ONE Letter to Santa Barbara County Supervisors of 1/22/97

TWO Letters to District Attorney, 12/11/97 & 3/25/98

THREE Subpoena denial letters, 8/31/98 & 11/18/98

FOUR M. G. Skuse Declaration & Statement S.B. Co. SUP. CRT. Clerk

FIVE Notarization & Letter to S.B. Co. schools, 12/18/97

SIX Declaration of C.A. Brown case No. M992970, 8/17/99

SEVEN Letter to A.P.A 2/15/00 & response from A.P.A., 5/22/00

EIGHT Renewal notices and citations of DMV. 5/05/99 & 6/02/99

NINE Declaration of Doctor Gary Novatt, 7/14/00

TEN Pages 123, 124, 125 of "Human Behavior" 1964

ELEVEN Transcripts of 7/17/00 hearing of motions

TWELVE Declaration of Lakin tire & Sears receipt, 7/6/00 & 6/6/00

THIRTEEN Face page of motion filed 6/20/00, OSC DMV, waiver

FOURTEEN Transcripts of trial, S.B. Co. SUP. CRT. case 220298, 9/8/98

FIFTEEN News article,7/19/00, "Boy 13....Fired into cieling.7/17/00"

SIXTEEN Arlington Theater receipt of 5/23/98

SEVENTEEN Statement of D.A.'s office & copy of citation w/request

EIGHTEEN Oaths of Office, Schwartz and Sneddon

NINETEEN Photos of abandoned or inoperative vehicles & report

TWENTY Letter to S.B.Co. Sheriff, LET. From M.H. DEPT. & to Susan Rose

TWENTY ONE Toyota receipt and Declaration of Service manager

TWENTY TWO Pages 173-176 of EMOTIONS and MEMORY, D. Rapaport, 1961

TWENTY THREE Blacks Law Dictionary, 3rd ED., 1933, page 911, Hypnotism

TWENTY FOUR Opening Statement of Defendant, 220298, 9/8/98

Plaintiff Christopher A. Brown complains as follows:

STATEMENT OF JURISDICTION

1. Defendant County of Santa Barbara, is and at all times mentioned herein was, a political subdivision of the State of California.

REQUEST FOR JUDICIAL NOTICE RE: JURISDICTION

2. Pursuant to the California Evidence Code section 452 (a), plaintiff requests judicial notice of (a);

(a) The decisional, constitutional, statutory law of any State of the United States and the resolutions and private acts of the Congress of the United States and of the Legislature of this state.

And of California Evidence Code section 452 (h),

(h) Facts and propositions that are not reasonably subject to dispute.

Plaintiff pursuant to 452 (h) requests judicial notice of the proposition that this civil action of law filed in the SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA, takes place in;

PURSUANT TO; [CONSTITUTION OF THE STATE OF CALIFORNIA, ARTICLE III, § 1,]

"the State of California, an inseparable part of the United States of America and the United States Constitution is the supreme law of the land.(1972)

3. And request of judicial notice that the fact, pursuant to California Evidence Code section 452 (h), "not reasonably subject to dispute", that in the superior court of the state of California, where this legal action was filed, as guaranteed by the authority of the Unites States Constitution, all people have;

PURSUANT TO; [UNITED STATES CODE, TITLE 42, § 1981.] "Equal rights under the law."

(a) .Statement of equal rights.

All persons within the jurisdiction of the United States shall have the same right in every State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exaction's of every kind, and to no other.

(c) Protection against impairment of the rights protected by this section are protected against impairment by non governmental discrimination and impairment under color of State law."

4. Plaintiff, pursuant to California Evidence Code, section 452 (h), particularly requests judicial notice of subsection (c), [U. S. C., TIT. 42, § 1981] for the purpose of clarifying the confusion created in the redundant language of (c) concerning protection(s) and make a legal, constitutional function of (c) into a proposition that is "not reasonably subject to dispute". Plaintiff asserts (c) provides protection for the protection against impairment of protection devoted to the rights protected by the section...........and impairment under color of State law. Plaintiff requests notice of a proposition pursuant to California Evidence Code, section 452 (h),"not reasonably subject to dispute", that the rights are, in essence, "the security of persons and property" and that;

]THE CONSTITUTION OF THE STATE OF CALIFORNIA, ARTICLE. VI, Section 10]

is a State law that THREATENS IMPAIRMENT of [U. S. C., TIT. 42, § 1981(a)] and "the security of persons and property", the core, essential right guaranteed by [U. S. C., TIT. 42, § 1981(a)] as authorized by the Congress acting UNDER THE SUPREME LAW OF THE LAND, The Constitution of The United States. Plaintiff, proposing the specificity or clarification of the Constitution of the State of California, for the purpose of eliminating unreasonable "dispute" cites the last paragraph of;

THE CONSTITUTION OF THE STATE OF CALIFORNIA, ARTICLE. VI, Section 10]

"The court may make such comment on the evidence and the testimony and credibility of any witness as in its opinion is necessary for proper determination of the cause."

Concerning the last paragraph of [CAL. CONST. ART. VI, § 10] , plaintiff requests judicial notice of a proposition pursuant to California Evidence Code, section 452 (h), a clarification of language intended to create understandings of language, "not reasonably subject to dispute", and that is the fact that the "comment" of the courts opinion concerning witness, testimony or evidence can only be made to a jury if "comment" is to influence determination of cause and that "making" of comment according to the courts opinion has nothing to do with "taking" of evidence, testimony or witness.

