You are on page 1of 85

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI


CENTRAL DIVISION

ROPERT GIPSON, )
Individually )
)
and )
)
ROBERT GIPSON, ) CASE # 09-4136-CV-C- NKL
as Next Friend of )
Casey Gipson, a minor child )
)
Plaintiffs, )
)
vs. )
)
SENATOR CLAIRE MCCASKILL )
UNITED STATES SENATOR FOR )
MISSOURI, in her official and individual
capacity, AND

SENATOR KIT BOND, )


UNITED STATES SENATOR FOR )
MISSOURI, in his official and individual
capacity, AND )
)
GOVENOR OF MISSOURI )
JAY NIXON, in his official and individual
capacity )
)
FORMER GOVENOR OF MISSOURI )
MATT BLUNT, in his official and individual
capacity )
)
MISSOURI STATE REP. )
TOM SELF, )
)
MISSOURI STATE SENATOR )
DELBERT SCOTT, )
)
MISSOURI STATE SENATOR )
JANE CUNNINGHAM, )
)

1
MISSOURI STATE REP. )
BRIAN NIEVES, )
)
ATTORNEY GENERAL FOR )
STATE OF MISSOURI )
KRISTOPHER KOSTER, )

COMMISSIONER FOR BENTON )


COUNTY )
MARK BRESHEARS, )
)
FORMER BENTON COUNTY )
JUDGE LARRY BURDETT, )
)
BENTON COUNTY JUDGE )
MARK B. PILLEY,
FORMER LAWYER
FOR PLAINTIFF

BENTON COUNTY JUDGE


MICHAEL HENDRICKSON )

MISSOURI CRIME VICTIMS


ADVOCATE
AND OTHERS

)
BENTON COUNTY PROSECUTING )
ATTORNEY KAREN WOODLEY,
AND OTHERS

CRIME VICTIMS ADVOCATE


BENTON COUNTY
NANCY LEONARD )

)
BENTON COUNTY CIRCUIT CLERK )
CHERYL SCHULTZ,
AND OTHERS )
)
POLICE CHIEF CARLISLE S. )
WALKER OF THE )
COLE CAMP POLICE DEPT., )
AND OTHERS )

2
BENTON COUNTY SHERIFF )
RICK FAJEN, )
AND OTHERS
)
POLICE CHIEF )
MICKEY MITTLESTADT OF THE )
LINCOLN POLICE DEPT.,
AND OTHERS
)
FORMER POLICE CHIEF )
KINKINNON OF THE )
LINCOLN POLICE DEPT.
AND OTHERS )
)
STATE OF MISSOURI DIRECTOR )
OF FAMILY SERVICES )
RONALD LEVY, )
)
FORMER STATE OF MISSOURI )
DIRECTOR OF FAMILY SERVICES )
DEBORAH E. SCOTT, )
)
STATE OF MISSOURI )
DIRECTOR OF CHILDREN’S DIV. )
OF SOCIAL SERVICES )
JAMES HARRISON )
)
DESIGNATED PRINCIPAL OF )
SOCIAL SERVICES )
CELESTA SUE HARTGRAVES )
)
BENTON COUNTY CASE WORKER )
DAWN LONG )
)
BENTON COUNTY CASE WORKER )
BEVERLY CHAPMAN )
)
BENTON COUNTY CASE WORKER )
PAULA WOOLERY )
)
BENTON COUNTY SUPERVISING )
CASE WORKER ALICE SHARON )
ZIDLICKY )
)
MISSOURI CHILD ADVOCATE )

3
STEVE MORROW )
)
MR. BROWN OF THE UNITED )
STATES SOCIAL SECURITY OFFICE )
SEDALIA MISSOURI, )
)
DEPUTY HAUN OF THE BENTON )
COUNTY SHERIFF DEPT. )
)
WILLIAM HAEFER; )
Circuit Manager, )
Benton County Children’s Division; )
Supervisor for Benton County )
Children’s Division; )
)
BEVERLEY CHAPMAN, )
Case/Social Worker for Benton )
County Children’s Division; )
)
JAMES JOHNS, ATTORNEY FOR )
BRANDY WILKENSON WARREN, )
)
BRANDY WILKENSON WARREN )
MOTHER OF CASEY GIPSON, )
)
ATTORNEY JAMES RICE,
FORMER ATTORNEY FOR
BRANDY WILKENSON WARREN )

DR. SUSAN WALDO, )


PSYCHOLOGIST
SEDALIA MISSOURI
)
DR. DANIELS, )
PSYCHIATRIST
COLUMBIA MISSOURI )

DR. TIM VUAGNIAUX,


COURT APPOINTED
PSYCHOLOGIST )
)
DR. WALLER )
PSYCHOLOGIST
)
DR. SALINGER (Clinton, MO) )
)

4
DR. JULIE CAHILL,

Tim Vuagniaux
SEDALIA MISSOURI
AND OTHERS

BANK OF AMERICA,
AND OTHERS

CHERYL PETERSEN
Principal Little Blue Bird School
AND OTHERS

LISA WILLOUGHBY
PRE-SCHOOL TEACHER
LITTLE BLUE BIRD SCHOOL

MS JANE DOE
PRE-SCHOOL TEACHER
LITTLE BLUE BIRD SCHOOL

PAMELA PILANT
KINDERGARTEN TEACHER
LITTLE BLUE BIRD SCHOOL

Defendants.

5
COMPLAINT

PART#2

COMES NOW, Robert Gipson, pro se, and for his cause of action for the wrongful

taking and unlawful deprivation of Plaintiff’s rights to parent his minor child, and for the

minor child’s right to be in the custody of his father, against the above named defendants,

and for his unlawful detention, arrest and incarceration by actions of government

employees Plaintiffs mental health and well being has been affected by government

workers to the extend Plaintiff has PTSD from being alienated from his child. Plaintiff

states the following: Suit is being brought against all Defendants in their official capacity

and individual capacity. Plaintiff states that qualified immunity does not exist here for

government workers nor does any other immunity. Defendants violated Plaintiffs Civil

Rights at various times from 2002 to most recent in 2009. Government workers

mentioned maliciously and with malice and while under the color of law, restricted

Plaintiffs having their freedom and right to happiness. Malicious Prosecution and

Malicious Arrest have caused enormous harm against Plaintiff Robert Gipson. For over

six years the unjustifiable and unreasonable excessive civil and criminal litigation against

Plaintiff Robert Gipson has caused in the excess of $250,000 dollars. Some Defendants

listed were often under government contract and violated state and federal laws by

bringing fraud upon the court, perverting the course of justice and violating the civil

rights of the Plaintiffs. Some Defendants listed were mandated reporters and purposely

6
neglected to report neglect and abuse that was reported by the minor child Casey Ryan

Gipson and Plaintiff Robert Gipson father of minor child.

Some Defendants listed knowingly conspired with each other to prosper politically and

financially at the expense of the minor child. Some Defendants listed abused their

judicial powers to oppress Plaintiffs. Some Defendants listed knowingly that a crime had

occurred and had the Authority to act failed to do so. Some Defendants listed tampered

with evidence and obstructed justice. Some Defendants listed knowingly perverted the

course of justice by forging signatures on official court records. Some Defendants listed

slandered Plaintiffs and created excessive litigation in order to embezzle money and

Garnished Plaintiffs bank account. The funds Garnished were Exempt and executed

without a court judgment. Bank of America conspired with James Johns, attorney for

Brandy Wilkenson embezzled money from Plaintiffs account. Defendant Brandy

Wilkenson, James Johns and members from the Missouri Children’s Division conspired

and succeeded in garnishing Plaintiffs Social Security Disability Benefits. Defendant Mr.

Brown from the Sedalia Missouri Social Security Office allowed Brandy Wilkenson to

become the Payee for the money for Plaintiffs child without notifying Plaintiff. Plaintiff

received money for his wounds which occurred in Iraq during his tour in 2003-2004.

Once again in July 2009 Defendant Brandy Wilkenson and her lawyer, James Johns are

attempting to embezzle money from Plaintiff and have accused Plaintiff of conducting a

home Sleep Study and medical testing on his minor child Casey Gipson. Defendants

have orchestrated yet another desperate approach to alienate the minor child from his

father. Defendant Brandy Wilkenson will never stop until she completely and with

malice destroys the bond between Plaintiffs Robert Gipson and son Casey Gipson.

7
Unfounded court orders to restrict the Plaintiffs to the present visitation of five hours

every other Saturday and Sunday has caused and will continue to destruct the family

unity. Police officers from Lincoln Missouri, Cole Camp Missouri and Benton County

Sherriffs office and case workers from the Missouri Children’s Division, conspired to

bring physical and mental harm to plaintiffs. Plaintiff has been subjected to numerous

interviews by police officers and case workers. The minor child has been subjected to

safe house interviews as the direct result of the Defendant Brandy Wilkenson making

false accusations that the Plaintiff Robert Gipson sexually molested his child Casey

Gipson. The Missouri Children’s Division case workers did video these interviews and

refuse to release the video to the Plaintiff even after Plaintiff has requested so in writing

to Ron Levy the Director of the Missouri Family Services and Jim Harrison the former

director of the Missouri Children’s Division. Medical Doctors and Psychologists failed

to inform the court and Authorities about the adverse medical conditions which have

stressed the minor child Casey Ryan Gipson. Psychologist and Psychiatrist who are

mandated reporters failed to report when the minor child Casey Ryan Gipson stated to

them that he was hit in the face by his mother Brandy Wilkenson. Psychologist failed to

protect the minor child when his father and Plaintiff Robert Gipson presented written

reports and documentation of neglect and abuse against the minor child by his mother

Brandy Wilkenson and his step father Jason Warren. Psychologist conspired with case

workers and to gain government contracts and favored case workers from the Missouri

Department of Children Services. Psychologist violated the HEPPA laws by releasing

personal information about Plaintiff Robert Gipson without consent from Plaintiff.

Psychologist ignored witness statements from Plaintiff Robert Gipson about neglect and

8
abuse against the minor child Casey Ryan Gipson. Directors from the Missouri Family

Services and the Missouri Children’s Division ignored and failed to properly investigate

written complaints and Hot Line reports about the neglect and abuse against Plaintiffs

Robert Gipson and Casey Gipson. Video, pictures and CD which showed neglect and

abuse against the child Casey Ryan Gipson was ignored by the Missouri Department of

Family Services which showed the minor child having severe medical problems with

Sleep Apnea, Burn Marks, Excessive bug bites, bruises and Obstructive airway. Reports

of loaded guns, and a home environment that endangered the minor child were ignored

by case workers from the Missouri Children’s Division. Case workers investigated over

fifteen legitimate reports from the Plaintiff Robert Gipson and also third party reports.

These reports reflect back to the first oven burn which the child received when he was a

baby. Reports sinse 2003 to 2009 have been poorly investigated and found to be Un-

substantiated time after time. The Investigations conducted were done so in a Haphazard

and careless process. The minor child was observed with obvious bruises, cuts, excessive

bug bites, smashed face, burnt arm, burnt ear by a cigarette. Reports of the child

observing his mother getting beat by her husband Jason Warren were ignored by case

workers and school principal Ms Peterson of the Cole Camp Elementary in Cole Camp

Missouri. Head wounds received by the child were ignored by school teachers. The

minor child was struck in the head by the rocks which came from an automobile that

caused the wounds. Police reports, witness statements, video, pictures, CD and court

testimony was presented as evidence and ignored by court judges, case workers, police,

psychologist, doctors, lawyers, school teachers, school principal and church pastors.

Third party witnesses were ignored when they reported by Hot Line calls and written

9
statements to the Missouri Children’s Division and state officials of the neglect and abuse

against the minor child Casey Ryan Gipson. Witness statements presented in court in

person and in writing were ignored by judges. Judge Larry Burdett and Judge Michael

Hendrickson’s Final Judgments and court rulings were unfounded. Their rulings were

unsubstantiated and with out merit. Their rulings were Bias against the Plaintiffs Robert

Gipson and Casey Gipson. There was no substantial evidence, no preponderance of

evidence to justify their rulings to modify and court judgments from 2005 to 2009. The

Plaintiffs rights to due process was violated severely Judge Larry Burdett and Judge

Michael Hendrickson allowed their court to be ruled by Brandy Wilkenson and her two

lawyers James Johns and Jim Rice. Case workers manipulated the court proceedings by

bringing fraud upon the court. Excessive litigation has caused Plaintiff Robert Gipson to

lose over $250, 000, 00 dollars and has caused mental anguish that has affected every

fiber of Plaintiffs life. Court orders and rulings by judge Burdett and Judge Michael

Hendrickson have severed the bond between father and son. Judge Burdett and judge

Hendrickson both have failed to up hold their oath of office and have failed to protect the

Constitutional Rights of Plaintiffs. Both judges allowed expert witnesses to get away

with bringing fraud upon the court and perverting the course of justice. Both judges

prevented Plaintiff Robert Gipson from presenting his motions and restricted Plaintiff

from presenting evidence that would be in the best interest of the minor child. Judge

Burdett and Judge Michael Hendrickson violated the Plaintiffs fourth amendment and

created an atmosphere of injustice in their court room. Judge Burdett held court hearings

with out the knowledge of Plaintiff. This allowed Brandy Wilkenson and her lawyer

James Rice favor in their case against Plaintiff Robert Gipson. Judge Burdett along with

10
his clerk of court ignored Plaintiffs request to have his motions heard. The Clerk failed

to give Plaintiff court dates as requested in Plaintiffs motion. It was not until time was up

that Plaintiff was given dates and it was at that time that the Benton County clerk stated

to Plaintiff that she does not read my motions. Plaintiff’s motions requested that the

Clerk provide a time to be heard. Judge Burdett informed the Benton County Clerk, Ms

Schultz not to send Plaintiff a copy of the Final judgment even after Plaintiff put the court

on notice that he was now a Pro-se litigant. Judge Burdett ignored Plaintiffs motion to

request that Jim Rice return Plaintiffs exhibits that were taken from the bench. Plaintiff

first entered pleadings in the Benton County court house in 2003. There has been nothing

but injustice and conspiracy to drain the pockets of Plaintiff through excessive litigation

and to deny Plaintiff his equal rights to be a father to his son.

Some Defendants listed conspired with Brandy Wilkenson Warren and Jason Warren to

bring false accusations of sexual abuse against Plaintiff Robert Gipson. Conspiracy to

bring a Child Protection Order, exparte hearings, child endangerment hearings, false

arrest reports, false contempt actions, false criminal reports, physical threats, threats

against Plaintiffs finances, threats against Plaintiffs home and alienating the minor child

from Plaintiff Robert Gipson. The actions of Defendants have crippled the relationship

between the father, Robert Gipson and his biological son Casey Ryan Gipson. These

atrocities will forever burden the family foundation that was once enjoyed by a loving

father and his precious seven year old child. The destruction and devastation brought

11
against Plaintiffs may be irreversible and may cause a lasting affect of mental disorders

upon Paintiffs.

JURISDICTION AND VENUE

1. This action is brought pursuant to the Constitution of the United States,

particularly the Fourteenth Amendment; the laws of the United States, particularly 42

U.S.C. §§ 1983 and 1988.

2. This Court has federal jurisdiction under 28 U.S.C §§ 1331 and 1343 (a).

3. The events described herein took place in Benton County, Missouri.

Hence, venue is proper within the Western District, Central Division under 28 U.S.C. §

1391 (b).

4. Plaintiffs request and demand a jury trial.

PARTIES

5. The Plaintiff, Robert Gipson is a resident of Benton County, State of

Missouri and is the natural father of Casey Ryan Gipson.

6. Plaintiff Robert Gipson brings this action as the parent of Casey Ryan

Gipson and as the next friend of Casey Gipson, a minor child, who is currently legally

unable to bring this cause to action himself.

