Escolar Documentos
Profissional Documentos
Cultura Documentos
FILED
12-10-2018
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN CIRCUIT COURT DANE COUNTY
2018CV000916
BRANCH 17
______________________________________________________________________________
and
v.
WISCONSIN SUPREME COURT, a governmental entity created by the Constitution of the State
of Wisconsin and empowered by Article VII thereof approved on February 1, 1848 and adopted
on March 13, 1848, as amended, from time to time, for facial and “as applied” unconstitutional
policies and procedures of the WISCONSIN SUPREME COURT and the LAWYER
1
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 2 of 102
REGULATION SYSTEM and for declaratory and injunctive relief allowed by Supreme Court of
Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
SUPREME COURT OF WISCONSIN
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
and
c/o Attorney General Brad Schimel
WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702
WISCONSIN SUPREME COURT, in its claimed capacity as the creator and overseer of the
LAWYER REGULATION SYSTEM, by repeal and re-creation of SCR Chapters 21 and 22 on
October 1, 2000, as amended from time to time thereafter, for facially and “as applied”
unconstitutional provision by declaratory and injunctive relief allowed by Supreme Court of
Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
2
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WISCONSIN SUPREME COURT, for claims of injury arising under Monell v. Department of
Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
LAWYER REGULATION SYSTEM
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
KEITH SELLEN, individually for his unlawful acts and omissions, as an employee of the
OFFICE OF LAWYER REGULATION and as supervisor of the employees and agents of the
OFFICE OF LAWYER REGULATION for claims of injury arising under Monell v. Department
of Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
LAWYER REGULATION SYSTEM, both facial and “as applied”
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served;
3
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ROBERT J. KASIETA, individually, as member of the Ninth District Ethics Committee of the
OFFICE OF LAWYER REGULATION and as investigator for the OFFICE OF LAWYER
REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, served by publication,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;
THERON EDWARD PARSONS IV, individually, as member of the Ninth District Ethics
Committee of the LAWYER REGULATION SYSTEM and/or the OFFICE OF LAWYER
REGULATION and as investigator for the OFFICE OF LAWYER REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served;
4
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LICHTFIELD CAVO, LLP, an Illinois limited liability partnership, as agent for WELLS FARGO
BANK, N.A., and as Respondeat Superior for the actions of MARK RATTAN, by service upon
its registered agent at
LITCHFIELD CAVO, LLP
Mark W. Rattan, Registered Agent
13400 Bishop’s Lane, Suite 290
Brookfield, Wisconsin 53005-6224;
WELLS FARGO BANK, N.A., as Respondeat Superior for the actions of MARK W. RATTAN;
LITCHFIELD CAVO, LLP; and STEPHANIE L. DYKEMAN, agents for Wells Fargo Bank,
N.A. with its corporate headquarters at
WELLS FARGO BANK, N.A.
420 Montgomery Street,
San Francisco, California 94104
and at
WELLS FARGO BANK, N.A.
101 N. Phillips Avenue
Sioux Falls, South Dakota 57104
JOHN DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein;
JANE DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein; and
5
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PLEASE TAKE NOTICE that the Plaintiffs, Wendy Alison Nora (Nora), Christopher
King (King) and Roger Peter Rinaldi (Rinaldi), in propria persona, and, pursuant to Wis. Stat.
sec. 802.09(1), in the interests of justice. Hearing on this Motion will be held on January 22,
2018 at 1:30 p.m. The Motion will be heard by telephone, as permitted by Wis. Stat.
sec. 807.13(1), unless any party to the action advises the Court of his or her intent to appear no
less than one week before the date set for the hearing.
NOW COME Plaintiffs Wendy Alison Nora (Nora), Christopher King (King) and Roger
Peter Rinaldi (Rinaldi), in propria persona and respectfully move the Court to allow them to file
their Second Amended Complaint attached hereto as Exhibit A in the interests of justice.
In support of this Motion for Leave to File the Second Amended Complaint, Plaintiffs
2. Nora filed the initial Complaint in this action on April 10, 2018.
3. All Defendants named in the initial Complaint appeared by Assistant Attorney General
6
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4. Nora responded to the Motion to Dismiss and advised the Court that she intended to
avoid the argument regarding the application of the Notice of Claim statute, Wis. Stat. sec.
893.XXX by amending the initial Complaint to plead civil rights violations to which the Notice
5. In Felder v. Casey, 487 U.S. 131, 153, 108 S.Ct. 2302, 101 L.Ed.2d 123 (1988), the
In enacting § 1983, Congress entitled those deprived of their civil rights to recover
full compensation from the governmental officials responsible for those deprivations. A
state law that conditions that right of recovery upon compliance with a rule designed to
minimize governmental liability, and that directs injured persons to seek redress in the
first instance from the very targets of the federal legislation, is inconsistent in both
purpose and effect with the remedial objectives of the federal civil rights law. Principles
of federalism, as well as the Supremacy Clause, dictate that such a state law must give
way to vindication of the federal right when that right is asserted in state court.
5. Nora had been aware for some time before she filed her initial Complaint of the
desires or intentions of Christopher King (King) of Seattle, Washington and Roger Peter Rinaldi
(Rinaldi) of Bristol, in Kenosha County, Wisconsin to bring civil rights claims against the certain
6. King and Rinaldi claim to have been damaged by the conduct of the some of the
Defendants identified in Nora’s April 10, 2018 Complaint as well as by other participants in the
Wisconsin Lawyer Regulation System (LRS) who are alleged to have caused injury to Nora and
nongovernment actors acting in concert with them and influencing the state actors to conceal
7. King and Rinaldi joined in Nora’s timely filed First Amended Complaint.
7
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EXHIBIT A
PROPOSED SECOND AMENDED COMPLAINT
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 13 of 102
and
v.
WISCONSIN SUPREME COURT, a governmental entity created by the Constitution of the State
of Wisconsin and empowered by Article VII thereof approved on February 1, 1848 and adopted
on March 13, 1848, as amended, from time to time, for facial and “as applied” unconstitutional
policies and procedures of the WISCONSIN SUPREME COURT and the WISCONSIN
LAWYER REGULATION SYSTEM (LRS) and for declaratory and injunctive relief allowed by
Supreme Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
1
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WISCONSIN SUPREME COURT, in its claimed capacity as the creator and principal of the
WISCONSIN LAWYER REGULATION SYSTEM (LRS), by repeal and re-creation of SCR
Chapters 21 and 22 on October 1, 2000, as amended from time to time thereafter, for facially and
“as applied” unconstitutional provision by declaratory and injunctive relief allowed by Supreme
Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980),
WISCONSIN SUPREME COURT
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
WISCONSIN SUPREME COURT, for claims of injury arising under Monell v. Department of
Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
WISCONSIN LAWYER REGULATION SYSTEM (LRS),
WISCONSIN SUPREME COURT
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
2
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3
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KEITH SELLEN, individually for his unlawful acts and omissions, as an employee of the
OFFICE OF LAWYER REGULATION and as supervisor of the employees and agents of the
OFFICE OF LAWYER REGULATION for claims of injury arising under Monell v. Department
of Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
LAWYER REGULATION SYSTEM, both facial and “as applied”
Represented by the OFFICE OF THE ATTORNEY GENERAL, previously personally
served, appearing without moving to dismiss for lack of personal jurisdiction or
insufficient service of process;
ROBERT J. KASIETA, individually, as member of the Ninth District Ethics Committee of the
OFFICE OF LAWYER REGULATION and as investigator for the OFFICE OF LAWYER
REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, served by publication,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;
THERON EDWARD PARSONS IV, individually, as member of the Ninth District Ethics
Committee of the LAWYER REGULATION SYSTEM and/or the OFFICE OF LAWYER
REGULATION and as investigator for the OFFICE OF LAWYER REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;
4
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David M. Potteiger
WALCHESKE & LUZI LLC
15850 W Bluemound Road, Suite 304
Brookfield, Wisconsin 53005-6008;
who, at all times relevant to the proceedings, had his principal place of business at
BASS & MOGLOWSKY, S.C.
501 West Northshore Drive, Suite 300
Milwaukee, Wisconsin 53217;
BASS & MOGLOWSKY, S.C., as claimed agent for FIDELITY NATIONAL TITLE
COMPANY, and as Respondeat Superior for the actions of DAVID M. POTTEIGER and
STEVEN W. MOGLOWSKY, with its principal place of business at
BASS & MOGLOWSKY, S.C.
501 West Northshore Drive, Suite 300
Milwaukee, Wisconsin 53217;
SHERYL ST. ORES, Assistant Litigation Counsel, individually and as an employee of the
WISCONSIN OFFICE OF LAWYER REGULATION, with her regular business address at
Sheryl St. Ores
OFFICE OF LAWYER REGULATION
110 East Main Street, Suite 315
Madison, Wisconsin 53703;
5
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PAUL W. SCHWARZENBART, individually and in his capacity as retained counsel for the
OFFICE OF LAWYER REGULATION, acting as an agent for the WISCONSIN SUPREME
COURT with his regular place of business at
PAUL W. SCHWARZENBART
222 W. Washington Ave., Suite 900
Madison, Wisconsin 53703;
LISA C. GOLDMAN, individually and in her capacity as the Referee appointed by the
WISCONSIN SUPREME COURT, acting as an agent for the WISCONSIN SUPREME COURT
with her regular place of business at
Lisa C. Goldman
DAVEY & GOLDMAN
5609 Medical Circle, Suite 101
Madison, Wisconsin 53719;
6
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LICHTFIELD CAVO, LLP, an Illinois limited liability partnership, as agent for WELLS FARGO
BANK, N.A., and as Respondeat Superior for the actions of MARK RATTAN, STEPHANIE
DYKEMAN, and its former employee, BRAD MARKVARDT, with its principal place of
business located at
LITCHFIELD CAVO, LLP
250 East Wisconsin Ave., Suite 800
Milwaukee, Wisconsin 53202
personal service pending through its registered agent, C T Corporation System, 301 S. Bedford
Street #213, Madison, Wisconsin 53703;
WELLS FARGO BANK, N.A., in its corporate capacity and as Respondeat Superior for the
actions of MARK W. RATTAN, LITCHFIELD CAVO, LLP, and STEPHANIE L. DYKEMAN,
agents for Wells Fargo Bank, N.A. with its principal office located at
WELLS FARGO BANK, N.A.
420 Montgomery Street,
San Francisco, California 94104
and its corporate headquarter located at
WELLS FARGO BANK, N.A.
101 N. Phillips Avenue
Sioux Falls, South Dakota 57104;
JOHN DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein;
JANE DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein; and
NOW COME the Plaintiffs Wendy Alison Nora (hereinafter Nora), Christopher King,
(hereinafter King), Roger Peter Rinaldi (hereinafter Rinaldi), all in propria persona, but not as
7
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agents of each other, as well as any others who may join in this action or who may appear as
Intervenors, and for their Complaint against the Defendants named above, and Defendants yet to
1. This Court has general jurisdiction over the claims and the parties under Article
Seven, Section 8 of the Wisconsin Constitution, Wis. Stat. Chapter 133, Wis. Stat. sec. 146.84,
42 U.S.C. sec. 1983, 18 U.S.C. sec. 1961 et seq. and has subject matter jurisdiction over this
action.
2. This Court has personal jurisdiction over the Defendants named in the April 9, 2018
Complaint (the originally-named Defendants) which is hereby amended, all of whom were
3. The July 18, 2018 Motion to Dismiss does not challenge or reserve the right to
challenge personal jurisdiction over any of the originally-named Defendants or the sufficiency of
process upon any of them, and, therefore, objection to personal jurisdiction, if any, is waived.
4. Venue of this Court is proper because a substantial part of the conduct complained of
5. The majority of the Defendants named herein reside in or have their primary place of
6. All of the Defendants have substantial contacts with the State of Wisconsin.
7. Service of process on the new parties Defendant named in the October 9, 2018 First
Amended Complaint (the first set of newly named Defendants) is pending and, to the extent
8
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8. When this Second Amended Complaint is allowed to be filed, service of process upon
the Defendants who were not previously named in the original Complaint or the First Amended
Parties Plaintiff
9. Plaintiff Wendy Alison Nora (Nora) is an adult and is presently a resident of the
County of Dane, State of Wisconsin and has her principal business office at 310 Fourth Ave. S.,
Suite 5010, in Minneapolis, Minnesota and joins in this action as to Counts One, Two, Three,
Four, Five, Seven, Eight, Nine, Ten, Eleven, Twelve, Thirteen and Fourteen, below.
10. Plaintiff Christopher King, (hereinafter King) is an adult and is presently a resident of
the County of King, State of Washington and proceeds separately as to Count Six, and joins in
11. Plaintiff Roger Peter Rinaldi (hereinafter Rinaldi) is an adult and is a citizen of the
County of Kenosha, State of Wisconsin and joins in this action as to Counts Seven, Eight, Nine,
Convention on February 1, 1848 and adopted by the People on March 13, 1848, as amended from
time to time, for claims of injury arising from violations of the Plaintiffs’ constitutional rights
pursuant to Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and “as
applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT and
9
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13. The STATE OF WISCONSIN is subject to this action for declaratory and injunctive
relief as allowed by Supreme Court of Virginia v. Consumers Union of the United States, Inc.,
the Constitution of the State of Wisconsin, approved by the delegates to the Constitutional
Convention on February 1, 1848 and adopted by the People on March 13, 1848, as amended from
time to time, for claims of injury arising from violations of the Plaintiffs’ constitutional rights
pursuant to Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and “as
applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT and
15. The WISCONSIN SUPREME COURT is subject to this action for declaratory and
injunctive relief as allowed by Supreme Court of Virginia v. Consumers Union of the United
16. Defendant WISCONSIN SUPREME COURT does not enjoy absolute immunity for
its administrative action and is joined in its administrative capacity, for claims of injury arising
from violations of the Plaintiffs’ constitutional rights pursuant to Monell v. Department of Social
Services, 436 U.S. 658 (1978) for facial and “as applied” unconstitutional policies and
SYSTEM.
