UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF MISSOURI

CENTRAL DIVISION

ROPERT GIPSON, )
Individually )
)
And )
)
ROBERT GIPSON, ) CASE NUMBER # 09 – 4136 – CV – C - NKL
as Next Friend of )
Casey Gipson, a minor child )
)
Plaintiffs, )
)
vs. )
Defendants, )

GOVERNOR OF MISSOURI )
JAY NIXON, in his official and individual
capacity )
)
)
RONALD LEVY, )
STATE OF MISSOURI DIRECTOR )
OF FAMILY SERVICES
in his official and individual
Capacity. )

JAMES HARRISON
STATE OF MISSOURI )
DIRECTOR OF CHILDREN’S DIV. )
OF SOCIAL SERVICES )
in his official and individual
Capacity.

DESIGNATED PRINCIPAL OF )
SOCIAL SERVICES
CELESTA SUE HARTGRAVES )
in her official and individual
Capacity. )
)
STEVE MORROW
MISSOURI CHILD ADVOCATE
in his official and individual
Capacity.

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BRYAN KINCAID
DESIGNATED PRINCIPAL OF )
SOCIAL SERVICES
in his official and individual
Capacity.

WILLIAM HAEFER; )
Circuit Manager, )
Benton County Children’s Division; )
in his official and individual
Capacity.
)
JAMES JOHNS, ATTORNEY FOR )
BRANDY WILKENSON WARREN, )
in his official and individual
Capacity.
)
BRANDY WILKENSON WARREN )
MOTHER OF CASEY GIPSON,
in her individual Capacity.

JASON WARREN
STEP FATHER OF CASEY GIPSON
in his individual Capacity.

HONARABLE JUDGE MICHAEL HENDRICKSON

30TH CIRCUIT JUDGE BENTON COUNTY MISSOURI
in his official and individual
Capacity.

OWNER AND OPERATORS

MYSPACE WEB SITE
in their official and individual
Capacity

ADMINISTRATORS
MYSPACE WEB SITE
in their official and individual
Capacity

MR LUTMAN
GAL FOR MINOR CHILD
in his official and individual
Capacity.

Defendants. )

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 COMPLAINT

PART #1

COMES NOW, Robert Gipson, pro se, and for his cause of action for the removal of Casey Ryan

Gipson’s picture from a Porn sex site on MYSPACE. Brandy Wilkenson, mother of Casey Gipson exploits sex

on the MYSPACE web site. Pictures, video, and advertisement as a sex coach is her marketing profile. This

brings discredit to the minor child when his picture is also on this web site. Defendants have had ample

opportunity to investigate the pictures and video of the Porn site on Brandy Wilkenson’s MYSPACE web site.

This is a Porn site and the minor child’s picture is posted for view by visiting customers. Robert Gipson

presented evidence to the Missouri Children’s Division, Benton County Sheriff’s Department and Honorable

Judge Michael Hendrickson. Defendants have protected Brandy Wilkenson and her husband Jason Warren at

the expense of the minor child. It is a Federal Violation to have pictures of children on a MYSPACE Porn site.

The owners and operators of MYSPACE has failed to monitor their Web site and has jeapordized the health and

welfare of the minor child Casey Ryan Gipson. Retaliation by the Benton County Sheriffs Department resulted

in harassment by means of arrest and civil rights violations against Robert Gipson. During the last court hearing

Judge Michael Hendrickson refused to remove the minor child’s picture from the MYSPACE PORN WEB

SITE. The GAL MR Lutman was also aware of this web site and did nothing. Mr. Lutman is presently the

GAL for the minor child. Mr Lutmans failure to protect the minor child is cause for dismissal. The Plaintiff was

subjected to excessive harassment during the June 2009 court hearing. Plaintiff was held by force and threat of

physical and mental abuse by Judge Hendrickson and the court Baliffs. The first court hearing consisted of five

Baliffs, two Prosecuting Attorneys and one person from the Missouri crime victims office who worked with

Karen Woodley the Benton County Prosecutor. This was nothing more than an imminent threat against

Plaintiff Robert Gipson. This threat infringed upon the integrity of the case and created a very hostile court

environment. This threat by court officials against the Plaintiff Robert Gipson violated his civil rights to a fair

trial and violated the Plaintiffs fourteenth amendment. This act of aggression against Plaintiff interrupted the

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normal course of justice. To this date July 15, 2009, Plaintiff continues to be oppressed by community

corruption. Plaintiff will never get a fair trial in the Benton County Missouri court house, nor in the Western

court of appeals. The attached documents also indicate a child and father who has endured excessive physical

and mental abuse. This abuse has been covered up by the Missouri Children’s Division, case workers and

supervisors. Mandated reporter, Psychologist and Defendant, Ms Erika Waller failed to report that the child

Casey Gipson was beat in the face and eye by his mother Brandy Wilkenson. Psychiatrist and Defendant Dr

Daniels from Columbia Missouri supervised Dr Waller. Both failed to report this abuse against the minor child.

Both were presented with many documents describing prior neglect and abuse against the minor child. Part one

and part two of Plaintiffs law suit identifies a consolidation of reports, pictures, video and CD to substantiate

Plaintiffs accusations against the Defendants. The first course of action requested by Plaintiffs is to remove

the minor child’s picture from the MYSAPCE porn site created and managed by Defendant Brandy Wilkenson

and her husband Defendant Jason Warren. The Defendants listed in part one and part two of this law suit

subjected the minor child to a life of hardship by ignoring obvious signs of neglect and abuse against the child.

Defendants, in their official and individual capacity to protect the minor child from harm as directed by the

United States Constitution, violated their oath of office. Defendants Brandy Wilkenson and Jason Warren

have conducted criminal activities against the minor child and Plaintiff Robert Gipson as stated in part one and

part two of this claim. Part one and part two of said claim relates to various Defendants who have violated the

civil rights of Plaintiffs. Part one and part two has attached supplemental evidence to support said claim.

Attached are photos, video, CD, medical documents, witness statements,and legal documents. Part one and

part two describes the actions of each Defendant, relief sought for by Plaintiffs, supplemental evidence, and

facts common to all counts.

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 JURISDICTION AND VENUE

1. This action is brought pursuant to the Constitution of the United States, particularly the

Fourteenth Amendment; the laws of the United States, particularly 42 U.S.C. §§ 1997.

2. This Court has federal jurisdiction under 28 U.S.C §§ 1331 and 1343 (a).

3. The events described herein took place in Benton County, Missouri. Hence, and MYSPACE

web site venue is proper within the Western District, Central Division under 28 U.S.C. § 1391 (b).