12
DEFENDANTS

7. Defendants Senator Claire McCaskill and Senator Kit Bonds, were and still are

the United States Senators for Missouri and was in such position at all times relevant to

this lawsuit. Plaintiff Robert Gipson did on or about August 2007, flew to Washington

D.C. to visit the office of Senator McCaskill. Plaintiff presented documents that clearly

showed neglect and abuse against the minor child Casey Ryan Gipson. Plaintiff

presented documents to the secretary of Senator McCaskill and Senator Kit Bond that

showed probable cause to investigate the accusations made by Plaintiff against the

Defendants of the Missouri Family Services and the Missouri Children’s Division.

Senator Claire McCaskill, Senator Kit Bond and their staff failed to investigate Plaintiffs

complaints and therefore subjected the minor child to further neglect and abuse. Plaintiff

Robert Gipson has endured on going attacks by government workers in the Missouri

Children’s Division and the local police departments. These Malicious attacks resulted in

false arrest and false accusations of child endangerment against Robert Gipson father of

child Casey Gipson. Other reports by third party witnesses were also ignored by Senator

McCaskill and her administration.

At all times relevant herein, Defendants Senator Claire McCaskill, Senator Kit

Bond, and their administrative staff failed to report the neglect and abuse against the

13
minor child Casey Ryan Gipson and failed to conduct a Congressional Investigation as

requested by Plaintiff Robert Gipson. Their failure to protect Casey Gipson has resulted

in further neglect and abuse by Defendant Brandy Wilkenson and others who have

conspired to do the same. As of this date July 4, 2009, Casey Gipson was observed by

Robert Gipson with a burn on the right side of his neck and observed the minor child

coughing at Wal-Mart. Plaintiff Robert Gipson Father of Casey Ryan Gipson has

observed the minor child with mild to severe Sleep Apnea and Obstructive Airway since

returning from Iraq in 2004. Complaints to Senator McCaskill and her administration

have fallen on deaf ears and it was and is in their jurisdiction to act in order to protect the

children of Missouri. When malicious criminal acts have been levied against such an

innocent child it is the duties of our elected officials to act. Senator Claire McCaskill and

Senator Kit Bonds are mandated reporters. Failure to report and investigate is within

their jurisdiction. The atrocities brought against the minor child Casey Ryan Gipson and

his father Robert Gipson has been documented. Documents were hand delivered by

Plaintiff Robert Gipson and also by e-mail. Log entries from 2006 to 2009 clearly

showed probable cause to conduct an Investigation against the Missouri Family Services

Director Debra Scott and the Missouri Children’s Division Supervisors, case workers and

other principals who violated the civil rights of Plaintiffs. This government body has

jurisdiction to act and to protect the citizens of Missouri when they are attacked by their

own government. Further neglect to assist in the on going abusive power against

Plaintiffs by the Missouri agencies mentioned is a direct violation of the Oath of Office

signed and presented by Senator Claire McCaskill and Senator Kit Bond. The State of

Missouri and its Citizens deserve protection by its leaders and Plaintiffs Robert Gipson

14
and Casey Gipson have yet to receive such protection.

8. Defendant, Former Governor for the State of Missouri, Matt Blunt and

his staff did receive in person and by e-mail documents and reports that clearly show

probable cause to investigate allegations of child neglect and abuse against Plaintiff

Casey Gipson. Accusations of Malicious intent to bring harm against Plaintiff Robert

Gipson were also reported to Matt Blunt and Jessica Windshield, Matt Blunts secretary

for Missouri constituents. Former governor Matt Blunt failed Plaintiffs by not acting in

accordance with his oath of office, Former governor Matt Blunt ignored the pleas from

Plaintiff Robert Gipson to investigate the crimes brought against him and his child Casey

Ryan Gipson. Plaintiff Robert Gipson requested that a Congressional Investigation be

conducted against the Missouri Family Services and the Missouri Children’s Division.

Plaintiff Robert Gipson was ignored by Matt Blunt and Jessica Windshield. The result of

Matt Blunts poor leadership resulted in the minor child Casey Ryan Gipson and his father

Robert Gipson to be maliciously attacked with criminal intent by case workers in the

Missouri Children’s Division. Jessica Windshield under the direct supervision of Matt

Blunt disregarded and lost important documents presented to them by third party

witnesses and Robert Gipson Plaintiff. During one visit to the former governor’s office,

Plaintiff Robert Gipson met with Jessica Windshield. Ms Windshield laughed in

Plaintiffs face as she sat behind her desk. There were three other people present. One

female sat to the left and behind Plaintiff and two males were at adjacent desks. Jessica

Windshield laughed as she degraded Plaintiff Robert Gipson by saying that she does not

have a file on the minor child Casey Ryan Gipson. Plaintiff Robert Gipson presented

15
Jessica Windshield with more documents and once again requested a scheduled meeting

with then Governor Matt Blunt. All requests were ignored and the files were once again

lost. Governor Matt Blunt and his administrative staff were involved in a law suit which

involved documents being shredded and lost. Plaintiffs Civil Rights were violated by

Matt Blunt and his staff. This government agency failed to protect the Plaintiffs and their

Un-ethical job performance violated the Plaintiffs Constitutional Rights. Plaintiffs Rights

to be protected by their government was and continues to be violated. Jessica Windshield

conspired with Debra Scott and the Missouri Children’s Division. Her vicious Bias attack

against Plaintiffs and her attempt to tamper with evidence was and is a federal violation

by a state worker. Former Governor Matt Blunt was in position to act and failed to do so.

There was and continues to be great injustice against Plaintiffs. There was probable

cause for Matt Blunt, Jessica Windshield and the office staff to act. Severe mental

anguish and physical injuries are a direct result of this administrations failure to protect

Plaintiffs. Plaintiffs Right to Protection was violated. A conspiracy between Jessica

Windshield and the Missouri Children’s Division was a direct result of no action taken to

protect the minor child from neglect and abuse. Plaintiff Robert Gipson questions if

Jessica Windshield attempted to schedule any meeting between Plaintiff Robert Gipson

or even presented the documents in question to then Governor Matt Blunt. Not once was

Plaintiff Robert Gipson contacted by Matt Blunt and at no time was a meeting scheduled.

At all times relevant herein, Defendants Matt Blunt and Jessica Windshield

violated office policies and regulations. Their acts may fairly be said to represent official

policy or were pursuant to the governmental custom of such a Government capacity, and

thereby the State of Missouri. Failure to protect the Constitutional Rights of a Citizen

16
and when two or more conspire to bring harm against any person is a felony crime.

When executed by a Government Official this does not allow this official any immunity

and if convicted of such crime is subject to be incarcerated. If such crime causes long

term affect as with the Plaintiffs Casey Ryan Gipson and Robert Gipson, such retroactive

compensatory damages and punitive damages as deemed necessary in the court of law.

10. Defendant, Governor Jay Nixon was at all times relevant herein, the

Governor assigned Ron Levy as the Director of the Missouri Family Services. Governor

Nixon assigned Ron Levy to over see the work of the entire Division and the supervisors

within the Division. Governor Jay Nixon received documents from Plaintiff Robert

Gipson which contained information identifying child neglect and abuse. Third parties to

said claim also presented valuable evidence and documents to same. Governor Nixon to

date has failed to conduct a proper investigation into the allegations reported by Plaintiff

Robert Gipson. As a result Plaintiffs Robert Gipson and his minor child also Plaintiff

Casey Ryan Gipson by and through his father have come under attack by various

government workers from the Missouri Children’s Division. Request by Plaintiff Robert

Gipson to meet with Governor Jay Nixon has been ignored. Numerous documents

presented to Governor Jay Nixon identifying child neglect and abuse against the minor

child Casey Ryan Gipson has been ignored. This agencies failure to act and protect

Plaintiffs has resulted in recent abuse against the minor child Casey Ryan Gipson and

minor child’s father Robert Gipson. Governor Jay Nixon and his staff failed to protect

Plaintiffs from the on going blatant attacks from case workers and local police in Benton

County Missouri. Plaintiffs Pleas for help have not been answered. Since Jan 2009 and

after Jay Nixon’s oath of office, Plaintiff Robert Gipson has pleaded with the staff of Jay

17
Nixon. Plaintiff Robert Gipson has personally visited the office of Jay Nixon and his

constituents’ staff. Plaintiff has been waiting since Jan 2009 for a response from

Governor Jay Nixon and his staff. This administration has failed to protect the

Constitutional Rights of Plaintiffs. Plaintiffs have reported numerous times of criminal

violations against them by government workers from the Missouri Children’s Division.

It has been six months since Plaintiff Robert Gipson has reported to this new

administration of the criminal acts and conspiracy to cause mental and physical harm

against Plaintiff Robert Gipson and his son Casey Ryan Gipson. Governor Jay Nixon is a

mandated reporter and has failed to repot and protect the Constitutional Rights of

Plaintiffs. The Right to pursue happiness without experiencing excessive force has and

continues to haunt Plaintiffs. In 2006 when then Attorney General Jay Nixon was in

office, Plaintiff and third party witnesses presented evidence and statements of neglect

and abuse against the minor child. Again, this information was ignored. Now that Jay

Nixon is the governor of Missouri, he continues to ignore the pleas from Plaintiffs. The

new Attorney General Kristopher Koster has evidence and statements from plaintiff and

third parties that show good reasons to investigate Plaintiffs claims. This administration

failed to investigate the child neglect reports. This is a direct violation under the color of

law under the Missouri mandated reporting statutes and laws.

11. Defendant, At all times relevant herein, Defendant Kristopher Koster was

presented with evidence and statements that clearly showed neglect and abuse against the

minor child Casey Ryan Gipson. Plaintiff states that once again that this government

agency as have all the others mentioned above have failed to protect the Constitutional

18
Rights of the Plaintiffs and have allowed criminal activities to take place under their tour

of duty. Plaintiff Robert Gipson in 2009 also visited the office of the Missouri Attorney

General Kristopher Koster. Plaintiff was told by the office staff that his complaint was

being investigated by a member of the Attorney Generals staff. Plaintiff was told this by a

White Male and a Dark Skin Female while standing in front of their desk. To date no one

from this agency has contacted Plaintiff. Plaintiff first contacted the Attorney Generals

Office in 2006 when Plaintiff was first accused of sexually molesting his precious child

Casey Ryan Gipson. Plaintiff also reported the criminal acts and community corruption

by the Lincoln Missouri, Cole Camp Missouri and Benton County Sheriffs Departments

against Plaintiffs.

12. Defendant, Tom Self, district representative in Benton County Missouri

was notified in 2006 after the first accusation that Plaintiff Robert Gipson first sexually

molested his minor child Casey Ryan Gipson. Plaintiff seeks relief through his local

reps and to date there has been no change. A meeting was held at Representatives Self

office with Plaintiff. Present was a lawyer representing the Missouri Family Services and

a lady who described herself as a principal from the Children’s Division here in Missouri.

Plaintiff Robert Gipson has made approximately 10-15 Hot Line calls to the Missouri

Child abuse Hot line. As indicated to Representative Tom Self during this meeting and

also by E-mails to his office administrator by the name of Peggy, neglect and abuse

continue to this day. Since the meeting with Tom Self, the minor child has been

neglected and abused by case workers who have assisted the mother of the minor child

Casey Gipson by helping her file false accusations that Plaintiff assaulted the mother and

step father Jason Warren. This conspiracy between the mother and case workers resulted

19
in an exparte hearing that was dismissed by a judge in Benton County Missouri in 2009.

This was just another attempt by the case workers to conspire and slander Plaintiff Robert

Gipson. Tom Self and his office administrator ignored Plaintiff Robert Gipson in 2006.

It was not until 2009 and after more false accusations and slander against Plaintiff did

Tom Self assist in setting up this meeting with the Missouri Family Services. By this

time Plaintiff lost his Constitutional Rights to be a father to his child Casey Ryan Gipson.

This witch hunt and malicious prosecution by case workers and the corruption in this

community and the injustice in the Benton County Court House devastated both

Plaintiffs. Tom Self lives in Cole Camp Missouri. The Cole Camp Police Department

has brought criminal intent against Plaintiff Robert Gipson. Such threats of arrest by

police officer Walker and others have caused unnecessary conflict.

Defendant, Delbert Scott, Missouri State Senator received correspondence by E-mail

From Plaintiff, Robert Gipson. During Plaintiffs meeting with Tom Self, and

representatives from the Missouri Children’s Division, Senator Scott arrived with

Plaintiffs E-mail in hand. Plaintiff shared his concerns with the Senator about the neglect

and abuse against his child Casey Gipson.

Defendant, Jane Cunningham, Missouri State Senator was present during a special

commitee hearing in Nov 2008. During this hearing Plaintiff testified about the neglect

and abuse brought against his son Casey Gipson. Plaintiff testified in reference to the

civil rights violations against Robert Gipson and Casey Gipson.

Senator Cunningham assisted other individuals and families who are presently

in a court case where their civil rights were violated. Plaintiff requested assistance with

the same. Plaintiff testified about the METH lab at the Grand Parents house of the minor

20
child and poor investigations by case workers from the Missouri Children’s Division.

Defendant, Brian Nieves, Missouri State Representative received E-mails from Plaintiff

Robert Gipson. Plaintiff shared his concerns about the contracts between the Missouri

Family Services and hired Lawyers and Psychologist who receive state and federal

funding for their services. There is a conflict of interest when lawyers and Psychologist

are hired by the state. There was and is a conflict of interest when Plaintiff Robert

Gipson attempted to discuss his child’s behavior with psychologist and these same

psychologist who contract with DFS/CPS turn and make the Plaintiff out to be a bad

father. Their Bias attack to favor case workers and to conspire to discredit the Plaintiff is

a direct result of money received by these psychologist from the Missouri Division of

Family Services. Case workers manipulated psychologist and certain psychologist

favored Brandy Wilkenson and assisted in modifying the court order.

They create a conflict of interest when they are paid for their services and then testify

against an innocent father and child.

13. Defendant, Mark Breshears, Commissioner for the County of Missouri

was and is during the time of said claim in a supervisory position. Mark Breshears is a

party to this case, knowingly and had knowledge of issues in his jurisdiction. Command

and control is absent from his leadership and falls short of leading this community.

Having knowledge of alleged instances and failure to protect the citizens in his district is

dereliction of duty and his oath of office. Failure to supervise and communicate within

has jeopardized the health and welfare of the minor child.

21
14. Defendant, Honorable Judge Larry Burdett, former Benton County Judge is a

party to this action due to his judiciary duties as a sitting judge in numerous hearings on

custody issues between Wilkenson vs Gipson. Judge Burdett violated Plaintiffs

fourteenth amendment. Judge Burdett allowed Brandy Wilkenson to proceed without

counsel after she filed her false accusations and motion to modify the then existing 2005

judgment. Judge Burdett coached Brandy Wilkenson while she was on the witness

stand in order to gain favor over Plaintiff Robert Gipson. Judge Burdett refused to

dismiss the case as requested by Plaintiff due to the failure of Brandy Wilkenson to

present any kind of evidence. Brandy Wilkenson accused Plaintiff of various false

accusations and when scheduled for court she was unable to argue her case. Later Brandy

Wilkenson obtained counsel with James Johns and after nine months of excessive

litigation judge Burdett modified the shared parenting plan. James Johns and Brandy

Wilkenson are once again brought fraud upon the court by presenting false accusations.

The fruit of the forbidden tree has rooted itself. Brandy Wilkenson, James Johns and

Judge Burdett have brought fraud upon the court and often were in contempt. Judge

Burdett modified the order in favor of Brandy Wilkenson. Judge Burdett allowed Brandy

Wilkenson and her lawyer James Johns to rule the court and disregarded Robert Gipson’s

evidence. Judge Burdett was Bias against Robert Gipson and allowed favor for Brandy

Wilkenson. During the eight hour court hearing, Robert Gipson was restricted to

approximately one hour on the stand which included other witnesses for Robert Gipson.

