Bick Cayer
- Apr 16, 2020
- 46 min read

PART 2 ANSWER TO INTERROGATORIES

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. ANSWER: Defendant Vince Frallicciardi assisted in 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 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, 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 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 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 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’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. INTERROGATORY NO. 9. 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 ANSWER: Included below are all facts and description of all actions taken by Defendant Frallicciardi or on Defendant Frallicciardi’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, 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. 10. Please state all facts upon which you are relying to establish that Defendant Jeff Albert 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 Albert or on Defendant Albert’s behalf that you contend violated your rights and an identification of the rights you claim were violated. ANSWER: Defendant Jeff Albert willfully and fraudulently impersonated a public servant. Impersonating a Public servant is a violation of Title 17-A of the Maine Criminal Code Part 2: Substantive Defenses Chapter 19: Falsification in Official Matters. § 457. Impersonating a Public Servant. 3. Impersonating a Public Servant is a Class E Crime. Defendant Jeff Albert resigned from the Planning Board (PB) in March 29, 2005 and was no longer an active or alternate member of the PB at the May 10, 2012, PB building permit Hearing. Defendant Jeff Albert moved to an unorganized territory, and did not reside in the Town of Madawaska about the time he resigned from the PB. Defendant Jeff Albert willfully, and fraudulently, inserted himself in the May 10, 2012 PB Hearing, (pursuant to the 2014 Rule 80K, building enforcement action,) as a PB member on May 10, 2012 without authorization or being sworn in as a PB member. Defendant Jeff Albert controlled the discussion at the May 10, 2012 hearing, and made a motion to table the permit application until a septic plan was available, even though he was not sworn in as a PB member. Defendant Jeff Albert did not attend any PB meetings or Hearings from March 29, 2005 to the May 10, 2012 PB Hearing for our building permits and attended only PB matters that pertained to us, Richard and Ann Cayer, from 2012, to 2013, where he controlled much of the discussions. At the first PB hearing in 2013, it was admitted by CEO Ouellet that we had not removed more than 50% of the value of the structure before removal. In spite of this material fact that we did not remove more than 50%, the PB voted that we needed a professional appraisal contrary to the SZO. After we paid for and received the appraisal, the town scheduled another unnecessary PB Hearing with such a convoluted article, that the PB members did not understand it, and ignored our appraisal. Jeff Albert voted we were in violation. Something that they had no authority to do, and when I asked them what I was supposed to do with my appraisal Jeff Albert said “[Y]ou will need it for court.” Defendant Jeff Albert made important motions or statements in all three (3) Hearings that determined the Hearing outcomes, but did not address the issue in the instant case as provided by the Madawaska SZO. Defendant Jeff Albert did not resign from the PB after the Hearings in 2013, however, he never attended any more PB meetings or hearings from that date on. Defendant Jeff Albert owns a trucking company, Albert Farms, which was hired by Chairman Vince Frallicciardi and the BOS to transport Military equipment that Vince Frallicciardi purchased at auctions for the Town of Madawaska, and others. Ann and I were investigation Vince Frallicciardi transportation account, and we were questioning Jeff Alberts trucking company’s involvement in these matters. Defendant Albert 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 Albert 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 Albert assisted in using court documents and/or court processes in prosecuting the 2010 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 Albert’s actions above were an intentional action taken under color of law which Defendant Albert knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law.

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

Defendant Albert’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 Albert’s wrongful and illegal activities.

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

INTERROGATORY NO. 11. Please state all facts upon which you are relying to establish that Defendant Jeff Albert 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 Albert or on Defendant Albert’s behalf that you contend constitute the basis for those torts.

NOTE: Jeff Albert only played a role as described by me beginning with the May 10, 2012 hearing as a Planning Board member pursuant to the 2014 building violation.

ANSWER: Defendant Albert 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 Albert 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 Albert 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 Albert’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 Albert acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Please refer to the same document for the facts. No.180 Due Process, Equal Protection, intentional infliction of emotional distress, and negligent infliction of emotional distress, --- No.183 Due Process, intentional infliction of emotional distress, and negligent infliction of emotional distress. ---No. 289 Due Process, Equal Protection, intentional infliction of emotional distress, and negligent infliction of emotional distress.

