Pinal County, a Political Subdivision, Sheri Cluff, Clerk of the Board, Pinal County Board of Supervisors, Pete Rios,

Supervisor, District 1, Bryan Martyn, Supervisor, District 2, David Snider, Supervisor, District 3, 31 N. Pinal Street Building A Florence, AZ 85132; Pinal County Sheriffs Office Paul Babeu, Sheriff 971 Jason Lopez Circle Building C Florence, AZ 85132; James Walsh, Pinal County Attorney, 30 N. Florence St Building D Florence, AZ 85132 RE: Notice of Claim Pursuant to A.R.S. 12-821.01 (A) To whom it may concern: Mark Dixon, undersigned, and referred to hereinafter as (Claimant/Victim) hereby gives his formal Notice of Claim pursuant to A.R.S. 12-821.01 (A). Claimant/Victim makes the following allegations based on facts, affidavits of witnesses, and statements made by County employees directly to Claimant/Victim, all of which are supported by incontrovertible evidence. This matter has been brought before the above named parties referred to hereinafter collectively as the (County), not for any malicious purpose, nor to harass the County, but solely in the name of Justice. In addition, Claimant/Victim, also gives formal notice, that the actions, inactions, crimes, and conspiracies, willfully preplanned and committed against him by sworn officers of the Pinal County Sheriffs Office, have unquestionably resulted in blatant deprivations of the Claimant/Victims Civil Rights, which are

secured and protected by the Fourth, Fifth and Fourteen Amendments of the Constitution of the United States, the Constitution of Arizona, and other significant State and Federal Laws. Therefore, the Claimant/Victim, hereby gives notice that pursuant to 42 U.S.C. 1983, 1985, 1986, 1988, that he is not barred from immediately initiating a Civil Rights action in Federal District Court which has original Jurisdiction pursuant to 28 U.S.C 1331 and 1343, as well as the authority to grant declaratory relief pursuant to 28 U.S.C. 2201 that the County and/or its employees, did willfully knowingly, and maliciously failed to provide the Claimant/Victim equal protection under the law. I. STATEMENT OF FACTS 1. On December 1, 2009, at 2:49 p.m., the Claimant/Victim received a telephone call from an individual who identified himself as Corporal Clarke, of the Pinal County Sheriffs Office. Clarke informed Claimant/Victim that pursuant to a statement made by Carol Lee Dixon,1 that the Claimant/Victim was in possession of property belonging to her, (a dog named Shilo) and that if the Claimant/Victim did not surrender the animal, that the Pinal County Sheriffs would arrest the Claimant/Victim for theft. 2. Upon receiving this information, the Claimant/Victim informed Clarke, that the animal was in fact his property, and that he could produce documentation that proved the Claimant/Victims ownership of the animal. Clarke flatly refused to consider the

Carol Lee Dixon, is in fact the ex-wife of the Claimant/Victim. The two were recently divorced in April of 2009, as a result of a divorce petition initiated and filed by Ms. Dixon, said petition was uncontested by the Claimant/Victim. Prior to the divorce, despite positive efforts by the Claimant /Victim to obtain proper medical and psychological care for her condition, Ms. Dixon continued to display erratic and irrational behavior, including a suicide attempt.

