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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 1 of 102

FILED
12-10-2018
CIRCUIT COURT
DANE COUNTY, WI
STATE OF WISCONSIN CIRCUIT COURT DANE COUNTY
2018CV000916
BRANCH 17
______________________________________________________________________________

WENDY ALISON NORA Case. No. 2018CV000916


310 Fourth Ave. S., #5010 Case Classification Codes:
Minneapolis, Minnesota 55415; Personal Injury - Other 30107
or Unclassified 30703
CHRISTOPHER KING
12048 Greenwood Ave.
Seattle, Washington 98133;

and

ROGER PETER RINALDI


22311 121st Street
Bristol, Wisconsin 53401;
Plaintiffs

v.

STATE OF WISCONSIN, a governmental entity, created by the Constitution of the State of


Wisconsin, approved by the delegates to the Constitutional Convention on February 1, 1848 and
adopted by the People on March 13, 1848, as amended from time to time, for claims of injury
arising under Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and “as
applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT and
the LAWYER REGULATION SYSTEM and for declaratory and injunctive relief allowed by
Supreme Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
STATE OF WISCONSIN
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
and
c/o Attorney General Brad Schimel
WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702

WISCONSIN SUPREME COURT, a governmental entity created by the Constitution of the State
of Wisconsin and empowered by Article VII thereof approved on February 1, 1848 and adopted
on March 13, 1848, as amended, from time to time, for facial and “as applied” unconstitutional
policies and procedures of the WISCONSIN SUPREME COURT and the LAWYER

1
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 2 of 102

REGULATION SYSTEM and for declaratory and injunctive relief allowed by Supreme Court of
Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
SUPREME COURT OF WISCONSIN
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
and
c/o Attorney General Brad Schimel
WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702

WISCONSIN SUPREME COURT, in its claimed administrative capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed legislative capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed enforcement capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed capacity as the creator and overseer of the
LAWYER REGULATION SYSTEM, by repeal and re-creation of SCR Chapters 21 and 22 on
October 1, 2000, as amended from time to time thereafter, for facially and “as applied”
unconstitutional provision by declaratory and injunctive relief allowed by Supreme Court of
Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

2
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 3 of 102

WISCONSIN SUPREME COURT, for claims of injury arising under Monell v. Department of
Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
LAWYER REGULATION SYSTEM
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

CHIEF JUSTICE PATIENCE D. ROGGENSACK, in her administrative capacity,


at her regular business address:
Chief Justice Patience D. Roggensack
WISCONSIN SUPREME COURT
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN OFFICE OF LAWYER REGULATION, a governmental entity created by the


WISCONSIN SUPREME COURT as the LAWYER REGULATION SYSTEM, by repeal and
re-creation of SCR Chapters 21 and 22 on October 1, 2000, as amended from time to time
thereafter, for claims of injury arising under Monell v. Department of Social Services, 436 U.S.
658 (1978) for unconstitutional policies and procedures of the LAWYER REGULATION
SYSTEM, both facial and “as applied”
Represented by the OFFICE OF THE ATTORNEY GENERAL, served by Hand-
Delivery;

WISCONSIN OFFICE OF LAWYER REGULATION, a Department of the WISCONSIN


SUPREME COURT for claims of injury arising under Monell v. Department of Social Services,
436 U.S. 658 (1978) for unconstitutional policies and procedures of the OFFICE OF LAWYER
REGULATION and as Respondeat Superior for violations of Wis. Stat. sec. 146.82 and 146.84
et seq. by the acts and omissions of employees and agents of the OFFICE OF LAWYER
REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, served by Hand-
Delivery;

KEITH SELLEN, individually for his unlawful acts and omissions, as an employee of the
OFFICE OF LAWYER REGULATION and as supervisor of the employees and agents of the
OFFICE OF LAWYER REGULATION for claims of injury arising under Monell v. Department
of Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
LAWYER REGULATION SYSTEM, both facial and “as applied”
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served;

3
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 4 of 102

TRAVIS J. STIEREN, individually and as an employee of the OFFICE OF LAWYER


REGULATION,
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served;

ROBERT J. KASIETA, individually, as member of the Ninth District Ethics Committee of the
OFFICE OF LAWYER REGULATION and as investigator for the OFFICE OF LAWYER
REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, served by publication,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;

THERON EDWARD PARSONS IV, individually, as member of the Ninth District Ethics
Committee of the LAWYER REGULATION SYSTEM and/or the OFFICE OF LAWYER
REGULATION and as investigator for the OFFICE OF LAWYER REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served;

EDWARD A. HANNAN, individually, as a member of HANNAN LEGAL, LLC


and as the former Chair of the Preliminary Review Committee (2011-2013)
of the WISCONSIN SUPREME COURT,
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served;

JAMES J. WINIARSKI, in his individual capacity, without subject matter jurisdiction or


competency to proceed under SCR Chapter 22 on and after August 16, 2016, at his regular place
of business:
James J. Winiarski
LAW OFFICES OF JAMES J. WINIARSKI
3625 W. Oklahoma Ave.
Milwaukee, Wisconsin 53215;

MARK W. RATTAN, individually and as an employee of LICHTFIELD CAVO, LLP, an Illinois


limited liability partnership, as agent for WELLS FARGO BANK, N.A., as Document Custodian
for multiple REMIC Trusts, as purported agent for HSBC BANK USA, N.A., as Trustee, by
service at his regular place of business
Mark W. Rattan
LITCHFIELD CAVO, LLP
13400 Bishop’s Lane, Suite 290
Brookfield, Wisconsin 53005-6224;

4
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 5 of 102

LICHTFIELD CAVO, LLP, an Illinois limited liability partnership, as agent for WELLS FARGO
BANK, N.A., and as Respondeat Superior for the actions of MARK RATTAN, by service upon
its registered agent at
LITCHFIELD CAVO, LLP
Mark W. Rattan, Registered Agent
13400 Bishop’s Lane, Suite 290
Brookfield, Wisconsin 53005-6224;

STEPHANIE L. DYKEMAN, as agent for WELLS FARGO BANK, N.A., as Respondeat


Superior for the actions of MARK W. RATTAN
Stephanie L. Dykeman
LITCHFIELD CAVO, LLP
13400 Bishop’s Lane, Suite 290
Brookfield, Wisconsin 53005-6224;

WELLS FARGO BANK, N.A., as Respondeat Superior for the actions of MARK W. RATTAN;
LITCHFIELD CAVO, LLP; and STEPHANIE L. DYKEMAN, agents for Wells Fargo Bank,
N.A. with its corporate headquarters at
WELLS FARGO BANK, N.A.
420 Montgomery Street,
San Francisco, California 94104
and at
WELLS FARGO BANK, N.A.
101 N. Phillips Avenue
Sioux Falls, South Dakota 57104

ATTORNEY GENERAL BRAD SCHIMEL


WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702
served personally by Hand-Delivery

JOHN DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein;

JANE DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein; and

CORPORATIONS A-Z, unidentified or unnamed corporations, partnerships, limited liability


companies and limited liability partnerships, participating in the acts complained of herein;
Defendants.

5
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 6 of 102

NOTICE OF MOTION AND MOTION OF PLAINTIFF WENDY ALISON NORA TO FILE


SECOND AMENDED COMPLAINT PURSUANT TO WIS. STAT. SEC. 802.09(1)

PLEASE TAKE NOTICE that the Plaintiffs, Wendy Alison Nora (Nora), Christopher

King (King) and Roger Peter Rinaldi (Rinaldi), in propria persona, and, pursuant to Wis. Stat.

sec. 802.09(1), in the interests of justice. Hearing on this Motion will be held on January 22,

2018 at 1:30 p.m. The Motion will be heard by telephone, as permitted by Wis. Stat.

sec. 807.13(1), unless any party to the action advises the Court of his or her intent to appear no

less than one week before the date set for the hearing.

NOW COME Plaintiffs Wendy Alison Nora (Nora), Christopher King (King) and Roger

Peter Rinaldi (Rinaldi), in propria persona and respectfully move the Court to allow them to file

their Second Amended Complaint attached hereto as Exhibit A in the interests of justice.

In support of this Motion for Leave to File the Second Amended Complaint, Plaintiffs

Nora, King and Rinaldi show the Court:

1. Wis. Stat. sec. 802.09(1) provides:

802.09 Amended and supplemental pleadings.


(1) Amendments. A party may amend the party’s pleading once as a matter of course at
any time within 6 months after the summons and complaint are filed or within the time
set in a scheduling order under s. 802.10. Otherwise a party may amend the pleading only
by leave of court or by written consent of the adverse party; and leave shall be freely
given at any stage of the action when justice so requires. . . .

2. Nora filed the initial Complaint in this action on April 10, 2018.

3. All Defendants named in the initial Complaint appeared by Assistant Attorney General

David C. Rice and moved to dismiss the initial Complaint.

6
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 7 of 102

4. Nora responded to the Motion to Dismiss and advised the Court that she intended to

avoid the argument regarding the application of the Notice of Claim statute, Wis. Stat. sec.

893.XXX by amending the initial Complaint to plead civil rights violations to which the Notice

of Claim requirements do not apply.

5. In Felder v. Casey, 487 U.S. 131, 153, 108 S.Ct. 2302, 101 L.Ed.2d 123 (1988), the

United States Supreme Court held:

In enacting § 1983, Congress entitled those deprived of their civil rights to recover
full compensation from the governmental officials responsible for those deprivations. A
state law that conditions that right of recovery upon compliance with a rule designed to
minimize governmental liability, and that directs injured persons to seek redress in the
first instance from the very targets of the federal legislation, is inconsistent in both
purpose and effect with the remedial objectives of the federal civil rights law. Principles
of federalism, as well as the Supremacy Clause, dictate that such a state law must give
way to vindication of the federal right when that right is asserted in state court.

Accordingly, the judgment of the Supreme Court of Wisconsin is reversed, and


the case is remanded for further proceedings not inconsistent with this opinion.

5. Nora had been aware for some time before she filed her initial Complaint of the

desires or intentions of Christopher King (King) of Seattle, Washington and Roger Peter Rinaldi

(Rinaldi) of Bristol, in Kenosha County, Wisconsin to bring civil rights claims against the certain

of the Defendants named by Nora in the initial Complaint.

6. King and Rinaldi claim to have been damaged by the conduct of the some of the

Defendants identified in Nora’s April 10, 2018 Complaint as well as by other participants in the

Wisconsin Lawyer Regulation System (LRS) who are alleged to have caused injury to Nora and

nongovernment actors acting in concert with them and influencing the state actors to conceal

their criminal and/or fraudulent misconduct.

7. King and Rinaldi joined in Nora’s timely filed First Amended Complaint.

7
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 8 of 102

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 9 of 102

SEPARATE SIGNATURE PAGES FOR


CO-PLAINTIFFS CHRISTOPHER KING AND ROGER PETER RINALDI FOLLOW

9
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 10 of 102

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 12 of 102

EXHIBIT A
PROPOSED SECOND AMENDED COMPLAINT
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 13 of 102

STATE OF WISCONSIN CIRCUIT COURT DANE COUNTY


BRANCH 17
______________________________________________________________________________

WENDY ALISON NORA Case. No. 2018CV000916


310 Fourth Ave. S., #5010 Case Classification Codes:
Minneapolis, Minnesota 55415; Personal Injury - Other 30107
or Unclassified 30703
CHRISTOPHER KING
12048 Greenwood Ave.
Seattle, Washington 98133;

and

ROGER PETER RINALDI


22311 121st Street
Bristol, Wisconsin 53401;
Plaintiffs

v.

STATE OF WISCONSIN, a governmental entity, created by the Constitution of the State of


Wisconsin, approved by the delegates to the Constitutional Convention on February 1, 1848 and
adopted by the People on March 13, 1848, as amended from time to time, for claims of injury
arising under Monell v. Department of Social Services, 436 U.S. 658 (1978) and for facial and
“as applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT
and the WISCONSIN LAWYER REGULATION SYSTEM (LRS) and for declaratory and
injunctive relief allowed by Supreme Court of Virginia v. Consumers Union of the United States,
Inc., 446 U.S. 719 (1980)
STATE OF WISCONSIN
c/o Attorney General Brad Schimel
WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702;

WISCONSIN SUPREME COURT, a governmental entity created by the Constitution of the State
of Wisconsin and empowered by Article VII thereof approved on February 1, 1848 and adopted
on March 13, 1848, as amended, from time to time, for facial and “as applied” unconstitutional
policies and procedures of the WISCONSIN SUPREME COURT and the WISCONSIN
LAWYER REGULATION SYSTEM (LRS) and for declaratory and injunctive relief allowed by
Supreme Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)

1
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 14 of 102

SUPREME COURT OF WISCONSIN


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;
and
SUPREME COURT OF WISCONSIN
c/o Attorney General Brad Schimel
WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702;

WISCONSIN SUPREME COURT, in its claimed capacity as the creator and principal of the
WISCONSIN LAWYER REGULATION SYSTEM (LRS), by repeal and re-creation of SCR
Chapters 21 and 22 on October 1, 2000, as amended from time to time thereafter, for facially and
“as applied” unconstitutional provision by declaratory and injunctive relief allowed by Supreme
Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980),
WISCONSIN SUPREME COURT
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, for claims of injury arising under Monell v. Department of
Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
WISCONSIN LAWYER REGULATION SYSTEM (LRS),
WISCONSIN SUPREME COURT
c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed administrative capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed legislative capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

2
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 15 of 102

WISCONSIN SUPREME COURT, in its claimed investigative capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed prosecutorial/adjudictory capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN SUPREME COURT, in its claimed appellate capacity,


c/o Patience D. Roggensack, Chief Justice
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

CHIEF JUSTICE PATIENCE D. ROGGENSACK, in her administrative capacity,


at her regular business address:
Chief Justice Patience D. Roggensack
WISCONSIN SUPREME COURT
16 East State Capitol
P.O. Box 1688
Madison, Wisconsin 53701-1688;

WISCONSIN OFFICE OF LAWYER REGULATION, a governmental entity created by the


WISCONSIN SUPREME COURT as the LAWYER REGULATION SYSTEM, by repeal and
re-creation of SCR Chapters 21 and 22 on October 1, 2000, as amended from time to time
thereafter, for claims of injury arising under Monell v. Department of Social Services, 436 U.S.
658 (1978) for unconstitutional policies and procedures of the LAWYER REGULATION
SYSTEM, both facial and “as applied”
Represented by the OFFICE OF THE ATTORNEY GENERAL, previously served by
Hand-Delivery, appearing without moving to dismiss for lack of personal jurisdiction or
insufficient service of process;

WISCONSIN OFFICE OF LAWYER REGULATION, a Department of the WISCONSIN


SUPREME COURT for claims of injury arising under Monell v. Department of Social Services,
436 U.S. 658 (1978) for unconstitutional policies and procedures of the OFFICE OF LAWYER
REGULATION and as Respondeat Superior for violations of Wis. Stat. sec. 146.82 and 146.84
et seq. by the acts and omissions of employees and agents of the OFFICE OF LAWYER
REGULATION

3
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 16 of 102

Represented by the OFFICE OF THE ATTORNEY GENERAL, previously served by


Hand-Delivery, appearing without moving to dismiss for lack of personal jurisdiction or
insufficient service of process;

KEITH SELLEN, individually for his unlawful acts and omissions, as an employee of the
OFFICE OF LAWYER REGULATION and as supervisor of the employees and agents of the
OFFICE OF LAWYER REGULATION for claims of injury arising under Monell v. Department
of Social Services, 436 U.S. 658 (1978) for unconstitutional policies and procedures of the
LAWYER REGULATION SYSTEM, both facial and “as applied”
Represented by the OFFICE OF THE ATTORNEY GENERAL, previously personally
served, appearing without moving to dismiss for lack of personal jurisdiction or
insufficient service of process;

TRAVIS J. STIEREN, individually and as an employee of the OFFICE OF LAWYER


REGULATION,
Represented by the OFFICE OF THE ATTORNEY GENERAL, previously personally
served, appearing without moving to dismiss for lack of personal jurisdiction or
insufficient service of process;

ROBERT J. KASIETA, individually, as member of the Ninth District Ethics Committee of the
OFFICE OF LAWYER REGULATION and as investigator for the OFFICE OF LAWYER
REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, served by publication,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;

THERON EDWARD PARSONS IV, individually, as member of the Ninth District Ethics
Committee of the LAWYER REGULATION SYSTEM and/or the OFFICE OF LAWYER
REGULATION and as investigator for the OFFICE OF LAWYER REGULATION
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;

EDWARD A. HANNAN, individually, as a member of HANNAN LEGAL, LLC


and as the former Chair of the Preliminary Review Committee (2011-2013)
of the WISCONSIN SUPREME COURT,
Represented by the OFFICE OF THE ATTORNEY GENERAL, personally served,
appearing without moving to dismiss for lack of personal jurisdiction or insufficient
service of process;

DAVID M. POTTEIGER, individually, as a former employee of BASS & MOGLOWSKY, S.C.,


and as claimed agent for FIDELITY NATIONAL TITLE COMPANY with his regular business
address at

4
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 17 of 102

David M. Potteiger
WALCHESKE & LUZI LLC
15850 W Bluemound Road, Suite 304
Brookfield, Wisconsin 53005-6008;
who, at all times relevant to the proceedings, had his principal place of business at
BASS & MOGLOWSKY, S.C.
501 West Northshore Drive, Suite 300
Milwaukee, Wisconsin 53217;

STEVEN W. MOGLOWSKY, individually, as an employee of BASS & MOGLOWSKY, S.C.,


as supervisor of David M. Potteiger as Respondeat Superior, at his regular business address:
Steven W. Moglowsky
BASS & MOGLOWSKY, S.C.
501 West Northshore Drive, Suite 300
Milwaukee, Wisconsin 53217;

BASS & MOGLOWSKY, S.C., as claimed agent for FIDELITY NATIONAL TITLE
COMPANY, and as Respondeat Superior for the actions of DAVID M. POTTEIGER and
STEVEN W. MOGLOWSKY, with its principal place of business at
BASS & MOGLOWSKY, S.C.
501 West Northshore Drive, Suite 300
Milwaukee, Wisconsin 53217;

FIDELITY NATIONAL TITLE COMPANY, a California corporation, in its corporate capacity


and as Respondeat Superior for the actions of DAVID M. POTTEIGER, and
BASS & MOGLOWSKY, S.C., claiming to be its agent
d/b/a FIDELITY NATIONAL FORECLOSURE AND BANKRUPTCY SERVICES at
1270 Northland Drive, Suite 200
Mendota Heights, Minnesota 55120
with its registered agent at
FIDELITY NATIONAL TITLE COMPANY
c/o C T CORPORATION SYSTEM
818 W 7th Street, Suite 930
Los Angeles, California 90017;

