PINEDALE — A Pinedale man is suing for over $15,000,000 alleging that he was denied the right to vote due to a no trespass order imposed on him as part of an Ex Parte Stalking Order of Protection that resulted from a domestic dispute.

The plaintiff Jason R. Harlow says that he was prevented from accessing the only polling place in Pinedale and was unable to cast an absentee ballot.

The defendants in the case include Shane R. Adams who the stalking order protected. Jerry L. McMackin, Russell K. Adams, Sublette County Wyoming and the Sublette County School District #1.

Shane Adams works at the Sublette County School District #1, the order of protection covered his place of employment as well as his home.

Harlow’s suit involved multiple counts outside of the allegation that he was prevented from voting. He is suing for a total sum of $ 4,000,000 on the first count. According to court documents Harlow alleged that “The defendant’s willful negligence in prohibiting Plaintiff from participating in a lawful election by threatening arrest and or fines for entering his assigned polling place, and for infringing on the very liberties and freedoms in which this country was founded on while willfully violating his civil  rights. Plaintiff requests the following sums from each Defendant: Shane R. Adams $ 1,000,000,  Jerry L. McMackin $250,000, Russell K Adams $250,000, Sublette County Wyoming $1,500,000, and Sublette County School District #1 $1,000,000.”

Harlow says that the incident rises to the level of a violation of his constitutional right to vote. He also alleges that Sublette County Circuit Court Magistrate Judge Lauretta Welch committed voter intimidation against him when she signed an order that imposed a blanket ban preventing him from accessing the polling place. According to Harlow’s filing, the order said that, “Respondent (Harlow), shall not be at the Petitioner’s place of employment or residence or so near the same as to upset the life of Petitioner under any circumstances. In addition, the Respondent shall not be at any other location where Petitioner may be found.” 

Harlow alleges that the Magistrate along with several experienced and trained law enforcement officers should have known that banning him from the polling place is illegal and that their willful disregard for his rights rises to the level of negligence.

Harlow also requests that the court order a law enforcement investigation into the actions of defendants; Shane Adams, Jerry McMackin, Russell K. Adams, Jeremy Qualls Principal of Pinedale High School, and Lauretta Welch Magistrate Judge for Sublette County. Harlow alleges that that any reasonable person would find being threatened by arrest and or fines by entering an assigned polling place would constitute intimidation.

Harlow also alleges several other counts involving personal property and alleged assaults he claims occurred but were ignored by law enforcement.

Updates as we get them.

Scroll down to read the full complaint.

 

Full text of the complaint follows:

 

IN THE DISTRICT COURT OF THE NINTH JUDICIAL DISTRICT,

COUNTY OF SUBLETTE, STATE OF WYOMING

 

Jason R. Harlow )

Plaintiff, )

Vs. ) Case: ___________________

)

Shane R. Adams, Individually )

Jerry L. McMackin, Individually )

Russell K. Adams, Individually )

Sublette County Wyoming )

Sublette County School District #1 )

Defendants

___________________________________________________________________________

COMPLAINT AT LAW AND JURY DEMAND

____________________________________________________________________________

 

COUNT I

-VIOLATION OF WYOMING STATE CONSTITUTIONAL RIGHT TO VOTE-

 

Now comes Plaintiff Jason R. Harlow complaining about Defendant Shane R. Adams, Jerry L.

McMackin, Russell K. Adams, Sublette County Wyoming, Sublette County School District #1

and alleges as follows:

 

1. That on June 14, 2016, Plaintiff Harlow was served two “Criminal Trespass Notice” by

Sublette County Sheriff’s Department, signed by Defendant Sublette County School

District #1 for the address of 101 E. Hennick Pinedale , and by Russell K. Adams for the

address of 307 S.  Madison, Pinedale as requested by Defendant Shane R Adams. See    

Exhibit “A”.

 

2. That one said Notice prohibits Plaintiff from entering the property located at “101 E. Hennick

Pinedale School District”.

 

3. That notice states “if you enter or remain on the premises listed above, then you are and may

be subject to arrest immediately, and subject to a fine not to exceed $750 and / or imprisonment

for not more than six months, or both”

 

4. That on June 14, 2016, Plaintiff was served an Ex Parte Stalking order of Protection, signed

by Magistrate Judge Lauretta Welch for the Circuit Court of Sublette County Wyoming, which

further prohibited Plaintiff from entering the premises belonging to Defendant Sublette County

School District #1.

 

5. That at the hearing held at the Sublette County Courthouse on June 21, 2016, Magistrate

Welch issued an order valid until June 21, 2017 that stated “Respondent shall not stop at, enter

into, or place under surveillance any of the following locations” and listed 101 E. Hennick

Pinedale, Wy. See Exhibit “B”.

 

6. That the order further states “Respondent shall not be at the Petitioner’s place of employment

or residence or so near the same as to upset the life of Petitioner under any circumstances. In

addition, the Respondent shall not be at any other location where Petitioner may be found”

 

7. That Plaintiff is legally prohibited from entering upon the grounds of Defendant Sublette

County School District #1, where Defendant Shane R Adams is employed.

 

8. That Plaintiff’s election polling place is located on the grounds of Defendant Sublette County

School District #1, and that Plaintiff is a registered voter in Sublette County, Wyoming. See

Exhibit “C”.

 

9. That by legally preventing Plaintiff from entering Defendant Sublette County School District    

#  1’s property, all Defendants have conspired to prevent Plaintiff in casting a lawful ballot in an

election at Plaintiff’s assigned polling place.

 

10. That Wyoming Constitution Article 1, Section 27 states “Elections shall be open, free and

equal, and no power, civil or military, shall at any time interfere to prevent an untrammeled

exercise of the right of suffrage.”

 

11. That Defendants have interfered with Plaintiff’s ability to exercise his Constitutional right to

vote by threatening arrest and or fines if he enters his assigned polling place and have operated

contrary to Section 27.

 

12. That the United States Constitution specifically allows Plaintiff to vote as he is of legal age,

and has never been convicted of any crime.

