The New Alanna Krause Case in Nuszen v. Nuszen

THE NEW ALANNA KRAUSE CASE

Nuszen, Gabrielle, v. Nuszen, Jack, et al. in the US Southern District of Texas, Houston Division

UPDATE: HANNAH NUSZEN(“H.N.,”)  

Transported to Solacium

New Haven Residential Treatment Center in

Utah . . .

to be Silenced, at Best

  1. Christina Wanies-Guirgis
    Texas Bar No. 24084772
    9555 W. Sam Houston Pkwy S., Suite 130
    Houston, Texas 77099
    Tel: (832) 582-8331
    Fax: (832) 379-7490
    Christinaw@waniesguirgispllc.com

Thomas M. Burton via pro hac vice
Utah Bar No. 00518
California Bar No. 035856
P.O. Box 1619
Salt Lake City, Utah 84110
Tel: (801) 918-1656
Thomasburtonlaw@aol.com

ATTORNEYS FOR GABRIELLE NUSZEN

IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE SOUTHERN DISTRICT OF TEXAS
______________________________________________________________

GABRIELLE NUSZEN, an individual and Guardian ad Litem for her minor sisters,

H.N., K.N., D.N. and Z.N., Minors,

Plaintiffs,

vs.

JACK NUSZEN; SHANNON ORAND NUSZEN; KAREN GOLLAHER; JAY BEVAN; GUARDIANS OF HOPE, a Texas Corporation; NORMA WILLCOCKSON; DOE DEFENDANTS I through X, inclusive; and DOE DEFENDANTS XI through XX, inclusive.

Defendants.

Case No. _________________________

COMPLAINT FOR PERSONAL INJURY,

FALSE IMPRISONMENT;

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS;

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS;

INVASION OF PRIVACY;

NEGLIGENCE; BREACH OF FIDUCIARY DUTY;

STRICT LIABILITY OF CARRIER;

CHILD ABUSE;

INJUNCTIVE RELIEF;

HABEAS CORPUS

JURY DEMANDED

     COME NOW, the Plaintiffs, GABRIELLE NUSZEN individually and as Guardian ad Litem for her minor sisters, H.N., K.N., D.N. and Z.N.

NATURE OF THE CASE

This is a case brought by all five daughters of Defendant, JACK NUSZEN (hereinafter “JACK”), their physically and emotionally abusive biological father, seeking protection from him notwithstanding physical custody that Harris County has negligently bestowed upon him in defiance of medical reports of serious and repetitive physical and emotional abuse that he has visited upon them.

JACK has been able to buy immunity from prosecution for child abuse in the family courts of Harris County, and has defied a Harris County custody order with impunity. Harris County agencies charged with protecting the Plaintiffs from JACK suffer from extreme laxity of duty and neglect of care, forcing the Plaintiffs to resort to this Court to protect their freedom and their constitutional rights.

PARTIES

1.      Plaintiff, GABRIELLE NUSZEN, (hereinafter “Gabrielle”), is a citizen of the State of [CONFIDENTIAL].

2.      Plaintiff H.N. has been held captive against her will and without her consent at several Utah licensed residential treatment centers — Aspen Assessment Center in Syracuse, Utah and New Haven Academy in Saratoga Springs, Utah for over a year, and has thus been forced to become a citizen of Utah.

3.      Plaintiffs, K.N., D.N. and Z.N., are minor citizens of the State of Texas, who have endured years of physical and emotional abuse at the hands of the Defendants, particularly JACK and SHANNON (referenced to below).

4.      Defendant, JACK NUSZEN, is the biological father of Gabrielle Nuszen and her minor sisters, H.N, K.N., D.N., and Z.N., and is a citizen of Texas.

5.      Defendant, SHANNON ORAND NUSZEN, is the wife of JACK and step-mother of Gabrielle and her minor sisters, H.N, K.N., D.N., and Z.N., and is a citizen of Texas.

6.         Defendant, KAREN GOLLAHER, is a psychologist appointed by the Harris County District Court and has failed and refused to protect any and all of the Plaintiffs.

7.       Defendant, JAY BEVAN, is a therapist appointed by Harris County and has failed and refused to protect any and all of the Plaintiffs.

8.        Defendant, GUARDIANS OF HOPE, is a Texas corporation that is an escort service that JACK paid to       take H.N. from her school and transport her across State lines from Texas to Utah to leave her stranded against   her will and without her consent.

9.       Defendant, NORMA WILLCOCKSON, is a Texas resident who owns and operates Guardians of Hope.

10.     Doe Defendants I through X are citizens of the State of Texas and employees of Harris County, Texas or   affiliated with it who, at all times material, were acting within the course and scope of their employment, or   authorization, as agents for the other named Defendants.

11.      Doe Defendants XI through XX were government agencies having regulatory powers and responsibilities   over the safety of the Plaintiffs, and the employees of said agencies, who at all times material were acting either within the course and scope of their employment and authorization, or else as individuals, but in either case as agents for the other named Defendants.

JURISDICTION

12.      Jurisdiction of this Court is invoked pursuant to: (a) 28 U.S.C. § 1332(a), (b), and (c); and (d) .  The amount in controversy exceeds the sum of Seventy Five Thousand Dollars.

VENUE

13.      Venue is appropriate in this Court pursuant to the provisions of 28 U.S.C. § 1391(a), (b) and (c).

FACTS

14.      After Miriam Nuszen divorced JACK he thereafter manipulated Harris County into giving him primary custody of all five of his daughters.

15.      In that position JACK promoted, by a frequent and consistent pattern of false representations and suppression of fact, that Miriam was afflicted with several levels of mental and emotional illness that adversely affected each and all of the Plaintiff children. He many times reported her and the children to The Department of Child and Family Services as part of a strategy to have them removed from their home with her, and to be placed with him for eventual shipment out of state in further retribution for the divorce.

16.      JACK established a pattern and practice of telling Harris County psychologists, counselors, judges, attorneys, police officers, and any and all other officials having anything to do with child care that Miriam was an inept and incompetent mother psychologically unfit to raise his daughters.

Contrary to fact, Miriam is a brilliant health care industry employee whom each and all of the daughters dearly love and wish to be with.

