Corruption in Government Must STOP -
Obey the Constitution

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Why is Obedience to the State and Federal Constitutions so Important?

Because Public Officers commit heinous criminal acts EVERY DAY 
which they would NOT commit if they honored their oaths to obey the Constitutions 

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Complainant Magritz's Verified Motion for Partial Summary Judgment

          In the federal court system a party can move the court for a Summary Judgment without waiting for the opposing party to answer the Complaint.  This helps expedite settling lawsuits and helps prevent shyster attorneys from dragging cases out for years in order to shaft their clients with horrendous legal fees for basically doing nothing but stall and pervert or prevent justice.  

Mtn Part Summ Judg.pdf
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          Magritz had pre-lawsuit Agreements by way of tacit procuration with 37 of the 41 Respondents, Public Officers of The Ozaukee County MOB who acted dishonestly and in Breach of their Fiduciary Duty.  
          As Public Officers and Trustees or Fiduciaries of the Public Trust created by the Constitutions, they had a duty to respond to Magritz, a beneficiary of the Public Trust.  They chose not to respond.  They chose to agree by their silence.  They had agreed that Corporation Counsel Dennis E. Kenealy had committed crimes which had provided them an "excuse" to steal the private property of Magritz at gunpoint. They had agreed with Magritz, therefore there was no controversy, and the judge should have granted partial summary judgment.

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COMPLAINANT’S VERIFIED MOTION
FOR PARTIAL SUMMARY JUDGMENT
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            Complainant Steven Alan Magritz moves this honorable Court for a partial summary judgment pursuant to FRCP Rule 56 (a):  “A party may move for summary judgment, identifying each claim or defense – or the part of each claim or defense – on which summary judgment is sought. The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law. The court should state on the record the reasons for granting or denying the motion.” Cursus Curiae est lex Curiae.[1]

            This honorable Court wherein Complainant has invoked Equity Jurisdiction is governed by the Maxims and Principles of Equity. Maxime ita dicta quia maxima est ejus dignitas et certissima auctaritas atque quod maxime omnibus probetur.[2] Principia probant non probantur.[3]  


[1]  The practice of the Court is the law of the Court.
[2]  A maxim is so called because its dignity is maximum and its authority the most certain, and because approved at the maximum by all.
[3]  Maxims have an inherent probative force, and need not to be proved.

            Complainant moves this honorable Court for a partial summary judgment against Respondents Ozaukee County, Ozaukee County Sheriff’s Department, Thomas E. Winker, Robert A. Brooks, Lee Schlenvogt, Daniel P. Becker, Joseph A. Dean, Raymond G. Meyer II, Jacob Curtis, Daniel R. Buntrock, Kathlyn T. Geracie, Andrew A. Petzold, Patrick Marchese, Karl V. Hertz, Cynthia G. Bock, Robert T. Walerstein, Nancy Sharp Szatkowski, John J. Slater, Jennifer K. Rothstein, Rose Hass Leider, Donald G. Dohrwardt, Richard C. Nelson, Alan P. Kletti, Thomas H. Richart, John C. Grosklaus, Glenn F. Stumpf, Gerald E. Walker, Gustav W. Wirth, Jr., James H. Uselding, Kathlyn M. Callen, Mark A. Cronce, Maurice A. Straub, Karen L. Makoutz, Ronald A. Voigt, Dennis E. Kenealy, Thomas W. Meaux, Andrew T. Struck, Rhonda K. Gorden, Sandy A. Williams, Andrew T. Gonring, and Adam Y. Gerol. The process server has reported to Complainant that Respondent Timothy F. Kaul is deceased, and that ten (10) attempts to serve Respondent William S. Niehaus at his residence have been made, but no one answered the door, therefore these two (2) Respondents are not included in this present motion.

