Gina V City of Augusta 2nd Amended Complaint 42 Usc 3601 Filed

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 1 of 115
PageID #: 111
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE
GinA
CIVIL NO. 1:16-cv-00100-NT
on her own behalf, and as Next Friend to the

court on behalf of all other low income disabled
and homeless tenants in Maine who are now,
have ever been or may ever be similarly situated,
Plaintiff
v
City of Augusta Maine
JURY TRIAL DEMANDED
a municipality, a body corporate and politic and

as a government agent for the State of Maine
Judicial Branch, and
VERIFIED
2ND AMENDED COMPLAINT
City of Augusta Police Department
Violation of
a body corporate and politic and a government
42 USC 12132,
agent for the City of Augusta and the State of
42 USC 3601, 3604(f) & 3617,
Maine Judicial Branch, and

City of Augusta All_Police Officers
1st, and 14th Amendments, and

42 USC 1981, 1983, 1985(3) & 1986
in their individual and official capacities as

government agents for the City of Augusta
and the State of Maine Judicial Branch, and
William Stokes
in his individual and official capacities as Chief
Deputy Attorney General for State of Maine, as
Mayor for City of Augusta and as a government
agent for State of Maine Judicial Branch, and
Matthew Pouliot
in his individual and official capacities as a
Representative for Maine (part of District 86,
1:16-cv-00100-NT
GinA v. City of Augusta et al, 2nd Amended Complaint
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including 32 Court Street), as Vice Chair of

City of Augusta Planning Board, and as a
government agent for State of Maine Judicial
Branch, and
William Bridgeo
in his individual and official capacities as
Manager for City of Augusta, and as a
government agent for State of Maine
Judicial Branch, and
Matt Nazar
in his individual and official capacities as
Director of Development Services for City
of Augusta and as a government agent for
State of Maine Judicial Branch, and
Royce Watson
in his individual capacity as owner and landlord
for 239 Cony Street, and his official capacity as a
government agent for City of Augusta and the
State of Maine Judicial Branch, and
Gregory Roy
in his individual capacity as owner and landlord
for 32 Court Street, and his official capacity as a
government agent for City of Augusta and the
State of Maine Judicial Branch
Defendants1
GinA wants to include Ray Corporation as a Defendant and co-conspirator in this

complaint but GinA has not had enough time or energy while defending other related
lawsuits to do enough research to fully understand how to successfully sue a private
corporation for ADA/FHA/FHAA deprivations and civil rights violations so GinA asks
this court to add Ray Corporation, Matt Ray and Rob Ray as Defendants if, and only if,
doing so will not negatively prejudice GinAs complaint.
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I.
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INTRODUCTION
GinAs Verified 2nd Amended Complaint is being filed in this case after GinA
discovered Judge John Nivisons name in the docket record for AUGSC-CR-2012286 indicating Judge John Nivision was absent all jurisdiction to oversee any type
of preliminary review of this case or 1:16-cv-00095-NT because Judge John Nivison
presided two times over one of GinAs bogus criminal cases in state court which was
fully dismissed on December 18, 2013 and December 16, 2014 by Michaela Murphy.
Judge John Nivisons participation in fraudulent criminal lawsuits against
GinA requires him to immediately and permanently recuse himself from having any
judicial participation in all cases for this and all related companion cases under 42
USC 144, 455 & 1631 because Judge John Nivison is a witness in AUGSC-CR2012-286.
GinA is authorized by 28 USC 2284 to request a three-judge court who have
never worked with any Maine Judicial Branch judges or attorneys to preside over
this case and the companion case 1:16-cv-00095-NT.
28 USC 3101, Prejudgment Relief
GinA is authorized by 28 USC 3101 to request all proper prejudgment relief
in the likely event GinA obtains a favorable judgment against any Defendant on
any one or more of her counts.
GinA requests the following prejudgment relief:
1.
permanent injunctions against the following parties, government agencies
and private corporations to provide all necessary required legal protections for all of
GinAs (1) confidential legal electronic computer data, (2) confidential legal and
private communications which occur by her computer and internet, and (3)
confidential legal electronic computer work product from illegal interference,
monitoring, spying, collection, control, storage, analysis and dissemination to or
from any and all official agents for:
a. U.S. Department of Justice
b. U.S. Department of Homeland Security
c. U.S. National Security Agency
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d. U.S. Central Intelligence Agency

e. Federal Bureau of Investigations, Re: FBI #922311VB1
f. William Stokes in his capacity as a superior court judge,
g. Diane Doyen, as an AG and William Stokes wife Re: GinAs cases
h. Maine Information and Analysis Center (MIAC),
i. City of Augusta Police Department,
j. Kennebec County Sheriffs Office,
k. Maine State Police, Re: SID #ME9003212,
l. Time Warner Cable, Re: Acct #678424010,
i. terminate all current and prevent all future illegal spying, monitoring,
control, interference, manipulation, redirecting, listing GinAs dynamic
IP address for GinAs current internet connection on the Spamhaus
Public Block List to interfere with GinAs official electronic government
communications with the federal courts by blocking her private SMTP
outgoing email home-based server activities which violate the 1st, 4th
and 14th Amendments,
ii. GinA has previously communicated with this court via email from her
private email address gina@mainetenants.org on September 12, 2015
when GinA received confirmation of her PACER account, September 21,
2015 when GinA received this courts electronic confirmation of her
Electronic Court Filing registration, and up until October 16, 2015
when GinA received Judge Nivisons Report And Recommended
Decision in 1:15-cv-00382-NT.
iii. On or between October 17-22, 2015, Time Warner Cable, either upon
their own initiative or upon direction of City of Augusta Police
Department, William Stokes, Leigh Saufley et al or one of their official
agents blocked GinAs electronic computer email communications being
sent to and from gina@mainetenants.org, gina@mainejustice.org and
peacivist@peacivist.org without a valid search warrant, legal probable
cause or any suspicion of criminal conduct.
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iv. On October 7 and 8, 2015, GinA communicated with court staff Renee
Bender and Melody Whitten regarding GinAs missing ECF filings for
1:15-cv-00382-NT which were sent from gina@mainetenants.org.
v. On October 23, 2015 at 1:38pm, GinA attempted to file a document into
this courts docket via gina@mainetenants.org for case 1:15-cv-00382NT which was never received by this court as evidenced by GinAs
communications with court staff Renee Bender and Melody Whitten.
vi. On or about October 29, 2015, GinA changed her ECF email address to
mtjloffice@gmail.com and began sending and receiving official
government email to and from this court again.
vii. GinA has since created a special email address especially for ECF
filings at gina.ecf@gmail.com which works without issues.
viii. GinAs private residential dynamic IP address has been blocked by
Time Warner Cable and its official government agents from sending
any official electronic email communications to the federal district court
and its agents from her home-based email server computer,
ix. GinA cannot use private email addresses at gina@mainetenants.org,
gina@mainejustice.org or peacivist@peacivist.org because all outgoing
email from her home-based computer is listed as SPAM on the PBL,
x. GinA has audio recorded at least three instances which have occurred
during private confidential conversations on GinAs computer between
April 3, 2016 and the current date from an unknown 3rd party
monitoring and spying on GinAs private Skype internet phone calls
when GinA is discussing confidential legal strategies, legal work
product and private medical information. See one piece of evidence here:
https://www.youtube.com/watch?v=Scc0rLufpCA
2.
federal oversight and investigation of City of Augusta municipal activities
since January 2009,

3.
federal investigation of state executive, judicial, legislative, commercial and
private agency contract activities regarding the Capital Judicial Center,
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4.
preliminary injunctions preventing legal transfer or disposing of any assets,
5.
proper writs of attachment against all Defendants personal and professional
property,
6.
proper garnishments, sequestrations, replevins,
7.
federal forensic financial audits and supervision of Defendants personal and
professional financial activities since January 2009 until entry of a final order in
these proceedings,
8.
lien Defendants personal and professional assets held:

a.
in each of their names alone and
b.
jointly
i. with any other legal or natural person,
ii. in the name of their privately owned businesses,
iii. no exceptions for any LLCs created in Defendants names,
iv. by Defendants or someone acting on behalf of Defendants,
9.
all proper attachments, repossessions and replevins against all personal and
professional assets which were transferred to any legal or natural person since
January 2009.
GinA is authorized by 18 USC 241 & 242 and 42 USC 3631to request all
proper relief be ordered against all natural men and women Defendants.
Venue is proper in the District of Maine under 28 USC 1391(b).
All Defendants are located and residing in Maine, and all events, actions and
omissions giving rise to this claim occurred in Maine.
I.
PUBLICITY is the BEST PROTECTION for PUBLIC CORRUPTION

The intriguing particulars of this case and its companion case, 1:16-cv-00095-
NT, shows what happens when anyone violates GinAs civil rights and then gravely
underestimate GinAs tenacity to get her proper legal justice for all malicious acts
which deprive GinA or her family of their fair housing rights solely because GinA is
a disabled, low income female without a paying job or her own car who has a history
of being homeless because she repeatedly demands to have a safe and affordable
home in her hometown of Augusta Maine.
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The court needs to keep in mind that GinA has been extremely vocal in many
public forums, locally and globally, about years of injustices committed against her.
GinA has a public reputation for discretely recording her interactions with
people under Maines One-Party Law and she encourages others to do the same.
Despite GinAs public reputation, Defendants continued their rogue, illegal
and discriminatory behaviors which GinA recorded in some type of electronic or
physical evidence and which proves Defendants crossed the legal line into criminal
violations worthy of criminal sanctions under 18 USC 241 and 242 and 42 USC
3631.
GinA poses a critical question to the court which it should consider when
reading this complaint:
How many other low income, disabled or homeless tenants have been
abused by Defendants in the same way, or worse, when Defendants knew those
low income, disabled tenants are not able to write a comprehensive lawsuit for
a federal court to get legal justice for official abuses by judges, attorneys and
government officials, or for their landlords lawless behaviors amid a growing
epidemic of homelessness caused by illegal and retaliatory evictions, or for
across-the-board constitutional and federal violations of their ADA and fair
housing rights by public servants and their official legal agents, and other
types of disparate treatments?
This particular case is about GinA who entered the adult world when she was
16 years old in 1986 to create a peaceful home free from abuse and discrimination in
her hometown of Augusta Maine. Her mother named her Gina Lynn Turcotte but
Gina changed her legal name to just GinA on December 19, 2014.
GinA never found a permanent peaceful home in Augusta Maine.
Instead, GinA has suffered for the past 7 years from illegal discrimination
and chronic abuses at the hands of her elected, appointed and administrative public
servants who all live off taxpayer money and by other private people who she
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trusted to provide her with safe affordable low income housing in Augusta which
Congress has promised to protect in 42 USC 3601 et seq., inter alia.
City of Augusta and its agents have (1) refused to build or maintain safe low
income affordable housing in Augusta, (2) repeatedly destroyed low income housing
units without providing any replacements, (3) discriminated against low income
disabled tenants by refusing to spend $300,000 cash assets to fix unsafe apartment
buildings, and (4) conspired with police departments, landlords, attorneys and the
Maine Judicial Branch agents to break ordinances and state laws to terrorize low
income disabled homeless tenants in Augusta so they will move out of the city, or die
trying to survive within the city limits amidst the abuses and illegal activities of
their judges and elected leaders.
GinA has been subjected to innumerable unnecessary criminal and civil court
actions as well as other punitive public events directly related to her disability and
her difficulty with self-sufficiently maintaining a safe affordable low income home
without getting federal Section 8 or other types of local public financial help.
Now GinA cannot even get a job outside of her isolated home in Sidney Maine
because she cannot travel independently by a car because City of Augusta Police
Department, City of Augusta All_Police Officers, and William Stokes, in
conspiracy with Leigh Saufley, et al., 1:16-cv-00095-NT, have conspired since 2011
to prohibit GinA from exercising her right to travel by filing bogus criminal charges
against GinA for four counts of Operating After Suspension, plus several additional
criminal and civil charges including refusing to submit to arrest which all directly
resulted from GinA properly reporting her permanent disability in 2005 to State of
Maine Bureau of Motor Vehicle as she was legally required to do under MV Rules
29-250, Ch. 3, Physical, Emotional And Mental Competence To Operate A Motor
Vehicle.
GinA was homeless without a stable mailing address after reporting her
medical condition in 2005 so Maine BMV Medical Unit arbitrarily and indefinitely
suspended drivers license #1491178 because GinA did not receive nor comply with
a BMV standard progress disability review requirement under Rule 29-250 Ch 3.
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Maine Judicial Branch joined Defendants conspiracy by wrongly upholding

an illegal medical suspension of license #1491178 on January 5, 2010 which directly
prevented GinA from maintaining a job to pay expenses for a safe affordable home.
William Stokes acted in his official capacity as Deputy Attorney General of
the Office of Attorney General Criminal Division in 2013 when he authorized his
agent AAG Donald Macomber to legally defend that medical suspension of the
drivers license in front of Leigh Saufley et al.
Defendant Greg Roy joined the conspiracy in 2012 when he spoke to agents of
City of Augusta and Maine Judicial Branch about selling 32 Court Street for the
new courthouse parking lot and then on January 8, 2014 when he responded to
GinAs email asking if she could view a 2 bedroom unit at 32 Court Street which she
sent in response to Greg Roys internet post.
Although State of Maine is not named directly as a defendant because that
lawsuit can only be filed in the Supreme Court of the United States, the State has
positioned itself as a co-conspirator in this case and in GinA v. Leigh Saufley, 1:16cv-00095-NT, by allowing its various government agencies, government agents and
private people to act in official capacities as government agents under color of state
laws when they were discriminating against GinA by constantly violating Congress
policies, federal laws, and federal civil rules of procedure because she is known to be
or is considered to be a disabled, low income homeless woman who exercises her
constitutionally-protected rights when GinA has tried to obtain and maintain safe
and affordable housing, have access to public information to research safe
affordable low income housing and have access to critical government and court
services to protect her federal fair housing rights.
The facts of this case support a legal and factual finding that all Defendants
in this case have conspired at some point during these events with one, many or all
Defendants in this case and one, many or all Defendants in GinA v. Leigh Saufley,
1:16-cv-00095-NT, and other unnamed co-conspirators, to illegally eliminate GinA
and other low income disabled people from the city limits of Augusta Maine under
color of state laws through abusive unconstitutional application of zoning, housing
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and building ordinances, eviction laws under 14 MRSA 6001 6030-E and Maine
Rules of Civil Procedure Rule 80D in conspiracy with county sheriffs and all agents
of Maine Judicial Branch by aggressively increasing enforcements of life safety
codes while allowing a plague of illegal evictions to grow statewide in clear violation
of the ADA, the FHA and the FHAA by:
(1)
shutting down low income apartment buildings without replacements,
(2)
refusing to legally condemn closed unfit low income apartment

buildings,
(3)
refusing to take financial responsibility for unfit buildings,
(4)
refusing to require unfit but not condemned buildings be repaired,
(5)
conspiring since 2009 with County of Kennebec and State of Maine

Judicial Branch to use legal threat of eminent domain against a church,
a mental health crisis service agency, a rooming house landlord, and 3
low income homeowners to forcibly purchase and destroy religious and
commercial properties and four habitable low income residential
dwellings on 32 Court and Perham Streets to build a courthouse parking
lot,
(6)
destroying 32 Court Street and Perham Street homes which were safely
providing and could continue to safely provide housing for more than 20
low income disabled people,
(7)
discriminating in favor of new elderly housing project investments,
(8)
creating not for profit and for profit corporations without a public vote
to apply for federal housing and tax credits to receive federal funding,
(9)
hoarding $300,000.00+/- cash assets since 2005 by the Augusta Housing

Service Corporation (a 501(c)(3) subsidiary created by Augusta Housing
Authority) which is required to be spent to build or repair low income
housing in Augusta Maine,
(10) refusing to hold closed public meetings to discuss low income disabled
tenants issues,
(11) refusing to initiate legal action against landlords for law violations,
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(12) refusing to protect low income disabled tenants against law-breaking

landlords and their attorneys.
In the background, while City of Augusta, Augusta Police Department,
All_Police Officers, William Stokes, William Bridgeo, and Matt Nazar were
aggressively shutting down unfit low income apartment buildings, which has
actually created a low income housing crisis in Augusta Maine, Augusta
Housing Service Corporation has been hoarding $300,000 in public cash,
William Stokes secured a $100,000 home equity loan on his $209,100 private home
in June 2014 and Matthew Pouliot bought a historic home valued at $162,900 for
only $72,000 in 2014-2015, all in Augusta which will be paid for with public taxes
which fully fund their public salaries and other publicly-supported private benefits.
GinAs History with William Stokes and other State of Maine agents
Within the first few months of GinAs employment with State of Maine BMV
in the OUI Unit starting on January 7, 2007, she recognized how most government
agents regularly target disabled low income drivers by requiring them to submit to
discriminatory conditions which includes revealing private confidential medical
information which is then used in a discriminatory and abusive way to deprive
them of their right to travel which deprives them of their ability to maintain a safe
affordable home which causes many of them to become homeless and destitute.
In April 2007 GinA took action to prevent the widespread pattern of official
abuse by formally submitting a proposal to her direct supervisor for internal policy
changes related to OUI and other serious driving offenses.
GinAs proposal would connect all licensed drivers with public information
about state-sponsored commuter services within Maine at minimal cost to BMV by
changing their policies to include one-page double-sided leaflets in postal mailed
envelopes to registered drivers telling them about the state-sponsored GoMaine
Commuter Connections vanpool and carpool services available to all Mainers and
telling all BMV callers about GoMaine Commuter Connections public services.
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Despite GinAs proposal receiving a full endorsement by all department

heads, plus the Deputy Secretary of States approval, Secretary of State Matthew
Dunlap completely disregarded it.
When GinA was told her proposal had been rejected by Secretary of State
Matthew Dunlap, she started asking certain pointed questions about why Matthew
Dunlap rejected a public proposal which had been fully endorsed by his department
heads and would reduce BMVs overall workload and related costs.
GinA was stonewalled every time she asked questions about her proposal.
On September 26, 2007 at 6:45pm, GinA survived a violent and destructive
micro-burst tornado in Windsor Maine when a tree crashed through the bedroom
ceiling of her brand new rented mobile home while GinA was standing in its path.
This natural disaster triggered GinAs symptoms of post-traumatic stress
disorder requiring her to take medical leave from the OUI Unit because of the very
provocative nature of her daily work talking with active alcoholics whose drivers
licenses had just been suspended and how GinAs fragile emotional state from
surviving a near-death experience affected GinAs daily interactions with people.
GinA took a medical leave September 27, 2007 until April 2008.
GinA and her daughter decided to go to California to recover from the trauma
they had just experienced in Windsor.
BMV requested GinA return to her job in April 2008 but GinA was unable to
return upon their request because Maine had received record-breaking snowfall in
2007-2008 which prevented GinA from traveling through New England into Maine
in her two-wheel drive pickup truck until after the snow melted.
GinA traveled by herself with her two cats in a pickup truck from California
to Maine in 7 days arriving in Maine on June 3, 2008; GinA immediately applied to
return to her job on June 9 or 10 in the BMV OUI Unit which was rejected.
After GinA returned to Maine on June 3, 2008, she applied for dozens of jobs
as a state employee until September 2010 after she was interviewed and arbitrarily
rejected more than 24 times for a state job.
After being rejected for 18 months, GinA got their hint, so she focused on law.
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GinAs futile attempt to return to her job as a state employee in the OUI Unit
or any other state job forced GinA to work as a construction flagger in 2008 which
severely injured GinAs physical health by proliferating GinAs scoliosis and lower
back problems and then as a humiliating minimum wage staff at Dunkin Donuts
until 2011 when she completely left the job market for lack of positive challenging
opportunities in her chosen occupation.
GinA is now forced to rely solely on her federal Social Security disability
insurance benefits, which she happily paid during her many full time jobs, but her
federal savings account does not allow GinA to live safely.
GinA was forced to live in substandard low income communities until she
moved into 32 Court Street on January 22, 2014 but she was then illegally evicted
by Leigh Saufley et al on September 26, 2014 so a courthouse parking lot could be
built at the expense of disabled low income homeless taxpayers.
Most low income apartment buildings in Augusta are dangerous and unfit
because City of Augusta et al have refused to maintain them and they refuse to force
the building owners to maintain them.
From 2010 until September 26, 2014, GinA has been public about the legal
injustices proliferated against her and other low income disabled tenants by City of
Augusta et al and Leigh Saufley et al which has directly caused All_Police Officers,
William Stokes, Matthew Pouliot, et al to chronically discriminate against GinA
because she is a low income, disabled woman who exercises her constitutionallyprotected right to have fair, safe and affordable low income housing.
City of Augusta Police Ofc. Eric DosSantos acted in his official capacity as a
police officer when he set a course of events into motion on February 10, 2011 by
making an unconstitutional traffic stop violating the 1st, 4th and 14th Amendments
for failure to obey a traffic control device at the corner of Townsend Road and
Marketplace Drive.
That traffic control device no longer exists.
Ofc. Eric DosSantos traffic stop has directly caused GinA to be repeatedly
deprived of her constitutionally secured rights to enjoy due process, to speak, to be
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heard, inter alia, to enjoy public services without discrimination under Title II of
the ADA, fair housing rights under 42 USC 3601 et seq., public transportation
services under the FHA/FHAA/ADA and receive public information under the 1st
Amendment and FOAA/FOIA.
GinA has been forced to legally defend herself since 2011 after certain City of
Augusta All_Police Officers filed and aggressively defended six bogus criminal and
other civil charges against GinA on February 10 and March 7, 2011 and again on
February 16, 2012 in conspiracy with Leigh Saufley et al in 1:16-cv-00095-NT which
they all knew resulted from a discriminatory medical suspension on January 5,
2010 of drivers license #1491178 under 29-A MRSA 2458(2)(D) by Maine
Secretary of State Bureau of Motor Vehicles Medical Unit for GinAs innocent
failure to receive or respond to BMVs official letters related to her disability.
Defendants violated Title II of the ADA by arresting GinA because of the
2010 drivers license medical suspension and filing and defending criminal and civil
charges against GinA even though they knew 29-A MRSA et seq. does not allow for
prosecution for GinAs innocent failure to receive postal mail while she is homeless.
Defendants have grossly violated the ADA, FHAA, 1st and 14th Amendments
inter alia which has prevented GinA from exercising her right to receive fair, safe
affordable low income housing in a safe Augusta neighborhood of her choice free
from threat of illegal discrimination, intimidation, coercion or harassment which
has proliferated all of GinAs homelessness, unemployment, poverty and disability
indicators, aside from all of GinAs other injuries caused by Defendants since 2009.
Defendants knowingly, intentionally and maliciously deprived GinA of rights
and privileges secured to her by 1st and 14th Amendments inter alia which directly
caused GinA to be physically homeless at least 2 times for at least 415 days
between March 1, 2012 November 11, 2014 while Defendants were serving in
official paid public trust capacities.
Defendants violated their legal duty to disclose personal and professional
financial conflicts of interest and knowingly used or knowingly neglected to prevent
other Defendants from using nonpublic government information for their own
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private financial gain to improve their own private housing and financial situations
violating their duties of public service under 5 CFR 2435.101 which allowed at least
William Stokes and Matthew Pouliot to improve their private residential and
financial situations at Maine taxpayers expense while they were knowingly taking
away GinAs and other low income disabled tenants home at 239 Cony Street, 3
Washington Street Place and 32 Court Street putting her physically onto the street
on September 26, 2014.
In addition to the disparate treatment against GinA since 2010, Defendants
actions have created widespread disparate impact against low income, disabled and
homeless classes of people in Maine which has directly caused an actual housing
crisis in Augusta Maine which Defendants refuse to resolve and which is evidenced
by Maine Judicial Branchs FY10-FY15 Annual Reports showing a 35% spike in
statewide evictions when all other areas of law have progressively declined.
GinA brings this suit against each Defendant individually and jointly in
direct conspiracy with and aided and abetted by all Defendants in Leigh Saufley et
al for all injuries GinA has sustained from February 10, 2011 to September 26, 2014
which resulted from Defendants conspiracy to violate GinAs rights as a disabled,
low income homeless woman as secured by the 1stand 14th Amendments inter alia of
the Constitution under color of state laws in their capacities as private individuals
and government agents as related to City of Augusta All_Police Officers and
William Stokes (in his official capacity as the Criminal Deputy AG) enforcement of
penalties of the traffic stop on March 7, 2011 on Marketplace Drive because Augusta
Police Ofc. Eric DosSantos knew about GinAs medical suspension and summoned
her anyway and William Stokes officially authorized Donald Macomber to defend
GinAs 80C Petition despite acknowledging the suspension was medical in nature, all
actions taken as a result of the March 7, 2011 traffic stop, all discriminatory actions
occurring at or for 239 Cony Street, 3 Washington Street Place and 32 Court Street
Augusta which violated GinAs rights as a disabled low income woman to enjoy fair
housing and all official actions Defendants took in their official capacities to deprive
GinA from speaking and being heard during public meetings and events.
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II.
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JURISDICTION AND VENUE
GinA claims federal jurisdiction under 28 USC 1331 & 1343 and Article III
2 which extends jurisdiction to all civil actions arising under the Constitution,
laws or treaties of the United States.
GinA claims federal jurisdiction under 42 USC 12133 for discrimination in
public services on the basis of GinAs disability in violation of 42 USC 12132.
GinA claims federal jurisdiction under 42 USC 3613(a) as amended by the
Fair Housing Amendments Act of 1988.
Declaratory and other proper relief is authorized by 28 USC 2201 & 2202
and 42 USC 3613(c) & 12133.
GinA requests any and all proper internal investigations, restraining orders, writs
of mandamus, writs of attachment, and prejudgment remedies including all proper
garnishments, sequestrations, replevins, independent third party audits and
supervision of Defendants personal and professional financial activities since
January 2010 and throughout these proceedings until execution of a final judgment,
and all necessary court oversight to secure a contingent lien on each and all of the
Defendants personal property held in each of their names both alone and jointly
with any other person or in the name of any of their privately owned and operated
businesses, including proper attachments, repossessions and replevins against all
personal and professional assets which were recently transferred as a fraudulent
transfer to any other person or corporation including proper attachments against
Matthew Pouliots private real estate agency Alliance Properties LLC, Royce
Watsons private real estate agency Kennebec Realty LLC, and Greg Roys
professional assets including all remaining funds from $140,000.00 in public money
Greg received from the City of Augusta and Maine Judicial Branch for sale of 32
Court Street in the event GinA obtains a favorable judgment against any one or
more of the Defendants on any one or more of her counts.
GinA requests all proper relief against each individual human Defendant in
their individual capacities as authorized by 18 USC 241 & 242 and 42 USC
3631.
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Venue is proper in the District of Maine under 28 USC 1391(b).