Approximately seven hours was allowed for James Johns and Brandy Wilkenson. This

22
allowed their hired expert witnesses to conspire and dominate the court leaving little

chance for justice to prevail. Judge Burdett and his clerk of court Sharron Schultz

restricted Plaintiffs rights to his case files and violated the Missouri Sunshine Law.

Plaintiff did put on notice to the Benton County court and judge Burdett “The Younger

Alert”. When Plaintiff Robert Gipson did finally get a chance to obtain his case file time

had ran out to file Plaintiffs appeal. The Western District Court of Appeals in Missouri

denied Plaintiffs request to file his LNOA Late Notice of Appeal. The Appeals court

clerk Mr. Lord made this decision on his own and signed his own legal document.

Plaintiff requested a reason for such denial and Mr. Lord stated on the phone to Plaintiff

“The child has settled.” Mr. Lord, in his capacity had no legal right to make such a

decision. It is now knowledge that Brandy Wilkenson’s attorney James Johns was once

the Clerk of Court at the same office as Mr. Lord. This is a conflict of interest. Plaintiff

has been forced into excessive custody litigation in Benton County since returning from

Iraq in Feb 2004. Plaintiff has lost his life savings and lost his Constitutional right to be a

father. Plaintiff fought in Iraq only to return to another war in family court. Judge

Burdett allowed case workers to sit beside the Plaintiff during court hearings. These court

hearings were staged. Case workers have for years used intimidation tactics to invade

Plaintiffs life. Judge Burdett’s reckless court rulings and his disregard for justice

allowed $14,000.00 to be garnished from Plaintiffs Bank account at Bank of America.

The second garnishment was executed without a court order and the Benton County

Clerk of court Sheryl Schultz assisted James Johns in collecting Plaintiffs exempt funds.

The first Garnishment was created by a conspiracy. Brandy Wilkenson and case workers

from the Missouri Children’s Division knew that I was receiving Combat Disability

23
payments and V.A. disability payments. They took advantage by dragging Plaintiff back

into court in order to gain financially. Before the first accusation that Plaintiff sexually

molested his minor child, the court order was 50-50 shared equal and physical custody.

Neither parent was ordered to pay child support. After the first accusation and seven

more to follow, Plaintiff was forced to become the non-custodial parent with limited

visitation. Forced supervised visitation by judge Burdett with the mother Brandy

Wilkenson as the supervisor was ordered by judge Burdett. Presently and after five years

of false accusations and excessive litigation, Plaintiff is going broke and with existing

threats of more garnishments and threats of losing his home and lively hood. Presently as

a result of judge Burdett’s and judge Hendrickson’s Un-founded rulings, Plaintiff is

subjected to only five hours of visitation every other Saturday and Sunday. Phone calls

have been restricted. Plaintiffs Robert Gipson and his son Casey Gipson have often gone

without any phone contact the longest being seven days. Plaintiff Robert Gipson put the

court on notice that he was a Pro-se litigant and for the court to inform Plaintiff of all

court issues. Plaintiff was informed by Sheryl Schultz the Benton County Court Clerk

that Judge Burdett informed her not to send the 2005 judgment to Plaintiff. Once again,

Plaintiff was denied his fourth amendment. Often judge Burdett’s rulings were un-

founded and there was no standard of evidence or preponderance of evidence to modify

the existing 2005, joint parenting plan and custody order. After the 50-50 parenting plan

was modified, Brandy Wilkenson once again brought false allegations against Plaintiff.

Once again the Benton County court has assisted the mother Brandy Wilkenson to gain

power and control and has forced the Plaintiffs to endure the pain of being alienated and

separated from each other. Judge Larry Burdett has violated his oath of office and

24
brought fraud upon the court and the United States Judiciary. Judge Burdett allowed

James Johns, Brandy Wilkensons former lawyer in 2005, to bring sanctions against

Plaintiff even though Plaintiff responded to all discovery requests. Judge Larry Burdett

allowed James Johns to remove exhibits from the bench. These exhibits were presented

by the Plaintiff Robert Gipson. During a supervised four hour visit, Plaintiff was at the

local Warsaw Missouri Park. Only one hour into the visit the GAL Mr. Stewart allowed

Brandy Wilkenson to remove the minor child from the Park. Judge Burdett refused to

charge Brandy Wilkenson or the GAL with contempt. Ms Haines, Plaintiffs lawyer was

present and did nothing. Plaintiffs have endured enough pain and seek relief from a

higher court.

15. Defendant, Honorable Judge Mark Pilley was once Plaintiffs former Attorney.

Plaintiff recused judge Pilley due to a conflict of interest when Plaintiff found out that

judge Pilley would preside over a criminal case in Benton County Missouri which was

filed by Defendant Brandy Wilkenson. When judge Pilley was Plaintiffs Attorney, he

attempted to use the minor child Casey Gipson as a plea bargaining tool as he conspired

with Karen Woodley the Benton County Prosecuting Attorney. Judge Pilley stated to

Robert Gipson Plaintiff “If you go along with the present custody issue I think I can get

Woodley to drop the assault charges” Judge Pilley wanted me to plead guilty to an assault

charge brought against me by Brandy Wilkenson. Judge Pilley wanted me to take

parenting classes and receive a two year probation. I refused and the case was dismissed

in a criminal trial. Brandy Wilkenson once again with her blatant diabolical lies framed

Plaintiff with false accusations to get custody of the minor child. This was nothing more

25
than yet another way to file charges against Plaintiff at the same time the civil case for

custody was pending. Judge Pilley and Karen Woodley obstructed justice by forcing

Plaintiff to wait more than six months for his case to be heard. Plaintiff’s fourteenth

amendment was violated. Both attempted to use the criminal case against me as the civil

custody case was pending. Presently there is yet another criminal case pending against

Plaintiff Robert Gipson. Once again Brandy Wilkenson, Karen Woodley and the Benton

County Sherriff Department are attempting to file charges against Plaintiff for child

endangerment. This was nothing more than another staged event created by Brandy

Wilkenson. Brandy Wilkenson called the Benton County Sherriff’s Department and

requested that five police officers be present during the exchange with the minor child.

Brandy Wilkenson gets what she wants when she wants it.

On April 26, 2009, Plaintiff was arrested for child endangerment. The incident was on

video and clearly showed that Casey Gipson was never in any danger. If the child was in

danger then why was it that the Plaintiff Robert Gipson was not arrested on site? The

children’s division was called and the incident was Un-substantiated. Plaintiff spent one

night in jail and was harassed all night by four bailiffs. Plaintiff arrived in court on June

2, 2009 to plead not guilty. Plaintiffs name was not on the docket nor did Karen

Woodley or any of the five police officers who attacked the Plaintiff and the minor child

show up. This is yet another false accusation to slander and bring harm to the Plaintiffs.

Prior to the April 26, 2009 arrest, the Benton County Sherriff’s Department once again

arrived at Plaintiffs residence in Lincoln Missouri the Wednesday prior to April 26, 2009

and the night before another scheduled court hearing. They banged on the door and

shined their lights in the windows of the residence. Why did they wait until almost

26
midnight before banging on Plaintiffs door? Plaintiff was home all day and all night with

the lights on in the evening. Plaintiff and his guest hid under the bed in fear for their

safety. To date, Plaintiff locks his bed room door in fear for his own safety.

16. Defendant, Karen Woodley, Prosecuting Attorney for Benton County. Karen

Woodley received a report from the Lincoln Missouri Police Department. Jason Warren,

husband of Brandy Wilkenson Warren and step father of Casey Gipson was charged and

arrested. Jason Warren made a threat to kill Plaintiff Robert Gipson. Jason Warren

prevented Robert Gipson and Casey Gipson from leaving the bed room. Robert Gipson

observed Jason Warren reach behind his back as if to be reaching for a gun. Plaintiff

Robert Gipson grabbed Casey Gipson and ran into the Bedroom at Robert Gipson’s

home. Jason Warren was drinking and returned to Plaintiffs home for the second time

this time during night hours. Karen Woodley denied Robert Gipson Plaintiff the

opportunity to testify at the court hearing and refused to communicate with Plaintiff to

allow for testimony and evidence. Karen Woodley, without Plaintiff knowing, held court

and allowed Jason Warren to be freed on a ten dollar fine and disturbing the peace

charge. This happened after Robert Gipson was held hostage in his own house and

Robert Gipson never had a chance to be present in court. Karen Woodley Perverted the

Course of Justice and jeopardized the Health and Welfare of the minor child and Robert

Gipson. This occurred on or about October 2005. Robert Gipson filed a Child Protection

order against Jason Warren and was forced to drop the charges as Judge Larry Burdett

would not allow Robert Gipson to proceed with the 2005 custody hearing unless Plaintiff

dropped the Child Protection order. Plaintiff waited for over five hours for his case to be

27
heard. While waiting Plaintiff’s lawyer demanded that the Protection order is dropped.

Brandy Wilkenson and Jason Warren have been protected from these criminal activities

at the expense of the minor child and Plaintiff Robert Gipson. James Rice was the

attorney fro Brandy Wilkenson at the time and as Robert Gipson waited for his case to be

heard, judge Burdett allowed James Rice to conduct court hearings as Plaintiff waited for

hours as his lawyer told him to drop the Child Protection Order. Presently as of June 2,

2009, Karen Woodley is once again the Prosecuting Attorney State vs Robert Gipson on

Benton County. During the first hearing in December 2008 and Jan 2009, Karen

Woodley was present in my civil case as she sat in front of Judge Michael Hendrickson.

Along with Karen Woodley were another Prosecuting Attorney and a lady from the

Crime Victims Office all sitting in a civil custody case. By law they are not allowed to

favor or take part in a civil case, their duties involve criminal cases. Along with Karen

Woodley were five police officers, bailiffs from the Benton County Sherriff’s

Department. This was nothing more than a threat. Five Baliffs and two Prosecuting

Attorneys and one Crime Victims Office. When I filed a report in 2005 with the Crime

Victims Office no one would return my call. I eventually received a letter from their

office stating that a crime was never committed as indicated by Karen Woodley when

Jason Warren Held Plaintiffs in the bed room. Plaintiffs will never get justice in Benton

County. Plaintiffs request that this court take jurisdiction over ant case in Benton County

and Plaintiff Robert Gipson sates that his life and his son’s life Casey Ryan Gipson is in

danger.

17. Defendant Cheryl Schultz is the Benton County Clerk of Court. She appears to be

28
the senior clerk. Ms Schultz authorized and signed a Garnishment against my bank

account. Bank of America allowed James Johns, attorney for Brandy Wilkenson to

Garnish against my account. The money Garnished was Exempt funds. These funds were

from my Social Security Disability and my Veterans Disability from the VA for my

wounds which I endured while in Iraq. Brandy Wilkenson knew that I was getting

money as did James Johns. This conspiracy to embezzle money from Plaintiff Robert

Gipson and take full control of child support and reduce visitation was their motive.

Brandy Wilkenson now has two adopted children and receives money from the state.

Jason Warren does not work. Money for Child Support from Robert Gipson and money

for the two foster children allow Brandy Wilkenson and Jason Warren to gain financially

at the expense of the minor child and Robert Gipson being forced to be alienated. James

Johns received over $8000.00 from judge Burdett for attorney fees in 2007 and is now

asking judge Michael Hendrickson for over $8000.00 for the last six months of excessive

litigation for 2009. False accusations created by Defendants Brandy Wilkenson and

James Johns forced Plaintiff back into court for the fourth year in a row. This insanity

created by these individuals continues without any over site. Plaintiff was falsely accused

for conducting an in home Sleep Study on the minor child and for conducting medical

testing. All UN-founded and no proof of any evidence presented since Dec 2008 to

Present. In 2003 prior to Plaintiff deploying to Iraq, Plaintiff got a DNA test and once

Paternity was proven, Brandy Wilkenson and her family disconnected the telephone. It

was not until approximately 1 ½ years later in 2004 that Plaintiff Robert Gipson had any

contact with his child Casey Ryan Gipson. Brandy Wilkenson stated that she will have

me in court for eighteen years. She has stated and I quote” I will make sure Casey hates

29
you and only listens to me” There is a lethal threat against Plaintiff Robert Gipson. This

unstable environment in which Plaintiffs must endure is one of high risk. To date Brandy

Wilkenson has not only kept her promise, she has the support from the corruption within

this community and various Government agencies.

Defendants, Carlisle Walker, Chief of Police for Cole Camp Missouri,

Officer Rick Fajen Benton County Sheriff Department,

Mickey Mittlestadt, present Chief of Police, Lincoln Missouri Police Department,

Chief Kinkinnon, former Chief of Police, Lincoln Missouri Police Department,

Deputy Haun violated the civil rights of Plaintiffs Robert Gipson and his child

Casey Ryan Gipson. The above Defendants acted under the color of law and

violated their oath of office. Their criminal intent to bring physical harm and

mental anguish against Plaintiffs is in direct violation of state and federal laws.

On or about Nov 9, 2006, Plaintiff went to the Cole Camp Little Blue Byrd Pre-School

to pick up his son Casey Gipson. Brandy Wilkenson the mother of Casey Gipson

removed the child from school even though it was the Plaintiffs Robert Gipson’s

visitation time. Brandy Wilkenson removed the child from school at the advice a case

worker. Plaintiff was informed that the mother made a report that Plaintiff sexually

molested the minor child. This was the first report of sexual abuse against Plaintiffs

by the mother. Ms Peterson the Principal for the Little Blue Byrd school stated

Plaintiff had the minor son bite the head off a snake with their clothes off.

When Plaintiff requested that the Cole Camp Police investigate the abduction of the

30
minor child by Brandy Wilkenson, the Cole Camp Police officer refused to do so.

In 2009, officer Walker once again threatened Plaintiff with arrest at the Little Blue

Bird school in Cole Camp Missouri. In Dec 2005, Officer named John Doe

threatened Plaintiff at Brandy Wilkinson’s residence even though once again it was

Plaintiffs visitation time. On fathers Day 2008, Plaintiff summoned an officer from

Cole Camp. Plaintiff arrived at the Cole Camp Police Department and reported that

Brandy Wilkenson failed to allow the minor child and Plaintiff their father’s day

visitation. Later Brandy Wilkenson stated that she forgot that it was Fathers day even

though she had left town on Friday to visit family in St Louis with her husband Jason

Warren. Plaintiff had no phone contact with the minor child until Sunday on Fathers

Day and not until Ms Wilkenson returned from St Louis. Plaintiff Robert Gipson

requested that the Cole Camp Police Officer (FEMALE) make a report of Jason

Warren making an attempt to slice the tires of Plaintiff. The female police officer did

not make a report and ignored Plaintiffs plea to protect the minor child and Plaintiff

Robert Gipson from harm by Jason Warren. . The Police officer on Fathers Day also

refused to make a report. The police officer on Fathers Day Stated “I have to check

with my boss to see if he will allow me to make the report” His boss was Chief of

Police Walker. Plaintiff has lost faith in the police. They have proven time and time

again that their intentions are to obstruct justice and protect Brandy Wilkenson and

Jason Warren even at the expense of the minor child Casey Ryan Gipson. For months

Plaintiff was followed by police from Cole Camp and Lincoln Missouri. Plaintiff was

followed to and from the Cole Camp Little Blue Bird School by marked police cars.

31
Defendant,

Chief Kinkinnon of the Lincoln Missouri Police Department tried to frame Plaintiff.

Chief Kinkinnon conspired with case worker from the Missouri Children’s Division.