SHERYL ST. ORES, Assistant Litigation Counsel, individually and as an employee of the
WISCONSIN OFFICE OF LAWYER REGULATION, with her regular business address at
Sheryl St. Ores
OFFICE OF LAWYER REGULATION
110 East Main Street, Suite 315
Madison, Wisconsin 53703;

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PAUL W. SCHWARZENBART, individually and in his capacity as retained counsel for the
OFFICE OF LAWYER REGULATION, acting as an agent for the WISCONSIN SUPREME
COURT with his regular place of business at
PAUL W. SCHWARZENBART
222 W. Washington Ave., Suite 900
Madison, Wisconsin 53703;

LISA C. GOLDMAN, individually and in her capacity as the Referee appointed by the
WISCONSIN SUPREME COURT, acting as an agent for the WISCONSIN SUPREME COURT
with her regular place of business at
Lisa C. Goldman
DAVEY & GOLDMAN
5609 Medical Circle, Suite 101
Madison, Wisconsin 53719;

JAMES J. WINIARSKI, in his individual capacity, without subject matter jurisdiction or


competency to proceed under SCR Chapter 22 on and after August 16, 2016, with his regular
place of business at
James J. Winiarski
LAW OFFICES OF JAMES J. WINIARSKI
3625 W. Oklahoma Ave.
Milwaukee, Wisconsin 53215,
personally served on December 10, 2018;

MARK W. RATTAN, individually and as an employee of LICHTFIELD CAVO, LLP, an Illinois


limited liability partnership, as agent for WELLS FARGO BANK, N.A., as Document Custodian
for multiple REMIC Trusts, as purported agent for HSBC BANK USA, N.A., as Trustee, with
his regular place of business at
Mark W. Rattan
LITCHFIELD CAVO, LLP
250 East Wisconsin Ave., Suite 800
Milwaukee, Wisconsin 53202,
personally served on December 9, 2018;

STEPHANIE L. DYKEMAN, as agent for WELLS FARGO BANK, N.A., as Respondeat


Superior for the actions of MARK W. RATTAN
Stephanie L. Dykeman
LITCHFIELD CAVO, LLP
250 East Wisconsin Ave., Suite 800
Milwaukee, Wisconsin 53202
service of process was avoided on December 9, 2018;

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LICHTFIELD CAVO, LLP, an Illinois limited liability partnership, as agent for WELLS FARGO
BANK, N.A., and as Respondeat Superior for the actions of MARK RATTAN, STEPHANIE
DYKEMAN, and its former employee, BRAD MARKVARDT, with its principal place of
business located at
LITCHFIELD CAVO, LLP
250 East Wisconsin Ave., Suite 800
Milwaukee, Wisconsin 53202
personal service pending through its registered agent, C T Corporation System, 301 S. Bedford
Street #213, Madison, Wisconsin 53703;

WELLS FARGO BANK, N.A., in its corporate capacity and as Respondeat Superior for the
actions of MARK W. RATTAN, LITCHFIELD CAVO, LLP, and STEPHANIE L. DYKEMAN,
agents for Wells Fargo Bank, N.A. with its principal office located at
WELLS FARGO BANK, N.A.
420 Montgomery Street,
San Francisco, California 94104
and its corporate headquarter located at
WELLS FARGO BANK, N.A.
101 N. Phillips Avenue
Sioux Falls, South Dakota 57104;

ATTORNEY GENERAL BRAD SCHIMEL


WISCONSIN DEPARTMENT OF JUSTICE
114 East State Capitol
Madison, Wisconsin 53702;

JOHN DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein;

JANE DOES 1-20, unidentified or unnamed individuals who acted in their individual, official
and employment capacities in the acts complained of herein; and

CORPORATIONS A-Z, unidentified or unnamed corporations, partnerships, limited liability


companies and limited liability partnerships, participating in the acts complained of herein;
Defendants.

(PROPOSED) SECOND AMENDED COMPLAINT

NOW COME the Plaintiffs Wendy Alison Nora (hereinafter Nora), Christopher King,

(hereinafter King), Roger Peter Rinaldi (hereinafter Rinaldi), all in propria persona, but not as

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agents of each other, as well as any others who may join in this action or who may appear as

Intervenors, and for their Complaint against the Defendants named above, and Defendants yet to

be named, allege and show the Court:

JURISDICTION AND VENUE

1. This Court has general jurisdiction over the claims and the parties under Article

Seven, Section 8 of the Wisconsin Constitution, Wis. Stat. Chapter 133, Wis. Stat. sec. 146.84,

42 U.S.C. sec. 1983, 18 U.S.C. sec. 1961 et seq. and has subject matter jurisdiction over this

action.

2. This Court has personal jurisdiction over the Defendants named in the April 9, 2018

Complaint (the originally-named Defendants) which is hereby amended, all of whom were

personally served or served by publication.

3. The July 18, 2018 Motion to Dismiss does not challenge or reserve the right to

challenge personal jurisdiction over any of the originally-named Defendants or the sufficiency of

process upon any of them, and, therefore, objection to personal jurisdiction, if any, is waived.

4. Venue of this Court is proper because a substantial part of the conduct complained of

transpired in the County of Dane, State of Wisconsin.

5. The majority of the Defendants named herein reside in or have their primary place of

business in the County of Dane, State of Wisconsin.

6. All of the Defendants have substantial contacts with the State of Wisconsin.

7. Service of process on the new parties Defendant named in the October 9, 2018 First

Amended Complaint (the first set of newly named Defendants) is pending and, to the extent

service is accomplished, Affidavits of Service will be filed with the Court.

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8. When this Second Amended Complaint is allowed to be filed, service of process upon

the Defendants who were not previously named in the original Complaint or the First Amended

Complaint will be initiated.

THE PARTIES, THEIR RELATIONSHIPS AND


FACTS COMMON TO ALL CAUSES OF ACTION

Parties Plaintiff

9. Plaintiff Wendy Alison Nora (Nora) is an adult and is presently a resident of the

County of Dane, State of Wisconsin and has her principal business office at 310 Fourth Ave. S.,

Suite 5010, in Minneapolis, Minnesota and joins in this action as to Counts One, Two, Three,

Four, Five, Seven, Eight, Nine, Ten, Eleven, Twelve, Thirteen and Fourteen, below.

10. Plaintiff Christopher King, (hereinafter King) is an adult and is presently a resident of

the County of King, State of Washington and proceeds separately as to Count Six, and joins in

Counts Ten, Eleven, Twelve and Fourteen, below.

11. Plaintiff Roger Peter Rinaldi (hereinafter Rinaldi) is an adult and is a citizen of the

County of Kenosha, State of Wisconsin and joins in this action as to Counts Seven, Eight, Nine,

Ten, Eleven, Twelve and Fourteen, below.

The Parties Defendants

12. Defendant STATE OF WISCONSIN is a governmental entity, created by the

Constitution of the State of Wisconsin, approved by the delegates to the Constitutional

Convention on February 1, 1848 and adopted by the People on March 13, 1848, as amended from

time to time, for claims of injury arising from violations of the Plaintiffs’ constitutional rights

pursuant to Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and “as

applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT and

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the LAWYER REGULATION SYSTEM (LRS).

13. The STATE OF WISCONSIN is subject to this action for declaratory and injunctive

relief as allowed by Supreme Court of Virginia v. Consumers Union of the United States, Inc.,

446 U.S. 719 (1980).

14. Defendant WISCONSIN SUPREME COURT is a governmental entity, created by

the Constitution of the State of Wisconsin, approved by the delegates to the Constitutional

Convention on February 1, 1848 and adopted by the People on March 13, 1848, as amended from

time to time, for claims of injury arising from violations of the Plaintiffs’ constitutional rights

pursuant to Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and “as

applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT and

the LAWYER REGULATION SYSTEM (LRS).

15. The WISCONSIN SUPREME COURT is subject to this action for declaratory and

injunctive relief as allowed by Supreme Court of Virginia v. Consumers Union of the United

States, Inc., 446 U.S. 719 (1980).

16. Defendant WISCONSIN SUPREME COURT does not enjoy absolute immunity for

its administrative action and is joined in its administrative capacity, for claims of injury arising

from violations of the Plaintiffs’ constitutional rights pursuant to Monell v. Department of Social

Services, 436 U.S. 658 (1978) for facial and “as applied” unconstitutional policies and

procedures of the WISCONSIN SUPREME COURT and the LAWYER REGULATION

SYSTEM.

17. The WISCONSIN SUPREME COURT is subject to this action for declaratory and

injunctive relief as allowed by Supreme Court of Virginia v. Consumers Union of the United

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States, Inc., 446 U.S. 719 (1980).

18. Defendant WISCONSIN SUPREME COURT is joined in its legislative capacity, for

a determination of the constitutionality of certain provisions of SCR Chapters 21 and 22 and for

injunctive relief under the authority of Supreme Court of Virginia v. Consumers Union of the

United States, 446 U.S. 719 (1980).

19. Defendant WISCONSIN SUPREME COURT is joined in its enforcement capacity,

for declaratory and injunctive relief under the authority of Supreme Court of Virginia v.

Consumers Union of the United States, 446 U.S. 719 (1980).

20. Defendant WISCONSIN SUPREME COURT is a governmental entity which is

covered by the prohibitions set forth in the Wisconsin Organized Crime Control Act (WOCCA)

at Wis. Stat. sec. 946.80-946.88 by the express terms of Wis. Stat. sec. 946.82(2) and is liable for

the conduct of its employees and agents in violation of the predicate acts of racketeering defined

at Wis. Stat. sec. 946.82(4) in its supervisory capacity pursuant to Wis. Stat. sec. 946.83 and/or

946.85.

21. Defendant WISCONSIN SUPREME COURT does not enjoy absolute immunity in

its supervisory capacity as a matter of law under Wis. Stat. sec. 946.83 and/or 946.85 and is

specifically liable for violations of Wis. Stat. sec. 946.80-946.87 under Wis. Stat. sec. 946.82(2).

22. Defendant Chief Justice Patience D. Roggensack, is the Chief Justice of the

Defendant WISCONSIN SUPREME COURT and Chief Justice Roggensack is joined in her

supervisory capacity for the acts in violation of Wis. Stat. secs. by participants in the LAWYER

REGULATION SYSTEM (LRS).

23. Chief Justice Patience D. Roggensack, is the Chief Justice of the Defendant

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WISCONSIN SUPREME COURT and Chief Justice Roggensack is joined in her administrative

capacity for failure to train and supervise the various components of the WISCONSIN

LAWYER REGULATION SYSTEM (LRS) to assure that it operates as required by the United

States Constitution and the Wisconsin Constitution, to the extent that SCR Chapters 21 and 22

are in compliance therewith.

24. The Defendant WISCONSIN SUPREME COURT was created by the Wisconsin

Constitution in 1848 and has original jurisdiction over certain matters and is the highest level of

appellate review in the State of Wisconsin.

25. In accordance with amendments to Article Seven of the Wisconsin Constitution, the

Defendant WISCONSIN SUPREME COURT is part of the Wisconsin Unified Court System.

26. Upon information and belief, the Defendant WISCONSIN SUPREME COURT

created the LAWYER REGULATION SYSTEM (LRS) without any legislative or executive

authority, replacing the former Wis. Stat. secs. 256.283-256.293.

27. Upon information and belief, the Defendant WISCONSIN SUPREME COURT

claims the authority to create and operate the WISCONSIN LAWYER REGULATION

SYSTEM (LRS) under its inherent powers.

28. Defendant OFFICE OF LAWYER REGULATION (OLR) is a part of the

WISCONSIN LAWYER REGULATION SYSTEM (LRS). See attached Exhibit A.

29. OLR operates both the investigative process and the prosecutorial process of the LRS

as set forth in Supreme Court Rule (SCR) 22.01-22.48.

30. The WISCONSIN SUPREME COURT acts through and is responsible for

supervising the Preliminary Review Committee (PRC) and the preliminary review panels

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operating as the charging authority under SCR 22.11(2).

31. The WISCONSIN SUPREME COURT also acts through and is responsible for

appointing the referees to conduct disciplinary proceedings under SCR 22.14(3) and is, therefore,

responsible for supervising the referees.

32. In its claimed inherent authority, the WISCONSIN SUPREME COURT purports to

have endowed referees with the powers of circuit court judges, presiding in civil matters. SCR

22.16(1) but who actually function in a prosecutorial function, as applied.

33. The WISCONSIN SUPREME COURT acts as the appellate court in lawyer

disciplinary proceedings under SCR 22.17(1).

34. The WISCONSIN SUPREME COURT, acting through its agents, is the

investigating, charging, and prosecuting authority, its appointed agent as referee is the trier of

fact, and it acts as the appellate court pursuant to SCR 21.13.

35. Defendant Keith Sellen (Sellen) is an adult resident of Dane County, Wisconsin,

whose principal business address is in Dane County, Wisconsin at OLR, 110 East Main Street,

Suite 315, Madison, Wisconsin 53703.

36. At all times relevant to the acts, omissions, occurrences and transactions complained

of herein, Sellen was the Director of OLR.

37. Sellen is joined in his individual and official capacities.

38. Sellen is joined in his official capacity for failure to train and supervise the

employees and agents of the OLR to prevent violations of Wis. Stat. secs. 146.82(5)(c) and

146.84(1)(b), (bm) and 146.84(2)(a)2., which deprived Nora of her right to Equal Protection of

the Laws of the State of Wisconsin guaranteed by the Fourteenth Amendment to the United

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States Constitution in violation of 42 U.S.C. sec. 1983.

39. Sellen is joined in his individual capacity for violations of the civil rights of Nora,

King and Rinaldi, contrary to 42 U.S.C. sec.1983, as set forth herein.

40. Sellen is individually liable for his participation in the civil rights violations of the

Plaintiffs and for failing to prevent the violation of each of the Plaintiffs’ civil rights as described

herein.

41. Sellen is individually liable for his violations of the Wisconsin Organized Crime

Control Act (WOCCA) at Wis. Stat. sec. 946.82(4), for the purpose of concealing the operation

of the Fraudulent Foreclosure Enterprise in the State of Wisconsin in which the property rights of

Wisconsin residents and citizens have been taken as the result of false pleadings, supported by

forged documents and authenticated by falsely sworn affidavits submitted by foreclosure

claimants represented by Wisconsin-licensed lawyers in order to avoid his official responsibility

to investigate the operation of the Fraudulent Foreclosure Enterprise hereinafter referred to as the

Fraudulent Foreclosure Enterprise.

42. Sellen is joined in this action in his individual capacity for his acts in furtherance of

the Fraudulent Foreclosure Enterprise.

43. Defendant Travis J. Stieren (Stieren) is an adult resident of Dane County, Wisconsin,

who is employed as an Investigator for OLR and whose primary place of business is located at

110 East Main Street, Suite 315, Madison, Wisconsin 53703.

44. At all times relevant to the acts, omissions, occurrences and transactions complained

of herein, Stieren was an employee of OLR and Sellen was his ultimate supervisor.

45. Stieren is joined in his individual capacity for his violations of Wis. Stat. secs.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 27 of 102

146.82(5)(c) and 146.84(1)(b) or (bm) and 146.84(2)(a)2. which deprived Nora of her right to

Equal Protection of the Laws of the State of Wisconsin guaranteed by the Fourteenth

Amendment to the United States Constitution in violation of 42 U.S.C. sec. 1983.

46. Stieren is joined in his individual capacity for his violation of Nora’s right to be free

from unreasonable searches and seizures guaranteed by the Fourth Amendment to the United

States Constitution and Article One, Section 11 of the Wisconsin Constitution.

47. Stieren is individually liable for his violation of Nora’s rights to Due Process

guaranteed by the Fourteenth Amendment to the United States Constitution and Article One,

Section 1 of the Wisconsin Constitution.

48. Stieren is joined in this action in his individual capacity for his acts in furtherance of

the Fraudulent Foreclosure Enterprise.

49. Defendant Robert J. Kasieta (Kasieta) is an adult resident of Dane County,

Wisconsin, whose principal business address is in Dane County, Wisconsin at KASIETA

LEGAL GROUP, LLC, 559 D’Onofrio Drive, Suite 222, Madison, Wisconsin 53719-2842.

50. At all times relevant to the acts, omissions, occurrences and transactions complained

of herein, Kasieta was a member of the District Nine Ethics Committee created under SCR

Chapter 21 and purporting to function pursuant to SCR Chapter 22.

51. Kasieta is joined in his individual capacity for his violations of Wis. Stat. secs.

146.82(5)(c) and 146.84(1)(b) or (bm) and 146.84(2)(a)2. which deprived Nora of her right to

Equal Protection of the Laws of the State of Wisconsin guaranteed by the Fourteenth

Amendment to the United States Constitution in violation of 42 U.S.C. sec. 1983.

52. Kasieta is joined in his individual capacity for his violation of Nora’s right to be free

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from unreasonable searches and seizures guaranteed by the Fourth Amendment to the United

States Constitution and Article One, Section 11 of the Wisconsin Constitution.

53. Kasieta is individually liable for his violation of Nora’s rights to Due Process

guaranteed by the Fourteenth Amendment to the United States Constitution and Article One,

Section 1 of the Wisconsin Constitution.

54. Kasieta is joined in this action in his individual capacity for his acts in furtherance of

the Fraudulent Foreclosure Enterprise.

55. Defendant Theron Edward Parsons IV (Parsons) is an adult resident of Dane County,

Wisconsin, who, upon information and belief, does business is in Dane County, Wisconsin at

702 N. Blackhawk Ave., Suite #104, Madison, Wisconsin 53705 and/or at Midwest Center for

Human Services, 313 Price Place, Suite 10, Madison, Wisconsin 53705 .

56. Upon information and belief, at all times relevant to the acts, omissions, occurrences

and transactions complained of herein, Parsons was a member of the District Nine Ethics

Committee created under SCR Chapter 21 and purporting to function pursuant to SCR

Chapter 22.

57. Parsons is joined in his individual capacity for his violations of Nora’s rights to

Equal Protection of the Laws of the State of Wisconsin under Wis. Stat. secs. 146.82(5)( c) and

146.84(1)(b) or (bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United

States Constitution and Article One, Section 1 of the Wisconsin Constitution.

58. Parsons is joined in his individual capacity for the unreasonable search and seizure of

Nora’s confidential medical information by the knowing unlawful disclosure thereof without her

consent required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the

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Fourth Amendment to the United States Constitution.

59. Parsons is joined in this action in his individual capacity for his acts in furtherance of

the Fraudulent Foreclosure Enterprise.

60. Defendant Edward A. Hannan (Hannan) is an adult resident of the State of

Wisconsin, whose residence is in Waukesha County and whose principal business address is in

Waukesha County, Wisconsin at HANNAN LEGAL, LLC, 1701 Pearl Street, Suite 11M,

Waukesha, Wisconsin 53186-5600.