17.      Miriam filed a police report, on or about two years ago, alleging that JACK threatened to kill her and their children. However, the Court refused to listen to such evidence and testimony, and failed to take such a report into consideration in rendering the custody order. In fact, JACK has sexually and physically abused Miriam during the course of their marriage, as well as abuse the children on repeated occasions.

18.      JACK, however, is a sociopathic liar and abuser of his children. For this reason, he hired Defendant NORMA WILLCOCKSON, and her escort service to remove H.N. without warning and against her will and consent from her Texas high school where she was a very excellent student of sound character.

19.      JACK sent H.N. to Island View Academy in Syracuse, Utah.

See Exhibit A:

Humana Provider Demographic Report Rendering Provider Name with Address. Island View’s philosophy is to deprive its participants of all contact with the outside world, to treat them with rudeness and hostility, and to punish them for disobedience by deprivation and physical abuse. Island View has been and continues to be the subject of much litigation and controversy over its mistreatment of the captive children under its supervision and control.

The tuition costs are enormous for a program run by amateurs who have no concept of proper health care administration or behavior. It has received much notoriety and adverse comment on survivor sites for its maltreatment of adolescents kept captive in its care.

20.      The state of Utah licenses such places as “residential treatment centers,” but there is no transparency, no accountability and minimal regulation, mostly by low level social workers aided by minimum wage enforcers of mindless rules measured by forced behavior of mostly truants thrown together without discrimination about who needs what treatment and why.

21.      There was never any screening or adjudication that H.N. needed any type of behavior modification. H.N. was taken without warning and has been forced to survive at Island View Academy. It is now upon new information and belief that H.N. has been moved to New Haven Academy without anyone accounting for her welfare or condition, either physical or mental.

FIRST CAUSE OF ACTION: PERSONAL INJURY

22.       Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

23.       JACK, as father and custodian of H.N., had a duty to protect her, care for her, and keep her safe. JACK, however, breached his duty:

a.      By failing to notify H.N. that he was going to send her out of state to Utah to be confined for the indefinite future at Island View Academy.

b.      By failing to obtain H.N.’s informed consent to be confined at Island View Academy.

c.      By failing to inform himself that Island View Academy was not a school, but a rigorous and punitive behavior modification technique reformatory, to which H.N. was not accustomed, and by failing to have determined by an independent physician or psychologist that there was any legitimate need to send H.N. to Island View in Utah for such harsh treatment that typically in adolescents causes post-traumatic stress disorder.

d.      By failing to understand that H.N. would be put in the company of many young women who were truant, addicted to drugs, promiscuous, convicted of criminal behavior, and that they were at Island View not for recreation, education, or counseling, but for severe behavior modification.

e.      By failing to consider whether H.N’s association with such individuals needing severe obedience training, often by rough handling and rude treatment, and that she would be there as well as the others under the overall assumption that everyone enrolled was truant, defiant, drug addicted, and sexually active, would be an appropriate placement for H.N. who was none of the above, but who would be likely contaminated by those who were.

f.      By making a placement that would deprive, for an indefinite period, H.N. of any association and communication with her mother and sisters whom she dearly loves.

g.      By instructing Island View Academy to prohibit H.N’s mother from having any contact with H.N., and not informing H.N. that she had not been abandoned by her mother and sisters, and that their not contacting her was due to their father’s prohibition carried out by the academies.

h.      By keeping H.N. separate from her sisters with whom she has had no contact whatsoever for over a year.

24.      Miriam Blank, H.N.’s mother, along with her sisters, had a close, warm and loving relationship with H.N. As a proximate result of the described separation, JACK deliberately damaged and harmed H.N., her sisters and their mother.

25.      JACK’s conduct was malicious, wanton and in reckless disregard of H.N.’s health, safety and welfare, by reason of which she and her sisters are entitled to recover punitive damages.

26.      Plaintiffs pray that this Court order JACK to release H.N. from Island View Academy or New Haven Academy or wherever else he is hiding her, and return her to her sister and Guardian ad Litem, Gabrielle, in [CONFIDENTIAL].

 

SECOND CAUSE OF ACTION: FALSE IMPRISONMENT

27.      Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

28.      H.N. learned upon arrival at Island View Academy that its operation was designed to imprison her against her will and without her consent, and that she had no recourse by communicating with her mother to free her from the benighted treatment to which she was hopelessly subject. She sought to leave the program, but Island View restrained her from any contact with the outside world, and refused her request to return to her mother.

29.      JACK’s confinement of H.N. at Island View in Utah wrongfully violated the Texas custody order that governed his care and keeping of H.N. He knew that his daughter, H.N., was of an age where she had federal and state constitutional rights to due process and a liberty interest not to be unlawfully confined by any parent, with or without custody, in a punitive, isolated, foreign venue with no recourse or contact with family members or legal assistance to gain release. JACK also knew full well that Island View, in keeping H.N. captive and isolated, would cause H.N. to suffer severe emotional distress due to the punitive treatment she would receive and the absence from her mother and the Plaintiffs that she would suffer.

30.      JACK’s conduct was malicious, wanton and in reckless disregard of H.N.’s health, safety and welfare, by reason of which she is entitled to recover punitive damages against him.

31.      Plaintiffs pray for judgment as hereafter stated.

THIRD CAUSE OF ACTION: INTENTIONAL INFLICTION
OF EMOTIONAL DISTRESS

32.      Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

33.      JACK’s sordid history of physically hurting H.N. and locking her away from family, friends, teachers, coaches, and home without warning, and in a brusque, public, humiliating manner, as if she were a person severely mentally ill or highly truant, caused her grievous mental and emotional distress.

34.      JACK’s conduct was outrageous, malicious, wanton and in reckless disregard of H.N.’s health, safety and welfare, by reason of which she is entitled to recover punitive damages.

35.      Plaintiffs pray for judgment as hereafter stated.

FOURTH CAUSE OF ACTION: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

36.      Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

37.      JACK had a duty to safeguard H.N. from demented hazing, denigration, isolation, confinement, and deprivation at his sole pleasure, and also not to inflict emotional distress on her sisters by depriving each and all of them from having contact with H.N. and she with them.

38.      JACK violated his duty to H.N. and her sisters by keeping them not only apart, but also in secret silence from each other, and their mother.

