Bill Windsor files an Amended Petition in effort to obtain a Stalking Protective Order against Claudine Dombrowski and her associates. This was filed in CASE NO. 13D1747 in the District Court of Shawnee County Kansas. Extensive exhibits are provided at the end of the Petition.
AMENDED VERIFIED PETITION
FOR EX PARTE PROTECTIVE ORDER
Comes Now, William M. Windsor (“Plaintiff”) and files this AMENDED VERIFIED PETITION FOR EX PARTE PROTECTIVE ORDER. PLAINTIFF shows the Court as follows:
- DEFENDANT CLAUDINE DOMBROWSKI (“DOMBROWSKI”) is a serial liar who, among other things, is publishing that the PLAINTIFF is a sexual deviant and a terrorist.
- DOMBROWSKI failed to appear for the hearing on July 25, 2013 at 1:30 pm.
- The Court commented on the need to amplify on the PLAINTIFF’S fear for his safety and the safety of his family. The Court also indicated the need to establish that DOMBROWSKI published the information that has caused fear.
- The PLAINTIFF references and incorporates the original petition as if attached hereto.
- The PLAINTIFF verifies this Petition before a notary under penalty of perjury stating that all facts contained herein are true and correct based upon his personal knowledge, so this Amended Verified Petition also serves as sworn testimony of the PLAINTIFF. This provides the information requested.
- The PLAINTIFF badly needs this Court to issue a protective order.
THE PURPOSE OF THE PROTECTION FROM STALKING ACT
- The clear purpose of the Protection from Stalking ACT (“PSA”) is to PROTECT people from others. The act is to be “liberally construed.”
- This means the Court must make a broad interpretation of the statute and the issues presented applicable to the statute.
- Liberally construing a 2002 act in 2013 means the PSA must properly consider cyber stalking. Online research indicates that a 1999 U.S. Department of Justice report may have the first explanation of this new form of stalking. Cyber stalking is clearly recognized as a significant form of stalking. This Court should “liberally construe” the need for protection to properly consider the impact of cyber-stalking and how it does apply to this statute.
- The internet has enabled online groups of often-anonymous people to self-organize to target individuals with online defamation, threats of violence and technology-based attacks. These include publishing lies and doctored photographs, threats of rape and other violence, posting sensitive personal information about victims, e-mailing damaging statements about victims to their employers, and manipulating search engines to make damaging material about the victim more prominent. Experts attribute the destructive nature of anonymous online mobs to group dynamics, saying that groups with homogeneous views tend to become more extreme as members reinforce each other’s beliefs, they fail to see themselves as individuals, so they lose a sense of personal responsibility for their destructive acts, they dehumanize their victims, which makes them more willing to behave destructively, and they become more aggressive when they believe they are supported by authority figures. This is being done to the PLAINTIFF, and more.
- There is absolutely no question that these people have followed the PLAINTIFF online and contacted the PLAINTIFF online for the purpose of harassing and intimidating the PLAINTIFF. They have attempted to terrify, threaten, harass, annoy, and offend the PLAINTIFF with lewd and profane language, lewd and lascivious acts, threats to inflict physical harm, and more.
- Virtually all of the stalking and harassment has been cyberstalking, the use of the Internet and email to stalk and harass the PLAINTIFF and those acquainted with the PLAINTIFF.
- The stalking includes the making of false accusations and false statements. These include that the PLAINTIFF is a pedophile, a pedophile lover, anti-gay, bigoted, a criminal operating a scam, and much more.
- The stalking includes monitoring, as the stalkers claim to be tracking the PLAINTIFF’s Internet activity. Some stalkers participate in the PLAINTIFF’s online radio talk shows to monitor and/or to disrupt the calls and the online chat. The monitoring includes repeated online posts of libelous, threatening, harassing statements.
- The stalking includes threats.
- Any reasonable person in possession of this information would regard it as sufficient to cause another reasonable person distress.
- The libel and slander is truly unbelievable. These stalkers invent one false claim after another. People who the PLAINTIFF doesn’t know make statements in writing that have no truth whatsoever and can be easily proven to be false. It’s like they feel they can say anything and get away with it.
- The stalkers have repeatedly violated the PLAINTIFF’s privacy rights and copyright by using photos and videos of me that they have no legal right to use. Photographs of the PLAINTIFF have been doctored. Absolutely sickening videos have been produced about the PLAINTIFF.
- The PLAINTIFF has 15 gigabytes of online posts, emails, videos, and more.
- The PLAINTIFF believes Claudine Dombrowski uses multiple aliases and screen names in her stalking of the PLAINTIFF.
