UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF OKLAHOMA

CIVIL DIVISION

CASE NUMBER:

Jacob Wayne Brauning, )

)
Plaintiff, )
)
) Jury Trial Demanded
Vs. )
)
John Gilbert Christian, et al. )
)
Defendant(s), )
)
)

COMPLAINT

1. Plaintiff, Jacob Wayne Brauning (“Plaintiff”), prose, for claims in

complaint against Defendant(s) alleges and states as follows:

I. INTRODUCTION

Plaintiff, in good faith, with good conscience and for good reason
brings complaint to the Eastern District Court of Oklahoma, seeking all Federal court remedy’s
and make known, Pontotoc and Seminole County Public officials in accord with Vision Bank
N.A. officials, and Oklahoma Heritage Bank officials, act outside the scope of the authority
granted to them by state law, violated and/or aided and abetted violations of Plaintiff’s
constitutional rights,

Plaintiff, Tradesman, Father and Business owner of local plumbing

company wherein, inundated in an extreme and outrageous scheme aimed to deprive Plaintiff of

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constitutional protected rights and fundamentals of due process of law together with defamation
and slander, for means to usurp property rights and assets

The Defendant(s) that are County Officials and/or parties to, clothed
with the authority of state law, in concert to their own accord and together, for self enrichment
and gratitude, devoid of good faith and good conscience, without consent, convert and take
millions worth of, property, assets, family heirlooms and privileged commercial trade secrets by
trespassing, oppose plaintiff from his home and property without cause with wrongful arrests,
and other acts comprising nearly one year of false imprisonment of Plaintiff along with other
tactics

Causing egregious damage and injury to Plaintiff, destroying his

business that had grossed in access over the previous nine years ten million dollars as a premier
service provider in good standing within the community and most importantly Plaintiff’s right to
be a father, granted to him from the Creator as fatherhood is to raise formidable young people
that understand and respect what's good about the world

Upon progress to form a defense for the wrongdoing, Plaintiff was

subjected to retaliations by the Defendant(s), including on information and belief, an attempt to
eliminate Plaintiff, by Pontotoc County Sheriff deputy, outside the jurisdiction of the Sheriff’s
Office in an effort to interfere Plaintiff from presenting facts known herein to this Court.

II. JURISDICTION AND VENUE

2. This action is brought pursuant to 42 U.S.C. § 1331 (federal question), as this

action arises under the Constitution and laws of the United States, and pursuant to 28
U.S.C. § 1343 (civil rights), as this action seeks redress for civil rights violations under
42 U.S.C. § 1983.

3. Venue is proper under 28 U.S.C. § 1391(b). At least one Defendant resides

within this judicial district, and the events giving rise to the claims asserted herein
mostly occurred within this judicial district.

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4. Plaintiff’s claims for relief are predicated upon 42 U.S.C. § 1983, which
authorizes actions to redress the deprivation, under color of state law, of rights,
privileges and immunities secured to Plaintiff by the First, Second, Fourth, Fifth,
Sixth, Eighth and Fourteenth Amendments to the Constitution of the United States and
for unlawful imprisonment, wrongful arrest, harassment, abuse of process, intentional
infliction of emotional distress, negligence, malicious prosecution, excessive bail,
defamation, constituting a deliberate indifference to Plaintiffs' constitutional rights and
leading directly to the aforesaid violations. This is an action for compensatory and
punitive damages for violation.

5. This Court has jurisdiction over claims seeking declaratory and injunctive relief
pursuant to 28 U.S.C. §§ 2201 and 2202, and Rules 57 and 65 of the Federal Rules of
Civil Procedure, as well as claims for nominal and compensatory damages against all
Defendant(s).

6. This Court has subject-matter jurisdiction over this matter pursuant to 28

U.S.C. § 1331 (federal question) and 28 U.S.C. § 1343(a) (3) (civil rights); 28 U.S.C.
§ 1367 provides supplemental jurisdiction over the state law tort claims that arose
from the same common nuclei of facts

7. Plaintiff is informed, believes, and therefore alleges that the individual

Defendant(s) acted as described herein with the intent to injure, vex, annoy, and harass
Plaintiff, and they subjected Plaintiff to cruel and unjust hardship in conscious
disregard of Plaintiff’s rights with the intention of causing Plaintiff injury and
depriving him of constitutional rights.

8. As a result of the foregoing, Plaintiff seeks injunctive and declaratory relief,

equitable relief, as well as economic, compensatory and punitive damages also
additional Treble Damages for all intentional and knowing violations against the
Defendant(s).

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9. These constitutional law violations are “capable of repetition, yet evading
review.” Roe v. Wade,

III. PARTIES

10. Plaintiff, Jacob Wayne Brauning, is an individual who was at all pertinent
dates as alleged herein a resident of the State of Oklahoma, residing within this
Court’s jurisdiction and otherwise sui juris.

11. Defendant, Sheriff, John Gilbert Christian, is an individual and county

elected official, (“John Christian”) the Sheriff of Pontotoc County Sheriff’s Office
Since Jan 02, 2009 and resides in the county, Duties of the Sheriff as follows:
responsible for keeping peace and enforcing the law also tasked with the operation of
the Pontotoc County Jail. 100 West 13th Street Ada, OK

12. Defendant, Judge, Charles Steven Kessinger is an individual and District

Judge in Pontotoc County Courthouse. (“Steven Kessinger”) OBA# 13194 admit date
9/20/1989; Office 2; with the 22nd Judicial District Casa, Inc. an Oklahoma Domestic
Not For-Profit Corporation filed On July 8, 2004. File Number is 2112043100.
Courthouse 120 W. 13th Street Ada, OK 74821

13. Defendant, Judge, Lori Lynn Jackson is an individual and Associate

District Judge in Pontotoc County Courthouse.(“Lori Jackson”) OBA# 16678 admit
date 9/28/1995; with the 22nd Judicial District Casa, Inc. an Oklahoma Domestic Not
For-Profit Corporation filed On July 8, 2004. File Number is 2112043100. Wife of
Cary Michael Jackson. Courthouse, 120 W. 13th Street Ada, OK 74821

14. Defendant, Judge, Gregory Darwin Pollard is an individual and Special

Judge in Pontotoc County Courthouse. (“Greg Pollard”) OBA# 19691 admit date
4/25/2003; with the 22nd Judicial District Casa, Inc. is an Oklahoma Domestic Not

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 For-Profit Corporation filed On July 8, 2004. File Number is 2112043100. Courthouse
120 W. 13th Street Ada, OK 74821

15. Defendant, Attorney, Sonya Renea Chronister is an individual and former

assistant attorney for the District Attorney’s Office. OBA# 33145 admit date
9/26/2017; in Pontotoc County #216. The DA plays a central role in criminal cases,
working with police to decide whether to bring charges and prosecute. 105 West 13th
Street Ada, OK 74820

16. Defendant, Clerk, Karen Lyn Dunnigan, is an individual and Court Clerk,
Pontotoc County Courthouse. The County Court Clerk’s primary responsibilities are to
record, file, and maintain the District Court proceedings by keeping books, trial
dockets, case files, and journals useful for locating past court proceedings. 120 W.
13th Suite 212, Ada, OK 74820

17. Defendant, Attorney, Alvin Dean Files is an individual and officer of the
court, (“Files”) and an Attorney who is and was at all pertinent dates as alleged herein
who licensed in the State of Oklahoma and practices in Pontotoc County, 121 S
Broadway Ave, Ada, Oklahoma, 74820

18. Defendant, Undersheriff, Arnold Gordon Scott is an individual and the

Undersheriff of the Pontotoc County Sheriff’s Office. A deputy sheriff is an agent of
the sheriff responsible for keeping the peace and enforcing the law. 100 West 13th
Street Ada, OK 74820

19. Defendant, Deputy, Michael Lee Walker is an individual and is a deputy

of the Pontotoc County Sheriff’s Office. A deputy sheriff is an agent of the sheriff
responsible for keeping the peace and enforcing the law. 100 West 13th Street Ada,
OK 74820

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20. Defendant, Deputy, Todd O’Neil Young is an individual and is a deputy
of the Pontotoc County Sheriff’s Office. A deputy sheriff is an agent of the sheriff
responsible for keeping the peace and enforcing the law. 100 West 13th Street Ada,
OK 74820

21. Defendant, Deputy, Derek Ray Stewart is an individual and is a deputy of

the Pontotoc County Sheriff’s Office. A deputy sheriff is an agent of the sheriff
responsible for keeping the peace and enforcing the law. 100 West 13th Street Ada,
OK 74820

22. Defendant, Sheriff, Shannon D Smith is an individual and county elected

official, the Sheriff of Seminole County Sheriff’s Office. Since Feb 23, 2009, Duties
of the county sheriff are as follows: responsible for keeping the peace and enforcing
the law also tasked with the operation of the Seminole County Jail. 211 E 2 nd Street
Wewoka, Ok 74884

23. Defendant, Deputy, Matthew Robert Haley is an individual and is a

deputy of the Seminole County Sheriff’s Office, also tasked as Jail Admin
a deputy is an agent of the sheriff responsible for keeping the peace and enforcing the
law. 211 E 2nd Street Wewoka, Ok 74884

24. Defendant, Steve Patrick Williams is an individual and was a deputy of

the Seminole County Sheriff’s Office. A deputy sheriff is an agent of the sheriff
responsible for keeping the peace and enforcing the law. 11393 Highway 56, Okemah,
OK 74859

25. Defendant, Deputy, Gary Leon Brooks is an individual and is a deputy of

the Seminole County Sheriff’s Office. A deputy sheriff is an agent of the sheriff
responsible for keeping the peace and enforcing the law. 211 E 2 nd Street Wewoka, Ok
74884

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26. Defendant, Attorney, Candice Michelle Irby is an individual and an
assistant attorney for the District Attorney’s Office OBA# 19841 admit date 9/30/2003
in Seminole County #193. The District Attorney plays a central role in criminal cases,
decide whether to bring charges and prosecute. 120 South Wewoka Ave
Wewoka, Oklahoma, 74884

27. Defendant, Trooper, William Richard Hayden is an individual and is a

Trooper of the Oklahoma Highway Patrol. OHP has patrol jurisdiction over all state
highways and waterways in Oklahoma. (F) Field troopers. 9351 County Road 1540,
Ada, OK 74820

28. Defendant, Cary Michael Jackson is an individual and who was at all
pertinent dates as alleged herein is the CFO employed by OKLAHOMA HERITAGE
BANK, Pontotoc County Ok, and Husband of Judge Lori Lynn Jackson. 327 Colton
Way, Ada, OK74820

29. Defendant, Chance David Branscum an individual and Credit Officer

employed by OKLAHOMA HERITAGE BANK an Oklahoma Corporation in
Pontotoc County Oklahoma. Domestic Bank doing business address located at 9 TH ST
AND MAIN, ROFF OK 74865

30. Defendant, OKLAHOMA HERITAGE BANK (hereinafter “OHB”),

an Oklahoma Corporation, Domestic Bank, The company has 3 principals on record.
The principals are Foy Phillips, J T Roberts, and James E Spann. The Registered
Agent on file for this company is R Darryl Fisher doing business address located at
9TH ST AND MAIN, ROFF OK 74865

31. Defendant, James Robert Hamby, is an individual and who was at all
pertinent dates as alleged herein, CEO of VISION BANK N.A., in Pontotoc County
Oklahoma and resides in Pontotoc County at 2409 Woodland Dr, Ada, OK 74820

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32. Defendant, Brandon Lee Tilley is an individual and Loan Organizer
employed by Vision Bank, N.A. Domestic For Profit Business Corporation in
Pontotoc County Oklahoma. The company's principal address is 101 E. Main St., Ada,
OK 74820

33. Defendant, Andrew Duane Gibson is an individual and Loan Organizer

employed by Vision Bank, N.A. Domestic For Profit Business Corporation in
Pontotoc County Oklahoma. The company's principal address is 101 E. Main St., Ada,
OK 74820

34. Defendant, VISION BANK, N.A. (hereinafter “Vision Bank”), The

Registered Agent on file for this company is Secretary Of State, 1019 Brazos, Austin,
TX For Mailing To: and is located at M.Keywood Deese, Senior Vice-President P O
Box 669, Ada, Oklahoma 74821-0669, Austin, TX 78701. The principal address is 101
E. Main St., Ada, OK 74820

35. Defendant, Brandon Wayne Smith is an individual and Registered

Agent of NEXT UP TOWING & RECOVERY LLC, A DOMESTIC LIMITED
LIABILITY COMPANY located at 314 W 12th St, Ada, OK 74820 in Pontotoc
County Oklahoma.