5. Plaintiff requests again judicial notice of a proposition, pursuant to California Evidence Code §452(h), "not reasonably subject to dispute", that "the rights" protected by U. S. C., TIT. 42, § 1981.(c)] concern "the security of persons and property" mentioned in [U. S. C., TIT. 42, § 1981.(a)] . Plaintiff requests further judicial notice, pursuant to California Evidence Code §452(a), that there are other "decisional, constitutional, statutory laws of any State of the United States", in this case "the constitutional, statutory law, legislature of this state, California, supporting the plaintiffs indisputable proposition. For example;

PURSUANT TO; [CONSTITUTION OF THE STATE OF CALIFORNIA, ART. I, § 1 (c)]

All people are by nature free and independent and have inalienable rights. Among these are enjoying and defending life and liberty, acquiring and possessing property, and pursuing and obtaining safety, happiness and privacy.(1974)

6. Plaintiff alleges that the defendants of the County of Santa Barbara failed to "faithfully discharge the duties" as sworn to in their OATHS of OFFICE (EXHIBIT EIGHTEEN) and evaded "their true faith and allegiance to the Constitution of the United States and the Constitution of California", an "obligation" taken" freely without purpose of evasion and by doing so the defendants violated the plaintiffs rights. A fact proven by EXHIBITS, plaintiff requests judicial notice of all of the following pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1), EXHIBIT THREE, (subpoena denials, 8/31/98 & 11/18/98), EXHIBIT FOURTEEN (Transcripts, 220298, 9/8/98) EXHIBIT SIX (Declaration case No. M992970, 8/17/99), EXHIBIT SEVENTEEN (DA. Statement & citation), EXHIBIT ELEVEN (Transcripts of 7/17/00) EXHIBIT TWENTY, letter to S.B.Co. Sheriff, LET. From M.H. DEPT. & to Susan Rose. As facts, these EXHIBITS, judicially noticed, and the court is compelled to notice them and must do so or violate plaintiffs rights, because plaintiff has satisfied requirements pursuant to California Evidence Code section 453(a)(b), creating conditions where "the trial court shall take judicial notice of any matter specified" in this case rendering the allegations that the county defendants have been evading their duties a proposition "not reasonably subject to dispute" or a "fact" pursuant to California Evidence Code section 452(h). Therefore by defendants evading their duties the plaintiff has been deprived of all of the above "inalienable rights, U.S.C. TIT. 42, § 1981, CAL. CONST., ART. I, § 1 (c)] , except life, to one degree or another, and that all of the deprivations have diminished his ability to "defend life" and by doing so the defendants are ENDANGERING CHILDREN.

7. Plaintiff asserts that a violation of [CAL. CONST. ART. I, § 28],; another of the "decisional, constitutional, statutory laws of any State of the United States", or "the constitution of this state, California," requested for judicial notice pursuant to California Evidence Code section 452(a), as supporting the plaintiffs "indisputable proposition" California Evidence Code section 452(h), concerning the core and essential rights protected by [U. S. C., TIT. 42, § 1981(c)] "the security of persons and property"; is threatened by the evasions of duty conducted by defendants of the county of Santa Barbara and this threatens the "rights of the people of the state of California" with regard to all of the issues of school violence the plaintiff propositionally sets forth in this complaint. Plaintiff requests judicial notice pursuant to California Evidence Code section 452(a)

[CONSTITUTION OF THE STATE OF CALIFORNIA, ART. I, § 28 (c)]

"All students and staff of public primary, elementary, junior high and senior high schools have the inalienable right to attend campuses which are safe, secure and peaceful."

8. HANSON Cement company is a corporation doing business in Santa Barbara County, Michael Schmidt is the manager. S. B. is the mother of plaintiffs son and W. P. is her father.

9. Plaintiff is ignorant of the true names and capacities of Defendants sued herein as Does 1-50, inclusive, and therefore sues these Defendants by such fictitious names. Plaintiff will amend this complaint to allege their true names and capacities when ascertained. Plaintiff is informed and believes and thereon alleges that each of the fictitiously named Defendants is intentionally and/or negligently responsible in some manner for the occurrences herein alleged, and that plaintiff's injuries hindering his efforts to protect his children and the community of children as herein alleged were proximately caused by that intent, omission and/or negligence and constitute indirectly CHILD ENDANGERMENT.

10. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned, each of the Defendants was the agent or employee of each of the remaining Defendants, and in doing the things herein alleged, was acting within the course and scope of such agency and/or employment.

11. Plaintiff is informed and believes and thereon alleges that all actions, events and occurrences that form the basis of the complaint herein occurred in the County of Santa Barbara, State of California subject to decisions of judicial officers having taken OATHS respecting the supreme law of the United States Constitution.