61. From on or about July 1, 2011 to on or about June 30, 2013 (the period relevant to

the acts, omissions, occurrences and transactions complained of herein as to Hannan), Hannan

was the Chairperson of the Preliminary Review Committee (PRC) established by the Wisconsin

Supreme Court under SCR Chapter 21 and purporting to function pursuant to SCR Chapter 22.

62. Hannan is joined in his individual capacity for his violations of Nora’s rights to

Equal Protection of the Laws of the State of Wisconsin under Wis. Stat. secs. 146.82(5)(c) and

146.84(1)(b) or (bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United

States Constitution and Article One, Section 1 of the Wisconsin Constitution.

63. Hannan is joined in his individual capacity for the unreasonable search and seizure of

Nora’s confidential medical information by the knowing unlawful disclosure thereof without her

consent required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the

Fourth Amendment to the United States Constitution.

64. Hannan is joined in this action in his individual capacity for his acts in furtherance of

the Fraudulent Foreclosure Enterprise.

65. Defendant David M. Potteiger (Potteiger) is an adult resident of the State of

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Wisconsin, is admitted to practice law before the Wisconsin Supreme Court and is believed to be

a resident of Milwaukee County.

66. Potteiger is joined in this action in his individual capacity for violations of Wis. Stat.

secs. 146.84, 943.20(1)(d), 943.38(1), 946.30, 946.30, 946.82(4) incorporating 18 U.S.C. secs.

1341, 1343, via 18 U.S.C. sec. 1961(1), and as a former employee of BASS & MOGLOWSKY,

S.C. (BASS & MOGLOWSKY), 501 West Northshore Drive, Suite 300, Milwaukee, Wisconsin

53217.

67. Potteiger claimed to be an agent for FIDELITY NATIONAL TITLE COMPANY.

68. Potteiger purported to represent RESIDENTIAL FUNDING COMPANY, LLC

(RFC) in a foreclosure action against Nora’s home located at 6931 Old Sauk Road, in Madison,

Wisconsin 53717 in Dane County Circuit Court Case No. 2009CV001096 titled Residential

Funding Company, LLC v. Nora, et al. (the Dane County Case).

69. Potteiger testified on April 5, 2016 that BASS & MOGLOWSKY was retained by an

entity known and identified as “GMAC RESCAP” to represent RFC.

70. There is not now and never has been an entity known as “GMAC RESCAP” in

existence.

71. Potteiger is joined in this action in his individual capacity for his acts in furtherance

of the Fraudulent Foreclosure Enterprise.

72. One of the techniques used by the Fraudulent Foreclosure Enterprise is to falsely

identify foreclosure plaintiffs.

73. Whoever wrote the PER CURIAM Opinion and Order of Wisconsin Supreme Court

intentionally conflated the identities of the Plaintiff in the foreclosure action, Residential Funding

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Company, LLC (RFC) with GMAC Mortgage Company, LLC (GMACM), which Nora identified

as the servicing agent responsible for negotiating the Loan Repayment Agreement (Agreement)

into a blended entity, RFC/GMAC, and attributed knowledge of the relationship between RFC

and GMACM (identified by the Court as GMAC) to Nora which Nora did not and does not have.

RFC was the Plaintiff and its relationship to GMACM was unknown to Nora at the time of the

negotiation of the Agreement.

74. The Agreement was negotiated with a representative of GMACM, which was not a

party to the foreclosure action, was not known to be represented by Potteiger and was known to

by Nora to be the successor in interest to Homecomings Financial, LLC, the servicing agent for

Aegis Mortgage Corporation, a bankrupt entity.

75. Defendant Steven M. Moglowsky (Moglowsky) is an adult resident of the State of

Wisconsin and is believed to be a resident of Milwaukee County.

76. Moglowsky is joined in this action in his individual capacity for violations of Wis.

Stat. sec. 146.84 and as an employee of BASS & MOGLOWSKY, S.C., 501 West Northshore

Drive, Suite 300, Milwaukee, Wisconsin 53217, as claimed agent for FIDELITY NATIONAL

TITLE COMPANY, and as supervisor of Potteiger for statutory liability pursuant to Wis. Stat.

secs. 946.83 and 946.85 and under the doctrine of Respondeat Superior for Potteiger’s violations

of Wis. Stat. sec. 148.84.

77. Moglowsky is joined in this action in his individual capacity for his acts in

furtherance of the Fraudulent Foreclosure Enterprise, including, but not limited to allowing the

email server of BASS & MOGLOWSKY, S.C. to be destroyed while litigation was pending or

falsely stating that the email server had been destroyed, if it was not.

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78. Defendant BASS & MOGLOWSKY, S.C., c/o Steven M. Moglowsky, Registered

Agent, 501 West Northshore Drive, Suite 300, Milwaukee, Wisconsin 53217, is a Wisconsin

professional corporation.

79. BASS & MOGLOWSKY, S.C. is joined in this action as claimed agent for

FIDELITY NATIONAL TITLE COMPANY, and as supervisor of Potteiger and Moglowsky for

statutory liability pursuant to Wis. Stat. secs. 946.83 and 946.85 and for violations of Wis. Stat.

sec. 146.84 by Potteiger and Moglowsky under the doctrine of Respondeat Superior.

80. FIDELITY NATIONAL TITLE COMPANY is a California corporation d/b/a

FIDELITY NATIONAL FORECLOSURE AND BANKRUPTCY SERVICES at 1270

Northland Drive, Suite 200 Mendota Heights, Minnesota 55120, with its corporate headquarters

located at 601 Riverside Ave., Jacksonville Florida 32204.

81. FIDELITY NATIONAL TITLE COMPANY d/b/a FIDELITY NATIONAL

FORECLOSURE AND BANKRUPTCY SERVICES located at 1270 Northland Drive, Suite 200

Mendota Heights, Minnesota 55120, with its affiliate LENDER PROCESSING SERVICES,

INC. (LPS), next known as BLACK KNIGHT FINANCIAL, LLC and now known as BLACK

KNIGHT, INC., through its subsidiary, DOCX and through its own employees, forged over one

million (1,000,000) Assignments of Mortgages and other false documents to further the operation

of the Fraudulent Foreclosure Enterprise and transmitted the forged documents by mail and wire

for filing in public land records throughout the United States of America.

82. A forged allonge to Nora’s Note was created by LPS and was transmitted to Nora

from Potteiger by U.S. mail on or about June 17, 2009 in furtherance of the Fraudulent

Foreclosure Enterprise.

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83. FIDELITY NATIONAL TITLE COMPANY is joined in its corporate capacity for its

participation in the Fraudulent Foreclosure Enterprise and as Respondeat Superior for the actions

of Potteiger, Moglowsky, BASS & Moglowsky, claiming to be its agent.

84. FIDELITY NATIONAL TITLE COMPANY will be served by service upon C T

CORPORATION SYSTEM, 818 W 7th Street, Suite 930, Los Angeles, California 90017.

85. Defendant Sheryl St. Ores (St. Ores) is an adult resident of the State of Wisconsin

and is believed to be a resident of Milwaukee County.

86. St. Ores joined in this action in her individual capacity for her participation in the

Fraudulent Foreclosure Enterprise while pretending to act as assistant litigation attorney for the

WISCONSIN OFFICE OF LAWYER REGULATION, with her principal place of business

located at 110 East Main Street, Suite 315, Madison, Wisconsin 53703.

87. Defendant Paul W. Schwarzenbart (Schwarzenbart) is an adult resident of the State

of Wisconsin and is believed to be a resident of Reedsburg in Sauk County.

88. Schwarzenbart is joined in this action in his individual capacity for his participation

in the Fraudulent Foreclosure Enterprise while pretending to act in his official capacity as

Retained Counsel for the WISCONSIN OFFICE OF LAWYER REGULATION with his

principal place of business at c/o STAFFORD ROSENBAUM, LLP, 222 W. Washington Ave.,

Suite 900, Madison, Wisconsin 53703.

89. Defendant Lisa C. Goldman (Goldman) is an adult resident of the State of Wisconsin

and is believed to be a resident of Dane County.

90. Goldman’s principal place of business is c/o DAVEY & GOLDMAN, 5609 Medical

Circle, Suite 101, Madison, Wisconsin 53719.

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91. Goldman is joined in this action in her individual capacity for her extrajurisdictional

acts pretending to be qualified to act as Referee in In re the Disciplinary Proceedings Against

Wendy Alison Nora (Office of Lawyer Regulation v. Nora), Appeal No. 2013AP000653-D

(hereinafter Nora) when she was actually biased, against Nora because she is required to

cooperate with OLR under SCR 22.15(5).

92. Goldman was appointed to act as the referee in Nora #1 and was purportedly granted

the powers of a circuit court judge in the trial of a civil matter under SCR 22.16(1), but she has

never been elected to serve as circuit court judge, has never received the training provided to

circuit court judges and the oath she signed is not the oath required of circuit court judges in the

State of Wisconsin.

93. Goldman prevented Nora from being able to be present her defense in the

disciplinary proceedings in violation of First Amendment Rights to petition the judiciary for

redress of grievances guaranteed by the First Amendment to the Constitution of the United States

and Article One, Section 3 of the Constitution of the State of Wisconsin and in violation of

Nora’s Due Process Rights guaranteed by the Fourteenth Amendment to the Constitution of the

United States and Article One, Section 1 of the Constitution of the State of Wisconsin.

94. Goldman is joined in her individual capacity for her acts in furtherance of the

Fraudulent Foreclosure Enterprise in which she repeatedly violated Wis. Stat. sec. 946.12(3) to

benefit OLR and the mortgage servicing agent’s lawyer Potteiger.

95. Defendant James J. Winiarski (Winiarksi) is an adult resident of the State of

Wisconsin and is joined in his individual capacity because he purported to act as the referee in In

re the Disciplinary Proceedings Against Wendy Alison Nora (Office of Lawyer Regulation v.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 35 of 102

Nora), Appeal No. 2015AP002442-D (hereinafter Nora #2) without subject matter jurisdiction or

competency to proceed under SCR Chapter 22 on and after August 16, 2016.

96. Winiarski is joined in his individual capacity because he was without subject matter

jurisdiction or competency to proceed under SCR 22.11 effective August 16, 2016, the date upon

which he purported to allow OLR to file the Second Amended Complaint in Nora #2 setting forth

facts for which the preliminary review panel had not found cause to proceed, contrary to SCR

22.11(2).

97. Winiarski was purportedly granted the powers of a circuit court judge in the trial of a

civil matter under SCR 22.16(1), but he has never been elected to serve as circuit court judge, has

never received the training provided to circuit court judges and, upon information and belief, the

oath he signed is not the oath required of circuit court judges in the State of Wisconsin.

98. After allowing OLR to file a Second Amended Complaint in Nora #2 on August 17,

2016 which had not been authorized by a preliminary review panel of the Preliminary Review

Committee (PRC) under SCR 22.06 and SCR 22.07, shortly before the date set for the pre-

hearing final conference set for August 30, 2016, Winiarski entered multiple orders intended to

deprive Nora of her right to defend herself in Nora #2 in violation of Nora’s Due Process Rights

guaranteed by the Fourteenth Amendment to the Constitution of the United States and Article

One, Section 1 of the Constitution of the State of Wisconsin.

99. Winiarski is joined in this action in his individual capacity for his acts in furtherance

of the Fraudulent Foreclosure Enterprise.

100. Winiarki’s principal place of business is 3625 Oklahoma Ave., in Milwaukee,

Milwaukee County, Wisconsin 53215.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 36 of 102

101. Defendant Mark W. Rattan (Rattan) of LITCHFIELD CAVO, LLP is an adult

resident of the State of Wisconsin and is believed to be a resident of Waukesha County.

102. Rattan is admitted to practice law before the Wisconsin Supreme Court and is

subject to the requirements of the Wisconsin Code of Professional Conduct at Chapter 20 of the

Supreme Court Rules (SCR).

103. Rattan’s principal place of business is c/o LITCHFIELD CAVO, LLP, 250 East

Wisconsin Ave., Suite 800, Milwaukee, Wisconsin 53202.

104. On March 22, 2017 and March 23, 2017, Rattan appeared at the extrajurisdictional

evidentiary hearing conducted by Winiarski in Nora #2 as counsel for one of OLR’s witnesses,

Attorney Stephanie L. Dykeman, who represents WELLS FARGO BANK, N.A. (WELLS

FARGO) and claims to represent a Real Estate Mortgage Investment Conduit (REMIC) Trust of

which HSBC Bank USA, N.A. was purportedly the Trustee in actions and proceedings involving

Rinaldi’s Homestead.

105. Rattan is joined in his individual capacity for disrupting the extrajurisdictional

evidentiary hearing in Nora #2 by assaulting King for the purpose of preventing King from

reporting on the public activities and events in Nora #2 in violation of King’s rights under the

First Amendment to the United States Constitution and Article One, Section 4 of the Wisconsin

Constitution.

106. Rattan is joined in his individual capacity for disrupting the extrajurisdictional

evidentiary hearing in Nora #2 by assaulting King for the purpose of interfering with Nora’s

rights to proceed to make her record at the public hearing in Nora #2 in violation of Nora’s rights

under the First Amendment to the United States Constitution and Article One, Section 3 of the

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 37 of 102

Wisconsin Constitution.

107. Rattan is joined as agent for WELLS FARGO and in his individual capacity for his

conduct in furtherance of the Fraudulent Foreclosure Enterprise in violation of WOCCA.

108. Defendant Stephanie L. Dykeman (Dykeman) is an adult resident of the State of

Wisconsin and is a resident of Milwaukee County.

109. Dykeman’s principal place of business is 250 East Wisconsin Ave., Suite 800,

Milwaukee, Wisconsin 53202.

110. Dykeman is joined in her capacity as agent for WELLS FARGO and as Respondeat

Superior for the actions of Rattan.

111. Dykeman is also joined individually for her conduct in furtherance of the Fraudulent

Foreclosure Enterprise in violation of WOCCA.

112. LITCHFIELD CAVO, LLP (LITCHFIELD CAVO) is an Illinois limited liability

partnership with its Wisconsin office location at 13400 Bishop’s Lane, Waukesha, Wisconsin

53005-6224.

113. The agent for service of process for LITCHFIELD CAVO with the Wisconsin

Department of Financial Institutions is C T Corporation System, 301 S. Bedford Street #213,

Madison, Wisconsin 53703.

114. LITCHFIELD CAVO, through certain of its employees including Dykeman, has

represented WELLS FARGO BANK, N.A. (WELLS FARGO) in the Rinaldi foreclosure and

bankruptcy cases since 2009.

115. LITCHFIELD CAVO is joined in its capacity as agent for WELLS FARGO and as

Respondeat Superior for the actions of Rattan and Dykeman and for its statutory liability under

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Wis. Stat. secs. 946.83 and 946.85 for the conduct of its employees in furtherance of the

Fraudulent Foreclosure Enterprise in violation of WOCCA.

116. Defendant WELLS FARGO BANK, N.A. (WELLS FARGO) is a national banking

association chartered under 12 U.S.C. sec. 24, with its principal offices at 420 Montgomery

Street, San Francisco, California 94104 and its corporate headquarters at 101 N. Phillips Avenue,

Sioux Falls, South Dakota 57104.

117. WELLS FARGO has been pursuing the remedy of foreclosure against the Rinaldi

Homestead, based on false pleadings, supported by forged documents and falsely sworn

affidavits since February 3, 2009.

118. WELLS FARGO is one of the leading participants in the Fraudulent Foreclosure

Enterprise throughout the nation.

119. WELLS FARGO is one of five (5) mortgage servicers which entered into the

National Mortgage Settlement with the United States of America, the United States Department

of Justice and forty-nine (49) state attorneys general, including the Attorney General for the State

of Wisconsin.

120. WELLS FARGO is joined in its corporate capacity for directing its employees and

agents to create forged documents, file false pleadings supported by forged document and falsely

sworn affidavits.

121. WELLS FARGO is joined as Respondeat Superior for the actions and omissions of

Rattan, Dykeman and LITCHFIELD CAVO.

122. Defendant Brad Schimel is the current Attorney General for the State of Wisconsin,

with his principal offices at 114 East State Capitol, Madison, Wisconsin 53702.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 39 of 102

123. The Attorney General is liable for the diversion of funds obtained for the benefit of

Homeowners and for the correction of the public records in several actions, including, but not

limited to the National Mortgage Settlement filed in the United States District Court for the

District of Columbia on April 4, 2012 in Case No. 12-cv-361 in which the Attorney General for

the STATE OF WISCONSIN participated (along with the attorneys general of 49 other states)

and the January 30, 2013 Consent Judgment between Lender Processing Services, Inc. (LPS),

next known as Black Knight Financial, LLC, and its affiliated entity DOCX, along with a

presently unidentifiable entity by the name of “LPS Default Solutions, Inc.,1 as a Delaware

corporation,” in Superior Court for the State of Connecticut, Hartford Division, to which

attorneys general of 45 states and the District of Columbia are co-signatories as discussed infra.

124. With respect to the challenges to constitutionality of Chapters 21 and 22 of the

Supreme Court Rules, facially or as applied to any of the Plaintiffs, the facial or “as applied”

constitutionality of any provision of Chapters 21 and 22 of the Supreme Court Rules, the

constitutionality of the operation of the LRS, facially or “as applied,” notice will be given to

Attorney General for the State of Wisconsin at the Wisconsin Department of Justice, 114 East

State Capitol, Madison, Wisconsin 53702 that the Plaintiffs challenge the constitutionality of the

WISCONSIN LAWYER REGULATION SYSTEM (LRS), facially or as applied to Nora, King,

and Rinaldi.

125. The Unnamed Individuals, Governmental Agencies and Corporate Entities Yet to Be

Named or Identified acted in concert with the named Defendants or at the direction of the named

1
There is presently no Delaware corporation registered as LPS Default Solutions, Inc. nor has
any corporation organized under the laws of any State of the United States of America been located.
Research is continuing.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 40 of 102

Defendants in the actions complained of or engaged in other actions or omissions which are

actionable torts to be subsequently pleaded herein.

NATURE OF THE CLAIMS

126. The acts and omissions (the Conduct) which give rise to the relief requested herein

have been undertaken by the Defendants, individually and in concert as specified herein,

deprived and continue to deprive the Plaintiffs of their constitutional rights, in violation of the

First Amendment (as to all Plaintiffs), the Fourth Amendment as to Nora only, and the Plaintiffs’

Due Process Rights and Rights to Equal Protection of the Laws, including the protections of the

Constitution of the State of Wisconsin under the Fourteenth Amendments to the United States

Constitution, contrary to 42 U.S.C. sec. 1983, respectively, as specified herein.

