Federal Civil Rights Claim and Racketeer Influenced and Corrupt

Organizations Act (Civil RICO) Claim and Pendent State Claims for
Declaratory, Injunctive and Punitive Relief (Footnotes appear as endnotes).
Note: This suit was dismissed and denied on appeal.

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF VIRGINIA

RICHMOND DIVISION

MURRAY L. STEINBERG
In behalf of himself, and
all those similarly situated,
and

CHELSEA RENEE STEINBERG

a minor child,

By her Next Friend, and

Natural Father,

MURRAY L. STEINBERG

Plaintiffs,

vs.

THE COMMONWEALTH OF VIRGINIA,

HENRICO COUNTY
The Honorable Judge L.A. HARRIS

The Honorable Judge KULP

Murray J. JANUS

Deanna L. DWORALOWSKI

BREMNER, BABER & JANUS

Katherine T. STEINBERG

Kenneth SHUMAKER

Pauline Kie

Defendants.

FULLY INFORMED JURY TRIAL DEMANDED

DEMAND FOR:

COMPENSATORY, PUNITIVE & EXEMPLARY DAMAGES

&

SEVENTY FIVE MILLION DOLLARS ($75,000,000.00)

TO BE ALLOCATED TO THE VIRGINIA STATE ATTORNEY

GENERAL'S BUDGET

(in addition to the current budget)

COMPLAINT
COMES NOW, the Plaintiffs in the above styled action and doth complain and
allege as follows:

-I-

CONSTITUTIONAL SOVEREIGNTY

1. The Plaintiffs are free and natural persons, citizens of the United States of
America and inhabitants of the Commonwealth of Virginia; all within the federal
jurisdiction of the United States District Court, Middle District of Virginia,
Richmond Division, now here appearing and pray for relief before this Honorable
Court herein, and invokes the sovereignty of the United States Constitution.

-II-

JURISDICTION AND VENUE

2. This action arises under the First, Fourth, Fifth, Ninth, and Fourteenth
Amendments to the United States Constitution and under the Civil Rights Act, Title
42, United States Code §§ 1983, 1985, 1986, and 1988 for violation of Plaintiff's
civil rights as guaranteed by the United States Constitution. This cause also arises
under Title 18, USC §§ 1962 and 1964, Civil RICO. This Court also has jurisdiction
over the Plaintiff's common law claims which arise out of the same nucleus of
operative facts as do Plaintiff's federal claims according to the principles of pendent
jurisdiction. Violations of Plaintiff's rights have occurred in Henrico County, thus
venue is properly placed with this Court. It is the Plaintiff's contention that because
of i) torturous outrage, ii) harassment by the Defendants, and iii) threats to one of
the Plaintiffs, that venue should remain in the Richmond Division or transferred
where the safety of the Plaintiffs and their families would be assured. All
proceedings "only tangentially" relate to the Plaintiff's domestic relations dispute.
Before this Court entertains a motion to dismiss, it should consider Ankerbrandt,
S.Ct.(1991) and Haffer v. Mello, (1991) 1 .

3. This case involves vital questions of civil rights important to many Americans of
similar circumstances throughout this nation, thus abstention should not be
considered.2 Exception to the abstention doctrine justly lies in this cause as Plaintiff
challenges state action, conduct as state officials, and others where such action and
conduct "under color of law" impinges on fundamental civil liberties and
constitutional rights.3 Plaintiff urges the Court to take particular concern since the
State system has been unwilling to protect those rights itself.4 Plaintiff avers that the
Commonwealth has breached it's obligation and duty to protect the civil liberties of
United States Citizens; both the Commonwealth's Constitution, the Code of
Virginia, and the United States Constitution. By such breaches of its duties the
Commonwealth has waived its Eleventh Amendment immunity. Plaintiff avers that
his complaint would be improperly placed in the state court as the Commonwealth
has refused to uphold the Constitution. Plaintiff's complaint involves numerous
other violations of Federal law.

4. Even a claim that Plaintiff's complaint might be resolved under the due process
clause of the Commonwealth's Constitution would not be grounds for abstention.5
The Court should further find reason to assume jurisdiction in light of the
intimidation tactics by the commonwealth judiciary, threats by judicial appointees,
intentional violation of the laws of the Commonwealth by its judiciary and its
judicial appointees, all with the design to obstruct him from bringing forth the
exercise of his constitutional and civil rights.6
5. This Court should not hold this litigant's pleadings to the same high standards of
perfection of lawyers.7 If faced with a motion to dismiss, the Court should give
Plaintiff's pleadings especially lenient treatment so that before the Court dismisses
the complaint of this In Propria Persona Plaintiff he can be given an opportunity to
offer evidence or further particularize his claim.8 The Federal Courts have related 9
that In Propria Persona Civil Rights pleadings are to be liberally construed.10

- III -

PARTIES

6. PLAINTIFF:

6.1 Plaintiff, Murray L. Steinberg 11 , sues in his own proper person both
individually and collectively.

6.2 Plaintiff, Chelsea Renee Steinberg 12 , sues by her next friend, and natural
father, Murray L. Steinberg.

7. At all times pertinent to this complaint, the defendants, each of them, while acting
in their capacities described and in doing the things hereafter set forth, were acting
under color of alleged state statutes, rules, and practices and federal laws, rules and
practices.