- Claudine Dombrowski has knowingly attempted to place the PLAINTIFF in fear of physical harm; she has associated with others who have threatened or implied the desire to commit physical harm to the PLAINTIFF, including people who have sent messages to the PLAINTIFF with deadly weapons – gun, knife, and hammer; has harassed the PLAINTIFF; has engaged in a purposeful course of conduct involving more than one incident that alarms or causes distress to the PLAINTIFF and serves no legitimate purpose; that she has followed the PLAINTIFF in public places online; has stalked the PLAINTIFF; has purposely and repeatedly engaged in an unwanted course of conduct that causes alarm to the PLAINTIFF when it is reasonable in the PLAINTIFF’S situation to have been alarmed by the conduct; has caused the PLAINTIFF to fear of danger of physical harm; has committed a pattern of conduct composed of repeated acts over a period of time that serves no legitimate purpose; has sent the PLAINTIFF unwanted communication; has made unwanted contact; and has been a major cause of the PLAINTIFF’S loss of his marriage, his children, and his grandchildren.
THE PLAINTIFF IS A VICTIM OF STALKING
- The PLAINTIFF is clearly a victim of stalking. Exhibit 1 hereto is a true and correct copy of a flash drive made by the PLAINTIFF containing approximately 7 gigabytes of evidence of stalking, defamation, harassment, threats, and more that the PLAINTIFF has obtained and kept on a hard drive.
- K.S.A. 60-31 provides: “This act shall be liberally construed to protect victims of stalking and to facilitate access to judicial protection for stalking victims….” And stalking is defined: “…an intentional harassment of another person that places the other person in reasonable fear for that person’s safety.” Harassment is defined as “a knowing and intentional course of conduct directed at a specific person that seriously alarms, annoys, torments or terrorizes the person, and that serves no legitimate purpose.” If we put those two definitions together, stalking is a knowing and intentional course of conduct directed at a specific person that seriously alarms, annoys, torments or terrorizes the person, that serves no legitimate purpose, and places the other person in reasonable fear for that person’s safety.
- The PLAINTIFF is a stalking victim.
- The only evidence before this Court is that the PLAINTIFF is a stalking victim.
- K.S.A. 60-31 doesn’t say that the law requires that a Court decide if a person is in reasonable fear for his safety; the law requires that the person says he is in reasonable fear for his safety and/or his family’s safety.
- The PLAINTIFF said in the original petition: “I fear for my safety. My family is terrorized.” The Plaintiff repeats this statement of fact. The PLAINTIFF is in reasonable fear for his safety.
- Since there is no evidence to the contrary and the only person in the world who can say whether or not he is in fear for his safety is the PLAINTIFF, this Court may not accept anything else as fact in making a prima facie decision.
- The threat from cyber-stalking is actually much greater than the threat when a man threatens a woman with physical harm. In the cyber-stalking that the PLAINTIFF must endure every second of every day, the stalking is from many people — a gang of cyber-stalkers. The PLAINTIFF believes as many as 1,000 people could be involved, and he has identified the names of over 500 who he knows or strongly believes to be involved in cyber-stalking him in some manner. Exhibit 2 hereto is a list of 532 of these people. As the president of the American Mothers Political Party, an organization with over 1,300 followers, DOMBROWSKI has mobilized and leads a perhaps unprecedented cyber-stalking campaign against the PLAINTIFF.
- Any one of these people could do physical harm to the PLAINTIFF or his family, and all who participate make it just that much more likely that the PLAINTIFF or his family will be harmed. Because they publish outlandish lies and defamation about the PLAINTIFF, a person who hates pedophiles could attack the PLAINTIFF because publications on the Internet and websites set up such as “Bill-Windsor-is-a-pedophile” may cause pedophile haters to believe the PLAINTIFF is a pedophile. It is well-known that in prison, the inmates generally hate pedophiles and will hurt them.
- The PLAINTIFF has been falsely and maliciously branded in all types of horrendous ways in publications that have reached millions all over the world: pedophile, pedophile lover, bigot, anti-gay, sexual deviant, terrorist, person who has sex with animals, con man, criminal, and much more.
- K.S.A. 60-31 requires a “course of conduct.” “Course of conduct” means conduct consisting of two or more separate acts over a period of time, however short, evidencing a continuity of purpose which would cause a reasonable person to suffer substantial emotional distress.
- The PLAINTIFF has provided extensive documentation of the course of conduct as Exhibits hereto. The cyber-stalking has been regular for at least 18 months. There are currently dozens of websites and hundreds of published articles set up to cyber-stalk and threaten the PLAINTIFF. The cyber-stalkers have taken special efforts to ensure that these websites and defamatory publications rank high in Internet searches. Exhibit 3 hereto includes pages from some of these websites with published statements that the PLAINTIFF is a terrorist, pedophile, stalker, abuser, sexual predator, sexual pervert, has no balls, only happy when sucking hard cock, cock sucker, sexual deviant, has a tiny penis, and more.