4. Plaintiffs request a jury trial.

5. Plaintiffs request protection by this court from any further civil rights violations

from the Benton County civil court.

6. Plaintiffs request a federal investigation into the complaints described in part

one and part two of this law suit.

7. Plaintiff request relief and preys that this court require all Defendants to take a voice analysis test and

that this court pay for such testing and investigation

PARTIES

8. The Plaintiff, Robert Gipson is a resident of Benton County, State of Missouri and is the natural

father of Casey Ryan Gipson.

9. Plaintiff Robert Gipson brings this action as the parent of Casey Ryan Gipson and as the next

friend of Casey Gipson, a minor child, who is currently legally unable to bring this cause to action himself.

10. Defendant William Haefer, was Circuit Manager of the Benton County Children’s Division,

office located in Warsaw, Missouri and was in such position at all times relevant to this lawsuit.

11. At all times relevant herein, Defendant William Haefer acted pursuant to the policies,

regulations, or decisions officially adopted or promulgated by Benton County, which acts may fairly be said to

represent official policy or were pursuant to the governmental custom of Benton County, and thereby the State

of Missouri.
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 12. Defendant Ron Levy, Director of the Missouri Family Services, was fully aware of this Porn

Site and failed the minor child miserably. The Defendant Ron Levy was at all times relevant here and assigned

by Governor Nixon to protect the children in Missouri from such neglect and abuse. Ron Levy received a CD

and video of the minor child showing neglect and abuse. Ron Levy and his staff of supervisors and case workers

failed to protect Casey Ryan Gipson. Plaintiff Robert Gipson appeared in person in front of Ron Levy, Mr.

Kincaide, and Ms Hartgrave. Once again the evidence presented to the agency responsible for protecting

Casey Ryan Gipson failed to process the information. Their actions have been fruitless. They refused to

recognize the credibility of this evidence and failed to recognize the previous years of “ HOT LINE” calls and

reports of neglect and abuse against the minor child. Their inability to evaluate, investigate and conduct

interviews has done a disservice to the minor child and Plaintiff Robert Gipson.

13. At all times relevant herein, Defendants Jim Harrison, Steve Morrow, Nancy Parks, Ms Hendrickson,

Paula Neese, Ms Hartgrave, Ron Levy violated the civil rights of the Plaintiffs and failed the minor child. All

failed to enforce the policies, regulations, or decisions officially adopted or promulgated by Missouri Childrens

Division, which acts may fairly be said to represent official policy or were pursuant to the governmental custom

of the State of Missouri. All were aware of neglect and abuse hot line calls that go back to the year 2004.

14. Defendant Steve Morrow was at all times relevant herein, the Missouri Advocate for Missouri

and assigned by Governor Blunt. Steve Morrow communicated with Jim Harrison and was fully aware of the

Porn web site and other neglect and abuse issues against the minor child. A meeting was held with Jim

Harrison, Steve Morrow and Robert Gipson father of the minor child present. Robert Gipson showed Steve

Morrow a video of the minor child with Sleep Apnea and Obstructive Airway. In 2009, Steve Morrow stated to

Plaintiff Robert Gipson that he viewed the two recorded video of Casey Gipson that was taken at the safe house

interview. Brandy Wilkenson, Paula Woolery and Rhonda Talley scheduled and initiated two safe house

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interviews as a result to the false accusations that Plaintiff sexually molested his minor child. Chief Kinkinnon

of the Lincoln Police Department also testified on the witness stand that there is a video and it was placed in the

wall locker at the Benton County Court House. Plaintiff is aware of two safe house interviews where the minor

child Casey Gipson was taken. One was in Springfield Missouri and the other in Sedalia Missouri. Plaintiff was

accused of being the perpetrator on two separate false accusations of sexual abuse Steve Morrow was first

contacted in Nov 2006 when the Plaintiff was accused of sexually molesting his minor child. Mr. Morrow was

hired by Matt Blunt. Both were aware of the issues with Casey Gipson and made a fruitless attempt to help this

child. the Plaintiff informed Mr. Morrow that the minor child was presented with a CPAC from the Respiratory

Doctor in Columbia Missouri after an emergency room visit. Again, 2008 and 2009 Mr. Morrow was

contacted by Plaintiff Robert Gipson as stated.

15. GOVERNOR OF MISSOURI

JAY NIXON, in his official and individual
capacity
Defendant, Governor Jay Nixon was at all times relevant herein, the Governor assigned Ron

Levy as the Director of the Missouri Division of Family Services. Governor Nixon assigned Ron Levy to over

see the work of the entire Division and the supervisors within the Division. Governor Jay Nixon received

documents from Plaintiff Robert Gipson which contained information identifying child neglect and abuse.

Third parties to said claim also presented valuable evidence and documents. Governor Nixon failed to conduct

a proper investigation into the allegations reported by Plaintiff Robert Gipson. As a result, Plaintiffs Robert

Gipson and his minor child also Plaintiff Casey Ryan Gipson by and through his father have come under attack

by various government workers from the Missouri Children’s Division. Request by Plaintiff Robert Gipson to

meet with Governor Jay Nixon has been ignored. Numerous documents presented to Governor Jay Nixon

identifying child neglect and abuse against the minor child Casey Ryan Gipson has been ignored. This agencies

failure to act and protect Plaintiffs have resulted in recent abuse against the minor child Casey Ryan Gipson and

minor child’s father Robert Gipson. Governor Jay Nixon and his staff failed to protect Plaintiffs from the on

7
going blatant attacks from case workers and local police in Benton County Missouri. Plaintiffs Pleas for help

have not been answered. Since Jan 2009 and after Jay Nixon’s oath of office, Plaintiff Robert Gipson has

pleaded with the staff of Jay Nixon. Plaintiff Robert Gipson has personally visited the office of Jay Nixon and

his constituents’ staff. Plaintiff has been waiting since Jan 2009 for a response from Governor Jay Nixon and

his staff. This administration has failed to protect the Constitutional Rights of Plaintiffs. Plaintiffs have

reported numerous times of criminal violations against them by government workers from the Missouri

Children’s Division. It has been six months since Plaintiff Robert Gipson has reported to this new

administration of the criminal acts and conspiracy to cause mental and physical harm against Plaintiff Robert

Gipson and his son Casey Ryan Gipson. Governor Jay Nixon is a mandated reporter and has failed to repot and

protect the Constitutional Rights of Plaintiffs. The Right to pursue happiness without experiencing excessive

force has and continues to haunt Plaintiffs. In 2006 when then Attorney General Jay Nixon was in office,

Plaintiff and third party witnesses presented evidence and statements of neglect and abuse against the minor

child. Again, this information was ignored. Now that Jay Nixon is the governor of Missouri, he continues to

ignore the pleas from Plaintiffs. The new Attorney General Kristopher Koster has evidence and statements

from plaintiff and third parties that show good reasons to investigate Plaintiffs claims. This administration

failed to investigate the child neglect reports. This is a direct violation under the color of law under the

Missouri mandated reporting statutes and laws.