127. The violation of constitutional rights of the Plaintiffs by the joint action of state

actors with the wilful participation of private parties is actionable under 42 U.S.C. sec. 1983,

Adickes v. Kress Company, 398 U.S. 144, 152 90 S.Ct. 1598, 26 L.Ed.2d 142 (1970). (“Private

persons, jointly engaged with state officials in the prohibited action, are acting ‘under color’ of

law for purposes of the statute. To act ‘under color’ of law does not require that the accused be

an officer of the State. It is enough that he is a willful participant in joint activity with the State or

its agents,” United States v. Price, 383 U.S. 787, 794, 86 S.Ct. 1152, 1157 (1966).

128. The operation of the Fraudulent Foreclosure Enterprise involves the commission of

the crimes identified below by state and nonstate actors, individually, in concert or in the

conspiracy to further the Fraudulent Foreclosure Enterprise.

129. For the Fraudulent Foreclosure Enterprise to succeed in judicial foreclosure

proceedings, Wisconsin lawyers knowingly file false complaints or file complaints without

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regard to the truthfulness of the allegations in the complaints which they refuse to amend when

confronted with evidence that the allegations in the complaints are false or are supported by

forged documents.

130. It is necessary to the operation of the Fraudulent Foreclosure Enterprise (the

Enterprise) that Wisconsin lawyers not be investigated by OLR because they routinely violate

SCR 20:3.3(1)(a) and SCR 20:8.4 and an investigation would lead to charges which would

expose the Enterprise.

131. The acts and omissions (the Conduct) which give rise to the relief requested herein

have been undertaken by the Defendants, individually and in concert, in violation of Wis. Stat.

secs. 946.83 and 946.85 as specified herein.

132. As to Nora only, the Conduct involving violations of Wis. Stat. secs. 146.82(5) and

146.84(2) for which the STATE OF WISCONSIN and its named employees and agents are both

criminally and civilly liable by the express terms thereof and are in violation of Wis. Stat. sec.

943.20(5), further and additional predicate acts in violation of WOCCA.

133. As to King only, a separate cause of action for consequential, special and punitive

damages from the assault committed by Rattan is pleaded as Count V.

134. The action for damages for violation of the Plaintiffs’ civil rights under 42 U.S.C.

sec. 1983 and for Rattan’s assault against King includes a demand for punitive damages because

the Conduct complained of was malicious or taken in an intentional disregard of Plaintiffs’

rights; double damages should be awarded to each of the Plaintiffs to the extent of the damages

proved at trial under Wis. Stat. sec. 946.87(4).

135. Plaintiffs seek a declarations of their rights and injunctive relief against the

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 42 of 102

continuing Fraudulent Foreclosure Enterprise.

136. Plaintiffs seek to have the WISCONSIN LAWYER REGULATION SYSTEM

(LRS) at Chapters 21 and 22 of the Supreme Court Rules declared unconstitutional on its face or

as applied to these Plaintiffs in its entirety or as to specific portions thereof.

GROUNDS FOR AND FACTS IN COMMON TO ALL CAUSES OF ACTION

137. The deprivation of Plaintiffs’ rights guaranteed the Constitution of the United States

by the Conduct of the Defendants violated 42 U.S.C. sec. 1983.

138. The Defendants Sellen, Stieren, Kasieta, Parsons, Hannan, Potteiger, Moglowsky,

St. Ores, Schwarzenbart, Goldman, Winiarski, Rattan, and Dykeman are joined in their

individual capacities for committing multiple violations of Wis. Stat. sec. 946.12(3), which are

predicate acts in violation of the Wisconsin Organized Crime Control Act (WOCCA), for the

purpose of concealing the operation of the Fraudulent Foreclosure Enterprise in the State of

Wisconsin in which the property rights of Wisconsin residents and citizens have been taken as

the result of false pleadings, supported by forged documents and authenticated by falsely sworn

affidavits submitted by foreclosure claimants represented by Wisconsin-licensed lawyers in order

to avoid investigation into the operation of the Fraudulent Foreclosure Enterprise.

139. Wis. Stat. sec. 946.82(4) makes it a state felony to commit any act enumerated in

18 U.S.C. sec. 1961(1) which includes 18 U.S.C. sec. 1341 (mail fraud) and 18 U.S.C. sec. 1343

(wire fraud).

140. Other predicate acts in violation of Wis. Stat. sec. 946.82(4) are violations of Wis.

Stat. sec. 943.30(5) (extortion by use of confidential medical information to gain pecuniary

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 43 of 102

advantage), Wis. Stat. sec. 943.38 (forgery), 946.12(3) (misconduct in public office), and

946.32(1) (false swearing) to further the operations of a racketeering enterprise, which is

identified herein as the Fraudulent Foreclosure Enterprise.

141. It is a state misdemeanor to violate Wis. Stat. sec. 146.82(5)(c) under the

circumstances set forth in Wis. Stat. sec. 146.84(2)(a) and (b).

142. It is a state felony to violate Wis. Stat. sec. 146.82(5)(c) under the circumstances set

forth in Wis. Stat. sec. 146.84(2)(c).

143. It is a state felony in violation of Wis. Stat. sec. 943.20(1)(d) to “obtain title to

property of another person by intentionally deceiving the person with a false representation

which is known to be false, made with intent to defraud, and which does defraud the person to

whom it is made.”

144. It is a state felony to violate Wis. Stat. sec. 946.30(5).

145. It is a state felony in violation of Wis. Stat. sec. 943.38(1)(a) to forge documents.

146. It is a state felony in violation of Wis. Stat. sec. 943.38(2) to utter forged

documents.

147. It is a state felony to violate Wis. Stat. sec. 946.12(3).

148. It is a state felony in violation of Wis. Stat. sec. 946.32 to “ make[s] or subscribe[s]

a false statement which he or she does not believe is true, when such oath, affirmation, or

statement is authorized or required by law or is required by any public officer or governmental

agency as a prerequisite to such officer or agency taking some official action.

149. It is a state felony under Wis. Stat. sec. 946.84 to violate Wis. Stat. secs. 946.81-

946.87.

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150. The Defendants as employees and agents of the WISCONSIN LAWYER

REGULATION SYSTEM (LRS), including, but not limited to Chief Justice Roggensack in her

supervisory and administrative capacities; the employees and agents of the Office of Lawyer

Regulation (OLR) Sellen, Stieren, Kasieta, Parsons, St. Ores, and Schwarzenbart; Hannan as

chair of the Preliminary Review Committee (PRC); the named Defendant Referees Attorneys

Goldman and Winiarski acted, as applicable, in concert with Potteiger, Moglowsky, BASS &

MOGLOWSKY, FIDELITY NATIONAL TITLE COMPANY, Rattan, Dykeman, LITCHFIELD

CAVO, and WELLS FARGO in furtherance of the Fraudulent Foreclosure Enterprise, as defined

at Wis. Stat. sec. 946.82(4) for the purpose of injuring the property rights of Wisconsin

Homeowners by the direct actions and omissions (the Conduct) and by aiding and abetting the

criminal acts of each other as parties to the crimes identified herein in violation of Wis. Stat. sec.

939.05(2)(b) and/or by participating in the racketeering activity by the Conduct specified herein.

151. As specified below, individual Defendants acted for the common purpose of

concealing the use of false pleadings, supported by forged documents, authenticated by falsely

sworn affidavits and ultimately, where necessary, perjured testimony, in order to further the

operations of a nationwide racketeering enterprise designated herein as the Fraudulent

Foreclosure Enterprise, the object of which is to obtain title to Wisconsin residential real estate

based on false pleadings and evidence.

152. Potteiger created forged documents identified as Exhibit B to his April 24, 2014

Affidavit and Exhibit 1 identified in his August 3, 2014 Affidavit, which St. Ores uttered and

upon which Schwarzenbart continued to rely, concealing the conclusive evidence of the forgery

of the said Exhibit B, with the knowledge of Sellen and Goldman.

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153. As to all of the Defendants claiming to act in their official capacities, violations of

18 U.S.C. secs. 1341, 1343, and 1962, and Wis. Stat. secs. 146.82(5) and 146.84(2), Wis. Stats.

secs. 943.20(1)(d), 943.30(5), 943.38, 946.12(3), 946.32 and Wis. Stat. sec. 946.82(4) cannot be

committed in an official capacity because employees and agents of the State of Wisconsin are not

authorized by their official capacity to commit crimes.

154. Commissions of the predicate acts in violation of Wis. Stat. sec. 946.82(4)identified

above, directly or as party to a crime as defined under Wis. Stat. sec. 939.05, including actions

undertaken in furtherance of the criminal conspiracy or in the capacity of a supervisor of the

Conduct under Wis. Stat. secs. 946.83 and/or Wis. Stat. sec. 946.85 give rise to a private rights of

action under Wis. Stat. secs. 946.87(2)(b) and 946.87(4) under which these Plaintiffs proceed in

Count Twelve.

155. Upon information and belief, the required investigation of the alleged misconduct of

Wisconsin licensed lawyers would reveal the involvement of participants in the WISCONSIN

LAWYER REGULATION SYSTEM (WLRS) and the Wisconsin Unified Court System as well

as the Wisconsin Supreme Court in at least wilful blindness to the ubiquitous frauds being

committed in Wisconsin circuit courts in foreclosure cases.

156. Upon information and belief, the required investigation of the alleged misconduct

of lawyers admitted to practice before the Wisconsin Supreme Court (hereinafter Wisconsin

lawyers) and would challenge the investigative resources of OLR.

157. Enforcement of the Code of Professional Conduct against attorneys representing

mortgage servicers could ultimately affect the value of the retirement funds in which employees

of the Unified Court System are invested and in which OLR employees and the justices of the

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 46 of 102

Wisconsin Supreme Court are believed to be beneficiaries.

158. The value of the salaries and retirement benefits of the state employees gained from

participation in and concealment of the Fraudulent Foreclosure Enterprise exceeds $25,000.00 to

each person.

159. The value of the profits gained by Litchfield Cavo, Wells Fargo Bank, Fidelity

National Title Company, Rattan, Dykeman, Potteiger and Moglowsky from participation in the

Fraudulent Foreclosure Enterprise exceeds $25,000.00 to each person.

160. Winiarski was paid over $25,000.00 ($38,811.03, including expenses) for his

participation in the Fraudulent Foreclosure Enterprise.

161. Schwarzenbart was paid over $25,000.00 ($28,053.98 in Nora #1 and $34,784.13

for a total of $62,838.11, including expenses) for his participation in the Fraudulent Foreclosure

Enterprise.

162. Goldman was paid only $11,064.24 (gross income) for her participation in the

Fraudulent Foreclosure Enterprise, but may have gained preferential appointments for further

pecuniary gain (resources) to be determined by discovery.

163. The STATE OF WISCONSIN and the Office of the Wisconsin Attorney General

are well aware of the operations of the Fraudulent Foreclosure Enterprise, having benefitted from

payments made by participants in the nationwide Fraudulent Foreclosure Enterprise through the

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 47 of 102

National Mortgage Settlement documents filed as Docs. 102, 113, 124, 135, and 146 in the case

titled United States of America, et al. v. Bank of America Corporation, et al., Case No. 12-cv-

361 in the United States District Court for the District of Columbia on April 4, 2012 from which

the STATE OF WISCONSIN received at least $30,191,806.00.

164. The STATE OF WISCONSIN and the Office of the Wisconsin Attorney General

are well aware of the scope and extent of the creation and recording of false documents with the

Wisconsin Registers of Deeds Offices based on its participation in the Consent Judgment titled

The State of Connecticut v. Lender Processing Services, Inc., et al. (the LPS Settlement) filed in

the Superior Court for the Hartford, Connecticut filed on January 31, 2013 from which the

STATE OF WISCONSIN received $1,505,315.00.

165. Upon information and belief, none of the total of at least $30,191,806.00 received

from the National Mortgage Settlement was used for the purposes stated in the Consent

Judgment, an excerpt of which is attached as Exhibit B, but was instead reported to have been

deposited into the general fund to plug a whole in the operating budget of the STATE OF

2
“JP Morgan Chase Consent Judgment” (291 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_Chase-4-11-12.pdf
3
“Bank of America Consent Judgment” (310 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_BoA-4-11-12.pdf
4
“Citi Consent Judgment” (314 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_Citibank-4-11-12.pdf
5
“Ally/GMAC Consent Judgment” (328 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_Ally-4-11-12.pdf
6
“Wells Fargo Consent Judgment” (315 pages) retrievable at
http://www.nationalmortgagesettlement.com/files/Consent_Judgment_WellsFargo-4-11-12.pdf

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 48 of 102

WISCONSIN in 2012.

166. Upon information and belief, none of the total of the $1,505,315.00 received from

the Consent Judgment in the LPS Settlement was to re-mediate damages to the public land

records in the STATE OF WISCONSIN resulting from the LPS forgery scheme for which the

penalty was imposed and no effort has been made to remove forged documents created by LPS

which were recorded in the offices of the Registers of Deeds in the State of Wisconsin.

167. Upon information and belief, the required investigation of the alleged misconduct

of Wisconsin lawyers would reveal the involvement of participants in the WISCONSIN

LAWYER REGULATION SYSTEM (WLRS), the Wisconsin Supreme Court and the Wisconsin

Unified Court System in at least wilful blindness to the ubiquitous frauds being committed in

Wisconsin circuit courts in foreclosure cases.

168. Upon information and belief, the required investigation of the alleged misconduct

of Wisconsin lawyers would challenge the investigative resources of OLR.

169. Enforcement of the Code of Professional Conduct against attorneys representing

mortgage servicers could ultimately affect the value of the retirement funds in which employees

of the Unified Court System are invested and in which OLR employees and the justices of the

Wisconsin Supreme Court are believed to be beneficiaries.

170. Upon information and belief, Sellen violated Wis. Stat. sec. 946.12(3) by allowing

OLR employees and other agents of the Wisconsin Supreme Court in the WISCONSIN

LAWYER REGULATION SYSTEM (WLRS) to conceal the misconduct of the Wisconsin

licensed lawyers against whom grievances were filed by homeowners and for which no

investigations were initiated, despite evidence showing the possibility of misconduct.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 49 of 102

171. Upon information and belief, Sellen concealed the misconduct of attorneys

representing mortgage servicers and of the named employees and agents of OLR and the LRS.

172. Sellen, in his official capacity, failed to adequately supervise and train staff and

participants in the LRS.

173. Sellen is joined in his individual capacity for his violations and allowing OLR

employees and participants in the LRS to violate Wis. Stat. secs. 146.82(5)(c) and 146.84(1)(b)

or (bm) and 146.84(2)(a)2, which deprived Nora of her right to Equal Protection of the Laws of

the State of Wisconsin guaranteed by the Fourteenth Amendment to the United States

Constitution in violation of 42 U.S.C. sec. 1983.

174. Sellen is individually liable for his participation in the civil rights violations of the

Plaintiffs and for failing to prevent the violation of each of the Plaintiffs’ civil rights.

175. At all times relevant to the acts, omissions, occurrences and transactions

complained of herein, Stieren was an employee of OLR and Sellen was his ultimate supervisor.

176. Stieren is individually liable for his violations of Wis. Stat. secs.

146.82(5)(c) and 146.84(1)(b) or (bm) and 146.84(2)(a)2 which deprived Nora of her right to

Equal Protection of the Laws of the State of Wisconsin guaranteed by the Fourteenth

Amendment to the United States Constitution in violation of 42 U.S.C. sec. 1983.

177. Stieren is individually capacity for his violation of Nora’s right to the confidentiality

of her temporary guardianship proceedings under color of official right in order to provide the

records to the Defendant Potteiger, contrary to Wisconsin law.

178. Stieren is individually liable for his violation of Nora’s right to be free from

unreasonable searches and seizures guaranteed by the Fourth Amendment to the United States

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 50 of 102

Constitution and Article One, Section 11 of the Wisconsin Constitution.

179. Stieren is individually liable for his violation of Nora’s rights to Due Process

guaranteed by the Fourteenth Amendment to the United States Constitution and Article One,

Section 1 of the Wisconsin Constitution.

180. At all times relevant to the acts, omissions, occurrences and transactions

complained of herein, Kasieta was a member of the District Nine Ethics Committee created

under SCR Chapter 21 and purporting to function pursuant to SCR Chapter 22.

181. Kasieta is individually liable for his violations of Nora’s rights to Equal Protection

of the Laws of the State of Wisconsin under Wis. Stat. secs. 146.82(5)( c) and 146.84(1)(b) or

(bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United States

Constitution and Article One, Section 1 of the Wisconsin Constitution.

182. Kasieta is individually liable for the unreasonable search and seizure of Nora’s

confidential medical information by the knowing unlawful disclosure thereof without her consent

required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the Fourth

Amendment to the United States Constitution.

183. Kasieta acted in conspiracy with the Potteiger and Moglowsky to silence Nora’s

Right to Petition the Judiciary for Redress of Grievances (Petition Rights) guaranteed by the First

Amendment to the United States Constitution and by Article One, Section 4 of the Wisconsin

Constitution and to deprive Nora of her property rights to her license to practice law in the State

of Wisconsin, in an effort to punish her for the lawful exercise of her Petition Rights in violation

of her rights to Due Process guaranteed by the Fourteenth Amendment to the United States

Constitution and Article One, Section 1 of the Wisconsin Constitution.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 51 of 102

184. Kasieta knew and acknowledged (in the Investigative Report he signed) that he

knew there was an issue as to whether or not the fact that Nora’s confidential medical

information was filed under federal court seal should prevent the use of the information, and

knew or should have known that Nora did not consent to the disclosure of her confidential

medical information for any purpose other than the purpose for which the information was filed

under seal, but Kasieta nevertheless re-disclosed Nora’s confidential medical information to

Parsons and Kasieta and Parsons re-disclosed the medical information to the District Nine Ethics

Committee and the Preliminary Review Committee (PRC) without Nora’s consent, in violation

of the Fourth and Fourteenth Amendments to the United States Constitution and Article One,

Sections 1 and 4 of the Wisconsin Constitution.

185. Kasieta refused to interview Nora at her request, so that she could explain her

current health status, claiming to have all the information needed to complete the investigation he

was assigned to perform by the District Nine Ethics Committee, together with Theron Edward

Parsons IV.

186. Parsons is individually liable for his violations of Wis. Stat. secs. 146.82(5)(c) and

146.84(1)(b) or (bm) and 146.84(2)(a)2. guaranteed by the Fourteenth Amendment to the United

States Constitution and Article One, Section 1 of the Wisconsin Constitution.

187. Parsons is individually liable for the unreasonable search and seizure of Nora’s

confidential medical information while knowing unlawful disclosure thereof without her consent

required by Wis. Stat. sec. 146.82(5)(c) was in violation of Nora’s rights guaranteed by the

Fourth Amendment to the United States Constitution, a misdemeanor under Wis. Stat. sec.

