Beruflich Dokumente
Kultur Dokumente
ROPERT GIPSON, )
Individually )
)
And )
)
ROBERT GIPSON, ) CASE NUMBER # 09 – 4136 – CV – C - NKL
as Next Friend of )
Casey Gipson, a minor child )
)
Plaintiffs, )
)
vs. )
Defendants, )
GOVERNOR OF MISSOURI )
JAY NIXON, in his official and individual
capacity )
)
)
RONALD LEVY, )
STATE OF MISSOURI DIRECTOR )
OF FAMILY SERVICES
in his official and individual
Capacity. )
JAMES HARRISON
STATE OF MISSOURI )
DIRECTOR OF CHILDREN’S DIV. )
OF SOCIAL SERVICES )
in his official and individual
Capacity.
DESIGNATED PRINCIPAL OF )
SOCIAL SERVICES
CELESTA SUE HARTGRAVES )
in her official and individual
Capacity. )
)
STEVE MORROW
MISSOURI CHILD ADVOCATE
in his official and individual
Capacity.
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BRYAN KINCAID
DESIGNATED PRINCIPAL OF )
SOCIAL SERVICES
in his official and individual
Capacity.
WILLIAM HAEFER; )
Circuit Manager, )
Benton County Children’s Division; )
in his official and individual
Capacity.
)
JAMES JOHNS, ATTORNEY FOR )
BRANDY WILKENSON WARREN, )
in his official and individual
Capacity.
)
BRANDY WILKENSON WARREN )
MOTHER OF CASEY GIPSON,
in her individual Capacity.
JASON WARREN
STEP FATHER OF CASEY GIPSON
in his individual Capacity.
ADMINISTRATORS
MYSPACE WEB SITE
in their official and individual
Capacity
MR LUTMAN
GAL FOR MINOR CHILD
in his official and individual
Capacity.
Defendants. )
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COMPLAINT
PART #1
COMES NOW, Robert Gipson, pro se, and for his cause of action for the removal of Casey Ryan
Gipson’s picture from a Porn sex site on MYSPACE. Brandy Wilkenson, mother of Casey Gipson exploits sex
on the MYSPACE web site. Pictures, video, and advertisement as a sex coach is her marketing profile. This
brings discredit to the minor child when his picture is also on this web site. Defendants have had ample
opportunity to investigate the pictures and video of the Porn site on Brandy Wilkenson’s MYSPACE web site.
This is a Porn site and the minor child’s picture is posted for view by visiting customers. Robert Gipson
presented evidence to the Missouri Children’s Division, Benton County Sheriff’s Department and Honorable
Judge Michael Hendrickson. Defendants have protected Brandy Wilkenson and her husband Jason Warren at
the expense of the minor child. It is a Federal Violation to have pictures of children on a MYSPACE Porn site.
The owners and operators of MYSPACE has failed to monitor their Web site and has jeapordized the health and
welfare of the minor child Casey Ryan Gipson. Retaliation by the Benton County Sheriffs Department resulted
in harassment by means of arrest and civil rights violations against Robert Gipson. During the last court hearing
Judge Michael Hendrickson refused to remove the minor child’s picture from the MYSPACE PORN WEB
SITE. The GAL MR Lutman was also aware of this web site and did nothing. Mr. Lutman is presently the
GAL for the minor child. Mr Lutmans failure to protect the minor child is cause for dismissal. The Plaintiff was
subjected to excessive harassment during the June 2009 court hearing. Plaintiff was held by force and threat of
physical and mental abuse by Judge Hendrickson and the court Baliffs. The first court hearing consisted of five
Baliffs, two Prosecuting Attorneys and one person from the Missouri crime victims office who worked with
Karen Woodley the Benton County Prosecutor. This was nothing more than an imminent threat against
Plaintiff Robert Gipson. This threat infringed upon the integrity of the case and created a very hostile court
environment. This threat by court officials against the Plaintiff Robert Gipson violated his civil rights to a fair
trial and violated the Plaintiffs fourteenth amendment. This act of aggression against Plaintiff interrupted the
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normal course of justice. To this date July 15, 2009, Plaintiff continues to be oppressed by community
corruption. Plaintiff will never get a fair trial in the Benton County Missouri court house, nor in the Western
court of appeals. The attached documents also indicate a child and father who has endured excessive physical
and mental abuse. This abuse has been covered up by the Missouri Children’s Division, case workers and
supervisors. Mandated reporter, Psychologist and Defendant, Ms Erika Waller failed to report that the child
Casey Gipson was beat in the face and eye by his mother Brandy Wilkenson. Psychiatrist and Defendant Dr
Daniels from Columbia Missouri supervised Dr Waller. Both failed to report this abuse against the minor child.
Both were presented with many documents describing prior neglect and abuse against the minor child. Part one
and part two of Plaintiffs law suit identifies a consolidation of reports, pictures, video and CD to substantiate
Plaintiffs accusations against the Defendants. The first course of action requested by Plaintiffs is to remove
the minor child’s picture from the MYSAPCE porn site created and managed by Defendant Brandy Wilkenson
and her husband Defendant Jason Warren. The Defendants listed in part one and part two of this law suit
subjected the minor child to a life of hardship by ignoring obvious signs of neglect and abuse against the child.
Defendants, in their official and individual capacity to protect the minor child from harm as directed by the
United States Constitution, violated their oath of office. Defendants Brandy Wilkenson and Jason Warren
have conducted criminal activities against the minor child and Plaintiff Robert Gipson as stated in part one and
part two of this claim. Part one and part two of said claim relates to various Defendants who have violated the
civil rights of Plaintiffs. Part one and part two has attached supplemental evidence to support said claim.
