Brother Wray,plaintiff versus Missouri Dept. of Mental Health,defendant
email@example.com Versus Page # 1 of 14Missouri Department of Mental HealthRichard Gowdy , Ph.D.
Dr. Susan K. BoyerDr. John S. Rabun Jr.Dr. Ashok MallayaDr. Richard Scott
DAMAGE CLAIM $10 MILLION> CIVIL LAWSUITMOTION TO PROCEED IN FORMA PAUPRISMOTION TO APPOINT COUNSEL IN SUPPORTJURY TRIAL DEMAND
I, Lorne Lei Wray acting pro se at this time requesting the benefit of a liberal construction,the plaintiff in the above entitled action now come before this most honorable court to request a JURY TRIAL to establish damages that have been brought upon the plaintiff by the above mentioned defendants. The plaintiff complains that such institutions and their employees did intentionally diagnois plaintiff with a false illness and behaviors for reasons of benefit to them,causing plaintiff loss of his liberties under the constitution of the UNITED STATES for no valid criminal or medical reason. The plaintiff can show with clear & convincing evidence that the defendants practiced fraud,coercion, personal vendettas ,forms of harassment, threats in order to justify incarcerating plaintiff for close to 10 years,under the guise of hospitalization. Factual evidence will show that the defendants fabricated a mental diagnois for the purpose of their benefit in reality has never existed but such can be made when the defendants are never questioned about such practice in order to determine if indeed any diagnois is valid. In practice of such deceit the defendants have caused the plaintiff loss of 10 years of personal freedoms,severe emotional distress as well as damage of reputation. The plaintiff offers further damages contained within his statement of claim,he prays that the motions contained herein are granted.Respectfully submitted,
______________________________________ Lorne Lei Wray
MOTION TO PROCEED IN FORMA PAUPRIS The plaintiff has enclosed the required forms and documentation in support of this motion.
MOTION TO APPOINT COUNSEL IN SUPPORT The plaintiff believes he brings before the court a complaint that has merit and demands relief but at this time he is unable to secure counsel in support as the motion to proceed as a poor person application will verify,this poverty should not deny him access to the judicial system so counsel in this matter is requested.
PLAINTIFF’S SUMMARY OF STATEMENT OF CLAIM
MISSOURI DEPARTMENT OF MENTAL HEALTH1. Plaintiff wrote numerous grievances and complaints to administration,many grievances went ignored,nor were any allegations of deceit or harassment by their doctors investigated.2. Staff was allowed to write false allegations against plaintiff such as sexual harassment but when found invalid such staff were not disciplined,these things were done in attempt to make plaintiff something he is not in support of fabricated illness.3. Staff was allowed to hit the plaintiff with a door but such staff was never disciplined,other staff done much less to clients and have been terminated any abuse towards plaintiff was ignored or made justified.4. Due to numerous lawsuits,grievances and the reporting of their doctors to the medical boards this defendant has become prejudice against plaintiff,never in support of release regardless of actual behaviors using it’s power to punish plaintiff for exercising his rights under the law as well as reject their opinion of him if he deems such false.5. The plaintiff was granted UNCONDITIONAL RELEASE from this defendant
RICHARD GOWDY PH.D. 1. Plaintiff was granted a full conditional release from mental health in January of 2006. Part of the conditions was that plaintiff must show appropriate behaviors while continuing to reside at mental facility for six months,plaintiff found employment and after six months he was reported to be successful even allowed to move his belonging to his new residence but unknown to plaintiff this defendant gave orders to defendant St. Louis Psychiatric Rehab. Ctr. To delay his release in fact do not renew his release for the following year as a conditional release must be renewed every 12 months,is this not a violation of plaintiff’s release? Why is this defendant allowed to violate the release conditions but if plaintiff had done such he would immediately be up for revocation? This is a prime example of how the defendants use their authority to harass the plaintiff as he had no valid reason to order such except his own personal prejudice driven by plaintiff’s numerous grievances,lawsuits and rejection of mental illness and medications or submitting to their treatment but plaintiff was still granted conditional release,also this defendant knew plaintiff had filed for UNCONDITIONAL RELEASE and he wanted less time without their supervision available so he could argue plaintiff hadn’t enough time on a full conditional release something he created in violation of conditional release agreement, this action also almost caused plaintiff to lose his employment something that would also help him secure denial of an unconditional release,it is clear his actions were made to cause harm to the plaintiff. It is funny of how when plaintiff renewed his release himself this defendant offered to renew such asking plaintiff to dismiss his own motions of which he did not,plaintiff was granted renewal of his release in March 2007 despite the prejudice actions of this defendant,plaintiff was granted full conditional release accepting no mental illness or medications present or in the past.2. This defendant continues to show personal prejudice and even hatred towards plaintiff by objection to his UNCONDITIONAL RELEASE,the defendant who has never evaluated or examined the plaintiff comes to court alone to testify against plaintiff,he offers quotes from his doctors that are negative towards plaintiff but he has called none to testify he ignores his doctors that favor plaintiff,he ignores the plaintiff’s doctors assigned to him after being released as well as the reports from the plaintiff’s probation officer,he wants to use his position to impress the court but he knows under the law plaintiff can’t be held if illness is not present and his own doctors report no sign of illness,the plaintiff with no illness doesn’t qualify for any of the defendant’s programs or disability aid,the plaintiff believes it is the defendant’s personal anger that has drove him to this point his disliking plaintiff for being released rejecting mental illness & drugs,the plaintiff filing numerous grievances and civil complaints. It is funny that none of the so called victims came to object,nor the prosecutor’s office only the defendant who represents mental health nor was objection from the facility plaintiff was held in for years,why is this?