146.84(2)(a)2.

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188. Parsons is joined in his individual capacity for conspiracy with the Defendant

Kasieta to silence Nora’s Right to Petition the Judiciary for Redress of Grievances (Petition

Rights) guaranteed by the First Amendment to the United States Constitution and by Article One,

Section 4 of the Wisconsin Constitution; and to deprive Nora of her property rights to her license

to practice law in the State of Wisconsin, in an effort to punish her for the lawful exercise of her

Petition Rights in violation of her rights to Due Process guaranteed by the Fourteenth

Amendment to the United States Constitution and Article One, Section 1 of the Wisconsin

Constitution.

189. Parsons, a Wisconsin licensed clinical social worker who advertises his Ph.D.

degree in the field of social work, did not interview Nora prior to signing off on the Investigative

Report, contrary to the most basic protocols of clinical counseling in which he is licensed by the

State of Wisconsin.

190. Parsons also knew or should have known that he could not re-disclose Nora’s

confidential medical information without her consent, based the fact of his professional licensure

in the field of clinical social work.

191. Kasieta and Parsons relied on and referred to Nora’s confidential medical

information in their Investigative Report to the District Nine Ethics Committee and attached her

confidential medical records to the Investigative Report in violation of Wis. Stat. secs.

146.84(1)(b) or (bm) and 146.84(2)(a)2., unlawfully disclosing Nora’s confidential medical

records without her consent.

192. From on or about July 1, 2011 to on or about June 30, 2013 (the period relevant to

the acts, omissions, occurrences and transactions complained of herein as to Hannan), Hannan

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was Nora’s litigation opponent in Waukesha County Circuit Court Case No. 2011CV003333

titled Bank of America, N.A. v. Amy Jo Brown (the Brown case), a fact that Hannan was required

to disclose to under SCR 60.04, and he failed to do so.

193. Because Hannan did not disclose his position as PRC Chair to Nora, Nora could not

have waived Hannan’s conflict of interest and had she known that Hannan was the PRC Chair,

she would have insisted on his recusal because he was Nora’s litigation opponent in the Brown

case, which involved substantially similar facts to the case of Nora v. Residential Funding

Company, LLC, et al., in the United States District Court for the Western of Wisconsin in Case

No. 10-cv-748 and Nora v. Residential Funding Company, LLC, et al., in the United States

Bankruptcy Court for the Southern District of NewYork in Adv. No. 13-01208.

194. When the Investigative Report was presented to the PRC for assignment by the PRC

Chair to the preliminary review panel, Hannan was then and there disqualified to act in the

capacity of PRC Chair under SCR 21.14(1)(e).

195. Without Nora’s consent, Stieren re-disclosed and, upon information and belief,

Sellen allowed Stieren to re-disclose, Nora’s confidential medical information which was

included in the December 10, 2010 Grievance filed by Potteiger (who was one of her litigation

opponents) to the District Nine Ethics Committee, which were again re-disclosed by the grievant

and his supervisor to the District Nine Ethics Committee Investigator (Kasieta), was next re-

disclosed by Kasieta to Parsons, and then re-disclosed by Kasieta and Parsons to Sellen, which

was again re-disclosed by Stieren and Sellen, to Hannan, contrary to Wis. Stat. sec. 146.82(5)(c)

and in violation of Wis. Stat. secs. 146.84(1)(b) or (bm) and 146.84(2)(a)2.

196. Upon information and belief, while then and there disqualified to act as Chair of the

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PRC, Hannan received, reviewed and then re-disclosed Nora’s confidential medical information

without Nora’s consent to the preliminary review panel of the PRC which he selected under SCR

22.06, contrary to Wis. Stat. secs. 146.82(5)(c) and in violation of Wis. Stat. secs.146.84(1)(b) or

(bm) and 146.84(2)(a)2. and then unlawfully re-disclosed Nora’s confidential medical

information to members of the preliminary review panel without Nora’s consent.

197. Hannan is individually liable for his violations of Wis. Stat. sec. 146.82(5)(c) and

146.84(1)(b) or (bm) and 146.84(2)(a)2. in violation of Nora’s Due Process and Equal Protection

Rights guaranteed by the Fourteenth Amendment to the United States Constitution and Article

One, Section 1 of the Wisconsin Constitution; for unreasonable search and seizure of her

confidential medical information by the knowing unlawful disclosure thereof without her consent

required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the Fourth

Amendment to the United States Constitution; and for conspiracy to deprive Nora of her property

rights to her license to practice law in the State of Wisconsin, in an effort to punish her for the

lawful exercise of her Petition Rights in violation of her rights to Due Process guaranteed by the

Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the

Wisconsin Constitution for the benefit of his clients in the Brown case, the law firm of

BLOMMER PETERMAN, S.C., next known as J PETERMAN LAW GROUP, LTD., now

known as BP PETERMAN LAW GROUP, LLC, and lawyers named as Defendants therein.

198. Rather than investigate grievances filed by homeowners with OLR under Supreme

Court Rules (SCR) Chapter 22, including, but not limited to the grievances filed by Plaintiffs

Nora, Rinaldi and other homeowners alerting OLR to the use of false pleadings, supported by

false copies of documents or forged documents, authenticated by falsely sworn affidavits or

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testimony as unsubstantiated or otherwise not warranting formal investigations in violation of

Wis. Stat. sec. 946.12(3), OLR employees refused to investigate homeowner grievances on

clearly erroneous grounds, including, but not limited to the completely false position that OLR

does not investigate grievances filed by persons who are not clients of the lawyers against whom

grievances are filed and, most often, for “insufficient” evidence of violations of the Code of

Professional Conduct.

199. OLR, Sellen, Stieren, Kasieta, Parsons and Hannan used Nora’s confidential

medical information which was unlawfully taken in violation of a federal court seal and produced

by one of Nora’s litigation opponents in order to deprive Nora of her property rights to her

license to practice law in the State of Wisconsin, in an effort to punish Nora for the lawful

exercise of her Petition Rights and for assisting her clients in the exercise of their Petition Rights

in violation of her rights to Due Process and Equal Protection of the Laws, guaranteed by the

Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the

Wisconsin Constitution.

200. Knowing that Nora’s confidential medical information was unlawfully re-disclosed,

Sellen took no action to discipline Stieren as allowed by Wis. Stat. sec. 146.84(3) nor did he take

any other action to prevent the continuing violation of Nora’s rights to be free from unreasonable

searches and seizures of her confidential medical information in violation of the Fourth

Amendment to the United States Constitution.

201. Nora and Rinaldi produced substantial, indeed VAST evidence to OLR which

established that certain Wisconsin-licensed lawyers were engaging in and facilitating mail fraud

and wire fraud in violation of Racketeer Influenced and Corrupt Organizations Act (RICO), 18

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U.S.C. sec. 1961, et seq. and the Wisconsin Organized Crime Control Act (WOCCA) Wis. Stat.

sec. 946.80, et seq., in violation of the Code of Professional Conduct, injuring the property and

allowing the property of the Plaintiffs Nora and Rinaldi as well as hundreds of other Wisconsin

homeowners to be injured.

202. The Defendants who are employees or agents of OLR and the Wisconsin Supreme

Court have the positive statutory duty to prevent the injuries to the public when Wisconsin-

licensed attorneys commit criminal acts.

203. The successful continuation of the Fraudulent Foreclosure Enterprise depends upon

concealment of its operations.

204. All of the named Defendants contributed to the concealment of the Fraudulent

Foreclosure Enterprise described herein by their specified actions taken under color of state law

to prevent the Plaintiffs from exercising their Petition Rights and to prevent the exposure of the

Fraudulent Foreclosure Enterprise to the public.

205. Nora and Rinaldi attempted to report the operation of the Fraudulent Foreclosure

Enterprise to OLR, as did other homeowners.

206. Had OLR investigated the evidence which shows the operation of the

Fraudulent Foreclosure Enterprise in which Wisconsin lawyers participate by filing false

pleadings, supported by false or forged copies of documents and falsely sworn affidavits, it is

believed in good faith, Rinaldi would not have spent over a decade in litigation to protect the

property interests in the Rinaldi Homestead and hundreds of Wisconsin homeowners would have

been protected from similar misconduct affecting their property rights and interests resulting in

the loss of hundreds of Wisconsin homes to foreclosure based on false documents.

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207. Instead, OLR dismissed homeowners’ grievances and collaborated with Nora’s

litigation opponents to prevent her from exercising her Petition Rights and advocating for her

clients, including Rinaldi, in the exercise of their Petition Rights.

208. When homeowner grievants, including but not limited to Nora and Rinaldi, sought

review by Sellen of OLR employees’ decisions not to investigate homeowner grievances, he

acted as if he was presiding as an appellate judge and upheld his subordinate’s decisions not to

investigate homeowner grievances on clearly erroneous grounds, knowing that his disposition of

grievances cannot be reviewed, thereby concealing the operations of the Fraudulent Foreclosure

Action by declining to protect the public from the use of false pleadings, supported by forged

documents and authenticated by falsely sworn affidavits in Wisconsin foreclosure actions.

209. The extent of the collaboration between OLR and Nora’s and Rinaldi’s litigation

opponents was not discovered until March, 2016.

210. On or about March 31, 2018, OLR provided thousands of pages of internal

documents to Nora in discovery in the case titled In re the Disciplinary Proceedings Against

Wendy Alison Nora (Office of Lawyer Regulation v. Nora), Appeal No. 2013AP000653-D

(hereinafter Nora #1).

211. OLR’s internal documents produced in discovery (which were produced untimely)

consisted of hundreds of pages of emails which exposed regulatory capture by which the

Fraudulent Foreclosure Enterprise, through Wisconsin attorneys and staff of OLR and the

Wisconsin Supreme Court to further the operations of the Enterprise, although suspicions were

raised in early June, 2015, when OLR refused to consider evidence that a Wisconsin lawyer,

David M. Potteiger (Potteiger) had fabricated a copy of an email and falsely swore that the email

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was sent to Nora on August 25, 2009 at 4:20 p.m., after Nora discovered evidence that the email

could not have been sent to her on that date and at that time.

212. After being provided with evidence that the August 25, 2009 email could not have

been sent at 4:20 p.m. on that date, OLR continued to prosecute Nora on the alleged false

evidence, solicited and produced additional false evidence from Potteiger, and then prevented

Nora from defending herself with the substantial evidence of OLR’s conspiracy with Potteiger to

violate Nora’s statutory and constitutional rights in Nora #1.

213. The concealment of the false evidence created by Potteiger and produced by OLR

led to Nora’s suspension from the practice of law in Wisconsin for one (1) year (pending further

relief by Petition for Certiorari to the United States Supreme Court or other relief) now admitted

to have been recommended by Sellen.

214. Based on substantial evidence that OLR was engaged in a conspiracy with mortgage

servicer lawyers to conceal their litigation misconduct, King, a journalist and videographer

attended proceedings in In re the Disciplinary Proceedings Against Wendy Alison Nora Office

of Lawyer Regulation v. Nora, No. 2013AP002442-D (OLR v. Nora), hereinafter Nora #2, for the

purpose of making a visual record of the Nora #2 proceedings.

215. On March 23, 2017, in the course of the Nora #2 proceedings, King was physically

assaulted by Rattan.

216. The assault on King was prevented and, upon information and belief, was intended

to prevent King from visually recording the Nora #2 proceedings.

217. Rattan was not removed from the proceedings in Nora #2 after he assaulted King.

218. Defendant James J. Winiarski (Winiarski), purporting to preside as referee in Nora

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#2, did not even admonish Rattan for assaulting King on March 23, 2017, but instead expressed

his own discomfort with the presence of King, in the capacity of what he himself characterized as

“the press”.

219. In violation of the First Amendment to the United States Constitution and Article

One, Section 3 of the Wisconsin Constitution, King was removed from the proceedings in Nora

#2 by Defendant James J. Winiarski (Winiarski) on March 24, 2017 when King expressed his

intention to lodge a complaint for violations of his rights, after King was physically assaulted by

Rattan.

220. When King filed a grievance with OLR for Rattan’s conduct on March 23, 2017,

Rattan was provided with a diversion agreement from which no discipline would be forthcoming

upon successful completion, whereas on August 8, 2018, Winiarski recommended that Nora be

suspended for consecutive period of two (2) years for assisting her clients in the exercise of their

Petition Rights based on his conclusion that Nora is a danger to the public and the legal system.

221. Nora has never conducted herself in the threatening, intimidating and disruptive

manner that Rattan conducted himself in the presence of Winiarski.

222. Winiarski, who did not take any action when Rattan disrupted the hearing on March

23, 2017, has recommended that Nora be suspended from practicing law in Wisconsin because

she is dangerous to the public and the legal system for the actions she took to represent Rinaldi

and Sheila M. Spencer.

223. The suspension of Nora in Nora #1 resulted in injury to the Plaintiffs Nora and

Nora’s clients, who were being represented by Nora at the time the suspension Order was

entered, including, but not limited to Rinaldi.

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224. Nora was denied Equal Protection of the Laws of the State of Wisconsin because no

elected judge conducted the evidentiary proceedings in Nora #1 and no justice of the Wisconsin

Supreme Court wrote the March 30, 2018 Opinion and Order.

225. Under SCR 22.16(1), the WISCONSIN SUPREME COURT purports to empower

referees appointed with the powers of a circuit court judge, but the referees who are Defendants

herein are lawyers admitted to practice before the Wisconsin Supreme Court and have never been

elected as required to constitutionally exercise the powers purportedly granted to them under

SCR 22.16(1).

226. Plaintiff Nora alleges that SCR 22.16(1) is unconstitutional on its face or as applied

to her in the subject proceedings titled Office of Lawyer Regulation v. Nora, No. 2013AP000653-

D (hereinafter Nora #1) and Office of Lawyer Regulation v. Nora, No. 2015AP002442-D

(hereinafter Nora #2).

227. SCR 21.15(4) requires all attorneys admitted to practice law in Wisconsin to

cooperate with OLR in the investigation, prosecution, and disposition of grievances and

complaints filed with or by the director of OLR and makes the wilful violation of the cooperation

requirement grounds for disciplinary action against an attorney admitted to practice law in the

Wisconsin.

228. Goldman and Winiarski in this Complaint are admitted to practice law in the

Wisconsin and have never been elected to serve as circuit court judges.

229. SCR 21.15(4) creates a conflict of interest as defined under SCR 21.13 pursuant to

SCR 60.04(4) for referees who are Wisconsin lawyers because they are required to cooperate

with OLR in disciplinary proceedings.

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230. SCR 60.04(4)(a) provides that a judge is required to recuse himself or herself when

his or her impartiality might be reasonably questioned.

231. By making attorneys admitted to practice before the Wisconsin Supreme Court

subject to discipline for noncooperation with the prosecution in a lawyer disciplinary proceeding,

an attorney practicing law in Wisconsin who acts as a referee in a lawyer disciplinary

proceedings cannot be neutral and detached, but is required to cooperate with the OLR.

232. Plaintiff Nora alleges that SCR 21.15(4) renders disciplinary proceedings in which

lawyers admitted to practice before the Wisconsin Supreme Court, but who are not and never

have been elected judges, are appointed as referees unconstitutional per se or as applied to her in

the subject proceedings titled Office of Lawyer Regulation v. Nora, No. 2013AP000653-D

(hereinafter Nora #1) and Office of Lawyer Regulation v. Nora, No. 2015AP002442-D

(hereinafter Nora #2).

233. Goldman and Winiarski cooperated with OLR in Nora #1 and Nora #2, respectively,

by preventing Nora from defending herself in violation of her First Amendment Right to petition

the judiciary for redress of grievances (Petition Rights) and her Fourteenth Amendment Right to

Due Process, guaranteed by the Constitution of the United States.

234. Winiarski prevented King from reporting on the Nora #2 proceedings by ejecting

King from the proceedings in retaliation for King preserving his right to petition the Wisconsin

Supreme Court for redress of his grievance against Rattan.

235. Rather than investigate grievances filed by homeowners with OLR under Supreme

Court Rules (SCR) Chapter 22, including, but not limited to the grievances filed by Plaintiffs

Nora, Rinaldi and other homeowners alerting OLR to the use of false pleadings, supported by

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false copies of documents or forged documents, authenticated by falsely sworn affidavits or

testimony as unsubstantiated or otherwise not warranting formal investigations in violation of

Wis. Stat. sec. 946.12(3), OLR employees, supervised by Sellen, refused to investigate

homeowner grievances on clearly erroneous grounds, including, but not limited to the completely

false position that OLR does not investigate grievances filed by persons who are not clients of the

lawyers against whom grievances are filed in the case of Nora’s grievance against Arthur

Moglowsky and, most often, for “insufficient” evidence of violations of the Code of Professional

Conduct as was the case in Rinaldi’s grievances against multiple lawyers participating in the

Fraudulent Foreclosure Enterprise.

236. When homeowner grievants sought review by Sellen of OLR employees’ decisions

not to investigate homeowner grievances, he acted as if he was presiding as an appellate judge

and upheld his subordinate’s decisions not to investigate homeowner grievances on clearly

erroneous grounds.

237. While repeatedly refusing to investigate grievances filed by homeowners, OLR used

false documents and falsely sworn affidavits created by Wisconsin lawyer Potteiger to injure

Plaintiff Nora’s property interests and her right to represent homeowners in an effort to “curtail”

her representation of homeowners at the request of and in collaboration with Nora’s litigation

opponents and the litigation opponents of Nora’s clients.

238. The State of Wisconsin is expressly liable for Nora’s damages under Wis. Stat. sec.

146.84.

239. The Wisconsin Supreme Court in its administrative capacity is liable for claims of

injury arising under Monell v. Department of Social Services, 436 U.S. 658 (1978) for facial and

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“as applied” unconstitutional policies and procedures of the WISCONSIN SUPREME COURT

and the LAWYER REGULATION SYSTEM and for declaratory and injunctive relief allowed by

Supreme Court of Virginia v. Consumers Union of the United States, Inc., 446 U.S. 719 (1980)

240. The Defendants named in their individual capacities are joined in their individual

capacities for violations of Nora’s rights to Due Process and Equal Protection of the Laws of the

State of Wisconsin under Wis. Stat. sec. 146.82(5)(c) and 146.84(1)(bm) guaranteed by the

Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the

Wisconsin Constitution, for unreasonable search and seizure of her confidential medical

information by the knowing unlawful disclosure and re-disclosure thereof without her consent

required by Wis. Stat. sec. 146.82(5)(c) in violation of Nora’s rights guaranteed by the Fourth

Amendment to the United States Constitution; for conspiracy with the Wisconsin-licensed

attorneys to silence Nora’s Right to Petition the Judiciary for Redress of Grievances (Petition

Rights) and the Petition Rights of the her clients, guaranteed by the First Amendment to the

United States Constitution and by Article One, Section 4 of the Wisconsin Constitution and for

violation of the duties owed to Nora not to be punished for exercising her rights as a property

owner in the State of Wisconsin to be protected from violations of criminal law by Wisconsin

attorneys.