 

13. That pursuant to the Fourteenth Amendment to the United States Constitution, “All persons

born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of

the United States and of the State wherein they reside. No State shall make or enforce any law

which shall abridge the privileges or immunities of citizens of the United States; nor shall any

State deprive any person of life, liberty, or property, without due process of law; nor deny to any

person within its jurisdiction the equal protection of the laws”.

 

14. That Defendants have willfully and negligently disenfranchised Plaintiff’s right to enter a

polling place to cast a ballot on election day August 16, 2016, and as of now Defendants will

also prohibit Plaintiff from casting a Presidential Election ballot at his assigned polling place on

November 8, 2016.  In doing so, Defendants have all violated Plaintiff’s civil and constitutional

rights to enter into a polling place to cast a ballot.

 

15. That Article 1, Section 27 of the Wyoming Constitution states “The State of Wyoming is an

inseparable part of the federal union, and the constitution of the United States is the supreme

law of the land.”

 

16. That Article 1, Section 6 of the Wyoming Constitution states “No person shall be deprived of

life, liberty or property without due process of law.”

 

17. That Defendants have fully violated Plaintiff’s right to vote in his assigned polling place, and

in doing so have deprived him of liberty, which is expressly prohibited by both the Wyoming and

United States Constitution.

 

18. That Defendants must be held fully accountable for their actions in denying an individual the

right to vote at his assigned polling place without any conviction or crime being committed, as

Plaintiff cherishes his freedoms which come from being a lawful citizen of the United States of

America and the State of Wyoming.

 

19. That Plaintiff is of no threat to any of the Defendants, or the persons charged in their care,

and has never been arrested for, nor convicted of any crime in his life.

 

20. That Plaintiff was fully available and eligible to cast a ballot in the August 16, 2016 election.

 

21. That a notice posted on the Sublette County Website stated “ Any person who expects to be

absent from his place of resident on Election Day, or who cannot be present at his precinct

polling place on Election Day because of illness, injury, disability, old age or tenets of religion,

may apply for an absentee ballot”. See Exhibit “D”.

 

22. That Plaintiff did not expect to be absent on Election day, and did not meet the qualifications

posted on the Sublette County Website to obtain an absentee ballot, and information on the

Wyoming Secretary of State’s website indicated Plaintiff could not obtain an absentee ballot on

the day of the election.

 

23. That countless men and women have served in the duty of the United States, many of which

have paid the ultimate price while defending the right to vote, and that the right to vote is

therefore priceless.

 

THEREFORE, Plaintiff hereby prays this Honorable Court for the total sum of $ 4,000,000 for

Defendant’s willful negligence in prohibiting Plaintiff from participating in a lawful election by

threatening arrest and or fines for entering his assigned polling place, and for infringing on the

very liberties and freedoms in which this country was founded on while willfully violating his civil

rights. Plaintiff requests the following sums from each Defendant: Shane R. Adams $ 1,000,000,

Jerry L. McMackin $250,000, Russell K Adams $250,000, Sublette County Wyoming

$1,500,000, and Sublette County School District #1 $1,000,000.

 

COUNT II

-VOTER INTIMIDATION-

 

Now comes Plaintiff Jason R. Harlow complaining about Defendant Shane R. Adams, Jerry L.

McMackin, Russell K. Adams, Sublette County Wyoming, Sublette County School District #1

and alleges as follows:

 

1. That on June 14, 2016, Plaintiff Harlow was served a “Criminal Trespass Notice” by

Sublette County Sheriff’s Department, signed by Defendant Sublette County School

District #1, as requested by Defendant Shane R Adams. See Exhibit “A”.

 

2. That said Notice prohibits Plaintiff from entering the property located at “101 E. Hennick

Pinedale School District”.

 

3. That notice states “if you enter or remain on the premises listed above, then you are and may

be subject to arrest immediately, and subject to a fine not to exceed $750 and / or imprisonment

for not more than six months, or both”

 

4. That on June 14, 2016, Plaintiff was served an Ex Parte Stalking order of Protection, signed

by Magistrate Judge Lauretta Welch for the Circuit Court of Sublette County Wyoming, which

further prohibited Plaintiff from entering the premises belonging to Defendant Sublette County

School District #1.

 

5. That at the hearing held at the Sublette County Courthouse on June 21, 2016, Magistrate

Welch issued an order valid until June 21, 2017 that stated “Respondent shall not stop at, enter

into, or place under surveillance any of the following locations” and listed 101 E. Hennick

Pinedale, Wy. See Exhibit “B”.

 

6. That the order further states “Respondent shall not be at the Petitioner’s place of employment

or residence or so near the same as to upset the life of Petitioner under any circumstances. In

addition, the Respondent shall not be at any other location where Petitioner may be found”

 

7. That Plaintiff is legally prohibited from entering upon the grounds of Defendant Sublette

County School District 1, where Defendant Shane R Adams is employed.

 

8. That Plaintiff’s election polling place is located on the grounds of Defendant Sublette County

School District #1, and that Plaintiff is a registered voter in Sublette County, Wyoming.

 

9. That by threatening arrest and fines for entering the grounds of Pinedale High School and

Sublette County School District, Defendants have committed voter intimidation, as defined in

W.S. §22-26-111 as “Inducing, or attempting to induce, fear in an election official or elector by

use of threats of force, violence, harm or loss, or any form of economic retaliation, for the

purpose of impeding or preventing the free exercise of the elective franchise or the impartial

administration of the Election Code.”

 

10. That any reasonable person would find being threatened by arrest and or fines by entering

an assigned polling place would constitute intimidation.

 

11. That W.S §22-26-101 provides that the commission of Voter Intimidation is a felony,

punishable by up to 5 years in the Department of Corrections, and / or up to a $10,000 fine.

 

12. That Plaintiff has been the victim of a felony committed by Defendants collectively.

 

13. That because of this intimidation placed upon Plaintiff, he was forced to miss voting in the

August 16, 2016 primary election.

 

14. That Defendants Jerry L McMackin and Russel K. Adams conspired in assisting Defendant

Shane R Adams in filing the original Criminal Trespass Notices, and the Order of Protection.

