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IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA

the people of the State of Oklahoma, ex rel Chuck A ,Figueroa, Secured Party Creditor Plaintiff

vs.

Mildred Otey , Reginald Sharp, Cheryl Cherry, Yvonne Fisher ,Pat Martin Wayne Pauley ,Teresa Dreiling Any and all agents, successors, deputies, Officers ,Does, and/or assigns of . Defendants

) ) ) ) Case No._______________ ) ) ) ASSIGNED TO JUDGE _______________ ) ) ) CIVIL COMPLAINT ) ) ) ) ) ) ) ) )

FILE ON DEMAND __________________________________________________________________________ Plaintiff alleges:

1.

Defendants

are

individuals

residing

in

Tulsa

County

Oklahoma.

2. , Chuck Arturo, Figueroa depose and say the following that I Chuck Arturo, Figueroa, herein Affiant became aware of a cause being filed to unlawfully seize his mothers property by Reginald Sharp and Yvonne Fisher that have no jurisdiction to do so, as Affiants mother was kidnapped by Reginald Sharp with assistance of Broken Arrow police and alleged Tulsa County Sheriffs deputy Pat Martin under

arms over Affiant and Affiants mothers objections as Affiants mother tried to fend off the kidnappers violent seizure under arms on or about October 8th 2011. Affiants mother was subsequently hidden where Affiant has not seen nor heard from his kidnapped mother since October 8th 2011 FACTS OF THE CASE 1. Roughly 2 weeks after the second kidnapping, the first one was on or about September 22nd 2011, the parties involved ,Reginald Sharp,Cheryl Cherry, Yvonne Fisher and Teresa Dreiling, closed Wanda Figueroa's bank account stole her funds and are having her social security sent to them under their control without the authority to do so . 2.On or about the first or second week of April, Reginald Sharp with the aid of Yvonne Fisher and parties involved submitted fraudulent documents to Tulsa District court small claims court to steal Affiants and Affiants mothers property, when Affiant became aware of the attempt by viewing the courts website it appeared to affiant that Reginald Sharp with assistance from Yvonne Fisher and alleged Judge Millie Otey are making an unwarranted attack on plaintiffs mothers and plaintiffs property by unlawful administrative process. 3.Affiant noticed alleged judge Millie Otey of affiants Legal Notice of Void Judgment and Ministerial Duty to Vacate Void Judgment and a Motion To vacate Void Judgment filed on or about the first week of April 2011. Affiant exercising his rights to defend property has made demand on alleged judge Millie Otey to vacate the void judgment as shown in exhibit E. As set forth in defendants affidavit attached hereto, (exhibit Z) a hearing was held on April 27th 2011 on Affiants motion to vacate void judgment at which Reginald Sharp failed to prove personal jurisdiction over detainee Wanda Figueroa from inception as challenged by affiant Chuck,A, Figueroa, in fact, Reginald Sharp admitted in his own testimony at hearing held on April 27th 2011 that he never had jurisdiction in the first instance over Wanda Figueroa.

4.Wanda Figueroa was unlawfully seized and subsequently transported to an unknown location. All parties involved in this unlawful action have failed to produce material fact sufficient to prove personal

jurisdiction over detainee Wanda Figueroa from the original inception as required by law and as requested in Affiant motion to vacate void judgment, void ab inition on the face of the record. 5.The Plaintiffs response to Affiants motion to vacate Void judgment fabricated by Yvonne Fisher in it entirety constituted an alleged fraud upon the court in that both the titled response Plaintiffs response to Affiant Motion to Vacate judgment fabricated by Yvonne Fisher by design would omit the key word Void totally changing the entire legality of Affiants motion to the district court, and that plaintiffs response to Affiant motion never once even attempted to show proof of jurisdiction over the party/ies involved in the first instance as challenged by and demanded by Affiant, never submitting documented material fact to prove jurisdiction from inception as challenged and demanded by Affiant, demonstrating the total absence of jurisdiction that renders said judgment void on the face of the record . 6. Affiant has challenged jurisdiction of alleged case from the beginning and was never answered by alleged plaintiff, as if they were and are never required to prove jurisdiction when challenged as they fraudulently attempted to address the hearing as only a motion to vacate judgment, not a motion to vacate Void Judgment.[emphasis added] 7. Millie Otey doing business as an alleged judge, has a clear legal duty to act pursuant to her oath of office, the cannon of ethics in reporting unethical conduct of attorneys that occur in her court and in her presence.. Millie Otey doing business as an alleged judge clearly observed the fraud upon the court in light of Yvonne fisher filing a deceptive fraudulent response Plaintiffs response to motion to vacate judgment allegedly designed to deceptively mitigate Affiants motion of vacate Void judgment to a non-void issue, allegedly in attempt to avoid the requirement to prove jurisdiction in the first instance, allegedly indicating that she is fully aware that alleged plaintiff never established jurisdiction in the first instance and was