17. The WISCONSIN SUPREME COURT is subject to this action for declaratory and
injunctive relief as allowed by Supreme Court of Virginia v. Consumers Union of the United
10
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18. Defendant WISCONSIN SUPREME COURT is joined in its legislative capacity, for
a determination of the constitutionality of certain provisions of SCR Chapters 21 and 22 and for
injunctive relief under the authority of Supreme Court of Virginia v. Consumers Union of the
for declaratory and injunctive relief under the authority of Supreme Court of Virginia v.
covered by the prohibitions set forth in the Wisconsin Organized Crime Control Act (WOCCA)
at Wis. Stat. sec. 946.80-946.88 by the express terms of Wis. Stat. sec. 946.82(2) and is liable for
the conduct of its employees and agents in violation of the predicate acts of racketeering defined
at Wis. Stat. sec. 946.82(4) in its supervisory capacity pursuant to Wis. Stat. sec. 946.83 and/or
946.85.
21. Defendant WISCONSIN SUPREME COURT does not enjoy absolute immunity in
its supervisory capacity as a matter of law under Wis. Stat. sec. 946.83 and/or 946.85 and is
specifically liable for violations of Wis. Stat. sec. 946.80-946.87 under Wis. Stat. sec. 946.82(2).
22. Defendant Chief Justice Patience D. Roggensack, is the Chief Justice of the
Defendant WISCONSIN SUPREME COURT and Chief Justice Roggensack is joined in her
supervisory capacity for the acts in violation of Wis. Stat. secs. by participants in the LAWYER
23. Chief Justice Patience D. Roggensack, is the Chief Justice of the Defendant
11
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WISCONSIN SUPREME COURT and Chief Justice Roggensack is joined in her administrative
capacity for failure to train and supervise the various components of the WISCONSIN
LAWYER REGULATION SYSTEM (LRS) to assure that it operates as required by the United
States Constitution and the Wisconsin Constitution, to the extent that SCR Chapters 21 and 22
24. The Defendant WISCONSIN SUPREME COURT was created by the Wisconsin
Constitution in 1848 and has original jurisdiction over certain matters and is the highest level of
25. In accordance with amendments to Article Seven of the Wisconsin Constitution, the
Defendant WISCONSIN SUPREME COURT is part of the Wisconsin Unified Court System.
26. Upon information and belief, the Defendant WISCONSIN SUPREME COURT
created the LAWYER REGULATION SYSTEM (LRS) without any legislative or executive
27. Upon information and belief, the Defendant WISCONSIN SUPREME COURT
claims the authority to create and operate the WISCONSIN LAWYER REGULATION
29. OLR operates both the investigative process and the prosecutorial process of the LRS
30. The WISCONSIN SUPREME COURT acts through and is responsible for
supervising the Preliminary Review Committee (PRC) and the preliminary review panels
12
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31. The WISCONSIN SUPREME COURT also acts through and is responsible for
appointing the referees to conduct disciplinary proceedings under SCR 22.14(3) and is, therefore,
32. In its claimed inherent authority, the WISCONSIN SUPREME COURT purports to
have endowed referees with the powers of circuit court judges, presiding in civil matters. SCR
33. The WISCONSIN SUPREME COURT acts as the appellate court in lawyer
34. The WISCONSIN SUPREME COURT, acting through its agents, is the
investigating, charging, and prosecuting authority, its appointed agent as referee is the trier of
35. Defendant Keith Sellen (Sellen) is an adult resident of Dane County, Wisconsin,
whose principal business address is in Dane County, Wisconsin at OLR, 110 East Main Street,
36. At all times relevant to the acts, omissions, occurrences and transactions complained
38. Sellen is joined in his official capacity for failure to train and supervise the
employees and agents of the OLR to prevent violations of Wis. Stat. secs. 146.82(5)(c) and
146.84(1)(b), (bm) and 146.84(2)(a)2., which deprived Nora of her right to Equal Protection of
the Laws of the State of Wisconsin guaranteed by the Fourteenth Amendment to the United
13
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39. Sellen is joined in his individual capacity for violations of the civil rights of Nora,
40. Sellen is individually liable for his participation in the civil rights violations of the
Plaintiffs and for failing to prevent the violation of each of the Plaintiffs’ civil rights as described
herein.
41. Sellen is individually liable for his violations of the Wisconsin Organized Crime
Control Act (WOCCA) at Wis. Stat. sec. 946.82(4), for the purpose of concealing the operation
of the Fraudulent Foreclosure Enterprise in the State of Wisconsin in which the property rights of
Wisconsin residents and citizens have been taken as the result of false pleadings, supported by
to investigate the operation of the Fraudulent Foreclosure Enterprise hereinafter referred to as the
42. Sellen is joined in this action in his individual capacity for his acts in furtherance of
43. Defendant Travis J. Stieren (Stieren) is an adult resident of Dane County, Wisconsin,
who is employed as an Investigator for OLR and whose primary place of business is located at
44. At all times relevant to the acts, omissions, occurrences and transactions complained
of herein, Stieren was an employee of OLR and Sellen was his ultimate supervisor.
45. Stieren is joined in his individual capacity for his violations of Wis. Stat. secs.
14
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146.82(5)(c) and 146.84(1)(b) or (bm) and 146.84(2)(a)2. which deprived Nora of her right to
Equal Protection of the Laws of the State of Wisconsin guaranteed by the Fourteenth
46. Stieren is joined in his individual capacity for his violation of Nora’s right to be free
from unreasonable searches and seizures guaranteed by the Fourth Amendment to the United
47. Stieren is individually liable for his violation of Nora’s rights to Due Process
guaranteed by the Fourteenth Amendment to the United States Constitution and Article One,
48. Stieren is joined in this action in his individual capacity for his acts in furtherance of
LEGAL GROUP, LLC, 559 D’Onofrio Drive, Suite 222, Madison, Wisconsin 53719-2842.
50. At all times relevant to the acts, omissions, occurrences and transactions complained
of herein, Kasieta was a member of the District Nine Ethics Committee created under SCR
51. Kasieta is joined in his individual capacity for his violations of Wis. Stat. secs.
146.82(5)(c) and 146.84(1)(b) or (bm) and 146.84(2)(a)2. which deprived Nora of her right to
Equal Protection of the Laws of the State of Wisconsin guaranteed by the Fourteenth
52. Kasieta is joined in his individual capacity for his violation of Nora’s right to be free
15
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from unreasonable searches and seizures guaranteed by the Fourth Amendment to the United
53. Kasieta is individually liable for his violation of Nora’s rights to Due Process
guaranteed by the Fourteenth Amendment to the United States Constitution and Article One,
54. Kasieta is joined in this action in his individual capacity for his acts in furtherance of
55. Defendant Theron Edward Parsons IV (Parsons) is an adult resident of Dane County,
Wisconsin, who, upon information and belief, does business is in Dane County, Wisconsin at
702 N. Blackhawk Ave., Suite #104, Madison, Wisconsin 53705 and/or at Midwest Center for
Human Services, 313 Price Place, Suite 10, Madison, Wisconsin 53705 .
56. Upon information and belief, at all times relevant to the acts, omissions, occurrences
and transactions complained of herein, Parsons was a member of the District Nine Ethics
Committee created under SCR Chapter 21 and purporting to function pursuant to SCR
Chapter 22.
57. Parsons is joined in his individual capacity for his violations of Nora’s rights to
Equal Protection of the Laws of the State of Wisconsin under Wis. Stat. secs. 146.82(5)( c) and
146.84(1)(b) or (bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United
58. Parsons is joined in his individual capacity for the unreasonable search and seizure of
Nora’s confidential medical information by the knowing unlawful disclosure thereof without her
consent required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the
16
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59. Parsons is joined in this action in his individual capacity for his acts in furtherance of
Wisconsin, whose residence is in Waukesha County and whose principal business address is in
Waukesha County, Wisconsin at HANNAN LEGAL, LLC, 1701 Pearl Street, Suite 11M,
61. From on or about July 1, 2011 to on or about June 30, 2013 (the period relevant to
the acts, omissions, occurrences and transactions complained of herein as to Hannan), Hannan
was the Chairperson of the Preliminary Review Committee (PRC) established by the Wisconsin
Supreme Court under SCR Chapter 21 and purporting to function pursuant to SCR Chapter 22.
62. Hannan is joined in his individual capacity for his violations of Nora’s rights to
Equal Protection of the Laws of the State of Wisconsin under Wis. Stat. secs. 146.82(5)(c) and
146.84(1)(b) or (bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United
63. Hannan is joined in his individual capacity for the unreasonable search and seizure of
Nora’s confidential medical information by the knowing unlawful disclosure thereof without her
consent required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the
64. Hannan is joined in this action in his individual capacity for his acts in furtherance of
17
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Wisconsin, is admitted to practice law before the Wisconsin Supreme Court and is believed to be
66. Potteiger is joined in this action in his individual capacity for violations of Wis. Stat.
secs. 146.84, 943.20(1)(d), 943.38(1), 946.30, 946.30, 946.82(4) incorporating 18 U.S.C. secs.
1341, 1343, via 18 U.S.C. sec. 1961(1), and as a former employee of BASS & MOGLOWSKY,
S.C. (BASS & MOGLOWSKY), 501 West Northshore Drive, Suite 300, Milwaukee, Wisconsin
53217.
(RFC) in a foreclosure action against Nora’s home located at 6931 Old Sauk Road, in Madison,
Wisconsin 53717 in Dane County Circuit Court Case No. 2009CV001096 titled Residential
69. Potteiger testified on April 5, 2016 that BASS & MOGLOWSKY was retained by an
70. There is not now and never has been an entity known as “GMAC RESCAP” in
existence.
71. Potteiger is joined in this action in his individual capacity for his acts in furtherance
72. One of the techniques used by the Fraudulent Foreclosure Enterprise is to falsely
73. Whoever wrote the PER CURIAM Opinion and Order of Wisconsin Supreme Court
intentionally conflated the identities of the Plaintiff in the foreclosure action, Residential Funding
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Company, LLC (RFC) with GMAC Mortgage Company, LLC (GMACM), which Nora identified
as the servicing agent responsible for negotiating the Loan Repayment Agreement (Agreement)
into a blended entity, RFC/GMAC, and attributed knowledge of the relationship between RFC
and GMACM (identified by the Court as GMAC) to Nora which Nora did not and does not have.
RFC was the Plaintiff and its relationship to GMACM was unknown to Nora at the time of the
74. The Agreement was negotiated with a representative of GMACM, which was not a
party to the foreclosure action, was not known to be represented by Potteiger and was known to
by Nora to be the successor in interest to Homecomings Financial, LLC, the servicing agent for
76. Moglowsky is joined in this action in his individual capacity for violations of Wis.
Stat. sec. 146.84 and as an employee of BASS & MOGLOWSKY, S.C., 501 West Northshore
Drive, Suite 300, Milwaukee, Wisconsin 53217, as claimed agent for FIDELITY NATIONAL
TITLE COMPANY, and as supervisor of Potteiger for statutory liability pursuant to Wis. Stat.
secs. 946.83 and 946.85 and under the doctrine of Respondeat Superior for Potteiger’s violations
77. Moglowsky is joined in this action in his individual capacity for his acts in
furtherance of the Fraudulent Foreclosure Enterprise, including, but not limited to allowing the
email server of BASS & MOGLOWSKY, S.C. to be destroyed while litigation was pending or
falsely stating that the email server had been destroyed, if it was not.
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78. Defendant BASS & MOGLOWSKY, S.C., c/o Steven M. Moglowsky, Registered
Agent, 501 West Northshore Drive, Suite 300, Milwaukee, Wisconsin 53217, is a Wisconsin
professional corporation.
79. BASS & MOGLOWSKY, S.C. is joined in this action as claimed agent for
FIDELITY NATIONAL TITLE COMPANY, and as supervisor of Potteiger and Moglowsky for
statutory liability pursuant to Wis. Stat. secs. 946.83 and 946.85 and for violations of Wis. Stat.
sec. 146.84 by Potteiger and Moglowsky under the doctrine of Respondeat Superior.
Northland Drive, Suite 200 Mendota Heights, Minnesota 55120, with its corporate headquarters
FORECLOSURE AND BANKRUPTCY SERVICES located at 1270 Northland Drive, Suite 200
Mendota Heights, Minnesota 55120, with its affiliate LENDER PROCESSING SERVICES,
INC. (LPS), next known as BLACK KNIGHT FINANCIAL, LLC and now known as BLACK
KNIGHT, INC., through its subsidiary, DOCX and through its own employees, forged over one
million (1,000,000) Assignments of Mortgages and other false documents to further the operation
of the Fraudulent Foreclosure Enterprise and transmitted the forged documents by mail and wire
for filing in public land records throughout the United States of America.
82. A forged allonge to Nora’s Note was created by LPS and was transmitted to Nora
from Potteiger by U.S. mail on or about June 17, 2009 in furtherance of the Fraudulent
Foreclosure Enterprise.
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83. FIDELITY NATIONAL TITLE COMPANY is joined in its corporate capacity for its
participation in the Fraudulent Foreclosure Enterprise and as Respondeat Superior for the actions
CORPORATION SYSTEM, 818 W 7th Street, Suite 930, Los Angeles, California 90017.
85. Defendant Sheryl St. Ores (St. Ores) is an adult resident of the State of Wisconsin
86. St. Ores joined in this action in her individual capacity for her participation in the
Fraudulent Foreclosure Enterprise while pretending to act as assistant litigation attorney for the
located at 110 East Main Street, Suite 315, Madison, Wisconsin 53703.