 

15. That Sublette County Circuit Court Magistrate Judge Lauretta Welch has committed

malfeasance against Plaintiff, and should have known the order she issued against Plaintiff

would constitute voter intimidation, and has therefore violated the public trust by ordering that a

felony be committed against Plaintiff.

 

THEREFORE, Plaintiff hereby prays this Honorable Court for the total sum of $ 1,500,000 for

Defendant’s willful commission of felony voter intimidation against Plaintiff, and Plaintiff further

requests the court to order a law enforcement investigation into this matter to pursue criminal

felony charges against Defendants Shane Adams, Jerry McMackin, Russell K. Adams, Jeremy

Qualls Principal of Pinedale High School, and Lauretta Welch Magistrate Judge for Sublette

County.

 

COUNT III

-FAILURE TO PROSECUTE-

 

Now comes Plaintiff Jason R. Harlow complaining about Defendant Shane R. Adams, Sublette

County Wyoming, Sublette County School District #1 and alleges as follows:

 

1. That on or about June 15, 2016, Plaintiff held a meeting with Sublette County Sheriff’s

Department, and spoke with Deputy Danielle Cooper.

 

2. That during this meeting, Plaintiff gave sworn testimony regarding physical and sexual

assault committed multiple times against him by Defendant Shane R Adams.

 

3. That Plaintiff gave details such has how Defendant Adams forced himself sexually upon

Plaintiff multiple times between November 2014 and April 2016. Plaintiff had said no to

sexual relations, and Defendant Adams would proceed with fondling, groping, and

penetrating Plaintiff’s anus with his finger, all against Plaintiff’s will and desire. Defendant’s

willful actions caused Plaintiff great pain in his anus, and caused multiple flare ups of

painful hemorrhoids, making defecation difficult and painful. See Exhibit “E”.

 

4. That Defendant Shane R Adams also sexually assaulted Plaintiff on October 17, 2015 in the

parking lot of the Best Western in Parsons Kansas, in front of at least 15 witnesses. Defendant

Adams, while severely intoxicated, attempted multiple times to kiss Plaintiff, and fondle his

genitals in public, in front of Plaintiff’s friends, when Plaintiff was not open about his

sexuality to them. Plaintiff had to physically push Defendant Adams away multiple times before

he ceased his sexual assault. This matter was reported to the Parsons Kansas Police via

Certified Mail on July 16, 2016, and establishes a pattern of illegal sexual behavior. See

Exhibit “F”

 

5. Plaintiff also gave testimony to Deputy Cooper on how Defendant Adams prevented Plaintiff

from leaving by physically restraining him, blocking the doorway, and preventing Plaintiff from

seeking help from law enforcement in December 2014. The Plaintiff is approximately 5’ 9” tall

and weighs approximately 130 pounds. Defendant Adams is approximately 6’ 2” and weighs

approximately 260 pounds, effectively double the size of the Plaintiff.

 

6. That such acts committed by Defendant Adams are contrary to W.S. §6-2-303, Second

Degree Sexual Assault, a felony punishable by up to 20 years incarceration, and W.S. §6-2-313

Sexual Battery, a misdemeanor punishable by up to one year incarceration and up to a $1,000

fine or both.

 

7. That on July 8, 2016, Plaintiff was notified via email by Deputy Danielle Cooper that the

County Attorney had decided not to pursue criminal charges due to “burden of proof issue and

the incidents were not reported until an Order of Protection had been filed”. See Exhibit “G”

 

8. That W. S. §6-2-311 states “Corroboration of a victim’s testimony is not necessary to obtain a

conviction for sexual assault.”

 

9. That upon receiving a copy of the case declination for the Sublette County Attorney’s office,

along with the written report from Deputy Cooper, there is no mention of Plaintiff filing a

Domestic Order of Protection, Case FV-2017-007 against Defendant Shane Adams, in which on

page two, details many of the same allegations made against Defendant Adams by Plaintiff.

 

10. That W.S. §6-2-309 states “Each victim reporting a sexual assault shall be informed of the

rights enumerated in this section, the victim’s rights to informed consent and the victim’s rights

as a victim of crime.  The victim shall also be informed of available medical, legal and advocacy

services.”

 

11. That Sublette County Sheriff’s Department willfully violated W.S. §6-2-309 by not informing

Plaintiff of all of the required information in that statute. Deputy Cooper only asked if Plaintiff

needed medical attention of any kind, and did not specifically offer Plaintiff any legal or

advocacy services, which were in fact needed, and that medical services are now required as

well.

 

12. That W.S. §6-2-307 (b) states “Consent of the victim is not a defense to a violation of W.S.

6-2-303(a)(vii) or 6-2-304(a)(iii).”

 

13. That Sublette County Sheriff’s Department employs Defendant Adams’s Brother Jesse

Adams as a correctional officer, which the average person would construe as a conflict of

interest by Sublette County Sheriff.

 

14. That Defendant Sublette County Wyoming willfully, negligently, and with malice chose to

ignore Plaintiff’s allegations, and in doing so did not fulfill their obligation to uphold and enforce

the law, and that the investigation should have been turned over to the Wyoming DCI  in order

to eliminate potential conflicts of interest. Additionally, there appears to have been sexual

discrimination as well as sexual orientation discrimination committed by Defendant Sublette

County, as the reporting party was of the male gender.

 

15. That Defendant Adams was at the time of the complaint, employed by Sublette County

School District #1, and as a function of his employment, was in the close proximity of young

males, and that any reasonable person can see a conflict between the Defendant’s employment

and the allegations placed upon him by Plaintiff, and should cause concern in the community for

the safety of the children attending Defendant Sublette County School District #1. Defendant

Sublette County School District #1 is negligent in allowing a potential sexual predator to work

around the most vulnerable members of our community.

 

16. That Defendant Adams has engaged in sexual relations on multiple occasions while on the

grounds, in the employment of Defendant Sublette County School District #1, during working

hours. One occurrence happened in April 2015 between Defendant Adams and another

employee of the school district, in which Defendant Adams performed oral sex in the men’s

restroom, and the second incident occurred in August 2015 as evidenced by text messages on

August 4, 2015, obtained with consent from Defendant Adams. See Exhibit “H”.

