IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI

CENTRAL DIVISION

ROBERT GIPSON, )
Individually )
) Case No, 09-4136-CV-C-NKL
AND )
)
ROBERT GIPSON )
As Next of Friend )
Casey Gipson, a minor child )
)
Plaintiffs, )
)
vs. )
Defendants,

Governor Jay Nixon, et al

FIRST MOTION TO AMEND T.R.O

AND

EMERGENCY HEARING

COMES NOW, Robert Gipson, pro se, and for his cause of action to amend his TRO

filed on July 20, 2009 and to clarify his request for such cause. Part one and part two of

complaint and all exhibits are the foundation for his motion. Part one consist of thirty four

pages and part two consist of eighty five pages. Plaintiff therefore states the following.

1. Plaintiff filed his complaint on Friday July 18, 2009.

2. On Monday, July 20, Plaintiff filed his first motion for a T.R.O.
3. Plaintiff observed the minor child with a broken arm on Saturday July 19.
4. On Tuesday, July 21, Plaintiff was informed that a phone conference hearing was
scheduled in seven days by Honorable Judge Nanette Laughrey.
5. Plaintiff began sending out e-mails to Defendants advising them of the same.

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6. Plaintiff is slightly restricted. He does not have access to the E.C.F. and is attempting to
notify the parties in a timely manner.
7. Plaintiff is asking that a Temporary Restraining Order be placed against the case workers
And supervisors assigned to the Missouri Children’s Services. As indicated in part one
and part two of Plaintiffs complaint, case workers and supervisors conducted themselves
in such a manner that brought harm to the Plaintiffs.

8. Defendants, James Johns, Brandy Wilkenson and Jason Warren have conspired to violate
the Plaintiffs civil and constitutional rights to have a father and son relationship.

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 COMPLAINT

PART #1

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

Casey Ryan Gipson’s picture from a Porn sex site on MYSPACE. Brandy Wilkenson, mother of

Casey Gipson exploits sex on the MYSPACE web site. Pictures, video, and advertisement as a

sex coach are her marketing profile. This brings discredit to the minor child when his picture is

also on this web site. Defendants have had ample opportunity to investigate the pictures and

video of the Porn site on Brandy Wilkenson’s MYSPACE web site. This is a Porn site and the

minor child’s picture is posted for view by visiting customers. Robert Gipson presented evidence

to the Missouri Children’s Division, Benton County Sheriff’s Department and Honorable Judge

Michael Hendrickson. Defendants have protected Brandy Wilkenson and her husband Jason

Warren at the expense of the minor child. It is a Federal Violation to have pictures of children

on a MYSPACE Porn site. The owners and operators of MYSPACE have failed to monitor their

Web site and have jeopardized the health and welfare of the minor child Casey Ryan Gipson.

Retaliation by the Benton County Sheriffs Department resulted in harassment by means of arrest

and civil rights violations against Robert Gipson. During the last court hearing Judge Michael

Hendrickson refused to remove the minor child’s picture from the MYSPACE PORN WEB

SITE. The GAL MR Lutman was also aware of this web site and did nothing. Mr. Lutman is

presently the GAL for the minor child. Mr. Lumens’ failure to protect the minor child is cause

for dismissal. The Plaintiff was subjected to excessive harassment during the June 2009 court

hearing. Plaintiff was held by force and threat of physical and mental abuse by Judge

Hendrickson and the court Baliffs. The first court hearing consisted of five Baliffs, two

Prosecuting Attorneys and one person from the Missouri crime victim’s office who worked with

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Karen Woodley the Benton County Prosecutor. This was nothing more than an imminent threat

against Plaintiff Robert Gipson. This threat infringed upon the integrity of the case and created a

very hostile court environment. This threat by court officials against the Plaintiff Robert Gipson

violated his civil rights to a fair trial and violated the Plaintiffs fourteenth amendment. This act

of aggression against Plaintiff interrupted the normal course of justice. To this date July 15,

2009, Plaintiff continues to be oppressed by community corruption. Plaintiff will never get a

fair trial in the Benton County Missouri court house, nor in the Western court of appeals. The

attached documents also indicate a child and father who have endured excessive physical and

mental abuse. This abuse has been covered up by the Missouri Children’s Division, case

workers and supervisors. Mandated reporter, Psychologist and Defendant, Ms Erika Waller

failed to report that the child Casey Gipson was beat in the face and eye by his mother Brandy

Wilkenson. Psychiatrist and Defendant Dr Daniels from Columbia Missouri supervised Dr

Waller. Both failed to report this abuse against the minor child. Both were presented with many

documents describing prior neglect and abuse against the minor child. Part one and part two of

Plaintiffs law suit identifies a consolidation of reports, pictures, video and CD to substantiate