INTERROGATORY NO. 12. Please state all facts upon which you are relying to establish that Defendant Don Chasse 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 Chasse or on Defendant Chasse’s behalf that you contend violated your rights and an identification of the rights you claim were violated.

Interrogatory No. 12. 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. 12 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.

INTEROGATORY NO. 12. Included below are all facts and description of all actions continued by Defendant Chasse or on Defendant Chasse’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 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: 2010 Rule 80K 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 continued by Don Chasse for Interrogatory # 12: 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. ANSWER: Defendant Don Chasse, 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 Chasse 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 Chasse 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 Chasse’s actions above were an intentional action taken under color of law which Defendant Chasse knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law. Defendant Chasse’s actions constitute intentional actions taken under color of law which Defendant Chasse knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities. Defendant Chasse’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 Chasse’s wrongful and illegal activities. Defendant Chasse 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 Chasse’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 Chasse acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint. Defendant Chasse was chairman of the board on June 29, 2010 and knew that we were the landowners and not the violators. Defendant Chasse knew we asserted at the June 29, 2010 meeting that we would have the tenants remove their RV before we were ever asked, which was done on a timely schedule preventing 16.I.(3) Legal Action. Defendant Chasse proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government. Defendant Chasse intentionally filed a 2010 Rule 80K enforcement (RV) Count I action against us with clear knowledge that the alleged violation was intentionally fraudulent because Chasse clearly knew at 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 Chasse also knew that we were the landowners and not the violators. Defendant Chasse proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government. See: MOTIVE

Defendant Chasse was chairman of the Board of Selectmen (BOS) at the June 29, 2010 selectmen meeting where he knew, or should have known, that it was illegal for the BOS to vote and determined that we had violated the Shoreland Zoning Ordinance (SZO) for a building violation because this was the duty and responsibility of the CEO Robert Ouellet.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting where attorney Richard Currier had been hired, and was at that meeting to intimidate and initiate a willful and fraudulent meritless code violation against us, all without any Hearings.

Defendant Chasse, the BOS, Town manager Christina Therrein, the CEO Ouellet, and attorney Richard Currier, all knew, or should have known, that all willful fraudulent claims to the Maine Superior court and the Maine Supreme Court by the Town attorneys, Richard Currier, and Jon Plourde, that we had a Notice of Hearing was not true, and constituted Willful Fraud on the Courts.

Defendant Chasse, the BOS, Town manager Christina Therrein, the CEO Ouellet, and attorney Richard Currier, all knew, or should have known, that all claims to the courts by the Town attorneys, Richard Currier, and Jon Plourde, that we had a Hearing, was not true and constituted Willful Fraud on the Courts.

Defendant Chasse, the BOS, Town manager Christina Therrein, the CEO Ouellet, and attorney Richard Currier, all knew, or should have known, that all claims to the courts by the Town attorneys, Richard Currier, and Jon Plourde, that we gave testimony was not true and constituted Willful Fraud on the Courts.

Defendant Chasse, the BOS, Town manager Christina Therrein, the CEO Ouellet, and attorney Richard Currier, all knew, or should have known at the June 29, 2010 selectmen meeting, that we owned and operated a campground, rented camps, and did not own the RV’s on those lots, or did not place the RV’s on those lots.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting and everyone, including attorney Currier, understood that we did not own a recreational vehicle (RV) and did not park RV’s on our campground and camp lots that we rented to tenants, and that tenants owned and parked their own RV’s.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting with attorney Currier and Therrien, and they all understood that the tenants at camp lot 468 were the ones that owned the RV that they parked at the camp that they had rented from us.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting when the code enforcement officer (CEO) Ouellet willfully and fraudulently claimed that a building permit was required to park an RV on a camp lot and defendant Chasse knew or should have known this was not true.

