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19. This paragraph is dedicated specifically to IMPD Lt./VEC Security Guard James Waters.

Since IMPD James Waters became the Security Guard for the VEC in year 2002, he had literally

advanced his career in IMPD at the Plaintiff expense. Plaintiff was arrested and transported

directly mental hospital. Police were using immediate detention only to justify own wrongful

arrest and they know it. Even if I was “crazy and mental” that’s not a crime. There was no life

treating situation for myself or anyone else which meets the standard of Indiana Law under

immediate detention. Immediate detention to Mental transportation was used to phishing that I

might be using a drug just because told by IMPD James Water. I was forced to take the drug test

for because IMPD James Waters’ accusations illegally.

19(a) In my Complaint-docket#1 ¶20, “On 6th day of March 2008; around 1430

hours, Lt. James Waters burned his police car engine to intimidate and

harass the Plaintiff as she was going into her building-4250. Lt. James

Waters had a smirk on his face. The Plaintiff knew instinctively that she

has to brace herself…... The Plaintiff was wondering why IMPD James

Waters and his cronies, VECHOA Board and the neighbors in Building

#4250 were intensifying their hostilities to her in March 2008. As this suit

is going forward the Plaintiff found the answer to her own question a

couple of months ago in 2009.

19(b) The Statue of limitation on all the 3 criminal cases’ which year is 2005,

2006 and 2007 ran out at the latest on March 2, 2008 as per “Order of

appointment of Special Judge” dated 2nd day of March, 2007 from the

Indiana Supreme Court no. 49S00-0702-SJ-62 (The Plaintiff just want the

Court to note the Date of the Order and the Plaintiff did not know that

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IMPD Lt James Waters part of 2009fed1Summary judgment 17JUL2009
Supreme Court Order existed until this year 2009..) James Waters’

feeling is hurt when the Plaintiff did not get convicted for the three

previous arrests and he conspire with others and have me arrested in

November 6, 2008. No cops with right mind of state will arrest me on last

year 2008. His conspiracy will not stop and will get only worse depend

on outcome of this lawsuit. In this Court, left me to defend myself last

time by dismissing my first lawsuit which situation worse is the proof. On

last March 6, 2008 incident-¶19(a)initiated by him was the subtle way to

show/tell me that he will not stop his harassment and intimidations by

more arrest of me which he did on Last arrest Nov 6, ‘08. How lucky I’m

that I get arrest once a year. If that is not the pattern and practice, I don’t

know what that could be. There are so many heartaches, degrading,

ridicules, etc., along the way by the Defendants that I had/have to endure

because one vs. Village, Indiana State and Federal. He is

empowered/anointed by the VEC HOA Boards, the Property managers,

especially building 4250 owners/residents to make me move out by any

means all for that matter dismissed my first lawsuit-1:05-cv-1616 by this

Court. I will suffer whoever I move/go live anywhere in the U.S. If I

(we) move out, this will only get worse because IMPD James Waters’

determinations to use me as to build his network/power to further his

career as he was/is doing.

19(c) The Court did not provide the Plaintiff with a copy of the Supreme Court

Orders and I, Kay Kim ran into by chance. IMPD James Waters

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was in close tap on my all case(s) because he was the mastermind behind

all the arrests and plan next attack.

19(d) Whenever the statute of limitation is any of her case is about to expire he

stirs up a new scheme and conspires with Defendants 2 & 3, his cronies in

IMPD, VECHOA Boards, Property Managers, Building 4250 Defendants

#3, #4, #5, #8, to get her arrested. He has to appease the VECHOA Board

and VEC residents of building 4250 if he intends to keep his VEC

Security Guard job which provided him a condominium unit free of

charge for the last 8 years. As a result the Plaintiff gets arrested on her

own property without probable cause on an average once a year. The

Plaintiff is not allowed to excise her rights as an owner of the condo unit.

19(e) There was a period of about 3 years between IMPD James Waters first

citation in 2002 against the Plaintiff in the VEC property parking lot for a

non-moving violation and her first arrest in year 2005 when he did not

bother her. The reason for the peace was that James Waters and the

VECHOA Board were too busy having sex with the property manager-

Sara Wilson who embezzled about $300,000- $500,000. They do not have

time to entertain #3, #4, #5’s discrimination. #8 Mae Vera and Scott Perry

did not move into VEC until the 2005 arrest.