Claimant/Victims side of the story, and ended the conversation with threats that he would forward a complaint to the Office of the Pinal County Attorney for Criminal Prosecution. 3. As a result of the conversation described in 1-2 above, on December 1, 2009, at 3:01 p.m., the Claimant/Victim contacted the Pinal County Sheriffs Office, and asked to speak to a Supervisor, after taking down his contact information he was advised that someone would call him back. 4. On December 1, 2009, at 3:27 p.m., the Claimant/Victim received a telephone call from the Pinal County Sheriffs Office, from an individual, who identified himself as Sergeant Cody. The Claimant/Victim advised Cody, of his previous conversation with Clarke, and further advised Cody, that the animal was in fact his property, and again offered to produce documentation that proved the Claimant/Victims ownership of the animal. This conversation concluded with Cody stating that he would look into the matter and contact the Claimant/Victim with his findings. 5. On December 1, 2009, at 3:33 p.m., Cody, contacted the Claimant/Victim with his findings, and informed the Claimant/Victim that while he disagreed with the manner in which Corporal Clarke was handling the matter, it was not within his authority to intervene or interfere with another Deputys investigation. 6. On December 2, 2009, at 1:15 p.m., the Claimant/Victim, along with his dog2 (Shilo), who has been the Claimant/Victims constant 24/7 friend and close companion for the past two and one half (2 1/2) years, both left from their residence located at 10380 W. Pasadena, in route
Because of their longstanding, and close emotional attachment, the Claimant/Victim had gone to the expense of having a computer chip, surgically implanted into Shilo by a certified professional Veterinarian, to insure her positive identification by any other Veterinarian or Animal Control Officer, to insure Shilos, quick and safe return, should she for any reason become separated from the excellent care, protection, as well as the constant love and affection she is provided by the Claimant/Victim, a single father who has also been awarded custody of both of his two children (one male, and one female) by the Pinal County Superior Court.
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to the Pinal County Attorneys Office, located in Florence, Arizona, for the sole purpose of presenting the ownership documents, previously ignored by Deputies of the Pinal County Sheriffs Office, as stated in 2 and 4 above, to put an end to the matter in controversy once and for all. 7. The Claimant/Victim, intentionally brought Shilo, confident that the County Attorneys Office, would as a matter of due diligence and its duty to insure the Claimant/Victims Fourteenth Amendment right to due process, would summon a Pinal County Animal Control Officer, who could, electronically verify Shilos ownership, resulting in a positive identification in favor of the Claimant/Victim, and take proper action, including an immediate dismissal of any criminal charges that may have been improperly initiated as threatened by Clarke, as shown in 2 above, who had refused to assert any due diligence or fair consideration of the Claimant/Victims Civil Rights in his investigation. 8. Upon leaving their residence, as previously identified in 6 above, Claimant/Victim, with Shilo in the vehicle as a passenger, proceeded West on Pasadena, and as required by law, properly signaled to indicate his intention to make a right hand turn, after which he made a complete stop at the intersection of Pasadena and Belaire. The pair then proceeded North on Belaire, and once again, upon approaching the intersection of Belaire and Woodruff, as required by law, properly signaled to indicate his intention to make a right hand turn, after which he made a complete stop at the intersection of Belaire and Woodruff. The pair then preceded East on Woodruff a very short distance when the Claimant/Victim, became aware that a Red Sport Utility Vehicle (SUV), with flashing lights was close behind him. 9. Quickly making the assumption that the vehicle was a Fire Department, Emergency Response Vehicle, responding to an emergency, the Claimant/Victim, as required by law

immediately signaled to turn right, and pulled off the pavement, onto the right hand shoulder of Woodruff, and made a complete stop, in a lawful and responsible effort to allow the Emergency Vehicle to safely pass. 10. Rather than pass, the Red SUV with lights still flashing, came to a stop behind the Claimant/Victims vehicle. The Claimant/Victim, in his rear view mirror, then observed a white male, dressed in plain clothes, exit the Red SUV and approach the Claimant/Victims parked vehicle which contained the Claimant/Victim as well as his companion Shilo. 11. Upon reaching the Claimant/Victims vehicle the plain clothed individual walked up to the driver side window of the Claimant/Victims vehicle and without making any effort to properly identify himself to the Claimant/Victim, demanded that the Claimant/Victim hand over his driver license.3 The Claimant/Victim then inquired as to the reason he had been pulled over? This individual, later determined to be a Detective Goode of the Pinal County Sheriffs Office, alleged that the Claimant/Victim had made an illegal right hand turn, and further stated the Claimant/Victim failed to signal a right hand turn, before preceding East on Woodruff after stopping at the intersection of Belaire and Woodruff. Upon receiving this questionable explanation, the Claimant/Victim complied with Goodes request to examine the Claimant/Victims driver license, at which time Goode, with the Claimant/Victims driver license in his possession, returned to his unmarked vehicle with the Claimant/Victims driver license.

The Claimant/Victims proof of insurance and registration were never requested as is common procedure in a routine traffic stop.