39.      JACK’s conduct was in reckless disregard of H.N.’s and her sisters’ health, safety and welfare, by reason of which Plaintiffs are entitled to recover punitive damages.

40.      Plaintiffs pray for judgment as hereafter stated.

FIFTH CAUSE OF ACTION: INVASION OF PRIVACY

 

41.      Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

42.      By having H.N. suddenly taken in broad daylight from her high school and in front of her peers by an escort service, and put in a Utah punitive behavior modification program totally isolated and silenced from all contact with family and friends, JACK cast H.N. in a false light as having done something so horribly wrong so that she was not fit to be trusted in normal society, including her own family.

43.      JACK’s conduct has caused Plaintiffs great mental and emotional distress.

44.      JACK’s conduct was malicious, wanton and in reckless disregard of H.N. and her sisters’ health, safety, and welfare, by reason of which the Plaintiffs are entitled to recover punitive damages.

45.      Plaintiffs pray for judgment as hereafter stated.

SIXTH CAUSE OF ACTION: NEGLIGENCE

46.        Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

47.       JACK had a father’s duty to treat her with dignity, respect, and tenderness. He, however, negligently conceived, supervised, maintained and controlled H.N.’s negligent imprisonment at Island View Academy and New Haven Academy in the particulars set out above.

48.      JACK’s conduct proximately caused personal injury and emotional distress to H.N. for all of 2014, and there is every indication, unless this Court intervenes, that he will continue to keep her away from the Plaintiffs and her mother until her majority two years hence.

49.       JACK’s conduct is in reckless disregard of H.N.’s health, safety and welfare, by reason of which Plaintiffs are entitled to recover punitive damages.

50.      Plaintiffs pray for judgment as hereafter stated.

SEVENTH CAUSE OF ACTION: BREACH OF FIDUCIARY DUTY

51.      Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

52.      By enrolling H.N. at Island View Academy and New Haven Academy in Utah, JACK cavalierly transferred his fiduciary duty as custodian of H.N. to surrogate strangers of no known merit in a foreign state who would, in turn, take H.N. into an unknown isolated, inhospitable and unforgiving area in a captive situation. JACK signed a power of attorney, giving custody of H.N. to Aspen and New Haven, which is evidenced in the contract between JACK and the residential treatment centers.

53.      Island View and New Haven breached their transferred fiduciary duties as surrogates to act in H.N.’s best interest, which proximately caused H.N. to sustain great pain, suffering, bodily injury and feelings of abandonment, and the Plaintiffs to suffer grievous mental and emotional distress over the needless suffering and isolation of their sister.

54.      The conduct of JACK in abandoning his duties under Title 5, Section 151.001(a)(2) and (3) of the Texas Family Code in favor of unknown Utah surrogates of no merit and dubious reputation was malicious, wanton and in reckless disregard of his fiduciary duty to care for H.N.’s health, safety and welfare, by reason of which Plaintiffs are entitled to recover both general and punitive damages against JACK, their father, for splitting them up and sending H.N. away, never to be seen or heard from again, a likely destiny for the remaining younger sisters unless this Court intervenes to prevent such a prospect.

55. Plaintiffs pray for judgment as hereafter stated.

EIGHTH CAUSE OF ACTION: STRICT LIABILITY OF CARRIER

56. Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

57.      JACK, in hiring NORMA WILLCOCKSON, to transport H.N. from Houston, Texas into Syracuse, Utah had a duty to use utmost care and diligence for H.N’s safe carriage, and was under the obligations to provide everything necessary for that purpose and to exercise to that end a reasonable degree of skill.

58.      For the reasons above stated, NORMA WILLCOCKSON failed to use utmost care
and diligence for the safe carriage of H.N., but followed JACK’s instructions to take H.N., whose mother also had custody, from her to an undisclosed location, and to take her suddenly without warning, and against her will and without her consent, knowing full well that such transport had to do with minors who have constitutional rights not to be kidnapped by one parent from another, both of whom have custodial rights and duties to be with their children, and they with them.

59.      NORMA WILLCOCKSON does this transporting of young people across state lines as a lucrative business without checking to see whether or not the transportation is regulated by interstate compact, and knows that her cargo is going to be confined in lock-down captivity without due process or any way to escape.

60.      The conduct of NORMA WILLCOCKSON was in reckless disregard of H.N.’s, health, safety and welfare, by reason of which both H.N. and her sisters are entitled to recover punitive damages.

61.      Plaintiffs pray for judgment as hereafter stated.

NINTH CAUSE OF ACTION: CHILD ABUSE

62.      Plaintiffs incorporate by this reference the foregoing paragraphs as if stated in full.

63.      JACK, while having the care, custody and control of H.N., isolated her from her mother in an unfamiliar area of the Utah desert at Island View and New Haven academies, and did so in order to:

a.      Subject H.N. to conditions and circumstances likely to produce great bodily and emotional harm;

b.      Cause her to suffer, and negligently allowed to be inflicted upon her unjustifiable physical pain and mental suffering;

c.      Cause or permit her to be injured; and

d.      Cause or permit her to be placed in such a situation that her health would be endangered.

64.      Before H.N. was sent to Utah, JACK physically abused both H.N., Gabrielle, and all of her sisters as their individual affidavits will show. Gabrielle has endured abuse from her father; as noted in a physician’s statement regarding Gabrielle’s injury in 2010, “dad hit…in face…abrasion to inside of bottom lip.[Gabrielle] has bruise to lower back and 2 fingerprint marks to L. [left] side of neck. [Gabrielle] states dad held her under water…”

See Exhibit B: Physician’s Statement Regarding Injury to Gabrielle Nuszen;

see also Exhibit C: Gabrielle Nuszen’s Affidavit, dated September 29, 2013; also

see Exhibit D: Physician’s Statement Regarding Injury to Kayla Nuszen.

65.      JACK’s cruel and reckless conduct toward these choice young girls is inexcusable and warrants this Court’s removal of JACK’s custody of and contact with his children hereinafter and forever.

66.      This Court has a duty to order a complete independent psychological assessment of JACK in order to ascertain whether or not he is a sociopath, in addition to having a narcissistic personality disorder or other mental health defects that need treatment, supervision and restraint from contact with his children.

