Motion for Emergency Injunctive Relief
In order to have a resolution to this issue
before school starts it is logical that a motion for emergency injunctive
relief in the form of an immediate trial is needed. On July 17, 2000 all
motions were denied and all requests for judicial notice were also denied.
1. Plaintiff hereby does move for a MOTION TO SHOW CAUSE for not granting EMERGENCY INJUNCTIVE RELIEF in the form of IMMEDIATE TRIAL for the civil action of Christopher A. Brown against the defendants, county of Santa Barbara and the Hanson cement company. The motion is based on the NOTICE OF MOTION, the REQUEST FOR JUDICIAL NOTICE of the exhibits attached to the complaint for CHILD ENDANGERMENT introduced as EVIDENCE justifying EMERGENCY INJUNCTIVE RELIEF and the declaration of Christopher A. Brown, and on such evidence as may be presented at the hearing of the motion.
Date;
pro per plaintiff, Christopher A. Brown,
PLAINTIFFS REQUESTS FOR JUDICIAL NOTICE
OF "COMMON KNOWLEDGE AND VERIFIABLE FACTS" AND EXTREME BEHAVIORS BY ADOLESCENTS IN SCHOOLS.
2. 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 of the "common knowledge and verifiable facts" as fulfillment of public confidence.
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
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
Plaintiff requests specifically that the court take judicial notice of the letter plaintiff delivered a to the Santa Barbara County Board of Supervisors on January 22, 1997 (see EXHIBIT ONE) warning of such violence in Santa Barbara schools.
REQUEST FOR JUDICIAL NOTICE
3. Plaintiff requests that the court take judicial notice 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 asks the court to recognize that none of the 18 instances of 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 time of the anniversary of the shootings at Columbine High School.
JUSTIFICATION OF EMERGENCY INJUNCTIVE RELIEF IN FORM OF IMMEDIATE TRIAL
4. Plaintiffs submission of this motion is predicated in the results of Santa Barbara Counties unaccountability concerning missing court case files as described in S.B.co.SUP.CRT case #220298, justifying EMERGENCY STATUS with relief in the requested form. Unaccountability is demonstrated in two denials of Subpoena duces tecum (complaint EXHIBIT THREE), upon the custodians of public records of Santa Barbara County (see paragraph 14. of complaint).
Due to the deprivation of fair hearings and contempt of court resulting in lost publicity, income and facility to gain legal representation or treatment for his injuries, plaintiffs daughter has been molested, S.B. co. SUP. CRT. M992970. Plaintiff has lost his rental residence, most belongings, been targeted for an automobile accident and further neglect to lawfulness will prevent plaintiff from acting in a fashion that protects his children and children in the schools, generally ENDANGERING CHILDREN. Additionally a danger to plaintiffs life is constituted in the continued conspiracy, making, with this motion, an emergency, personally for the plaintiff.
REQUEST FOR ORDER
5. Plaintiff respectfully requests that the order of the court resulting from this motion be in writing and set a date for trial no later than 30 days from the filing of this motion.
DECLARATION OF CHRISTOPHER A. BROWN
6. I Christopher a. Brown Declare on June 19, 2000 under the penalty of the laws of perjury of the State of California that the foregoing is true and correct.
Date;
Christopher A. Brown