12. The Claimant/Victim was then startled by a second plain clothed individual,4 later identified as Sergeant LeBlanc, who appeared outside of the Claimant/Victims Driver side window. LeBlanc, having deliberately postured himself immediately outside of the Claimant/Victims vehicle, stood with his gun hand readied on his side-arm in a threatening, calculated manner as if his true intention was to draw his weapon and fire upon Claimant/Victim. The Claimant/Victim was then startled by an third plain clothed individual,5 who also unexpectedly appeared outside of the Claimant/Victims passenger side window, and postured himself in a threatening manner similar to that of LeBlanc.6 13. The Claimant/Victim asked LeBlanc, if his actions were in regards to the Claimant/Victims dog and LeBlanc stated that it was. LeBlanc then asked the Claimant/Victim if he would surrender Shilo and the Claimant/Victim informed LeBlanc that he would not, and that he was already in route to the County Attorneys Office to properly address the pending Criminal charges, and to provide the County Attorney with documentation to resolve the matter of Shilos true ownership. 14. LeBlanc then informed the Claimant/Victim that his drivers license was suspended and he had the authority arrest the Claimant/Victim, as well as impound his vehicle (a significant tool necessary for the Claimant/Victim to provide a living for himself and his children) for a minimum of 30 days, if the Claimant/Victim refused to submit to his threats and surrender Shilo. LeBlanc then implied that he would refrain from such actions if the Claimant/Victim agreed to surrender Shilo to him.
4

This individual was unquestionably the Supervising Officer in charge, who directed the dubious actions of the other Deputies.
The identity of this third plain clothed Deputy is yet to be determined.

The Claimant/Victim later ascertained that these two individuals had approached his vehicle from an unmarked blue sedan, they had concealed behind the Red SUV driven by Goode.

15. Goode then approached from the Red SUV and notified the Claimant/Victim that his Arizona Driver License was in fact suspended. Faced with the option of being deprived of his liberty or submitting to the illegal seizure and unconstitutional deprivation of Shilo, the Claimant/Victim reluctantly agreed to submit to the extortion conspiracy, and surrender his companion Shilo to LeBlanc. 16. After further discussion LeBlanc agreed to follow the Claimant/Victim back to his residence so the Claimant/Victim could obtain Shilos leash and surrender her. After arriving at his residence,7 the Claimant/Victim again politely asserted that Shilo legal belonged to him and assured LeBlanc, that he could produce credible witnesses that could confirm Shilos ownership. LeBlanc then informed the Claimant/Victim that Carol Lee Dixon alleged that Shilos computer chip would confirm she was the legal owner.8 17. The Claimant/Victims son James Dixon, having arrived at the residence at the same time as his father, and the Pinal County Sheriff Officers, also pleaded with LeBlanc to allow him the opportunity to produce witnesses as well. The Claimant/Victim then produced credible documentation, including a certificate, that lists the Claimant/Victim as Shilos registered owner, which was issued by the Veterinarian who surgically implanted Shilos computer Chip, a License issued by the Pinal County Animal Care and Control, a Rabies Vaccination Certificate issued by the Casa Grande Animal Hospital and an invoice issued by the Casa Grande Animal Hospital receipting that the Claimant/Victim had invested over One Hundred and Fifty Dollars ($150.00)9

The fact that these three deputies instructed the Claimant/Victim to illegally operate his vehicle with a suspended driver license to obtain a leash for the dog, implies a pre-conceived plan had been made for the sole purpose of obtaining the Claimant/Victims dog. 8 No attempt was made to summon an Animal Control Officer to electronically scan the computer chip.
9

See STATE v. HERNANDEZ, 121 Ariz. 544 (App. 1979) A.R.S. Sec. 13-621(A) states: "A person who, for his own gain . . buys, sells, possesses, conceals or receives personal property, knowing or having reason to believe that the property is stolen . . . is guilty of a felony if the value of the property is one hundred dollars or more"