19(f) When VECHOA Boards did not stop #3 Patricia Ladenthin and #8 Scott

Perry from harassing me in the common area the Plaintiff asked to have

the financial report from VEC Treasurer Bryan Whitfiled. He said, “….

Did you ask financial report when Sara Wilson was the property

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manager?” When the Plaintiff answered “no” he said “Then why are you

asking now?”

19(g) IMPD Lt. /VEC Security guard James Waters is directly and indirectly

involved in all my criminal and civil cases except the City County

Building Case. His involvements in all the cases can be proved beyond

doubts. All The Plaintiff need is an Order from this court or Indiana

Criminal Court to compel MCS Communications Department to produce

CAD/Event Detail History of transcripts for all the incidents on the day of

arrests.

19(h) City County Building ¶42-46 incident/arrest could have been prevented.

There was a chain of events starting with IMPD/VEC Security Guard

James Waters intentionally did not want to stop the 4250 #6 residents for

letting their dog to urinate and excrete on the balcony. IMPD James

Waters, VECHOA Boards, Property manager-Sharon Overley (Defendant

of 1:05-cv-1616) and #3 Patricia L, #4 Linda Handlon of building 4250

were all elated when 4250#6 Karen Herring was making my life hell.

Then 4250 #6 Karen Herring had a toilet overflow causing damages to my

unit. The Plaintiff filed for relief to her damages in the civil court. The

State Civil Court dismissed the case under 12b6 even though the Plaintiff

had claimed and itemized the cost of the damages down to penny and she

also had a court filing and letter from the Defendant admitting guilt. The

defendants in this case learned the trick and want this Court to dismiss the

case under 12b6 too. When the lawsuit was dismissed, there was

community celebration in the VEC. IMPD James Waters and #5 Susan

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Sclipsea knew about the dismissal even before the Plaintiff return home

from the State civil court. 4250 #6 Karen Herring moved out of VEC in

2006. The new owner/resident of #6 Shannon & Kyle Love decided to

move/sell their unit 3 years later. Before they move out they flooded my

unit with toilet water for 3 days. When the Plaintiff buzzed the unit#6 to

get insurance information from Shannon & Kyle Love, he threatened to

call the police and have them arrest her for harassment. He called the

Police but she was not arrested. They assumed that they can get away like

the others. They wanted to use the police to intimidate her. It only can

happen over and over again, because I’m not white. So the Plaintiff

claimed for relief in the Small Claims Court. The Judge started to give

advice to the defendants before the trial as if it is the normal practice and

“fact finding” purpose. A Judge should never decide on a case until he

hears the facts from both parties. Small Claims Court Judge Douglas

didn’t care. He already decided how much damage was caused even

refused to accept Plaintiff’s exhibits for the damage. My first Toilet

Overflow experience, I (we) got about $30. to repaint. I noticed that a

couple of days later yellow color sips through from the bathroom ceiling.

I let other left to imagination what that might be. If they dilute the yellow

colored water to make looks clear water, it will make matter worse

because bigger areas will be contaminated with more serious damage. I

didn’t know what was the proper way to rectify the situation back then.

Anyway, the Judge asked the defendants to get State Farm Insurance to

give an appraisal for the damage repair. Small Claims Court Judge A.

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Stephen Douglas, Court Clerks, and Defendants are as usual busy

networking to screw me up. Even Defense counsel, James A. Edgar is

involved to influence my case which I have no problem with it. It’s free

country. I knew that this suit of Defendants 2 in ¶4, and even, IMPD

James Waters, etc., gang up to influence in even my Small Claims court

lawsuit. Well, I’m learning how the United States justice systems at work

and whatever. Furthermore counsel James A. Edgar wants the Federal

court to “….tamper..” me by convicting me on the 4 criminal cases

without any evidence so that he can share any judgment the Plaintiff may

get from the Small Claims Court. The Plaintiff has to inform him

regrettably that James Edgar may have to wait for a very long time

because this case may be heading to a higher court and thereafter to meet

worse corruptors-Judge Sosin and the staff. This case shows that the

residents/owners of building 4250 are doing the same thing to the Plaintiff

over and over again. This is because they have the blessings of IMPD

Lt./VEC Security Guard James Waters & VECHOA Boards, Property

Manager(s), residents/owners of building 4250 to conspire against the

Plaintiff. Obviously after the sale of the unit they will tell the new owner

her stories and how the police and all levels of courts screwed her over

the years. It is their rights to talk whatever they want and the Plaintiff has

no problem as long as they don’t become a copy cat. Unfortunately most

people become a copy cat and react and repeat the criminal acts against

the Plaintiff. All the malice and criminal acts do not break the Plaintiff

they only make her stronger. The Plaintiff finds some comfort in God and

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that he did not create all human beings equal. This is my short answer to

Defense counsel, James A. Edgar’s brief, “….tamper… “and whatever.