88. Schwarzenbart is joined in this action in his individual capacity for his participation
in the Fraudulent Foreclosure Enterprise while pretending to act in his official capacity as
Retained Counsel for the WISCONSIN OFFICE OF LAWYER REGULATION with his
principal place of business at c/o STAFFORD ROSENBAUM, LLP, 222 W. Washington Ave.,
89. Defendant Lisa C. Goldman (Goldman) is an adult resident of the State of Wisconsin
90. Goldman’s principal place of business is c/o DAVEY & GOLDMAN, 5609 Medical
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91. Goldman is joined in this action in her individual capacity for her extrajurisdictional
Wendy Alison Nora (Office of Lawyer Regulation v. Nora), Appeal No. 2013AP000653-D
(hereinafter Nora) when she was actually biased, against Nora because she is required to
92. Goldman was appointed to act as the referee in Nora #1 and was purportedly granted
the powers of a circuit court judge in the trial of a civil matter under SCR 22.16(1), but she has
never been elected to serve as circuit court judge, has never received the training provided to
circuit court judges and the oath she signed is not the oath required of circuit court judges in the
State of Wisconsin.
93. Goldman prevented Nora from being able to be present her defense in the
disciplinary proceedings in violation of First Amendment Rights to petition the judiciary for
redress of grievances guaranteed by the First Amendment to the Constitution of the United States
and Article One, Section 3 of the Constitution of the State of Wisconsin and in violation of
Nora’s Due Process Rights guaranteed by the Fourteenth Amendment to the Constitution of the
United States and Article One, Section 1 of the Constitution of the State of Wisconsin.
94. Goldman is joined in her individual capacity for her acts in furtherance of the
Fraudulent Foreclosure Enterprise in which she repeatedly violated Wis. Stat. sec. 946.12(3) to
Wisconsin and is joined in his individual capacity because he purported to act as the referee in In
re the Disciplinary Proceedings Against Wendy Alison Nora (Office of Lawyer Regulation v.
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Nora), Appeal No. 2015AP002442-D (hereinafter Nora #2) without subject matter jurisdiction or
competency to proceed under SCR Chapter 22 on and after August 16, 2016.
96. Winiarski is joined in his individual capacity because he was without subject matter
jurisdiction or competency to proceed under SCR 22.11 effective August 16, 2016, the date upon
which he purported to allow OLR to file the Second Amended Complaint in Nora #2 setting forth
facts for which the preliminary review panel had not found cause to proceed, contrary to SCR
22.11(2).
97. Winiarski was purportedly granted the powers of a circuit court judge in the trial of a
civil matter under SCR 22.16(1), but he has never been elected to serve as circuit court judge, has
never received the training provided to circuit court judges and, upon information and belief, the
oath he signed is not the oath required of circuit court judges in the State of Wisconsin.
98. After allowing OLR to file a Second Amended Complaint in Nora #2 on August 17,
2016 which had not been authorized by a preliminary review panel of the Preliminary Review
Committee (PRC) under SCR 22.06 and SCR 22.07, shortly before the date set for the pre-
hearing final conference set for August 30, 2016, Winiarski entered multiple orders intended to
deprive Nora of her right to defend herself in Nora #2 in violation of Nora’s Due Process Rights
guaranteed by the Fourteenth Amendment to the Constitution of the United States and Article
99. Winiarski is joined in this action in his individual capacity for his acts in furtherance
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102. Rattan is admitted to practice law before the Wisconsin Supreme Court and is
subject to the requirements of the Wisconsin Code of Professional Conduct at Chapter 20 of the
103. Rattan’s principal place of business is c/o LITCHFIELD CAVO, LLP, 250 East
104. On March 22, 2017 and March 23, 2017, Rattan appeared at the extrajurisdictional
evidentiary hearing conducted by Winiarski in Nora #2 as counsel for one of OLR’s witnesses,
Attorney Stephanie L. Dykeman, who represents WELLS FARGO BANK, N.A. (WELLS
FARGO) and claims to represent a Real Estate Mortgage Investment Conduit (REMIC) Trust of
which HSBC Bank USA, N.A. was purportedly the Trustee in actions and proceedings involving
Rinaldi’s Homestead.
105. Rattan is joined in his individual capacity for disrupting the extrajurisdictional
evidentiary hearing in Nora #2 by assaulting King for the purpose of preventing King from
reporting on the public activities and events in Nora #2 in violation of King’s rights under the
First Amendment to the United States Constitution and Article One, Section 4 of the Wisconsin
Constitution.
106. Rattan is joined in his individual capacity for disrupting the extrajurisdictional
evidentiary hearing in Nora #2 by assaulting King for the purpose of interfering with Nora’s
rights to proceed to make her record at the public hearing in Nora #2 in violation of Nora’s rights
under the First Amendment to the United States Constitution and Article One, Section 3 of the
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Wisconsin Constitution.
107. Rattan is joined as agent for WELLS FARGO and in his individual capacity for his
109. Dykeman’s principal place of business is 250 East Wisconsin Ave., Suite 800,
110. Dykeman is joined in her capacity as agent for WELLS FARGO and as Respondeat
111. Dykeman is also joined individually for her conduct in furtherance of the Fraudulent
partnership with its Wisconsin office location at 13400 Bishop’s Lane, Waukesha, Wisconsin
53005-6224.
113. The agent for service of process for LITCHFIELD CAVO with the Wisconsin
114. LITCHFIELD CAVO, through certain of its employees including Dykeman, has
represented WELLS FARGO BANK, N.A. (WELLS FARGO) in the Rinaldi foreclosure and
115. LITCHFIELD CAVO is joined in its capacity as agent for WELLS FARGO and as
Respondeat Superior for the actions of Rattan and Dykeman and for its statutory liability under
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Wis. Stat. secs. 946.83 and 946.85 for the conduct of its employees in furtherance of the
116. Defendant WELLS FARGO BANK, N.A. (WELLS FARGO) is a national banking
association chartered under 12 U.S.C. sec. 24, with its principal offices at 420 Montgomery
Street, San Francisco, California 94104 and its corporate headquarters at 101 N. Phillips Avenue,
117. WELLS FARGO has been pursuing the remedy of foreclosure against the Rinaldi
Homestead, based on false pleadings, supported by forged documents and falsely sworn
118. WELLS FARGO is one of the leading participants in the Fraudulent Foreclosure
119. WELLS FARGO is one of five (5) mortgage servicers which entered into the
National Mortgage Settlement with the United States of America, the United States Department
of Justice and forty-nine (49) state attorneys general, including the Attorney General for the State
of Wisconsin.
120. WELLS FARGO is joined in its corporate capacity for directing its employees and
agents to create forged documents, file false pleadings supported by forged document and falsely
sworn affidavits.
121. WELLS FARGO is joined as Respondeat Superior for the actions and omissions of
122. Defendant Brad Schimel is the current Attorney General for the State of Wisconsin,
with his principal offices at 114 East State Capitol, Madison, Wisconsin 53702.
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123. The Attorney General is liable for the diversion of funds obtained for the benefit of
Homeowners and for the correction of the public records in several actions, including, but not
limited to the National Mortgage Settlement filed in the United States District Court for the
District of Columbia on April 4, 2012 in Case No. 12-cv-361 in which the Attorney General for
the STATE OF WISCONSIN participated (along with the attorneys general of 49 other states)
and the January 30, 2013 Consent Judgment between Lender Processing Services, Inc. (LPS),
next known as Black Knight Financial, LLC, and its affiliated entity DOCX, along with a
presently unidentifiable entity by the name of “LPS Default Solutions, Inc.,1 as a Delaware
corporation,” in Superior Court for the State of Connecticut, Hartford Division, to which
attorneys general of 45 states and the District of Columbia are co-signatories as discussed infra.
Supreme Court Rules, facially or as applied to any of the Plaintiffs, the facial or “as applied”
constitutionality of any provision of Chapters 21 and 22 of the Supreme Court Rules, the
constitutionality of the operation of the LRS, facially or “as applied,” notice will be given to
Attorney General for the State of Wisconsin at the Wisconsin Department of Justice, 114 East
State Capitol, Madison, Wisconsin 53702 that the Plaintiffs challenge the constitutionality of the
and Rinaldi.
125. The Unnamed Individuals, Governmental Agencies and Corporate Entities Yet to Be
Named or Identified acted in concert with the named Defendants or at the direction of the named
1
There is presently no Delaware corporation registered as LPS Default Solutions, Inc. nor has
any corporation organized under the laws of any State of the United States of America been located.
Research is continuing.
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Defendants in the actions complained of or engaged in other actions or omissions which are
126. The acts and omissions (the Conduct) which give rise to the relief requested herein
have been undertaken by the Defendants, individually and in concert as specified herein,
deprived and continue to deprive the Plaintiffs of their constitutional rights, in violation of the
First Amendment (as to all Plaintiffs), the Fourth Amendment as to Nora only, and the Plaintiffs’
Due Process Rights and Rights to Equal Protection of the Laws, including the protections of the
Constitution of the State of Wisconsin under the Fourteenth Amendments to the United States
127. The violation of constitutional rights of the Plaintiffs by the joint action of state
actors with the wilful participation of private parties is actionable under 42 U.S.C. sec. 1983,
Adickes v. Kress Company, 398 U.S. 144, 152 90 S.Ct. 1598, 26 L.Ed.2d 142 (1970). (“Private
persons, jointly engaged with state officials in the prohibited action, are acting ‘under color’ of
law for purposes of the statute. To act ‘under color’ of law does not require that the accused be
an officer of the State. It is enough that he is a willful participant in joint activity with the State or
its agents,” United States v. Price, 383 U.S. 787, 794, 86 S.Ct. 1152, 1157 (1966).
128. The operation of the Fraudulent Foreclosure Enterprise involves the commission of
the crimes identified below by state and nonstate actors, individually, in concert or in the
proceedings, Wisconsin lawyers knowingly file false complaints or file complaints without
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regard to the truthfulness of the allegations in the complaints which they refuse to amend when
confronted with evidence that the allegations in the complaints are false or are supported by
forged documents.
Enterprise) that Wisconsin lawyers not be investigated by OLR because they routinely violate
SCR 20:3.3(1)(a) and SCR 20:8.4 and an investigation would lead to charges which would
131. The acts and omissions (the Conduct) which give rise to the relief requested herein
have been undertaken by the Defendants, individually and in concert, in violation of Wis. Stat.
132. As to Nora only, the Conduct involving violations of Wis. Stat. secs. 146.82(5) and
146.84(2) for which the STATE OF WISCONSIN and its named employees and agents are both
criminally and civilly liable by the express terms thereof and are in violation of Wis. Stat. sec.
133. As to King only, a separate cause of action for consequential, special and punitive
134. The action for damages for violation of the Plaintiffs’ civil rights under 42 U.S.C.
sec. 1983 and for Rattan’s assault against King includes a demand for punitive damages because
rights; double damages should be awarded to each of the Plaintiffs to the extent of the damages
135. Plaintiffs seek a declarations of their rights and injunctive relief against the
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(LRS) at Chapters 21 and 22 of the Supreme Court Rules declared unconstitutional on its face or
137. The deprivation of Plaintiffs’ rights guaranteed the Constitution of the United States
138. The Defendants Sellen, Stieren, Kasieta, Parsons, Hannan, Potteiger, Moglowsky,
St. Ores, Schwarzenbart, Goldman, Winiarski, Rattan, and Dykeman are joined in their
individual capacities for committing multiple violations of Wis. Stat. sec. 946.12(3), which are
predicate acts in violation of the Wisconsin Organized Crime Control Act (WOCCA), for the
purpose of concealing the operation of the Fraudulent Foreclosure Enterprise in the State of
Wisconsin in which the property rights of Wisconsin residents and citizens have been taken as
the result of false pleadings, supported by forged documents and authenticated by falsely sworn
139. Wis. Stat. sec. 946.82(4) makes it a state felony to commit any act enumerated in
18 U.S.C. sec. 1961(1) which includes 18 U.S.C. sec. 1341 (mail fraud) and 18 U.S.C. sec. 1343
(wire fraud).
140. Other predicate acts in violation of Wis. Stat. sec. 946.82(4) are violations of Wis.
Stat. sec. 943.30(5) (extortion by use of confidential medical information to gain pecuniary
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advantage), Wis. Stat. sec. 943.38 (forgery), 946.12(3) (misconduct in public office), and
141. It is a state misdemeanor to violate Wis. Stat. sec. 146.82(5)(c) under the
142. It is a state felony to violate Wis. Stat. sec. 146.82(5)(c) under the circumstances set
143. It is a state felony in violation of Wis. Stat. sec. 943.20(1)(d) to “obtain title to
property of another person by intentionally deceiving the person with a false representation
which is known to be false, made with intent to defraud, and which does defraud the person to
whom it is made.”
145. It is a state felony in violation of Wis. Stat. sec. 943.38(1)(a) to forge documents.
146. It is a state felony in violation of Wis. Stat. sec. 943.38(2) to utter forged
documents.
148. It is a state felony in violation of Wis. Stat. sec. 946.32 to “ make[s] or subscribe[s]
a false statement which he or she does not believe is true, when such oath, affirmation, or
149. It is a state felony under Wis. Stat. sec. 946.84 to violate Wis. Stat. secs. 946.81-
946.87.
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REGULATION SYSTEM (LRS), including, but not limited to Chief Justice Roggensack in her
supervisory and administrative capacities; the employees and agents of the Office of Lawyer
Regulation (OLR) Sellen, Stieren, Kasieta, Parsons, St. Ores, and Schwarzenbart; Hannan as
chair of the Preliminary Review Committee (PRC); the named Defendant Referees Attorneys
Goldman and Winiarski acted, as applicable, in concert with Potteiger, Moglowsky, BASS &
CAVO, and WELLS FARGO in furtherance of the Fraudulent Foreclosure Enterprise, as defined
at Wis. Stat. sec. 946.82(4) for the purpose of injuring the property rights of Wisconsin
Homeowners by the direct actions and omissions (the Conduct) and by aiding and abetting the
criminal acts of each other as parties to the crimes identified herein in violation of Wis. Stat. sec.