- The PLAINTIFF was not a gun owner before this happened to him, but now he owns a gun. Because he does not yet have a carry permit, and because he travels all over the country, carrying a gun for protection is legally problematic. So, the PLAINTIFF bought pepper spray, a little buzzer-like stun gun, a portable alarm, a dashcam, and a Louisville Slugger baseball bat. The pepper spray, stun gun, and portable alarm go everywhere the PLAINTIFF goes except courthouses, police stations, and other places where these items are prohibited. The baseball bat and dashcam remain in the PLAINTIFF’S Jeep at all times. The PLAINTIFF keeps his doors locked at all times, consciously tries to always park under a light, sits with his back to the wall so he can see an entire room, walks briskly, and considers that anyone approaching could be a danger. The PLAINTIFF can no longer publish where he will be working because cyber-stalkers have threatened to come and hurt him. The PLAINTIFF is attempting to keep the location of his new residence a secret so stalkers will not come and harm him and terrorize him as some have published they will do. The PLAINTIFF heaves a sigh of relief every time he turns on his car and it doesn’t blow up. On two occasions, the Plaintiff has come to his car in the morning in a hotel parking lot to find the motor running, the air conditioning on high, and the car locked with the only key in the PLAINTIFF’S pocket.
- The PLAINTIFF does these things because he fears for his safety.
- The PLAINTIFF’S family is terrorized by the cyber-stalking and threats. The PLAINTIFF and his wife rarely ever had a relationship problem in 42 years together, but the PLAINTIFF’S wife divorced him solely because she is absolutely terrorized. The PLAINTIFF’S adult children are very afraid. The PLAINTIFF’S daughter will not allow the PLAINTIFF to have any communication with his two precious granddaughters who he loves more than words could ever express. When the PLAINTIFF’S wife announced she was divorcing him, she specifically stated that she was doing it in hopes that she could distance herself from the cyber-stalkers and threats.
THE SPECIFIC THREATS
- The PLAINTIFF has received many threats, some explicit and some veiled.
- DOMBROWSKI recently published that she was going to use a .45 on the PLAINTIFF and put him out of his misery. [Exhibit 4 hereto.] She also published the name and address of where the PLAINTIFF could be found in Topeka – information that the PLAINTIFF did not provide to anyone. [Exhibit 5 hereto.]
- DOMBROWSKI has declared war on the PLAINTIFF. [Exhibit 6 hereto.]
- DOMBROWSKI recently published that she was going to have an Army against the PLAINTIFF if he ever came to Topeka. [Exhibit 7 hereto.]
- DOMBROWSKI’S Facebook page has promoted for her over 1,300 followers to watch the movie, “Kill Bill.” [Exhibit 8 hereto.]
- DOMBROWSKI’S #2 person in the so-called American Mothers Political Party, Lorraine Tipton, has published in an article defaming the PLAINTIFF that one of her favorite scenes from a movie is one where a man named Bill gets killed. [Exhibit 9 hereto.]
- One of DOMBROWSKI’S associates, Curtis Butler, has recorded a YouTube video in which he threatens to track the PLAINTIFF down wherever he moves and do bodily harm to him. In the video, Butler admits that he is an alcoholic, and he is drinking Everclear straight from the bottle. Those who know what to look for indicate that he shows signs of being on meth. Curtis Butler is extremely frightening. No one in their right mind would record a video saying they were going to kill someone, but he did. Curtis Butler is absolutely someone who could do physical harm to the PLAINTIFF. [This Video is in a folder titled Curtis Butler on Exhibit 1 hereto.]
- Another of DOMBROWSKI’S associates, Sean Boushie, has repeatedly threatened to hurt and kill the PLAINTIFF. He has used Charles Manson as his photo, a huge knife, and a Glock gun. He has threatened to shoot the PLAINTIFF. He says that when the PLAINTIFF comes to Missoula Montana, a bulletproof vest won’t do any good, implying he will go for a headshot. [Exhibit 10 hereto contains various threats from Sean Boushie.]
- Another of DOMBROWSKI’S associates, Brannon Bridge, has published several videos in which he indicates he plans to beat the PLAINTIFF with a hammer. In another video, he is seen sticking pins into a Bill Windsor doll. [Exhibit 1 hereto includes these videos in a folder titled Brannon Bridge.]