attempting to assist alleged plaintiff in continuing to unlawfully move forward in absence of jurisdiction and in violation of the law.[emphasis added] 8. Millie Otey while doing business as an alleged judge, knew or should have known that she had a ministerial duty to comply with the uncontroverted facts of the record and act accordingly thereto as requested in Affiants motion tho vacate void judgment. The motion to vacate as void included precedent case law on standing on jurisdictional void (see memorandum in support/brief overview of law of voids exhibit D). 9. Millie Otey in a criminal fashion decided to unlawfully move forward wholly without jurisdiction perjuring her official oath see Exhibit OA,and causeing great injury and damage to affiant and affiants mother. The vacation of a void judgment that is void on its face as requested of the alleged judge Millie Otey was not a discretionary act in that the judgment is void on its face and requires the ministerial act of vacating the same if requested to by any party affected thereby . 10. On or about April 26th 2011, Affiant was attacked by alleged sheriffs deputies by gunpoint on Affiants property as sheriffs deputies broke down Affiants front door by sheriffs deputies battering ram and drew pistols to Affiants head screaming at Affiant to lay on the ground in Affiants living room in Affiants home screaming at Affiant that Affiant will be shot if Affiant didn't fall and lay on the ground, screaming at Affiant that this is a eviction that the property and house now belong to the DHS and forcefully at gunpoint drove Affiant from his home, off the family property, showing Affiant no warrant, no valid documentary papers or anything. This happened 1 day before Affiants hearing to vacate void judgment as there was a controversy involving said alleged case and alleged judge Millie Otey was duly noticed of void judgment prior to armed invasion. Alleged judge Millie Otey on or about the 18th of April 18th 2011 set an hearing for Affiants motion to vacate void judgment to be heard on the 27th of April 2011. 11. Although Millie Otey doing business as an alleged judge set hearing for Affiants motion to vacate void judgment for April 27th 2011, and there was an apparent controversy to be resolved, Tulsa County Sheriffs

deputies were allegedly instructed to forcefully under arms invade Affiants home and under arms forcefully eject Affiant from his home using deadly force if necessary, which in fact nearly resulted in the death of Affiant. 12. Affiant has challenged jurisdiction from inception and the parties involved have refused to comply with Affiants lawful challenge and demand by refusing to issue/return writ of habeas corpus (on or about Nov 3 rd 2010, exhibit H), refusing to respond to Affiants praecipes (Exhibits, P,Q,J,D), never responding to or refuting Affiants affidavits in support/Criminal Activity Report (Exhibits M, GL,U) , which now stand as fact. 13. The record shows that although Affiant has constantly challenged jurisdiction no evidentiary hearing was ever held requiring the Reginald Sharp to appear to validate the unlawful seizure and restraint of Affiants mother Wanda Figueroa as Affiant has not seen or heard from his kidnapped mother since the second abduction on October 8th 2010, (the first kidnapping that started the unlawful acts of the parties involved was on or about September 22nd 2010) as Affiant fears that Affiants mother is in danger of life and limb as Affiant has evidence that alleged plaintiffs have been forcing dangerous drugs in Affiants mothers body and in fact Affiants mother may be already dead from plaintiffs unlawful actions. 14. Plaintiff Reginald sharp admitted under oath when interrogated by Petitioner at motion to vacate void judgment hearing held on April 27th 2011, that plaintiff never established jurisdiction in the first instance over Wanda Figueroa on the face of the record.[emphasis added] 15. Affiant has a clear legal right and duty to request of the A Millie Otey doing business as alleged judge, to vacate the judgment as void. Millie Otey doing business as alleged judge has a clear legal duty in that both the law and her job required specific performance based on the face of the record. 16. Affiant brought to the attention to Millie Otey doing business as alleged judge, her ministerial duty to vacate the void judgment as it has been proven to be void on the face of the record as Reginald Sharp has failed to prove jurisdiction in the first instance over affiants mother and hence her property and in fact that

Reginald Sharp admitted under oath on his own testimony that he had no jurisdiction from the first instance over Wanda Figueroa and Millie Otey doing business as alleged judge defiantly decided, without authority to do so, to move forward any way unlawfully, totally and wholly without jurisdiction on the face of the record and trespass on the law and against affiant and affiants mother causing great injury and damage against affiant and affiants mother.

1.Title 21, Chpt 30 Section 835 - Concealing a Person to Elude Writ of Habeas Corpus 2.Title 21,Cpt 19 Section 543 - Compounding or Concealing Crime 3. Title 21 Chpt 13 sec 455 preventing witness from giving testimony 4. Title 21 Chpt 30 Section 836 - Assisting in Concealing Person 5. Title 21 Chpt 19 Section 544 - Compounding or Delaying Prosecution 6. Title 21 Chpt 14 Section 462 - Theft, Destruction, etc. of Records by Others 7. Title 21 Chpt 63 Section 1572 - Forgery of Records 8. title 21 sec 1533 Sham legal process 9. Kidnapping 10. fraud 11. Violations of Constitution of State of Oklahoma: Article 2 Section 10, Article 2 Section IIII -2, section 2 6 section 2- 10, section 2- 30, section 2-16, section 2- 12 , too many to list all. REMEDY

WHEREFORE, plaintiff prays:

1. That defendant be ordered to cease and desist the unlawful detention of plaintiffs mother and to

immediately discharge plaintiffs mother, to immediately cease forcing dangerous drugs in plaintiffs mothers body, stealing of plaintiffs and plaintiffs mothers property and the return of plaintiffs and plaintiffs mothers house and for damages (see exhibit G) and punitive damages for the injury/damages as this court deems fair and just 2. Compensatory damages in the amount of $15,000.00 3. Punitive damages in the amount of $870,000.000 4. If summary judgment not awarded, Trial by jury on all issues triable by jury That plaintiff be allowed extensive discovery pursuant to Federal rules of Civil Procedure 26-37. in order to uncover and document the massive fraud in the actions of the defendants. That this court convene a Grand Jury, pursuant to Federal rule of Criminal Procedure 6(a), see United States v. Christian, 660 F.2d 892,900 (3d Cir. 1981), to investigate the Criminal depredations of the defendants named herein. 2. To inquire into the alleged unlawful criminal seizer of plaintiffs mother and to answer for their alleged unlawful actions. For general and special damages resulting from defendant's unlawful fraudulent acts 3. For costs 4. For other relief that the Court considers proper.

Date: June 14th 2011 .

by_______________________________ Chuck A, Figueroa, All Rights Reserved