IN USA DISTRICT COURT
Case No.

Clifford “RAY” Hackett

Plantiff,
vs.
(Exhibit A) Defendants

COMPLAINT

COMES NOW the plaintiff, Clifford “RAY” Hackett, pro se, and files this complaint against the defendants as follows:

Defendants

Defendant, Jacqueline Hackett is the estranged spouse of the plaintiff, Clifford “RAY” Hackett, with primary place of residence at:Hilton Hotel Durango 501 Camino Del Rio, Durango, Colorado, 81301. Defendant, Jacqueline Hackett, may be served summons at her primary place of residence: Hilton Hotel Durango 501 Camino Del Rio, Durango, Colorado, 81301. Defendant, Jacqueline Hackett is herein after referred to as “Jacqueline Hackett” or “Mrs. Hackett.”

FACTS PERTAINING TO THE PARTIES

Plaintiff, Clifford “RAY” Hackett, is a United States Citizen and resides in Homeless shelters. Plaintiff, Clifford “RAY” Hackett, is a blind and deaf man, is retired, and is the estranged spouse of defendant, Jacqueline Hackett.

Clifford and Jacqueline Hackett are the parents of four children: Hazel, Faye, Norman, and 2 killed by abortion. They were married on may 2, 2002 But marriage was made fake by defendant without plaintiff’s knowledge.

Jacqueline Hackett has kept all of the books and records.

Jacqueline Hackett a resident of colorado, filed for divorce from Clifford "RAY" Hackett in the District Court of San Juan County, New Mexico , in 2010.

Jacqueline Hackett filed for divorce from Clifford "RAY" Hackett in the District Court of San Juan County, New Mexico, in May, 2010 (Case No. 01 DM 59). Clifford "RAY" Hackett was not served with divorce papers until January, 2010 by a US marshal breaking into his apartment.

Zane Swank represented Mrs. Hackett in the filing of her divorce, but withdrew when plaintiff proved defendant was a colorado resident..

Attorney letigra is a second lawyer hired by Mrs. Hackett , but withdrew whn plaintiff proved defendant was a colorado resident.

Gina Reyes is a child support worker in Durango, 1060 E. 2 nd Ave Durango, CO 81301. .

FACTS PERTAINING TO THE CASE

On or about May 14, 2010, Jacqueline . Hackett filed for divorce from her husband, Clifford "RAY" Hackett She had been (stated to plaintiff) having an affair with Judge John A. Dean.

On this same date, prior to Mr. Hackett being served with divorce papers, Judge Dean ordered that Jacqueline Hackettbe given complete custody of the kids. This occurred the same day her divorce was filed in San Juan County District Court.

Plaintiff was not served with the summons for his divorce until January 16, 2002 when a Marshall broke into his house.

This represents a violation of Supreme Court Rule 1.9 of New Mexico Rules of Professional Conduct for attorneys.

Approximately 99% of the motions filed byClifford "RAY" Hackett were denied or ignored by San Juan County Court since January 16, 2002, when he was served.

Defendant had an affair with Judge Dean, throughout much of the divorce proceedings. Plaintiff has recordings of her admitting it.

Clifford "RAY" Hackettwas severely distraught over the intentional acts of the attorneys and judges in his divorce proceedings. His family had split up and he was blocked from his children for years. The defendants couldn’t have cared less.

Mr. Hackett called the Association for Honest Attorneys for assistance in May, 2006. He was to the point that he felt his life would be better if it ended. The mental anguish and emotional distress of his divorce dragging out for years had taken its toll on his health, and he felt he was dying a slow death.

As a result of the unethical and illegal practices of the defendants in this matter, plaintiff was subjected to such severe emotional distress that no person should have to endure.

The initial filing of the divorce by defendant is invalid due to the lack of service on Plaintiff until January, 2002. Other errors exist in court paperwork.

Plaintiff is justified in his claims involving tort of outrage and outrageous government conduct in this matter. Due to such outrageous government conduct, Plaintifft has been unable to obtain effective assistance of counsel to date and must proceed pro se in this matter.

All of the defendants violated Clifford "RAY" Hackett’s rights under the 5th Amendment by prolonging his legal matter without good cause and with the objective of depleting his assets for their own use. Therefore, the doctrine of special circumstances applies with regard to plaiontiff’s lack of legal representation and his necessity to proceed pro se.