            It is undisputed, as evidenced in Complainant’s verified Complaint, Complainant’s Affidavit in support of said Complaint, “Exhibit F” which is the Agreement with Complainant of 37 of the 41 individual named Respondents, “Exhibit N” which is Complainant’s unrebutted Affidavit of Criminal Report against officers of the court, and “Exhibit O”, that the above named individual Respondents in their individual capacity (which does not include the legal fictions named “Ozaukee County” or “Ozaukee County Sheriff’s Department”):

• Admit, by and through their actions including but not limited to their filing, or attempting to file, Motion(s) To Dismiss, that the facts alleged in Complainant’s Verified Complaint are true;
  

• Have made numerous false representations to this Court in their unsworn Motion(s) To Dismiss in an attempt to deceive this honorable Court, as pointed out in Complainant’s 
  

         Motion(s) to Strike, qui facit alium facit per se. (He who does anything by another,    
         does it himself). The act of the agent is the act of the principal;

• Have evidenced in their Motion(s) to Dismiss their dishonesty, bad faith, unclean hands, and false representations in an attempt to deceive this honorable Court and prevent or pervert justice, and by those acts alone are barred from any relief whatsoever. He Who Comes Into Equity Must Have Clean Hands; 
  

• Are public officers holding a position of public trust;
  

• Are bound to support the Constitution of the United States of America pursuant to Article Six (6) sections Two (2) and Three (3) of said Constitution;
  

• Are fiduciaries or trustees of the Public Trust that was created by the Constitution of the United States of America; 
  

• As fiduciaries of the Public Trust are under an inescapable obligation to serve with the highest fidelity, honesty, integrity, and good faith; 
  

• Owe absolute loyalty and obedience to that Trust Document, the Constitution of the United States of America, which created the Public Trust;
  

• Take their offices cum onere, that is, with all the responsibilities and personal liabilities attached to their individual person, including both compensatory and punitive damages for injuries caused by breach of their fiduciary duty. Equity Acts Upon the Person; 
  

• Must at all times, without exception, display honesty, integrity, and good faith to beneficiaries;
  

• Owe a fiduciary duty to Complainant, who is a beneficiary of the Public Trust; 
  

• Are prohibited from taking private property for public use without just compensation by the Fifth Article in Amendment to the Constitution of the United States of America;
  

• Are prohibited from impairing the obligation of contracts by Article I, Section 10, Clause 1 of the Constitution of the United States of America; 
  

• Agree that Complainant did not intend for Complaint’s private property to be hypothecated to the public and does not intend said private property to be hypothecated to the public, as further evidenced by “Exhibit A” – Complainant’s Confirmation Deed, “Exhibit B” – Complainant’s secured interest, “Exhibit D” – Senate debate on sale of public land, “Exhibit E” – Act of Congress on sale of public land, “Exhibit H” – Affidavit of Publication regarding liquidated damages, “Exhibit J” – Declaration and Claim of Rights in Land Patents, “Exhibit K” – Notice and Claim to Private Land Rights, and, “Exhibit L” – Affidavit of Publication, Notice of Claim;  
  

• Violated the self-executing mandate “nor shall private property be taken for public use without just compensation” set forth in Article the Fifth in Amendment to the Constitution of the United States of America by attempting to take Complainant’s private property through “registration” and “taxation”;
  

• Took Complainant’s private property for public use without just compensation, as evidenced by “Exhibit G”, in violation of Article the Fifth in Amendment to the Constitution of the United States of America which prohibits such a taking;
  

• Violated the absolute prohibition against impairing the obligation of contracts set forth in Article I Section 10 Clause 1 of the Constitution of the United States of America by attempting to take Complainant’s private property through “registration” and “taxation”;
  

• Violated the absolute prohibition against impairing the obligation of contracts set forth in Article I Section 10 Clause 1 of the Constitution of the United States of America by seizing with violence and force of arms Complainant’s private lands, of which Complainant was an heir or assign by and through an executed contract called a Land Patent issued by The United States of 
  