Defendant Chasse knew, or should have known that the CEO never issued permits to park RV’s on house or camp lots, and the BOS had previously defended the right to park RV’s on house and camp lots against claims by us that David Rouleau had several RV’s on his illegally subdivided house lot.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting when the CEO claimed that by parking an RV on the camp lot 468 it changed the use of that lot and added another Residential Dwelling unit and Chasse knew that was not true because he had received a letter from DEP Maclagan explaining that to him.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting when I apologized and said, I didn’t know, and if that’s how you will interpret that language, I will remove the RV. I said that before ever having been told by the BOS or by the CEO to remove the RV, as required pursuant to 16H (2)(a), Enforcement.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting when the board members ignored the clear language of the Madawaska SZO provision under Enforcement 16H (3) Legal Action, told us that we had to pay a $500.00 fine and sign a consent agreement for something that we had not done. Abuse of Process and Rights violation.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting when we requested another meeting to discuss this illegal action and he told us to put it in a letter and he would address it.

Defendant Chasse was chairman of the BOS when he ignored two letters by me requesting another meeting to discuss the fact that we were not the alleged code violators, and there was no violation.

Defendant Chasse was chairman of the BOS when the town BOS willfully and fraudulently authorized the town attorney Richard Currier, to apply Legal Action pursuant to 16H (3) against us by willfully and fraudulently ignoring the fact that the RV had been removed by the date determined at the June 29, 2010 BOS meeting.

Defendant Chasse was chairman of the BOS when the town BOS knew or should have known that we satisfied our responsibility as landowners by requiring the tenants to correct the alleged violation pursuant to provision 16H (2)(a), in spite of the fact that we were not the violators, and there was no violation.

Defendant Chasse was chairman of the BOS, when he, the town BOS, and attorney Richard Currier, knew or should have known that any “Legal Action” pursuant to 16 H. Enforcement (3) could only begin, “[W]hen the above action does not result in the correction or abatement of the violation or nuisance condition.” Because Defendant Chasse, the BOS, CEO Ouellet, Town manager Christina Therrien, and attorney Richard Currier all knew we had the RV’s removed by the tenant as directed by the BOS in a timely manner, therefore, any “Legal Action,” was not warranted or legal, was a violation of our rights, and an abuse of the Legal Process.

Defendant Chasse was chairman of the BOS when the BOS authorized attorney Richard Currier to send us a letter warning us that we had to sign a consent agreement and pay a $500.00 fine by a certain date or else the Town would file an enforcement action against us in Superior court.

Defendant Chasse was chairman of the BOS when he and, or the BOS willfully, and fraudulently, authorized Legal actions against us by the Town attorney Richard Currier, denying us Due Process pursuant to the provisions of 16 H (3) of the Madawaska SZO.

Defendant Chasse’s authorization requesting attorney Richard Currier to serve us a Consent Agreement that included mostly willful and fraudulent lies that had to be signed by us, including paying a $500 fine, with the threat of court actions if we failed to do so, was seen by us as an Abuse of Process, and extortion by the Town of Madawaska, and its employees.

Defendant Chasse was chairman of the BOS at the June 29, 2010 selectmen meeting when CEO Ouellet clearly said, “[C]ampground is two or more, so I figure this cannot be a campground….So that’s what I see and today I went to take a look again at the lot, today there’s only one. The little white one is there, the other brownish one is gone.” Attorney Richard Currier was at that June 29, 2010 selectman meeting sitting next to us, Richard and Ann Cayer, and clearly heard this statement by CEO Ouellet.

2014 Rule 80K enforcement action (Building Violation)

ANSWER: Defendant Don Chasse assisted in continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for action.

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

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

Defendant Chasse’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 Chasse’s wrongful and illegal activities.

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

For many years, defendant Chasse’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. 13. Please state all facts upon which you are relying to establish that Defendant Don Chasse 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 Chasse or on Defendant Chasse’s behalf that you contend constitute the basis for those torts. Defendant Don Chasse, as chairman of the BOS Chasse 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. Because this intentional act by the Town, Chairman Don Chasse, 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, because no reasonable person would have believed that we had violated any SZO rule. Defendant Don Chasse 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 Chasse 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 Chasse assisted in continuing a civil proceeding (through the 2014 Rule 80K enforcement action) against us without probable cause and without reasonable grounds for the action. Defendant Chasse 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 Chasse 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 Chasse assisted in 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 Chasse’s actions above were an intentional action taken under color of law which Defendant Chasse knew or should have known would deprive us of our constitutional rights, privileges, and immunities without due process of law. Defendant Chasse’s actions constitute intentional actions taken under color of law which Defendant Chasse knew or should have known would interfere with our free exercise of our federal and state constitutional rights, privileges, and immunities. Defendant Chasse’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 Chasse’s wrongful and illegal activities. Defendant Chasse 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 Chasse’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 Chasse acted negligently and engaged in tortious conduct against us, as alleged in the Amended Complaint.

