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body fair game, as is hiappening at an increasing rate, judging from the newspapers. The General Orders are saecific that no excessive force may be used and treating a 73 year old, physically limited, man as they did in defiance of these General Orders, the law and other applicable rules, making Ross fair game for their sadistic inclinations is an outrage of illegality and misconduct, that has caused and will further indefinitely cause Plaintiff great suffering and medical expense that he cannot afford. His life has been ruined. 55. The Defendants failed to protect Plaintiff as law and rules require instead of attacking him and therefore they are jointly and severally responsible for failing to do so. They have wantonly violated Ross' constitutional rights. especially those of due process and the right to liberty and ha~ainess. 56. The resultant injuries to Plaintiff, the aggravation of his physical disabilities and his inability to lead a normal life hereafter, were caused purposefully, recklessly, and in part negligently and by the carelessness of all Defendants, singly or jointly. So is the deprivation of his enjoyment of life in the country and loss of consort, in North Kohala, with its quiet atmosphere that he deserves at his advanced age of 75. It has also caused lonalasting and unnecessary suffering, areal Dhvsical harm that cannot be overcome. severe and permanent mental anguish and suffering and intolerable financial distress in the form of very expensive medications that Ross cannot afford and the above indicated lack of providing for a reasonable income because of increasing age and physical dis- abilities caused by the Defendants. The medical costs by itself will exceed 5150.000 . 57. The material cost of building materials that are rotting away, an unfinished house that is subject to the ruinous forces of nature and restauration of extensive land- scaping and orchard Ross created, which is now overgrown and changed into a wilder- ness, worse than where the land was undeveloped, also exceeds a sum of 5150.000. 58. It also causes great and permanent mental anguish to have to live in constant fear of ever being arrested again, which with rogues that the Hawaii County police seems to have in plentiful supply is not imaginary, while again being handcuffed on the back as required by the GO would result in the loss of use of both his arms, because the operations cannot be repeated, and of course no price can be set on that, no money will ever suffice to compensate for such a loss and its dire consequenses, ~g