Bick Cayer
- Apr 16, 2020
- 45 min read

PART 1 ANSWER TO INTERROGATORIES

STATE OF MAINE SUPERIOR COURT

AROOSTOOK, ss. CIVIL DOCKET

Docket No.: CARSC-CV-2018-135

RICHARD CAYER and ANN CAYER,

Plaintiffs

v. PLAINTIFFS’ ANSWER TO

INTERROGATORIES

TOWN OF MADAWASKA,

Defendants

PLAINTIFFS, Richard Cayer and Ann Cayer, subject to the objections noted below, answers Defendants’ Interrogatories Propounded to Plaintiffs as follows:

INTERROGATORY NO. 1. Please state your name, address, social security number, date of birth, marital status and identify your present employer or employers.

ANSWER: Richard Cayer Ann Cayer

245 lakeshore Rd. 245 Lakeshore Rd.

Saint David, Maine 04773 Saint David Maine 04773

000-00-0000 000-00-0000

Date of birth-May 27,1945 Date of birth -January 21, 1947

Married 54 years Married 54 years

Retired 2007 Retired 2007

INTERROGATORY NO. 2. Please identify each of your employers for the last ten years, stating for each employer your employment position, salary or hourly wage, and reason for leaving your position.

ANSWER: Richard Cayer Ann Cayer

Richard and Ann Cayer have both been retired from Fraser Paper since 2007.

INTERROGATORY NO. 3.

Please state the highest-grade level of education that you achieved and identify all educational institutions you have attended (beginning with high school), stating for each institution your years of attendance, the nature of course of your studies, and any degrees, diplomas or certificates confirmed.

ANSWER: Richard and Ann Cayer both graduated grade 12 high school.

INTERROGATORY NO. 4. Please state all facts upon which you are relying to establish that Defendant Robert Ouellet violated your constitutional or civil rights for which you seek relief under 42 U.S.C. § 1983 or 5 M.R.S. §§ 4681 et seq., including a description of all actions taken by Defendant Ouellet or on Defendant Ouellet’s behalf that you contend violated your rights and an identification of the rights you claim were violated.

Rule 33 (a) of M.R.Civ.P. is clear, “[N]ot more than a total of 30 interrogatories may be served by a party on any other party. Each distinct subpart in an interrogatory shall be deemed a separate interrogatory for the purposes of this rule.”

Although attorney Wall's requests are intentionally unduly burdensome, greatly exceed the limit of 30 interrogatories by up to a possibility of 60 interrogatories, in clear violation of Rule 33, I have formulated a method to respond, and hope it is acceptable. The request is for “[A]ll facts…including a description of all actions taken by Defendant…and an identification of the rights you claim were violated.” The Town of Madawaska and its four (4) employees, Robert Ouellet, Christina Therrien, Don Chasse, and Vince Frallicciardi are identical, and because they all conspired to achieve the same results, for the same reasons, in the same cases, albeit, in different capacities, and at different times, we have formulated our response stating all facts, for the Town of Madawaska and it’s five employees, as a separate document. Please reference the numbers below stating the description of the specific violations corresponding to the 51page document named INTERROGATORY - Violation of Constitutional and Civil Rights Under 42 US.C. § 1983 M.R.S. §§ 4681et seq. and Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress, AND Negligent Infliction of Emotional Distress.

Interrogatory No. 4. Contains questions four (4) separate and distinct subparts/counts.

1. Count V. (Violation of Federal Civil Rights---42 U.S.C. § 1983)

2. Count VI. (Violation of Maine Civil Rights Act---5 M.R.S. §§ 4681) et seq,

Moreover, interrogatory No. 4 contains questions to two (2) separate and distinct subparts/counts, i.e. for two (2) separate and distinct code violations. One code violation is for the 2010 Rule 80K RV Enforcement Action, and the other is for the 2014 80K building code Enforcement Action, therefore, the two code violations on different years, cannot logically be identical rights violations, and are deemed separate interrogatories for the purpose of this rule.

3. 2010 Rule 80K Enforcement Action.

4. 2014 Rule 80K Enforcement Action.

2010 Rule 80K RV Enforcement Action

ANSWER: Defendants Robert Ouellet, Town manager, Christina Therrien, Don Chasse, and Vince Frallicciardi all assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 and 2014 Rule 80K enforcement actions) against us without probable cause and without reasonable grounds for action. Because these intentional acts by the Town and its employees proved to be meritless and without probable cause they should not, and cannot, be legally identified as an “Enforcement action.” These were clearly “intentional acts,” “in bad faith,” to punish us for our petitioning activities, and for taking part in our local government.

Defendant Ouellet continued in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based.

Defendant Ouellet assisted in initiating and/or using court documents and/or court processes in prosecuting the 2010 80K enforcement action against us in a manner that was not proper in the regular conduct of proceedings with a motive to injure and/or delay us.

Defendant Ouellet’s actions above were an intentional action taken under color of law which Defendant Ouellet knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law.

Defendant Ouellet’s actions constitute intentional actions taken under color of law which Defendant Ouellet knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities.

Defendant Ouellet’s actions were undertaken for the purposes of intimidating, coercing, and/or punishing us so that we would not exercise our rights to speak/and or report of Defendant Ouellet’s wrongful and illegal activities.

Defendant Ouellet engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us.

Defendant Ouellet’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable.

Defendant Ouellet acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Ouellet knew that we were the landowners and not the violators.

Defendant Ouellet knew we asserted at the June 29, 2010 meeting that we would have the tenants remove their RV, which was done on a timely schedule preventing any Legal Action pursuant to 16.I.(3) of the SZO without a Hearing.

Defendant Ouellet proceeded in this civil proceeding to punish us because we exercised our rights of public participation in town government.

Defendant Ouellet’s willful fraudulent claims under oath in the anti-SLAPP case were proven false when the case was dismissed with prejudice.

Defendant Ouellet intentionally filed and continued a 2010 Rule 80K enforcement (RV) Count I action against us with clear knowledge that the alleged violation was intentionally fraudulent. Moreover, Ouellet clearly knew and understood that after the August 09, 2012 Settlement Conference when Judge Daigle told him that RV’s are not Residential Dwelling units as described in the Madawaska SZO. Defendant Ouellet also knew that we were the landowners and not the violators. Defendant Ouellet proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government.

Defendant Ouellet intentionally and fraudulently filed Count II, creating a campground, with knowledge that this was false because Ouellet said at the June 29, 2010 board meeting “this cannot be a campground.” Attorney Currier was at that meeting and he (Currier) intentionally and fraudulently made those claims in the Maine Superior Court, and the Maine Supreme Court.

The Town and its employees, defendant Ouellet, and attorneys Richard Currier and Jon Plourde, willfully and fraudulently defended both counts in the anti-SLAPP case before the Maine Supreme Court. The dismissal with prejudice is dispositive proof that they all (6 defendants) willfully committed fraud on the Maine Courts. In our tort filing we supply a separate document headed as MOTIVE. Although this lawsuit is in regards to actions by the Town and its employees that fraudulently began as code enforcement actions that we have proven to be false, we intend to prove that those actions were actually fraudulent intentional acts in bad faith, meant to punish us for our public participation in local town politics. The Motive document exposes what the Town and its employees did this to us, and why they did it. These intentional act in bad faith by the Town and its employees did not start in June of 2010, it began in 1988 when we bought the Campground, and escalated from there. Please go to ourcivilrights.me for more information.