12. The County of Santa Barbara had a duty to use constructive notice concerning extreme violence of children in schools (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT ONE) violation of [CAL. CONST. ART. I, § 28 (c).] The District Attorney had a duty to use information concerning the causes of homicides and suicides violation of [CAL. CONST, ART. I, § 1 (c)] (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBITS TWO & FIVE). HANSON cement company had a duty to operate their trucking operation with reasonable safety and to fairly treat the public seeking compensation who may suffer damage. Geoffrey Simpson of Santa Barbara County solid waste management had a duty to fairly enforce laws and not discriminate against the plaintiff or use laws as tools of harassment (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT NINETEEN, photos of abandoned or inoperative vehicles). Page 1 of EXHIBIT NINETEEN, all but 1 of the vehicles on the page are within 2 blocks of the storage location of the plaintiffs vehicle which was stored in a back yard, behind a canvas screen and covered with a tarp. The 5 images on the bottom left of page 1 are all vehicles stored in the front or side yards, all are visible from the street, only one is covered. The 2 vehicles on the right side of page 1 have spider webs and leaves clinging to the tires. Of page 2, the white VW rabbit at the bottom of the page is within 1/2 block and parked on the street. Plaintiff recalls it being there for over a year. The two vehicles above it are within two blocks and visibly clinging to the left front tires are spider webs with leaves in them. The top vehicle is west of turnpike by four blocks. Page 3 are in downtown Goleta within two blocks of Hollister on the street. Page 4 are located off a public alley running parallel to Hollister 2 blocks towards the Ocean. The neighbor of the blue pickup stated that "the truck hasn't moved in 2 years. The actions of the defendants 1. through 5. caused or threatened the plaintiffs physical state or caused economic loss and by doing so inflicting emotional distress distracting or disabling plaintiff from activities that will protect his children or children in County schools and children in California schools generally ENDANGERING CHILDREN. Defendants 6. and 7. by their acts or other acts of omission, having knowledge of the threat to children and violations of plaintiffs rights contained in this complaint, fail to act and endanger the defendants children and children generally.

13. Plaintiff relied on the County of Santa Barbara after plaintiff delivered a letter of constructive notice concerning danger to children in schools and the public, January 22, 1997 (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT ONE), to use available facts to recognize Plaintiffs claims of danger to his children and to students in schools generally. Plaintiff relied on the District Attorney to fulfill its duty by utilizing the investigative powers of its office to determine if missing court case files could indirectly pose the threat that the plaintiff claimed in his letters of December 19, 1997, March 26, 1998 (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT TWO) and December 18, 1997 (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT FIVE), protecting children in schools and the public. The omission of action by the District Attorney was by choice. When human lives have been lost and are threatened, and this omission is intentionally repeated, it becomes official indiscretion, not rightful or lawful, removing ALL immunity the District Attorneys office possesses from simple neglect to investigate or prosecute. OATH evasion, violation of [CAL. CONST. ART. I, § 1 (c)]

14. Defendant County failed to appear and honor subpoena duces tecum on September 8, 1998, (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT THREE subpoena denial letters) properly filed and served upon the custodian of records at the Santa Barbara County Jail, after evidence, tangibly substantial to the existence identity and location of arrest and booking records needed to identify the future potential causes of lethal violence in County schools was presented to the county. The Declaration of George Michael Skuse and Statement of Clerk of Superior Courts (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT FOUR). The County Counsel advised the custodian of records at the County jail to deny the subpoena duces tecum violation of [U. S. C., TIT. 42, § 1981] & [CAL. CONST. ART. I, § 7(a)], legally filed and served, violating law and aiding in the evasion of duty as defined in the OATHS of OFFICE (judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT EIGHTEEN). Defendant Naomi Schwartz and defendant Thomas Sneddon had a duty to "bear true faith and allegiance to the Constitution of the United States and the Constitution of California ....... or without...... purpose of evasion". By the denials of subpoena duces tecum proven with EXHIBIT THREE for defendant Schwartz and substantiated as to the allegations directed towards the district attorney by EXHIBIT TWO.

15. Christopher A. Brown, the plaintiff in this legal action, under the provisions of;

California Evidence Code section 452.

Matters which may be judicially noticed.

Judicial notice may be taken of the following matters..........

California Evidence Code section 452.

(a) The decisional, constitutional, and statutory law of any State of the United States and the resolutions and private acts of the Congress of the United States and of the Legislature of this state.

(d) Records of (1) any court of this State...........

(h) Facts and propositions that are not reasonably subject to dispute and are capable of immediate and accurate determination by resort to sources of reasonably indisputable accuracy.

And the provisions of;

California Evidence Code section 453. Compulsory judicial notice upon request.

The trial court shall take judicial notice of any matter specified in section 452 if a party requests it and:

(a) Gives each adverse party sufficient notice of the request, through the pleadings or otherwise, to enable such adverse party to prepare to meet the request; and

(b) Furnishes the court with sufficient information to enable it to take judicial notice of the matter.

(g) "Facts and propositions that are of such common knowledge within the territorial jurisdiction of the court that they cannot be reasonably be the subject of dispute.

Law Revision Comment

Of section 453 of the California Evidence Code states, concerning sufficiency of information provided for judicial notice;

i.e that no reasonable person having the same information as is available to the judge could rationally disbelieve the fact.

And pursuant to;

California Evidence Code section 454. Information that may be used in taking judicial notice.

(a) In determining the propriety of taking judicial notice of a matter, or the tenor thereof:

(1) Any source of pertinent information...........

Plaintiff implements California Evidence Code 452 and the compulsory judicial notice applied to the court by California Evidence Code 453 in all requests for judicial notice of this complaint pursuant to laws developed under the United Sates Constitution, U. S. C. TITLE 42 Sec. 1981. Equal rights under the law (a) and (c).

16. Plaintiff requests judicial notice of ALL EXHIBITS of this complaint pursuant to paragraph 15 above and the;

[CONSTITUTION OF CALIFORNIA, ARTICLE I, Section 7 (a)]

A person may not be deprived of life, liberty, or property without due process of law or denied equal protection of the laws; provided nothing contained herein or elsewhere in this Constitution imposes upon the State of California or any public entity, board or official any obligations or responsibilities which exceed those imposed by the Equal Protection Clause of the 14th Amendment to the United States Constitution...........