Defendant Chasse intentionally filed a 2010 Rule 80K enforcement (RV) Count I action against us with clear knowledge that the alleged violation was intentionally fraudulent because Chasse clearly knew at 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 Chasse also knew that we were the landowners and not the violators. Defendant Chasse proceeded in this civil proceeding to punish us because we exercised our rights in public participation in town government. See: MOTIVE

Defendant Chasse, the BOS, Town manager Christina Therrein, the CEO Ouellet, and attorney Richard Currier, all knew, or should have known, that all claims to the courts by the Town attorneys, Richard Currier, and Jon Plourde, that we gave testimony was not true and constituted Willful Fraud on the Courts.

Defendant Chasse was chairman of the BOS when he ignored two letters by me requesting another meeting to discuss the fact that we were not the alleged code violators, and there was no violation.

RV 2010 ENFORCEMENT ACTION

See: All Facts are provided in the document named INTEROGETORY 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.,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. 14. Please state all facts upon which you are relying to establish that Town of Madawaska 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 on Defendant Town of Madawaska’s behalf that you contend violated your rights and an identification of the rights you claim were violated.

ANSWER: The actions, facts, and occurrences set forth above by named Defendants’ were undertaken pursuant to the policies, customs, and/or practices of the Town of Madawaska and as such, were undertaken under the color of law for the Town of Madawaska.

The Town of Madawaska is vicariously liable under the common law doctrine of agency superior, the responsibility of the superior for the acts of their subordinate or in a broader sense, the responsibility of any third party that had the “right, ability or duty to control” the activities of these civil and Constitutional rights violators. This doctrine of vicarious liability is supported by the common law doctrine for liability of the property owner; when a tenant violates any municipal ordinance and the owner had the “right, ability or duty to control” or correct a land use violation, and does not (correct it), the landowner is responsible for the violation. The Town had the right, ability or duty to control its employees. In our case the Town chose to support, continue, and finance the intentional acts by its employees and agents against us, in bad faith, over a period of 31 years. These facts show a clear policy and custom of discrimination against us by the Town of Madawaska and its employees. The documents that support this policy and custom of discrimination against us, are all public documents available at the Town office.

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 will support our claim of what the Town and its employees did to us, 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.

Pursuant to Title 30-A: Municipalities, Chapter 101. § 2002. Municipality as body corporate, the residents of a municipality are a body corporate which may sue and be sued, appoint attorneys, and adopt a seal. (1989)

The Town of Madawaska voted for, and supplied the Town employees with the finances to bring these illegal actions against us. The Town of Madawaska knew, or should have known of the illegal intentional acts that its employees perpetrated against us, in bad faith.

The Town of Madawaska willfully ignores enforcement of State Laws pursuant to Title 38 Article 2B Mandatory Shoreland Zoning, and we cannot appeal these CEO enforcement decisions.

Town of Madawaska has adopted an SZO denying us the right to appeal any enforcement decision pursuant to 16 H “[A]ny order, requirement, decision or determination made, or failure to act, in the enforcement of this ordinance is not appealable to the Board of Appeals.

This ordinance approved by the Town of Madawaska allows the Town and the CEO to discriminate and violate our Constitutional right to petition Government, our equal protection rights, and Due Process Rights.

At a recent town meeting Robert (Bob) Bellefleur, attorney and Town Meeting moderator, denied us the right to amend the legal fees used to prosecute against us in court by the town, during the budget discussion. Attorney Bellefleur is bias against us and intentionally denied us public participation in our town meeting, which violated our Constitutional rights by falsely claiming that we could not amend the proposed budget agenda.