DR. SUSAN K. BOYER1. Plaintiff believes due to her personal friendship with defendant John Rabun even thou her experience tells her different she decided to help support Rabun’s original false diagnois,again since no one will follow to say if such is valid or not,this defendant did proceed to aid in continuing this fabrication of mental defect.2. Defendant has never examined plaintiff in order to make diagnois,her diagnois is based on what others have written,in fact this defendant told plaintiff she doesn’t care how appropriate his behaviors are she will chart him as being bizarre,she requests to the court an order to force medication,of which was denied.3. Defendant has the power to restrict his freedoms and does so severely even placing him on suicide watch when there is no evidence of such,staff do not observe any suicidal behaviors.4. Defendant placed upon him a diagnois of delusions that plaintiff was having romantic fantasies about her without his knowledge,plaintiff was informed of this new illness by requesting the reading of his charts,it is impossible that such diagnois is true in that this defendant being a caucasion woman,plaintiff has no history of any inter-racial relationships in fact would advise against such and has made very clear his preference of a spouse for years and all know this defendant doesn’t fit the criteria,again fabrication designed to justify and support the original manufactured illness,in fact plaintiff did all he could to avoid defendant it was her persistence in wanting to talk with plaintiff as plaintiff knows anything he says or does can be manipulated to seem in mental default.
JOHN S. RABUN JR.1. This defendant is the original author of mental defect upon the plaintiff his diagnois is biased as none of the charges were proven to be valid,nor did he speak with any person in plaintiff’s favor.This defendant had no choice but to favor guilt as if plaintiff is not guilty then a mental illness doesn’t exist,again since he knows no one will follow behind him this defendant chooses to fabricate a mental illness.2. Defendant told the court plaintiff was in need of immediate hospitalization due to dangerousness but did not explain why there was no acts of so called danger during the three months plaintiff was free on bond prior to his examination,it is clear this defendant’s intent was to fill a bed,plaintiff’s unconditional release order states the original offense was not violent or dangerous,so how was this determined by this defendant to be so? The defendant offers no evidence in support as required by
DR. RICHARD SCOTT1. Defendant has never examined plaintiff and with his experience like defendant Boyer it is impossible for the plaintiff to believe that he would also concur with defendant Rabun,since Rabun is a colleague in most cases one supports the other and since no one will follow behind to test that validity Scott chose to support the fabricated diagnois of Rabun.2. Defendant accused plaintiff of making threats against the facility and attempting to start a riot within the facility in 1998,an accusation proven by the facility as invalid but made to support plaintiff being ill. Another form of harassment,additional fraud.3. Defendant makes plaintiff’s attempts to use the facility grievance system as well as civil lawsuits some form of mental default because in his mind they never do anything wrong but the plaintiff will show this is far from true.4. Defendant who was in charge of the ward ignored plaintiff’s complaints of being frozen by air conditioning causing the plaintiff to suffer for weeks unnecessarily in 1998,being unable to sweat has caused plaintiff’s body to act other than what it had prior to this as plaintiff avoids air conditioning,a unknown gas a health hazard.
