Professional Documents
Culture Documents
09-4136-CV-C-NKL Complaint Part 2 of 2
09-4136-CV-C-NKL Complaint Part 2 of 2
ROPERT GIPSON, )
Individually )
)
and )
)
ROBERT GIPSON, ) CASE # 09-4136-CV-C- NKL
as Next Friend of )
Casey Gipson, a minor child )
)
Plaintiffs, )
)
vs. )
)
SENATOR CLAIRE MCCASKILL )
UNITED STATES SENATOR FOR )
MISSOURI, in her official and individual
capacity, AND
1
MISSOURI STATE REP. )
BRIAN NIEVES, )
)
ATTORNEY GENERAL FOR )
STATE OF MISSOURI )
KRISTOPHER KOSTER, )
)
BENTON COUNTY PROSECUTING )
ATTORNEY KAREN WOODLEY,
AND OTHERS
)
BENTON COUNTY CIRCUIT CLERK )
CHERYL SCHULTZ,
AND OTHERS )
)
POLICE CHIEF CARLISLE S. )
WALKER OF THE )
COLE CAMP POLICE DEPT., )
AND OTHERS )
2
BENTON COUNTY SHERIFF )
RICK FAJEN, )
AND OTHERS
)
POLICE CHIEF )
MICKEY MITTLESTADT OF THE )
LINCOLN POLICE DEPT.,
AND OTHERS
)
FORMER POLICE CHIEF )
KINKINNON OF THE )
LINCOLN POLICE DEPT.
AND OTHERS )
)
STATE OF MISSOURI DIRECTOR )
OF FAMILY SERVICES )
RONALD LEVY, )
)
FORMER STATE OF MISSOURI )
DIRECTOR OF FAMILY SERVICES )
DEBORAH E. SCOTT, )
)
STATE OF MISSOURI )
DIRECTOR OF CHILDREN’S DIV. )
OF SOCIAL SERVICES )
JAMES HARRISON )
)
DESIGNATED PRINCIPAL OF )
SOCIAL SERVICES )
CELESTA SUE HARTGRAVES )
)
BENTON COUNTY CASE WORKER )
DAWN LONG )
)
BENTON COUNTY CASE WORKER )
BEVERLY CHAPMAN )
)
BENTON COUNTY CASE WORKER )
PAULA WOOLERY )
)
BENTON COUNTY SUPERVISING )
CASE WORKER ALICE SHARON )
ZIDLICKY )
)
MISSOURI CHILD ADVOCATE )
3
STEVE MORROW )
)
MR. BROWN OF THE UNITED )
STATES SOCIAL SECURITY OFFICE )
SEDALIA MISSOURI, )
)
DEPUTY HAUN OF THE BENTON )
COUNTY SHERIFF DEPT. )
)
WILLIAM HAEFER; )
Circuit Manager, )
Benton County Children’s Division; )
Supervisor for Benton County )
Children’s Division; )
)
BEVERLEY CHAPMAN, )
Case/Social Worker for Benton )
County Children’s Division; )
)
JAMES JOHNS, ATTORNEY FOR )
BRANDY WILKENSON WARREN, )
)
BRANDY WILKENSON WARREN )
MOTHER OF CASEY GIPSON, )
)
ATTORNEY JAMES RICE,
FORMER ATTORNEY FOR
BRANDY WILKENSON WARREN )
4
DR. JULIE CAHILL,
Tim Vuagniaux
SEDALIA MISSOURI
AND OTHERS
BANK OF AMERICA,
AND OTHERS
CHERYL PETERSEN
Principal Little Blue Bird School
AND OTHERS
LISA WILLOUGHBY
PRE-SCHOOL TEACHER
LITTLE BLUE BIRD SCHOOL
MS JANE DOE
PRE-SCHOOL TEACHER
LITTLE BLUE BIRD SCHOOL
PAMELA PILANT
KINDERGARTEN TEACHER
LITTLE BLUE BIRD SCHOOL
Defendants.
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COMPLAINT
PART#2
COMES NOW, Robert Gipson, pro se, and for his cause of action for the wrongful
taking and unlawful deprivation of Plaintiff’s rights to parent his minor child, and for the
minor child’s right to be in the custody of his father, against the above named defendants,
and for his unlawful detention, arrest and incarceration by actions of government
employees Plaintiffs mental health and well being has been affected by government
workers to the extend Plaintiff has PTSD from being alienated from his child. Plaintiff
states the following: Suit is being brought against all Defendants in their official capacity
and individual capacity. Plaintiff states that qualified immunity does not exist here for
government workers nor does any other immunity. Defendants violated Plaintiffs Civil
Rights at various times from 2002 to most recent in 2009. Government workers
mentioned maliciously and with malice and while under the color of law, restricted
Plaintiffs having their freedom and right to happiness. Malicious Prosecution and
Malicious Arrest have caused enormous harm against Plaintiff Robert Gipson. For over
six years the unjustifiable and unreasonable excessive civil and criminal litigation against
Plaintiff Robert Gipson has caused in the excess of $250,000 dollars. Some Defendants
listed were often under government contract and violated state and federal laws by
bringing fraud upon the court, perverting the course of justice and violating the civil
rights of the Plaintiffs. Some Defendants listed were mandated reporters and purposely
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neglected to report neglect and abuse that was reported by the minor child Casey Ryan
Some Defendants listed knowingly conspired with each other to prosper politically and
financially at the expense of the minor child. Some Defendants listed abused their
judicial powers to oppress Plaintiffs. Some Defendants listed knowingly that a crime had
occurred and had the Authority to act failed to do so. Some Defendants listed tampered
with evidence and obstructed justice. Some Defendants listed knowingly perverted the
course of justice by forging signatures on official court records. Some Defendants listed
slandered Plaintiffs and created excessive litigation in order to embezzle money and
Garnished Plaintiffs bank account. The funds Garnished were Exempt and executed
without a court judgment. Bank of America conspired with James Johns, attorney for
Wilkenson, James Johns and members from the Missouri Children’s Division conspired
and succeeded in garnishing Plaintiffs Social Security Disability Benefits. Defendant Mr.
Brown from the Sedalia Missouri Social Security Office allowed Brandy Wilkenson to
become the Payee for the money for Plaintiffs child without notifying Plaintiff. Plaintiff
received money for his wounds which occurred in Iraq during his tour in 2003-2004.
Once again in July 2009 Defendant Brandy Wilkenson and her lawyer, James Johns are
attempting to embezzle money from Plaintiff and have accused Plaintiff of conducting a
home Sleep Study and medical testing on his minor child Casey Gipson. Defendants
have orchestrated yet another desperate approach to alienate the minor child from his
father. Defendant Brandy Wilkenson will never stop until she completely and with
malice destroys the bond between Plaintiffs Robert Gipson and son Casey Gipson.
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Unfounded court orders to restrict the Plaintiffs to the present visitation of five hours
every other Saturday and Sunday has caused and will continue to destruct the family
unity. Police officers from Lincoln Missouri, Cole Camp Missouri and Benton County
Sherriffs office and case workers from the Missouri Children’s Division, conspired to
bring physical and mental harm to plaintiffs. Plaintiff has been subjected to numerous
interviews by police officers and case workers. The minor child has been subjected to
safe house interviews as the direct result of the Defendant Brandy Wilkenson making
false accusations that the Plaintiff Robert Gipson sexually molested his child Casey
Gipson. The Missouri Children’s Division case workers did video these interviews and
refuse to release the video to the Plaintiff even after Plaintiff has requested so in writing
to Ron Levy the Director of the Missouri Family Services and Jim Harrison the former
director of the Missouri Children’s Division. Medical Doctors and Psychologists failed
to inform the court and Authorities about the adverse medical conditions which have
stressed the minor child Casey Ryan Gipson. Psychologist and Psychiatrist who are
mandated reporters failed to report when the minor child Casey Ryan Gipson stated to
them that he was hit in the face by his mother Brandy Wilkenson. Psychologist failed to
protect the minor child when his father and Plaintiff Robert Gipson presented written
reports and documentation of neglect and abuse against the minor child by his mother
Brandy Wilkenson and his step father Jason Warren. Psychologist conspired with case
workers and to gain government contracts and favored case workers from the Missouri
personal information about Plaintiff Robert Gipson without consent from Plaintiff.
Psychologist ignored witness statements from Plaintiff Robert Gipson about neglect and
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abuse against the minor child Casey Ryan Gipson. Directors from the Missouri Family
Services and the Missouri Children’s Division ignored and failed to properly investigate
written complaints and Hot Line reports about the neglect and abuse against Plaintiffs
Robert Gipson and Casey Gipson. Video, pictures and CD which showed neglect and
abuse against the child Casey Ryan Gipson was ignored by the Missouri Department of
Family Services which showed the minor child having severe medical problems with
Sleep Apnea, Burn Marks, Excessive bug bites, bruises and Obstructive airway. Reports
of loaded guns, and a home environment that endangered the minor child were ignored
by case workers from the Missouri Children’s Division. Case workers investigated over
fifteen legitimate reports from the Plaintiff Robert Gipson and also third party reports.
These reports reflect back to the first oven burn which the child received when he was a
baby. Reports sinse 2003 to 2009 have been poorly investigated and found to be Un-
substantiated time after time. The Investigations conducted were done so in a Haphazard
and careless process. The minor child was observed with obvious bruises, cuts, excessive
bug bites, smashed face, burnt arm, burnt ear by a cigarette. Reports of the child
observing his mother getting beat by her husband Jason Warren were ignored by case
workers and school principal Ms Peterson of the Cole Camp Elementary in Cole Camp
Missouri. Head wounds received by the child were ignored by school teachers. The
minor child was struck in the head by the rocks which came from an automobile that
caused the wounds. Police reports, witness statements, video, pictures, CD and court
testimony was presented as evidence and ignored by court judges, case workers, police,
psychologist, doctors, lawyers, school teachers, school principal and church pastors.
Third party witnesses were ignored when they reported by Hot Line calls and written
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statements to the Missouri Children’s Division and state officials of the neglect and abuse
against the minor child Casey Ryan Gipson. Witness statements presented in court in
person and in writing were ignored by judges. Judge Larry Burdett and Judge Michael
Hendrickson’s Final Judgments and court rulings were unfounded. Their rulings were
unsubstantiated and with out merit. Their rulings were Bias against the Plaintiffs Robert
evidence to justify their rulings to modify and court judgments from 2005 to 2009. The
Plaintiffs rights to due process was violated severely Judge Larry Burdett and Judge
Michael Hendrickson allowed their court to be ruled by Brandy Wilkenson and her two
lawyers James Johns and Jim Rice. Case workers manipulated the court proceedings by
bringing fraud upon the court. Excessive litigation has caused Plaintiff Robert Gipson to
lose over $250, 000, 00 dollars and has caused mental anguish that has affected every
fiber of Plaintiffs life. Court orders and rulings by judge Burdett and Judge Michael
Hendrickson have severed the bond between father and son. Judge Burdett and judge
Hendrickson both have failed to up hold their oath of office and have failed to protect the
Constitutional Rights of Plaintiffs. Both judges allowed expert witnesses to get away
with bringing fraud upon the court and perverting the course of justice. Both judges
prevented Plaintiff Robert Gipson from presenting his motions and restricted Plaintiff
from presenting evidence that would be in the best interest of the minor child. Judge
Burdett and Judge Michael Hendrickson violated the Plaintiffs fourth amendment and
created an atmosphere of injustice in their court room. Judge Burdett held court hearings
with out the knowledge of Plaintiff. This allowed Brandy Wilkenson and her lawyer
James Rice favor in their case against Plaintiff Robert Gipson. Judge Burdett along with
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his clerk of court ignored Plaintiffs request to have his motions heard. The Clerk failed
to give Plaintiff court dates as requested in Plaintiffs motion. It was not until time was up
that Plaintiff was given dates and it was at that time that the Benton County clerk stated
to Plaintiff that she does not read my motions. Plaintiff’s motions requested that the
Clerk provide a time to be heard. Judge Burdett informed the Benton County Clerk, Ms
Schultz not to send Plaintiff a copy of the Final judgment even after Plaintiff put the court
on notice that he was now a Pro-se litigant. Judge Burdett ignored Plaintiffs motion to
request that Jim Rice return Plaintiffs exhibits that were taken from the bench. Plaintiff
first entered pleadings in the Benton County court house in 2003. There has been nothing
but injustice and conspiracy to drain the pockets of Plaintiff through excessive litigation
Some Defendants listed conspired with Brandy Wilkenson Warren and Jason Warren to
bring false accusations of sexual abuse against Plaintiff Robert Gipson. Conspiracy to
bring a Child Protection Order, exparte hearings, child endangerment hearings, false
arrest reports, false contempt actions, false criminal reports, physical threats, threats
against Plaintiffs finances, threats against Plaintiffs home and alienating the minor child
from Plaintiff Robert Gipson. The actions of Defendants have crippled the relationship
between the father, Robert Gipson and his biological son Casey Ryan Gipson. These
atrocities will forever burden the family foundation that was once enjoyed by a loving
father and his precious seven year old child. The destruction and devastation brought
11
against Plaintiffs may be irreversible and may cause a lasting affect of mental disorders
upon Paintiffs.
particularly the Fourteenth Amendment; the laws of the United States, particularly 42
2. This Court has federal jurisdiction under 28 U.S.C §§ 1331 and 1343 (a).
Hence, venue is proper within the Western District, Central Division under 28 U.S.C. §
1391 (b).