- Another of DOMBROWSKI’S associates, Allie Overstreet, swore in a petition for a protective order in Missouri that the PLAINTIFF had repeatedly published that he had bought a gun and planned to kill a large group of people, including her. She filed a police report at the same time making this charge and dozens of absolutely false claims. The purpose of this was to try to get the PLAINTIFF sent to prison. This threat was very real as the PLAINTIFF had to travel from his home in Georgia to Lafayette County Missouri to stand trial for being a would-be serial killer and/or mass murderer. [Exhibit 11 hereto is the sworn affidavit for a protective order and the report filed with the Higginsville Police Department.]
- Another woman, Shannon E. Miller, has apparently filed a similar complaint with the Biloxi Mississippi Police Department. [Exhibit 1 hereto contains a folder titled Shannon Miller, and this includes stalking and harassment from this woman, a big supporter of the American Mothers Political Party.]
- Members of DOMBROWSKI’S group, the so-called American Mothers Political Party, have published that they have made police complaints and FBI complaints all over the country; they have published that they are working with the IRS against the PLAINTIFF; and they launched a letter-writing campaign to try to get the Sundance Film Festival to block the premiere of the PLAINTIFF’S movie at the festival. The very real threat that some law enforcement agency will act against the PLAINTIFF is very real, even though the PLAINTIFF has not committed any crimes, has never been arrested or charged with a crime, and doesn’t even have a traffic ticket or parking ticket in over 12 years. [Exhibit 1 hereto contains a folder titled AMPP, and this includes stalking and harassment from the American Mothers Political Party.]
- Another group of DOMBROWSKI’S associates publish one defamatory article after another at http://joeyisalittlekid.blogspot.com. This website recently published an article with a reward if someone did bodily harm to the PLAINTIFF while he was in Texas, and double the reward if the PLAINTIFF was sent to the morgue. [Exhibit 12 hereto is this reward notice.] [Exhibit 1 hereto contains a folder titled Joeyisalittlekid that includes stalking and harassment from this group.]
- Lord only knows how many threats have been published online. The PLAINTIFF anticipates that it would take at least one full-time person just to keep up with what is published and the comments that people make. The PLAINTIFF fears that there are far more threats that he doesn’t know about.
THE PRIVACY RIGHTS OF THE PLAINTIFF HAVE BEEN VIOLATED
- The privacy rights of the PLAINTIFF have been violated.
- DOMBROWSKI and her associates have given publicity to matters concerning the PLAINTIFF.
- DOMBROWSKI and her associates have invaded the PLAINTIFF’s privacy. The PLAINTIFF’s name has been misappropriated as has the name of his deceased parents. The PLAINTIFF’s photos and intellectual property have been misappropriated many times. [Exhibit 13 hereto is a Facebook site set up in the name of the PLAINTIFF.] [Exhibit 14 hereto is a Facebook site set up in the name of the PLAINTIFF’S deceased father. Photos taken from his tribute website include him in his death bed and is coffin at the funeral home. Another page shows what is allegedly his skeleton, and another page has a photo of him on his death bed allegedly having phone sex with his deceased wife, the PLAINTIFF’S mother.] [Exhibit 15 hereto is a Facebook site set up in the name of the PLAINTIFF’S deceased mother. It shows what is allegedly her skeleton bones wearing a wig.]
- DOMBROWSKI and her associates have publicly disclosed private facts about the PLAINTIFF, and totally false personal information has been publicly disclosed. Facts disclosed include alleged sex life, alleged criminal activity, alleged failure to pay taxes, alleged pedophilia, and much more.
- There is an absolutely false article on Business Week’s website posted by DOMBROWSKI that claims the PLAINTIFF is a sexual deviant and a terrorist. [Exhibit 16 hereto is this article.] [Exhibit 17 hereto is a printout of hundreds of web pages out of over 10,000 that are showing “Bill Windsor – Sexual Deviant.] [Exhibit 18 hereto are the definitions of deviant, sexual deviant, and terrorist – each of which are highly defamatory, false, and criminal if true.] [Exhibit 19 hereto are screenshots of some of DOMBROWSKI’S websites defaming and stalking the PLAINTIFF.]
- The PLAINTIFF’s personal photos, photos of family members, as well as photos and alleged photos of his family have been published to damage the PLAINTIFF and in violation of his privacy and intellectual property rights. The matters publicized would be offensive to a reasonable person. The disclosures have humiliated the PLAINTIFF.
DOMBROWSKI HAS COMMITTED MANY VIOLATIONS
OF KANSAS CRIMINAL STATUTES
- DOMBROWSKI has committed many counts of violations of Kansas’ statute on Criminal Defamation.