939.05(2)(b) and/or by participating in the racketeering activity by the Conduct specified herein.
151. As specified below, individual Defendants acted for the common purpose of
concealing the use of false pleadings, supported by forged documents, authenticated by falsely
sworn affidavits and ultimately, where necessary, perjured testimony, in order to further the
Foreclosure Enterprise, the object of which is to obtain title to Wisconsin residential real estate
152. Potteiger created forged documents identified as Exhibit B to his April 24, 2014
Affidavit and Exhibit 1 identified in his August 3, 2014 Affidavit, which St. Ores uttered and
upon which Schwarzenbart continued to rely, concealing the conclusive evidence of the forgery
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153. As to all of the Defendants claiming to act in their official capacities, violations of
18 U.S.C. secs. 1341, 1343, and 1962, and Wis. Stat. secs. 146.82(5) and 146.84(2), Wis. Stats.
secs. 943.20(1)(d), 943.30(5), 943.38, 946.12(3), 946.32 and Wis. Stat. sec. 946.82(4) cannot be
committed in an official capacity because employees and agents of the State of Wisconsin are not
154. Commissions of the predicate acts in violation of Wis. Stat. sec. 946.82(4)identified
above, directly or as party to a crime as defined under Wis. Stat. sec. 939.05, including actions
Conduct under Wis. Stat. secs. 946.83 and/or Wis. Stat. sec. 946.85 give rise to a private rights of
action under Wis. Stat. secs. 946.87(2)(b) and 946.87(4) under which these Plaintiffs proceed in
Count Twelve.
155. Upon information and belief, the required investigation of the alleged misconduct of
Wisconsin licensed lawyers would reveal the involvement of participants in the WISCONSIN
LAWYER REGULATION SYSTEM (WLRS) and the Wisconsin Unified Court System as well
as the Wisconsin Supreme Court in at least wilful blindness to the ubiquitous frauds being
156. Upon information and belief, the required investigation of the alleged misconduct
of lawyers admitted to practice before the Wisconsin Supreme Court (hereinafter Wisconsin
mortgage servicers could ultimately affect the value of the retirement funds in which employees
of the Unified Court System are invested and in which OLR employees and the justices of the
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158. The value of the salaries and retirement benefits of the state employees gained from
each person.
159. The value of the profits gained by Litchfield Cavo, Wells Fargo Bank, Fidelity
National Title Company, Rattan, Dykeman, Potteiger and Moglowsky from participation in the
160. Winiarski was paid over $25,000.00 ($38,811.03, including expenses) for his
161. Schwarzenbart was paid over $25,000.00 ($28,053.98 in Nora #1 and $34,784.13
for a total of $62,838.11, including expenses) for his participation in the Fraudulent Foreclosure
Enterprise.
162. Goldman was paid only $11,064.24 (gross income) for her participation in the
Fraudulent Foreclosure Enterprise, but may have gained preferential appointments for further
163. The STATE OF WISCONSIN and the Office of the Wisconsin Attorney General
are well aware of the operations of the Fraudulent Foreclosure Enterprise, having benefitted from
payments made by participants in the nationwide Fraudulent Foreclosure Enterprise through the
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National Mortgage Settlement documents filed as Docs. 102, 113, 124, 135, and 146 in the case
titled United States of America, et al. v. Bank of America Corporation, et al., Case No. 12-cv-
361 in the United States District Court for the District of Columbia on April 4, 2012 from which
164. The STATE OF WISCONSIN and the Office of the Wisconsin Attorney General
are well aware of the scope and extent of the creation and recording of false documents with the
Wisconsin Registers of Deeds Offices based on its participation in the Consent Judgment titled
The State of Connecticut v. Lender Processing Services, Inc., et al. (the LPS Settlement) filed in
the Superior Court for the Hartford, Connecticut filed on January 31, 2013 from which the
165. Upon information and belief, none of the total of at least $30,191,806.00 received
from the National Mortgage Settlement was used for the purposes stated in the Consent
Judgment, an excerpt of which is attached as Exhibit B, but was instead reported to have been
deposited into the general fund to plug a whole in the operating budget of the STATE OF
2
“JP Morgan Chase Consent Judgment” (291 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_Chase-4-11-12.pdf
3
“Bank of America Consent Judgment” (310 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_BoA-4-11-12.pdf
4
“Citi Consent Judgment” (314 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_Citibank-4-11-12.pdf
5
“Ally/GMAC Consent Judgment” (328 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_Ally-4-11-12.pdf
6
“Wells Fargo Consent Judgment” (315 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_WellsFargo-4-11-12.pdf
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WISCONSIN in 2012.
166. Upon information and belief, none of the total of the $1,505,315.00 received from
the Consent Judgment in the LPS Settlement was to re-mediate damages to the public land
records in the STATE OF WISCONSIN resulting from the LPS forgery scheme for which the
penalty was imposed and no effort has been made to remove forged documents created by LPS
which were recorded in the offices of the Registers of Deeds in the State of Wisconsin.
167. Upon information and belief, the required investigation of the alleged misconduct
LAWYER REGULATION SYSTEM (WLRS), the Wisconsin Supreme Court and the Wisconsin
Unified Court System in at least wilful blindness to the ubiquitous frauds being committed in
168. Upon information and belief, the required investigation of the alleged misconduct
mortgage servicers could ultimately affect the value of the retirement funds in which employees
of the Unified Court System are invested and in which OLR employees and the justices of the
170. Upon information and belief, Sellen violated Wis. Stat. sec. 946.12(3) by allowing
OLR employees and other agents of the Wisconsin Supreme Court in the WISCONSIN
licensed lawyers against whom grievances were filed by homeowners and for which no
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171. Upon information and belief, Sellen concealed the misconduct of attorneys
representing mortgage servicers and of the named employees and agents of OLR and the LRS.
172. Sellen, in his official capacity, failed to adequately supervise and train staff and
173. Sellen is joined in his individual capacity for his violations and allowing OLR
employees and participants in the LRS to violate Wis. Stat. secs. 146.82(5)(c) and 146.84(1)(b)
or (bm) and 146.84(2)(a)2, which deprived Nora of her right to Equal Protection of the Laws of
the State of Wisconsin guaranteed by the Fourteenth Amendment to the United States
174. Sellen is individually liable for his participation in the civil rights violations of the
Plaintiffs and for failing to prevent the violation of each of the Plaintiffs’ civil rights.
175. At all times relevant to the acts, omissions, occurrences and transactions
complained of herein, Stieren was an employee of OLR and Sellen was his ultimate supervisor.
176. Stieren is individually liable for his violations of Wis. Stat. secs.
146.82(5)(c) and 146.84(1)(b) or (bm) and 146.84(2)(a)2 which deprived Nora of her right to
Equal Protection of the Laws of the State of Wisconsin guaranteed by the Fourteenth
177. Stieren is individually capacity for his violation of Nora’s right to the confidentiality
of her temporary guardianship proceedings under color of official right in order to provide the
178. Stieren is individually liable for his violation of Nora’s right to be free from
unreasonable searches and seizures guaranteed by the Fourth Amendment to the United States
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179. Stieren is individually liable for his violation of Nora’s rights to Due Process
guaranteed by the Fourteenth Amendment to the United States Constitution and Article One,
180. At all times relevant to the acts, omissions, occurrences and transactions
complained of herein, Kasieta was a member of the District Nine Ethics Committee created
under SCR Chapter 21 and purporting to function pursuant to SCR Chapter 22.
181. Kasieta is individually liable for his violations of Nora’s rights to Equal Protection
of the Laws of the State of Wisconsin under Wis. Stat. secs. 146.82(5)( c) and 146.84(1)(b) or
(bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United States
182. Kasieta is individually liable for the unreasonable search and seizure of Nora’s
confidential medical information by the knowing unlawful disclosure thereof without her consent
required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the Fourth
183. Kasieta acted in conspiracy with the Potteiger and Moglowsky to silence Nora’s
Right to Petition the Judiciary for Redress of Grievances (Petition Rights) guaranteed by the First
Amendment to the United States Constitution and by Article One, Section 4 of the Wisconsin
Constitution and to deprive Nora of her property rights to her license to practice law in the State
of Wisconsin, in an effort to punish her for the lawful exercise of her Petition Rights in violation
of her rights to Due Process guaranteed by the Fourteenth Amendment to the United States
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184. Kasieta knew and acknowledged (in the Investigative Report he signed) that he
knew there was an issue as to whether or not the fact that Nora’s confidential medical
information was filed under federal court seal should prevent the use of the information, and
knew or should have known that Nora did not consent to the disclosure of her confidential
medical information for any purpose other than the purpose for which the information was filed
under seal, but Kasieta nevertheless re-disclosed Nora’s confidential medical information to
Parsons and Kasieta and Parsons re-disclosed the medical information to the District Nine Ethics
Committee and the Preliminary Review Committee (PRC) without Nora’s consent, in violation
of the Fourth and Fourteenth Amendments to the United States Constitution and Article One,
185. Kasieta refused to interview Nora at her request, so that she could explain her
current health status, claiming to have all the information needed to complete the investigation he
was assigned to perform by the District Nine Ethics Committee, together with Theron Edward
Parsons IV.
186. Parsons is individually liable for his violations of Wis. Stat. secs. 146.82(5)(c) and
146.84(1)(b) or (bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United
187. Parsons is individually liable for the unreasonable search and seizure of Nora’s
confidential medical information while knowing unlawful disclosure thereof without her consent
required by Wis. Stat. sec. 146.82(5)(c) was in violation of Nora’s rights guaranteed by the
Fourth Amendment to the United States Constitution, a misdemeanor under Wis. Stat. sec.
146.84(2)(a)2.
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188. Parsons is joined in his individual capacity for conspiracy with the Defendant
Kasieta to silence Nora’s Right to Petition the Judiciary for Redress of Grievances (Petition
Rights) guaranteed by the First Amendment to the United States Constitution and by Article One,
Section 4 of the Wisconsin Constitution; and to deprive Nora of her property rights to her license
to practice law in the State of Wisconsin, in an effort to punish her for the lawful exercise of her
Petition Rights in violation of her rights to Due Process guaranteed by the Fourteenth
Amendment to the United States Constitution and Article One, Section 1 of the Wisconsin
Constitution.
189. Parsons, a Wisconsin licensed clinical social worker who advertises his Ph.D.
degree in the field of social work, did not interview Nora prior to signing off on the Investigative
Report, contrary to the most basic protocols of clinical counseling in which he is licensed by the
State of Wisconsin.
190. Parsons also knew or should have known that he could not re-disclose Nora’s
confidential medical information without her consent, based the fact of his professional licensure
191. Kasieta and Parsons relied on and referred to Nora’s confidential medical
information in their Investigative Report to the District Nine Ethics Committee and attached her
confidential medical records to the Investigative Report in violation of Wis. Stat. secs.
192. From on or about July 1, 2011 to on or about June 30, 2013 (the period relevant to
the acts, omissions, occurrences and transactions complained of herein as to Hannan), Hannan
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was Nora’s litigation opponent in Waukesha County Circuit Court Case No. 2011CV003333
titled Bank of America, N.A. v. Amy Jo Brown (the Brown case), a fact that Hannan was required
193. Because Hannan did not disclose his position as PRC Chair to Nora, Nora could not
have waived Hannan’s conflict of interest and had she known that Hannan was the PRC Chair,
she would have insisted on his recusal because he was Nora’s litigation opponent in the Brown
case, which involved substantially similar facts to the case of Nora v. Residential Funding
Company, LLC, et al., in the United States District Court for the Western of Wisconsin in Case
No. 10-cv-748 and Nora v. Residential Funding Company, LLC, et al., in the United States
Bankruptcy Court for the Southern District of NewYork in Adv. No. 13-01208.
194. When the Investigative Report was presented to the PRC for assignment by the PRC
Chair to the preliminary review panel, Hannan was then and there disqualified to act in the
195. Without Nora’s consent, Stieren re-disclosed and, upon information and belief,
Sellen allowed Stieren to re-disclose, Nora’s confidential medical information which was
included in the December 10, 2010 Grievance filed by Potteiger (who was one of her litigation
opponents) to the District Nine Ethics Committee, which were again re-disclosed by the grievant
and his supervisor to the District Nine Ethics Committee Investigator (Kasieta), was next re-
disclosed by Kasieta to Parsons, and then re-disclosed by Kasieta and Parsons to Sellen, which
was again re-disclosed by Stieren and Sellen, to Hannan, contrary to Wis. Stat. sec. 146.82(5)(c)
196. Upon information and belief, while then and there disqualified to act as Chair of the
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PRC, Hannan received, reviewed and then re-disclosed Nora’s confidential medical information
without Nora’s consent to the preliminary review panel of the PRC which he selected under SCR
22.06, contrary to Wis. Stat. secs. 146.82(5)(c) and in violation of Wis. Stat. secs.146.84(1)(b) or
(bm) and 146.84(2)(a)2. and then unlawfully re-disclosed Nora’s confidential medical
197. Hannan is individually liable for his violations of Wis. Stat. sec. 146.82(5)(c) and
146.84(1)(b) or (bm) and 146.84(2)(a)2. in violation of Nora’s Due Process and Equal Protection
Rights guaranteed by the Fourteenth Amendment to the United States Constitution and Article
One, Section 1 of the Wisconsin Constitution; for unreasonable search and seizure of her
confidential medical information by the knowing unlawful disclosure thereof without her consent
required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the Fourth
Amendment to the United States Constitution; and for conspiracy to deprive Nora of her property
rights to her license to practice law in the State of Wisconsin, in an effort to punish her for the
lawful exercise of her Petition Rights in violation of her rights to Due Process guaranteed by the
Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the
Wisconsin Constitution for the benefit of his clients in the Brown case, the law firm of
BLOMMER PETERMAN, S.C., next known as J PETERMAN LAW GROUP, LTD., now
known as BP PETERMAN LAW GROUP, LLC, and lawyers named as Defendants therein.
