that this Honorable Court IMMEDIATELY ISSUE AN ORDER TO EACH INDIVIDUAL DEFENDANT HEREIN TO SHOW CAUSE WHY THIS COMPLAINT SHOULD NOT BE PERMITTED TO PROCEED.
WHEREFORE, by and through the United States of America, Plaintiff Manuel Arias respectfully demands that this Honorable Court assess any and all costs associated with the filing and processing of this Complaint, including any and all costs associated to Attorney Fees of the United States, against each defendant herein, AND TO GRANT ANY OTHER RELIEF this Honorable Court finds against each defendant herein.
EXECUTED ON: 6/30/1997
OFFICIAL NOTICE OF PUBLICATION I. MANUEL ARIAS, THE AFFIANT HEREIN, UNDER THE PENALTY OF PERJURY, UNDER THE LAWS OF THE UNITED STATES OF AMERICA, OF AGE OF THE MAJORITY, AND HAVING PERSONAL KNOWLEDGE OF THE FACTS HEREIN, BASED UPON MY SINCERE BELIEFS, I HEREBY AVER:
1. THAT EACH AND EVERY SINGLE AVERMENT WITHIN MY ATTACHED QUI TAM COMPLAINT IS TRUE AND CONSISTENT WITH MY PERSONAL KNOWLEDGE AND SINCERE BELIEFS, AND THIS COMPLAINT HAS NOT BEEN BROUGHT ABOUT FOR ANY IMPROPER PURPOSES;
2. THAT EACH AND EVERY DOCUMENT AND ARTICLE APPENDED HERETO IS TRUE AND CORRECT AND HAS NOT BEEN MANIPULATED IN ANY FASHION, AND THAT EACH DOCUMENT AND ARTICLE IS ACCURATE AND HAS NOT BEEN CHANGED IN ANY WAY FROM ITS ORIGINAL CONTENT;
3. THAT DEFENDANT GEORGE VOINOVICH HAS USED HIS DEFENDANT BROTHERS' CONSTRUCTION COMPANY POWER AND MUSCLE AND MONEY TO GAIN HIS WAY INTO STATE POLITICS AND THEREAFTER, HAS USED HIS OFFICIAL OFFICE TO MANIPULATE, FALSIFY, PERPETRATE AN ORGANIZED ILLEGAL SCHEME, AS AVERRED WITHIN THE ATTACHED COMPLAINT;
4. THAT "IF" THE UNITED STATES FAILS TO LAWFULLY AND THOROUGHLY INVESTIGATE THE GENUINE FACTS AS PLEAD WITHIN THE ATTACHED COMPLAINT. IT IS MY PERSONAL BELIEF THAT THE ORGANIZED CORRUPTION AS PLEAD WITHIN THE ATTACHED COMPLAINT WILL CONTINUE AND WILL CONTINUE TO ILLEGALLY PROSPER;
5. THAT WHEN I WAS BEING HOUSED AT VARIOUS DEFENDANT OPERATED AND RELATED PRISONS, I SAW WITH MY OWN EYES VARIOUS DOCUMENTS, PLANS, AND BLUEPRINTS THAT LISTED THE NAMES OF THE VOINOVICH CONSTRUCTION COMPANY;
6. THAT IT IS BASED UPON MY PERSONAL KNOWLEDGE AND SINCERE BELIEFS THAT DEFENDANT GEORGE VOINOVICH IS USING AND WILL CONTINUE TO USE HIS OFFICIAL OFFICE TO CAUSE, EITHER PERSONALLY AND/OR BY AND THROUGH HIS AGENTS AND EMPLOYEES THE DELIBERATE MANIPULATION OF FACTS & FIGURES & STATISTICS TO BE PROVIDED TO THE UNITED STATES GOVERNMENT TO FURTHER AN ILLEGAL ORGANIZED ILLEGAL SCHEME TO DEFRAUD THE UNITED STATES OF AMERICA OUT OF COUNTLESS MILLIONS OF DOLLARS AS DIRECTLY AVERRED TO WITHIN THE ATTACHED COMPLAINT;
7. THAT WHEN I APPEARED BEFORE DEFENDANT CAPOTS, AS AVERRED TO WITHIN THE ATTACHED COMPLAINT, BASED UPON MY PERSONAL KNOWLEDGE & SINCERE BELIEFS, AND PERSONAL EXPERIENCE IN LIFE, I BELIEVE THAT DEFENDANT CAPOTS USED HIS UNCHECKABLE AND UNBRIDLED DISCRETIONARY OFFICIAL OFFICE POSITION AND POWER TO OPENLY PRACTICE HIS OBVIOUS DEEP SEATED HATRED AND HIS OBVIOUS DEEP SEATED PREJUDICE FOR THE SPANISH RACE AGAINST ME DURING THE COURSE OF THE MENTIONED
PAROLE RELATED HEARING, AND THAT DEFENDANT CAPOTS DENIED ME A FAIR HEARING AND USED HIS POWER AND OFFICE TO PUNISH ME BY DENYING ME A FAIR HEARING OR A PAROLE ONLY BECAUSE OF THE FACT THAT I AM A PUERTO RICAN MAN WHO WAS MARRIED AND WAS INVOLVED WITH CAUCASIAN WOMEN IN MY PAST LIFE.