And,

[ARTICLE IV of the CONSTITUTION OF CALIFORNIA, Section 16 (a)]

All laws of a general nature have uniform operation

And,

[ARTICLE III of the CONSTITUTION OF CALIFORNIA, Section 3.5]

An administrative agency, including an administrative agency created by the Constitution or an initiative statute, has no power:

(a) To declare a statute unenforceable, or to refuse to enforce a statute, on the basis of it being unconstitutional unless an appellate court has made a determination that such statute is unconstitutional;

17. By the advice of the County Counsel to records supervisor Darleen Thompson of the County jail, EXHIBIT THREE (letter denying subpoena duces tecum), while defendant Schwartz was chair of the board of supervisors and in control of the County Counsel, plaintiff was denied "equal protection of the law"; and the allowance of this by judge William Gordon (a county employee) on September 8, 1998 was a violation of ARTICLE I, Section 7 (a) and ARTICLE IV, Section 16 (a), as well as ARTICLE III, Section 3.5 of the CONSTITUTION OF CALIFORNIA because allowing the denial of the subpoena, controlled by a "general law", was not "uniform in operation" and effectively was a refusal to enforce a statute.

18. Plaintiff requests judicial notice of all of the following pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT TWENTY, Letter to S.B.Co. Sheriff, LET., 2 LET.'s from M.H. DEPT. & 1 to Susan Rose. The plaintiff s motorcycle was stolen from his residence prior being evicted in May of 1999. He first wrote the letter to the Santa Barbara County Sheriffs Department to gain its recovery and provided the phone number of the person who took it. There was no action taken to recover the plaintiffs property. Later per a request to the Supervisors he was granted a meeting with the Director of the Mental Health Department, Merna Mcmillan and Dr. Nicholson on September 21, EXHIBIT TWENTY. At the meeting the plaintiff explained the situation of hypnotic abuses in the County and requested of the Director that a request to the State Department of Mental Health be made to administer experimental treatments utilizing augmented hypnosis (see 2nd page of EXHIBIT TWENTY) information that a meeting with State Mental Health was planned and the request would be made with a written response. After no effort was made by the Sheriffs Department to recover the plaintiffs property and no response was received on the request to the State Department of Mental Health, the plaintiff wrote the letter to Supervisor Rose, the Supervisor of his district, requesting her assistance in gaining the recovery of his property and the results of the request to the State Department of Mental Health (last page of EXHIBIT TWENTY is last letter of series. No response was received, a violation of plaintiffs Federal and State Constitutional rights by Supervisor Susan Rose, [U. S. C., TIT. 42, § 1981] & [CAL. CONST. ART. I, § 7(a).

19. The County of Santa Barbara has or its employees acting on information, or omission of information from the defendants 1. and 2. repeatedly violated ARTICLE III, Section 3.5 of the CONSTITUTION OF CALIFORNIA by its exercise of its power, when it has "no power" under the constitution authorizing its actions or omissions of actions, and effectively declared, by legal actions or omissions of actions, statutes unenforceable because no appellate court has made a determination that "uniform operation" of such statute is unconstitutional. Plaintiff sues defendants Schwartz, Rose and Sneddon as the county employees obligated by OATH to the duties of their offices invoked by plaintiffs information and evaded by influence to other employees of the county.

These and other violations of the CONSTITUTION OF CALIFORNIA also culminate in the decisions of ORDERS granting demurrers in cases;

220298 Order sustaining demurrer, October 30, 1997

226736 Order sustaining demurrer, January 27, 1999

Since January 22, EXHIBIT ONE, Defendants of the County had information from the plaintiff, then later from the news media, common knowledge, concerning extreme, senseless, mass, lethal violence in schools across the United States matching substantially plaintiffs warnings.

20. On December 18, 1998 plaintiff was targeted for a staged automobile collision. Plaintiff has lost his residence May 12,1998 as a result of the deprivation of his equal protection of law, plaintiffs civil right, resulting in his sufferance of; theft (EXHIBIT TWENTY, Letter to S.B.Co. Sheriff, LET. From M.H. DEPT. & to Susan Rose), assaults, frauds, false arrest, slander, illness, tire shot out 6/6/00 (EXHIBIT TWELVE), cement truck incident 6/9/00 and diminished ability to provide needed protection and guidance to his two children and to effectively act to protect the community of children that they are a part of. Santa Barbara County breached its duty to the Plaintiff, as a municipality under California State laws, subjecting plaintiff to danger from the continuing conspiracy brought to its attention through court action on May 16 1997, and September 8, 1998 with the intent of depriving, by injury, penalty or punishment, the plaintiff of means to warn county residents of the specific threats to violence in schools plaintiff is aware of.

21. Judicial notice is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of recent notes found at local schools in the spring of 2000; Dos Pueblos high school, Goleta Valley Junior high and San Marcos high school, common knowledge and verifiable fact, demonstrate locally, APPROXIMATELY, the threats for violence that plaintiffs letters of constructive notice warned of in 1997 and 1998 (see EXHIBIT FIVE). Letters from around the United States similar to those found locally and the lethal violence elsewhere indicate that without proper legal action, extreme lethal violence will occur in Santa Barbara County schools and California schools generally.

