Motion for Emergency Injunctive Relief
Now I realize I should have put the essence of this motion into the complaint. By placing it here it was possible for the order denying my filing "En Forma Pauperis" (waiver of the filing fees) to not acknowledge the lethal seriousness and the genuine need for immediate justice.
Plaintiff hereby does move for a MOTION TO SHOW CAUSE for not granting EMERGENCY INJUNCTIVE RELIEF in the form of IMMEDIATE TRIAL for the civil action of Christopher A. Brown against the defendants, county of Santa Barbara, City of Santa Barbara, Santa Barbara News Press and Sharon Reinhold . The motion is based on the NOTICE OF MOTION, the REQUEST FOR JUDICIAL NOTICE of the attached exhibits introduced as EVIDENCE justifying EMERGENCY INJUNCTIVE RELIEF and the declaration of Christopher A. Brown, and on such evidence as may be presented at the hearing of the motion.
Date;____________pro per plaintiff, Christopher A. Brown,
PLAINTIFFS REQUESTS FOR JUDICIAL NOTICE
OF "COMMON KNOWLEDGE AND VERIFIABLE FACTS" CONFIRMING DEADLY AND EXTREME BEHAVIORS IN A PATTERN, OVER TIME, BY ADOLESCENTS IN SCHOOLS AND THE PUBLIC.
Christopher A. Brown, the plaintiff in this legal action introduces the dates of recent extreme behaviors in schools as "COMMON KNOWLEDGE AND VERIFIABLE FACTS", and evidence of a repeating pattern of action in time that requires, in the protection of lives, immediate attention by the court, compelling judicial notice of the exhibits of this motion as fulfillment of public confidence.
March 24, 1998, Jonesboro Arkansas, 9 killed, 10 wounded.
April 24, 1998, Edinboro Pennsylvania, 1 killed, 2 wounded.
May 19, 1998, Fayetteville Tennessee, 1 killed.
May 21, 1998, Springfield Oregon, 4 killed 22 injured.
May 21, 1998, Charles County, MO Plan modeled after Jonesboro uncovered.
April 20, 1999, Littleton Colorado, 15 killed, 22 wounded.
May 20, 1999, Conyers Georgia, 6 wounded.
Plaintiff requests specifically that the court take judicial notice of the concentration of extreme behaviors on or about the twenty first day of the month within the listed "common knowledge and verifiable facts" above and asks the court to recognize that the twenty first day of the month has the greatest significance in the solar year followed by the procession of the equinoxes as the indexing points for the circadian rhythm, the biological clock of the human subconscious mind. See EXHIBIT SEVENTEEN for additional events.
REQUEST FOR JUDICIAL NOTICE
Plaintiff requests that the court take judicial notice of the attached EXHIBIT EIGHTEEN, page 911 of the 1933 "Blacks Law Dictionary, third edition", concerning HYPNOTISM. In particular plaintiffs asks recognition of the statement in paragraph two, lines 5,6&7 ".........and perhaps the exercise of a telepathic power not as yet fully understood........"
REQUEST FOR JUDICIAL NOTICE
Plaintiff requests that the court take judicial notice of the attached opening statement of Attorney for defendant, EXHIBIT NINETEEN (filed September 8, 1998) in civil action at trial Superior Court (S.B.co.SUP.CRT) case #220298.
INTEGRATION AND INFERENCE OF EXHIBITS
The purpose of the request for judicial notice of EXHIBIT EIGHTEEN and EXHIBIT NINETEEN is for integration, with inference, of a manipulation of legal process made by defendants attorney in Santa Barbara Superior Court case #220298. The opening statement of the defendants attorney, EXHIBIT NINETEEN became a vehicle, with the courts recognition of the inference covertly introduced, with language having a "defensive tone", asserting on page 2, lines 3 and 4, with statements serving the interests of the defendants conspiracy as described in (S.B.co.SUP.CRT) case #220298 & 209449 (EXHIBIT TEN), by utilizing the unwilling but injured plaintiff to gain official recognition of hypnotic abuses and subconscious programming with the introduction of the opening statement into legal proceedings of A courts record.
Plaintiffs responses to interrogatories requested by defendants attorney were used as a basis to infer the activity of telepathy that the defendant in case 220298 intends to introduce into legal pleading, then stating by undefined process of inference, what could, as if in trial, be used to intentionally define the activity of telepathy, is instead presented in the defendants opening statement (Page 2-,2,3) as a "claim by the plaintiff.......that the defendant.....inflicted harmful hypnotic telepathy on him" constitutes a manipulation of the legal process.
