October 6, 2016

To:

Donald P. Pyle
Clerk of Crawford County, Kansas
PO Box 249
County Courthouse 2nd
Floor
Girard Ks 66713

NOTICE OF CLAIM
(Pursuant to K.S.A. 12-105(b)(d)

1.

Name and Address of Claimants:

Kasey King
PO Box 101
Opolis Ks 66760
Eric Muathe
1410 Bitner Terrace
Pittsburg, Ks 66762
Julie Stover
303 South Jefferson
Frontenac Ks 66763

2.

A Concise State of the Factual Basis of the Claim

a.

Date of Incidents: A couple weeks before October 29, 2015/and October 29, 2015

b.

Time of Incidents: During business hours of Saia Smile Center/ Friday night at Steve Kissane

c.

Place of Incidents: Saia Smile Center/Steve Kissanes private residence

d.

Circumstances of the act, omission, or event complained of:

On approximately 3 weeks on a Friday night prior to October 29, 2016 Crawford County Sheriffs
Deputy Stu Hite went by the private residence of Steve Kissane with another man in suits and ties and

Steve Kissane was not sure if they were K.B.I. officers, Federal marshalls, or Crawford County
Sherriffs. The only way that Mr. Kissane could identify any of the officers was that he knew Stu Hite
as acquaintances since both Mr. Kissane and Stu Hite have been living in the Crawford
County/Cherokee County area for over twenty (20) years. Mr. Hite went by Mr. Kissanes private
residence without a search warrant or court order from a judge in the private grand jury sealed case
of 2015MR2P to ask Mr. Kissane if he actually signed grand jury petition or if Kasey King, Julie Stover,
or Eric Muathe forged his name since they were listed as carriers on the petition. Mr. Hite informed
Mr. Kissane that they were going around checking signatures to make sure that people actually signed
the grand jury petition and that there names were not signed or that Kasey King, Julie Stover, and Eric
Muathe would be arrested for forgery and fraud. Mr. Kissane informed Stu Hite and the man in the
black suit that he did indeed sign the grand jury petition but after this incident Steve Kissane was
scared to be part of the federal lawsuit in case number 16-cv-2108 where the plaintiffs are
represented by attorney Prince Adebayo Ogunmeno from Kansas City, Kansas 66102.
On October 29, 2015 Stu Hite went to Connie Gibbs private place of employment at Saia Smile Center
without a search warrant or court order from a judge in the private grand jury sealed case of
2015MR2P to ask her if she knew Eric Muathe, Kasey King, and Julie Stover and if she actually signed
the grand jury petition or if Kasey King, Eric Muathe, or Julie Stover forged her name. Connie Gibbs
informed Stu Hite that she did know who Kasey King, Eric Muathe , and Julie Stover was and that she
did sign the grand jury petition. Stu Hite then informed Connie Gibbs that she should watch out being
associated with those three people because they had already taken Eric Muathes car and that the
Crawford County Sherriffs Department were taking his house next.
The way that Kasey King, Julie Stover, and Eric Muathe heard about these incidents is because Steve
Kissane is friends with Kasey King and has known Mr. King for over thirty (30) years from when Mr.
Kissane used to umpire baseball games that Mr. King played in when he was younger. Mr. Kissane
had informed another friend of Kasey King who had signed the grand jury petition in case number
2015MR2P Marc Doherty that the K.B.I. had came by his house and that they were looking to arrest
Kasey King, Eric Muathe, and Julie Stover for forgery and fraud from the grand jury petition they had
people sign. Marc Dohery then informed another carrier of the grand jury petition in case number
2015MR2P Travis Carlton that the K.B.I. had went by Steve Kissanes house looking to arrest Kasey
King, Eric Muathe, and Julie Stover for forgery and fraud because not everyone had really signed
signatures from the petition.
On October 31, 2015 Eric Muathe called Kasey King and informed him that the grandmother of his
children who is friends with Connie Gibbs told Eric that she heard from Connie Gibbs that Eric
Muathe, Kasey King, and Julie Stover were going to be arrested for forgery and fraud and that they
were going to take Erics house because they had already taken his car.
On October 31, 2015 the daughter of Connie Gibbs, Mikahila Gibbs who also was a signer of the
sealed grand jury petition in case number 2015MR2P called Julie Stover at approximately 7:30 p.m.
during a college football game that Julie Stover, Kasey King, and Eric Muathe were going to be