Attached are photos, video, CD, medical documents, witness statements,and legal documents. Part one and
part two describes the actions of each Defendant, relief sought for by Plaintiffs, supplemental evidence, and
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JURISDICTION AND VENUE
1. This action is brought pursuant to the Constitution of the United States, particularly the
Fourteenth Amendment; the laws of the United States, particularly 42 U.S.C. §§ 1997.
2. This Court has federal jurisdiction under 28 U.S.C §§ 1331 and 1343 (a).
3. The events described herein took place in Benton County, Missouri. Hence, and MYSPACE
web site venue is proper within the Western District, Central Division under 28 U.S.C. § 1391 (b).
5. Plaintiffs request protection by this court from any further civil rights violations
7. Plaintiff request relief and preys that this court require all Defendants to take a voice analysis test and
PARTIES
8. The Plaintiff, Robert Gipson is a resident of Benton County, State of Missouri and is the natural
9. Plaintiff Robert Gipson brings this action as the parent of Casey Ryan Gipson and as the next
friend of Casey Gipson, a minor child, who is currently legally unable to bring this cause to action himself.
10. Defendant William Haefer, was Circuit Manager of the Benton County Children’s Division,
office located in Warsaw, Missouri and was in such position at all times relevant to this lawsuit.
11. At all times relevant herein, Defendant William Haefer acted pursuant to the policies,
regulations, or decisions officially adopted or promulgated by Benton County, which acts may fairly be said to
represent official policy or were pursuant to the governmental custom of Benton County, and thereby the State
of Missouri.
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12. Defendant Ron Levy, Director of the Missouri Family Services, was fully aware of this Porn
Site and failed the minor child miserably. The Defendant Ron Levy was at all times relevant here and assigned
by Governor Nixon to protect the children in Missouri from such neglect and abuse. Ron Levy received a CD
and video of the minor child showing neglect and abuse. Ron Levy and his staff of supervisors and case workers
failed to protect Casey Ryan Gipson. Plaintiff Robert Gipson appeared in person in front of Ron Levy, Mr.
Kincaide, and Ms Hartgrave. Once again the evidence presented to the agency responsible for protecting
Casey Ryan Gipson failed to process the information. Their actions have been fruitless. They refused to
recognize the credibility of this evidence and failed to recognize the previous years of “ HOT LINE” calls and
reports of neglect and abuse against the minor child. Their inability to evaluate, investigate and conduct
interviews has done a disservice to the minor child and Plaintiff Robert Gipson.
13. At all times relevant herein, Defendants Jim Harrison, Steve Morrow, Nancy Parks, Ms Hendrickson,
Paula Neese, Ms Hartgrave, Ron Levy violated the civil rights of the Plaintiffs and failed the minor child. All
failed to enforce the policies, regulations, or decisions officially adopted or promulgated by Missouri Childrens
Division, which acts may fairly be said to represent official policy or were pursuant to the governmental custom
of the State of Missouri. All were aware of neglect and abuse hot line calls that go back to the year 2004.
14. Defendant Steve Morrow was at all times relevant herein, the Missouri Advocate for Missouri
and assigned by Governor Blunt. Steve Morrow communicated with Jim Harrison and was fully aware of the
Porn web site and other neglect and abuse issues against the minor child. A meeting was held with Jim
Harrison, Steve Morrow and Robert Gipson father of the minor child present. Robert Gipson showed Steve
Morrow a video of the minor child with Sleep Apnea and Obstructive Airway. In 2009, Steve Morrow stated to
Plaintiff Robert Gipson that he viewed the two recorded video of Casey Gipson that was taken at the safe house
interview. Brandy Wilkenson, Paula Woolery and Rhonda Talley scheduled and initiated two safe house
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interviews as a result to the false accusations that Plaintiff sexually molested his minor child. Chief Kinkinnon
of the Lincoln Police Department also testified on the witness stand that there is a video and it was placed in the
wall locker at the Benton County Court House. Plaintiff is aware of two safe house interviews where the minor
child Casey Gipson was taken. One was in Springfield Missouri and the other in Sedalia Missouri. Plaintiff was
accused of being the perpetrator on two separate false accusations of sexual abuse Steve Morrow was first
contacted in Nov 2006 when the Plaintiff was accused of sexually molesting his minor child. Mr. Morrow was
hired by Matt Blunt. Both were aware of the issues with Casey Gipson and made a fruitless attempt to help this
child. the Plaintiff informed Mr. Morrow that the minor child was presented with a CPAC from the Respiratory
Doctor in Columbia Missouri after an emergency room visit. Again, 2008 and 2009 Mr. Morrow was
Levy as the Director of the Missouri Division of Family Services. Governor Nixon assigned Ron Levy to over
see the work of the entire Division and the supervisors within the Division. Governor Jay Nixon received
documents from Plaintiff Robert Gipson which contained information identifying child neglect and abuse.