The Maine Supreme Court decision in our 2010 RV Special Motion to Dismiss is arbitrary, Capricious, and not in accordance with law. If this Supreme Court decision, based on the willful fraudulent claims made under oath by the Town and its attorneys, is not reviewed and overturned with appropriate sanctions applied, the Maine Supreme Court should accept full liable for its defamatory decisions and statements, on the Supreme court website.

INTERROGATORY NO. 4.

ANSWER: Included below are all facts and description of all actions taken by Defendant Ouellet or on Defendant Ouellet’s behalf that we contend constitute the bases for those torts. Please reference the numbers below stating the description of the specific violations corresponding to the 51page document named INTERROGATORY - Violation of Constitutional and Civil Rights Under 42 US.C. § 1983 M.R.S. §§ 4681et seq. and Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress, AND Negligent Infliction of Emotional Distress.

No.8, Due Process, Equal Protection, ----No.10. Due Process, Equal Protection ----No.11. Due Process, Equal Protection ----No.12. Due Process, Equal Protection ---No.13 Due Process, Equal Protection ----No.14 Due Process, Equal Protection---- No.15 Due Process, Equal Protection---- No.19 Due Process, Equal Protection ----No.21 Due Process, Equal Protection ---- No.26 Due Process, Equal Protection---- No.29 Due Process, Equal Protection---- No.30 Due Process, Equal Protection ----No.31 Due Process, Equal Protection ----No.32 Due Process, Equal Protection No.34---- Due Process, Equal Protection---- No.35 Due Process, Equal Protection ----No.36 Due Process, Equal Protection---- No.37 Due Process, Equal Protection--- No.38 Due Process, Equal Protection---- No.40 Due Process, Equal Protection---- No.41 Due Process, Equal Protection ----No.42 Due Process, Equal Protection ----No.43 Due Process, Equal Protection ----No.44 Due Process, Equal Protection ----No.45 Due Process, Equal Protection---- No.46 Due Process, Equal Protection ----No.47 Due Process, Equal Protection---- No.48 Due Process, Equal Protection--- No.50 Due Process, Equal Protection---- No.51 Due Process, Equal Protection---- No.52 Due Process, Equal Protection---- No.53 Extortion, Abuse of Process, Equal Protection, Due Process, ----No.54. Due Process, Equal Protection, ---- No.60 Due Process, Equal Protection---- No.61. Due Process, Equal Protection---- No. 64 Due Process, Equal Protection ---No.65. Due Process, Equal Protection ----No.66 Due Process, Equal Protection No. 71. ---Due Process, Equal Protection ---No.74. Due Process, Equal Protection ---No.80. Due Process, Equal Protection ---No. 84. Due Process, Equal Protection ----No. 85. Due Process, Equal Protection---- No.89. Due Process, Equal Protection---- No. Due Process, Equal Protection ---No.90 Due Process, Equal Protection---- No.91.Violation M.R.S.A. Title 14 § 556--- No.93 No. 92. Violation M.R.S.A. Title 14 § 556--- No.93 Violation M.R.S.A. Title 14 § 556---- No.95. Violation M.R.S.A. Title 14 § 556---- No.97. Violation M.R.S.A. Title 14 § 556---- No.98. Violation M.R.S.A. Title 14 § 556 and Due Process, Equal Protection---- No.100. Due Process, Equal Protection---- No.101. Due Process, Equal Protection---- No.102 Due Process, Equal Protection---- No.107. Due Process, Equal Protection---- No.108. Due Process, Equal Protection---- No.110 Due Process, Equal Protection---- No.113. Violation M.R.S.A. Title 14 § 556--- No.115 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.117 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection --No.118 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.119 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.120 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.121 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.125 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.126 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.127.Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.128.Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No.129 Due Process, Equal Protection ---No.130. Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ----No.134 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.135 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.136 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection-- No.140. Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.142 Due Process, Equal Protection--- No.144 Due Process, Equal Protection--- No.146 Due Process, Equal Protection--- No.148 Due Process, Equal Protection--- No.153 Due Process, Equal Protection

2014 Rule 80K enforcement action (Building Violation)

ANSWER: Defendant Robert Ouellet, assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 and 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action. Because this intentional act by the Town and its employees proved to be meritless and without probable cause it should not, and cannot, be legally identified as an “Enforcement action.” It was an intentional act in bad faith to punish us for our petitioning activities, and for taking part in our local government.

Defendant Robert Ouellet assisted in initiating, procuring and/or continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action.

Defendant Ouellet proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based.

Defendant Ouellet assisted in initiating and/or using court documents and/or court processes in prosecuting the 2014 Rule 80K enforcement action against us in a manner that was not proper in the regular conduct of the proceeding with the motive to injure and/or delay us.

Defendant Ouellet engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us.

Defendant Ouellet’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable.

Defendant Ouellet acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Ouellet intentionally and fraudulently filed a meritless complaint and lawsuit with an illegal permanent Stop Work order in violation of our Due Process rights pursuant to the SZO 16. I. (3) because our permits were vested. Defendant Ouellet proceeded in this civil proceeding to punish us, because we exercised our rights to public participation in town government. See: MOTIVE

Defendant Ouellet continued support of the willful fraudulent claims made under oath by him, and others, in the anti-SLAPP case that were proven false when the case was dismissed with prejudice.

For many years, defendant Ouellet’s willful illegal actions, (intentional acts in bad faith) have caused Ann and I serious emotional distress, harmful to our health, were intentionally undertaken to punish us. Although there is no test or measure for the stress and harm done to our lives, our health, finances, or our reputations, one can only imagine what we have been through. We did not keep notes or records on how many sleepless nights, or doctors’ visits claiming that we just did not feel right. Ask yourselves how you would feel, knowing that someone with the power to do such a deprived act, if they would do this to your loved ones, as was done to Ann, my loved one?

Below are all facts and description of all actions for Interrogatory #4: Lot 468 building violations.