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16. JAMES HARRISON
STATE OF MISSOURI
DIRECTOR OF CHILDREN’S DIV.
OF SOCIAL SERVICES
in his official and individual
Capacity.

Defendant, Jim Harrison failed to investigate the evidence presented to him by Plaintiff. Mr. Harrison made

every attempt to obstruct justice prior to leaving his position with the Missouri Social Services Childrens

Division. Mr. Harrison was in a position to investigate such evidence and failed to do so. His actions violated

the civil rights of plaintiffs. His tenure with the Childrens Division created obstacles that prevented proper

leadership in order to conduct professional investigations. This lack of knowledge and disregard for policies

and procedures failed short. Mr. Harrison is mentioned in part one and part two of this claim. Mr. Harrison

, under color of authority and in their capacity as agents of the State of Missouri, individually and collectively

placed the Minor child’s health in jeopardy by ignoring the legitimate complaints by Robert Gipson and witness

Gina Swartz. The Missouri Childrens Division Defendants purposely ignored the complaints by Robert Gipson

Plaintiff and in so doing further neglected the well being of the minor child and did perpetuate the exposure of

the minor child to the Porn site on MYSPACE.

17. DESIGNATED PRINCIPAL OF

SOCIAL SERVICES
CELESTA SUE HARTGRAVES
in her official and individual
Capacity.

Defendant, Celesta Sue Hartgrave, is mentioned in part one and part two of Plaintiffs claim. Ms Hartgraves

relationship with Defendant Mr. Harrison makes her a party to this claim. Ms Hartgrave also failed to properly

investigate and evaluate various evidence and claims made by Plaintiff Robert Gipson. Her lack of skills

hindered her from assisting the minor child Casey Gipson and Robert Gipson.

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18. STEVE MORROW
MISSOURI CHILD ADVOCATE
in his official and individual
Capacity.
Defendant Steve Morrow, Missouri Children’s advocate, was at all times relevant herein, the

Missouri Advocate for Missouri and assigned by Governor Blunt. Steve Morrow communicated with Jim

Harrison and was fully aware of the Porn web site and other neglect and abuse issues against the minor child.

A meeting was held with Jim Harrison, Steve Morrow and Robert Gipson father of the minor child present.

Robert Gipson showed Steve Morrow a video of the minor child with Sleep Apnea and Obstructive Airway. In

2009, Steve Morrow stated to Plaintiff Robert Gipson that he viewed the two recorded video of Casey Gipson

that was taken at the safe house interview. Brandy Wilkenson, Paula Woolery and Rhonda Talley scheduled

and initiated two safe house interviews as a result to the false accusations that Plaintiff sexually molested his

minor child. Chief Kinkinnon of the Lincoln Police Department also testified on the witness stand that there is

a video and it was placed in the wall locker at the Benton County Court House. Plaintiff is aware of two safe

house interviews where the minor child Casey Gipson was taken. One was in Springfield Missouri and the

other in Sedalia Missouri. Plaintiff was accused of being the perpetrator on two separate false accusations of

sexual abuse Steve Morrow was first contacted in Nov 2006 when the Plaintiff was accused of sexually

molesting his minor child. Mr. Morrow was hired by Matt Blunt. Both were aware of the issues with Casey

Gipson and made a fruitless attempt to help this child. the Plaintiff informed Mr. Morrow that the minor child

was presented with a CPAC from the Respiratory Doctor in Columbia Missouri. The child was taken to the

Emergency room in Columbia after having Sleep Apnea and Upper respiratory infection in Plaintiffs car.

Plaintiff, once again has attempted to get the support from the Missouri advocate office. It appears that Mr

Morrow and his office staff is more concerned with federal funding than to helping children in Missouri. Again

in 2008 and 2009 Mr. Morrow was contacted by Plaintiff Robert Gipson. It has been now over two and half

years that Mr Morrow has known of such neglect and abuse against the minor child. Plaintiffs aks for relief to

assign another advocate in this position. Plaintiff request that Defendant Steve Morrow resign from his job as

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advocate for Missouri Children. Steve Morrow has not once prepared any reports and has failed to properly

investigate said claims. Steve Morrow is waisting the tax payers money and is not competent to hold such a

prestigious job such as protecting children from harm.

19. BRYAN KINCAID

DESIGNATED PRINCIPAL OF
SOCIAL SERVICES
in his official and individual
Capacity.

Defendant, Bryan Kincaid, assisted Mr. Ron Levy who is the director of the Missouri Social Services and

supervisor over Mr. Kincaid. Mr. Kincaid obstructed justice and investigations within the division. Defendant

ignored valuable evidence that was presented by Plaintiff Robert Gipson and other third party witnesses. Mr

Kincaid created a hostile environment. Plaintiff informed Mr. Kincaid that he refuses to communicate with him

or any other supervisor and demanded to schedule a meeting with Ms Debra Scott. This request was made after

case workers and supervisors failed to support the minor child and ignored obvious pictures of abuse and other

credible evidence. Mr Kincaid, Mr Levy and their staff created a hostile environment in their office when they

oppressed Plaintiff by having a police officer stalk the Plaintiff during a scheduled meeting in their office.

Defendant Bryan Kincaid is mentioned in part one and part two of this claim.

20. WILLIAM HAEFER;

Circuit Manager,
Benton County Children’s Division;
in his official and individual
Capacity.

Defendant, William Haefer, was inpostion at al times and had knowledge of the issues and complaints

presented by Plaintiff. Mr Haefer failed to supervise his workers and as a result the minor child was un

protected. Mr Haefer had ample opportunity to over see the work of his subordinates and failed to do so. AT no

time did Mr Haefer introduce a plan of action to reduce the pain and suffering that affected the minor child

Casey Ryan Gipson and Plaintiff Robert Gipson.