22. The Defendant, District Attorney, by its intentional acts of omission, did not act on the information of the letters (EX. TWO P. 10, 5th para.), subjected plaintiffs daughter to sexual molestation by failing to conduct investigations appropriate to the information. At the trial of the accused molester, Walter Olsen, Sid Weiser, senior assistant District Attorney neglected the duty of the District Attorneys office to protect the plaintiffs children and children of the County, by refusing to enter into evidence on 9/17/99, the plaintiffs declaration, concerning the nature of the defendant in Santa Maria case #M992970 as a repeat offender. Plaintiff requests judicial notice of pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT SIX, violating [U. S. C., TIT. 42, § 1981] & [CAL. CONST. ART. I, § 7(a)].

23. The Defendant, District Attorney, by neglecting to act on the information of EXHIBIT TWO, generally, has subjected the plaintiff to false arrest in a citizens arrest on April 30, 2000. The Santa Barbara County Sheriffs Deputies refused at the scene, 4799 Glenbrook, to arrest plaintiff for battery. Tia Macias, who called Deputies, then insisted upon making a citizens arrest for battery. Plaintiff was handcuffed and put into a patrol car, cited and released. Defendant District Attorney has rejected the case for prosecution. The refusal of Deputies to arrest and the rejection of the case by the District Attorneys office (plaintiff requests judicial notice of pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT SEVENTEEN) materially constitutes a violation of plaintiffs rights [U. S. C., TIT. 42, § 1981] & [CAL. CONST. ART. I, § 7(a)] & [CAL. CONST. ART. IV, § 16(a)] malfeasance, negligence and infliction of emotional and mental distress further disabling plaintiff from taking actions needed to protect his children and endangering the children of the county schools and generally children in the State of California.

24. The defendants of the County of Santa Barbara neglect to duty subjected plaintiff to the RECKLESS ENDANGERMENT of the defendants HANSON Cement Company on June 9, 2000 when truck driver Pat Cloward failed to stop his cement truck after it began unloading aggregate cement in the southbound right lane of HWY 101 at 50 MPH damaging plaintiffs car to a degree it was disabled. After bringing the damaged vehicle to HANSON for inspection, HANSONS mechanic David Buck unreasonably stated that HANSON wasn't responsible for the fact that plaintiffs car would not hold an idle and that he was an expert mechanic declaring it impossible that the tons of sand and aggregate rock hitting and flowing under and over plaintiffs car could cause the problem, even when the plaintiff stated unequivocally that immediately following the incident his cars performance became erratic and then wouldn't idle. HANSONS mechanic became silent when plaintiff pointed out the unreasonable paradox created by the plaintiff, supposedly normally, driving around in a car that wouldn't idle or start unless two people were involved in the process. One to jump the solenoid wire and the other to operate the throttle. HANSONS mechanic was challenged to start plaintiffs vehicle by himself and he could not do it. Plaintiff knowing that he could be stranded in the vehicle refused to leave in a car he cannot start. Suddenly the mechanic only knows about diesel trucks and will not fix plaintiffs car.

25. The fact that plaintiffs car was damaged in the way described by the incident is proven by EXHIBIT TWENTY ONE, plaintiff requests judicial notice of this EXHIBIT pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) consisting of a receipt from Toyota of Santa Barbara and Declaration of the Service manager of the facility. The receipt states in the "MISC" section near the center of the page "CUSTOMER STATES: HAS BEEN STARTING BY BYPASSING THE STARTER SWITCH, CHECK AND ADVISE. The mechanic and Michael Schmidt at HANSON were informed of this 0n 6/9/00. Near the top of the receipt from Toyota of Santa Barbara, in the section labeled LABOR & PARTS it states, DOES NOT HOLD AN IDLE ALSO HAS MISFIRE......VEHICLE WAS FOLLOWING A CEMENT TRUCK THAT DUMPED GRAVEL, ETC HAS HAD PROBLEM SINCE, CHECK AND ADVISE. FOUND ENGINE FUSE BLOWN CAUSING RUNNING ROUGH CONDITION REPLACED FUSE. Plaintiff was informed by the mechanic that the fuse element was actually broken rather than blown by electrical overload and the declaration of the Service Manager at Toyota states that "the brittle fuse element does break and fail under normal driving conditions such as a bumpy road and that the broken conductor can cause intermittent starting/running problems." this supports plaintiffs contention that the "shock' of aggregate rock at 50 MPH against the steel and glass of the car was sufficient to break the brittle fuse element and cause the rough running condition. The right front headlight and the passenger side rear window were broken, the windshield cracked and the radiator damaged as well.

26. After first asking for a rental car, plaintiff showed Michael Schmidt why it was especially important that plaintiff have transportation, EXHIBIT THREE, the subpoena denials. Plaintiff informed Michael Schmidt that because of the subpoena denials children were being caused to commit extreme violence in schools and that the plaintiff was trying to stop a scheduled school shooting in Santa Barbara. Plaintiff reminded Michael Schmidt of the recent threatening notes found in local schools.

27. All of the plaintiffs information was ignored and common reason was ignored while throughout the verbal exchanges the mechanic asserted that the plaintiff is trying to "milk" the incident for personal gain. An attempt to anger and provoke the plaintiff by concerted abuse of logic intended to avoid reasonable, rightful, lawful performance in the incident that HANSON had legal liability for and became INFLICTION OF EMOTIONAL AND MENTAL DISTRESS indirectly disabling the plaintiff in his efforts to protect his children and children in the schools with public information or CHILD ENDANGERMENT. Defendant Michael Schmidt then called the Santa Barbara County Sheriff who threatened the plaintiff with arrest for trespass. Plaintiff to date has had car repaired and it does operate but is not secure enough for plaintiff to leave his tools in while his car is parked and unattended in the course of his employment.