8. DEFENDANTS:

8.1 Defendant, Commonwealth of Virginia13 , was at all times material to this

Complaint. This suit against the COMMONWEALTH OF VIRGINIA is brought
under the "expressly authorized" exception of 42 USC § 1983 to 28 USC § 2283
anti-injunction provision for equitable relief. The COMMONWEALTH OF
VIRGINIA is sued in cause for its willful participation in the deprivation of civil
rights guaranteed by the Constitution of the United States wherein it is alleged that
"under color of law" proceedings of state courts were motivated by i) bad faith, ii)
harassment, iii) and deliberate and selective application and/or omission of state law
that flagrantly and patently violated express constitutional prohibitions. Defendant
was the direct or proximate cause of Plaintiff's injury and causes for relief.

8.2 Defendant, Henrico County, was at all times material to this Complaint. Henrico
County is sued in cause for its willful participation in the deprivation of civil rights
guaranteed by the Constitution of the United States wherein it is alleged that "under
color of law" proceedings of state courts were motivated by i) bad faith, ii)
harassment, iii) and deliberate and selective application and/or omission of state law
that flagrantly and patently violated express constitutional prohibitions. Defendant
was the direct or proximate cause of Plaintiff's injury and causes for relief.

8.3 Defendant, the Honorable Judge L.A. Smith, judge14 of Henrico County Circuit
Court, in and for Henrico County, Virginia, was at all times material to this
Complaint. Smith is sued individually and in his official capacity wherein it is
alleged that he subjected and caused the depravation of Plaintiff's civil rights and
privileges secured by the United States Constitution. That he, having knowledge of
the wrongs conspired to be done as alluded to in 42 USC § 1985, or wrongs about
to be committed, and having the power15 to prevent or aid in preventing the same,
neglected or refused to do that which he by reasonable diligence could have
prevented. The Defendant was the direct or proximate cause of Plaintiff's injury and
causes for relief.

8.4 Defendant, the Honorable Judge James Kulp, judge of Henrico County Circuit
Court, in and for Henrico County, Virginia, was at all times material to this
Complaint. Kulp is sued individually and in his official capacity wherein it is
alleged that he subjected and caused the depravation of Plaintiff's civil rights and
privileges secured by the United States Constitution. That he, having knowledge of
the wrongs conspired to be done as alluded to in 42 USC § 1985, or wrongs about
to be committed, and having the power to prevent or aid in preventing the same,
neglected or refused to do that which he by reasonable diligence could have
prevented. The Defendant was the direct or proximate cause of Plaintiff's injury and
causes for relief.

8.6 Defendant, Murray J. Janus 16 , Esquire, was at all times material to this
Complaint and a lawyer who practices his profession in the area of Henrico County,
Virginia. Defendant Janus is licensed by the State Bar of Virginia. He is affiliated
with the defendant Bremner, Baber & Janus, as a partner, member, or agent of
Bremner, Baber, & Janus, wherefore it is alleged that "under color of law", he
personally participated in or directed the alleged violations of Plaintiff's rights and
that his specific conduct was the direct or proximate cause of Plaintiff's injury and
causes for relief.

8.6 Defendant, Deanna L. Dworakowski 17 , Esquire, was at all times material to

this Complaint and a lawyer who practices her profession in the area of Henrico
County, Virginia. Defendant Dworakoski is licensed by the State Bar of Virginia.
She is affiliated with the defendant Bremner, Baber & Janus, as a partner, member,
or agent of Bremner, Baber & Janus, wherefore it is alleged that "under color of
law", she personally participated in or directed the alleged violations of Plaintiff's
rights and that her specific conduct was the direct or proximate cause of Plaintiff's
injury and causes for relief.

8.7 Defendant, Bremner, Baber & Janus 18 , was at all times material to this cause.
A law firm with offices located in Richmond, Virginia, provided legal services to
the Defendant Katherine T. Steinberg, wherefore it is alleged that "under color of
law" the firm, by and through a member, principal, partner or agent of said firm,
participated in or directed the alleged violations of Plaintiff's rights and further, that
the specific influence or acts of its officer(s), principal(s), partner(s), or member(s)
was the direct or proximate cause of the Plaintiff's injury and cause for relief.
Defendant Bremner, Baber & Janus is a "person" and an "enterprise" within the
meaning of 18 USC § 1961 (3) (4).

8.7 Defendant, Katherine T. Steinberg 19 , was at all times material to this

complaint and former wife to the Plaintiff Murray Steinberg and mother to the
Plaintiff Chelsea Steinberg. She is sued individually as a "STATE ACTOR",
wherefore it is alleged that she participated in or directed the alleged violations of
the Plaintiff's civil rights while cloaked "under color of law" and that her specific
conduct was the direct or proximate cause of the Plaintiff's injury and causes for
relief.

8.8 Defendant, Kenneth Shumaker, was at all times material to this complaint and
adulterer with the former wife to the Plaintiff Murray Steinberg. He is sued
individually as a "STATE ACTOR", wherefore it is alleged that she participated in
or directed the alleged violations of the Plaintiff's civil rights while cloaked "under
color of law" and that her specific conduct was the direct or proximate cause of the
Plaintiff's injury and causes for relief.

8.9 Defendant, Pauline KIE, was at all times material to this complaint. She is sued
individually as a "STATE ACTOR", wherefore it is alleged that she participated in
or directed the alleged violations of the Plaintiff's civil rights while cloaked "under
color of law" and that her specific conduct was the direct or proximate cause of the
Plaintiff's injury and causes for relief.