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21. JAMES JOHNS, ATTORNEY FOR
BRANDY WILKENSON WARREN,
in his official and individual
Capacity.
Defendant, James Johns, assisted his client and Defendant Brandy Wilkenson in bringing fraud upon the

court. Mr Johns and his client and mother of the minor child Casey Gipson were in contempt of court when they

deceived the court under oath on issues pertaining to the MYSPACE porn web site. The fruit of the forbidden

tree which is rooted in Defendants trial tactics has caused the Plaintiffs to suffer severely Defendant James

Johns has coached his client to lie on the witness stand. In 2007 James Johns was fully aware of the

MYSPACE porn site and in June 2009 coached his client to bring fraud upon the court. James Johns is a threat

to the minor child Casey Gipson. James Johns has mislead the 30th district court in Benton County Missouri.

James Johns has conspired with Brandy Wilkenson to bring slander against Plaintiff Robert Gipson. Mr Johns is

mentioned in part one and part two of this cliam.

22. BRANDY WILKENSON WARREN )

MOTHER OF CASEY GIPSON,
in her official and individual
Capacity.
Defendant, Brandy Wilkenson, mother of the minor child Casey Gipson created a MYSPACE web site. This

web site exploits sex and has live video and pictures that is available to be seen by young children. In 2007 and

as of June 2009, this site is still in existence. Plaintiff has pleaded with Defendant and the court to remove the

picture of his son Casey Gipson from this site. Defendant has full access to this site and Brandy Wilkenson is

the one who makes the adjustments to the site. Brandy Wilkenson and her disrespect for the minor child refuses

to remove the minor childs picture. Attached as MYSPACE exhibits one, two and three shows a porn web site.

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23. JASON WARREN
STEP FATHER OF CASEY GIPSON
in his official and individual
Capacity.
Defendant, Jason Warren, step father of Casey Gipson and husband of Brandy Wilkenson Warren has

assisted Ms. Wilkenson in her porn site activities. In his 2007 deposition, Mr. Warren refers to the sex coach

add created by Defendant Ms Brandy Wilkenoson. Attached as exhibit number twenty one is a deposition from

Mr Warren in 2007. Mr Warren once held Plaintiff and his son Casey Gipson hostage in Plaintiffs home in

2005. Mr.Warrens radical behavior is a threat to Plaintiffs. Mr Warren attempted to cut the tires of Plaintiff at

the store in Cole Camp Missouri. Attached are exhibits A,D, E, F, G,H, K, M, S, and X. These exhibits

illustrate the reckless behavior of Jason Warren. Plaintiff was once told by his child Casey Gipson “Mommy

got beat at the washing machine by daddy Jason and I tried to tell him no but he would not listen” another time

Casey Gipson told Plaintiff “Mommy told me to call 911 but it was dark outside and I was scarred”

Plaintiff wqas told by his child Casey Gipson “ Daddy Jason gives me medication but I am not supposed to tell

You.” Jason Warren and Brandy Wilkenson Warren have created a high risk environamnt for the minor child.

Their thhrest of physical and mental abuse against Plaintiffs are unwarranted. Their criminal activities will not

stop until they achieve their ultimate objective. Their objective is to sever the bond between the Plaintiffs and

embezzle money from Plaintiffs bank account. Jason Warrens threats and criminal activities are documented

back to 2003 and presently in 2009. Exhibit D, is a letter from Carol Dale, Plaintiffs sister. Ms. Dale
witnessed Defendant Jason Warren slamming a chair down in the living room at the childs house in Cole Camp

Missouri. This threat against Plaintiffs and his sister was the first of many more to follow. Plaintiffs fear for

their lives and seek protection from Jason Warren. Jason Warren sated to Plaintiff in October 2005, “You think

I am crazy now, you’re a dead man.” Jason warren was observed by Plaintiffs neighbor Shirley Kaiser beating

his wife Barndy Wilkenson in the front yard of Plaintiffs home in Lincoln Missouri.

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24. HONARABLE JUDGE MICHAEL HENDRICKOSN
30TH CIRCUIT JUDGE BENTON COUNTY MISSOURI
in his official and individual
Capacity.

Defendant, Honarable Judge,Michael Hendrickson refused to hear Plaintiffs Motions for a change of

Vinue. For three months in 2009 judge Hendrickson delayed hearing Plaintiffs Motion for Temporary

Custody of the minor child and Motion to Return Plaintiffs Constitutional Rights. Even though prior

judgments and rulings were handed down by judge Hendrickosn, Plaintiff was denied to be heard until a

GAL was assigned for the minor child. The present GAL Mr Lutman ignored Plaintiffs documents of the

Porn Site by Brandy Wilkenson and numerous medical reports that clearly showed the minor child in need

of medical attention. Plaintiff met with the Defendant, GAL in May-June and gave him pictures of the

injuries on the minor child. Plaintiff also gave Mr Lutman pictures of the Porn web site. In the June 2009

hearing in Benton County, the GAL not once asked Brandy Wileknson any questions about the minor child.

The GAL appears to have copied prior texts from the previous court judgment and used this text to favor

Brandy Wilkenson. Mr Lutman has failed to review all the prior medical documents that reveal Casey

Gipson does have prior reports of Sleep Apnea. Reports of URI Upper Respiratory Infection, Tonsil Idus,

Bronchitos. These medical reports are documented back to 2004, 2005. The GAL Mr Lutman ignored the

testimony from witness Gina Schwartz who testified about her observing the minor child with Sleep Apnea.

MR Lutman ignored testimony from Plaintiff Robert Gipson testifying that he took the child to the

Emrgency room on Jan 4, 2009. Plaintiff asked the GAL to retrieve the medical records from James Johns

and the video that shows the minor child in sever stress of Sleep Apnea. On July 4, 2009 Plaintiff observed

a burn on Casey Gipson’s neck. On Sunday July 12, 2009, Plaintiff was informed by the minor child that he

has poison Ivy. Plaintiff is restricted from observing his childs medical issues. This restriction puts the

childs health and welfare in danger. Plaintiff has been removed and alienated from his child to insure

Plaintiff can no longer report.

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25. OWNER AND OPERATORS
MYSPACE WEB SITE
in his official and individual
Capacity

Defendants, of MYSPACE has allowed Brandy Wilkenson to freely exploit sex on the internet. The

owner and operators of this agency has violated the civil rights of the minor child Casey Gipson

26. ADMINISTRATORS
MYSPACE WEB SITE
in their official and individual Capacity
Defendants, of MYSPACE has allowed Brandy Wilkenson to freely exploit sex on the internet. The

owner and operators of this agency has violated the civil rights of the minor child Casey Gipson. They allowed

pictures of minor children to be on the same web page where sex acts and exploiting sex were conducted and

revealed

27. MR LUTMAN
GAL FOR MINOR CHILD

Defendant, Mr Lutman failed to properly represent the minor child. Plaintiff Robert Gipson presented the GAL

Mr. Lutman credible evidence of the MYSPACE porn site created by Defendant and mother of Casey Ryan

Gipson the minor child. Mr. Lutman failed to review vital medical documents that indicated that Casey Ryan

Gipson the minor child had mild and severe Sleep Apnea. Mr Lutman Mr Lutman refused to come to Plaintiffs

home to conduct a home study. Mr Lutman ignored pictures of child neglect and abuse against the minor child.