All Defendants are located and residing in Maine, and all events, actions and
omissions giving rise to this claim occurred in Maine.
III.
STATUTORY AUTHORITY
42 USC 3613(b)(1) authorizes GinA to request a court-appointed attorney

who has never interacted with any of the Defendants or their co-conspirators which
GinA requests to be appointed as stand-by counsel only to advise her about federal
laws and rules of procedure.
GinA is authorized to bring suit pursuant to 42 USC 12209(6) & 12133
against any public entity or any person acting on behalf of any public entity who
discriminates against GinA by excluding her from participation in or be denied the
benefits of the services, programs, or activities of a public entity because GinA is
female, low income, has a permanent disability and has a history of being homeless.
GinA is authorized to initiate this action under 42 USC 3613(a) to bring a
civil action against any person who discriminates against, interferes with, coerces or
intimidates her in making fair terms, conditions, and privileges or otherwise makes
a dwelling unavailable because she is a member of four protected classes of people
based on her being known to be female, low income, disabled and homeless.
GinA is authorized to initiate this action under 42 USC 1981 to bring suit
against any person who impairs her equal rights or discriminates against her as a
disabled, low income homeless white woman under color of state laws to violate her
equal rights to make fair terms and enforce rental contracts for her constitutionally
protected property interests for 239 Cony Street, 3 Washington Street Place, and 32
Court Street Augusta and to enjoy the full and equal benefit of all laws and
proceedings for the security of GinAs person and property.
GinA is authorized to initiate this action under 42 USC 1983 to bring suit
against any person who subjects or causes her to be subjected to the deprivation of
any rights, privileges and immunities secured to her by the Constitution and laws
under color of state law.
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GinA is authorized to initiate this action under 42 USC 1985(2) and 1986
to bring suit against any person who conspires with any other person to deprive her
of federal rights under color of state law and against any person who, having
knowledge that any of the wrongs conspired to be done and having the power to
prevent or aid in preventing the commission of the wrongful action, neglects or
refuses to prevent such act which serves to violate GinAs federal rights as secured
by the Constitution and laws.
IV.
PARTIES
GinA
GinA is a white, never-married, single mother to her 28 yr. old daughter, and
a grandmother to GinAs daughters 5 yr. old daughter.
GinA has been financially self-sufficient since the age of 16, except between
2000-2005 when she lived with her now ex-fianc in his Readfield Maine home.
GinA is known to be a member of four classes of protected people in Maine:
(1) female, (2) low income, (3) disabled, and (4) homeless pursuant to 17-A MRSA
1151, sub-8, B, as enacted by PL 1995, c. 149, 1, effective August 23, 2006.
GinA has paid into the Social Security disability and retirement fund since
1985 which qualifies her to receive monthly Social Security disability benefits.
GinA has earned more than 80 college credits toward a Bachelors Degree in
Mental Health and Human Services at University of Maine at Augusta.
GinA has an extensive work history as a legal secretary for Maine law firms.
GinA worked at various Maine government agencies from 1994 until 2008.
GinA was last employed full time from January 2007 until April 2008 with
the State of Maine Bureau of Motor Vehicle OUI Unit.
GinA left her employment with State of Maine due to her disabilities.
GinA is known to be a woman with permanent physical and mental health
disabilities which substantially restrict her daily physical activities.
GinAs disabilities require her to have special housing to accommodate her
two service animals and her need to use medicinal cannabis for management of her
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post-traumatic stress disorder symptoms and severe back pain caused by scoliosis
and degenerative disc disease.
GinA is known to be a member of the low income community as evidenced by
her eligibility for and receipt of Medicare, MaineCare, SNAP and LIHEAP benefits.
GinA is eligible for but has never received Section 8 housing benefits.
GinA has always paid her own full fair market rents from employment wages
when she was working or from federal Social Security disability benefits.
Royce Watson owns 239 Cony Street, Augusta.
GinA lived at 239 Cony Street, Augusta from January 9, 2010 through March
1, 2012, being evicted by Leigh Saufley et al after GinA reported an active oil leak to
City of Augusta, William Stokes, William Bridgeo, and Matt Nazar.
GinA was homeless from March 1, 2012 until January 13, 2013.
Ray Corporation (Rob Ray and Matt Ray) owns 3 Washington Street Place.
GinA lived at 3 Washington Street Place, Augusta from January 13, 2013
through October 19, 2013, being evicted by Leigh Saufley et al after GinA reported
the building to City of Augusta and Matt Nazar as an illegal rooming house in June.
GinA was homeless from October 19, 2013 until January 22, 2014.
Greg Roy owned 32 Court Street, Augusta until October 29, 2014 when he
transferred legal title to Maine Governmental Facilities Authority.
GinA lived at 32 Court Street, Augusta from January 22 until September 26,
2014 being evicted by Leigh Saufley et al because Defendants conspired to allow
tenant occupancy for only eight months without giving proper public FOAA/FOIA
warnings or disclosures.
GinA was homeless from September 26, 2014 through November 11, 2014.
GinA is currently living in a single family log cabin at 2528 West River Road,
Town of Sidney, County of Kennebec, which GinA bought with (Estate of) Wayne
Richard Leach from David Brennan on November 11, 2014.
GinA has not engaged in any prohibited acts that would disqualify her from
exercising all of her rights under 42 USC 3604(f) and any pertinent federal laws.
City of Augusta
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City of Augusta is a municipality and a body corporate and politic with an

address of 1 Cony Street, City of Augusta, County of Kennebec.
City of Augusta, its agents and elected officers are instrumentalities of the
United States by virtue of City of Augusta and its agents accepting federal funding
which requires it to enforce and follow all pertinent federal laws.
City of Augusta Police Department
City of Augusta Police Department is a government agency of the City of
Augusta with an address of 33 Union Street, City of Augusta, County of Kennebec.
City of Augusta All_Police
City of Augusta All_Police includes all individuals who have ever acted in
their official capacity as a police officer to any call or report involving GinA from
January 2010 until the present day, with specific mention of these individuals:
1. William Stokes (as Mayor/Chief Law Enforcement Officer for Augusta)
2. Jared Mills
3. Robert Gregoire
4. Christopher Shaw
5. Christopher Guay
6. Scott Harris
7. Peter Cloutier
8. Laura Drouin
9. Eric Lloyd
William Stokes
William Stokes lives at 21 Fairview Avenue Augusta.
William Stokes acted in a quasi-executive/quasi-judicial capacity as Chief
Deputy Attorney General, Criminal Division for Office of Maine Attorney General
during the course of events in this complaint until July 31, 2014.
William Stokes role as a Chief Attorney General of the Criminal Division of
Office of Attorney General gives him extreme power and influence over all persons
in Maine.
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William Stokes wife, Diane Doyen, is employed and acted as an Attorney

General with Office of Attorney General during the entire course of events outlined
in this complaint until the present day which effectually doubles William Stokes
political power inside and outside all government activities.
William Stokes acted as Chief Deputy Attorney General in September 2013
when he authorized his agent Tracy Thompson of the Consumer Protection Division
to formalize a criminal investigation into GinAs public legal advocacy activities.
William Stokes acted in an executive capacity as Mayor of City of Augusta
beginning June 16, 2011 until July 31, 2014.
William Stokes role as Mayor of City of Augusta gives him extreme power
and influence over all public agencies, individuals and businesses in Augusta.
William Stokes acted in an executive capacity as Mayor of City of Augusta
while he was acting in a quasi-judicial capacity as Chief Deputy Attorney General.
William Stokes engaged in official government activities as a public servant,
at least as Mayor of City of Augusta in 2014, to buy 32 Court Street on behalf of
City of Augusta for the Maine Judicial Branch.
William Stokes accepted Gov. Paul LePages nomination for a superior court
judgeship on or about May 7, 2014.
William Stokes recorded a $100,000.00 home equity loan on June 20, 2014.
William Stokes private Augusta home is currently valued at $205,100.00.
William Stokes was confirmed by Maine Legislature on July 31, 2014 as a
superior court judge to sit at the Capital Judicial Center, 1 Court Street, Augusta.
Matthew Pouliot
Matthew Pouliot lives at 99 Winthrop Street, Augusta which he bought on
November 1, 2013 for $72,000, valued at $162,900 with 3,082+/-sqft of living space.
99 Winthrop Street Augusta has a clear title, a recorded land patent, and
historical protections by the City of Augusta Historic Preservation Commission.
Matthew Pouliot owned at 14 Winthrop Court, Augusta beginning July 24,
2007 which is valued at $99,000.00 and has 2,398sqft of living space recorded in Bk
9438 Pg 195.
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Matthew Pouliot works as a licensed Realtor in the Augusta Maine area.

Matthew Pouliot was elected in December 2012 as a Representative for the
126th Legislature in District 86 for part of Augusta including 32 Court Street.
Matthew Pouliot was reelected to the 127th Legislature which he holds today.
Matthew Pouliots role as a Representative gives him extreme power and
influence over the City of Augusta, Maine Judicial Branch and all persons in Maine.
Matthew Pouliot served as Vice Chair of the City of Augusta Planning Board
from September 2009 until February 2013 during which time he directed talks on
the demise of 32 Court Street and a final location for the courthouse parking lot.
Matthew Pouliots wife, Heather Pouliot, served on the City of Augusta
Planning Board in 2014; she is currently a City of Augusta Planning Board member
until 2018 which doubles Matthews political power and influence in Augusta.
Matthew Pouliot serves as Board Director of the Augusta Housing Service
Corporation which is a 501(c)(3) non-profit corporation created by City of Augusta
Housing Authority in 1996 for the purpose of real estate development and creation
of programs that promote social and economic growth for persons of lower income.
(See http://augustahousing.org/?q=about/ahsc )
William Bridgeo
William Bridgeo is employed as Manager of City of Augusta, 1 Cony Street,
Augusta, County of Kennebec. William Bridgeo was appointed as City Manager by
the Augusta City Council in April of 1998 to serve as the chief executive officer and
purchasing agent of City of Augusta, exercise control over all departments and
divisions, make employee appointments and removals, and keep the City Council
fully advised as to the business, financial condition and future needs of the City of
Augusta, inter alia.
Matt Nazar
Matt Nazar is employed as Director of Development Services, City of
Augusta, 1 Cony Street, Augusta, County of Kennebec.
Matt Nazar oversees Keith Luke, Robert Overton, Gary Fuller, and other
employees in the Department of Development Services.
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Matt Nazar authorized Keith Luke to hold purchase negotiations with Greg
Roy for 32 Court Street at the same time Matt Nazar authorized Robert Overton to
officially approve occupancy at 32 Court Street for Unit 1 in January 2014, Unit 2
in February 2014, and two efficiency units on the second floor in June 2014.
City of Augusta, William Stokes, Matthew Pouliot (as a state legislator) and
William Bridgeo oversee and are jointly officially responsible for all activities of City
of Augusta Police Department and All_Police officers as well as Matt Nazar as the
Director of Development Services while Matt Nazar directs, supervises, approves,
enforces and defends all official activities of Robert Overton and Keith Luke in the
Code Enforcement Bureau, Economic and Community Development, Engineering
Bureau, Facilities and Systems Bureau, and Planning Bureau for City of Augusta.
City of Augusta, William Stokes, Matthew Pouliot, William Bridgeo and Matt
Nazar are jointly officially responsible for all official actions performed by Keith
Luke, Deputy Director of Development Services, who directly communicated with
Greg Roy to present City of Augustas official offer to purchase 32 Court Street on
behalf of Maine Governmental Facilities Authority and Maine Judicial Branch to
build the courthouse parking lot.
At the same time Matt Nazar authorized Robert Overton to give Greg Roy
official approval for Greg to solicit unsuspecting tenants to move into 32 Court
Street without any public warnings of the insanely noisy environment that would
make tenants living conditions unhappy and would then be kicked onto the street.
Royce Watson
Royce Watson lives at 94 Parkwood Drive, Augusta, County of Kennebec.
Royce Watson owns and acts a landlord for 239 Cony Street Augusta.
Royce Watson owns and acts a landlord for 170 units in Augusta as of
September 22, 2014. (See http://www.pressherald.com/2014/09/22/augusta-sessionsto-offer-training-in-mental-health-first-aid/ )
Royce Watson acts in his official capacity as a Licensed Real Estate Broker
for other homeowners in Augusta, Gardiner and statewide.
Royce Watson works full time as a licensed Realtor in Maine.
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Royce Watson owns and operates Kennebec Realty LLC in Augusta Maine.
Royce Watson knowingly acted as a government agent in conspiracy with and
on behalf of City of Augusta, City of Augusta All_Police Officers, William Stokes,
William Bridgeo and Matt Nazar during events regarding 239 Cony Street in this
complaint.
Royce Watson was titled one of the worst landlords in Augusta by Code
Enforcement Officer Robert Overton during conversations Robert had with GinA.
Gregory Roy
Gregory Roy lives at 389 Costello Road, Gardiner, County of Kennebec.
Gregory Roy owned and acted as a landlord, realtor, and builder for 32 Court
Street, Augusta, County of Kennebec.
Gregory Roy owned and operated more than two rental residential buildings
in Maine in 2014. Current data is unknown.
Gregory Roy works as a licensed Realtor in Maine.
Gregory Roy was sanctioned on November 16, 2006 by a unanimous vote of
the Maine Real Estate Commission for Gregs deceptive advertising behaviors.
Gregory Roy knowingly acted as a government agent since at least September
2012 on behalf of City of Augusta, William Stokes, Matthew Pouliot, William
Bridgeo and Matt Nazar during events regarding 32 Court Street in this complaint.
V.
CONSTITUTIONAL AND STATUTORY BACKGROUND
1st and 14th Amendments

1st Am. Congress shall make no law respecting an establishment of religion,
or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the
press; or the right of the people peaceably to assemble, and to petition the government
for a redress of grievances.
14th Am. Section 1. All persons born or naturalized in the United States, and
subject to the jurisdiction thereof, are citizens of the United States and of the state
wherein they reside. No state shall make or enforce any law which shall abridge the
privileges or immunities of citizens of the United States; nor shall any state deprive
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any person of life, liberty, or property, without due process of law; nor deny to any
person within its jurisdiction the equal protection of the laws.
The 1st and 14th Amendments combined with the 7th Amendment guarantee a
de novo trial by jury in state superior court during eviction actions as confirmed by
Pernell v. Southall Realty, 416 US 363 (1974) and other federal court precedents.
5 USC 105 - Executive agency
For the purpose of this title, Executive agency means an Executive
department, a Government corporation, and an independent establishment.
5 CFR 2635.101 Basic obligation of public service
(a) Public service is a public trust. Each employee has a responsibility to the
United States Government and its citizens to place loyalty to the Constitution, laws
and ethical principles above private gain. To ensure that every citizen can have
complete confidence in the integrity of the Federal Government, each employee shall
respect and adhere to the principles of ethical conduct set forth in this section, as well
as the implementing standards contained in this part and in supplemental agency
regulations.
(b) General principles. The following general principles apply to every
employee and may form the basis for the standards contained in this part. Where a
situation is not covered by the standards set forth in this part, employees shall apply
the principles set forth in this section in determining whether their conduct is proper.
(1) Public service is a public trust, requiring employees to place loyalty to the
Constitution, the laws and ethical principles above private gain.
(2) Employees shall not hold financial interests that conflict with the
conscientious performance of duty.
(3) Employees shall not engage in financial transactions using nonpublic
Government information or allow the improper use of such information to
further any private interest.
(4) An employee shall not, except as permitted by subpart B of this part, solicit
or accept any gift or other item of monetary value from any person or entity
seeking official action from, doing business with, or conducting activities
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regulated by the employee's agency, or whose interests may be substantially

affected by the performance or nonperformance of the employee's duties.
(5) Employees shall put forth honest effort in the performance of their duties.
(6) Employees shall not knowingly make unauthorized commitments or
promises of any kind purporting to bind the Government.
(7) Employees shall not use public office for private gain.
(8) Employees shall act impartially and not give preferential treatment to any
private organization or individual.
(9) [omitted for irrelevance to this complaint]
(10) Employees shall not engage in outside employment or activities, including
seeking or negotiating for employment, that conflict with official Government
duties and responsibilities.
(11) Employees shall disclose waste, fraud, abuse, and corruption to
appropriate authorities.
(12) Employees shall satisfy in good faith their obligations as citizens,
including all just financial obligations, especially thosesuch as Federal,
State, or local taxesthat are imposed by law.
(13) Employees shall adhere to all laws and regulations that provide equal
opportunity for all Americans regardless of race, color, religion, sex, national
origin, age, or handicap.
(14) Employees shall endeavor to avoid any actions creating the appearance
that they are violating the law or the ethical standards set forth in this part.
Whether particular circumstances create an appearance that the law or these
standards have been violated shall be determined from the perspective of a
reasonable person with knowledge of the relevant facts.
(c) Related statutes. In addition to the standards of ethical conduct set forth in
this part, there are conflict of interest statutes that prohibit certain conduct.
Criminal conflict of interest statutes of general applicability to all employees, 18
U.S.C. 201, 203, 205, 208, and 209, are summarized in the appropriate subparts of
this part and must be taken into consideration in determining whether conduct is
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proper. Citations to other generally applicable statutes relating to employee conduct

are set forth in subpart I and employees are further cautioned that there may be
additional statutory and regulatory restrictions applicable to them generally or as
employees of their specific agencies. Because an employee is considered to be on notice
of the requirements of any statute, an employee should not rely upon any description
or synopsis of a statutory restriction, but should refer to the statute itself and obtain
the advice of an agency ethics official as needed.
5 CFR 2635.601 - Standards of Ethical Conduct for Employees of the
Executive Branch
This subpart contains a disqualification requirement that applies to
employees when seeking employment with persons whose financial interests would be
directly and predictably affected by particular matters in which the employees
participate personally and substantially. Specifically, it addresses the requirement of
18 U.S.C. 208(a) that an employee disqualify himself from participation in any
particular matter that will have a direct and predictable effect on the financial
interests of a person with whom he is negotiating or has any arrangement
concerning prospective employment. See 2635.402 and 2640.103 of this chapter.
Beyond this statutory requirement, it also addresses the issues of lack of impartiality
that require disqualification from particular matters affecting the financial interests
of a prospective employer when an employee's actions in seeking employment fall
short of actual employment negotiations.
Americans with Disabilities Act
42 USC 12132. Discrimination
Subject to the provisions of this subchapter, no qualified individual with a
disability shall, by reason of such disability, be excluded from participation in or be
denied the benefits of the services, programs, or activities of a public entity, or be
subjected to discrimination by any such entity.
42 U.S.C. 12101 et seq.
The Americans with Disabilities Act prohibits discrimination on the basis of
disability in State and local government, public accommodations, commercial
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facilities, transportation, and telecommunications. Title II of the ADA prohibits

discrimination in publicly owned housing. Privately-owned housing is covered by the
Fair Housing Act
Title II covers all activities of State and local governments regardless of the
government entity's size or receipt of Federal funding. Title II requires that State and
local governments give people with disabilities an equal opportunity to benefit from
all of their programs, services, and activities (e.g. public education, employment,
transportation, recreation, health care, social services, courts, voting, and town
meetings).
The Fair Housing Act, as amended in 1988, prohibits housing discrimination
on the basis of race, color, religion, sex, disability, familial status, and national
origin. Its coverage includes private housing, housing that receives Federal financial
assistance, and State and local government housing. It is unlawful to discriminate
in any aspect of selling or renting housing or to deny a dwelling to a renter
because of the disability of that individual, an individual associated with the
renter, or an individual who intends to live in the residence. Other covered activities
include, for example, financing, zoning practices, new construction design, and
advertising. (See http://www.ada.gov/cguide.htm#anchor62335 )
The Fair Housing Act of 1968
42 USC 3601 - 3631
The Fair Housing Act declares it to be the policy of the United States to
provide, within constitutional limitations, for fair housing throughout the United
States. [See 42 U.S.C. 3601.] Congress considered the realization of this policy to be
of the highest priority. [See Trafficante v. Metro. Life Ins. Co., 409 U.S. 205, 211
(1972) (internal citation omitted).] The language of the Fair Housing Act prohibiting
discrimination in housing is broad and inclusive; [Id. at 209.] the purpose of its
reach is to replace segregated neighborhoods with truly integrated and balanced
living patterns. [Id. at 211.] In commemorating the 40th anniversary of the Fair
Housing Act and the 20th anniversary of the Fair Housing Amendments Act, the
House of Representatives recognized that the intent of Congress in passing the Fair
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Housing Act was broad and inclusive, to advance equal opportunity in housing and
achieve racial integration for the benefit of all people in the United States. [See H.
Res. 1095, 110th Cong., 2d Sess., 154 Cong. Rec. H2280-01 (April 15, 2008) (2008
WL 1733432).] (See https://www.federalregister.gov/articles/2011/11/16/201129515/implementation-of-the-fair-housing-acts-discriminatory-effects-standard)
Fair Housing Amendments Act of 1988

Disparate Impact
The Supreme Courts 5-4 ruling, argued on January 21, 2015 and decided on
June 25, 2015 in Texas Department of Housing and Community Affairs v. The
Inclusive Communities Project, Inc., No. 131371, focused on the disparate impact
portion of the Fair Housing Act of 1968, which prevents housing discrimination.
The Supreme Court ruled in Texas that a housing practice is discriminatory if
it has a disproportionately adverse impact on any group based on race, national
origin, color, religion, sex, familial status, or disability.
Disparate Treatment
Under the FHA, disparate treatment refers to housing practices that
intentionally treat similarly situated persons differently.[See Reinhart, 482 F.3d at
1229 (A disparate-treatment claim requires proof of differential treatment of
similarly situated persons or groups; the discrimination must be intentional.
(citations omitted)).] In other words, a practice qualifies as disparate treatment if it
applies rules to a protected set of people that are different from the rules that it
applies to others. [See Sharpvisions, Inc. v. Borough of Plum, 475 F. Supp. 2d 514,
523 (W.D. Pa. 2007) (Disparate treatment, under the FHA, may be shown by
demonstrating that a given legislative provision discriminates against the
handicapped on its face, i.e. applies different rules to the disabled than are applied
to others. (quoting Arc of N.J., Inc. v. New Jersey, 950 F. Supp. 637, 643 (D.N.J.
1996)))].
(See http://digitalcommons.law.lsu.edu/cgi/viewcontent.cgi?article=6488&context=lalrev )
the three-stage McDonnell Douglas/Burdine analysis applies to Fair
Housing Act cases. [See United States v. Badgett, 976 F.2d 1176, 1178 (8th Cir.
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1992)] However, the prima facie case under this analysis is an evidentiary standard
it defines the quantum of proof plaintiff must present to create a rebuttable
presumption of discrimination that shifts the burden to defendant to articulate some
legitimate, nondiscriminatory reason for its conduct. Under the Federal Rules of
Civil Procedure, an evidentiary standard is not a proper measure of whether a
complaint fails to state a claim. See Moore v. Clarke, 821 F.2d 518, 519 (8th Cir.
1987) (the whole spirit of the Federal Rules is to discourage the pleading of
evidence). When a federal court reviews the sufficiency of a complaint ... [t]he issue
is not whether a plaintiff will ultimately prevail but whether the claimant is entitled
to offer evidence to support the claims. Scheuer v. Rhodes, 416 U.S. 232, 236, 94 S.
Ct. 1683, 1686, 40 L. Ed. 2d 90 (1974). Bruce Ring, Plaintiff-Appellant, v. First
Interstate Mortgage, Inc.; Federal National Mortgage Association, DefendantsAppellees, 984 F.2d 924 (8th Cir. 1993)
42 USC 3617 - Interference, coercion, or intimidation
When Congress prohibited housing discrimination based on a disability, they
also outlawed interference, coercion or intimidation with enjoyment or exercise of
any fair housing rights, It shall be unlawful to coerce, intimidate, threaten, or
interfere with any person in the exercise or enjoyment ofany right granted or
protected by section 3604 of this title.
Embedded within those federal fair housing rights are the federal rights to
freedom of religion, press and expression under the 1st Amendment, right to enjoy a
trial by jury under the 7th Amendment, and due process rights under 5th and 14th
Amendments which extends to all federal, state, and local governments and their
official private and public government agents during performance of official duties.
42 USC 1981 Equal rights under the law
Racial Discrimination in Maine
Maine and Vermont are recorded as being the whitest states in the nation
with a combined population of approximately 1.8 million white people.
Congress originally enacted 42 USC 1981(a) Statement of equal rights to
protect people in minority groups from being discriminated against because of their
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race, color, national origin, ethnicity or religion, but Congress certainly did not
intend for 1981 to exclude white people from enjoying the same rights they were
guaranteeing minorities to have, as evidenced by Congress plain language of the
code itself which expressly extends the same equal protections to All persons
within the jurisdiction of the United States , not just to minorities or non-whites.
If Congress intended to forbid white people from exercising or enjoying their
equal rights under 1981 they would have clearly expressed that exclusion in the
Code which would serve to constructively ban most inhabitants of Maine and
Vermont from enjoying equal rights protections because the U.S. Census Bureau
constantly records both Maine and Vermont to have 95% white citizens.
Certainly, 1981 cannot be used to outlaw white people from exercising their
equal civil rights because Congress explicitly guarantees all persons within
theUnited States will enjoy the same rightas is enjoyed by white citizens;
thus, application of 1981 to exclude white people would be reverse discrimination
in violation of Congress non-discrimination policy, plain language and intent.
42 USC 1983 Civil action for deprivation of rights
Every person who, under color of any statute, ordinance, regulation, custom,
or usage, of any State , subjects, or causes to be subjected, any citizen of the United
States to the deprivation of any rights, privileges, or immunities secured by the
Constitution and laws, shall be liable to the party injured in an action at law, suit in
equity, or other proper proceeding for redress,.
42 USC 1985(3) Depriving persons of rights or privileges
If two or more persons in any State conspire for the purpose of depriving,
either directly or indirectly, any person or class of persons of the equal protection of
the laws, or of equal privileges and immunities under the laws; or for the purpose of
preventing or hindering the constituted authorities of any State from giving or
securing to all persons within such State the equal protection of the laws; in any
case of conspiracy set forth in this section, if one or more persons engaged therein do,
or cause to be done, any act in furtherance of the object of such conspiracy, whereby
another is injured in his person or property, or deprived of having and exercising any
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right or privilege of a citizen of the United States, the party so injured or deprived
may have an action for the recovery of damages occasioned by such injury or
deprivation, against any one or more of the conspirators.
42 USC 1986 Action for neglect to prevent
Every person who, having knowledge that any of the wrongs conspired to be
done, and mentioned in section 1985 of this title, are about to be committed, and
having power to prevent or aid in preventing the commission of the same, neglects or
refuses so to do, if such wrongful act be committed, shall be liable to the party
injured, or his legal representatives, for all damages caused by such wrongful act,
which such person by reasonable diligence could have prevented; and such damages
may be recovered in an action on the case; and any number of persons guilty of such
wrongful neglect or refusal may be joined as defendants in the action;
VI.
FACTUAL BACKGROUND
GinA presents the following sampling of pertinent facts in a successive