28. Plaintiff is not an attorney and is disempowered materially and distressed mentally thusly he offers only these points and authorities. California Government Code(s) 27329, 27322.4, 26202.6, 34090.6, 69503, 68152, 68150. 14741.

29. The defendant County and its continued failures to act according to duties defined by government codes set forth in previously filed legal actions, 220298 & 226736, as well as other codes and laws the plaintiff is unable to list due to his injuries both recent and past, is endangering children as shown by exhibits considered with inference to the violence that is common knowledge and verifiable fact, demonstrated around the United States, have endangered the plaintiffs children and the children of the county schools generally. Indirectly, defendant Michael Schmidt of HANSON, by unfairly treating plaintiff who has informed defendant of the counties evasion of duty and plaintiffs compensating efforts, is endangering children.

30. Christopher A. Brown, the plaintiff in this legal action introduces extreme behaviors in schools as "COMMON KNOWLEDGE AND VERIFIABLE FACTS", that requires, in the protection of lives, immediate attention by the court, compelling judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of the "common knowledge and verifiable facts" listed below.

Dec. 6, 1999, Fort Gibson, Okla. 4 wounded.

Nov. 19, 1999, Deming, N.M. 1 killed

May 20, 1999, Conyers Georgia, 6 wounded

April 20, 1999, Littleton, Colo., 15 killed, 22 wounded

June 15, 1998, Richmond, Va., 1 wounded

May 21, 1998, Springfield, Ore., 2 killed, 22 wounded

May 21, 1998, St. Charles, Mo. , Plan modeled after Jonesboro uncovered

May 21, 1998, Onalaska, Wash., 1 killed

May 21, 1998, Houston Tex. , 1 wounded

May 19, 1998, Johnston, R.I., Threatening notes

May 19, 1998, Fayetteville, Tenn.,1 killed

April 28, 1998, Pomona, Calif., 2 killed 1 wounded

April 24, 1998, Edinboro, Pa., 1 killed

March 24, 1998, Jonesboro, Ark., 5 killed, 10 wounded

TIMELINE: plaintiffs letter of Decmember 22, 1997 to the county board of supervisors.

Dec. 1, 1997, West Paducah, Ky., 3 killed, 5 wounded

Oct. 1, 1997, Pearl, Miss., 2 killed 7 wounded

Feb. 19, 1997, Bethel, Alaska., 2 killed, 2 wounded

Feb. 2, 1996, Moses Lake, Wash., 3 killed, 1 wounded

31. Plaintiff requests specifically that the court take judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1), of the letter plaintiff delivered a to the Santa Barbara County Board of Supervisors on January 22, 1997 (see EXHIBIT ONE) warning of potentials of such violence in Santa Barbara schools.

32. Plaintiff requests that the court take judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of the common knowledge and verifiable facts relating to notes threatening violence found at; Dos Pueblos high school, Goleta Valley Junior high and San Marcos high school. Plaintiff further requests the court to notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) the proposition that none of the 18 instances of violence (or threatened violence) above involved females as the perpetrators and that the author of the threatening note found at San Marcos High school has not been identified and that the notes were found in the approximate anniversary of the shootings at Columbine High School in Colorado. Plaintiff also requests judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of the fact that NONE of the popular theories circulating attempting to explain the extreme violence accounts for the fact that girls were targeted in a number of instances. In fact the theories tend to indicate boys should be targeting other males. Another aspect that deserves judicial notice is that the existing theories do not address is the fact that 5 events of violence occur within a 2 day period of the days of the month. Plaintiffs warnings do address this aspect (EX. TWO, P.10, 5th para. EX. FIVE, P.5, 2nd para.).

33. Plaintiff requests judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of the fact that boys were shooting girls was addressed in his letter (EX. TWO, P.10, 5th para. EX. FIVE, P.5, 2nd para.) and the phenomena of the majority of the violence occurring on very nearly the same day of the month (EX ONE. P.1, 2nd para. EX. TWO, P.7, 3rd para. EX. FIVE P.2, 5th para.)

34. Plaintiff is aware that he can present no accepted approval/accreditation of his authority to understand the psychology driving the violence in the schools. Plaintiff requests for judicial notice of EXHIBIT SEVEN (A.P.A. letter) and EXHIBIT TWENTY TWO pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1), consisting of a letter to the American Psychological Association (A.P.A.) and the response letter from the A.P.A.. Plaintiffs letter to the A.P.A. requests commentary on a 1961 "EMOTIONS and MEMORY" (EXHIBIT TWENTY TWO) a book by David Rapaport and EXHIBIT TWENTY THREE, page 911 of Blacks Law dictionary, "Hypnotism" as well as the opening statement filed by the defendants attorney in Santa Barbara Superior case #220298, EXHIBIT TWENTY FOUR.

35. The process of inference will be needed to assimilate the meaning of the response letter dated, May 22, 2000 from the A.P.A.. The second sentence of the letter implies by its structure that the director of the Ethics Department of the A.P.A. in Washington DC. left the directorship because the plaintiffs letter and its requests had touched on a foundation of factors constituting a MAJOR breach of ethics by psychology in general. The implication of the preceding sentence is that there is NO AUTHORITY in psychology that can competently accredit the plaintiff, his theories or experience or provide competent evaluation of the cause of the extreme violence in the schools across the Nation. Inferentially, the meaning of this paragraph is that the court is the ONLY authority capable of responsible reasoning adequate to empower the plaintiff to act in the protection of his children and children in county schools or the State of California. To do this the court will need to make a decision in the plaintiffs favor based on the evidence of the complaint and the information introduced at trial.

