Roy D. Reha, Sui Juris
Citizen of Iowa State
2913 Delaware Avenue
Des Moines 50317-3544
IOWA, USA
All Rights Reserved
Without Prejudice
IOWA DISTRICT COURT
POLK COUNTY
CITY OF DES MOINES, IOWA, ) Case No. CE 43045
)
Plaintiff, )
v. )
)
ROY REHA [sic], )
)
Defendant. )
----------------------------------)
Roy D. Reha, Sui Juris, ) VERIFIED CROSS-COMPLAINT
) FOR QUIET TITLE RELIEF,
Cross-Plaintiff, ) DECLARATORY AND INJUNCTIVE
v. ) RELIEF, AND DAMAGES;
) JURY TRIAL DEMANDED:
City of Des Moines, Iowa, ) Article VI, Section 3,
Vicky Long Hill, and ) U.S. Constitution (oaths);
Does 1 thru 100, ) 4 U.S.C. 101 (State oaths);
) 18 U.S.C. 1964 (Civil RICO);
Cross-Defendants. ) Universal Declaration of
) Human Rights (a U.S. Treaty);
__________________________________) and Iowa Bar Rules.
COMES NOW Roy D. Reha, Citizen of Iowa State, expressly not a citizen of the United States (“federal citizen”), and CROSS-PLAINTIFF in the above entitled action (hereinafter “CROSS-PLAINTIFF”) to file and serve this, His VERIFIED CROSS-COMPLAINT FOR QUIET TITLE RELIEF, DECLARATORY AND INJUNCTIVE RELIEF, AND DAMAGES; JURY DEMANDED against all named Cross-Defendants and all unnamed Does 1 thru 100 supra, and to provide formal Notice of same to all interested parties.
The Proper Parties to this action are Cross-Plaintiff Roy D. Reha, Sui Juris, and Cross-Defendants City of Des Moines, Iowa, Vicky Long Hill, and Does 1 thru 100 as yet unnamed.
Cross-Plaintiff hereby verifies the existence of a bona fide controversy over title to the private real property itemized as follows:
The South 50 feet to the West 150 feet of Lot 4 PERIN PLACE, an Official Plat, now included in and forming a part of the City of Des Moines, Polk County, Iowa,
Pursuant to Article 25 in the Universal Declaration of Human Rights, Cross-Plaintiff asserts a fundamental Right to housing and to enjoy His private real property as if it were His castle. Article 25 reads:
Article 25
1. Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in circumstances beyond his control.
[bold emphasis added]
Cross-Plaintiff was at no time under any obligation(s) whatsoever to any named Cross-Defendants, by virtue of any valid contract or commercial agreement, whether written or verbal, whether expressed or implied in fact. No such contract or commercial agreement exists, from which any obligation(s) might arise.
Moreover, Cross-Defendant denies that any such obligation(s) ever arose under operation of Law, because none of Cross-Defendants’ claim(s) to the property supra has any basis in any fundamental Law(s).
Cross-Plaintiff denies ever having damaged any property(s) of any named Cross-Defendants, and Cross-Plaintiff denies ever having injured any Person(s) employed by, or associated in any way with, any named Cross‑Defendants.
Cross-Plaintiff hereby specifically denies and negatively avers as follows:
Cross-Plaintiff specifically denies that named Cross-Defendant Vicky Long Hill has ever executed a valid oath of office, as required by Iowa State law(s) and by the federal statute at 4 U.S.C. 101.
Cross-Plaintiff specifically denies that a valid license to practice law in the State of Iowa has ever been issued to named Cross-Defendant Vicky Long Hill, as required by Iowa State law(s) and by the Iowa Bar Rules. See Attachment B.
Cross-Plaintiff specifically denies that named Cross-Defendant Vicky Long Hill has any valid power(s) of attorney to represent the fictitious entity and named Plaintiff CITY OF DES MOINES, IOWA supra.
Cross-Plaintiff specifically denies that named Cross-Defendant City of Des Moines, Iowa has ever made any proper appearances in the instant case, now or at any time in the past.
Cross-Plaintiff specifically denies that named Cross-Defendant City of Des Moines, Iowa has ever filed any valid complaint(s) or other proper pleadings in the instant case, now or at any time in the past.
Cross-Plaintiff specifically denies that named Cross-Defendant City of Des Moines, Iowa has ever made any proper attempts to prosecute the instant case, now or at any time in the past.
Cross-Plaintiff specifically denies that any valid contract(s) exist, whether written or verbal, whether expressed or implied in fact, between Himself and Cross-Defendant City of Des Moines, Iowa and/or named Cross-Defendant Vicky Long Hill.
Cross-Plaintiff specifically denies that any sort of “equitable” relationship exists now, or ever has existed, between Himself and Cross-Defendant City of Des Moines, Iowa and/or named Cross-Defendant Vicky Long Hill.
Cross-Plaintiff specifically denies that any bonding agent(s) have ever indemnified criminal conduct in any of the terms and conditions enumerated in any of the surety bonds, or other insurance coverage(s), required of Cross-Defendant City of Des Moines, Iowa and of all staff working in the latter’s Office of the City Attorney.
Cross-Plaintiff specifically denies that any valid lien(s) exist against His estate, including but not limited to the real property described supra.
Cross-Plaintiff specifically denies that any verified complaint(s) have ever been served upon Him that would give this honorable Court original jurisdiction over any alleged injury(s) to People, or over any alleged damage(s) to property(s) of any kind or description whatsoever.