         America prior to Wisconsin becoming one of the states of the Union, as evidenced in  
         paragraphs nine (9) through eighteen (18) of Complainant’s Affidavit in Support of 
         Complainant’s Verified Complaint, and, as evidenced by “Exhibit D” – Senate debate on
         sale of public land, March 6, 1820, “Exhibit E” – Act of Congress on sale of public land,
         April 24, 1820, “Exhibit J” – Declaration and Claim of Rights, Land Patents, recorded
         ROD 1994, “Exhibit K” – Notice & Claim to Private Land Rights, recorded ROD April
         1997, “Exhibit L” – Affidavit of Publication, Notice of Claim, July 1997, and “Exhibit M” –
         Selected relevant pages, Abstract of Title, 6 pages only;

• Took Complainant’s private land in violation of Article I Section 10 Clause 1 which prohibits the State, as well as public officers, from impairing the obligation of contracts;
  

• Have been unjustly enriched, directly or indirectly, by the taking of Complainant’s private property for public use without just compensation;
  

• Have acted in insurrection or rebellion to the Constitution of the United States of America, directly, or by consent, or by assent, by and through the taking by force and violence of Complainant’s private property in contravention of the mandates or prohibitions enumerated above and set forth in the aforesaid Constitution, to which Constitution said Respondents owe absolute loyalty and obedience;
  

• Are prohibited by Section Three (3) of the Fourteenth Article in Amendment to the Constitution of the United States of America from holding any office, civil or military, under the United States, or under any State, for having engaged in insurrection or rebellion to said Constitution;
  

• Are prohibited by Section Four (4) of the Fourteenth Article in Amendment to the Constitution of the United States of America from receiving any emoluments whatsoever from the United States or any State;
  

• Have participated in, or consented to, or assented to, ultra vires acts such as the committee named the Taxation and General Claims Committee “authorizing” a foreclosure action against Complainant’s private property when said Committee was in want of statutory authority to so authorize; 
  

• Have participated in, or consented to, or assented to ultra vires acts or criminal acts including but not limited to theft of tendered payment from the public office of county treasurer, theft and concealment of public documents (Complainant’s Answer and Counterclaim) from the office of the clerk of court, false representations to the Ozaukee County Circuit Court, theft and concealment of public documents (Complainant’s Claim against the County) from the office of the county clerk, taking of Complainant’s private property for public use without just compensation, impairing the obligation of contracts, misprision of felony, abuse of legal process, malicious prosecution, concealment of crimes, retaliation against a victim and witness of crime, false imprisonment, domestic terrorism, and others, all of which when combined have caused Complainant an injury. Equity Will Suffer No Wrong Without a Remedy; 
  

• Have acted disloyal, dishonestly, in bad faith, with lack of integrity, in breach of their fiduciary duty as Trustees of the Public Trust, with the result that they, in their individual capacity, have brought impairment of reputation, disapprobation, rebuke, reproach, revilement, et cetera, upon the good name of the State;
  

• Have acted dishonestly, in bad faith, with lack of integrity, in breach of their fiduciary duty to Complainant as a beneficiary of the Public Trust, with the result that they, in their individual capacity, have caused Complainant an injury.
  

         COMPLAINANT MOVES this honorable Court for a Declaratory Judgment declaring: the herein before named individual Respondents are public officers and fiduciaries of the Public Trust with the duty of absolute loyalty to the Constitution of The United States of America, and as such fiduciaries must serve with the highest fidelity, honesty, integrity, and good faith; each of the Respondents must at all times, without exception, display honesty, integrity, and good faith to beneficiaries of the Public Trust; the Complainant is a beneficiary of the Public Trust to whom Respondents owe a fiduciary duty; each of the Respondents, individually, have acted with disloyalty to the Constitution of the United States of America; each of the Respondents, individually, have acted in breach of their fiduciary duty as a trustee of the Public Trust; each of the Respondents have acted in breach of their fiduciary duty to Complainant.