PARTIES
6. 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
12
DEFENDANTS
7. Defendants Senator Claire McCaskill and Senator Kit Bonds, were and still are
the United States Senators for Missouri and was in such position at all times relevant to
this lawsuit. Plaintiff Robert Gipson did on or about August 2007, flew to Washington
D.C. to visit the office of Senator McCaskill. Plaintiff presented documents that clearly
showed neglect and abuse against the minor child Casey Ryan Gipson. Plaintiff
presented documents to the secretary of Senator McCaskill and Senator Kit Bond that
showed probable cause to investigate the accusations made by Plaintiff against the
Defendants of the Missouri Family Services and the Missouri Children’s Division.
Senator Claire McCaskill, Senator Kit Bond and their staff failed to investigate Plaintiffs
complaints and therefore subjected the minor child to further neglect and abuse. Plaintiff
Robert Gipson has endured on going attacks by government workers in the Missouri
Children’s Division and the local police departments. These Malicious attacks resulted in
false arrest and false accusations of child endangerment against Robert Gipson father of
child Casey Gipson. Other reports by third party witnesses were also ignored by Senator
At all times relevant herein, Defendants Senator Claire McCaskill, Senator Kit
Bond, and their administrative staff failed to report the neglect and abuse against the
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minor child Casey Ryan Gipson and failed to conduct a Congressional Investigation as
requested by Plaintiff Robert Gipson. Their failure to protect Casey Gipson has resulted
in further neglect and abuse by Defendant Brandy Wilkenson and others who have
conspired to do the same. As of this date July 4, 2009, Casey Gipson was observed by
Robert Gipson with a burn on the right side of his neck and observed the minor child
coughing at Wal-Mart. Plaintiff Robert Gipson Father of Casey Ryan Gipson has
observed the minor child with mild to severe Sleep Apnea and Obstructive Airway since
returning from Iraq in 2004. Complaints to Senator McCaskill and her administration
have fallen on deaf ears and it was and is in their jurisdiction to act in order to protect the
children of Missouri. When malicious criminal acts have been levied against such an
innocent child it is the duties of our elected officials to act. Senator Claire McCaskill and
Senator Kit Bonds are mandated reporters. Failure to report and investigate is within
their jurisdiction. The atrocities brought against the minor child Casey Ryan Gipson and
his father Robert Gipson has been documented. Documents were hand delivered by
Plaintiff Robert Gipson and also by e-mail. Log entries from 2006 to 2009 clearly
showed probable cause to conduct an Investigation against the Missouri Family Services
Director Debra Scott and the Missouri Children’s Division Supervisors, case workers and
other principals who violated the civil rights of Plaintiffs. This government body has
jurisdiction to act and to protect the citizens of Missouri when they are attacked by their
own government. Further neglect to assist in the on going abusive power against
Plaintiffs by the Missouri agencies mentioned is a direct violation of the Oath of Office
signed and presented by Senator Claire McCaskill and Senator Kit Bond. The State of
Missouri and its Citizens deserve protection by its leaders and Plaintiffs Robert Gipson
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and Casey Gipson have yet to receive such protection.
8. Defendant, Former Governor for the State of Missouri, Matt Blunt and
his staff did receive in person and by e-mail documents and reports that clearly show
probable cause to investigate allegations of child neglect and abuse against Plaintiff
Casey Gipson. Accusations of Malicious intent to bring harm against Plaintiff Robert
Gipson were also reported to Matt Blunt and Jessica Windshield, Matt Blunts secretary
for Missouri constituents. Former governor Matt Blunt failed Plaintiffs by not acting in
accordance with his oath of office, Former governor Matt Blunt ignored the pleas from
Plaintiff Robert Gipson to investigate the crimes brought against him and his child Casey
conducted against the Missouri Family Services and the Missouri Children’s Division.
Plaintiff Robert Gipson was ignored by Matt Blunt and Jessica Windshield. The result of
Matt Blunts poor leadership resulted in the minor child Casey Ryan Gipson and his father
Robert Gipson to be maliciously attacked with criminal intent by case workers in the
Missouri Children’s Division. Jessica Windshield under the direct supervision of Matt
Blunt disregarded and lost important documents presented to them by third party
witnesses and Robert Gipson Plaintiff. During one visit to the former governor’s office,
Plaintiffs face as she sat behind her desk. There were three other people present. One
female sat to the left and behind Plaintiff and two males were at adjacent desks. Jessica
Windshield laughed as she degraded Plaintiff Robert Gipson by saying that she does not
have a file on the minor child Casey Ryan Gipson. Plaintiff Robert Gipson presented
15
Jessica Windshield with more documents and once again requested a scheduled meeting
with then Governor Matt Blunt. All requests were ignored and the files were once again
lost. Governor Matt Blunt and his administrative staff were involved in a law suit which
involved documents being shredded and lost. Plaintiffs Civil Rights were violated by
Matt Blunt and his staff. This government agency failed to protect the Plaintiffs and their
Un-ethical job performance violated the Plaintiffs Constitutional Rights. Plaintiffs Rights
conspired with Debra Scott and the Missouri Children’s Division. Her vicious Bias attack
against Plaintiffs and her attempt to tamper with evidence was and is a federal violation
by a state worker. Former Governor Matt Blunt was in position to act and failed to do so.
There was and continues to be great injustice against Plaintiffs. There was probable
cause for Matt Blunt, Jessica Windshield and the office staff to act. Severe mental
anguish and physical injuries are a direct result of this administrations failure to protect
Windshield and the Missouri Children’s Division was a direct result of no action taken to
protect the minor child from neglect and abuse. Plaintiff Robert Gipson questions if
Jessica Windshield attempted to schedule any meeting between Plaintiff Robert Gipson
or even presented the documents in question to then Governor Matt Blunt. Not once was
Plaintiff Robert Gipson contacted by Matt Blunt and at no time was a meeting scheduled.
At all times relevant herein, Defendants Matt Blunt and Jessica Windshield
violated office policies and regulations. Their acts may fairly be said to represent official
policy or were pursuant to the governmental custom of such a Government capacity, and
thereby the State of Missouri. Failure to protect the Constitutional Rights of a Citizen
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and when two or more conspire to bring harm against any person is a felony crime.
When executed by a Government Official this does not allow this official any immunity
and if convicted of such crime is subject to be incarcerated. If such crime causes long
term affect as with the Plaintiffs Casey Ryan Gipson and Robert Gipson, such retroactive
compensatory damages and punitive damages as deemed necessary in the court of law.
10. Defendant, Governor Jay Nixon was at all times relevant herein, the
Governor assigned Ron Levy as the Director of the Missouri 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 to same. Governor Nixon to
date has 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 has 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 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
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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
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
11. Defendant, At all times relevant herein, Defendant Kristopher Koster was
presented with evidence and statements that clearly showed neglect and abuse against the
minor child Casey Ryan Gipson. Plaintiff states that once again that this government
agency as have all the others mentioned above have failed to protect the Constitutional
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Rights of the Plaintiffs and have allowed criminal activities to take place under their tour
of duty. Plaintiff Robert Gipson in 2009 also visited the office of the Missouri Attorney
General Kristopher Koster. Plaintiff was told by the office staff that his complaint was
being investigated by a member of the Attorney Generals staff. Plaintiff was told this by a
White Male and a Dark Skin Female while standing in front of their desk. To date no one
from this agency has contacted Plaintiff. Plaintiff first contacted the Attorney Generals
Office in 2006 when Plaintiff was first accused of sexually molesting his precious child
Casey Ryan Gipson. Plaintiff also reported the criminal acts and community corruption
by the Lincoln Missouri, Cole Camp Missouri and Benton County Sheriffs Departments
against Plaintiffs.
was notified in 2006 after the first accusation that Plaintiff Robert Gipson first sexually
molested his minor child Casey Ryan Gipson. Plaintiff seeks relief through his local
reps and to date there has been no change. A meeting was held at Representatives Self
office with Plaintiff. Present was a lawyer representing the Missouri Family Services and
a lady who described herself as a principal from the Children’s Division here in Missouri.
Plaintiff Robert Gipson has made approximately 10-15 Hot Line calls to the Missouri
Child abuse Hot line. As indicated to Representative Tom Self during this meeting and
also by E-mails to his office administrator by the name of Peggy, neglect and abuse
continue to this day. Since the meeting with Tom Self, the minor child has been
neglected and abused by case workers who have assisted the mother of the minor child
Casey Gipson by helping her file false accusations that Plaintiff assaulted the mother and
step father Jason Warren. This conspiracy between the mother and case workers resulted
19
in an exparte hearing that was dismissed by a judge in Benton County Missouri in 2009.
This was just another attempt by the case workers to conspire and slander Plaintiff Robert
Gipson. Tom Self and his office administrator ignored Plaintiff Robert Gipson in 2006.
It was not until 2009 and after more false accusations and slander against Plaintiff did
Tom Self assist in setting up this meeting with the Missouri Family Services. By this
time Plaintiff lost his Constitutional Rights to be a father to his child Casey Ryan Gipson.
This witch hunt and malicious prosecution by case workers and the corruption in this
community and the injustice in the Benton County Court House devastated both
Plaintiffs. Tom Self lives in Cole Camp Missouri. The Cole Camp Police Department
has brought criminal intent against Plaintiff Robert Gipson. Such threats of arrest by
From Plaintiff, Robert Gipson. During Plaintiffs meeting with Tom Self, and
representatives from the Missouri Children’s Division, Senator Scott arrived with
Plaintiffs E-mail in hand. Plaintiff shared his concerns with the Senator about the neglect
Defendant, Jane Cunningham, Missouri State Senator was present during a special
commitee hearing in Nov 2008. During this hearing Plaintiff testified about the neglect
and abuse brought against his son Casey Gipson. Plaintiff testified in reference to the
Senator Cunningham assisted other individuals and families who are presently
in a court case where their civil rights were violated. Plaintiff requested assistance with
the same. Plaintiff testified about the METH lab at the Grand Parents house of the minor
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child and poor investigations by case workers from the Missouri Children’s Division.
Defendant, Brian Nieves, Missouri State Representative received E-mails from Plaintiff
Robert Gipson. Plaintiff shared his concerns about the contracts between the Missouri
Family Services and hired Lawyers and Psychologist who receive state and federal
funding for their services. There is a conflict of interest when lawyers and Psychologist
are hired by the state. There was and is a conflict of interest when Plaintiff Robert
Gipson attempted to discuss his child’s behavior with psychologist and these same
psychologist who contract with DFS/CPS turn and make the Plaintiff out to be a bad
father. Their Bias attack to favor case workers and to conspire to discredit the Plaintiff is
a direct result of money received by these psychologist from the Missouri Division of
They create a conflict of interest when they are paid for their services and then testify
was and is during the time of said claim in a supervisory position. Mark Breshears is a
party to this case, knowingly and had knowledge of issues in his jurisdiction. Command
and control is absent from his leadership and falls short of leading this community.
Having knowledge of alleged instances and failure to protect the citizens in his district is
dereliction of duty and his oath of office. Failure to supervise and communicate within
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14. Defendant, Honorable Judge Larry Burdett, former Benton County Judge is a
party to this action due to his judiciary duties as a sitting judge in numerous hearings on
counsel after she filed her false accusations and motion to modify the then existing 2005
judgment. Judge Burdett coached Brandy Wilkenson while she was on the witness
stand in order to gain favor over Plaintiff Robert Gipson. Judge Burdett refused to
dismiss the case as requested by Plaintiff due to the failure of Brandy Wilkenson to
present any kind of evidence. Brandy Wilkenson accused Plaintiff of various false
accusations and when scheduled for court she was unable to argue her case. Later Brandy
Wilkenson obtained counsel with James Johns and after nine months of excessive
litigation judge Burdett modified the shared parenting plan. James Johns and Brandy
Wilkenson are once again brought fraud upon the court by presenting false accusations.
