LOUISIANA CIVIL CASE REPORTING . PART A Civil Case Cover Sheet - LA. RS, 13:4688 and Part G, §13, Louisiana Supreme Court Geaecal Adeuiisteative Rates ‘This evil ease cover shee shall be completed by councel forthe patitioner, counsel's autborized ‘epeseatative, or by the pro se liigan (i nt cepresented by counsel and submitted with he oxiginal petition filed with the court. The information shouldbe the best available atthe time of fing, ‘This ‘aformation does aot constitute a discovery request, response or supplementation, and isnot admissible atta, sanctus Z6igtley R; fa Dow KD =e 2FE a rue. sou Comep Hal cme uth Qidaad Oe E179 Parish of Faing:| Name of Lead Petitioner's Attorney Name of Pro Se Litigaat: Number of named petitioners: Number of mained defendants: ‘Type of Lawsuit: Please check the categories which most appropriately apply to this suit (0 more than 3 categories shauld be checked): Auto: Personal Injury Auto: Property Damage Auto: Wrongful Death Tuto: Uninsured Motorist Ben Asbestos: Property Damage T Aabestos: Pesonalfqjury/Death “Product Liability = Premise Liabitity a Intentional Bodily lajury ___Inteational Property Damage 2 t —_lateational Wrongful Death. — Unfair Business Practice 7 Business Tort Trad Defamation —Protessional Negligence Bavironmental Tort Metical Malpractice T Ieullctual Property “Toxie Tort Tegal Malpractice Othe Tort (describe below) Totter Professional Malpcactice Redhibiion TT Macitime Ops ati Wrong Death tale Tad dt pits —Geneeal Negligence vinlitinn @ Cokthite bined Zeg hts Please briefly describe the aatare ofthe litigation ia one sentence of additional detail: folowing te competion oth my cone, ous pcm, bythe is dcp wil be simited oe Ofc tel Adin Sees Ssip¢ Louisa, by the Ce of Cou. Gi as Ba Slop Phone aunber: 21K * 36 ¢ SS ermaitaticss: Ce hank( @ Aol. amoc STATE OF LOUISIANA PARISH OF OUACHITA FOURTH DISTRICT COURT STANLEY R. PALOWSKY, Ill, Individually, FILED [Ss and on behalf of ALTERNATIVE ENVIRONMENTAL SOLUTIONS, INC. versus no. 15-2179 ALLYSON CAMPBELL DY. CLERK OF COURT PETITION FOR DAMAGES: NOW INTO COURT, through undersigned counsel, comes Plaintiff, Stanley R. Palowsky, Il, who appears herein individually and as a 50-percent shareholder and director of ‘Alternative Environmental Solutions, Inc. (“AESI”), a Louisiana corporation, and who respectfully represents as follows: 1 Made defendant herein is Allyson Campbell, an individual of the full age of majority and aresident and domiciliary of the Parish of Ouachita, State of Louisiana. 2 At all times pertinent to this lawsuit, Defendant was acting under color of law but outside the course and scope of her employment duties as a law clerk for the Fourth Judicial District Court (Fourth JDC’). 3. Pursuant to Louisiana Code of Civil Procedure article 615, made nominal iefendant herein is AESI. Palowsky states that it would be a vain and useless act for him to demand thet ‘AESI bring the present action as the other 50-percent shareholder of AESI is W. Brandon Cork, who, as discussed below, has been sued by Palowsky in a related action. 3 3 Campbell's Actions in Palowsky v. Cork * 4 At all times pertinent to his causes of action against Campbell, Palowsky and AESI, detivatively, have been plaintiffs in the matter of Palowsky v. Cork, et al, Docket No. 13-2059 of CASE ASSIGRED TO: CV. SECTaT.the Fourth Judicial District Court, and Campbell has been employed as a law clerk in the Fourth we. 5. In Palowsky v. Cork, Plaintiff filed suit against W. Brandon Cork, the other 50-percent shareholder of AESI, for damages he suffered as a result of Cork’s theft, fraud, racketeering, and breach of fiduciary duty, the latter of which Cork testified was done, at least in part, at the direction of his counsel therein." 6. Upon information and belief, Campbellmaliciously and intentionally harmed Palowsky and willfully violated his constitutionally-protected rights to both due process” and access to courts'in Palowsky v. Corkwhen she spoliated, concealed, removed, destroyed, shredded, withheld, and/or improperly “handled” court documents such as memoranda of law, orders, pleadings, sealed court documents, and chamber copies of pleadings filed with the clerk and hand-delivered to the judge’s office. 