No.160 Due Process, Equal Protection--- No.161 Due Process, Equal Protection--- No.162 Due Process, Equal Protection ---No.163 Due Process, Equal Protection ---No.168 Due Process, Equal Protection ---No.170 Due Process, Equal Protection--- No.174 Due Process, Equal Protection--- No.175 Due Process, Equal Protection--- No.179. Due Process, Equal Protection No.180 Due Process, Equal Protection--- No.182 Due Process, Equal Protection No.183 Due Process, Equal Protection--- No.184 Due Process, Equal Protection--- No.188 Due Process, Equal Protection--- No.195 Due Process, Equal Protection--- No.196 Due Process, Equal Protection--- No.204 Due Process, Equal Protection--- No.205 Due Process, Equal Protection--- No.206 Due Process, Equal Protection--- No.207 Due Process, Equal Protection--- No.208 Due Process, Equal Protection--- No.214 Due Process, Equal Protection--- No.215. Article I the right to petition Government--- No.216 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT. --- No.217. VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT--- No. 218 Article I Section II Power inherent in People. --- No. 219 Article I Section II Power inherent in People. --- No. 220 Article I Section II Power inherent in People. ---No. 221 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT Article I Section II Power inherent in People. --- No. 222 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT Article I Section II Power inherent in People. ---No. 223 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT Article I Section II Power inherent in People. --- No. 225 Due Process, Equal Protection No. 226 Due Process, Equal Protection ---No. 227 Due Process, Equal Protection ---No. 228 Due Process, Equal Protection ---No. 229 Due Process, Equal Protection ---No. 231. Due Process, Equal Protection--- No. 232. Due Process, Equal Protection--- No. 237. Due Process, Equal Protection ---No. 240. Due Process, Equal Protection--- No. 243. Due Process, Equal Protection ---No. 244. Due Process, Equal Protection ---No. 247. Due Process, Equal Protection ---No. 248 Due Process, Equal Protection--- No. 249 Due Process, Equal Protection ---No. 252 Due Process, Equal Protection ---No. 254 Due Process, Equal Protection ---No.258 Due Process, Equal Protection ---No. 259 Due Process, Equal Protection ---No. 260 Due Process, Equal Protection--- No. 265 Due Process, Equal Protection--- No. 266Due Process, Equal Protection--- No. 267 Due Process, Equal Protection ---No. 268 Due Process, Equal Protection--- No. 269 Due Process, Equal Protection ---No. 271 Due Process, Equal Protection ---No. 272 Due Process, Equal Protection ---No. 273 Due Process, Equal Protection ---No. 275 Due Process, Equal Protection--- No. 276 Due Process, Equal Protection ---No. 278 Due Process, Equal Protection ---No. 279 Due Process, Equal Protection--- No. 280 Due Process, Equal Protection ---No. 283 Due Process, Equal Protection ---No. 287 Due Process, Equal Protection ---No. 288 Due Process, Equal Protection ---No. 289 Due Process, Equal Protection ---No. 290 Due Process, Equal Protection ---No. 291 Due Process, Equal Protection ---No. 292 Due Process, Equal Protection--- No. 293 Due Process, Equal Protection ---No. 294 Due Process, Equal Protection--- No. 292 Due Process, Equal Protection--- No. 296 Due Process, Equal Protection ---No. 297 Due Process, Equal Protection---- No. 298 Due Process, Equal Protection ---No. 299 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 300 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 302 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 304 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 305 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 227 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 306 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 307 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 308 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 309 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 311 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 312 Due Process, Equal Protection M.R.S.A. Title 14 § 556 violation ---No. 313 Due Process, Equal Protection Violation--- No. 314 Due Process, Equal Protection Violation--- No. 316 Due Process, Equal Protection Violation--- No. 319 Due Process, Equal Protection Violation ---No. 320 Due Process, Equal Protection Violation--- No. 322 Due Process, Equal Protection Violation ----No. 323 Due Process, Equal Protection Violation--- No. 324 Due Process, Equal Protection Violation--- No. 326 Due Process, Equal Protection Violation--- No. 312 Due Process, Equal Protection Violation--- No. 328 Due Process, Equal Protection Violation ---No. 329 Due Process, Equal Protection Violation ---No. 333 Due Process, Equal Protection Violation ---No. 312 Due Process, Equal Protection Violation ---No. 334 Due Process, Equal Protection Violation ---No. 336 Due Process, Equal Protection Violation. INTERROGATORY NO. 5. Please state all facts upon which you are relying to establish that Defendant Robert Ouellet should be held liable for wrongful use of civil process, abuse of process, intentional infliction of emotional distress, or negligent infliction of emotional distress, including a description of all actions taken by Defendant Ouellet or on Defendant Ouellet’s behalf that you contend constitute the basis for those torts. ANSWER: Defendant Robert Ouellet, assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 and 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action. Because this intentional act by the Town and its employees proved to be meritless and without probable cause it should not, and cannot, be legally identified as an “Enforcement action.” It was an intentional act in bad faith to punish us for our petitioning activities, and for taking part in our local government. Defendant Robert Ouellet assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 Rule 80K enforcement action) against us without probable cause, and without reasonable grounds for action. Defendant Ouellet proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based. Defendant Ouellet assisted in initiating, procuring, and/or continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for the action. Defendant Ouellet proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based. Defendant Ouellet assisted in initiating and/or using court documents and/or court processes in prosecuting the 2010 80K enforcement action against us in a manner that was not proper in the regular conduct of proceedings with a motive to injure and/or delay us. Defendant Ouellet assisted in initiating and/or using court documents and/or court processes in prosecuting the 2014 Rule 80K enforcement action against us in a manner that was not proper in the regular conduct of the proceeding with the motive to injure and/or delay us. Defendant Ouellet’s actions above were an intentional action taken under color of law which Defendant Ouellet knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law. Defendant Ouellet’s actions constitute intentional actions taken under color of law which Defendant Ouellet knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities. Defendant Ouellet’s actions were undertaken for the purposes of intimidating, coercing, and/or punishing us so that we would not exercise our rights to speak/and or report of Defendant Ouellet’s wrongful and illegal activities. Defendant Ouellet engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us. Defendant Ouellet’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable. Defendant Ouellet acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint. INTERROGATORY NO. 5. Contains eight (8) distinct subparts/counts. 1. Count I. Wrongful use of Civil PROCEEDINGS, 2010 Rule 80K Enforcement Action. 2. Count II. Wrongful use of Civil PROCEEDINGS, 2014 Rule 80K Enforcement Action. 3. Count III. Abuse of Process—2010, Rule 80K Enforcement Action. 4. Count IV. Abuse of Process—2014, Rule 80K Enforcement Action. 5. Count VII. Intentional Infliction of Emotional Distress. 2010, Rule 80K Enforcement Action. 6. Count VIII. Negligent Infliction of Emotional Distress. 2010, Rule 80K Enforcement Action. 7. Count VII. Intentional Infliction of Emotional Distress. 2014, Rule 80K Enforcement Action. 8. Count VIII. Negligent Infliction of Emotional Distress. 2014, Rule 80K Enforcement Action. RV 2010 ENFORCEMENT ACTION See: All Facts are provided in the 51page document named, INTERROGATORY - Violation of Constitutional and Civil Rights Under 42 US.C. § 1983 M.R.S. §§ 4681et seq. and Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress, AND Negligent Infliction of Emotional Distress. ANSWER: All Facts, and Description of all actions include: No. 5 Intentional Infliction of Emotional Distress. –No.8 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress. ---No.9. Abuse of Process Intentional Infliction of Emotional Distress. ---No.15,19,22, Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress—No.29 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.30 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress----No.31 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.32 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.33 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress ---No.34 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress. ----No. 35 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.51 Abuse of Process, Intentional Infliction of Emotional Distress. ---No. 52. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.53. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.56 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. 63 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.65 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. 66,67,68,69,70,71, Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.76,77, Abuse of Process, ----No.81 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.82,83,84 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.90,91,93,97,98, Abuse of Process. ---No.102, Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.140,141,142,144, 145,146,147,148, 149,150,152, Abuse of Process (because the Town should have acknowledged their Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress, and settled.) We also blame the Court for this violation of Rights. LOT 468 BUILDING VIOLATIONS GENERAL ALLEGATIONS No. 160,161,162,163,164 Negligent Infliction of Emotional Distress, Intentional Infliction of Emotional Distress, ---No.168,170, Abuse of Process, Intentional Infliction of Emotional Distress---No.174,175,177.179.180.181.183.184. Abuse of Process, Intentional Infliction of Emotional Distress---No.188,190, Abuse of Process, Intentional Infliction of Emotional Distress---No.195, Abuse of Process, Intentional Infliction of Emotional Distress---No.205, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.206, 207, 208, 209,210,211, 212,213,214,215,216,217,218,222,223,224, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.225, 226,227,228,229231,232,233,234,Abuse of Process---No.235, 236, 237,239, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.243,244,245,246,248,249, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.252,254,255,256,257,258,259,260,261,262, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.264,265,266,267,268,269,270,271,272,273,275,276,277,278,279,280, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.284,285,286,287,288,289 Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress,---No.289,290,291, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.296,297,298, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.299,300,309,314,315 Abuse of Process, Intentional Infliction of Emotional Distress---No.320, Intentional Infliction of Emotional Distress---No.322,323, Abuse of Process, Intentional Infliction of Emotional Distress.---No. 334,336,337,339,341,343. Abuse of Process, Intentional Infliction of Emotional Distress. (because the Town should have acknowledged their Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress, and settled.) We also blame the Court for this violation of Rights. INTERROGATORY NO. 6. Please state all facts upon which you are relying to establish that Defendant Christina Therrien violated your constitutional or civil rights for which you seek relief under 42 U.S.C. § 1983 or 5 M.R.S. §§ 4681 et seq., including a description of all actions taken by Defendant Therrien or on Defendant Therrien’s behalf that you contend violated your rights and an identification of the rights you claim were violated. Interrogatory No. 6. Contains questions four (4) separate and distinct subparts/counts.