The fruit of the forbidden tree has rooted itself. Brandy Wilkenson, James Johns and
Judge Burdett have brought fraud upon the court and often were in contempt. Judge
Burdett modified the order in favor of Brandy Wilkenson. Judge Burdett allowed Brandy
Wilkenson and her lawyer James Johns to rule the court and disregarded Robert Gipson’s
evidence. Judge Burdett was Bias against Robert Gipson and allowed favor for Brandy
Wilkenson. During the eight hour court hearing, Robert Gipson was restricted to
approximately one hour on the stand which included other witnesses for Robert Gipson.
Approximately seven hours was allowed for James Johns and Brandy Wilkenson. This
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allowed their hired expert witnesses to conspire and dominate the court leaving little
chance for justice to prevail. Judge Burdett and his clerk of court Sharron Schultz
restricted Plaintiffs rights to his case files and violated the Missouri Sunshine Law.
Plaintiff did put on notice to the Benton County court and judge Burdett “The Younger
Alert”. When Plaintiff Robert Gipson did finally get a chance to obtain his case file time
had ran out to file Plaintiffs appeal. The Western District Court of Appeals in Missouri
denied Plaintiffs request to file his LNOA Late Notice of Appeal. The Appeals court
clerk Mr. Lord made this decision on his own and signed his own legal document.
Plaintiff requested a reason for such denial and Mr. Lord stated on the phone to Plaintiff
“The child has settled.” Mr. Lord, in his capacity had no legal right to make such a
decision. It is now knowledge that Brandy Wilkenson’s attorney James Johns was once
the Clerk of Court at the same office as Mr. Lord. This is a conflict of interest. Plaintiff
has been forced into excessive custody litigation in Benton County since returning from
Iraq in Feb 2004. Plaintiff has lost his life savings and lost his Constitutional right to be a
father. Plaintiff fought in Iraq only to return to another war in family court. Judge
Burdett allowed case workers to sit beside the Plaintiff during court hearings. These court
hearings were staged. Case workers have for years used intimidation tactics to invade
Plaintiffs life. Judge Burdett’s reckless court rulings and his disregard for justice
The second garnishment was executed without a court order and the Benton County
Clerk of court Sheryl Schultz assisted James Johns in collecting Plaintiffs exempt funds.
The first Garnishment was created by a conspiracy. Brandy Wilkenson and case workers
from the Missouri Children’s Division knew that I was receiving Combat Disability
23
payments and V.A. disability payments. They took advantage by dragging Plaintiff back
into court in order to gain financially. Before the first accusation that Plaintiff sexually
molested his minor child, the court order was 50-50 shared equal and physical custody.
Neither parent was ordered to pay child support. After the first accusation and seven
more to follow, Plaintiff was forced to become the non-custodial parent with limited
visitation. Forced supervised visitation by judge Burdett with the mother Brandy
Wilkenson as the supervisor was ordered by judge Burdett. Presently and after five years
of false accusations and excessive litigation, Plaintiff is going broke and with existing
threats of more garnishments and threats of losing his home and lively hood. Presently as
subjected to only five hours of visitation every other Saturday and Sunday. Phone calls
have been restricted. Plaintiffs Robert Gipson and his son Casey Gipson have often gone
without any phone contact the longest being seven days. Plaintiff Robert Gipson put the
court on notice that he was a Pro-se litigant and for the court to inform Plaintiff of all
court issues. Plaintiff was informed by Sheryl Schultz the Benton County Court Clerk
that Judge Burdett informed her not to send the 2005 judgment to Plaintiff. Once again,
Plaintiff was denied his fourth amendment. Often judge Burdett’s rulings were un-
the existing 2005, joint parenting plan and custody order. After the 50-50 parenting plan
was modified, Brandy Wilkenson once again brought false allegations against Plaintiff.
Once again the Benton County court has assisted the mother Brandy Wilkenson to gain
power and control and has forced the Plaintiffs to endure the pain of being alienated and
separated from each other. Judge Larry Burdett has violated his oath of office and
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brought fraud upon the court and the United States Judiciary. Judge Burdett allowed
James Johns, Brandy Wilkensons former lawyer in 2005, to bring sanctions against
Plaintiff even though Plaintiff responded to all discovery requests. Judge Larry Burdett
allowed James Johns to remove exhibits from the bench. These exhibits were presented
by the Plaintiff Robert Gipson. During a supervised four hour visit, Plaintiff was at the
local Warsaw Missouri Park. Only one hour into the visit the GAL Mr. Stewart allowed
Brandy Wilkenson to remove the minor child from the Park. Judge Burdett refused to
charge Brandy Wilkenson or the GAL with contempt. Ms Haines, Plaintiffs lawyer was
present and did nothing. Plaintiffs have endured enough pain and seek relief from a
higher court.
15. Defendant, Honorable Judge Mark Pilley was once Plaintiffs former Attorney.
Plaintiff recused judge Pilley due to a conflict of interest when Plaintiff found out that
judge Pilley would preside over a criminal case in Benton County Missouri which was
filed by Defendant Brandy Wilkenson. When judge Pilley was Plaintiffs Attorney, he
attempted to use the minor child Casey Gipson as a plea bargaining tool as he conspired
with Karen Woodley the Benton County Prosecuting Attorney. Judge Pilley stated to
Robert Gipson Plaintiff “If you go along with the present custody issue I think I can get
Woodley to drop the assault charges” Judge Pilley wanted me to plead guilty to an assault
parenting classes and receive a two year probation. I refused and the case was dismissed
in a criminal trial. Brandy Wilkenson once again with her blatant diabolical lies framed
Plaintiff with false accusations to get custody of the minor child. This was nothing more
25
than yet another way to file charges against Plaintiff at the same time the civil case for
custody was pending. Judge Pilley and Karen Woodley obstructed justice by forcing
Plaintiff to wait more than six months for his case to be heard. Plaintiff’s fourteenth
amendment was violated. Both attempted to use the criminal case against me as the civil
custody case was pending. Presently there is yet another criminal case pending against
Plaintiff Robert Gipson. Once again Brandy Wilkenson, Karen Woodley and the Benton
County Sherriff Department are attempting to file charges against Plaintiff for child
endangerment. This was nothing more than another staged event created by Brandy
Wilkenson. Brandy Wilkenson called the Benton County Sherriff’s Department and
requested that five police officers be present during the exchange with the minor child.
Brandy Wilkenson gets what she wants when she wants it.
On April 26, 2009, Plaintiff was arrested for child endangerment. The incident was on
video and clearly showed that Casey Gipson was never in any danger. If the child was in
danger then why was it that the Plaintiff Robert Gipson was not arrested on site? The
children’s division was called and the incident was Un-substantiated. Plaintiff spent one
night in jail and was harassed all night by four bailiffs. Plaintiff arrived in court on June
2, 2009 to plead not guilty. Plaintiffs name was not on the docket nor did Karen
Woodley or any of the five police officers who attacked the Plaintiff and the minor child
show up. This is yet another false accusation to slander and bring harm to the Plaintiffs.
Prior to the April 26, 2009 arrest, the Benton County Sherriff’s Department once again
arrived at Plaintiffs residence in Lincoln Missouri the Wednesday prior to April 26, 2009
and the night before another scheduled court hearing. They banged on the door and
shined their lights in the windows of the residence. Why did they wait until almost
26
midnight before banging on Plaintiffs door? Plaintiff was home all day and all night with
the lights on in the evening. Plaintiff and his guest hid under the bed in fear for their
safety. To date, Plaintiff locks his bed room door in fear for his own safety.
16. Defendant, Karen Woodley, Prosecuting Attorney for Benton County. Karen
Woodley received a report from the Lincoln Missouri Police Department. Jason Warren,
husband of Brandy Wilkenson Warren and step father of Casey Gipson was charged and
arrested. Jason Warren made a threat to kill Plaintiff Robert Gipson. Jason Warren
prevented Robert Gipson and Casey Gipson from leaving the bed room. Robert Gipson
observed Jason Warren reach behind his back as if to be reaching for a gun. Plaintiff
Robert Gipson grabbed Casey Gipson and ran into the Bedroom at Robert Gipson’s
home. Jason Warren was drinking and returned to Plaintiffs home for the second time
this time during night hours. Karen Woodley denied Robert Gipson Plaintiff the
opportunity to testify at the court hearing and refused to communicate with Plaintiff to
allow for testimony and evidence. Karen Woodley, without Plaintiff knowing, held court
and allowed Jason Warren to be freed on a ten dollar fine and disturbing the peace
charge. This happened after Robert Gipson was held hostage in his own house and
Robert Gipson never had a chance to be present in court. Karen Woodley Perverted the
Course of Justice and jeopardized the Health and Welfare of the minor child and Robert
Gipson. This occurred on or about October 2005. Robert Gipson filed a Child Protection
order against Jason Warren and was forced to drop the charges as Judge Larry Burdett
would not allow Robert Gipson to proceed with the 2005 custody hearing unless Plaintiff
dropped the Child Protection order. Plaintiff waited for over five hours for his case to be
27
heard. While waiting Plaintiff’s lawyer demanded that the Protection order is dropped.
Brandy Wilkenson and Jason Warren have been protected from these criminal activities
at the expense of the minor child and Plaintiff Robert Gipson. James Rice was the
attorney fro Brandy Wilkenson at the time and as Robert Gipson waited for his case to be
heard, judge Burdett allowed James Rice to conduct court hearings as Plaintiff waited for
hours as his lawyer told him to drop the Child Protection Order. Presently as of June 2,
2009, Karen Woodley is once again the Prosecuting Attorney State vs Robert Gipson on
Benton County. During the first hearing in December 2008 and Jan 2009, Karen
Woodley was present in my civil case as she sat in front of Judge Michael Hendrickson.
Along with Karen Woodley were another Prosecuting Attorney and a lady from the
Crime Victims Office all sitting in a civil custody case. By law they are not allowed to
favor or take part in a civil case, their duties involve criminal cases. Along with Karen
Woodley were five police officers, bailiffs from the Benton County Sherriff’s
Department. This was nothing more than a threat. Five Baliffs and two Prosecuting
Attorneys and one Crime Victims Office. When I filed a report in 2005 with the Crime
Victims Office no one would return my call. I eventually received a letter from their
office stating that a crime was never committed as indicated by Karen Woodley when
Jason Warren Held Plaintiffs in the bed room. Plaintiffs will never get justice in Benton
County. Plaintiffs request that this court take jurisdiction over ant case in Benton County
and Plaintiff Robert Gipson sates that his life and his son’s life Casey Ryan Gipson is in
danger.
17. Defendant Cheryl Schultz is the Benton County Clerk of Court. She appears to be
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the senior clerk. Ms Schultz authorized and signed a Garnishment against my bank
account. Bank of America allowed James Johns, attorney for Brandy Wilkenson to
Garnish against my account. The money Garnished was Exempt funds. These funds were
from my Social Security Disability and my Veterans Disability from the VA for my
wounds which I endured while in Iraq. Brandy Wilkenson knew that I was getting
money as did James Johns. This conspiracy to embezzle money from Plaintiff Robert
Gipson and take full control of child support and reduce visitation was their motive.
Brandy Wilkenson now has two adopted children and receives money from the state.
Jason Warren does not work. Money for Child Support from Robert Gipson and money
for the two foster children allow Brandy Wilkenson and Jason Warren to gain financially
at the expense of the minor child and Robert Gipson being forced to be alienated. James
Johns received over $8000.00 from judge Burdett for attorney fees in 2007 and is now
asking judge Michael Hendrickson for over $8000.00 for the last six months of excessive
litigation for 2009. False accusations created by Defendants Brandy Wilkenson and
James Johns forced Plaintiff back into court for the fourth year in a row. This insanity
created by these individuals continues without any over site. Plaintiff was falsely accused
for conducting an in home Sleep Study on the minor child and for conducting medical
testing. All UN-founded and no proof of any evidence presented since Dec 2008 to
Present. In 2003 prior to Plaintiff deploying to Iraq, Plaintiff got a DNA test and once
Paternity was proven, Brandy Wilkenson and her family disconnected the telephone. It
was not until approximately 1 ½ years later in 2004 that Plaintiff Robert Gipson had any
contact with his child Casey Ryan Gipson. Brandy Wilkenson stated that she will have
me in court for eighteen years. She has stated and I quote” I will make sure Casey hates
29
you and only listens to me” There is a lethal threat against Plaintiff Robert Gipson. This
unstable environment in which Plaintiffs must endure is one of high risk. To date Brandy
Wilkenson has not only kept her promise, she has the support from the corruption within
Deputy Haun violated the civil rights of Plaintiffs Robert Gipson and his child
Casey Ryan Gipson. The above Defendants acted under the color of law and
violated their oath of office. Their criminal intent to bring physical harm and
mental anguish against Plaintiffs is in direct violation of state and federal laws.