STATEMENT OF THE FACTS

36. December 2018, Alvin D. Files (“Files”), Unknown to Plaintiff without

firsthand knowledge of any facts, Files makes false statements on petition that were
improper as Files attempts to force association with plaintiff, claiming to representing
Vision Bank as a debt collector although a claim on which relief could be granted was
never made

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37. Files brought an action against Plaintiff, serving Summons and Petition
with Case # CJ-2018-205, by way of Process Server on Plaintiff, at his Principal
Residence in Byng, with a mailing address of 5262 County Road 3565 Ada,
Oklahoma. Without any prior notice from bank such as demand, default nor
acceleration notice as required via contract

38. On or about the 1 st of February 2009, Plaintiff after working as an

Oklahoma licensed Plumber since leaving Seminole State Collage in 2005, created
from scratch a Plumbing Company serving the Ada, Oklahoma and surrounding areas
that quickly became the industry leader

39. Soon after, Plaintiff opened a Business Checking Account at the Byng
Branch of OHB, for Plaintiff’s Plumbing Company, CACTUS PLUMBING OF ADA
LLC (“ Cactus Plumbing ”), a Limited liability Company under Oklahoma law, OHB
in recipe and agreement of Articles of Organization filled with the Oklahoma
Secretary of State

40. Cary Mike Jackson (“Mike Jackson”) the CFO of OHB and married to
Judge, Lori Lynn Jackson (“Lori Jackson”) an Associate District Judge of Pontotoc
County Courthouse

41. Plaintiff managed and worked as a skilled tradesman in the plumbing

business, Cactus Plumbing, which by 2015 the company had grossed in access over
the previous nine years ten million dollars which were deposited through its’ OHB
account, and consistently showed growth each year since companies inception also
provided employment to the community

42. Plaintiff who had been in the new construction industry nearly ten years
carefully began to design and had blueprints drafted for the two story 6,001 sq.
Brauning family home.

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43. One year early purchased the land a wooded 19.33 acres north of Ada,
on dead end black top road and completed, Office/Shop with living quarters inside the
fenced and gated Estate.

44. Plaintiff began developing the land for primary structure in a large scale
land development wherein two million yards of dirt was hauled off, in preparation for
home site location, the expense was funded out-of-pocket by the plaintiff and the
home build would start next

45. For the new construction project financing for the primary residence,
Plaintiff went with Vision bank for fifty percent of the budget for the home build his
was seeking and the construction of home would soon began

46. After returning home from an Oklahoma City Thunder’s basketball

Game with Loan Organizer Brandon Tilley, who had arranged the event and trip was
courtesy of Vision bank wherein a discussion over project occurred

47. On or about May 05, 2015, Plaintiff began construction of primary

residence a two-story home managing the construction of the build as well as
providing the plumbing and installation with unique features like radiant heated floors
on demand hot water, large Cedar Posts, stamped concrete, theater room with outside
kitchen and others features

48. Fifteen months later of hard work and sacrifice and with family
temporarily living in shop while pervious home was leased in a contract to buy,
Plaintiff moves family into home a few days before kids would started a new school
year August of 2016

49. On March 7, 2017, Plaintiff and wife file for divorce and custody of two
natural-born sons in Tara Janea v. Jacob Wayne Brauning, case # FD-2017-00032,
Judge Lori Jackson was the presiding judge

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50. Plaintiff’s Wife despite the temporary order moves children to a different
county and shortly afterwards moves in with then boyfriend T. Sanders, and began to
parental alienate plaintiff from his biological children, even refusing a welfare check
via phone call regarding children’s safety after a tornado had struck the area that
summer, Judge Lori Jackson denied Plaintiffs request to enforce the child custody
and visitation order

51. Allegations made from a disgruntled person plaintiff had only seen a few
times and after Plaintiff denied a request for a relationship, plaintiff was threaten and
harassed to the point of changing phone numbers and reported activity to lawyer and
Sheriff's Department inquiring on protective order wherein person arrived uninvited to
Plaintiffs home the evening of June 30 2017 a call was made to sheriff’s department
wherein they removed person

52. Plaintiff had no contact with person after incident although false
allegation occurred weeks Later and after receiving hundreds of prior threats by email,
allegations were made and a deputy was sent to Plaintiff’s home wherein Plaintiff
complied and allowed device to be scanned, after review deputy remarks was: there's
no evidence also there were pervious threats made this is bogus you're good to go
thanks for cooperating

53. On October 24 2017, Over three months later, Plaintiff was charged with
child abuse and injury a felony that would carry a minimum prison sentence of ten
years that would be the first of many malicious prosecutions by former Pontotoc
County Assist D.A. Sonya Chronsiter and Seminole County D.A. Candice Irby that
would work in accord

54. Assistance D.A. Sonya Chronsiter, never attempted to prosecute alleged

claim that was absent a probable cause affidavit, evidence, as allegations were
frivolous void of any facts, case was dismissed at first pretrial however causing
unnecessary damage and injury to plaintiff and his good reputation

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55. In 2015, Plaintiff made the front page of ADAHUB, a magazine featuring
plaintiff and his plumbing company, after hard work and effort had been a success for
nearly a decade
56. Plaintiff would now appear on the front page of the JAILBIRDS, a
publication featuring jail mug shots, herein facts will alleges intentional defamation to
cause damage to reputation in a willful abuse of process as motives began to be
apparent

57. On or about February 30, 2018 , case was dismissed, however caused
needless damage to plaintiff, and willfully attack of his well known good reputation
after requesting attorney to file a complaint of malicious prosecution, counsel declined
and disclosed outside of the Pontotoc County Courthouse, counsel states he did not do
those types of cases also,

58. Attorney Josh Pryron informed Plaintiff that “ he was being induced and
had a target on his back by County Officials” and that was about all he could say
Pryron, strongly suggested that Plaintiff leave Ada, relocating to another town as he
said they weren’t happy about beating frivolous case and would likely retaliated
against Plaintiff.

59. While working outside of home on or about April 14, 2018, Plaintiff
and son’s observed a maroon Chevrolet pick-up stop in front of his residence at 5262
CR 3565, Ada Oklahoma and drove out in side x side to investigate

60. Upon Plaintiff approaching this vehicle, Plaintiff learned that the
occupants were Banker Mike Jackson and Judge Lori Jackson and realizing then the
connection and that the pair was married.

61. Mike Jackson, an OHB official, which Plaintiff currently used OHB
for his Plumbing Company’s banking and fleet vehicle purchase financing and most

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 matters of banking for his company at that time, Plaintiff could not understand what
his divorce Judge, Lori Jackson and Banker Mike Jackson, were doing in his driveway
looking at his home as Mike Jackson said “ I was admiring your home you done a fine
job ” waived and drove away

62. The Plaintiff’s Estate is located on a dead-end road in the furthest

northern area of Pontotoc County and closed to thru traffic it would not be unusual to
go weeks without new visitors

63. A judge from judicial office should maintain the dignity appropriate
to judicial office and act in a manner consistent with the integrity and independence of
the judiciary, and should encourage members of the family to adhere to the same
standards of political conduct

64. Plaintiff then contacted realtor informed him of what happened as

property was pending being listed for sale, realtor confirmed home was not yet listed
and he had not told anyone

65. On December 14, 2018, a Summons and Petition was served on

Plaintiff at his primary principal residence near, 5262 CR 3565 Ada Okla. by process
servicer the day of Plaintiffs infant daughters funeral service that passed away from
complication of birth, graveside service was posted in the Ada evening news paper by
the Chickasaw Nation Hospital, Plaintiff also informed Andrew Gibson from Vision
Bank after routine call

66. Case No. CJ-2018-205 prepared by Alvin D. Files, (“Files”)

person was unknown to Plaintiff also Vision Bank agent had not informed Plaintiff of
Files and he was without contract, Files in fact entering material misrepresentation of
material facts made with knowledge of its falsity, that demands been made was untrue
and as a fact no letter of default or similar had been made and Plaintiff had made
overpayments all year including a not required (9,400.00) deposited in escrow at

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 closing reckless disregard of its truth, which there was justifiable reliance causing
Plaintiff damages

67. Petition was without a in fact supporting affidavit, firsthand

knowledge on the record nor Plaintiff’s payment history with any memorandum,
report, record, or data compilation, in any form, of acts, events, conditions, opinions,
or diagnoses, made at or near the time by, or from information transmitted by, a person
with by the testimony of the custodian or other qualified witness knowledge or by
certification that complies with Rule 902(11), Rule 902(12), failing to meet necessary
elements as deposed in deny answer and rebuttals as follows:

68. In order to properly offer a business record into evidence, two

foundations must
a. Be established. A “foundation” is a sequence of facts that lead
the court to the
69. logical conclusion that the offered evidence meets the criteria
for admission.

70. The first “foundation” the witness must lay is authentication or

identification of
i. the document being offered, that is, the witness must say
what the document is
b. this means the document should be attached to the affidavit as
an exhibit and
71. the witness should refer to it.

72. Neither demand letter nor Notice of Acceleration as a fact per

confirmation delivery with USPS had been received as per contract, also Plaintiff was
not in default, furthermore not so much as a phone call was received from Vision
Bank’s agents of any discrepancy

73. On or about January 4, 2019, Plaintiff noticed a withdraw from

checking account he did not make from business account at OHB, an unauthorized
withdraw of thirty five hundred ($3,500.00) (Cash) was withdrawn from Cactus
Plumbing’s checking account

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74. Plaintiff the only person listed on account as a fact was in
Oklahoma City at time of withdraw, Plaintiff arrived at OHB to investigate, Will
Martin manger at the Byng branch
75. Met Plaintiff and kindly assisted with the matter after being made aware and would
check on issue, Martin said he would review the footage at time of transaction Plaintiff
waited in lobby

76. Martin went to a private room at the bank, twenty minutes later
came back to lobby contacting one of his superiors by phone and speaking to Mike
Jackson at tellers counter afterwards told Plaintiff, video footage was not available,
gave no further explanation other than, sorry for the unauthorized withdraw of funds
and seemingly disappointed, Martin gives Plaintiff a recipe from withdraw slip of the
($3,500.00)(Cash) withdraw in question, on the paper was a copy of Jacob Brauning’s
signature and not a forgery

77. OHB declined to provide footage evidence or make available

for review video recording of said transaction also denied to refund unauthorized
withdraw as request

78. On or about January 9, 2019 Plaintiff arrived at the Pontotoc

County Court House to the office of Karen Dunnigan, Court Clerk, hand delivering
answer to Case # CJ-2018-205

79. Denying the petition and dismissing action for improper

procedure also failing to state a claim on which relief could be granted, requesting debt
to be validated and original creditor’s information in response to Case # CJ-2018-205
to the custody of the PCDC Court Clerk.

80. Answer to petition per summons instructions would cause a

cease and stay pending response by Vision Bank

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81. On or about January 16 2019, upon reviewing the Real Estate
Settlement Procedures Act rules, discovering lenders failure to provide, fair notice,
HUD–1 settlement statements, required disclosures and closing documents, Plaintiff
discovers fraud and breach of fiduciary duties of good faith and fair dealing

82. Also upon review of mortgage contract and promissory note

that states at section (9.) Enforcement of note and acceleration enforceable only upon
two or more signatures applied to promissory note, date January 12, 2018.

83. Promissory note as a fact only bears one signature therefore not
enforceable and the entire process of foreclosure was void or voidable, defective and
unlawfully per contract. As stated per section (9.) promissory note

84. On Plaintiffs duty to due diligences, prepared a RESPA

Qualified Written Request, Complaint, Dispute, TILA and other requests per the
Federal Consumer Protection laws, Plaintiff verified documents by notary at Citizens
Bank in Ada, prepared with cover sheet and mailed U.S. Certified mail return receipt
to Vision Bank, Attention M.Keywood Deese

85. Based on Plaintiffs findings of RESPA violations, failed

compliance with Regulation X, along with failure to provide notice of acceleration,
rendering contract impossible and breach thereof the finding of the facts by Plaintiff,
gained the knowledge that Vision Bank, Files and other’s were engaging in
misconduct and schemes on a pattern of residential mortgage fraud.

86. Plaintiff requested Vision Bank to answer within 60 days of

receipt, per rules of RESPA Plaintiff received returned signed PS form 3811 receipt
card of delivery and confirmation

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87. On January 21 2019, Plaintiff after learning any attachment to
land title, Plaintiff must receive notice, Plaintiff was never noticed by U.S. mail or
otherwise so for that regard, Plaintiff contacted the Pontotoc County Clerk and
Commissioned Staff to perform a Title Search of the record for Estate Property
providing the lot and legal and mailing address.