3. Count V. (Violation of Federal Civil Rights---42 U.S.C. § 1983)

4. Count VI. (Violation of Maine Civil Rights Act---5 M.R.S. §§ 4681) et seq,

Moreover, Interrogatory No. 6. contains questions to two (2) separate and distinct subparts/counts, i.e. for two (2) separate and distinct code violations. One code violation is for the 2010 Rule 80K RV Enforcement Action, and the other is for the 2014 80K building code Enforcement Action, therefore, the two code violations on different years, cannot logically be identical rights violations, and are deemed separate Interrogatories for the purpose of the Rule and these responses.

3. 2010 Rule 80K Enforcement Action.

4. 2014 Rule 80K Enforcement Action.

2010 Rule 80K RV Enforcement Action

ANSWER: Since she was hired in 2006, Town Manager Christina Therrien, has pursued an agenda of hate against us. She has defamed us, has been responsible for many illegal acts, denied us rights and privileges guaranteed by the Constitution of the United States of America and the Constitution of Maine. Her intentional acts in bad faith, for the 2010 RV violation, were successfully defended in the anti-SLAPP case before the Maine Supreme Court by attorneys Richard Currier and Jon Plourde, knew those statements were false and to be fraud on the courts. The dismissal with prejudice is dispositive proof that they all willfully committed fraud on the Maine Courts. In our tort filing we supply a separate document headed as MOTIVE. Although this lawsuit is in regards to actions by the Town and its employees which fraudulently began as code enforcement actions that we have proven to be false, we now intend to prove that those actions were actually fraudulent intentional acts in bad faith, meant to punish us for our public participation in local town politics. The Motive document exposes what the Town and its employees did this to us over a long period of many years, and why they did it. This intentional act in bad faith by the Town and its employees did not start in June of 2010, it began in 1988 when we bought the Campground, and escalated from there. Please go to ourcivilrights.me for more information.

Defendant Christina Therrien, assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 and 2014 Rule 80K enforcement actions) against us without probable cause and without reasonable grounds for action. Because this intentional act by the Town and its employees proved to be meritless and without probable cause it should not, and cannot, be legally identified as an “Enforcement action.” It was an Intentional Act in Bad Faith. This Intentional Act in Bad Faith was intended to punish us for our petitioning activities, and for taking part in our local government. There is no doubt that they have succeeded. They have ruined our lives.

Defendant Christina Therrien, assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010, and 2014, Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action.

Defendant Therrien proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based.

Defendant Therrien assisted in initiating and/or using court documents and/or court processes in prosecuting the 2010, and 2014, 80K enforcement action against us in a manner that was not proper in the regular conduct of proceedings with a motive to injure and/or delay us.

Defendant Therrien’s actions above were an intentional action taken under color of law which Defendant Therrien knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law.

Defendant Therrien’s actions constitute intentional actions taken under color of law which Defendant Therrien knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities.

Defendant Therrien’s actions were undertaken for the purposes of intimidating, coercing, and/or punishing us so that we would not exercise our rights to speak/and or report of Defendant Therrien’s wrongful and illegal activities.

Defendant Therrien engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us.

Defendant Therrien’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable.

Defendant Therrien acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Therrien knew that we were the landowners and not the violators.

Defendant Therrien knew we asserted at the June 29, 2010 meeting that we would have the tenants remove their RV, which was done on a timely schedule preventing 16.I.(3) Legal Action.

Defendant Therrien willfully and fraudulently defended both counts in the anti-SLAPP case before the Maine Supreme Court.

Defendant Therrien proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government. See: MOTIVE

Defendant Therrien’s willful fraudulent claims under oath in the anti-SLAPP case were proven false when the case was dismissed with prejudice.

Defendant Therrien intentionally filed a 2010 Rule 80K enforcement (RV) Count I action against us with clear knowledge that the alleged violation was intentionally fraudulent because Therrien clearly knew at the August 09, 2012 Settlement Conference when Judge Daigle told them that RV’s are not Residential Dwelling units as described in the Madawaska SZO. Defendant Therrien also knew that we were the landowners and not the violators. Defendant Therrien proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government.

Defendant Therrien conspired, and was an integral responsible actor, in most, or all of the violations and illegal acts concerning us while she was town manager.