- IV -

STATEMENT OF THE CASE

9. This is an action for declaratory and injunctive relief and relief for damages
brought by Plaintiff, who is unable to afford an attorney and comes before this
Court In Propria Persona. The subject of this suit is the depravation of Plaintiff's
constitutionally guaranteed rights and conspiracy to violate those rights. Plaintiff
and his family have undergone extraordinary harassment, intimidation, and threats
by state officials and other parties. He and his family have suffered extreme mental
anguish in pursuit of redress for a lengthy pattern of deprivations of his
Constitutional rights, liberties, malicious acts, and character assignation against him
and his family.

10. This claim arises under the United States Constitution, particularly under the
provisions of Article I §§ 8,9, and 10; Article V; and of the First, Fourth, Ninth,
Tenth, and Fourteenth Amendments to the Constitution. As those issues concern the
Plaintiff, this case involves claims that the defendants conspired20 and engaged in
conduct in furtherance of that conspiracy which violates RICO and the Plaintiff's
civil rights accorded him under federal statute. Authority for this suit is given this
Court under USC Title 42 §§ 1983, 1985, 1986, 1988, and Civil RICO USC Title 18
§ 1964. Numerous criminal acts under Federal and Virginia criminal give rise in
support of this action out of the same operative facts under USC Title 18 §§ 241,
242, 1512, 1963, RICO and the Virginia Criminal Code.

-V-

THE LAW

11. The Court is moved to take judicial notice of the following Virginia and Federal
laws:

THE SUPREME LAW OF THE LAND:

11.1 The Constitution of the United States is the "supreme law of the land" and is
itself a law for which it the duty of all Courts "high and low", both State and
National, to sustain and enforce as they do all other laws. Any law, rule, policy, or
decree must be "made in pursuance thereof" and not as to subvert the Constitution.
When any law or ruling is not made in pursuance thereof it is unconstitutional, void
and of no effect. Even if the wording of a law or ruling is constitutionally correct, if
it is not applied equally it is unconstitutional. The Fourteenth Amendment Due
Process Clause and Equal Protection Clause are among the most defiled of all rights
in the state court.State trial courts often, by intimidation and financial restriction,
deny Access to the Courts as identified by the United States Fifth Circuit Court of
Appeals in Ryland v. Shapiro.21

FEDERAL CRIMINAL CODE:

Title 18 Crimes and Criminal Procedure: 22

Under

11.2 18 USC § 3 Accessory after the fact, it is a criminal offense if a person

knowing that an offense against the United States has been committed, receives,
relieves, comforts or assists the offender in order to hinder or prevent his
apprehension, trial or punishment;

11.3 18 USC § 241 Conspiracy Against Rights of Citizens it is a federal criminal

offense23 if two or more persons conspire to injure, oppress, threaten, or intimidate
any inhabitant of any state, territory, or district in the free exercise or enjoyment of
any right or privilege secured to him by the Constitution or laws of the United
States, or because of his having so exercised such right or privilege, such persons
may be fined and/or imprisoned;

11.4 18 USC § 242 Deprivation of Rights Color of Law it is a criminal offense if

under color of any law, statute, ordinance, regulation, or custom a person wilfully
deprives an inhabitant of any State of his rights, privileges, or immunities secured or
protected by the Constitution or laws of the United States, and punishable by fine or
imprisonment for no more than one year.
11.5 18 USC § 512 Tampering with a Witness, victim, or informant it is a federal
criminal offense to interfere with the communication by any person to a law
enforcement officer or judge of the United States of information relating to the
commission or possible commission of a Federal offense;

11.6 18 USC §§ 1961-1963 Racketeer Influenced and Corrupt Organizations Act it

is a criminal offence punishable by fine or imprisonment of not greater than twenty
years for any acts or threat involving extortion which is chargeable under State law
and punishable by imprisonment for more than one year or any act under certain
provisions of Title 18 of the United States Code including but not limited to § 1341
(relating to mail fraud), § 1343 (relating to wire fraud), § 1503 (relating to
obstruction of justice), § 1510 (relating to obstruction of criminal investigations), §
1511 (relating to the obstruction of State or local law enforcement), § 1513 (relating
to retaliating against a witness, victim, or an informant), § 1951 (relating to
interference with commerce);

VIRGINIA STATUTES:

11.7 The Code of Virginia, 1950 as ammended.

-VI -

FACTUAL ALLEGATIONS

12. It is again important to note, that under this suit, pursuance of a conspiracy,
conspiracy, and wilful intent need not be proven, just that the natural consequences
of the alleged actions resulted in the depravation of constitutional rights24 .
American Society has observed the formation of a new scheme to administer a
perverted system to deal with domestic relations cases. It has been devised within
the vacuum of the federal courts. This vacuum has formed within the over-burdened
courts, whom, over the past twenty years have virtually removed themselves as the
protectors of individual rights pertaining to the family. Any uncontrolled system
takes great profits from injustices which an adversarial system can provide when it
is unprotected by the federal courts. The architects of this scheme are those who
profit greatest from the infliction of cruelty, torment and destruction of lives. They
are the state judicial appointees25 , lawyers, huge bureaucratic establishments that
receive power and funding through the destruction of families via the depravation of
inherent, inalienable and constitutionally guaranteed rights26 . It is more than a
system of petty tyrants, it is an industry dedicated to profiteering at the expense of
the American family 27 . A network of institutions, legislation, regulation, and
practices has been established in a vestigial sally to accomplish no more than to
devour the prosperity of the American family. The network does this without regard
to the damage inflicted upon children, parents, families (direct and extended),
business, society in general, and individual rights. It lends itself to be perverted by
those who have created an industry out of it. An industry that puts selfish interests
before law or morality. This industry improperly operates and determines the lives
of the very young based on a deficiency of facts, archaic biases, and disregard for
any rules of evidence or presumptions of innocence, that has resulted in proceedings
in which diagnoses are made, certainty of speculative opinion is expressed, and
actions taken on the basis of unsupported belief using techniques and methodology
riddled with error and falsehood. The declaration of these great wrongs are not
limited to the solitary claim of the Plaintiff. It is the plea to the Federal Court,
Guardian of the Great Writ, to defend the Constitution, that is voiced by thousands
of Americans, even the President of the United States of America, who has voiced
rhetoric and issued Executive Orders 28 from the White House, indicating
recognition of some of the concerns contained herein.

13. The Plaintiff alleges that the defendants have continuously impeded and
hindered the due course of justice, with intent to deny the Plaintiff equal protection
of the law and discriminated by so doing.

- VII -

CAUSES OF ACTION

FIRST CLAIM

RACKETEER INFLUENCED & CORRUPT ORGANIZATION ACT (RICO)

AGAINST ALL DEFENDANTS

15. Plaintiff incorporates by reference the allegations in ¶¶ 1 - 14.

PERSONS AND ENTERPRISES

16. Plaintiff and all of the Defendants are "persons" within the meaning of 18 USC
§ 1961 (3).

17. Defendants Harris, Kulp, Janus, Dworalowski, K. Steinberg, Shumaker, Bremner

Baber & Janus are "enterprises" as defined in 18 USC § 1961 (4) by virtue of being
an individual, partnership, corporation, association or other legal entity. All of the
defendants are participants in an "association-in-fact" enterprise hereinafter referred
to as the "Family Disservice Enterprise" (FDE). The FDE consists of attorneys,
social workers, health care professionals, and the institutions that participate in
identifying the requisites for the family structure, caretakers, and parental roles. This
enterprise has existed in the Henrico County, in the Commonwealth of Virginia for
a long time and continues to flourish. It is the aggregate make of many other
enterprises whose profits depend on the misfortunes of families. It has for its
mission the appropriation of illegal income which it obtains from the victims, such
as the Plaintiff, of an erroneous system of guidelines, practices and habits developed
by the FDE that are in violation of the laws of God, decent man, the United States,
Virginia and the County of Henrico. The FDE obtains is illegal income from the tax
rolls of counties, from the State, it's agencies, the agencies of the Federal
government, those it victimizes by its activities, and even its own participants. The
purpose of the enterprise is separate and distinct from the racketeering activities in
which the enterprise has engaged. All of the defendants named in this claim have
participated in the affairs of this enterprise as described below. The Family
Disservice Enterprise operates as follows:

17.1 By making false allegations and fraudulent statements, including introducing

such allegations and fraud in divorce, custody, access (visitation), child and spousal
support proceedings.

17.2 By willfully and intentionally fabricating "evidence" and pleadings interposed

in bad faith with malice in order to achieve their end, without fear of punishment
because of the habits, guidelines and conspiratorial nature of their alleged criminal
activities.

17.3 By purposeful and calculated harassment to drive the mark and his/her family
into financial ruin so that the mark may not seek legal recourse.

17.4 By invading their mark's privacy by slander and libel.

17.5 By conspiring with the spouse of the mark, to cause immense mental anguish.

17.6 By going so far as to cause the mark to be falsely imprisoned for things 29 that
are not even illegal or criminal.

17.7 The State Court in and for Henrico County constitutes an "enterprise" within
the meaning of 18 USC § 1961 (4).

PREDICATE ACTS

18. By the conduct described in the Complaint, Defendants did i) knowingly used
intimidation, threats 30 , and misleading conduct toward the Plaintiff with the intent
to prevent the testimony of the Plaintiff, ii) hinder and prevent communication iii)
intentionally harassed Plaintiff, which by their magnitude constitute a predicate
RICO act under Title 18 USC § 1961 (1) (A).

PATTERN OF RACKETEERING ACTIVITY

19. The unlawful conduct alleged in ¶ ¶ 17 through 17.10 constitutes a "pattern of

racketeering activity" within the meaning of Title 18 USC § 1961 (5). These
activities had the same purposes of obtaining illegal income or obtaining a benefit to
which they would not otherwise be entitled. As such, they are related to one another
within the meaning of the "relationship element" of a RICO pattern, having the
same participants, results and methods of commission. Also theses activities have
taken place over an extended period of time, in the case of the Plaintiff alone, from
April 1991 to the present. Other children and parents, including the Plaintiff's
children and family, on information and belief, are being victimized by these illegal
activities in which these same defendants continue to participate. The Virginia
Supreme Court, Virginia Court of Appeals, Virginia Circuit Courts, Virginia
Juvenile and Domestic Relations Courts, as well as the Family Law Courts in other
States, have become beset by this type of activity which threatens the system of
justice in these courts. The conduct of the defendants in infiltrating those activities,
if unchecked, carries the threat that the necessary protection of the individual and
collective rights of the victimized children and parents may cease to exist and cause
immeasurable injury to both their emotional well-being and their general welfare. It
has a chilling universal effect on the social well-being of the country further
effecting the economy 31 and competitiveness of the United States. It is this type of
long-term and deep reaching conduct that RICO was conceived to prevent and
comports with the "continuity" element of a RICO pattern.