ALLEGATIONS OF FACT
Cross-Plaintiff hereby formally alleges as follows:
Cross-Plaintiff is a Citizen of Iowa State by Right of birth, presently and fully entitled to all Rights, Privileges and Immunities guaranteed to Him by the Constitution for the United States of America (“U.S. Constitution”) and by the Constitution of the State of Iowa.
As such, Cross-Plaintiff is entitled to, and hereby asserts, His fundamental Right to due process of law in the instant case.
Cross-Plaintiff hereby alleges willful misrepresentation by Cross-Defendant Vicky Long Hill, for alleging to appear on behalf of named Cross-Defendant City of Des Moines, Iowa in the instant case, without any power(s) of attorney and without either the valid oath of office or the valid license to practice law that are both required by Iowa State law(s).
Cross-Plaintiff hereby alleges contempt of court by Cross-Defendant Vicky Long Hill, for alleging to appear on behalf of named Cross-Defendant City of Des Moines, Iowa in the instant case, without any power(s) of attorney and without either the valid oath of office or the license to practice law that are required by Iowa State law(s).
Cross-Plaintiff hereby alleges fraud upon this honorable Court by Cross-Defendant Vicky Long Hill, for alleging to appear on behalf of named Cross-Defendant City of Des Moines, Iowa in the instant case, without any power(s) of attorney and without either the valid oath of office or the license to practice law that are required by Iowa State law(s).
Cross-Plaintiff hereby also alleges that a Civil RICO conspiracy exists by which all named Cross-Defendants supra and as yet unnamed Does 1 thru 100 supra are now and have been engaged in a pattern of racketeering activity during the preceding ten (10) calendar years, the purpose of which conspiracy, among other things, is to deprive Cross-Plaintiff of His fundamental Rights as guaranteed by the U.S. Constitution as lawfully amended, and by the Iowa State Constitution.
DECLARATORY RELIEF
Cross-Plaintiff seeks declaratory relief in the form of judicial orders, judgments, and decrees that His allegations of fact supra are true and correct, and that Cross-Plaintiff does enjoy unclouded allodial title to the real property in question.
INJUNCTIVE RELIEF
Cross-Plaintiff initially seeks a preliminary injunction enjoining all named Cross-Defendants from all forms of trespass and from all other forms of damage(s) to His estate, under color of law, which the latter may have already inflicted, and which the latter may be planning to inflict or otherwise are likely to be contemplating in the instant case and in all related matters.
Cross-Plaintiff hereby notifies all named Cross-Defendants of His lawful intent to petition this honorable Court for an order converting said preliminary injunction into a permanent injunction, with all deliberate speed and only as this Court deems just and proper.
DAMAGES
Cross-Plaintiff seeks prompt recovery of all actual, consequential, and exemplary damages, as determined by lawful jury verdict and multiplied three-fold (3X) as authorized by the Civil RICO statutes at 18 U.S.C. 1964, in addition to the costs of this action.
This honorable Court has original jurisdiction of Civil RICO actions pursuant to the holding of the U.S. Supreme Court in the case of Tafflin v. Levitt, 493 U.S. 455 (1990).
Cross-Plaintiff hereby requests mandatory judicial notice of Attachments “A” and “B” infra, and incorporates same by reference to Attachments “A” and “B”, as if set forth fully here.
I, Roy D. Reha, Cross-Plaintiff in the above entitled matter, hereby verify, under penalty of perjury, under the laws of the United States of America, without the “United States” (federal government), that the above statement of facts and laws is true and correct, according to the best My current information, knowledge, and belief, so help Me God, pursuant to 28 U.S.C. 1746(1). See Supremacy Clause in the Constitution for the United States of America, as lawfully amended (Constitution, Laws and Treaties of the United States are all the supreme Law of this Land).
Dated: August 1, 2002 Anno Domini
Signed: /s/ Roy D. Reha
____________________________________________________
Printed: Roy D. Reha, Sui Juris, Cross-Plaintiff
All Rights Reserved without Prejudice
PROOF OF SERVICE
I, Roy D. Reha, hereby certify, under penalty of perjury, under the laws of the United States of America, without the "United States", that I am at least 18 years of age, a Citizen of ONE OF the United States of America, and that I personally served the following document(s): VERIFIED CROSS-COMPLAINT FOR QUIET TITLE RELIEF,DECLARATORY AND INJUNCTIVE RELIEF, AND DAMAGES;JURY TRIAL DEMANDED:Article VI, Section 3, U.S. Constitution (oaths);4 U.S.C. 101 (State oaths);18 U.S.C. 1964 (Civil RICO);Universal Declaration of Human Rights (a U.S. Treaty); and,Iowa Bar Rules by placing one true and correct copy of said document(s) in first class U.S. Mail, with postage prepaid and properly addressed to: Clerk of CourtPolk County Courthouse5th & Mulberry StreetsDes Moines 50309-4289IOWA, USA Office of the City AttorneyCity of Des Moines, Iowa400 East First StreetDes Moines 50309-1891IOWA, USA
Vicky
Long Hill
c/o City Hall
400 East First Street
Des Moines 50309-1891
IOWA, USA
Dated: August 1, 2002 Anno Domini
Signed: /s/ Roy D. Reha
____________________________________________________
Printed: Roy D. Reha, Sui Juris, Cross-Plaintiff
All Rights Reserved without Prejudice
Attachment “A”:
AFFIDAVIT OF CROSS-PLAINTIFF
IN RE HIS DILIGENT EFFORTS TO OBTAIN
THE OATH OF OFFICE AND LICENSE TO PRACTICE LAW
REQUIRED OF CROSS-DEFENDANT VICKY LONG HILL
Attachment “B”:
Iowa Bar Rules