          COMPLAINANT MOVES this honorable Court for Judgment imposing a Constructive Trust over the private land, “Respondent” 62.25 acres of land in the town of Fredonia, taken from Complainant for public use without just compensation and in violation of the prohibition against impairing the obligation of contracts on or about October 24, 2001. Respondents, and each of them, especially Ozaukee County and Ozaukee County Sheriff’s Department have been unjustly enriched by the taking of Complainant’s private property valued in excess of $700,000.00 without any compensation whatsoever to Complainant. Respondents have obtained “legal” title to or possession of Complainant’s private land by fraud, violations of Constitutional prohibitions and mandates, and acts in breach of their fiduciary duty to Complainant, therefore 

they are involuntary constructive trustees of Complainant’s private land for the benefit of Complainant. Equity Acts Specifically, and Not by Way of Compensation.

          COMPLAINANT MOVES this honorable Court for Judgment imposing a Constructive Trust over the private effects or private chattels or private appurtenances, in whatever form they may have been converted to, taken from Complainant for public use without just compensation on or about October 24, 2001 and subsequently converted into cash, used, consumed, sold, transferred, destroyed, et cetera. Respondents, and each of them, especially Ozaukee County and Ozaukee County Sheriff’s Department have been unjustly enriched by the taking of Complainant’s private effects or chattels, including but not limited to a large quantity of various building materials such as dimensional lumber and concrete blocks as well as dozens of automobiles, many with valuable big-block engines, all of which could have been sold for cash if they weren’t “used” personally by Respondents. Respondents are involuntary constructive trustees of Complainant’s private effects, in whatever form to which they may have been converted or which they may currently have, for the benefit of Complainant. Therefore this Court should impose a constructive trust on the private effects taken from Complainant and on the bank accounts of Ozaukee County and the Ozaukee County Sheriff’s Department pending the outcome of the accounting demanded by Complainant.

          COMPLAINANT MOVES this honorable Court for judgment ordering Ozaukee County to forthwith return possession and control of Complainant’s private land, named as “Respondent” 62.25 acres of land in the town of Fredonia, to the exclusive dominion of Complainant. The Judgment should order the clerk of Ozaukee County, or other properly authorized person/public officer, to forthwith provide Complainant with a properly signed and acknowledged Deed, to be drafted by Complainant, the terms of which guarantee that

Respondents, or any of them, or their successors, will never, ever again, interfere with, or attempt to interfere with, in any way or by any means or under any subterfuge whatsoever, including but not limited to “taxation”, the peaceful enjoyment, possession, use, and exclusive dominion by Complainant or Complainant’s heirs or assigns. Equity Acts Specifically, and Not by Way of Compensation. Equity Regards That as Done Which in Good Conscience Ought to Have Been Done. Equity Will Not Suffer a Wrong Without a Remedy.

          COMPLAINANT MOVES this honorable Court for judgment ordering Respondent Ozaukee County and Respondent Ozaukee County Sheriff’s Department to forthwith provide Complainant with an accounting, signed under penalty of perjury by a properly authorized person/public officer of each Respondent, of the use, or disposition, or cutting or harvesting, or removal, of all the private effects taken from Complainant, without exception, including but not limited to appurtenances or things both below the surface of the ground and above the surface of the ground. Respondents shall also account for monies or mense profits or other property or services given to, or received by, any of the Respondents with respect to Complainant’s private effects or private property. Failure to provide an accounting forthwith will result in a receivership imposed upon Respondent Ozaukee County.

          COMPLAINANT MOVES this honorable Court for judgment ordering Respondent Ozaukee County and Respondent Ozaukee County Sheriff’s Department to return to Complainant the private effects taken from Complainant by Respondents, or in the alternative, if Respondents have used or consumed or destroyed or disposed of or converted any of Complainant’s private effects, to compensate Complainant therefore an equitable amount as determined by Complainant. Equity Will Not Suffer a Wrong Without a Remedy.