- 21-4004 – Criminal Defamation: (a) Criminal defamation is communicating to a person orally, in writing, or by any other means, information, knowing the information to be false and with actual malice, tending to expose another living person to public hatred, contempt or ridicule; tending to deprive such person of the benefits of public confidence and social acceptance; or tending to degrade and vilify the memory of one who is dead and to scandalize or provoke surviving relatives and friends.
- Exhibit 1 hereto contains a folder titled Claudine Dombrowski that includes extensive evidence of defamation. [Exhibit 20 hereto contains a few of the various published statements by DOMBROWSKI defaming, harassing, and/or stalking the PLAINTIFF.]
- DOMBROWSKI has committed many counts of violations of Kansas’ criminal statute on Stalking.
- 21-3438. Stalking: (a) Stalking is: (1) Intentionally or recklessly engaging in a course of conduct targeted at a specific person which would cause a reasonable person in the circumstances of the targeted person to fear for such person’s safety, or the safety of a member of such person’s immediate family and the targeted person is actually placed in such fear; (2) intentionally engaging in a course of conduct targeted at a specific person which the individual knows will place the targeted person in fear for such person’s safety or the safety of a member of such person’s immediate family; or (1) “Course of conduct” means two or more acts over a period of time, however short, which evidence a continuity of purpose. A course of conduct shall not include constitutionally protected activity nor conduct that was necessary to accomplish a legitimate purpose independent of making contact with the targeted person. A course of conduct shall include, but not be limited to, any of the following acts or a combination thereof: (A) Threatening the safety of the targeted person or a member of such person’s immediate family. (B) Following, approaching or confronting the targeted person or a member of such person’s immediate family. (G) Any act of communication. (2) “Communication” means to impart a message by any method of transmission, including, but not limited to: Telephoning, personally delivering, sending or having delivered, any information or material by written or printed note or letter, package, mail, courier service or electronic transmission, including electronic transmissions generated or communicated via a computer. (3) “Computer” means a programmable, electronic device capable of accepting and processing data. (5) “Immediate family” means father, mother, stepparent, child, stepchild, sibling, spouse or grandparent of the targeted person; any person residing in the household of the targeted person; or any person involved in an intimate relationship with the targeted person.
- The PLAINTIFF is far from the only person who is stalked by DOMBROWSKI. Exhibit 21 hereto is the Affidavit of Janice Levinson prepared for this Court that details her stalking by DOMBROWSKI. [Exhibit 22 hereto includes screenshots of other websites that DOMBROWSKI operates to stalk and defame others, including Topeka attorneys and doctors.]
- The criminal definition of “stalking” in Kansas clearly incorporates the PLAINTIFF’S family, and the PLAINTIFF’S family members have made their fear absolutely clear to the PLAINTIFF.
- DOMBROWSKI has committed many counts of violations of Kansas’ statute on Criminal Threats.
- 21-3419 – Criminal threat: (a) A criminal threat is any threat to: (1) Commit violence communicated with intent to terrorize another, or to cause the evacuation, lock down or disruption in regular, ongoing activities of any building, place of assembly or facility of transportation, or in reckless disregard of the risk of causing such terror or evacuation, lock down or disruption in regular, ongoing activities; [emphasis added]
- Previously referenced threats to shoot the PLAINTIFF with a .45, Kill Bill, wage war on the PLAINTIFF, and bring an army against the PLAINTIFF may all be considered criminal threats.
THE ACTIVITY THAT MAY BREED A KILLER
- The threats to the PLAINTIFF are not just from specific threats to do harm or veiled death threats, they are also from all the defamatory, malicious, complete fabrications of criminal activity statements published all over the Internet. [Exhibits 1, 12, 17, 19, 20 hereto contain just a few of the thousands of web pages that defame the PLAINTIFF.]
- Thus far, the PLAINTIFF has identified over 32 websites set up specifically to defame him and incite people who read the sites, and many other websites operated by DOMBROWSKI and her associates that are used for the same purposes. These sites include the following:
- Bill Windsor – Sexual Deviant, Homeland Terrorist and His Cult Group
- Janice Levinson: Using the Blood of Battered Mothers and Children for
- Kansas Secretary of State Is not happy with Lawless America
- Janice Levinson: When You Play With Wolves
- Bill Windsor – Endangering Domestic Violence Victims and Survivors
- William M Windsor: An American Terrorist
- Bill Windsor – Endangering Domestic Violence Victims and Survivors
- Unforgiven Little Bill Death Scene — https://www.facebook.com/lorraine.tipton.14
Pages from some of these websites are attached as Exhibit 19 the AFFIDAVIT. All may be viewed online.
- The PLAINTIFF fears that an unbalanced person reading some of this information may well provide the biggest threat. The PLAINTIFF fears injury or death from someone that he doesn’t even know who has been incited by the unbelievable claims, comparisons to Hitler, and assertion after assertion that the PLAINTIFF sexually abuses children.