241. The Defendants named in their individual capacities are joined in their individual

capacities for violations of King’s rights to Due Process and Equal Protection of the Laws of the

State of Wisconsin guaranteed by the Fourteenth Amendment to the United States Constitution

and Article One, Section 1 of the Wisconsin Constitution and for conspiracy with the Wisconsin-

licensed attorneys to silence King’s First Amendment rights as a journalist and Winiarski and

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Sellen are specifically liable for the violation of King’s Right to Petition the Judiciary for

Redress of Grievances (Petition Rights), guaranteed by the First Amendment to the United States

Constitution and by Article One, Section 4 of the Wisconsin Constitution.

242. The Defendants named in their individual capacities are joined in their individual

capacities for violations of Rinaldi’s rights to Due Process and Equal Protection of the Laws of

the State of Wisconsin guaranteed by the Fourteenth Amendment to the United States

Constitution and Article One, Section 1 of the Wisconsin Constitution and for conspiracy with

the Wisconsin attorneys to interfere with Rinaldi’s First Amendment Right to Petition the

Judiciary for Redress of Grievances (Petition Rights), guaranteed by the First Amendment to the

United States Constitution and by Article One, Section 4 of the Wisconsin Constitution.

243. The Defendant Wisconsin Supreme Court, in its administrative capacity, and the

Defendants named in their individual capacities are joined for violations of Rinaldi’s rights to

Due Process and Equal Protection of the Laws of the State of Wisconsin guaranteed by the

Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the

Wisconsin Constitution and for conspiracy with the Wisconsin attorneys to interfere with

Rinaldi’s First Amendment Right to Petition the Judiciary for Redress of Grievances (Petition

Rights), guaranteed by the First Amendment to the United States Constitution and by Article

One, Section 4 of the Wisconsin Constitution and for violation of the duties owed to Rinaldi as a

property owner in the State of Wisconsin to be protected from violations of criminal law by

Wisconsin attorneys.

244. OLR, Sellen, Stieren, Kasieta, Parsons and Hannan used Nora’s confidential

medical information which was unlawfully taken in violation of a federal court seal and produced

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by one of Nora’s litigation opponents in order to deprive Nora of her property rights to her

license to practice law in the State of Wisconsin, in an effort to punish Nora for the lawful

exercise of her Petition Rights and for assisting her clients in the exercise of their Petition Rights

in violation of her rights to Due Process and Equal Protection of the Laws, guaranteed by the

Fourteenth Amendment to the United States Constitution and Article One, Section 1 of the

Wisconsin Constitution.

245. Nora and Rinaldi produced substantial, indeed VAST evidence to OLR which

established that certain Wisconsin-licensed lawyers were engaging in and facilitating mail fraud

and wire fraud in violation of Racketeer Influenced and Corrupt Organizations Act (RICO), 18

U.S.C. sec. 1961, et seq. and the Wisconsin Organized Crime Control Act (WOCCA) Wis. Stat.

sec. 946.80, et seq., in violation of the Code of Professional Conduct, injuring the property and

allowing the property of the Plaintiffs Nora and Rinaldi as well as hundreds of other Wisconsin

homeowners to be injured.

246. The Defendants who are employees or agents of OLR and the Wisconsin Supreme

Court have the positive statutory duty to prevent the injuries to the public when Wisconsin-

licensed attorneys commit criminal acts.

247. The successful continuation of the Fraudulent Foreclosure Enterprise depends upon

concealment of its operations.

248. All of the named Defendants participated in the concealment of the Fraudulent

Foreclosure Enterprise described herein by their specified actions taken under color of state law

to prevent the Plaintiffs from exercising their Petition Rights and to prevent the exposure of the

Fraudulent Foreclosure Enterprise to the public.

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249. Nora and Rinaldi attempted to report the operation of the Fraudulent Foreclosure

Enterprise to OLR, as did other homeowners.

250. Had OLR investigated the evidence which shows the operation of the

Fraudulent Foreclosure Enterprise in which Wisconsin licensed lawyers participate by filing

false pleadings, supported by false or forged copies of documents and falsely sworn affidavits, it

is believed in good faith, Rinaldi would not have spent over a decade in litigation to protect the

property interests in the Rinaldi Homestead and hundreds of Wisconsin homeowners would have

been protected from similar misconduct affecting their property rights and interests resulting in

the loss of hundreds of Wisconsin homes to foreclosure based on false documents.

251. Instead, OLR dismissed homeowners’ grievances and collaborated with Nora’s

litigation opponents to prevent her from exercising her Petition Rights and advocating for her

clients in the exercise of their Petition Rights.

252. The extent of the collaboration between OLR and Nora’s and Rinaldi’s litigation

opponents was not discovered until March, 2016.

253. On or about March 31, 2018, OLR provided thousands of pages of internal

documents to Nora in discovery in the case titled In re the Disciplinary Proceedings Against

Wendy Alison Nora (Office of Lawyer Regulation v. Nora), Appeal No. 2013AP000653-D

(hereinafter Nora #1).

254. The internal documents produced in discovery (which were produced untimely)

consisted of hundreds of pages of emails which exposed regulatory capture by which the

Fraudulent Foreclosure Enterprise, through its Wisconsin-licensed attorneys and staff of OLR

and the Wisconsin Supreme Court to further the operations of the Enterprise, although suspicions

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were raised in early June, 2015, when OLR refused to consider evidence that a Wisconsin-

licensed lawyer, David M. Potteiger (Potteiger) had fabricated a copy of an email and falsely

sworn that the email was sent to Nora on August 25, 2009 at 4:20 p.m., after Nora discovered

evidence that the email could not have been sent to her on that date and at that time.

255. After being provided with evidence that the August 25, 2009 email could not have

been sent at 4:20 p.m. on that date, OLR continued to prosecute Nora on the alleged false

evidence, solicited and produced additional false evidence from Potteiger, and then prevented

Nora from defending herself with the substantial evidence of OLR’s conspiracy with Potteiger to

violate Nora’s statutory and constitutional rights in Nora #1.

256. The concealment of the false evidence created by Potteiger and produced by OLR

led to Nora’s suspension from the practice of law in Wisconsin for one (1) year now admitted to

have been recommended by Sellen (pending further relief by Petition for Certiorari to the United

States Supreme Court or other relief).

257. Based on substantial evidence that OLR was engaged in a conspiracy with mortgage

servicer lawyers to conceal their litigation misconduct, King, a journalist and videographer

attended proceedings in In re the Disciplinary Proceedings Against Wendy Alison Nora Office

of Lawyer Regulation v. Nora, No. 2013AP002442-D (OLR v. Nora), hereinafter Nora #2, for the

purpose of making a visual record of the Nora #2 proceedings.

258. On March 23, 2017, in the course of the Nora #2 proceedings, King was physically

assaulted by Rattan.

249. The assault on King was not prevented by Winiarski and, upon information and

belief, was intended to prevent King from visually recording the Nora #2 proceedings and

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reporting on the public events.

250. Rattan was not removed from the proceedings in Nora #2 by Winiarski after he

assaulted King.

251. Winiarski, purporting to preside as referee in Nora #2, did not even admonish

Rattan for assaulting King on March 23, 2017, but instead expressed his own discomfort with the

presence of King, in the capacity of what he himself characterized as “the press”.

252. In violation of the First Amendment to the United States Constitution and Article

One, Section 3 of the Wisconsin Constitution, King was eventually removed from the

proceedings in Nora #2 by Winiarski on March 24, 2017 when King expressed his intention to

lodge a complaint for violations of his rights, after King was physically assaulted by Rattan.

253. Some members of the public who were entitled to attend the public proceedings in

Nora #2 chose not to attend because they were expecting to have access to King’s video

recording of the proceedings and the public was denied access to the video recording which had

been arranged at the expense of time, travel and technology to each of the Plaintiffs King and

Nora in the respective amounts of expenses to be proved at trial.

254. Nora and King intended to have King’s video of the entire proceedings made

publicly available in video format and to have excerpts of the complete video published.

255. When King filed a grievance with OLR for Rattan’s conduct on March 23, 2017,

Rattan was provided with a diversion agreement from which no discipline would be forthcoming

upon successful completion, whereas on August 8, 2018, Winiarski recommended that Nora be

suspended for consecutive period of two (2) years for assisting her clients in the exercise of their

Petition Rights based on his conclusion that Nora is a “danger to the public and the legal

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system.”

256. Nora has never conducted herself in the threatening, intimidating and disruptive

manner that Rattan conducted himself in the presence of Winiarski.

257. The suspension of Nora in Nora #1 resulted in injury to the Plaintiffs Nora and

Nora’s clients, who were being represented by Nora at the time the suspension Order was

entered, including, but not limited to Rinaldi, some of whom may seek leave to intervene in these

proceedings.

258. Nora was denied Equal Protection of the Laws of the State of Wisconsin in her right

to the protection of Wis. Stat. sec. 146.82(5) and because no elected judge conducted the

evidentiary proceedings in Nora #1 and no justice of the Wisconsin Supreme Court wrote the

March 30, 2018 Opinion and Order.

259. This is an action for damages for violation of the Plaintiffs’ civil rights under 42

U.S.C. sec. 1983, for treble damages under 18 U.S.C. sec. 1964(c) to each of the Plaintiffs for

the violation of RICO and/or for double damages to each of the Plaintiffs under Wis. Stat. sec.

946.87(4) under WOCCA, as well as for declaration of the Plaintiffs’ rights, for injunctive relief

against the continuing RICO operation and to have the Wisconsin LAWYER REGULATION

SYSTEM (LRS) declared unconstitutional as applied to these Plaintiffs.

260. James J. Winiarski (Winiarski) was the referee in Nora #2 and is joined in his

individual capacity because he was without subject matter jurisdiction or competency to proceed

under SCR 22.11 effective August 16, 2016, the date upon which he purported to allow OLR to

file the Second Amended Complaint in Nora #2 setting forth facts for which the preliminary

review panel had not found cause to proceed, contrary to SCR 22.11(2).

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261. Thereafter, Winiarski entered multiple orders intended to deprive Nora of her right

to defend herself in Nora #2 in violation of Nora’s Petition Rights and her Due Process Rights.

262. The Conduct complained of herein was initiated in the State of Wisconsin for the

benefit of a Fraudulent Foreclosure Enterprise operating in Wisconsin as well as nationally and

internationally.

263. The Conduct involves concealing evidence of crimes committed in intrastate and

interstate commerce by and for the benefit of the Fraudulent Foreclosure Enterprise, in which

Wisconsin licensed lawyers aid and abet their clients in conspiracy to produce false evidence,

authenticated by falsely sworn affidavits and testimony, in violation of the constitutional rights of

homeowners with intent to injure the property rights of homeowners and which has continued

unabated despite efforts to bring these serious issues to the SUPREME COURT OF

WISCONSIN, through its OFFICE OF LAWYER REGULATION (OLR).

264. Rather than investigate grievances filed by homeowners with OLR under Supreme

Court Rules (SCR) Chapter 22, including, but not limited to Nora and Rinaldi, OLR has

dismissed homeowner grievances alerting OLR to the use of false pleadings, supported by false

copies of documents or forged documents, authenticated by falsely sworn affidavits or testimony

as unsubstantiated or otherwise not warranting formal investigations in violation of Wis. Stat.

sec. 946.12(3) and has pursued Nora for reporting the misconduct of Wisconsin lawyers who act

to further the Fraudulent Foreclosure Enterprise to OLR.

265. While repeatedly refusing to investigate grievances filed by homeowners, OLR used

false documents and falsely sworn affidavits created by a Wisconsin licensed lawyer to injure

Plaintiff Nora’s property interests and her right to represent homeowners in an effort to “curtail”

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her representation of homeowners at the request of and in collaboration with Nora’s litigation

opponents and the litigation opponents of Nora’s clients.

266. The Defendants Wisconsin Supreme Court and OLR are joined in their

administrative and investigative capacities and the Defendants Sellen, Stieren, Kasieta, Parsons,

Hannan, St. Ores, Schwarzenbart and Goldman are joined in their individual capacities for

violations of Nora’s rights to Equal Protection of the Laws of the State of Wisconsin under Wis.

Stat. sec. 146.82(5)(c) and 146.84(1)(bm), guaranteed by the Fourteenth Amendment to the

United States Constitution and Article One, Section 1 of the Wisconsin Constitution; for

unreasonable search and seizure of her confidential medical information by the knowing

unlawful disclosure thereof without her consent required by Wis. Stat. sec. 146.82(5)(c) in

violation of Nora’s rights guaranteed by the Fourth Amendment to the United States

Constitution; for conspiracy with the Defendants Potteiger and Moglowsky to silence Nora’s

Right to Petition the Judiciary for Redress of Grievances (Petition Rights) guaranteed by the First

Amendment to the United States Constitution and by Article One, Section 4 of the Wisconsin

Constitution; and to deprive Nora of her property rights to her license to practice law in the State

of Wisconsin, in an effort to punish her for the lawful exercise of her Petition Rights in violation

of her rights to Due Process guaranteed by the Fourteenth Amendment to the United States

Constitution and Article One, Section 1 of the Wisconsin Constitution.

267. All of the named Defendants are joined in this action for their participation in the

concealment of the Fraudulent Foreclosure Enterprise described herein by their specified actions

taken under color of state law to prevent the Plaintiffs from exercising their Petition Rights and

to prevent the exposure of the Fraudulent Foreclosure Enterprise to the public by excluding the

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press from the proceedings.

268. Had OLR investigated the Fraudulent Foreclosure Enterprise in which Wisconsin

lawyers participate by filing false pleadings, supported by false or forged copies of documents

and falsely sworn affidavits, it is believed in good faith, that Rinaldi would not have spent over a

decade in litigation to protect his property interests in his Homestead, Nora would have been

protected from the fraudulent foreclosure of her Homestead and hundreds of Wisconsin

homeowners would have been protected from similar misconduct affecting their property rights

and interests.

269. Instead, OLR and its employees and agents collaborated with Nora’s litigation

opponents to prevent her from exercising her Petition Rights and advocating for her clients in the

exercise of their Petition Rights.

270. The extent of the collaboration between OLR and Nora’s litigation opponents was

not discovered until March, 2016, when OLR provided thousands of pages of internal

documents, although evidence was available as early as June, 2015, when OLR refused to

consider evidence that Wisconsin lawyer, David M. Potteiger (Potteiger) had fabricated a copy of

an email and falsely sworn that the email was sent to Nora on August 25, 2009 at 4:20 p.m. and

falslely denied that Exhibit B to Potteiger’s April 24, 2014 Affidavit was a forgery.

271. Kasieta conspired with Potteiger and Moglowsky to re-disclose Nora’s confidential

medical information to injure her property interests in her admission to practice law in Wisconsin

and Parsons acted in concert with Kasieta toward that end.

272. Kasieta and Parsons wilfully re-disclosed Nora’s confidential medical information

to discriminate against what they perceived to be a disability but did not allow her to explain that

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she had recovered from the underlying condition and when she recovered from the totally

disabling effects of a head injury including a temporary seizure disorder and seeking to have her

disciplined for having been afflicted in violation of the ADAA.

273. St. Ores conspired with Potteiger in pursuing the prosecution of Nora to the extreme

extent of acting in concert with Potteiger, having Potteiger advise her about the affects of current

case law on Nora’s defenses and providing her with facts (although, in significant part, false) to

support a legal theory of Nora’s motivation which was entirely false.

274. Stieren conspired with Potteiger and with Foshag to accomplish Potteiger’s stated

goal of curtailing Nora’s litigation directed toward exposing the Fraudulent Foreclosure

Enterprise operating in Wisconsin and throughout the nation.

275. Schwarzenbart denied the existence of the exculpatory evidence and then concealed

the exculpatory evidence which would have conclusively proven that the August 25, 2009 4:20

p.m. email was not and could not have been sent by Potteiger.

276. Schwarzenbart submitted an Affidavit on June 9, 2016 in which he vouched for

Potteiger’s credibility in Nora #2 to continue the concealment of the selective and vindictive

prosecution of Nora in an effort to deprive her of full and fair proceedings in her defense.

277. Stieren lied about the Investigative Report produced to the PRC in Nora #2 in order

to support the misrepresentation to Winiarski that the PRC had considered the record in the

Matter of Sheila M. Spencer, when he knew that the Investigative Report involved only the

Decision of the Seventh Circuit and not the record in the Wood County Circuit Court (Case No.

2009CV000283).

276. Stieren lied at the evidentiary hearing in Nora #1 when he swore under oath that he

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only spoke to Potteiger (in violation of the witness sequestration order) for five (5) minutes after

twice testifying that he conversed with Potteiger for approximately half an hour.

278. St. Ores and Schwarzenbart continued to prosecute Nora on the alleged false

evidence (forged Exhibit B purporting to be the email sent to Nora on August 25, 2009 at 4:20

p.m.) according to the falsely sworn April 24, 2014 Affidavit of Potteiger submitted by OLR in

Nora #1.

279. St. Ores solicited and produced additional false evidence from Potteiger, and then

Schwarzenbart and Goldman prevented Nora from defending herself with the substantial

evidence of OLR’s conspiracy with Potteiger to violate Nora’s statutory and constitutional rights

in Office of Lawyer Regulation v. Nora, No. 2013AP000652-D (OLR v. Nora), hereinafter Nora

#1.

280. Goldman participated in the concealment of the false evidence produced by

Potteiger ultimately known to be false by OLR.

281. Goldman prevented Nora from being able to present her defense throughout a

tortured process of discretionary abuses accumulated as evidence of actual bias from which

Goldman refused to be disqualified resulting in structural error.

282. The concealment of the false evidence created by Potteiger and produced by OLR

led to Nora’s suspension from the practice of law in Wisconsin for one (1) year (pending further

relief by Petition for Certiorari to the United States Supreme Court or other relief).

283. Based on substantial evidence that OLR was engaged in a conspiracy with mortgage

servicer lawyers to conceal their litigation misconduct, King, a journalist and videographer

attended proceedings in Office of Lawyer Regulation v. Nora, No. 2013AP002442-D (OLR v.

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Nora), hereinafter Nora #2, for the purpose of making a visual record of the Nora #2

proceedings.

284. On March 23, 2017, in the course of the Nora #2 proceedings, King was physically

assaulted by a mortgage servicer’s lawyer, Mark W. Rattan (Rattan). The assault on King was

intended to prevent King from visually recording the Nora #2 proceedings.

285. Having already been deprived of Due Process in Nora #1, Nora wanted to assure

that a visual record of the evidentiary hearing to be conducted ultra vires by Winiarski was made.