88. After title search was complete staff reported property was not
subject to lien, title was free of attachments, and instrument was recorded, mortgage in
fact paid, Jan 18, 2018, Furthermore it is a Fact, if any consideration was provided by
Vision Bank had been re-paid in full with interest and Plaintiff held factor lien on
principal residences as in possession and right and held Superior title

89. Saturday morning, January 19, 2019, Plaintiff convoyed a

general warranty deed and promised Title of Brauning Estate, 19.20 acres of land and
improvements at 5262 County Road 3565 Ada, Oklahoma as Grantor and Superior
Title holder thereof to Plaintiff’s heir and oldest Natural Born Son, C.H. Brauning
delivering to him and he accept it, C.H. Brauning, stored warranty deed in the family
safe room that was behind a custom book shelf that concealed the hidden room
wherein Documents, Gun Collection and ammo was stored

90. On or about Tuesday January 29, 2019, Plaintiff U.S. mailed

prepared written notice of revocation, rescission of signature along with withdraw of
consent documents verified by notary at Citizens bank of Ada along with IRS form-56
removing any Estate appointments

91. Plaintiff after making copies and scanning into computer,

delivered to U.S. mail documents certified mailed with return receipt to Vision Bank,
asking for rebuttal if incorrect with 30 days, Plaintiff also mailed Aforementioned
documents regular First-Class to 101 E Main Street, Ada Ok 74820 one attention,
James Hamby CEO and another attention Brandon Tilley

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92. On or about February 14, 2019, at 09:00, OHB, employee
Chance Branscum (“Branscum”) and Pontotoc County Sheriff’s Office (“ PCSO “) ,
Deputy Michael Walker (“Walker”), Deputy Todd Young (“Young”) and Brandon
Smith- NEXT UP TOWING & RECOVERY LLC, trespass on land and chattels at
Plaintiff’s primary principal residence without fair notice and without consent from
land owner wherein they,

93. Trespassers forced entry threw gate at the plaintiff’s principal

residences, trespass on land and invade privacy of the owners land and humble abode
in conspiracy to deprive Plaintiff and innocent others of property rights violating
constitutional rights and fundamentals of due process of law in the taking of life,
liberty and property of Plaintiff

94. Arriving at Plaintiff’s home Branscum, Walker and Young

force entry into garage, unlawful entry, into dwelling trespass to chattels and business
interference including Invasion of Privacy, Art. 2, § 30 of the Oklahoma State
Constitution also protects the right of the people to be secure in their persons, houses,
papers and effects against unreasonable searches or seizures

95. Branscum, Walker and Young forcing entry into Cactus

Plumbing’s Office and Shop, unlawful entry for Invasion of privacy and began to
search confidential business information in a extreme breach of security to business
confidential and private records

96. Branscum entering into office begins searching filing cabinets,

bins, files and folders until finding Cactus Plumbing’s confidential files and removes
entire folder of private records, unauthorized acquisition of confidential client data,
social security numbers, bank accounts, driver’s license numbers, plumbing license
number, employers EIN’s and disclosures

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97. Wherein taking titles, contracts of current and past loan
agreements and other contracts without authorization appropriates, takes, carries away
by fraud theft of trade secrets that is integral to the business transactions and restrict
access on a “need-to-know’ basis trampling the rights of the Business, Plaintiff and
Innocent Customers and third parties

98. OHB, Branscum, PCSO, Walker, Young and Brandon Smith

take and removes Chevrolet 3500 flat bed, three commercial vehicles, two Atv’s,
chattels, commodities, materials, power tools, fuel tanks and fuel and other property
willfully taking of property and property rights without consent without due process or
fair notice in civil theft

99. In the conversion and interference with ownership of property,

tortuous interference with private business affairs, Illegal Search and Seizure that
amounts to none the less of Economic Espionage, all while breaching the peace by the
very sheriff’s department charged with maintaining the peace and protecting the rights
of the people of the county

100. Upon leaving Branscum and Walker drop inside home

garage a legally defective Court documents signed by Judge Lori Jackson, OHB Mike
Jackson’s wife that before taking appointment as Judge was hired by OHB and legated
several cases shortly before taken role as associate judge in a outrageous conflict of
interest, wherein Branscum makes fraudulent false statements under the penalty of
perjury

101. Any person who knowingly procures or offers any false or

forged instrument to be filed, registered, or recorded in any public office within this
state, which instrument, if genuine, might be filed or registered or recorded under any
law of this state or of the United States, shall be guilty of a felony

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102. Taking by force approximately ($233,71.00) of commercial
property belonging to Cactus Plumbing, and Plaintiff’s Nature Born Son’s converted
by OHB, Branscum, Mike Jackson, PCSO, Walker, Young, Stewart, Christian aided
by Judge Lori Jackson in a conspiracy conversion to deprive Plaintiff of property in
the intent to take Brauning Estate

103. Actions done without the owner’s permission and without

privilege to private property by fraud and breach of contract of Cactus Plumbing’s
Articles of Origination agree to by OHB.

104. Plaintiff’s fundamental rights and protections of due process

were trampled by the defendant’s willful actions causing immediate and irreparable
injury and damage in the color of law

105. Along with the devastating losses to long time successful

company that had been a positive impact in the community along with a willful
invasion of privacy, trespassing on private property posted no trespassing and fine of
ten thousand ($10,000.00) per person per violation, wrongful acts and civil theft
recorded to private CCTV DVR located in home

106. Defendants leave property, Walker and Young, in PCSO’s

vehicle’s immediately travel to Plaintiff’s location, creating a emergency where none
previously existed Plaintiff in commission of his contract at Dart Manufacturing
Company in Ada Okla. Walker and Young approach Plaintiff battery and assault along
with unlawful warrantless arrested

107. While Plaintiff was engaging in federally protected activities

of trade and interstate commerce was interfered by the defendants willfully
depriving Plaintiff of rights, Plaintiff demanded causes of action, Walker states
defendant just had an arrest warrant issued out of Seminole County however denied
presenting such document, in their Hostage taking

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108. PCSO, Walker and Young’s Intentional trespass to person,
chattels, searches without warrant, tortuous interference, and conversion of property,
Deputy Walker and Young allege plaintiff will be charged with auto theft of his own
marital motor vehicle and that as long as it would keep him locked up for a while as
they were using malicious prosecution to seize assets

109. Plaintiff noticed Walker and Young that he would prepare a

lawsuit and included them for the color of law violations, Walker laughed and said I
like to see you try. Plaintiff noticed Walker and Young to have body cams on and
recording, the actions of the defendants in conspiracy extortion for self-enrichment
and Hostage taking

110. 17:00 Defendants after unlawful warrantless arrested, subject

Plaintiff to false imprisonment at the Pontotoc County Jail (“ PCJ “) Defendants return
to Dart Co. and without authorization appropriates Cactus Plumbing property, Utility
Truck, Equipment and Case 580M Series II Backhoe.

111. Interfering with business dealing to cause economic

espionage, obtaining trade secrets and cause Plaintiff loss of consortium, loss of use
and damage reputation of Plaintiff and his business after forced shutdown, caused
willfully with malice and a depraved mind all business dealing inferred by the
defendant’s causing immediate and irreparable injury damage in a conspiracy to
convert assets affecting the Plaintiff and other third parties and Cactus Plumbing
employees in an irreparable damage money could never make whole

112. Approximately ($139,410.00) of commercial assets, property

rights belonging to Cactus Plumbing converted by PCSO in concert with OHB,
fundamental rights, protections of due process and fair notice were completely
trampled willfully by defendants with a future lost wages of ($3.1 million) in gross
annual sales each year of loss not recovered from

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113. Actions causing immediate, irreparable, injury, loss, and
damage to plaintiff along with the devastating loss to long time successful company
that had been a positive impact in the community, with a willful conspiracy to deprive
Plaintiff of constitutional rights, protections and resources to further implement the
taking of Estate

114. Only six days prior to above-mentioned act, PCSO, Walker

and Young trespassed on land posted private property and principal residence, Walker
as Young stood-by illegally searched dwelling, shop, Cactus Plumbing’s office and
Camper

115. Plaintiff was returning from a hike in the woods when he spotted
Walker at the rear of his home talking on cell phone asking permission to discharge his
weapon into the woods to “flush out plaintiff” at that point Plaintiff stood by upon the
exit of this dangerous person

116. Walker assumed plaintiff was hiding from him as Walker was
acting in the color of law without privilege one of several times by trespasses and
invasion of privacy, violating rights of plaintiff without consent, wrongful acts
recorded on CCTV DVR located in home

117. On or about February 17 2019, a bond was posted on behalf of

Plaintiff for PCJ, PCJ refused to release Plaintiff stated a “hold” for a charge in
Seminole County required Plaintiff to wait up to ten day for transfer although Plaintiff
had not been in Seminole County in over two years to obtain a charge as Seminole
County was acting in accord with Pontotoc County to commit malicious prosecution to
archive the ongoing conversion of Plaintiff’s Estate and Cactus Plumbing’s assets

118. PCJ denied plaintiff medical needs of C-PAP machine that plaintiff
is ordered by doctor to use every night for treatment of severe sleep apnea as torture

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 for refusing to consent to Jail Staff’s paper-work and standing up for Plaintiff’s
constitutional protected right’s in defeating a wrongful foreclosure scam

119. On February 21, 2019, seven days after of being kidnapped

Plaintiff was charged which failure to release the victim within twenty-four hours after
he shall have been unlawfully seized, is trafficking in person, Plaintiff is taken in front
of Judge Gregory Darwin Pollard (“Pollard”) wherein Plaintiff ask to summit a plea,
respectfully declined to participate, Plaintiff stated he did not consent nor did they
have consent to use any accounts, securities or to act as beneficiary or creditor to the
Brauning Estate

120. Too much amusement of the jail staff, Pollard entered a plea of not
guilty of which Plaintiff objected, charge of knowingly concealing stolen property of
his own marital motor vehicle, absent of accuser as there was none in bondless Case #
CF-2019-00075.

121. Pollard a former customer of plaintiff’s that ended in a altercation

after plaintiff arrived to the Pollard home for plumbing service, Pollard confronted
plaintiff angry fired plaintiff, has been bias since, the unusual encounter, plaintiff
believes for an ancillary reason

122. Plaintiff did not receive a fair and impartial hearing, Pollard
affirming unlawfully arrest and imprisonment without consent of plaintiff causing
damage and injuries among other things, Contract interference and business relation
interference harming third parties willfully violating Plaintiff’s constitutional rights
under the color of law

123. Plaintiff was transported to Seminole County Jail (“SCJ”) and later
released on February 24 2019, after eleven (11) days of false imprisonment within
days after Plaintiff was released, Seminole County Sheriff’s Office (“SCSO”) Deputy

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 Steve Williams along with Assistant Seminole County D.A. Candice Irby, dropped
frivolous Case # CF-2019-00075

124. Filed a week prior on February 26 2019, charged Plaintiff again

with obtaining cash or merchandise by bogus check/false pretenses in Case # CM-
2019-00074 done without probable cause or sworn affidavit without evidence, or
injured party an arrest warrant was posted on Plaintiff’s person in a conspiracy to
deprive Plaintiff of due process

125. In a deprivation of rights under the color of law by way of

malicious prosecution to unlawfully imprison Plaintiff without consent to defraud and
cause business relations interference, evade trade secrets and conversion of property
without privilege

126. On March 11 2019, unlawful action that should have ceased, for
both answer being made to complaint CJ-2018-00205 and RESPA letter and other
documents severed to lender canceling unenforceable agreement and making void
however

127. In the attempt to cease the unlawful actions and misconduct by the
defendants and desperate to save home from the unlawful conversion of the Brauning
Home Plaintiff travels to Muskogee, Oklahoma to file chapter 13 bankruptcy Case #
1980229 in the Eastern District Court of Oklahoma to stay and cease action

128. Notice was given to Vision Bank and PCSO along with a ceased
and desisted demand, for the actions of willful deprivation of rights under the
color of law on or about Tuesday April 2, 2019 Simple Contract/Security Agreement
became null and void and not enforceable, Vision Bank was in default, non-response
failed to rebutted letter(s), and Verified Notice of Default was sent

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129. On Wednesday April 24 2019, Plaintiff makes a written request
for records, body camera footage and oath of office for Walker, Young and sheriff
John Christian to PCSO for the two incidents on Plaintiff private property and
unlawful arrest February of 2019

130. On May 3 2019, Plaintiff arrived at Pontotoc County Clerk’s

Office, as documents were not record, ignored or discarded by Clerk of the Court,
Documents were brought to County Clerk to file on land record Plaintiff’s wife
Savanna takes documents into Clerk’s Office to File and Record verified documents
at Pontotoc County Clerk’s Office, with Tammy Brown as follows:

a. “1-2019-002231 Book 3302 05/03/2019 2:58 PM Pg: 001-044 Fee

$99.00”

131. The Following, A Public Declaration and Private Notice of

Immediate Withdraw of Consent, Legal Notice and Demand, Notice of Private
Ownership. All Property Belonging to the Debtor Belongs to the Secured Party
Including but not Limited to, All Computers and Personal Possessions in on or Around
location.