DR. ASHOK MALLAYA1. Defendant due to his extensive medical experience it is impossible for him to concur with the diagnois of defendant Rabun,however again since he is a colleague and who is to follow up to examine if an illness is indeed valid this defendant also chose to support defendant Rabun,however after being made to testify under oath and attempting to explain the illness this defendant would later state plaintiff has no illness,why?2. When this defendant learned plaintiff was not taking medication he became enraged,reducing his functioning level from the high 80’s to the high 40’s but clearly plaintiff is functioning high and not consuming drugs,one would think a doctor would be happy his patient is being healed without drugs but then again this supports plaintiff’s accusation that such diagnois has always been false.3. In 2003 this defendant did threaten the plaintiff with seeking for him a guardian of who will in turn grant them permission to force drugs upon him,it is apparent this threat could not be carried out due to plaintiff’s ability to also communicate with the court,he stated for that purpose I’ll increase the severity of the illness,can he do this?4. In March of 2003 the plaintiff was placed on total ward restriction having no freedoms for no reason except punishment for rebelling against a fabricated illness and kindergarten like care/treatment.This defendant did order forced medication upon the plaintiff for refusing to accept his punishment being uplifted,plaintiff did by threats of a forced injection did swallow unknown pills,later on that night plaintiff did arise and report his legs throbbing with pain and shaking,this is also a side effect of this particular drug,the plaintiff has had no physical problems prior to this except accidents playing basketball,least to say administration found fault in this treatment and all plaintiff’s freedoms were returned,being that plaintiff was not violent,federal law was violated SELLS v. UNITED STATES 20035. In protest of unfair treatment the plaintiff went on a six day hunger strike,the assigned doctor who was the defendant shown no signs of concern as plaintiff was never seen eating or drinking,is this like a doctor but then in retaliation for this hunger strike the defendant was not allowed to participate in the facility BLACK HISTORY MONTH CELEBRATION of which happens once a year and he is African-american,clearly this was done to punish.6. Defendant did not protest the placing of another client who had made threats against the plaintiff who was suffering from delusions that the plaintiff was harming his family,this was done in hopes that this patient hurts the plaintiff or they could turn the story around in that the plaintiff was the aggressor,the plaintiff was placed on total ward restriction all the while the sick patient allowed to roam freely,what does this tell us?7. In 2004 defendant was asked by the plaintiff to show a pattern of behaviors that relate to the illness given to him with his charts that have been written by himself and various staff,defendants response was get out of his office,so plaintiff and a staff witness was asked to leave and defendant followed behind stating I am so sick of this,later the defendant would defer the axis one diagnois,in plaintiff’s belief this wasn’t done because defendant like plaintiff this was done to take the pressure off from the defendant having to describe and explain the existence of some illness under oath as the plaintiff’s legal abilities was now getting him to court on a regular basis,where did the illness go? Administration claims and it is very convenient for them that it is a come and go illness that has never came and went prior to them and has yet to come and go once out of their grip.8. The defendant prescribed drugs that never was approved by the FDA for the said alleged illness,least to say it was common knowledge that drugs most of the time have no effect upon persons with the defect given to plaintiff,but much effort was given to make plaintiff consume drugs,why?
1. Mental illness or not the defendant intentionally for no true valid criminal or medical reason denied the plaintiff the right to contract,engage in any occupations of life,to marry,establish a home,raise children,worship how he deems fit or even enjoy all the privileges common to the orderly pursuit of happiness by free men. MEYER v.
GROUNDS & FACTS FOR FILING THIS CASE
1. The plaintiff was granted unconditional release from the defendants
Therefor,it is clear that something is wrong in the Missouri Department of Mental Health. An investigation into their own records will testify to a practice of fraud & harassment so bold they didn’t attempt to hide anything as who is going to check behind them? Mental health has been exposed with the threat of closing the BELLEFONTAINE facility in which it has revealed clients for years suffered neglect and abuse,the plaintiff suggests the same but it is more mental rather than physical in nature but abuse just the same.The defendants should not be protected by any form of immunity as they have violated the public trust,in the practice of deceit done in a malicious manner with the intent to harm not to cure or bring help.There is no doubt the plaintiff for over 10 years been treated in an unjust manner & should be compensated for this pain and suffering,least to say embarrassment.The plaintiff’s only remedy is the authority of this court,those employed by the state should not be allowed to behave in such an outrageous manner & such should not be tolerated,one should find plaintiff’s accusations frighteningly perturb.The defendants actions have not been performed in good faith but with a deceitful nature,incompetence,arrogance or gross negligence as the evidence,not opinions,as the facts not opinions will bare witness to. Petitioner at this time do affirm under penalty of perjury under the laws of the state of
__________________________________ Lorne Lei Wray