On or about Nov 9, 2006, Plaintiff went to the Cole Camp Little Blue Byrd Pre-School
to pick up his son Casey Gipson. Brandy Wilkenson the mother of Casey Gipson
removed the child from school even though it was the Plaintiffs Robert Gipson’s
visitation time. Brandy Wilkenson removed the child from school at the advice a case
worker. Plaintiff was informed that the mother made a report that Plaintiff sexually
molested the minor child. This was the first report of sexual abuse against Plaintiffs
by the mother. Ms Peterson the Principal for the Little Blue Byrd school stated
Plaintiff had the minor son bite the head off a snake with their clothes off.
When Plaintiff requested that the Cole Camp Police investigate the abduction of the
30
minor child by Brandy Wilkenson, the Cole Camp Police officer refused to do so.
In 2009, officer Walker once again threatened Plaintiff with arrest at the Little Blue
Bird school in Cole Camp Missouri. In Dec 2005, Officer named John Doe
threatened Plaintiff at Brandy Wilkinson’s residence even though once again it was
Plaintiffs visitation time. On fathers Day 2008, Plaintiff summoned an officer from
Cole Camp. Plaintiff arrived at the Cole Camp Police Department and reported that
Brandy Wilkenson failed to allow the minor child and Plaintiff their father’s day
visitation. Later Brandy Wilkenson stated that she forgot that it was Fathers day even
though she had left town on Friday to visit family in St Louis with her husband Jason
Warren. Plaintiff had no phone contact with the minor child until Sunday on Fathers
Day and not until Ms Wilkenson returned from St Louis. Plaintiff Robert Gipson
requested that the Cole Camp Police Officer (FEMALE) make a report of Jason
Warren making an attempt to slice the tires of Plaintiff. The female police officer did
not make a report and ignored Plaintiffs plea to protect the minor child and Plaintiff
Robert Gipson from harm by Jason Warren. . The Police officer on Fathers Day also
refused to make a report. The police officer on Fathers Day Stated “I have to check
with my boss to see if he will allow me to make the report” His boss was Chief of
Police Walker. Plaintiff has lost faith in the police. They have proven time and time
again that their intentions are to obstruct justice and protect Brandy Wilkenson and
Jason Warren even at the expense of the minor child Casey Ryan Gipson. For months
Plaintiff was followed by police from Cole Camp and Lincoln Missouri. Plaintiff was
followed to and from the Cole Camp Little Blue Bird School by marked police cars.
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Defendant,
Chief Kinkinnon of the Lincoln Missouri Police Department tried to frame Plaintiff.
Chief Kinkinnon conspired with case worker from the Missouri Children’s Division.
Chief Kinkinnon and the case worker stated that my son Casey Gipson stated that I
fondled him. Plaintiff, cross exam of officer Kinkinnon during a court hearing in
Benton County Missouri. Plaintiff was informed by Chief Kinkinnon that a tape was
made during an interview with the minor child. When asked where the video tape
was of the child Casey Gipson making such statement, Chief Kinkinnon stated that
the tape was out in the wall locker of the court house. Approximately two weeks
after this court hearing, chief Kinkinnon resigned from his job and left town. During
Plaintiffs interview with Chief Kinkinnon at the Lincoln police station, both the case
worker and the Chief were attempting to frame the Plaintiff for sexually molesting his
minor child Casey Gipson. Following this accusation by Chief Kinkinnon, another
false accusation that the Plaintiff had his son bite the head off a snake with their
clothes off was brought against Plaintiff. Chief Kinkinnon informed Robert Gipson,
Plaintiff that he is handing the case over to Karen Woodley the Prosecuting Attorney
for Benton County. Later, when asked, Karen Woodley stated that Chief Kinkinnon
never gave her any case and that she did not know what I was talking about. This
Plaintiff was informed by both Paula Woolery and Rhonda Talley, case workers for
the Missouri Children’s Division that the minor child was interviewed in a safe house
located in Sedalia Missouri and Springfield Missouri. To date Plaintiff has yet to
review the tapes even after multiple requests to the Missouri Family Services and the
32
Missouri Children’s Division. Steve Morrow, the Missouri Advocate for Children
stated that he saw the Video. Plaintiff requested a copy of said video from Ron Levy,
Jim Harrison, and others. Plaintiff feels that no tape exists and that this was all an
a direct federal violation against the Plaintiffs. The government workers involved in
this conspiracy have committed felony crimes and are excused from any kind of
qualified immunity or any other kind of immunity. Rhonda Talley and Paula
Woolery are threats to the community and to the children of Missouri. Their actions
to frame Plaintiff Robert Gipson is a felony crime and should be prosecuted at the
19. Defendant, Sheriff Officer Rick Fajen Benton County Sheriff Department,
Officer Rick Fajen is in Authority and has over site to the policies and procedures
within the Benton County Sherriffs Department. His knowledge on the issues
pertaining to Casey Gipson and Robert Gipson makes him a party to this action.
Plaintiff has been harrased, arrested and stalked by numerious poilice officers
from the Benton County Sheriffs Department. On April 26, 2009, Plaintiff was
approximately 1:00pm on April 26, 2009, Plaintiff filed a complaint against the
Sherrifs Department. This was filed in person inside the building in Warsaw
Missouri where the Head Quarters is located. AS Plaintiff was filling out said
complaint, AN officer whos badge and signature could not be read handed
33
Plaintiff a yellow slip which was a summons to appear on June 2, 2009. This
summons stated that Plaintiff is being charged for Child Endangerment. Plaintiff
requested numerious times for the correct spelling of the officer presenting the
summons and was told different spellings and was refused such information. As
the Plaintiff continued to fill out the complaint form officers from the Sherriffs
Department assaulted Plaintiff and hand cuffed him. Plaintiff was jailed and
harassed by four jail guards as he attempted to sleep. Plaintiffs jail cell was
freezing cold and Plaintiff suffered from being cold and sleeping on an Iron bed
in a block cell that was designed for severe confinement. Plaintiff was not
allowed to sleep and was harrassed throughout the night by having his lights
turned off and on and loud noises that were just as lowed as the bombs that
exploded in Iraq. These loud noises were abnormal and shook the cell floor and
caused Plaintiff to jump. Plaintiff was presented food without any utensils to eat
the food. Plaintiff asked every jail guard for their names and many said FUCK
YOU. Plaintiff asked to make a phone call and was told that phone calls are only
made for inmates who want to bail out. Plaintiff demanded to be released and it
was not until the next morning was Plaintiff released and released without paying
bond. Plaintiff asked for police reports of his arrest and names of the jail guards
morning, Plaintiffs Robert Gipson and his seven year old son Casey Gipson were
assaulted by five police officers from the Benton County Sherriffs office. These
five police officers were lined up side by side standing in front of the minor child
and Plaintiff. Plaintiff and his child have been subjected to unnecessary
34
harassment in the past and this simply drew the line concerning excessive force
and excessive threat, Plaintiff took video of the incident in order to protect
Plaintiff and his minor child. Plaintiff also took video the Dec 25, 2008 incident
where the Lincoln police pulled over Plaintiff and his child on Christams night
once again excessive and unnessary harassment. The Lincoln police officer
stated that his car dash cam was recording. It was sad to witness a six year old
child be subjected to such mental abuse. Plaintiff also took video of the
Wednesday incident where the police banged on his door at his residence in
Lincoln Missouri at 11:30 p:m. Brandy Wilkenson has established a bond with
the local police. Her and her husband Jason Warren have used the police to
harrass Plaintiffs. The local police ave conspired to protect Brandy Wilkenson by
providing personal escorts in and out of town and escorts for Jason warren and
attempting to make the Plaintiff out to be some insane Iraq Veteran. Plaintiff
was on another occasion arrested in his home and after Plaintiff was hand cuffed,
the police officer from Lincoln stated and I quote “ Fuck you, you are not getting
dressed.” Plaintiff was arrested and hauled off to Benton County jail in his
slippers and long johns. Plaintiffs civil rights have been severly violated.
Abusive power used against Plaintiff has caused severe mental depression and
mental anguish. To date Plaintiff seeks psychological counseling to help with his
anxiety and depression. The Benton County police and their brutality against
Plaintiff has caused Plaintiff to have nervous break downs. n the past was
harrased and arrested in his home by the Benton County Sherriff and Lincoln
Police. Prior to April 26, 2009, Police officers from the Sheriiffs department
35
arrived at Plaintiffs home and banged on the door and shined there flash lights
into Plaintiffs house at approximately 11:30pm the night before Plaintiff had a
Plaintiff Robert Gipson first moved into his home in Lincoln Missouri on May
10, 2005, , Chief of Police Mr Kinnkinnon parked his car an stalked Plaintiff. For
the last four years, Plaintiff has been arrested twice, jailed once, pulled over
Benton County Sherriffs office. The first court date in Dec 2009, Plaintiff was
20. Defendant, Mickey Mittlestadt, present Chief of Police, Lincoln Missouri Police
October 2005. This report stated that Jason Warren husband of Brandy warren had
threatened the life of Plaintiff Robert Gipson and Casey Gipson. Plaintiffs were held
hosateg by Jason Warren at Robert Gipsons home in Lincoln Missouri. This police
report was not presented to Karen Woodley the Prosecuting Attorney in Benton county.
Officer Mickey Mittlestadt failed to create a thorough report of this incident. Neighbor
of Plaintiff, Ms Keiser gave a police report to the Lincoln Police Department, Karen
Woodley and Hot Lined the Missouri Childrens Division. A phone call to Ms Keiser
36
from a Male case worker to Ms Keiser stated that this was an isolated incident. The
Childrens Division is and was fully aware of this incident. This incident took place in
2005. Plaintiffs were held hostage by Jason Warren. Jason Warren was drunk under the
influence of alchol and came to the residence of Robert Gipson. On October 2005,
Brandy Wilkenson came to seek safety at Plaintiffs residence. Brandy Wilkesnon had a
black eye and bruises on her right hip. Jason Warren beat Brandy Wilkenson in the front
yard at the resident of Robert Gipson in Lincoln Missouri. Witness was neighbor Ms
Keiser. Jason Warren orced his way into the residence of Robert Gipson where casey
Gipson was and also Brandy Wilkenson. Plaintiff grabbed the minor child and ran into
his bedroom. This was after Jason Warren reached behind his back as to grab for a gun
and stated to Plaintiff to come outside. Shortl after Plaintiff received a phone call from
Jason Warren sated to Plaintiff “You think Im crazy you wait you’re a dead man”
Officer Mike Mittlestadt was the reporting officer. Officer Mike Mittlestadt contacted
the Cole Camp Police and they went to Jason warrens home in Cole Camp Missouri wher
Jason warren went to after the hostage situation. Jason Warren was observed drinking
alchol on his steps in Cole Camp when the police arrived. Brandy Wilkenson refused to
admit that Jason Warren beat her and to this day denies the time when my son watched in
horrow as Jason Warren beat her at the Washing Machine at her Cole Camp residence.
Plaintiff was told by the minor child and I quote “Mommy got beat at the washing by
daddy Jason and I tried to tell him no but he would not listen”
20. Defendant, Officer Haun of the Benton County Sherriffs Department threatened
37
Wilkenson the mother of Brandy Wilkeson. On or about Nov 9, 2006, Plaintiff
filed a missing person report with the Benton County Sherriffs Department.
Plaintiff requested that he be escorted to the Grand Parents of the minor child
Casey Gipson. Officer Haun was the escorting officer. Plaintiff pointed out to
officer Huan the house where the minor child may be located. Officer Haun went
to the house and Plainiff waited near the stop sign down the street. This was in
Warsaw Missouri. When officer Hau returned he stated that the child was there
and stated to Plaintiff “If you go over there I wil arrest you” Officer Haun
handed Plaintiff a business card with the name of a case worker from the
Missouri Childrens Division. Plaintiff asked Officer Haun for a copy of a Safety
Plan and there was not one to obtain. Once again Brandy Wilkenson alienated
the child from Plaintiff and used the local police for her own cause. Officer
Hauns threat on Nov 2006 and his conspiracy to help Brandy Wilkenson to
kidnap Plaintiffs son was the act of a felon. Plaintiffs civil rights were
Maliciously violated. On April 26, 2009, Officer Haun once again harrased
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
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
38
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 shows Casey Gipson does have prior reports of Sleep
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 Plaintiff can no longer report.