to ensure Shilo was well and would continue to be healthy. All of these documents provide a preponderance of incontrovertible evidence establishing that the Claimant/Victim is and continues to be the legal owner of Shilo (see EXHIBITS 1-4). 18. None of the evidence swayed LeBlanc, in his unrelenting resolve to illegally seize Shilo from her proper owner. Further, LeBlanc failed to produce any Court issued Warrant, Writ, Civil Standby Order or any other valid Order signed by a Judge, which would have given him the authority to seize Shilo from her legal owner.10 LeBlanc, after examining the Claimant/Victims ownership documents, took some written notes and then advised James Dixon that if he could produce affidavits that proved Shilo belonged to the Claimant/Victim, Shilo would be returned to James father. James Dixon then inquired to LeBlanc as to what he was going to do with Shilo, and LeBlanc advised him that it was his intention to deliver Shilo to Carol Lee Dixon.11 19. The Claimant/Victim then surrendered Shilo, leash and all to LeBlanc, who along with the other Deputies appeared to be vacating the Claimant/Victims premises. The Deputies already heading to their vehicles to leave, suddenly hesitated and after a short conference between LeBlanc and Goode, that was held out of ear shot of both James Dixon and the Claimant/Victim, Goode prepared a citation directed against the Claimant/Victim for driving on a suspended license, which Goode handed to LeBlanc who in turn, handed to the Claimant/Victim (see Exhibit 5). LeBlanc then further offered threats to the Claimant/Victim, by
No reasonable person, nor Judge nor Jury, in good conscience, can deduce that the alleged illegal right turn discussed in 11, constitutes probable cause which would legally authorize the Deputies to seize the Claimant/Victims property within the scope of the Fourth Amendment of the United States Constitution, especially in the absence of any Court issued documents. As suggested by Deputy Cody in 2 above, this matter was the result of a Criminal investigation proper procedure would be to confiscate and secure the animal as evidence until the matter could be decided by a Judge. LeBlancs actions broke the chain of evidence which suggested that Clarkes alleged criminal investigation was nothing more than a fraudulent unfounded threat.
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stating that if any of the information he had given to LeBlanc were false, or there were any problems, that LeBlanc would come back and arrest him for driving on a suspended license.12 20. The Claimant/Victim then had his son James Dixon drive him to the Casa Grande City Court, and after determining that a previous civil traffic matter he previously thought had been resolved, was still outstanding, paid the required fine. James Dixon then drove the Claimant/Victim to the Arizona Department of Motor Vehicle Office (DMV). Upon receiving the required documentation showing that the deficiency, which had resulted in the suspension of the Claimant/Victims Driver License had been resolved (See Exhibit 6), the Claimant/Victims Drivers license was reinstated (See Exhibit 7). 21. On December 3, 2009, at approximately 12:00 p.m. James Dixon, as discussed in 18 above, obtained several affidavits from individuals asserting that Shilo was in fact owned by the Claimant/Victim (see Exhibits 8-13). As previously instructed by LeBlanc, James delivered said affidavits to the Pinal County Sheriff Office located at Trekell Road and Cottonwood lane in Casa Grande. The documents were entrusted to a Sheriffs Office employee to be given to LeBlanc, for proper consideration. 22. On December 4, at 8:32 a.m. the Claimant/Victim contacted the Pinal County Sheriffs Office and left message requesting LeBlanc to contact him so a meeting could be arranged to resolve this matter. To date no call has been received, and this inaction has resulted in the filing of this Notice of Claim pursuant to A.R.S. 12-821.01 (A). II. POINTS OF STATE AND FEDERAL LAW 23. The above statement of facts sadly documents a shocking and repulsive account of an arrogant abuse of authority perpetrated by the very individuals who have been entrusted by the
The Claimant/Victim was in fact never issued a citation or warning for the alleged illegal right hand turn which also implies that the deputies in fact staged the traffic stop, resulting in a brazen criminal scheme, executed in excess of the deputys authority.
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citizens of Pinal County to abide by their solemn oath which pursuant to A.R.S. 38-231 (E), clearly states that they are required to support the Constitution of the United States and the Constitution and laws of the State of Arizona 24. Article II, Section 4, of the Arizona Constitution, definitively states that, No person shall be deprived of life, liberty, or property without due process of law. In addition, Article II, Section 2, which precedes section 4, definitively states that, All political power is inherent in the people, and governments derive their just powers from the consent of the governed, and are established to protect and maintain individual rights. Most importantly, Article II, section 1, which precedes all of the Articles of the Arizona Constitution, cited herein, definitively states, A frequent recurrence to fundamental principles is essential to the security of individual rights and the perpetuity of free government. 25. There is no question that the Pinal County Sheriffs Office has the duty to investigate any matter which is brought to their attention. With this duty also comes the responsibility to fairly and impartially conduct all investigations in a matter that protects the Civil Rights of the all of parties being investigated. The Federal Courts have shown that they have little or no tolerance for State Officials who fail to do so. See SCREWS v. UNITED STATES, L325 U.S. 91 (1945) at Page 129; with the United States Supreme Court stating: Generally state officials know something of the individual's basic legal rights. If they do not, they should, for they assume that duty when they assume their office. Ignorance of the law is no excuse for men in general. It is less an excuse for men whose special duty is to apply it, and therefore to know and observe it. If their knowledge is not comprehensive, state officials know or should know when they pass the limits of their authority, so far at any rate that their action exceeds honest error of judgment and amounts to abuse of their office and its