PRAYER FOR RELIEF

          WHEREFORE, Plaintiffs pray for judgment as follows:

1.      A Writ of Habeas Corpus producing H.N. before this Court to be examined as to her present circumstances and as to whether or not she has the right to be released from Island View, Aspen, or New Haven in Utah and returned to her sister, Gabrielle, in [CONFIDENTIAL].

2.      Injunctive relief in the form of an Order enjoining further possession of H.N. by any aforesaid venue in Utah, and immediately releasing H.N. and transferring legal and physical custody to her sister, Gabrielle, so that she may provide for H.N.’s education at legitimate schools in the State of [CONFIDENTIAL] or elsewhere, before H.N. falls further behind academically.

3.      General damages according to proof, but in no event lower than $100,000.

4.      Punitive damages according to proof.

5.      Costs of suit.

6.      Such other and further relief that the Court deems just.

Dated: March 12, 2015

Respectfully Submitted,
/s/ Thomas M. Burton
Thomas M. Burton via pro hac vice
Utah Bar No. 00518
California Bar No. 035856
P.O. Box 1619
Salt Lake City, Utah 84110
Tel: (801) 918-1656
Thomasburtonlaw@aol.com

/s/ Christina Wanies-Guirgis
Christina Wanies-Guirgis
Texas Bar No. 24084772
9555 W. Sam Houston Pkwy S., Suite 130
Houston, Texas 77099
Tel: (832) 582-8331
Fax: (832) 379-7490
Christinaw@waniesguirgispllc.com

“On April 3, 2014, another lawsuit was filed by a mother from Houston, Texas in Utah Federal Court against Aspen Education Group, Aspen Institute of Behaviorial Assessment, Bain Capital, Guardians of Hope, Harris County Office of Human Resources and Risk Management, lead defendant Jack Nuszen, and Norma Willcockson, the alleged child trafficker that transported the teenage girl from Houston, Texas to Syracuse, Utah forcibly against her will to be locked up in Aspen RTC. In the lawsuit, the mom called the place a private prison”

Related Cases and Opinions, or “Comments” and “Consensus” (You may cut and paste the following links into your browser to access the following):

Mom Calls Rehab a Private Prison, Courthouse News.com, Johnny Bonner, Monday, April 07, 2014, last update: 1:45AMPT, http://www.courthousenews.com/2014/04/07/66859.htm, khttps://www.docketalarm.com/cases/Utah_District_Court/1–14-cv-00041/Blank_v._Nuszen_et_al/Blank v. Nuszen et al, Utah District Court, Case No. 1:14-cv-00041
Magistrate Judge Evelyn J. Furse, presiding, docket://gov.uscourts.utd.1-14-cv-00041, http://www.plainsite.org/dockets/262qlvzq7/utah-district-court/blank-v-nuszen-et-al/;http://www.law360.com/cases/533dc9e7d0a47d14bc00ae93Miriam Blank v. Jack Nuszen Appeal from 246th District Court of Harris County (memorandum opinion )(opinion issued August 11, 2015),http://law.justia.com/cases/texas/first-court-of-appeals/2015/01-13-01061-cv.html; http://caselaw.findlaw.com/tx-court-of-appeals/1710332.html;Court of Appeals of Texas, Houston (1st Dist.); https://casetext.com/case/blank-v-nuszen-2(Miriam Blank, Appellant v. Jack Nuszen, AppelleeNO. 01–13–01061–CV Decided: August 11, 2015);(Read more at: http://caselaw.findlaw.com/tx-court-of-appeals/1710332.html#sthash.V2pBXcU0.dpuf);https://www.pacermonitor.com/public/case/3175847/Blank_v_Nuszen_et_al;

(Dedicated to) The Real Mommies and Daddies of the Real America,and Our Children Who Want to Come Home, inspired by/for my little Julian-Jacob “Worrell”: of family Saloom; UPDATE: HANNAH NUSZEN(“H.N.,”)  Transported to Solacium New Haven Residential Treatment Center in Utah . . .to be Silenced, at Best, https://jonisaloom.wordpress.com/2015/04/22/the-new-alanna-krause-case-nuszen-gabrielle-v-nuszen-jack-et-al-in-the-us-southern-district-of-texas-houston-division/; https://redditjs.com/r/troubledteens/comments/351aaf/L/351aaf; http://wwaspsurvivors.com/breakingcodesilence/; Court Accused (Alanna Krause Case), http://jillkramer.net/court-accused/, Children Against Court-Appointed Child Abuse-CA3, by Jennifer Collins, Holly Collins’ daughter, http://ca3cacaca.blogspot.com/2008_11_01_archive.html;CHILDREN SENT TO “REPROGRAMMING” CAMP IF THEY REFUSE TO RECANT SEX ABUSE BY FATHER By RebelWCause, Posted January 10, 2010,San Diego, California,Full Text of IACHR Petition. On May 11, 2007 – Just before Mother’s Day weekend, ten mothers, one victimized child, now an adult, leading national and state organizations filed a complaint against the United States,http://www.scribd.com/doc/163320183/Full-Text-of-IACHR-Petition-On-May-11-2007-Just-before-Mother-s-Day-weekend-ten-mothers-one-victimized-child-now-an-adult-leading-national-an

----- Original Message -----
From: JLSIlberg@aol.com
To: sinaia5@netvision.net.il
Sent: Tuesday, November 05, 2002 4:24 PM
Subject: the children are fighting back


Israel will have the following mess to look forward to in the next few
years if they continue on the current path.
See below.
Joy

731 Fern Street . New Orleans, Louisiana 70118. 
504.314.8400.
504.314.8600 
                        Fax .mailto:Ducotelaw@aol.com                            
                                                                        
           Becki L. Truscott, Asssociate  Counsel  
   Of the N.C.   
 FOR IMMEDIATE RELEASE: November 3,2002
LAWSUIT FILED BY ALANNA KRAUSE AGAINST HER FATHER, THERAPIST, AND COURT 
-APPOINTED ATTORNEY Marin County's Marshall Krause, Sandra M. Acevedo, 
Lana Clark, Ph.D. and Diamond, Bennington & Simborg, P.C. all named in 
Federal Lawsuit
       Eighteen year old Alanna Krause filed a multi-million dollar 
federal court lawsuit [Case No. C-02-5277, Northern District of 
California on November 1 in San Francisco against her father, Marin 
County attorney Marshall W. Krause, her psychotherapist Lana Clark, her 
court-appointed attorney Sandra Acevedo and the law firm of Diamond, 
Bennington & Simborg, alleging that she suffered years of childhood 
abuse at the hands of her father. 