Plaintiffs accusations against the Defendants. The first course of action requested by Plaintiffs

is to remove the minor child’s picture from the MYSAPCE porn site created and managed by

Defendant Brandy Wilkenson and her husband Defendant Jason Warren. The Defendants listed

in part one and part two of this law suit subjected the minor child to a life of hardship by

ignoring obvious signs of neglect and abuse against the child. Defendants, in their official and

individual capacity to protect the minor child from harm as directed by the United States

Constitution, violated their oath of office. Defendants Brandy Wilkenson and Jason Warren

have conducted criminal activities against the minor child and Plaintiff Robert Gipson as stated

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in part one and part two of this claim. Part one and part two of said claim relates to various

Defendants who have violated the civil rights of Plaintiffs. Part one and part two has attached

supplemental evidence to support said claim. Attached are photos, video, CD, medical

documents, witness statements,and legal documents. Part one and part two describes the actions

of each Defendant, relief sought for by Plaintiffs, supplemental evidence, and facts common to

all counts.

PARTIES

The Plaintiff, Robert Gipson is a resident of Benton County, State of Missouri and

is the natural father of Casey Ryan Gipson.

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.

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 T.R.O. REQUESTED AGAINST THE FOLLOWING DEFENDANTS

See: number 10 thru 27 in part one of complaint on pages 5 thru 15

9. Defendant William Haefer,

10. Defendant William Haefer

12. Defendant Ron Levy,

13. Defendants Jim Harrison, Steve Morrow, Nancy Parks, Ms Hendrickson, Paula

Neese, Ms Hartgrave, Ron Levy

14. Defendant Steve Morrow

16. Defendant, Jim Harrison

17. Defendant, Celesta Sue Hartgrave,

18. Defendant Steve Morrow, 1

19. Defendant, Bryan Kincaid,

20. Defendant, William Haefer,

21. Defendant, James Johns,

22. Defendant, Brandy Wilkenson,

23. Defendant, Jason Warren

24. Defendant, Honorable Judge,Michael Hendrickson

25. OWNER AND OPERATORS

MYSPACE WEB SITE

26. ADMINISTRATORS
MYSPACE WEB SITE
Defendants, of MYSPACE have allowed Brandy Wilkenson to freely exploit sex on the internet.

The owner and operators of this agency has violated the civil rights of the minor child Casey

Gipson. They allowed pictures of minor children to be on the same web page where sex acts and

exploiting sex were conducted and revealed

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27. MR LUTMAN
GAL FOR MINOR CHILD

Defendant, Mr Lutman failed to properly represent the minor child.

28.. At all times relevant herein, Defendants listed above and below violated agency policies,

and regulations. They failed to properly investigate and interview parties of interest and ignored

Plaintiffs pleas to help the minor child Casey Ryan Gipson. These policies, decisions officially

adopted or promulgated by the State of Missouri were Maliciously ignored. which acts may

fairly be said to represent official policy or were pursuant to the governmental custom of the

State of Missouri.

29. At all times relevant herein, Defendants have acted under the color of authority of

the law of the State of Missouri.

FACTS COMMON TO ALL COUNTS

See: number 30 thru 36 in part one of complaint on pages 16, 17 and 18

Count I – Denial of Substantive Due Process

See: number 37 thru 41 in part one of complaint on page 18 and 19

WHEREFORE, Plaintiffs pray judgment against Defendants and issue a TRO against

the defendants listed above.

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 Count II - 42 U.S.C. §1983 CONSPIRACY

See items 42 thru 47 as listed in Part #1 of complaint on pages 19 and 20.

WHEREFORE, Plaintiffs pray judgment against Defendants; for Plaintiffs’ costs of this

action, including reasonable attorney fees; and such other relief as may be granted by the Court.

Count III – Missouri State Law Claim - Torturous Interference

See items 48 thru 58 of Part one in complaint on pages 20 and 21.

58 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. It was and continues to be the actions of said Defendants

that forced the Plaintiffs to take action and seek relief in this court.

WHEREFORE, Defendants listed as individuals and those acting under the color of law should

be sanctioned and fined accordingly as required by law. Temporary Restraining Orders should

be granted to protect Plaintiffs from any chance of further harm to them physically or mentally.

Plaintiff has exhausted his resources in the circuit court and the appellate court. Plaintiff Robert

Gipson has been bullied long enough. Plaintiff Robert Gipson states that the mental anguish

caused by the Defendants and government agencies has caused PTSD. Plaintiff, Robert Gipson

has endured seven years of an all out assault against his family. This has and could forever

devastate his future life. Plaintiffs Bank account has been garnished. Funds that were exempt

from garnishment were frauduantley obtained by James Johns, Brandy Wilkenson’s lawyer.