19(i) VEC Security Guard/IMPD Lt James Waters cover up for the unit #6 to his

own delight and to further appease the VECHOA Boards, Property

Managers, and Building 4250 residents/owners. James Waters would like

to keep the security job in VEC permanently. Lt James Waters is using

his cronies and other police under him to continue to arrest me

until the Plaintiff moves out of her unit. All others (VECHOA Boards,

Defendants 2 in ¶4) are conspirators to support the James Waters mission. In

docket #1-Complaint, ¶31, his VEC security report dated June 26, 2008 is a

blatant example of James Waters showing off his power by mocking the

Plaintiff in his security report. Since the Dog and the Toilet Overflow

incidents in 2006 the Plaintiff does not talk to him. The Plaintiff gave up

asking him for help after the “dog excrement” incident was ignored. The

Plaintiff has never complained to him about managements and neighbors.

The Plaintiff cannot excise her rights as an owner of the unit because of

his police connections. On the day of her last arrest on Nov 6, 2008, there

was a scheduled VECHOA meeting which she had intended to attend.

James Waters conspired with the residents of Block 4250 including #5

Charles Ritter to get her arrested so that she cannot attend the meeting.

That is one of the reasons the Plaintiff suspects that #5 Susan Sclipsea and

Charles Ritter do not have to pay the association fee and they become foot

soldier of the VEC HOA Boards and property manager. There are many

people who have not been paying the association fees over the years.

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Elections to the VECHOA Boards are rigged. Once they into the Board

they excuse their “friends” from paying the Association fees. As for the

Plaintiff she gets arrested.

19(j) James Waters got promoted from SGT to Lt. and became IMPD Master

detective and the “chair” for the Police Promotion Board at my expense.

As soon as this suit is over and dismissed, IMPD Lt. James Waters will

again send his cronies to harass the Plaintiff and make her life hell with

more arrests. He has been doing the same to the Plaintiff since he was

Sgt., and now as a Lt. and the Chair of the promotion Board he is

unstoppable and will continue to be the VECHOA Board’s hero to make

the Plaintiff life as miserable as hell. As a policeman in the anti vice

department James Waters is literally raping the hooker(s) in exchange of

non arrests and helping to run the prostitution ring all for that matter, he

might the ring leader with his rank. How in the world did he get promoted

when there are so many more good and honest policemen in IMPD?

IMPD Lt. James Waters is a “junky”. I found out that among his peers, he

is known as the “DOG”.

19(k) All civil matters. No criminal offence has been committed. IMPD James

Waters often employs “entrapment” tactic to catch the prostitutes. He

then, let other cops to arrest him/her for the prostitution. He used the

similar tactics against the Plaintiff. He told other cops by false accusation

about me and the situation; then, let other-lower rank cops to arrest me.

He always stay in the background, but out in the open, he contradicts own

words/acts pretend let others take the fault. My entire life, cops,

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prosecutors and the judges are the highest pyramid scheme of the liar.

Wow! all over the world people look up to the United States for corrupt

free government, police, and judicial system. All the arrest he involved

directly were in my own property under false accusations/witnesses and

no probable cause. As the IMPD Sgt.-Lt./VEC security officer, he can

make own arrest but never because he knows I did not break any laws and

he is familiar with the VEC bye-laws and yet he sent the Police to arrest

me even though no crimes occurred. Our first encounter of IMPD James

Waters was, he came “BANG” on my door with his right hand on the

“GUN” at 3 a.m. because my car parameter sensor chirp for a couple of

times. (Parameter sensor was turned on after 12 p.m. and only chirp for a

second when someone near as a warning. It’s not an alarm.). It has low

decimal and one cannot possibly hear with inside of unit in a normal

setting. Even so, I could have turned off no problem if anyone complaint.

No need for him to behave like that. He wants to make sure that #4Linda

Handlon sees him an action that how he is side of “whites”. That first

encounter, IMPD Sgt. James Waters threatened me for arrest when I

complaint about his conduct the way he handling the situation. Treated

me like some hard core criminal for that. After about 10 hours later knock

on my unit door and gave us a non moving violation citation. We had to

go to the Court. That’s how this thing started. The case was dismissed by

the Environmental Court. Since then he has been using other people and

police to arrest me. It is my humble opinion that Lt. James Waters is at

best a “junkie and pimp”. During the last on November 6, 2008 the

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arresting Police inflicted unnecessary and excessive force on the Plaintiff

who suffered intense internal pain and bleeding for 2 months.