 

17. That on Friday June 10, 2016, Defendant Shane Adams left during his working hours at

Sublette County School District #1, to take Plaintiff to the Pinedale Medical Clinic at

approximately 7:58 am. Defendant Adams bragged about not having clocked out and how he

was getting paid to be there. Defendant Shane Adams clocked out for lunch at approximately

10:30am, and clocked back in at approximately 11;00am. Plaintiff and Defendant Shane Adams

did not leave the Medical Clinic until almost 12:00pm. These actions show negligence and

contempt against his own employer, and the public including Plaintiff, who fund his salary.

 

18. That upon moving from 435 Onyx Pinedale, Defendant Shane R Adams committed theft

against Plaintiff. This was reported to Deputy Danielle Cooper who is employed by Defendant

Sublette County Sheriff’s Department on June 26, 2016. The total amount of real and

intellectual property taken from Plaintiff is in excess of $250,000.

 

19. That among the items taken from Plaintiff by Defendant Shane Adams are three bottles of

prescription medication, including pain medication, antibiotics, and anti nausea medication not

belonging to, nor prescribed to him, creating probable cause for drug related offenses.

 

20. That Deputy Cooper refused to investigate or prosecute, calling the matter “civil”.

 

21. That W.S. §6-3-402 defines Theft as “A person is guilty of theft if he knowingly takes or

exercises unauthorized control over or makes an unauthorized transfer of an interest in the

property of another person with the purpose of depriving the other person of the property.”

 

22. That Defendant Shane Adams has these items (details in count 8) without permission, and

Defendant Russell K. Adams is knowingly allowing stolen goods to be kept under his control at

his residence at 307 S. Madison, Pinedale.

 

23. That Sublette County Sheriff’s Department and Sublette County Wyoming County Attorney

have neglected their duties to investigate and pursue criminal charges in multiple felonious

crimes committed against the Plaintiff.

 

THEREFORE, Plaintiff hereby prays this Honorable Court for the total sum of $150,000 for

Defendant Shane Adams commission of criminal sexual assaults on Plaintiff, and

$150,000 for Sublette County’s failure to inform Plaintiff of his rights as a sexual abuse victim as

required by law, and for their willful failure to investigate felony theft, and felony sexual assault..

 

COUNT IV

NEGLIGENCE

 

Now comes Plaintiff Jason R. Harlow complaining about Defendant Shane R. Adams, Jerry L.

McMackin, Russell K. Adams, Sublette County Wyoming, Sublette County School District #1

and alleges as follows:

 

1. That in the course of the events that have transpired between Plaintiff and Defendant Shane

Adams, a minimum of three persons with law degrees whom have been admitted to the

Wyoming bar have reviewed this case.

 

2. That at least two additional law enforcement officers whom have extensive training in the law

have seen this case.

 

3. That none of these highly trained and educated individuals realized that they were violating

Plaintiff’s civil rights, when any reasonable person could see a violation of the law had occurred

against Plaintiff , creating serious reasonable doubts about their training, education, and

experience in serving their community.

 

4. That Magistrate Welch should have known that she was violating Plaintiff’s civil rights when

issuing the Order of Protection.

 

5. That Defendants Shane Adams, Russell K. Adams, Sublette County Wyoming, Sublette

County Wyoming and Sublette County School District #1 were very aware that the only polling

place in Pinedale is on the grounds of Defendant Sublette County School District #1.

 

6. That Defendant Shane Adams should have personally known that Plaintiff is active in the

political process, and takes his civil rights very seriously.

 

7. That Defendant McMackin, in a selfish attempt to remove Plaintiff from Defendant Shane

Adams’s life, should have known that a public educational facility is open to the public, and

those kind of locations are generally used for community events, including but not limited to

elections.

 

8. That all Defendants were negligent in their actions and thoughts against Plaintiff, and all

should have known that Plaintiff has civil rights that are unable to be taken from him without due

process of law.

 

9. That removing an individual’s priceless civil rights and liberties guaranteed to them at the time

of birth until the time of death is cause for action, and should result in damages being awarded

to the Plaintiff.

 

10. That on or about December 29, 2015, Plaintiff discovered Defendant Shane R. Adams in

unauthorized possession of Plaintiff’s 9mm Taurus pistol loaded with 10 personal protection

rounds of ammunition. Defendant Adams informed Plaintiff that he was wanting to commit

suicide. Defendant Adams is not trained in the use or safety of firearms, nor has he never

attended any firearms safety course, thus putting the safety of Plaintiff at risk as well as persons

in neighboring households. Thus Defendant Adams was negligent in his unauthorized and

untrained handling of Plaintiff’s firearm.

 

11. That on July 20, 2016, Defendant Shane Adams closed the post office box without notice

used by both Plaintiff and Defendant Adams since October 2014, which multiple text messages

indicate the post office box was shared. See Exhibit “I”

 

12. That Defendant Adams was well aware that Plaintiff received lifesaving medication at that

address, and had done so since February 2016. See Exhibit “J”.

 

13. That due to Defendant Shane Adams’s negligent, willful, and malicious actions, Plaintiff was

unable to receive his medication, and missed one dose because of Defendant Adams’s actions.

 

14. That by missing even one dose of this medication, Plaintiff risks extreme life threatening

complications, including but not limited to developing resistance to the medication.

 

15. That the Order of Protection states that Plaintiff must notify the court immediately of any

change of mailing address.

 

16. That by closing the post office box without notice, Defendant Adams purposely caused

Plaintiff to be in contempt of the court order.

 

17. That on June 13, 2016 as Defendant Shane Adams was moving from the residence he

shared with Plaintiff at 435 Onyx Pinedale, WY, the parties had a discussion about how to pay

future household expenses, as both parties were on the lease. See Exhibit “K”

 

18. That both parties had been paying one half of all utilities and rent for the residence. See

Exhibit “L”

 

19. That the agreement was Defendant Adams would continue to pay property owner Joella

Dugan one half of the monthly rent ($400), and half of electric and gas, and Defendant Adams

further stated this in writing in his petition for Order of Protection on page three, that “I will

continue to fulfill my half of the lease (half of rent, utilities, and some yardwork) until Mr. Harlow

is removed from it or the lease is completed”. See Exhibit “M”.