Ms. Krause claims that Acevedo and Clark knew of her abuse, but failed to protect her.  Ms. Krause, now an 
honors student at Northwestern University, has been a vocal critic of 
the Marin County family court system and the use of court-appointed 
attorneys for children in custody cases who ignore substantial evidence 
of child abuse and fight to keep children with parents about whom the
children complain. Ms. Krause demands a trial by jury on all issues.    
    On July 17, 2000, The San Francisco Daily Journal published Ms. 
Krause=E2=80=99s editorial comment, =E2=80=9C 
Letting Children Speak for 
Themselves: Youth in Court Need Attorneys Who Represent Their Interests 
Fairly, Strongly.=E2=80=9D

http://www.ocof.org/KidsSpeakOut/Alanna=E2=80=99s%20Truth.htm and/or 
http://www.leadershipcouncil.org/Research/PAS/PAS4/pas4.html.


       Ms. Krause is represented by a nationally renowned legal team,
New Orleans attorneys Richard Ducote and Becki Truscott,and Napa 
attorney Seth Goldstein.
________________________________________________________________
Contact: Richard Ducote, Attorney at Law, 504.314.8400
              Seth Goldstein, Attorney at Law, 707.226.6660
              Alanna Krause, mailto:  alannakrause@hotmail.com   
     
Additional resource: 

Richard Ducote, Guardians ad Litem in Private 
Custody Litigation: The Case for Abolition, 3 Loyola Journal of Public 
Interest Law 106 (Spring 2002).
_________________________________________________________________________

CIVIL ACTION
C 02 5277

Seth L. Goldstein (Cal. Bar # 176882)
1125 Jefferson Street
Napa, CA 94559
(707) 226-6660
(707) 226-6661 [Fax]
Local Counsel for Plaintiff Alanna Krause
__________________________________
Richard L. Ducote, of the Louisiana Bar
Counsel pro hac vice for Plaintiff Alanna Krause
Office of Richard Ducote, Attorney at Law
731 Fern Street=20
New Orleans, LA 70118
(504) 314-8400
(504) 314-8600 [Fax]
___________________________________
Becki L. Truscott, of the North Carolina Bar
Counsel 

pro hac vice for Plaintiff Alanna Krause
Office of Richard Ducote, Attorney at Law
731 Fern Street
New Orleans, LA 70118
(504) 314-8400
       (504) 314-8600 [Fax]
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
          ALANNA KRAUSE,                                                 
Plaintiff
                                 CIVIL ACTION NO.
                                  C-02-5277
vs.
 
MARSHALL W. KRAUSE; SANDRA ACEVEDO;
DIAMOND, BENNINGTON & SIMBORG, P.C.; and LANA CLARK, PH.D., Defendants
                                      JURY TRIAL DEMANDED
___________________________________
 COMPLAINT FOR COMPENSATORY AND PUNITIVE DAMAGES

     The Complaint of Alanna Krause,through the undersigned counsel, respectfully shows as follows:=20 NATURE OF COMPLAINT=20 1. This is an action to recover compensatory and punitive damages on = behalf of Plaintiff Alanna Krause, who, because of the tortious conduct = of all of these Defendants from approximately 1993 through 1997, and the tortious conduct of Defendant Marshall W. Krause from approximately 1991-1997, as set forth herein, suffered, inter alia, years of ongoing severe physical, psychological and emotional abuse.

 PARTIES

 2. Plaintiff Alanna Krause is an eighteen (18) year old female citizen of the State of Illinois. She is the biological daughter of Defendant Marshall W. Krause. domiciled within this District. He is an attorney and the biological father of Plaintiff Alanna Krause. Furthermore, at all times relevant herein he was the romantic/sexual partner of Defendant Lana Clark.
 
4. Defendant Sandra Acevedo is a citizen of the State of California domiciled within this District. She is an attorney, and at all times relevant herein the attorney appointed to represent the interests of the Plaintiff Alanna Krause in the Marin County Superior Court,Case No. FL4889, In re: Marriage of Marshall W. Krause and Lauren Krause.
 
5. Defendant Diamond, Bennington & Simborg, P.C. is a professional law corporation chartered under California law and domiciled in this District. At all times relevant, it was the employer of Defendant Acevedo and, thus, vicariously liable for her tortious conduct as set forth herein.

 6. Defendant Lana Clark, Ph.D. is a citizen of the State of California domiciled within this District. At all times relevant herein,she was a licensed California mental health professional serving as a "psychotherapist"for Plaintiff Alanna Krause, while at the same time engaging in a romantic/sexual relationship with Defendant Marshall W. Krause.

 JURISDICTION AND VENUE

 7. This Court has jurisdiction over this action pursuant to 28 U.S.C.§ 1332, as there is complete diversity of citizenship between the parties and the damages exceed $75,000 exclusive of costs and interest.
 
8. This Court is the proper venue for this action pursuant to 28 U.S.C.1391 (a), as a Defendant resides within this District and a substantial part of the tortious conduct complained of herein occurred within this District.

 CAUSES OF ACTION: DEFENDANT MARSHALL W. KRAUSE

 (ASSAULT & BATTERY, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, CONSPIRACY TO DEPRIVE PLAINTIFF OF ACCESS TO THE COURTS, TORTIOUS INTERFERENCE WITH MOTHER-CHILD RELATIONSHIP)

 9. Plaintiff re-urges Paragraphs 1-8 in extenso.

 10. Assault and Battery:

 During the course of Plaintiff's minority inCalifornia
 and elsewhere, Defendant Marshall W. Krause repeatedly,intentionally, violently, and cruelly assaulted and battered Plaintiff = causing her severe physical, psychological, and emotional pain and = suffering, the effects of which Plaintiff will suffer for the rest of = her life
 
11. Intentional Infliction of Emotional Distress:

 During the course of Plaintiff's minority, Defendant Marshall W. Krause continuously, = repeatedly, intentionally, and cruelly inflicted severe emotional = distress on Plaintiff Alanna Krause by threatening her, intimidating = her, berating her, manipulating her, and improperly admitting her to a = locked treatment facility for the purpose of squelching her reports of = his abuse and severing her contact with the outside world. Such = conduct was intentional, outrageous, and designed to inflict severe = emotional distress on Plaintiff.
 