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

Defendant Town of Madawaska, Chairman Frallicciardi, the Selectboard, and Christina Therrien willfully and deliberately conspired in secret with the intention to violate our right to proceed with our petition to secede from the Town of Madawaska. The Town and its employees willfully ignored the provision of the Maine State statute, by refusing to act as mandated by Title 30-A Chapter 113. § 2171-D. ADVISORY REFERENDUM (1999). The town and its employees did not have the right to refuse to act as sanctioned and justified by the Maine Supreme court decision. The word “Shall” was the operative word describing the mandatory function that the defendants intentionally refused to perform in violation of their oath of office, intentionally violating our Constitutional right to petition Government.

Defendant Town of Madawaska is also vicariously liable for the actions of its employees Frallicciardi, the Board of selectpersons, and Defendant Therrien when they conspired secretly with the Maine Municipal Association (MMA), State Representative Ken Therriault, and the Maine Legislature to illegally amend the secession statute in secret and applied it to us, violating our right to petition Government . The right to petition Government is a violation of the most sacred and fundamental Constitutional right pursuant to Article I of the United States, and State of Maine Constitution which the Courts swear to protect and defend.

The Maine Supreme Court also violated our constitutional right by intentionally denying us our right of protection for this illegal act pursuant to M.R.S.A. Title 1. § 302 with the arbitrary and capricious decision, not according to law, when they allowed the Town to amend the secession statute and applied it to us after we filed our petition.

INTERROGATORY NO. 15. Please state all facts upon which you are relying to establish that Defendant Town of Madawaska 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 Town of Madawaska or on Defendant Town of Madawaska’s behalf that you contend constitute the basis for those torts.

ANSWER: The Town of Madawaska is vicariously liable under the common law doctrine of agency superior, the responsibility of the superior for the acts of their subordinate or in a broader sense, the responsibility of any third party that had the “right, ability or duty to control” the activities of these civil and Constitutional rights violators. This doctrine of vicarious liability is supported by the common law doctrine for liability of the property owner; when a tenant violates any municipal ordinance and the owner had the “right, ability or duty to control” or correct a land use violation, and does not (correct it), the landowner is responsible for the violation. The Town had the right, ability or duty to control its employees. In our case the Town chose to support, continue, and finance the intentional acts by its employees and agents against us, in bad faith, over a period of 31 years. These facts show a clear policy and custom of discrimination against us by the Town of Madawaska and its employees.

The actions, facts and occurrences set forth above by named Defendants’ were undertaken pursuant to the policies, customs, and/or practices of the Town of Madawaska and as such, were undertaken under the color of law for the Town of Madawaska. The (Facts) proving discrimination, (differential treatment) libel, defamation, malicious prosecution, abuse of process, intentional infliction of emotional distress, etc., are available, and are provided in all public records held by the Town of Madawaska.

All loss from the rental, profit from sale of new home, or any other possibility, is unknowable, because of the Town’s employee’s, and their illegal, meritless, intentional acts, in bad faith. These civil rights violations by the Town and its employees, denied us of our Constitutional Rights, ruined our reputation, our lives, our health, and has harmed us financially, very severely.

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 will show what the Town and its employees did this to us, 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.

The Town of Madawaska willfully ignores enforcement of State Laws pursuant to Title 38 Article 2B Mandatory Shoreland Zoning, and we cannot appeal these CEO enforcement decisions.

This ordinance approved by the Town of Madawaska allows the CEO to violate our Constitutional right to petition Government, our equal protection rights, and Due Process Rights.

Attorney and Town Meeting moderator Robert Bellefleur denied us the right to amend the legal fees used to prosecute against us in court by the town, during the budget discussion.

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

Defendant Town of Madawaska, 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. requiring the board to act in accordance to statute and the oath of office to uphold the Constitutional rights of each and every citizen.

Pursuant to our petition to secede from the Town, the provisions of the Maine State Statute, Title 30-A Chapter 113. § 2171 et seq. did not provide the BOS to ignore the word “Shall” to hold a public meeting or vote, and willfully determine to refuse to act or fail to act. This intentional act by the BOS violated our Constitutional right to petition Government.