Chief Kinkinnon and the case worker stated that my son Casey Gipson stated that I

fondled him. Plaintiff, cross exam of officer Kinkinnon during a court hearing in

Benton County Missouri. Plaintiff was informed by Chief Kinkinnon that a tape was

made during an interview with the minor child. When asked where the video tape

was of the child Casey Gipson making such statement, Chief Kinkinnon stated that

the tape was out in the wall locker of the court house. Approximately two weeks

after this court hearing, chief Kinkinnon resigned from his job and left town. During

Plaintiffs interview with Chief Kinkinnon at the Lincoln police station, both the case

worker and the Chief were attempting to frame the Plaintiff for sexually molesting his

minor child Casey Gipson. Following this accusation by Chief Kinkinnon, another

false accusation that the Plaintiff had his son bite the head off a snake with their

clothes off was brought against Plaintiff. Chief Kinkinnon informed Robert Gipson,

Plaintiff that he is handing the case over to Karen Woodley the Prosecuting Attorney

for Benton County. Later, when asked, Karen Woodley stated that Chief Kinkinnon

never gave her any case and that she did not know what I was talking about. This

message was received by phone recording at Plaintiffs home in Lincoln Missouri.

Plaintiff was informed by both Paula Woolery and Rhonda Talley, case workers for

the Missouri Children’s Division that the minor child was interviewed in a safe house

located in Sedalia Missouri and Springfield Missouri. To date Plaintiff has yet to

review the tapes even after multiple requests to the Missouri Family Services and the

32
Missouri Children’s Division. Steve Morrow, the Missouri Advocate for Children

stated that he saw the Video. Plaintiff requested a copy of said video from Ron Levy,

Jim Harrison, and others. Plaintiff feels that no tape exists and that this was all an

ambush to slander Plaintiff. This conspiracy to slander and defamation of character is

a direct federal violation against the Plaintiffs. The government workers involved in

this conspiracy have committed felony crimes and are excused from any kind of

qualified immunity or any other kind of immunity. Rhonda Talley and Paula

Woolery are threats to the community and to the children of Missouri. Their actions

to frame Plaintiff Robert Gipson is a felony crime and should be prosecuted at the

fullest extend of the law.

19. Defendant, Sheriff Officer Rick Fajen Benton County Sheriff Department,

Officer Rick Fajen is in Authority and has over site to the policies and procedures

within the Benton County Sherriffs Department. His knowledge on the issues

pertaining to Casey Gipson and Robert Gipson makes him a party to this action.

Plaintiff has been harrased, arrested and stalked by numerious poilice officers

from the Benton County Sheriffs Department. On April 26, 2009, Plaintiff was

falsely arrested and incarsarrated by the Benton County Sherrifs Department. At

approximately 1:00pm on April 26, 2009, Plaintiff filed a complaint against the

Sherrifs Department. This was filed in person inside the building in Warsaw

Missouri where the Head Quarters is located. AS Plaintiff was filling out said

complaint, AN officer whos badge and signature could not be read handed

33
Plaintiff a yellow slip which was a summons to appear on June 2, 2009. This

summons stated that Plaintiff is being charged for Child Endangerment. Plaintiff

requested numerious times for the correct spelling of the officer presenting the

summons and was told different spellings and was refused such information. As

the Plaintiff continued to fill out the complaint form officers from the Sherriffs

Department assaulted Plaintiff and hand cuffed him. Plaintiff was jailed and

harassed by four jail guards as he attempted to sleep. Plaintiffs jail cell was

freezing cold and Plaintiff suffered from being cold and sleeping on an Iron bed

in a block cell that was designed for severe confinement. Plaintiff was not

allowed to sleep and was harrassed throughout the night by having his lights

turned off and on and loud noises that were just as lowed as the bombs that

exploded in Iraq. These loud noises were abnormal and shook the cell floor and

caused Plaintiff to jump. Plaintiff was presented food without any utensils to eat

the food. Plaintiff asked every jail guard for their names and many said FUCK

YOU. Plaintiff asked to make a phone call and was told that phone calls are only

made for inmates who want to bail out. Plaintiff demanded to be released and it

was not until the next morning was Plaintiff released and released without paying

bond. Plaintiff asked for police reports of his arrest and names of the jail guards

and was denied. On April 26, 2009 at approximately 8:00 am on Sunday

morning, Plaintiffs Robert Gipson and his seven year old son Casey Gipson were

assaulted by five police officers from the Benton County Sherriffs office. These

five police officers were lined up side by side standing in front of the minor child

and Plaintiff. Plaintiff and his child have been subjected to unnecessary

34
harassment in the past and this simply drew the line concerning excessive force

and excessive threat, Plaintiff took video of the incident in order to protect

Plaintiff and his minor child. Plaintiff also took video the Dec 25, 2008 incident

where the Lincoln police pulled over Plaintiff and his child on Christams night

once again excessive and unnessary harassment. The Lincoln police officer

stated that his car dash cam was recording. It was sad to witness a six year old

child be subjected to such mental abuse. Plaintiff also took video of the

Wednesday incident where the police banged on his door at his residence in

Lincoln Missouri at 11:30 p:m. Brandy Wilkenson has established a bond with

the local police. Her and her husband Jason Warren have used the police to

harrass Plaintiffs. The local police ave conspired to protect Brandy Wilkenson by

providing personal escorts in and out of town and escorts for Jason warren and

attempting to make the Plaintiff out to be some insane Iraq Veteran. Plaintiff

was on another occasion arrested in his home and after Plaintiff was hand cuffed,

the police officer from Lincoln stated and I quote “ Fuck you, you are not getting

dressed.” Plaintiff was arrested and hauled off to Benton County jail in his

slippers and long johns. Plaintiffs civil rights have been severly violated.

Abusive power used against Plaintiff has caused severe mental depression and

mental anguish. To date Plaintiff seeks psychological counseling to help with his

anxiety and depression. The Benton County police and their brutality against

Plaintiff has caused Plaintiff to have nervous break downs. n the past was

harrased and arrested in his home by the Benton County Sherriff and Lincoln

Police. Prior to April 26, 2009, Police officers from the Sheriiffs department

35
arrived at Plaintiffs home and banged on the door and shined there flash lights

into Plaintiffs house at approximately 11:30pm the night before Plaintiff had a

court hearing. They never identified themselves as police officers. When

Plaintiff Robert Gipson first moved into his home in Lincoln Missouri on May

10, 2005, , Chief of Police Mr Kinnkinnon parked his car an stalked Plaintiff. For

the last four years, Plaintiff has been arrested twice, jailed once, pulled over

twice, summoned to appear in court approximately four times and threatened to

be arrested by police officers from Cole Camp Missouri, Lincoln Missouri,

Benton County Sherriffs office. The first court date in Dec 2009, Plaintiff was

surrounded by five police officers. Plaintiffs are innocent victims of this

conspiracy and seeks relief from this higher court.

20. Defendant, Mickey Mittlestadt, present Chief of Police, Lincoln Missouri Police

Department. Officer Mickey Mittlestadt, received a police report from Plaintiff in

October 2005. This report stated that Jason Warren husband of Brandy warren had

threatened the life of Plaintiff Robert Gipson and Casey Gipson. Plaintiffs were held

hosateg by Jason Warren at Robert Gipsons home in Lincoln Missouri. This police

report was not presented to Karen Woodley the Prosecuting Attorney in Benton county.

Officer Mickey Mittlestadt failed to create a thorough report of this incident. Neighbor

of Plaintiff, Ms Keiser gave a police report to the Lincoln Police Department, Karen

Woodley and Hot Lined the Missouri Childrens Division. A phone call to Ms Keiser

36
from a Male case worker to Ms Keiser stated that this was an isolated incident. The

Childrens Division is and was fully aware of this incident. This incident took place in

2005. Plaintiffs were held hostage by Jason Warren. Jason Warren was drunk under the

influence of alchol and came to the residence of Robert Gipson. On October 2005,

Brandy Wilkenson came to seek safety at Plaintiffs residence. Brandy Wilkesnon had a

black eye and bruises on her right hip. Jason Warren beat Brandy Wilkenson in the front

yard at the resident of Robert Gipson in Lincoln Missouri. Witness was neighbor Ms

Keiser. Jason Warren orced his way into the residence of Robert Gipson where casey

Gipson was and also Brandy Wilkenson. Plaintiff grabbed the minor child and ran into

his bedroom. This was after Jason Warren reached behind his back as to grab for a gun

and stated to Plaintiff to come outside. Shortl after Plaintiff received a phone call from

Jason Warren sated to Plaintiff “You think Im crazy you wait you’re a dead man”

Officer Mike Mittlestadt was the reporting officer. Officer Mike Mittlestadt contacted

the Cole Camp Police and they went to Jason warrens home in Cole Camp Missouri wher

Jason warren went to after the hostage situation. Jason Warren was observed drinking

alchol on his steps in Cole Camp when the police arrived. Brandy Wilkenson refused to

admit that Jason Warren beat her and to this day denies the time when my son watched in

horrow as Jason Warren beat her at the Washing Machine at her Cole Camp residence.

Plaintiff was told by the minor child and I quote “Mommy got beat at the washing by

daddy Jason and I tried to tell him no but he would not listen”

20. Defendant, Officer Haun of the Benton County Sherriffs Department threatened

Plaintiff that he would arrest Plaintiff if he went near the residence of Ms

37
Wilkenson the mother of Brandy Wilkeson. On or about Nov 9, 2006, Plaintiff

filed a missing person report with the Benton County Sherriffs Department.

Plaintiff requested that he be escorted to the Grand Parents of the minor child

Casey Gipson. Officer Haun was the escorting officer. Plaintiff pointed out to

officer Huan the house where the minor child may be located. Officer Haun went

to the house and Plainiff waited near the stop sign down the street. This was in

Warsaw Missouri. When officer Hau returned he stated that the child was there

and stated to Plaintiff “If you go over there I wil arrest you” Officer Haun

handed Plaintiff a business card with the name of a case worker from the

Missouri Childrens Division. Plaintiff asked Officer Haun for a copy of a Safety

Plan and there was not one to obtain. Once again Brandy Wilkenson alienated

the child from Plaintiff and used the local police for her own cause. Officer

Hauns threat on Nov 2006 and his conspiracy to help Brandy Wilkenson to

kidnap Plaintiffs son was the act of a felon. Plaintiffs civil rights were

Maliciously violated. On April 26, 2009, Officer Haun once again harrased

Plaintiff while Plaintiff was in the Benton County Jail.

21. Defendant, Honarable Judge,Michael Hendrickson refused to hear Plaintiffs

Motions for a change of Vinue. For three months in 2009 judge Hendrickson

delayed hearing Plaintiffs Motion for Temporary Custody of the minor child and

Motion to Return Plaintiffs Constitutional Rights. Even though prior judgments

and rulings were handed down by judge Hendrickosn, Plaintiff was denied to be

heard until a GAL was assigned for the minor child. The present GAL Mr

Lutman ignored Plaintiffs documents of the Porn Site by Brandy Wilkenson and

38
numerous medical reports that clearly showed the minor child in need of medical

attention. Plaintiff met with the Defendant, GAL in May-June and gave him

pictures of the injuries on the minor child. Plaintiff also gave Mr Lutman pictures

of the Porn web site. In the June 2009 hearing in Benton County, the GAL not

once asked Brandy Wileknson any questions about the minor child. The GAL

appears to have copied prior texts from the previous court judgment and used this

text to favor Brandy Wilkenson. Mr Lutman has failed to review all the prior

medical documents that shows Casey Gipson does have prior reports of Sleep

Apnea. Reports of URI Upper Respritory Infection, Tonsil Idous, Bronchitus.

These medical reports are documented back to 2004, 2005. The GAL Mr

Lutman ignored the testimony from witness Gina Schwartz who testified about

her observing the minor child with Sleep Apnea. MR Lutman ignored testimony

from Plaintiff Robert Gipson testifying that he took the child to the Emrgency

room on Jan 4, 2009. Plaintiff asked the GAL to retrieve the medical records

from James Johns and the video that shows the minor child in sever stress of

Sleep Apnea. On July 4, 2009 Plaintiff observed a burn on Casey Gipson’s neck.

On Sunday July 12, 2009, Plaintiff was informed by the minor child that he has

poison Ivy. Plaintiff is restricted from observing his childs medical issues. This

restriction puts the childs health and welfare in danger. Plaintiff has been

removed and alienated from his child to insure Plaintiff can no longer report.

22. Defendants, Missouri Crime Victims Office, Plaintiff contacted the Missouri

Crime Victims office in 2005, 2006. The agency was informed about the crime

39
against Plaintffs Robert Gipson and Casey Gipson. Plaintiffs were held hostage

hin Plaintiffs home in Lincoln Missouri in October 2005. Defendant Karen

Woodely from the Benton County Prosecuters Office refused to release

information to the Missouri Crime Victims Office. The agency informed

Plaintiff that no crime was committed by Defendnat Jason Warren the husband of

Defendant Brandy Wilkenson. Jason Warren was fined ten dollars for

distrurbing the peace. This was after witness statements from neighbor Shirley

Kaiseer and Robert Gipson was presented to the local police in Lincoln Missouri

and the Benton County Sherriffs Office. Presently in June 2009, the Crime

Victims Office assited Brandy Wilkenson in a court case where Defendants

Brandy Wilkenson and Jason Warren filed an Exparte against Plaintiff Robert

Gipson. In this same case, case workers from the Missouri Childrens Division

assisted Brandy Wilkenson in moving this case to court as indicated in Brandy

Wilkensons statement to the court. Malicious intent with Malice to bring harm

to the Plaintiffs. This action was brought against Plaintiff Robert Gipson to add

more insult to injury as the attempt to modify the existing court order was

pending. Court records indicate the same stradagy in previous years, 2005, 2006

when Defendant Brandy Wilkenson and her case workers conspired with the

same motives.

23. CRIME VICTIMS ADVOCATE Benton County Missouri, Plaintiff received

Phone call on his cell phone on the morning of the Exparta hearing from a lady from

Karen Woodleys office identyfing her name and postion with the Crime Victims

Office. She stated that she is willing to appear in court and assist her against Plaintiff

40
Robert Gipson. In 2005, 3006, Plaintiff received no help from the Crime Victims

Advocate in Karen Woodleys Office even when Plaintiff requested assistance. The

Office in Jefferson City also ignored Plaintiff.

24. Defendant, Ron Levy, Director of the Missouri Family Services, was fully

aware of the Porn Site and failed the minor child miserably. The Defendant Ron

Levy was at all times relevant here and assigned by Governor Nixon to protect

the children in Missouri from such neglect and abuse. Ron Levy received a CD

and video of the minor child showing neglect and abuse. Ron Levy and and his

staff of supervisors and case workers failed to protect Casey Ryan Gipson.

Plaintiff Robert Gipson appeared in person in front of Ron Levy, Mr

Kincaide,and Ms Hartgrave. Once again the evidence presented to the agency

responsible for protecting Casey Ryan Gipson failed to process the information.

Their actions have been fruitless. They refused to recognize the credibility of

this evidence and failed to recognize the previous years of HOT Line calls and

reports of neglect and abuse aginst the mior child. Their inability to evaluate,

investigate and conduct interviews has done a disservice to the minor child and

Plaintiff Robert Gipson. Their actions were substandard for such prestigious

positions.

25. Defendant, Debra Scott, Former State of Missouri, Director of Family Services.

Ms Scott received documents and numerous request from Plaintiff to schedule a

41
meeting. Plaintiff reached out to the director knowing that her supervisors and case

workers failed to protect the minor child. Plaintiffs Robert Gipson and his son Casey

Gipson. Debra Scott ignored vital information from third party witnesses that

described events of neglect and abuse against the minmor child Casey Gipson.

At all times relevant herein, Defendants Jim Harrison, Steve Morrow, Nancy Parks,

and Ms Hendrickson violated the civil rights of the Plaintiffs and failed the minor child.

All failed to enforce the policies, regulations, or decisions officially adopted or

promulgated by Missouri Children’s Division, which acts may fairly be said to represent

official policy or were pursuant to the governmental custom of the State of Missouri.

Defendnat, Celesta Sue Hartgrave, designated principal of Social Services. Ms.