132. All Value Associated with Any Accounts Including xxx-xx-8162,

All Personal Property, Contents or Anything of Value on, in, or Around
Property Located at or near Plaintiffs Principal Residence Estate at 5262 County
Road 3565 Ada, Oklahoma.

133. Affidavit of Facts by Specific Negative Averment and Denial of

Corporate Existence, Acceptance Foreign St, All Rights Reserved, Notice Private
Acceptance Oath of Office

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134. Notice to, PONTOTOC COUNTY and SEMINOLE COUNTY
SHERIFF OFFICES Legal Notice and Demand, Withdraw of Consent, Notice of
Private Property and Fee Schedule If harmed or State and Federal Rights were
Violated again by Defendants

135. County Clerk Tammy Brown sent logged Documents to Plaintiff at

home address

136. On May 13 th 2019, Plaintiff faxed forty four page Legal Notices
and Fee Schedule to Vision Bank, PCSO and PCDC Clerks Office, for fair notice and
warning for compliance copy sent Certified Mail® Return Receipt to Vision Bank
along with Notice of Dishonor Opt. to cure, certificate of service in follow-up of
Notice of Default letter Sent April 2 2019.

137. As Legal Notices to Defendants Violating Plaintiffs Rights under

the Color of Law, no instructions to file into pending court case were given nor did
documents have pleadings or case numbers of any cases of record with no attempts to
contact plaintiff with malice,

138. PCDC, Court Clerk Karen Dunnagan filed Legal Notices into Case # CJ-
2018-00205

139. On May 14 th 2019, Plaintiff arrived at PCDC, H. Ledgerwood hand

delivered to the custody of Clerk, a Motion to Vacate a Void Judgment for Case # CJ-
2018-00205 and did not leave until the PCDC Court Clerk, filed stamped
Plaintiff’s Copy of Motion

140. On May 15 th 2019, at around 07:45 Wednesday morning Plaintiffs’

Natural-Born son’s where brought home, by their mother to spend the rest of the week
with their father as they were out of school for summer break and had our annual
camping trip planned at the lake

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141. At around 09:39 Plaintiff, heard a knock at the door, opening door
Plaintiff was torn from home, after OHP, Trooper William Hayden (“Hayden”)
reached in past threshold with PSCO Deputy Derek Steward (“Steward”) another
Deputy, grabbed hold of Plaintiff

142. Plaintiff, broke loose the wrist hold from Hayden and hip tossed
Hayden over Plaintiffs’ side, Hayden landed on his back onto the front porch as Police
Equipment flew off from his person at the impacted and the Plaintiffs sons
came near the area

143. The two PCSO Deputy’s stood froze, without a move as Hayden got
up and started to engage Plaintiff again, as Plaintiff’s oldest son Colten, yelled “ daddy
” in a worried tone, Plaintiff immediately stopped resisting the unlawful detainer and
attempted to calm both sons

144. Plaintiff, was assaulted, hands cuffed behind his back, without cause
and authority officers were willfully unlawful and outrageous to trespass on land and
trespass on person to make unlawful and warrantless arrest, Plaintiff demanded what
authority they had for trespassing onto on Plaintiff’s posted private property, and
violated Plaintiff’s and minor sons right to be secure in their own dwelling, Trooper
Hayden said: “ You will found out, when we get you to jail ” the three officers
acting in the color of law

145. Plaintiff, desperate not to abandon his minor children, pleaded with
Hayden and Stewart that their conduct was unlawful, that they had a sworn oath to
uphold the law they laughed

146. Defendants, Hayden and Stewart, without permission to be on

property that was posted no trespassing warning of fine ($10,000) per person per
violation, defendants wrongfully imprisoned plaintiff in a conspiracy deprivation of

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 rights under the color of law with the willful intent to defraud for the conversion of
property as to deprive Plaintiff and prevent any objections

147. To deprive any remedies or appeals available to Plaintiff in the

extreme and outrageous violations of Plaintiff’s rights afforded or protected by the
Oklahoma state and U.S. Constitution in a conspiracy to usurp Estate properly and life
itself of the Plaintiff, the laws of necessity, of self preservation under full attack by
those charged to protect it

148. Defendants violating Art. 2, § 30 of the Oklahoma State

Constitution also protects the right of the people to be secure in their persons, houses,
papers and effects against unreasonable searches or seizures

149. As Plaintiff, assembled a formidable defense to prevail over the

actions brought against Plaintiff in a lawfully and peaceful manner Plaintiff following
the rules of procedure to the best of his abilities would be no affect to unlawful arrest
and false imprisonment

150. Plaintiffs son’s were home alone without anyone familiar to them
for close to a hour after watching the traumatic painful event, witnessing three armed
deputies willfully inflict violence to their father, assaulting and battering him at their
home, Plaintiff was not armed

151. Home CCTV camera mount directly above front door at entrance of
home recorded entire event of the misconduct, Plaintiff taken hostage to PCJ, in
considerable pain and imprisoned without consent and battling anxiety, chest pains
and valve prolapsed

152. Later the same day, Sheriff John Christian, would hold a Sherriff’s
Sale listing one parcel of 3 parcels, as the unlawfully action had not ceased, further
violating, Plaintiff’s inherit right of due process of law, and true reason for Plaintiff’s

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 being forced into involuntary servitude in the willful conspiracy and conversion and
ongoing trespass

153. On May 16 2019, Plaintiff charged with resisting arrest and

tampering with utilities CM-2019-00515 - CM-2019-00516 Pollard affirmed
evidencing no prior causes to enter on to land and imprison Plaintiff, while defendants
conspire and would benefit from peonage and trafficking in persons of the Plaintiff, so
that he could not object to preceding against him

154. On May 19 2019, Sunday evening PCJ Jail staff, against the
Sheriffs orders contact EMS reporting Plaintiff’s high blood pressure and chest pains,
wherein EMS found Plaintiff unfit for incarceration due to heart condition, Plaintiff
was released after (4) days

155. On or about June 14, 2019 Plaintiff faxed Motion to Dismiss and
objection response to the Motion to Confirm Sheriff’s Sale of Case No. CJ-2018-
00205 to clerk of court the response contained an verified Affidavit of Truth and Fact
and Complaint of fraud on the Court, Plaintiffs Affidavit and Complaint for Case No.
CJ-2018-00205.

156. On or about June 17, 2019 Plaintiff received by certified mail and
first of record, mailing from Vision Bank delivered with return receipt to Vision Bank
Plaintiff signed for mail was received at principal residence 5262 County Road 3565
Ada, Oklahoma by rural route carrier, plaintiff planned to open and review mailing in
the next couple of days

157. On June 18, 2019, Plaintiff arrived home that evening after being
gone for three to four hours to find gate lock cut off and posted no trespassing signs
had been tore down along with remote gate CCTV wireless camera were gone

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158. Plaintiff, arrived at his home to find door knobs’ changed on
home and shop and garage doors secured closed with a paper taped to door that stated
“writ of assistance”, Files name at bottom in the outrageous trespass to land and
chattels along with invasion of privacy

159. Plaintiff, noticed power had been turned off, once inside home,
plaintiff noticed home had been ran sacked, CCTV DVR to 4K NV5216 home
surveillance system was removed families prized Gun Collection as well as entire
large supply of ammo was gone Guns and ammo used for all for lawfully hunting and
target shooting purposes, PCSO, in UNLAWFUL POSSESSION AND RECEIPT OF
FIREARMS

160. Ten thousand federal reserve notes belonging mostly to Plaintiffs

Son’s ($10,100.00) (Cash), Plaintiff’s prized U.S. Stamp collection, EE Bonds,
Contracts, Certificates of live birth, Marriage Certificates, Security bonds, SS cards,
Personal and highly Confidential business records and trade secrets were taken from
Plaintiffs Winchester Safe

161. Plaintiff, then entering his home office to find, opened and
unopened U.S. Mail including most recent mail delivered to plaintiff from Vision
Bank, were taken also Cactus Plumbing’s HP Laptop used for the sole purpose for
private accounting and accounts receivables containing private and confidential
customer records such as identities, debit card payments, checking and routing
numbers as well as tax documents

162. As well as employee’s tax files and withholding's, tax

identification numbers privilege Trade Secrets designed over the past 10 years
including one US patent and one pending US patent for a Plumbing trade fixture an
commercial self-leveling and adjusting floor drain in design to solve the problem of
un-level floor drain tops causing trip hazards in commercial applications

30
163. HP Pavilion Pro desktop computers (2), SD and thumb drive
storage cards full of Confidential information, Court Case documents, Complaints of
Color of law violations along with a mountain of evidence, were all taken by Files and
the PCSO after unlawful entry of home

164. Plaintiff had been preparing a Civil Rights Complaint to be

filed in the Eastern District Court of Oklahoma and had documents prepared to that
point listing, Lori L Jackson, John Christen, Alvin D Files, Michael Walker, Todd
Young, William Hayden, Derek Stewart and OHB for Civil Rights violations

165. Now the private information was in the hands of the defendants
and well known exactly what Plaintiff sought as things went from bad to worse for
plaintiff in the truly unbelievable and complex to comprehend level of malicious
misconduct and abuse of office that was transpiring

166. Witness Tampering, Retaliation destruction of evidence, or

deceit, Including obstruction of pending local and federal court proceedings with
willful intent to enter Plaintiff’s humble abode to confiscate evidence was a willful
conspiracy that trampled the rights of the plaintiff and destroyed Plaintiffs federal
lawsuit and pending court cases in Pontotoc Court that Plaintiff was a party to in the
extreme outrageous actions of Defendants

167. Plaintiffs power was not turned off from home, a call was made
to report outage to the power company, Plaintiffs believes the power was turned off
illegally by Files and PCSO
168. Plaintiff re-installed original locks that was left on bar table and
a new pad lock at gate along with no trespassing sign, pictures were taken of incident

169. The following warm summer morning of June 19 2019, the

Plaintiff awoken, then makes call to the FBI, Washington DC Office headquarters, to
report the criminal activates that PCSO appeared to be involved with and Spoke to

31
 Special Agent Whitney, that logged a report and advised Plaintiff to immediately call
the state Attorney’s office

170. Plaintiff dialed the Oklahoma State Attorney General’s office

and spoke with agent that instructed Plaintiff to make a police report complaint and
email back to their OAG office, Plaintiff then notices plain and PCSO vehicles began
to gather outside of locked gate, in the front of home, Plaintiff makes 911 call to report
along with burglary, breaking and entering the dispatcher advised Plaintiff, PCSO
Deputy would return a call to take report

171. A moment later Plaintiff, received a call from Arnold Scott

PCSO undersheriff, Plaintiff explained, Alvin D Files and PCSO organized a breaking
and entering into property and home, entering dwelling against the will of the owner
and explained the loss of property

172. Arnold Scott stated that there were deputies outside of

Plaintiffs gate, to make a report with deputies, fearing that the PCSO was engaging in
misconduct Plaintiff stayed in home, Arnold Scott Called Plaintiff again and stated “
this is a lawfully order to step outside and talk to PCSO if you did not do so the PCSO
deputy’s would force entry into your home”

173. Plaintiff hand wrote a complaint and attempted to email it to

the Oklahoma State Attorneys Generals office as phone powered off due to dead
battery as power was still off in home and phone was not charged over night, at 13:00,
Plaintiffs in fear of having more damage done to home, Plaintiff steps outside of home
locking the door behind him

174. Plaintiff was approached by six officers with AR-15 tactical

rifles locked and loaded aiming at body of Plaintiff, ordered to the ground at gun
point, Walker then showed up from behind them assaulted and unlawfully arrested
Plaintiff, cuffing hands behind back very tightly causing immediate agonizing pain