22. Defendants, Missouri Crime Victims Office, Plaintiff contacted the Missouri
Crime Victims office in 2005, 2006. The agency was informed about the crime
39
against Plaintffs Robert Gipson and Casey Gipson. Plaintiffs were held hostage
Plaintiff that no crime was committed by Defendnat Jason Warren the husband of
Defendant Brandy Wilkenson. Jason Warren was fined ten dollars for
distrurbing the peace. This was after witness statements from neighbor Shirley
Kaiseer and Robert Gipson was presented to the local police in Lincoln Missouri
and the Benton County Sherriffs Office. Presently in June 2009, the Crime
Brandy Wilkenson and Jason Warren filed an Exparte against Plaintiff Robert
Gipson. In this same case, case workers from the Missouri Childrens Division
Wilkensons statement to the court. Malicious intent with Malice to bring harm
to the Plaintiffs. This action was brought against Plaintiff Robert Gipson to add
more insult to injury as the attempt to modify the existing court order was
pending. Court records indicate the same stradagy in previous years, 2005, 2006
when Defendant Brandy Wilkenson and her case workers conspired with the
same motives.
Phone call on his cell phone on the morning of the Exparta hearing from a lady from
Karen Woodleys office identyfing her name and postion with the Crime Victims
Office. She stated that she is willing to appear in court and assist her against Plaintiff
40
Robert Gipson. In 2005, 3006, Plaintiff received no help from the Crime Victims
Advocate in Karen Woodleys Office even when Plaintiff requested assistance. The
24. Defendant, Ron Levy, Director of the Missouri Family Services, was fully
aware of the 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 and his
staff of supervisors and case workers failed to protect Casey Ryan Gipson.
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 aginst the mior child. Their inability to evaluate,
investigate and conduct interviews has done a disservice to the minor child and
Plaintiff Robert Gipson. Their actions were substandard for such prestigious
positions.
25. Defendant, Debra Scott, Former State of Missouri, Director of Family Services.
41
meeting. Plaintiff reached out to the director knowing that her supervisors and case
workers failed to protect the minor child. Plaintiffs Robert Gipson and his son Casey
Gipson. Debra Scott ignored vital information from third party witnesses that
described events of neglect and abuse against the minmor child Casey Gipson.
At all times relevant herein, Defendants Jim Harrison, Steve Morrow, Nancy Parks,
and Ms Hendrickson violated the civil rights of the Plaintiffs and failed the minor child.
promulgated by Missouri Children’s Division, which acts may fairly be said to represent
official policy or were pursuant to the governmental custom of the State of Missouri.
Hartgrave worked with Jim Harrison the director of the children’s division. Ms Hartgrave
worked with Nancy Parks and Paula Neese. All of these defendants were fully aware of
the neglect and abuse against Casey Giposn the minor child. Ms Hartgrave reviewed the
pictures and video of Casey Gipson and was fully aware of the numerous Hot Line calls
Defendant, Dawn Long, Benton County Case Worker. Ms Long investigated the
Hot Line call made by Plaintiff in 2004. Plaintiff reported that the minor child was
investigation as indicated by Plaintiffs attached exhibitPlaintiff first found out about the
oven burn in 2004 when he saw Casey Gipson. When the Plaintiff asked Brandy
42
Wilkenson how Casey got the burn Ms. Wilkenson stated “It is none of your business.”
This was said in front of the GAL Mr. Stewart and James Rice, Defendant, Brandy
Wilkenosn’s lawyer. Defendant Dawn Long once again investigated a HOT Line Call
stating that Plaintiff was arrested for child endangerment. Even though this was found to
be Un-substantiated, this was staged by the Benton County Sherriff’s Department and
Plaintiff has video to show the same. Dawn long arrived at the Benton County Sherriff’s
Department on April27, 2009 at approximately 8:00 a.m. With Dawn Long was officer
Haun. Officer Haun in Nov 2006 conspired with Brandy Wilkenson and a case worker
from the Missouri Children’s Division. Officer Haun stated to Plaintiff “If you go to the
house I will arrest you” This was after he handed Plaintiff a business card from a case
worker from CPS. Like so many other case workers and investigators from the
Children’s Division, Dawn Long was moved from one position to another. When
Plaintiff went to the Warsaw Missouri office for Social Services, Plaintiff was told that
Dawn Long no longer works in the Children,s Division. It appears as of Jan 2009, Ms.
Long is back working as a case worker. Many workers from the Directors, case workers,
supervisors change jobs and are moved around the state especially when complaints are
filed. This makes it hard to communicate with these government workers and it appears
that this is executed to prevent any information being obtained for any legal actions.
Defendant Dawn Long had the opportunity to help the minor child when she knew about
the oven burn. Dawn Long refused to contact any witnesses that the Plaintiff Robert
Gipson attempted to bring to her attention. Plaintiff himself was never interviewed and
was ignored. Numerous other complaints of neglect and abuse have been reported to the
Hot Line and CPS. The way in which the Children’s Division evaluates and investigates
43
such complaints is sub standard. It is vertualy imposible for a child to endure so many
injuries and reported by so many people that at least one incident would be found to be
substantiated against the Defendant and mother Brandy Wilkenson. This has been
nothing more than a cover up for over six years by this community of police, case
workers, psychologist, lawyers, judges, court clerks etc. Defendant Dawn Long has been
aware of high risk environment that faces the minor child Casey Gipson. She has turned
her head at the obvious signs of neglect by a mother that may have mental problems. Ms.
Long has ignored and has failed to report to other case workers and supervisors knowing
that after 2005, and present in 2009 that more neglect and abuse was occurring and
Defendant, Beverly Chapman, Benton County case worker. Ms Chapman observed the
minor child Casey Gipson in her office at the Warsaw Missouri Social Services. Plaintiff
informed Ms Chapman that the minor child had been burned by a cigarette. No report
was created even after the child had pictures taken by two Sheriffs from the Benton
County Sherriff’s Department. The minor child was burned a few days after a doctors
report stateted not to allow the child around smoke. This doctor report was presented to
Brandy Wilkenson by Plaintiff Robert Gipson. Plaintiff took the minor child to the
Emergency room in Sedalia Missouri after the child was having Sleep Apnea and
Obstructed Airway. Defendant Beverly Chapman arrived for the 2007 court hearing in
Benton County court house. Ocompaning her were case workers Paula Woolery, Rhonda
Talley, and Casey Gipson’s preschool teacher. This was yet another conspiracy to help
the mother Brandy Wilkenson to gain custody of the minor child Casey Gipson. As
indicated by Plaintiffs exhibit, these case workers were informed not to attend these
44
hearings. Their lawyer stated in his motion that “ The Childrens Division would not be
able to function without their case workers present for duty.” These case workers
slandered the Plaintiff in court and in their case summery reports. Defendant Beverly
Chapman informed the Plaintiff during a phone conversation that Plaintiff is giving her to
much information and that she has to get to another client. Ms Chapman arrived at the
Plaintiffs house in Lincoln Missouri with an escport from the Benton County Sherriffs
Department. In front of Ms Chapman Plaintiff counted over twenty bugs bites and
reported other issues concerning the minor childs health and welfare. Prior to entering
Plaintiffs house, Ms Chapman shook her leg and jokingly stated “ oops I have a chigger.”
Prior to leaving Plaintiffs residence, Defendant Beverly Chapman stated “My colleagues
and I think that you should take parenting classes because you are a single father” Ms.
Chapman stated to Plaintiff “You have my pen” as she laughed she put her face next to
Plaintiffs face and said “JOKE”. The Sherriff who escorted Ms Chapman was from the
Plaintiffs home, Plaintiff has been arrested by the Benton County Sherriff’s Department.
This conspiracy continues even today with pending charges against the Plaintiff for child
endangerment. When the Plaintiff arrived on June 2, 2009 to plead not guilty, Plaintiffs
name was not on the court docket. This arrest on Child Endangerment was set up by
Brandy Wilkenson and carried out by the Sherriff’s Department. Plaintiff requested the
cigarette burn report from Beverly Chapman and the Sherriff’s Department. To date the
report has not been turned over to Plaintiff. The Benton County Sherriff’s stated that
they have no report. The police officers who took the pictures of Casey Gipson’s ear
never documented the incident and covered up the investigation. The physician and
45
mandated reporter at Dr Cahill’s office also failed to report the ear burn. Plaintiff has the
pictures of the ear burn that were taken by the Sherriff’s Department in his attached
exhibit files. Beverly Chapman stated in her office to Plaintiff “ The grandmother
accidently burned Casey” Defendant Brandy Wilkenson informed Plaintiff that Meliss
burned Casey Gipson. Casey Gipson informed the Plaintiif Robert Gipson that he was
burned by a cigarette. While in the church bathroom in Warsaw Missouri, Plaintiff asked
the minor child how he got the ear mark. Beverly Chapman used the Sherriff to
intimedate Plaintiff.
Defendant, Paula Woolery, Benton County case worker. In 2205, Ms Woo;ery stated
to Plaintiff “I will take your child from you” Ms. Woolery was investigating a Hot Line
call that was made by Brandy Wilkenson. Defendant Brandy Wilkeson, mother of Casey
Gipson, stated that the Plaintiff and father of the minor child Casey Gipson, sexually
molested the minor child. Paula Woolery conspired with the Chief of Police Mr
Kinkinnon of the Lincoln Missouri Police Department. During the interview of Plaintiff
at the Lincoln Police Department, Paula Woolery and the Chief attempted to frame
Plaintiff. Their attempt to slander Plaintiff and make him out to be a child molester was
their primary motive. Paula Woolery stated that the child was taken to a safe house for
an interview and was video taped. Plaintiff has requested the videofrom the Childrens
Division and has asked for the address and contact information to the safe house in
Sedalia Missouri and Springfiled Missouri. Case workers Paula Woolery and Rhonda
Talley stated that video tapes exist of both safe house interviews of the minor child.
Chief Kinkinnon also stated on the witness stand that the video tape of the minor child
46
was out in the locker in the court house. Chief Kinkinnon stated “As far as I am
concerned, the child is better off with you not around.” Paula Woolery has assisted her
remove the minor child from Plaintiffs life. Ms Woollery and her threats to take the child
was nothing more than abusive power. Defendant Paula Woolery with her biological lies
and blatant unfairness has caused great harm against Plaintiffs Robert Gipson and Casey
Gipson.
)
Defendant Alice Sharon Zidlicky, Benton County supervisor over case workers. Ms
Zidlicky met with Plaintiff at the Warsaw Social Services Office. Ms Zidlicky made
conspired with her case workers to slander Plaintiff. Ms Zidlicky stated to the Plaintiff “
You try to turn everything around.” Ms Zidlicky had every opportunity to protect the
minor child. She failed to properly investigate and as a direct result Casey Gipson the
minor child has had to endure years of neglect and abuse. The conspiracy between
supervisors and case workers here in Missouri is an act of fraud. Obstructing justice
has affected the lives of two innocent citizens. Plaintiffs Robert Gipson and Casey
Gipson request a full federal investigation into the abusive powers of the Missouri
Childrens Division Directors, supervisors, case workers and staff. Plaintiffs request
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
47
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
48
minor child. Plaintiffs aks for relief to assign another advocate in this position. Plaintiff
request that Defendant Steve Morrow resign from his job as 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 prestigious job such as protecting children from harm.
In 2007, Brandy Wilkenson was given money from Mr Brown the Supervisor at
the Sedalia Social Security Office. Defendant James Johns Garnished Plaintiffs
Bank account at the same time as Mr. Brown was making Defendant Brandy Wilkenson
the Payee. The Benton County Clerks office assisted James Johns. Plaintiff
was not aware that Mr. Brown authorized Brandy Wilkenson to be the payee of over
$650.00 until after the fact. The staff under Mr. Brown sent Plaintiff a letter advising
Plaintiff to call them. Plaintiff did call and the staff ignored Plaintiff. At the same time
James Johns Garnished yet another $1,400.00 as Brandy Wilkenson was receiving extra
money from the Social Security Office in Sedalia Missouri. Congressman Ike Skelton
received notice from Plaintiff that this was and is a federal violation. To date Plaintiff
has not heard back from the Congressman. This conspiracy is happening again. As of
June 2009, James Johns is asking Judge Michael Hendrickson for attorney fees. James
Johns, former GAL Mr Stewart and the present GAL MR Lutman together along with
Brandy Wilkenson has conspired to embezzle money from Plaintiff Robert Gipson.