286. King, who was aware of the disciplinary proceedings against Nora (which he

recognized as being an attempt to silence the issues of homeowners because he has extensively

investigated and documented violations of property owners Due Process Rights in video format)

intended to report on the complete evidentiary proceedings to be recorded in video format.

287. On October 31, 2016, the date the evidentiary hearing was scheduled to commence,

King set up his recording technology at the hearing location.

288. Winiarski, preemptively and without cause, warned King that he would eject King

from the proceedings if there was any “intimidation of witnesses”.

289. The evidentiary hearing set to commence of October 31, 2016 was rescheduled due

to the unavailability of Nora’s co-counsel, who was prevented from traveling from the

Minneapolis, Minnesota area to Madison, Wisconsin for medical reasons.

290. Thereafter, Nora was injured on January 17, 2017 in a fall on ice when she hit her

head on pavement and the evidentiary hearing was again rescheduled to begin on March 22,

2017.

291. Schwarzenbart immediately launched an effort to engage in ADAA discrimination

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by harassing her about her condition on January 18, 2017 and for weeks thereafter, but it appears

that OLR subsequently decided to disengage from disability discrimination against Nora.

292. Winiarski, however, engaged in a persistent in an effort to compel Nora to claim

unfitness to practice law in the course of the disciplinary proceedings, as evidenced by a series of

intrusive orders directed against her because of her temporary disability.

293. King was present at the evidentiary hearing on March 22, 2017 and recorded the

proceedings in video format on November 22 and 23, 2017.

294. Nora had been charged by OLR with violations of the Code of Professional Conduct

for her defense of the Rinaldi Homestead in Nora #2 against WELLS FARGO and its affiliates,

arguing that WELLS FARGO and its law firms were using forged documents to attempt to

foreclose against the Rinaldi Homestead.

295. By agreement with her co-counsel, Nora, who was still impaired by her recent

injury, was nevertheless responsible for the cross-examination of Attorney Dykeman, who

represented WELLS FARGO, certain of its affiliated entities, and claimed to represent HSBC

Bank USA, N.A., “HSBC Bank USA, National Association, as Trustee for Wells Fargo Asset

Securities Corporation Home Equity Asset-Backed Certificates, Series 2005-2” and/or “HSBC

Bank USA, National Association, as Trustee for Wells Fargo Home Equity Asset-Backed

Securities 2005-2 Trust, Home Equity Assert(sic)-Backed Certificates, Series 2005-2” and/or

“HSBC Bank USA, N.A. as Trustee WFHET 2005-1”, despite the true facts of Wells Fargo’s

interest in the Rinaldi collateral documents and the disputed claim for secured debt.

296. Before Nora was able to complete her examination of Attorney Dykeman, Rattan

rose from his chair and physically assaulted King in an effort to interfere with the video

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recording in a loud, boisterous and threatening manner, disrupting the hearing.

297. Winiarski did not take any action to reprimand Rattan for the disruption of the

hearing and did not eject him from the proceedings.

298. Nora was distracted by Rattan’s disruption of the evidentiary hearing which affected

her concentration when examining Rattan’s client and associate, Dykeman.

299. Winiarski attempted to justify Rattan’s disruption of the hearing suggesting that the

room was small and that somehow King’s pre-approved journalistic presence justified Rattan’s

assault on King and disruption of the hearing.

300. On March 24, 2017, King was ejected from the hearing by Winiarski when he

advised Winiarski of his intention to complain about Winiarski’s refusal to admonish Rattan for

the assault on King to the WISCONSIN SUPREME COURT in retaliation for King giving notice

to Winiarski of his intent to exercise his Petition Rights.

301. King was subjected to the retaliatory ejection before Nora was able to commence

her testimony in her defense, depriving Nora of the video record King had intended to make and

depriving the public of the full video report King was prepared to make, in violation of the First

Amendment Rights of Nora and King and their rights under Article One, Section 3 of the

Wisconsin Constitution, contrary to 42 U.S.C. sec. 1983.

302. King filed a grievance with OLR regarding the misconduct of Rattan at Nora’s

hearing which Rattan had disrupted.

303. During the OLR investigation, Rattan falsely claimed that the unaltered video

evidence of the assault had been altered by King, on letterhead provided by his Wisconsin-

licensed attorney who serves with Schwarzenbart on a committee appointed to make

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recommendations to improve OLR procedures.

304. Rattan was found by OLR to have shown no remorse and to have acknowledged no

wrongdoing.

305. Nevertheless, Sellen approved the resolution of King’s grievance by having Rattan

successfully complete a diversion program (upon information and belief he may have proposed

it). Disposition by diversion reserved for situations in which the outcome of the disciplinary

process was likely to be no more severe than a private reprimand. SCR 22.10(3)(a).

306. There is no precedent for concluding that discipline no more severe than a private

reprimand should be the outcome for disrupting a hearing by assaulting a journalist with the

intent to prevent reporting at a public hearing, see, e.g. Office of Lawyer Regulation v. Sommers,

339 Wis.2d 580, 811 N.W.2d 387, 2012 WI 33 (Wis., 2012); or making a misrepresentation to

OLR in the course of a disciplinary investigation, as the OLR investigator found that Rattan had

done, contrary to SCR 21.15(4) and SCR 20:8.1.

307. Sellen abused his discretion by permitting the diversion of discipline for a serious

violation of the Code of Professional Conduct in violation of the Equal Protection Rights of

King, Nora, and Rinaldi and contrary to Wis. Stat. sec. 946.12(3).

308. In the meantime, Winiarski, claiming continuing subject matter jurisdiction and/or

competency contrary to SCR 22.11(2) and acting upon the ultra vires Second Amended

Complaint in Nora #2 which OLR attempted to amend according to the proof and which

Winiarski himself amended, contrary to the evidence in the record, has recommended that Nora

be subjected to a suspension of an additional two (2) years because Nora, who, unlike Rattan, has

never disrupted a hearing, “is dangerous to the public and legal system”.

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309. The remarkable distinction between the treatment of Rattan, an attorney whose law

firm represents financial institutions and Nora, who defends property owners against frauds being

committed against them by financial institutions, demonstrates the constitutional violations by

the LRS and OLR, as agents for the Wisconsin Supreme Court of which these Plaintiffs

complain.

310. Nora filed a grievance against Attorney Arthur Moglowsky (Moglowky) in 2009

which was not investigated because the OLR intake investigator, Jonathan Zeisser, determined

that OLR does not investigate grievances unless the grievance is filed by a client, which is

patently false.

311. Nora sought Sellen’s review of the determination not to investigate her grievance

and Sellen decided not to investigate Nora’s grievance on other grounds, indicating that a

complete record to support Nora’s position has not been provided to him by Nora. The

additional evidence (the Transcript of the May 19, 2009 Hearing in the foreclosure action) was

in Nora’s possession and could have been presented if the investigation, falsely denied by the

intake investigator, has been allowed to proceed.

312. Potteiger filed the grievance against Nora, in part, in retaliation for Nora’s exercise

of her Petition Rights in filing the Moglowsky grievance, which she then believed she was

required to do as a mandatory reporter under SCR 20:8.3(a).

313. OLR then investigated Nora at the behest of Potteiger, an employee, of

Moglowsky’s law firm, BASS & MOGLOWSKY, S.C., using confidential medical information

obtained without Nora’s consent, depriving Nora of the protection of Wis. Stat. sec. 146.82(5),

in violation of Wis. Stat. sec. 146.84 in retaliation for her exercise of her Petition Rights.

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314. Rinaldi filed grievances with OLR complaining of litigation misconduct by

Wisconsin attorneys in the first foreclosure action commenced in Kenosha County Circuit Case

No. 2009CV000353, complaining that false documents were being filed by WELLS FARGO

attorneys in the circuit court action and he continued to complain to OLR that false documents

were filed in the public record into 2014, when he produced the newly discovered Wells Fargo

Home Mortgage Foreclosure Attorneys Manual (the Manual) which instructs attorneys how to

obtain false documents for filing in foreclosure cases.

315. OLR refused to investigate any of Rinaldi’s grievances, yet it charged Nora with

misconduct for producing the Manual as new evidence in defense of the Rinaldi Homestead in

Nora #2.

316. Rinaldi appealed from the award of summary judgment to WELLS FARGO as the

unnamed real party in interest and not HSBC Bank USA, N.A. as Trustee for the Wells Fargo

Home Equity Asset-Backed 2005-2 Trust, the correct name for the Real Estate Mortgage

Investment Conduit (REMIC) Trust to which attorneys for WELLS FARGO misled Rinaldi to

believe was the REMIC Trust to which the Rinaldi Note and Mortgage had been conveyed, while

suing for foreclosure and bringing claims against the Rinaldi Homestead in three (3) other

“similar” names.

317. On November 13, 2017, it was discovered, after nine (9) years of litigation with

WELLS FARGO, using three (3) different but “similar” names, the REMIC Trust into which

WELLS FARGO’s affiliate, Wells Fargo Asset Securities Corporation, had reported to the

Securities and Exchange Commission (SEC) that the Rinaldi Note and Mortgage was

“deposited” into the Wells Fargo Mortgage-Backed Securities 2005-7 Trust.

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319. WELLS FARGO is both the Trustee and the servicing agent for the Wells Fargo

Mortgage-Backed Securities 2005-7 Trust.

320. Rinaldi had been misled for a decade by the litigation conduct of WELLS FARGO’s

lawyers, Dykeman and others, using the techniques described in the Manual and misdirecting

him to seek redress against the wrong party.

321. Nora, who holds a mortgagee interest in the Rinaldi Homestead for services

provided in the defense of the Rinaldi Homestead, is the Intervenor-Appellant in the Rinaldi

appeal still pending on her Opening Brief before the Wisconsin Court of Appeals in Appeal No.

2018AP001390.

323. On November 7, 2018, Dykeman made recklessly false statements to prevent

Rinaldi from obtaining a first extension of time to file his Opening Brief in his appeal from

Summary Judgment and attempted to prevent Nora from pursuing her appeal as proposed

intervenor in the second foreclosure action, including, but not limited to:

a. Dykeman asserted as fact that Nora was continuing to practice law as the representative

of Rinaldi in her capacity as Intervenor-Appellant when, as a matter of law, the interest of Nora

and Rinaldi are adverse (she is the mortgagee and Rinaldi is the mortgagor);

b. Asserting as a fact that Nora was practicing law in violation of her post-disciplinary

suspension requirements, when Nora disclosed her activities as mortgagee in the Rinaldi case and

OLR determined that her Affidavit, including that disclosure, was apparently in compliance with

the requirements of SCR 22.26. See ¶¶326 and 327, below.

324. Dykeman’s most recent known or recklessly false statements were transmitted by

mail and wire in violation of Wis. Stat. sec. 946.82(4) and are the most recent predicate acts of

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racketeering in violation of Wis. Stat. secs. 946.80-946.87, and occurred after the June 14, 2018

Judgment was granted in the second foreclosure action.

325. Schwarzenbart’s most recent contribution to the operation of the Fraudulent

Foreclosure Enterprise occurred on November 26, 2018, when he attempted to prevent Nora from

having the opportunity to file motions in the appeal of Winiarski’s August 8, 2018 Report and

Recommendation to the Wisconsin Supreme Court in Nora #2 by opposing Nora’s First Motion

for Extension of Time to File her Opening Brief.

326. Like Dykeman in the Rinaldi appeal in Appeal No. 2018AP001390, Schwarzenbart

falsely claimed that Nora was violating the conditions imposed by the March 30, 2018 Opinion

and Order of the Wisconsin Supreme Court, modified on June 12, 2018.

327. Schwarzenbart, as retained counsel for OLR in Nora #1 and Nora #2, knew or

should have known that OLR had determined that Nora’s disclosed post-suspension involvement

in the second Rinaldi foreclosure case as proposed intervenor and on appeal as Intervenor-

Appellant had been determined by OLR on June 18, 2018 to be in apparent compliance with the

post-disciplinary requirements of SCR 22.26, because OLR wrote, “The affidavit appears to

comply with the requirements of SCR 22.26 and it has been placed it in our file concerning your

post-discipline compliance.”

328. Schwarzenbart’s knowing or recklessly false statements in his opposition filed on

November 26, 2018 were transmitted by mail and wire to Nora in violation of Wis. Stat. sec.

946.82(4), adopting predicate acts of racketeering set forth in 18 U.S.C. sec. 1961(1), which

includes mail fraud in violation of 18 U.S.C. sec. 1341 and wire fraud in violation of 18 U.S.C.

sec. 1343.

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329. The Fraudulent Foreclosure Enterprise has been operating in the State of Wisconsin

using the Wisconsin Unified Court System to launder real estate titles obtained by judgments

entered in Wisconsin circuit courts based on false pleadings, supported by forged documents

authenticated by falsely sworn affidavits contrary to Wis. Stat. secs. 943.20(1)(d), 943.38 and

946.32, using the same scheme as that employed in both Rinaldi foreclosure actions in the

Kenosha County Circuit Court (Case Nos. 2009CV000353 and 2017CV000473) and in Nora’s

second foreclosure case in Dane County Circuit Court (Case No. 2009CV001096).

330. Notice will be given to the Attorney General at the Wisconsin Department of

Justice, 114 East State Capitol, Madison, Wisconsin 53702 that the Plaintiffs challenge the

constitutionality of the LAWYER REGULATION SYSTEM (LRS), facially and as applied to

Nora, King, and Rinaldi.

331. The Unnamed Individuals, Governmental Agencies and Corporate Entities Yet to Be

Named or Identified acted in concert with the named Defendants or at the direction of the named

Defendants in the actions complained of or engaged in other actions or omissions which are

actionable torts to be subsequently pleaded herein.

COUNT ONE (Nora only) for


Violations of Wis. Stat. sec. 146.82(5)( c), Actionable Pursuant to
Wis. Stat. sec. 146.84(1)(b) and (bm) and (2), as applicable, as to the State of Wisconsin; the
Wisconsin Lawyer Regulation System (LRS); the Wisconsin Supreme Court in its
administrative and investigative capacity; named participants in the Wisconsin Lawyer
Regulation System (LRS) and named employees and agents of the Office of Lawyer
Regulation (OLR), as agents for the Wisconsin Supreme Court; Sellen, Stieren,
Kasieta, Parsons, and Hannan

335. Plaintiff re-alleges ¶¶1-9 and 12-331, above, as if fully set forth herein.

336. Plaintiff has been damaged by the unlawful re-disclosure of her confidential medical

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records by the Defendants and others who obtained Plaintiff’s confidential medical records by

and through them, including, but not limited to actual damages, special damages, reputational

damages, and mental anguish.

337. Sellen was Stieren’s supervisor and failed to supervise Stieren to assure compliance

with Wis. Stat. secs. 146.82(5)(c) and to prevent violations of Wis. Stat. secs. 146.84(1)(b) or

(bm) and 146.84(2)(a)2.

338. Sellen assigned the District Nine Ethics Committee to investigate Potteiger’s

grievance and is responsible for Stieren re-disclosing Plaintiff’s confidential medical records to

the District Nine Ethics Committee because he failed to supervise Stieren to assure compliance

with Wis. Stat. secs. 146.82(5)(c) and to prevent violations of Wis. Stat. sec. 146.84(1)(bm).

339. Sellen failed to take any remedial action upon being informed of the violations of

Wis. Stat. secs. 146.82(5)(c) by Stieren, Kasieta, Parsons, and Hannan to prevent further damage

to the Plaintiff.

340. Plaintiff has been damaged by Sellen’s negligent supervision of Stieren and is

entitled to her damages resulting from Sellen’s negligent supervision including, but not

limited to actual damages, special damages, reputational damages, and mental anguish.

341. Plaintiff has been damaged by the unlawful re-disclosure of her confidential medical

records by the Defendants and others who obtained Plaintiff’s confidential medical records by

and through them, including, but not limited to actual damages, special damages, reputational

damages, and mental anguish.

342. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.

146.84(1)(bm).

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COUNT TWO (Nora only) for


Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights under the Fourth Amendment to
the United States Constitution by the Unlawful Search and Seizure of Nora’s Confidential
Medical Information and Temporary Guardianship Records and of the Fourth
Amendment to United States Constitution and Article One, Section 11 of the Wisconsin
Constitution, Depriving Nora of Equal Protection of Wis. Stat. sec. 146.82(5)( c), actionable
pursuant to Wis. Stat. sec. 146.84(1)(b) and (bm), as applicable, as to the State of
Wisconsin; the Wisconsin Supreme Court in its administrative and legislative capacity;
named participants in the Wisconsin Lawyer Regulation System (LRS) and named
employees and agents of the Office of Lawyer Regulation (OLR), as agents for the
Wisconsin Supreme Court; Sellen, Stieren, Kasieta, Parsons, and Hannan

343. Plaintiff Nora re-alleges ¶¶1-9, 12-331, and 333-342, above, as if fully set forth

herein.

344. By the re-disclosures of Nora’s confidential medical information Sellen, Stieren,

Kasieta, Parsons and Hannan violated Wis. Stat. secs. 146.82(5)(c) and Wis. Stat. secs.

146.84(1)(b) or (bm) and 146.84(2)(a)2 and 943.30(5).

345. By the re-disclosures of Nora’s confidential medical information by Sellen, Stieren,

Kasieta, Parsons and Hannan violated Nora’s rights under the Fourth Amendment to the United

States Constitution and Article One, Section 11 of the Wisconsin Constitution, contrary to Wis.

Stat. secs. 146.82(5)(c) and Wis. Stat. secs. 146.84(1)(b) or (bm) and 146.84(2)(a)2.

346. By the re-disclosures of Nora’s confidential medical information, allowed by Sellen,

by Stieren, Kasieta, Parsons and Hannan, deprived Nora of her rights to her Due Process rights

under the Laws of the State of Wisconsin at Wis. Stat. secs. 146.82(5)(c) and Wis. Stat. secs.

146.84(1)(b) or (bm) and 146.84(2)(a)2.

347. By the re-disclosures of Nora’s confidential medical information Stieren, Kasieta,

Parsons and Hannan deprived Nora of her rights to Equal Protection of the Laws of the State of

Wisconsin at Wis. Stat. secs. 146.82(5)(c) and Wis. Stat. secs. 146.84(1)(b) or (bm) and

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146.84(2)(a)2.

348. By using the requirement that Nora cooperate with OLR investigations under SCR

21.15(4) to obtain confidential guardianship court documents and re-disclosing the confidential

guardianship documents to Potteiger under the pretext of the policy of informing a grievant of an

attorney’s response, Stieren, supervised by Sellen, acting as agent for the Wisconsin Supreme

Court, a governmental entity of the State of Wisconsin, violated Nora’s confidentiality rights in

violation of her Due Process and Equal Protection Rights under the Fourteenth Amendment of

the United States Constitution and Article One, Section 1 of the Wisconsin Constitution.