 

20. Defendant Adams mentioned to Plaintiff that he would be disconnecting the Directv satellite

television service, the garbage service, and the DSL Internet Service with Century Link.

 

21. That Plaintiff told Defendant Shane Adams that he would fully pay for the cost of the internet

service and send this amount to Defendant on a monthly basis with the rest of the utility costs.

 

22. That Defendant Adams knew Plaintiff needed to the internet in order to operate the

businesses he owns and operates, including his online photography business, which requires

unlimited data due to the very large file sizes produced by a professional photographer.

 

23. That on June 24, 2016, Plaintiff received a list of the monthly bills, and Defendant indicated

that he had transferred the internet service into Plaintiff’s name, and provided a login id and

password for Century Link.

 

24. That Plaintiff never agreed to this, and never authorized his billing information to be provided

to Century Link by Defendant Adams.

 

25. That Plaintiff did try to login to the Century Link site to see the amount due so that he could

pay Defendant Shane Adams, but was informed by the website that the user name or password,

provided by Defendant Adams, was invalid. See Exhibit “N”.

 

26. That on July 20, 2016, Defendant Shane Adams disconnected the internet service with

Century Link, and without notice to Plaintiff.

 

27. That the lack of DSL internet service prohibits Plaintiff from conducting business operations,

and earning income, and prevents Plaintiff from backing up priceless, one of a kind images to

the online cloud service, potentially causing Plaintiff damages in the event of data loss.

 

28. That Defendant Shane Adams was negligent in cancelling the Century Link DSL service,

and has prevented Plaintiff from conducting lawful commerce.

 

29. That on August 5, 2016, Plaintiff was notified by his landlord Joella Dugan that the natural

gas bill “hadn’t been paid, and that Pinedale Natural Gas is transferring the service into my

name”.

 

30. That upon contacting Pinedale Natural Gas, Plaintiff learned at Defendant Shane Adams

“had requested the service be removed from his name”.

 

31. That this negligent action by Defendant Shane Adams is contrary to his written statement on

June 14, 2016 in which he stated he would continue to pay half of the utilities at 435 Onyx., and

that Defendant Shane Adams’s actions caused the gas service to be terminated, therefore

preventing Plaintiff from preparing meals, cleaning, and bathing, all of which are especially

important for Plaintiff due to his medical condition.

 

32. That on June 13, 2016, Defendant Shane Adams made a complaint to his supervisor, Mr.

Jeremy Qualls Principal of Pinedale High School, as evidenced by Defendant Adams’s written

testimony in case ST-2016-003 on page 4, presumably about Defendant Adams’s claims of

harassment.

 

33. That according to Sublette County School District #1 policy number “GBN” any harassment,

intimidation or bullying of any individual, school employee, or volunteer is prohibited. See

Exhibit “O”.

 

34. This policy states that it applies to all locations on school premises, and further states

“Employees who engage in bullying, harassment, or intimidation shall be subject to disciplinary

action up to and including termination.”

 

35. That as demonstrated in Plaintiff’s filing of a Domestic Order of Protection, FV-2016-0017,

on page four, that Plaintiff “saw Shane in my rear view mirror on the school grounds making

threatening gestures at me”. See Exhibit “P”

 

36. That this policy further states on page two, that an investigation shall be completed and that

during the investigation “The principal or his/her designees shall interview witnesses, including,

but not limited to the alleged victim and the individual(s) alleged to have engaged in the

harassment, intimidation, or bullying”.

 

37. That this policy also states “The person conducting the investigation shall prepare a written

report of the findings and conclusions of the investigation”

 

38. That a written report could not have been properly completed without Defendant Sublette

County School District #1 contacting Plaintiff, and had Defendant done so, they would have

known that an employee of theirs was making threatening gestures in contradiction to this

policy.

 

39. That the policy also states “Any employee who is found to have made deliberate or

intentionally false accusations, reports, or complaints is subject to discipline, up to and including

termination”.

 

40. That Defendant Sublette County School District #1 could not have enforced the above

mentioned clause without conducting a thorough investigation, and by not contacting Plaintiff for

his version of the events, are negligent in performing it’s duties as outlined in this policy.

 

41. That no interview was ever performed, and that no contact was ever made by the

Principal of Pinedale High School to Plaintiff, therefore violating the school’s own policy.

 

42. That Defendant Sublette County School District #1 was negligent in not conducting a full

investigation, and obtaining Plaintiff’s side of the story prior to issuing a criminal trespass notice

against Plaintiff.

 

43. That upon receiving the ExParte order of protection filed by Defendant Adams on June 14,

2016, two pages were included which contain confidential and personal identifying information

about both Plaintiff and Defendant Adams. These pages state in large capital letters  “This page

is confidential and released only to law enforcement” See Exhibit “Q”.

 

44. That these pages were released to Plaintiff due to negligence on the part of Defendant

Sublette County Wyoming Circuit Court Clerk Amy Knotts, and creates serious doubts that

Plaintiff’s personal information is secure in their care and custody.

 

45. That on June 21, 2016, Plaintiff entered the Sublette County Circuit Court to attend a

hearing regarding ST-2016-003 with a bottle of Fiji drinking water.

 

46. That Plaintiff was forbidden to take this bottle of water with him into the court room by a

Sublette County Sherriff’s Deputy serving as Bailiff.

 

47. That because of Plaintiff’s illness, and the medication used to treat it, Plaintiff experiences

very dry mouth and throat, making it difficult for him to speak without frequent hydration, and

causes severe discomfort.

 

48. That Plaintiff notified Bailiff of this condition, and was still refused the ability to hydrate

during the multi hour court proceedings, with the Deputy stating “that’s the rule”, despite the only

sign being posted in the waiting area indicated that only cell phones were prohibited.

 

49. That Defendant Sublette County Wyoming should have exceptions in it’s policies to permit

reasonable accommodations by persons with disabilities, but does not according to the Bailiff

who denied Plaintiff hydration.

 

50. That even persons incarcerated have free access to drinking water.

 

51. That Defendant Sublette County was negligent in providing a reasonable accommodation to

Plaintiff by refusing him the ability to drink water, therefore discriminating against Plaintiff.