The second garnishment was executed without a court order. Bank of America allowed this

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transaction. Plaintiff was injured in Iraq. His Social Security Disability check was re routed to

Brandy Wilkenson without Plaintiffs knowledge. Brandy Wilkenosn with the help from Mr.

Brown and staff workers from the Sedalia Missouri Social Security Office conspired to make

Brandy Wilkenson the payee of Plaintiffs Disability check. Plaintiff was injured in Iraq and

receives money for his injuries. Brandy Wilkenson and her lawyer James Johns have conspired

to bring false accusations against Plaintiff in order to obtain Plaintiffs money that was once used

to support his child. Prior to such garnishment, Plaintiff provided financial support for the minor

child in excess of the money now being paid out. Garnishment was just another reason for

Brandy Wilkenson to file false accusations against Plaintiff and file to modify the previous court

orders. The garnishment of the Plaintiff’s SSI, and savings account was nothing short of a

criminal act. Plaintiff asks relief in the following.

1. This Federal law suit is the direct result of the Defendants Malicious attacks.

2. Plaintiffs have suffered and have endured excessive mental anguish as a result of the

actions and non actions of Defendants.

3. Plaintiff Robert Gipson, father of Casey Ryan Gipson has gone through extensive mental

therapy as a direct result of Defendants failure to protect the minor child from neglect and

abuse.

4. The Department of Veterans Affairs Psychologist and Civilian Psychologists have

documented testimony from Plaintiff Robert Gipson on the abuse and neglect against the

minor child Casey Ryan Gipson and the civil rights violations against both Plaintiffs.

5. The Defendants and Government agencies listed have violated their oath of office.

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 SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS

BEGINNING WITH LETTER A THRU Z

See A thru Z in part one of complaint on pages 25 thru 27 of complaint

SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS

MYSPACE PORN SITE WITH PICTURES OF THE MINOR CHILD

CASEY RYAN GIPSON AGE SIX

See: Page 28 in complaint

. MYSPACE PORN SITE of Brandy Wilkenson dated August 15, 2008 as Exhibit #1 presented

by Robert Gipson and witness dated on Feb 14, 2009. Presented as evidence on June 2009 in a

hearing held in Benton County Missouri with Honorable Judge Michael Hendrickson presiding.

Consisting of twelve pages.

. MYSPACE PORN SITE, Exhibit #2, dated 2008. Eleven pages starting with Page 2 of 5 and

last page 8 of 8.

MYSPACE Calendar of Brandy Wilkenson dated Aug 22. 2008

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 MYSPACE PICTURES

EXHIBT #1, 2 AND 3

See: A thru J in part one of complaint on pages 28 and 29

MYSPACE EXHIBIT

#2

See: page 30 in part one of complaint.

A. Dated Aug 15, 2008, shows the flow of traffic coming to the web site and Brandy

Wilkinson’s communication with her clients to market her business.

B. Exhibit consists of eleven pages.

MYSPACE EXHIBIT

#3

See: page 30 in part one of complaint

Exhibit #3 shows the schedule of Brandy Wilkinson’s nightly activities when she was a sex

coach and exploiting sex. These schedules and the reckless life of Brandy Wilkenson subjected

the minor child to a high risk environment. The minor child was left with Jason Warren during

these late night parties and in one incident the minor child was locked outside his house and

burned his hand on a stick from a fire with Jason Warren present. The minor child informed

Plaintiff that his ears were cold and there were no keys to get into the house and his mommy was

gone. . Plaintiff has been alienated from his child and can no longer protect his child from

neglect and abuse.

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 PICTURES OF CASEY RYAN GIPSON WHICH DISPLAY ABNORMAL AND

EXCESSIVE INJURIES OF NEGLECT AND ABUSE

See: number 15 thru 21 in part one of complaint on pages 31 and 32

STATEMENTS FROM PLAINTIFF ROBERT GIPSON

See number 18 thru 23 in part one of complaint on page 33

MOTION FOR TRO CONTINUED WITH PART TWO OF PLAINTIFFS COMPLAINT

Part two of Plaintiffs complaint consists of eighty four pages.

1. Plaintiff request that a T.R.O. be issued to the Defendants listed below.

2. That every doctor listed be prevented from treating Casey Gipson
3. That every school teacher from the minor child’s pre-school and kinder garden be issued
a T.R.O.
4. That Ms Peterson be issues a TRO
5. That every police officer listed be issued a TRO
6. That the Bank of America be issued a TRO and reframe from allowing identity fraud
7. That Bank of America be issued a P.R.O. Permanent Restraining Order from allowing
James Johns or any other person or agency from garnishing exempt funds
8. That every Psychologist listed as Defendant be issued a TRO and have no contact with
Plaintiffs unless in a court hearing.
9. That Jason Warren be issued a TRO and be prevented from any contact with the minor
child unless in the presence of another adult.
10. That Jason Warren not be allowed to drive a car with Casey Gipson as a passenger
11. That Jason Warren not be within one mile from Plaintiffs during any visitation changes.