The Town of Madawaska should be held vicariously responsible for the illegal acts of its employees because as respondent superior the Town had the responsibility as a third party and had the “right, ability or duty to control” the activities of the violators, its employees.

Defendant Town of Madawaska, Frallicciardi, the Board of selectpersons, 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.

INTERROGATORY NO. 16. Please identify all persons with knowledge of the events and allegations in the Plaintiffs’ Complaint, including a description of the facts known to each person and the basis of that knowledge.

ANSWER: Richard Cayer, Plaintiff to this lawsuit

Ann Cayer, Plaintiff to this lawsuit

Luke Rossignol, Esq., attorney for Richard Cayer and Ann Cayer

Robert Ouellet, Defendant to this lawsuit

Christina Therrien, Defendant to this lawsuit

Vince Frallicciardi, Defendant to this lawsuit

Jeff Albert, Defendant to this lawsuit

Don Chasse, Defendant to this lawsuit

O’Neill Clavette BOS member in June 29, 2010 meeting

Michael Williams BOS member in June 29, 2010 meeting

Robert Bob Williams Past BOS member

Ivan Fletcher BOS member in June 29, 2010 meeting

Brenda Therriault BOS member in June 29, 2010 meeting

Barbra Skinner BOS member

Brian Thibault BOS chairman

David Morin BOS member

Andrew ‘Drew” Dube present CEO

Ross Dubois temporary town manager Chief of Police

Ryan Pelletier past town manager

Robert Bellefleur, previous town Attorney, Town Meeting moderator,

Arthur Faucher past town manager

Manon Bilodeau past town employee

Sara Pelletier past town employee

Sherry Pelletier past town employee and notary public

Vince Sirois PB chairman 2013 meetings

Vince Vanier PB member 2013 meetings

Tom Schneck PB member 2013 meetings

Gary Dufour PB member 2006 and 2010

Mark Morneault BOA member 2006 meeting

Jean Cayer BOA member 2006 meeting

Ginette Albert BOA member 2006 meeting

Carl Albert BOA member 2006 meeting

David Rouleau filed complaints

Roger Collin filed complaints

Helen Morin conspired with town manager Therrien and CEO Ouellet

Manon Bilodeau post town employee

Stephenie Maclagan past DEP employee

Town of Madawaska, Defendant to this lawsuit

John J. Wall, III, Esq., attorney for all named Defendant’s

Richard Currier, Esq., of Currier, Trask & Dunleavy, previous attorney for the Town of Madawaska

Jon Plourde, Esq., previously of Currier, Trask & Jordan, previous attorney for the Town of Madawaska

Burman Banville, Town meeting moderator

Ken Therriault State Representative

INTERROGATORY NO. 17. Please identify all persons who may be called to present expert testimony in support of the claims in the Plaintiffs’ Complaint and please state all opinions they are prepared to give, the bases of those opinions, and the facts or other information they are relying upon with regard to those opinions.

ANSWER: Plaintiffs will designate any expert witnesses in this matter in accordance with the Court’s Scheduling Order, or any other Pretrial Order issued by the Court, and Rule 26 of the Maine Rules of Civil Procedure.

The expert witness’s below have knowledge of and participated on behalf of the Town of Madawaska with legal advice, and with knowledge about the amendment pursuant to Title 30-A Chapter 113: § 2171 et. seq in the State Legislature.

Ken Therriault past State Representative who was responsible for illegally amending the secession statute denying us knowledge of the amendment.

MMA representative Dufour who was responsible for initiating the illegal amendment on behalf of the Town of Madawaska.

MMA director Richard P. Flewelling. Legal counsel for the Town of Madawaska in regards to the secession petition.

INTERROGATORY NO. 18. Please identify all photographs, video recordings, plans, maps, reports, audio recordings, statements, written or recorded records of any kind, documents or tangible things that relate to the occurrence or to the allegations in the Plaintiffs’ Complaint.

ANSWER: See Responses to Request for Production of Documents

We are willing, and have offered to provide access to any and all files in our possession that we are legally required to provide under state law. Because of the large number of files and documents we cannot in good faith duplicate all the documents. We are willing to work with the defendant’s attorney or anyone else to meet this request. We are willing to provide any document or any other information for a specific piece of evidence requested by attorney Wall. Please identify specifically or exactly what information that you are requesting, and we will do our best to provide you with it. Most of these files are Town public records.