36. Plaintiff requests judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT NINE and EXHIBIT TEN and proposes the court relate the relationship of; page 123 of EXHIBIT TEN .5 "organic effects, normally outside voluntary control", last sentence of the paragraph, "A number of other studies report the reduction of warts as the result of hypnotic suggestion (McDowell, 1949)."; to EXHIBIT NINE, a declaration establishing that the plaintiffs son has warts on his hands that are being treated by a medical doctor. THE SPECIFIC PROPOSITION OF INFERENCE IS: The studies reporting the reduction of warts of EXHIBIT TEN as a result of hypnotic suggestion, infer, that warts can be caused by the same hypnotic influence with a reversed intent. The plaintiff PROPOSES EXTENDED INFERENCE with regard to .6 of page 123, EXHIBIT TEN, antisocial, repugnant or dangerous acts, as well as judicial notice of page 124, .7, "posthypnotic suggestion", and page 125, C2.1, third paragraph, "some people can be hypnotized against their will" where THE CUMULATIVE PROPOSITION OF INFERENCE REQUIRED IS: If the severity of physiological cellular control of tissue growth is possible and post hypnotic suggestion functions in sophisticated numerical counting and "antisocial or dangerous acts" caused by hypnosis are documented as well as hypnosis of a subject against their will and numerous violent events occur on nearly the same day; then the plaintiffs warnings of ENDANGERMENT TO CHILDREN In county schools has a BASIS IN ESTABLISHED FACT (indisputable, California Evidence Code section 452(h) supporting the targeting of females, the timing of the school violence and plaintiffs allegations generally.

37. Additional INFERENCE is PROPOSED in support of the last sentence for integration with the above EXTENDED INFERENCE to; page 125, C2, EXHIBIT TEN "suggestibility.....is somewhat greater for ...girls" and C2.1, "Needs and motivation appear to be related in various ways to suggestibility"; relating by inference to the fact that male students were shooting female students in the school violence, requested for judicial notice on pages 8 and 9 of this complaint. Judicial notice of EXHIBIT FIFTEEN is requested pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) in support of the preceding sentence as well as its relationship in time to the hearing of the plaintiffs motions on July 17, 2000 or the need for proper discretionary legal action of the court.

38. Plaintiffs ex-wife, Defendant S. B. was informed of plaintiffs concern for the potential of her nieces suicide in 1993 (plaintiff is uncertain of exact date) approximately 6 months prior to her nieces suicide. Three days following the suicide of her niece plaintiff reminded her of his concern that was emphasized in a statement made by plaintiff in 1993 consisting of this language. "I hope she makes it." (referring to the nieces 18th birthday) Approximately one week prior to the birthday, she, the niece, Bianca R. G., overdosed on over-the-counter sleeping pills. S. B. did not at the time remember the plaintiffs earlier statement when the plaintiff attempted to remind her. Four days later she remembered and was emotionally distraught for a period of at least two days.

39. Defendant W. P. witnessed defendant S. B.'s emotional distress and her verbalization of her recall of the plaintiffs making the statement, predicting the suicide six months prior to its occurrence. Defendants W. P. and S. B. have been informed of plaintiffs contention that his son has been subconsciously influenced and is endangered physically, (see EXHIBIT NINE and TEN) by inference of page 10 paragraph 33 of this complaint, plaintiffs son is psychologically endangered. The defendants continued inaction despite knowledge of plaintiffs legal actions and violations of laws by the county and the escalation's in school violence and plaintiffs continually increasing body of evidence supporting his contentions, constitutes by omission, CHILD ENDANGERMENT

40. Defendants S. B. and W. P. have been informed of the fact that on May 23, 1998, plaintiffs son was rendered somnambulistic, placed in a somnambulistic trance at the "State and A" restaurant by another patron when plaintiff left his son at their table alone for less than 2 minutes. Defendant S. B. arranged and insisted, that the plaintiff take his son to lunch and the Arlington theater on that day at that time for the premier of "Godzilla" and that the plaintiff and his son eat before going to the movie. To assist in assuring that they were at that place at that time the defendant S. B. offered to pay for everything. When plaintiff explains to her that she facilitated the meeting in time because she was influenced unconsciously by hypnosis she becomes indignant and angry with plaintiff, refusing to listen to plaintiffs concerns for his son.

41. Plaintiff requests judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT SIXTEEN, Arlington theater receipt from "Godzilla", dated May 23, 1998.

42. When the plaintiff mentions these facts, the suicide and the theater and the unconscious hypnosis, defendant S. B. becomes angry and threatens to prevent the plaintiff from visiting his son, further endangering the defendants son.

43. Plaintiff requests judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b) & 454 (a)(1) of EXHIBIT TWENTY TWO, page 175 and 176 of "EMOTIONS and MEMORY", D. Rapaport, 1961, and EXHIBIT TWENTY THREE, Blacks law, 3rd Edition, page 911, hypnotism. Plaintiff requests judicial notice pursuant to California Evidence Code section 452(h), 453(a)(b), & 454 (a)(1) of "a proposition beyond reasonable dispute" as derived from EXHIBIT TWENTY TWO. The first sentance of page 175 of EMOTIONS and MEMORY,

"The general tendency" of the subject to forget the events of the trance after emerging from it."