 

52. That in denying Plaintiff the ability to hydrate due to his medical condition, Defendant

Sublette County has directly and willfully violated the Americans With Disabilities Act.

 

53. That Defendant Jerry McMackin was negligent in giving Defendant Shane Adams poor

advice, and has manipulated Adams into filing an order of protection, blatantly lying in court,

abandoning his household, thus leaving Plaintiff alone, scared, and full of fear for

his safety and freedoms.

 

THEREFORE Plaintiff Jason R. Harlow hereby prays this Honorable Court for the following

relief resulting from Defendant’s willful negligence: Defendant Shane R. Adams $ 500,000,

Defendant Jerry L. McMackin $250,000, Defendant Russell K. Adams $100,000, Defendant

Sublette County Wyoming $1,500,000, Defendant Sublette County School District #1 $500,000.

 

COUNT V

THEFT OF PERSONAL & INTELLECTUAL PROPERTY

 

Now comes Plaintiff Jason R. Harlow complaining about Defendant Shane R. Adams, Jerry L.

McMackin, and Russell K. Adams and alleges as follows:

 

1. That Plaintiff and Defendant Adams shared a life and home together in a domestic

relationship from approximately October 30, 2014 until June 13, 2016.

 

2. That both parties had willfully signed a one year lease for a home located at 435 Onyx,

Pinedale, WY in April 2016.

 

3. That Defendant Adams on his own free will, vacated the premises on June 13, 2016 with the

assistance of Defendants Jerry L McMackin and Russell K Adams.

 

4. That upon relocating to 307 S. Madison, Pinedale, WY, Defendant Adams willingly and

knowingly took property belonging to Plaintiff and as of this filing, as failed to return the property,

and that defendant Russell K. Adams and Jerry L. McMackin were notified of this occurrence at

the time, but failed to prevent it and in fact assisted in the commission of theft.

 

5. That W.S. §6-3-402 defines Theft as “A person is guilty of theft if he knowingly takes or

exercises unauthorized control over or makes an unauthorized transfer of an interest in the

property of another person with the purpose of depriving the other person of the property.”

 

6. That theft is a felony, punishable by imprisonment of up to 10 years if the property value is

over $1,000, or is a misdemeanor punishable by imprisonment of up to 6 months if the property

value is under $1,000.

 

7. That Plaintiff is a professional wildlife photographer who earns a portion of his living from

taking and selling prints of the area’s wildlife.

 

8. That Defendant Shane Adams is in possession of at least 50 original digital copies of high

resolution images created and fully owned by Plaintiff, without Plaintiff’s permission.

 

9. That these images are protected by United States Copyright law, and Wyoming theft laws.

 

10. That the Plaintiff would license the use these images for the sum of $5,000 each for

commercial purposes.

 

11. That the total commercial licensing value of these digital photographs is at least $250,000.

 

12. That Defendant Adams has published at least three of Plaintiff’s images on his personal

Facebook page, without compensation given to Plaintiff. See Exhibit “R”.

 

13. That the willful publication without written authorization of these images is in direct violation

of United States Copyright law, and should be considered theft in the State of Wyoming.

 

14. That Defendant Shane R. Adams has not compensated Plaintiff for the fair use of these

images in any manner and holds no license to use them in any way.

 

15. That due to the court order in ST-2016-003, Plaintiff is prevented from “placing under

surveillance” Defendant Shane Adams, and is therefore unable to know if his intellectual

property is being used for any sort of gain, or if it is being distributed by Defendant Shane

Adams in any form.

 

16. That on multiple occasions, Plaintiff requested access to Defendant Adams Dell laptop

computer in order to retrieve these images. Defendant Adams refused to find the power supply

cable for the laptop and refused to provide the password, thus preventing Plaintiff from obtaining

his intellectual property.

 

17. That Defendant Shane Adams has committed theft against Plaintiff by knowingly taking

various Christmas decorations, some given to Plaintiff by his mother, his deceased Aunt, and

his Deceased Grandmother, along with a list of other items. A complete list may be found in

Exhibit “S”.

 

18. That the value of these items are hard to determine, due to their sentimental value. However

Plaintiff estimates the value of these items to be over $1600. Defendant Russell K. Adams is

fully aware that these items are in his home, and is currently in possession of known stolen

property.

 

19. That Defendant Adams is in possession of over $150 worth of software belonging to

Plaintiff, and has access to online training purchased by Plaintiff.

 

20.. That Defendant Adams is in possession of the sole backup of Plaintiff’s iTunes music

library, valued at approximately $550.

 

21. That Defendant Shane Adams has the combination to Plaintiff’s floor safe, which contains

precious metals, ammunition, and important personal paperwork.

 

22. That an inventory of Plainttiff’s personal property on July 30, 2016 revealed missing silver

and gold from Plaintiff’s safe. See Exhibit “T”.

 

23. That the only person who could have taken those metals would be Defendant Shane R.

Adams as he had the safe’s combination, and a key to the home, and did enter the home on at

least one occasion when Plaintiff was not present on July 12, 2016.

24. That the approximate value of these milling precious metals is $293.63

 

25. That on July 1, 2016, Plaintiff obtained a judgment against Defendant Shane Adams in the

amount of $281 in case SC-2016-0052 in Sublette County Wyoming Circuit Court.

 

26. That the value of the missing coins is nearly the same amount as the judgment awarded to

Plaintiff.

 

THEREFORE Plaintiff hereby prays this court for the following relief against Defendant Shane

1. Adams:1. Return all real property, in good condition, belonging to Plaintiff or pay the sum of

$1,600, and 2. Allow all intellectual digital property belonging to Plaintiff to be extracted and then

deleted from any and all computers, tablets, Facebook pages etc belonging to Defendant

Adams, and allow the full inspection of same to ensure the images have been destroyed, or pay

the sum of $100,000. For assisting in the commission of felony theft, Plaintiff requests $10,000

each from Defendants Shane Adams, Jerry McMackin and Russell K Adams.