PROOF THAT DOMBROWSKI HAS
PERSONALLY STALKED THE PLAINTIFF
- The PLAINTIFF has met, filmed, and photographed DOMBROWSKI.
- The PLAINTIFF has a contract with DOMBROWSKI in which she provided her name, address, phone, email, and website information. When the PLAINTIFF filmed DOMBROWSKI in 2012, she told the PLAINTIFF that she was the president and founder of the American Mothers Political Party. The PLAINTIFF has received emails and messages from DOMBROWSKI.
- The publications by DOMBROWSKI include her photograph and are tied to accounts in her name. The photographs match photographs that the PLAINTIFF has of DOMBROWSKI.
- Publications by DOMBROWSKI and some of her associates appear on the so-called American Mothers Political Party website. [Exhibit 23 hereto.]
- Music that plays on the http://americanmotherspoliticalparty.org/ website is identical to that on many of the other websites operated by DOMBROWSKI.
- The American Mothers Political Party has a BlogTalk Radio program. These programs have the voice of Claudine Dombrowski that is the same as her voice in the video filmed by the PLAINTIFF. One example is: http://www.blogtalkradio.com/americanmotherspoliticalparty/2011/08/25/american-mothers-political-party [Exhibit 24 hereto.]
- The BlogTalk radio website lists the website for the American Mothers Political Party, the Facebook page, and the Twitter account – all of which have been used to stalk the PLAINTIFF. [Exhibit 25 hereto.]
- The American Mothers Political Party website shows DOMBROWSKI’S official Safe at Home address provided by the Kansas Secretary of State. This is the same address that the PLAINTIFF provided to this Court for service on DOMBROWSKI. [Exhibit 26 hereto.]
- The American Mothers Political Party website has a Contact Page that has the ability to show the email address. That email address goes to DOMBROWSKI. [Exhibit 27 hereto.]
- The American Mothers Political Party website has published the article declaring the PLAINTIFF to be a sexual deviant and a terrorist, the same article that DOMBROWSKI published on the Business Week website and many other sites. http://americanmotherspoliticalparty.blogspot.com/2013/06/bill-windsor-sexual-deviant-homeland.html [Exhibit 28 hereto.]
- The blogs promoted on the American Mothers Political Party include many where the PLAINTIFF has been defamed and stalked. These include DOMBROWKSI’S personal blog where defamation and stalking has been done against the PLAINTIFF: A Mothers Rage,A Movement Against Domestic Violence, A Target No More, Abusers Getting Custody, Alexis A. Moore, Alpha Inventions, American Children Underground (Jennifer Collins), American Mothers Political Party, AngelFury, AngelGroup.org, Angelzfury, Anne Caroline Drake, Anonymiss, Anonymoms (we are everywhere), Anonymuma, Anonymums, Australian Mothers Political Party, Australian Shared Parenting Law Debate, Autism Custody Battles, Baitul Salaam Network, Battered Moms Loose Custody To Abusers, Battered Mothers Custody Conference – BMCC, Battered Mothers – A Human Right’s Issue, Battered Mothers Child Custody Court Abuse, Battered Women Battered Children Custody Abuse, Best Interest Of The Child, Bring Jared Home, Bzzzz, Busted, California Protective Parents Association, Caroline Halonen-Rice – A Mothers Love, Chaos Theory, Children Against Court Appointed Child Abuse – CA3, Children’s Voices in Family Law, Claudine Dombrowski, Cold North Wind, Confessions of a Tormented Soul, County In Need of Change, Court Whores, Courageous Kids, Custody Prep for Moms, Dastardly Dads, Defend the Children, Domestic Violence Legal Empowerment and Appeals Project, Exposing the Untold Truths of Family Law (AU), Fatherlessness Family Court In America, Fathers Rights Naked Feminist Avengers, Feminist Manifesto, Fighting for Arizona’s Children, Find Jean Paul Diaz Lacombe, Fraud On The Court, Free Us Now, Gendered Violence Portal, GIVE ME MY MOM, Glenn’s Cult, Good Guys and Gals in Politics, Help Save Malie, How to Disapear, Human Rights For Abused Mothers And Children, Just Bee Aware, Justice for Children, Justice’s Posterous, Kansas Family Court Reform Coalition, Kansas Mothers For Custodial Justice, Kansans for Judicial Accountability, Kids In Distress (AU), Kids Need Mums (UK), Let’s Get Honest, Lovefraud, Mama Liberty, Media Misses, Mothers of Lost Children, Momentum Of Mothers (MOM), Mommy Go Bye-Bye, Mother – Fucking: The Saga of