1 Thomas C. Horne, Esq. SBA 002951 2 HORNE SLATON, PLLC 6720 North Scottsdale Road, Suite 285 3 Scottsdale, AZ 85253 4 Tel: (480) 483-2178 Fax: (480) 367-0691 5 Email:
[email protected] 6 Attorneys for Plaintiff 7 ARIZONA SUPERIOR COURT 8 MARICOPA COUNTY 9 DONALD M. SHOOTER, an 10 NO. individual, 11 COMPLAINT Plaintiff, 12 Civil Rights Violation, Including vs. Violation of 42 U.S.C. §1983, 13 Defamation, False Light Invasion of STATE OF ARIZONA; KIRK and Privacy, and Aiding and Abetting 14 and Conspiracy, and Wrongful JANAE ADAMS, husband and wife; 15 Termination JAVAN “J.D.” and HOLLY 16 MESNARD, husband and wife, JURY TRIAL DEMANDED 17 Defendant. 18 19 20 Plaintiff alleges as follows: 21 JURISDICTION AND VENUE 22 23 1. Plaintiff Donald Shooter was a member of the Arizona House of 24 Representatives, or at other times was a member of the Arizona Senate, and was for a 25 time Chairman of the Senate Appropriations Committee, Chairman of the House 26 27 Appropriations Committee and Chairman of the Joint Legislative Budget Committee. 28 2. During all times relevant, Defendant Kirk Adams was Chief of Staff to 1 the Governor of Arizona. 2 3. During all times relevant Defendant Javen Mesnard was Speaker of the 3 Arizona House of Representatives. 4 5 4. The actions of Adams and Mesnard were for the benefit of their respective 6 marital communities consisting of themselves and their respective wives.. 7 5. Jurisdiction and venue are proper in Maricopa County. 8 9 I. FACTUAL PREDICATE TO CLAIMS INCLUDING DEFENDANTS’ CORRUPT MOTIVES FOR THE VIOLATION OF CIVIL RIGHTS, 10 DEFAMATION, AND FALSE LIGHT, INVASION OF PRIVACY AND CONSPIRACY (AND PUBLIC RECORDS REQUEST VIOLATIONS?) 11 12 A.