2010 RV Violations.

No.8, Due Process, Equal Protection, ----No.10. Due Process, Equal Protection ----No.11. Due Process, Equal Protection ----No.12. Due Process, Equal Protection ---No.13 Due Process, Equal Protection ----No.14 Due Process, Equal Protection---- No.15 Due Process, Equal Protection---- No.19 Due Process, Equal Protection ----No.21 Due Process, Equal Protection ---- No.26 Due Process, Equal Protection---- No.29 Due Process, Equal Protection---- No.30 Due Process, Equal Protection ----No.31 Due Process, Equal Protection ----No.32 Due Process, Equal Protection No.34---- Due Process, Equal Protection---- No.35 Due Process, Equal Protection ----No.36 Due Process, Equal Protection---- No.37 Due Process, Equal Protection--- No.38 Due Process, Equal Protection---- No.40 Due Process, Equal Protection---- No.41 Due Process, Equal Protection ----No.42 Due Process, Equal Protection ----No.43 Due Process, Equal Protection ----No.44 Due Process, Equal Protection ----No.45 Due Process, Equal Protection---- No.46 Due Process, Equal Protection ----No.47 Due Process, Equal Protection---- No.48V Due Process, Equal Protection--- No.50 Due Process, Equal Protection---- No.51 Due Process, Equal Protection---- No.52 Due Process, Equal Protection---- No.53 Extortion, Abuse of Process, Equal Protection, Due Process, ----No.54. Due Process, Equal Protection, ---- No.60 Due Process, Equal Protection---- No.61. Due Process, Equal Protection---- No. 64 Due Process, Equal Protection ---No.65. Due Process, Equal Protection ----No.66 Due Process, Equal Protection No. 71. ---Due Process, Equal Protection ---No.74. Due Process, Equal Protection ---No.80. Due Process, Equal Protection ---No. 84. Due Process, Equal Protection ----No. 85. Due Process, Equal Protection---- No.89. Due Process, Equal Protection---- No. Due Process, Equal Protection ---No.90 Due Process, Equal Protection---- No.91.Violation M.R.S.A. Title 14 § 556--- No.93 No. 92. Violation M.R.S.A. Title 14 § 556--- No.93 Violation M.R.S.A. Title 14 § 556---- No.95. Violation M.R.S.A. Title 14 § 556---- No.97. Violation M.R.S.A. Title 14 § 556---- No.98. Violation M.R.S.A. Title 14 § 556 and Due Process, Equal Protection---- No.100. Due Process, Equal Protection---- No.101. Due Process, Equal Protection---- No.102 Due Process, Equal Protection---- No.107. Due Process, Equal Protection---- No.108. Due Process, Equal Protection---- No.110 Due Process, Equal Protection---- No.113. Violation M.R.S.A. Title 14 § 556--- No.115 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.117 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection --No.118 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.119 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.120 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.121 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.125 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.126 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.127.Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.128.Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No.129 Due Process, Equal Protection ---No.130. Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ----No.134 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.135 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.136 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection-- No.140. Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.142 Due Process, Equal Protection--- No.144 Due Process, Equal Protection--- No.146 Due Process, Equal Protection--- No.148 Due Process, Equal Protection--- No.153 Due Process, Equal Protection

2014 Rule 80K Enforcement Action (Building Violation)

ANSWER: Defendant Christina Therrien assisted in initiating, procuring and/or continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action.

Defendant Therrien proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based.

Defendant Therrien assisted in initiating and/or using court documents and/or court processes in prosecuting the 2014 Rule 80K enforcement action against us in a manner that was not proper in the regular conduct of the proceeding with the motive to injure and/or delay us.

Defendant Therrien s actions were undertaken for the purposes of intimidating, coercing, and/or punishing us so that we would not exercise our rights to speak/and or report of Defendant Therrien’s wrongful and illegal activities.

Defendant Therrien engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us.

Defendant Therrien’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable.

Defendant Therrien acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Therrien intentionally, fraudulently, in secret, and at times without authorization, engaged in many, or most of the different illegal acts by the boards, and CEO, in order to intentionally and willfully harm us.

Defendant Therrien intentionally and fraudulently filed, through the CEO Ouellet, many meritless complaints and lawsuits including an illegal permanent Stop Work order in violation of our Due Process rights, pursuant to the SZO 16 I (3) because our permits were vested. Defendant Therrien proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government.

Defendant Therrien intentionally and fraudulently filed a meritless complaint and lawsuit with an illegal permanent Stop Work order in violation of our Due Process rights, pursuant to the SZO 16 I (3) because our permits were vested.

Defendant Therrien intentionally filed a meritless complaint and lawsuit in violation of our Due Process rights pursuant to the SZO 16 I (3) because our permits were vested.

Defendant Therrien willful fraudulent claims under oath in the anti-SLAPP case were proven false when the case was dismissed with prejudice.

Defendant Therrien and the Town built an illegal campground without the proper permits, approvals, and notices, in order to compete illegally against our campground.

Defendant Therrien was the driving force for most of the illegal actions against us while she was Town Manager

Defendant Therrien conspired secretly with the Maine Municipal Association MMA, State Representative Ken Therriault, and the Maine Legislature to illegally violate our Right to petition Government in violation of Article I of the U.S. and State Constitution, by illegally amending a law and applying it to us without Due Process.

Defendant Therrien conspired with Chairman Frallicciardi and the Board to violated our right to proceed with our petition to secede from the Town of Madawaska, by ignoring the Provision of the Maine State Statute, Title 30-A Chapter 113. § 2171 et seq.

Defendant Therrien willfully attended a Board of the Department of Environmental Protection appeal by us, in order to prevent us from exercising our right to build an individual private boatlanding as determined by a Superior Court Decision. Therrien did this despicable act without town or board approval. At that DEP board appeal, she fraudulently testified that the Town BOS did not support my application for an individual boat landing without authorization by the board.

For many years, defendant Therrien’s willful illegal actions, have caused Ann and I serious emotional distress, intentionally undertaken to punish us. Although there is no test or measure for the stress and harm done to our lives, our health, finances, or our reputations, one can only imagine what we have been through. We did not keep notes or records on how many sleepless nights, or doctors’ visits that we just did not feel right. Ask yourselves how you would feel, knowing that someone with the power to do such a deprived act, if they would do this to your loved ones as was done to Ann, my loved one?

INTERROGATORY NO. 6. Included below are all facts and description of all actions taken by Defendant Therrien or on Defendant Therrien’s behalf that we contend constitute the bases for those torts. Please reference the numbers below stating the description of the specific violations corresponding to the 51page document named INTERROGATORY - Violation of Constitutional and Civil Rights Under 42 US.C. § 1983 M.R.S. §§ 4681et seq. and Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress, AND Negligent Infliction of Emotional Distress.

Below are all facts and description of all actions for Interrogatory # 6: Lot 468 building violations.