Mr. Lutman has only appeared in one court hearing and has labled Plaintiff Robert Gipson as an unfit parent

who requires limited visitation with the minor child. Mr Lutman has conspired with James Johns to bring

slander against Plaintiff Robert Gipson. Mr Lutman has failed to review the case file of Plaintiffs and has acted

with unethical and bias opinions. Mr Lutmans lack of knowledge in trial preparation has been a disservice to

the minor child. His disregard to the health and welfare of the minor child has created a negative impact.

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 28.. At all times relevant herein, Defendants violated agency policies, and regulations. They failed to

properly investigate and interview parties of interest and ignored Plaintiffs pleas to help the minor child Casey

Ryan Gipson. These policies, decisions officially adopted or promulgated by the State of Missouri were

Maliciously ignored. which acts may fairly be said to represent official policy or were pursuant to the

governmental custom of the State of Missouri.

29. Relief is sought against each and every Defendant, jointly and severally, as well as their agents,

assistants, successors, employees, and persons acting in concert or cooperation with them, or at their direction

or under their supervision. Relief is also sought against insurance companies or company of any state

government agency mentioned in this law suit and any and all Townships, cities, Counties mentioned in this

claim. Also, any Defendants, government agencies or individuals not yet listed in this law suit that may have

contributed in violating the civil rights of Plaintiffs.

29. At all times relevant herein, Defendants have acted under the color of authority of

the law of the State of Missouri.

FACTS COMMON TO ALL COUNTS

30. In 2007, Brandy Wilkinson and Jason Warren did create a Porn site on MYSPACE. Attached

documents show a Porn site on MYSAPCE in 2007 and 2008 with blog entries and scheduled activities in 2008

and 2009.

31. Evidence was presented to the Benton County Sheriffs Department by Plaintiff Robert Gipson.

A chain of evidence log with attached pictures was also presented.

32. Evidence was presented to the Missouri Childrens Division along with a chain of evidence log in

2008. As was the CD and video of the minor child in distress.

33. In 2007, Jason Warren during a deposition testified that a web site was created and that this site

16
was on MYSPACE and did exploit sex.

34. The Children’s Division ignored the complaints from Plaintiff of the various neglect and abuse

accusations, this immediately was a cause for alarm. Complaints exposing the minor child to the Porn Site was

made by the Plaintiff and other witnesses. The Missouri Department of Childrens Division jeapordized the

Health and Welfare of the minor child. This denied to the minor child and Plaintiff Robert Gipson the rights

and privileges guaranteed by the United States Constitution including, but not limited to, the right to be

protected, to be free of invasion of bodily integrity and to be free from being denied their rights under the equal

protection clause of the Fourteenth Amendment.

35. Defendants, Jim Harrison, and others from the Missouri Childrens Division, under color of

authority and in their capacity as agents of the State of Missouri, individually and collectively placed the Minor

child’s health in jeopardy by ignoring the legitimate complaints by Robert Gipson and witness Gina Swartz.

The Missouri Childrens Division Defendants purposely ignored the complaints by Robert Gipson Plaintiff and

in so doing further neglected the well being of the minor child and did perpetuate the exposure of the minor

child to the Porn site on MYSPACE.

36. Defendants failed to do a thorough investigation of the complaints made by plaintiff and witnesses

regarding the Porn site on MYSPACE. The Government agencies described as Defendants and the Individuals

described as Defendants neglected and exposed the minor child Casey Ryan Gipson to a world of Pornography.

This is both child neglect and child abuse. Defendants individually and acting in concert with one another

conspired to deprive plaintiff his natural birth right to protect his child Casey Ryan Gipson. Specifically, the

defendants did, individually and acting in concert with one another committed or participated in the following

acts:

a. Ignored or refused to properly investigate the allegations of child neglect and exposure of the

child to a MYSPACE Porn Site.

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 b. Manufactured, or coerced, a court hearing to protect the mother from any criminal charges of

having pictures of children on her Porn site.

c. Defendants individually, collectively and all under color of authority, did use their positions to

maneuver against Plaintiff Robert Gipson to ignore crucial evidence which would have protected

the minor child from this Porn Site and other acts of physical and mental neglect..

d. .As of June 2009, the child’s picture and this MYSPACE Porn Site did exist. As of July 4, 2009,

the child had a burn on his neck.

e. Ignored or refused to properly investigate the allegations of child neglect as indicated in the

documents and pictures presented as evidence and exhibits.

f. Defendants violated their duties and ignored obvious signs of neglect and abuse against the

minor child during the dates 2002 thru 2009

g. Defendants for over six years have failed to protect the minor child.

h. Defendants from the Missouri Childrens Division for over six years have protected Brandy

Wilkenson from criminal prosecution and are in dereliction of their duties.

I. Defendants from the Children’s Division have a child in dire need of their protection from a high

risk environment.

Count I – Denial of Substantive Due Process

37. Plaintiffs restate and re-allege all allegations contained in the above captions and paragraphs of

this complaint as though fully set forth herein.

38. Plaintiffs cause of action against the above named defendants for the failure to investigate, and

refusal to remove Casey Gipson from the MYSPACE web site.

Denial of the substantive due process rights of Casey Gipson and the right to be protected, all of which

is a denial of his due process rights under the Fourteenth Amendment. Moreover, the minor child is in eminent

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danger due to the intentional misconduct of the defendant’s.

39. Defendants’ actions, as stated above, were reckless and outrageous and

subjected Plaintiff to loss of consortium with his child, damage to his business and personal reputations.

40. The acts of defendants under this count were under the color of state and federal law.

41. Plaintiffs are entitled to a recovery of reasonable attorney fees pursuant to

42 U.S.C. §1988.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount

that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for

punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable

attorney fees; and such other relief as may be granted by the Court.

Count II - 42 U.S.C. §1983 CONSPIRACY

42. Plaintiffs, for Count One of their complaint, incorporate by reference paragraphs and evidence

provided to this court.as if fully set forth herein.