Third parties to said claim also presented valuable evidence and documents. Governor Nixon failed to conduct
a proper investigation into the allegations reported by Plaintiff Robert Gipson. As a result, Plaintiffs Robert
Gipson and his minor child also Plaintiff Casey Ryan Gipson by and through his father have come under attack
by various government workers from the Missouri Children’s Division. Request by Plaintiff Robert Gipson to
meet with Governor Jay Nixon has been ignored. Numerous documents presented to Governor Jay Nixon
identifying child neglect and abuse against the minor child Casey Ryan Gipson has been ignored. This agencies
failure to act and protect Plaintiffs have resulted in recent abuse against the minor child Casey Ryan Gipson and
minor child’s father Robert Gipson. Governor Jay Nixon and his staff failed to protect Plaintiffs from the on
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going blatant attacks from case workers and local police in Benton County Missouri. Plaintiffs Pleas for help
have not been answered. Since Jan 2009 and after Jay Nixon’s oath of office, Plaintiff Robert Gipson has
pleaded with the staff of Jay Nixon. Plaintiff Robert Gipson has personally visited the office of Jay Nixon and
his constituents’ staff. Plaintiff has been waiting since Jan 2009 for a response from Governor Jay Nixon and
his staff. This administration has failed to protect the Constitutional Rights of Plaintiffs. Plaintiffs have
reported numerous times of criminal violations against them by government workers from the Missouri
Children’s Division. It has been six months since Plaintiff Robert Gipson has reported to this new
administration of the criminal acts and conspiracy to cause mental and physical harm against Plaintiff Robert
Gipson and his son Casey Ryan Gipson. Governor Jay Nixon is a mandated reporter and has failed to repot and
protect the Constitutional Rights of Plaintiffs. The Right to pursue happiness without experiencing excessive
force has and continues to haunt Plaintiffs. In 2006 when then Attorney General Jay Nixon was in office,
Plaintiff and third party witnesses presented evidence and statements of neglect and abuse against the minor
child. Again, this information was ignored. Now that Jay Nixon is the governor of Missouri, he continues to
ignore the pleas from Plaintiffs. The new Attorney General Kristopher Koster has evidence and statements
from plaintiff and third parties that show good reasons to investigate Plaintiffs claims. This administration
failed to investigate the child neglect reports. This is a direct violation under the color of law under the
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16. JAMES HARRISON
STATE OF MISSOURI
DIRECTOR OF CHILDREN’S DIV.
OF SOCIAL SERVICES
in his official and individual
Capacity.
Defendant, Jim Harrison failed to investigate the evidence presented to him by Plaintiff. Mr. Harrison made
every attempt to obstruct justice prior to leaving his position with the Missouri Social Services Childrens
Division. Mr. Harrison was in a position to investigate such evidence and failed to do so. His actions violated
the civil rights of plaintiffs. His tenure with the Childrens Division created obstacles that prevented proper
leadership in order to conduct professional investigations. This lack of knowledge and disregard for policies
and procedures failed short. Mr. Harrison is mentioned in part one and part two of this claim. Mr. Harrison
, under color of authority and in their capacity as agents of the State of Missouri, individually and collectively
placed the Minor child’s health in jeopardy by ignoring the legitimate complaints by Robert Gipson and witness
Gina Swartz. The Missouri Childrens Division Defendants purposely ignored the complaints by Robert Gipson
Plaintiff and in so doing further neglected the well being of the minor child and did perpetuate the exposure of
Defendant, Celesta Sue Hartgrave, is mentioned in part one and part two of Plaintiffs claim. Ms Hartgraves
relationship with Defendant Mr. Harrison makes her a party to this claim. Ms Hartgrave also failed to properly
investigate and evaluate various evidence and claims made by Plaintiff Robert Gipson. Her lack of skills
hindered her from assisting the minor child Casey Gipson and Robert Gipson.
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18. STEVE MORROW
MISSOURI CHILD ADVOCATE
in his official and individual
Capacity.
Defendant Steve Morrow, Missouri Children’s advocate, was at all times relevant herein, the
Missouri Advocate for Missouri and assigned by Governor Blunt. Steve Morrow communicated with Jim
Harrison and was fully aware of the Porn web site and other neglect and abuse issues against the minor child.
A meeting was held with Jim Harrison, Steve Morrow and Robert Gipson father of the minor child present.
Robert Gipson showed Steve Morrow a video of the minor child with Sleep Apnea and Obstructive Airway. In
2009, Steve Morrow stated to Plaintiff Robert Gipson that he viewed the two recorded video of Casey Gipson
that was taken at the safe house interview. Brandy Wilkenson, Paula Woolery and Rhonda Talley scheduled
and initiated two safe house interviews as a result to the false accusations that Plaintiff sexually molested his
minor child. Chief Kinkinnon of the Lincoln Police Department also testified on the witness stand that there is
a video and it was placed in the wall locker at the Benton County Court House. Plaintiff is aware of two safe
house interviews where the minor child Casey Gipson was taken. One was in Springfield Missouri and the
other in Sedalia Missouri. Plaintiff was accused of being the perpetrator on two separate false accusations of
sexual abuse Steve Morrow was first contacted in Nov 2006 when the Plaintiff was accused of sexually
molesting his minor child. Mr. Morrow was hired by Matt Blunt. Both were aware of the issues with Casey
Gipson and made a fruitless attempt to help this child. the Plaintiff informed Mr. Morrow that the minor child
was presented with a CPAC from the Respiratory Doctor in Columbia Missouri. The child was taken to the
Emergency room in Columbia after having Sleep Apnea and Upper respiratory infection in Plaintiffs car.
Plaintiff, once again has attempted to get the support from the Missouri advocate office. It appears that Mr
Morrow and his office staff is more concerned with federal funding than to helping children in Missouri. Again
in 2008 and 2009 Mr. Morrow was contacted by Plaintiff Robert Gipson. It has been now over two and half
years that Mr Morrow has known of such neglect and abuse against the minor child. Plaintiffs aks for relief to
assign another advocate in this position. Plaintiff request that Defendant Steve Morrow resign from his job as
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advocate for Missouri Children. Steve Morrow has not once prepared any reports and has failed to properly
investigate said claims. Steve Morrow is waisting the tax payers money and is not competent to hold such a
Defendant, Bryan Kincaid, assisted Mr. Ron Levy who is the director of the Missouri Social Services and
supervisor over Mr. Kincaid. Mr. Kincaid obstructed justice and investigations within the division. Defendant
ignored valuable evidence that was presented by Plaintiff Robert Gipson and other third party witnesses. Mr
Kincaid created a hostile environment. Plaintiff informed Mr. Kincaid that he refuses to communicate with him
or any other supervisor and demanded to schedule a meeting with Ms Debra Scott. This request was made after
case workers and supervisors failed to support the minor child and ignored obvious pictures of abuse and other
credible evidence. Mr Kincaid, Mr Levy and their staff created a hostile environment in their office when they
oppressed Plaintiff by having a police officer stalk the Plaintiff during a scheduled meeting in their office.