No.160 Due Process, Equal Protection--- No.161 Due Process, Equal Protection--- No.162 Due Process, Equal Protection ---No.163 Due Process, Equal Protection ---No.168 Due Process, Equal Protection ---No.170 Due Process, Equal Protection--- No.174 Due Process, Equal Protection--- No.175 Due Process, Equal Protection--- No.179. Due Process, Equal Protection No.180 Due Process, Equal Protection--- No.182 Due Process, Equal Protection No.183 Due Process, Equal Protection--- No.184 Due Process, Equal Protection--- No.188 Due Process, Equal Protection--- No.195 Due Process, Equal Protection--- No.196 Due Process, Equal Protection--- No.204 Due Process, Equal Protection--- No.205 Due Process, Equal Protection--- No.206 Due Process, Equal Protection--- No.207 Due Process, Equal Protection--- No.208 Due Process, Equal Protection--- No.214 Due Process, Equal Protection--- No.215. Article I the right to petition Government--- No.216 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT. --- No.217. VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT--- No. 218 Article I Section II Power inherent in People. --- No. 219 Article I Section II Power inherent in People. --- No. 220 Article I Section II Power inherent in People. ---No. 221 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT Article I Section II Power inherent in People. --- No. 222 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT Article I Section II Power inherent in People. ---No. 223 VIOLATION ARTICLE I RIGHT TO PETION GOVERNMENT Article I Section II Power inherent in People. --- No. 225 Due Process, Equal Protection No. 226 Due Process, Equal Protection ---No. 227 Due Process, Equal Protection ---No. 228 Due Process, Equal Protection ---No. 229 Due Process, Equal Protection ---No. 231. Due Process, Equal Protection--- No. 232. Due Process, Equal Protection--- No. 237. Due Process, Equal Protection ---No. 240. Due Process, Equal Protection--- No. 243. Due Process, Equal Protection ---No. 244. Due Process, Equal Protection ---No. 247. Due Process, Equal Protection ---No. 248 Due Process, Equal Protection--- No. 249 Due Process, Equal Protection ---No. 252 Due Process, Equal Protection ---No. 254 Due Process, Equal Protection ---No.258 Due Process, Equal Protection ---No. 259 Due Process, Equal Protection ---No. 260 Due Process, Equal Protection--- No. 265 Due Process, Equal Protection--- No. 266Due Process, Equal Protection--- No. 267 Due Process, Equal Protection ---No. 268 Due Process, Equal Protection--- No. 269 Due Process, Equal Protection ---No. 271 Due Process, Equal Protection ---No. 272 Due Process, Equal Protection ---No. 273 Due Process, Equal Protection ---No. 275 Due Process, Equal Protection--- No. 276 Due Process, Equal Protection ---No. 278 Due Process, Equal Protection ---No. 279 Due Process, Equal Protection--- No. 280 Due Process, Equal Protection ---No. 283 Due Process, Equal Protection ---No. 287 Due Process, Equal Protection ---No. 288 Due Process, Equal Protection ---No. 289 Due Process, Equal Protection ---No. 290 Due Process, Equal Protection ---No. 291 Due Process, Equal Protection ---No. 292 Due Process, Equal Protection--- No. 293 Due Process, Equal Protection ---No. 294 Due Process, Equal Protection--- No. 292 Due Process, Equal Protection--- No. 296 Due Process, Equal Protection ---No. 297 Due Process, Equal Protection---- No. 298 Due Process, Equal Protection ---No. 299 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 300 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 302 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 304 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 305 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 227 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 306 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 307 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 308 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 309 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No. 311 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No. 312 Due Process, Equal Protection M.R.S.A. Title 14 § 556 violation ---No. 313 Due Process, Equal Protection Violation--- No. 314 Due Process, Equal Protection Violation--- No. 316 Due Process, Equal Protection Violation--- No. 319 Due Process, Equal Protection Violation ---No. 320 Due Process, Equal Protection Violation--- No. 322 Due Process, Equal Protection Violation ----No. 323 Due Process, Equal Protection Violation--- No. 324 Due Process, Equal Protection Violation--- No. 326 Due Process, Equal Protection Violation--- No. 312 Due Process, Equal Protection Violation--- No. 328 Due Process, Equal Protection Violation ---No. 329 Due Process, Equal Protection Violation ---No. 333 Due Process, Equal Protection Violation ---No. 312 Due Process, Equal Protection Violation ---No. 334 Due Process, Equal Protection Violation ---No. 336 Due Process, Equal Protection Violation. INTERROGATORY NO. 7. Please state all facts upon which you are relying to establish that Defendant Christina Therrien should be held liable for wrongful use of civil process, abuse of process, intentional infliction of emotional distress, or negligent infliction of emotional distress, including a description of all actions taken by Defendant Therrien’s or on Defendant Therrien’s behalf that you contend constitute the basis for those torts. ANSWER: Defendant Christina Therrien, assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 and 2014 Rule 80K enforcement actions) against us without probable cause and without reasonable grounds for action. Because this intentional act by the Town and its employees proved to be meritless and without probable cause it should not, and cannot, be legally identified as an “Enforcement action.” It was an intentional act in bad faith to punish us for our petitioning activities, and for taking part in our local government. Defendant Christina Therrien assisted in initiating, procuring and/or continuing a civil proceeding (through the 2010 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action. Defendant Therrien proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based. Defendant Therrien assisted in initiating, procuring, and/or continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for the action. Defendant Therrien proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based. Defendant Therrien assisted in initiating and/or using court documents and/or court processes in prosecuting the 2010 80K enforcement action against us in a manner that was not proper in the regular conduct of proceedings with a motive to injure and/or delay us. Defendant Therrien assisted in initiating and/or using court documents and/or court processes in prosecuting the 2014 Rule 80K enforcement action against us in a manner that was not proper in the regular conduct of the proceeding with the motive to injure and/or delay us. Defendant Therrien’s actions above were an intentional action taken under color of law which Defendant Therrien knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law. Defendant Therrien’s actions constitute intentional actions taken under color of law which Defendant Therrien knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities. Defendant Therrien’s actions were undertaken for the purposes of intimidating, coercing, and/or punishing us so that we would not exercise our rights to speak/and or report of Defendant Therrien’s wrongful and illegal activities. Defendant Therrien engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us. Defendant Therrien’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable. Defendant Therrien acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint. Defendant Therrien and the Town built an illegal campground without the proper permits, approvals, and notices, in order to compete illegally against our campground. INTERROGATORY NO. 7. Contains eight (8) distinct subparts/counts. 1. Count I. Wrongful use of Civil PROCEEDINGS, 2010 Rule 80K Enforcement Action. 2. Count II. Wrongful use of Civil PROCEEDINGS, 2014 Rule 80K Enforcement Action. 3. Count III. Abuse of Process—2010, Rule 80K Enforcement Action. 4. Count IV. Abuse of Process—2014, Rule 80K Enforcement Action. 5. Count VII. Intentional Infliction of Emotional Distress. 2010, Rule 80K Enforcement Action. 6. Count VIII. Negligent Infliction of Emotional Distress. 2010, Rule 80K Enforcement Action. 7. Count VII. Intentional Infliction of Emotional Distress. 2014, Rule 80K Enforcement Action. 8. Count VIII. Negligent Infliction of Emotional Distress. 2014, Rule 80K Enforcement Action. RV 2010 ENFORCEMENT ACTION See: All Facts are provided in 51page document named INTEROGETORY - Violation of Constitutional and Civil Rights Under 42 US.C. § 1983 M.R.S. §§ 4681et seq. and Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress, AND Negligent Infliction of Emotional Distress. ANSWER: All Facts, and Description of all actions. No. 5 Intentional Infliction of Emotional Distress. –No.8 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress. ---No.9. Abuse of Process Intentional Infliction of Emotional Distress. ---No.15,19,22, Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress—No.29 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.30 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress----No.31 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.32 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.33 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress ---No.34 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress. ----No. 35 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.51 Abuse of Process, Intentional Infliction of Emotional Distress. ---No. 52. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.53. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.56 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. 63 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.65 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No. 66,67,68,69,70,71, Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.76,77, Abuse of Process, ----No.81 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.82,83,84 Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.90,91,93,97,98, Abuse of Process. ---No.102, Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress---No.140,141,142,144, 145,146,147,148, 149,150,152, Abuse of Process (because the Town should have acknowledged their Abuse of Process, Wrongful Use of Civil Process. Intentional Infliction of Emotional Distress, and settled.) We also blame the Court for this violation of Rights. LOT 468 BUILDING VIOLATIONS GENERAL ALLEGATIONS No. 160,161,162,163,164 Negligent Infliction of Emotional Distress, Intentional Infliction of Emotional Distress, ---No.168,170, Abuse of Process, Intentional Infliction of Emotional Distress---No.174,175,177.179.180.181.183.184. Abuse of Process, Intentional Infliction of Emotional Distress---No.188,190, Abuse of Process, Intentional Infliction of Emotional Distress---No.195, Abuse of Process, Intentional Infliction of Emotional Distress---No.205, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.206, 207, 208, 209,210,211, 212,213,214,215,216,217,218,222,223,224, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.225, 226,227,228,229231,232,233,234,Abuse of Process---No.235, 236, 237,239, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.243,244,245,246,248,249, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.252,254,255,256,257,258,259,260,261,262, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.264,265,266,267,268,269,270,271,272,273,275,276,277,278,279,280, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.284,285,286,287,288,289 Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress,---No.289,290,291, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.296,297,298, Wrongful Use of Civil Process, Abuse of Process, Intentional Infliction of Emotional Distress---No.299,300,309,314,315 Abuse of Process, Intentional Infliction of Emotional Distress---No.320, Intentional Infliction of Emotional Distress---No.322,323, Abuse of Process, Intentional Infliction of Emotional Distress.---No. 334,336,337,339,341,343. Abuse of Process, Intentional Infliction of Emotional Distress. INTERROGATORY NO. 8. Please state all facts upon which you are relying to establish that Defendant Vince Frallicciardi violated your constitutional or civil rights for which you seek relief under 42 U.S.C. § 1983 or 5 M.R.S. §§ 4681 et seq., including a description of all actions taken by Defendant Frallicciardi or on Defendant Frallicciardi’s behalf that you contend violated your rights and an identification of the rights you claim were violated. Interrogatory No. 8. Contains questions four (4) separate and distinct subparts/counts.