43. This Count constitutes the claims of Plaintiffs with respect to all Defendants. Defendants acted

in concert against Plaintiff Robert Gipson to deprive him of his Civil Rights to protect his child Casey Ryan

Gipson.

44. Defendants used the power and prestige of their positions to investigate and discredit plaintiff

Robert Gipson as a part of this conspiracy.

45. The campaign by Defendants caused substantial emotional and financial

damages to Plaintiffs Robert Gipson and Casey Gipson,

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 45. Defendants’ actions, as stated above, were reckless and outrageous and

subjected Plaintiffs to loss of consortium with his child and personal reputations.

46. The acts of defendants under this count were under the color of state law.

47. Plaintiffs are entitled to a recovery of reasonable attorney fees pursuant to

42 U.S.C. §1988.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount

that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for

punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable

attorney fees; and such other relief as may be granted by the Court.

Count III – Missouri State Law Claim - Torturous Interference

48. Plaintiff, for Count Four of his complaint, incorporate by reference paragraphs and by evidence

presented to this court of this complaint as if fully set forth herein.

49. This Count constitutes the claims of Plaintiffs with respect to all Defendants.

50. Plaintiffs are father and son and Father Robert Gipson, prior to the acts of Defendants enjoyed a

close loving relationship with his son Casey Gipson who had joint physical custody. This permitted the .

Plaintiffs to have and maintain a close loving relationship and for father to protect son regarding his medical

needs and regarding his son’s exposure to domestic violence in the home of his Mother.

50. Each of the Plaintiffs had and enjoyed a close, loving and constitutionally protected relationship

and had the expectation that this relationship would continue.

51. Defendants were aware of the close relationship between the Plaintiffs and knew that only by

manufactured and dissemination of false, spurious and incendiary allegations could this relationship be severed
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in open court as Plaintiff Robert Gipson had joint custody and presumed by Missouri law RSMO.452.375 et

sec.. Defendants were aware of the nature, extent, closeness and constitutionally protected nature of Plaintiffs

relationship. Defendants’ actions were an intentional interference with the familial relationship and the

expectancy of Plaintiffs under the Constitution to such a familial relationship.

52. Defendants have no reasonable justification for their actions to interfere with the relationship and

plaintiffs’ expectation that it would continue unmolested. The means used to interfere with the relationship was

an unlawful and wrongful interference with plaintiff's constitutionally protected relationship. Such actions were

taken in the absence of malice, spite, or ill will.

53. Defendants’ conduct caused damage to plaintiffs’ constitutionally protected relationship.

54. Plaintiffs were damaged as a result of defendants’ actions.

55. Defendants used threats of criminal charges, defamatory information, misrepresentation of facts,

and abuse of the Court process to interfere with the Plaintiffs’ constitutional protected relationship.

56. Defendants’ actions, as stated above, were reckless and outrageous and subjected Plaintiffs to

loss of consortium with one another.

57. The derogatory and unfounded statements of Defendants caused Plaintiffs the loss of their

constitutional protected relationship.

58 Plaintiffs are entitled to a recovery of their reasonable attorney fees and

Punitive damages under Missouri Common Law for tortuous interference with their constitutionally protected

relationship. Plaintiff seeks relief in not being required to pay any fees for any lawyer hired by any defendant. It

was and continues to be the actions of said Defendants that so viciously created such hardship against Plaintiffs.

WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount

that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for

punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable
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attorney fees; and such other relief as may be granted by the Court. Plaintiffs reserve the right to use this

information in any future law suits in this court against any additional Defendants or government agencies.

Plaintiff Robert Gipson speaking for Plaintiff Casey Ryan Gipson states that the minor child Casey Ryan

Gipson be allowed full consideration to file any future law suit. Plaintiff Robert Gipson states that there may

become a time in the future when the minor becomes of age to file a civil suit against the Defendants listed or

the government agencies listed for their failure to protect him when at such a young age. When Casey Ryan

Gipson gets older he reserves the right to file suit if his present physical and or mental medical issues become

more severe or permanent. The Plaintiffs reserve the right to amend any part of this claim to include adding

additional Defendants and government agencies and third party witnesses. Plaintiffs reserve the right to address

and report additional significant events relevant to the claim in this law suit. Plaintiffs reserve the right to

amend, add, delete or quash any summery judgment against said claim. Also to bring forth motions, pleadings

and civil suit to be combined with the present claim being sought. Plaintiff’s state that the severity of the

atrocities brought against them could require additional amendments. Plaintiff Robert Gipson states that the

mental anguish caused by the Defendants and government agencies has caused PTSD. Plaintiff Robert Gipson

states that seven year aggressive and all out assault against his family, has and could forever devastate his future

life. Plaintiffs Bank account has been garnished. Funds that were exempt from garnishment were frauduantly

obtained by James Johns, Brandy Wilkenson’s lawyer. The second garnishment was executed with out any

court order. Bank of America allowed this transaction. Plaintiff was injured in Iraq. His Social Security

Disability check was re routed to Brandy Wilkenson without Plaintiffs knowledge. Brandy Wilkenosn with the

help from Mr Brown and staff workers from the Sedalia Missouri Social Security Office conspired to make

Brany Wilkenson the payee of Plaintiffs Disability check. Plaintiff was injured in Iraq and receives money for

his injuiries. Brandy Wilkenson and her lawyer James Johns have conspired to bring false accusations against

Plaintiff in order to obtain Plaintiffs money that was once used to support his child. Prior to such garnishment

of Plaintiffs money from his Social Security, Plaintiff provided financial support for the minor child in excess of

the money now being paid out. Garnishment was just another reason for Brandy Wilkenson to file false

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accusations against Plaintiff and file to modify the previous court orders. The garnishment of the Plaintiffs

SSI, and savings account was nothing short of a criminal crime. Plaintiff asks relief in the following.

1. Plaintiffs Gipson and minor child Casey Ryan Gipson be given consideration for a thorough and

complete Federal Investigation on all comaplints brought before this court.

2. A Congressional Investigation into the work ethics of the Defendants listed in the above caption and

their federal violations against the Plaintiffs.

3. Preliminary hearings scheduled at the earliest convenience

4. That this court put Defendants on Notice immediately and shorten their time to respond.

5. That this court considers this an emergency case and take actions to protect the minor child by taking

over jurisdiction and review all previous court hearings, transcripts, pleadings, motions, pictures, CD,

video, judges notes, all evidence submitted and or not submitted to any party, all supporting documents

of any kind legal or not legal, any and all information that is in the best interest of the minor child’s

health and welfare, all medical documents pertaining to the minor child, all audio calls made to the

Missouri children’s Hotline and all calls from Plaintiff Robert Gipson to the Benton County 9/11

Emergency Services.