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12. That Jason Warren not be left alone with Casey Gipson for any reason.
13. That no one at any time smoke in the presence of the minor child if in doors or in a car.
14. That no police officer listed as Defendants come within one mile of Plaintiffs
15. That Judge Hendrickson be issued a TRO and be prevented from ruling on any court
issues that involve Plaintiffs
16. That all rulings made by Judge Hendrickson be TRO and the 2005 custody order be
restored.
17. That all Defendants listed be issued a TRO and have no contact with Plaintiffs unless in a
court setting
18. That a new Pediatrician be assigned for the minor child
19. That the GAL Mr Lutman recues himself from his duties
20. That CASA Court Appointed Special Advocate be appointed for the minor child
21. That Ms Peterson be issued a TRO and not be in the presence of the minor child
22. That James Johns, attorney for Defendant Brandy Wilkenson, TRO and recues himself
from any contact with Plaintiffs and reframe from any communication with Brandy
Wilkenson about the minor child or Plaintiff Robert Gipson.
23. That Sheryl Schultz be issued a TRO and make no entries on any of the Plaintiffs court
files.

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 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 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

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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. 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

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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 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

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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 sense

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 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 without 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

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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 without 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 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.

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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 against Plaintiffs may be irreversible and may cause a

lasting effect of mental disorders upon Plaintiffs’.

DEFENDANTS

13. Defendant, Mark Breshears,.

14. Defendant, Honorable Judge Larry Burdett,

15. Defendant, Honorable Judge Mark Pilley

16. Defendant, Karen Woodley,

17. Defendant Cheryl Schultz

Defendants, Carlisle Walker,

Officer Rick Fajen

Mickey Mittlestadt, Chief Kinkinnon,

Deputy Haun

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Chief Kinkinnon

19. Defendant, Sheriff Officer Rick Fajen

20. Defendant, Mickey Mittlestadt,

.Defendant, Officer Haun Defendant, Honarable Judge,Michael Hendrickson

Defendants, Missouri Crime Victims Office,

CRIME VICTIMS ADVOCATE

Defendant, Ron Levy,

Defendant, Debra Scott,

Defendants Jim Harrison, Steve Morrow, Nancy Parks, and Ms Hendrickson

Defendant, Celesta Sue Hartgrave,

Defendant, Dawn Long,

Defendant, Beverly Chapman,

Defendant, Paula Woolery,

Defendant Alice Sharon Zidlicky,

Defendant Steve Morrow,

Defendant, Mr. Brown,

Defendant, Sherriff Deputy officer Haun,

Defendant, William Haefer,

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

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Defendant, Dr. Tim Vuagniaux, court appointed psychologist.

Defendant, DR. Erika Waller, psychologist for child and father.

Defendant, DR. Salenger, psychologist for child.

Defendant, Dr. Julie Cahill, physician for child.

Bank of America,

Defendant, Ms. Peterson, School Principal for minor child.

Defendant, MS,
Defendant, MS, Wooleby, Pre-school teacher for minor child,

Defendant, MS, kinder garden teacher for minor child,

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 FACTS COMMON TO ALL COUNTS

See: number 14 thru 20 on part two of complaint.

Count I – Denial of Substantive Due Process

See: Number 21 thru 25 of complaint

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.

Count II - 42 U.S.C. §1983 CONSPIRACY

See number 26 thru 34 of complaint.

. 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 Quash all Summery judgments against this suit by

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any and all Defendants.

Count III – Missouri State Law Claim - Tortuous Interference

See: number 35 thru 46 in part two of complaint.

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.

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 COMPLAINT CONTINUED

SIGNIFICANT EVENTS AND TIME FRAMES

FROM

MAY 26, 2002 – July 9, 2009

See: number 1 thru 29 in part two of complaint. Pages 66 thru 70.

2003

See: number 30 thru 32 in part two of complaint. Pages 71 and 72

2004

See: number 33 thru 43 in part two of complaint. Pages 73 and 74

2005

See: number 43 thru 44 in part two of complaint. Pages 75 and 76

2006

See: number 45 thru 48 in part two of complaint. Pages 77

2007
See: number 49 thru 52 in part two of complaint. Pages 78 and 79

2008
See: number 54 thru 57 in part two of complaint. Pages 81 thru 83
2009

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See: number 58 thru 60 in part two of complaint. Page 84 and 85

Plaintiff states that all the information provided is true to the best of his knowledge. Notice
of Service is attached. This motion will be e-mailed, hand delivered and sent by U.S.
certified mail to Defendants listed in this motion.

Robert Gipson
105 South Center ST
Lincoln Missouri 65338
660-723-4044 cell

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