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function. When they enter such a domain in dealing with the citizen's rights, they should do so at their peril, whether that be created by state or federal law. For their sworn oath and their first duty are to uphold the Constitution, then only the law of the state which too is bound by the charter The United States Supreme Court further stated: officials who violate it must act in intentional or reckless disregard of individual rights and cannot be ignorant that they do great wrong. This being true, they must be taken to act at peril of incurring the penalty placed upon such conduct by the federal law, as they do of that the state imposes 26. As clearly shown in 1-2 above, Clarke, had already tried and convicted the Claimant/Victim before he ever made contact with him. The callus and prejudicial manner in which he conducted his investigation and phone interview with the Claimant/Victim, implies not only that he had already established a questionable alliance with Carol Lee Dixon, but that he would also go to any length to enforce his position by offering threats in an attempt to intimidate the Claimant/Victim into surrendering property which the Claimant/Victim could clearly prove belonged to him (See EXHIBITS 1-4). If Clarke, through his investigation, had obtained evidence deemed sufficient enough to compel the County Attorneys Office into seeking a Criminal Indictment, then why didnt he forward the matter to the County Attorney in the first place? Why didnt the Pinal County Sheriffs Deputies properly refer Carol Lee Dixon to the Justice Court who has been granted the authority to decide such matters instead of abusing their limited authority by improperly taking the law into their own hands?

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27. Pursuant to A.R.S. 13-1804 A.(5) A person commits theft by extortion by knowingly obtaining or seeking to obtain property or services by means of a threat to do in the future any of the following: 5. Accuse anyone of a crime or bring criminal charges against anyone 26. An examination of the facts stated above in 12 within the meaning of the simple language contained in A.R.S. 13-1804 A.(1) A person commits theft by extortion by knowingly obtaining or seeking to obtain property or services by means of a threat to do in the future any of the following: 1. Cause physical injury to anyone by means of a deadly weapon or dangerous instrument These same facts when considered within the provisions of A.R.S. 13-1804 C. Theft by extortion as defined in subsection A, paragraph 1 is a class 2 felony. Otherwise, theft by extortion is a class 4 felony A.R.S. 13-1804 C when examined in the contexts of the facts unquestionably provides clear and convincing evidence that LeBlanc, and the unidentified deputy have managed to have effectively taken the present level of corruption, already alleged by the media and believed by the Public at Large to be particularly prevalent in the Pinal County Sheriffs Office, to a disgustingly new low by taking actions that equate to being nothing less than a class 2 felony within the meaning of A.R.S. 13-1804 C! 27. Additionally the facts stated above in 14 and 19, when considered within the meaning of the simple language contained in A.R.S. 13-1804 A.(7), which states that A person commits theft by extortion by knowingly obtaining or seeking to obtain property or services by means of a threat to do in the future any of the following:

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7. Take or withhold action as a public servant or cause a public servant to take or withhold action the only question left to answer here is who is going end up under the bus, Sergeant LeBlanc or Carol Lee Dixon? 28. The facts stated above in 1-2, 12,14, and 19 provide a preponderance of evidence that Corporal Clarke, Carol Lee Dixon, Detective Goode, Sergeant LeBlanc and the unidentified deputy, all knowingly and willingly committed the crime of theft by extortion within the meaning of A.R.S. 13-1804 as defined in subsection A, and set forth in paragraphs 1, 5, and 7. 29. Pursuant to A.R.S. 13-1003A. A person commits conspiracy if, with the intent to promote or aid the commission of an offense, such person agrees with one or more persons that at least one of them or another person will engage in conduct constituting the offense and one of the parties commits an overt act in furtherance of the offense The facts as examined in 26-29 above leave no question that the individuals listed in 29 above, willingly and intentionally conspired to commit the crime of theft by extortion as evidenced by the fact that Shilo was unlawfully seized from her true owner as shown in 17 above, and further made evident through (EXHIBITS 1-4). 30. As is the case with A.R.S. 13-1003A, similarly, 42 U.S.C. 1985(3) states If two or more persons in any State or Territory conspire or go in disguise on the highway or on the premises of another, for the purpose of depriving, either directly or indirectly, any person or class of persons of the equal protection of the laws, or of equal privileges and immunities under the laws In addition 42 U.S.C. 1985(3) further provides:

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in any case of conspiracy set forth in this section, if one or more persons engaged therein do, or cause to be done, any act in furtherance of the object of such conspiracy, whereby another is injured in his person or property, or deprived of having and exercising any right or privilege of a citizen of the United States, the party so injured or deprived may have an action for the recovery of damages occasioned by such injury or deprivation, against any one or more of the conspirators Why is it that a federal law designed to combat and quash the Ku Klux Klan after the civil war now can be applied to the actions of the Pinal County Sheriffs Office? 31. A.R.S. 13-1003B. further states that If a person guilty of conspiracy, as defined in subsection A of this section, knows or has reason to know that a person with whom such person conspires to commit an offense has conspired with another person or persons to commit the same offense, such person is guilty of conspiring to commit the offense with such other person or persons, whether or not such person knows their identity Therefore it must follow that Sergeant Cody, named in 4 and 5 above, while appearing to be an unwilling participant in this Conspiracy, may also be guilty of the crime of theft by extortion as stated in 29 above. 32. The federal question of Sergeant Codys guilt is easily answered by 42 U.S.C. 1986 which definitively states, Every person who, having knowledge that any of the wrongs conspired to be done, and mentioned in section 1985 of this title, are about to be committed, and having power to prevent or aid in preventing the commission of the same, neglects or refuses so to do, if such wrongful act be committed, shall be liable to the party injured, or his legal representatives, for all damages caused by such wrongful act, which such person by reasonable diligence could have prevented; and such damages may be recovered in an action on the case;

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and any number of persons guilty of such wrongful neglect or refusal may be joined as defendants in the action 33. There is no question that Sergeant Cody has the duty to abide by conform to the solemn oath as discussed in 23, and to adhere to the principles stated in 24 and to properly apply the laws as discussed in 24. 34. As provided by A.R.S. 13-1003 C. A person who conspires to commit a number of offenses is guilty of only one conspiracy if the multiple offenses are the object of the same agreement or relationship and the degree of the conspiracy shall be determined by the most serious offense conspired to Therefore as shown above in 28-34 and as provided by A.R.S. 13-1804 C. all six (6) of the above named parties may be found guilty of a Class 2 felony. 35. As shown by the facts stated in 2-4, 6-9, 13, and 16-22 above, the Claimant/Victim has made every reasonable attempt to assert his Civil Rights, each time being forcefully and intentionally denied any opportunity of being afforded the equal protection of his rights guaranteed to him by the Fourth and Fifth Amendments to the Constitution of the United States of America, by the very individuals whom the Fourteenth Amendment commands to uphold and provide due process protection. 36. Pursuant to A.R.S. 11-201 A. The powers of a county shall be exercised only by the board of supervisors or by agents and officers acting under its authority and authority of law. This begs the question of what authority did the County act under in the actions taken by its officers described in the paragraphs above? 37. A.R.S. 11-202 A. states that Each county is a body politic and corporate, possessing all the powers expressly provided in the constitution or laws of this state and such

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powers as are necessarily implied therefrom Therefore, it must follow, that the County, as required of all branches of state government, must strictly adhere to all of the requirements of the Arizona Constitution and that its purpose is that it has been established to protect and maintain individual rights! It also follows that the County, pursuant to A.R.S. 11-201A.(1), has the power to: Sue and be sued. 38. The Supreme Court and Justice Rehnquist recognized the necessity for citizens to be able to assert their Civil Rights in Federal Courts in PARRATT v. TAYLOR, 451 U.S. 527 (1981)101 S.Ct. 1908 by stating: The Court recognized as much in Monroe v. Pape, 365 U.S. 167 (1961), when we explained after extensively reviewing the legislative history of 1983, that "[i]t is abundantly clear that one reason the legislation was passed was to afford a federal right in federal courts because, by reason of prejudice, passion, neglect, intolerance or otherwise, state laws might not be enforced and the claims of citizens to the enjoyment of rights, privileges and immunities guaranteed by the (Page 53) Fourteenth Amendment might be denied by the state agencies." Id., at 180. III. CONCLUSION 39. Surely, the County Officials whose private names appear on the first page of this Notice of Claim, and who have been entrusted with the power, duty and obligation that their official positions require, obtained their given authority, not through illegal seizure or unscrupulous, tyrannical actions, but rather through the consent and approval of the honest hardworking Citizens who elected them, based on their character, honesty and uncompromising ability to recognize, strike down and correct a grave injustice whenever it raises its ugly head . Over One Hundred (100) years ago, the United States Supreme Court in United States v. Lee, 106 U.S. 196 (1882), unequivocally stated:

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No man in this country is so high that he is above the law. No officer of the law may set that law at defiance with impunity. All the officers of the government, from the highest to the lowest, are creatures of the law, and are bound to obey it. The Supreme Court then sincerely added: It is the only supreme power in our system of government, and every man who by accepting office participates in its functions is only the more strongly bound to submit to that supremacy, and to observe the limitations which it imposes upon the exercise of the authority which it gives 40. The Claimant/Victim; in a good faith effort to allow the County a fair opportunity to correct, investigate, prosecute and properly redress the grave injustices; which the Countys duly sworn agents, while illegally masquerading under the color of Arizona State Law, have undeniably, knowingly and maliciously caused to be visited upon the Claimant/Victim; which has resulted in intentional, and willful deprivations of the Claimant/Victims Civil Rights, Privileges and Immunities guaranteed to Claimant/Victim and all Arizona Citizens, by and through the Supreme Law, which is the Constitution of the United States of America, as properly stated in the Arizona State Constitution and further supported by other Arizona and Federal Laws; the Claimant/Victim respectfully offers the following Terms of Settlement. III. TERMS OF SETTLEMENT a. As just compensation for the Countys Duly Sworn Agents intentional, malicious and illegal actions, which in return caused the Claimant/Victim to deprived of the constant support, security, comfort, as well as love and affection of his companion Shilo, the Claimant/Victim will accept $1,000.00 per day commencing on Wednesday December 2, 2009, until such a time that

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Claimant/Victims irreplaceable, companion Shilo is safely returned to him, unharmed and in a healthy condition as previously documented and made evident in attached (EXHIBIT 4). b. As just compensation for the Countys Duly Sworn Agents intentional, malicious and injurious behavior as described in a. above which has caused and continues to cause the Claimant/Victim, constant worry, mental anguish, pain and suffering, loss of sleep, all of which has manifested into a noticeable decline of the Claimant/Victims physical health and well-being as made evident by a dangerous, and measurable increase in the Claimant/Victims blood pressure, which in return has resulted in a decrease of the Claimant/Victims ability to productively and safely operate heavy equipment, which in return has caused and continues to cause the Claimant/Victim financial losses for which he will accept $1,000.00 per day commencing on Wednesday December 2, 2009, until such a time that Claimant/Victims irreplaceable Companion Shilo, is safely returned to him, unharmed and in a healthy condition as previously documented and made evident in (EXHIBIT 4) and as previously stated in a. above.

c. As just compensation for the Countys Duly Sworn Agents having entered into a conspiracy to extort his property by employing various threats as shown in above which resulted in a blantent deprivation of the Claimant/Victims Civil Rights. The County shall pay to the Claimant/Victim, no less than $50,000.00 composed of $10,000 for each of the Countys five (5) deputies directly involved in this malicious and felonious assault on the Claimant/Victims Civil Rights. d. Claimant/Victim demands that the named deputies be immediately put on

administrative leave and a thorough investigation commence. Upon completion, a complete report to be forwarded to the Pinal County Attorneys Office for charging review. By this

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statement the ClaimantNietim exercises his Right to be apprised of all phases of any resulting prosecutions. e. As to Ms Carol Lee Dixon, the ClaimantNictim also wishes that formal charges be brought against her for False Reporting to a Police Officer, as well as any and all other Criminal Charges deemed to be appropriate for her part in this Criminal Conspiracy. By this statement the ClaimantNictim exercises his Right to be apprised of all phases of any resulting prosecutions.
f. ClaimantNictim reserves the right to seek civil relief in Federal Court against the

Conspirators, the County and its agents in their official and/or individual capacities if the equitable relief is not granted. Dated December

2009
.....

MarkDixon ~z~ P.O. Box 12695 Casa Grande, AZ 85130 (520) 705-2945

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