NOTICE OF CLAIM AGAINST THE STATE OF ARIZONA Claim must be fled in accordance with A.R.S.§12-821.01 Please type or print legibly. Allblanks MUST be completed. CLAIMANT INFORMATION. const re ee a CO Prone ¢ (Hone) Wor Date of Brty_10141988 FACTS, DATE OF OCCURRENCE LOCATIONOF OCCURRENCE | (Use this Section only for ROADWAY CLAIMS) oe. (INCLUDE CITY) ‘ongoing 2022-2923 | Maricopa County Superior Cot DIRECTION OF TRAVEL Southest Division Mesa Arizona _ — TIME OF OCCURRENCE EXTTINILEPOSTISTREET NAME _AMIPM, ~~ INTERSTATE/HIGHWAY LICENSE PLATE NUMBER STATE — — ~ —_ 1 Vin = Identify the circumstances under which the damages or injuries were sustained, the cause thereof and the nature and extent of the damage and/or injuries, List the State agency if known. You may attach additional ages if necessary. Please see attached Amount of Claim $_5.000,000 .. inorder for a claim to be valid, ARS 12-821.01 (A) requires the laimant to include a specific emount for which the claim can be settled. The statute requires the claim be filed with the State of Arizona wit " 8. Cleimant Signature: ate: 11/01/2023 Mail or hand deliver the ORIGINAL to: Office of the Attorney General 2005 N. Central Avenue Phoenix, AZ 85004 NOTE: Include all sypporting documents (Estimates, Bils, Photographs,etc.) Please maintain a copy of the completed Notice of laim and supporting documents for your records. evised10/2020 Website CopyAttachment to Notice of Claim Office of the Attorney General 2005 N. Central Avenue Phoenix, AZ 85004 Charlene Jackson & Paul Etnire 18857 E Swan Dr Queen Creek, AZ 85142 RE: Notice of Claim Pursuant to ARS 12-821.01. Charlene Denise Jackson — Maricopa County Superior Court Judge. ‘This Notice of Claim is regarding State Employee Charlene D Jackson who is a Maricopa County Superior Court Judge. | am ready to file a Complaint in District Court against Judge Charlene Jackson, suing her in both her official and individual capacity. I will be requesting a Jury Trial. This letter is meant to put you on notice of the claim and provide you with a reasonable opportunity to investigate and resolve the claim. This notice of claim does not include every theory of liability, possible fact, argument, or citation to case law and relevant statutes. I reserve the right to include and assert additional facts, theories, arguments, citations, etc. as this matter proceeds. I reserve the right to amend, supplement, correct, clarify, etc. this Notice of Claim, as necessary. I reserve the right to add or supplement potentially responsible or liable employees or agents of the State of Arizona as Defendants, Judge Jackson is accused of interference with the parent / child relationship, deprivation of victims’ rights, deprivation of rights under the color of law, deprivation of State Protected Constitutional Rights, deprivation of Federally Protected Constitutional Rights, deprivation of Statutory Rights, deprivation of Civil Rights, denial of Equal Protection, Failure to Protect, Abuse of Process, discrimination, retaliation, endangerment, Intentional Infliction of Emotional Distress, conspiracy to commit Interstate Domestic Violence, and more. TITLE 18, U.S.C., SECTION 242 Section 42, Title 18 makes it a crime for a person acting under color of any law to deprive a person of a right or privilege protected by the Constitution or laws of the United States. Whoever, under color of any law, statute, ordinance, regulation, or custom, willfully subjects any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, ... shall be fined under this title or imprisoned not more than one year, or both... TITLE 18, U.S.C., SECTION 241 This statute makes it unlawful for two or more persons to conspire to injure, oppress, threaten, or intimidate any person of any state, territory or district in the free exercise orenjoyment of any right or privilege secured to him/her by the Constitution or the laws of the United States, (or because of his/her having exercised the same). It further makes it unlawful for two or more persons to go in disguise on the highway or on the premises of another with the intent to prevent or hinder his/her free exercise or enjoyment of any rights so secured. Punishment varies from a fine or imprisonment of up to ten years, or both; and if death results, or if such acts include kidnapping or an attempt to kidnap, ageravated sexual abuse or an attempt to commit aggravated sexual abuse, or an attempt to Kill, shall be fined under this title or imprisoned for any term of years, or for life, or may be sentenced to death. Judge Charlene Jackson has repeatedly violated and is actively depriving me and my 5- year-old child of our State and Federally protected Constitutional Rights. Judge Jackson ‘committed misconduct that interferes with her Judicial duties while acting outside the scope