349. Nora did not know that her confidential guardianship documents had been disclosed

to Potteiger until after she received the untimely discovery produced by OLR on March 31, 2018.

350. By using the requirement that Nora cooperate with OLR investigations under SCR

21.15(4) to obtain information from Nora regarding her work product in her client’s cases and

then re-disclosing her work product to Potteiger, along with her confidential guardianship court

documents under the pretext of informing a grievant of an attorney’s response, Nora was

deprived of her constitutional rights in violation of 42 U.S.C. sec. 1983.

351. Upon information and belief, were it not for the re-disclosure of Nora’s confidential

medical information, the District Nine Ethics Committee’s investigation would not have

recommended charges and no cause would have been found to charge Nora with ethics violations

in Nora #1.

352. In the alternative to ¶351, above, Nora’s legal and factual contentions would have

been taken seriously were it not for the disclosure of her confidential medical information.

353. Upon information and belief, had Hannan not failed to disclose his conflict of

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 87 of 102

interest, which Nora would not have waived requiring him to recuse himself from the PRC in the

Nora case, cause for formal changes would not have been found.

354. Nora has been damaged by the violation of her constitutional rights under the First,

Fourth and Fourteenth Amendments to the Constitution of the United States, contrary to 42

U.S.C. sec. 1983.

355. Nora is entitled to the remedies for violation of her statutory protections under

146.82(5)(c) and Wis. Stat. secs. 146.84(1)(b) or (bm) and 146.84(2)(a), (b) and/or (c) made

actionable under 42 U.S.C. sec. 1983, as set forth in this Count One, in an amount to be proved at

trial.

356. Nora has been damaged by the unlawful re-disclosure of her confidential medical

records by the Defendants and others who obtained Plaintiff’s confidential medical records by

and through them, including, but not limited to actual damages, special damages, reputational

damages, and mental anguish.

357. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.
COUNT THREE (Nora only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights to Due Process and Equal
Protection of the Laws guaranteed by the Fourteenth Amendment to the United States
Constitution and Article One, Section 1 of the Wisconsin Constitution in OLR’s
Investigative, Charging and Prosecutorial Process based on illegally obtained confidential
medical information as to the State of Wisconsin; the Wisconsin Supreme Court in its
administrative and investigative capacity; named participants in the Wisconsin Lawyer
Regulation System (LRS) and named employees and agents of the Office of Lawyer
Regulation (OLR), as agents for the Wisconsin Supreme Court; Potteiger, individually;
Moglowsky, individually; Fidelity National Title Company, in its corporate capacity and as
Respondeat Superior; Sellen, Stieren, Kasieta, Parsons, and Hannan

358. Plaintiff Nora re-alleges ¶¶1-9, 12-331, 333-341, and 343-357, above, as if

75
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 88 of 102

fully set forth herein.

359. Plaintiff Nora has been damaged by violation of her rights to Due Process and Equal

Protection of the Laws by the unlawful re-disclosure of her confidential medical records by the

Defendants and others who obtained Plaintiff’s confidential medical records by and through

them, including, but not limited to actual damages, special damages, reputational damages, and

mental anguish.

360. Defendants acted maliciously toward the Plaintiffs or in an intentional disregard of

the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.

361. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.
COUNT FOUR (Nora only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights under the First Amendment and
the Due Process Clause of the Fourteenth Amendment to the United States Constitution and
Article One, Sections 1 and 4 of the Wisconsin Constitution for prosecution of Nora for the
exercise of her Petition Rights in Nora #1 as to the State of Wisconsin; the Wisconsin
Supreme Court in its administrative, investigative and prosecutorial capacity; named
participants in the Wisconsin Lawyer Regulation System (LRS) and named employees and
agents of the Office of Lawyer Regulation (OLR), as agents for the Wisconsin Supreme
Court; Sellen, Stieren, St. Ores and Schwarzenbart, individually

362. Plaintiff Nora re-alleges ¶¶1-9, 12-331, 333-341, 343-357, and 359-361, above, as if

fully set forth herein.

363. Plaintiffs has been damaged by being punished for the exercise of her Petition

Rights, including, but not limited to actual damages, special damages, reputational damages, and

mental anguish.

364. Defendants acted maliciously toward the Plaintiff or with intentional disregard of

the rights of the Plaintiff, contrary to Wis. Stat. sec. 895.043.

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 89 of 102

365. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.

COUNT FIVE (Nora and King only) for


Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights under the First and Fourteenth
Amendments to the United States Constitution and Article One Sections 1, 3 and 4 of the
Wisconsin Constitution as to the State of Wisconsin; the Wisconsin Supreme Court in its
administrative capacity; named participants in the Wisconsin Lawyer Regulation System
(LRS) and named employees and agents of the Office of Lawyer Regulation (OLR), as
agents for the Wisconsin Supreme Court; Rattan, LITCHFIELD CAVO, LLP,
Dykeman, and Winiarski

366. Plaintiffs Nora and King re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, and

363-365, above, as if fully set forth herein.

367. Plaintiffs have been damaged by the interference with the exercise of Freedom

Speech and of the Press, in violation of 42 U.S.C. sec. 1983, including, but not limited to actual

damages, special damages, reputational damages, and mental anguish.

368. Defendants Rattan and Winarski acted maliciously toward Plaintiffs or in an

intentional disregard of the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.

369. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.
COUNT SIX (King only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of the First Amendment to the United
States Constitution and Article One Sections 3 and 4 of the Wisconsin Constitution as to the
State of Wisconsin; the Wisconsin Supreme Court in its administrative capacity; the Office
of Lawyer Regulation (OLR), as agent for the Wisconsin Supreme Court; Sellen, Rattan,
LITCHFIELD CAVO, LLP, Dykeman and Winiarski

370. Plaintiff King re-alleges ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365, and

367-369, above, as if fully set forth herein.

371. Plaintiff King has suffered damages as from the violation of his rights to Freedom

77
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 90 of 102

of Speech, functioning in his capacity as the press under the First Amendment to the Constitution

of the United States and Article One, Section 4 of the Constitution of the State of Wisconsin

which guarantee Freedom of the Press in violation of 42 U.S.C. sec. 1983, including, but not

limited to actual damages, special damages, reputational damages, and mental anguish in an

amount to be determined at trial.

372. King’s Petition Rights were violated by Winiarski when he ejected King from the

hearing in Nora #2 on March 24, 2017 in retaliation for King’s stated intention to exercise his

Petition Rights.

373. Defendants acted maliciously toward the Plaintiff or in an intentional disregard of

the rights of the Plaintiff, contrary to Wis. Stat. sec. 895.043.

374. Plaintiff is entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.

COUNT SEVEN (Nora and Rinaldi) for


Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First and
Fourteenth Amendments to the United States Constitution and Article One, Section 3 of the
Wisconsin Constitution as to the State of Wisconsin; the Wisconsin Supreme Court in its
administrative capacity; named participants in the Wisconsin Lawyer Regulation System
(LRS) and named employees and agents of the Office of Lawyer Regulation (OLR), as
agents for the Wisconsin Supreme Court; Sellen, Rattan, Dykeman,
LITCHFIELD CAVO, LLP, and Wells Fargo Bank, N.A.

375. Plaintiffs Nora and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361,

363-365, 367-369, and 371-374, above, as if fully set forth herein.

376. Upon information and belief, the named Defendants have failed to perform their

duties to protect Nora, Rinaldi and other homeowners from the criminal conduct of Wisconsin

attorneys in furtherance of the Fraudulent Foreclosure Enterprise in violation of their Petition

78
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 91 of 102

Rights.

377. Plaintiffs have been damaged by the violation of their Petition Rights, contrary to

42 U.S.C. sec. 1983, including, but not limited to actual damages, special damages, reputational

damages, and mental anguish in an amount to be determined at trial.

378. Defendants acted maliciously toward the Plaintiffs or in an intentional disregard of

the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.

379. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.
COUNT EIGHT (Nora and Rinaldi only) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First
Amendment to the United States Constitution and Article One Section 3 of the Wisconsin
Constitution as to the State of Wisconsin; the Supreme Court of Wisconsin, by its agents the
Lawyer Regulation System (LRS), Sellen, Goldman, and Winiarksi, in their claimed official
capacity and in their individual capacities; and Rattan and Dykeman, individually; and
Litchfield Cavo, LLP and Wells Fargo Bank, N.A.,
in their corporate and individual capacities

380. Plaintiff Nora and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-

365, 367-369, 371-374, and 376-379, above, as if fully set forth herein.

381. Plaintiffs were damaged by interference with the press to expose the activities at the

hearing in Nora #2.

382. Defendants acted maliciously toward the Plaintiffs or in an intentional disregard of

the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.

383. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.

79
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 92 of 102

COUNT NINE (Nora and Rinaldi only) for


Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First
Amendment and the Due Process Clause of the Fourteenth Amendment to the United States
Constitution and Article One, Sections 1 and 4 of the Wisconsin Constitution to as to the
State of Wisconsin; the Wisconsin Supreme Court in its administrative capacity; the Office
of Lawyer Regulation (OLR), as agent for the Wisconsin Supreme Court, Sellen, Stieren,
St. Ores, Schwarzenbart, Goldman, and Winiarski

384. Plaintiff Nora and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-

365, 367-369, 371-374, 376-379, and 381-383, above, as if fully set forth herein.

385. Upon information and belief, Plaintiffs Nora and Rinaldi and other clients of Nora

were damaged by the interference in their attorney-client relationship by the disclosure of Nora’s

confidential work product to Stieren, who re-disclosed her work product to Potteiger and Foshag,

while they were litigation opponents of Nora and Rinaldi, respectively.

386. Compensatory damages for injury to the confidential attorney-client relationship

include monetary loss and mental anguish in an amount to be proved at trial.

387. Defendants acted maliciously toward the Plaintiffs or in an intentional disregard of

the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.

388. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.
COUNT TEN (Nora, King and Rinaldi) for
Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First and
Fourteenth Amendments to the United States Constitution and Article One Sections 3 and 4
of the Wisconsin Constitution as to the State of Wisconsin, the Wisconsin Supreme Court in
its administrative capacity, the Office of Lawyer Regulation (OLR), as agent for the
Wisconsin Supreme Court, and Sellen

389. Plaintiffs Nora, King and Rinaldi re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-

361, 363-365, 367-369, 371-374, 376-379, 381-383, and 385-388, above, as if fully set forth

herein.

80
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 93 of 102

390. Plaintiffs have been damaged by the violation of their Petition Rights including, but

not limited to actual damages, special damages, reputational damages, and mental anguish.

391. Defendants acted maliciously toward the Plaintiffs or in an intentional disregard of

the rights of the Plaintiffs, contrary to Wis. Stat. sec. 895.043.

392. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.

COUNT ELEVEN (Nora, King and Rinaldi) for


Violations of 42 U.S.C. sec. 1983 by Deprivation of Rights guaranteed by the First and
Fourteenth Amendment to the United States Constitution and Article One Sections 3 and 4
of the Wisconsin Constitution as to by failure to adequately train and supervise referees of
the Lawyer Regulation System (LRS) as to the State of Wisconsin; the Wisconsin Supreme
Court in its administrative capacity; the Office of Lawyer Regulation (OLR), as agent for
the Wisconsin Supreme Court and Sellen

393. Plaintiffs Nora and King re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-

365, 367-369, 371-374, 376-379, 381-383, and 385-392, above, as if fully set forth herein.

394. Plaintiffs have been damaged by the violation of their Petition Rights due to the

failure to adequately train and supervise referees in the LRS including, but not limited to actual

damages, special damages, reputational damages, and mental anguish in an amount to be

determined at trial.

COUNT TWELVE (Nora, King and Rinaldi) for


Violations of the Wisconsin Organized Crime Control Act (WOCCA) at
Wis. Stat. sec. 946.80-946.87 as to the Wisconsin Supreme Court in its administrative,
investigative, prosecutorial/adjudicatory and appellate capacities and the named
participants in the Wisconsin Lawyer Regulation System (LRS), including grievants,
witnesses and their attorneys for double damages to the
Plaintiffs’ property rights and interests

395. Plaintiffs re-allege re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365,

367-369, 371-374, 376-379, 381-383, 390-392, and 394, above, as if fully set forth herein.

81
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 94 of 102

396. Plaintiffs have been damaged by the violation of WOCCA by the violations of Wis.

Stat. secs 943.20(1)(d), 943.38(1), 946.30, 946.30, 946.82(4) incorporating 18 U.S.C. secs. 1341,

1343, via 18 U.S.C. 1961(1) in the amount of double their damages, including, but not limited to

actual damages for loss of property rights:

a. For Nora: the loss of the right to peaceful enjoyment of her home from activities of the

Fraudulent Foreclosure Enterprise; and

b. For Nora: the loss of equity in her home from the activities of the Fraudulent

Foreclosure Enterprise; and

c. For Rinaldi: the loss of the right to peaceful enjoyment of his home from activities of

the Fraudulent Foreclosure Enterprise; and

d. For Rinaldi: the loss of the opportunity to build equity in his home from the activities

of the Fraudulent Foreclosure Enterprise.

397. Plaintiffs Nora and King have been damaged by the injury to their intellectual

property rights: for Nora, her property right to the complete video record of the events and

activities at the March 24 and 27, 2018 for posterity and for the documentary film she has

planned which has been lost forever; and for King, the right to use the video content for

journalistic purposes.

398. Plaintiffs Nora and King are entitled to double their loss of intellectual property

rights in the amount to be determined at trial.

399. Plaintiffs Nora, King and Rinaldi are entitled to double the amount of their special

damages, reputational damages, and mental anguish in an amount to be determined at trial.

400. The Defendants’ violations of WOCCA (crimes) were perpetrated maliciously

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Case 2018CV000916 Document 49 Filed 12-10-2018 Page 95 of 102

against the Plaintiffs or in reckless disregard of their rights, contrary to Wis. Stat. sec. 895.043.

401. Plaintiffs are entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043 which may subject to doubling.

COUNT THIRTEEN (Nora only) for


Violations of 42 U.S.C. sec. 1983 by Deprivation of Equal Protection and Due Process
under the Americans with Disabilities Act as Amended effective January 2, 2009 (the
ADAA) as to the Wisconsin Supreme Court in its administrative, investigative,
prosecutorial/adjudicatory and appellate capacities and the named participants in the
Wisconsin Lawyer Regulation System, Sellen, Stieren, Kasieta, Parsons, Hannan,
Schwarzenbart, Goldman, Winiarski, acting in concert with Potteiger and Moglowsky

402. Plaintiffs re-allege re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365,

367-369, 371-374, 376-379, 381-383, 390-392, 394, and 396-401, above, as if fully set forth

herein.

403. The Wisconsin Supreme Court in its administrative, investigative, prosecutorial/

adjudicatory and appellate capacities and the named participants in the Wisconsin Lawyer

Regulation System, Sellen, Stieren, Kasieta, Parsons, Hannan, Schwarzenbart, Winiarski, acting

in concert with Potteiger and Moglowsky discriminated against Plaintiff Nora for her perceived

disability and used her medical condition to punish her in Nora #1 and Nora #2.

404. Plaintiff Nora has been damaged by the Defendants’ discrimination against her for

her perceived disabilities in violation of the ADAA, including, but not limited to actual

damages, special damages, reputational damages, and mental anguish.

405. The Defendants’ violations of ADAA malicious or in reckless disregard of Nora’s

rights, contrary to Wis. Stat. sec. 895.043.

406. Nora is entitled to punitive damages to the extent allowed by Wis. Stat. sec.

895.043.

83
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 96 of 102

COUNT FOURTEEN (Nora, King, and Rinaldi) for


Declaratory and/or Injunctive Relief to declare the Wisconsin Lawyer Regulation System
(LRS) facially unconstitutional, in whole or in part, or as applied as specified in a
subsequent notice to the Wisconsin Department of Justice, Office of the Attorney General

407. Plaintiffs re-allege re-allege ¶¶1-9, 12-331, 333-341, 343-357, 359-361, 363-365,

367-369, 371-374, 376-379, 381-383, 390-392, 394, and 396-401, 403-405, above, as if fully set

forth herein.

408. Plaintiffs will seek declaratory determinations of the constitutionality of SCR

Chapters 21 and 22, facially or “as applied” and/or for injunctive relief to prevent continuing and

future violations of the Plaintiffs’ constitutional rights by subsequent Motions.

DEMAND FOR JUDGMENT

WHEREFORE, Plaintiffs demand judgment:

A. Nora requests judgment on Count One for her actual damages, special damages,

reputational damages, and mental anguish and for the applicable exemplary damages allowed by

Wis. Stat. sec. 146.84(1)(b) and (bm), and for such other relief as may be just and appropriate in

these premises.

B. Plaintiff Nora requests judgment for her claims under 42 U.S.C. sec. 1983 on Counts

Two, Three and Four for her actual damages, special damages, reputational damages, and mental

anguish and for the applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an

amount to be determined at trial.

C. Plaintiffs Nora and King request judgment on their claims under 42 U.S.C. sec. 1983

on Count Five for their actual damages, special damages, reputational damages, and mental

anguish and for the applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an

84
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 97 of 102

amount to be determined at trial.

D. Plaintiff King requests judgment on his claim under 42 U.S.C. sec. 1983 on Count Six

for his actual damages, special damages, reputational damages, and mental anguish and for the

applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an amount to be

determined at trial.

E. Plaintiffs Nora and Rinaldi request judgment their claims under 42 U.S.C. sec. 1983

on Counts Seven, Eight and Nine for their actual damages, special damages, reputational

damages, and mental anguish and for the applicable exemplary damages allowed by Wis. Stat.

sec. 895.043, in an amount to be determined at trial.

F. Plaintiffs Nora, King, and Rinaldi request judgment on Counts Ten and Eleven under

42 U.S.C. sec. 1983 for their actual damages, special damages, reputational damages, and mental

anguish and for the applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an

amount to be determined at trial.

G. Plaintiffs Nora, King, and Rinaldi request judgment on Count Twelve for their actual

damages, special damages, reputational damages, and mental anguish for violations of the

Wisconsin Organized Crime Control Act (WOCCA) at Wis. Stat. sec. 946.80-946.87 and for the

applicable exemplary damages allowed by Wis. Stat. sec. 895.043, in an amount to be

determined at trial.

H. Plaintiff Nora requests judgment on her claim for violations of her ADAA Rights at

42 U.S.C. sec. 12101, et seq. under 42 U.S.C. sec. 1983 on Count Six for his actual damages,

special damages, reputational damages, and mental anguish and for the applicable exemplary

damages allowed by Wis. Stat. sec. 895.043, in an amount to be determined at trial.

85
Case 2018CV000916 Document 49 Filed 12-10-2018 Page 98 of 102

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