198. Rather than investigate grievances filed by homeowners with OLR under Supreme
Court Rules (SCR) Chapter 22, including, but not limited to the grievances filed by Plaintiffs
Nora, Rinaldi and other homeowners alerting OLR to the use of false pleadings, supported by
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Wis. Stat. sec. 946.12(3), OLR employees refused to investigate homeowner grievances on
clearly erroneous grounds, including, but not limited to the completely false position that OLR
does not investigate grievances filed by persons who are not clients of the lawyers against whom
grievances are filed and, most often, for “insufficient” evidence of violations of the Code of
Professional Conduct.
199. OLR, Sellen, Stieren, Kasieta, Parsons and Hannan used Nora’s confidential
medical information which was unlawfully taken in violation of a federal court seal and produced
by one of Nora’s litigation opponents in order to deprive Nora of her property rights to her
license to practice law in the State of Wisconsin, in an effort to punish Nora for the lawful
exercise of her Petition Rights and for assisting her clients in the exercise of their Petition Rights
in violation of her rights to Due Process and Equal Protection of the Laws, guaranteed by the
Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the
Wisconsin Constitution.
200. Knowing that Nora’s confidential medical information was unlawfully re-disclosed,
Sellen took no action to discipline Stieren as allowed by Wis. Stat. sec. 146.84(3) nor did he take
any other action to prevent the continuing violation of Nora’s rights to be free from unreasonable
searches and seizures of her confidential medical information in violation of the Fourth
201. Nora and Rinaldi produced substantial, indeed VAST evidence to OLR which
established that certain Wisconsin-licensed lawyers were engaging in and facilitating mail fraud
and wire fraud in violation of Racketeer Influenced and Corrupt Organizations Act (RICO), 18
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U.S.C. sec. 1961, et seq. and the Wisconsin Organized Crime Control Act (WOCCA) Wis. Stat.
sec. 946.80, et seq., in violation of the Code of Professional Conduct, injuring the property and
allowing the property of the Plaintiffs Nora and Rinaldi as well as hundreds of other Wisconsin
homeowners to be injured.
202. The Defendants who are employees or agents of OLR and the Wisconsin Supreme
Court have the positive statutory duty to prevent the injuries to the public when Wisconsin-
203. The successful continuation of the Fraudulent Foreclosure Enterprise depends upon
204. All of the named Defendants contributed to the concealment of the Fraudulent
Foreclosure Enterprise described herein by their specified actions taken under color of state law
to prevent the Plaintiffs from exercising their Petition Rights and to prevent the exposure of the
205. Nora and Rinaldi attempted to report the operation of the Fraudulent Foreclosure
206. Had OLR investigated the evidence which shows the operation of the
pleadings, supported by false or forged copies of documents and falsely sworn affidavits, it is
believed in good faith, Rinaldi would not have spent over a decade in litigation to protect the
property interests in the Rinaldi Homestead and hundreds of Wisconsin homeowners would have
been protected from similar misconduct affecting their property rights and interests resulting in
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207. Instead, OLR dismissed homeowners’ grievances and collaborated with Nora’s
litigation opponents to prevent her from exercising her Petition Rights and advocating for her
208. When homeowner grievants, including but not limited to Nora and Rinaldi, sought
acted as if he was presiding as an appellate judge and upheld his subordinate’s decisions not to
investigate homeowner grievances on clearly erroneous grounds, knowing that his disposition of
grievances cannot be reviewed, thereby concealing the operations of the Fraudulent Foreclosure
Action by declining to protect the public from the use of false pleadings, supported by forged
209. The extent of the collaboration between OLR and Nora’s and Rinaldi’s litigation
210. On or about March 31, 2018, OLR provided thousands of pages of internal
documents to Nora in discovery in the case titled In re the Disciplinary Proceedings Against
Wendy Alison Nora (Office of Lawyer Regulation v. Nora), Appeal No. 2013AP000653-D
211. OLR’s internal documents produced in discovery (which were produced untimely)
consisted of hundreds of pages of emails which exposed regulatory capture by which the
Fraudulent Foreclosure Enterprise, through Wisconsin attorneys and staff of OLR and the
Wisconsin Supreme Court to further the operations of the Enterprise, although suspicions were
raised in early June, 2015, when OLR refused to consider evidence that a Wisconsin lawyer,
David M. Potteiger (Potteiger) had fabricated a copy of an email and falsely swore that the email
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was sent to Nora on August 25, 2009 at 4:20 p.m., after Nora discovered evidence that the email
could not have been sent to her on that date and at that time.
212. After being provided with evidence that the August 25, 2009 email could not have
been sent at 4:20 p.m. on that date, OLR continued to prosecute Nora on the alleged false
evidence, solicited and produced additional false evidence from Potteiger, and then prevented
Nora from defending herself with the substantial evidence of OLR’s conspiracy with Potteiger to
213. The concealment of the false evidence created by Potteiger and produced by OLR
led to Nora’s suspension from the practice of law in Wisconsin for one (1) year (pending further
relief by Petition for Certiorari to the United States Supreme Court or other relief) now admitted
214. Based on substantial evidence that OLR was engaged in a conspiracy with mortgage
servicer lawyers to conceal their litigation misconduct, King, a journalist and videographer
attended proceedings in In re the Disciplinary Proceedings Against Wendy Alison Nora Office
of Lawyer Regulation v. Nora, No. 2013AP002442-D (OLR v. Nora), hereinafter Nora #2, for the
215. On March 23, 2017, in the course of the Nora #2 proceedings, King was physically
assaulted by Rattan.
216. The assault on King was prevented and, upon information and belief, was intended
217. Rattan was not removed from the proceedings in Nora #2 after he assaulted King.
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#2, did not even admonish Rattan for assaulting King on March 23, 2017, but instead expressed
his own discomfort with the presence of King, in the capacity of what he himself characterized as
“the press”.
219. In violation of the First Amendment to the United States Constitution and Article
One, Section 3 of the Wisconsin Constitution, King was removed from the proceedings in Nora
#2 by Defendant James J. Winiarski (Winiarski) on March 24, 2017 when King expressed his
intention to lodge a complaint for violations of his rights, after King was physically assaulted by
Rattan.
220. When King filed a grievance with OLR for Rattan’s conduct on March 23, 2017,
Rattan was provided with a diversion agreement from which no discipline would be forthcoming
upon successful completion, whereas on August 8, 2018, Winiarski recommended that Nora be
suspended for consecutive period of two (2) years for assisting her clients in the exercise of their
Petition Rights based on his conclusion that Nora is a danger to the public and the legal system.
221. Nora has never conducted herself in the threatening, intimidating and disruptive
222. Winiarski, who did not take any action when Rattan disrupted the hearing on March
23, 2017, has recommended that Nora be suspended from practicing law in Wisconsin because
she is dangerous to the public and the legal system for the actions she took to represent Rinaldi
223. The suspension of Nora in Nora #1 resulted in injury to the Plaintiffs Nora and
Nora’s clients, who were being represented by Nora at the time the suspension Order was
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224. Nora was denied Equal Protection of the Laws of the State of Wisconsin because no
elected judge conducted the evidentiary proceedings in Nora #1 and no justice of the Wisconsin
Supreme Court wrote the March 30, 2018 Opinion and Order.
225. Under SCR 22.16(1), the WISCONSIN SUPREME COURT purports to empower
referees appointed with the powers of a circuit court judge, but the referees who are Defendants
herein are lawyers admitted to practice before the Wisconsin Supreme Court and have never been
elected as required to constitutionally exercise the powers purportedly granted to them under
SCR 22.16(1).
226. Plaintiff Nora alleges that SCR 22.16(1) is unconstitutional on its face or as applied
to her in the subject proceedings titled Office of Lawyer Regulation v. Nora, No. 2013AP000653-
D (hereinafter Nora #1) and Office of Lawyer Regulation v. Nora, No. 2015AP002442-D
227. SCR 21.15(4) requires all attorneys admitted to practice law in Wisconsin to
cooperate with OLR in the investigation, prosecution, and disposition of grievances and
complaints filed with or by the director of OLR and makes the wilful violation of the cooperation
requirement grounds for disciplinary action against an attorney admitted to practice law in the
Wisconsin.
228. Goldman and Winiarski in this Complaint are admitted to practice law in the
Wisconsin and have never been elected to serve as circuit court judges.
229. SCR 21.15(4) creates a conflict of interest as defined under SCR 21.13 pursuant to
SCR 60.04(4) for referees who are Wisconsin lawyers because they are required to cooperate
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230. SCR 60.04(4)(a) provides that a judge is required to recuse himself or herself when
231. By making attorneys admitted to practice before the Wisconsin Supreme Court
subject to discipline for noncooperation with the prosecution in a lawyer disciplinary proceeding,
proceedings cannot be neutral and detached, but is required to cooperate with the OLR.
232. Plaintiff Nora alleges that SCR 21.15(4) renders disciplinary proceedings in which
lawyers admitted to practice before the Wisconsin Supreme Court, but who are not and never
have been elected judges, are appointed as referees unconstitutional per se or as applied to her in
the subject proceedings titled Office of Lawyer Regulation v. Nora, No. 2013AP000653-D
(hereinafter Nora #1) and Office of Lawyer Regulation v. Nora, No. 2015AP002442-D
233. Goldman and Winiarski cooperated with OLR in Nora #1 and Nora #2, respectively,
by preventing Nora from defending herself in violation of her First Amendment Right to petition
the judiciary for redress of grievances (Petition Rights) and her Fourteenth Amendment Right to
234. Winiarski prevented King from reporting on the Nora #2 proceedings by ejecting
King from the proceedings in retaliation for King preserving his right to petition the Wisconsin
235. Rather than investigate grievances filed by homeowners with OLR under Supreme
Court Rules (SCR) Chapter 22, including, but not limited to the grievances filed by Plaintiffs
Nora, Rinaldi and other homeowners alerting OLR to the use of false pleadings, supported by
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Wis. Stat. sec. 946.12(3), OLR employees, supervised by Sellen, refused to investigate
homeowner grievances on clearly erroneous grounds, including, but not limited to the completely
false position that OLR does not investigate grievances filed by persons who are not clients of the
lawyers against whom grievances are filed in the case of Nora’s grievance against Arthur
Moglowsky and, most often, for “insufficient” evidence of violations of the Code of Professional
Conduct as was the case in Rinaldi’s grievances against multiple lawyers participating in the
236. When homeowner grievants sought review by Sellen of OLR employees’ decisions
and upheld his subordinate’s decisions not to investigate homeowner grievances on clearly
erroneous grounds.
237. While repeatedly refusing to investigate grievances filed by homeowners, OLR used
false documents and falsely sworn affidavits created by Wisconsin lawyer Potteiger to injure
Plaintiff Nora’s property interests and her right to represent homeowners in an effort to “curtail”
her representation of homeowners at the request of and in collaboration with Nora’s litigation
238. The State of Wisconsin is expressly liable for Nora’s damages under Wis. Stat. sec.
146.84.
239. The Wisconsin Supreme Court in its administrative capacity is liable for claims of
injury arising under Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and
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“as applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT
and the LAWYER REGULATION SYSTEM and for declaratory and injunctive relief allowed by
Supreme Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
240. The Defendants named in their individual capacities are joined in their individual
capacities for violations of Nora’s rights to Due Process and Equal Protection of the Laws of the
State of Wisconsin under Wis. Stat. sec. 146.82(5)(c) and 146.84(1)(bm) guaranteed by the
Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the
Wisconsin Constitution, for unreasonable search and seizure of her confidential medical
information by the knowing unlawful disclosure and re-disclosure thereof without her consent
required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the Fourth
Amendment to the United States Constitution; for conspiracy with the Wisconsin-licensed
attorneys to silence Nora’s Right to Petition the Judiciary for Redress of Grievances (Petition
Rights) and the Petition Rights of the her clients, guaranteed by the First Amendment to the
United States Constitution and by Article One, Section 4 of the Wisconsin Constitution and for
violation of the duties owed to Nora not to be punished for exercising her rights as a property
owner in the State of Wisconsin to be protected from violations of criminal law by Wisconsin
attorneys.
241. The Defendants named in their individual capacities are joined in their individual
capacities for violations of King’s rights to Due Process and Equal Protection of the Laws of the
State of Wisconsin guaranteed by the Fourteenth Amendment to the United States Constitution
and Article One, Section 1 of the Wisconsin Constitution and for conspiracy with the Wisconsin-
licensed attorneys to silence King’s First Amendment rights as a journalist and Winiarski and
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Sellen are specifically liable for the violation of King’s Right to Petition the Judiciary for
Redress of Grievances (Petition Rights), guaranteed by the First Amendment to the United States
242. The Defendants named in their individual capacities are joined in their individual
capacities for violations of Rinaldi’s rights to Due Process and Equal Protection of the Laws of
the State of Wisconsin guaranteed by the Fourteenth Amendment to the United States
Constitution and Article One, Section 1 of the Wisconsin Constitution and for conspiracy with
the Wisconsin attorneys to interfere with Rinaldi’s First Amendment Right to Petition the
Judiciary for Redress of Grievances (Petition Rights), guaranteed by the First Amendment to the
United States Constitution and by Article One, Section 4 of the Wisconsin Constitution.