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175. Plaintiff was then forced into Walkers, PCSO vehicle as John
Christian, Walker and others with PCSO and State of Oklahoma Troopers Forced
entry into Plaintiff’s Home invaded and searched over the next two hours, Plaintiff’s
hand cuff’s had not been locked and continued to get tighter and tighter in agonizing
pain in the small confined space, that seemed to be getting dangerously warn in the
late July direct sunlight at 13:30, the air was blowing in Walkers Cruiser, turned to
A/C with a speed of (3) or (4), Plaintiff’s arms and legs became numb and pain
subsided

176. A George Smith towing truck arrived and towed off Plaintiff’s
Black Z71 and left the others, Plaintiff was removed from his humble abode in a
unlawful theft of person for means to usurp and convert estate property, plaintiff had
not been served any lawful process nor did one exists as from its inception, is a
complete nullity and without legal effect

177. Walker and Christian approached Plaintiff, Walker opens door,

Plaintiff tells the Sheriff this is completely illegal, that he demands to speak to Judge
Kessinger, Christian reply’s “ we are here on his orders”, using other offensive
language he said “ have fun in jail”

178. Defendants completely destroying what was left of Plaintiff’s

Business, livelihood and taking all resources of Plaintiff’s as right to privacy would be
violated in the most dehumanizing way as strangers sift through Plaintiff’s home and
contents and remaining business files to removing it all in the act of color of law,
being ran sacked by the defendants in the morally shocking conspiracy of Deprivation
of Rights Under Color of Law

179. That was the last time Plaintiff or his family would dwell in their
home as the unlawfully taking of the Brauning Estate had been pulled off the Estate
owned lawfully by the Plaintiff with clear title as Plaintiff was taken to PCJ and
unlawfully imprisoned damaging the Plaintiff in excess of (1.644,684.00)

33
180. Defendants violating Art. 2, § 30 of the Oklahoma State
Constitution also protects the right of the people to be secure in their persons, houses,
papers and effects against unreasonable searches or seizures

181. Plaintiff was forced into involuntary servitude and deprived of

his relationship with his family devoid of equal protection and due process of law
while Kessinger, Jackson, Files, Christian would administer Plaintiffs affairs without
consent in a tortuous conversion

182. On June 20 2019, Plaintiff was charged with Breaking and

Entering Dwelling without Permission in Case # CM-2019-00638 Judge Pollard,
Affirms the extreme and outrageous conduct therefore aiding and abetting the
constitutional rights violations in the color of law
183. Holding Plaintiff hostage, denying Plaintiff from appearing to
pending court cases making false statements that defendant failed to appear, while in
adverse possession of Plaintiff property and disbursing property as Lori and Mike
Jackson and Files would trespass and occupy Plaintiffs home making changes to home
invading Plaintiffs privacy without consent from the owner

184. On June 22, 2019, A invalid Motion to leave to enter Deficiency

Judgment in Case # CJ-2018-00205 Steven Kessinger the presiding Judge, however
Judge Lori Jackson was administering the case knowingly executes, or attempts to
execute, a scheme or artifice document rubber stamped “ L. Jackson ” as the risk
was hers to assume as was her scheme

185. The Record stated defendant (Jacob Wayne Brauning) failed to

appear Plaintiff defaulted which would mean Plaintiff was afforded the opportunity of
free will to do so which is highly false, while held by what equals to the legal
definition of ransom in PCJ and deprived due process and equal protection of law

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186. On or about August 1 2019, Plaintiff was shackled with ankle
cuffs that connected to a chain that ran up front of body connecting to hand cuffs then
fasten to a large leather belt and Plaintiff was taken to the crowed PCDC, dressed in
county issued orange jump-suit to the court room of presiding judge, Lori Jackson,
wherein learned, without fair notice was a emergency hearing for the invalid
modification of parental rights for divorce case # FD-2017-00032

187. Plaintiff recently settled with joint custody with former spouse
after over a year long process that was less than productive, Plaintiff was advised by
former spouse’s Garvin County Mental Health Case Worker of which Plaintiff given
permission to speak to prior, the mental health consular stated it was imperative,
Plaintiff retained custody of Sons and advised Plaintiffs Council to subpoena
representative

188. Wherein presiding Judge Lori Jackson, denied subpoena request,

also request to enter evidence on the record along with witness testimony and
affidavits, denied two impartial witness’s the day of hearing, to testify concealing ex-
spouses mental health issues that were left untreated after fleeing treatment at the red-
rock faculty in Norman, Ok also Paul’s Valley Police department records of EOD’s
and apprehension wherein plaintiff’s pistol was removed from her person and
confiscated and her right to carry was barred, records were denied admissible into
case by Jackson.

189. Plaintiff was brought before the Court for termination of his
parental rights in the extreme and outrageous misconduct and retaliation , Plaintiff
strongly disagreed denied to sign papers stated he disagreed, did not consent and
motioned to dismiss, motion was denied by Jackson

190. After court was dismissed and Plaintiff was leaving Court room,
Jackson stated:

35
191. “I would advise Mr. Brauning to be more Cooperative next time he's in my
courtroom”
192. The court date was scraped from the record and replaced with a court date late in
the year of 2019 and yet again Plaintiff was not given fair notice and Jackson would
yet again administer Plaintiff’s affairs without nor with strict compliance of due
process of law violating Plaintiffs rights as well as Plaintiff’s inherent unalienable
rights as there seems no moral bounds nor ethical line, Judge Jackson will not cross

193. On August 9 2019, Plaintiff was charged with False Assertion of

Law for the legal notice’s Plaintiff fairly served on defendants, May 13 2019, felony in
Case # CF-2019-00358 wherein pursuant to statue would bring on a Bar Attorney,
Deputy Steward knowingly executes, a scheme and artifice, however one statement,
Steward made one correct statement that Plaintiff was having financial troubles,
although misleading as the fact is the financial troubles were directly caused by him
and his co-conspirators

194. Stewart, failed to mention the Plaintiff when left to his own
accord is a talented and skilled tradesman top-off his trade and craft at the peak of his
career and in just less than a decade the team that was put together quickly became the
professionals young apprentices aspire to be, and together as a team build the best
service company the Ada area had ever seen, respectfully.

195. On August 22, 2019, A invalid Order Confirming Sale in Case #

CJ-2018-00205 Judge Steven Kessinger the presiding Judge, however Judge Lori
Jackson was administering the case knowingly executes, or attempts to execute, a
scheme or artifice document rubber stamped “ L. Jackson ” as the risk was hers to
assume as was her scheme

196. On August 22, 2019, A invalid Deficiency Judgment in Case #

CJ-2018-00205 Judge Steven Kessinger the presiding Judge, however Judge Lori
Jackson was administering the case knowingly executes, or attempts to execute, a

36
 scheme or artifice document rubber stamped “ L. Jackson ” as the risk was hers to
assume as was her scheme the Record stated Plaintiff (Jacob Wayne Brauning) failed
to appear and defaulted, as Plaintiff was held ransom at PCJ

197. Possible conflicts of interest that could cause an unfair and bias
of a judge is the duty of Judge to acknowledge and recues themselves as ethically
bound however pursuant to the opposite would be bad faith unclean hands and a abuse
of office

198. The obligation of their official duties therefore if you go back to

Judge Lori Jackson’s last case in private practice before taking the position as Judge,
the matter was brought to the CLEVELAND COUNTY COURT, wherein Lori
Jackson was the Attorney for the Plaintiff in a Foreclosure matter CJ-2014-728
wherein before the case was complete, Lori Jackson would be sworn in as Associate
District Judge for Pontotoc County, facts states as follows

a. Jackson was retained by Plaintiff Vision Bank N.A.

b. Jackson referred Summers and Files to Vision Bank N.A.
c. Jan 30 2015 Jackson Motions Withdrawal and Substitution
d. Appoints Summers & Files law firm for Vision Bank N.A.

199. Judge Lori Jackson, in her private practice had a long history
representing Vision Bank N.A., working with preferential treatment of constituents
including Summers & Files Law Firm, wherein administering Vision Bank N.A. VS
Jacob Wayne Brauning in a overwhelming conflict of interest that aided and abided
the unfair treatment of the Plaintiff and a Abuse of Office by Jackson

200. On or around August 24 2019, Plaintiff was given by PCJ Staff

a letter sent to PCJ (Jacob Wayne Brauning) from Summers and Files Law Firm, letter
was refused --RTS
37
201. On or around the 26th of August 2019 Plaintiff was given by
PCJ Staff a letter sent to PCJ (Jacob Brauning) from Vision Bank inside was a three
page letter from Files stating:

38
202. Alvin D Files, above letter is substantial evidence of FRAUD,
FALSE STATEMENTS AND MISREPTRESENTATION also evidence as a Fact of
Files, is a perpetrator of the fraud, Files was without authority to take one step onto
Plaintiff’s private property, June 18 2019, or other time including other Defendants in
the Willfully and Outrageous acts of Wrongdoers

203. Even to presume Plaintiff, did abandoned his Estate and not
trafficked in persons and held hostage at the PCJ, Plaintiff had a Mortgage clause
provision on Insurance policy and declaration that states if property became vacated or
abandoned lender is to notify Insurance company and Insurance company would take
possession pay mortgagee any arrears up to the full amount of loan

204. Vision Bank was in agreement with terms therein to be listed

mortgagee and had there on copy of policy and made the payment to the Insurance
Company from escrows funds Plaintiff deposited into, however Insurance provider
was never contacted and policy stayed in effect until May of 2021

205. Files, knowingly executes a scheme and artifice in his statement of

fraud that Plaintiff up and abandoned his home just left everything he has work hard
for his whole life in Files attempt to conceal the Fraud Files perpetrated along with
Christian and Walker wherein they break into a home in the county to rob homeowner
and to squash evidence that exposes their criminal syndicate

206. Files Letter wherein Files makes False statements, Mail Fraud,
schemes, in the conspiracy for Conversion of Plaintiffs Property by mail fraud that
Files, Jackson and Vision Bank were in adverse possession of without consent of the
Owner in continuing criminal trespass to land and property, Files continues to make
false statements of household furnishing were contaminated with methamphetamine
Plaintiff’s humble abode has be defiled by the profane

39
207. Files by duress of goods attempts to perpetrate further fraud upon
plaintiff with the decisive and ill mind to gain wavier of liability for the conspirators
and co-conspirators as they desperately need, the effect of duress and undue influence
in order to get possession of goods wrongfully detained

208. In the gross fraud, malice, oppression, or wanton, willful, reckless

conduct criminal indifference to civil obligations by defendants to usurp life, liberty
and property of Plaintiff, Files unlawfully entered Plaintiffs home in a extreme
violation of Plaintiff’s rights along with Criminal acts of the trespassers the average
man would be put away for a long time, Files and PCSO were despite a duty to protect
evidence would destroy evidence to conceal their misconduct despite:

209. A lawyer must not knowingly disobey an obligation under the rules of a tribunal
except for an open refusal based on an assertion that no valid obligation exists.
210. A lawyer must not falsify evidence, counsel or assist a witness to testify falsely,
or offer an inducement to a witness that is prohibited by law.
211. A lawyer must not unlawfully obstruct another party’s access to evidence or
unlawfully alter, destroy, or conceal a document or other material having potential
evidentiary value, or counsel or assist

212. Kessinger, Jackson and Files and all other persons required not to
Knowingly or willfully make any false statement or representation of the facts as a
member of the legislative judicial branch as was known to the Defendants after
unlawfully taken evidence that Plaintiff was preparing a federal civil rights lawsuit
that Defendants would attempt to cover up and conceal their misconduct along with
committed gross violations of Plaintiff’s constitutional rights

213. On August 27, 2019, two days prior to scheduled court date of the
29th without fair notice and a unfair surprise Plaintiff was taken in shackles to the
empty third floor room of the Pontotoc County Court House wherein Judge Steven
Kessinger, ordered plaintiff, do not contact Vision Bank, Plaintiff asking about his
property, judge Kessinger replies “you lost it”
214. Kessinger, strongly warned Plaintiff, not to go back plaintiff's
home at 5262 CR 3565 Ada, Okla. and if he knew what was best and didn’t want to go

40
 to the state prison for seven years he would move on, making no voluntary agreement,
Plaintiff released later that day
215. Plaintiff arrives at his home to find home locked up with new
hardware home was empty with remodeling going on inside and a Bates Security
system had been installed, Plaintiff removes (2) hidden devices from property noticing
new trail cameras had been installed rear of home, all Plaintiff’s vehicles had been
removed except Plaintiff’s Buick sedan however keys were removed, plaintiff gathers
up a few items placed in a concealed location and leaves property narrowly avoiding
PCSO vehicle patrolling