One Fucked Mother, Mothers Are Vanishing, Mothers Fight For Justice, Mothers For Equality, Mothers For Justice (UK), Mothers Intelligent Secret Service, Mothers Intelligence Secret Service -M.I.S.S., Mothers of Lost Children – Indiana, My Ex Is Worst Than Yours!!, Name That Pedophile, National Alliance for Family Court Justice, National Organization For Men Against Sexism on Custody & Abuse, New Jersey Women for Family Court Reform, No More Broken Wings, Non Custodial Moms of NY, Noncustodial Parent Community, NOMAS, No Way Out- But One, Obstreperous Expressions, Parental Alienation Racket, Parental Alienation Scam, Parenting News Network, Protective Parents For Children’s Rights, Randi James, Sacagawea’s Blog, Safety 4 Parents and Kids (AU), Save Aaliyah, Saving Damon, Sin Denied, Single Mum-AU, Stacey Momany, Stokes Family Blog, Stop Family Violence, Susan Murphy Milano’s Journal, Tailored Life Coaching, The Custody Scam, The Elders, The Institute for Relational Harm Reduction, The Leadership Council, The Liz Library, The Majority United, The National Domestic Violence Pro Bono Directory, The Shared Parenting Disaster, The Survivor Manual from Angela Shelton, The Truth About The Family Court, Times Up! ,UniFem, UN Mothers, Until You Say Uncle – by Julie Levine, VANISHED!, Violence Against Women News Central, Was It Really Worth It?, Women As Mothers, Women in Crime Ink, Womens Legal Resource, WomensLaw.org.
- The American Mothers Political Party Facebook page has viciously stalked and defamed the PLAINTIFF. The page currently has an article posted by DOMBROWSKI showing her photograph, a photograph that the PLAINTIFF recognizes to be her. [Exhibit 29 hereto.]
- The American Mothers Political Party website has a membership application. That application is hosted at DocStoc. The DocStoc page with the application shows that it was posted by DOMBROWSKI. [Exhibit 30 hereto.] When you click on the link for DOMBROWSKI’S name, it takes you to her DocStoc account page which includes copies of numerous filings in her legal cases in Shawnee County Kansas. [Exhibit 31 hereto.]
- The American Mothers Political Party website has a link to the group’s Twitter page. The Twitter account shows numerous posts that are stalking and defaming the PLAINTIFF. [Exhibit 32 hereto.]
- The American Mothers Political Party has a YouTube page. That page contains a video that stalks and defames the PLAINTIFF. [Exhibit 33 hereto.]
- The American Mothers Political Party has produced many videos that stalk and defame the PLAINTIFF. [Exhibit 1 hereto contains a folder titled Videos. The Court is asked to watch the video titled 1-Diarrhea of the Mouth – YouTube to get a flavour for what these videos contain.]
- DOMBROWSKI has a WordPress account. That account shows her to be the author of the articles on that site. [Exhibit 34 hereto.] When you click on her name, it takes you to a page that shows the articles that she has written. These include the widely-published article that the PLAINTIFF is a sexual deviant and a terrorist. [Exhibit 35 hereto.] One of these articles includes a photo of a woman carrying a gun, and in the published information, DOMBROWSKI says she will show the PLAINTIFF how to use a 45 calibre gun when he comes to Topeka. “It will be my pleasure to show you how to use a .45 up close and personal. Put you out of your misery, mercy! [Exhibit 36 hereto.]
- DOMBROWSKI has a LinkedIn page. It shows her to be the CEO of the American Mothers Political Party, and it includes the photograph shown on many of the defamatory and stalking publications against the PLAINTIFF by DOMBROWSKI. [Exhibit 37 hereto.]
- DOMBROWSKI has a website titled angelfury.org. [Exhibit 38 hereto.] When you click on her name at the bottom of the page, it opens an email addressed to her. [Exhibit 39 hereto.] The email address is the one that DOMBROWSKI gave to the PLAINTIFF as her email address. This website includes links to many of the websites and webpages that stalk and defame the PLAINTIFF.
- http://abusiveadvocates.wordpress.com/ contains an article identifying DOMBROWSKI as the CEO and co-founder of the American Mothers Political Party. [Exhibit 40 hereto.]
- http://angelzfury.blogspot.com/2010/07/american-mothers-political-party-is-now.html is another website written by DOMBROWSKI. It clearly shows her to be the creator of the American Mothers Political Party. [Exhibit 41 hereto.]
