(CONTINUED)
    46. Defendants MARTIN LaPRADE and ALFRED ROGERS had and breached
a duty not to imprison Plaintiff for the purpose of collecting a
Money Judgment.
    47. The execution of the above-described Arrest Warrant, and the
incarceration of Plaintiff, through concurrent publicity, proximately
caused damage to Plaintiff's reputation, ability to conduct his law
practice, standing as a member of the Arizona Bar, and ability to
earn an income through his law practice.
                             CLAIM III
    48. Plaintiff incorporates by reference the allegations of
paragraphs 1 through 47 hereinabove, and further alleges:
    49. Defendants MARTIN LaPRADE and ALFRED ROGERS had and breached
a duty not to condition the release of Plaintiff upon payment of a
money Judgment.
    50. The wrongful conditions attached to Plaintiff's release from
incarceration, and the continuing non-exoneration of the Appearance
Bond, proximately caused Plaintiff to incur a repayment obligation of
$22,000 to Appearance Bond Surety John Hirschfeld.
                                   CLAIM IV
    51. Plaintiff incorporates by reference the allegations of
paragraphs 1 through 50 hereinabove, and further alleges:
    52. Defendants MARTIN LaPRADE and ALFRED ROGERS engaged in ex-
parte communications, among which ALFRED ROGERS assisted in drafting
or dictated one or more of the wrongful Petitions for Order to Show
Cause re: Contempt set forth above.
    53. The ex-parte collusion between Defendants MARTIN LaPRADE and
ALFRED ROGERS with respect to the matters herein complained of,
constitutes ethical misconduct on the part of MARTIN LaPRADE.
    54. Ex-parte collusion between Defendants MARTIN LaPRADE and
ALFRED ROGERS with respect to the matters herein complained of,
constitutes judicial misconduct on the part of ALFRED ROGERS, and
further comprises extra-judicial acts independently depriving said
Defendants of Judicial immunity or Judicially-derived immunity.
    54. Defendants MARTIN LaPRADE and ALFRED ROGERS engaged in a
conspiracy to deny to Plaintiff his Constitutional rights, within the
scope of 42 U.S. Code 1985.
    55. Defendants MARTIN LaPRADE and ALFRED ROGERS had and breached
a duty not to conspire to deny to Plaintiff his Constitutional
rights.
    55. The conspiracy by Defendants MARTIN LaPRADE and ALFRED
ROGERS proximately caused damage to Plaintiff's reputation, ability
to conduct his law practice, standing as a member of the Arizona Bar,
and ability to earn an income through his law practice.
                              CLAIM V
    56. Plaintiff incorporates by reference the allegations of
paragraphs 1 through 55 hereinabove, and further alleges:
    57. Since August 6, 1993, Defendant ALFRED ROGERS engaged in ex-
parte communications with other judges of the Maricopa County
Superior Court, and on information and belief solicited from the
media defamatory publications, for the purpose of damaging
Plaintiff's reputation, ability to conduct his law practice, standing
as a member of the Arizona Bar, and ability to earn an income through
his law practice.
    58. Said ex-parte communications by ALFRED ROGERS with other
judges and solicitation from the media of defamatory publications,
were, on information and belief, malicious, defamatory, beyond the
scope of ALFRED ROGERS' jurisdiction or judicial duties, and did in
fact damage Plaintiff's reputation among judges, the public, and
Plaintiff's law clientele, ability to conduct his law practice,
standing as a member of the Arizona Bar, and ability to earn an
income through his law practice.
(CONTINUED)
--- DB 1.58/004910
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