6. Plaintiff reserves the right to amend this Complaint in order to present more evidence and add additional

Defendants and witnesses.

7. Plaintiff request that the court allow a place in the court house annex for all depositions and provide a

court reporter at no expense to the Plaintiffs.

8. Plaintiff asks for financial relief in filing this complaint and states that the actions of the Defendants

have caused a financial nightmare for the last seven years against the Plaintiffs.

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9. This Federal law suit is the direct result of the Defendants Malicious attacks on the Plainiffs.

10. Plaintiffs have suffered and have endured excessive mental anguish as a result of the actions and non

actions of Defendants.

11. Plaintiff Robert Gipson, father of Casey Ryan Gipson has gone through extensive mental therapy as a

direct result of Defendants failure to protect the minor child from neglect and abuse.

12. The Department of Veterans Affairs Psychologist and Civilian Psychologists have documented

testimony from Plaintiff Robert Gipson on the abuse and neglect against the minor child Casey Ryan

Gipson and the civil rights violations against both Plaintiffs.

13. The Defendants and Government agencies listed have violated their oath of office and have Maliciously

assaulted two innocent law abiding citizens.

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 SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS

BEGINNING WITH LETTER A THRU Z

A. Letter dated February 15, 2003 from Plaintiff Robert Gipson

B. Letter from Attorney Kathleen Shaul, letter dated April 13, 2004.

C. Letter from Attorney Rebecca Hain, dated June 3, 2004 to Childrens Division

D. Letter from Carol Dale, Plaintiffs sister, dated 2004

E. Letter to Dawn Long case worker, Warsaw Missouri, Benton County, dated Aug 3, 2004

F. Police reports from Plaintiff Robert Gipson dated October 23, 2005

G. Police report dated October 25, 2005 from Shirley Kaiser, neighbor of Plaintiff

H. Letter to Attorney Mr. Hayden dated on or about October 24, 2005

I. Plaintiffs motion dated Jan 3, 2007.

J. Plaintiffs motion dated Jan 4, 2007.

K. Plaintiffs motion dated Jan 4, 2007.

L. Attorney for Childrens division Roger Owensby dated Feb 6, 2007.

M. Psychologist Erika Waller interview with minor child Casey Gipson dated July 7, 2007

N. Plaintiffs character witness Shannon Noland dated Jan 18, 2007.

O. Character witness David Lambkin, dated Jan 18, 2007

P. Rev. Sam Hinkle, dated Jan 22, 2007.

Q. Sonja Frost, dated Feb 6, 2007

R. Plaintiffs letter dated May 28, 2008 to Dr Julie Cahill, Dr Robert Frederickson, Dr Stanley Wilson and Dr

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Jeffrey Sharp of the Family Medicine Associates and Family doctors who have treated and observed Casey

Ryan Gipson.

S. Plaintiffs Service Delivery Grievance dated November 25, 2008

T. Children’s Mercy Hospital Emergency Department/Minor Care Date January 4, 2009

. Jan 4, 2009. The minor child stopped breathing for approximately ten seconds and was taken to Kansas City

Childrens Mercy Hospital. Plaintiff Robert Gipson took his child to the Emergency room after observing him

with Sleep Apnea for two consecutive nights and after observing the child with a bloody nose at the Kansas

City Museum. The doctor’s report indicated a URI Upper Respiratory Infection.

U. Doctor report Dated Dec 23, 2008, Child is 3 1/2 Father of Casey Gipson has observed mild to severe

Sleep Apnea as the child sleeps. Father has observed the child since 2004 with OSA Obstructive Sleep Apnea

and congestion.

17 Nov 17, 2006, Obstruction and 100.3 temp. Jan 10, 2005, child has coughed.

V. E-MAIL’s and LETERS TO THE FOLLOWING PERSONS REQUESTING A

CONGRESSIONAL HEARING INTO THE UNETHICAL PRACTICES OF

THE MISSOURI CHILDRENS DIVISION AND MISSOURI FAMILY

SERVICES. DATED JANUARY 20, 2009 AND DELIVERED PERSONALLY

TO MISSOURI GOVERNOR JAY NIXON, ATTORNEY GENERAL CHRIS

KOSTER AND THE MISSOURI FAMILY SERVICES IN JEFFERSON CITY

MISSOURI ACROSS THE STREET FROM THE STATE CAPITAL IN

JEFFERSON CITY MISSOURI.

1. PRESIDENT OF THE UNITED STATES MR OBAMA

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 2. MISSOURI GOVERNOR JAY NIXON
3. MISSOURI ATTORNEY GENERAL CHRIS KOSTER
4. DIRECTOR OF MISSOURI FAMILY SERVICES RON LEVY
5. MISSOURI REPRESENTATIVE BRIAN NIEVES
6. MISSOURI SENATOR JANE CUNNINGHAM
7. MISSOURI SENATOR DELBERT SCOTT
8. MISSOURI REPRESENTATIVE TOM SELF
9. MISSOURI CHILDRENS DIVISION MS CELESTA HARTGRAVE
10. MISSOURI CHILDRENS DIVISION BRIAN KINKADE
11. MISSOURI CONGRESSMAN KIT BONDS
12. MISSOURI SENATOR CLAIRE MCCASKILL WASHINGTON DC

W. Plaintiffs Service Records. Proof of service. DDF 214 and Iraq tour of duty.

X. Plaintiffs Diary while in Iraq starting in March 2003 and ending Dec 27, 2003

Y.

Z.

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 SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS

MYSPACE PORN SITE WITH PICTURES OF THE MINOR CHILD

CASEY RYAN GIPSON AGE SIX

. MYSPACE PORN SITE of Brandy Wilkenson dated August 15, 2008 as Exhibit #1 presented by Robert

Gipson and witness dated on Feb 14, 2009. Presented as evidence on June 2009 in a hearing held in Benton

County Missouri with Honorable Judge Michael Hendrickson presiding. Consisting of twelve pages.

. MYSPACE PORN SITE, Exhibit #2, dated 2008. Eleven pages starting with Page 2 of 5 and last page 8 of 8.

MYSPACE Calendar of Brandy Wilkenson dated Aug 22. 2008

MYSPACE PICTURES

EXHIBT #1, 2 AND 3

A. The Picture on page# 1 of Exhibit #1 was copied by Robert Gipson on Feb 14, 2009. Sworn statement

identifies the same. Page number two dated Aug 15, 2008 shows the communication and web site

address of Brandy Wilkenson. This picture exploits sex.