SUBSTANTIVE RICO VIOLATIONS

20. By reason of the conduct alleged in this Complaint, Defendants have violated
RICO in that they have:

20.1 Acquired or maintained, directly or indirectly, an interest in or control of an

enterprise (the "Enterprise") and of the component enterprises of the aggregate in or
affecting and preventing the filing and communication of federal civil and criminal
complaints, testimony, and evidence pertaining to other criminal RICO, both
Federal and State criminal violations, civil torts and civil violations to law
enforcement officials or judges of the United States through a pattern of
racketeering activity, in violation of Title 18 USC § 1962 (b); and/or:

20.2 Participated in, associated with or conducted the affairs of an enterprise,

including all alleged enterprises, in or affecting the filing and communication of
federal civil and criminal complaints, testimony, and evidence pertaining to other
criminal RICO, both Federal and State criminal violations, civil torts and civil
violations to law enforcement officials or judges of the United States through a
pattern of racketeering activity, in violation of Title 18 USC § 1962 (c); and/or:

20.3 Conspired to violate Title 18 USC § 1962 (c) in violation of Title 18 USC §
1962 (d).

INJURY TO PLAINTIFF

22. By reason of Defendants violation of Title 18 USC § 1962 as set out above,
Plaintiff M. Steinberg, was injured in his practice and business and has suffered
extreme emotional anguish and distress over the harm inflicted to his children and
family. By Defendant's specific conduct they have severely damaged his business
reputation and prevented him from earning a livelihood. Defendants have continued
in this purpose since April 1991 to the present causing continued loss of benefits to
his children and family. Plaintiff has suffered injury and loss of his livelihood in the
amount of THREE MILLION DOLLARS ($3,000,000.00) which by law he is
entitled to recover from Defendants.

22.1 By reason of Defendants violation of Title 18 USC § 1962 as set out above,
Plaintiff C. Steinberg, was injured in her benefit from the practice and business of
her Father and has suffered extreme emotional anguish and distress over the harm
inflicted to the benefit to which she is entitled by virtue of her father's livelihood.
By Defendant's specific conduct they have severely damaged her father's business
reputation and prevented him from earning a livelihood. Defendants have continued
in this purpose since April 1991 to the present causing continued loss of benefits to
Plaintiff C. Steinberg and her family. Plaintiff has suffered injury and loss of her
benefit in the amount of THREE HUNDRED THOUSAND DOLLARS
($300,000.00) which by law she is entitled to recover from Defendants.

SECOND CLAIM

INVASION OF PRIVACY

AGAINST ALL DEFENDANTS

23. Plaintiff incorporates the allegations contained in ¶¶ 1 - 15.

24. By the conduct alleged in this Complaint, Defendants deliberate actions

conspired to and did intentionally intrude on the personal privacy of the Plaintiff in
his right to private and peaceful enjoyment of his relationship with his children and
family.

25. Defendant's intrusion on Plaintiff's privacy was substantial and is highly

offensive and objectionable to persons of reasonable sensibilities.

26. Defendant's willful action with reckless disregard to the rights of the Plaintiff
and said actions intruded upon the Plaintiff's private communication with his
children and denied communication and access. These actions both disturbed the
Plaintiff and the stability of the children, the familial relationship and intruded upon
the private father-daughter relationship.

27. As direct and proximate result of these wrongful actions, Plaintiff, M. Steinberg,
has suffered mental anguish and despair, continued loss of his practice and business
reputation, loss of earning and benefit, loss of earnings potential, all to his damage
in the sum of no less than THREE MILLION DOLLARS ($3,000,000.00).

27.1 As direct and proximate result of these wrongful actions, Plaintiff, C.

Steinberg, has suffered mental anguish and despair, continued loss of her father's
earnings benefit, loss of earnings potential, all to her damage in the sum of no less
than THREE HUNDRED THOUSAND DOLLARS ($300,000.00).

THIRD CLAIM
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

AGAINST ALL DEFENDANT'S

28. Plaintiff incorporates the allegations contained in ¶¶ 1 - 15.

29. Defendants actions were deliberately calculated to interfere with Plaintiff's

father-daughter relationship and to alienate the daughter from her father.

30. All of the above actions by the Defendants have been intended and calculated by
them to cause extreme emotional distress to the Plaintiff, or alternatively,
Defendants knew or should have known that their actions would result in extreme
emotional distress to the Plaintiff.

31. Actions by the Defendants have been so extreme and outrageous as to go

beyond all possible bounds of decency, especially that it interrupts and denies the
father-child relationships, and even violates Virginia Statutes intended to maintain
those relationships.

32. The Defendant's actions have been the direct and proximate cause of extreme
emotional upset and mental and psychological injury. Said extreme emotional
distress is of such a nature that no reasonable person could be expected to endure it.

