Keith B. Gallagher Citizen of the United States of America Pro Per for Plaintiffs FILE ON DEMAND Superior Court of California County of Merced The People of the State of California, and Keith Gallagher, Plaintiffs, vs. James Buttrey, Mark Pazin, and Larry Morse II, Defendants ) ) Case No.: ____________________ Criminal Complaint and Citizen’s Arrest: Felony Stalking and Felony Accessories to Stalking Over the past years, Merced County Sheriff’s Department Commander James Buttrey (now opportunely retired from the Department at age 40, with full perquisites and now marketing himself without compunction) did unlawfully, willfully, maliciously, and repeatedly follow and harass a Sheriff’s Department female employee(s) (name withheld for privacy and respect) and others, and did make credible and overt threats to place that person(s) in reasonable fear for their safety and the safety of their family(ies) in violation of Penal Code Section 646.9(a), Stalking-Felony. Commander James Buttrey’s actions were, and remain, more than a breach of ethics, Merced County Sheriff’s Department Codes of Conduct and By-Laws, and applicable labor and civil rights laws. They constitute a serious and ongoing threat to the community considering the Defendant’s predatory pattern of behavior, the fact that he carries loaded guns with the skill and resolve to use them, made overt threats to his victims, his and his employer’s total lack of contrition and responsibility, and plenty more that would alarm any rational citizen—should Merced County law enforcement officials such as Merced County Sheriff Mark Pazin and Merced County District Attorney, entrusted to protect our public’s safety, “give a damn.” Further, the Defendant Buttrey’s conduct has brought NO disciplinary action by his supervisors at the Merced County Sheriff’s Department or the Merced County District Attorney’s Office, thus giving Defendant Buttrey the license to sustain this pattern of extreme criminality. This latter fact is witnessed by the Defendant’s continued employment by the Merced County Sheriff’s Department without being placed on administrative leave, loss of income, demotion of rank, or any other appropriate penalty for someone who clearly goes, as Sheriff Pazin trenchantly put it in a recent persecution, “beyond the parameters of common sense.” (A matter of public record.) Thus, the Defendants pose overt and credible threats to the victim(s) and other vulnerable members of our community. Buttrey, Pazin, and Morse’s criminal conduct demonstrates a high degree of criminal sophistication and grave threats to the community. Sheriff Mark Pazin and District Attorney Larry Morse II failed to hold Buttrey to task and, in truth, abetted violations of law. Thus, Pazin and Morse are criminal accomplices to Felony Stalking of the first order. This expresses a criminal conspiracy of a "high degree of criminal sophistication" and represents an "escalating pattern of criminality." The Merced community is supposed to believe that those who go beyond the bounds of law and common sense should face severe penalties by Merced County’s law enforcement. Clearly, Sheriff Mark Pazin and District Attorney Larry Morse II have not performed their duties—certainly not equitably or with nominal integrity. The documented evidence, corroborated by credible testimony, is conclusive. The Merced Sun Star and other media reports, eyewitnesses, and an “independently” and costly commissioned investigative report (which we demand be subpoenaed forthwith) are among the corroborative sources. Moreover, Keith Gallagher sent both Pazin and Morse correspondence (one attached) to inform them of his apt concern. Sheriff Mark N. Pazin cowardly responded by sending an envoy to ask Gallagher “what he thinks the Sheriff should do about” the criminal conduct. Tragically, hypocritically, though predictably, these facts have been suppressed by the concerted acts of Pazin, Morse, the bureaucracies they command, along with Merced’s media and elites. In sum, the plaintiffs, on behalf of the citizens of the great and just County of Merced, request the prosecution this case with zeal—much in accord with recent precedent. We need to put these “bizarre,” “irrational,” and iniquitous offenders under the wraps of TWENTY MILLION DOLLARS bail, long-term incarceration, and public pillory. Thus far these criminals have caused, among other predictable, proximate, and substantial consequences, at least one victim to be exiled to protecting Mickey Mouse at Disneyland and sacrifice a promising career. For this behavior and considerably more criminality, none of the Defendants have shown any remorse. Conversely, they seem emboldened to carry forward their extreme criminality. The plaintiffs respectfully appreciate all concern and attention to this important matter and the grave and imminent threat it poses to our welfare. Thereby, we demand the immediate citizen’s arrest, lawful detention, and prosecution of all Defendants. I, Keith Gallagher, declare under penalty of perjury, and with understandable concern for his safety, that the foregoing is true and correct. Dated this 7th day of August, 2013 Keith Gallagher Citizen of the United States of America
Posted on: Sat, 10 Aug 2013 20:56:10 +0000
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