Defendant Bryan Kincaid is mentioned in part one and part two of this claim.
Defendant, William Haefer, was inpostion at al times and had knowledge of the issues and complaints
presented by Plaintiff. Mr Haefer failed to supervise his workers and as a result the minor child was un
protected. Mr Haefer had ample opportunity to over see the work of his subordinates and failed to do so. AT no
time did Mr Haefer introduce a plan of action to reduce the pain and suffering that affected the minor child
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21. JAMES JOHNS, ATTORNEY FOR
BRANDY WILKENSON WARREN,
in his official and individual
Capacity.
Defendant, James Johns, assisted his client and Defendant Brandy Wilkenson in bringing fraud upon the
court. Mr Johns and his client and mother of the minor child Casey Gipson were in contempt of court when they
deceived the court under oath on issues pertaining to the MYSPACE porn web site. The fruit of the forbidden
tree which is rooted in Defendants trial tactics has caused the Plaintiffs to suffer severely Defendant James
Johns has coached his client to lie on the witness stand. In 2007 James Johns was fully aware of the
MYSPACE porn site and in June 2009 coached his client to bring fraud upon the court. James Johns is a threat
to the minor child Casey Gipson. James Johns has mislead the 30th district court in Benton County Missouri.
James Johns has conspired with Brandy Wilkenson to bring slander against Plaintiff Robert Gipson. Mr Johns is
web site exploits sex and has live video and pictures that is available to be seen by young children. In 2007 and
as of June 2009, this site is still in existence. Plaintiff has pleaded with Defendant and the court to remove the
picture of his son Casey Gipson from this site. Defendant has full access to this site and Brandy Wilkenson is
the one who makes the adjustments to the site. Brandy Wilkenson and her disrespect for the minor child refuses
to remove the minor childs picture. Attached as MYSPACE exhibits one, two and three shows a porn web site.
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23. JASON WARREN
STEP FATHER OF CASEY GIPSON
in his official and individual
Capacity.
Defendant, Jason Warren, step father of Casey Gipson and husband of Brandy Wilkenson Warren has
assisted Ms. Wilkenson in her porn site activities. In his 2007 deposition, Mr. Warren refers to the sex coach
add created by Defendant Ms Brandy Wilkenoson. Attached as exhibit number twenty one is a deposition from
Mr Warren in 2007. Mr Warren once held Plaintiff and his son Casey Gipson hostage in Plaintiffs home in
2005. Mr.Warrens radical behavior is a threat to Plaintiffs. Mr Warren attempted to cut the tires of Plaintiff at
the store in Cole Camp Missouri. Attached are exhibits A,D, E, F, G,H, K, M, S, and X. These exhibits
illustrate the reckless behavior of Jason Warren. Plaintiff was once told by his child Casey Gipson “Mommy
got beat at the washing machine by daddy Jason and I tried to tell him no but he would not listen” another time
Casey Gipson told Plaintiff “Mommy told me to call 911 but it was dark outside and I was scarred”
Plaintiff wqas told by his child Casey Gipson “ Daddy Jason gives me medication but I am not supposed to tell
You.” Jason Warren and Brandy Wilkenson Warren have created a high risk environamnt for the minor child.
Their thhrest of physical and mental abuse against Plaintiffs are unwarranted. Their criminal activities will not
stop until they achieve their ultimate objective. Their objective is to sever the bond between the Plaintiffs and
embezzle money from Plaintiffs bank account. Jason Warrens threats and criminal activities are documented
back to 2003 and presently in 2009. Exhibit D, is a letter from Carol Dale, Plaintiffs sister. Ms. Dale
witnessed Defendant Jason Warren slamming a chair down in the living room at the childs house in Cole Camp
Missouri. This threat against Plaintiffs and his sister was the first of many more to follow. Plaintiffs fear for
their lives and seek protection from Jason Warren. Jason Warren sated to Plaintiff in October 2005, “You think
I am crazy now, you’re a dead man.” Jason warren was observed by Plaintiffs neighbor Shirley Kaiser beating
his wife Barndy Wilkenson in the front yard of Plaintiffs home in Lincoln Missouri.
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24. HONARABLE JUDGE MICHAEL HENDRICKOSN
30TH CIRCUIT JUDGE BENTON COUNTY MISSOURI
in his official and individual
Capacity.
Defendant, Honarable Judge,Michael Hendrickson refused to hear Plaintiffs Motions for a change of
Vinue. For three months in 2009 judge Hendrickson delayed hearing Plaintiffs Motion for Temporary
Custody of the minor child and Motion to Return Plaintiffs Constitutional Rights. Even though prior
judgments and rulings were handed down by judge Hendrickosn, Plaintiff was denied to be heard until a
GAL was assigned for the minor child. The present GAL Mr Lutman ignored Plaintiffs documents of the
Porn Site by Brandy Wilkenson and numerous medical reports that clearly showed the minor child in need
of medical attention. Plaintiff met with the Defendant, GAL in May-June and gave him pictures of the
injuries on the minor child. Plaintiff also gave Mr Lutman pictures of the Porn web site. In the June 2009
hearing in Benton County, the GAL not once asked Brandy Wileknson any questions about the minor child.