33. By the conduct described above, Defendants caused Plaintiff, M. Steinberg, to

suffer severe emotional distress for which he is entitled to recover compensatory
damages in the sum of SIX MILLION DOLLARS ($6,000,000.00).

33.1 By the conduct described above, Defendants caused Plaintiff, C. Steinberg, to

suffer severe emotional distress for which she is entitled to recover compensatory
damages in the sum of SIX HUNDRED THOUSAND DOLLARS ($600,000.00).

FOURTH CLAIM

INTERFERENCE WITH FAMILY RELATIONS

AGAINST ALL DEFENDANTS

34. Plaintiff incorporates the allegations contained in ¶¶ 1 - 15

35. The actions of the Defendants have caused, and were deliberately intended to
cause, an intentional interference with the family relationship, ie: the relationship of
the Plaintiff, M. Steinberg with his children.

36. The actions of the Defendants have caused, and were deliberately intended to
cause, an intentional interference with the family relationship, ie., the relationship of
the Plaintiff, C. Steinberg with her father.
37. By the conduct described above, Defendants caused Plaintiff, M. Steinberg, to
suffer severe emotional distress for which he is entitled to recover compensatory
damages in the sum of SIX MILLION DOLLARS ($6,000,000.00).

37.1 By the conduct described above, Defendants caused Plaintiff, C. Steinberg, to

suffer severe emotional distress for which she is entitled to recover compensatory
damages in the sum of SIX HUNDRED THOUSAND DOLLARS ($600,000.00).

FIFTH CLAIM

CIVIL CONSPIRACY

AGAINST ALL DEFENDANTS

38. Plaintiff incorporates the allegations contained in ¶¶ 1 - 15.

39. Defendant, K. Steinberg, conspired with Defendants to interfere and interrupt

the Plaintiffs family relationship. This conspiracy and interruption constitutes
interference with Plaintiff's family relationships and an invasion of his privacy by
intruding into his personal affairs and intentionally imposing emotional distress upon
Plaintiff.

40. The conduct described in the Complaint constitutes an actionable civil

conspiracy against Plaintiff which entitles him to recover from the Defendants the
sum of at least THREE MILLION DOLLARS ($3,000,000.00) as compensatory
damages and THREE MILLION DOLLARS ($3,000,000.00) as exemplary
damages.

41. In furtherance of their conspiracy the Defendants carried out the acts which they
conspired to do.

SIXTH CLAIM

DEPRIVATION OF CIVIL RIGHTS

AGAINST ALL DEFENDANTS

42. Plaintiff incorporates the allegations contained in ¶¶ 1 - 15.

43. The conduct of the Defendants under color of law described in the complaint
constitutes a violation of Plaintiff's constitutional guarantees by abridging his
privileges and rights under the provisions of Article I, §§ 8, 9, and 10; Article V;
and of the First, Fourth, Fifth, Ninth, Tenth, Thirteenth and Fourteenth
Amendments to the Constitution. The Defendants under color of law deprived the
Plaintiff Due Process of Law, denied Plaintiff of Equal Protection of the Laws, the
right to required and sufficient Notice, the right to a Hearing with proper notice, the
right to an Impartial Tribunal, the right to Confront and Cross-Examine, the
substantive and procedural right to Access to the Court and other rights under
Virginia law. The state did not have jurisdiction to hold a hearing without proper
notice, motion, or pleadings. By such actions the Defendants violated Plaintiff's
right to Due Process; which is actionable under 28 USC § 1983. In further support
of Plaintiff's claim he shows that Defendants violated criminal law under 18 USC
§§ 241 and 242, and Virginia Statutes.

PREDICATE ACTS AND SUBSTANTIVE 42 USC § 1983 VIOLATIONS

44. By the conduct described in this complaint, Defendants did under color of
statute, ordinance, regulation, rule custom and usage of the State subject or caused
to be subjected to Plaintiff, within the States's jurisdiction, to the deprivation of
rights, privileges and immunities secured by the constitution, statutes, rules, policies,
or ordinances.

44.1 Defendant's K. Steinberg and Murray Janus filed a falsified pleading in

violation of Virginia Rules of Civil Procedure and Statutes. Defendant K. Steinberg
initiated the action in civil court; a violation of civil rights, both substantive and
procedural of right to access to the courts; a criminal offense under Virginia
statutes. Defendants Janus and Bremner, Baber and Janus gained economic benefit
for instituting pleadings they knew were false.

44.2 Defendants deprived Plaintiff of rights and privileges under Virginia Rules of
Civil procedure, Virginia Statutes, the Virginia Constitution, the Constitution of the
United States of America and substantive and common law of the State and the
United States by depravation of, but not limited to, the right to notice, right to
motion and pleading as a prerequisite for a hearing, right to cross examination, the
right to call witnesses, the right to a fair trial and other rights not mentioned;
violations of the Constitution and criminal offense under 18 USC §§ 241 and 242.

INJURY TO PLAINTIFF

45. By nature of their acceptance of authority delegated to them by the

Commonwealth of Virginia, Harris and Kulp, were acting under color of state
authority in carrying out their conduct of deprivation of Plaintiff's rights and in
furtherance of the conspiracy. The other Defendants conspired with persons acting
under color of state authority and are, therefore, also responsible for their conduct as
state actors which is actionable under 42 USC § 1983.

