COMES NOW R. Mark Armstrong, pro se (“Plaintiff”), and hereby files a Complaint and Demand for Jury Trial. The causes of action include but are not limited to: 1) Qua Tam (Claims A, B and C) Federal Water Pollution Control Act (FWPCA) (1972) [33 U.S.C. § 1367] : Solid Waste Disposal Act (SWDA) (1976) [42 U.S.C. § 6971] : FCA, 31 U.S.C. 3730(b)-(g) 2)Racketeer Influenced and Corrupt Organizations Act (“RICO”) 18 U.S.C. §1961 et seq., 3) Due Process and Equal Protection Clauses 42 U.S.C. Section 1983 (Claim A) First Amendment as controlled by Garcetti_v._Ceballos Violations, (Claim B) Fourteenth Amendment Violations, 4) Retaliation under 31 U.S.C. § 3730(h), 5) Intentional infliction of emotional distress, for prima facie tort Tortuous Breach of Implied Covenant …show more content…
It is herein argued that the that the permit does not meet location standards and would not be allowed to be permitted if not for the nepotism and unethical conduct of Dale Anderson and C Langstan.
18. C Langston not only received awards but increases in duties and responsibilities and also wages.
19. The hiding of the personal relationship and violation of WY Stat § 9-13-104 damages the public and cost the people including but not limited to the 12 homes burnt down, those forced to haul trash over 150 miles one way, and untold human health effects. This is a form of fraud!
Claim C
20. During the FOIA / Sun Shine discovery process it was determined the C Langston has not stored and archived her emails as required by law. This should then exclude her from public service.
21. The failure to archive or destroying the emails must be viewed adversely for the City and C Langston.
22. This has destroyed evidence and prof of the illegal nepotism that is known but