          COMPLAINANT MOVES this honorable Court for judgment ordering disgorgement by Respondent Ozaukee County and Respondent Ozaukee County Sheriff’s Department, as being unjustly enriched by disloyal fiduciaries or trustees ex maleficio, of all gains or profits, all the fruits, in every form, the increase, the income, other property acquired by the constructive trustee(s) by the exchange or use of Complainant’s private property in any way, including but not limited to the fair rental value of Complainant’s private property provided to public officers and the benefits received from the hypothecation of Complainant’s property by way of the issuance of bonds or otherwise. Disgorgement is designed to deprive the wrongdoer of all gains flowing from the wrong rather than to compensate the victim of the fraud. Only full disgorgement satisfies the principle of preventing unjust enrichment.

          COMPLAINANT MOVES this honorable Court for judgment ordering Respondents, and each of them, to pay Complainant an equitable “return on investment” based upon the fair market value on October 24, 2001 of Complainant’s private property taken for public use without just compensation, for the entire period of time Respondents have or had possession, use, or control of Complainant’s private property. When Chancery has Jurisdiction for One Purpose, it will Take Jurisdiction for All Purposes.

          COMPLAINANT MOVES this honorable Court for judgment ordering the individual Respondents named herein above, which does not include the legal fictions named Ozaukee County or Ozaukee County Sheriff’s Department, pay Complainant liquidated damages in the amount of Fifteen Million dollars ($15,000,000.00), pursuant to the public notice set forth in Exhibit H, for injuries caused by Respondents’ acts in breach of their fiduciary duty, and, as punitive damages to give bad actors a legal spanking to send a message to public officers that the egregious malfeasance by public officers exhibited in this suit will not be tolerated. Injuries 

sustained by Complainant at the hands of Respondents acting in breach of their fiduciary duty include but are not limited to loss of standing in the community, loss of or injury to reputation, loss of livelihood, loss of profits, loss of liberty, and/or severe emotional distress and personal injuries. Equity Acts Upon the Person. When Chancery has Jurisdiction for One Purpose, it will Take Jurisdiction for All Purposes. Equity will not Suffer a Wrong Without a Remedy. Equity Delights to do Complete Justice, and Not by Halves.

          COMPLAINANT MOVES this honorable Court for judgment protecting the good name of the state by removing from public office by way of Quo Warranto the individual Respondents named herein above for their disloyal acts, insurrection, or rebellion against the Constitution of the United States of America, pursuant to Section Three of the Fourteenth Article in Amendment. Judgment must also be rendered pursuant to Section Four of the aforesaid Amendment prohibiting Respondents from receiving any emoluments whatsoever from the United States or any State. Respondents have acted egregiously with contempt for the fundamental principle of supremacy of law, the crux of our constitutional government, which requires that all public officials obey the mandates of the Constitution. Respondents have been recalcitrant in their contempt for the Constitution. The contemptuous acts of Respondents Sandy A. Williams, Adam Y. Gerol, and Andrew T Gonring, being officers of the court, particularly shock the conscience by their misprision of felony and/or retaliation against a victim of crime who sought justice from them. Quo warranto is intended to prevent the exercise of powers that are not conferred by law. It is a preventative remedy addressed to preventing a continuing exercise of an authority unlawfully asserted rather than to correcting what has already been done under that authority. The Respondents, and each of them, have been recalcitrant in their breach of fiduciary duty and disloyalty to the Constitution of the United States of America. 

Respondents, by their attempts to deceive this honorable Court by way of interloper agents, have evidenced their recalcitrance and the necessity to remove them from public office and forever bar them from holding any office, civil or military, under the United States, or under any State. The good name of the state must be protected from further disrepute by preventing Respondents from repeating or continuing their disloyalty, insurrection, or rebellion. Equity Acts Upon the Person. When Chancery has Jurisdiction for One Purpose, it will Take Jurisdiction for All Purposes.

          COMPLAINANT MOVES this honorable Court to retain jurisdiction for purposes of complete judgment, execution of judgment, and contempt proceedings.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Dated this ____ day of July 2012.