INTERROGATORY NO. 19. Please itemize all damages you are claiming in the Plaintiffs’ Complaint were caused by the occurrence or the actions of the Defendants, including in your answer the nature or category of the damages, the amount of damages for each category, and a description of how the damages in each category were determined or calculated.

ANSWER: Damages to reputation. Libel. Slander. Defamation. $1,000,000.

Loss of use of property.

Violation of our Constitutional rights to form a more perfect union, and the right to life, property and the pursuit of happiness, the right to petition Government.

Legal fees $98,000

The loss of income to the lot 468 over a period of 9 years could be more than $15,000 to $30,000.

The loss of use of the property by us with a new rental building is in excess of $39,000.

The loss of use of the property by us as a new residential home is in excess of $150,000.

The loss incurred by delayed construction, and damage is in excess of $30,000.

The losses above include damages to our rental business reputation, and resale value.

Punitive damages: $1,000,000.

INTERROGATORY NO. 20. Please describe all injuries of any nature (e.g. physical, mental, emotional, etc.) that you are claiming in the Plaintiffs’ Complaint were caused by the occurrence or the actions of the Defendants and identify all persons or entities with whom you consulted or from whom you received treatments to address those injuries.

ANSWER: Ann and I worked full time jobs at the local (Fraser) paper mill, 43 years for me 30 years for Ann, and raised 3 children. During this time from 1980 to 1988 we had (5) five sideline businesses. This was all done with the goal that after our retiring from Fraser paper, we would build 5 residential homes that we could rent, or sell, in order to supplement our retirement during our “Golden Years.” However, because of Roger Collin and his association’s influence on the town government, Collin was successful in pressuring the town to bring many meritless enforcement actions against us, in violation of our Due process, and equal protection rights. These illegal actions by the Town has literally shattered our lives, financially, emotionally, mentally, and physically. A simple review of the meetings, meritless code violations, and lawsuits by the Town and its employees against us speaks volumes. In spite of all these rights violations against us by the Town and its employees, they have never been successful with even one claim for violation of any rule, law, or ordinance.

Because Roger Collin and David Rouleau instigated most of these complaints against us at the onset, we pointed out obvious code violations they were guilty of, we successfully forced the town to enforce State law against Collin and Rouleau, albeit it with small fines, because the Town intentionally ignored serious State SZO rules and laws. The Town and its employees intentionally, willfully, and fraudulently retaliated against us with intentional acts in bad faith by filing meritless lawsuits for no other reason than to punish us for exercising fundamental rights guaranteed by the Constitution of Maine and the Constitution United States to petition Government.

INTERROGATORY NO. 21. Please state whether you currently suffer from injuries of any nature (e.g. physical, mental, emotional, etc.) that you are claiming in the Plaintiffs’ Complaint were caused by the occurrence or the actions of the Defendants.

ANSWER: Ann and I worked full time jobs at the local (Fraser) paper mill, 43 years for me 30 years for Ann, and raised 3 children. During this time from 1980 to 1988 we had (5) five sideline businesses. This was all done with the goal of after our retiring from Fraser paper, we would build 5 residential homes that we could rent, or sell, in order to supplement our retirement during our “Golden Years.” However, because of Roger Collin and his association’s influence on the town government, Collin was successful in pressuring the town to bring many meritless enforcement actions against us, in violation of our Due process, and equal protection rights. These illegal actions by the Town has literally shattered our lives, financially, emotionally, mentally, and physically. A simple review of the meetings, meritless code violations, and lawsuits by the Town and its employees against us speaks volumes. In spite of all these rights violations against us by the Town and its employees, they have never been successful with even one claim.

Because Roger Collin and David Rouleau instigated most of these complaints against us, we pointed out obvious code violations they were guilty of, we successfully forced the town to enforce State law against Collin and Rouleau with small fines, because the Town intentionally ignored serious State SZO rules and laws. The Town employees intentionally, willfully, and fraudulently retaliated against us with meritless lawsuits for no other reason than to punish us.