timeline of events which will show irrefutable evidence from public city and court
records of an ongoing criminal conspiracy between Defendants in this case and all
Defendants in GinA v. Leigh Saufley et al, 1:16-cv-00095-NT to maliciously deprive
GinA of her federal rights to receive fair housing and government services because
she is a low income disabled woman who has a history of being homeless and vocal
about the legal injustices that have occurred against her in her effort to have a safe,
affordable and peaceful low income rental home in Augusta.
Defendants conspiracy was intended to deprive GinA and did in fact deprive
GinA of her federal rights to equal protection of the laws as a disabled low income
woman with a history of homelessness under Title II of the ADA, the FHA and
FHAA, 1st and 14th Amendments inter alia, 42 USC 3601, 3604 and 3617.
Drivers Licenses, Disabilities and Evictions in Maine (FY10-FY15)
1.
City of Augusta, City of Augusta Police Department, City of Augusta
All_Police Officers, William Stokes, and Matthew Pouliot in Matthews role as a

public servant in the 126th and 127th Maine Legislatures, aggressively enforce 29-A
MRSA 1251. License required (1-A.) Residents required to obtain license.
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Within 30 days of becoming a resident of this State, a person shall apply to obtain a
license in accordance with section 1301.
2.
As Chief Deputy Attorney General of the Criminal Division, William Stokes
oversees and enforces 29-A MRSA 1251. License required (1-A.) and Maine
Bureau of Motor Vehicle Rules 29-250, Ch. 3. Physical, Emotional and Mental
Competence to Operate a Motor Vehicle which pertains to all Maine licensed drivers
and says in part:
1-A) The Secretary of State shall determine the physical, emotional, and
mental competence of a person to operate a motor vehicle with the advice of the
Medical Advisory Board and on the basis of the Functional Ability Profiles.
2-A) Medical conditions requiring report. Conditions for which a person
is required to submit a report to the Secretary of State include, but are not
limited to, neurological, cardiovascular, metabolic, musculoskeletal, visual,
emotional and psychiatric and substance abuse.
3.
Maines total 2015 population was 1,329,328 with 1,019,865 licensed drivers.
4.
More than 90% of Maines inhabitants are legally licensed to travel by car to
go to work, to maintain their homes and provide for their daily survival needs.
5.
Nearly 70 percent of Americans are on at least one prescription drug, and
more than half take two, Mayo Clinic and Olmsted Medical Center researchers
say. Antibiotics, antidepressants and painkilling opioids are most commonly
prescribed, their study found. Twenty percent of patients are on five or more
prescription medications, according to the findings, published online in the
journal Mayo Clinic Proceedings.
(See http://newsnetwork.mayoclinic.org/discussion/nearly-7-in-10-americans-takeprescription-drugs-mayo-clinic-olmsted-medical-center-find/)
6.
Mainers are dying at record rates from opioid overdoses. The vast majority of
Maines 272 drug overdose deaths in 2015 an all-time high were due to heroin,
fentanyl, prescription opioids or a combination.
(See http://www.pressherald.com/2016/03/16/doctors-back-legislation-to-curbopioid-prescriptions/)
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7.
PageID #: 144
About 350,000 Mainers were prescribed a total of 80 million opioid pills in
2014, according to the latest figures available from the Maine DHHS. Meanwhile,
about 15,500 people received treatment for opioid abuse at a state-sponsored
program in 2015, according to Maine DHHS. (Ibid.)
8.
350,000 Mainers [who] were prescribed a total of 80 million opioid pills in
2014 have drivers licenses because 95% of Maine inhabitants are legally licensed.
9.
Therefore, 350,000 Mainers [who] were prescribed a total of 80 million opioid
pills in 2014 made up 34% of the total Maine population with a drivers license.
10.
According to Robert O'Connell, director of legal affairs, adjudications and
hearings at the Bureau of Motor Vehicles, the general recidivism rate for OUI
offenses in 2012 was 26 percent(See
http://www.seacoastonline.com/article/20130426/news/304260392 )
11.
The latest data shows Maine BMV collected $30,595,950 in Class C license
renewal fees over the past six years totaling $5,099,325 per year taxpayer revenue
for Class C drivers licenses alone.
12.
Maine people live 43 people per sq. mile traveling across 30,843 miles to go to
work to provide for their families housing, financial and daily survival needs.
(See http://www.census.gov/quickfacts/table/PST045215/00,23 )
13.
OUI arrests are made for use of alcohol, street drugs, and legally prescribed
medicine regardless if it is taken according to or in conflict with doctors orders.

14.
Legal, financial and interpersonal penalties for OUI offenses are severe and
include several thousand dollars of out-of-pocket costs per individual per event plus
several months of psychiatric counseling, forced isolation from community, job loss,
public humiliation, family estrangements, emotional injuries and homelessness.
15.
To his critics, [Maine Governor Paul] LePages decision to bypass the

Waltham, Mass., meeting [about the surge in opioid overdoses] struck them as
combative business as usual for a governor who, alone in New England, is
emphasizing law enforcement over treatment as a response to the drug crisis.
While other governors have called for hefty increases in funding for treatment,
LePage called for $2 million to hire 14 drug agents, four judges, and four
prosecutors to target a drug trade he said is ravaging the state.
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We must hunt down the dealers and get them off the streets, LePage said in
March when he proposed beefed-up enforcement.
The proposal foundered when LePage, at the 11th hour, would not agree with
Maines House of Representatives to scale back the package to 10 agents,
eliminate the judges and prosecutors, and keep $750,000 for treatment that
had been added in earlier negotiations, said Kathleen Newman, the governors
deputy chief of staff
(See
https://www.bostonglobe.com/metro/2014/07/06/maine-governorpaul-lepage-stresses-jail-not-treatment-way-win-drugwar/CZA4AAinGdjNLqt02WtgPJ/story.html
16.
Many [Maine] people dont want to take [pain] medicines, said Brent Scobie,
who oversees the program [for alternative pain management therapy at Acadia
Hospital in Bangor Maine]. They want to reduce, if not eliminate, them.
Launched in September 2012, the program served 54 patients from across the
state in its first year, Scobie said. Many of the patients saw improvements in
the severity of their pain, their ability to handle day-to-day life in spite of it,
and their level of psychological distress, he said. Attending once a week for
eight sessions, patients learn to understand the relationship between pain and
stress and how to monitor their thoughts and behaviors to better manage
symptoms.
Chronic pain patients in Maine are increasingly turning to such approaches,
due in no small part to changes in the states Medicaid program. In response
to legislation targeting the states opiate addiction problem, MaineCare, the
states version of Medicaid, in January 2013 began requiring chronic pain
patients to try alternative therapies and limiting their daily painkiller dosing.
The program also restricts patients to two weeks of opioid painkillers during a
year, unless a doctor justifies a longer treatment period.
As a result, MaineCare recorded a remarkable 30 percent drop since 2011 in
the number of recipients receiving prescriptions for opiate medications. The
reduction, for drugs such as OxyContin, Vicodin and hydrocodone, led to
savings of more than $1 million last year, according to Dr. Kevin Flanigan,
MaineCares medical director.
Im very pleased that MaineCares been able to take the lead and shift its
policy toward one that embraces what the evidence and the literature shows to
be more effective treatment of pain, Flanigan said. Weve been able to do that
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so far without negatively impacting those people who truly require opioids for
pain management. In short, I think our members are getting a higher level of
care today because those options are available to them.
(See http://bangordailynews.com/2014/02/27/health/mainecare-sees-30percent-drop-in-patients-on-prescription-opiates-with-new-emphasis-onalternative-therapies/ )
17.
Maine Judicial Branchs 2015 Annual Report shows court revenue for FY10
FY15:
18.
a.
decreased for traffic fines by 17% from $12,245,878 to $10,108,163
b.
decreased for court fines by 19% from $14,394,383 to $11,632,039
c.
decreased for surcharges by 12% from $7,361,827 to $6,419,581
d.
decreased for fees by 18% from $10,487,417 to $8,585,842.
Maine Judicial Branchs 2015 Annual Report shows court filings decreased or
remained stable across the board in all areas for FY10-FY15 except evictions.
19.
Maine Judicial Branchs 2015 Annual Report shows a 35% spike in district
court evictions for FY10-FY15:
20.
a.
FY10 4,717
b.
FY11 5,162
c.
FY12 5,352
d.
FY13 5,702
e.
FY14 6,076
f.
FY15 6,177
All Maine evictions from FY10 through FY15 were ordered in a Rule 80D
summary process pursuant to 14 MRSA 6001 6030-E with no discovery and

presided over by a single judge in a state district court.
21.
MRCivP 80D(b) Summons. The summons in forcible entry and detainer
actions shall bear the signature or facsimile signature of the judge or the clerk,
contain the name and address of the court and the names of the parties, be directed
to the defendant, state the day when the action is returnable, which shall be not less
than 7 days from the date of service of the summons;
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22.
PageID #: 147
MRCivP 80D(c) Complaint. The complaint for forcible entry and detainer
shall be filed no later than one day before the date of the hearing. which prevents a
tenant from obtaining and serving subpoenas to secure personal appearances and
sworn testimony from City of Augusta Code Enforcement Officers during any trial.
23.
MRCivP 80D(e)(1) Hearing Date. All forcible entry and detainer actions
shall be in order for trial on the return day.

24.
MRCivP 80D(f) Removal. There shall be no removal of forcible entry and
detainer actions, except as provided by statute.

25.
Maine Judicial Branchs 2011-2015 Annual Reports show no eviction trials
by jury occurred in superior court from FY10 through FY15.

26.
MRCivP Rule 80D(2) Appeal by Jury Trial De Novo.

(A) Notice of Appeal and Demand for Jury Trial. Either party may appeal to
the Superior Court by jury trial de novo on any issue so triable of right by
filing a notice of appeal as provided in Rule 76D. A party who seeks a jury
trial de novo shall include in the notice of appeal a written demand for
jury trial and shall file with the notice an affidavit or affidavits meeting
the requirements of Rule 56(e) and setting forth specific facts showing that
there is a genuine issue of material fact as to which there is a right to trial
by jury. Failure to make demand for jury trial with accompanying
affidavit or affidavits constitutes a waiver of the right to jury trial, and the
appeal shall be on questions of law only, as provided in paragraph (1) of
this subdivision.
27.
14 MRSA 6008. Appeal

1. Right to appeal. Either party may appeal on questions of law from a
judgment to the Superior Court as in other civil actions. Either party may
appeal on any issue triable by right by a jury to a trial de novo in the Superior
Court as provided in this section. The time for filing an appeal of the
judgment of the District Court expires upon the issuance of the writ of
possession pursuant to section 6005 or 30 days from the time the judgment is
entered, whichever occurs first.
2. Appeal by defendant; record; stay. When the defendant appeals, the
defendant shall pay to the plaintiff or, if there is a dispute about the rent, to
the District Court, any unpaid portion of the current month's rent or the rent
arrearage, whichever is less. The District Court shall promptly transmit the
record and any such payments to the Superior Court without waiting for the
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preparation of a transcript of recorded testimony. The Superior Court may

stay the issuance of a writ of possession pending disposition of the appeal.
A. The Superior Court shall condition the granting and continuation of
the stay on the defendant's payment of rent for the premises as required
by this subsection at the time of appeal and on payment of any rent that
has accrued since the filing of the appeal to the plaintiff or, if there is a
dispute about the rent, into an escrow account to be administered by the
clerk of the Superior Court. Upon application of either party, the Superior
Court may authorize payments from the escrow account for appropriate
expenses related to the premises. The appeal decision or an agreement of
the parties must provide for the disposition of the escrowed rent.
B. The Superior Court may condition the granting and continuation of the
stay, in appropriate cases, on the defendant's agreement to refrain from
causing any nuisance or damage.
3. Vacation of stay; security; remedial order. Upon finding a
violation of the conditions for granting the stay, the Superior Court shall
vacate the stay and may issue a writ of possession. The Superior Court may
require the plaintiff to provide security as may be necessary to protect the
defendant's interest while the appeal is pending. If the defendant prevails, the
Superior Court may issue a remedial order as necessary to make the defendant
whole, including damages.
4. Claim of title. In disputes involving a claim of title, the District Court
may provide for discovery on an expedited schedule.
5. Security. For the purposes of this section, "security" may include a
bond, an escrow account, a lien, a mortgage, an order to make payments under
a lease or contract as they become due or any other financial protection as is
reasonably necessary to protect the interests of a party. The District Court and
the Superior Court may make any necessary orders with respect to the
provision of security, revise the orders when required by the interests of justice,
sanction a party for failure to comply with a security requirement and waive
or modify the requirement of security for good cause shown and recited in an
order.
6. Affidavit required. A notice of appeal filed by the defendant must be
accompanied by an affidavit stating the defendant has complied with the
requirements of subsection 2 regarding the payment of rent.
28.
14 MRSA 6008(2) requires
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When the [tenant] appeals, the [tenant] shall pay to the [landlord] or,
if there is a dispute about the rent, to the District Court, any unpaid portion
of the current month's rent or the rent arrearage, whichever is less
29.
Rep. Matthew Pouliot, R-Augusta, said In some of these cases, its evident
that theres a major problem in the buildings, but tenants dont have many
resources, so they move in anyway, Pouliot said.
Just because someone is poor doesnt mean they have to live in substandard
housing, he said
However, the problem of bad housing, he said, is getting dire in the city.
People call Augusta disgusta, and a lot of it has to do with the buildings they
see when they drive around town, he said. And they are disgusting in many
cases.
(See http://www.centralmaine.com/2013/10/07/augusta-lawmaker-wantsmaine-renters-to-get-three-days-notice-before-having-to-move/ )
GinAs History with Defendants since 2007
30.
GinA was a lifetime tenant in Augusta Maines low income community since
she was 16 years old until September 26, 2014.

31.
GinA worked her last full time job in the elite Maine BMV, OUI Unit from
January 7, 2007 until April 2008 when she left her job because of her disability.
32.
In 2007 Maine BMV, OUI Unit was operated by 8 employees who served all
persons charged with OUI and other serious driving offenses on Maine roads.
33.
GinAs official responsibilities included, but were not limited to:

a.
b.
c.
d.
e.
f.
g.
receiving, reading and confirming every OUI police report had all
required legal cues for arrest in Maine,
communicating with all police officers to correct deficient police reports,
properly suspending drivers licenses for OUI, habitual offenses and
other serious driving offenses,
communicating directly with clerks of all courts in the United States,
all drivers, community programs and government agencies,
confirming all reinstatement requirements were met,
ensuring accuracy of each driver record before restoring licenses, and
other necessary duties.
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34.
PageID #: 150
GinAs six month employment probation performance evaluation in July 2007
with BMV OUI Unit shows GinA received 3 letters of praise from her customers and
directors for exemplary interpersonal communication and customer service skills
and her high aptitude with learning complex laws, rules, and civil procedures.
35.
In April 2007, GinA submitted a formal proposal to her direct supervisor,
Laurie Carrier, suggesting BMV can reduce OUI recidivism and other violation
rates by changing its internal policies in the following ways:
a.
b.
c.
36.
distribute public information fliers about commuter and transportation

services to all registered licensees in Maine in every piece of BMV postal
mail,
expand the GoMaine Commuter Connections carpool and vanpool
services to provide safe, reliable transportation to people who are
serving OUI and other type of license suspensions, and
offer a work-restricted license to all suspended licensees.
Laurie Carrier endorsed GinAs proposal and submitted it to Senior Section
Manager Linda Grant who sent it through the proper chain of command with full
endorsement by all department heads.
37.
Deputy Secretary of State delivered GinAs proposal to Secretary of State
Matthew Dunlaps office in June 2007.

38.
Secretary of State Matthew Dunlap completely disregarded GinAs proposal.
39.
Matthew Dunlap disregarded GinAs proposal to offer public information to
all licensees about state-funded public transportation services which aggravates an

actual barrier for disabled, low income and homeless people across Maine who need
to benefit from and participate in all government transportation services so they
can get to work as protected by Title II, ADA and Fair Housing Amendments Act.
40.
GOMAINE Commuter Connections is a statewide, state-funded and state
operated commuter program sponsored by the Maine Turnpike Authority and

Maine Department of Transportation. (See http://www.gomaine.org/about/ )
41.
In September 2005, under dictates of Motor Vehicle Rules 29-250 Ch. 3, GinA
reported that she was prescribed pharmaceuticals by her doctor for her disability.
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42.
PageID #: 151
BMV classified GinAs disability according to the "Functional Ability Profiles"
as Level 3a, Active Impairment, Minimal. requiring a standard progress report at

4-year intervals, with the first scheduled for September 2009.
43.
In August 2006, GinA eliminated all prescribed pharmaceutical and over-the-
counter medicines from her life using only medical cannabis to relieve her pain.
44.
BMV records show the Medical Unit required GinA to surrender to a medical
evaluation in November 2009 due to medications she had been prescribed in 2005.
45.
There is no factual dispute GinA did not receive BMVs requests for a medical
evaluation because GinA was homeless and did not have a mailing address.
46.
Maine Bureau of Motor Vehicles issued GinA violation free credits for years
2008, 2009 and 2010 (issued on March 8, 2011).

(See AUGDC-CR-2011-512, AUGDC-CR-2011-513, AUGSC-CR-2012-286,
AUGSC-CR-2012-667, inter alia).
47.
BMVs November and December 2009 requests for medical evaluation
addressed to GinA were both returned to BMV by USPS as undeliverable.

48.
On January 5, 2010 Maine Bureau of Motor Vehicle Medical Unit suspended
drivers license #1491178 without any good or legal cause for GinAs inability to
comply with the medical evaluation which was directly related to GinAs disability.
49.
On January 5, 2010, BMV suspended driver license #1491178 without a
hearing under 29-A MRSA 2458(2)(D) Is incompetent to drive a motor vehicle.

50.
GinA did not know license #1491178 had been suspended for a medical
reason on January 5, 2010 until Augusta Police Ofc. Eric DosSantos told her on
February 10, 2011 during the traffic stop at Townsend Road and Marketplace Dr.
51.
GinA told Augusta Ofc. Eric DosSantos he had no probable cause of criminal
conduct to make a traffic stop but he continued to infringe the 4th Amendment by
issuing a violation summons and complaint for failure to obey traffic control device.
52.
Almost exactly one month later on March 7, 2011, Augusta Police Ofc. Eric
DosSantos stopped GinA at the exact same place on Marketplace Drive at the exact
same time as the February 10, 2011 traffic stop because he knew license #1491178
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was suspended by the BMV Medical Unit for an unknown medical reason and he
knew GinA worked at Dunkin Donuts inside WalMart around that time of day.
53.
GinA denied having any knowledge of a license suspension and denied having
any medical issues which would cause the Medical Unit to suspend the license.
54.
Augusta Ofc. Eric DosSantos asked directly with GinA declining knowing
about any medical issues that would cause BMV Medical Unit to suspend the driver
license #1491178 in 2010.
55.
Augusta Ofc. Eric DosSantos proceeded to issue two uniform summons and
complaints for operating after suspension with violation dates February 10, 2011
and March 7, 2011 both occurring on Townsend Road and Marketplace Drive. (See
AUGDC-CR-2011-512 and AUGDC-CR-2011-513)
56.
Augusta Ofc. Eric DosSantos knowingly stripped GinA of her ability to travel
in her own car to her job at Dunkin Donuts inside WalMart.

57.
GinAs inability to transport herself caused GinA to have to quit her job.
58.
GinA has not worked in the local community since she quit Dunkin Donuts.
59.
GinAs inability to get a job inhibits GinAs ability to maintain a safe home.
60.
GinAs inability to transport herself in her own car so she can maintain a job
and a safe home caused her to be chronically homeless from 2012 through 2014.
61.
GinAs inability to transport herself in her own car interferes with GinAs
ability to eat, interact with friends and family, receive public services, and access
the courts to redress her legal grievances with her government and private persons.
62.
GinAs demands for a jury trial in her eviction cases are always denied.
63.
GinAs steady defense of state court evictions has given state judges, clerks,
government agents, landlords, and their attorneys limitless reasons to hold negative
biases and to illegally discriminate against GinA.
64.
Most of GinAs evictions were baseless, punitive and discriminatory.
65.
GinAs recent history of homelessness was caused by Defendants separate
and joint conspiracies in their individual and official capacities:

a.
March 1, 2012 until January 13, 2013,
(See Watson v. Turcotte, AUGDC-SA-2011-___)
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b.
PageID #: 153
October 19, 2013 until January 22, 2014,
(See Ray Corp. v. Turcotte, AUGDC-SA-2013-332 and AP-13-35)

c.
September 26, 2014 until November 11, 2014,
(See Roy v. Turcotte, AUGDC-SA-2014-453, AP-14-56, KEN-14-410,

1:15-cv-00031-NT; and Turcotte v. Roy, KEN-CV-14-176)
66.
On or about January 9, 2010, GinA moved into 239 Cony Street Unit 2.
67.
GinA had no problems with Royce Watson or the tenants for over a year.
68.
On February 10, 2011, Augusta Police Ofc. Eric DosSantos stopped GinA for
failure to obey traffic control device on Townsend Rd and Marketplace Drive and
issued a ticket for a minor traffic violation. (See Violations Bureau Tckt # 21576761,
AUGDC-CR-2011-512 and AUGDC-CR-2011-513)
69.
On March 7, 2011, City of Augusta Police Ofc. Eric DosSantos stopped GinA
as a direct result of his February 10th stop because he knew license #1491178 was
suspended for medical reasons and asked GinA if she had any medical issues that
would cause the BMV Medical Unit to suspend license #1491178.
(See AUGDC-CR-2011-512 and AUGDC-CR-2011-513)
70.
Ofc. Eric DosSantos issued two uniform summonses for Operating After
Suspension even though he knew the suspension was a medical suspension and
not considerable as a prior offense for operating after suspension charges.
(See AP-13-17 and KEN-13-517)
71.
On March 8, 2011, BMV License Services printed LS-LT-08 for driver license
#1491178 stating,
1.
Your privilege(s) to operate/apply for a motor vehicle operators license in

the State of Maine has been restored as of March 8, 2011 03:36:00 PM.
2.
The suspension(s) listed below have been deleted from your record:
January 5, 2010, FAILURE TO COMPLY WITH MEDICAL
EVALUATION REQUEST.
72.
On April 17, 2011 the basement at 239 Cony Street, Augusta flooded from
excessive rain runoff from the Haskell Street hill overwhelming the oil burner and
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causing it to send carbon monoxide into the building forcing GinA to make a 911
call to City of Augusta Fire Department for emergency assistance.
73.
City of Augusta Fire Department attempted but could not communicate with
Royce Watson because Royce refused to answer his cell or house phone on that day.
74.
In July 2011, sand fleas invaded GinAs apartment causing her to ask Royce
Watson to properly eradicate the fleas which Royce repeatedly refused to do.
75.
Royce Watson blamed GinA and her service animals for the flea infestation.
76.
From July through the entire month of August 2011, GinA and Royce Watson
engaged in very combative interactions via text and email regarding Royces refusal
to eradicate the sand fleas in the building.
77.
August 13, 2011, KJ article Big step to new county courthouse says,
In October 2009, MSJC CJ Leigh Saufley projected a $55 million new
building to include consolidated superior and district courts and officesHowever,

its taken longer than expected to secure the property
78.
On September 1, 2011, Royce Watson moved Jack Alahverdian into 239 Cony
Street, Unit 1.
79.
Jack Alahverdian told GinA he was Royce Watsons maintenance manager
and that Royce Watson had used Jack Alahverdian to maintain other buildings.
80.
Between Sept 1 28, 2011, GinA made more police reports to Augusta
Police Department for Emergency 911 help with Jack Alahverdians

violence than GinA had ever called the police department in the past.
81.
Throughout the month of September 2011 and until GinA moved out of 239
Cony Street on March 1, 2012, City of Augusta Police and Royce Watson maliciously
interfered with GinAs quiet enjoyment by allowing Jack Alahverdian to maintain
extremely loud music with several surround sound stereo speakers and a subwoofer
mounted on his apartment walls which police officers personally observed vibrated
all walls and windows causing GinA to suffer extreme physical and mental duress.
82.
In late September 2011, after GinA repeatedly demanded Augusta Police
Department prohibit Jack Alahverdian from torturing GinA with his extremely loud
music, an Augusta Police Officer gave GinA a Notice under 17-A MRSA 506-A
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PageID #: 155
even though the officer knew a police officer is required to serve the notice and then
directed GinA to serve it on Jack Alahverdian to cease and desist his harassment.
83.
GinA never served the notice because she knew police are required to serve.
84.
On September 28, 2011, Tim Cason and GinA smelled oil in the air so they
got permission from Jack Alahverdian to enter the basement discovering an oil leak
from the oil tank causing GinA to report the oil leak to Jack Alahverdian.
85.
GinA asked Jack to report the oil leak to Royce Watson because Royce was no
longer talking to GinA as a result of the flea problem.