- The angelzfury.blogspot.com website has a hyperlink for DOMBROWSKI as the author. [Exhibit 42 hereto.] When you click it, it takes you to a Google Plus account for DOMBROWSKI. [Exhibit 43 hereto.] This has a number of stalking and defamatory publications, including one that shows she knew about the stalking hearing and was never going into another courtroom ever again. This website also shows that DOMBROWSKI published the confidential name and address of the hotel where the PLAINTIFF was staying in Topeka.
- https://www.facebook.com/ClaudineDombrowski is one of many Facebook sites that DOMBROWSKI has. This site contains many articles that defame and stalk the PLAINTIFF, including the one that says he is a sexual deviant and a terrorist. [Exhibit 44 hereto.]
- Imagine Publicity is a PR firm that has DOMBROWSKI as a client. http://imaginepublicity.com/clients/claudine-dombrowski/ shows a photo of DOMBROWSKI that matches the photos the PLAINTIFF has of DOMBROWSKI, and it states that she is the leader of the American Mothers Political Party. [Exhibit 45 hereto.]
- The PLAINTIFF did a complete download of the American Mothers Political Party website that contains massive stalking and defamation of the PLAINTIFF. [Exhibit 1 hereto contains a folder titled AMPP.]
- If you do a Yahoo search for “Bill Windsor deviant,” many web pages are returned, most of which are websites written by DOMBROWSKI. The same thing is true of searches for “Bill Windsor terrorist,” “Bill Windsor scam,” and “Bill Windsor fraud.” Similar results are generated if you use William instead of Bill.
- A Google search for “Bill Windsor – sexual deviant” returns 15,500 pages. One of the first results is a DOMBROWSKI site titled kansansforjudicialaccountability, and it shows her photo and the sexual deviant article. The PLAINTIFF reviewed every web page returned by Google, and every one of them was the article published by DOMBROWSKI declaring the PLAINTIFF to be a sexual deviant and a terrorist. [Exhibit 17 hereto.]
- KSA 60-31 provides that this Court may enter temporary relief orders as it deems necessary to protect the victim from being stalked. Temporary orders may be granted ex parte on presentation of a verified petition by the victim supporting a prima facie case of stalking. The PLAINTIFF desperately needs protection from stalking. The PLAINTIFF has provided this verified petition that provides the information that absolutely establishes a prima facie case of stalking.
- As the hearing on this matter was continued, the Court may make such temporary orders as it deems necessary. The statute provides the following may be in an order of protection from stalking, and the PLAINTIFF respectfully requests this relief:
- Restraining the Defendant and anyone associated with her from following, harassing, telephoning, contacting, or otherwise communicating with the victim, including emailing, posting messages online, publishing or maintaining websites about the PLAINTIFF, or publishing articles or comments online about the PLAINTIFF. Such order shall contain a statement that if such order is violated such violation may constitute stalking as defined in K.S.A. 2012 Supp. 21-5427, and amendments thereto, and violation of a protective order as defined in K.S.A. 2012 Supp. 21-5924, and amendments thereto.
- Restraining the defendant and anyone associated with her from abusing, molesting, or interfering with the privacy rights of the victim. This includes use of the PLAINTIFF’S photos, videos, and intellectual property, use of any information about the PLAINTIFF’S deceased parents or his family, publication of any private information about the PLAINTIFF. Such order shall contain a statement that if such order is violated, such violation may constitute stalking as defined in K.S.A. 2012 Supp. 21-5427, and amendments thereto, assault as defined in subsection (a) of K.S.A. 2012 Supp. 21-5412, and amendments thereto, battery as defined in subsection (a) of K.S.A. 2012 Supp. 21-5413, and amendments thereto, and violation of a protective order as defined in K.S.A. 2012 Supp. 21-5924, and amendments thereto.
- Restraining the defendant and anyone associated with her from entering upon or in the PLAINTIFF’S residence or the immediate vicinity thereof or hotels that he uses while traveling, or upon or in the PLAINTIFF’S place of work, which includes filming locations in every state. Such order shall contain a statement that if such order is violated, such violation shall constitute criminal trespass as defined in subsection (a)(1)(C) of K.S.A. 2012 Supp. 21-5808, and amendments thereto, and violation of a protective order as defined in K.S.A. 2012 Supp. 21-5924, and amendments thereto.
- Any other order deemed necessary by the court to carry out the provisions of this act, to include a provision that this order shall apply to all who have associated with the defendant in stalking the PLAINTIFF, including all members and followers of the American Mothers Political Party and joeyisalittlekid.blogspot.com.
WHEREFORE, PLAINTIFF prays that this Court enter an order granting the petition for an ex parte protective order.
Submitted this 26th day of July, 2013,
William M. Windsor
13D1747-Plaintiffs-Amended-Petition-2013-07-26-Exhibit-01 is a 7 GB flash drive.