5. Count V. (Violation of Federal Civil Rights---42 U.S.C. § 1983)

6. Count VI. (Violation of Maine Civil Rights Act---5 M.R.S. §§ 4681) et seq,

Moreover, interrogatory No. 8 contains questions to two (2) separate and distinct subparts/counts, i.e. for two (2) separate and distinct code violations. One code violation is for the 2010 Rule 80K RV Enforcement Action, and the other is for the 2014 80K building code Enforcement Action; therefore, the two code violations on different years, cannot logically be identical rights violations, and are deemed separate interrogatories for the purpose of this rule.

3. 2010 Rule 80K Enforcement Action.

4. 2014 Rule 80K Enforcement Action.

2010 RV Violation

Although defendant Vincent Frallicciardi was not a participant in the June 29, 2010 RV enforcement action meeting, he was later responsible for pursuing the illegal intentional act for the RV enforcement action.

No.8, Due Process, Equal Protection, ----No.10. Due Process, Equal Protection ----No.11. Due Process, Equal Protection ----No.12. Due Process, Equal Protection ---No.13 Due Process, Equal Protection ----No.14 Due Process, Equal Protection---- No.15 Due Process, Equal Protection---- No.19 Due Process, Equal Protection ----No.21 Due Process, Equal Protection ---- No.26 Due Process, Equal Protection---- No.29 Due Process, Equal Protection---- No.30 Due Process, Equal Protection ----No.31 Due Process, Equal Protection ----No.32 Due Process, Equal Protection No.34---- Due Process, Equal Protection---- No.35 Due Process, Equal Protection ----No.36 Due Process, Equal Protection---- No.37 Due Process, Equal Protection--- No.38 Due Process, Equal Protection---- No.40 Due Process, Equal Protection---- No.41 Due Process, Equal Protection ----No.42 Due Process, Equal Protection ----No.43 Due Process, Equal Protection ----No.44 Due Process, Equal Protection ----No.45 Due Process, Equal Protection---- No.46 Due Process, Equal Protection ----No.47 Due Process, Equal Protection---- No.48V Due Process, Equal Protection--- No.50 Due Process, Equal Protection---- No.51 Due Process, Equal Protection---- No.52 Due Process, Equal Protection---- No.53 Extortion, Abuse of Process, Equal Protection, Due Process, ----No.54. Due Process, Equal Protection, ---- No.60 Due Process, Equal Protection---- No.61. Due Process, Equal Protection---- No. 64 Due Process, Equal Protection ---No.65. Due Process, Equal Protection ----No.66 Due Process, Equal Protection No. 71. ---Due Process, Equal Protection ---No.74. Due Process, Equal Protection ---No.80. Due Process, Equal Protection ---No. 84. Due Process, Equal Protection ----No. 85. Due Process, Equal Protection---- No.89. Due Process, Equal Protection---- No. Due Process, Equal Protection ---No.90 Due Process, Equal Protection---- No.91.Violation M.R.S.A. Title 14 § 556--- No.93 No. 92. Violation M.R.S.A. Title 14 § 556--- No.93 Violation M.R.S.A. Title 14 § 556---- No.95. Violation M.R.S.A. Title 14 § 556---- No.97. Violation M.R.S.A. Title 14 § 556---- No.98. Violation M.R.S.A. Title 14 § 556 and Due Process, Equal Protection---- No.100. Due Process, Equal Protection---- No.101. Due Process, Equal Protection---- No.102 Due Process, Equal Protection---- No.107. Due Process, Equal Protection---- No.108. Due Process, Equal Protection---- No.110 Due Process, Equal Protection---- No.113. Violation M.R.S.A. Title 14 § 556--- No.115 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.117 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection --No.118 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.119 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.120 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.121 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.125 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.126 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.127.Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.128.Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ---No.129 Due Process, Equal Protection ---No.130. Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection ----No.134 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.135 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection---- No.136 Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection-- No.140. Violation M.R.S.A. Title 14 § 556 Due Process, Equal Protection--- No.142 Due Process, Equal Protection--- No.144 Due Process, Equal Protection--- No.146 Due Process, Equal Protection--- No.148 Due Process, Equal Protection--- No.153 Due Process, Equal Protection

Below are all facts and description of all actions for Interrogatory # 8: Lot 468, 2014 building violations.

Defendant Frallicciardi assisted in using court documents and/or court processes in prosecuting the 2010 80K enforcement action against us in a manner that was not proper in the regular conduct of proceedings with a motive to injure and/or delay us.

Defendant Frallicciardi’s actions above were an intentional action taken under color of law which Defendant Frallicciardi knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law.

Defendant Frallicciardi’s actions constitute intentional actions taken under color of law which Defendant Frallicciardi knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities.