Hartgrave worked with Jim Harrison the director of the children’s division. Ms Hartgrave

worked with Nancy Parks and Paula Neese. All of these defendants were fully aware of

the neglect and abuse against Casey Giposn the minor child. Ms Hartgrave reviewed the

pictures and video of Casey Gipson and was fully aware of the numerous Hot Line calls

to the Missouri Children’s call center.

Defendant, Dawn Long, Benton County Case Worker. Ms Long investigated the

Hot Line call made by Plaintiff in 2004. Plaintiff reported that the minor child was

burned by an oven. Ms Long was also presented by Plaintiff a request to open an

investigation as indicated by Plaintiffs attached exhibitPlaintiff first found out about the

oven burn in 2004 when he saw Casey Gipson. When the Plaintiff asked Brandy

42
Wilkenson how Casey got the burn Ms. Wilkenson stated “It is none of your business.”

This was said in front of the GAL Mr. Stewart and James Rice, Defendant, Brandy

Wilkenosn’s lawyer. Defendant Dawn Long once again investigated a HOT Line Call

stating that Plaintiff was arrested for child endangerment. Even though this was found to

be Un-substantiated, this was staged by the Benton County Sherriff’s Department and

Plaintiff has video to show the same. Dawn long arrived at the Benton County Sherriff’s

Department on April27, 2009 at approximately 8:00 a.m. With Dawn Long was officer

Haun. Officer Haun in Nov 2006 conspired with Brandy Wilkenson and a case worker

from the Missouri Children’s Division. Officer Haun stated to Plaintiff “If you go to the

house I will arrest you” This was after he handed Plaintiff a business card from a case

worker from CPS. Like so many other case workers and investigators from the

Children’s Division, Dawn Long was moved from one position to another. When

Plaintiff went to the Warsaw Missouri office for Social Services, Plaintiff was told that

Dawn Long no longer works in the Children,s Division. It appears as of Jan 2009, Ms.

Long is back working as a case worker. Many workers from the Directors, case workers,

supervisors change jobs and are moved around the state especially when complaints are

filed. This makes it hard to communicate with these government workers and it appears

that this is executed to prevent any information being obtained for any legal actions.

Defendant Dawn Long had the opportunity to help the minor child when she knew about

the oven burn. Dawn Long refused to contact any witnesses that the Plaintiff Robert

Gipson attempted to bring to her attention. Plaintiff himself was never interviewed and

was ignored. Numerous other complaints of neglect and abuse have been reported to the

Hot Line and CPS. The way in which the Children’s Division evaluates and investigates

43
such complaints is sub standard. It is vertualy imposible for a child to endure so many

injuries and reported by so many people that at least one incident would be found to be

substantiated against the Defendant and mother Brandy Wilkenson. This has been

nothing more than a cover up for over six years by this community of police, case

workers, psychologist, lawyers, judges, court clerks etc. Defendant Dawn Long has been

aware of high risk environment that faces the minor child Casey Gipson. She has turned

her head at the obvious signs of neglect by a mother that may have mental problems. Ms.

Long has ignored and has failed to report to other case workers and supervisors knowing

that after 2005, and present in 2009 that more neglect and abuse was occurring and

continues to this day.

Defendant, Beverly Chapman, Benton County case worker. Ms Chapman observed the

minor child Casey Gipson in her office at the Warsaw Missouri Social Services. Plaintiff

informed Ms Chapman that the minor child had been burned by a cigarette. No report

was created even after the child had pictures taken by two Sheriffs from the Benton

County Sherriff’s Department. The minor child was burned a few days after a doctors

report stateted not to allow the child around smoke. This doctor report was presented to

Brandy Wilkenson by Plaintiff Robert Gipson. Plaintiff took the minor child to the

Emergency room in Sedalia Missouri after the child was having Sleep Apnea and

Obstructed Airway. Defendant Beverly Chapman arrived for the 2007 court hearing in

Benton County court house. Ocompaning her were case workers Paula Woolery, Rhonda

Talley, and Casey Gipson’s preschool teacher. This was yet another conspiracy to help

the mother Brandy Wilkenson to gain custody of the minor child Casey Gipson. As

indicated by Plaintiffs exhibit, these case workers were informed not to attend these

44
hearings. Their lawyer stated in his motion that “ The Childrens Division would not be

able to function without their case workers present for duty.” These case workers

slandered the Plaintiff in court and in their case summery reports. Defendant Beverly

Chapman informed the Plaintiff during a phone conversation that Plaintiff is giving her to

much information and that she has to get to another client. Ms Chapman arrived at the

Plaintiffs house in Lincoln Missouri with an escport from the Benton County Sherriffs

Department. In front of Ms Chapman Plaintiff counted over twenty bugs bites and

reported other issues concerning the minor childs health and welfare. Prior to entering

Plaintiffs house, Ms Chapman shook her leg and jokingly stated “ oops I have a chigger.”

Prior to leaving Plaintiffs residence, Defendant Beverly Chapman stated “My colleagues

and I think that you should take parenting classes because you are a single father” Ms.

Chapman stated to Plaintiff “You have my pen” as she laughed she put her face next to

Plaintiffs face and said “JOKE”. The Sherriff who escorted Ms Chapman was from the

Benton County Sherriff’s Department. Twice since Ms Chapman appeared at the

Plaintiffs home, Plaintiff has been arrested by the Benton County Sherriff’s Department.

This conspiracy continues even today with pending charges against the Plaintiff for child

endangerment. When the Plaintiff arrived on June 2, 2009 to plead not guilty, Plaintiffs

name was not on the court docket. This arrest on Child Endangerment was set up by

Brandy Wilkenson and carried out by the Sherriff’s Department. Plaintiff requested the

cigarette burn report from Beverly Chapman and the Sherriff’s Department. To date the

report has not been turned over to Plaintiff. The Benton County Sherriff’s stated that

they have no report. The police officers who took the pictures of Casey Gipson’s ear

never documented the incident and covered up the investigation. The physician and

45
mandated reporter at Dr Cahill’s office also failed to report the ear burn. Plaintiff has the

pictures of the ear burn that were taken by the Sherriff’s Department in his attached

exhibit files. Beverly Chapman stated in her office to Plaintiff “ The grandmother

accidently burned Casey” Defendant Brandy Wilkenson informed Plaintiff that Meliss

burned Casey Gipson. Casey Gipson informed the Plaintiif Robert Gipson that he was

burned by a cigarette. While in the church bathroom in Warsaw Missouri, Plaintiff asked

the minor child how he got the ear mark. Beverly Chapman used the Sherriff to

intimedate Plaintiff.

Defendant, Paula Woolery, Benton County case worker. In 2205, Ms Woo;ery stated

to Plaintiff “I will take your child from you” Ms. Woolery was investigating a Hot Line

call that was made by Brandy Wilkenson. Defendant Brandy Wilkeson, mother of Casey

Gipson, stated that the Plaintiff and father of the minor child Casey Gipson, sexually

molested the minor child. Paula Woolery conspired with the Chief of Police Mr

Kinkinnon of the Lincoln Missouri Police Department. During the interview of Plaintiff

at the Lincoln Police Department, Paula Woolery and the Chief attempted to frame

Plaintiff. Their attempt to slander Plaintiff and make him out to be a child molester was

their primary motive. Paula Woolery stated that the child was taken to a safe house for

an interview and was video taped. Plaintiff has requested the videofrom the Childrens

Division and has asked for the address and contact information to the safe house in

Sedalia Missouri and Springfiled Missouri. Case workers Paula Woolery and Rhonda

Talley stated that video tapes exist of both safe house interviews of the minor child.

Chief Kinkinnon also stated on the witness stand that the video tape of the minor child

46
was out in the locker in the court house. Chief Kinkinnon stated “As far as I am

concerned, the child is better off with you not around.” Paula Woolery has assisted her

collegues and Brandy Wilkenson in a systematic assault against Plaintiff in order to

remove the minor child from Plaintiffs life. Ms Woollery and her threats to take the child

was nothing more than abusive power. Defendant Paula Woolery with her biological lies

and blatant unfairness has caused great harm against Plaintiffs Robert Gipson and Casey

Gipson.

)
Defendant Alice Sharon Zidlicky, Benton County supervisor over case workers. Ms

Zidlicky met with Plaintiff at the Warsaw Social Services Office. Ms Zidlicky made

every attempt to discredit Plaintiff. Ms Zidlicky ignored Plaintiffs complaints and

conspired with her case workers to slander Plaintiff. Ms Zidlicky stated to the Plaintiff “

You try to turn everything around.” Ms Zidlicky had every opportunity to protect the

minor child. She failed to properly investigate and as a direct result Casey Gipson the

minor child has had to endure years of neglect and abuse. The conspiracy between

supervisors and case workers here in Missouri is an act of fraud. Obstructing justice

has affected the lives of two innocent citizens. Plaintiffs Robert Gipson and Casey

Gipson request a full federal investigation into the abusive powers of the Missouri

Childrens Division Directors, supervisors, case workers and staff. Plaintiffs request

Justice and a fair trial.

Defendant Steve Morrow, Missouri Children’s advocate, was at all

times relevant herein, the Missouri Advocate for Missouri and assigned by Governor

Blunt. Steve Morrow communicated with Jim Harrison and was fully aware of the Porn

47
web site and other neglect and abuse issues against the minor child. A meeting was held

with Jim Harrison, Steve Morrow and Robert Gipson father of the minor child present.

Robert Gipson showed Steve Morrow a video of the minor child with Sleep Apnea and

Obstructive Airway. In 2009, Steve Morrow stated to Plaintiff Robert Gipson that he

viewed the two recorded video of Casey Gipson that was taken at the safe house

interview. Brandy Wilkenson, Paula Woolery and Rhonda Talley scheduled and initiated

two safe house interviews as a result to the false accusations that Plaintiff sexually

molested his minor child. Chief Kinkinnon of the Lincoln Police Department also

testified on the witness stand that there is a video and it was placed in the wall locker at

the Benton County Court House. Plaintiff is aware of two safe house interviews where

the minor child Casey Gipson was taken. One was in Springfield Missouri and the other

in Sedalia Missouri. Plaintiff was accused of being the perpetrator on two separate false

accusations of sexual abuse Steve Morrow was first contacted in Nov 2006 when the

Plaintiff was accused of sexually molesting his minor child. Mr. Morrow was hired by

Matt Blunt. Both were aware of the issues with Casey Gipson and made a fruitless

attempt to help this child. the Plaintiff informed Mr. Morrow that the minor child was

presented with a CPAC from the Respiratory Doctor in Columbia Missouri. The child

was taken to the Emergency room in Columbia after having Sleep Apnea and Upper

respiratory infection in Plaintiffs car. Plaintiff, once again has attempted to get the

support from the Missouri advocate office. It appears that Mr Morrow and his office staff

is more concerned with federal funding than to helping children in Missouri. Again in

2008 and 2009 Mr. Morrow was contacted by Plaintiff Robert Gipson. It has been now

over two and half years that Mr Morrow has known of such neglect and abuse against the

48
minor child. Plaintiffs aks for relief to assign another advocate in this position. Plaintiff

request that Defendant Steve Morrow resign from his job as advocate for Missouri

Children. Steve Morrow has not once prepared any reports and has failed to properly

investigate said claims. Steve Morrow is waisting the tax payers money and is not

competent to hold such a prestigious job such as protecting children from harm.

Defendant, Mr. Brown, Supervisor Sedalia Missouri Social Security Office.

In 2007, Brandy Wilkenson was given money from Mr Brown the Supervisor at

the Sedalia Social Security Office. Defendant James Johns Garnished Plaintiffs

Bank account at the same time as Mr. Brown was making Defendant Brandy Wilkenson

the Payee. The Benton County Clerks office assisted James Johns. Plaintiff

was not aware that Mr. Brown authorized Brandy Wilkenson to be the payee of over

$650.00 until after the fact. The staff under Mr. Brown sent Plaintiff a letter advising

Plaintiff to call them. Plaintiff did call and the staff ignored Plaintiff. At the same time

James Johns Garnished yet another $1,400.00 as Brandy Wilkenson was receiving extra

money from the Social Security Office in Sedalia Missouri. Congressman Ike Skelton

received notice from Plaintiff that this was and is a federal violation. To date Plaintiff

has not heard back from the Congressman. This conspiracy is happening again. As of

June 2009, James Johns is asking Judge Michael Hendrickson for attorney fees. James

Johns, former GAL Mr Stewart and the present GAL MR Lutman together along with

Brandy Wilkenson has conspired to embezzle money from Plaintiff Robert Gipson.

Defendant, Sherriff Deputy officer Haun, Benton County Sherriffs Department.

49
Plaintiff contacted the Cole Camp Police and the Benton County Sherriffs

Department. Plaintiff was threatened by Benton County Sherriff Police Officer

Haun. On or about Nov 9, 2006, Plaintiff reported the kidnapping of Casey Ryan

Gipson. Plaintiff escorted Offcer Haun to a suspected place where the child may

Be. There was a court order in place which authorized Plaintiff to have his weekly

visitation. Officer Haun warned the Plaintiff not to go near the house. Officer Haun

conspired with Brandy Wilkenson and case workers from the Missouri Children’s

Division. Officer Haun works in the same Department as the other Officers who

have harassed and falsely arrested Plaintiff on April 26, 2009. On April 27, 2009,

officer Haun escorted Dawn Long into the holding area at the Warsaw Benton

County Sherriff’s jail. Officer Haun conspired with CPS case workers and

obstructed justice. Officer Haun failed to report the high risk environment which

the minor child is subjected to. When the Plaintiff escorted officer Haun to the

Grandparents house of the minor child, there were over five hunting rifles leaned up

against a van in the grandparents yard, These weapons were unmanned.

Prior reports back in 2004 and 2005 by Plaintiff was also about loaded guns

in the grandparents house, These guns were against the wall. The minor child was

crawling in the grandparents house. Plaintiff has made reports about the health

hazards at the grandparents house. This reports were presented to case workers,

police and supervisors. Officer Haun’s threats towards Plaintiff in 2006 and the on

going threatsin 2009 by this same police department have proven to abusive and

out of control. Prior to Plaintiff’s arrest on April 26, 2009, officers from the

Sherriff’s Department harassed Plaintiff on Wednesday by banging on his door at

50
11;30 p.m. In 2007, Plaintiff was arrested and taken into custody. The arresting

officers did not have an arrest warrant nor did they read Plaintiff his rights. Plaintiff

was once again arrested on false accusations by Defendant Brandy Wilkenson. The

police officers making the arrest ignored Plaintiffs statements. The Lincoln police

officer at the time of the arrest and after Plaintiff was handcuffed stated “ FUCK

you, your not getting dressed, your leaving now.” Plaintiff was taken into custody

with his slippers and long johns on. In Christmas 2008, Plaintiff was once again had

his civil rights violated. With Plaintiffs child in his car, the Lincoln Police, pulled the

Plaintiff’s car over and harassed the Plaintiff. Plaintiff moved to Lincoln Missouri

on May 10. 2005. Plaintiff has been Maliciously attacked ever since. Plaintiff

request that this court provide protection for Plaintiff and his minor son Casey

Gipson. Plaintiff has received death threats and has had many times dead animals

thrown in his yard. Plaintiff has received calls on his cell phone and the caller shot

rounds from a gun as Plaintiff was listening. Plaintiff has received threats on the

internet and has been stalked. Plaintiff has called the Benton County 911 number

and was ignored. It has been proven time and time again that Plaintiff and his child

Casey Gipson will be ignored and not get the protection from the government

agencies in this community nor by any other state agency in Missouri. Plaintiffs

request that a federal investigation be conducted into the claims made against the

Benton County Sherriff’s Department and all other municipalities as indicated by

Plaintiff.