1. Upon information and belief, Defendant maliciously withheld and concealed documents ‘and pleadings in the trial court as well as from the record that was sent to the Second Circuit Court of Appeal for its review of an application for supervisory writs filed by Cork. Said documents include the following: a. Plaintiff AEST’s Opposition to W. Brandon Cork’s Motion to Strike Answer filed January 13, 2014, Notably Judge J. Wilson Rambo stated at the beginning of the hhearing on the motion to strike that he had this pleading, yet it has remained “missing” from the record. b. Plaintif's Memorandum in Support of his Motion to Clarify Protective Order filed March 14, 2014. While the motion itself is included in the record, the 7 Tas deposition, Cork swore under oath in he presence ofhis counsel, Thomas M. Hayes, Il and Brendon ‘Creekbaum thet hewas under the “direction” of said counse! when be competed with ABSI without elling Palowsky. 2a Const. Art 1§2. 71a. Const Ar. 1822. Page?supporting memorandum (with attached exhibits) was not in the record or in an envelope of sealed exhibits sent to the Second Circuit Court of Appeal. . _AESI’s Reply Memorandum to Clarify Language in Protective Order to Allow Proper Reporting of Crimes, Tax Fraud, Racketeering, andConspiracy filed June 24,2014, with attached correspondence amongcounsel for the respective parties. 4 AEST's Original Opposition to Writ Application of W. Brandon Cork filed on or about July 15, 2014. For some reason, this pleading was missing from the Second Circuit's record, which was prepared by the trial court, though Cork’s application filed June 18, 2014, was included in the envelope of sealed documents filed with the appellate court clerk. e. Third Amending and Supplemental Petition of Plaintiff, Stanley R. Palowsky, Il, and Third Party Demand of Defendant, Alternative Environmental Solutions, Inc. with attached order requesting leave to file same filed on August 13, 2014.*Although this pleading itself was missing from the record sent to the Second Circuit, Cork’s memorandum in opposition to same was not. £ Palowsky'sand AESI’sMemorandum in Support of Motion to Recuse Judge Rambo as well as exhibits attached to same. This pleading is discussed more specifically below.> ‘Notably, such actions should constitute a violation of La. R.S. 14:132, the criminal statute which addresses the destruction or alteration of public records and sets forth the punishment for same, 9% ‘Such actions by Campbell of repeatedly and maliciously withholding and concealing “missing” court documents were part of a proven pattern of misconduct outside the course and scope of her duties as a law clerk but under color of law. “ath pleading, Palowsky and AESI added Cork’s counsel as defendants for their participation in Cork’s racketeering activites. ‘The trial court never actually granted leave to fle said pleading, so Palowsky and AES] ‘were forced to file separate suit, docket number 14-2412, against Cork’s counsel. That suit has now been ‘consolidated with Palowsky’s original suit against Cork the trial court's record was reviewed today, and the pleadings listed herein are still Page 3 sing from the record.10. Palowsky avers that Campbell undertook these acts with malice and with the intention not only to cause him loss and to injure and inconvenience him, but also to obtain unjust advantages for his opponent(s) and their counsel, At the very least, these actions constitute fraud per Louisiana Civil Code article 1953. UL Plaintiff was forced to file a motion to recuse Judge J. Wilson Rambo in his suit against Cotk after the following significant events involving Campbell, Judge Rambo’s law clerk at the time, occurred: a. Campbell published and declared in the Sunday edition of the Monroe newspaper ‘TheNews-Star her bias, favoritism, and praise for Cork’s counsel Thomas M. Hayes, II, when she wrote in her weekly “society” column that he, as well as Judge D. Milton Moore, Ill, of the Second Circuit Court of Appeal, had the “IT” factor, “a somewhat undefinable quality that makes you and everyone else around stand taller when they enter the room, listen a little more closely, encourage you to take fashion or life risks, make each occasion a little more fun, and generally inspire you to aim to achieve that ‘IT” factor for yourself.” ‘Many of Palowsky’s filings went missing from the record and/or were withheld from Judge Rambo in status conferences and hearings as noted above. Palowsky leamed that Campbellhad been investigated by both Judge Carl V. Sharp and Judge Benjamin Jones for destruction of court documents in another ‘matter as set forth in a written complaint filed against her by Monroe attorney Cody Rials. Her conduct was corroborated by an eyewitnessinterviewed by Judge Sharpwho stated that Campbell boasted in a local bar that she bad, indeed, shredded or withheld a court document in order to cause loss, injury, or inconvenience to attomey Rials. This clearly showed Palowsky that Campbell, the law clerk assigned to his case, had aptly demonstrated that she was beyond supervision