Defendant Frallicciardi’s actions were undertaken for the purposes of intimidating, coercing, and/or punishing us so that we would not exercise our rights to speak/and or report of Defendant Frallicciardi’s wrongful and illegal activities.

Defendant Frallicciardi engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us.

Defendant Frallicciardi’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable.

Defendant Frallicciardi acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Frallicciardi knew that we were the landowners and not the violators.

Defendant Frallicciardi knew or should have known we asserted at the June 29, 2010 meeting that we would have the tenants remove their RV, which was done on a timely schedule preventing 16.I.(3) Legal Action.

Defendant Frallicciardi willfully and fraudulently defended both counts in the anti-SLAPP case before the Maine Supreme Court.

Defendant Frallicciardi proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government.

Defendant Chairman Frallicciardi and Christina Therrien conspired with the Board and violated our right to proceed with our petition to secede from the Town of Madawaska, by willfully ignoring the Provision of the Maine State Statute, Title 30-A Chapter 113. § 2171 et seq.

Defendant Frallicciardi and Defendant Therrien conspired secretly with the Maine Municipal Association MMA, State Representative Ken Therriault, and the Maine Legislature to illegally violate our Right to petition Government in violation of Article I of the U.S. and State Constitution, by illegally amending a law in secret, and applying it to us without Due Process.

Defendant Frallicciardi, the Board of Selectmen, and Therrien willfully and fraudulently refused to follow Title 30-A Chapter 113. § 2171 et seq. to (request a vote), but instead, admitted to the courts that they refused to act, willfully violating our rights.

Defendant Frallicciardi intentionally continued a 2010 Rule 80K enforcement (RV) Count I and Count II actions against us with clear knowledge that the alleged violation was intentionally fraudulent because Frallicciardi clearly knew at the August 09, 2012 Settlement Conference when Judge Daigle told CEO Ouellet, and Currier, that RV’s are not Residential Dwelling units as described in the Madawaska SZO. Defendant Frallicciardi also knew that we were the landowners and not the violators. Defendant Frallicciardi proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government. Defendant Frallicciardi knew or should have known that CEO Ouellet said “this cannot be a campground” at the June 29, 2010 board meeting.

2014 Rule 80K enforcement action (Building Violation)

ANSWER: Defendant Vince Frallicciardi assisted in initiating, procuring and/or continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action.

Defendant Frallicciardi proceeded in this civil proceeding against us with a primary purpose other than securing proper adjudication of the claim or claims upon which those proceedings were based.

Defendant Frallicciardi assisted in initiating and/or using court documents and/or court processes in prosecuting the 2014 Rule 80K enforcement action against us in a manner that was not proper in the regular conduct of the proceeding with the motive to injure and/or delay us.

Defendant Frallicciardi engaged in intentional or reckless conduct that inflicted upon us serious and emotional distress or was substantially certain to result in serious emotional distress to us.

Defendant Frallicciardi’s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable.

Defendant Frallicciardi acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Frallicciardi intentionally and fraudulently filed a meritless complaint and lawsuit with an illegal permanent Stop Work order, in violation of our Due Process rights pursuant to the SZO 16 I (3) because our permits were vested. Defendant Frallicciardi proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government.

On January 24, 2013, Justice Hunter granted count II for the 2010 RV violation.

On March 25, 2013 we filed a Special Motion to Dismiss.

On April 8, 2013, CEO Ouellet granted the third building permit.

On May 28, 2013 we filed a petition to secede from the town the town of Madawaska. CEO Ouellet investigated our building less than 48 hours after we filed the petition to secede, (this is the 2014 building violation) and issued a notice of violation on June 4, 2013 for the instant 2014 building violation.

Sometime in June of 2013 we met with chairman Frallicciardi and board member Dave Morin who told us they would help us with the permanent Stop Work order and notice of violation, if we dropped the secession against the town.

On June 10, 2014 we filed a Special Motion to dismiss for the building violation. No. 285.

Defendant Frallicciardi, and CEO Ouellet, intentionally, and fraudulently, filed a meritless complaint and lawsuit with an illegal permanent Stop Work order in violation of our Due Process rights, pursuant to the SZO 16. I. (3) because our permits were vested.

For many years, defendant Frallicciardi’s willful illegal actions, have caused Ann and I serious emotional distress, intentionally undertaken to punish us. Although there is no test or measure for the stress and harm done to our lives, our health, finances, or our reputations, one can only imagine what we have been through. We did not keep notes or records on how many sleepless nights, or doctors’ visits that we just did not feel right. Ask yourselves how you would feel, knowing that someone with the power to do such a deprived act, if they would do this to your loved ones as was done to Ann, my loved one?

At a Madawaska Town Meeting on June 16, 2015 I requested information for the transportation account. Vince Frallicciardi told me to come to the town office and he would give me the information. On June 29, 2015 I asked Frallicciardi for the information and he threatened me in a violent confrontation to which the police came to stop.

On July 6, 2015 I filed a Title 17-A 2931 protection from harassment temporary order which was denied by justice O’Mara in District Court. We feared defendant Frallicciardi because he has a criminal record, was dishonorably discharged from the marines, and imprisoned for 18 months for stealing military equipment. While chairman of the board of selectmen he was in charge of purchasing military equipment and had a $10,000 account for transportation which I was investigating. He hired Jeff Albert’s trucking company to haul the military equipment. Frallicciardi has a reputation for being a dangerous person and for fighting in town. He resigned from the board after illegally buying guns from the Madawaska Chief of Police Ross Dubois. This was a crime because he was a convicted felon.

On July 6, and 7, 2015 I requested The Town Police Department to issue the restraining order and the police all refused to issue the harassment complaint against Chairman Frallicciardi even though it was their responsibility. Because of this refusal we had to hire the Sheriff to issue the harassment complaint. The police are hired by the board of selectmen, worked with Frallicciardi to buy military equipment, and illegally sold him guns.

After Christina Therrien resigned, Chief of Police Ross Dubois temporarily assumed her position as town manager. During this time, I met with Ross Dubois (chief of police) about chairman Frallicciardi. After I informed Dubois about Frallicciardi’s criminal history with theft of military equipment, Dubois assured me everything was legal because he was in charge of the military equipment. and refused to take any action against Vince Frallicciardi.

After Dubois assumed his position as chief of police, he sold guns to a convicted felon Vince Frallicciardi, and said he did nothing wrong because he was cleared after an investigation. Shortly after this investigation began, Chairman Frallicciardi resigned. The Board of Selectpersons never discussed any of this in public. Everything was done illegally, secretly in executive session, and no legal action was ever taken against Frallicciardi.

INTERROGATORY NO. 9. Please state all facts upon which you are relying to establish that Defendant Vince Frallicciardi should be held liable for wrongful use of civil process, abuse of process, intentional infliction of emotional distress, or negligent infliction of emotional distress, including a description of all actions taken by Defendant Frallicciardi or on Defendant Frallicciardi’s behalf that you contend constitute the basis for those torts.

READ PART II

Why Town Government Fails

OUR CIVIL RIGHTS

The Long View of Local and State Politics

PART 1 ANSWER TO INTERROGATORIES

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