DECLARATION OF CHRISTOPHER A. BROWN
Plaintiff Christopher A. Brown declares under the penalties of the laws of perjury of the United States of America that he has never used the word "telepathy" in his legal pleadings or his public speaking prior to September 8, 1998.
INFERENCE
The opening statement of the defendants attorney, EXHIBIT NINETEEN, became a vehicle", is submitted, for the courts inference, by the plaintiff and is supported as a vehicle by the final aspect presented in the defendants opening statement concerning "relevant evidence" (Page 3-20,24)
DECLARATION OF CHRISTOPHER A. BROWN
Plaintiff declares under the penalties of the laws of perjury of the United States of America that he has never done research into the relevancy of "spectral" evidence in American Courts.
INFERENCE
EXHIBIT NINETEEN, the opening statement, lastly, points to the courts inability to accept the evidence the defendant covertly perceives as needed to describe hypnosis as it is unconsciously used. The highly descriptive activities of hypnotic technique elicited through form interrogatories from plaintiff of EXHIBIT NINETEEN, page 2 that are unnecessary, redundant or irrelevant to denial or defensive legal posturing of the alleged acts of the complaint 220298, (EXHIBIT NINE) support the inference that the information on page 2 of the opening statement is selected from responses to interrogatories because they are the specific activities of hypnosis defendant in 220298 intends to enter into legal record. The information is organized and presented defensively in the opening statement, exploiting the courts bias to perceive the hypnotic activities only as "ordinary every day activities engaged in by defendant.". The absence of denial of the alleged acts in EXHIBIT NINETEEN makes a mockery of the helpless plaintiff in the prejudice court (see MOTION TO DISQUALIFY, complaint EXHIBIT SEVEN and subpoena denials, complaint EXHIBIT EIGHT), leaving the defendants only possible tracks of legal record while maintaining innocence, deceptively opposing allegation to feign innocence without denying and forcing plaintiff to continue to find recourse through legal action against the County of Santa Barbara. This legal action.
JUSTIFICATION OF EMERGENCY INJUNCTIVE RELIEF IN FORM OF IMMEDIATE TRIAL
Plaintiffs submission of this motion is predicated in the results of Santa Barbara Counties unaccountability concerning missing court case files (see EXHIBIT FIVE) as described in S.B.co.SUP.CRT case #220298, (EXHIBIT NINE) of his complaint, justifying EMERGENCY STATUS with relief in the requested form. Unaccountability is demonstrated in two denials of Subpoena duces tecum (complaint EXHIBIT EIGHT), upon the custodians of public records of Santa Barbara County. (EXHIBIT FIVE) of the complaint confirms the missing insanity actions, needed, as precedent, by the court to consider the plaintiffs case, and this motions argument for INJUNCTIVE RELIEF with ease.
Plaintiff has been informed by the nature of his injuries as described in (S.B.co.SUP.CRT) case #220298) and recognizes that the behaviors listed inEXHIBIT SEVENTEEN, as well as indicated dates of the events of extreme violence occurring on or near the twenty first day of the month, are caused by subconscious programming and believes that a decision by this court to grant the MOTION FOR IMMEDIATE INJUNCTIVE RELIEF to put the plaintiffs complaint to trial, on emergency basis, will save lives.
Due to the deprivation of fair hearings and contempt of court resulting in lost publicity, income and facility to gain legal representation or treatment for his injuries, plaintiffs daughter has been molested, S.B. co. SUP. CRT. M992970. Plaintiff has lost his rental residence, most belongings and further neglect to lawfulness will create a danger to plaintiffs life, constituting, with this motion, an emergency, personally for the plaintiff.
REQUEST FOR ORDER
Plaintiff respectfully requests that the order of the court resulting from this motion be in writing and address lines 20-24 on page 3 of the defendants opening statement (EXHIBIT NINETEEN) of case 220298, of September 8, 1998, with regard to status of the relevance of the evidence to this court of EXHIBIT EIGHTEEN concerning telepathy and EXHIBIT NINETEEN (2-3,4) concerning telepathy.
DECLARATION OF CHRISTOPHER A. BROWN
I Christopher A. Brown Declare on October 18, 1999 under the penalty of the laws of perjury of the United States of America that the foregoing is true and correct.
Date;_____________Christopher A. Brown