Plaintiff has demanded that defendants take action to make plaintiff whole for his losses. Defendants have refused plaintiff’s demands.

PRELIMINARY STATEMENT

Defendants violated numerous national laws, statutes, ordinances and regulations, including but not limited to: due process, right not to be deprived of property under the 5th amendment (as incorporated to the states through the 14th amendment) and plaintiff’s right to be heard which was denied due to the influence of the court. The overt acts of fraud and collusion in this matter which were engaged in by the defendants to deprive plaintiff of his assets include, but are not limited to: ordering plaintiff to pay child support without a proper basis for doing so. Violations also exist concerning Supreme Court Rule 227, and Mr. Hackett should be reimbursed by the Lawyers’ Fund for Client Protection (LFCP) for the dishonest conduct of the lawyers and judges in this matter.

This case warrants claims involving tort of outrage, bad faith, outrageous government conduct and manifest injustice. The defendant’s acts and failures to act are criminal in nature as they are indicative of legalized stealing from the plaintiff, and depict “the dagger of an assassin” in actions toward him. Accordingly, plaintiff is justified in alleging each of the following claims against the defendant.

CAUSES OF ACTION

Violations of Plaintiffs’ 5th Amendment Rights
(as incorporated to the States through the 14th Amendment)

The conduct of the defendants in depriving plaintifft of his property (income and assets) without due process of law constitutes a violation of plaintiff’s rights under the 5th Amendment to the United States Constitution, as incorporated to the States through the 14th Amendment.

The defendant owed Clifford “RAY” Hackett a duty under the 5th and 14th Amendments not to violate his rights under the United States Constitution as a citizen of the United States. The defendant’s overt acts of fraud denied him due process of law.
Plaintiff relied in good faith that the attorneys, judges and other court officials would act legally and ethically in resolving his child support.

The illegal and unethical conduct of the defendants constitutes denial of plaintiff’s due process rights under the 5th and 14th Amendments to the United States Constitution.

The defendants breached the duty owed plaintiff and willfully deprived him of his property and his right to be heard.

As a result of the defendants’ conduct to deprive Clifford “RAY” Hackett of his due process rights, plaintiff has suffered damages in excess of $75,000.00.

WHEREFORE, plaintiff respectfully requests judgments of the court against all of the defendants awarding to plaintiff (i) damages in excess of $75,000.00; (ii) pre- and post-judgment interest; (iv) costs, including reasonable attorney fees for this action; and (v) any other relief deemed just and equitable by the court.

Civil Conspiracy and/or Collusion
Plaintiff incorporates by reference Exhibit A of this Petition.

WHEREFORE, plaintiff respectfully requests judgments of the court against the above named defendants awarding to plaintiff (i) damages in excess of $75,000.00 for each defendant; (ii) pre- and post-judgment interest; (iii) costs, including reasonable attorney fees, for this action; and (iv) any other relief deemed just and equitable by the court.

Fraud and Misrepresentatoin
Plaintiff incorporates by reference Exhibit A of this Petition.

WHEREFORE, plaintiff respectfully requests judgments of the court against the above named defendants awarding to plaintiff (i) damages in excess of $75,000.00 for each defendant; (ii) pre- and post-judgment interest; (iii) costs, including reasonable attorney fees, for this action; and (iv) any other relief deemed just and equitable by the court.

Intentional Infliction of Emotional Distress
Plaintiff incorporates by reference Exhibit A of this Petition.

WHEREFORE, plaintiff respectfully requests judgments of the court against all of the defendants awarding to plaintiff (i) damages in excess of $75,000.00 for each defendant; (ii) pre- and post-judgment interest; (iii) costs, including reasonable attorney fees, for this action; (iv) injunctive relief enjoining all defendants from continuing the intentional infliction of emotional distress; and (v) any other relief deemed just and equitable by the court.

DEMAND FOR JURY TRIAL
Plaintiff respectfully requests that the issues in this matter be heard by a jury.

DESIGNATION OF TRIAL
Plaintiff designates Hawaii as the location for the trial in this matter.

Respectfully submitted,

Clifford “RAY” Hackett
440 Kapiolani, Hilo, hawaii, 96720, Phone: (808)365-9745

By________________________________
Clifford “RAY” Hackett, pro se