49
Plaintiff contacted the Cole Camp Police and the Benton County Sherriffs
Haun. On or about Nov 9, 2006, Plaintiff reported the kidnapping of Casey Ryan
Gipson. Plaintiff escorted Offcer Haun to a suspected place where the child may
Be. There was a court order in place which authorized Plaintiff to have his weekly
visitation. Officer Haun warned the Plaintiff not to go near the house. Officer Haun
conspired with Brandy Wilkenson and case workers from the Missouri Children’s
Division. Officer Haun works in the same Department as the other Officers who
have harassed and falsely arrested Plaintiff on April 26, 2009. On April 27, 2009,
officer Haun escorted Dawn Long into the holding area at the Warsaw Benton
County Sherriff’s jail. Officer Haun conspired with CPS case workers and
obstructed justice. Officer Haun failed to report the high risk environment which
the minor child is subjected to. When the Plaintiff escorted officer Haun to the
Grandparents house of the minor child, there were over five hunting rifles leaned up
Prior reports back in 2004 and 2005 by Plaintiff was also about loaded guns
in the grandparents house, These guns were against the wall. The minor child was
crawling in the grandparents house. Plaintiff has made reports about the health
hazards at the grandparents house. This reports were presented to case workers,
police and supervisors. Officer Haun’s threats towards Plaintiff in 2006 and the on
going threatsin 2009 by this same police department have proven to abusive and
out of control. Prior to Plaintiff’s arrest on April 26, 2009, officers from the
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11;30 p.m. In 2007, Plaintiff was arrested and taken into custody. The arresting
officers did not have an arrest warrant nor did they read Plaintiff his rights. Plaintiff
was once again arrested on false accusations by Defendant Brandy Wilkenson. The
police officers making the arrest ignored Plaintiffs statements. The Lincoln police
officer at the time of the arrest and after Plaintiff was handcuffed stated “ FUCK
you, your not getting dressed, your leaving now.” Plaintiff was taken into custody
with his slippers and long johns on. In Christmas 2008, Plaintiff was once again had
his civil rights violated. With Plaintiffs child in his car, the Lincoln Police, pulled the
Plaintiff’s car over and harassed the Plaintiff. Plaintiff moved to Lincoln Missouri
on May 10. 2005. Plaintiff has been Maliciously attacked ever since. Plaintiff
request that this court provide protection for Plaintiff and his minor son Casey
Gipson. Plaintiff has received death threats and has had many times dead animals
thrown in his yard. Plaintiff has received calls on his cell phone and the caller shot
rounds from a gun as Plaintiff was listening. Plaintiff has received threats on the
internet and has been stalked. Plaintiff has called the Benton County 911 number
and was ignored. It has been proven time and time again that Plaintiff and his child
Casey Gipson will be ignored and not get the protection from the government
agencies in this community nor by any other state agency in Missouri. Plaintiffs
request that a federal investigation be conducted into the claims made against the
Plaintiff.
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Defendant, Attorney, James Johns, Brandy Wilkenson’s Attorney in 2007 and 2009
Defendant, Former, Attorney James Rice, Attorney for Brandy Wilkenson in 2004,
Defendant, DR. Erika Waller, psychologist for child and father. Ms Waller failed to
report the neglect and abuse against the minor child Casey Gipson. Casey Gipson was
interviewed by Erika Waller in the office building of Dr. Daniels in Columbia Missouri.
During this interview, Casey was asked a series of questions by Dr. Waller. Three of the
1. What makes you mad? Casey answered, when mommy hits me in the face.
2. What makes you saddest? Casey answered, when mommy hits me in the eye.
Dr. Waller never reported this to the proper authorities. Dr. Waller is a mandated
reporter. Dr. Waller received an intake form from Plaintiff Robert Gipson. Plaintiff
also was interviewed by Dr. Waller and Dr. Daniels. Plaintiff informed both doctors
of the previous incidents where the child had witnessed his mom getting beat by
Jason Warren. Plaintiff presented various documents containing reports of abuse. Dr.
Waller and Dr. Daniels were both in a position to protect Casey Gipson. Plaintiff had
presented many documented accounts of neglect and abuse against the child. Prior to
Dr. Waller interviewing Casey Gipson, she was already aware of the childs past
52
history in witnessing domestic violence and the child himself being a victim of
physical and mental abuse. Plaintiff never received any report that described what
the minor child had said to Dr Waller unitl approximately one and a half years later.
Plaintiff was not informed of these issues of his son being beat in the face by his
mother. Plaintiff was litigating in family court on these same issues. Dr. Waller and
Dr Daniles were aware of the court hearings. Casey Gipson could have been
protected by these two doctors and they both failed him. As the father of the minor
child, Plaintiff was kept in the dark. Dr. Waller and Dr Daniels are both mandated
reporters. They were paid over $1,000.00 dollars for their services. There were only
three visits to the Columbia office. These doctors were put on notice about the high
risk environment that endangered Casey Gipson’s life. They heard the cries of a child
pleading for help and covered up vital reports. These reports tha clearly showed a
child and father in need of professional help were masked and kept silent. Attached
in Plaintiffs exhibit is a copy of Dr. Wallers report. This mandated reporter like so
many others have deceived Casey Ryan Gipson. The school teacher who told Casey
Gipson to keep it to himself when Casey told her about the 911 call also deceived the
minor child.
53
Defendant, DR. Salenger, psychologist for child. Dr. Salenger treated Casey Gipson
for two weeks before Plaintiff had any idea that his child was going through counseling.
Dr Salenger was recruited by Jim Rice, Brandy Wilkenson’s attorney. Plaintiff was kept
in the dark for weeks before being informed by Brandy Wilkenson that Casey seeing Mr.
Salenger. Prior to Casey Gipson seeing Dr. salenger, Plaintiff informed Defendant
Brandy Wilkenson that Casey was beating his face on the airplane and said “Mommy got
beat at the washing machine by daddy Jason and I tried to tell him no but he would not
listen.” Plaintiff informed Defendant Brandy Wilkenson that he was taking Casey to see
a professional. When Plaintiff arrived to pick up the minro child, Brandy Wilkesnon
refused visitation even though the court order allowed such visit. Once again Brandy
Wilkenson was in contempt. Plaintiff attempted to have a Cole Camp Police officer
escort the Plaintiff to retrieve his child. The Cole Camp police officer like all the others
sated “If you do not leave I will arrest you and this convcersation is over” The Cole
Camp police officer also stated that he just spoke with Jim Rice, the attorney for
Defendant and then the police officer said “Your only here to see Brandy.” When
Plaintiff made a schedule to see Mr Salenger and requested docymenst, Dr. Salenger
reluctantly refused. Plaintiff took Casey Gipson for a counseling visit with Dr. Salenger.
Plaintiff observed Casey Gipson crawling over the thighs of Dr. Salenger. Plaintiff was
not comfortable seeing this. The room was very dirty and the toys were broken and
filthy. The smell of mold and cigaretts filed the air. When Plaintiff asked Dr. Salenger
54
why did he wait two weeks to inform Plaintiff that he was treating his son? Dr. Salenger
stated “ The mother told me that you knew.” Plaintiff did not know that his child was
being treated. Plaintiff tried to get his child a counselor close to Lincoln Missouri. The
drive to Clinton was selected by Brandy Wilkenson. As always, Defendant Brandy
Wilkenson and her lawyers deceive and manipulate their way to achieve their desired
goals. To date their goals are to destroy the life of a father and son who once had a
natural loving bond. They have a blatant disregard for human life.
Defendant, Dr. Julie Cahill, physician for child. Dr Julie Cahill failed to report to the
court that Casey Gipson has a medical history for being treated with prescriptions of Iron
medication and antibiotics. Plaintiff inquired about the use of to much antibiotics on his
child. Dr. Cahill refused to contact Dr. Nicholas at the Children’s Mercy Hospital.
evaluated for his Sleep Apnea. Brandy Wilkenson interrupted this scheduling. At the
time Plaintiff had every right to seek medical attention for his child. Presently, Plaintiff
has been forced to a five hour visitation and is unable to help his child. Dr Cahill sates
that the child is normal. Dr Cahill did observe the minor child sleep for two years. No
doctor can effectively evaluate a child for Sleep Apnea unless it is done by a Sleep Study
and the child is seen by an E.N.T. On Jan 4, 2009, Plaintiff took the child to the
emergency room because the child stopped breathing for approximately ten seconds.
Once again Defendant Brandy Wilkenson ignored Plaintiffs concerns and interrupted the
emergency room visit Prior to Nov 6, 2006, Plaintiff observed Casey Gipson with svere
Sleep Apnea. It was not until Jan 2009 that the Plaintiff was able to observe two nights
of the child having Sleep Apnea was Plaintiff able to provide medical help by taking
55
Casey Gipson to the emergency room. Dr. Cahill and other doctors from her office have
masked the true medical issues that affect my son Casey Gipson. They have ignored
phone calls and written reports from Plaintiff. Attached is a letter to Dr Cahill in
Plaintiffs exhibits.
ndant, Bank of America,
Defendant, Ms. Peterson, School Principal for minor child. Ms Peterson has
interrupted many times Plaintiffs relationship with his child. Ms Peterson created a false
accusation that the Plaintiff sexually molested his child Casey Gipson. Defendant Ms
Peterson conspired with Brandy Wilkenson to frame Plaintiff and slander. This was the
second Hot Line call that Plaintiff sexually molested his child. The first one was just
months if not weeks prior to the School Principal doing the same. She called the Hot
Line and recorded this called Plaintiff on his cell phone and sated “You are not welcome
in
my school and we will take care of Casey’s education” Ms Peterson sated that she
watched Plaintiff on the security monitor. Ms Peterson staed that the Plaintiff is a threat
to the children on the play ground. Plaintiff brought his child a yellow car and showed
him the car at the playground fence. Ms Peterson informed Plaintiff that she will call the
police if Plaintiff gets out of his car. The year before this threat, Plaintiff was always at
the school play ground. On one other occasion as the Plaintiff was waiting to greet his
child at the school Christams play, Defendant Brandy Wilkenson refused Plaintiff from
having any contact with his child. Ms Peterson interrupted and assisted Brandy
Wilkesnon. The minor child was crying because he could not stay and watch the first
graders sing. This is once again the insanity that the Plaintiffs must experience at the
56
Defendant, MS, Pre-school teacher for minor child, Plaintiffs right to father his child
was interrupted by the pre school teachers at the Little Blue Byrd School. During a
Holloween, n breakfast Plaintiff sat beside his child Casey Gipson. Next to the Plaintiff
approximately ten feet away, the two pre- school teachers were talking about a parent
who failed to listen to them and they removed the parents child. This was a very odd
subject fot two school teachers to be having in front of their students. Later one of the
school teachers testified against the Plaintiff Robert Gipson. Plaintiff was accused of
feeding his child his breakfast. The fact was that the Plaintiff was attempting to
encourage his child to eat his breakfast. This was just another way for these teachers to
assist the mother to get custody. These same two pre-school teachers interrogated my
child and reported that I sexually molested him. The report from the case worker and
these teachers was that “ Plaintiff had his child bite the head off a snake after playing buc
the Donkey.” Ms Peterson and her staff of teachers were well aware of the head
injuries that Casey Gipson had on his head. Casey informed Plaintiff that “a car threw
rocks on him and made him spin around and he laughed.” In a school picture the
minor child had yet another head wound. Plaintiff was informed by his child “ Connor
hit me in the head with a rock and blood went down my stomach” Casey Gipson stated
that the blood ran down to his feet when his grandmother washed him off in the shower”
of Casey Gipson. Plaintiff was informed by his child that his mom yelled from behind
closed doors. Brandy Wilkenson told the minor child Casey Gipson to go call 911 and
tell Melissa. Casey Gipson told his school teacher and she replied “Keep it to your self”.
57
Plaintiffs child Casey Gipson informed Plaintiff of this incident during one of his visits.
Plaintiff has reported this incident and many others. School teachers and principals are
mandated reporters. These are severe violations and these school officials violated the
civil rights of the minor child. They have failed to protect this child.
14. In 2003 , Brandy Wilkinson, did cause a Petition for Declaration of Paternity to be
filed against Robert Gipson, in the Circuit Court of Benton County, Missouri, in cause
number #03CV694772.
15. In that cause Robert Gipson was found to be the natural father of Casey
Gipson, a minor child and the parties were awarded Joint Legal and Joint Physical
making a “hot line” reports of abuse/neglect against Brandy Wilkinson, the mother of
Casey Gipson, to the Children’s Division, defendant Brandy Wilkinson did cause and or
did conspire with others to cause an unfounded and untrue “hot line” report of sexual
58
abuse against plaintiff Robert Gipson to be made to the Children’s Division of Benton
County, all in retaliation for his lawful and correct report of abuse/neglect against her
for plaintiff’s reports of her medical neglect and exposing the minor child Casey Gipson
to domestic abuse by his then step father, she did cause a Motion to Modify to be filed in
the above captioned matter, said Motion seeking to deprive plaintiff of his joint custody
rights.