12. Conspiracy to Deprive Plaintiff of Access to the Courts: 

During the course of the pendency of child custody and visitation proceedings in the Marin County Superior Court, Defendant Marshall W. Krause conspired with Defendants Lana Clark and Sandra Acevedo to deprive Plaintiff of her right to access to and protection of the court by intentionally and maliciously discrediting Plaintiff and her mother's accurate reports of Defendant Krause's abuse, by preventing Plaintiff from presenting evidence to the court concerning her father's abuse, by maliciously attempting to deny Plaintiff the benefit of juvenile court child protection proceedings and by denying Plaintiff the benefit of counsel who truly would advocate for the child rather than advocating for the interests of Defendant Krause and his lover Lana Clark.

 13. Tortious Interference with Mother-Child Relationship:

 From approximately 1993-1999, Defendant Marshall W. Krause intentionally, maliciously, and tortiously interfered with Plaintiff's relationship with her mother by denying her contact with her mother, battering her as punishment for having contact with her mother, isolating her from her mother, harassing and intimidating her mother in the course of the custody litigation for the purpose of financially and emotionally ruining her mother to ensure that her mother could no longer continue to fight to protect Plaintiff, and blocking access to Plaintiff's and Plaintiff's mother's financial resources to deny them the means to litigate Plaintiff's protection. All of this conduct by Marshall W. Krause, who viciously abused Plaintiff's mother during the course of their marriage, was designed to punish Plaintiff's mother for leaving him and was motivated by his misogyny.

 DAMAGES SOUGHT FROM DEFENDANT MARSHALL W. KRAUSE:

 14. Plaintiff re-urges Paragraphs 1-13 in extens
 
15. As a result of the tortious conduct set forth above, Plaintiff suffered severe physical pain and suffering, fear, anxiety, depression, loss of civil rights and remedies, severe and permanent emotional and psychological pain and suffering, despair, physical restraint and confinement, loss of a relationship with her mother, and other compensable damages.

 16. Plaintiff itemizes her damages due her from
 Defendant Marshall W. Krause as follows:

 A. Assault and Battery: $10,000,000. 

 B. Intentional Infliction of Emotional Distress: $10,000,000.

 C. Conspiracy to Deny Access to the Courts: $10,000,000.

 D. Tortious Interference With Mother-Child Relationship: $10,000,000.

 17. The tortious conduct of Defendant Marshall Krause was intentional, malicious, willful, wanton, outrageous and in total disregard for the rights and interests of Plaintiff Alanna Krause, and, thus, Defendant Marshall W. Krause is liable to Plaintiff for punitive damages to deter him and others like him from engaging in this same sort of abuse.

 18. Plaintiff accordingly demands punitive damages: $15,000,000.

 CAUSES OF ACTION: 

DEFENDANT SANDRA ACEVEDO

 (LEGAL MALPRACTICE, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, CONSPIRACY TO DEPRIVE PLAINTIFF OF ACCESS TO THE COURT,TORTIOUS INTERFERENCE WITH MOTHER-CHILD RELATIONSHIP)

 19. Plaintiff re-urges Paragraphs 1-18 in extenso.

 20. On January 3, 1994, Defendant Sandra Acevedo was appointed "minor's counsel" under California Family Code =C2=A7=C2=A7 3150-313 by the Marin County Superior Court in Case No.4889 to properly represent the interests and welfare of Plaintiff Alanna Krause. 

As a result of that appointment, Defendant Sandra Acevedo had a high duty to investigate the law and facts surrounding Plaintiff's situation, and to advocate positions in court which furthered Plaintiff's interests and welfare. She remained Plaintiff's attorney through October 1994, but her negative impact continued through 1997.
 
21. At all times relevant, Defendant Acevedo was fully aware of the tortious acts being committed against Plaintiff by Defendant Marshall Krause, as Plaintiff, her mother, and others repeatedly told Defendant Acevedo of the abuses and begged Acevedo to take the necessary steps to protect her.

 22. Legal Malpractice:

 Contrary to her duty to properly and competently represent Plaintiff's interests, Defendant Acevedo advocated solely for the interests of Defendant Marshall W. Krause and his lover Lana Clark, successfully convincing the court to place Plaintiff in her father's sole custody and to terminate Plaintiff's contact with her mother.
 Defendant instead did everything possible to ensure Plaintiff's continued vulnerability at the hands of her father, and did absolutely nothing to protect her young client. Defendant Acevedo was only interested in furthering her standing with Defendant Marshall W. Krause, a powerful and prominent attorney, and completely undermined any potential for Plaintiff's protection in the court.
 
23. Intentional Infliction of Emotional Distress: Defendant Acevedo's affirmative steps to place Plaintiff in the custody of her abusive father, and to completely impair Plaintiff's ability to find protection in the legal system, when Defendant Acevedo knew that Plaintiff was being abused were sufficiently willful, wanton, and outrageous to constitute intentional infliction of emotional distress.