B. Page number three dated Feb 17, 2009 shows a picture of Brandy Wilkenson. Bottom right is a typed

biography that Brandy Wilkenson wrote about herself. This biography is enlarged on the last page of

exhibit #1. This biography indicates the high risk environment that the minor child is subjected to.

C. Page #4, shows more sexual content, dated Feb 17, 2009. Prior to Feb 17, 2009, Brandy Wilkenson

created another web site exploiting sex in 2007.

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D. Page #5, dated Aug 15, 2008, shows the communication between Brandy Wilkenson and her friends.

The first and last blog identifies how Brandy Wilkenson hates being married and promoting her parties. .

E. Page #7 is an enlarged picture printed on Feb 14, 2009 by Plaintiff Robert Gipson

F. Page #8 is a live video of a women having sex with a dildo. This can be viewed by children as Brandy

Wilkenson’s web site is not restricted and allows anyone of any age to view the explicit sex acts and the

exploitation of sex and sex toys.

G. Page #9, dated Feb 17, 2009, shows the picture of the minor child Casey Gipson. Plaintiff request relief

from this court to have this picture removed and this web site restricted. Children should not have their

picture posted on this type of web site that exploits sex.

H. A chain of custody document presented to the Benton County Sherriff’s Department is attached in

binder #1. Binder number #1, also has part one of Plaintiffs complaint.

I. Plaintiffs complaint is also offered on digital CD format

J. Pictures of neglect and abuse is also offered by CD format

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 MYSPACE EXHIBIT

#2

K. Dated Aug 15, 2008, shows the flow of traffic coming to the web site and Brandy Wilkinson’s

communication with her clients to market her business.

L. Exhibit consists of eleven pages.

MYSPACE EXHIBIT

#3

Exhibit #3 shows the schedule of Brandy Wilkinson’s nightly activities when she was a sex coach and

exploiting sex. These schedules and the reckless life of Brandy Wilkenson subjected the minor child to a high

risk environment. The minor child was left with Jason Warren during these late night parties and in one

incident the minor child was locked outside his house and burned his hand on a stick from a fire with Jason

Warren present. The minor child informed Plaintiff that his ears were cold and there were no keys to get into the

house and his mommy was gone. . Plaintiff has been alienated from his child and can no longer protect his

child from neglect and abuse.

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 PICTURES OF CASEY RYAN GIPSON WHICH DISPLAY ABNORMAL AND EXCESSIVE

INJURIES OF NEGLECT AND ABUSE

EXHIBITS #15 THRU #21

15. Pictures were taken by Robert Gipson in Warsaw Missouri Benton County. Taken on or about Easter

2004. Taken at the Bunk House Lodge on HWY 65. Child was age two when these pictures were taken.

Pictures show a bruised head and nose. Exhibit consists of four pictures.

16. Pictures take by Robert Gipson in Lexington Kentucky on or about Dec 2005. Pictures show a burned

right arm. Plaintiff also observed the child with congestion and wet hair in this same picture. Exhibit

consists of three pictures.

17. Summer of 2008 pictures. Eleven pictures taken by Plaintiff Robert Gipson and developed Sept 2008.

Excessive bug bites on the child’s back, arm pit, legs, ear, buttocks, legs, rectum and inner thighs. poison

18. CD with pictures of the minor child Casey Ryan Gipson. These pictures were also presented to the

Missouri Childrens Division as was a video showing the child in mild to severe Sleep Apnea and other

chronic medical conditions.

19. Pictures taken by the Benton County Sherriffs Department. Beverly Chapman never prepared a report

on this burn. The minor child was burned by a cigarette on his right ear. Different stories were told on how

he got the burn. Days prior to this burn the child was taken to the emergency room by Plaintiff Robert

Gipson. The doctor at the Sedalia emergency room stated that Casey had Tonsil Idous. In her report, she

stated that the child is to stay away from smoke. She capiti;ized the word smoke in her report. Plaintiff

gave this report to Defendant Brandy Wilkenson. Days later the child was observed with a cigarette burn on

his ear. Brandy Wilkenson sated that Melissa burned Casey and Beverly Chapman stated that the

grandmother burned Casey. Plaintiff requested a copy of the police report and the Sherriff sated that they

had no report. A doctor at Dr Cahills office who is a mandated reporter failed to also make a report. By law

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any burn is to be reported to the authorities. None prepared any report and this was now the second burn

and numerous other neglect and abuse reports by Plaintiff and other concerned citizens.

20. Twenty nine pictures of Casey Gipson. High risk environment and poor health conditions.

21. . Deposition of Jason warren on July 27, 2009. Page #16, covers MYSPACE web site and issues of

Brandy Wilkenson being a sex coach. In June 2009, Defendant Brandy Wilkesnon stated that she does not

monitor the web site. She is the administrator and she is the one who markets and organizes her pictures

and video Page 17, Question 18 and answers 24 is nothing further from the truth. Brandy Wilkenson and

Jason Warren have for years violated the civil rights of Plaintiffs. They will stop at nothing to achieve their

goals. Brandy Wilkenson tried to stop Plaintiff Robert Gipson from having his name put on the child’s birth

certificate. She refused to tell the New York Division of Social Services who the childs father was. Brandy

Wilkenson once told the Plaintiff “I will move to Mexico”

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 STATEMENTS FROM PLAINTIFF ROBERT GIPSON

18. Plaintiff has video of the minor child from 2004 to Jan 2009 showing the child with mild to severe Sleep

Apnea, coughing, wet hair, excessive bug bites and skin poison.

19. The minor child was burned by an oven door, burned by a cigarette, burned by an open fire.

20. On July 4, 2009 the minor child was observed by Robert Gipson with a burn mark on his neck.

21. Plaintiff states that he has never seen the minor child sleep with out having mild or severe sleep apnea and

or congestion.

22. On July 5, 2009 Plaintiff observed Casey Gipson coughing at Wal-Mart in Warsaw Missouri. Plaintiff has

observed this type of cough and congestion since 2004. On Jan 4, 2009 Plaintiff took his child to the

emergency room. The minor child experinaced Sleep Apnea and Upper Respiratory Congestion.

23. Proof of military records of Plaintiff Robert Gipson

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 CERTIFICATE OF SERVICE

A copy of the foregoing was presented in person to: Clerk of the United States District

Court Western District of Missouri Central Division on this ______ day of______2009.

Respectfully submitted,

_____________________

Robert Gipson

105 South Center St

Lincoln, Missouri 65338

___________________

Robert Gipson

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