216. August 29 2019, Plaintiff birthday, he was told the Seminole

County Sheriffs Department went by Plaintiff’s Mother’s house North of Konawa
Okla., in Seminole County, Plaintiff Looks up record on ODCR webpage and both
Seminole and Pontotoc County had “OSW” issued from Both Counties just a day after
release and was apparently looking for Plaintiff

217. August 30 2019, Plaintiff travels to Friend Cody’s home in

Pottawattamie County, that Plaintiff hadn’t visited in over ten years as would be a safe
location as no one knew were Plaintiff was and would attempt to recover from the
wrongs perpetrated against him Plaintiff was offered a small room inside of shop that
plaintiff would make home over the next few months

218. As Seminole and Pontotoc County Sheriff's office worked

consistently attempting to learn plaintiff's location and his whereabouts even going as
far as PCSO deputy Musgrove’s sister or sister-in-law messaging plaintiff on his social
media and inviting him to dinner in Ada, Okla. randomly upon asking if she knows
deputy Musgrove’s person blocked Plaintiff as he knew it was related to PCSO also
attempts to learn whereabouts was Plaintiffs ex-wife as she would attempt to learn of
plaintiffs location without success

219. On September 25 & 26, 2019, despite the fear of reprisal plaintiff
in the usual course of communication with bank, emailed, Jim Hamby, Brandon

41
 Tilley, Andrew Gibson, written requested release of private property, plaintiff received
no response from bank

220. On October 1 & 4, 2019, plaintiff emailed Jim Hamby,

Brandon Tilley, Andrew Gibson, written requested release of private property,
plaintiff received no response on or about October 5, 2019 on a Saturday Plaintiff calls
PCSO requesting the ability to gather personal belonging and clothing as cold weather
was nearing deputy replied Plaintiff needed to turn himself in and what was his
location, Plaintiff disconnected call

221. However was never their goal return property they were in
adverse poss. of they to work with the Plaintiff or fulfill their objections as fiduciary,
in good faith

222. On November 11 2019, Plaintiff longing for his relationship

with his Sons that are his entire world asks Cody’s son, that is in the same grade as
Plaintiff’s youngest son asks him to tell Ruger, that his “Father was sorry he has not
seen them and to tell him his Dad loves him with all his heart and always will”, he
arrives home after school and confirms message was delivered and that Ruger misses
his father and was asking many question about him.

223. On November 12, 2019, at 13:00 PCSO Deputy, Walker

arrives in his personal vehicle to Cody’s home uninvited concealing vehicle on the
north side of shop to surprise Plaintiff, exiting his vehicle holding an AR-15, wearing
plain black on private property rural Pottawatomie County, Walker, confronted Cody,
home on his lunch break one hour later than usual at gunpoint demanded Mr. Starks
give him his cell phone and keys

224. Walker headed for shop, Plaintiff then heard commotion of a

man coming through the shop and he was kicking things over as he was looking down
the sight rail of his AR-15, Plaintiff demanded the person who was pointing the AR-15

42
 at him to identify himself. Soon after, Plaintiff recognized Walker, who never
identified himself nor planned too

225. Plaintiff knew this was a bad situation as Walker has

violated plaintiff’s rights for the last year and half, also well familiar with rifles and
you only look down the sight to achieve a accurate shot and plaintiff was convinced
this was a hit job to conceal the outrageous misconduct, Plaintiff shouted “ I am
unarmed and pose no threat ” Walker continued towards Plaintiff, kicking through
two doors entering Plaintiff’s area

226. Plaintiff escaped out an adjacent shop door, Walker

following close behind left the interior of the shop, Walker once outside fired one shot
at Plaintiff who fled to home, Plaintiff makes it to the home south of the shop, Walker
stopped twenty foot from front door, noticing Plaintiff pulled out cell-phone and began
recording the events

227. Plaintiff standing in Mr. Starks’ home, Walker lowers rifle

and pulls JBX firing at Plaintiff hitting him with a ball bullet hitting Plaintiff in the
face and in left eye, Plaintiff was able to shut the door, locked the deadbolt and made it
to the rear of home to a bathroom where he rinsed and washed out the eye and face
then dialed 911

228. Walker re-entered shop area removing Plaintiff computer,

U.S Mail, federal cases Plaintiff was preparing and evidence, then went to his pickup
and changed jacket and hat at 13:49 Plaintiff spoke to Pottawatomie County dispatch
requesting urgent help from Sheriff', POTTAWATOMIE COUNTY SHERIFF'S
OFFICE (“ PottCSO”) was unaware of Walkers presence until after 14:00 unaware
that PCSO were in their county

229. Dispatch gave Plaintiff instructions to stay in home and

standby until PottCSO Palmer arrived, Plaintiff followed instruction throughout the

43
 remainder of the event, during the 911 call with PottCSO,

230. Within ten minutes five to six PCSO Deputies arrived and
surrounded home as It was obvious they were nearby on standby a, PCSO Deputies
demanded Cody tell them where power disconnect was for home to kill camera’s after
noticing cameras on exterior of home

231. Plaintiff was uploading a FB live stream that would be

later transferr to YouTube and shared all over the world As PCSO Deputies prepared
entry into home, PottCSO Deputies arrived and ordered PCSO, Deputies to leave
property, PottCSO Palmer shouted “ PONTOTOC COUNTY GET THE F*K OUT
OF HERE NOW ” PCSO immediately loaded up, left the property

232. Walker with PCSO requested transfer of Plaintiff to

PCSO via radio, PottCSO Palmer denied PCSO's request and took Plaintiff to the
Emergency Room at Shawnee Hospital as Plaintiff was having a micro valve
prolapsed with heart pulsing over 105, extreme duress of being stalked and shot at,
then shot by Walker in his outrageous misconduct that left Plaintiff’s injured left eye
swollen closed and vision in eye permanently damaged

233. Plaintiff at PottCSO instruction, filed a incident

statement regarding PCSO's and Walker’s misconduct, Plaintiff believes PCSO
conspiracy and attempt to Kill Plaintiff, Walker as stated in PottCSO report did not
have a warrant did not call in assist until after pursuing Plaintiff, Walker brags about
shooting Plaintiff in face and later received a promotion, new PCSO vehicle, fifteen
days paid leave the end of December by Christian

234. Plaintiff, in pain after hospital release was taken to the

Pottawatomie County Jail for the OSW issued for Plaintiff’s person out of Seminole
and Pontotoc County on November 15 2019, Plaintiff was transferred to SCJ and

44
 forced into involuntary servitude Plaintiff denied follow-up to original doctor and
denied requested for C-PAP

235. Plaintiff was forced into solitary confinement for

thirteen days in a eight by ten cell without a phone as punishment for denying consent
and refused to sign SCJ paperwork Plaintiff made six written requests to SCSO
Deputy Matt Haley (‘Haley”) to speak to Shannon Smith (“Smith”) the Sheriff and
was denied request, Plaintiff hand wrote a petition of writ of habeas corpus to be
given to the Court and was denied or not entered

236. Plaintiff would sit in Jail on Thanksgiving day away

from his family for the first time without committing a crime, Plaintiff makes a call to
oldest sons cell phone wherein their mother answered asking to speak with the boys
that Plaintiff really needed to hear their voice, their mother responded and stated she
got engaged and they have a new father now and that Plaintiff will never see them
again and hung-up

237. After the taking of his property and near death attempt
to eliminate Plaintiff and with injuries in a conspiracy to deprive Plaintiff’s
fundamental rights plaintiff suffered and continues to suffer Intentional infliction of
emotional distress on December 3 2019, Plaintiff was transferred to PCJ, forced into
involuntary servitude then back to SCJ where plaintiff spent twenty five (25) days
imprisoned

238. On December 12 2019, After Plaintiff had been released

from jail just a few days Plaintiff arrived at SCSO to pick-up funds per phone
conversation with SCSO staff Plaintiff went inside to receive check of sums on trustee
account after a prepaid card given by SCJ at release did not work, Plaintiff was
unlawfully arrested by Deputy Gary Brooks and Haley, after checking that no warrants
were posted prior to entering SCSO

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239. Plaintiff was told by PCJ staff by Melissa Pierce a check
was being issued for Plaintiff, the next four hours, Plaintiff sat in SCJ holding with his
foot cuffed to a bench Plaintiff never received lawful warrant, began having chest
pains begged for EMS Melissa Pierce denied request told plaintiff he would die
before EMS was called

240. Haley told plaintiff he was being held on orders from

the PCSO sheriff John Christian and that PCSO Deputy Young, was in route to pick-
up and transfer Plaintiff to PCJ, PCSO Deputy Young, arrived after chat with Melissa
Pierce and degrading comments made regarding plaintiff’s “ fake alleged heart
condition ” Young shackled Plaintiff

241. While in transport to PCJ Young adjusting his ring then

attempted to strike Plaintiff slightly clipping Plaintiff on the left ear shortly
before arriving to the PCJ On December 13 2019, Plaintiff was charged by Judge
Greg Pollard, via TV court, never given presentments or documents, still unaware of
charge plaintiff stated to Pollard they did not have consent and Plaintiff did not wish to
participate as rights were violated

242. Pollard denied as he laughed and called the remaining

inmates and posted hold on Plaintiff for another ($50,000) fifty thousand dollar bond,
Plaintiff was bonded out once again on or about December 18 2019 serving six more
days of involuntary servitude on December 21 2019 Plaintiff checked ODCR website
and had yet again posted Arrest Warrants issued out of Seminole or Pontotoc County
decided to leave the state

243. On December 22 2019 Plaintiff fled and sought refuge

in the State of Texas out of fear for his safety, began preparing a 1983 civil rights
violation case against defendants, May of 2020 plaintiff travels with camper to Eufaula
Okla. to be near Muskogee where Plaintiff planned on fling 1983 lawsuit against the
aforementioned defendants

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244. Kessinger, Pollard, Hayden separately from each other
enter into a agreement or equal of a home mortgage financing transaction(s) with
Vision Bank N.A., via information recorded on land in 2020, record for Pontotoc
County Oklahoma

245. August 8th 2020, Pittsburg County Sheriff's deputies

arrest plaintiff and take Camper along with Computer and case Plaintiff had been
preparing for six months, Arrested Plaintiff for OSW issued out of Pontotoc and
Seminole County and holds from both counties were placed the same day so that
plaintiff could not leave jail

246. However Plaintiff received great care from jail medical

staff visited doctor and therapist was given heart medication and anxiety medication,
began healing the trauma on January 15 2021, Plaintiff became very ill, taken to the
hospital by jail staff Plaintiff was diagnosed with Covid-19 was treated and released
from jail despite holds

247. May of 2021 Arrest Warrants for Plaintiff’s arrest would

disappeared shortly after making Oklahoma Open Records Act, 51 §24A.1 et seq.
Request for Records, PCA, Transcripts and Case Records with Seminole and Pontotoc
County Court Clerk’s
248. Upon making a records request to Seminole SCJ plaintiff
was told from staff that plaintiff has never been an inmate of their jail and no records
of incarceration or cases, Upon review of ODCR website several cases were deleted
from the record along with the charge of trespassing, breaking and entering of
Plaintiffs own home when plaintiff was seized in Pontotoc County June 19th of 2019
and property unlawfully converted

249. Vision Bank and Files Falsely statements of fraud and

misrepresentation wherein Files states Plaintiff abandoned home, in the color of law
Files commits mail fraud for the fifth time, While Vision Bank, Files and the Jacksons

47
 are in adverse possession of the Brauning Estate remodeling and installing security
systems while Plaintiff is the lawfully owner

250. Furthermore upon investigations Plaintiff found further illegal activity by

and between the chief district Judge Charles Steven Kissinger, and the associate Judge
Lori Lynn Jackson

251. Oath of Office filed with the OKLAHOMA SECRETARY OF STATE on

January 16 2019, Oath of Office filled for judge Kessinger and Jackson both having
sworn or affirmed falsely, or having violated said oath, or affirmation shall be guilty of
perjury, and shall be disqualified from holding any office of trust or profit within the
State, Article XV, Oklahoma Constitution, Oath of Office:

252. All public officers, before entering upon the duties of their offices, shall take
and subscribe to the following oath or affirmation:

"I, ........., do solemnly swear (or affirm) that I will support, obey, and defend the
Constitution of the United States, and the Constitution of the State of Oklahoma, and that I
will not, knowingly, receive, directly or indirectly, any money or other valuable thing, for the
performance or nonperformance of any act or duty pertaining to my office, other than the
compensation allowed by law; I further swear (or affirm) that I will faithfully discharge my
duties as ......... to the best of my ability.