 24. Conspiracy to Deprive Plaintiff of Access to the Courts: During the course of her representation of Plaintiff, Defendant repeatedly conspired with Defendant Marshall W. Krause and Defendant Lana Clark to = deprive Plaintiff of her right to access by the court by intentionally = preventing the court from hearing evidence of Defendant Marshall = Krause's abuse of Alanna and her mother, by engaging in ex parte = communications with the court in violation of Plaintiff's due process = rights, by coercing and financially harassing Plaintiff's mother into = abandoning her legal efforts to protect Alanna through the courts, by = knowingly allowing the introduction of false testimony, by allowing into = evidence and/or the court's consideration the bogus, disreputable, and = pro child-abuser "Parental Alienation Syndrome" theory concocted by the = discredited misogynist Richard Gardner, by failing to disclose to the = court the unethical and prejudicial relationship between Defendant = Marshall Krause and Defendant Lana Clark, by prohibiting Alanna Krause = from testifying on her own behalf in order to obtain protection from the = abuse, by sabotaging child protective services investigations into = Plaintiff's abuse, and other acts.=20 25. Tortious Interference with Mother-Child Relationship: During the = course of her "representation" of Plaintiff, Defendant vigorously and = continuously tortiously used her position as Plaintiff's "advocate" to = wrongfully interfere with the relationship between Plaintiff and her = mother, resulting in her mother's inability to protect Plaintiff and in = further harm to Plaintiff.=20 DAMAGES SOUGHT FROM DEFENDANT SANDRA ACEVEDO=20 26. Plaintiff re-urges Paragraphs 1-25 in extenso.=20 27. As a result of the tortious conduct set forth above, Plaintiff = suffered severe physical pain and suffering, fear, anxiety, depression, = loss of civil rights and remedies, severe and permanent emotional and = psychological pain and suffering, despair, physical restraint and = confinement, loss of a relationship with her mother, and other = compensable damages.=20 28. Plaintiff itemizes her damages due her from Defendant Sandra = Acevedo as follows:=20 A. Legal Malpractice: = $5,000,000.=20 B. Intentional Infliction of Emotional Distress: $5,000,000.=20 C. Conspiracy to Deny Access to the Courts: $5,000,000.=20 D. Tortious Interference With Mother-Child=20 Relationship: = $5,000,000.=20 29. The tortious conduct of Defendant Sandra Acevedo was reckless, = malicious, wanton, outrageous and in total disregard for the rights and = interests of Plaintiff Alanna Krause, and, thus, Defendant Sandra = Acevedo is liable to Plaintiff for punitive damages to deter her and = others like her from engaging in this same sort of misconduct.=20 30. Plaintiff accordingly demands punitive damages: $10,000,000.=20 CAUSES OF ACTION: DEFENDANT DIAMOND, BENNINGTON & SIMBORG, P.C.=20 (NEGLIGENCE, VICARIOUS LIABILITY)=20 31. Plaintiff re-urges Paragraphs 1-30 in extenso.=20 32. At all times relevant herein, Defendant Sandra Acevedo was an = employee of the law firm Diamond, Bennington & Simborg, P.C., and was = acting in the course and scope of her employment. Defendant Diamond, = Bennington & Simborg, P.C. (hereinafter called "D, B&S") financially = benefitted from Defendant Acevedo's actions as set forth herein, as the = fees she recovered were paid to the law firm.=20 32. Negligence : At all times relevant herein, D, B&S had a duty to = properly supervise its employee Defendant Acevedo to ensure that she was = properly representing her clients, who were the firm's clients, but D, = B, & S breached that duty and allowed Defendant Acevedo to conduct her = tortious activity unfettered. D, B & S was more concerned in furthering = its status with Defendant Marshall W. Krause, a prominent and powerful = local attorney, than it was in ensuring that his victim, Plaintiff = Alanna Krause, was adequately represented.=20 33. Vicarious Liability: D, B, & S is vicariously liable for the torts = of Defendant Sandra Acevedo as set forth herein under the doctrine of = respondeat superior, and is thus solidarily liable for all damages = suffered by Plaintiff as a result of Defendant Acevedo's acts and = omissions set forth herein.=20 34. As a direct and proximate result of D, B, and S's negligence, = Plaintiff suffered all of the damages set forth herein, supra.=20 DAMAGES SOUGHT FROM DEFENDANT DIAMOND, BENNINGTON & SIMBORG, P.C.=20 35. Plaintiff itemizes her damages due her from Defendant D, B & S as = follows:=20 A. Legal Malpractice: = $5,000,000.=20 B. Intentional Infliction of Emotional Distress: $5,000,000.=20 C. Conspiracy to Deny Access to the Courts: $5,000,000.=20 D. Tortious Interference With Mother-Child=20 Relationship: = $5,000,000.=20 CAUSES OF ACTION: DEFENDANT LANA CLARK, PH.D.=20 (MALPRACTICE, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, CONSPIRACY = TO DEPRIVE PLAINTIFF OF ACCESS TO THE COURTS, TORTIOUS INTERFERENCE WITH = MOTHER-CHILD RELATIONSHIP, FAILURE TO REPORT CHILD ABUSE TO CHILD = PROTECTION AGENCIES)=20 36. Plaintiff re-urges Paragraphs 1-35 in extenso.=20 37. At all times relevant, Defendant Lana Clark, Ph.D., was a clinical = social worker licensed by the State of California and was purportedly = serving as a "psychotherapist" and/or "evaluator" for Plaintiff Alanna = Krause, with whom Defendant Lana Clark had a social worker-client = relationship. Defendant Lana Clark held herself out as being = sufficiently qualified and expert to "evaluate" and "treat" Plaintiff.=20 38. At all times relevant herein, Defendant Lana Clark had a conflict = of interest regarding her client Alanna Krause, as Defendant Clark was = engaged in an ongoing sexual/romantic relationship with Defendant = Marshall W. Krause, her client's abuser.=20 39. Malpractice: Contrary to her duty to properly and competently = evaluate and treat Plaintiff, Defendant Lana Clark, while knowing that = Defendant Marshall W. Krause was violently abusing and neglecting = Plaintiff, acted solely for the interests of Defendant Marshall W. = Krause, successfully convincing the court to place Plaintiff in her = father's sole custody and to terminate Plaintiff's contact with her = mother. Defendant did everything possible to discredit Plaintiff and = to ensure Plaintiff's continued vulnerability at the hands of her = father, and did absolutely nothing to protect her young client. = Defendant Clark was only interested in furthering her unethical and = improper relationship with Defendant Marshall W. Krause, and completely = undermined any potential for Plaintiff's protection in the court or = though child protective services. Furthermore, Defendant Clark utilized = and advanced in Plaintiff's case the bogus, disreputable, and pro-child = abuser "Parental Alienation Syndrome" theory concocted by the = discredited misogynist Richard Gardner, further ensuring Plaintiff's = continued abuse and neglect at the hands of her father. These acts and = omissions were grossly negligent and constituted professional = malpractice.