                                                            Respectfully submitted,

                                                            By: ____________________________________

                                                                        Steven Alan Magritz, Complainant

                                       Proof of Service

I certify that all 43 Respondents for whom a summons has been issued by the Court are being served a copy of this “Complainant’s Verified Motion For Partial Summary Judgment” on this July ___ 2012 by way of first class, postage prepaid United States mail, mailed to their respective residence address indicated in Complainant’s filings with the clerk of court.

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The Proposed Partial Summary Judgment the "judge" never signed.

Partial SJ.pdf
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JUDGMENT GRANTING COMPLAINANT
PARTIAL SUMMARY JUDGMENT
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           Complainant Steven Alan Magritz invoked the Equity Jurisdiction of this Court against Respondents, forty-one (41) of whom were public officers being sued in their individual capacity for breach of fiduciary duty. Complainant moves this Court for a partial summary judgment, which is herewith GRANTED.

            This Court adopts the unrebutted allegations of fact set forth in Complainant’s Verified Complaint, Affidavit in Support of said Complaint, and accompanying exhibits as true. In summary, this Court finds the following:

            The Respondents to which this partial summary judgment applies are:

Ozaukee County, Ozaukee County Sheriff’s Department, Thomas E. Winker, Robert A. Brooks, Lee Schlenvogt, Daniel P. Becker, Joseph A. Dean, Raymond G. Meyer II, Jacob Curtis, Daniel R. Buntrock, Kathlyn T. Geracie, Andrew A. Petzold, Patrick Marchese, Karl V. Hertz, Cynthia G. Bock, Robert T. Walerstein, Nancy Sharp Szatkowski, John J. Slater, Jennifer K. Rothstein, Rose Hass Leider, Donald G. Dohrwardt, Richard C. Nelson, Alan P. Kletti, Thomas H. Richart, John C. Grosklaus, Glenn F. Stumpf, Gerald E. Walker, Gustav W. Wirth, Jr., James H. Uselding, Kathlyn M. Callen, Mark A. Cronce, Maurice A. Straub, Karen L. Makoutz, Ronald A. Voigt, Dennis E. Kenealy, Thomas W. Meaux, Andrew T. Struck, Rhonda K. Gorden, Sandy A. Williams, Andrew T. Gonring, and Adam Y. Gerol.  

            The above named thirty-nine (39) individual Respondents are public officers and fiduciaries of the Public Trust created by the Constitution of the United States of America. Such 

trustees of the Public Trust are bound to support said Constitution pursuant to Article Six, Sections Two and Three, owe absolute loyalty and obedience to the Constitution, and are under an inescapable obligation to serve with the highest fidelity, honesty, integrity, and good faith. Respondents must at all times, without exception, display honesty, integrity, and good faith to Complainant, a beneficiary of the Public Trust.

            The above named Respondents have breached their fiduciary duty to the Constitution of the United States of America and to Complainant by violating the mandates or prohibitions required by said Constitution. Respondents have violated the self-executing clause of the Fifth Amendment, which says “nor shall private property be taken for public use without just compensation” by subjecting Complainant’s private property to statutes, rules, or regulations that apply only to the public property. Respondents further subsequently violated the aforesaid Amendment by the physical taking of Complainant’s private property for public use, property valued in excess of $700,000.00, without paying Complainant so much as one dime.

            Respondents have further breached their fiduciary duty to the Constitution of the United States of America and to Complainant by violating the absolute prohibition against impairing the obligation of contracts set forth in Article I, Section 10, Clause 1. Complainant is heir or assign of a Land Patent, an executed contract, granted by the United States of America to a purchaser prior to the incorporation of Wisconsin into the Union. As such heir or assign, Complainant is entitled to all of the rights, privileges, and immunities granted to the original patentee by the United States of America. Respondents have violated the aforesaid absolute prohibition by attempting to take Complainant’s private property through “registration” and “taxation” contrary to the expressed conditions set forth in the executed contract, the Land Patent, granted by the United States of America.  Respondents further violated the aforesaid absolute prohibition by physically seizing with violence and force of arms Complainant’s private land contrary to the 

expressed conditions set forth in the executed contract, the Land Patent, granted by the United States of America.