243. The Defendant Wisconsin Supreme Court, in its administrative capacity, and the
Defendants named in their individual capacities are joined for violations of Rinaldi’s rights to
Due Process and Equal Protection of the Laws of the State of Wisconsin guaranteed by the
Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the
Wisconsin Constitution and for conspiracy with the Wisconsin attorneys to interfere with
Rinaldi’s First Amendment Right to Petition the Judiciary for Redress of Grievances (Petition
Rights), guaranteed by the First Amendment to the United States Constitution and by Article
One, Section 4 of the Wisconsin Constitution and for violation of the duties owed to Rinaldi as a
property owner in the State of Wisconsin to be protected from violations of criminal law by
Wisconsin attorneys.
244. OLR, Sellen, Stieren, Kasieta, Parsons and Hannan used Nora’s confidential
medical information which was unlawfully taken in violation of a federal court seal and produced
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by one of Nora’s litigation opponents in order to deprive Nora of her property rights to her
license to practice law in the State of Wisconsin, in an effort to punish Nora for the lawful
exercise of her Petition Rights and for assisting her clients in the exercise of their Petition Rights
in violation of her rights to Due Process and Equal Protection of the Laws, guaranteed by the
Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the
Wisconsin Constitution.
245. Nora and Rinaldi produced substantial, indeed VAST evidence to OLR which
established that certain Wisconsin-licensed lawyers were engaging in and facilitating mail fraud
and wire fraud in violation of Racketeer Influenced and Corrupt Organizations Act (RICO), 18
U.S.C. sec. 1961, et seq. and the Wisconsin Organized Crime Control Act (WOCCA) Wis. Stat.
sec. 946.80, et seq., in violation of the Code of Professional Conduct, injuring the property and
allowing the property of the Plaintiffs Nora and Rinaldi as well as hundreds of other Wisconsin
homeowners to be injured.
246. The Defendants who are employees or agents of OLR and the Wisconsin Supreme
Court have the positive statutory duty to prevent the injuries to the public when Wisconsin-
247. The successful continuation of the Fraudulent Foreclosure Enterprise depends upon
248. All of the named Defendants participated in the concealment of the Fraudulent
Foreclosure Enterprise described herein by their specified actions taken under color of state law
to prevent the Plaintiffs from exercising their Petition Rights and to prevent the exposure of the
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249. Nora and Rinaldi attempted to report the operation of the Fraudulent Foreclosure
250. Had OLR investigated the evidence which shows the operation of the
false pleadings, supported by false or forged copies of documents and falsely sworn affidavits, it
is believed in good faith, Rinaldi would not have spent over a decade in litigation to protect the
property interests in the Rinaldi Homestead and hundreds of Wisconsin homeowners would have
been protected from similar misconduct affecting their property rights and interests resulting in
251. Instead, OLR dismissed homeowners’ grievances and collaborated with Nora’s
litigation opponents to prevent her from exercising her Petition Rights and advocating for her
252. The extent of the collaboration between OLR and Nora’s and Rinaldi’s litigation
253. On or about March 31, 2018, OLR provided thousands of pages of internal
documents to Nora in discovery in the case titled In re the Disciplinary Proceedings Against
Wendy Alison Nora (Office of Lawyer Regulation v. Nora), Appeal No. 2013AP000653-D
254. The internal documents produced in discovery (which were produced untimely)
consisted of hundreds of pages of emails which exposed regulatory capture by which the
Fraudulent Foreclosure Enterprise, through its Wisconsin-licensed attorneys and staff of OLR
and the Wisconsin Supreme Court to further the operations of the Enterprise, although suspicions
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were raised in early June, 2015, when OLR refused to consider evidence that a Wisconsin-
licensed lawyer, David M. Potteiger (Potteiger) had fabricated a copy of an email and falsely
sworn that the email was sent to Nora on August 25, 2009 at 4:20 p.m., after Nora discovered
evidence that the email could not have been sent to her on that date and at that time.
255. After being provided with evidence that the August 25, 2009 email could not have
been sent at 4:20 p.m. on that date, OLR continued to prosecute Nora on the alleged false
evidence, solicited and produced additional false evidence from Potteiger, and then prevented
Nora from defending herself with the substantial evidence of OLR’s conspiracy with Potteiger to
256. The concealment of the false evidence created by Potteiger and produced by OLR
led to Nora’s suspension from the practice of law in Wisconsin for one (1) year now admitted to
have been recommended by Sellen (pending further relief by Petition for Certiorari to the United
257. Based on substantial evidence that OLR was engaged in a conspiracy with mortgage
servicer lawyers to conceal their litigation misconduct, King, a journalist and videographer
attended proceedings in In re the Disciplinary Proceedings Against Wendy Alison Nora Office
of Lawyer Regulation v. Nora, No. 2013AP002442-D (OLR v. Nora), hereinafter Nora #2, for the
258. On March 23, 2017, in the course of the Nora #2 proceedings, King was physically
assaulted by Rattan.
249. The assault on King was not prevented by Winiarski and, upon information and
belief, was intended to prevent King from visually recording the Nora #2 proceedings and
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250. Rattan was not removed from the proceedings in Nora #2 by Winiarski after he
assaulted King.
251. Winiarski, purporting to preside as referee in Nora #2, did not even admonish
Rattan for assaulting King on March 23, 2017, but instead expressed his own discomfort with the
252. In violation of the First Amendment to the United States Constitution and Article
One, Section 3 of the Wisconsin Constitution, King was eventually removed from the
proceedings in Nora #2 by Winiarski on March 24, 2017 when King expressed his intention to
lodge a complaint for violations of his rights, after King was physically assaulted by Rattan.
253. Some members of the public who were entitled to attend the public proceedings in
Nora #2 chose not to attend because they were expecting to have access to King’s video
recording of the proceedings and the public was denied access to the video recording which had
been arranged at the expense of time, travel and technology to each of the Plaintiffs King and
254. Nora and King intended to have King’s video of the entire proceedings made
publicly available in video format and to have excerpts of the complete video published.
255. When King filed a grievance with OLR for Rattan’s conduct on March 23, 2017,
Rattan was provided with a diversion agreement from which no discipline would be forthcoming
upon successful completion, whereas on August 8, 2018, Winiarski recommended that Nora be
suspended for consecutive period of two (2) years for assisting her clients in the exercise of their
Petition Rights based on his conclusion that Nora is a “danger to the public and the legal
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system.”
256. Nora has never conducted herself in the threatening, intimidating and disruptive
257. The suspension of Nora in Nora #1 resulted in injury to the Plaintiffs Nora and
Nora’s clients, who were being represented by Nora at the time the suspension Order was
entered, including, but not limited to Rinaldi, some of whom may seek leave to intervene in these
proceedings.
258. Nora was denied Equal Protection of the Laws of the State of Wisconsin in her right
to the protection of Wis. Stat. sec. 146.82(5) and because no elected judge conducted the
evidentiary proceedings in Nora #1 and no justice of the Wisconsin Supreme Court wrote the
259. This is an action for damages for violation of the Plaintiffs’ civil rights under 42
U.S.C. sec. 1983, for treble damages under 18 U.S.C. sec. 1964(c) to each of the Plaintiffs for
the violation of RICO and/or for double damages to each of the Plaintiffs under Wis. Stat. sec.
946.87(4) under WOCCA, as well as for declaration of the Plaintiffs’ rights, for injunctive relief
against the continuing RICO operation and to have the Wisconsin LAWYER REGULATION
260. James J. Winiarski (Winiarski) was the referee in Nora #2 and is joined in his
individual capacity because he was without subject matter jurisdiction or competency to proceed
under SCR 22.11 effective August 16, 2016, the date upon which he purported to allow OLR to
file the Second Amended Complaint in Nora #2 setting forth facts for which the preliminary
review panel had not found cause to proceed, contrary to SCR 22.11(2).
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261. Thereafter, Winiarski entered multiple orders intended to deprive Nora of her right
to defend herself in Nora #2 in violation of Nora’s Petition Rights and her Due Process Rights.
262. The Conduct complained of herein was initiated in the State of Wisconsin for the
internationally.
263. The Conduct involves concealing evidence of crimes committed in intrastate and
interstate commerce by and for the benefit of the Fraudulent Foreclosure Enterprise, in which
Wisconsin licensed lawyers aid and abet their clients in conspiracy to produce false evidence,
authenticated by falsely sworn affidavits and testimony, in violation of the constitutional rights of
homeowners with intent to injure the property rights of homeowners and which has continued
unabated despite efforts to bring these serious issues to the SUPREME COURT OF
264. Rather than investigate grievances filed by homeowners with OLR under Supreme
Court Rules (SCR) Chapter 22, including, but not limited to Nora and Rinaldi, OLR has
dismissed homeowner grievances alerting OLR to the use of false pleadings, supported by false
sec. 946.12(3) and has pursued Nora for reporting the misconduct of Wisconsin lawyers who act
265. While repeatedly refusing to investigate grievances filed by homeowners, OLR used
false documents and falsely sworn affidavits created by a Wisconsin licensed lawyer to injure
Plaintiff Nora’s property interests and her right to represent homeowners in an effort to “curtail”
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her representation of homeowners at the request of and in collaboration with Nora’s litigation
266. The Defendants Wisconsin Supreme Court and OLR are joined in their
administrative and investigative capacities and the Defendants Sellen, Stieren, Kasieta, Parsons,
Hannan, St. Ores, Schwarzenbart and Goldman are joined in their individual capacities for
violations of Nora’s rights to Equal Protection of the Laws of the State of Wisconsin under Wis.
Stat. sec. 146.82(5)(c) and 146.84(1)(bm), guaranteed by the Fourteenth Amendment to the
United States Constitution and Article One, Section 1 of the Wisconsin Constitution; for
unreasonable search and seizure of her confidential medical information by the knowing
unlawful disclosure thereof without her consent required by Wis. Stat. sec. 146.82(5)(c) in
violation of Nora’s rights guaranteed by the Fourth Amendment to the United States
Constitution; for conspiracy with the Defendants Potteiger and Moglowsky to silence Nora’s
Right to Petition the Judiciary for Redress of Grievances (Petition Rights) guaranteed by the First
Amendment to the United States Constitution and by Article One, Section 4 of the Wisconsin
Constitution; and to deprive Nora of her property rights to her license to practice law in the State
of Wisconsin, in an effort to punish her for the lawful exercise of her Petition Rights in violation
of her rights to Due Process guaranteed by the Fourteenth Amendment to the United States
267. All of the named Defendants are joined in this action for their participation in the
concealment of the Fraudulent Foreclosure Enterprise described herein by their specified actions
taken under color of state law to prevent the Plaintiffs from exercising their Petition Rights and
to prevent the exposure of the Fraudulent Foreclosure Enterprise to the public by excluding the
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268. Had OLR investigated the Fraudulent Foreclosure Enterprise in which Wisconsin
lawyers participate by filing false pleadings, supported by false or forged copies of documents
and falsely sworn affidavits, it is believed in good faith, that Rinaldi would not have spent over a
decade in litigation to protect his property interests in his Homestead, Nora would have been
protected from the fraudulent foreclosure of her Homestead and hundreds of Wisconsin
homeowners would have been protected from similar misconduct affecting their property rights
and interests.
269. Instead, OLR and its employees and agents collaborated with Nora’s litigation
opponents to prevent her from exercising her Petition Rights and advocating for her clients in the
270. The extent of the collaboration between OLR and Nora’s litigation opponents was
not discovered until March, 2016, when OLR provided thousands of pages of internal
documents, although evidence was available as early as June, 2015, when OLR refused to
consider evidence that Wisconsin lawyer, David M. Potteiger (Potteiger) had fabricated a copy of
an email and falsely sworn that the email was sent to Nora on August 25, 2009 at 4:20 p.m. and
falslely denied that Exhibit B to Potteiger’s April 24, 2014 Affidavit was a forgery.
271. Kasieta conspired with Potteiger and Moglowsky to re-disclose Nora’s confidential
medical information to injure her property interests in her admission to practice law in Wisconsin
272. Kasieta and Parsons wilfully re-disclosed Nora’s confidential medical information
to discriminate against what they perceived to be a disability but did not allow her to explain that
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she had recovered from the underlying condition and when she recovered from the totally
disabling effects of a head injury including a temporary seizure disorder and seeking to have her
273. St. Ores conspired with Potteiger in pursuing the prosecution of Nora to the extreme
extent of acting in concert with Potteiger, having Potteiger advise her about the affects of current
case law on Nora’s defenses and providing her with facts (although, in significant part, false) to
274. Stieren conspired with Potteiger and with Foshag to accomplish Potteiger’s stated
goal of curtailing Nora’s litigation directed toward exposing the Fraudulent Foreclosure
275. Schwarzenbart denied the existence of the exculpatory evidence and then concealed
the exculpatory evidence which would have conclusively proven that the August 25, 2009 4:20
p.m. email was not and could not have been sent by Potteiger.
Potteiger’s credibility in Nora #2 to continue the concealment of the selective and vindictive
prosecution of Nora in an effort to deprive her of full and fair proceedings in her defense.
277. Stieren lied about the Investigative Report produced to the PRC in Nora #2 in order
to support the misrepresentation to Winiarski that the PRC had considered the record in the
Matter of Sheila M. Spencer, when he knew that the Investigative Report involved only the
Decision of the Seventh Circuit and not the record in the Wood County Circuit Court (Case No.
2009CV000283).
276. Stieren lied at the evidentiary hearing in Nora #1 when he swore under oath that he
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only spoke to Potteiger (in violation of the witness sequestration order) for five (5) minutes after
twice testifying that he conversed with Potteiger for approximately half an hour.
278. St. Ores and Schwarzenbart continued to prosecute Nora on the alleged false
evidence (forged Exhibit B purporting to be the email sent to Nora on August 25, 2009 at 4:20
p.m.) according to the falsely sworn April 24, 2014 Affidavit of Potteiger submitted by OLR in
Nora #1.
279. St. Ores solicited and produced additional false evidence from Potteiger, and then
Schwarzenbart and Goldman prevented Nora from defending herself with the substantial
evidence of OLR’s conspiracy with Potteiger to violate Nora’s statutory and constitutional rights
in Office of Lawyer Regulation v. Nora, No. 2013AP000652-D (OLR v. Nora), hereinafter Nora
#1.