=20 40. Intentional Infliction of Emotional Distress: Defendant Lana Clark's = affirmative steps to place Plaintiff in the custody of her abusive = father, and to completely impair Plaintiff's ability to find protection = in the legal system, when Defendant Clark knew that Plaintiff was being = abused were sufficiently willful, wanton, and outrageous to constitute = intentional infliction of emotional distress.=20 41. Conspiracy to Deprive Plaintiff of Access to the Courts: During the = course of her "treatment" and "evaluation" of Plaintiff, Defendant = Clark repeatedly conspired with Defendant Marshall W. Krause and = Defendant Sandra Acevedo to deprive Plaintiff of her right to access by = the court by intentionally preventing the court from hearing evidence of = Defendant Marshall Krause's abuse of Alanna and her mother, by engaging = in ex parte communications with the court in violation of Plaintiff's = due process rights, by coercing and financially harassing Plaintiff's = mother into abandoning her legal efforts to protect Alanna through the = courts, by knowingly aiding and abetting the introduction of false = testimony and reports, by allowing into evidence and/or the court's = consideration the bogus, disreputable, and pro child- abuser "Parental = Alienation Syndrome" theory concocted by the by the discredited = misogynist Richard Gardner, by failing to disclose to the court the = unethical and prejudicial relationship between Defendant Marshall = Krause and herself, by seeking to prohibit Alanna Krause from testifying = on her own behalf in order to obtain protection from the abuse, by = sabotaging child protective services investigations into Plaintiff's = abuse, and other acts.=20 42. Tortious Interference with Mother-Child Relationship: During the = course of her "evaluation" and "treatment" of Plaintiff, Defendant = Clark vigorously and continuously tortiously used her position as = Plaintiff's "therapist" to wrongfully interfere with the relationship = between Plaintiff and her mother, resulting in her mother's inability to = protect Plaintiff and in further harm to Plaintiff.=20 43. Failure to Report Child Abuse to Child Protection Agencies: During = the course of Defendant Clark's therapist-client relationship with = Plaintiff, Defendant Clark knew that Plaintiff was being abused and = neglected by Defendant Marshall W. Krause, but, despite being a = "mandated reporter" of child abuse and neglect under California Penal = Code =C2=A7=C2=A711165 et seq., and, in violation of her legal duty, = intentionally and in bad faith failed to report the abuse and neglect to = the appropriate authorities. Furthermore, Defendant Clark, acting in = bad faith, deliberately sabotaged any child protection investigations = initiated by Plaintiff and others. Defendant Clark's acts and = omissions in this regard proximately caused Plaintiff to suffer = additional abuse and neglect, and the other damages set forth above.=20 DAMAGES SOUGHT FROM DEFENDANT LANA CLARK, PH.D.=20 44. Plaintiff re-urges Paragraphs 1-43 in extenso.=20 45. As a result of the tortious conduct set forth above, Plaintiff = suffered severe physical pain and suffering, fear, anxiety, depression, = loss of civil rights and remedies, severe and permanent emotional and = psychological pain and suffering, despair, physical restraint and = confinement, loss of a relationship with her mother, and other = compensable damages.=20 46. Plaintiff itemizes her damages due her from Defendant Lana Clark as = follows:=20 A. Professional Malpractice: $5,000,000. = B. Intentional Infliction of Emotional Distress: $5,000,000.=20 C. Conspiracy to Deny Access to the Courts: $5,000,000.=20 D. Tortious Interference With Mother-Child=20 Relationship: = $5,000,000.=20 47. The tortious conduct of Defendant Lana Clark was reckless, = malicious, wanton, outrageous and in total disregard for the rights and = interests of Plaintiff Alanna Krause, and, thus, Defendant Lana Clark = is liable to Plaintiff for punitive damages to deter her and others like = her from engaging in this same sort of misconduct.=20 48. Plaintiff accordingly demands punitive damages: $10,000,000.=20 JOINT AND SEVERAL LIABILITY=20 49. As set forth herein, all defendants are joint tortfeasors engaged in = a common plan and scheme, and, thus, all are jointly and severally = liable for all damages suffered by Plaintiff herein.=20 JURY TRIAL DEMAND=20 50. Plaintiff is entitled to and demands a trial by jury on all issues.=20 PRAYER=20 WHEREFORE, Plaintiff prays that after all due proceedings, there be = judgment rendered in favor of Plaintiff and against Defendants Marshall = W. Krause, Sandra Acevedo, Diamond, Bennington & Simborg, P.C., and = Lana Clark, Ph.D. jointly and severally for such damages as are set = forth herein, plus interest from the date of the filing of this = Complaint, all costs of these proceedings, reasonable attorney's fees as = allowed by law, and for such other equitable relief as is appropriate.=20 Respectfully submitted,=20 ALANNA KRAUSE, Plaintiff By her counsel: ______________________________=20 Seth L. Goldstein (Cal. Bar # 176882)=20 1125 Jefferson Street=20 Napa, CA 94559=20 (707) 226-6660=20 (707) 226-6661 [Fax]=20 Local Counsel __________________________________=20 Richard L. Ducote, of the Louisiana Bar=20 Counsel pro hac vice=20 Office of Richard Ducote, Attorney at Law=20 731 Fern Street=20 New Orleans, LA 70118=20 (504) 314-8400=20 (504) 314-8600 [Fax] ___________________________________=20 Becki L. Truscott, of the North Carolina Bar=20 Counsel pro hac vice=20 Office of Richard Ducote, Attorney at Law=20 731 Fern Street=20 New Orleans, LA 70118=20 (504) 314-8400=20 (504) 314-8600 [Fax]=20 =20 =20 Copy of date stamped filing attached.=20 =3D=3D=3D=3D=3D=3D=3D> Help/Info: http://www.ee.bgu.ac.il/~academia/Academia_List.txt =3D=3D=3D=3D=3D=3D=3D> PLEASE AVOID LONG QUOTES AND RAW FORWARDS =3D=3D=3D=3D=3D=3D=3D> CONSULT ME BEFORE POSTING VIRUS ALERTS OR CHAIN LETTERS =3D=3D=3D=3D=3D=3D=3D> SUBSCRIBE/UNSUBSCRIBE REQUESTS ONLY TO =3D=3D=3D=3D=3D=3D=3D> maintainer e-mail: <censor@ee.bgu.ac.il> --Boundary_(ID_dxQnhNDmAOVG3a/7YXKWyg) http://www.ee.bgu.ac.il/~academia/2002_directory/2002_11_directory/2002_11_05.txt

 

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