Defendant, William Haefer, 30th Circuit Manager, Benton County Missouri


Children’s Division

51
Defendant, Attorney, James Johns, Brandy Wilkenson’s Attorney in 2007 and 2009

Defendant, Brandy Wilkenson, Mother of minor child Casey Gipson

Defendant, Former, Attorney James Rice, Attorney for Brandy Wilkenson in 2004,

Defendant, Dr, Susan Waldo, minor child’s counselor.

Defendant, Dr. Daniels, Psychiatrist

Defendant, Dr. Tim Viauniaux, court appointed psychologist.

Defendant, DR. Erika Waller, psychologist for child and father. Ms Waller failed to

report the neglect and abuse against the minor child Casey Gipson. Casey Gipson was

interviewed by Erika Waller in the office building of Dr. Daniels in Columbia Missouri.

During this interview, Casey was asked a series of questions by Dr. Waller. Three of the

questions were as follows.

1. What makes you mad? Casey answered, when mommy hits me in the face.
2. What makes you saddest? Casey answered, when mommy hits me in the eye.

Dr. Waller never reported this to the proper authorities. Dr. Waller is a mandated

reporter. Dr. Waller received an intake form from Plaintiff Robert Gipson. Plaintiff

also was interviewed by Dr. Waller and Dr. Daniels. Plaintiff informed both doctors

of the previous incidents where the child had witnessed his mom getting beat by

Jason Warren. Plaintiff presented various documents containing reports of abuse. Dr.

Waller and Dr. Daniels were both in a position to protect Casey Gipson. Plaintiff had

presented many documented accounts of neglect and abuse against the child. Prior to

Dr. Waller interviewing Casey Gipson, she was already aware of the childs past

52
history in witnessing domestic violence and the child himself being a victim of

physical and mental abuse. Plaintiff never received any report that described what

the minor child had said to Dr Waller unitl approximately one and a half years later.

Plaintiff was not informed of these issues of his son being beat in the face by his

mother. Plaintiff was litigating in family court on these same issues. Dr. Waller and

Dr Daniles were aware of the court hearings. Casey Gipson could have been

protected by these two doctors and they both failed him. As the father of the minor

child, Plaintiff was kept in the dark. Dr. Waller and Dr Daniels are both mandated

reporters. They were paid over $1,000.00 dollars for their services. There were only

three visits to the Columbia office. These doctors were put on notice about the high

risk environment that endangered Casey Gipson’s life. They heard the cries of a child

pleading for help and covered up vital reports. These reports tha clearly showed a

child and father in need of professional help were masked and kept silent. Attached

in Plaintiffs exhibit is a copy of Dr. Wallers report. This mandated reporter like so

many others have deceived Casey Ryan Gipson. The school teacher who told Casey

Gipson to keep it to himself when Casey told her about the 911 call also deceived the

minor child.

53
Defendant, DR. Salenger, psychologist for child. Dr. Salenger treated Casey Gipson

for two weeks before Plaintiff had any idea that his child was going through counseling.

Dr Salenger was recruited by Jim Rice, Brandy Wilkenson’s attorney. Plaintiff was kept

in the dark for weeks before being informed by Brandy Wilkenson that Casey seeing Mr.

Salenger. Prior to Casey Gipson seeing Dr. salenger, Plaintiff informed Defendant

Brandy Wilkenson that Casey was beating his face on the airplane and said “Mommy got

beat at the washing machine by daddy Jason and I tried to tell him no but he would not

listen.” Plaintiff informed Defendant Brandy Wilkenson that he was taking Casey to see

a professional. When Plaintiff arrived to pick up the minro child, Brandy Wilkesnon

refused visitation even though the court order allowed such visit. Once again Brandy

Wilkenson was in contempt. Plaintiff attempted to have a Cole Camp Police officer

escort the Plaintiff to retrieve his child. The Cole Camp police officer like all the others

sated “If you do not leave I will arrest you and this convcersation is over” The Cole

Camp police officer also stated that he just spoke with Jim Rice, the attorney for

Defendant and then the police officer said “Your only here to see Brandy.” When

Plaintiff made a schedule to see Mr Salenger and requested docymenst, Dr. Salenger

reluctantly refused. Plaintiff took Casey Gipson for a counseling visit with Dr. Salenger.

Plaintiff observed Casey Gipson crawling over the thighs of Dr. Salenger. Plaintiff was

not comfortable seeing this. The room was very dirty and the toys were broken and

filthy. The smell of mold and cigaretts filed the air. When Plaintiff asked Dr. Salenger

54
why did he wait two weeks to inform Plaintiff that he was treating his son? Dr. Salenger

stated “ The mother told me that you knew.” Plaintiff did not know that his child was

being treated. Plaintiff tried to get his child a counselor close to Lincoln Missouri. The
drive to Clinton was selected by Brandy Wilkenson. As always, Defendant Brandy

Wilkenson and her lawyers deceive and manipulate their way to achieve their desired

goals. To date their goals are to destroy the life of a father and son who once had a

natural loving bond. They have a blatant disregard for human life.

Defendant, Dr. Julie Cahill, physician for child. Dr Julie Cahill failed to report to the

court that Casey Gipson has a medical history for being treated with prescriptions of Iron

medication and antibiotics. Plaintiff inquired about the use of to much antibiotics on his

child. Dr. Cahill refused to contact Dr. Nicholas at the Children’s Mercy Hospital.

Plaintiff scheduled an appointment with an E.N.T. so that Casey Gipson could be

evaluated for his Sleep Apnea. Brandy Wilkenson interrupted this scheduling. At the

time Plaintiff had every right to seek medical attention for his child. Presently, Plaintiff

has been forced to a five hour visitation and is unable to help his child. Dr Cahill sates

that the child is normal. Dr Cahill did observe the minor child sleep for two years. No

doctor can effectively evaluate a child for Sleep Apnea unless it is done by a Sleep Study

and the child is seen by an E.N.T. On Jan 4, 2009, Plaintiff took the child to the

emergency room because the child stopped breathing for approximately ten seconds.

Once again Defendant Brandy Wilkenson ignored Plaintiffs concerns and interrupted the

emergency room visit Prior to Nov 6, 2006, Plaintiff observed Casey Gipson with svere

Sleep Apnea. It was not until Jan 2009 that the Plaintiff was able to observe two nights

of the child having Sleep Apnea was Plaintiff able to provide medical help by taking

55
Casey Gipson to the emergency room. Dr. Cahill and other doctors from her office have

masked the true medical issues that affect my son Casey Gipson. They have ignored

phone calls and written reports from Plaintiff. Attached is a letter to Dr Cahill in

Plaintiffs exhibits.
ndant, Bank of America,

Defendant, Ms. Peterson, School Principal for minor child. Ms Peterson has
interrupted many times Plaintiffs relationship with his child. Ms Peterson created a false

accusation that the Plaintiff sexually molested his child Casey Gipson. Defendant Ms

Peterson conspired with Brandy Wilkenson to frame Plaintiff and slander. This was the

second Hot Line call that Plaintiff sexually molested his child. The first one was just

months if not weeks prior to the School Principal doing the same. She called the Hot

Line and recorded this called Plaintiff on his cell phone and sated “You are not welcome
in

my school and we will take care of Casey’s education” Ms Peterson sated that she

watched Plaintiff on the security monitor. Ms Peterson staed that the Plaintiff is a threat

to the children on the play ground. Plaintiff brought his child a yellow car and showed

him the car at the playground fence. Ms Peterson informed Plaintiff that she will call the

police if Plaintiff gets out of his car. The year before this threat, Plaintiff was always at

the school play ground. On one other occasion as the Plaintiff was waiting to greet his

child at the school Christams play, Defendant Brandy Wilkenson refused Plaintiff from

having any contact with his child. Ms Peterson interrupted and assisted Brandy

Wilkesnon. The minor child was crying because he could not stay and watch the first

graders sing. This is once again the insanity that the Plaintiffs must experience at the

hands of Defendant Brandy Wilkenson

56
Defendant, MS, Pre-school teacher for minor child, Plaintiffs right to father his child

was interrupted by the pre school teachers at the Little Blue Byrd School. During a

Holloween, n breakfast Plaintiff sat beside his child Casey Gipson. Next to the Plaintiff

approximately ten feet away, the two pre- school teachers were talking about a parent

who failed to listen to them and they removed the parents child. This was a very odd

subject fot two school teachers to be having in front of their students. Later one of the

school teachers testified against the Plaintiff Robert Gipson. Plaintiff was accused of

feeding his child his breakfast. The fact was that the Plaintiff was attempting to

encourage his child to eat his breakfast. This was just another way for these teachers to

assist the mother to get custody. These same two pre-school teachers interrogated my

child and reported that I sexually molested him. The report from the case worker and

these teachers was that “ Plaintiff had his child bite the head off a snake after playing buc

the Donkey.” Ms Peterson and her staff of teachers were well aware of the head

injuries that Casey Gipson had on his head. Casey informed Plaintiff that “a car threw

rocks on him and made him spin around and he laughed.” In a school picture the

minor child had yet another head wound. Plaintiff was informed by his child “ Connor

hit me in the head with a rock and blood went down my stomach” Casey Gipson stated

that the blood ran down to his feet when his grandmother washed him off in the shower”

Defendant, MS, Wooleby, Pre-school teacher for minor child,

Defendant, MS, kinder garten teacher for minor child,


The Kinder Garden teacher failed to report to the authorities about the abuse in the home

of Casey Gipson. Plaintiff was informed by his child that his mom yelled from behind

closed doors. Brandy Wilkenson told the minor child Casey Gipson to go call 911 and

tell Melissa. Casey Gipson told his school teacher and she replied “Keep it to your self”.

57
Plaintiffs child Casey Gipson informed Plaintiff of this incident during one of his visits.

Plaintiff has reported this incident and many others. School teachers and principals are

mandated reporters. These are severe violations and these school officials violated the

civil rights of the minor child. They have failed to protect this child.

FACTS COMMON TO ALL COUNTS

14. In 2003 , Brandy Wilkinson, did cause a Petition for Declaration of Paternity to be

filed against Robert Gipson, in the Circuit Court of Benton County, Missouri, in cause

number #03CV694772.

15. In that cause Robert Gipson was found to be the natural father of Casey

Gipson, a minor child and the parties were awarded Joint Legal and Joint Physical

custody over said minor child.

16. On or about November 9, 2006, in retaliation against the plaintiff for

making a “hot line” reports of abuse/neglect against Brandy Wilkinson, the mother of

Casey Gipson, to the Children’s Division, defendant Brandy Wilkinson did cause and or

did conspire with others to cause an unfounded and untrue “hot line” report of sexual

58
abuse against plaintiff Robert Gipson to be made to the Children’s Division of Benton

County, all in retaliation for his lawful and correct report of abuse/neglect against her

regarding the minor child Casey Gipson.

17. On or about February 7, 2007 defendant Brandy Wilkinson, in retaliation

for plaintiff’s reports of her medical neglect and exposing the minor child Casey Gipson

to domestic abuse by his then step father, she did cause a Motion to Modify to be filed in

the above captioned matter, said Motion seeking to deprive plaintiff of his joint custody

rights.

18. When the Children’s Division ignored the complaints of medical neglect

and exposure of the minor child to domestic violence, made by plaintiff against defendant

Brandy Wilkinson, hereinafter referred to as “Mother,” the defendants then collectively

and individually denied to the minor child the rights and privileges guaranteed to the by

the United States Constitution including, but not limited to, the right to be protected, to be

free of invasion of bodily integrity and to be free from being denied their rights under the

equal protection clause of the Fourteenth Amendment.

19. Defendants, from the Missouri Childrens Division and others acting in

their official and individual capacity and, under color of authority and in their capacity as

agents of the State of Missouri, individually and collectively placed the Minor child in

defendant Brandy Wilkinson’s home under authority of the Children’s Division, and did

thereby ensure that the lawful joint custody rights of the plaintiff could not be exercised

as set forth in the original Decree of Paternity, and in so doing further neglected the

medical health and well being of the minor child and did perpetuate the exposure of the

minor child to the domestic violence in the home of Mother and thereby prevented

59
plaintiff from properly protecting his child, and did harm both plaintiff Robert Gipson

and the minor child Casey Gipson by depriving each of them of their constitutional rights

to have a child in the custody of their lawful parents. Moreover, the following

defendants, Dr Julie Cahill and other doctors from her office knowingly refused the

minor medical care for his chronic airway obstruction and have placed the minor child’s

life in jeopardy. On Jan 4, 2009, the child was taken to the Kansas City Missouri

Childrens Hospital after experiencing Sleep Apnea for two nights in a row and a bloody

nose and congestion the day before the Jan emergency room visit.

20. Defendants failed to do a thorough investigation of the complaints made

by plaintiff regarding the medical neglect and exposure of the child to domestic violence

in the home of defendant Mother and the mother’s mother Shela Wilkenson. Defendants

individually and acting in concert with one another conspired to deprive plaintiff of the

joint custody rights he had with his minor child Casey Gipson and further did act alone

and in concert to deprive Casey Gipson of his right to be n the custody of his father

Robert Gipson. Specifically, the defendants

did, individually and acting in concert with one another committed or participated in the

following acts:

a. Ignored or refused to properly investigate the allegations of medical

neglect and exposure of the child to domestic violence in the home of

Mother;

b. Manufactured, or coerced, false evidence of abuse and or neglect by

Plaintiff, Robert Gipson, in a retaliatory effort to deprive Robert Gipson of

60
his lawful custody rights and to deprive Casey Gibson of the love, comfort

and protection of his lawful father;

c. Defendants individually, collectively and all under color of authority, did

use their positions to manufacture false allegations against Plaintiff

Robert Gipson to the end that he should temporarily be deprived of his

joint custody rights as to Casey Gipson, and subsequently, that deprivation

was used by Mother in her Motion to Modify proceeding which have

resulted in plaintiff having extremely limited contact with his son.

d. Refused plaintiff access to evidence which purportedly contained evidence

against plaintiff as indicated by an alleged videotape of an interview with

the minor child. Yet, this evidence has been used to further the conspiracy

to deprive the minor of a relationship with his father.

Count I – Denial of Substantive Due Process

21. Plaintiffs restate and re-allege all allegations contained in paragraphs 1

through 20 of this complaint as though fully set forth herein.

22. Plaintiffs cause of action against the above named defendants for the

failure to investigate, wrongful removal of Casey Gipson from his father Robert Gilpin,

was due to their denial of the substantive due process rights of Casey Gipson to associate

with his Father and the right to be protected, all of which is a denial of his due process

rights under the Fourteenth Amendment. Moreover, the minor child is in eminent danger

due to the intentional medical neglect of the defendant’s.

61
23. Defendants’ actions, as stated above, were reckless and outrageous and

subjected Plaintiff to loss of consortium with his child, damage to his business and

personal reputations.

24. The acts of defendants under this count were under the color of state law.

25. Plaintiffs are entitled to a recovery of reasonable attorney fees pursuant to

42 U.S.C. §1988.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory

damages in an amount that will justly compensate Plaintiffs for economic and non-

economic damages in excess of $500,000.00; for punitive damages in such amounts as

justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and

such other relief as may be granted by the Court.

Count II - 42 U.S.C. §1983 CONSPIRACY

26. Plaintiffs, for Count One of their complaint, incorporate by reference

paragraphs 1 through 50 of this complaint as if fully set forth herein.

27. This Count constitutes the claims of Plaintiffs with respect to Defendants

from the Missouri Childrens Division.

28. Defendants from the Missouri Childrens Division acted in concert against

Plaintiff Robert Gipson to deprive him of his Joint Custody rights, by manufacturing false

allegations to discredit Plaintiff Robert Gipson, encouraging others to do the same, and

using those false allegations to deprive him of his Joint Custody rights through Juvenile

and family Court proceedings..

62
29. Defendants, from the Division used the power and prestige of their

positions to investigate and discredit plaintiff Robert Gipson as a part of this

conspiracy.

30. Defendants shared the objective to discredit plaintiff Robert Gipson and

deprive him of his Joint Custody rights.