18. When the Children’s Division ignored the complaints of medical neglect
and exposure of the minor child to domestic violence, made by plaintiff against defendant
and individually denied to the minor child the rights and privileges guaranteed to the 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
19. Defendants, from the Missouri Childrens Division and others acting in
their official and individual capacity and, under color of authority and in their capacity as
agents of the State of Missouri, individually and collectively placed the Minor child in
defendant Brandy Wilkinson’s home under authority of the Children’s Division, and did
thereby ensure that the lawful joint custody rights of the plaintiff could not be exercised
as set forth in the original Decree of Paternity, and in so doing further neglected the
medical health and well being of the minor child and did perpetuate the exposure of the
minor child to the domestic violence in the home of Mother and thereby prevented
59
plaintiff from properly protecting his child, and did harm both plaintiff Robert Gipson
and the minor child Casey Gipson by depriving each of them of their constitutional rights
to have a child in the custody of their lawful parents. Moreover, the following
defendants, Dr Julie Cahill and other doctors from her office knowingly refused the
minor medical care for his chronic airway obstruction and have placed the minor child’s
life in jeopardy. On Jan 4, 2009, the child was taken to the Kansas City Missouri
Childrens Hospital after experiencing Sleep Apnea for two nights in a row and a bloody
nose and congestion the day before the Jan emergency room visit.
by plaintiff regarding the medical neglect and exposure of the child to domestic violence
in the home of defendant Mother and the mother’s mother Shela Wilkenson. Defendants
individually and acting in concert with one another conspired to deprive plaintiff of the
joint custody rights he had with his minor child Casey Gipson and further did act alone
and in concert to deprive Casey Gipson of his right to be n the custody of his father
did, individually and acting in concert with one another committed or participated in the
following acts:
Mother;
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his lawful custody rights and to deprive Casey Gibson of the love, comfort
the minor child. Yet, this evidence has been used to further the conspiracy
22. Plaintiffs cause of action against the above named defendants for the
failure to investigate, wrongful removal of Casey Gipson from his father Robert Gilpin,
was due to their denial of the substantive due process rights of Casey Gipson to associate
with his Father 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 danger
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23. 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.
24. The acts of defendants under this count were under the color of state law.
42 U.S.C. §1988.
damages in an amount that will justly compensate Plaintiffs for economic and non-
justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and
27. This Count constitutes the claims of Plaintiffs with respect to Defendants
28. Defendants from the Missouri Childrens Division acted in concert against
Plaintiff Robert Gipson to deprive him of his Joint Custody rights, by manufacturing false
allegations to discredit Plaintiff Robert Gipson, encouraging others to do the same, and
using those false allegations to deprive him of his Joint Custody rights through Juvenile
62
29. Defendants, from the Division used the power and prestige of their
conspiracy.
30. Defendants shared the objective to discredit plaintiff Robert Gipson and
32. Defendants’ actions, as stated above, were reckless and outrageous and
subjected Plaintiffs to loss of consortium with his child damage to his business and
personal reputations.
33. The acts of defendants under this count were under the color of state law.
42 U.S.C. §1988.
damages in an amount that will justly compensate Plaintiffs for economic and non-
justice requires; for Plaintiffs’ costs of this action, including reasonable attorney fees; and
such other relief as may be granted by the Court. Plaintiff states that he has been forced
to file such suit in order to protect the interest of his minor child. Plaintiff moves to
63
Quash all Summery judgments against this suit by any and all Defendants.
36. This Count constitutes the claims of Plaintiffs with respect to all
Defendants.
37. Plaintiffs are father and son and Father Robert Gipson had previously to
the acts of Defendants enjoyed a close loving relationship with his son Casey Gipson
over who he shared joint Custody . This permitted the plaintiffs to have and maintain a
close loving relationship and for father to protect son regarding his medical needs and
38. Each of the Plaintiffs had and enjoyed a close, loving and constitutionally
protected relationship and had the expectation that this relationship would continue.
39. Defendants were aware of the close relationship between the Plaintiffs and
knew that only be manufacture and dissemination of false, spurious and incendiary
allegations could this relationship be severed 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 and the expectancy of Plaintiffs under the Constitution to such a familial
64
relationship.
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 taken in the
protected relationship.
representation of facts, and abuse of the Court process to interfere with the Plaintiffs’
constitutionally relationship.
44. Defendants’ actions, as stated above, were reckless and outrageous and
46. Plaintiffs are entitled to a recovery of their reasonable attorney fees and
Punitive damages under Missouri Common Law for tortuous interference with their
damages in an amount that will justly compensate Plaintiffs for economic and non-
65
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
COMPLAINT CONTINUED
FROM
1. Casey Ryan Gipson was born in Missouri on May 26, 2002. Brandy Wilkenson
mother of Casey Gipson refused to allow the father, Plaintiff Robert Gipson to be
2. Plaintiff Robert Gipson and Brandy Wilkenson met in New York City just prior
3. Brandy Wilkenson informed Plaintiff Robert Gipson that she was pregnant and
the child was not his. Brandy Wilkenson sated that she had tests and that she was
support even though he was informed that the child was no his.
5. Plaintiff was in the United States Army in New York and was ordered to proceed
to New York City on 9/11/01. Plaintiff was the Operation NCO for the rescue
operation in New York City on 9/11/01. Plaintiff deployed to New York City to
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6. Following 9/11, Plaintiff moved to Florida to join the Florida National Guard
changed her story and now stated that Plaintiff Robert Gipson was indeed the
was Unemployed and even though no DNA test was done, Plaintiff still
supported Brandy Wilkenson. AT this time there was no proof of DNA test done
to confirm that Plaintiff Robert Gipson was indeed the father of the un-born
child.
9. On Nov 2002, Plaintiff Robert Gipson gave Brandy Wilkenson $1,500.00 dollars
to fly her and the minor child to Florida where they initialy stayed in Plaintiffs
condo in largo Fla. Plaintiff did so knowing that he was getting ready to deploy
to Iraq.
10. When Brandy Wilkenson arrived to the Plaintiffs condo with the minor child she
began to get phone calls from Jason Warren her now present husband.
11. Brandy Wilkenson and Plaintiff was invited to Betty Matson’s daughters home
12. Prior to the dinner, Plaintiff took Brandy Wilkenson and the minor child Casey
allowing Mr. Rogers and his mother from seeing the child. Finally after begging,
Brandy Wilkenson allowed Plaintiff to take the baby up to the house of Mr.
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Rogers. Brandy Wilkenson refused to come up to the house and remained in the
car.
13. The next day after the dinner, Brandy Wilkenson attacked the Plaintiff in his
home in Largo Florida and ripped the phone out of the wall. . Plaintiff Robert
Gipson then took the baby Casey Gipson and Brandy Wilkenson to a Hotel in
Clearwater Beach. With great regret, Plaintiff left the baby with Brandy
14. Later that night Brandy Wilkenson left a message on Plaintiffs answering
machine that the baby Casey Gipson has been crying all day and that she was
taking him to the hospital. She also stated that Casey needs diapers.
15. Reluctantly, Plaintiff fearing for his safety and the safety of the baby, Plaintiff
returned to the hotel. When Plaintiff arrived, it was very cold out side and
Plaintiff observed Brandy Wilkenson with the baby and the baby had only a
diaper on. Plaintiff immediately took the baby and stood outside the hotel room
16. Later that night, once again Brandy Wilkenson attacked the Plaintiff and this
time she ripped the hotel phone out of the wall. Plaintiff pushed Brandy
Wilkenson off him and then Plaintiff secured the baby in his arms. At this time
the baby was crying and stopped crying when Plaintiff held him.
17. Brandy Wilkenson then snatched the baby out of Plaintiffs arms and ran out side.
18. At this time Plaintiff had yet obtained a DNA test and had no legal rights.
Plaintiff was only there to provide comfort for the baby knowing that Brandy
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Wilkenson was attempting to conspire an attempt to bring discredit to Plaintiff.
19. Brandy Wilkenson went next door to the pay phone and called the police and
20. The child was out in the cold in his diaper for over forty minutes as Brandy
21. Plaintiff was falsely arrested on a false accusation by Brandy Wilkenson that
Plaintiff assaulted her. Plaintiff was arrested and stayed in mhe Largo jail for
22. This was Brandy Wilkenson’s first attempt of her conspiracy slander and bring
23. Brandy Wilkenson left town the next morning and flew to New York to see
Jason warren. Jason Warren sated this in person in 2004 during a visit at the
Warsaw a Park.
24. Brandy Wilkenson and others planned this staged event. She left town the next
Mr Gibson. She told the Prosecuting Attorney that she will not be returning to
25. The damage was done. Plaintiff spent over forty eight hours in jail prior to
deploying to Iraq. Brandy Wilkenson received phone calls at Plaintiffs condo and
she made calls from the laundry matt prior to being taken to the Largo Hotel.
Brandy Wilkenson was coached and she succeeded in falsely accusing Plaintiff
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26. To this day Brandy Wilkenson has brought numerous false accusations against
Plaintiff. She has done so with the assistance of case workers, judges, lawyers,
psychologist, doctors and others who have made false reports and slandered
Plaintiff.
27. Brandy Wilkenson has manipulated the courts and other individuals in order to
gain custody of the minor child Casey Ryan Gipson. Brandy Wilkenson is from
Warsaw Missouri. She once stated to the Plainitff and I quote “ This is a small
28. Prior to deploying to Iraq, Plaintiff received a phone call from Brandy
Wilkenson, she stated “ I will have you in court for the next eighteen years and
29. Brandy Wilkenson had a video camera set u in her hotel room. The video camera
was set on a table facing the couch. Brandy Wilkenson reached over to kiss
Plaintiff in front of the camera. She did so to deceive Plaintiff and to attempt to
Wilkenson came to Plaintiffs house in Lincoln Missouri. She stated that she was
divorcing Jason warren and that she wanted to be with me. I told her that I can
not be with her. The next morning I took Brandy Wilkenson to a house that was
for sell. She said that the house was to small. Brandy Wilkenson came to
Plaintiffs house in Lincoln with a black eye and bruised hip. She lied to Jason
warren and said she was there because she locked her kesy in her car and needed
a place to stay. Brandy Wilkenson is a danger to Casey Ryan Gipson and her
other two biological children and her two foster children. If she continues to be
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allowed to deceive the courts, police and others, she will never stop her insanity.
2003
30. Plaintiff deployed to Iraq in May 2003. Prior to deploying Plaintiff had a DNA
test done and it was confirmed that Casey Ryan Gipson was Plaintiffs child.
This DNA test was samples from a swab DNA test, no blood test was done.
31. When plaintiff informed Brandy Wilkenson that he had a DNA test done Brandy
Easter 2004 Plaintiff had no contact with the minor child. It was not until Easter
2004 that Plaintiff held his child Casey Ryan Gipson. It was at this time that
Plaintiff first saw the burn mark on Casey Gipsons arm. Plaintiff asked Brandy
Wilkenson how the burn mark got there and she stated and I quote “ Its non of
your business” This was stated in front of the GAL Mr Stewart and Wilkensons
lawyer Jim Rice. This was stated at the Warsaw Park next to the swimming pool
and on the Tennis courts. It was at the Tennis courts that Jason Warren stated
that he was the one waiting in New York for Brandy Wilkenson.
32. It was also Easter 2004 that Plaintiff reported the severe bruises on Casey
Gipson’s nose and forehead. NOTE: SEE Exhibit with pictures of minor
child. Brandy Wilkenson never took the child to the hospital for the bruised
nose and bruised for head. She never took the child to the hospital for the oven
burn. To date the child has Sleep Apnea and obstructed Airway. His nasal
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Infection which he gets severly in the winter. NOTE: Plaintiff has presented a
video, cd, and pictures showing the severe Sleep Apnea and other stressors
Hartgrave, Steve Morrow, Nancy Parks and Missouri Foster care program.
Various case workers and Investigators have also been put on notice.
When his nose and forhead was smashed he may have had his nasal passage way
affected and this could be why he has trouble breathing through his nose. The
minor child is subjected to smoke, mold and environments that put him at hig
risk. On Jan 4, 2009, Plaintiff took the minor child to the Childrens Mercy
interrupted the doctors when she called the hospital and stated I have no rights
and that she was the custodial parent. Brandy Wilkenson has achieved her goals
and objectives of alienating the minor child from his father Robert Gipson.
Since the childs birth, Brandy Wilkenson, Jim Rice and James johns have
conspired to make this a reality and have conspired to braek the bond between
Plaintiff Robert Gipson and the minor child Casey Gipson. Un-founded reports
and false accusations of sexual abuse, child endangerment and many other false
accusations have resulted in Plaintiff losing custody of his child Casey Gipson.
When two or more conspire to bring harm against another person is a federal
crime. When such harm violates a persons civil and constitutional rights, this
also is a federal violation. When government workers bring with Malice and
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NOTE: SEE NOTES FROM PLAINTIFF DATED FEBRUARY 15, 2003 AT
2004
33. Plaintiff returned from Iraq in Feb 2004. Plaintiff was stationed in Ft Stewart
Georgia from Feb 2004 thru May 2005. Plaintiff would fly monthly to Warsaw
34. Plaintiff was dragged through the family court system in Benton County
Missouri. When Plaintiff arrived to review his case files, the Clerk of court
35. While in Iraq, Plaintiff hired a lawyer from St Louis Missouri. This lawyer
deceived Plaintiff and stated that she had filed motions with the court. This was
36. Once again Plaintiff was deceived by Benton County Clerk and judge Burdett.
From Feb 2004 thru May 2005, Plaintiff was dragged through the family court in
Benton County. Excessive litigation and months of court hearings cost Plaintiff
thousands of dollars.