The GAL appears to have copied prior texts from the previous court judgment and used this text to favor
Brandy Wilkenson. Mr Lutman has failed to review all the prior medical documents that reveal Casey
Gipson does have prior reports of Sleep Apnea. Reports of URI Upper Respiratory Infection, Tonsil Idus,
Bronchitos. These medical reports are documented back to 2004, 2005. The GAL Mr Lutman ignored the
testimony from witness Gina Schwartz who testified about her observing the minor child with Sleep Apnea.
MR Lutman ignored testimony from Plaintiff Robert Gipson testifying that he took the child to the
Emrgency room on Jan 4, 2009. Plaintiff asked the GAL to retrieve the medical records from James Johns
and the video that shows the minor child in sever stress of Sleep Apnea. On July 4, 2009 Plaintiff observed
a burn on Casey Gipson’s neck. On Sunday July 12, 2009, Plaintiff was informed by the minor child that he
has poison Ivy. Plaintiff is restricted from observing his childs medical issues. This restriction puts the
childs health and welfare in danger. Plaintiff has been removed and alienated from his child to insure
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25. OWNER AND OPERATORS
MYSPACE WEB SITE
in his official and individual
Capacity
Defendants, of MYSPACE has allowed Brandy Wilkenson to freely exploit sex on the internet. The
owner and operators of this agency has violated the civil rights of the minor child Casey Gipson
26. ADMINISTRATORS
MYSPACE WEB SITE
in their official and individual Capacity
Defendants, of MYSPACE has allowed Brandy Wilkenson to freely exploit sex on the internet. The
owner and operators of this agency has violated the civil rights of the minor child Casey Gipson. They allowed
pictures of minor children to be on the same web page where sex acts and exploiting sex were conducted and
revealed
27. MR LUTMAN
GAL FOR MINOR CHILD
Defendant, Mr Lutman failed to properly represent the minor child. Plaintiff Robert Gipson presented the GAL
Mr. Lutman credible evidence of the MYSPACE porn site created by Defendant and mother of Casey Ryan
Gipson the minor child. Mr. Lutman failed to review vital medical documents that indicated that Casey Ryan
Gipson the minor child had mild and severe Sleep Apnea. Mr Lutman Mr Lutman refused to come to Plaintiffs
home to conduct a home study. Mr Lutman ignored pictures of child neglect and abuse against the minor child.
Mr. Lutman has only appeared in one court hearing and has labled Plaintiff Robert Gipson as an unfit parent
who requires limited visitation with the minor child. Mr Lutman has conspired with James Johns to bring
slander against Plaintiff Robert Gipson. Mr Lutman has failed to review the case file of Plaintiffs and has acted
with unethical and bias opinions. Mr Lutmans lack of knowledge in trial preparation has been a disservice to
the minor child. His disregard to the health and welfare of the minor child has created a negative impact.
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28.. At all times relevant herein, Defendants violated agency policies, and regulations. They failed to
properly investigate and interview parties of interest and ignored Plaintiffs pleas to help the minor child Casey
Ryan Gipson. These policies, decisions officially adopted or promulgated by the State of Missouri were
Maliciously ignored. which acts may fairly be said to represent official policy or were pursuant to the
29. Relief is sought against each and every Defendant, jointly and severally, as well as their agents,
assistants, successors, employees, and persons acting in concert or cooperation with them, or at their direction
or under their supervision. Relief is also sought against insurance companies or company of any state
government agency mentioned in this law suit and any and all Townships, cities, Counties mentioned in this
claim. Also, any Defendants, government agencies or individuals not yet listed in this law suit that may have
29. At all times relevant herein, Defendants have acted under the color of authority of
30. In 2007, Brandy Wilkinson and Jason Warren did create a Porn site on MYSPACE. Attached
documents show a Porn site on MYSAPCE in 2007 and 2008 with blog entries and scheduled activities in 2008
and 2009.
31. Evidence was presented to the Benton County Sheriffs Department by Plaintiff Robert Gipson.
32. Evidence was presented to the Missouri Childrens Division along with a chain of evidence log in
33. In 2007, Jason Warren during a deposition testified that a web site was created and that this site
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was on MYSPACE and did exploit sex.
34. The Children’s Division ignored the complaints from Plaintiff of the various neglect and abuse
accusations, this immediately was a cause for alarm. Complaints exposing the minor child to the Porn Site was
made by the Plaintiff and other witnesses. The Missouri Department of Childrens Division jeapordized the
Health and Welfare of the minor child. This denied to the minor child and Plaintiff Robert Gipson the rights
and privileges guaranteed by the United States Constitution including, but not limited to, the right to be
protected, to be free of invasion of bodily integrity and to be free from being denied their rights under the equal
35. Defendants, Jim Harrison, and others from the Missouri Childrens Division, under color of
authority and in their capacity as agents of the State of Missouri, individually and collectively placed the Minor
child’s health in jeopardy by ignoring the legitimate complaints by Robert Gipson and witness Gina Swartz.
The Missouri Childrens Division Defendants purposely ignored the complaints by Robert Gipson Plaintiff and
in so doing further neglected the well being of the minor child and did perpetuate the exposure of the minor
36. Defendants failed to do a thorough investigation of the complaints made by plaintiff and witnesses
regarding the Porn site on MYSPACE. The Government agencies described as Defendants and the Individuals
described as Defendants neglected and exposed the minor child Casey Ryan Gipson to a world of Pornography.