(1) of the same paragraph states that, "The hypnotist can successfully suggest that no posthypnotic amnesia develop". In other words, suggestion conducive to remembering is successful. If this is so it is a reasonable proposition "not subject to dispute" that suggestion to forget will be more successful because of the general "tendency to forget" presented as the first sentence of the section. At the top of page 176 there is the end of a footnote that begins on page 175 stating, "we find hypnotized people indignantly denying they have been hypnotized." This paragraph is in support of plaintiffs contention that S. B. has been influenced with hypnosis evidenced by her "indignant denial" in conjunction with the plaintiffs experience on May 23, 1998 (see first sentnece of para. 37). With consideration of the next paragraph it also supports plaintiffs contention that children in schools have been influenced with hypnosis and they would not remember the hypnotic contact.

44. The implications of (2) reversed, as well of (4), (page 175 EMOTIONS and MEMORY) with regard to cognitive reinforcements creating severe distortions and the inclusive consideration of multiple subjects, given conditional, reciprocal suggestion motivated by repressed parental complex, fears or desires and phylogenically sourced affectations, can be extreme in memory control as well as action.

45. In final support of the threat to children plaintiff asserts is responsible for the extreme violence in the schools through this complaint, (listed in paragraph 30) the plaintiff requests judicial notice pursuant to California Evidence Code section 452.

(d) Records of (1) any court of this State...........

452(h) and 453(a)(b) and 454(a)(1)

of EXHIBIT TWENTY FOUR, Two pages of opening Statement at trial September 8, 1998 filed by attorney to the defendant in Santa Barbara County Superior Court case 220298, filed August 12, 1997. Respondent requests judicial notice of a SPECIFIC PROPOSITION OF INFERENCE demonstrated by EXHIBIT TWENTY FOUR with the respondents declaration of this paragraph. California Evidence Code section 452 (h) "Facts and propositions that are not reasonably subject to dispute. The second page of EXHIBIT TWENTY FOUR at lines 1-4, "This tort action arises out of a claim by plaintiff Christopher Brown that Defendant Medicine man inflicted "harmful hypnotic telepathy" on him from 1959 to "present."

I Christopher Brown declare under the penalty of perjury under the laws of the State of California that I did not and have never used the word telepathy prior to September 8, 1998 and that the word is introduced by the defendant as derived by inference from the plaintiffs answers to interrogatories and requests for admissions.

Date;

Christopher A. Brown

46. Respondent requests judicial notice of a SPECIFIC PROPOSITION OF INFERENCE California Evidence Code section 452 (h) Facts and propositions that are not reasonably subject to dispute. The text of the second page of EXHIBIT TWENTY FOUR does not contain a denial of the plaintiffs assertions or allegations in case 220298. It does contain a compiled description of the hypnotic activities derived from plaintiffs answers to interrogatories and requests for admissions, facts totally unnecessary to the defense although their presence in the opening statement supports the defense attorney quotation of plaintiffs assertions of lines 7-11 and by stating that the descriptions "would not constitute a cause of action".

47. Defendant S. B. abuses prescription drugs, alcohol and cocaine, past and present, and provides a poor model of femininity or maternal/parental guidance for her son resulting in the boys escapism into computer games. His self esteem has been compromised in this and S. B.'s relationships with men has brought the child in contact and control of alcoholic individuals who have applied psychological abuse and further damaged his self esteem and confidence inhibiting his social instincts. Plaintiffs son has been targeted for ridicule by classmate(s) Dan M., who called in June of this year to apologize to plaintiffs son for teasing him for his non social behavior. Defendant W. P. unwillingly; due to his daughters abusive reactions to his objections, behavioral patterns plaintiffs son is learning; empowers his daughter in her activities constituting CHILD ENDANGERMENT.

48. As a proximate result of the negligence or intent of all defendants, plaintiff was hurt and injured in his health, strength, reputation and activity, sustaining injury to his person, depriving the plaintiff of his economic ability and legal rights to protect his children and the community of children they are a part of. All of which injuries have caused, and continue to cause, plaintiff great mental, physical, nervous pain and suffering, humiliation, mental anguish and emotional distress. Plaintiff is informed and believes and thereon alleges that the injuries will result in some permanent disability to him. As a result of such injuries, Plaintiff has suffered general damages in an amount according to proof.

49. As a further proximate result of the negligence of Defendant, County of Santa Barbara, Plaintiff and his children have incurred, and will continue to incur, medical and related expenses in an amount according to proof.

50. As a further proximate result of the negligence of Defendant, County of Santa Barbara, and the other defendants, plaintiffs earning capacity has been greatly impaired, both in the past and present in an amount according to proof. The impairment has detracted from and reduced his ability to protect his children. Plaintiffs children are of a community of children and plaintiff must protect the community of children to provide competent protection for his own.

51. I Declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Date;

Christopher A. Brown

52. WHEREFORE, Plaintiff prays for judgment against the Defendants and each of them as follows.

FIRST CAUSE OF ACTION

1. for general damages according to proof.

2. for medical and related expenses according to proof.

3. for loss of earnings according to proof.

4. for costs of suit incurred herein.

5 for such other and further relief as the Court deems proper.

SECOND CAUSE OF ACTION

(see 1.,2.,3.,4., & 5 of FIRST CAUSE OF ACTION)

THIRD CAUSE OF ACTION

(see 1.,2.,3.,4., & 5 of FIRST CAUSE OF ACTION)

FORTH CAUSE OF ACTION

(see 1.,2.,3.,4., & 5 of FIRST CAUSE OF ACTION)

FIFTH CAUSE OF ACTION

(see 1.,2.,3.,4., & 5 of FIRST CAUSE OF ACTION)

Date;

Christopher A. Brown,

in propria-persona