86.
On September 30, 2011, 8:30am Royces heating and plumbing contractor
2Johns trespassed on GinAs home by opening GinAs entry door and entering the
internal landing for the purposes of serving GinA with a Notice to Quit.
87.
Royce Watsons Notice to Quit claims Royce made two prior attempts to serve
it on September 29 even though Royce had not yet created the Notice to Quit until
September 30 at 8:20am.
88.
On September 30, 2011, 10:05pm, Jack Alahverdian said to GinA,

What the f*ck do you want? Just because you got served an eviction notice
doesnt mean I had anything to do with it.
89.
GinA had not told Jack that the plumber served her with an eviction notice
earlier that morning which information could have only come from Royce Watson
or Royces plumber who was acting under Royces direction and command.
90.
On September 30, 2011, 10:05pm GinA was threatened with bodily harm by
Jack Alahverdian to be committed by unknown third persons so GinA called Royce

Watson at October 1, 2011, 6:20pm, and reported Jack Alahverdian as a dangerous
tenant.
91.
City of Augusta Police know Jack Alahverdian has a long violent criminal
history including violating active court orders for protection from domestic abuse.
92.
On October 1, 2011, GinA called City of Augusta Police Department to report
Jack Alahverdians violent threats resulting in Ofc. Christopher Guay filing a false
police report under Incident #11002-2846-OF, Call #11-54462.
93.
City of Augusta Ofc. Christopher Guay twice named GinA as a suspect.
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94.
PageID #: 156
On October 3, 2011, GinA reported an environmental violation to U.S. EPA
on their website regarding the active oil leak occurring in the basement at 239 Cony
Street, Augusta Maine.
95.
GinA never received any type of response from USEPA or its subsidiaries.
96.
On October 25, 2011, GinA and Tim Cason reported the oil leak at 239 Cony
Street to City of Augusta Code Enforcement prompting Robert Overton to perform

an immediate inspection on that day.
97.
On October 25, 2011 around 3:45pm, Robert Overton called State of Maine
DEP to report an active oil leak at 239 Cony Street Augusta.

98.
On October 25, 2011 at 4:30pm DEP arrived at 239 Cony Street to conduct a
full inspection and immediate cleanup of the basement oil spill.

99.
DEP gave Royce Watson an official recommendation to replace the oil tank.
100.
Royce Watson refused to replace the oil tank in October 2011 because DEP
did not issue an official order.

101.
On November 2, 2011, Civil Deputy Sheriff Harry McKenney served GinA
with a Summons and Complaint for forcible entry and detainer for 239 Cony Street.
102.
During GinAs conversation she recorded Harry McKenney say most
landlords lie on their eviction papers by claiming service was attempted three
times in good faith when the landlord and Harry McKenney know it has not.
103.
Harry McKenney expressly said a well-known Augusta landlord regularly
falsifies his eviction notices.

104.
GinA showed Harry McKenney the legal defects in Royce Watsons Notice to
Quit but Harry McKenney served the illegal summons and complaint anyway.
105.
On November 18, 2011, GinA filed a 10-page sworn affidavit with City of
Augusta Police Department to correct Ofc. Christopher Guays false police report
filed in October 2011.
106.
On January 18, 2012, City of Augusta Police Ofc. Peter Cloutier and his
partner arrived at 239 Cony Street and knocked on GinAs door responding to Jack
Alahverdians official complaint about GinA exercising her rights under the 1st
Amendment to take video and audio recordings of public spaces.
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107.
PageID #: 157
GinA showed Ofc. Peter Cloutier respect and civility by entertaining his
illegal interrogation about exercising her 1st Amendment rights.

108.
After Ofc. Peter Cloutier confirmed GinA was home alone, he opened GinAs
apartment door under false pretenses claiming he couldnt see GinA through the
screen door even though both internal and external lights were turned on and his
partner didnt articulate having any difficulty seeing GinA.
109.
Ofc. Peter Cloutier forcefully entered GinAs internal entry without GinAs
permission or an invitation to search GinAs home for suspected marijuana.

110.
GinA told Ofc. Peter Cloutier she was recording the entire event on audio and
she showed him the device in her left hand.

111.
Ofc. Peter Cloutier said it was fine that GinA was recording his actions.
112.
GinA demanded that Ofc. Peter Cloutier leave her home multiple times.
113.
Ofc. Peter Cloutier expressly refused to leave GinAs home.
114.
Ofc. Peter Cloutier threatened to search GinAs home the easy way or the
hard way
115.
Ofc. Peter Cloutier attempted to climb the stairway to GinAs living space.
116.
GinA physically blocked Ofc. Peter Cloutiers body with her 120lb body when
he tried to climb the stairway to GinAs living space.

117.
GinA and Ofc. Peter Cloutier verbally sparred nose to nose on her stairway.
118.
Ofc. Peter Cloutier threatened to arrest GinA for refusing to allow his search.
119.
Ofc. Peter Cloutier demanded GinA allow him to search her private spaces by
telling GinA it was going to happen the easy way or the hard way
120.
GinA demanded Ofc. Peter Cloutier leave her home unless he had a search
warrant.
121.
Ofc. Peter Cloutier left GinAs home saying he would be back with a search
warrant.
122.
Ofc. Peter Cloutier never returned, with or without a search warrant.
123.
GinA was never served with a search warrant by any City of Augusta Police
Officer to search 239 Cony Street on January 18, 2012 or thereafter.

1:16-cv-00100-NT
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PageID #: 158
124.
Despite a search warrant, GinA is a certified medical cannabis patient.
125.
On January 18, 2012, the moment Ofc. Peter Cloutier left 239 Cony Street,
GinA created and sent an email to Chief Robert Gregoire, other law enforcement,
government and private recipients with an attached file of the unedited raw audio
file with the true recorded interaction between GinA and Ofc. Peter Cloutier.
(See https://www.youtube.com/watch?v=w9pS5cEUorI )
126.
On January 19, 2012, GinA received an email from Deputy Chief Jared Mills
saying he initiated an internal investigation about Ofc. Peter Cloutiers behavior.

127.
On January 25, 2012, GinA and Tim Cason attended a personal meeting at
City of Augusta City Center to tell Sgt. Shaw the same details which GinA caught
on audio recording on January 18, 2012 when Ofc. Peter Cloutier invaded her home.
128.
On February 16, 2012, City of Augusta Ofc. Christopher Guay made an
unconstitutional traffic stop on GinAs private automobile without any probable

cause. (See AUGSC-CR-2012-286 and 1:16-cv-00095-NT)
129.
On February 21, 2012 at 2:45pm, GinA received an official written apology
from Major Jared Mills on behalf of City of Augusta Police Department about Ofc.
Peter Cloutiers illegal forceful invasion of GinAs home on January 18, 2012:
Gina,
On January 18th 2012, Officers Cloutier and Drouin met with you in
response to a complaint they received from your neighbor. During the course of
their investigation Officer Cloutier began to question you in reference to the
odor of marijuana he believed he smelled coming from your apartment. You
filed a complaint with the Chief of Police in regards Officer Cloutier's
behavior during this incident. Sergeant Shaw investigated the incident and
determined that Officer Cloutier did in fact act inappropriate in regards to his
demeanor, and the way in which he questioned you. Due to the fact that
Officer Cloutier's behavior was unprofessional, sanctions have been taken
against him and his behavior has been corrected. I want to apologize on behalf
of Officer Cloutier and the Augusta Police Department for this unfortunate
situation you had to endure. Thank you for bringing this incident to our
attention, and please contact me if you have any issues with the Augusta
Police Department in the future. If you have any questions or if you would like
to discuss this situation in person or by telephone please let me know and I
will make myself available upon your request.
Major Jared Mills
Augusta Police Department
1:16-cv-00100-NT
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130.
PageID #: 159
On February 23, 2012, GinA attended a City of Augusta City Council meeting
to notify the City of Augusta council and its agents that an active oil leak was
occurring at that moment at 239 Cony Street and that GinA was being evicted as a
direct result of making a report of it to the US EPA, DEP and Code Enforcement.
131.
GinA expressly asked City of Augusta City Council, William Stokes, William
Bridgeo and their agents to take proactive steps to remedy the oil leak and prevent
the illegal eviction from 239 Cony Street, Unit 2.
132.
City of Augusta, William Stokes and its agents refused to remedy the oil leak
or prevent the illegal eviction.

133.
On February 28, 2012, GinA was served by sheriff with an illegal Writ of
Possession issued by Augusta District Court.

134.
GinA took the writ of possession to the Kennebec Journal and asked Betty
Adams to help remedy the active oil leak that was poisoning the neighborhood and
to help prevent GinAs illegal eviction.
135.
Betty Adams and the Kennebec Journal declined to help GinA in any way.
(See https://www.youtube.com/watch?v=EEtKKWbxlQ4 )
136.
Royce Watson and David VanBaars, Esq. spent six months evicting GinA in
conspiracy with Leigh Saufley et al. with a writ of possession expiring on March 1,
2012.
137.
Royce Watson replaced the oil tank at 239 Cony Street on March 29, 2012.
138.
GinA was homeless from March 1, 2012 until January 13, 2013 when she
moved into 3 Washington Street Place, Augusta.

139.
July 9, 2012, KJ article Courthouse expansion has Tuesday hearing

The [Planning] boards approval would give the proposed [courthouse] project
green light to proceed pending a zoning change which is up for public hearing
by City Council at its July 19 meeting.The zone was changed several years
ago to business professional to accommodate a courthouse expansion.
140.
August 20, 2012, KJ article Augusta courthouse work promises traffic
disruptions
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PageID #: 160
A judge, the project manager and the court construction overseer roughed out
a construction schedule and its effect at a meeting last week for judges,
lawyers, clerks and others who work in the county-owned courthouse at
Winthrop and State Streets.
vibration and noise from construction will affect both operational and
administrative functionsthe delivery of justice will clearly be impacted
during those high-noise periods ~ Superior Court C.J. Thomas Humphrey
141.
September 26, 2012, KJ article Courthouse construction noise drives trial
from Augusta to quieter Farmington

[Judge Michaela] Murphy had to repeat herself several times
142.
On January 13, 2013, GinA moved into 3 Washington Street Place with a
belief GinA was renting a single room in a legal, safe and decent rooming house.
143.
On or about January 18, 2013, GinA made her first complaint for theft and
violence to Ray Corporation by GinAs roommate Tyler Robinson.

144.
City of Augusta Police know Tyler Robinson to be a violent, drug-addicted liar
who beats on women and commits armed robbery on private homes.

145.
Rob Ray, Matt Ray, Justin Ray, and Cody Degraf all conspired with Tyler
Robinson because hes a man.

146.
Ray Corporation agents never took any steps to stop or prohibit Tylers daily
theft, violence and extreme aggression against GinA and Tylers live-in girlfriend.
147.
January 26, 2013, KJ article, Court construction projects neighbors endure
noise, shaking with good humor,

The front porch of the apartment building at 32 Court St. offers a great view
of the construction site of a new courthouse bordered by Winthrop, Perham
and Court Streets. The tenants in the seven-unit building, and other nearby
households, get to hear and feel the construction, as well. They rock to the
rhythm of 276 piles being pounded into bedrockThey hear the beep, beep,
beep of the trucksWork begins at 7a.m. and ends at 5p.m
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PageID #: 161
I dont have to set my alarm clock any more in the morning, said Rep. Matt
Pouliot, R-Augusta, who lives on Winthrop Court, within sight of the project.
Pouliot is on the citys Planning Board and saw the project proposal in its
initial stages.
the constant racket has gotten to Shannon Perkins, who has lived in an
apartment at 32 Court St. for about a year. Its insanely noisy, she said, which
is a particular problem during her childrens nap time.
Scott Theriaulttook a more philosophical approachWe all pretty much
know theres nothing we can do about it
Gregory Roy, owner of 32 Court St, and a Realtor affiliated with the Maine
Real Estate Network, said the fallout from the courthouse construction has
done some damage to the occupants psyche. I believe it may have resulted
in some unhappy tenants Its easy enough to find new tenants; its just
making the living conditions unhappy
Some $62 million in bonds were authorized to pay for the Augusta
courthouse Its coming in under budget, and on target to be under budget,
[Philip] Johnston said.
148.
In March 2013, City of Augusta Code Enforcement closed 32 Court Street.
149.
On May 1, 2013, City of Augusta Code Enforcement sent an official letter to
Ray Corporation regarding unsafe conditions at 1 & 3 Jefferson Street.

150.
On June 1, 2013, GinA informally created MAINE TENANTS JUSTICE
LEAGUE, Inc. for the purpose of educating tenants and landlords about their legal
rights and responsibilities to each other, to connect them with public legal resources
and to provoke legislative changes.
151.
On June 3, 2013, GinA emailed a Notice of Claim to Ray Corporation for the
injuries and other violations which were occurring at 3 Washington Street Place.
152.
On June 3, 2013, 11:20am, an official public email was sent from Detective
Sergeant Matthew Clark to City of Augusta All_Police,

This morning a [sic] received a call from Gina Turcotte. She and several
other tenants at 3 Washington Street Place, [sic] are very upset that Scott Andrews (a
registered sex offender) moved in the building over the weekend... She has voiced her
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PageID #: 162
plans to make life difficult for the landlord, as well as Andrews. I have cautioned her
about harassment, and told her to try and work things out with the landlord. After
taking [sic] with her, I believe that she understands our legal limitations here. FYI,
in the event that we get called there to deal with an issue there. [sic] I have drawn a
call number detailing her complaint so we have it on file.
***One thing of interest with Turcotte is that she has tried using the Sovereign
citizen standing with us in the past and is now looking for each and every law she
can use to get Andrews out of her home. Double standards?
153.
On June 3, 2013, 12:44pm, Chief Robert Gregoire sent an email to William
Bridgeo,
FYI, If you dont remember Ms. Tourcotte [sic] I can refresh your memory.
154.
June 3, 2013, 2:02pm, William Bridgeo sent an email to Chief Robert
Gregoire,
No refresher required.. [emphasis added]
155.
On June 7, 2013, GinA made an official report to Code Enforcement Officer
Robert Overton regarding the illegal rooming house at 3 Washington Street Place
which provoked Rob Overton to conduct an immediate partial inspection.
156.
On June 7, 2013, 11:53am, Code Enforcement sent an email to Ray
Corporation,
It appears that you are renting this building as a rooming houseThis
building is not permitted by the city to be used as a rooming house.
157.
On June 7, 2013, 4:58pm Matt Nazar sent an email to William Bridgeo,

Ms. Turcotte is the woman we spoke with at a Cony Street address last year.
158.
On June 16, 2013, 12:13am GinA sent an email to Robert Overton,
We are all on the verge of homelessness if Ray Corporation buildings are shut
down. And we are all living in these buildings because we have no other place to go.
I am here because of Royce Watsons illegal and retaliatory actions
There are many people who will certainly end up on the street if Ray
Corporation wiggles out of their responsibility on the heels of their criminality. I am
hoping that your office will support our efforts to find safe housing without causing
each of us undue financial hardship above and beyond the injuries the landlord has
already caused us.
1:16-cv-00100-NT
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159.
PageID #: 163
On June 19, 2013, 10:43pm, GinA sent an email to Robert Overton,

Ray Corporation has not respectedyour order to cease and desist renting
their Augusta buildings as rooming houses, as evidenced by them
RENEWING their craigslist ad on June 18 at 9:09am, which you can find
here: http://maine.craigslist.org/roo/3878356274.html [sic]
160.
On June 20, 2013, Ray Corp. filed an eviction complaint against GinA. (See
AUGDC-SA-2013-332)
161.
On June 25, 2013, Robert Overton, City of Augusta Fire Department and Rob
Ray of Ray Corp conducted a full building inspection of 3 Washington Street Place.
162.
On July 9, 2013, Code Enforcement Officer Robert Overton issued Ray Corp.
an official violation notice for 3 Washington Street Place with many life-threatening
violations including occupants living in 3rd floor units without any 2nd emergency
exit or egress windows.
163.
On July 19, 2013, 4:55pm, GinA sent an email to Robert Overton,

Today (Saturday) at 1p, RAY CORPORATION (Cody) showed up on the
property to show Unit 4 to a prospective tenant. I confronted Cody with the
code enforcement letter and asked him to read it which he refused to do.
164.
On July 21, 2013, Augusta District Court held an eviction bench trial in Ray
Corp. v. Gina Turcotte, AUGDC-SA-13-332 issuing a judgment of forcible entry and

detainer claiming, Court finds Plaintiff overcame presumption of retaliation under
14 MRSA 6001(3).
165.
On July 22, 2013, 4:18pm, GinA sent an email to Robert Overton,

I have been told by the tenants on the 3rd floor (front) that they have been
told by Ray Corp. that they do NOT need to move out and that everything is
ok. FYI.
166.
On July 31, 2013, 10:10am, Robert Overton sent an email to Rob Ray
regarding 3 Washington Street Place,
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PageID #: 164
I spoke with an Augusta Police Officer yesterdayThey want me to put an

end to your buildings being used as rooming houses
167.
On August 26, 2013, 3:48pm, GinA sent an email to Robert Overton and Ray
Corporation,
Attached is a picture of a new hole in the porch of Unit 1 which occurred
today as a result of my stepping too hard on the rotting board on my porch
and which broke through with very little effort.
168.
On August 29, 2013, 10:16am, William Bridgeo sent an email to Council,
All_City_Department_Directors, All_City_Bureau_Heads,
Its clear that the entire topic of our citys substandard rental housing stock
must be discussed by Council this fall
169.
On August 29, 2013, 7:46pm, Cheryl Clukey sent an email to William
Bridgeo,
Im happy to hear that the council will address the substandard housing in
Augusta and will work to propose new ordinances to eliminate these shameful
housing situation [sic]. I have been in a few and I do not understand how they
pass city code. The large one on North St. in my neighborhood is a disgrace.
Thanks, Cheryl Clukey
170.
On September 10, 2013, 1:02pm Robert Overton sent an email to GinA with a
forwarded message dated September 4, 2013, 4:01pm from Robert Overton to Ray
Corporation re: 1 & 3 Jefferson Street and 3 Washington Street Place,
I received a call from a concerned tenant that recently signed a lease with
you. They were told that vacant units were ordered to not be occupied until
they conformed with minimum standards.
171.
On September __ 2013, William Stokes gave official approval in his capacity
as Deputy AG for Tracy Thompson to conduct a formal criminal investigation about

GinAs legal advocacy work with MAINE TENANTS JUSTICE LEAGUE, Inc.
172.
On or about September 19, 2013, Tracy Thompson called and asked GinA for
legal advice even though William Stokes and Tracy Thompson know GinA is not a
licensed attorney. (See https://www.youtube.com/watch?v=wnNg2-Px6Uo )
1:16-cv-00100-NT
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173.
PageID #: 165
On September 27, 2013, 10:28am, Jim Osier sent an email to Keith Luke
refusing to sell his home at 13 Perham Street, Augusta for the courthouse parking
lot My property is not for sale and I will not allow an appraisal of it!
174.
On October 2, 2013 3:11pm, Keith Luke sent an email to Jim Osier, I
appreciate that this is a difficult situation, which is one of the reasons that the city
(and not the state) has taken the lead on negotiations [sic] Perham Street
homeowners.
175.
On October 2, 2013, David Pare sent a public defamatory email to Rob
Overton at City of Augusta Code Enforcement office alleging GinA was giving free
legal advice:
Your buddy Gina is back at it again. She is now giving free legal advice! I
think Im going to use her for my next eviction. If she put this much effort
toward an actual career, she could be wealthy. I called Gina Turcotte. Lets
settle this one. www.mainetenants.org (See June 18, 2014 email from GinA to
Rob Overton)
176.
On October 4, 2013, Rob Ray of Ray Corp. shut off the hot water supply to the
entire building at 3 Washington Street Place padlocking the basement door to try to
prevent any tenants from making entry to turn it back on.
177.
On October 7, 2013, Matthew Pouliot was interviewed by the KJ in an article
titled, Augusta lawmaker wants Maine renters to get three days notice before
having to move,
Rep. Matthew Pouliot, R-Augusta, said he wants to bring clarity to landlordtenant responsibilities after cities and towns deem a building unfit for habitation
under code
In some of these cases, its evident that theres a major problem in the
buildings, but tenants dont have many resources, so they move in anyway, Pouliot
said.
Just because someone is poor doesnt mean they have to live in substandard
housing, he said
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Pouliot said the bills are an attempt to balance the needs of landlords who
want to get profit out of buildings and tenants who want good deals.
However, the problem of bad housing, he said, is getting dire in the city.
People call Augusta disgusta, and a lot of it has to do with the buildings they
see when they drive around town, he said. And they are disgusting in many cases.
178.
On October 7, 2013, Rob Ray, Matt Ray and their agents physically moved all
tenants, except for GinA, out of 3 Washington Street Place.

179.
Ray Corporation relocated all tenants at 3 Washington Street Place, except
for GinA, to other locations at Ray Corporations expense.

180.
On October 7, 2013 Robert Overton gave an interview to the KJ in the article
above,
Rob Overton, the Augusta code enforcement officer who has led the
crackdown, said to his knowledge, nobody has been left homeless after the closings
because the city and landlords have arranged for alternative housing.
Last week, the city closed two buildings at 1 and 3 Jefferson St., displacing 12
tenants in the buildings owned by the Lewiston-based Ray Corp. after finding
numerous code violations.
In that case, Overton said tenants were notified twice, but there was turnover
in the buildings between spring and fall.
When he issued that order in May, he said tenants were notified. But since
then, he said the Ray Corp. was operating the house against code as a boarding
home, so only two tenants living at the buildings last week were also there in May.
181.
On October 8, 2013, Rob Ray, Matt Ray, Justin Ray and Cody Degraf
boarded up every window and door except for GinAs personal windows and entry
door at 3 Washington Street Place.
182.
On October 11, 2013, 3:33pm, William Bridgeo sent an email to Matt Nazar,
Lon called me this afternoon. He told me he has someone who is interested in
Lon building an office building on the old Y site for lease. Lon would like to
have his brother David meet with us next week to discuss the matter (zoning
issues, etc)
1:16-cv-00100-NT
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183.
PageID #: 167
On October 16, 2013, Augusta District Court (Valerie Stanfill) ordered a writ
of possession against GinA for 3 Washington Street Place, Unit 1, Augusta.

184.
On October 18, 2013, 2:28pm, Robert Overton sent an email to City of
Augusta Police Major Jared Mills,

In the last few weeks, weve been working to get the tenants out of 3
Washington Street Place. As of today the only occupant of the building is Gina
Turcotte. We didnt push too hard to get her out due to the fact that she is
about to be evicted.
185.
City of Augusta public records for October 2013 show,
The houses [on Perham and 32 Court Street] have been appraised at $38,000,
$50,000, $85,000 and $110,000 for a total of $283,000. The City wants to help resolve
the parking issue with the new courthouse since it fought so hard to keep it
downtown. The best solution would be to purchase the 4 properties and build a
parking lot for at least 100 spaces. (See FOAA Response 001385)
186.
On October 30, 2013, Matt Nazar sent an email to Lon Walters and William
Bridgeo,
Several members, including one that lives no more than 50 feet from the Old
Y property, spoke very favorably about the possibility of redevelopment
187.
On October 30, 2013, 5:13pm, Lon Walters sent an email to Matt Nazar,
Matt, please pass along to the planning board members, especially the person
with big concerns, that they are all welcome to have the building design they think
best for the site. Just make the check in the amount of $1m.
188.
On November 21, 2013, GinA testified at an Augusta City Council meeting.

