And Now,
A Motion Is Before the Judge...
The
stage is set for confrontation as the Motion to Amend the
original complaint in Case No. CV03-00192 - M. A.
Edwards, Et Al, vs Water Works Inc, Et Al, now includes
the first of the complaints involving AAWC personnel in
the Washoe County matter.
Additional
complaints are planned by Plaintiffs in Federal Court
over FAA, TSA and Homeland Security matters. Certain
deliberate acts by AAWC personnel are considered by
Plaintiffs to be criminal in nature, and criminal
complaints will also be filed with the appropriate
authorities as soon as next week.
In his Amended Complaint, Edwards, January and Blincoe
cite fifteen Causes of Action including Deliberate
Misrepresentation, Breach of Agreement, Fraud,
Conspiracy, Abuse of Process, Breach of Fiduciary
Responsibilities, Threats of Violence, Interference with
Contract, Fraudulent Conveyance per NRS 112.140 et. seq.,
Breach of the Covenant of Good Faith and Fair Dealing,
Intentional Business Torts, Breaking and Entering,
Burglary and Theft, Conversion of Property and
Destruction of Building.
Of
note in the First Cause of Action is the charge that Fred
Christle, the agent representing Water Works Inc.,
"did deliberately misrepresent his educational
attendance, experience and graduation honors, military
service, professional qualifications, professional
licenses and work history to Plaintiffs in order to
obtain a position of trust with Plaintiffs. Defendant
Fred Christle has represented to Plaintiffs that he
attended and graduated from Stanford University, cum
laude,with a Juris Doctorate degree in Constitutional
Law, and that he is a member of the American Bar
Association."
After
Christle failed repeated written and oral requests to
produce his degrees and certifications from Stanford,
Edwards made contact with the University in Palo Alto,
California, which responded that they had no record of
Mr. Christle's attendance.
Likewise,
Mr. Christle has produced no documentation to support his
other claims to Plaintiffs, who barred him from the
practice of Law inside their building and instructed him
to remove items related to his "Law Practice."
A
check of the Search Engines at the American Bar
Association, Martindale.Com, Martindale-Hubbell's
Lawyer.Com, the Nevada State Bar, California State Bar,
Utah State Bar, Arizona State Bar, Oregon State Bar and
Idaho State Bar, found no listings for Mr. Christle.
Searches were conducted using First Name, Last Name,
City, State, County and "Stanford University,"
where Mr. Christle apparently indicated to Plaintiffs
that his Juris Doctorate degree was earned.
According
to Edwards, those named in the complaint had prior
knowledge of Christle's misrepresentations and further,
so too did Christle's wife Barbara and son Scott, along
with Krys Bart, the Director of the Airport Authority of
Washoe County (AAWC). According to Plaintiffs, at no time
did anyone in this group inform them properly of the
falsity of Christle's claims.
Also
disturbing is the fact that legal documents prepared for
clients by Christle were notarized by Edgington, a Notary
Public for AAWC, who had the responsibility of verifying
Christle's identity and information, which included his
degrees, certificates, State Bar membership/number, etc.
Acting as an Attorney at Law, Mr. Christle is further
alleged by Edwards to have represented and caused harm to
other clients of his in the Reno area and on Reno-Stead
Airport grounds.
If
Christle was practicing Law without a license, not only
could he face serious charges and lawsuits, but so too,
could others face liability and financial responsibility
for his actions, including but not limited to Polak,
Bart, Edgington, Attorney Murtha, the AAWC and Washoe
County.
In the second cause of action, Plaintiffs Edwards, Paul
January and Clyde Blincoe, collectively contend that
Christle entered into an agreement with them to provide
"exclusive and non-exclusive use of certain assets
and facilities of Water Works, Inc., in exchange for
labor, equipment, services, materials, repairs, and
monetary compensation provided and paid by
Plaintiffs," all of which were delivered to
Christle, along with monthly payments to the AAWC since
the "Constructive Eviction" and which have
continued without fail as recently as January, 2004.
Christle
is alleged to have breached his part of the contract by
transferring assets of the old Water Works Inc., to a new
"Trust" known as "P&B
Enterprises," made up owners and agents of Christle,
including the AAWC, Attorney Murtha, Arthur Bob Park and
Patsy Joe Park, along with "other persons and
entities."
Further,
this Civil Action now formally includes the naming of Ms.
Krys T. Bart, Director of the Airport Authority of Washoe
County and now the highest-placed Defendant in the
ongoing case since she controls Attorney Murtha. Bart is
named along with Barbara Christle (estranged wife), son
Scott Christle, Murtha Esq., Polak, Edgington and Mr.
& Mrs. Park, along with others still unknown at this
time of writing (an investigation is ongoing), for
assisting Defendant Fred Christle in the breach of the
original agreement. All the current Defendants are
alleged to have benefited financially from the breaching
of the original agreement.
Damage
to property and denial of the Plaintiffs' right to
utilize the Water Works parcel and their building are
also indicated.