281. Goldman prevented Nora from being able to present her defense throughout a
tortured process of discretionary abuses accumulated as evidence of actual bias from which
282. The concealment of the false evidence created by Potteiger and produced by OLR
led to Nora’s suspension from the practice of law in Wisconsin for one (1) year (pending further
relief by Petition for Certiorari to the United States Supreme Court or other relief).
283. Based on substantial evidence that OLR was engaged in a conspiracy with mortgage
servicer lawyers to conceal their litigation misconduct, King, a journalist and videographer
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Nora), hereinafter Nora #2, for the purpose of making a visual record of the Nora #2
proceedings.
284. On March 23, 2017, in the course of the Nora #2 proceedings, King was physically
assaulted by a mortgage servicer’s lawyer, Mark W. Rattan (Rattan). The assault on King was
285. Having already been deprived of Due Process in Nora #1, Nora wanted to assure
that a visual record of the evidentiary hearing to be conducted ultra vires by Winiarski was made.
286. King, who was aware of the disciplinary proceedings against Nora (which he
recognized as being an attempt to silence the issues of homeowners because he has extensively
investigated and documented violations of property owners Due Process Rights in video format)
287. On October 31, 2016, the date the evidentiary hearing was scheduled to commence,
288. Winiarski, preemptively and without cause, warned King that he would eject King
289. The evidentiary hearing set to commence of October 31, 2016 was rescheduled due
to the unavailability of Nora’s co-counsel, who was prevented from traveling from the
290. Thereafter, Nora was injured on January 17, 2017 in a fall on ice when she hit her
head on pavement and the evidentiary hearing was again rescheduled to begin on March 22,
2017.
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by harassing her about her condition on January 18, 2017 and for weeks thereafter, but it appears
that OLR subsequently decided to disengage from disability discrimination against Nora.
unfitness to practice law in the course of the disciplinary proceedings, as evidenced by a series of
293. King was present at the evidentiary hearing on March 22, 2017 and recorded the
294. Nora had been charged by OLR with violations of the Code of Professional Conduct
for her defense of the Rinaldi Homestead in Nora #2 against WELLS FARGO and its affiliates,
arguing that WELLS FARGO and its law firms were using forged documents to attempt to
295. By agreement with her co-counsel, Nora, who was still impaired by her recent
injury, was nevertheless responsible for the cross-examination of Attorney Dykeman, who
represented WELLS FARGO, certain of its affiliated entities, and claimed to represent HSBC
Bank USA, N.A., “HSBC Bank USA, National Association, as Trustee for Wells Fargo Asset
Securities Corporation Home Equity Asset-Backed Certificates, Series 2005-2” and/or “HSBC
Bank USA, National Association, as Trustee for Wells Fargo Home Equity Asset-Backed
Securities 2005-2 Trust, Home Equity Assert(sic)-Backed Certificates, Series 2005-2” and/or
“HSBC Bank USA, N.A. as Trustee WFHET 2005-1”, despite the true facts of Wells Fargo’s
interest in the Rinaldi collateral documents and the disputed claim for secured debt.
296. Before Nora was able to complete her examination of Attorney Dykeman, Rattan
rose from his chair and physically assaulted King in an effort to interfere with the video
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297. Winiarski did not take any action to reprimand Rattan for the disruption of the
298. Nora was distracted by Rattan’s disruption of the evidentiary hearing which affected
299. Winiarski attempted to justify Rattan’s disruption of the hearing suggesting that the
room was small and that somehow King’s pre-approved journalistic presence justified Rattan’s
300. On March 24, 2017, King was ejected from the hearing by Winiarski when he
advised Winiarski of his intention to complain about Winiarski’s refusal to admonish Rattan for
the assault on King to the WISCONSIN SUPREME COURT in retaliation for King giving notice
301. King was subjected to the retaliatory ejection before Nora was able to commence
her testimony in her defense, depriving Nora of the video record King had intended to make and
depriving the public of the full video report King was prepared to make, in violation of the First
Amendment Rights of Nora and King and their rights under Article One, Section 3 of the
302. King filed a grievance with OLR regarding the misconduct of Rattan at Nora’s
303. During the OLR investigation, Rattan falsely claimed that the unaltered video
evidence of the assault had been altered by King, on letterhead provided by his Wisconsin-
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304. Rattan was found by OLR to have shown no remorse and to have acknowledged no
wrongdoing.
305. Nevertheless, Sellen approved the resolution of King’s grievance by having Rattan
successfully complete a diversion program (upon information and belief he may have proposed
it). Disposition by diversion reserved for situations in which the outcome of the disciplinary
process was likely to be no more severe than a private reprimand. SCR 22.10(3)(a).
306. There is no precedent for concluding that discipline no more severe than a private
reprimand should be the outcome for disrupting a hearing by assaulting a journalist with the
intent to prevent reporting at a public hearing, see, e.g. Office of Lawyer Regulation v. Sommers,
339 Wis.2d 580, 811 N.W.2d 387, 2012 WI 33 (Wis., 2012); or making a misrepresentation to
OLR in the course of a disciplinary investigation, as the OLR investigator found that Rattan had
307. Sellen abused his discretion by permitting the diversion of discipline for a serious
violation of the Code of Professional Conduct in violation of the Equal Protection Rights of
King, Nora, and Rinaldi and contrary to Wis. Stat. sec. 946.12(3).
308. In the meantime, Winiarski, claiming continuing subject matter jurisdiction and/or
competency contrary to SCR 22.11(2) and acting upon the ultra vires Second Amended
Complaint in Nora #2 which OLR attempted to amend according to the proof and which
Winiarski himself amended, contrary to the evidence in the record, has recommended that Nora
be subjected to a suspension of an additional two (2) years because Nora, who, unlike Rattan, has
never disrupted a hearing, “is dangerous to the public and legal system”.
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309. The remarkable distinction between the treatment of Rattan, an attorney whose law
firm represents financial institutions and Nora, who defends property owners against frauds being
the LRS and OLR, as agents for the Wisconsin Supreme Court of which these Plaintiffs
complain.
310. Nora filed a grievance against Attorney Arthur Moglowsky (Moglowky) in 2009
which was not investigated because the OLR intake investigator, Jonathan Zeisser, determined
that OLR does not investigate grievances unless the grievance is filed by a client, which is
patently false.
311. Nora sought Sellen’s review of the determination not to investigate her grievance
and Sellen decided not to investigate Nora’s grievance on other grounds, indicating that a
complete record to support Nora’s position has not been provided to him by Nora. The
additional evidence (the Transcript of the May 19, 2009 Hearing in the foreclosure action) was
in Nora’s possession and could have been presented if the investigation, falsely denied by the
312. Potteiger filed the grievance against Nora, in part, in retaliation for Nora’s exercise
of her Petition Rights in filing the Moglowsky grievance, which she then believed she was
Moglowsky’s law firm, BASS & MOGLOWSKY, S.C., using confidential medical information
obtained without Nora’s consent, depriving Nora of the protection of Wis. Stat. sec. 146.82(5),
in violation of Wis. Stat. sec. 146.84 in retaliation for her exercise of her Petition Rights.
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Wisconsin attorneys in the first foreclosure action commenced in Kenosha County Circuit Case
No. 2009CV000353, complaining that false documents were being filed by WELLS FARGO
attorneys in the circuit court action and he continued to complain to OLR that false documents
were filed in the public record into 2014, when he produced the newly discovered Wells Fargo
Home Mortgage Foreclosure Attorneys Manual (the Manual) which instructs attorneys how to
315. OLR refused to investigate any of Rinaldi’s grievances, yet it charged Nora with
misconduct for producing the Manual as new evidence in defense of the Rinaldi Homestead in
Nora #2.
316. Rinaldi appealed from the award of summary judgment to WELLS FARGO as the
unnamed real party in interest and not HSBC Bank USA, N.A. as Trustee for the Wells Fargo
Home Equity Asset-Backed 2005-2 Trust, the correct name for the Real Estate Mortgage
Investment Conduit (REMIC) Trust to which attorneys for WELLS FARGO misled Rinaldi to
believe was the REMIC Trust to which the Rinaldi Note and Mortgage had been conveyed, while
suing for foreclosure and bringing claims against the Rinaldi Homestead in three (3) other
“similar” names.
317. On November 13, 2017, it was discovered, after nine (9) years of litigation with
WELLS FARGO, using three (3) different but “similar” names, the REMIC Trust into which
WELLS FARGO’s affiliate, Wells Fargo Asset Securities Corporation, had reported to the
Securities and Exchange Commission (SEC) that the Rinaldi Note and Mortgage was
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319. WELLS FARGO is both the Trustee and the servicing agent for the Wells Fargo
320. Rinaldi had been misled for a decade by the litigation conduct of WELLS FARGO’s
lawyers, Dykeman and others, using the techniques described in the Manual and misdirecting
321. Nora, who holds a mortgagee interest in the Rinaldi Homestead for services
provided in the defense of the Rinaldi Homestead, is the Intervenor-Appellant in the Rinaldi
appeal still pending on her Opening Brief before the Wisconsin Court of Appeals in Appeal No.
2018AP001390.
Rinaldi from obtaining a first extension of time to file his Opening Brief in his appeal from
Summary Judgment and attempted to prevent Nora from pursuing her appeal as proposed
intervenor in the second foreclosure action, including, but not limited to:
a. Dykeman asserted as fact that Nora was continuing to practice law as the representative
of Rinaldi in her capacity as Intervenor-Appellant when, as a matter of law, the interest of Nora
and Rinaldi are adverse (she is the mortgagee and Rinaldi is the mortgagor);
b. Asserting as a fact that Nora was practicing law in violation of her post-disciplinary
suspension requirements, when Nora disclosed her activities as mortgagee in the Rinaldi case and
OLR determined that her Affidavit, including that disclosure, was apparently in compliance with
324. Dykeman’s most recent known or recklessly false statements were transmitted by
mail and wire in violation of Wis. Stat. sec. 946.82(4) and are the most recent predicate acts of
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racketeering in violation of Wis. Stat. secs. 946.80-946.87, and occurred after the June 14, 2018
Foreclosure Enterprise occurred on November 26, 2018, when he attempted to prevent Nora from
having the opportunity to file motions in the appeal of Winiarski’s August 8, 2018 Report and
Recommendation to the Wisconsin Supreme Court in Nora #2 by opposing Nora’s First Motion
326. Like Dykeman in the Rinaldi appeal in Appeal No. 2018AP001390, Schwarzenbart
falsely claimed that Nora was violating the conditions imposed by the March 30, 2018 Opinion
and Order of the Wisconsin Supreme Court, modified on June 12, 2018.
327. Schwarzenbart, as retained counsel for OLR in Nora #1 and Nora #2, knew or
should have known that OLR had determined that Nora’s disclosed post-suspension involvement
in the second Rinaldi foreclosure case as proposed intervenor and on appeal as Intervenor-
Appellant had been determined by OLR on June 18, 2018 to be in apparent compliance with the
post-disciplinary requirements of SCR 22.26, because OLR wrote, “The affidavit appears to
comply with the requirements of SCR 22.26 and it has been placed it in our file concerning your
post-discipline compliance.”
November 26, 2018 were transmitted by mail and wire to Nora in violation of Wis. Stat. sec.
946.82(4), adopting predicate acts of racketeering set forth in 18 U.S.C. sec. 1961(1), which
includes mail fraud in violation of 18 U.S.C. sec. 1341 and wire fraud in violation of 18 U.S.C.
sec. 1343.
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329. The Fraudulent Foreclosure Enterprise has been operating in the State of Wisconsin
using the Wisconsin Unified Court System to launder real estate titles obtained by judgments
entered in Wisconsin circuit courts based on false pleadings, supported by forged documents
authenticated by falsely sworn affidavits contrary to Wis. Stat. secs. 943.20(1)(d), 943.38 and
946.32, using the same scheme as that employed in both Rinaldi foreclosure actions in the
Kenosha County Circuit Court (Case Nos. 2009CV000353 and 2017CV000473) and in Nora’s
second foreclosure case in Dane County Circuit Court (Case No. 2009CV001096).
330. Notice will be given to the Attorney General at the Wisconsin Department of
Justice, 114 East State Capitol, Madison, Wisconsin 53702 that the Plaintiffs challenge the
331. The Unnamed Individuals, Governmental Agencies and Corporate Entities Yet to Be
Named or Identified acted in concert with the named Defendants or at the direction of the named
Defendants in the actions complained of or engaged in other actions or omissions which are
335. Plaintiff re-alleges ¶¶1-9 and 12-331, above, as if fully set forth herein.
336. Plaintiff has been damaged by the unlawful re-disclosure of her confidential medical
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records by the Defendants and others who obtained Plaintiff’s confidential medical records by
and through them, including, but not limited to actual damages, special damages, reputational
337. Sellen was Stieren’s supervisor and failed to supervise Stieren to assure compliance
with Wis. Stat. secs. 146.82(5)(c) and to prevent violations of Wis. Stat. secs. 146.84(1)(b) or
338. Sellen assigned the District Nine Ethics Committee to investigate Potteiger’s
grievance and is responsible for Stieren re-disclosing Plaintiff’s confidential medical records to
the District Nine Ethics Committee because he failed to supervise Stieren to assure compliance
with Wis. Stat. secs. 146.82(5)(c) and to prevent violations of Wis. Stat. sec. 146.84(1)(bm).
339. Sellen failed to take any remedial action upon being informed of the violations of
Wis. Stat. secs. 146.82(5)(c) by Stieren, Kasieta, Parsons, and Hannan to prevent further damage
to the Plaintiff.
340. Plaintiff has been damaged by Sellen’s negligent supervision of Stieren and is
entitled to her damages resulting from Sellen’s negligent supervision including, but not
limited to actual damages, special damages, reputational damages, and mental anguish.