(See https://www.youtube.com/watch?v=WcXHB6-L7os )
189.
On December 12, 2013, GinA filed a formal complaint with the Board of
Overseers of the Bar against David Van Baars for his legal malpractice during Ray
Corp. v. Gina Turcotte, saying, in part,
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PageID #: 168
City of Augusta Code Enforcement has been in direct contact with Mr. Van
Baars since at least September 2012 about Ray Corporations noncompliance with
local ordinances and rules governing rooming houses
190.
On December 31, 2013, Kennebec Journal published GinAs letter to the
Editor as the Founder of MAINE TENANTS JUSTICE LEAGUE, Inc. expressing

her desire to work with City of Augusta, landlords and tenants to help fix the low
income housing crisis.
191.
On January 03, 2014, 5:36pm, GinA sent an email to Major Jared Mills, Sgt.
Chris Shaw, et al:

Dear Sgt. Shaw and Major Mills:
Now that I have properly disposed of the frivolous retaliatory OAS and
other criminal charges from February 16, 2012 with a full dismissal, I can
now turn my attention back to the aggressive, unprofessional and
unconstitutional incident with Ofc. Peter Cloutier from January 18, 2012.
I strongly believe these two incidents are directly correlated, with the
OAS arrest and subsequent court action being retaliation for my recording
and reporting Ofc. Cloutier's unprofessional conduct and publicizing it for the
world to see on YouTube (which currently has more than 1800 views).
https://www.youtube.com/watch?v=w9pS5cEUorI
After I had an hour-long investigative meeting with Sgt. Shaw on
January 25, 2012, Major Mills sent me an email on February 21, 2012, at
2:45pm which is restated below:
Gina,
On January 18th 2012, Officers Cloutier and Drouin met with you in
response to a complaint they received from your neighbor. During the course of
their investigation Officer Cloutier began to question you in reference to the
odor of marijuana he believed he smelled coming from your apartment. You
filed a complaint with the Chief of Police in regards Officer Cloutier's
behavior during this incident. Sergeant Shaw investigated the incident and
determined that Officer Cloutier did in fact act inappropriate in regards to his
demeanor, and the way in which he questioned you. Due to the fact that
Officer Cloutier's behavior was unprofessional, sanctions have been taken
against him and his behavior has been corrected. I want to apologize on behalf
of Officer Cloutier and the Augusta Police Department for this unfortunate
situation you had to endure. Thank you for bringing this incident to our
attention, and please contact me if you have any issues with the Augusta
Police Department in the future. If you have any questions or if you would like
to discuss this situation in person or by telephone please let me know and I
will make myself available upon your request.
Major Jared Mills
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PageID #: 169
Augusta Police Department

***
Major Mills indicated "sanctions have been taken against [Ofc. Peter
Clouter] and his behavior has been corrected" but I was never informed of
those specific sanctions or corrective actions. Additionally, nobody at the
Augusta Police Department has ever offered me any kind of remedial
compensation for "this unfortunate situation [I] had to endure"...
I strongly believe this situation with Ofc. Cloutier was not only very
unfortunate, but it was also the cause which compelled Ofc. Christopher Guay
to stop me a month later on February 16, 2012 without probable cause and
only because he was familiar with my car and he knew I recorded Ofc.
Cloutier's illegal behavior. I believe Ofc. Guay and other officers had seen the
USDOT signs on my car during their regular patrols along Cony Street
because my car was always parked very close to the road.
I lived at 239 Cony Street from January 25, 2010 until March 1, 2012.
Additionally, as a direct result of that frivolous and unconstitutional
traffic stop by Ofc. Guay on Feb. 16, 2012, I was physically assaulted by Sgt.
Shaw, Ofc. Guay and Ofc. Harris in their unlawful and unreasonably forceful
seizure of my car and my body, then imprisoning me for several hours, not to
mention the many injuries resulting from those actions which have persisted
ever since.
These are not just "unfortunate situations" which can be ignored; it
would be unwise to think these events have not impacted my life in very
significant ways for which the Augusta Police Dept. is directly responsible...
All criminal charges from Feb. 16, 2012 were dismissed on December
18, 2013 by A.D.A. Joelle Pratt and Judge Murphy. I am now going to
challenge all civil traffic infractions from that date as well.
I strongly believe the aggressive criminal prosecution and the Augusta
Police Department's willful destruction of and refusal to provide video and
audio evidence of the arrest all resulted directly from my interactions with
Ofc. Peter Cloutier in January 2012.
I believe the other Augusta police officers are extremely unhappy I
recorded Ofc. Cloutier acting unlawfully and I am now being aggressively
targeted as a violent "sovereign citizen" (a misnomer).
I have personally read the Maine Criminal Justice Academy's 2011
mandatory training manual regarding "sovereign citizens" and I know all
police officers are taught to believe and presume all "sovereign citizens" are
violent, gun-toting, deadly people suspected of carrying at least 1 gun and 1
sharp weapon at all times... also, the MCJA training manual indicates
"sovereign citizens" are considered to be "domestic terrorists" worthy of
heightened aggression and police action.
This type of stereotypical profiling violates my natural right to equal
protection, is unconstitutional, discriminatory, highly prejudicial and directly
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causes all officers to act with unreasonable aggression against peaceful people,
as I believe happened to me on February 16, 2012 and thereafter.
I strongly believe the formal education provided by MCJA and the
internal policies of the Augusta Police Department regarding "sovereign
citizens" have caused, and are continuing to cause an elevated risk of
unreasonably aggressive and unconstitutional behaviors by police officers
which is causing an elevated risk of physical, emotional and other types of
injury to peaceful people who are stopped or questioned without reasonable
suspicion or probable cause of committing a 'crime'.
I am extremely offended that I am being targeted by my public servants
who have sworn an oath to protect me simply because I assert my natural
rights as protected by the Maine Constitution and 17 MRSA 2931.
Unfortunately, it is now almost exactly 2 years after I was arrested by
your officers and I cannot even begin to express how severely my life has been
disrupted and injured by these unlawful, illegal and unconstitutional actions.
My life has been seriously injured, my rights have been grossly violated,
my liberty consistently threatened, and being physically and constructively
imprisoned by not being able to transport myself or leave my home without
"supervision" (by a chauffeur) since early 2012. I was forced to sell my car
because of the effect these charges had on my ability to use or financially
maintain my car. I was forced by subsequent circumstances to live in the
armpit of Augusta's ghetto on Washington Street Place (so I could afford my
rent and walk to the store), my family relationships have been directly injured
as a result of these actions and my emotional, mental and physical health has
also seriously deteriorated as a direct result of not being able to transport
myself or take care of myself the way I did before these frivolous charges were
lodged against me.
I have already expressed in writing to the State, via email on December
17, 2013, that I consider these actions to rise to the level of malicious
prosecution and am prepared to seek my proper redemption through the only
avenue available - the court system.
But I am coming to you first.
I know the police department, as well as each police officer, are required
to maintain a bond or an insurance policy intended to resolve these exact
unfortunate situations.
I also know that "discretionary immunity" and "qualified immunity"
does not apply when "(1) constitutional rights were violated, and (2) those
rights were so clearly established that reasonable [officers] would have known
that their specific actions transgressed those rights." Creamer v. Sceviour, 652
A.2d 110, 113 (Me. 1995)
I believe the incident from January 18, 2012 with Ofc. Peter Cloutier,
admonished by Major Mills' apology, evidently proves my "constitutional
rights were violated, and (2) those rights were so clearly established that
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reasonable [officers] would have known that their specific actions transgressed
those rights."
Also, combining Major Mills' decision about the January 18, 2012
incident with the full dismissal of all criminal charges for the February 2012
OAS arrest, I believe there is solid evidence to prove the existence of a direct
correlation between both incidents from January and February 2012.
This is a very serious situation which must be resolved immediately,
appropriately and fairly. I am a reasonable woman willing to negotiate a
reasonable settlement, but the Augusta Police Department must first decide if
they are going to accept responsibility for the unfortunate actions of their
officers.
I did notice that Ofc. Peter Cloutier's name is no longer listed on your
website as a Patrol Officer:
http://www.augustamaine.gov/index.asp?Type=B_BASIC&SEC={3D85517B
-4BA1-47B0-80C8-491D45625A4C}&DE={F0682F3D-E592-4EBD-A0BBF47EB42F3287}
Does this obvious omission signify Ofc. Peter Cloutier has been
terminated from your employment and relieved of his police authority?
Please respond in writing within 7 business days with a request for a
meeting or an offer of settlement.
Thank you for your priority attention to this matter.
In Peace,
GinA Turcotte
192.
On January 3, 2014, 7:04pm, Robert Gregoire sent an email to William
Bridgeo regarding GinAs January 3rd email:

Lets discuss with Ralph on Monday. (we will likely refer to our liability
insurance carrier and then review with the City Attorney) BB
193.
On or about January 8, 2014, Matt Nazar and Robert Overton verbally
approved an occupancy permit for Unit 1, 32 Court Street which caused Greg Roy to
post public rental advertisements on the internet which prompted GinA to answer
the rental ad by email on January 8, 2014 at 9:27am.
194.
On January 11, 2014, GinA viewed Unit 1, 32 Court Street with Tim Cason
at which time they observed several red City of Augusta Code Enforcement signs on
all doors indicating the house was unfit for occupancy.
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195.
PageID #: 172
GinA told Greg Roy she was homeless and disabled, that she was receiving
monthly social security disability benefits, had special housing needs which
required her to be within walking distance to the courthouse, the stores and public
transportation and that she had two well-trained service (emotional therapy)
animals (cats).
196.
GinA expressly asked Greg for a long-term rental contract exceeding 5 years.
197.
Greg Roy demanded six good housing references from GinA which she gave.
198.
On January 13, 2014, GinA sent an email to Robert Overton of City of
Augusta Code Enforcement:

I went and looked at an apt. at 32 Court Street today. The building is
owned by Greg Roy. He said one of the 2 bdrm units is just about ready to be
rented after he gets your approval. He asked me to give him 6 references so I
gave him your name as one of them and explained that 3 Washington Street
Place was under city orders to close because it was being used as an illegal
rooming house, among other problems. I know you cannot give an official
reference for me but you can offer your personal opinion of my character. I
explained to Greg [Roy] that my interaction with you has stemmed from my
housing fiasco over the last 2 yrs but mostly from the past year of my living at
Washington Street Place.
199.
On January 13, 2014, 10:58am, Robert Overton sent an email to GinA,
responding to her request for a reference to live at 32 Court Street,

Gina, I will gladly tell Mr. Roy that I believe that you are a good
tenant and that you keep your apartment in great condition. I have to answer
his questions honestly, but will offer no more than what he requests not that
I would have anything negative to report. Rob.
200.
Robert Overton failed to tell GinA 32 Court Street was on target by the City
of Augusta et al to be razed by the end of that year for the courthouse parking lot.
201.
On January 17, 2014, GinA sent an email and made a phone call to Robert
Overton at City of Augusta Code Enforcement office,

I left a message on your voicemail that Greg is waiting to hear back
from you asaphe wont rent me the apt. until he gets your approval I gotta
get outta where Im living BEFORE 1/22 HOPEFULLY THIS
WEEKEND [sic]
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202.
PageID #: 173
Robert Overton never told GinA 32 Court Street was on target to be razed by
the City of Augusta and Maine Judicial Branch for a parking lot by the end of 2014.
203.
On January 17, 2014, 2:15pm, Robert Overton sent GinA an email,

Just spoke with Mr. Roy. Have a great weekend!
204.
Nobody told GinA before she moved into 32 Court Street that it was on target
to be sold for a Maine Judicial Branch parking lot before the end of that year.
205.
Matt Nazar and Robert Overtons official approval that Unit 1, 32 Court
Street was safe, decent and approved to be occupied caused GinA to communicate
with Greg Roy to sign a rental contract on January 22, 2014 for 32 Court Street.
206.
Greg Roy told GinA he was going to convert the second floor efficiency units
to small legal offices to benefit from the courthouse business.

207.
Greg Roy intentionally defrauded GinA to enter an at will rental contract
without telling GinA the property was going to be sold to City of Augusta within a
few months on behalf of Maine Judicial Branch. (See AUGDC-SA-2014-453, AP-1456, KEN-14-410, KEN-CV-14-176 and 1:16-cv-00095-NT)
208.
On January 22, 2014, GinA moved into Unit 1, 32 Court Street under an at
will lease despite repeatedly asking Greg Roy for a very long term lease.
209.
On January 22, 2014, Maine Municipal Association denied GinAs Claim
#212P3814 for the January 18, 2012 incident with Ofc. Peter Cloutier.
210.
On January 22, 2014, Anthon Douin (Anthony.douin@maine.gov) sent an
email to Phyllis Vonherrich at City of Augusta regarding Court Building Parking,

which said in part,
The houses on Perham Street include an 1850s schoolhouse, and buildings
which originally stood where the jail is now. The house on the corner of
Perham and Court is the Plummer House. He was City Marshall in the
1850sFifty years ago the Parking District razed the 1780s Child House for
parking on lower Winthrop Street. Anthony
211.
On January 31, 2014, Matthew Pouliot and his wife signed a mortgage deed
for $107,500.00 to buy 99 Winthrop Street Augusta for $72,000.00 as recorded in

Kennebec County Registry of Deeds in Bk 11622 Pg 60 on February 6, 2014.
212.
On February 9, 2014, KJ article Houses behind jail eyed for Augusta
courthouse parking, As a new four-story courthouse takes shape on Winthrop

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Streets lower hill, overlooking downtown, efforts are underway to secure more
parking spaces for people who will use the justice center. So far, the focus is on a
block of four buildings, most of them more than a century old, that form a residential
island along Perham Street. The buildings include an apartment house at 32 Court
St. that had been for sale previously, a two-family house at 19-21 Perham St. and
single-family homes at 13 and 15 Perham St
The city Planning Board required more parking than the 93 spaces in
the court systems original proposal to avoid having courthouse parking spill
over into neighborhood streets.
Maine Supreme Judicial Court Associate Justice Joseph Jabar and
Augusta City Manager William Bridgeo said establishing parking at the
Perham Street properties would be ideal and would allow for 87 more spaces
for people using the new building.
Were trying to really make it more user-friendly by establishing a
parking lot behind the jail and next to the courthouse, Jabar said. Thats a
perfect spot. That would add over 80 parking spaces so people wont have to
walk up the hill.
Parking on Perham Street would be about on the same level as the
buildings main entrance.
However, he said those planning the courthouse realize that people are
living in those houses. Were trying to negotiate a fair price for them, Jabar
said.
Bridgeo said a number of entities have worked cooperatively on the
courthouse project and related parking, including the county and the Augusta
Parking District.
Theres no discussion of anything other than attempting to negotiate
voluntary sales of these properties, Bridgeo said. What weve done so far is
the city accepted responsibility to secure appraisals of four parcels to be paid
out of the courthouse project.
He said negotiations then would take place with the property owners to
see if they can agree on a price.
Theyve all expressed a willingness to talk to us, Bridgeo said, adding
that the negotiations would be confidential.
In the meantime, the building project has reached the halfway stage
213. On February 12, 2014, 5:47am, GinA sent an email to Betty Adams regarding
their February 9th article,
Responding to your article published on 2/9 titled, "Houses behind jail
eyed for Augusta courthouse parking", I must offer my input since apparently
none of our city councilors are thinking about the most vital issue our city is
facing lately - LACK OF SAFE, LOW INCOME RESIDENTIAL HOUSING!
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How can our public officials even entertain any idea of demolishing
more residential homes to make way for a parking lot without comparatively
replacing those dwelling units when there is a perfect location for that parking
lot or another parking garage on the old YMCA building site at the corner of
Winthrop and State Streets. That parking garage can be connected to the old
or new courthouses by a catwalk or an underground tunnel, both which
already exist in our local government structures.
Did I mention this property is already cleared and ready for
construction and would save HUGE AMOUNTS of money for this project's
bottom line? There are no buildings to purchase, no people to relocate, no
structures to raze and no cleaning to perform... All that is needed is for the city
to purchase the property or exercise eminent domain over that property for the
greater good of the public, if necessary, which they are likely to do on
Court/Perham Street if push comes to shove.
And why was this tiny detail not decided and finalized BEFORE they
broke ground on the new courthouse?
I moved into 32 Court Street 2 weeks ago because the location and rent
are perfect for my needs and the owner who, in my opinion is one of the best
landlord's in the city, has been renovating the building for the past year.
The article says, "to residents, the idea appears to be somewhat
welcome." However, the article does not indicate that those residents total only
4 individuals who have not been faced with homelessness in the past 20 years
and who do not necessarily understand the paramount need for their
buildings to remain intact whether they choose to live on this block or not.
The article also does not mention that those 4 buildings are actually
capable of housing at least 20 people each having their own bedroom because
32 Court Street is a 6 unit building, 13 Perham is a 5 bedroom single family
house, 15 Perham Street can be home for at least 3 people and 19-21 Perham
Street is currently home to at least 2 or more people.
Regardless of the longtime residents' willingness to sell their buildings,
what about low income tenants who are going to lose permanent use of 32
Court Street? Where are they going to live?
We all need to stop thinking about making more business and start
thinking about making more peace, which is not going to happen by
destroying 4 residential homes without replacing them with 4 comparable new
buildings which will house the same number of people!
I will most definitely be objecting at all stages of the legal process with
whatever miniscule rights are afforded to tenants because I have a right to not
be forcibly removed from my home to make way for a vacant piece of property
that will be used ONLY M-F 8-5p!
How is any of this ok with any of you?
GinA Turcotte
Founder and President
MAINE TENANTS JUSTICE LEAGUE
1:16-cv-00100-NT
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PageID #: 176
32 Court Street, Apt 1

Augusta
207.358.8887
214.
On February 12, 2014 at 2:21pm, GinA sent an email to City of Augusta,
William Stokes, William Bridgeo regarding the February 9th KJ article,

I am forwarding an email I sent to the KJ and Betty Adams responding
to the article on Feb. 9th about razing the Perham/Court Street block of 4
residential homes to make the block into a parking lot.
I am flabbergasted the city council and our public officials would even
entertain such a notion in light of the epidemic of lost low income rental units
over the past few years.
Also, to add insult to injury, there is a perfect vacant lot at the old
YMCA site that would be ideal for a new parking garage which could be
attached to the new courthouse via underground tunnels or exterior catwalks
(since 18-wheelers do not usually use the Winthrop Street hill to descend into
Water Street).
I live at 32 Court Street and must be notified of all actions taken by the
city and the county courthouse project so I will be afforded my time to object to
being forcibly removed from my home so some people can build an
unnecessary parking lot which will only be utilized 40 hours per week !!
Please notify me of all hearings and meetings regarding this project so I
may have an opportunity to address the council and other interested parties.
Thank you.
GinA Turcotte
Founder and President
MAINE TENANTS JUSTICE LEAGUE
32 Court Street, Apt 1
Augusta
207.358.8887
215.
On February 14, 2014, GinA sent an email to Greg Roy regarding the KJ
article, Hi Greg! I'm forwarding both emails to the city council and the KJ about
razing this block. I think we both need to go raise some hell at the next city council
meeting !
216.
On February 16, 2014, KJ article Augusta Housing Authority leader wants to
help renters,
The new leader of the Augusta Housing Authority wants the
organization to take a more aggressive role in addressing what she describes
as the near-crisis level lack of affordable, safe housing in the city. Over the last
year, 65 housing units were lost in Augusta, some to fires, but most were shut
down by the city for safety code violations found in some of the aging rental
housing stock That has tightened up the availability of rental housing in
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Augusta. Were at a near-crisis situation in this community right now, said

Amanda Bartlett, executive director of the Augusta Housing Authority. With
me coming on board, it seems like a good time to look at expanding our role, so
were not just doing vouchers. This is an opportunity for us to address a need
in the community. I think the time is right to do something. Bartlett said
the authority already has an arm created specifically for real estate
development, the Augusta Housing Service Corporation, but that entity has
never really been active. She said the nonprofit corporation has about
$307,000 in funds set aside for real estate development.
217.
On February 17, 2014, GinA sent an email to City of Augusta, William
Stokes, William Bridgeo and Greg Roy, about the courthouse project,
Please notify me of all meetings and hearings regarding razing the
Perham/Court Street block so I may be present to testify.
218.
On February 20, 2014, GinAs letter to the editor was published by the
Kennebec Journal, Former YMCA site better for new parking garage,
Responding to your article published on Feb. 9 titled, Houses behind
jail eyed for Augusta courthouse parking, I must offer my input since
apparently none of our city councilors is thinking about the most vital issue
our city faces lack of safe, low-income residential housing!
How can our public officials even entertain the idea of demolishing
more residential homes to make a parking lot without comparatively replacing
those dwelling units? There is a perfect location for that parking lot or another
parking garage on the old YMCA building site at the corner of Winthrop and
State streets. That parking garage could be connected to the old or new
courthouses by a catwalk or an underground tunnel, both of which already
exist in our local government structures.
This property is already cleared and ready for construction and would
save huge amounts of money for this projects bottom line. There are no
buildings to purchase, no people to relocate, no structures to raze and no
cleaning to perform. All the city needs to do is purchase the property or
exercise eminent domain over that property for the greater good of the public,
if necessary, which it is likely to do on Court Street/Perham Street if push
comes to shove.
The article also does not mention that those four buildings are capable
of housing at least 20 people or where future tenants of 32 Court St. will live.
We all need to stop thinking about making more business and start
thinking about making more peace, which is not going to happen by
destroying four residential homes without replacing them with comparable
new buildings that will house the same number of people.
How is any of this OK with Augusta residents?
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Gina Turcotte, Augusta, Founder and president, Maine Tenants Justice

League (See
http://www.centralmaine.com/2014/02/20/former_ymca_site_better_for_ne
w_parking_garage_/ )
219.
On March 1, 2014, GinA sent an email to Frank OHara, Planning Decisions,
Inc., asking for an agenda for the March 4th housing forum.
220.
On March 1, 2014, GinA received an emailed response from Frank OHara,
with an agenda and a list of presenters which did not include anyone speaking as a
tenant or on behalf of any tenant groups.
221.
On March 4, 2014, City of Augusta held their very first Augusta Community
Housing Forum, beginning at 6:30 8:30pm with only GinA speaking on behalf of
tenants, as a disabled low income tenant herself and founder of MAINE TENANTS
JUSTICE LEAGUE, Inc. (See https://www.youtube.com/watch?v=eTVYeqYg57o )
222.
On March 4, 2014, KJ article Augusta needs cheaper, safer housing, forum
participants say
The struggling economy is hitting both tenants and landlords as the
citys already-old housing stock ages, forcing low-income tenants to live in
unsafe apartments they cant afford and leaving landlords without enough
money to make needed improvements.
Officials, tenants, landlords and others at a housing forum Tuesday
described a housing situation in need of repair.
The housing stock in Augusta is very old, Code Enforcement officer
Rob Overton said at a housing forum hosted by the city and Augusta Housing
Authority. Take a building built in the early 1900s, long before the existence
of any of the life safety codes we have today, combine it with years of neglect,
and youve got a recipe for very dangerous situations. Were finding tenants in
these buildings are very aware of the problems but feel they have no other
options, so they remain there. Were finding many different attitudes among
owners. One is the inability to fix the buildings because of the cost. In many
cases, youre talking about tens of thousands of dollars. In very few instances,
so far, are we seeing these conditions corrected. Id like to say the housing
stock is in better condition than it was 18 months ago, but Im sad to say thats
not the case.
Amanda Bartlett, executive director of the Augusta Housing Authority,
said the lack of affordable housing in the city is a near-crisis situation. She
wants the authority to play a larger role in improving local housing beyond
distributing federal Section 8 housing vouchers to low-income residents in the
Augusta area. So she wants the quasi-municipal Augusta Housing Authority
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to expand its role by potentially getting into developing, rehabilitating,

building and/or owning housing units
223.
On March 7, 2014, Robert Overton sent an email to Royce Watson,

Royce, Per your previous request to receive any information/documents
pertaining to Gina Turcotte and your property at 239 Cony Rd. I forward the
following to you [emphasis added]
224.
On March 10, 2014, 10:05am, Royce Watson sent an email to Robert Overton,
[GinA] needs to take some of her free time and get a job.
225.
On March 18, 2014, Philip Johnston sent an email to William Bridgeo, Matt
Nazar, Joseph Jabar et al, In a meeting this morning Bill Bridgeo suggested we
present the parking lot project at a Planning Board Workshop, even though we do not
have purchase and sale agreements in place for any of the properties. The idea is to
informally present the project to the Board to reduce the application/approval time
once agreements are in place.
226.
On April 10, 2014, City of Augusta Police Ofc. Laura Drouin called GinA for
the purpose of officially threatening to arrest GinA for GinA trying to communicate
with her daughter about private peaceful, non-criminal family issues. (See
https://www.youtube.com/watch?v=U6FCwGhMfyo)
227.
On April 17, 2014, Matt Nazar authorized Keith Luke to send an official offer
to Greg Roy on behalf of City of Augusta and Maine Judicial Branch to buy 32 Court
Street for $85,000.00.
228.
On May 3, 2014, Greg Roy asked GinA to help draft and edit his official
rejection letter to City of Augusta.