253. The January 16 2019, The current Oath of Office for, Judge
Charles Steven Kessinger, wherein the “and defend” (AND) is changed to “or defend”

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 (OR) Further the (I) “I will not” is changed to (THEY) “they will not”, in a
Misrepresentation of Oath of Office as follow:

254. The January 16 2019, to current Oath of Office for, Judge Lori Lynn Jackson,
wherein the “and defend” (AND) is changed to “or defend” (OR) Further the (I) “I
will not” is changed to (THEY) “they will not”, in a Misrepresentation of Oath of
Office as follow:

49
255. The facts on the record support this allegation. A state court
judge has no absolute immunity for his or her actions, if they were not judicial or taken
in the complete absence of all jurisdictions. Mireles v. Waco, 502 U.S. 9, 112 Sect.
286, 116 L.Ed.2d 9

256. Any such officer or member of the legislature who shall refuse to take the oath
herein prescribed, shall forfeit his office, and any person who shall be convicted of
having sworn falsely to, or of violating his said oath shall forfeit his office, and
thereafter be disqualified from holding any office of profit or trust in this state unless

50
 he shall have been restored to civil rights.

257. Exact form of oath to be taken by executive and judicial

officers and members of Legislature as prescribed

258. ART. XV, § 2'S FORFEITURE-OF-OFFICE CLAUSE

TARGETS SOLELY FAILURE TO TAKE THE CONSTITUTIONAL OATH
REQUIRED OF ALL PUBLIC OFFICERS Shall a Constitutional Amendment providing
for the form of oath of office to be taken and subscribed to by all public officers of
Oklahoma, be approved by the people, relief may be raised as an issue at any stage of the
judicial process by any party or by the court sua sponte

259. Plaintiff was denied by the Defendants, willfully and under

the color of law, the protectable property interest and of a process that was owed to
him, the fundamental requirement of due process is “the opportunity to be heard at a
meaningful time and in a meaningful manner violation of procedural due process
rights deprived of a constitutionally protected interest in life, liberty or property,”

260. No citizen of this state shall be taken or imprisoned, or be

disseised of his or her freehold or liberties or free customs, or outlawed or exiled or
condemned, or otherwise destroyed, but by lawful judgment of his or her peers, or by
due process of law." “No person, of what estate or condition soever, shall be taken or
imprisoned, or disinherited, or put to death -without being brought to answer by due
process of law

261. No person shall be put out of his or her franchise or freehold,

or lose his or her life or limb, or goods and chattels, unless he or she be duly brought
to answer. and be forejudged of the same by due course of law, and if anything be
done contrary to the same it shall be void in law, and holden for none."

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262. Stated in the 5th Amendment to the Federal Constitution,
1789, in the simple declaration that "no person shall be deprived of life, liberty, or
property without due process of law;

263. “No duty rests more imperatively upon the courts than the
enforcement of those constitutional provisions intended to secure that equality of
rights which is the foundation of free government."

Count I
42 U.S.C. § 1983: False Arrest

264. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

265. As described in the preceding paragraphs, the Defendants, Lori Jackson, Greg
Pollard, Steven Kissinger, Shannon Smith, Candice Irby, Steve Williams, John
Christian, Michael Walker, William Hayden, Matt Haley, Arnold Scott, Sonya
Chronsiter, Derek Stewart, Gary Brooks, Alvin D Files and Todd Young, deprived the
Plaintiff of a right secured by the Constitution and laws of the United States and
defendant’s acted under color of law, unlawfully detained and falsely arrested Plaintiff
without legal justification or probable cause.

266. Defendants knew that Plaintiff had not committed any crimes and still continued
to effectuate the arrest, detention, and prosecution of Plaintiff for the charge.

267. The misconduct described in this Count was undertaken with malice, willfulness,
and reckless indifference to the rights of Plaintiff.

268. The misconduct described in this Count was objectively unreasonable and was
undertaken intentionally with willful indifference to Plaintiff’s constitutional rights,

52
 specifically the First, Fourth and Fourteenth Amendments to the United States
Constitution, and hence 42 U.S.C. § 1983.

269. As a result of the unjustified violation of Plaintiff’s rights by the Defendant

Officers, Plaintiff has suffered injury, including emotional distress.

i. Count II
42 U.S.C. § 1983: Excessive Force

270. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein

271. As described in the preceding paragraphs, the Defendants, Shannon Smith, Steve
Williams, John Christian, Michael Walker, William Hayden, Matt Haley, Arnold
Scott, Derek Stewart, Gary Brooks, Alvin D Files and Todd Young, deprived the
Plaintiff of a right secured by the Constitution and laws of the United States and
defendant’s acted under color of law, Unlawfully detained and falsely arrested
Plaintiff without legal justification or probable cause. Unjustified and excessive use of
force, Plaintiff suffered pain and injury, as well as emotional distress.

272. This conduct violated the Fourth and Fourteenth Amendments to the United
States Constitution, and hence 42 U.S.C. § 1983.

273. The misconduct described in this Count was objectively unreasonable and was
undertaken intentionally with malice, willfulness, and reckless indifference to
Plaintiff’s constitutional rights.

274. The aforementioned actions of the Defendant’s were the direct and proximate
cause of the constitutional violations, and the attendant injuries resulting there from, as
set forth above.

53
275. As a result of the Defendant’s unjustified and excessive use of force Plaintiff has,
as a direct and proximate cause, suffered pain and injury, including emotional distress.

Count III
42 U.S.C. § 1983: Due Process
VIOLATION OF OKLAHOMA CONSTITUTION SECTION II-7

276. Each of the paragraphs of this Complaint is incorporated as if fully restated herein

277. Defendants, Lori Jackson, Greg Pollard, Steven Kissinger, Shannon Smith,
Candice Irby, John Christian, Michael Walker, William Hayden, Matt Haley, Arnold
Scott, Sonya Chronsiter, Derek Stewart, Alvin D Files and Todd Young, deliberately
destroyed, hid, and/or prevented the creation of impeaching and exculpatory evidence,
deprived the Plaintiff of a right secured by the Constitution and laws of the United
States and defendant’s acted under color of law, Specifically:

a. Destroyed Evidence, Court Record, Video Records, and 911 audio

b. Failed to audio record any part of their encounter with Plaintiff despite being

c. asked by the Plaintiff on several requests and while equipped with such devices

d. Destroyed, carried off and hid evidence from Plaintiff’s home

e. Falsely entered records throughout the criminal proceedings regarding the

aforementioned matters.

278. In depriving Plaintiff of these rights, Defendants committed these unlawful

violations under color of state law in bad faith and with malicious purpose in reckless,
wanton, and willful disregard of Plaintiffs’ human, safety, and property rights. 27. This
deprivation under color of state law is actionable under and may be redressed by 42
U.S.C. §1983.

279. In the manner described above, Defendant’s deprived Plaintiff of Due Process
in violation of the 5th and 14th Amendments to the United States Constitution. Also

280. A Father enjoys the right to associate with his children which is guaranteed by
this First Amendment as incorporated in Amendment 14, which is embodied in the

54
 concept of "liberty" in the Due Process Clause of the 14th Amendment and Equal
Protection Clause of the 14th Amendment.

281. Defendant’s actions set forth above were so arbitrary as to shock the
conscience.

282. Such violations of Plaintiff’s rights were undertaken intentionally, with malice
and willful indifference to Plaintiff’s rights.

283. As a result of the above-described wrongful conduct, Plaintiff has suffered

pain and injury, as well as emotional distress.
284. The misconduct alleged in this Count was undertaken while the Defendant’s
were acting within the scope of their office.
285. Plaintiff was denied Procedural due process; Substantive due process, due
process rights, malicious intention to cause a deprivation of constitutional rights and
other injuries intentionally by the defendants in their government actions that threaten
the denial of life, liberty, or property in the color of law, the misconduct described in
this Count was undertaken with malice, willfulness, and reckless indifference to the
rights of the Plaintiff.

i. Count IV
State Law Claim: False Imprisonment

286. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.
287. Plaintiff was imprisoned by the Defendants, Lori Jackson, Greg Pollard, Steven
Kissinger, Shannon Smith, Candice Irby, Steve Williams, John Christian, Michael
Walker, Matt Haley, Arnold Scott, Sonya Chronsiter, Derek Stewart, Gary Brooks,
Alvin D Files and Todd Young, deprived the Plaintiff of a right secured by the
Constitution and laws of the United States and defendant’s acted under color of law
and thereby had his liberty to move about unlawfully restrained, despite the
Defendant’s knowledge that there was no probable cause for doing so.
288. The actions of the Defendant’s were undertaken intentionally, with malice and

55
 reckless indifference to Plaintiff’s rights.

289. As a result of the wrongful infringement of Plaintiff’s rights, Plaintiff has, as a

direct and proximate cause, suffered injury, including emotional distress.

290. As described above, the Defendant’s conduct was undertaken within the scope of
their office such that their employer is liable for their actions.

i. Count V
42 U.S.C. § 1983: Conspiracy to Commit Constitutional Violations

291. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

292. As discussed in greater detail above, the Defendants deprived the Plaintiff of a
right secured by the Constitution and laws of the United States and defendant’s acted
under color of law, conspired with each other to cause damage to the Plaintiff by:

a. Agreeing not to report each other after witnessing and/or using excessive force
relative to the Plaintiff;

b. Agreeing not to generate reports documenting their conduct to cover-up their

own and each other’s misconduct;

c. Agreeing to generate reports and other documents which omitted material facts
relating to the arrest and containing patent falsities;

d. Agreeing to falsely charge criminal proceedings; and

e. Agreeing to hide, destroy, and/or prevent the creation of evidence of the

Constitutional violations described above and, including, stopping the video
camera recording equipment during the stop; changing the record of the court,
self enrichment and taking of Plaintiffs property, turning off/disabling all audio
recording equipment; and agreeing to generate reports which falsely indicated
that no video recording existed in order to cover up the above mentioned
misconduct.

293. The aforementioned actions of the Defendant’s were the direct and proximate

56
 cause of the violations of the United States Constitution discussed above, and to the
bill of rights, and the attendant injury and emotional distress resulting therefore.

i. Count VI
42 U.S.C. § 1983: Failure to Intervene

294. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

295. As described more fully above, the Defendants, Lori Jackson, John Christian,
Steven Kissinger, Greg Pollard, Shannon Smith, Candice Irby, Steve Williams,
Michael Walker, William Hayden, Matt Haley, Arnold Scott, Sonya Chronsiter, Derek
Stewart, Gary Brooks, Alvin D Files and Todd Young, deprived the Plaintiff of a right
secured by the Constitution and laws of the United States and defendant’s acted under
color of law, Defendants had a reasonable opportunity to prevent the violations of
Plaintiff’s constitutional rights as set forth above.

296. As a result of the Defendant’s failure to intervene, Plaintiff suffered pain and
injury, damages as well as emotional distress.

297. The Defendants’ actions were undertaken intentionally with malice and reckless
indifference to Plaintiff’s rights.

298. The misconduct described in this Count was undertaken by the Defendant’s
within the scope of their employment and under color of law.

i. Count VII
State Law Claim: Malicious Prosecution

299. Each of the paragraphs of this Complaint is incorporated

as if fully restated herein.

300. As described more fully above, the Defendants, Lori Jackson, John Christian,
Steven Kessinger, Greg Pollard, Shannon Smith, Candice Irby, Steve Williams,

57
 Michael Walker, Sonya Chronsiter and Alvin D Files, deprived the Plaintiff of a right
secured by the Oklahoma Constitution and laws of the United States and defendant’s
acted under color of law commenced, caused to be commenced, and/or continued a
criminal proceeding against Plaintiff for which Defendant’s knew there was no
probable cause, and the criminal proceeding terminated in Plaintiff’s favor in a manner
indicative of innocence.

301. The Defendant’s actions were undertaken intentionally, with malice and
reckless indifference to the rights of others—specifically, the Plaintiff’s.

302. The Defendant’s accused Plaintiff of criminal activity knowing those

accusations to be without probable cause, and they made written and other statements
with the intent of exerting influence to institute and continue judicial proceedings.

303. Statements and reports of the Defendant’s regarding Plaintiff’s alleged criminal
culpability were made with knowledge that the statements were false.
304. 281. As a result of the Defendant’s malicious prosecution, Plaintiff has
suffered, as a direct and proximate cause, injury, including emotional distress.

i. Count VIII
State Law Claim: Assault and Battery

305. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.
306. As described more fully in the preceding paragraphs, the Defendant’s John
Christian, Shannon Smith, Steve Williams, Michael Walker, William Hayden, Matt
Haley, Arnold Scott, Derek Stewart, Gary Brooks, Alvin D Files and Todd Young,
deprived the Plaintiff of a right secured by the Constitution and laws of the United
States and defendant’s acted under color of law used unnecessary and unreasonable
force against Plaintiff, which included harmful and offensive touching.