341. Plaintiff has been damaged by the unlawful re-disclosure of her confidential medical
records by the Defendants and others who obtained Plaintiff’s confidential medical records by
and through them, including, but not limited to actual damages, special damages, reputational
342. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.
146.84(1)(bm).
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343. Plaintiff Nora re-alleges ¶¶1-9, 12-331, and 333-342, above, as if fully set forth
herein.
Kasieta, Parsons and Hannan violated Wis. Stat. secs. 146.82(5)(c) and Wis. Stat. secs.
Kasieta, Parsons and Hannan violated Nora’s rights under the Fourth Amendment to the United
States Constitution and Article One, Section 11 of the Wisconsin Constitution, contrary to Wis.
Stat. secs. 146.82(5)(c) and Wis. Stat. secs. 146.84(1)(b) or (bm) and 146.84(2)(a)2.
by Stieren, Kasieta, Parsons and Hannan, deprived Nora of her rights to her Due Process rights
under the Laws of the State of Wisconsin at Wis. Stat. secs. 146.82(5)(c) and Wis. Stat. secs.
Parsons and Hannan deprived Nora of her rights to Equal Protection of the Laws of the State of
Wisconsin at Wis. Stat. secs. 146.82(5)(c) and Wis. Stat. secs. 146.84(1)(b) or (bm) and
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146.84(2)(a)2.
348. By using the requirement that Nora cooperate with OLR investigations under SCR
21.15(4) to obtain confidential guardianship court documents and re-disclosing the confidential
guardianship documents to Potteiger under the pretext of the policy of informing a grievant of an
attorney’s response, Stieren, supervised by Sellen, acting as agent for the Wisconsin Supreme
Court, a governmental entity of the State of Wisconsin, violated Nora’s confidentiality rights in
violation of her Due Process and Equal Protection Rights under the Fourteenth Amendment of
the United States Constitution and Article One, Section 1 of the Wisconsin Constitution.
349. Nora did not know that her confidential guardianship documents had been disclosed
to Potteiger until after she received the untimely discovery produced by OLR on March 31, 2018.
350. By using the requirement that Nora cooperate with OLR investigations under SCR
21.15(4) to obtain information from Nora regarding her work product in her client’s cases and
then re-disclosing her work product to Potteiger, along with her confidential guardianship court
documents under the pretext of informing a grievant of an attorney’s response, Nora was
351. Upon information and belief, were it not for the re-disclosure of Nora’s confidential
medical information, the District Nine Ethics Committee’s investigation would not have
recommended charges and no cause would have been found to charge Nora with ethics violations
in Nora #1.
352. In the alternative to ¶351, above, Nora’s legal and factual contentions would have
been taken seriously were it not for the disclosure of her confidential medical information.
353. Upon information and belief, had Hannan not failed to disclose his conflict of
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interest, which Nora would not have waived requiring him to recuse himself from the PRC in the
Nora case, cause for formal changes would not have been found.
354. Nora has been damaged by the violation of her constitutional rights under the First,
Fourth and Fourteenth Amendments to the Constitution of the United States, contrary to 42
355. Nora is entitled to the remedies for violation of her statutory protections under
146.82(5)(c) and Wis. Stat. secs. 146.84(1)(b) or (bm) and 146.84(2)(a), (b) and/or (c) made
actionable under 42 U.S.C. sec. 1983, as set forth in this Count One, in an amount to be proved at
trial.
356. Nora has been damaged by the unlawful re-disclosure of her confidential medical
records by the Defendants and others who obtained Plaintiff’s confidential medical records by
and through them, including, but not limited to actual damages, special damages, reputational
357. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
COUNT THREE (Nora only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights to Due Process and Equal
Protection of the Laws guaranteed by the Fourteenth Amendment to the United States
Constitution and Article One, Section 1 of the Wisconsin Constitution in OLR’s
Investigative, Charging and Prosecutorial Process based on illegally obtained confidential
medical information as to the State of Wisconsin; the Wisconsin Supreme Court in its
administrative and investigative capacity; named participants in the Wisconsin Lawyer
Regulation System (LRS) and named employees and agents of the Office of Lawyer
Regulation (OLR), as agents for the Wisconsin Supreme Court; Potteiger, individually;
Moglowsky, individually; Fidelity National Title Company, in its corporate capacity and as
Respondeat Superior; Sellen, Stieren, Kasieta, Parsons, and Hannan
358. Plaintiff Nora re-alleges ¶¶1-9, 12-331, 333-341, and 343-357, above, as if
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359. Plaintiff Nora has been damaged by violation of her rights to Due Process and Equal
Protection of the Laws by the unlawful re-disclosure of her confidential medical records by the
Defendants and others who obtained Plaintiff’s confidential medical records by and through
them, including, but not limited to actual damages, special damages, reputational damages, and
mental anguish.
361. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
COUNT FOUR (Nora only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights under the First Amendment and
the Due Process Clause of the Fourteenth Amendment to the United States Constitution and
Article One, Sections 1 and 4 of the Wisconsin Constitution for prosecution of Nora for the
exercise of her Petition Rights in Nora #1 as to the State of Wisconsin; the Wisconsin
Supreme Court in its administrative, investigative and prosecutorial capacity; named
participants in the Wisconsin Lawyer Regulation System (LRS) and named employees and
agents of the Office of Lawyer Regulation (OLR), as agents for the Wisconsin Supreme
Court; Sellen, Stieren, St. Ores and Schwarzenbart, individually
362. Plaintiff Nora re-alleges ¶¶1-9, 12-331, 333-341, 343-357, and 359-361, above, as if
363. Plaintiffs has been damaged by being punished for the exercise of her Petition
Rights, including, but not limited to actual damages, special damages, reputational damages, and
mental anguish.
364. Defendants acted maliciously toward the Plaintiff or with intentional disregard of
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365. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
366. Plaintiffs Nora and King re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, and
367. Plaintiffs have been damaged by the interference with the exercise of Freedom
Speech and of the Press, in violation of 42 U.S.C. sec. 1983, including, but not limited to actual
intentional disregard of the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.
369. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
COUNT SIX (King only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of the First Amendment to the United
States Constitution and Article One Sections 3 and 4 of the Wisconsin Constitution as to the
State of Wisconsin; the Wisconsin Supreme Court in its administrative capacity; the Office
of Lawyer Regulation (OLR), as agent for the Wisconsin Supreme Court; Sellen, Rattan,
LITCHFIELD CAVO, LLP, Dykeman and Winiarski
370. Plaintiff King re-alleges ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365, and
371. Plaintiff King has suffered damages as from the violation of his rights to Freedom
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of Speech, functioning in his capacity as the press under the First Amendment to the Constitution
of the United States and Article One, Section 4 of the Constitution of the State of Wisconsin
which guarantee Freedom of the Press in violation of 42 U.S.C. sec. 1983, including, but not
limited to actual damages, special damages, reputational damages, and mental anguish in an
372. King’s Petition Rights were violated by Winiarski when he ejected King from the
hearing in Nora #2 on March 24, 2017 in retaliation for King’s stated intention to exercise his
Petition Rights.
374. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
375. Plaintiffs Nora and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361,
376. Upon information and belief, the named Defendants have failed to perform their
duties to protect Nora, Rinaldi and other homeowners from the criminal conduct of Wisconsin
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Rights.
377. Plaintiffs have been damaged by the violation of their Petition Rights, contrary to
42 U.S.C. sec. 1983, including, but not limited to actual damages, special damages, reputational
379. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
COUNT EIGHT (Nora and Rinaldi only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First
Amendment to the United States Constitution and Article One Section 3 of the Wisconsin
Constitution as to the State of Wisconsin; the Supreme Court of Wisconsin, by its agents the
Lawyer Regulation System (LRS), Sellen, Goldman, and Winiarksi, in their claimed official
capacity and in their individual capacities; and Rattan and Dykeman, individually; and
Litchfield Cavo, LLP and Wells Fargo Bank, N.A.,
in their corporate and individual capacities
380. Plaintiff Nora and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-
365, 367-369, 371-374, and 376-379, above, as if fully set forth herein.
381. Plaintiffs were damaged by interference with the press to expose the activities at the
383. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
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384. Plaintiff Nora and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-
365, 367-369, 371-374, 376-379, and 381-383, above, as if fully set forth herein.
385. Upon information and belief, Plaintiffs Nora and Rinaldi and other clients of Nora
were damaged by the interference in their attorney-client relationship by the disclosure of Nora’s
confidential work product to Stieren, who re-disclosed her work product to Potteiger and Foshag,
388. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
COUNT TEN (Nora, King and Rinaldi) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First and
Fourteenth Amendments to the United States Constitution and Article One Sections 3 and 4
of the Wisconsin Constitution as to the State of Wisconsin, the Wisconsin Supreme Court in
its administrative capacity, the Office of Lawyer Regulation (OLR), as agent for the
Wisconsin Supreme Court, and Sellen
389. Plaintiffs Nora, King and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-
361, 363-365, 367-369, 371-374, 376-379, 381-383, and 385-388, above, as if fully set forth
herein.
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390. Plaintiffs have been damaged by the violation of their Petition Rights including, but
not limited to actual damages, special damages, reputational damages, and mental anguish.
392. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
393. Plaintiffs Nora and King re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-
365, 367-369, 371-374, 376-379, 381-383, and 385-392, above, as if fully set forth herein.
394. Plaintiffs have been damaged by the violation of their Petition Rights due to the
failure to adequately train and supervise referees in the LRS including, but not limited to actual
determined at trial.
395. Plaintiffs re-allege re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365,
367-369, 371-374, 376-379, 381-383, 390-392, and 394, above, as if fully set forth herein.
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396. Plaintiffs have been damaged by the violation of WOCCA by the violations of Wis.
Stat. secs 943.20(1)(d), 943.38(1), 946.30, 946.30, 946.82(4) incorporating 18 U.S.C. secs. 1341,
1343, via 18 U.S.C. 1961(1) in the amount of double their damages, including, but not limited to
a. For Nora: the loss of the right to peaceful enjoyment of her home from activities of the
b. For Nora: the loss of equity in her home from the activities of the Fraudulent
c. For Rinaldi: the loss of the right to peaceful enjoyment of his home from activities of
d. For Rinaldi: the loss of the opportunity to build equity in his home from the activities
397. Plaintiffs Nora and King have been damaged by the injury to their intellectual
property rights: for Nora, her property right to the complete video record of the events and
activities at the March 24 and 27, 2018 for posterity and for the documentary film she has
planned which has been lost forever; and for King, the right to use the video content for
journalistic purposes.
398. Plaintiffs Nora and King are entitled to double their loss of intellectual property
399. Plaintiffs Nora, King and Rinaldi are entitled to double the amount of their special
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against the Plaintiffs or in reckless disregard of their rights, contrary to Wis. Stat. sec. 895.043.
401. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.
402. Plaintiffs re-allege re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365,
367-369, 371-374, 376-379, 381-383, 390-392, 394, and 396-401, above, as if fully set forth
herein.
adjudicatory and appellate capacities and the named participants in the Wisconsin Lawyer
Regulation System, Sellen, Stieren, Kasieta, Parsons, Hannan, Schwarzenbart, Winiarski, acting
in concert with Potteiger and Moglowsky discriminated against Plaintiff Nora for her perceived
disability and used her medical condition to punish her in Nora #1 and Nora #2.
404. Plaintiff Nora has been damaged by the Defendants’ discrimination against her for
her perceived disabilities in violation of the ADAA, including, but not limited to actual
406. Nora is entitled to punitive damages to the extent allowed by Wis. Stat. sec.
895.043.
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407. Plaintiffs re-allege re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365,
367-369, 371-374, 376-379, 381-383, 390-392, 394, and 396-401, 403-405, above, as if fully set
forth herein.
Chapters 21 and 22, facially or “as applied” and/or for injunctive relief to prevent continuing and
A. Nora requests judgment on Count One for her actual damages, special damages,
reputational damages, and mental anguish and for the applicable exemplary damages allowed by
Wis. Stat. sec. 146.84(1)(b) and (bm), and for such other relief as may be just and appropriate in
these premises.
B. Plaintiff Nora requests judgment for her claims under 42 U.S.C. sec. 1983 on Counts
Two, Three and Four for her actual damages, special damages, reputational damages, and mental
anguish and for the applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an
C. Plaintiffs Nora and King request judgment on their claims under 42 U.S.C. sec. 1983
on Count Five for their actual damages, special damages, reputational damages, and mental
anguish and for the applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an
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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 97 of 102
D. Plaintiff King requests judgment on his claim under 42 U.S.C. sec. 1983 on Count Six
for his actual damages, special damages, reputational damages, and mental anguish and for the
determined at trial.
E. Plaintiffs Nora and Rinaldi request judgment their claims under 42 U.S.C. sec. 1983
on Counts Seven, Eight and Nine for their actual damages, special damages, reputational
damages, and mental anguish and for the applicable exemplary damages allowed by Wis. Stat.
F. Plaintiffs Nora, King, and Rinaldi request judgment on Counts Ten and Eleven under
42 U.S.C. sec. 1983 for their actual damages, special damages, reputational damages, and mental
anguish and for the applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an
G. Plaintiffs Nora, King, and Rinaldi request judgment on Count Twelve for their actual
damages, special damages, reputational damages, and mental anguish for violations of the
Wisconsin Organized Crime Control Act (WOCCA) at Wis. Stat. sec. 946.80-946.87 and for the
determined at trial.
H. Plaintiff Nora requests judgment on her claim for violations of her ADAA Rights at
42 U.S.C. sec. 12101, et seq. under 42 U.S.C. sec. 1983 on Count Six for his actual damages,
special damages, reputational damages, and mental anguish and for the applicable exemplary
85
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 98 of 102
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