let alone discipline. Page 44 1n 2014, Judge Benjamin Jones was againappointed to investigate complaints that Campbell was, once more, improperly “handling” Palowsky’s filings. Judge Jones concluded that the missing documents resulted from nothing more than delays caused by a “new filing process” in the Clerk's office.Nevertheless, the Clerk of Court advised counsel for Palowsky that the “new filing process” referenced by Judge Jones did not exist. ¢. Also in 2014, Campbell published a column entitled “A Modern Guide to Handle Your Scandal” advocating that “half the fun is getting there, and the other half is in the fix. ..."She went on to advise her readers as follows: [FJor the more adventurous among us, keep the crowd guessing. Send it out — lies, half truths, gorilla dust, whatever you've got... . [Jou are on the receiving end of one of the highest forms of flattery, as we always say “you're no one until someone is out to get you.” That special somebody cared enough to try and blacken yout reputation and went and tured you into a household name? Bravo. You're doing something right.” 12, Palowsky filed the motion to recuse Judge Rambo to escape recurring abuses of process, bias, prejudice, and the problem of Plaintiff's pleadings frequently disappearing, In compliance “with this Court's local rules, Palowsky contemporaneously filed a supporting memorandum with the Clerk of Court detailingthe facts and circumstances, including Campbell's actions,which justified his recusal request. Moreover, counsel hand delivered a copy of same to Judge Rambo’s chambers. 13, Ironically, though, shorily after the recusal motion and memo were filed, Judge Rambo held a status conference wherein he expressed his extreme displeasure to Plaintiff's counsel that Plaintiff had filed a motion to recuse without a supporting memorandum.Counsel for AEST and Palowsky advised Judge Rambo that was exactly why they were asking him to recuse himself, £e., because their filings were obviously being intercepted before he could read them. Pagesrc Obviously Campbell had, once again, acted outside the course and scope of her employment to intentionally harm Plaintiff by withholding and/or concealing court documents and wrongfully thwartinghis constitutional rights to access to the court and due process. 15. ‘After Palowskyand AESI suffered harm which was intentionally and maliciously inflicted upon them in Judge Rambo’s court for more thantwo years by Campbell in her efforts to damage ‘themand assist theiropponents and their counsel, Judge Rambo, while denying bias,recused himself without a hearing. Palowsky’s case was then assigned to Judge Carl V. Sharp. 16. Palowsky then filed a motion to recuse the Fourth JDC judges en banc on the basis that Campbell and the Court had become inextricably intertwined in litigation when Chief Judge H. Stephens Winters filed suit number 15-0770 onMarch 20, 2015, against Hanna Medi Inc. d/b/a! ‘The Ouachita Citizen newspaper, after it had filed a criminal complaint against the Court over public records requests dealing with the Court's internal investigations of possible payroll frand involving Campbell (as reported March 3, 2015 in The News-Star) and felonious destruction of court documents."It is not clear whether the “immediate investigation” reported in The News-Star vwas handled, at least in part, by Judge Jones 1. In that suit, the Court argued that Campbell’s right to privacy in her employment file was stronger than the public's right to know if its tax funds were being paid to someone who was committing, or allegedly committing, payroll fraud. Campbell intervened in that suit and, thereby, became a party to the litigation. 18. Significantly, unlike all other law clerks employed by the Court, Campbell reportedly did not electronically enter the time she spent at work, and her office reportedly went vacant for days, ifnot weeks, ata time.19. Moreover,Campbell hadposted several pictureson her Facebook pagewhich were viewable by the public’and which indicated that that she not only did her job in restaurants and/or bars, but also that she drank alcohol while doing soFor example, she captioned one picture, which was obviously taken in a restaurant and which showed food and alcoholic beverages, “Seafood nachos at the office.”She then posted a picture from the same restaurant of the half-eaten meal and two empty drink glasses and commented, “Too many house hooker 20. Nonetheless, the Court stridently protected Campbell's privacy “rights” and deprived the public of the opportunity to leam whether they were paying her to “work” while she was out of the office eating and drinking alcohol. 