19(l) IMPD James Waters found out how and where the Plaintiff gets her

information in her first federal lawsuit and the criminal courts. He

then used his rank and connections to obstruct her discoveries for her

cases.

19(m) Even if the Court does not care or act on her “unintelligent rumblings”

someone must investigate Lt. James Waters for his involvements in all the

unlawful activities. People take care of their own kind. Judge for judges,

police for police, neighbors for neighbor, etc., and I’m a chopped liver.

So, I don’t expect much; especially, after he got promoted at my expense.

But, not only pay-monetarily to me but at the least, he should be

transferred out of the IMPD or stop working VEC Security Guard.

Because, I was told VEC HOA Boards not going to fire him and let this

Court decide. He should be fired or demoted from his job in IMPD.

Instead he got promoted from Sgt. to Lt. and became the chair of the

Police Promotion Board. He has much power and authority to promote

the police who harass, intimidate and arrest me. He building his

network/power at my expenses. The Plaintiff has seen him transporting

several hookers” in his squad car to and from his home. He can do

whatever he likes so long as it does not involve her. He should move to a

bigger community where he can make much more money and stop

intimidating. This court failed to protect me. Now, it seems conspiring

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with IMPD, Defense counsels and all Defendants in ¶4 to bury me for

good.

20. Because IMPD James Waters told other cops I might be on drug and “crazy”,

IMPD cops uses that as a crutch to arrest me without probable cause. Not only that, entire State

of Indiana Criminal Justice System- Judges, Prosecutors, etc. labeled me as such and try their

best to send me to mental institution ordering repeated mental evaluations. State appointed

psycho doctors are paid by them and they know the rules of the game what kind of

answer/diagnose to come up with. Immediate detention to Mental transportation and other

agencies were used to phishing to get solid proof against the Plaintiff. The Plaintiff reiterate and

reallege that the named and unnamed Defendants are involved in “Conspiracy in Character of the

Agreement” with “Criminal Intent” & under Color of Law against Plaintiff, Kay Kim, Pro. Se.

21. Over the years and up to this day, the Defendants called, slandered and labeled the

Plaintiff as “mental, “crazy” “liars” and “habitual criminal”. The Defendants can call the

Plaintiff whatever they like but repeated criminal incidents and slanders make them liable for

their malicious actions. Many unnamed supervisory Defendants intentionally neglect to stop the

calculated actions against the Plaintiff. The promotion of IMPD James Waters from Sgt. to Lt.

is the most outrageous of them all. It reflects the IMPD’s “Law Enforcement Standard”.

22. The Defendants should know more about the Plaintiff than those mentioned in

this suit and have more evidences against her. The incidents are not mere hear say and innocent

disagreements but criminal malice. Otherwise the lack of evidence and their denial of the

Plaintiff’s accusations shows that the Defendants are lying by their own admissions.

22(a) I, Plaintiff, Kay Kim, Pro Se nominates Event History Detail for all the

arrests in my VEC real and common property as a Designation of

Evidence.

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22(b) I request that the Court Order to the Marion County Sheriff

Communication Department to produce for on the day of all

arrests. It will confirm what the role of IMPD Lt. James Waters’ role

in the arrested of the Plaintiff over and over again as I alleged.

I, Plaintiff, Kay Kim, Pro Se DEMAND the Court to issue an permanent injunction

with own motion against IMPD Lt. James Waters from me, my family and my property from

1, 000. yards in addition to CMP –docketed 120 monetarily and hold the VEC HOA Boards and

the IMPD to holds commensurate restitution/responsibilities against them as it was detailed in

CMP-docketed 120. They conspire intentionally neglected to protect me for reoccurring false

arrests and hardship. Character issue: Linda Handlon brings 3-5differrent male a week (vary by
the wk to mo). With her & James Waters’ life style, it is high probability of something
something. Sharon Overley and JamesWaters’s similar value, it is high probability of something-
umumum. Also, Mr. Jaames A. Edgar knew Linda Handlon before he become her counsel, it is
hight probablity of som’umm som’umm…Did you? If ansewer is yew, she doen’t even have to
pay you $.

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