The first allegation with serious ties to criminal
conduct is contained in the Third Cause of Action and
involves an allegation of Fraud on the part of Fred
Christle and Water Works Inc., whom Edwards, January and
Blincoe cite as "never" intending "to
honor the terms and conditions of the agreement with
Plaintiffs even though said Defendants demanded complete
performance of the obligations of Plaintiffs under the
agreement."
Edwards
indicates in the Second Amended complaint that
"Defendants demand of performance by Plaintiffs was
an attempt to defruad Plaintiffs of labor, equipment,
services, materials, repairs, and monetary compensation
provided to Defendants upon their demand."
Harm
to Plaintiffs buisiness operations are alleged once
again, since Plaintiffs were effectively blocked from
obtaining the return value on their investment into the
Water Works parcel, bulding and coffers.
The second serious Criminal issue comes under the Fourth
Cause of Action in which Edwards, January and Blincoe are
alleging "Conspiracy" by the Defendants, who
allegedly "conspired between themselves and others
to deprive Plaintiffs of the benefits of the breached
agreement and to obtain the benefits of their demands for
labor, equipment, services, materials, repairs, and
monetary compensation from Plaintiffs." Edwards
notes that the conspiracy was partially successful and
has harmed Plaintiffs' business operations as a result.
The
Conspiracy is supported by the fact that members of the
Law Firms, AAWC and RARA, were sitting on each other's
Boards in a multiple "Conflict of Interest"
operation forbidden by Nevada State Law.
Among the most interesting of charges is "Abuse of
Process," contained in the Fifth Cause of Action.
This is an act where individuals file false, frivolous
and/or fraudulant litigation actions with a Court with
the perpetrator(s) having the intent of using the Law
itself to abuse his/her/their intended victims, i.e.,
using the Law for profit and not for justice. In fact,
using the Law to abuse others and cause injustice --
exploitation, in other words.
With
an Attorney and his Law Firm involved in the action,
disbarment proceedings could occur against the Attorney
and both the Attorney and Law Firm could face
considerable fines, orders of restitution, along with
actual and punitive damages being paid to Plaintiffs
and/or the Community. The Community would likely receive
Public Service Pro Bono (Charity) work in lieu of some
fines and damages, provided the Law Firm were permitted
to continue operation under such dubious circumstances.
Edwards,
January and Blincoe charge that Defendants and others yet
to be named, "attempted to deprive Plaintiffs of the
benefits of the breached agreement by filing an action
before the Justice Court, County of Washoe, Reno, Nevada
in a specious attempt to evict Plaintiffs from a portion
of the assets and facilities wrongfully transferred by
Defendants Water Works, Inc. and Fred Christle to P&B
Enterprises."
The
questionable filing by the Defendants took an unexpected
twist when the Defendants unceremoniously lost the
action. Defendants had argued that Mr. Christle was the
lawful lease holder and that the agreement was between
the AAWC and Christle. The AAWC Attorneys concurred with
the Defendant.
Plaintiffs
in turn had argued that they were the Lawful lease
holders and that Christle was, as General Manger, their
employee. The terms of the contract were such that the
Judge in the case referred to them as
"unconscienable," in that -- in the Defendants'
view -- the lease was considered terminated upon the
death of the "General Manager" or if the
General Manager's employment was terminated by Edwards or
January, the true Lease holders.
The
highly suspicious arangement of this particular wording
did not withstand the Judge's scrutiny, nor did it
survive "Severability," in which the protocol
states that where an existing Law or action of Law
nullifies the term of a contract -- as was the case of
this particular clause, particularly when the Judge ruled
against the clause and the Defendants presenting it --
only that term is nullified and the remaining portions of
the contract remain in force and in effect for the
remaining time in the contract.
The
Court ordered that Mr. Christle was not the Lease holder
and merely an employee of Edwards and January, the true
Lease holders. The Court also recognized Edwards and
January as the true Lease holders and gave them back the
rights that the Defendants had unsuccessfully tried to
take away.
One
would think that the "Abuse of Process" would
have ended with the Court's decision. In fact, it only
became worse as both the AAWC and the Reno Air Racing
Association (RARA), refused to recognize the Court's
order and took jurisdiction over the matter themselves,
displaying a glaring contempt for the Court and Judge
Dannon.
The
end result: Edwards, January and Blincoe were locked out,
their property confiscated and ultimately stolen and
willfully destroyed, since it was taken to the dump
without Authority -- the Court's in this case, the Law
having precedent over the Lease Agreement due to its
deficiencies.
Likewise,
their (Plaintiffs') Tenant's passes denied them and given
to Fred Christle during the Reno Air Races, whom the AAWC
and RARA would only recognize as the Tenant in another
flagrant act of contempt against Judge Dannon's court and
order, an act culminating with the destruction of the
Plaintiffs' building on the Water Works parcel...
...a
building which did not belong to the AAWC but rather, to
Edwards and January; one that was utilized by Blincoe and
their customers, friends and associates, including an
offer of use to the National Air Racing Group (NAG) that
was quashed by Mike Houghton and the Executive Committee
at RARA.
Continued...Page2
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