21. Additionally, in that same litigation, a draft judgment which was unsigned, undated, and lunfiled in the suit record was somehow received and circulated by and between Campbell, 2 party litigant, and Judicial Administrator Judge Jones more than one week in advance of any signed and dated judgment or reasons for judgment being made available to the public or to the defendant, The Ouachita Citizen.® bell’s History ofintentionallyMishandling and Misplacing Pleadit Without Any Reprisal from Her Supervising Judges 2. Palowsky submits that his allegations against Campbell must be viewed in light of other actions she has taken during her employment as a law clerk as well as her personal philosophies n life which she smugly publishes in her weekly “society” column and which might lead one to believe that she is, to put it mildly, narcissistic and incapable of submitting to any authority, * Campbell has subsequently either removed the photographs fom her Facebook aocount or changed he privacy setings so thatthe general public cannot view ber pictures, in an interview with The Ouachita Citizen, Judge Jones admitted the impropriety of having an unsigned and undated deft of judgment before same is released to all partes inthe Kitgation, but he refused to state fom whom. he obtained such document and, more disturbingly, when it was obtained. Page 72B. For example, on May 31, 2015, she wrote, “You will always be fond of me. I represent to you all the sins you have never had the courage to commit,” a quote which she attributed to ‘Oscar Wilde before he was imprisoned. 2m, On February 15, 2015, she quoted Oscar Wilde again when she said that “to love oneself is the beginning of a lifelong romance.” 25, On April 5, 2015, she told her readers as follows: “I say live life to the fullest, follow no one’s rules except your own (and law enforcement, of course) and continue to excel at your own personal spectacular talents.” 26. On April 12, 2015, she ended her column by quoting Henry Rollins: “In winter, I plot and plan, In the Spring I move.” 20. On June 14, 2015, Campbell again cited Oscar Wilde and stated, “Consistency is the last refuge of the unimaginative.” She then described how she “concocted . . . a faux rom-com worthy ‘don’t leave me” airport scene,” and she declared, “goodness, I love attention.” She then closed her column with W. David Johansen’s words “I am doing exactly what I want to do, and 1 ‘am having fun doing it.” 28. On June 21, 2015, Campbell wrote, “Escape the ordinary. Almost anything is possible if you have enough time and enough nerve.” 29. ‘On July 12, 2015, she penned, “It's not cheating if it’s in our favor.” 30. In another display of narcissism, when Campbell’s alleged improprieties and the litigation between the Court and The Ouachita Citizen were reported on by The Acadiana Advocate, Campbell posted a comment on the paper's online site and stated as follows; “Dear Pageadvocate: first of all my name is spelled Allyson, not Allison.” She then went on to explain to the paper what an ad hoc judge does. 31. Regardless of Campbell's writings in her society column, Palowsky states that ‘Campbell's actions of improperly handling pleadings and filings appear to be not only habitual, but alsotacitly approved by this Court as she has apparently never even been reprimanded, much less disciplined, for same. 32. For example, upon information and belief, when the Clerk of Court could not locate ‘S2writ applications which had been “missing” for months, it was discovered that Campbell, who ‘was clerking for Judge Carl Sharp at the time, had used the applicationsas an end table in her office, 33. ‘As another example, and as noted above, Monroe attorney Cody Rials complained to Judge Sharp thatCampbell had withheld and/or shredded his court document in a case that was pending before said judge. Upon information and belief, Rials was ordered to reduce his complaint of such felonious conduct to writing, which he did. When Judge Sharp was investigating this complaint, it is believed that he interviewed an eyewitness to the fact that Campbell sat in a bar and boasted of shredding Rials’ document so that he, Judge Sharp, could not review it’ 34, Subsequently, Defendant was re-assigned to clerking duties for Judge Rambo, who presided over Palowsky's suit against Cork, as well as Judge Frederic C.Amman, a close friend and personal confidant of Campbell. Notably, Judge Amman, Judge B. Scott Leehy, and Judge Rambo are the ones who signed Campbell’s timesheets. * The Fourth JDC judges advised TheOuachita Citizen that there were no discipline records involving Campbell \which te court could provide n response