31. The campaign by Defendants caused substantial emotional and financial

damages to Defendant Robert Gipson.

32. Defendants’ actions, as stated above, were reckless and outrageous and

subjected Plaintiffs to loss of consortium with his child damage to his business and

personal reputations.

33. The acts of defendants under this count were under the color of state law.

34. Plaintiffs are entitled to a recovery of reasonable attorney fees pursuant to

42 U.S.C. §1988.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory

damages in an amount that will justly compensate Plaintiffs for economic and non-

economic damages in excess of $900,000.00; for punitive damages in such amounts as

justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and

such other relief as may be granted by the Court. Plaintiff states that he has been forced

to file such suit in order to protect the interest of his minor child. Plaintiff moves to

63
Quash all Summery judgments against this suit by any and all Defendants.

Count III – Missouri State Law Claim - Tortious Interference

35. Plaintiffs, for Count Four of their complaint, incorporate by reference

paragraphs 1 through 34 of this complaint as if fully set forth herein.

36. This Count constitutes the claims of Plaintiffs with respect to all

Defendants.

37. Plaintiffs are father and son and Father Robert Gipson had previously to

the acts of Defendants enjoyed a close loving relationship with his son Casey Gipson

over who he shared joint Custody . This permitted the plaintiffs to have and maintain a

close loving relationship and for father to protect son regarding his medical needs and

regarding his son’s exposure to domestic violence in the home of Mother.

38. Each of the Plaintiffs had and enjoyed a close, loving and constitutionally

protected relationship and had the expectation that this relationship would continue.

39. Defendants were aware of the close relationship between the Plaintiffs and

knew that only be manufacture and dissemination of false, spurious and incendiary

allegations could this relationship be severed in open court as Plaintiff Robert Gipson had

joint custody and presumed by Missouri law RSMO.452.375 et sec.. Defendants were

aware of the nature, extent, closeness and constitutionally protected nature of Plaintiffs

relationship. Defendants’ actions were an intentional interference with the familial

relationship and the expectancy of Plaintiffs under the Constitution to such a familial

64
relationship.

40. Defendants have no reasonable justification for their actions to interfere

with the relationship and plaintiffs’ expectation that it would continue unmolested. The

means used to interfere with the relationship was an unlawful and wrongful interference

with plaintiff's constitutionally protected relationship. Such actions were taken in the

absense of malice, spite, or ill will.

41. Defendants’ conduct caused damage to plaintiffs’ constitutionally

protected relationship.

42. Plaintiffs were damaged as a result of defendants’ actions.

43. Defendants used threats of criminal charges, defamatory information, mis-

representation of facts, and abuse of the Court process to interfere with the Plaintiffs’

constitutionally relationship.

44. Defendants’ actions, as stated above, were reckless and outrageous and

subjected Plaintiffs to loss of consortium with one another.

45. The derogatory and unfounded statements of Defendants caused Plaintiffs

the loss of their constitutionally protected relationship.

46. Plaintiffs are entitled to a recovery of their reasonable attorney fees and

Punitive damages under Missouri Common Law for tortuous interference with their

constitutionally protected relationship.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory

damages in an amount that will justly compensate Plaintiffs for economic and non-

65
economic damages in excess of $900,000.00; for punitive damages in such amounts as

justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and

such other relief as may be granted by the Court.

COMPLAINT CONTINUED

SIGNIFICANT EVENTS AND TIME FRAMES

FROM

MAY 26, 2002 – July 9, 2009

1. Casey Ryan Gipson was born in Missouri on May 26, 2002. Brandy Wilkenson

mother of Casey Gipson refused to allow the father, Plaintiff Robert Gipson to be

present during birth of the minor child.

2. Plaintiff Robert Gipson and Brandy Wilkenson met in New York City just prior

to Sept 11, 2001.

3. Brandy Wilkenson informed Plaintiff Robert Gipson that she was pregnant and

the child was not his. Brandy Wilkenson sated that she had tests and that she was

pregnant by another man and not Plaintiff Robert Gipson.

4. Plaintiff Robert Gipson assisted Brandy Wilkenson with financial an emotional

support even though he was informed that the child was no his.

5. Plaintiff was in the United States Army in New York and was ordered to proceed

to New York City on 9/11/01. Plaintiff was the Operation NCO for the rescue

operation in New York City on 9/11/01. Plaintiff deployed to New York City to

assist in the 9/11 disaster.

66
6. Following 9/11, Plaintiff moved to Florida to join the Florida National Guard

where he later deployed to Iraq .

7. Prior to moving to Florida, Plaintiff was surprised by Brandy Wilkenson as she

changed her story and now stated that Plaintiff Robert Gipson was indeed the

father of her un born child.

8. Plaintiff sent money to Brandy Wilkenson while residing in Florida. Plaintiff

was Unemployed and even though no DNA test was done, Plaintiff still

supported Brandy Wilkenson. AT this time there was no proof of DNA test done

to confirm that Plaintiff Robert Gipson was indeed the father of the un-born

child.

9. On Nov 2002, Plaintiff Robert Gipson gave Brandy Wilkenson $1,500.00 dollars

to fly her and the minor child to Florida where they initialy stayed in Plaintiffs

condo in largo Fla. Plaintiff did so knowing that he was getting ready to deploy

to Iraq.

10. When Brandy Wilkenson arrived to the Plaintiffs condo with the minor child she

began to get phone calls from Jason Warren her now present husband.

11. Brandy Wilkenson and Plaintiff was invited to Betty Matson’s daughters home

for a Thanksgiving Dinner.

12. Prior to the dinner, Plaintiff took Brandy Wilkenson and the minor child Casey

Gipson to Bryan Rogers home. Brandy Wilkenson prevented Plaintiff from

allowing Mr. Rogers and his mother from seeing the child. Finally after begging,

Brandy Wilkenson allowed Plaintiff to take the baby up to the house of Mr.

67
Rogers. Brandy Wilkenson refused to come up to the house and remained in the

car.

13. The next day after the dinner, Brandy Wilkenson attacked the Plaintiff in his

home in Largo Florida and ripped the phone out of the wall. . Plaintiff Robert

Gipson then took the baby Casey Gipson and Brandy Wilkenson to a Hotel in

Clearwater Beach. With great regret, Plaintiff left the baby with Brandy

Wilkenson at the hotel and returned to his Condo in Largo Fla.

14. Later that night Brandy Wilkenson left a message on Plaintiffs answering

machine that the baby Casey Gipson has been crying all day and that she was

taking him to the hospital. She also stated that Casey needs diapers.

15. Reluctantly, Plaintiff fearing for his safety and the safety of the baby, Plaintiff

returned to the hotel. When Plaintiff arrived, it was very cold out side and

Plaintiff observed Brandy Wilkenson with the baby and the baby had only a

diaper on. Plaintiff immediately took the baby and stood outside the hotel room

with the child in the sun trying to warm the child.

16. Later that night, once again Brandy Wilkenson attacked the Plaintiff and this

time she ripped the hotel phone out of the wall. Plaintiff pushed Brandy

Wilkenson off him and then Plaintiff secured the baby in his arms. At this time

the baby was crying and stopped crying when Plaintiff held him.

17. Brandy Wilkenson then snatched the baby out of Plaintiffs arms and ran out side.

18. At this time Plaintiff had yet obtained a DNA test and had no legal rights.

Plaintiff was only there to provide comfort for the baby knowing that Brandy

68
Wilkenson was attempting to conspire an attempt to bring discredit to Plaintiff.

19. Brandy Wilkenson went next door to the pay phone and called the police and

reported that Plaintiff Robert Gipson attacked her.

20. The child was out in the cold in his diaper for over forty minutes as Brandy

Wilkenson stood outside talking to the Largo Police Officers.

21. Plaintiff was falsely arrested on a false accusation by Brandy Wilkenson that

Plaintiff assaulted her. Plaintiff was arrested and stayed in mhe Largo jail for

over forty eight hours.

22. This was Brandy Wilkenson’s first attempt of her conspiracy slander and bring

discredit against the Plaintiff.

23. Brandy Wilkenson left town the next morning and flew to New York to see

Jason warren. Jason Warren sated this in person in 2004 during a visit at the

Warsaw a Park.

24. Brandy Wilkenson and others planned this staged event. She left town the next

morning. Brandy Wilkenson was contacted by the Largo Prosecution Attorney

Mr Gibson. She told the Prosecuting Attorney that she will not be returning to

Florida for court and the P.A. dismissed the charges.

25. The damage was done. Plaintiff spent over forty eight hours in jail prior to

deploying to Iraq. Brandy Wilkenson received phone calls at Plaintiffs condo and

she made calls from the laundry matt prior to being taken to the Largo Hotel.

Brandy Wilkenson was coached and she succeeded in falsely accusing Plaintiff

of assault when in reality it was the Plaintiff who was assaulted.

69
26. To this day Brandy Wilkenson has brought numerous false accusations against

Plaintiff. She has done so with the assistance of case workers, judges, lawyers,

psychologist, doctors and others who have made false reports and slandered

Plaintiff.

27. Brandy Wilkenson has manipulated the courts and other individuals in order to

gain custody of the minor child Casey Ryan Gipson. Brandy Wilkenson is from

Warsaw Missouri. She once stated to the Plainitff and I quote “ This is a small

town and they will protect me”

28. Prior to deploying to Iraq, Plaintiff received a phone call from Brandy

Wilkenson, she stated “ I will have you in court for the next eighteen years and

will make sure Casey hates you”

29. Brandy Wilkenson had a video camera set u in her hotel room. The video camera

was set on a table facing the couch. Brandy Wilkenson reached over to kiss

Plaintiff in front of the camera. She did so to deceive Plaintiff and to attempt to

create an issue and have it on recording. On or about October 2005, Brandy

Wilkenson came to Plaintiffs house in Lincoln Missouri. She stated that she was

divorcing Jason warren and that she wanted to be with me. I told her that I can

not be with her. The next morning I took Brandy Wilkenson to a house that was

for sell. She said that the house was to small. Brandy Wilkenson came to

Plaintiffs house in Lincoln with a black eye and bruised hip. She lied to Jason

warren and said she was there because she locked her kesy in her car and needed

a place to stay. Brandy Wilkenson is a danger to Casey Ryan Gipson and her

other two biological children and her two foster children. If she continues to be

70
allowed to deceive the courts, police and others, she will never stop her insanity.

2003

30. Plaintiff deployed to Iraq in May 2003. Prior to deploying Plaintiff had a DNA

test done and it was confirmed that Casey Ryan Gipson was Plaintiffs child.

This DNA test was samples from a swab DNA test, no blood test was done.

31. When plaintiff informed Brandy Wilkenson that he had a DNA test done Brandy

Wilkenson had her phone disconnected. From May 2003 to approximately

Easter 2004 Plaintiff had no contact with the minor child. It was not until Easter

2004 that Plaintiff held his child Casey Ryan Gipson. It was at this time that

Plaintiff first saw the burn mark on Casey Gipsons arm. Plaintiff asked Brandy

Wilkenson how the burn mark got there and she stated and I quote “ Its non of

your business” This was stated in front of the GAL Mr Stewart and Wilkensons

lawyer Jim Rice. This was stated at the Warsaw Park next to the swimming pool

and on the Tennis courts. It was at the Tennis courts that Jason Warren stated

that he was the one waiting in New York for Brandy Wilkenson.

32. It was also Easter 2004 that Plaintiff reported the severe bruises on Casey

Gipson’s nose and forehead. NOTE: SEE Exhibit with pictures of minor

child. Brandy Wilkenson never took the child to the hospital for the bruised

nose and bruised for head. She never took the child to the hospital for the oven

burn. To date the child has Sleep Apnea and obstructed Airway. His nasal

passage is often congested especially when he has an URI Upper Respiratory

71
Infection which he gets severly in the winter. NOTE: Plaintiff has presented a

video, cd, and pictures showing the severe Sleep Apnea and other stressors

which the child has endured. Presented to Brandy Wilkenson, Dr Cahill, Dr

Nicholson Children Mercy Hospital, Mr. Harrison, Ron Levy, Ms

Hartgrave, Steve Morrow, Nancy Parks and Missouri Foster care program.

Various case workers and Investigators have also been put on notice.

When his nose and forhead was smashed he may have had his nasal passage way

affected and this could be why he has trouble breathing through his nose. The

minor child is subjected to smoke, mold and environments that put him at hig

risk. On Jan 4, 2009, Plaintiff took the minor child to the Childrens Mercy

Hospital due to Sleep Apnea and Obstructive Airway. Brandy Wilkenson

interrupted the doctors when she called the hospital and stated I have no rights

and that she was the custodial parent. Brandy Wilkenson has achieved her goals

and objectives of alienating the minor child from his father Robert Gipson.

Since the childs birth, Brandy Wilkenson, Jim Rice and James johns have

conspired to make this a reality and have conspired to braek the bond between

Plaintiff Robert Gipson and the minor child Casey Gipson. Un-founded reports

and false accusations of sexual abuse, child endangerment and many other false

accusations have resulted in Plaintiff losing custody of his child Casey Gipson.

When two or more conspire to bring harm against another person is a federal

crime. When such harm violates a persons civil and constitutional rights, this

also is a federal violation. When government workers bring with Malice and

Malicious prosecution against a person, this excuses them from immunity.

72
NOTE: SEE NOTES FROM PLAINTIFF DATED FEBRUARY 15, 2003 AT

2300HRS WHILE ON MILITARY DUTY IN FT STUART GEAORGIA

PRIOR TO DEPLOYING TO IRAQ.

2004

33. Plaintiff returned from Iraq in Feb 2004. Plaintiff was stationed in Ft Stewart

Georgia from Feb 2004 thru May 2005. Plaintiff would fly monthly to Warsaw

Missouri from Georgia to see the minor child.

34. Plaintiff was dragged through the family court system in Benton County

Missouri. When Plaintiff arrived to review his case files, the Clerk of court

stated that there was no case opened.

35. While in Iraq, Plaintiff hired a lawyer from St Louis Missouri. This lawyer

deceived Plaintiff and stated that she had filed motions with the court. This was

nothing more further from the truth.

36. Once again Plaintiff was deceived by Benton County Clerk and judge Burdett.

From Feb 2004 thru May 2005, Plaintiff was dragged through the family court in

Benton County. Excessive litigation and months of court hearings cost Plaintiff

thousands of dollars.

37. Plaintiff spent thousands of dollars to attend court hearing after court hearing.

Plaintiff had to file motion after motion to get visitation with his child Casey

Gipson.

38. Plaintiff even though there was a judgment for visitation, was alienated from the

minor child numerious times after arriving in Missouri from Georgia.

39. The GAL Mr Stewart forced the Plaintiff to terminate a four hour visit for no

73
apparent reason.

40. Plaintiff had every legal right to visit his child. Plaintiff did nothing to deserve

such treatment by Brandy Wilkenson or the GAL MR Stewart.

41. Plaintiff returned from Iraq expecting to have a normal life with his child. Sinse

his return, Plaintiff and his minor child has endured acts of inhumane treatment

and at the hands of court officials who have destroyed Plainitff’s life.

42. Plaintiff was forced to endure over nine months of excessive court hearings.

Many court hearings were like a revolving door having to motion for visitation

time and time again. Eroneous court motions filed by Defendants Jim Rice,

James Johns and Brandy Wilkenson created a hostile environment.

43. Plaintiff was treated un fairly when he returned from Iraq. Plaintiff’s civil rights

to be a father to his child were infringed upon.

NOTE: SEE PICTURES OF BURN MARKS OF CASEY GIPSON AGE TWO

74
2005

43. On May 10, 2005, Plaintiff Robert Gipson moved to Lincoln Missouri. Once again

Plaintiff endured at the hands of this unjust family court in Benton County Missouri,

months of court hearings and it was not unitl on or about November 2005 was Plaintiff

awarded Joint Physical custody.