of judicial functions. Judge Jackson violated numerous subsections of the Arizona Code of Judicial Conduct, calling her judicial integrity into question. Judge Charlene Jackson’s pattern of misconduct has gone beyond a potential abuse of discretion and equates to criminal conduct. Under our Constitution, judges serve as arbitrators of justice. When Judges violate the rights we entrust them with defending, while breaking the laws we expect them to uphold, they undermine the legitimacy of the judicial system. Judge Jacksons actions continue to traumatize me and my 5-year-old child, causing us severe emotional distress. Judge Jacksons conduct was and continues to be extreme: and outrageous. Judge Jacksons conduct was committed with certainty that such distress would result. Her conduct is so outrageous, it is regarded as utterly intolerable in a civilized! community. Judge Jackson should not be presiding over cases where children’s “best-intaresgs” ar “safety” are a factor in her decision making, Judge Jackson has never considered my childs best interests. Judge Jackson habitually considers her biased, prejudiced, personal interests. This is well demonstrated in Judge Jacksons pattern of misconduct affecting her entire docket, regrettably this is not an isolated incident of Judge Jackson’s misconduct. Judge Jackson is issuing illegal, unconstitutional, biased orders across her docket. There is an entire group of Family Law attorneys who refuse to accept cases that Judge Jackson is assigned to because it’s that obvious that Judge Jackson doesn’t issue her orders based on the law but based on personal reasons. Judge Jackson repeatedly fails to disclose her personal relationships with attorneys or parties to cases, Judge Jackson has her own family members’ case assigned to her docket. The State of Arizona is allowing the Judicial misconduct to continue knowing this Judge is intentionally harming the citizens of Arizona. Judge Jackson repeatedly fails to follow Maricopa County Superior Court Procedures and Arizona Rules of Family Law Procedures. Judge Jackson repeatedly and intentionally fails to make findings on the record, even when the applicable statute expressly says she “shall” do so. Judge Jackson issued orders in a case when she never properly obtained jurisdiction, then refused to vacate those VOID orders. Instead of fixing her past errors, Judge Jackson retaliatedand issued enforcement of the VOID orders. Judge Jackson cannot legally enforce Court Orders that were VOID to begin with nor can she continue issuing orders absent jurisdiction. Judge Jackson removed an innocent child from an Order of Protection that was issued in another competent Jurisdiction without any due process. Judge Jackson then repeatedly refused to protect the child who is a documented victim of abuse. Judge Jackson fails to comply with the requirements of the UCCJEA which is a State and Federal requirement. Judge Jackson fails to comply with the requirements of A.R.S. 25-403 and more specifically A-R.S, 25-403.03. As a family Court Judge those are the statutes Judge Jackson should be basing most of her decisions from. Judge Jackson deprived me and my daughter of due process on multiple occasions. Judge Jackson has deprived me and my daughter of Equal Protection. Judge Jackson has violated multiple Rules of the Judicial Code of Conduct including but not limited to: Canon 1, Rule 1.1 Compliance with the Law. Canon 1, Rule 1.2 Promoting Confidence in the Judiciary. Canon 2, Rule 2.2 Impartiality and Faimess. Canon 2, Rule 2.3 Bias, Prejudice, and Harassment. Canon 2, Rule 2.4 External Influences on Judicial Conduct. Canon 2, Rule 2.5 Competence, Diligence, and Cooperation. Canon 2, Rule 2.6 Ensuring the Right to Be heard. Canon 2, Rule 2.11 Disqualification. Canons 2, Rule 2.15 Responding to Judicial and Lawyer Misconduct. Yadge Jackson allowed an attomey and a party she favored to commit extensive perjury and Freud Upon the Court, even presenting misrepresentations and false statements on an application — affidavit for a warrant, which is not only against the Arizona Rules of Civil Procedure, the Arizona Rules of Professional Conduct, and the Arizona Code of Judicial Conduct, but is also a criminal offense. When Judge Jackson was made aware and provided substantial evidence of the Fraud Upon the Court and significant perjury, Judge Jackson refused to vacate the orders obtained by Fraud which Judge Jackson is obligated to do under Arizona Law. Judge Jackson knowingly and intentionally placed me and my child in danger with our abuser, a State Created Danger that Judge Jackson herself created. Judge Jackson has ruined our lives. Me and my daughter live in hiding from our abuser as Judge Jackson supports our abuser in his relentless conduct of stalking, harassing, intimidating,