37. Plaintiff spent thousands of dollars to attend court hearing after court hearing.
Plaintiff had to file motion after motion to get visitation with his child Casey
Gipson.
38. Plaintiff even though there was a judgment for visitation, was alienated from the
39. The GAL Mr Stewart forced the Plaintiff to terminate a four hour visit for no
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apparent reason.
40. Plaintiff had every legal right to visit his child. Plaintiff did nothing to deserve
41. Plaintiff returned from Iraq expecting to have a normal life with his child. Sinse
his return, Plaintiff and his minor child has endured acts of inhumane treatment
and at the hands of court officials who have destroyed Plainitff’s life.
42. Plaintiff was forced to endure over nine months of excessive court hearings.
Many court hearings were like a revolving door having to motion for visitation
time and time again. Eroneous court motions filed by Defendants Jim Rice,
43. Plaintiff was treated un fairly when he returned from Iraq. Plaintiff’s civil rights
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2005
43. On May 10, 2005, Plaintiff Robert Gipson moved to Lincoln Missouri. Once again
Plaintiff endured at the hands of this unjust family court in Benton County Missouri,
months of court hearings and it was not unitl on or about November 2005 was Plaintiff
44. Defendant Brandy Wilkenson continued her manipulation and refused to listen to
Plaintiffs concerns about the neglect and abuse by her husband Jason Warren. To this
day Brandy Wilkenson has denied that she was beat by Jason warren in front of the minor
child and has ignored Plaintiffs concerns about the Sleep Apnea that Plasintiff has
observed since 2004. Plaintiff has observed the minor child Casey Gipson with Sleep
44. On or abour October 2005, Plaintiff was held hostage by Jason warren. Jason Warre
forced his way into the home of Robert Gipson in Lincoln Missouri. Prior to this Jason
warren has attacked the minor child in 2004 as well as the Plaintiff. Jason Warren has
driven wreclessley with the minor child in his van. Jason warren tried to slice the tires of
Plaintiff at the store in Cole Camp Missouri. Jason warren chased the Plaintiff and
attempted to restrain the minor child from going with the Plaintiff on numerous
scheduled visits. On fathers Day 2008, Jason warren took the child to St Louis Missouri
45. In the year 2005, Plaintiff took the minor child Casey Gipson to see Dr Julie Cahill.
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Numerous times sinse 2005, Plainitff has observed the minor child with Sleep Apnea and
Obstructed Airway. Many doctors at the Emergency room in Sedalia Missouri and
Columbia Missouri have stated on medical reports that Casey has Tonsil Idous, Upper
44. Brandy Wilkenson has been informed many times by Plaintiff that Casey Gpson
is sick. Plaintiff has called Dr Cahill and other doctors sinse 2004 and has taken
Casey Gpson to doctors in Colorado, Florida and Missouri. The Sleep Apnea
has been mild to severe. In 2009 Casey Gipsons Oxygen desaturation level was
88% for over three minutes. This is severe considering his prior health record at
shows mild to severe Sleep Apnea and Congestion. To date and as of Jan 2009,
Casey Gipson was taken to the Hospital in Kansas City Missouri where he was
diagnost with an URI Upper Respiratoy Infection. The URI increases the risk of
severe Sleep Apnea. If Sleep Apnea is not treated properly a child could have
long term medical problems with their heart, lungs and other medical issues and
at times even death. Plaintiff has informed the courts, doctors and Brandy
Wilkenson of what he and others have witnessed. Plaintiff has observed the
minor child with severe Sleep Apnea and has taken video to show the same.
Other witnesses have also observed such medical conditions with the minor
child.
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AT PLAINTIFFS HOUSE IN LINCOLN MISSOURI DATED OCTOBER 25, 2005.
2006
45. Former Senator Talent sent a letter to the former director of the Missouri
Childrens Division, Debra Scott as did thirdy party witnesses of their concerns
for Casey Gipson the minor child. Following these letters, Brandy Wilkenson
made the first false accusation that the Plaintiff sexually molested his child
Casey Gipson. This was done in order to modify the existing court order.
46. Shortly after the school principal Ms Peterson and her Pre-school staff from Cole
Camp Elementary Little Blue Byrd school, made yet another Hot Line call to the
Missouri Child Abuse HotLine. They accused Plaintiff for sexually molested his
child Casey Gipson. This is yet another conspiracy to slander and degrade
Plaintiff.
47. On Nov 2006, Brandy Wilkenson kidnapped the minor child from his pre-school.
This was a day when Plaintiff had a court ordered visitation. Prior to Nov 9,
2006, Plaintiff tried to call to speak to Casey Gipson and Brandy Wilkenosn
never answered the phone. Once again Brandy Wilkenson made yet another
false accusation to the Authorities that Plaintiff abused his child this time she
said that I sexually molested my son Casey Gipson. These actions by Defendant
Brandy Wilkenson, caused the minor child and father to be once again alienated
from each other. This caused sever mental anguish for both father and son.
Brandy Wilkenson brain washed the child to believe that his father was not
talking to him. During a brief viist at the Warsaw bowling alley, Casey Gipson
stated to the Plaintif and I quote “Mommy said that your not talking to me and
only to others” Plaintiff explained to his child that is not ture and he is only
talking to him. When Defendant Brandy Warren approached the Plaintiff and his
minor chjild at the Estes Bowling Aley, the minor child looked at the Defendant
and stated “See, my daddy is only talking to me” During another viist at the
Estes Bowling Alley, Defendant Brandy Wilkenson staged a scene out side the
Estes Bowling Alley and had Plaintiff arrested. Defendants Brandy Wilkenson
and her husband Jason Warren made a false Police report that Plaintiff pinned
the Defendant against her van. After months of court hearings and delays in the
Benton County Court House, Defendant was found not guilty. Once again
Defendants Wilkenson and Warren slandered and decived the Plaintiff to get
custody of the minor child and discredit Plaintiff. This was done just prior to a
civil hearing that involved custody of the minor child.
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48. Plaintiff contacted the Cole Camp Police and the Benton County Sherriffs
Department. Plaintiff was threatened by Benton County Sherrif Police Officer
Haun. As Plaintiff escorted Offcier Haun to a suspected place where the child
may be, Offcier Haun warned the Plaintiff not to go near the house. Officer
Haun conspired with Brandy Wilkenson and case workers from the Missouri
Childrens Division. Officer Haun works in the same Department as the other
Officers who have harrased and falsely arrested Plaintiff on April 26, 2009.
2007
49. On or about September 2007 and after approximately nine months of more court
and discredit Plaintiff. This was done to help Defendant Brandy Wilkenson to gain
50. The ruling to modify the shared custody and joint custody oder was Un-founded.
The new 2007 court order is and was changed drastically based on false
accusations. The accusations were unfounded and had not merits for such a change
51. The final court trial lasted for approximately eight hours. Out of these eight
hours, Plaintiff had approximately one hour for him and his witnesses to testify.
Defendant and her hired guns had approximately seven hours to control the court
hearings.
52. Defendants who testified confidently had contracts with case workers and the
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53. Deendants who are listed in this claim such ascase workers Paula Woolery,
Rhonda Talley, and Brenda Chapman were ordered not to appear in court as it would
affect their capacity as case workers. Their lawyer motioned the court to Quash
their subeona to appear. These case workers ignored their lawyer and appeared to
conspire with Brandy Wilkenson to help her change the modification order. These
case workers are the same one who said tha I had my son bite the head off a snake
with our clothes off. These same case workers stated that sinse I am a single father
that Plaintiff should take parenting classes. These same case workers were informed
by Plaintiff about the neglect and abuse and observed for them selves burn marks,
MONITOR HER PORN SITE. SHE IS THE ONLY ONE THAT CAN PUT
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2008
54. After the new court judgment in Sept 2007, Defendant Brandy Wilkenson once
again was in contempt of court. She continued to ignored the pleas of Plaintiff
Robert Gipson about his concerns. Plaintiff reported many times that the
Minor child Casey Gipson was having Sleep Apnea. Defendant deceived the
Plaintiff when she stated numerious times that she had a doctors appointment yet she
never did, Plaintiff called Dr cahill to inquire about the appointments and was
informed that no appointment were schaeduled. Defendant also canceled the E.N.T
visit at the Childrens Mercy Hospital. Defendant has accused Plaintiff of over
medicating his child and conducting an in home Sleep Study and conducting medical
Defendant will do what ever it takes to continue to destroy the relationship between
55. Defendant, Dr Julie Cahill failed to inform the court that the minor child Casey
Gipson had been treated with multiple prescriptions of antibiotics in 2005 and 2006
Plaintiff had been taking his child to her and other doctors and shared his concerns
about the on going prescriptions that were being used to treat his child. Casey
Gipson’s medical condition never changed in 2005, 2006 time frame. As of Jan
2009, the severe Sleep Apnea and Upper respritory continues to aile Plaintiffs child.
the minor child Dr Julie Cahill ignored Plaintiffs phone calls at the Emergency room
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and at her office in Sedalia Missouri as did her other staff doctors who work in her
office. Plaintiff on one occasion brought the minor child in for an ear burn. The
minor child was burnt by a cigarette and the male doctor refused to report this
incident even though the mother, child and case worker and Defendant Beverly
Chapman reported same to Plaintiff. Plaintiffs letter to Dr Cahill dated May 28,
2008 consisting of five pages describes various medical issues back to 2005.
56. Dr Julie Cahill was fully aware of the Sleep Study that Plaintiff requested for the
minor child in 2007 at the Children Mercy Hospital Dr Cahill knew from prior
medical report that the child had a history of congestion and Sleep Apnea. Dr
cahill
assisted James Johns in court by having her staff present medical records. James
Johns received a bundle of records approximately one inch high. The day before,
Plaintiff received records from the same staff worker that was only 1/8 inch high.
Medical records were with held from Plaintiff. Dr Cahill received a video and
written statements that were delivered to her office by Plaintiff. Plaintiff requested
that all scheduled appointments for the child be recorded and that Plaintiff be
notified. The same video showing the child in distress with sever Sleep Apnea was
June 2009 the minor child had an appointment and Plaintiff was never
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57. Defendants from the Benton County Sherriffs Department received from
Pllaintiff a Chain of Custody Letter dated Dec 5, 2008. Prior to this date Plaintiff
had already been arrested by this same Sherrifs Department and again on April 26,
2009 arrested and jailed by the Sherriffs Department. To date the Sherriffs
Department has made no attempt to investigate the Porn Site of Brandy Wilkenson.
Once again the Sherriffs Department has failed to protect the minor child. Plaintiff
PORN SITE DATED 2007, 2008 AND 2009. RON LEVY, MS HARTGRAVE,
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NOTE:
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2009
58. From the birth of the minor child, Brandy Wilkenson has manipulated her evil
ways to bring destruction against the Plaintiffs Robert Gipson and his son Casey
Gipson. NOT: SEE Exhibit# 1, letter by Plaintiff Robert Gipson dated Feb, 15,
2003at 2300 hrs. This was prepared prior to Plaintiff deploying to Iraq.
59. Presently the Plaintiff is now restricted to only five hours a month every other
Saturday and Sunday. This pending court order is destroying the natural bond that
was once enjoyed by Plaintiffs. Once again false accusations against Plaintiff and
60. Court rulings by judge Micheal Hendrickson have been unfounded and
Supervised visitation consisting of nine hours every other Saturday and Sunday. The
judge and his Clerk Ms Schultz attempted to gain favor from the Missouri Children’s
responded and stated that they do not have jurisdiction and could not assist. After
knowing this, judge Hendrickson then forced a five hour visitation schedule
every other Saturday and Sunday against Plaintiffs. This forced schedule is and has
Plaintiff stated that he will not subject the minor child to such imprisonment and that
is when Ms Schultz contacted her friend at the Warsaw Children’s Division and had
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a worker there to send a request to the Springfield Department of Children’s ivision.
Plaintiff went to the Warsaw office and requested copy of said letter. To date
Plaintiff has yet to obtain such letter. Ms Schultz stated that the request was made
by her. It appears that the Warsaw Office for the Childrens Division knows nothing
action by the Family Services to monitor a nine hour visitation of the Plaintiffs.
Plaintiff challenges this court to find any evidence that subjects the Plaintiffs to such
Plaintiff sates that all the information provided is true to the best of his
knowledge. Notice of Service is attached.
Robert Gipson
105 South Center ST
Lincoln Missouri 65338
660-723-4044 cell
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