229.
On May 5, 2014, Greg Roy submitted a letter GinA edited to City of Augusta.
230.
On May 5, 2014, GinA submitted her own objection letter to City of Augusta,
William Stokes, Matt Pouliot, William Bridgeo, and Gregory Roy,

This letter shall be considered my legal public objection to all
negotiations between all elected officers of the City of Augusta and the State of
Maine to acquire 32 COURT STREET, AUGUSTA for the purpose of building
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a parking lot for increased court business and enhancement of tax revenue at
the peoples expense causing severe injury to the public.
I am a legal tenant of 32 COURT STREET having excitedly moved into
this building in February 2014 after being homeless for many years. I did not
impetuously choose this building without thorough economic discernment.
I chose this building for many critical reasons, some of which are listed
below:
1. Location (next to Superior Court for ongoing personal court business)
2. Location (near District Court for ongoing personal court business)
3. Location (walking distance to my daughter and granddaughters home)
4. Location (walking distance to libraries, businesses and social services)
5. Location (few residents, peaceful nights, weekends and holidays)
6. Location (very high safety area, no crime or public disturbances)
7. Location (unique view of historical buildings, river and sunset/sunrise)
32 COURT STREET is a safe, decent and sanitary building capable of
housing seven low income tenants at very reasonable rates with many
amenities included
Taking this dwelling away from the community you are sworn to
represent, protect and serve would perpetuate a homelessness crisis which all
officers of the City of Augusta and the State of Maine are duty-bound to
prevent or remediate, not proliferate with illogical tax-enhancing, libertyendangering commercial projects.
Increasing court business does not benefit the public nor is it for the
greatest public good since most court business imposes sizable taxes,
individual duties and liberty injuries.
Tax is defined by Blacks Law 9th, as A charge, usu. monetary,
imposed by the government on persons, entities, transactions, or property to
yield public revenue.
As you can see, the definition of tax is not restrained to a particular
type of tax ~ if any municipality or body politic assesses a fee on 'the public, it
is a tax by definition.
Therefore, all court revenue, fines, fees, penalties and charges are taxes.
1 MRSA 816(1)(B) prohibits exercising eminent domain power when
taking a private property primarily for the enhancement of tax revenue, such
as for a new courthouse.
Arbitrary destruction of a rare licensed rooming house to build a
parking lot is utterly abusive, discriminatory and repugnant to many
constitutional and human rights protections afforded to every low income and
homeless tenant in the state.
32 COURT STREET is an exceptional property with its rooming house
licensure, its unique and peaceful view of the horizon and historic buildings,
and a secluded location near many businesses and city services.
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The People of the State of Maine will be doubly taxed by this project by
the fact that public bonds were issued to finance this project which need to be
paid by the very same people who will be taxed, sanctioned and their liberties
hijacked within the court facility they paid to build.
Additionally, since the new court facility will accommodate more
people, attract new business and will have certain financial expenses paid
for by those very people, naturally the state and the city will be increasing
their budget appropriations to meet those tax burdens which naturally will
increase the need for increased court tax revenue which will come directly from
the public.
Evidently, the public does not benefit from more court fees, fines, duties
and taxes.
Amanda Bartlett is the new executive director for Augusta Housing
Authority who recently said Were at a near-crisis situation in this
community right now, and that she wants Augusta Housing Authority to
expand its role by potentially getting into developing, rehabilitating, building
and owning housing units.
A Kennebec Journal newspaper article dated February 16, 2014
indicates, The new leader of the Augusta Housing Authority wants the
organization to take a more aggressive role in addressing what she describes
as the near-crisis level lack of affordable, safe housing in the city.
The City of Augusta co-sponsored a community housing forum with
Augusta Housing Authority on March 4, 2014 to discuss how to fix the
homelessness crisis and rapidly decreasing number of safe, decent and
habitable apartment buildings in the city.
Augusta Housing Authority is a municipal board created by elected
officials of the City of Augusta; therefore, Augusta Housing Authority is a
municipal subdivision and a body politic having only as much authority
as the people explicitly authorize it to have and only for the publics collective
safety, health, and welfare benefit.
Amanda Bartlett indicated that their sister corporation, Augusta
Housing Service Corporation, which is an IRS 170(b)(1)(a)(vi) organization
and which receives most of its support from a governmental unit or the general
public, has liquid assets of three hundred thousand dollars ($300,000) which
is purportedly saved for acquisition, development and maintenance of low
income properties although none has been spent since the private corporation
was formed in 1997.
City of Augusta Office of Economic and Community Development has
declared on their official government website, We're strengthening alreadyestablished neighborhoods with programs designed to rehabilitate vacant
or dilapidated homes. We're working with developers to bring contemporary
loft-style apartments, overlooking the scenic and recreational opportunities
afforded by the majestic Kennebec River, to our revitalized downtown district.
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City of Augusta OECD further states on their Neighborhood

Revitalization page, City officials and the OECD staff value these
neighborhoods, and we're investing in them. We're striving to preserve the
special qualities of our community, and revitalize the areas that need our
helpAnd we're encouraging and supporting the establishment of
neighborhood associations, so that we can all work together in planning for
the future of our neighborhoods and our city.
Offensively contradicting these pledges made by the OECD, the city has
engaged in ongoing secret negotiations since 2009, without any consideration
for the public you serve or your electors in this neighborhood, about
demolishing four residential buildings which are capable of housing at least
twenty people and which are all currently inhabited by peaceful, law-abiding
individuals, many of whom have lived in this small neighborhood for decades.
As reported by the Kennebec Journal on March 19, 2014, While the
new building near the intersection of State and Winthrop streets isnt expected
to generate new jobs, it will consolidate about 100 employees under one roof.
Hundreds more will come to conduct business.
It is imperative to note that court business is not conducted for the
publics benefit but instead imposes a serious fiscal injury on many citizens
who are coerced and intimidated to use court services under duress, imminent
threat of arrest and loss of liberties.
As disclosed in the March 19th newspaper article, the new building
isnt expected to generate new jobs illustrates its limited actual benefit to the
public who are paying the bonds which are financing this $55 million project
with no new jobs.
It is imperative to note the old YMCA lot on the corner of Winthrop and
State Streets is clear and ready for development and which will not eliminate
any habitable dwellings nor displace any tenants or businesses.
It is also a more practical location for a parking lot since the patrons of
the Lithgow Library and surrounding businesses will also be able to use the
parking spaces.
If the size of that lot is less than what is needed for a parking lot,
another reasonable option would be to build another parking garage to
supplement the parking garage at the bottom of Winthrop Street which is not
currently used to full capacity.
If there are safety concerns when crossing Winthrop Street from the
YMCA lot, the next reasonable option would be to build a suspended catwalk
or underground tunnel from the old YMCA lot connecting to the old or new
court house.
Building a suspended catwalk or underground tunnel across Winthrop
Street is viable because the street is not allowed to be used by oversized
vehicles or heavy equipment and all traffic moves very slowly and cautiously
due to pedestrians and regular traffic. The catwalk and tunnel will also
guarantee pedestrian comfort and safety during the winter months.
1:16-cv-00100-NT
Page 72 of 115
PageID #: 183
I rented this apartment at 32 COURT STREET with the intention of

living here for many years in order to develop my professional business which
requires living within immediate proximity to the courthouses, as well as other
critical reasons.
If the elected officers for the City of Augusta and State of Maine truly
want to preserve the special qualities of our community they will abandon
all ideas of destroying 32 COURT STREET and all PERHAM STREET
residences.
If elected officers acting as the agents for the City of Augusta and the
State of Maine decide to continue negotiations, they will be required to explain
how taking four residential properties instead of utilizing a comparable
vacant parking lot is for the greatest good of the public and with the least
private injury to the tenants and businesses who will be displaced.
I also reserve and will exercise all my rights under the Maine
Constitution and Maine Revised Statutes to receive just compensation for all
losses, injuries, expenses and other related costs required to pay for and
relocate me to a comparable residence with identical financial and personal
benefits.
Since I will be directly impacted by all activities against 32 COURT
STREET, I require to be notified with appropriate advance written notice and
be included in all subsequent hearing, conferences, meetings and negotiations.
Please send correspondence about all conferences, meetings,
negotiations and hearings to me at 32 Court St Apt 1, Augusta or you can
telephone me at [phone number redacted].
In Peace,
GinA Turcotte
32 Court St Apt 1
Augusta, Maine 04330
231.
On May 7, 2014, William Stokes was publicly nominated by Governor Paul
LePage for superior court judgeship.

232.
On May 15, 2014, GinA testified at a City of Augusta Council meeting. (See
https://www.youtube.com/watch?v=Nz9FOPgR3D4 )
233.
On May 15, 2014,KJ article Augusta councilors OK former Hodgkins Middle
School lease; The Augusta Housing Authority plans to turn vacant school of the
Capital Citys east side into housing for senior citizens.
Resident Gina Turcotte, in a tense exchange with Mayor William
Stokes over how much time she should be allowed to speak, said she agrees
there is a need for more affordable housing for seniors in the city, but said
Hodgkins is a not a safe building for that housing because of the presence of
asbestos and mold in the old school.
1:16-cv-00100-NT
Page 73 of 115
PageID #: 184
Stephen Langsdorf, city attorney, said any such issues with the safety of
the building would be remediated by the developer.
Bunker confirmed that, noting generally asbestos is completely removed
from buildings for such projects, by environmental engineering firms who
remove it and test to verify it has all been removed. He said most kinds of
molds can be removed, as well, and testing would take place to make sure it is
all gone, and the air is safe to breath.
It is very highly regulated, he said of asbestos. Just about every old
building has asbestos in it. Its part of the deal.
Amanda Bartlett, the housing authoritys executive director, said the
agency plans to use federal and state historic preservation tax credits and lowincome housing tax credits from the state housing authority to help pay for the
project.
City Manager William Bridgeo said the city also could consider
granting a tax increment financing package to help fund the project, thus
allowing the authority to keep some or all of the property taxes it would pay on
the building.
The housing authority is a nonprofit organization, and thus it normally
wouldnt be required to pay property taxes, but it might form a for-profit
company to be able to take advantage of tax credits unavailable to nonprofits.
In response to criticism from Turcotte the city would be making a profit
from the venture, through the housing authority, Langsdorf said the for
profit designation is simply a legal designation that would allow the housing
authority to obtain state and federal tax credits for the project, and the city
would not be engaged in any sort of profit-making venture.
This is about the only way historic structures in Maine get
rehabilitated, Bridgeo said. Without using state and federal tax credits, wed
be tearing down buildings like Old City Hall and the flatiron building.
Bartlett said the Augusta Housing Authority is one of only a few
housing authorities in Maine that doesnt develop and own housing properties.
We need to get it done, Bartlett said. It is time here, in Augusta, to
expand some housing opportunities.
234.
On May 15, 2014, GinA had a conversation with Matthew Pouliot in his
official capacity as her state Representative of the Maine Legislature on Facebook,

9:27pm
GinAthena Turcotte
we need to talk about the courthouse project and the perham/court
street plan
i jsut went head to head with mayor stokes
i live at 32 court street
i'm not moving
my landlord is not selling
we will be the last tenants standing
1:16-cv-00100-NT
Page 74 of 115
PageID #: 185
9:28pm
Matthew Pouliot
I'm afraid there is not many options for parking
9:28pm
GinAthena Turcotte
what about the ymca lot?
no mention of that whatsoever
its DOUBLE the size of this lot!!!
and its already cleared !!!
.96 acres !!
these 4 properties are ONLY .4 ACRES!!
and we will lose 20 UNITS!
the bldg next door is a 5 bedroom house!
this bldg is a 6 unit bldg
19-21 perham st is at least 3 or 4 units
and danny ayotte's is a single family that needs a lot of work
so where do i go ??
the city has no plan for me or the other 5 tenants in this bldg
we need to talk
the owner and i have sent our official objections to the city
and MTJL sent their official objection also
last week
the owner and i are working closely and collaboratively. he also joined
MTJL as a board director representing landlords and real estate agents
and homeowners
did you know the city has been planning to take these 4 bldgs since
2009 and NEVER SAID A WORD until 2012 !!
or 2011 at the earliest to the residnets on the street
i've surveyed people on this street
the city has made a total of 4 contacts with the next door neighbor
starting 3yrs ago
but they've been planning this since 2009 according to the KJ
why did they wait until NOW ????
whats going on????
and why did Mayor Stokes just get nominated to be a superior court
judge in the very courthouse they are going to destroy my bldg to make a
parking lot for ????
did he sell my block for the judgeship???
i sure think so !
i'm HOT
I'M LIVID!!
i'm going PUBLIC
1:16-cv-00100-NT
Page 75 of 115
PageID #: 186
VERY VERY VERY PUBLIC

my landlord is hot
he is stubborn and will not back down
we have already spoken at length
he and i will be standing here when the other 3 homes are demolished
it WILL go to court
9:35pm
Matthew Pouliot
I am certain the.building.project has.nothing to do with the judgeship
9:35pm
GinAthena Turcotte
i wouldnt be so sure, but i appreciate your caution
9:36pm
Matthew Pouliot
I just think it's too far into the project to change it. I dont.think Lon
Walters wants to sell the YMCA lot.for.parking
9:37pm
GinAthena Turcotte
its not a matter of want anymore... the city IS going to take this block by
eminent domain if we dont do something... why cant they take the
YMCA lot by eminent domain instead? it will be cheaper!
9:37pm
Matthew Pouliot
It's a terrible situation but takings occur every day
9:37pm
GinAthena Turcotte
no people to relocate, no bldg to destory, no cleanup to perform... its all
ready to buildg
its NOT OK
I WILL NOT ALLOW IT
IT WILL GO TO COURT
I will file as a tenant
or a 3rd party intervenor
i will fight the state and the city to the end
and i'm good at what i do
they are taking my home away form me
without a backup plan!! as MY CITY COUNCILORS/??
1:16-cv-00100-NT
Page 76 of 115
PageID #: 187
9:38pm
Matthew Pouliot
I'm sorry you have to go through this, but I feel like you purposely seek
out these situations
9:38pm
GinAthena Turcotte
i did not know this was an issue when i moved in here
i had no clue
do not blame me for landlng in this situation
that is OFFENSIVE !!!!
i did NOT choose this !!
I HAD NO CLUE UNTIL THE 2ND MONTH
the city NEVER CONTACTED THE LANDLORD until APRIL !!!!
9:39pm
Matthew Pouliot
You could move, no? There are a ton of vacant units in Augusta
9:39pm
GinAthena Turcotte
NO!
i want to stay with this landlrod
given my prior experiences
as you just clarified
my landlrod and i are friends
he is now a board director of MTJL... this is not just about
displacement of a tenant
this is a government issue that needs a public resolution
9:41pm
Matthew Pouliot
Takings are terrible but happen for the public good.
Again, sorry you have to deal with this
9:42pm
GinAthena Turcotte
if you are a city representative for augusta, i am officially requesting
that you schedule an appt to come here to talk with me and this bldg
owner... this is NOT OK... this is not going to happen without a court
battle... i guarantee it
i'm already researching eminent domain precedent
i'm good at what i do
this will cost the city $$$$$$$$$$$$
1:16-cv-00100-NT
Page 77 of 115
PageID #: 188
i promise you that

they are NOT acting in the public's best interest
i just testiifed to that fact on the record tonight
on the live broadcast
i am not going to be silent any longer
i will be very very public
if yu care about us as your constituents, then you will make a point to
listen to greg roy about what has happened to his bldg
this is NOT ABOUT ME
this is about THE PEOPLE
the angels put me in this bldg... i did not choose this fight and would
prefer to deal with my other issues instead.
but i dont have much of a choice now
and i am asking you as my city rep. to take time to speak with my
landlord and the person who will be detrimentally affected by this
unnecessary taking
its abusive and a breach of the city's fiduciary duty
i respect you, Matt, and am coming to you with that respect intact ...
but, if you dont listen to greg and what the city has done to him to take
this property, i will wonder what your agenda is ...
do not make this about me... it has nothing to do with me... this is about
Greg and how the city has been secretly planning to take his property
since 2009 at least without a word to him !!
and they know this is a FOR PROFIT BUSINESS they are taking away
from him !!
and they only offered him $85,000 !!
such an insult
like i said, I'M HOT
but i'm in control of myself and have my focus well refined
i will be taking this public in every venue i have available to me
as soon as it stops live streaming i will be cutting a copy and uploading
it to youtube so the public can see what i just did
for them
so, with that said, please call Greg Roy, the owner of 32 Court Street, or
come by to see him anytime during the day... if there is a burgandy
pickup truck or burgandy car in front of the building, he is here
working
his phone humber is 207-215-8548
he knows im making contact with you and approves
i'm signing off FB now and going to do some work for a Scarborough
tenant ... please think about what i've said and give me a thoughtful
response in due time... thank you for your time and consideration.
10:34pm
1:16-cv-00100-NT
Page 78 of 115
PageID #: 189
Matthew Pouliot
Ok, I'll talk to Greg
235.
On May 20, 2014, GinA sent an email to Matthew Pouliot regarding Official
Complaint against State of Maine,

Rep. Matthew Pouliot, (Augusta),
This message is being sent as an OFFICIAL COMPLAINT about the
State of Maines and City of Augustas secret negotiations since 2009 (or
earlier) to destroy 4 occupied private homes and a private for-profit business of
17 years on Perham/Court Streets to build a parking lot for the new
courthouse in Augusta.
Rep. Matthew Pouliot, since you have removed and blocked me from
your Facebook wall, I am sending this message to your official public email
address as a Maine legislator demanding you launch an official investigation
into this injurious, deceptive and commercial public activity.
The State MUST PROVE this eminent domain taking IS NOT for
COMMERCIAL PURPOSES nor Primarily for the enhancement of tax
revenue under 1 MRSA 816(1)(B) which is the very nature of ALL COURT
BUSINESS!!
I WILL be filing an official claim in Superior Court as a tenant and 3rd
party intervener under Maine Tort Claims Act for the GRAVE INJURY
caused to myself by the State of Maine, the City of Augusta, the Maine
Governmental Facilities Authority and ALL ITS REPRESENTATIVES !!
Rep. Matthew Pouliot, you are a STATE REPRESENTATIVE for
myself and Greg Roy and all other inhabitants on this block.
You have a FIDUCIARY DUTY to PROTECT OUR INTERESTS at the
state level.
I am requiring you to launch an official investigation into this
fraudulent activity and that you make your investigation and its results
public.
Be advised that ALL COMMUNICATIONS between myself and ALL
PUBLIC OFFICERS will be made publicly available on the internet so
everyone knows what their representatives are doing with their money and
credit.
I require that you respond within 24 hours since I have already
previously communicated with you about this official matter.
Greg Roy, the owner of 32 Court Street, Augusta, is also waiting for
your official contact.
In Peace,
GinA Turcotte
32 Court Street, Apt. 1
Augusta
[phone number redacted]
1:16-cv-00100-NT
Page 79 of 115
236.
PageID #: 190
On May 22, 2014, City of Augusta Code Enforcement issued a letter to Greg
Roy approving occupancy for the two rear apartments on the second floor at 32
Court Street,
May 22,2014
Gregory Roy
389 Costello Road
Gardiner, ME 04345
Re: 32 Court Street
Tax Map 33, Lot 230
Augusta, ME 04330
Mr. Roy,
This letter is to confirm that the Code Enforcement Office has approved
occupancy of the two rear apartments on the second floor at the above
referenced address.
Occupancy of the second floor apartments on the Court Street side of the
building and on the floors above the second floor is currently prohibited.
If you have any questions regarding this matter, please do not hesitate
to contact my office.
Sincerely,
Robert Overton
Code Enforcement Officer
***
237.
On June 5, 2014, Greg Roy asked GinA to post internet rental ads on his
behalf for both of the 2nd floor efficiency units expressly giving preference for
long-term residents.
238.
On June 17, 2014, GinA made an official complaint to City of Augusta, Matt
Nazar, regarding noise from the courthouse construction site,

This is being sent as an official complaint about the hours worked by
the construction crews at the court house project on Court Street.
I was awoken again this morning at 6:30am by the nuisance of the
beeping noises coming from the heavy construction equipment.
These workers arrive on the worksite as early as 5:30am and begin work
anywhere between 6:15-6:30am every day complete with construction noises.
These construction people show NO RESPECT for the residences in this
neighborhood and make unnecessary noises by beeping machinery horns to
drown out someone talking to them, throwing metal onto metal to create loud,
booming noises at early hours of the morning, and other unnecessary activities
that create loud noises at unreasonable times and for unreasonable purposes.
I am at the end of my patience with this construction project and the
disrespect being shown to the people who live in this neighborhood.
1:16-cv-00100-NT
Page 80 of 115
PageID #: 191
Please inform Consigli and any other contractor that they are not to
begin any work before 7am M-F.
I expect to hear from you promptly.
Thank you.
GinA Turcotte
32 COURT ST
AUGUSTA
[phone number redacted]
239.
On June 18, 2014, 8:56am, GinA sent an email to Rob Overton,

Who is David Pare? What was the context and content of your
conversation with him about me as referenced in the message [dated
October 2, 2013, 8:21:44am]? GinA
240.
On June 18, 2014, Rob Overton sent an email to GinA regarding David Pares
email to Rob Overton,

Mr. Pare is one of the good local landlords and seems to be a good
person. He pays attention to the City Council meetings and has called me
regarding some of the issues you have brought up at the meetings and some of
the earlier issues that you experienced on Cony Street. He also calls me
occasionally to ask about code requirements for different type of buildings. He
believes that you could make a good living providing (for a fee) landlords the
type of advice/advocacy you give to tenants.
I actually have received several calls from landlords about what you are
doing with MTJL. You are becoming very well known among the landlord
community. I always recommend that they contact you directly if they want
info on what you do.
I certainly do not believe that Mr. Pare meant any disrespect to you, but
I can certainly see how it could appear as such without knowing the context of
the phone conversation that we had prior to this email!
I will forward the other emails that he has sent me (I do not recall any
others that involved you or MTJL, but will check and send them to you).
Rob
241.
On June 18, 2014, 12:59pm GinA sent an email to Rob Overton,and I slept
in my bed for the first time in several months (I usually sleep on the couch to create a
sound buffer between my ears and the construction zone).
242.
On June 20, 2014, William Stokes recorded a $100,000.00 Home Equity loan
in Kennebec County Registry of Deeds for in Book 11718 Pg 225

243.
On July 10, 2014 Greg Roy gave GinA a 30-day no-fault Notice to Quit.
1:16-cv-00100-NT
Page 81 of 115
244.
PageID #: 192
On July 10, 2014 Lindsey Liepman of WMTW-TV news reported live in front
of 32 Court Street regarding the demolition of the Perham Street properties which
were delayed by City of Augustas Historic Preservation Commission.
(See http://www.wmtw.com/news/augusta-home-demolitions-delayed/26890186#!bc7RPn)
245.
On July 11, 2014, 7:55am, GinA sent an email to Matt Nazar and Robert
Overton,
The construction workers have begun to violate the noise ordinance
again. They are beginning to deliver and use heavy equipment before 7am.
This morning they had heavy equipment delivered at 6:00am and they opened
the gate and began using the equipment before 7am.
This has been happening progressively over the past couple weeks. Most
workers still use the lower gate to enter but many of them, especially the heavy
equipment and deliveries, are still using this gate as early as 5am
I dont know how loud I have to scream to get these people to respect my
need to sleep PEACEFULLY without the BEEP BEEP BEEP BEEP BEEP
BEEP outside my window every morning that makes for a very unpleasant
awakening and a very unpleasant day and very unpleasant experiences for
people who have to deal with me for the rest of that day
Please tell Consigli that I have legal rights to have quiet and peaceful
enjoyment of my home despite their desire and need to stick with their work
schedule there are laws and ordinances for a reason.
Thank you.
GinA Turcotte
246.
On July 23, 2014, Keith Luke sent an email responding to GinAs July 22,
2014 FOAA request:

Keith,
If this request is being made to you in error, I request that you forward
this FOAA request to the appropriate person for a prompt response.
***
Is it true the City of Augusta has offered Greg Roy $184,000 for the
purchase of 32 Court Street?
If this is not true, what is the 2nd offer which was made to Greg Roy?
I am aware Greg has rejected the 2nd offer as well.
Please immediately produce in accordance with the Maine Freedom of
Access Act all written correspondence between the City of Augusta and Greg
Roy since January 1, 2014 regarding the purchase negotiations of 32 Court
Street.
Thank you.
GinA Turcotte
***
1:16-cv-00100-NT
Page 82 of 115
PageID #: 193
Attached are the only two documents that are responsive to your
request.
KPL
Keith P. Luke
Deputy Director of Development Services
City of Augusta
16 Cony Street
Augusta, ME 04330
ph: (207) 626-2336
fx: (207) 626-2520
***
September 26, 2013
Gregory B. Roy
389 Costello Road
Gardiner, Maine 04345
Dear Mr. Roy:
In 2012 you were contacted by the City of Augusta's Development
Services office regarding the purchase of your property to support the
expansion of the Kennebec County Courthouse. For a variety of reasons, our
ability to begin negotiations with property owners and make fair market offers
on property was delayed until now.
In the coming weeks the city will be preparing an offer on your property.
Our goal is to present you with an offer based on fair market value. To assist
in making this determination the city has retained an independent licensed
appraiser Tracy Vickerson of Vickerson Appraisal Service in Winthrop
(CG#215 State of Maine).
Next week Tracy Vickerson will be contacting you to coordinate an
inside and outside inspection of your property. This will insure the most
accurate appraisal of your property's worth. Once Vickerson Appraisal Service
has completed their work, I will be scheduling individual meetings with
property owners to discuss both the appraisal and corresponding city purchase
offer.
The city's goal is to make this a transparent process and maintain an
open dialog with property owners. We understand that the decision to sell
property especially one's home is not an easy one. We will do everything
that we can to make the process both fair and equitable.
Please feel free to contact me if you have any questions about either the
appraisal or acquisition process.
Regards,
Keith P. Luke
Email: keith.luke@augustamaine.gov
***
April 17, 2014
1:16-cv-00100-NT
Page 83 of 115
PageID #: 194
Gregory B. Roy
389 Costello Road
Gardiner, Maine 04345
Dear Mr. Roy:
As you are aware, work on the Maine Judicial Center is entering its
final phase, with the goal of completion in the winter of 2015. An important
part of the project is the acquisition of private property on Perham Street to
accommodate new parking for the facility.
While the new Judicial Center will be owned by the State of Maine, both
Kennebec County and the City of Augusta have been cooperating closely on the
project. The City has taken the lead role in negotiating the sale of private
property. Our goal is to negotiate the sale of your property both fairly and
equitably.
In the fall of 2013 the city contracted with Tracy Vickerson a licensed
real estate appraiser from Winthrop to conduct an external appraisal of the
properties on Perham Street. A copy of that appraisal has been included with
this offer letter. Based on that appraisal, the city is prepared to offer eightyfive thousand dollars ($85,000) for the purchase of the apartment building
and property at 32 Court Street.
At this point, our suggestion is that you take ten days to consider the
citys offer and perhaps consult an attorney to discuss your position with
regard to an option agreement. I suggest that we meet at Augusta City Hall on
Monday, May 5th at 1PM to discuss the citys offer and your needs as we seek
to move forward on this project.
Additionally, I am available to discuss the citys offers and address
your questions at any time at (207) 751-2962.
Regards,
Keith P. Luke
Email: keith.luke@augustamaine.gov
247.
On July 25, 2014, Robert Overton sent an email to GinA responding to her
July 25, 2014 FOAA request re: Map 33, Lot 230, 32 Court Street,
Every new public record created or received by your office since May 1,
2014 regarding Map 33, Lot 230 (32 Court Street).
(See June 5, 2014 FOAA request, June 17 and July 11, 2014, official
complaints to City of Augusta, Matt Nazar)
May 22, 2014, 1:38pm email from Robert Overton to William Bridgeo:
I met with Mr. Roy today at 1130am at 32 Court Street. While
inspecting the building, he mentioned the plans for the area to potentially be
used for parking for the Court facility. He went on to say that he was aware
that the other property owners on Perham Street had come to agreements with
the City for the sale of their property. He said that he was not sure if he should
continue to fix up 32 Court Street or "move on to something else". I told him
1:16-cv-00100-NT
Page 84 of 115
PageID #: 195
that the City Manager would like to meet with him in an effort to negotiate the
sale of his property. He replied that he received an email requesting a meeting
and apologized for not responding to it. He did not say what he intended to do.
Robert Overton
Code Enforcement Officer
City of Augusta
16 Cony Street
Augusta, Maine 04330
ph: (207) 626-2365
fax: (207) 626-2520
***
May 7, 2014, 1:04pm
From: Matt Nazar
To: William Bridgeo; AII_City_Department_Directors;
AII_City_Bureau_Heads; Robert Overton; Gary Fuller
Cc: Stephen Langsdorf
Subject: FW: FOAA request , Map 33, Lot 230, 32 Court Street, Augusta
Bill,
Ms. Turcotte is sending separate emails to staff members with her
FOAA requests. At this point, you've told me that Steve will be handling
the assembly of information for Ms. Turcotte. If any other departments
or bureaus receive FOAA requests from Ms. Turcotte, I assume Steve
will be handling them? So far, the requests have been for two specific
properties in the city- 32 Court Street, and the old YMCA property.
Matt
Matthew A. Nazar
Director of Development Services
City of Augusta
16 Cony Street
Augusta,ME 04330
ph:{207) 626-2365
fax: {207) 626-2520
248.
On August 20, 2014, GinA was forced to participate in a fraudulent eviction
hearing for AUGDC-SA-14-453 presided over by Valerie Stanfill. (See 1:16-cv00095-NT)

249.
On August 23, 2014, 1:10pm GinA sent an email to William Bridgeo
regarding her objection to any extension of courthouse work hours,