This is both child neglect and child abuse. Defendants individually and acting in concert with one another
conspired to deprive plaintiff his natural birth right to protect his child Casey Ryan Gipson. Specifically, the
defendants did, individually and acting in concert with one another committed or participated in the following
acts:
a. Ignored or refused to properly investigate the allegations of child neglect and exposure of the
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b. Manufactured, or coerced, a court hearing to protect the mother from any criminal charges of
c. Defendants individually, collectively and all under color of authority, did use their positions to
maneuver against Plaintiff Robert Gipson to ignore crucial evidence which would have protected
the minor child from this Porn Site and other acts of physical and mental neglect..
d. .As of June 2009, the child’s picture and this MYSPACE Porn Site did exist. As of July 4, 2009,
e. Ignored or refused to properly investigate the allegations of child neglect as indicated in the
f. Defendants violated their duties and ignored obvious signs of neglect and abuse against the
g. Defendants for over six years have failed to protect the minor child.
h. Defendants from the Missouri Childrens Division for over six years have protected Brandy
I. Defendants from the Children’s Division have a child in dire need of their protection from a high
risk environment.
37. Plaintiffs restate and re-allege all allegations contained in the above captions and paragraphs of
38. Plaintiffs cause of action against the above named defendants for the failure to investigate, and
Denial of the substantive due process rights of Casey Gipson and the right to be protected, all of which
is a denial of his due process rights under the Fourteenth Amendment. Moreover, the minor child is in eminent
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danger due to the intentional misconduct of the defendant’s.
39. Defendants’ actions, as stated above, were reckless and outrageous and
subjected Plaintiff to loss of consortium with his child, damage to his business and personal reputations.
40. The acts of defendants under this count were under the color of state and federal law.
42 U.S.C. §1988.
WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount
that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for
punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable
attorney fees; and such other relief as may be granted by the Court.
42. Plaintiffs, for Count One of their complaint, incorporate by reference paragraphs and evidence
43. This Count constitutes the claims of Plaintiffs with respect to all Defendants. Defendants acted
in concert against Plaintiff Robert Gipson to deprive him of his Civil Rights to protect his child Casey Ryan
Gipson.
44. Defendants used the power and prestige of their positions to investigate and discredit plaintiff
subjected Plaintiffs to loss of consortium with his child and personal reputations.
46. The acts of defendants under this count were under the color of state law.
42 U.S.C. §1988.
WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount
that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for
punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable
attorney fees; and such other relief as may be granted by the Court.
48. Plaintiff, for Count Four of his complaint, incorporate by reference paragraphs and by evidence
49. This Count constitutes the claims of Plaintiffs with respect to all Defendants.
50. Plaintiffs are father and son and Father Robert Gipson, prior to the acts of Defendants enjoyed a
close loving relationship with his son Casey Gipson who had joint physical custody. This permitted the .
Plaintiffs to have and maintain a close loving relationship and for father to protect son regarding his medical
needs and regarding his son’s exposure to domestic violence in the home of his Mother.
50. Each of the Plaintiffs had and enjoyed a close, loving and constitutionally protected relationship
51. Defendants were aware of the close relationship between the Plaintiffs and knew that only by
manufactured and dissemination of false, spurious and incendiary allegations could this relationship be severed
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in open court as Plaintiff Robert Gipson had joint custody and presumed by Missouri law RSMO.452.375 et
sec.. Defendants were aware of the nature, extent, closeness and constitutionally protected nature of Plaintiffs
relationship. Defendants’ actions were an intentional interference with the familial relationship and the
52. Defendants have no reasonable justification for their actions to interfere with the relationship and
plaintiffs’ expectation that it would continue unmolested. The means used to interfere with the relationship was
an unlawful and wrongful interference with plaintiff's constitutionally protected relationship. Such actions were
55. Defendants used threats of criminal charges, defamatory information, misrepresentation of facts,
and abuse of the Court process to interfere with the Plaintiffs’ constitutional protected relationship.
56. Defendants’ actions, as stated above, were reckless and outrageous and subjected Plaintiffs to
57. The derogatory and unfounded statements of Defendants caused Plaintiffs the loss of their
Punitive damages under Missouri Common Law for tortuous interference with their constitutionally protected
relationship. Plaintiff seeks relief in not being required to pay any fees for any lawyer hired by any defendant. It
was and continues to be the actions of said Defendants that so viciously created such hardship against Plaintiffs.
WHEREFORE, Plaintiffs pray judgment against Defendants for compensatory damages in an amount
that will justly compensate Plaintiffs for economic and non-economic damages in excess of $900,000.00; for
punitive damages in such amounts as justice requires; for Plaintiffs’ costs of this action, including reasonable
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attorney fees; and such other relief as may be granted by the Court. Plaintiffs reserve the right to use this
information in any future law suits in this court against any additional Defendants or government agencies.
