MISTER Jeff Griffin Served with Malpractice Lawsuit
(for masquerading as a mayor and breaking the Law)
GRIFFIN WALKING PAPERS!WALKING PAPERS!WALKING PAPERS!GRIFFIN
......."Clown" Case (finally) Ordered to Trial. Trial Date is 28 Sept, 2004.
...........................That is 5 Years After the Crime was Committed!
.....
Who is the Real Clown?
Jeff Griffin, masquerading as Reno's mayor, illegally ordered Sam Dehne removed from a Reno city council Public meeting, shouting: "Somebody get that clown out of here!".
This was not the first time Griffin had broken the Law of good honest open government.
The rest of that Reno City Council is also not without sin. On that fateful date of 22 June, 1999, they sat idly by and watched the Laws of America and Nevada and Reno (that they swore a Sacred Oath to obey and oversee) blatantly broken.
On 18 April, 2002 the $$$$taxpayer-funded, conflict of interest-infested Reno city hall attorneys (who are actually some of Defendants!!!) filed a bogus Motion for Summary Judgment (which is just "fancy" word for Motion to Dismiss)... hoping that they could find a judge who can't read... or who is naive enough to believe a pack of lies.
"Click" here to read Sam's Opposition to city hall's desperate Motion.
"Click" here to read the Federal Appeals Court UNANIMOUS (25 to zero) Order
Internet version: click
Note: It was Mister Griffin who "interrupted" the meeting.
run run runrun run run run run
.......................................Reno City Hall has really "boxed" itself in with this one.
Here's the Malpractice Suit (filed in Federal Court):
MARTIN G. CROWLEY
Nevada Bar No. 3049
JEFFREY A. DICKERSON
Nevada Bar No. 2690
Attorneys for Plaintiff
.........................................................UNITED STATES DISTRICT COURT
..................................................................DISTRICT OF NEVADA
........................................................Case No. CV-N-01-0376-RAM
..........................................................Federal Ninth Apppeals Court (03 - 15174)
"SAM" DENIS EDWARD DEHNE,
Lt Col, USAF, (ret) Sam Dehne, click here
Plaintiff,
................................................................................................COMPLAINT AND JURY DEMAND
vs.
CITY OF RENO, a municipal corporation,
JEFF GRIFFIN, individually,
Defendants
----------------------------------------/
Plaintiff, for his complaint against Defendants, complains and avers as follows:
1. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §1331 and 1367.
2. On June 22, 1999, Plaintiff was a citizen and attendee at a Reno City Council meeting regularly scheduled and agendized.
3. On June 22, 1999, at this Public Meeting, Plaintiff submitted a standard Reno Request to Speak form concerning an official Agenda item pertaining to televising of Reno Airport Authority Board of Trustees Meetings, thus clearly signifying his wish to speak freely on this matter of importance and of public concern.
4. When this agenda item came up for consideration, Defendant Griffin, who chaired the meeting, ignored Plaintiff's official Request to Speak form until Plaintiff pointed out in a wholly non-disruptive fashion from the chamber that he had a legal right to speak.
5. Defendant, rather than honoring the official Request to Speak form as a matter of standing custom and policy, said he was not inclined to allow Plaintiff to speak, asked the rest of the city council to "vote" on Plaintiff's Request to Speak.
6. Plaintiff approached the Reno city attorney and discreetly pointed out that Defendant was wrong and had perhaps overstepped the bounds established for his participation in matters relating to the Airport Authority. These bounds had been established for his participation in matters relating to the Airport Authority. These bounds had been established by the Ethics Commission, and this speech was thus on a matter of public concern. The city attorney then walked over and whispered something in the Defendant Griffin's ear, which, Plaintiff believes discovery will show, included these matters of public concern ~ denial of a citizen's right to speak, and to speak about the referenced matters of public concern. Defendant Griffin ordered the meeting into recess.
7. Plaintiff then, in non-disruptive fashion, pointed out that Defendant Griffin had no right to recess the meeting before honoring Plaintiff's official Request to Speak.
8. Defendant Griffin ordered Plaintiff removed from the meeting, stating: "Somebody get this clown out of here!" and "I want this guy out of here."
9. Upon reconvening of the Public Meeting, Defendant Griffin admitted that he had acted inappropriately in discussing the agendized item and withdrew.
.......................................FIRST CLAIM FOR RELIEF
10. Defendant Griffin, with the acquiescence and ratification of the City of Reno, through its City Council, acted to chill and censor the content of Plaintiff's speech on important public issues before a limited public forum with no reasonable justification for such restriction, subjecting him to liability under 42 U.S.C. §1983 for Plaintiff's damages based upon a violation of Plaintiff's First Amendment rights to Free Speech
and to Petition for redress of grievances.
11. Griffin acted pursuant to a custom of the City of Reno in that Plaintiff and others on other repeated occasions have suffered similar chill and censorship, including removal from said meetings.
12. Griffin acted pursuant to a policy of the City of Reno in that Griffin as Chair of City council meetings is the City's final policy maker in matters relating to the conduct of proceedings such as the one described hereinabove.
13. Griffin and the City of Reno are liable to Plaintiff pursuant to 42 U.S.C. §1983 for damages and equitable relief as follows:
For general damages including outrage, disappointment, otherwise unnecessary concern, anxiety, reasonable fear, aggravation of civil rights.
For declaratory judgment declaring Plaintiff's rights so violated.
For injunctive relief enjoining Defendants from such unconstitutional conduct in the future, and for training of those running public meetings in constitutional rights of members of the public, and
For punitive damages against Griffin only as he acted with clear malice and in deliberate indifference to Plaintiff's rights.
WHEREFORE, Plaintiff prays for judgment in his favor and against the Defendants jointly and severally as follows:
1. For general damages in sums to be proved at trial.
2. For special damages in sums to be proved at trial.
3. For punitive damages a substantial sum which will educate, punish and deter Griffin and others;
4. For declaratory relief and injunctive relief as set forth
5. Reasonable attorney's fees and costs of suit pursuant to statute,
including 42 U.S.C. §1988; and
6. For such other and further relief as the Court deems just and proper.
DATED this 21st day of June, 2001.
LAW OFFICE OF
JEFFREY A. DICKERSON
Signature
LAW OFFICE OF
MARTIN G. CROWLEY
Signature
Gimme More!Gimme More!Gimme More!
Jeffy "the Juggler" Griffin and his Council Clown Clones
Aren't Mister Griffin and Reno City Hall the real Clowns... with their never-ending juggling acts?
More on "The Clown Affair" (click)
And The Final Report to Appeals Court (click)