to the newspaper's request for public records. During the tal ofthe ‘Court’ suit against the newspaper, counsel for the Court argued to the adhoc judge that there was no “eyewitness” testimony to Campbell's alleged felonious destruction of court documents Page‘This Court Should Recuse Itself from This Matter 35, Palowsky avers that the Fourth JDC should recuse itself from this matter since Campbell is an employee of the Court, 36. Moreover, as discussed above, this Court has an apparent history of protecting Campbell even though several attorneys in different cases, including Palowsky v. Cork, have complained about her suspected felonious destruction of documents and even though she has reportedly been investigated for public payroll fraud. 37. ‘Not only has this Court allowed Campbell to do as she pleases at the courthouse without recourse, but as noted above, it chose to sue a local newspaper to protect her employment records from being made public, and therein, it denied that there were any eyewitnesses to Campbell's destruction of documents even though Judge Jones and Judge Sharp reportedly interviewed an eyewitness who personally heard Campbell bragging about same. 38. ‘The above facts and circumstances require that the Fourth JDC be recused en bane and ‘nad hoc judge be appointed to hear and decide the instant lawsuit, ‘Requests for Relief 39. To date, Plaintiff has endured more than two years of needless delay, court costs, attomey fees, embarrassment, mental stress, and inconvenience (as referred to in Civil Code article 1953) and has, likewise, been denied his rights of access to the courts and due process of law as a result of a patter of malicious and intentional misconduct on the part of Campbell. 40. Campbell's wrongdoing has been reported time and again by different attomeys in ifferent cases and investigated time and again by this Court butnevertheless has been allowed to continue. It is now painfully apparent that she has been unsupervised and uncontrollable for years. Page 10au Palowsky avers that Campbell's actions constitute fraud, conspiracy to commit fraud, abuse of process, destruction or concealment of public records, intentional infliction of emotional distress, and violation of his rights under the Louisiana Constitution to due process and access to the courts. 42, Palowsky therefore states that he, individually and on behalfof AESI, is entitled to be compensated for any and all damages he and AESI have suffered as the result of Campbell's fraud, conspiracy to commit fraud, abuse of process,destruction or concealment of public records, intentional infliction of emotional distress, and violation of his Louisiana constitutional rights of due process and access to the courts. 43. At this time, Plaintiff seeks no relief under any federal law, 44, Palowsky hereby requestsa trial by jury on all his claims, including without limitation, his intentional tort claim. WHEREFORE, Plaintiff, Stanley R. Palowsky, [individually and on behalf of AESI, prays that after due proceedings are had, there be judgment rendered herein in favor of Plaintiffand against Defendant, Allyson Campbell, for all sums as are fait and just under the circumstances, together with reasonable attomey fees and court costs. Plaintiff further prays for all orders and decrees necessary and proper under the premises and for full, general, and equitable relief. Page 11ctfully submitted: | SEDRIC E. BANKS #2730 Attomey at Law 1038 North Ninth Street Monroe, La. 71201 318-388-1655 telephone 318-388-0227 facsimile a p North Jefferson Ave. fington, La, 70433 871-5231 telephone 985-871-5324 facsimile Attorneys for Plaintiff, Stanley R Palowsky, IIT PLEASE PERSONALLY SERVE: ALLYSON CAMPBELL 300 St. John St. Monroe, LA 71201 PLEASE SERVE: ALTERNATIVE ENVIRONMENTAL SOLUTIONS, INC., ‘Through its agent for service of process: Sedric E. Banks 1038 North Ninth St. Monroe, LA 71201 Page 12STATE OF LOUISIANA PARISH OF OUACHITA FOURTH DISTRICT COURT STANLEY R. PALOWSKY, I, Individually, FILED: 2 and on behalf of ALTERNATIVE ENVIRONMENTAL SOLUTIONS, INC. VERSUS NO._15-2179 ALLYSON CAMPBELL DY. CLERK OF COURT ‘VERIFICATION BE IT KNOWN that on the 22 day of July, 2015, personally came and appeared, STANLEY R. PALOWSKY, IU, plaintiff in the above styled and captioned lawsuit, who, ‘upon being duly sworn by me, Notary, did depose and state that he is, indeed, the plaintiff {n said suit and that he, has read all allegations contained in the Petition and that all of said allegations are true and correct to the best of his knowledge, information and belief Thus done and passed on the above day and date in Monroe, La. ST R-PALOWAKY, Ill