Lawsuit Against Permit Signers

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NAME XXXXXX XXXXXX
Plaintiff

v.

Lindsey XXXXXXXXXXXXX
Lisa XXXXXXXXXXXXXX
SUMMONS

STATE OF NEW MEXICO
COUNTY OF SANTA FE
FIRST JUDICIAL DISTRICT
xxxxxxxxx xxxxxxx
Plaintiff,

v.

No. D101CV20xxxxxxxx
LINDSEY xxxxx
LISA xxxxxxxx
Defendants.

SUMMONS - THE STATE OF NEW MEXICO

TO: xxxxxxxxxxxxxxxxx, Defendant
ADDRESS:____xxxxxxxxxxxxxxxxxxxxxx_________________________________________ You are required to serve upon xxxxxxx xxxxx, plaintiff's attorney, an answer or motion in response to the complaint which is attached to this summons within thirty (30) days after service of this summons upon you, exclusive of the day of service, and file your answer or motion with the court as provided in Rule 1-005 NMRA. If you fail to file a timely answer or motion, default judgment may be entered against you for the relief demanded in the complaint.

Attorney for plaintiff:
xxxxxxx xxxxx
PO Box xxxx
Albuquerque, NM 87190
Phone 505-xxx-xxxx EXT. xxx

WITNESS the Honorable RAYMOND Z. ORTIZ, district judge of the First judicial district court of the State of New Mexico, and the seal of the district court of Santa Fe county, this ____ day of April, 2010.

STEPHEN T. PACHECO
Clerk of court

By _________________________________<
Deputy

Dated: _______________________

COMPLAINT

FIRST JUDICIAL DISTRICT COURT
COUNTY OF SANTA FE
STATE OF NEW MEXICO

xxxxxxxxx xxxxxxx,

Plaintiff,
vs.

LISA xxxxxxxx, LINDSEY XXXXX,

Defendants.

COMPLAINT FOR DECLARATORY & INJUNCTIVE RELIEF
Plaintiff XXXXXXXXX xxxxxxx, through xxx attorney Xxxxxxx Xxxxx, for his complaint against Defendants Lisa xxxxxxxx and Lindsey xxxxx states as follows:

This is an action seeking declaratory and injunctive relief.

Defendants are both residents of Santa Fe, New Mexico, and the actions complained of occurred in Santa Fe, County.

Venue and jurisdiction lie in this Court because the contract was signed in Santa Fe, New Mexico.

Plaintiff is a citizen and resident of Xxxxxxxxxxx.. >li>Plaintiff seeks an Order declaring that Defendants had and have no legal authority to sign any agreement, application, contract or any other document in the name of Plaintiff, the Rainbow Family or the Rainbow Gathering, and barring them from any such future actions.

Plaintiff is a long-time participant in the free assembly commonly known as the Annual Rainbow Gathering ("Rainbow Gathering").

The Rainbow Gathering is a free assembly of equal individuals. There are no leaders, no hierarchy, and no one can speak for or represent said assembly. The gathering is a participatory and voluntary assembly, lacking any prior legal affiliation by attendees or any group membership at any time.

On June 17, 2009, Lisa xxxxxxxx and Lindsey Xxxxx signed a permit application and permit for the Rainbow Gathering to take place in Rio Arriba County, New Mexico, in June and July, 2009. The application was for a Noncommercial Group Use ("NGU"). The defendants were not gathering participants but people from the general citizenry of the nation.

They signed a permit and application "on behalf of" Plaintiff binding hxx to the terms of the contract they signed.

he permit was issued in the name of the "Rainbow Family."

The signers of the permit and application have attempted to speak for the group and Plaintiff, which heretofore was a participatory - Free Assembly - of equal individuals.

The Rainbow Gathering is not an "Event," and Defendants had no authority to make it into one.

Plaintiff refused to sign a permit application in 1999 to assemble on federal land, and was then imprisoned in the federal penitentiary for ninety days.

Neither Lisa Xxxxxxxxx nor Lindsey Xxxxx had or has authority to sign any documents on behalf of Plaintiff or the "Rainbow Family." They had no legal authority to contract with anyone that resulted in a binding agreement on Plaintiff or other third parties.

Lisa Xxxxxxxx and Lindsey Xxxxx are not agents or representatives of Plaintiff or of the people assembling.

Defendants Lisa Xxxxxxxx and Lindsey Xxxxx cannot be agents for an assembly of equal individuals who have no ability to assign agency or delegate authority.

Defendants sought to contract on behalf of Plaintiff and uninformed others without the knowledge of Plaintiff or those being contracted for. Defendants had no understanding of the Gathering nor any legal connection to the Gathering.

Upon information and belief, Defendant Lisa Xxxxxxxx has never been present at a gathering.

Plaintiff affirmatively disclaims any cause of action arising under the Constitution, treatises or other laws of the United States, including but not limited to any claim arising from an act or omission on a federal enclave or by any officer of the United States or any agent or person acting on behalf of such individual is being asserted against the Defendants. No claim under admiralty or maritime is alleged. To the extent this paragraph conflicts with any other allegations herein, this paragraph shall control.

WHEREFORE, Plaintiff prays this Court enter an Order declaring that: A. The permit application signed by Lisa Xxxxxxxx and Lindsey Xxxxx in regards to the assembly of June and July 2009 in the State of New Mexico and commonly known as the Annual Rainbow Gathering, and all other documents they have signed on behalf of the Plaintiff, the Rainbow Gathering or Rainbow Family are void and null.
B. That the Defendants had and have no legal authority to sign any legal documents on behalf of Plaintiff, the Rainbow Gathering, the Rainbow Family, or its participants.
C. Defendants are enjoined from signing any further documents in the name of any free assembly of individuals, known or referred to as a "Rainbow Gathering," "Rainbow Family" or on its behalf.
D. Plaintiff be awarded costs of suit and attorneys fees.
E. Granting all other relief that law and justice allow.

Xxxxxxx Xxxxx

Signed:_________________________
Law Office of Xxxxxxx Xxxxx
P.O. Box xxxxx
Albuquerque, NM 87190
Phone 505-xxx-xxxx EXT. xxx