46. As a direct and proximate result of Defendant's wrongful conduct, Plaintiff has
suffered mental anguish and despair, loss of personal and business reputation, and
loss of livelihood, loss of earning potential, loss of consortium with his daughter,
and consortium of his family assembly, all to his damage of Ten Million Dollars
($10,000,000.00).

47. The Defendants were willful, wanton, malicious, reckless, grossly negligent and
illegal entitling Plaintiff to an award of exemplary damages in the sum of no less
than Ten Million Dollars ($10,000,000.00).

- VIII -

JURY DEMAND

48. Plaintiff hereby exercises his right to demand a trial by jury of this cause.

- IX -

PRAYER FOR RELIEF

49. Plaintiff respectfully prays for judgement in his favor and against Defendants,
and prays further that this Court:

49.1 Declare that the Defendants have engaged in a past, continuing pattern and
practice of deprivation of civil rights under color of state law thereunder, and
substantive and procedural right to access the courts under the First and Fourteenth
Amendments of the United States Constitution; and the Due Process clause and
Equal Protection clause under the Fourteenth Amendment of the United States
Constitution.

49.2 Declare that the Defendants have acted illegally and unconstitutionally in
violating Plaintiff's constitutional rights and liberties and have acted illegally and
unconstitutionally and in a capricious and willful manner in hindering and
preventing the Plaintiff's effort to bring actions in Court.

49.3 Declare that the proceedings of the State court herein identified and all orders
promulgated therefrom, are null, void and of no effect.

49.4 Issue an injunction enjoining Defendants from continuing to maintain practices

and policies of violation of civil rights including but not limited to access to the
courts both state and federal, due process, equal treatment under the law, extortion,
threats, unlawful arrests, and harassment of Plaintiff and all citizens of the State or
the separate states.

49.5 Issue an injunction enjoining Defendants from interfering with Plaintiff's

pursuit of filing his federal actions in this Court or any other court of this nation.

49.6 Issue an injunction enjoining Defendants, their lawyers, employees, others

otherwise directed in their duties by the Defendants from interfering with Plaintiff's
practice or business and enjoining Defendants from harassing or communicating
with his clients.

49.7 Order the State of Virginia to appropriate funds in the amount of SEVENTY
FIVE MILLION DOLLARS ($75,000,000.00) to the State Attorney Generals office
for the investigation and prosecution of corrupt public officials in addition to its
current budget.

49.8 Award compensatory damages to Plaintiff as to all of these claims together

with pre-judgement interest against Defendants herein, jointly or severally.

49.9 Award exemplary damages proved by Plaintiff as to all these claims.

49.10 Award treble damages as required by law.

49.11 Award Plaintiff's costs incurred in this suit.

49.12 Award Plaintiff such costs other and further relief as the court may deem just
and proper.

50. AND FURTHER ORDER AND ADJUDGE:

52.1 A federal criminal investigation of the actions of the Defendants and others
unnamed or unknown against the Plaintiff for indictment of the Defendants on the
criminal charges for Malicious Conspiracy to deny Plaintiff equal access to the
court, actions constituting child abuse, and criminal actions consideration of
evidence of perjury to a court of law, conduct prejudicial to the due administration
of justice, the criminal actions alluded to in this complaint, and any other charges
deemed appropriate by this Court.

To the best of my knowledge and in the belief that justice will prevail -- Based on
that foundation and consistent to the statements by J.D. Redman,Superior Court
Judge. et seq.

Truth is found only when dedicated men are free to inquire after it. If we refuse to
fight for the dignity of truth we have substituted expediency for justice.

Respectfully submitted,

MURRAY L. STEINBERG, In Propria Persona

Thomas Jefferson - 3rd Preident of the United States - 1743 - 1826 : "Experience
hath shown that even the best forms of [government] those entrusted with power
have, in time, and by slow operation, perverted it into tyranny."