arrested for forgery and fraud because they had forged peoples name on the petition and they were
going to take Erics house because they had already taken his car.
Eric Muathe then contacted Connie Gibbs and printed off a color picture of the Crawford County
Sherriffs Department and took it to Ms. Gibbs and Ms. Gibbs identified Stu Hite as the man that came
to her private employment to harass her and interrogate her about signing the grand jury petition.
Connie Gibbs knew who Stu Hite was because Mr. Hites daughters take dance at the local YMCA and
Connie Gibbs daughter Mikahila Gibbs was the teacher of the dance class and Mr. Hites daughters.
Eric Muathe had the picture of the Crawford County Sherriffs Department with him and ran into
Steve Kissane at Wal-Mart and told Mr. Kissane what Eric Muathe had heard from Travis Carlton and
Marc Doherty that the K.B.I. went by Steve Kissanes private residence on a Friday night to interrogate
him and ask him if he signed the grand jury sealed petition in case number 2015MR2P or if Kasey King,
Eric Muathe, and Julie Stover forged his name.
Mr. Kissane informed Eric Muathe that it was indeed Stu Hite who came to his private residence on a
Friday night in October of 2015 to ask him if he signed the grand jury petition or if his name was
forged. Mr. Kissane then was approximately 90% he could identify the other officer who came by his
private residence and the officers name is ____________.
Dan Peak allowed Stu Hite to go investigate this matter because both are members of Lady of Lourdes
Church with the defendants Lori Bolton-Fleming, A.J. Wachter, and Robert Fleming in the private
grand jury sealed petition. Stu Hite is also a member of the private Crestwood Country Club along
with defendants in the private grand jury sealed case of 2015MR2P Lori Bolton-Fleming, A.J. Wachter,
Robert Fleming, and Kurtis Loy and that is why Crawford County Sheriffs Department conspired to
violate the private constitutional rights of Kasey King, Eric Muathe, and Julie Stover.
3.

The Name and Address of Public Officer or Employee, if known

1.

Dan Peak
Sheriff Crawford County, Kansas
225 N. Enterprise Drive
Girard, Ks 66743

2.

Deputy Sheriff Stu Hite

Crawford County Kansas Sheriff Department
225 N. Enterprise Drive
Girard, Ks 66743

3.

Crawford County Sheriffs Department

225 N. Enterprise Drive

Girard, Ks 66743
4.

A Concise State of the Nature and the Extent of the Injury Claim to have been suffered.
a.

Nature of the Claim

The claimant asserts the following claims:

1.
Violation of claimants civil rights under 42 U.S.C. Sections 1981, 1983, and 1985
through the First, Fourth and the Fourteenth Amendment to the United States Constitution,
2.

Defamation; including invasion of privacy, false light

3.

Negligence

4.

Negligence training

5.

Abuse of process, power, and authority

6.

Fraud

7.

Tortious Interference with Contractual Relations

8.

Supervisory Liability

9.

Municipal Liability

10.
Claimants reserves right to asset other legal theories of recovery as additional
information becomes available to claimants.
b.

The Extent of Injury:

The claimant, as a direct and proximate result of the actions and/or inactions of the
defendant,
suffered denial of constitutional and civil rights, equal protection of the law, indignity,
humiliation, damage to reputation and other damages for which they are entitled to compensatory
damages from responsible parties.
5.

A Statement of the Amount of Monetary Damages that is being requested:

State claims

$250,000.000

Federal claims

$350,000.000

Punitive damages

In am amount to be determined by the jury

Claimant reserves the rights to amend his damage claims as more information becomes
available to the claimant.
We look forward to your response to our settlement proposal shortly. Meanwhile, please
write if you need additional information, or if you have questions. We thank you so much for your
cooperation in the regard.
Sincerely yours,
Kasey King
Eric Muathe
Julie Stover