Failure to preserve records

I had an attorney who had agreed to read and edit my legal filings. He refused to make appearances for me. He expected the County to file a demurrer and that I would receive permission to amend my complaint.

1. Defendant Medicine man, a.k.a. Gray Wolf, is and at all times herein mentioned was, a resident of the County of Santa Barbara, State of California.

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

3. 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 as herein alleged were proximately caused by that intent and/or negligence.

4. 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.

5. 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.

6. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned, Defendant Medicine man is, and was, a Medicine man of the coastal band of Chumash Native American Indians of Santa Barbara, and under the control of the 'antap' and directly responsible for the creation and maintenance of the oral histories of said Native Americans.

7. Plaintiff is informed and believes and thereon alleges that the 'antap' is an ancient society/organization comprised of spiritual leaders of native Medicine people who only communicate, through and during the extremely deep hypnotic trances of an unconsciously networked group of people, controlled by hypnosis, over longer than normal periods of time.

8. Plaintiff is informed and believes and thereon alleges that at all times herein mentioned on or about June 1, 1959 and continuing to the present, in an effort to establish officially an understanding of their hypnotic abilities, the Medicine man, at the direction of the 'antap', hypnotized, instructed, and manipulated Plaintiff, Plaintiffs family members and others, without their conscious knowledge, so as to psychologically control Plaintiff's actions, thoughts and emotions, and approximately cause the injuries and damages described below.

9. Plaintiff is informed and believes and thereon alleges that Defendant Medicine man removed Plaintiffs natural memory and prerogative of choice, based therein as a child, through the use of hypnosis by using desires in Plaintiffs subconscious mind created by the Native Medicine community. Plaintiff further alleges that Defendant Medicine man then exploited the desires in a conspiracy involving Plaintiff but kept secret from the Plaintiff by the use of hypnotic memory control and consumed Plaintiffs natural life and it's benefits or rewards, psychologically, emotionally, socially, culturally and economically for a minimum of 38 years for the purpose of forcing Plaintiff to take legal action to create again an official understanding; and to make the Native Medicine community conscious of their hypnotic skills; and to recover the truth of the Chumash peoples past.

10. Plaintiff is informed and believes and thereon alleges in the exploitation of the conspiracy, Defendant Medicine man controlled Plaintiffs life dynamically without Plaintiffs conscious awareness and used hypnosis to control others to present opportunities for fulfillment of desires created artificially in Plaintiff at childhood, with hypnosis. Plaintiffs past is now comprised of bizarre events conceived by Defendant Medicine man and other Medicine people.

11. As a proximate result of the intentional acts of Defendant Medicine man, Plaintiff was hurt and injured in his health, strength, and activity, sustaining injury to his person, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical, and nervous pain and suffering. 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.

12. As a further proximate result of the intentional acts of Defendant Medicine man, Plaintiff has incurred, and will continue to incur, medical and related expenses in an amount according to proof.

13. As a further proximate result of the intentional acts of Defendant Medicine man, Plaintiffs earning capacity has been greatly impaired, both in the past and present in an amount according to proof.

14. Plaintiff realleges paragraphs 1-5 of the general allegations and paragraphs 6-13 of the First Cause of Action, and incorporates them herein as if set out in full.

15. Plaintiff is informed and believes and thereon alleges that, at all times herein mentioned, Defendant Santa Barbara County had a duty to maintain preserve and make available public records, including local Courts and County Board of Supervisors meetings, as the legal custodian.

16. Plaintiff is informed and believes and thereon alleges approximately 750 of the civil commitment case files of the local Court, from the period 1875 to 1885, were and are, either missing, lost or destroyed.

17. Plaintiff is informed and believes and thereon alleges that a letter in his possession from the Clerk of Court documenting the inconsistencies of the District Court case file Index and the Insanity records on microfilm indicate that an unusual event of enormity occurred in and around those years. The letter states that the Index shows 72 insanity actions in the years, 1876 to 1878. Plaintiff alleges that this number of civil commitment proceedings is abnormally high and that the letter also documents 65 more case files than are listed in the Index.