Plaintiff Robert Gipson speaking for Plaintiff Casey Ryan Gipson states that the minor child Casey Ryan
Gipson be allowed full consideration to file any future law suit. Plaintiff Robert Gipson states that there may
become a time in the future when the minor becomes of age to file a civil suit against the Defendants listed or
the government agencies listed for their failure to protect him when at such a young age. When Casey Ryan
Gipson gets older he reserves the right to file suit if his present physical and or mental medical issues become
more severe or permanent. The Plaintiffs reserve the right to amend any part of this claim to include adding
additional Defendants and government agencies and third party witnesses. Plaintiffs reserve the right to address
and report additional significant events relevant to the claim in this law suit. Plaintiffs reserve the right to
amend, add, delete or quash any summery judgment against said claim. Also to bring forth motions, pleadings
and civil suit to be combined with the present claim being sought. Plaintiff’s state that the severity of the
atrocities brought against them could require additional amendments. Plaintiff Robert Gipson states that the
mental anguish caused by the Defendants and government agencies has caused PTSD. Plaintiff Robert Gipson
states that seven year aggressive and all out assault against his family, has and could forever devastate his future
life. Plaintiffs Bank account has been garnished. Funds that were exempt from garnishment were frauduantly
obtained by James Johns, Brandy Wilkenson’s lawyer. The second garnishment was executed with out any
court order. Bank of America allowed this transaction. Plaintiff was injured in Iraq. His Social Security
Disability check was re routed to Brandy Wilkenson without Plaintiffs knowledge. Brandy Wilkenosn with the
help from Mr Brown and staff workers from the Sedalia Missouri Social Security Office conspired to make
Brany Wilkenson the payee of Plaintiffs Disability check. Plaintiff was injured in Iraq and receives money for
his injuiries. Brandy Wilkenson and her lawyer James Johns have conspired to bring false accusations against
Plaintiff in order to obtain Plaintiffs money that was once used to support his child. Prior to such garnishment
of Plaintiffs money from his Social Security, Plaintiff provided financial support for the minor child in excess of
the money now being paid out. Garnishment was just another reason for Brandy Wilkenson to file false
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accusations against Plaintiff and file to modify the previous court orders. The garnishment of the Plaintiffs
SSI, and savings account was nothing short of a criminal crime. Plaintiff asks relief in the following.
1. Plaintiffs Gipson and minor child Casey Ryan Gipson be given consideration for a thorough and
2. A Congressional Investigation into the work ethics of the Defendants listed in the above caption and
4. That this court put Defendants on Notice immediately and shorten their time to respond.
5. That this court considers this an emergency case and take actions to protect the minor child by taking
over jurisdiction and review all previous court hearings, transcripts, pleadings, motions, pictures, CD,
video, judges notes, all evidence submitted and or not submitted to any party, all supporting documents
of any kind legal or not legal, any and all information that is in the best interest of the minor child’s
health and welfare, all medical documents pertaining to the minor child, all audio calls made to the
Missouri children’s Hotline and all calls from Plaintiff Robert Gipson to the Benton County 9/11
Emergency Services.
6. Plaintiff reserves the right to amend this Complaint in order to present more evidence and add additional
7. Plaintiff request that the court allow a place in the court house annex for all depositions and provide a
8. Plaintiff asks for financial relief in filing this complaint and states that the actions of the Defendants
have caused a financial nightmare for the last seven years against the Plaintiffs.
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9. This Federal law suit is the direct result of the Defendants Malicious attacks on the Plainiffs.
10. Plaintiffs have suffered and have endured excessive mental anguish as a result of the actions and non
actions of Defendants.
11. Plaintiff Robert Gipson, father of Casey Ryan Gipson has gone through extensive mental therapy as a
direct result of Defendants failure to protect the minor child from neglect and abuse.
12. The Department of Veterans Affairs Psychologist and Civilian Psychologists have documented
testimony from Plaintiff Robert Gipson on the abuse and neglect against the minor child Casey Ryan
13. The Defendants and Government agencies listed have violated their oath of office and have Maliciously
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SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS
B. Letter from Attorney Kathleen Shaul, letter dated April 13, 2004.
C. Letter from Attorney Rebecca Hain, dated June 3, 2004 to Childrens Division
E. Letter to Dawn Long case worker, Warsaw Missouri, Benton County, dated Aug 3, 2004
F. Police reports from Plaintiff Robert Gipson dated October 23, 2005
G. Police report dated October 25, 2005 from Shirley Kaiser, neighbor of Plaintiff
M. Psychologist Erika Waller interview with minor child Casey Gipson dated July 7, 2007
R. Plaintiffs letter dated May 28, 2008 to Dr Julie Cahill, Dr Robert Frederickson, Dr Stanley Wilson and Dr
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Jeffrey Sharp of the Family Medicine Associates and Family doctors who have treated and observed Casey
Ryan Gipson.
. Jan 4, 2009. The minor child stopped breathing for approximately ten seconds and was taken to Kansas City
Childrens Mercy Hospital. Plaintiff Robert Gipson took his child to the Emergency room after observing him
with Sleep Apnea for two consecutive nights and after observing the child with a bloody nose at the Kansas
City Museum. The doctor’s report indicated a URI Upper Respiratory Infection.
U. Doctor report Dated Dec 23, 2008, Child is 3 1/2 Father of Casey Gipson has observed mild to severe
Sleep Apnea as the child sleeps. Father has observed the child since 2004 with OSA Obstructive Sleep Apnea
and congestion.
17 Nov 17, 2006, Obstruction and 100.3 temp. Jan 10, 2005, child has coughed.
W. Plaintiffs Service Records. Proof of service. DDF 214 and Iraq tour of duty.
X. Plaintiffs Diary while in Iraq starting in March 2003 and ending Dec 27, 2003
Y.
Z.
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SUPPLEMENTAL EVIDENCE AND EXHIBITS PROVIDED AS ATTACHMENTS
. MYSPACE PORN SITE of Brandy Wilkenson dated August 15, 2008 as Exhibit #1 presented by Robert
Gipson and witness dated on Feb 14, 2009. Presented as evidence on June 2009 in a hearing held in Benton
County Missouri with Honorable Judge Michael Hendrickson presiding. Consisting of twelve pages.
. MYSPACE PORN SITE, Exhibit #2, dated 2008. Eleven pages starting with Page 2 of 5 and last page 8 of 8.
MYSPACE PICTURES
A. The Picture on page# 1 of Exhibit #1 was copied by Robert Gipson on Feb 14, 2009. Sworn statement
identifies the same. Page number two dated Aug 15, 2008 shows the communication and web site
B. Page number three dated Feb 17, 2009 shows a picture of Brandy Wilkenson. Bottom right is a typed
biography that Brandy Wilkenson wrote about herself. This biography is enlarged on the last page of
exhibit #1. This biography indicates the high risk environment that the minor child is subjected to.