 

COUNT VI

FRAUD

 

Now comes Plaintiff Jason R. Harlow, complaining about Defendant Shane R. Adams and

alleges as follows:

 

1. That on or about September 29, 2014, Defendant Shane Adams made a marriage proposal

to Plainitff. See Exhibit “U”.

 

2. That Plaintiff said yes and agreed to the proposal, and engagement rings were exchanged.

 

3. That Defendant Adams further asked Plaintiff to relocate his permanent residency from

Springfield, Missouri to Pinedale Wyoming, and Plaintiff agreed, as engagement is typically a

sign of a promising, truthful, long lasting relationship.

 

4. That Defendant made multiple written promises to Plaintiff, and promised “forever’ on

countless occasions, as well as stating how no matter what, Defendant wanted Plaintiff in his

life, as he was a “blessing”. See Exhibit “V”

 

5. That in order to relocate, Plaintiff had to effectively abandon his two successful businesses,

stable affordable housing, and his position with the Halltown Missouri fire department.

 

6. That due to Defendant’s willful actions of infidelity with at least 15 other men, physical

assault, false imprisonment, and sexual abuses, Plaintiff had to choice but to abandon the

engagement in December 2015, but had no choice but to remain in the housing situation due to

financial circumstances.

 

7. That the engagement between Plaintiff & Defendant Shane Adams lasted 14 months.

 

8. That Plaintiff incurred over $1,408 in moving expenses to relocate from Missouri to Wyoming.

See Exhibit “W”

 

9. That Plaintiff’s cost of living increased from $0, as his housing, utilities, mobile telephone,

fuel, and vehicle insurance were covered by his company as a part of his compensation  

package as CEO, to well over $700 per month.

 

10. That Plaintiff incurred over $9,800 in living expenses previously payed for by his company,

an additional $1,408 in moving expenses, and at least $750 in food and household goods

brought by Plaintiff to his new home in Wyoming with Defendant.

 

11. That Plaintiff lost over $7,009 in guaranteed payments from his company during the 14

months of engagement.

 

12. That because of Plaintiff’s absence, additional employees were hired to fufill his obligations

to the companies during their busiest times of the year, incurring over $15,000 of cost to

Plaintiff’s companies.

 

13. That because of Plaintiff’s absence from his companies, the amount of total revenue has

decreased in both 2015 and 2016.

 

14. That due to the willful acts of Defendant Shane Adams, Plaintiff has suffered a loss of over

$ 18,967 in lost compensation, incurred living expenses, and moving expenses.

 

15. That Defendant Adams, after having maxed out his own Discover credit card and solicited

the assistance of a debt consolidation company due to his inability to manage finances, began

to request to utilize Plaintiff’s Discover card. This credit card was used for such expenses by

Defendant for a mobile telephone insurance deductible, concert tickets, groceries, tourist

attraction tickets, utility bills and more. The total debt on Plaintiff’s Discover card belonging to

Defendant is $1,871.27. See Exhibit “X”.

 

16. That Defendant verbally promised to pay Plaintiff for these charges but has not.

 

17. That any reasonable person would agree that when asking someone to commit to marriage,

that multiple acts of infidelity, emotional and physical abuse, and sexual abuse would be

grounds to terminate the engagement. See Exhibit “Y”,

 

18. That by willfully committing these acts against Plaintiff, Defendant has broken his promise to

engage in marriage with Plaintiff, and therefore has committed fraud by deceit, deception,

misrepresentation and negligence, causing Plaintiff great emotional and financial harm.

 

19. That on June 13, 2016 as Defendant Shane Adams was moving his belongings from 435

Onyx, Pinedale, a conversation was held on how Plaintiff and Adams would continue to pay the

monthly bills for the household. See Exhibit “Z”.

 

20. That the agreement was Defendant Adams would continue to pay property owner Joella

Dugan one half of the monthly rent ($400), and half of electric and gas, and Defendant Adams

further stated this in writing in his petition for Order of Protection on page three, that “I will

continue to fulfill my half of the lease (half of rent, utilities, and some yardwork) until Mr. Harlow

is removed from it or the lease is completed”.

 

21. Defendant Adams stated to Plaintiff that he would be disconnecting the Directv satellite

television service, the garbage service, and the DSL Internet Service with Century Link.

 

22. That Plaintiff told Defendant Shane Adams that he would fully pay for the cost of the internet

service and send this amount to Defendant on a monthly basis with the remainder of his portion  

of the utility costs.

 

23. That on June 24, 2016, Plaintiff received a list of the monthly bills, and Defendant indicated

that he had transferred the internet service into Plaintiff’s name, and provided a login id and

password for Century Link. See Exhibit “AA”.

 

24. That Plaintiff never agreed to this, and never authorized his billing information to be provided

to Century Link by Defendant Adams.

 

25. That Defendant Shane Adams willfully committed fraud against Plaintiff by transferring

billing responsibility into his name without permission, and in doing so has also committed

identity theft by using Plaintiff’s personal information to obtain services from a third party.

 

26. That on March 14, 2016, Plaintiff applied for food stamp benefits through the State of

Wyoming Department of Family Services.

 

27. That Plaintiff was given form DFS 109, “Request for Rental Verification” for his landlord to  

complete and return to the Pinedale DFS office.

 

28. That Plaintiff approached Defendant Shane R Adams and asked him to take the form to

landlord Joella Dugan for completion, as Plaintiff had a prior obligation.

 

29. That Defendant Shane Adams completed the entirety of form 109, and declared himself as

landlord, signing this document on March 14, 2016. See Exhibit “BB”

 

30. That Defendant Shane Adams delivered this form to the Pinedale DFS office on March 15,

2016.

 

31. That this form states at the top of the page, “Anyone who makes false statements to obtain

or help another person obtain assistance for which they are not eligible, is subject to penalties

under the laws of the State of Wyoming.

 

32. That by completing this form, Defendant Adams was certifying and declaring that he was the

landlord of the property where Plaintiff resides.

 

33. That Plaintiff issued Defendant Shane Adams a check and or cash on a monthly basis for

one half of the rent, and one half of all utilities and services to the household.