18. Plaintiff is informed and believes and thereon alleges that the Santa Barbara County Board of Supervisors conducted secret meetings for the months of March and April of 1876. Plaintiff is further informed and believes and thereon alleges that the missing, lost or destroyed minutes of those meetings contain references to the massacres of Native people and references to the secreting of the public records.

19. Plaintiff is informed and believes and thereon alleges that the incompleteness of the Court cases for the years 1875 to 1876 combined with the lack of page numbers, lack of dates for listed cases, or a beginning or ending date for the Index, document an effort by Santa Barbara County to conceal or hide the actual size of a serious event(s) occurring in Santa Barbara County before and after 1876.

20. Plaintiff is informed and believes and thereon alleges that the County of Santa Barbara breached its duty as the legal custodian of such public records by the acts described in the paragraphs 16, 17,18 and 19 above.

21. Plaintiff further alleges that the neglect to make free to the public, public records consisting of approximately 750 District Court case files, caused the 'antap' to hypnotically, by the use of Defendant Medicine man and the Native Medicine community, over many decades, to exploit with impunity the ignorance of the public, the Plaintiffs parents and the Plaintiff and to conspire unconsciously in the community to control, dynamically, plaintiffs life.

22. Plaintiff is informed and believes that this loss of meaning or reconstitution of meaning of 38 years of memory by this diabolical method, as it is recently discovered by the Plaintiff, represents an irreversible condition of mental anguish for the remainder of the Plaintiffs life as the truth of the depth of the hypnotic manipulation endured impacts the Plaintiffs future emotionally, psychologically and physically.

23. As a proximate result of the negligence of Defendant, County of Santa Barbara, Plaintiff was hurt and injured in his health, strength and activity, sustaining injury to his person, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical, and nervous pain and suffering. 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.

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

25. As a further proximate result of the negligence of Defendant, County of Santa Barbara, Plaintiffs earning capacity has been greatly impaired, both in the past and present in an amount according to proof.

26. Plaintiff realleges paragraphs 1-5 of the general allegations and paragraphs 6-13 of the First Cause of Action and paragraphs 14-24 of the second cause of action, and incorporates them herein as if set out in full.

27. At all times herein mentioned, Defendant County of Santa Barbara had a duty to maintain and preserve public records. At all times herein mentioned Defendant Medicine man had a duty to not hypnotically influence Plaintiff without Plaintiffs conscious awareness or knowledge

28. On or about June 1, 1959, the County of Santa Barbara neglected to maintain the public record and caused from that time, and continuing to the present, Defendant Medicine man, at the direction of the 'antap', to hypnotize, instruct and manipulate Plaintiff within the conspiracy kept secret from the Plaintiff, without Plaintiffs conscious knowledge or consent, so as to psychologically control Plaintiffs thoughts actions and emotions; or to inflict the removal of the Plaintiffs right to a natural destiny and deprivation of freedom to select and work with natural memory for the prerogative of choice throughout Plaintiffs life to the present.

29. Medicine man's conduct was intentional and malicious and done for the purpose of causing Plaintiff to suffer, humiliation, loss of reputation, mental anguish and emotional and physical distress for the purpose of forcing Plaintiff to take legal action. Defendant County of Santa Barbara's conduct was done with knowledge that Plaintiffs emotional and physical distress would thereby increase, and was done with a wanton and reckless disregard of the consequences to Plaintiff.

30. As a result of the aforementioned acts Plaintiff was hurt and injured in his health, strength and activity, sustaining injury to his person, all of which injuries have caused, and continue to cause, Plaintiff great mental, physical, and nervous pain and suffering. 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.

31. As a result of the aforementioned acts, Plaintiff has incurred, and will continue to incur, medical and related expenses in an amount according to proof.

32. As a result of the aforementioned acts, Plaintiffs earning capacity has been greatly impaired, both in the past and present in an amount according to proof.

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