Manager Bridgeo,
I have been told the courthouse construction crew has recently
submitted a request to extend construction work hours beyond 6pm M-F and
that the decision is solely yours as City Manager.
1:16-cv-00100-NT
Page 85 of 115
PageID #: 196
If this is not true, I am filing my official objection for all future requests
for an extension of work hours for as long as I live at 32 Court Street.
As a resident who lives closest to the courthouse project, I
CATEGORICALLY OBJECT to any extension of work hours beyond 6pm
because it will severely exacerbate my current injuries caused by the
continuous noise pollution and physical, emotional and psychological torture I
am required to endure 7a-6p M-F and which is the foundation of the Notice of
Claim I filed on August 5, 2014 against the City of Augusta and 14 public
officials including yourself.
Please understand and take official notice of the fact that I am inside
my home at 32 Court Street 99% of the time and I suffer GREATLY during the
day with emotional, mental and physical issues caused by the construction
noises and other related disturbances.
The City of Augusta and its employees are knowingly and willfully
torturing me with 11 HOURS EVERY WEEK DAY (55 hours per week) of
CONSTANT noise pollution, earth work, dust, dirt, debris, traffic, and
interference with my freedom to communicate.
If the City of Augusta, any of its agents or employees grants any
extension of work hours for the construction project, those official public
decisions will be used as evidence by myself that all public officials involved in
that decision acted intentionally, wantonly and recklessly in disregard for the
needs of the areas residents resulting in EXTREME PHYSICAL,
EMOTIONAL AND PSYCHOLOGICAL TRAUMA for all residents on
PERHAM & COURT STREETS, clearly illustrating the Citys secret
motivations to intentionally injure the public which would be a fundamental
breach of their legal duties as public servants.
Manager Bridgeo, this situation is contentious enough without
exacerbating the situation by extending construction work hours for the court
house project which you know will most definitely cause extreme distress for 4
residences.
If any extension to work beyond 6p M-F is granted for the courthouse, I
will take whatever legal action is available to remedy my injuries in addition
to the legal action I have already initiated.
Please understand that legal immunity defenses do not protect against
individual and professional negligence or reckless behavior.
In consideration of the fact that you are fully aware of the trauma the
construction project is already causing me and my neighbors, your actions will
be judged as intentional, wanton and reckless if any extension is granted to
the courthouse project.
If my objection is ignored and construction work hours are extended, I
will use that decision as further evidence of discrimination against me as an
alleged sovereign citizen and domestic terrorist having no legal credibility
with my public officials because of their negative prejudice against me as a
truth-speaking constitutional woman and evidenced by their pattern of
1:16-cv-00100-NT
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PageID #: 197
behavior of ignoring me and allowing my rights to be continuously and

egregiously violated.
Manager Bridgeo, I have done nothing to deserve this kind of blatant
discrimination and negative prejudicial behavior by my public officials.
I am a law-abiding, truthful, peaceful woman who is only seeking
community-wide lawfulness, fairness and justice.
Please reject all requests by the courthouse construction crew to work
beyond 6pm M-F.
Thank you,
GinA Turcotte
32 Court Street Apt. 1
Augusta Maine
250.
On September 03, 2014 , 11:32am, GinA sent an email to Rob Overton,

I have spiders and fleas and other bugs that are becoming a
nuisance to both myself and my cats. I have ordered flea medicine for my cats
which will be here this week but I dont know how to properly clean my house
of the bug problem.
Please do not contact Greg about this yet. He got an eviction judgment
against me for a 30-day notice and I have appealed it for a jury trial in
Superior Court. Things are heating up on Court Street.
251.
On September 11, 2014, 9:38am, Rob Overton sent an email to GinA,

Currently, are there any other tenants in the building?
252.
On September 11, 2014, 9:41am, GinA sent an email to Rob Overton,

Nobody else physically resides here except myself, although there is a legal
tenant and his belongings in Unit 2 who is in county jail with no planned date of
release
253.
On September 12, 2014, 1:25pm, Rob Overton sent an email to GinA,

I spoke with Greg this afternoon. He said that his exterminator refused to
work in your apartment, but declined to tell me why
254.
On September 16, 2014, 1:18pm, GinA sent an email to Rob Overton,

I just filed another notice of appeal in District Court on questions of law
claiming all at will leases and two sections of the eviction law are
unconstitutional which effectively strip me of my rights to enjoy and possess
my property and which prevent me from asserting any legal defenses against
eviction.
Ive also asked for a stay on the writ of possession which has not yet
issued.
1:16-cv-00100-NT
Page 87 of 115
PageID #: 198
My notice of appeal was filed properly within the 30 days after

judgment (August 20) and before the writ of possession issued so I should be
allowed to appeal on questions of law, but that decision will be up to the same
judges who are going to park their cars in my bedroom when this building is
torn down for the courthouse parking lot so Im not going to hold my breath
expecting the judges to rule in my favor.
The judges, the City and the State want this block for their precious
courthouse parking lot and thats all there is to it and they will get it one
way or another
But Im not going down without making them earn their victory in
public view
By the way, I will be testifying at the public council meeting this week to
protest their proposed historic district which I suspect will not include the
Perham/Court Street block its going to be a very interesting public meeting
Ill let you know what District Court says about staying the writ of
possession on my appeal that I filed today
think good thoughts!
Gina
255.
On September 22, 2014, 4:32pm, Rob Overton sent an email to GinA,

I also made it clear to Greg that he will not be allowed to move
anyone else into the building until the electrical issues and the porches and
railings are corrected to my satisfaction. This will require a master electrician
to certify that the electrical is safe and code compliant
256.
On September 24, 2014, 8:42am, GinA sent an email to Rob Overton,

The sheriff tried to serve a writ of possession on my [sic] yesterday but I
didnt answer the door. I have to be careful not to answer the door for him
today because it will start the 48 hours tolling and I dont have a place to go
yet Are you coming over today?
257.
On September 24, 2014, 9:19am, email from Rob Overton to GinA,

Yes, I will be there later this morning. Around 11 to 1130 if that works
for you?
258.
Robert Overton immediately called Kennebec County Sheriffs Office to tell
them GinA was at home so they could serve her with the writ of possession.
259.
On September 24, 2014 around 11:15am, GinA was served with a writ of
possession while GinA was outside talking to Robert Overton.

260.
On September 25, 2014, 12:06pm, email from Rob Overton to GinA,

Gina,
1:16-cv-00100-NT
Page 88 of 115
PageID #: 199
I know you already gave it to me, but I cannot find the name of the
gentleman that leases the other unit in your building. I want to make sure that
he does not fall through the cracks since he is not there and may not be aware
of the issues in the building. Any contact info you can share is greatly
appreciated.
I hope your apartment viewing on Gage went well. How does the inside
of that building look?
Rob
261.
On September 26, 2014, GinA moved out of 32 Court Street but she was not
able to remove all of her possessions and was forced to leave some of her possessions
at the property.
262.
GinA was homeless from September 26 until November 11, 2014.
263.
While GinA was homeless, she was threatened with false arrest by City of
Augusta Police, with gun violence and bodily injury by Mike Vermette of Winslow,
and she lost over $1000 cash to theft by strangers who rented her a place to sleep.
264.
On June 12, 2015, Matthew Pouliot and his wife refinanced their new historic
home at 99 Winthrop Street for $150,000.00 (for which they only paid $72,000) as
recorded on June 17, 2015 in Bk 12012 Pg 246.
265.
On July 10, 2015 at 6:55am GinA commented on a July 9, 2015 KJ article
titled With Augusta apartment building gone, Kennebec courthouse gains public
parking lot,
such a slap in my face ... but i promise i'm not done yet ... [sic]
266.
On July 10, 2015 at 1:58pm Michael St.Andrews commented on the same KJ
article above,
So let me get this straight, we razed 3 apartment buildings for a new
parking lot (say goodbye to developed property tax income), when the old Ymca
property was already there and available. Where was the thinking on
this????? [sic]
(See https://www.centralmaine.com/2015/07/09/with-augusta-apartmentbuilding-gone-kennebec-courthouse-gains-public-parking-lot/comments/ )
1:16-cv-00100-NT
Page 89 of 115
VI.
PageID #: 200
STATEMENT OF THE CASE
GinA asks this court the same question Michael St. Andrews asked,
Where was the thinking on this?????
Today, GinA lives alone at 2528 West River Road, Sidney at a safe distance
away from City of Augusta All_Police Officers now without a paying job, a car or a
drivers license with support from a community caseworker and GinAs immediate
neighbors while trying to exercise her federal fair housing rights to have a safe and
affordable low income dwelling which Congress promised to protect against all
unlawful discrimination, intimidation, coercion, harassment or interference in 42
USC 3601 and 3617.
The evidence in this complaint and its companion complaint 1:16-cv-00095NT show Defendants and their co-conspirators thinking was not about serving low
income disabled homeless tenants or about fulfilling their legal duties as paid public
servants, licensed real estate brokers and landlords who all have a legal duty under
42 USC 3601 inter alia.
The evidence proves Defendants individual and joint thinking was only
about creating more court business at low income disabled homeless Maine
taxpayers expense and to bolster their own personal, professional, financial and
political positions as individuals, public servants and licensed real estate brokers.
Mainers are now required to pay expenses for the concrete monstrosity at 1
(32) Court Street, Augusta while trying to recover from the permanent destruction
of four historic residential buildings which have injured and will continue to injure
every low income disabled homeless tenant in Maine at least by not having access to
four safe habitable low income dwellings on Perham and 32 Court Streets.
To add insult to injury, City of Augusta, William Bridgeo and Matt Nazar
now want to declare the 1 Court Street neighborhood as part of a historic district
after they intentionally destroyed four historic residential homes that were more
than a century old each and which was home to Augustas first City Marshall.
1:16-cv-00100-NT
Page 90 of 115
PageID #: 201
Instead, Mainers now have to pay a $60M bond for a new courthouse which
will not generate any new jobs at the direct expense of low income disabled people.
Defendants did not individually partake in each and every event in this
complaint but they each individually conspired with at least one or many other
Defendants for the purpose of depriving GinA of her fair housing rights because she
is a disabled, low income woman with a history of being homeless and who legally
defends herself and helps other tenants learn how to legally defend themselves.
GinAs 415 days of forced homelessness from March 1, 2012 until November
11, 2014 were due to Defendants' malicious interference with GinAs housing rights.
The evidence shows William Stokes, Matthew Pouliot and Greg Roy directly
personally benefited from the sale and destruction of 32 Court Street after GinA
was evicted by Maine Judicial Branch at the hands of Leigh Saufley et al in a state
court which William Stokes knew was completely absent all jurisdiction, see 1:16cv-00095-NT, because the court was going to be the final owner of the land after
GinA was literally kicked out onto the street by their illegal forceful eviction.
Greg Roy should have filed the eviction case in federal district court or the
state district court should have transferred the eviction case sua sponte to a federal
district court.
Aside from Greg Roys illegal eviction, on behalf of City of Augusta et al, the
federal district court would have been required to conduct a fact finding on the
legality of GinAs eviction and City of Augusta and Maine Judicial Branch using
threat of eminent domain to force a sale of occupied low income homes on Perham
and 32 Court Street for construction of a new courthouse and its parking lots
without replacing any lost dwelling units.
GinA holds Defendants individually responsible for their distinct actions as
well as jointly responsible for aiding and abetting, or neglecting to prevent any or
all other Defendants from intimidating, coercing, harassing, threatening, arresting,
assaulting and imprisoning GinA from February 10, 2011 until September 26, 2014.
1:16-cv-00100-NT
Page 91 of 115
PageID #: 202
Defendants actions were intended to deprive GinA and which in fact deprived
GinA of her fair housing rights as a disabled low income woman who has a history
of homelessness and speaking publicly against legal injustices about housing rights.
A.
Title II, Americans with Disabilities Act, 42 USC 12132

1.
Medical Suspension under 29-A MRSA 2458(2)(D),

a.
January 5, 2010
b.
The protections afforded under Title II of the ADA are of
meaningful access to government benefits and programs requiring

public entities to take reasonable steps to ensure people with
disabilities are able to participate in and enjoy public proceedings,
government services and activities.
c.
Proving a prima facie case under Title II of the ADA means
GinA must establish that she is: (1) a qualified individual with a
disability; (2) she was excluded from participation in or denied the
benefits of the public entitys services, programs, or activities or was
otherwise discriminated against; and (3) such exclusion, denial of
benefits, or discrimination was by reason of her disability.
d.
The courts have said public entities certainly have the right to
consider whether a person with a disability poses a direct threat to the

health and safety of others. However, the Department of Justice
regulations insist that any such direct threat finding must be based on
reasonable medical judgment relying on current medical knowledge or
on the best available objective evidence, not on medical presumptions
made in 2005 for actions taken in 2010.
e.
GinA safely traveled on Maine and federal roads starting in
1988 in her own automobile. GinA received violation free credits for
that safe behavior for years 2008, 2009 and 2010 so it was reasonable
to presume GinA did not pose a threat to the public nor was she in any
way incompetent to drive a motor vehicle (as evidenced by violation
free credits) simply because of some medication she was known to have
1:16-cv-00100-NT
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PageID #: 203
taken in 2005 which was the sole basis of BMVs license suspension on
January 5, 2010.
f.
BMVs January 5, 2010 medical suspension directly caused
William Stokes to officially defend the medical suspension and its

criminal results in his official capacity as Deputy Criminal AG which
set a course of legal events into motion which directly deprived GinA of
her fair housing rights and her rights under the ADA as a disabled,
low income homeless woman when she tried to access government and
court services to find and maintain a safe affordable low income home.
g.
Title II ADA regulations prohibit a public entity from
administering a licensing program in a manner subjecting qualified

individuals with disabilities to discrimination on the basis of disability.
In addition to citing to the Code of Federal Regulations outlining this
principle, courts refer to Department of Justices Title II technical
assistance manual which prohibits a public entity from establishing
any requirements for programs or activities of licensees resulting in
the discrimination against those qualified individuals with disabilities.
h.
Although the ADA contains a provision that discrimination
occurring as a result of licensing requirements is not discrimination

under the ADA, any action which interferes with GinAs fair housing
rights, such as revoking the drivers license which took away GinAs
ability to get a job to pay for housing, preventing her from traveling to
and from her housing, going to the grocery store, visiting family,
accessing government and court services, and many similar examples,
which are all clear violations of the FHA and FHAA because a medical
suspension of the drivers license was a direct result of GinAs known
disability which was not known to pose any type of danger or public
threat and which directly and significantly interfered with and
prohibited GinA from exercising her fair housing rights under the
FHAA.
1:16-cv-00100-NT
Page 93 of 115
i.
PageID #: 204
There are two defenses the Defendants may use if they try to
overcome any sovereign immunity defense. First, under United States

v. Georgia 546 U.S. 151 (2006), sovereign immunity is waived where
the facts rise to the level of a constitutional violation. Second, if the
facts do not rise to the level of a constitutional violation, the courts
must then adhere to the principles laid out in Tennessee v. Lane 541
U.S. 509 (2004) which gets into the issue of any equal protection
classes which GinA may fall into and whether BMVs licensing scheme
is a proportional response to the alleged harm BMV claims they were
attempting to redress by the medical suspension for incompetence.
j.
Maine BMV, City of Augusta, City of Augusta Police
Department, City of Augusta All_Police Officers, and William Stokes

as Deputy Criminal AG conspired to criminally prosecute GinA for a
medical suspension of drivers license #1491178 which was solely
based on her disability.
B.
Congressional Fair Housing Policy, 42 USC 3601It shall be unlawful
to coerce, intimidate, threaten, or interfere with any person in the exercise or

enjoyment ofany right granted or protected by section 3604 of this title.
1.
Disparate Impact
a.
Augusta Maines Low Income Housing Crisis of 2015

i.
City of Augusta, Augusta Housing Authority, Augusta Housing

Service Corporation, William Stokes, Matthew Pouliot, William
Bridgeo, Matthew Pouliot, their agents, commissions and bureaus
have:
(A)
Failed to pass proper local ordinances to fix unfit low income
housing,
(B)
Failed to enforce existing local ordinances to fix unfit low income
housing,
(C)
Failed to condemn unfit low income housing,
(D)
Failed to repair unfit low income rental buildings,
1:16-cv-00100-NT
Page 94 of 115
(E)
PageID #: 205
Refused to spend any money to build new or repair existing unfit
low income housing,

(F)
Discriminated in favor of elderly housing by renovating three
public buildings for elderly housing projects,

(G)
Destroyed four low income buildings for court business,
(H)
Changed zoning ordinances to allow expansion of a courthouse in
a low income residential neighborhood,

(I)
Created Augusta Housing Service Corporation and other non-
profit and for-profit corporations without the peoples public vote and
approval,
(J)
Created non-profit and for-profit corporations for the sole
purpose of receiving federal funding to create elderly housing projects,

(K)
Allowed Augusta Housing Service Corporation to neglect its
public duty under its charter and IRS 501(c)(3) exemption to build and
repair low income housing units while it has $300,000 cash assets,
(L)
Refused to hold closed public meetings for tenants,
(M)
Refused to file legal actions against law-breaking landlords on
behalf of and in protection of tenants,

(N)
Refused to appear on behalf of tenants without a court-issued
subpoena for all eviction actions,

(O)
Caused or allowed GinA and other low income disabled tenants
to become homeless at least 3 or more times,

(P)
This list is not exclusive of many different types of disparate
impact Defendants have inflicted upon the low income disabled and
homeless classes of people in Maine.
2.
Eminent Domain prohibited

The State MUST PROVE this eminent domain taking IS NOT for
COMMERCIAL PURPOSES nor Primarily for the enhancement of tax
revenue under 1 MRSA 816(1)(B) which is the very nature of ALL COURT
BUSINESS!!
1:16-cv-00100-NT
Page 95 of 115
PageID #: 206
(See May 20,2014 email between GinA and Matthew Pouliot) and
(See Maine Judicial Branch FY10-FY15 Annual Reports announcing
all court money is deposited into the State of Maine General Fund making
up 2% of total taxpayer general funds)
a.
Destruction of Perham and 32 Court Streets residences

The only purpose Defendants had to destroy Perham and 32 Court
Street low income homes was to build the Capital Judicial Center and
its parking lots; otherwise, GinA would likely still be living in Unit 1 at
32 Court Street and Perham Street homeowners would still be alive
and living in their homes.23
b.
Capital Judicial Center, 1 Court Street, Augusta, 2009 2015
The old YMCA lot on the corner of Winthrop and State Streets is
vacant and cleared and is double the total size of the entire Perham
Street and 32 Court Street block.
At least GinA and Michael St. Andrews made public suggestions to

the City of Augusta for more court parking at the old YMCA vacant
lot which would not have displaced any homeowners or businesses
and would have allowed more residents to use the public parking
garage or parking lot during evenings, weekends and holidays.
Another viable option was to build onto the existing parking garage
at the bottom of Winthrop Street which is not utilized at any time to
its fullest capacity during the workweek and which could provide
safe undercover parking spots for court business and which could
have been connected to the courthouse by an underground tunnel or
Interesting side note: Jim Osier passed away on March 23, 2015 after being forced out of his
Perham Street home in late 2014. (See September 27, 2013, 10:28am email between Jim Osier and
Keith Luke) (See http://obituaries.centralmaine.com/obituaries/mainetodaycentralmaine/obituary.aspx?n=james-w-osier&pid=174486650
3 City of Augustas online assessment database no longer shows Perham Street in the street index.
2
1:16-cv-00100-NT
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PageID #: 207
above-ground catwalk which already exist in government building

structures and state-owned properties.
3.
Disparate Treatment
Fair Housing Amendments Act of 1988, 42 USC 3604(f)

GinA has provided this court with overwhelming public evidence in her
Factual Background and companion case 1:16-cv-00095-NT which certainly shows
all individual Defendants in this case are males and the corporations are overseen
by males who discriminated against GinA at least for one or many reasons. Without
deciphering each individual event in its micro context to determine if GinA was
being discriminated against because she was a female, disabled, low income or
homeless, it is undeniable that GinA was subjected to repeated events of illegal
discrimination which all began as a result of GinA reporting her disability to BMV
in 2005 and all actions all Defendants have taken in defense of that initial
discrimination, and other events of discrimination which occurred in defense of
themselves and their conspiracy to cover it all up.
239 Cony Street, Unit 2
Traffic Violation, Ticket #2576761, February 10, 2011
In or around 2006 the City of Augusta, William Bridgeo and their agents
approved the installation of a No Left Turn sign at the corner of Townsend Road
and Marketplace Drive to control left-turning traffic during the expansion of the
Marketplace at Augusta shopping center which began in 2005.
Until the City of Augusta installed that traffic control device, everyone was
allowed to make a left turn onto Townsend Road from Marketplace Drive.
Augusta Ofc. Eric DosSantos was ascending the hill on Townsend Road from
Civic Center Drive and alleged to have seen GinA make a left turn onto Townsend
Road from Marketplace Drive even though Ofc. Eric DosSantos has never provided
any dashcam video to prove his allegations.
GinA told Ofc. Eric DosSantos he had no probable cause or suspicion of any
kind of criminal conduct which would allow him to stop GinAs car but Ofc. Eric
1:16-cv-00100-NT
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PageID #: 208
DosSantos ignored his oath to the constitution and gave GinA a violation summons
#2576761 for failure to obey traffic control device and sent GinA on her way.
Evidence of disparate treatment against GinA by Leigh Saufley et al in
conspiracy with City of Augusta et al abundantly exists in the companion case and
other lower state court cases as referenced in 1:16-cv-00095-NT.
Supporting evidence in reference to all criminal prosecutions and legal
actions resulting from City of Augusta et als actions exist in the companion case
and other lower state court cases as referenced in 1:16-cv-00095-NT.
AUGDC-CR-2011-512 and AUGDC-CR-2011-513
On March 7, 2011 GinA had just left her job at Dunkin Donuts in WalMart
at Marketplace Shopping Center traveling in her legally registered and insured
automobile without engaging in any behaviors which would give any police officer
probable cause to make a traffic stop on GinAs private car.
Despite GinAs lawful behavior, and despite Ofc. Eric DosSantos knowledge
that license #1491178 was suspended by BMV Medical Unit for medical reasons and
#1491178 driver record showed violation free credits for 2008 and 2009, Eric
DosSantos again violated his oath to the constitution and effected an illegal traffic
stop on GinAs car without any probable cause or suspicion of any kind of criminal
conduct.
Eric DosSantos illegal, unconstitutional and discriminatory actions were all
based on his foreknowledge that GinA had a disability for which BMV Medical Unit
had suspended license #1491178 for medical reasons.
Despite Eric DosSantos knowledge of the benign medical suspension, he
issued uniform summonses for two counts of operating after suspension and other
civil violations which had the effect of directly discriminating against GinA as a
direct result of her disability and directly because GinA had properly reported her
disability and its medications to BMV Medical Unit in 2005 under MVRules 29-250
Ch. 3 which rule is unconstitutional on its face, biased against people with
disabilities, a direct violation of Title II of the ADA, and an indirect violation of the
FHA and FHAA because Mainers must be able to travel independently by car in
1:16-cv-00100-NT
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PageID #: 209
order to obtain and maintain safe and affordable housing because there is not
enough state-sponsored or private funded commuter services to serve Mainers who
live in isolated communities on the outskirts of major areas.
Additionally, State of Maine Secretary of State Matthew Dunlap exacerbated
the problem by rejecting GinAs fully-endorsed proposal in 2007 to offer public
information about the state-sponsored and state-funded GoMaine Commuter
Connections to all licensed drivers so they would have a way to transport
themselves if they ever found themselves in a situation similar to GinAs or similar
situations of the customers GinA and her co-workers served in the OUI Unit.
AUGSC-CR-2012-286
On February 16, 2012, GinA was forcibly physically removed from her car
and arrested by City of Augusta Police Department Sgt. Christopher Shaw, Augusta
Police Ofc. Christopher Guay and Augusta Police Ofc. Scott Harris for operating
after suspension and other criminal and civil charges no more than one month after
GinAs private home was invaded by Augusta Police Ofc. Peter Cloutier on January
18, 2012 which GinA recorded and released to the public and had a meeting with
Sgt. Christopher Shaw about no more than two weeks prior to the February 16th
arrest.
GinA informed City of Augusta Police et al that she considered the February
16th traffic stop to be retaliation for GinA recording Ofc. Peter Cloutiers illegal
invasion of GinAs private home and it was Augusta Police Departments and
Augusta All_Police Officers way of intimidating GinA for exercising her rights to
have safe, affordable and peaceful housing.
3 Washington Street Place, Unit 1
GinA was forced to live in the armpit of Augustas ghetto in a room that GinA
believed was a legal rooming house at 3 Washington Street Place because she had to
sell her a car because she didnt have the ability to travel in her car without facing
constant threat of illegal arrest and imprisonment by City of Augusta Police and
their other law enforcement and judicial agents for reporting her disability to BMV
in 2005.
1:16-cv-00100-NT
Page 99 of 115
PageID #: 210
GinA was then forced to find a safe affordable low income dwelling in the
inner city of Augusta which she could afford on less than $835 cash per month social
security disability benefits without having the ability to get a part time job because
she didnt have access to regular intercity or inner-city public transportation during
the week or on the weekends because it doesnt exist in the Augusta area.
Instead, GinA spent most of her time learning how to write this lawsuit.
AG Criminal Investigation September 2013, MTJL
Attempted Entrapment by William Stokes and Tracy Thompson
After GinA endured years of official abuses and discrimination at the hands
of her government servants and private abuse by greedy ruthless lawless landlords,
GinA decided the public needed to be educated and they needed GinAs assistance to
educate themselves about their rights and responsibilities as tenants and landlords.
GinAs legal background which grew partly from her experiences defending
herself against ruthless landlords for the past 30 years and partly from being
trained by some of Maines best attorneys and judges in Maine gives her the skills
necessary to walk the fine line between providing public education and giving legal
advice which GinA knows she is not legally qualified to do under Maine BAR Rules.
Even if GinA was a licensed practicing attorney, GinA knows only a litigant
or witness can enter evidence and facts into the record so a lawyers activities would
be limited to discussing the law and procedure of any lawsuit which GinA already
knew from prior years of working with state government, courts, lawyers, landlords
and other legal people.
GinA always encourages people to learn the law and rules of procedure so
they do not feel they must rely on attorneys for laws everyone should be educated to
learn.
William Stokes and his official state agent Tracy Thompson disregarded their
knowledge that GinA is not a licensed attorney when they initiated formal criminal
investigations into GinAs public legal advocacy activities with her nonprofit civic
league, MAINE TENANTS JUSTICE LEAGUE which she incorporated in July
2013.
1:16-cv-00100-NT
Page 100 of 115
PageID #: 211
William Stokes acted in his official capacity as Criminal Deputy Attorney