FOOTNOTES/ENDNOTES

1 Ankerbrant S.Ct. 91-637, 6 FLW 5408; Haffer v. Mello,

2 Wright v. McMann, 387 f 2d 519 (CA2 NY 1967; Canton v. Spokane School
Dist., 498 F 2d 840 (CA9 Wash 1974); Collins v. Collins, 597 F Supp 33 (ND Ga
1984), later proceeding 613 F Supp 1306 (ND Ga), 784 F 2d 402 (CA11, affd w/o
op), later proceeding 834 F 2d 961 (CA ga), 9 FR Serv 3d 1149.
3 See: New Jersey-Philadelphia Presbytery of Bible Presbyterian Church v. New
Jersey State Board of Higher Education, 482 F Supp 969 (CA3 NJ 1980, affd), 654
F 2d 868, Hanna v. Toner, 630 F 2d 442 (CA Ohio 1980, cert den), 67 L Ed 2d 346,
101 S BNA FEP Cas 218, 6 CCH EPD ¶ 8746, White v. Walnut Hill Tel. Co., 84
FRD 138 (WD Ark 1979), 52 ALR Fed 99.
4 Collins, supra.
5 Wisconsin v. Constantineau, 400 US 433 (1971), 27 L Ed 2d 515, 91 S Ct 507.
6 See Perez v. Ledema, 401 US 82 (1971), 27 L Ed 2d 701, 91 S Ct 674;
International Soc. for Krishna Consciousness, Inc. v. Conlisk, 374 F Supp 1010 (ND
Ill 1973).
7 In Propria Persona pleadings are to be considered without regard to technicality;
In Propria Persona pleadings are not to be held to the same high standards of
perfection as lawyers. Haines v. Kerner, 92 S Ct 594; Jenkins v. McKethen, 395 US
411, 4421 (1969); Pickering v. Penna Ry. Co., 151 F 2d 240; Puckett v. Cox, 456 F
2d 233; See also Powell, 914 F 2d 1459 (11th Cir 1990).
8 Waller v. Butkovich, 605 F Supp 1137 (MD NC 1985).
9 Hurney v. Carver, 602 F 2d 993 (CA1 Mass 1979); Stephenson v. Gaskins,539 F
2d 1066 (CA5 Ga 1976); Holloway v. Gunnell, 685 F 2d 150 (CA5 Tex 1982); Ross
v. Franzen, 777 F 2d 1216 (CA7 Ill 1985), 3 FR Serv 3d 346; Anderson v. Sixth
Judicial Dist. Court, 521 F 2d 420 (CA8 Minn 1975), Nickens v. White, 536 F 2d
802 (CA8 Mo 1976).
10 A surfeit of factual allegations is not necessary grounds to strike the pleadings,
especially when those pleadings are prepared by an In Propria Persona litigant
untutored in the requirements of federal procedural rules. Hann v. Lane, 610 F Supp
32 (ND Ill 1985) (aff'd in part w/o op and rev'd in part w/o op).
11 Hereinafter referred to as "Murray Steinberg".
12 Hereinafter may be referred to as "Chelsea Steinberg".
13 Hereinafter may be referred to as "the State or State". The terms "state" or
"states"are reserved to identify any or a number of states and/or commonwealths
which make up the United States of America.
14 Judicial definition that misuse of power possessed by virtue of state law and
made possible only because the wrong-doer is clothed with the authority of state
law within this section is applicable to Judge. Duke v. The State of Texas, 327 F
Supp 1218 (1971).
15 Liability in damages for unconstitutional or otherwise illegal conduct has the
very desirable effect of deterring such conduct. Indeed, this was precisely the
proposition upon which 42 USC 1983 was enacted. "...Judges may be punished
criminally for willful deprivations of constitutional rights on the strength of 18 USC
242; Imbler v. Pachtman, US 47 L Ed 2d 128, 96 S Ct.
16 Hereinafter may be referred to as "Murray Janus", or "M. Janus"
17 Hereinafter may be referred to as " Deanna Dworakoski" or "Janus' assistant".
18 Hereinafter may be referred to as Janus' law firm.
19 Also known as Katherine Shumaker; Hereinafter may be referred to as "Kathy
Steinberg" or "K. Steinberg". 20 To maintain an action under § 1983, it is not
necessary to allege or prove that the defendants intended to deprive the plaintiff of
his constitutional rights, or that they acted willfully, purposely, or in the pursuance
of a conspiracy... it is sufficient to establish that the depravation of Constitutional
rights or privileges was the natural consequences of defendants acting "under color
of law", irrespective of whether such consequences were intended. Ethridge v.
Rhodes, DC Ohio, 268 F Supp 83 (1967); Whirl v. Kern, CA5 Texas, 407 F 2d 781
(1968).
21 Ryland v. Shapiro, 708 F 2d 967 (1983). {See parts [2] - [8]} 22 Section 1 of Act
June 25, 1948, c. 645, 62 Stat. 683; as codified in part "Title 18 of the United States
Code; see Title 18 U.S.C.A.
23 Judges are not immune from criminal sanctions under the Civil Rights Act. ex
Parte Virginia, 100 US 339 (1879).
24 To maintain an action under § 1983, it is not necessary to allege or prove that the
defendants intended to deprive the plaintiff of his constitutional rights, or that they
acted willfully, purposely, or in the pursuance of a conspiracy... it is sufficient to
establish that the depravation of Constitutional rights or privileges was the natural
consequences of defendants acting "under color of law", irrespective of whether
such consequences were intended. Ethridge v. Rhodes, DC Ohio, 268 F Supp 83
(1967; Whirl v. Kern, CA5 Texas, 407 F 2d 781 (1968; Ury v. Santee, DC Ill.
(1969).
25 Virtually all judicial appointees are members of the same fraternity of lawyers
that thrive on the unchecked adversarial system that has evolved.
26 See: "Vested interests of the "child savers" to destroy American Families"
November, 1992 Esquire magazine.
27 "How did we happen to take the wrong turn? Because we lost our sense of
professionalism, the compass that kept us on course for so long. Without the
compass, far too many lawyers have been completely preoccupied with
accumulating wealth, to the utter neglect of their public and ethical responsibilities."
The Honorable Judge Harry L. Carrico, Chief Justice, Virginia S.Ct.
28 See; President Reagan's Executive Order on The Family, (E.O. 12606) Federal
Register Vol 52, No. 1974, Title 3 (1987)
29 One example, the Plaintiff M. Steinberg, was sentenced to the Henrico County
Jail for 10 days for "allegedly" raising his voice to his wife during a conversation he
was having with her at the home where she resides with her paramour.
30 Defendant Janus went so far as to insinuate death by being shot through the head,
to the Plaintiff M. Steinberg, and on another occasion indicated that M. Steinberg
had signed his "death-wish" when he filed a Rule to Show Cause against Defendant
Janus.
31 See; Ohio Psychological Assn. study on Small Businesses