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preparations. ALL THIS WAS DIRECTLY CAUSED BY THE ABOVE ILLEGAL AND RECKLESS ACTIONS OF THE DEFENDANTS. WITHOUT ANY PROBABLE CAUSE 51. During most of the last two years Ross has also suffered from stomach pro- blems that did not exist prior. Ultimately this has led to bleeding stomach ulcerations for which he is still being treated by gastro-enterologists with antibiotics and diets that are even more restrictive than his usual diet, causing weight loss and much grief, because it is irreversible. This is the same affliction that Governor Cayetano is suffering from, it is caused by too much stress that the body cannot cope with. to Ross' case at age 75. the never ceasing prosecution and related litigation. that was caused by the illegal and reckless actions of some and negligent actions of the other police Defendants did unnecessarily cause permanent stomach damage with daily pain and suffering. The criminal case is presently in appeal to the Hawaii Supreme Court and the case file is appr. 10 inches. It will take years to get resolved because of ancillary legal problems. 52. The condition that Ross finds himself in, and that was directly caused by the reckless illegal actions complained of supra, has totally destroyed his ongoing plans to build a number of houses on the land at his domicile that when completed would give him the income that he now cannot attain, to the extent that even the first house has not been completed and may not be completed ever. He has now no money left. 53. The constant medications that Ross may have to use indefinitely are mostly sedatives, that on this island, without public transportation, have made it impossible for him to travel between his domicile and Hilo unless he is driven by somebody else. So for continuous court actions in Hilo, as there have been for years now, he must stay in Hilo at an extravagant and under normal conditions unnecessary cost, that has rendered him broke and this was caused by the negligent actions of all Defendants. 54. It was the duty of all Defendants herein, but especially of the County police to protect Ross as the Naw requires as prime reason for the existence of the police, pur- suant to HRS 52D and the County Charter. Whenever a complaint comes in, police must tread carefully and not like a bunch of cowboys hunting down run-away cattle. Ross has a clean criminal record and should not be treated worse than a criminal. lust because the Defendants do not like him, or because they think that the war on drugs makes every- 17