8. THAT THE TWO STATUTES AS MENTIONED WITHIN THE ATTACHED COMPLAINT VIOLATE ARTICLE I, SECTION I OF THE U.S. CONSTITUTION AND FEDERAL LAWS. UPON THEIR FACE. AND AS BEING APPLIED TO ME AND THAT THESE TWO STATUTES SHOULD BE STRUCK DOWN AS BEING HIGHLY OFFENSIVE TO THE UNITED STATES CONSTITUTION AND FEDERAL LAWS.
9. THAT I HAVE NO OTHER REAL, ADEQUATE OR MEANINGFUL REMEDY IN THE ORDINARY COURSE OF THE LAW AND I AM GENUINELY FEARFUL THAT DEFENDANTS, SINGLY OR COLLECTIVELY WILL SEEK TO RETALIATE AGAINST ME FOR THE FILING OF THIS QUI TAM ACTION AGAINST EACH DEFENDANT FOR GOOD CAUSE, AS THE OPEN AND CONCEALED RECORDS WILL DEMONSTRATE TO THE COURT UPON DISCOVERY.
10. THAT I AM AN AMERICAN CITIZEN; I AM RESPECTFULLY DEMANDING THAT THE UNITED STATES OF AMERICA THOROUGHLY AND COMPLETELY INVESTIGATE THE GENUINE MATERIAL FACTS AS AVERRED WITHIN THE ATTACHED COMPLAINT, AS A MATTER OF LAW AND PUBLIC POLICY RELATED CONFIDENCE AND TRUST.
MANUEL ARIAS
I, the undersigned herebly certify that I have forwarded a true and correct copy of this QUI TAM ACTION to BOTH: the Honorable Janet Reno,
Esquire, 10th., Street & Constitution Avenue, N.W., Washington, D.C., 20530, via CERTIFIED U.S. MAIL; and I have sent an additional copy of this Instrument to the : Office of the United States Attorney General, for the Northern District of Ohio, at 1800 Bank One Center, 600 Superior Avenue, N.W., Cleveland, Ohio, 44114-2600 via regular U.S. MAIL on this 30th day of June, 1997; all postage related costs hereon have been satisfied in advance. Supporting documentation is available and will soon be at this location. Check for this documentation later.
MANUEL ARIAS
2500 SOUTH AVON-BELDEN ROAD
GRAFTON, 0H 44044
Publication of this CompIaint
may be sought or possibly
posted upon the Bulletin
Board(s) of AMERICA ONLINE &
INTERNET/WEBSITE within Sixty
Days of the filing date hereon.
STATE OF OHIO )
) : SS
LORAIN COUNTY )
PAGE ONE OF TWO PAGES
AFFIDAVIT 0F PLAINTIFF MANUEL ARIASPAGE TWO OF TWO PAGES
FURTHER AFFIANT SAYETH NAUGHT
DUAL CERTIFICATE OF SERVICE
MR. MANUEL ARIAS
2500 SOUTH AVON BELDEN ROAD
GRAFTON, OHIO 44044