C. Page #4, shows more sexual content, dated Feb 17, 2009. Prior to Feb 17, 2009, Brandy Wilkenson
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D. Page #5, dated Aug 15, 2008, shows the communication between Brandy Wilkenson and her friends.
The first and last blog identifies how Brandy Wilkenson hates being married and promoting her parties. .
E. Page #7 is an enlarged picture printed on Feb 14, 2009 by Plaintiff Robert Gipson
F. Page #8 is a live video of a women having sex with a dildo. This can be viewed by children as Brandy
Wilkenson’s web site is not restricted and allows anyone of any age to view the explicit sex acts and the
G. Page #9, dated Feb 17, 2009, shows the picture of the minor child Casey Gipson. Plaintiff request relief
from this court to have this picture removed and this web site restricted. Children should not have their
H. A chain of custody document presented to the Benton County Sherriff’s Department is attached in
binder #1. Binder number #1, also has part one of Plaintiffs complaint.
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MYSPACE EXHIBIT
#2
K. Dated Aug 15, 2008, shows the flow of traffic coming to the web site and Brandy Wilkinson’s
MYSPACE EXHIBIT
#3
Exhibit #3 shows the schedule of Brandy Wilkinson’s nightly activities when she was a sex coach and
exploiting sex. These schedules and the reckless life of Brandy Wilkenson subjected the minor child to a high
risk environment. The minor child was left with Jason Warren during these late night parties and in one
incident the minor child was locked outside his house and burned his hand on a stick from a fire with Jason
Warren present. The minor child informed Plaintiff that his ears were cold and there were no keys to get into the
house and his mommy was gone. . Plaintiff has been alienated from his child and can no longer protect his
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PICTURES OF CASEY RYAN GIPSON WHICH DISPLAY ABNORMAL AND EXCESSIVE
15. Pictures were taken by Robert Gipson in Warsaw Missouri Benton County. Taken on or about Easter
2004. Taken at the Bunk House Lodge on HWY 65. Child was age two when these pictures were taken.
Pictures show a bruised head and nose. Exhibit consists of four pictures.
16. Pictures take by Robert Gipson in Lexington Kentucky on or about Dec 2005. Pictures show a burned
right arm. Plaintiff also observed the child with congestion and wet hair in this same picture. Exhibit
17. Summer of 2008 pictures. Eleven pictures taken by Plaintiff Robert Gipson and developed Sept 2008.
Excessive bug bites on the child’s back, arm pit, legs, ear, buttocks, legs, rectum and inner thighs. poison
18. CD with pictures of the minor child Casey Ryan Gipson. These pictures were also presented to the
Missouri Childrens Division as was a video showing the child in mild to severe Sleep Apnea and other
19. Pictures taken by the Benton County Sherriffs Department. Beverly Chapman never prepared a report
on this burn. The minor child was burned by a cigarette on his right ear. Different stories were told on how
he got the burn. Days prior to this burn the child was taken to the emergency room by Plaintiff Robert
Gipson. The doctor at the Sedalia emergency room stated that Casey had Tonsil Idous. In her report, she
stated that the child is to stay away from smoke. She capiti;ized the word smoke in her report. Plaintiff
gave this report to Defendant Brandy Wilkenson. Days later the child was observed with a cigarette burn on
his ear. Brandy Wilkenson sated that Melissa burned Casey and Beverly Chapman stated that the
grandmother burned Casey. Plaintiff requested a copy of the police report and the Sherriff sated that they
had no report. A doctor at Dr Cahills office who is a mandated reporter failed to also make a report. By law
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any burn is to be reported to the authorities. None prepared any report and this was now the second burn
and numerous other neglect and abuse reports by Plaintiff and other concerned citizens.
20. Twenty nine pictures of Casey Gipson. High risk environment and poor health conditions.
21. . Deposition of Jason warren on July 27, 2009. Page #16, covers MYSPACE web site and issues of
Brandy Wilkenson being a sex coach. In June 2009, Defendant Brandy Wilkesnon stated that she does not
monitor the web site. She is the administrator and she is the one who markets and organizes her pictures
and video Page 17, Question 18 and answers 24 is nothing further from the truth. Brandy Wilkenson and
Jason Warren have for years violated the civil rights of Plaintiffs. They will stop at nothing to achieve their
goals. Brandy Wilkenson tried to stop Plaintiff Robert Gipson from having his name put on the child’s birth
certificate. She refused to tell the New York Division of Social Services who the childs father was. Brandy
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STATEMENTS FROM PLAINTIFF ROBERT GIPSON
18. Plaintiff has video of the minor child from 2004 to Jan 2009 showing the child with mild to severe Sleep
Apnea, coughing, wet hair, excessive bug bites and skin poison.
19. The minor child was burned by an oven door, burned by a cigarette, burned by an open fire.
20. On July 4, 2009 the minor child was observed by Robert Gipson with a burn mark on his neck.
21. Plaintiff states that he has never seen the minor child sleep with out having mild or severe sleep apnea and
or congestion.
22. On July 5, 2009 Plaintiff observed Casey Gipson coughing at Wal-Mart in Warsaw Missouri. Plaintiff has
observed this type of cough and congestion since 2004. On Jan 4, 2009 Plaintiff took his child to the
emergency room. The minor child experinaced Sleep Apnea and Upper Respiratory Congestion.
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CERTIFICATE OF SERVICE
A copy of the foregoing was presented in person to: Clerk of the United States District
Court Western District of Missouri Central Division on this ______ day of______2009.
Respectfully submitted,
_____________________
Robert Gipson
___________________
Robert Gipson
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