44. Defendant Brandy Wilkenson continued her manipulation and refused to listen to

Plaintiffs concerns about the neglect and abuse by her husband Jason Warren. To this

day Brandy Wilkenson has denied that she was beat by Jason warren in front of the minor

child and has ignored Plaintiffs concerns about the Sleep Apnea that Plasintiff has

observed since 2004. Plaintiff has observed the minor child Casey Gipson with Sleep

Apnea sinse 2004.

44. On or abour October 2005, Plaintiff was held hostage by Jason warren. Jason Warre

forced his way into the home of Robert Gipson in Lincoln Missouri. Prior to this Jason

warren has attacked the minor child in 2004 as well as the Plaintiff. Jason Warren has

driven wreclessley with the minor child in his van. Jason warren tried to slice the tires of

Plaintiff at the store in Cole Camp Missouri. Jason warren chased the Plaintiff and

attempted to restrain the minor child from going with the Plaintiff on numerous

scheduled visits. On fathers Day 2008, Jason warren took the child to St Louis Missouri

knowing that it was Plaintiffs scheduled visitation.

45. In the year 2005, Plaintiff took the minor child Casey Gipson to see Dr Julie Cahill.

75
Numerous times sinse 2005, Plainitff has observed the minor child with Sleep Apnea and

Obstructed Airway. Many doctors at the Emergency room in Sedalia Missouri and

Columbia Missouri have stated on medical reports that Casey has Tonsil Idous, Upper

Respritory Blockage and Bronchitus.

44. Brandy Wilkenson has been informed many times by Plaintiff that Casey Gpson

is sick. Plaintiff has called Dr Cahill and other doctors sinse 2004 and has taken

Casey Gpson to doctors in Colorado, Florida and Missouri. The Sleep Apnea

has been mild to severe. In 2009 Casey Gipsons Oxygen desaturation level was

88% for over three minutes. This is severe considering his prior health record at

shows mild to severe Sleep Apnea and Congestion. To date and as of Jan 2009,

Casey Gipson was taken to the Hospital in Kansas City Missouri where he was

diagnost with an URI Upper Respiratoy Infection. The URI increases the risk of

severe Sleep Apnea. If Sleep Apnea is not treated properly a child could have

long term medical problems with their heart, lungs and other medical issues and

at times even death. Plaintiff has informed the courts, doctors and Brandy

Wilkenson of what he and others have witnessed. Plaintiff has observed the

minor child with severe Sleep Apnea and has taken video to show the same.

Other witnesses have also observed such medical conditions with the minor

child.

NOTE: SEE POLICE REPORT DATED OCTOBER 25, 2005 BY ROBERT

GIPSON PLAINTIFF AND POLICE REPORT FROM SHIRLEY KAISER

WITNESS TO JASON WARREN BEATING BRANDY WILKENSON WARREN

76
AT PLAINTIFFS HOUSE IN LINCOLN MISSOURI DATED OCTOBER 25, 2005.

2006

45. Former Senator Talent sent a letter to the former director of the Missouri
Childrens Division, Debra Scott as did thirdy party witnesses of their concerns
for Casey Gipson the minor child. Following these letters, Brandy Wilkenson
made the first false accusation that the Plaintiff sexually molested his child
Casey Gipson. This was done in order to modify the existing court order.

46. Shortly after the school principal Ms Peterson and her Pre-school staff from Cole
Camp Elementary Little Blue Byrd school, made yet another Hot Line call to the
Missouri Child Abuse HotLine. They accused Plaintiff for sexually molested his
child Casey Gipson. This is yet another conspiracy to slander and degrade
Plaintiff.

47. On Nov 2006, Brandy Wilkenson kidnapped the minor child from his pre-school.
This was a day when Plaintiff had a court ordered visitation. Prior to Nov 9,
2006, Plaintiff tried to call to speak to Casey Gipson and Brandy Wilkenosn
never answered the phone. Once again Brandy Wilkenson made yet another
false accusation to the Authorities that Plaintiff abused his child this time she
said that I sexually molested my son Casey Gipson. These actions by Defendant
Brandy Wilkenson, caused the minor child and father to be once again alienated
from each other. This caused sever mental anguish for both father and son.
Brandy Wilkenson brain washed the child to believe that his father was not
talking to him. During a brief viist at the Warsaw bowling alley, Casey Gipson
stated to the Plaintif and I quote “Mommy said that your not talking to me and
only to others” Plaintiff explained to his child that is not ture and he is only
talking to him. When Defendant Brandy Warren approached the Plaintiff and his
minor chjild at the Estes Bowling Aley, the minor child looked at the Defendant
and stated “See, my daddy is only talking to me” During another viist at the
Estes Bowling Alley, Defendant Brandy Wilkenson staged a scene out side the
Estes Bowling Alley and had Plaintiff arrested. Defendants Brandy Wilkenson
and her husband Jason Warren made a false Police report that Plaintiff pinned
the Defendant against her van. After months of court hearings and delays in the
Benton County Court House, Defendant was found not guilty. Once again
Defendants Wilkenson and Warren slandered and decived the Plaintiff to get
custody of the minor child and discredit Plaintiff. This was done just prior to a
civil hearing that involved custody of the minor child.

77
48. Plaintiff contacted the Cole Camp Police and the Benton County Sherriffs
Department. Plaintiff was threatened by Benton County Sherrif Police Officer
Haun. As Plaintiff escorted Offcier Haun to a suspected place where the child
may be, Offcier Haun warned the Plaintiff not to go near the house. Officer
Haun conspired with Brandy Wilkenson and case workers from the Missouri
Childrens Division. Officer Haun works in the same Department as the other
Officers who have harrased and falsely arrested Plaintiff on April 26, 2009.

2007
49. On or about September 2007 and after approximately nine months of more court

hearings, Defendant judge Larry Burdett allowed Defendant Brandy Wilkenson a

ruling in her favor to modify the existing 2005 custody judgment.

Defendants listed in this complaint conspired with Brandy Wilkenson to slander

and discredit Plaintiff. This was done to help Defendant Brandy Wilkenson to gain

custody and force a modification change.

50. The ruling to modify the shared custody and joint custody oder was Un-founded.

The new 2007 court order is and was changed drastically based on false

accusations. The accusations were unfounded and had not merits for such a change

in the 2005 judgment.

51. The final court trial lasted for approximately eight hours. Out of these eight

hours, Plaintiff had approximately one hour for him and his witnesses to testify.

Defendant and her hired guns had approximately seven hours to control the court

hearings.

52. Defendants who testified confidently had contracts with case workers and the

Missouri Childrens Division.

78
53. Deendants who are listed in this claim such ascase workers Paula Woolery,

Rhonda Talley, and Brenda Chapman were ordered not to appear in court as it would

affect their capacity as case workers. Their lawyer motioned the court to Quash

their subeona to appear. These case workers ignored their lawyer and appeared to
conspire with Brandy Wilkenson to help her change the modification order. These

case workers are the same one who said tha I had my son bite the head off a snake

with our clothes off. These same case workers stated that sinse I am a single father

that Plaintiff should take parenting classes. These same case workers were informed

by Plaintiff about the neglect and abuse and observed for them selves burn marks,

cuts, bruises, and excessive bug bites on Casey Ryan Gipson.

NOTE: SEE DEPOSITION OF JASON WARREN ON JULY 27, 2007. SEE

PAGE SIXTEEN. JASON WARREN ADMITS TO PORN SITE. BRANDY

WILKENSON SATED IN THE JUNE HEARING THAT SHE DID NOT

MONITOR HER PORN SITE. SHE IS THE ONLY ONE THAT CAN PUT

THE CHILDS PICTURE ON HER PORN SITE. PAGE 16 Q. #9 Q.#15

ANSWER, DECEIVING AS HIS ENTIRE DEPOSITION

79
2008
54. After the new court judgment in Sept 2007, Defendant Brandy Wilkenson once

again was in contempt of court. She continued to ignored the pleas of Plaintiff

Robert Gipson about his concerns. Plaintiff reported many times that the

Minor child Casey Gipson was having Sleep Apnea. Defendant deceived the

Plaintiff when she stated numerious times that she had a doctors appointment yet she

never did, Plaintiff called Dr cahill to inquire about the appointments and was

informed that no appointment were schaeduled. Defendant also canceled the E.N.T

visit at the Childrens Mercy Hospital. Defendant has accused Plaintiff of over

medicating his child and conducting an in home Sleep Study and conducting medical

testing. There is no such evidence t substantiate such claims by Defendant.

Defendant will do what ever it takes to continue to destroy the relationship between

the Plaintiffs and his child Casey Ryan Gipson.

55. Defendant, Dr Julie Cahill failed to inform the court that the minor child Casey

Gipson had been treated with multiple prescriptions of antibiotics in 2005 and 2006

Plaintiff had been taking his child to her and other doctors and shared his concerns

about the on going prescriptions that were being used to treat his child. Casey

Gipson’s medical condition never changed in 2005, 2006 time frame. As of Jan

2009, the severe Sleep Apnea and Upper respritory continues to aile Plaintiffs child.

the minor child Dr Julie Cahill ignored Plaintiffs phone calls at the Emergency room

80
and at her office in Sedalia Missouri as did her other staff doctors who work in her

office. Plaintiff on one occasion brought the minor child in for an ear burn. The

minor child was burnt by a cigarette and the male doctor refused to report this

incident even though the mother, child and case worker and Defendant Beverly

Chapman reported same to Plaintiff. Plaintiffs letter to Dr Cahill dated May 28,

2008 consisting of five pages describes various medical issues back to 2005.

(See Attached Exhibit O.) (A) AND (T)

56. Dr Julie Cahill was fully aware of the Sleep Study that Plaintiff requested for the

minor child in 2007 at the Children Mercy Hospital Dr Cahill knew from prior

medical report that the child had a history of congestion and Sleep Apnea. Dr

cahill

assisted James Johns in court by having her staff present medical records. James

Johns received a bundle of records approximately one inch high. The day before,

Plaintiff received records from the same staff worker that was only 1/8 inch high.

Medical records were with held from Plaintiff. Dr Cahill received a video and

written statements that were delivered to her office by Plaintiff. Plaintiff requested

that all scheduled appointments for the child be recorded and that Plaintiff be

notified. The same video showing the child in distress with sever Sleep Apnea was

also presented to Dr Nicholas at the Childrens Mercy Hospital in Kanmsas CityIn

June 2009 the minor child had an appointment and Plaintiff was never

notified by Dr Cahill or Defendant Brandy Wilkenson.

(SEE ATTACHDMENTS LETTER TO DR CAHILL DATED MAY 28, 2008)

81
57. Defendants from the Benton County Sherriffs Department received from

Pllaintiff a Chain of Custody Letter dated Dec 5, 2008. Prior to this date Plaintiff

had already been arrested by this same Sherrifs Department and again on April 26,

2009 arrested and jailed by the Sherriffs Department. To date the Sherriffs

Department has made no attempt to investigate the Porn Site of Brandy Wilkenson.

Once again the Sherriffs Department has failed to protect the minor child. Plaintiff

Casey Gipsons pictures are also on the Porn Site.

NOTE: SEE ATTACHMENTS CHAIN OF CUSTODY LETTER DATED

DEC 5, 2008 AND PICTURES FROM BRANDY WILKESNONS MYSPACE

PORN SITE DATED 2007, 2008 AND 2009. RON LEVY, MS HARTGRAVE,

MR HARRISON, NANCY PARKS DEB HENDRICKSON AND JUDGE

HENDRICKSON ALSO HAVE COPIES OF PICTURES FROM THE

MYSPACE PORN SITE THAT SHOWS CASEY GIPSON THE MINOR

CHILDS PICTURES. (SEE ALSO EXHIBIT E DATED NOV 25, 2008.)

82
NOTE:

SEE E-MAIL LETERS TO THE FOLLOWING PERSONS REQUESTING A

CONGRESSIONAL HEARING INTO THE UNETHICAL PRACTICES OF

THE MISSOURI CHILDRENS DIVISION AND MISSOURI FAMILY

SERVICES. DATED JANUARY 20, 2009 AND DELIVERED PERSONALLY

TO MISSOURI GOVERNOR JAY NIXON, ATTORNEY GENERAL CHRIS

KOSTER AND THE MISSOURI FAMILY SERVICES IN JEFFERSON CITY

MISSOURI ACROSS THE STREET FROM THE STATE CAPITAL IN

JEFFERSON CITY MISSOURI

1. PRESIDENT OF THE UNITED STATES MR OBAMA


2. MISSOURI GOVERNOR JAY NIXON
3. MISSOURI ATTORNEY GENERAL CHRIS KOSTER
4. DIRECTOR OF MISSOURI FAMILY SERVICES RON LEVY
5. MISSOURI REPRESENTATIVE BRIAN NIEVES
6. MISSOURI SENATOR JANE CUNNINGHAM
7. MISSOURI SENATOR DELBERT SCOTT
8. MISSOURI REPRESENTATIVE TOM SELF
9. MISSOURI CHILDRENS DIVISION MS CELESTA HARTGRAVE
10. MISSOURI CHILDRENS DIVISION BRIAN KINKADE
11. MISSOURI CONGRESSMAN KIT BONDS
12. MISSOURI SENATOR CLAIRE MCCASKILL WASHINGTON DC

83
2009

58. From the birth of the minor child, Brandy Wilkenson has manipulated her evil

ways to bring destruction against the Plaintiffs Robert Gipson and his son Casey

Gipson. NOT: SEE Exhibit# 1, letter by Plaintiff Robert Gipson dated Feb, 15,
2003at 2300 hrs. This was prepared prior to Plaintiff deploying to Iraq.

59. Presently the Plaintiff is now restricted to only five hours a month every other

Saturday and Sunday. This pending court order is destroying the natural bond that

was once enjoyed by Plaintiffs. Once again false accusations against Plaintiff and

excessive court hearings have brought more injustice.

60. Court rulings by judge Micheal Hendrickson have been unfounded and

unsubstantiated. At one point judge Hendrickson ordered that Plaintiff have

Supervised visitation consisting of nine hours every other Saturday and Sunday. The

judge and his Clerk Ms Schultz attempted to gain favor from the Missouri Children’s

Division, Juvinile Division to monitor the supervised visitation. The Division

responded and stated that they do not have jurisdiction and could not assist. After

knowing this, judge Hendrickson then forced a five hour visitation schedule

every other Saturday and Sunday against Plaintiffs. This forced schedule is and has

caused an incredable amount of damage to the family of Plaintiff Robert Gipson.

Plaintiff stated that he will not subject the minor child to such imprisonment and that

is when Ms Schultz contacted her friend at the Warsaw Children’s Division and had

84
a worker there to send a request to the Springfield Department of Children’s ivision.

Plaintiff went to the Warsaw office and requested copy of said letter. To date

Plaintiff has yet to obtain such letter. Ms Schultz stated that the request was made

by her. It appears that the Warsaw Office for the Childrens Division knows nothing

of such request from Defendant Ms Schultz. Ms Cheryl Schultz is

responsible for obstructing justice. Ms Schultz also manipulated the course of

action by the Family Services to monitor a nine hour visitation of the Plaintiffs.

There is no proof to restrict Plaintiff Robert Gipson to any Supervised visitation.

Plaintiff challenges this court to find any evidence that subjects the Plaintiffs to such

cruel and unusual punishment.


As of July 17, 2009, Plaintiffs have had their phone calls restricted by Defendant Brandy Wilkenson.
The following dates consisted with no phone contact. June 26, 27, 28,29 and 30th.

July 1, 6, 8, 9, 10, 11, 15, and 16th.

This type of alienation disrupts Plaintiffs family.

Plaintiff sates that all the information provided is true to the best of his
knowledge. Notice of Service is attached.

Robert Gipson
105 South Center ST
Lincoln Missouri 65338
660-723-4044 cell

85