General when he authorized his agent Tracy Thompson to entrap GinA to give
Tracy Thompson legal advice about a tenants rights when a landlord is required to
eradicate bed bugs from a rental unit. However, an hour later, GinA responded to
Tracys entrapment attempt with a lawful response directing Tracy or her in-house
attorneys to read the law which terminated all formal criminal investigations into
GinAs public legal advocacy activities, as far as GinA knows.
William Stokes authorized the illegal attempt to entrap GinA simply because
GinA was exercising her rights under the 1st Amendment and 42 USC 3601 and
3617 to educate the public about their rights and responsibilities when engaging in
landlord/tenant contract relationships.
MAINE TENANTS JUSTICE LEAGUE, which is operated by just GinA at
this time, has served over 150 tenants and other types of callers since June 1, 2013,
prevented more than 6 illegal evictions, delayed countless other illegal evictions,
spoken with tenants who have been abused by Pine Tree Legal Assistance, Code
Enforcement, Attorney General, Maine State Housing Authority, City of Augusta,
and other co-conspirators who violate tenants fair housing rights, created a positive
statewide relationship with tenants and social service agencies in Maine which
provide services for low income disabled homeless people.
MAINE TENANTS JUSTICE LEAGUE recently received a call from a tenant
who had been referred by his community caseworker. GinA suggested he call the
Office of Attorney General Consumer Protection Division and file an official report
against the landlord for deceptive and unfair trade practices and violations of the
ADA and Fair Housing Act.
32 Court Street, Unit 1
Maine Judicial Branch, Leigh Saufley et al, City of Augusta and their agents
conspired to aggressively target 32 Court and Perham Streets for demolition
because they knew the homeowners were all low income people who did not have
the financial ability, education, occupational background or spiritual tenacity to
challenge Maine Judicial Branchs illegal taking of their low income private homes
1:16-cv-00100-NT
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PageID #: 212
for construction of a courthouse parking lot when City of Augusta and its agents
knew the old YMCA lot was double the size of the Perham/32 Court Street block,
was vacant, cleared, and would not displace any homeowners or tenants.
City of Augusta and its agents allowed GinA to occupy 32 Court Street as a
low income disabled tenant even though they knew they were targeting 32 Court
Street to be razed for the courthouse parking lot which they never told GinA.
After City of Augusta and its agents allowed GinA to move into a rare legal
rooming house low income apartment building which they were planning to take
away from her within nine months through force of an illegal eviction, they then
discriminated against GinA by subjecting her to constant torture of loud persistent
early morning noises emanating from the construction site before and after 7am
and refusing to shut down 32 Court Street for violations to life safety codes.
In addition to discriminating against GinA after allowing her to move into an
unfit dwelling, Robert Overton facilitated the service of the illegal writ of possession
by calling Kennebec County Sheriffs office to tell them GinA would be home during
Robert Overtons inspection of the flea infestation on September 24, 2014.
Less than twenty-four hours later adding insult to injury, Robert Overton
called GinA in his official capacity as Code Enforcement Officer to get the phone
number of the male tenant in Unit 2 so he would not fall through the cracks
because he [was] not there even though Robert Overton had never taken any type of
protective action on GinAs behalf the entire 5 years she has worked with him.
Robert Overton told GinA that Robert Overton was very comfortable about
why he did everything he did as a Code Enforcement Officer for City of Augusta and
Matt Nazar so GinA reasonably presumes Robert Overton was acting under official
direction of the City of Augusta and its official agents when he constantly
discriminated against GinA because she was a woman who was known to have a
history of homelessness who was disabled low income and in desperate need of a
safe and affordable rental housing in the inner areas of Augusta.
Robert Overton took advantage in his official capacity as a Code Enforcement
Officer of personal private conversations he had with GinA over the past five years
1:16-cv-00100-NT
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PageID #: 213
about his work for the City of Augusta and about the various illegal activities of the
local landlords which the City of Augusta continues to conspire to perpetuate.
As the KJ described, Robert Overton was hired by City of Augusta to lead
the crackdown.
The true question is what type of crackdown are the Maine Judicial
Branch, the City of Augusta and Robert Overton leading?
The evidence proves the Maine Judicial Branch and City of Augustas legal
crackdown is discriminatory against low income disabled and homeless tenants who
have no other resources for safe and affordable housing in Maine in violation of
every low income disabled homeless tenants federal fair housing and ADA rights.
Interference, Intimidation, Coercion, 42 USC 3617
It shall be unlawful to coerce, intimidate, threaten, or interfere with any
person in the exercise or enjoyment ofany right granted or protected by section
3604 of this title.
This complaint depicts some of the most significant deprivations and acts of
interference, intimidation, coercion, and discrimination achieved against GinA since
2011 and which directly deprived her of her fair housing rights by preventing her
from traveling in her own car to and from a paying job, to and from her home in a
neighborhood of her choice outside of the city limits of Augusta which was the direct
and proximate cause for GinAs homelessness from 2012 2014 until she moved out
of Augusta on September 26 and into Sidney on November 11, 2014.
However, illegal deprivations against GinAs fair housing rights as a disabled
low income woman did not stop when she left legal boundaries of Augusta because
Leigh Saufley et al continued to enforce the original conspiracy in GinA v. David
Brennan, KEN-CV-15-58 and David Brennan v. GinA, WATDC-SA-15-271, inter
alia, as described in more detail in the companion case 1:16-cv-00095-NT.
COUNT I
Violation of 42 USC 12132
1:16-cv-00100-NT
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1.
GinA re-alleges and incorporates by reference the allegations set forth above.
2.
Defendants repeatedly and knowingly violated Title II of the ADA when they
intentionally and maliciously discriminated against and excluded GinA and other
low income disabled and homeless tenants from participation in or denied GinA and
other low income disabled and homeless tenants benefits of the services, programs,
or activities of City of Augustas public activities regarding low income housing.
3.
Defendants repeatedly subjected GinA to discrimination based on her
disability during performance of their official duties as public servants.

COUNT II
4.
5.
Defendants wrongfully violated the policy of the United States to provide,
within constitutional limitations, for fair housing throughout the United States. by
repeatedly denying GinA and other low income disabled and homeless tenants their
fair housing rights to live in safe affordable low income housing without the threat
of interference, coercion or intimidation by private people and public servants for
exercising their fair housing rights under 42 USC 3601 et seq.
COUNT III
Violation of 42 USC 3604(f)
6.
7.
Defendants wrongfully discriminated in the terms, conditions, or privileges of
low income rental units and otherwise made low income rental units unavailable to
GinA and other low income disabled and homeless tenants and denied GinA the
right to enjoy long-term rental contracts for her low income dwellings because of
GinAs disability and because she is a member of the homeless community which
makes her and people who are similarly situated most vulnerable to greedy ruthless
predator landlords like Royce Watson, Ray Corporation and Greg Roy.
COUNT IV
8.
1:16-cv-00100-NT
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9.
PageID #: 215
The public evidence listed in this complaint amply prove Defendants have
repeatedly coerced, intimidated, threatened, or interfered with GinAs exercise and

enjoyment of, or on account of GinA having exercised or enjoyed, any right granted
or protected by section 3604 of Title 42 USC.
COUNT V
Violation of 1st Amendment
10.
11.
The public evidence listed in this complaint amply proves Defendants have
repeatedly deprived GinA of her right to speak, to be heard, to have access to public
information and to assemble as aptly evidenced in the many public records restated
verbatim in the Factual Background.
COUNT VI
Violation of 14th Amendment
12.
13.
The public evidence listed in this complaint amply proves Defendants have
repeatedly deprived GinA of her right to enjoy due process as evidenced in the many
public records stated verbatim in her Factual Background.
COUNT VII
42 USC 1981
14.
15.
Defendants repeatedly and chronically violated GinAs equal rights under
color of state laws as a disabled low income homeless woman to violate her fair
housing rights, to violate the ADA and her right to travel as a disabled low income
homeless woman, to speak, to be heard, to assemble, to make fair terms in her
rental contracts, to have equal rights to have access to public information about safe
affordable housing that directly impacts her fair housing rights and her life, liberty
and pursuit of happiness, to have equal rights to have quiet enjoyment of her
residence free from governmental interferences with her right to exchange
information, to be free from threat of being forced to be a party to and give evidence
at fraudulent eviction bench trials presided over by courts and public servants who
1:16-cv-00100-NT
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PageID #: 216
would be acting in complete absence of all jurisdiction, and to enjoy full and equal
benefit of laws and proceedings for the security of GinAs person and property, inter
alia.
16.
Defendants City of Augusta Police Department, City of Augusta All_Police
Officers and William Stokes filed and then conspired with Leigh Saufley et al when
prosecuted and defended multiple bogus criminal and civil charges against GinA
directly and solely because of GinAs disability in 2011 and 2012 for GinA exercising
her right to travel in her private car to get to her job and a grocery store without a
drivers license solely because the BMV Medical Unit maliciously and arbitrarily
suspended drivers license #1491178 for medical incompetence as a direct result of
GinA reporting her legal disability under Motor Vehicle Rules 29-250 Ch. 3 which is
unconstitutional and directly violates HIPAA privacy clauses, Title II of the ADA
for fair public transportation and government services, the FHA and Fair Housing
Amendments Act of 1988 by preventing GinA from traveling by herself in her own
private car to and from her safe and affordable low income home to her minimum
wage part-time job so GinA could maintain her safe, peaceful home in Augusta for
her daughter and granddaughter.
COUNT VIII
42 USC 1983
17.
18.
Defendants subjected or caused GinA to be subjected to a deprivation of her
rights, privileges and immunities secured to her by the federal constitution and
federal laws under color of state laws during public government proceedings and
exchanges of public information during GinAs quest for safe affordable low income
housing in Augusta in pursuit of GinAs federal ADA and fair housing rights.
19.
rights, privileges and immunities with regard to her federal ADA and fair housing
rights at both 239 Cony Street and 3 Washington Street Place where she was
terrorized by tenants and landlords because she is a disabled low income woman
1:16-cv-00100-NT
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PageID #: 217
who exercises her right to have safe affordable low income housing and to be secure
in her papers and property from illegal search and seizure.
20.
rights, privileges and immunities secured by the federal constitution and laws
under color of state law because GinA was a disabled homeless low income woman
desperate for safe affordable housing in the inner city of Augusta by allowing Unit
1, 32 Court Street to be opened and occupied in January 2014 without warning
GinA of the imminent dangers directly causing GinA to enter into a fraudulent
rental contract with Greg Roy for eight months of a torturous occupancy directly
resulting in GinA being forced to be a party to a fraudulent eviction lawsuit in
AUGDC-SA-14-453, and ensuing fraudulent appellate proceedings in AP-14-56 and
KEN-14-410 which were all wrongfully presided over by state courts and state
judicial servants who knew they were acting with a complete absence of all
jurisdiction because of their significant conflict of interest with Greg Roy in their
future purchase and possession of his property at 32 Court Street.
21.
Defendants wrongful deprivation of GinAs equal rights, privileges and
immunities secured to her by the Constitution under color of state laws by

discriminating against GinA when GinA reported the oil leak at the basement of
239 Cony Street and the illegal ensuing discriminatory eviction by Royce Watson
which was the direct and proximate cause for the all of GinAs injuries caused
during her occupancy and business transaction for 239 Court Street after October 1,
2011, all injuries GinA sustained while she was homeless between March 1, 2012
and January 13, 2013, and all injuries GinA has sustained as an occupant at 3
Washington Street Place as a direct result of being fraudulently evicted by use of
excessive and improper police power by Defendants judicial agents on March 1,
2012 from 239 Cony Street in Royce Watson v. Gina Turcotte, AUGDC-SA-2011-___.
22.
Defendants wrongful deprivation of GinAs equal rights, privileges and
immunities secured to her by the Constitution under color of state laws by censoring
public information about the imminent demise of 32 Court Street was the direct and
proximate cause for the all of GinAs injuries caused during her occupancy and
1:16-cv-00100-NT
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PageID #: 218
business transaction for 32 Court Street, all injuries GinA sustained while she was
homeless between September 26 and November 11, 2014, and all injuries GinA has
sustained as an occupant at 2528 West River Road, Sidney as a direct result of
being fraudulently evicted by use of excessive and improper police power by
Defendants judicial agents on August 19 and September 26, 2014 in AUGDC-SA14-453.
COUNT IX
Violation of 42 USC 1985 (3)
23.
24.
Defendants wrongfully conspired to deter GinA by force, intimidation and
threat of force under color of state laws from testifying and attending public
meetings and proceedings.
COUNT X
25.
26.
Defendants had knowledge that the wrongs they conspired to do herein and
having the power to prevent or aid in preventing the commission of such unlawful
acts or neglected or refused to prevent those wrongful acts despite Defendants
ability to prevent such wrongful acts did in fact cause severe, permanent and
irreparable injuries to GinAs person, property, reputation, health, safety and
welfare.
GinAs DAMAGES
27.
GinA was unwillingly homeless for at least 415 days between March 1, 2012
and November 11, 2014 directly due to Defendants criminal conspiracies,

28.
GinA suffers daily emotional torture watching her 28 year old daughter
struggle to find safe affordable low income housing in a safe neighborhood in

Augusta for GinAs 5 year old granddaughter.
29.
GinA suffers emotional torture knowing her daughter and granddaughter are
suffering at the hands of GinAs abusive mother because GinAs daughter has to live
1:16-cv-00100-NT
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PageID #: 219
with GinAs mother while GinAs daughter tries to find a safe affordable low income
home in a peaceful Augusta neighborhood for GinAs granddaughter.
30.
GinA worries greatly about where GinA will live if she ever needs to find
rental housing in Augusta at any time in the future.

31.
GinA suffers daily emotional torture because she is financially and physically
unable to help her daughter and granddaughter because GinA cannot travel by
herself to get a paying job so she doesnt have many ways to help her family.
32.
GinAs inability to help her daughter and granddaughter has been the direct
and proximate cause for the significant deterioration and breakdown in GinAs
relationship with her daughter because GinAs daughter does not understand the
criminal and legal injustices committed against GinA for the past 7 years.
33.
GinA has been alienated from her entire family as a direct result of GinA
being charged with multiple criminal and civil charges, her inability to get a job,
maintain stable housing, have a relationship with her daughter, granddaughter and
other family members the way she is supposed to have and wants to have,
34.
GinA lost thousands of dollars to theft and out-of-pocket direct expenses
while she was homeless, including costs for housing, transportation and storage,
35.
GinA was threatened with bodily injury by a firearm and false arrest by
Augusta Police while she was homeless between September 26 and November 11,
2014.
36.
GinA has become hyper vigilant of any type of attacks that may be lodged
against her which has caused her to always be on alert for any subtle signs of
danger which causes her severe sleep deprivation and other persistent physical,
emotional and mental injuries,
37.
GinAs physical health has deteriorated to such a severe state that she is now
considered legally malnourished due to her in inability to transport herself to the

grocery store, because of her housing instabilities and financial destitution,
38.
GinA has lost most of her teeth since 2011 because of total malnourishment,
39.
GinAs loss of most of her teeth exacerbates her total malnourishment,
1:16-cv-00100-NT
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40.
PageID #: 220
GinAs loss of most of her teeth directly damages GinAs public reputation,
personal relationships, and her total self-esteem, physical health and wellness,
41.
GinAs malnourishment and tooth loss has directly caused GinA to experience
a very dangerous weight loss of more than 30 pounds since 2012,

42.
GinAs inability to travel independently has served to imprison GinA within
her various homes since March 7, 2011 as a direct result of Augusta Police
Department, William Stokes and their judicial agents maliciously prosecuting GinA
for having a medical disability and making a proper report of it to BMV,
43.
GinAs inability to travel to the outskirts of Augusta and other parts of Maine
in her own private car without a chauffeur was the direct and proximate cause for
GinA having to live in the armpit of the ghetto at 3 Washington Street Place which
served to re-traumatize GinA by having to experience Tyler Robinsons daily
domestic violence against GinA and his live-in girlfriend for which GinA had no
landlord or police protection,
44.
GinA lost possession and ownership of her beloved service animal to Humane
Society Waterville Area (Smokey, her well-trained emotional therapy cat) after
GinA was kicked out of 239 Cony Street and had to stay a hotel in Waterville that
evicted GinA after 3 days under threat of false arrest for refusal to pet fees,
45.
GinA had to sell her beloved Toyota Celica in 2013 so she had money to pay
rent since she was falsely arrested each time she attempted to use her property,
46.
GinA has spent the past 5 years doing nothing but learning how to defend
herself under the law and how to write this lawsuit which has deprived GinA of the
basic enjoyments and simple pleasures of life in Maine,
47.
GinA has suffered in innumerable ways physically, mentally, emotionally,
spiritually, interpersonally, financially, publicly, privately, locally and globally all

at the hands of GinAs official public servants who have shown their utter
incompetent to hold any office of public trust.
DEMAND FOR RELIEF
48.
As a result of the described federal, constitutional and public trust violations,
GinA demands the following relief:
1:16-cv-00100-NT
Page 110 of 115
A.
PageID #: 221
Declaratory relief that all Defendants conspired to deprive GinA of her rights
under Title II ADA and Fair Housing Act in all cases related to 32 Court
Street with Leigh Saufley et al even though Defendants knew Leigh Saufley
et al would be acting with a complete absence of all jurisdiction.
B.
Declaratory relief that all Defendants conspired to discriminate against GinA

in violation of the Title II of the ADA in the delivery of public government
services related to her federal fair housing rights because GinA is a disabled
low income woman who has a history of being homeless and vocal about any
violation of her federal fair housing rights as a disabled low income homeless
woman.
C.
Permanent injunctive relief removing all Defendants from public office for all
municipalities in the State of Maine and any other state.
D.
Permanent injunctive relief forever barring all Defendants from holding any
government or public office of public trust at taxpayer expense in any state.
E.
All proper criminal penalties as authorized by 18 USC 241 & 242.
F.
All proper penalties as authorized by 42 USC 3613(c) & 12133.
G.
Actual and punitive damages for all terroristic acts GinA endured at 239
Cony Street at the hands of City of Augusta Police and Jack Alahverdian.
H.
Actual and punitive damages for Augusta Police Ofc. Christopher Guay
falsifying October 1, 2011 police report regarding Alahverdian.
I.
Actual and punitive damages for Augusta Police Ofc. Peter Cloutiers illegal
invasion of Unit 2, 239 Cony Street on January 18, 2012 which he was found
guilty by his commanding officer.
J.
Actual and punitive damages for Augusta Police Sgt. Christopher Shaw, Ofc.
Christopher Guay and Ofc. Scott Harris maliciously and forcibly arresting
GinA on February 16, 2012 due to her disability.
K.
Actual and punitive damages for Augusta Polices malicious illegal

prosecution of all criminal charges because of GinAs disability from February
10 and March 7, 2011 and February 16, 2012.
1:16-cv-00100-NT
Page 111 of 115
L.
PageID #: 222
Actual and punitive damages for GinAs actual and constructive

imprisonment after being arrested and prosecuted for operating after
suspension due to her disability.
M.
Actual and punitive damages for City of Augusta Police Department illegally
towing GinAs Toyota Celica in 2012 forcing GinA to sell it in 2013.
N.
Actual costs to move into and out of 3 Washington Street Place.
O.
Actual and punitive damages for all terroristic acts GinA endured at the
hands of Tyler Robinson and Scott Andrews at 3 Washington Street Place.
P.
Actual costs to move into and out of 32 Court Street.
Q.
Actual and punitive damages for all terroristic acts GinA endured at the
hands of Greg Roy, City of Augusta and its agents at 32 Court Street.
R.
Actual costs to establish and maintain a safe home for 5 years.
S.
Actual and punitive damages for all discriminatory acts since February 10,
2011.
T.
Permanent injunction barring all municipal or state demolitions of low

income buildings in Augusta and statewide without providing an equal
number of replacement units in same or nearby neighborhoods.
U.
Permanent injunction prohibiting any municipality or its boards,

commissions, departments and agencies from creating a for-profit or nonprofit corporate or commercial subsidiary without the peoples vote, approval,
direction and oversight.
V.
Permanent injunction prohibiting the creation of elderly housing projects

without creating equal number of low income disabled units,
W.
Affirmative equitable relief as follows:

1) Require Defendants to repair and maintain existing unfit and condemned
low income rental buildings within the inner city limits of Augusta to
replace no less than twenty low income units which the City of Augusta
destroyed on Perham and 32 Court Streets,
2) Require Defendants to enact and obey local ordinances requiring all unfit
low income rental buildings to be repaired and reopened by the owner, the
1:16-cv-00100-NT
Page 112 of 115
PageID #: 223
City, the State or by a joint combined effort within 90 days of its actual
closure or the property shall be subject to legal condemnation and the
owners loss of legal title to the City,
3) Require City of Augusta and its municipal agents enact, regularly
publicize in their weekly council meeting agendas, release to all
mainstream media sources, and obey local ordinances requiring the
municipality to hold monthly closed door confidential meetings for
Augusta tenants only so tenants can speak freely about the abuses they
suffer by their landlords, other tenants, and their problems with low
income Augusta buildings without having any fear of legal retaliation by
landlords, attorneys and other legally and physically vengeful people,
4) Require Defendants to enact and obey local ordinances requiring all
landlords to record the name of their liability insurance company in local
public records so tenants can properly redress their actual and legal
injuries caused by landlords and their substandard housing,
5) Declare MRCivP 80D unconstitutional as it strips every tenant of their 1st,
7th, and 14th Amendment rights to a trial by jury and to enjoy due process
of discovery under MRCivP Rule 26 inter alia.
6) Declare 14 MRSA 6001 6030-E unconstitutional because it strips every
tenant of their 1st, 7th, and 14th Amendment rights to enjoy a trial by jury
and to enjoy due process of discovery under MRCivP Rule 26 inter alia.
7) Declare at will leases to be unconstitutional when the landlord refuses to
offer or refuses to accept at least a 6-month renewable lease from any
tenant who requests protections of a term rental.
8) Declare that City of Augusta, City of Augusta Police Department, and
Augusta All_Police Officers violated GinAs rights under the 1st, 4th, and
14th Amendments when Ofcs. Cloutier, Shaw, Guay and Harris used
excessive and abusive police power when they invaded GinAs private
home on 1/18/12 and private automobile on 2/16/12, and arrested and
imprisoned GinA all because of GinAs disability and GinA exercising her
1:16-cv-00100-NT
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PageID #: 224
right to travel as protected in Shapiro v. Thompson, 394 U.S. 618 (1969)

inter alia.
X.
All proper criminal penalties against each individual defendant provided by

28 USC 241 & 242 and 42 USC 3631.
Y.
All other proper monetary, declaratory, injunctive and equitable relief this
Court finds appropriate.
Z.
Actual costs to bring suit.

Due to the public significance of the events cited in this complaint and GinAs
need to proceed without legal representation, GinA requests any necessary leave to
correct any technical or procedural errors or omissions which may cause this court
to dismiss any part of the complaint, in part or whole, sua sponte.
Sworn and subscribed to under pains and penalties of perjury on this 21st day
of April, 2016.
_____/GinA______________________________
GinA
2528 West River Road
Sidney, Maine 04330
(207) 209-1767
gina.ecf@gmail.com
VERIFICATION
I, GinA, verify that I have read this Verified 2nd Amended Complaint and
swear the facts stated herein are true based on my own knowledge, experiences,
information, and belief.
1:16-cv-00100-NT
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PageID #: 225
Executed under pains and penalties of perjury on this day in the town of
Sidney, county of Kennebec, state of Maine.
DATE: April 21, 2016
1:16-cv-00100-NT
_____/GinA______________________________
Page 115 of 115

Gina V City of Augusta 2nd Amended Complaint 42 Usc 3601 Filed

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Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 1 of 115

IN THE UNITED STATES DISTRICT COURT

CIVIL NO. 1:16-cv-00100-NT

on her own behalf, and as Next Friend to the

JURY TRIAL DEMANDED

a municipality, a body corporate and politic and

City of Augusta Police Department

a body corporate and politic and a government

agent for the City of Augusta and the State of

42 USC 3601, 3604(f) & 3617,

Maine Judicial Branch, and

1st, and 14th Amendments, and

in their individual and official capacities as

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 2 of 115

including 32 Court Street), as Vice Chair of

GinA wants to include Ray Corporation as a Defendant and co-conspirator in this

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 3 of 115

permanent injunctions against the following parties, government agencies

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 4 of 115

d. U.S. Central Intelligence Agency

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 5 of 115

federal oversight and investigation of City of Augusta municipal activities

since January 2009,

federal investigation of state executive, judicial, legislative, commercial and

private agency contract activities regarding the Capital Judicial Center,

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 6 of 115

preliminary injunctions preventing legal transfer or disposing of any assets,

proper writs of attachment against all Defendants personal and professional

proper garnishments, sequestrations, replevins,

federal forensic financial audits and supervision of Defendants personal and

lien Defendants personal and professional assets held:

in each of their names alone and

PUBLICITY is the BEST PROTECTION for PUBLIC CORRUPTION

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 7 of 115

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 8 of 115

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 9 of 115

Maine Judicial Branch joined Defendants conspiracy by wrongly upholding

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 10 of 115

shutting down low income apartment buildings without replacements,

refusing to legally condemn closed unfit low income apartment

refusing to take financial responsibility for unfit buildings,

refusing to require unfit but not condemned buildings be repaired,

conspiring since 2009 with County of Kennebec and State of Maine

discriminating in favor of new elderly housing project investments,

hoarding $300,000.00+/- cash assets since 2005 by the Augusta Housing

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 11 of 115

(12) refusing to protect low income disabled tenants against law-breaking

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 12 of 115

Despite GinAs proposal receiving a full endorsement by all department

GinA v. City of Augusta et al, 2nd Amended Complaint

Case 1:16-cv-00100-NT Document 14 Filed 04/21/16 Page 13 of 115

GinA v. City of Augusta et al, 2nd Amended Complaint