INTERROGATORY NO. 22. If you claim to have suffered a permanent impairment of any nature (e.g. physical, mental, emotional, etc.) as a result of the occurrence, please state the nature of the impairment, the areas of your body that have been affected, and the health care providers that have determined that the impairment is permanent.

ANSWER: I know of no measure for the sleepless nights, anxiety, stress, loss of freedom, and pursuit of happiness that the illegal acts by the Town and its employees have inflicted on us, that can even come close to describing how this has negatively affected our lives.

INTERROGATORY NO. 23. Please describe all injuries of any nature (e.g. physical, mental, emotional, etc.) that you have suffered or illnesses in the past 10 years, or conditions for which you have sought treatment from a health care provider in the past 10 years, and identify all persons or entities with whom you consulted or from whom you received treatments to address those injuries, illnesses, or conditions.

OBJECTION: Needlessly repetitive. Plaintiff objects to Interrogatory 23 on the grounds that it is overly broad, seeks information that is protected, and seeks information that is not likely to lead to the discovery of admissible evidence.

INTERRGATORY NO. 24. If you claim that your damages in this lawsuit include lost wages or lost income, please state the factual basis for your claim, the amount of wages or income you claim to have lost and the method by which the amounts lost were determined or calculated.

ANSWER: Needlessly repetitive. See Interrogatory No. 19. No claim for lost wages. Plaintiffs are both retired.

INTERROGATORY NO. 25. If you claim that your income earning capacity has been diminished as a result of the occurrence, please state the factual basis for your claim, the amount of damages you claim to have incurred due to your loss of earning capacity and the method by which your damages were determined or calculated.

ANSWER: Needlessly repetitive. See Interrogatory No. 19. No claim for lost wages. Plaintiffs are both retired.

INTERROGATORY NO. 26. If have ever made a claim (in any legal or administrative proceeding or pursuant to an insurance policy) for personal injury, workers compensation benefits, social security benefits, unemployment benefits or disability benefits, please describe the nature of the claim, the date the claim was made, the events that gave rise to the claim (including the dates the events occurred) and identify the other parties to the claim.

ANSWER: To my knowledge or memory, I do not recall of any such claims. However, we have made a claim for social security benefits, and do in fact receive social security benefits. We may have made claims for unemployment benefits. My claim might have been in 1971 during a labor dispute. Ann’s claim may have been in the late 1970’s and early 1980’s. We agree to execute an authorization to permit the Defendants to obtain copies of the responsive records.

INTERROGATORY NO. 27. If you have ever been convicted of a crime or pled guilty or nolo contendre to a criminal charge, please state the date of the conviction or plea, the charge that was the subject of the conviction or plea and the court in which the conviction or plea was entered.

ANSWER: None. No.

INTERROGATORY NO. 28. If you have received any payment or compensation from any person or entity for injuries or damages you claim resulted from the occurrence, please identify each person or entity from whom payment or compensation was received, the amounts of each payment or compensation and the dates on which the payments or compensation were received.

ANSWER: None.

INTERROGATORY NO. 29. Please identify by date each and every payment made to you or on your behalf by MaineCare or Medicare related to the injuries you claim are related to the incident that is the subject of the above captioned lawsuit, include in your answer the total amounts by date paid to you or on your behalf.

ANSWER: None. Needlessly repetitive. See attached document request for production.

INTERROGATORY NO. 30. Please identify all persons or entities you have provided with notice concerning the claims in the Plaintiffs’ Complaint or upon whom you have made demands concerning your claims, including in your answer the dates each notice or demand was made and the method by which each notice or demand was made.

ANSWER: See Notice of Claim served on parties dated November 17, 2016.

Dated: ____________________ ____________________________________

Richard Cayer

Dated: ____________________ ____________________________________

Ann Cayer

STATE OF MAINE

AROOSTOOK, SS. ___________________, 2019

Personally, appeared the above-named Richard Cayer and Ann Cayer, and upon oath stated that the above answers are true and correct to the best of their knowledge, information and belief.

Before me,

Notary Public/Attor

Why Town Government Fails

OUR CIVIL RIGHTS

The Long View of Local and State Politics

PART 2 ANSWER TO INTERROGATORIES

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