307. At that time, Plaintiff had a reasonable apprehension that he was in considerable
danger and would be subjected to great bodily harm.

308. The misconduct described in this Count was undertaken with malice, willfulness,

58
 and reckless indifference to the rights of others—specifically, the Plaintiff.

309. As described in the preceding paragraphs, the conduct of the Defendant’s acting
under color of law and within the scope of their employment, was undertaken willfully
and wantonly, proximately causing Plaintiff’s injuries.

i. Count IX
ii. State Law Claim: Intentional Infliction of Emotional Distress

310. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

311. In the manner described more fully above, the Defendants, Lori Jackson, Greg
Pollard, Steven Kessinger, Shannon Smith, Candice Irby, Steve Williams, John
Christian, Michael Walker, William Hayden, Matt Haley, Arnold Scott, Sonya
Chronsiter, Derek Stewart, Gary Brooks, Alvin D Files and Todd Young deprived the
Plaintiff of a right secured by the State and Federal Constitution and laws of the
United States and defendant’s acted under color of law engaged in extreme and
outrageous conduct, including, but not limited to:

a. Threatening to shoot Plaintiff while pointing weapons at him without any

reasonable justification;
b. Putting extremely tight handcuffs on that were not properly locked so that they
continually got tighter and caused more and more pain and discomfort;

c. Refused numerous requests by Plaintiff to loosen them or use two sets of

handcuffs;
d. Held Plaintiff in custody for months walked by his cell and laughed.
e. Jackson took custody of Plaintiff’s Sons away and kept Plaintiff from having a
relationship with them

312. The Defendants intended that their conduct would cause severe emotional
distress to the Plaintiff and knew that there was a high probability that their conduct

59
 would cause severe emotional distress to the Plaintiff.

313. The misconduct described in this Count was undertaken with malice, willfulness,
and reckless indifference to the rights of others.

314. As a proximate result of this misconduct, Plaintiff suffered injuries, including

but not limited to severe emotional distress.

i. Count X
State Law Claim: Respondent Superior

315. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

316. In committing the acts alleged in the preceding paragraphs, the Defendant
Officers were acting as members and agents of the PCSO and SCSO deprived the
Plaintiff of a right secured by the Constitution and laws of the United States and
defendant’s acted under color of law, at all relevant times during their employment.

317. Defendant Pontotoc County Sheriff’s Office and Seminole County Sheriff’s
Office is liable as principal for all torts committed by its agents when acting as its
agent.

i. Count XI
State Law Claim: Indemnification

318. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

319. Oklahoma law provides that public entities are directed to pay any tort judgment
for compensatory damages for which employees are liable within the scope of their
employment activities.

320. The Defendant Officers are employees of the PONTOTOC COUNTY

SHERIFFS OFFICE AND SEMINOLE COUNTY SHERIFFS OFFICE, who acted

60
 within the scope of their employment in committing the misconduct described herein.

COUNT XIII: 42 U.S.C. § 1983

(CLAIM RECKLESS INDIFFERENCE TO PLAIFFS’ CLEARLY ESTABLISHED

CONSTITUTIONAL RIGHTS)

321. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

322. As described more fully above, the Defendants, Lori Jackson, John Christian,
Steven Kissinger, Greg Pollard, Shannon Smith, Candice Irby, Steve Williams,
Michael Walker, William Hayden, Matt Haley, Arnold Scott, Sonya Chronsiter, Derek
Stewart, Gary Brooks, Alvin D Files and Todd Young, deprived the Plaintiff of a right
secured by the Constitution and laws of the United States and defendant’s acted under
color of law, Defendants had a reasonable opportunity to prevent the violations of
Plaintiff’s constitutional rights as set forth above.

323. As a result of the Defendant’s Indifference to Plaintiff’s Constitutional rights,

Plaintiff suffered pain and injury, damages as well as emotional distress.

324. The Defendants’ actions were undertaken intentionally with malice and reckless
indifference to Plaintiff’s rights.

325. The misconduct described in this Count was undertaken by the Defendant’s
within the scope of their employment and under color of law.

COUNT XIV

(Fraud)

326. Each of the paragraphs of this Complaint is incorporated as if fully restated herein

Alvin D Files, John Christian, Lori Jackson, Chance David Branscum, Andrew Duane Gibson
and without right or permission from Plaintiff, made false statements and misrepresentations
under the color of law

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As the intended, direct and proximate result thereof, Plaintiff was harmed, and

continue to suffer harm, for which OHB, Vision Bank, Alvin D Files, John Christian, Lori
Jackson, Steven Kessinger, Cary Michael Jackson, Chance David Branscum, James Robert
Hamby, Brandon Lee Tilley, Andrew Duane Gibson and Brandon Wayne Smith are liable.

Plaintiff has been damaged by defendants’ fraudulent representations and

conduct in an amount in excess of ($4,155,000,) to be determined at trial.

As a result of the Defendant’s Indifference to Plaintiff’s Constitutional rights, Plaintiff suffered

pain and injury, damages as well as emotional distress.

COUNT XV

(Breach of Fiduciary Duty)

327. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

OHB, Vision Bank, , James Robert Hamby, Brandon Lee Tilley without right or permission
from Plaintiff, under the color of law

Improperly exercised control over and converted for their own use the Plaintiffs Estate, private
land and property

Breached duty by taking under the color of law, Plaintiff’s property land and funds and
Plaintiff’s Estate to their own use.

OHB And Vision Bank breached the agreement with plaintiffs by failing to use the

funds provided in accordance with their agreement, failing to return the property, and instead
converting the funds and Plaintiff’s Estate to their own use.

Plaintiff continue to suffer harm, Plaintiff has been damaged as a consequence of OHB, Vision
Bank, James Robert Hamby, Brandon Lee Tilley

Breach of contract damaging Plaintiff in excess of ($4,155,000,) to be determined at trial.

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OHB and Vision Bank breached the fiduciary duty they owed to plaintiffs by

Failing and refusing to return the Estate and all property to Plaintiff, upon information and belief,

Converting Plaintiff’s Estate to their own use.

Plaintiff has been damaged by OHB and Vision Bank breach of the fiduciary duty they owed to
Plaintiff

As a result of the Defendant’s Indifference to Plaintiff’s Constitutional rights, Plaintiff suffered

pain and injury, damages as well as emotional distress.

COUNT XVI

(Breach of Contract)

328. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

OHB, Vision Bank, James Robert Hamby, Brandon Lee Tilley without right or permission from
Plaintiff, actions of WRONGFUL FORECLOSURE, CIVIL THEFT, TRESSPASS

Improperly exercised control over and converted for their own use the Plaintiffs Estate, private
land and property under the color of law

OHB And Vision Bank breached the agreement with plaintiffs by failing to use the

Converting Plaintiff’s property land and funds and Plaintiff’s Estate to their own use.

Plaintiff continue to suffer harm, Plaintiff has been damaged as a consequence of OHB, Vision
Bank, James Robert Hamby, Brandon Lee Tilley

Breach of contract in an amount in excess of ($4,155,000,) to be determined at trial.

The Defendants intended that their conduct would cause severe emotional distress to the Plaintiff
and knew that there was a high probability that their conduct would cause severe emotional
distress to the Plaintiff.

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 The misconduct described in this Count was undertaken with malice, willfulness, and reckless
indifference to the rights of others.

As a proximate result of this misconduct, Plaintiff suffered injuries, including but not limited to
severe emotional distress

As a result of the Defendant’s Indifference to Plaintiff’s Constitutional rights, Plaintiff suffered

pain and injury, damages as well as emotional distress.

COUNT XVII

(Conversion)

329. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

OHB, Vision Bank, Alvin D Files, John Christian, Lori Jackson, Steven Kessinger, Cary
Michael Jackson, Chance David Branscum, James Robert Hamby, Brandon Lee Tilley, Andrew
Duane Gibson and Brandon Wayne Smith without right or permission from Plaintiff,

By WRONGFUL FORECLOSURE, CIVIL THEFT, TRESSPASS and Fraud and under the
color of law, improperly exercised control over and converted Plaintiff’s Estate, 5262 County
Road 3565 Ada, Oklahoma Nineteen and a half acres of land and Plaintiffs Primary dwelling and
secondary structure for their own use the Plaintiffs Estate, private land and property

The Plaintiff is entitled to the immediate return all property with punitive damages and economic
damages of these funds.

Plaintiff continue to suffer harm, Plaintiff has been damaged in an amount in excess of
($4,155,000,)

Plaintiff’s company, Cactus Plumbing has been damaged in an amount in excess of ($9,414,000,)

The Defendants intended that their conduct would cause severe emotional distress to the Plaintiff
and knew that there was a high probability that their conduct would cause severe emotional
distress to the Plaintiff.

From a constructive trust for the benefit of Estate of Jacob Wayne Brauning

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 The misconduct described in this Count was undertaken with malice, willfulness, and reckless
indifference to the rights of others.

As a result of the Defendant’s Indifference to Plaintiff’s Constitutional rights, Plaintiff suffered

pain and injury, damages as well as emotional distress.

COUNT XVIII

(Unjust Enrichment)

330. Each of the paragraphs of this Complaint is incorporated as if fully restated

herein.

OHB, Vision Bank, Alvin D Files, John Christian, Lori Jackson, Steven Kessinger, Cary Michael
Jackson, Chance David Branscum, James Robert Hamby, Brandon Lee Tilley, Andrew Duane
Gibson and Brandon Wayne Smith without right or permission from Plaintiff, under the color of
law, have been unjustly enriched by the amounts they converted and have refused and failed to
return.

Defendants in equity and good conscience should pay to plaintiffs as a result of

Defendants’ willful unjust enrichment an amount in excess of ($4,155,000,) to be determined at

trial.

From a constructive trust for the benefit of Estate of Jacob Wayne Brauning

Plaintiff continues to suffer harm as a result of the Defendant’s Indifference to Plaintiff’s

Constitutional rights; Plaintiff suffered pain and injury, damages as well as emotional distress

PRAYERS FOR RELIEF

1. WHEREFORE, Plaintiff, Jacob Wayne Brauning pray that this Court:

2. Enter judgment in their favor and against the defendants on all Counts of the

3. Complaint; Plaintiffs Claims

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4. Return the Estate of Jacob Wayne Brauning to Plaintiff property at 5263 CR 3565 Ada,
Oklahoma 19.33 acres of land, 6,001 sq foot home and 30x40 shop

5. Award plaintiffs all damages they sustained as a result of defendants’ conduct

6. pursuant to Counts I - XVIII, including without limitation an amount equal to the

7. ($13,596,000) to plaintiff

8. Order that ($13,596,000) provided by defendants to Plaintiff be held in a

9. constructive trust pending return to plaintiff;

10. Award plaintiff lost wages, earnings, their attorneys’ fees, costs and pre-and post-
judgment interest; and

11. Grant such further relief as this Court deems just and proper On Counts I - XVII, for
appropriate declaratory relief and for compensatory damages, in an amount to be
determined at trial, and for necessary
12. On Count XVII, judgment against the Defendants, punitive damages, injunctive relief to

13. restrain the Defendants from further unlawful conduct; an order requiring

14. disgorgement of unlawful gains obtained by the Defendants as a result of their

15. Unlawful conduct; restitution or other remedial relief Post-judgment relief to prohibit the
Defendants from violating 11 U.S.C. §§ 362.

16. Defendants Pay Sums due in Violations to Plaintiff’s Fee schedule rights violations
notice and demand serviced on Defendants May of 2019

17. For all other and further relief as the Court may deem just proper and equitable.

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 Jury Demand

1. Plaintiff, Jacob Wayne Brauning, hereby demands a trial by jury pursuant to Federal
Rule of Civil Procedure 38(b) on all issues so triable.

CERTIFICATION AND CLOSING

2. Under Federal Rule of Civil Procedure 11, by signing below, I certify to the best of my
knowledge, information, and belief that this complaint: (1) is not being presented for an
improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the
cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for
extending, modifying, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support
after a reasonable opportunity for further investigation or discovery; and (4) the
complaint otherwise complies with the requirements of Rule 11.

3. I agree to provide the Clerk’s Office with any changes to my address where case–related
papers may be served. I understand that my failure to keep a current address on file with
the Clerk’s Office may result in the dismissal of my case

___________________________
Jacob Wayne Brauning
Prose/Plaintiff

2700 N Kickapoo Ave

Private Mail # 155
Shawnee, Oklahoma 74804
[email protected]
(405) 458-8580

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