            Respondents have been unjustly enriched by the aforesaid violations.

            The record of this Court evidences the breach of fiduciary duty in this case has been ongoing for over fifteen years, and appears to have become more egregious with each passing day, as evidenced by the unclean hands of the Respondents who have made numerous misrepresentations to this Court in an apparent attempt to deceive this Court. He Who Comes Into Equity Must Have Clean Hands.

            JUDGMENT IS HEREBY GRANTED to Complainant as follows:

A Constructive Trust is imposed upon the private land and other private effects taken from Complainant by Respondents on or about October 24, 2001, as well as upon the bank accounts of Respondents Ozaukee County and the Ozaukee County Sheriff’s Department. Said Respondents are to forthwith provide Complainant, and this Court, with the detailed accounting as described in Complainant’s Motion For Partial Summary Judgment. Said accounting shall be sworn to under penalty of perjury. Failure or refusal to provide the aforesaid accounting forthwith will result in a receivership imposed upon Ozaukee County.

Respondents Ozaukee County and Ozaukee County Sheriff’s Department, which have been unjustly enriched by disloyal fiduciaries or trustees ex maleficio, shall return to Complainant, or compensate Complainant for, all of the private effects taken from Complainant, and shall disgorge all gains or profits, all the fruits, in every form, the increase, the income, other property acquired by the exchange or use of Complainant’s private property in any way, including but not limited to the fair rental value of Complainant’s private property provided to public officers and the benefits received from the hypothecation of Complainant’s property by way of the issuance of bonds or otherwise.

          Ozaukee County, which has been unjustly enriched by disloyal fiduciaries or trustees ex maleficio, shall forthwith return possession and control of Complainant’s 62.25 acres of private land to the exclusive dominion of Complainant. Respondents, or any of them, or their successors, shall never, ever again, interfere with, or attempt to interfere with, in any way or by any means or under any subterfuge whatsoever, including but not limited to “taxation”, the peaceful enjoyment, possession, use, and exclusive dominion by Complainant or Complainant’s heirs or assigns.  The clerk of Ozaukee County, or other properly authorized person/public officer, shall forthwith provide Complainant with a properly signed and acknowledged Deed, to be drafted by Complainant, the terms of which guarantee that Respondents, or any of them, or their successors, will never, ever again, interfere with, or attempt to interfere with, in any way or by any means or under any subterfuge whatsoever, including but not limited to “taxation”, the peaceful enjoyment, possession, use, and exclusive dominion by Complainant or Complainant’s heirs or assigns.

The individual Respondents named herein above, and each of them, shall pay Complainant an equitable “return on investment” based upon the fair market value on October 24, 2001 of Complainant’s private property taken for public use without just compensation, for the entire period of time Respondents have or had possession, use, or control of Complainant’s private property. 

            The individual Respondents named herein above, and each of them, shall pay Complainant liquidated damages in the amount of Fifteen Million dollars ($15,000,000.00), pursuant to the public notice set forth in Complainant’s Exhibit H, for injuries caused by Respondents’ acts in breach of their fiduciary duty, and, as punitive damages to give bad actors a legal spanking to send a message to public officers that the egregious malfeasance by public officers exhibited in this suit will not be tolerated.

            The good name of the state must be jealously protected. The Respondent public officers named herein above have acted contemptuously of the Constitution of the United States, have engaged in insurrection or rebellion against the same, and are recalcitrant in their malfeasance as evidenced by their attempts to deceive this Court. It is the judgment of this Court that they be removed from office and forever barred from holding any office, civil or military, under the United States, or under any State, pursuant to Section Three of the Fourteenth Amendment. Further, it is the judgment of this Court that any emoluments paid to them shall be deemed illegal and in violation of Section Four of the Fourteenth Amendment.

            This Court retains jurisdiction of this suit in Equity.

                                                                        ______________________________
                                                                          Honorable Emmet G. Sullivan, Judge
                                                                          district court of the United States
                                                                          District of Columbia

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