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Huminski federal Complaint USDC (Connecticut) - draft 1

Huminski federal Complaint USDC (Connecticut) - draft 1

Ratings: (0)|Views: 113|Likes:
Published by Sheriff_Joe_Arpaio
Facial attack upon unconstitutional harassment laws and corrupt police.
Facial attack upon unconstitutional harassment laws and corrupt police.

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Published by: Sheriff_Joe_Arpaio on Jul 10, 2014
Copyright:Traditional Copyright: All rights reserved

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07/31/2014

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original

 
1 In The
United States District Court (Conn.)
S
COTT
H
UMINSKI
, for himself and ) Those similarly situated, ) P
LAINTIFF
 ) v. ) CIVIL ACTION S
TATE OF
C
ONNECTICUT
, ) G
OVERNOR
S
HUMLIN
, ) DOCKET
 
 NO. S
TATE OF
V
ERMONT
, ) A
TTORNEY
G
EN
.
 
W
ILLIAM
S
ORRELL
, ) G
OVERNOR
M
ALLOY
, ) C
ONNECTICUT
A
TTY
.
 
G
ENERAL
J
EPSON
, ) T
HE
S
TATE OF
A
RIZONA
, ) G
OVERNOR
J
AN
B
REWER 
, ) A
RIZONA
A
TTORNEY
G
ENERAL
H
ORNE
, ) T
OWN OF
G
ILBERT
,
 
A
RIZONA
, ) G
ILBERT
P
OLICE
D
EPARTMENT
 ) D
ETECTIVE
D
EBRA
H
ARTIN
, ) G
ILBERT
P
OLICE
J
OHN
D
OE
#1 ) T
OWN OF
W
ILTON
C
ONNECTICUT
, ) W
ILTON
P
OLICE
D
EPARTMENT
, ) D
ETECTIVE
P
ETE
T
REHAN
, ) JURY
 
TRIAL
 
DEMAND C
ITY OF
S
URPRISE
,
 
A
RIZONA
, ) S
URPRISE
P
OLICE
D
EPARTMENT
, ) L
T
.
 
J
OHN
B
ACON
, ) L
T
.
 
H
AROLD
B
RADY
, ) O
FFICER
H
ECTOR
H
EREDIA
, ) P
OLICE
O
FFICER
H
ECTOR
H
EREDIA
, ) C
ITY OF
 N
ORWALK 
,
 
C
ONNECTICUT
, )  N
ORWALK
P
OLICE
D
EPARTMENT
, ) C
OMMONWEALTH OF
M
ASSACHUSETTS
, )
 
2 MA
 
A.G.
 
M
ARTHA
C
OAKLEY
, ) G
OV
.
 
D
EVEL
P
ATRICK 
, ) T
IM
D
ORN
, ) D
EFENDANTS
. )
Complaint for Declaratory and Injunctive Relief Declaratory Action 28 USC § 2201, 42 USC § 1983, 42 USC §§ 1985(2),(3)
 NOW COMES, Scott Huminski ("Huminski") and hereby complains follows: INTRODUCTION This action constitutes a facial and as applied attack upon the harassment statutes of Connecticut and Arizona and the common law of Vermont as violative of the First Amendment, Due Process and that they are unconstitutionally vague and over-broad on their faces. This action also seeks declaratory and injunctive relief against law enforcement and governmental employees that issued threats against Huminski under the color of State harassment laws and
colluded and conspired to violate Huminski’s rights
, privileges and immunities secured under the United State Constitution. 42 U.S.C. § 1983, 42 U.S.C. §§ 1985(2),(3).  Numbered Section of Complaint 1)
 
Jurisdiction is proper under federal question jurisdiction, notably the constitutionality of State harassment statutes and threats issued under the color of State law. 2)
 
All claims are brought jointly and severally. 3)
 
 No monetary damages or relief is sought in this lawsuit. 4)
 
Huminski brings this action on his own behalf and on behalf of the 10 million residents of Arizona, Connecticut, Massachusetts and Vermont concerning the patently unconstitutional harassment laws of those States and zeal of law enforcement to use State law to obstruct civil litigation and other protected expression.
 
3 5)
 
All claims are brought in individual and official capacities and, as this matter constitutes a facial challenge upon State statutes, the Governors and Attorney Generals of the various states have been included as defendants.
6)
Surprise, Arizona police officer, Hector Heredia, issued a written email threat against Huminski under the color of AZ Rev. Stat. § 13-2921 stating as follows:
 This is Officer H. Heredia #2019 from the Surprise Police Department. I would like to inform you that Mr. Michael [sic] Nelson filed a
harassment 
 complaint with this department today. Mr. Huminski I would like to set up an interview with you reference this
harassment
allegation. My scheduled work days are Wednesday through Saturday 6:00  A.M. to 4:00 P.M. Please do not have any type of contact with either Michael [sic] Nelson or Anthony Tsontakislaw until I speak with you and hear your side. You can call me at 623-222-4262 to set up an interview or leave a message when you will be able to come during the mentioned work days and hours. Thank-you. (emphasis added)
7)
 
The Heredia email was issued the day prior to a civil hearing in an Arizona court case Huminski v. Nelson. Anthony Tsontakislaw[sic] was the attorney for defendant Mr.  Nelson. The civil matter was to secure a restraining order against Justin Nelson to  protect Huminski, his wife and his minor niece and nephew who Nelson admittedly showed a sadistic interest in. Mr. Nelson issued death threats against Huminski and his wife. Justin M. Nelson (murdered in October, 2012 related to this litigation) admitted he was the closest friend and advisor of Sheriff Joseph Arpaio and discussed matters related to this litigation at family breakfast with Sheriff Joe Arpaio, allegedly putting Huminski
in the crosshairs of Sheriff Arpaio and the Maricopa County Sheriff’s Office for
retaliation. Mr. Nelson indicated that he was a practicing sadist and wish to have sadistic
contact with Huminski’s minor niece and nephew in Connecticut. Nelson had made efforts to track down Huminski’s niece and nephew in Connecticut.
8)
 
Mr. Nelson was a law enforcement insider in Arizona and a close friend and advisor of Sheriff Arpaio, Officer Heredia engaged in the threat against civil litigation in solidarity
with Sheriff Arpaio and to protect the Sheriff’s close friend, Justin Nelson, a law enforcement insider. Noteworthy is the issue that Mr. Nelson’s attorney, Anthony
Tsontakis, is legislative counsel for the Arizona legislature and also a strong supporter and friend of Sheriff Arpaio. Upon information and belief, Officer Heredia issued the threat prohibiting litigation with Mr. Tsontakis to support a politically well-connected legislative counsel Anthony Tsontakis and a close friend and advisor of Sheriff Arpaio.
9)
Surprise, Arizona police officer, Hector Heredia, stated the following in police taped telephone conversations with Huminski (emphasis added),
 

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