 

34. That because the amount due changed on a month to month basis, Defendant Adams

would issue Plaintiff a spreadsheet showing the total amount due for rent, utilities, and other

household services, which clearly shows each paid half the amount due. See Exhibit “L”

 

35. That Defendant Adams reduced services as landlord including natural gas service, garbage

service, internet and satellite television service after he relocated from the residence.

 

36. That if Defendant is not the landlord, Defendant Shane Adams should be held accountable

and prosecuted for falsifying documents and committing fraud with the Wyoming Department of

Family Services.

 

37. That Defendant Shane Adams’s actions placed Plaintiff at risk of losing benefits and facing

potential criminal penalties.

 

38. That Defendant Shane Adams deceived Plaintiff by reducing household services and utilities

after stating both verbally to Plaintiff, Magistrate Judge Welch, and in writing in his petition for

ST-2016-003 that he would continue to fulfill his obligations.

 

39. That Defendant Shane Adams has committed fraud against the People of the State of

Wyoming by fraudulently certifying that he was Plaintiff’s landlord on an official document.

 

THEREFORE Plaintiff Jason R. Harlow prays this Honorable Court for relief from the actions of

Defendant Shane R Adams in the Amount of $ 20,838.27 in actual damages, and an additional

$42,000 in punitive damages for Plaintiff’s losses.

 

COUNT VII

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

 

Now comes Plaintiff Jason R. Harlow complaining about Defendant Shane R. Adams, Jerry L.

McMackin, Russell K. Adams, Sublette County Wyoming, Sublette County School District #1

and alleges as follows:

 

1. That due to the collective actions of all Defendants demonstrated in this complaint, Plaintiff

has suffered great mental anguish and emotional distress.

 

2. That because of Defendant’s willful actions in attempting to remove plaintiff’s constitutional

rights, circumnavigate the laws of both Wyoming and the United States, deny him the

opportunity to vote at his polling place in an election, committing voter intimidation, disclosing

his confidential medical information, being negligent, failing to prosecute a crime, violating the

Americans With Disability Act, Fraud, committing discrimination, and violating the equal

protection clause, Plaintiff has been subjected to great emotional harm and distress.

 

3. Plaintiff has experienced difficulty sleeping, hives, diarrhea, loss of appetite, weight loss,

anxiety, fear, a severe panic attack, loss of interest in things he enjoys, and has been forced to

seek additional professional counseling because of the stresses placed upon him by

Defendants.

 

4. That due to extreme stress and sudden turmoil, Plaintiff has involuntarily increased his

cigarette consumption to over 3 packs per day, and has also increased his alcohol consumption

in an attempt to deal with the stresses placed upon him, which is causing irreparable harm to his

body and financial harm.

 

5. That in addition to these stresses, Plaintiff dealt with countless abuses inflicted by Defendant

Adams during their 19 month relationship, including: Not being permitted to make friends,

constant lies, constant infidelity when Adams had sexual relations with at least 15 men during

the relationship, including sleeping with 3 men over two days time on Christmas, constant false

accusations of infidelity, forced Plaintiff to purchase Defendant Adams tobacco products until

Plaintiff’s funds were depleted, & used Plaintiff’s state food benefits for himself. Additionally

Defendant withheld Plaintiff’s emotional support animal from him, taking her to Utah for multiple

days in order to have sexual relations with Jerry McMackin. Defendant committed abuse toward

the Plaintiff in the form of extreme social isolation and mental manipulation. See Exhibit “CC”.

 

6. That Defendant Shane Adams on more than one occasion, committed a felony against

Plaintiff by using his size to commit sexual abuse against Plaintiff. One on occasion while on a

business trip to Kansas, Defendant Shane Adams attempted to force himself sexually upon

Plaintiff in a public setting, causing extreme embarrassment for Plaintiff, and disclosing his

sexual orientation to professional associates and friends who were not aware of Plaintiff’s

sexual orientation.

 

7.  That some of the effects of sexual assault include anger, anxiety, shame, fear, depression,

guilt, rationalism, mood swings, numbness, loneliness, social anxiety, and difficulty

concentrating, all of which Plaintiff has been experiencing since Defendant Shane Adams began

his constant assaults and abuses against Plaintiff.

 

8. That Plaintiff had no privacy as Defendant Adams would comb though Plaintiff’s laptop and

mobile telephone, often times by force and coercion.

 

9. That because of the actions of the Defendants, Plaintiff had uncontrollable episodes of crying

and trembling often times for over an hour, nearly on a daily basis even six weeks after

Defendant Adams relocated.  

 

10. That Plaintiff has experienced anxiety, nervousness, and even paranoia while living in fear

that Defendant Shane Adams will tell yet another lie to the courts and or law enforcement,

resulting in Plaintiff’s arrest.

 

11. That Plaintiff gave up direct control over two successful small businesses in Missouri, a

position with the Halltown Missouri Fire Department, a relationship of eight years, pets, a stable

income, and friends in order to relocate to Pinedale Wyoming.

 

12. That this relocation by Plaintiff was based upon countless verbal and written statements

made by Defendant Adams, in which he made multiple promises, and mentally manipulated

Plaintiff. Plaintiff was very reluctant initially to allow things to progress and clearly stated this in

text messages. See Exhibit “DD”.

 

13. That Plaintiff tried to leave the relationship on three occasions, and was coerced into staying

by Defendant Shane Adams.

 

14. That due to both circumstances and the actions of Defendant Shane Adams, Plaintiff was

unable to financially afford to abandon the living arrangements, and was thus subjected to

additional abuses and manipulations.

 

15. That Plaintiff has feared for his safety from Defendants Shane Adams, Jerry McMackin and

Russell Adams since mid June 2016, and has been forced to carry a lawfully concealed

weapon on his person on a daily basis to ensure his protection from said Defendants, one

(Shane Adams) of which outweighs Plaintiff by over 120 pounds, and another (Jerry McMackin)

who is more than double Plaintiff’s size of 140 pounds.

 

16. That Defendant Shane Adams appears to be a mentally disturbed individual, who has a

documented history of pursing “the next best thing” in regards to relationships.

 

17. That Defendant Shane Adams’s ex boyfiend Jeff (last name unknown) stated in

conversation to Plaintiff on July 15, 2016 that when they were dating in 2012 (when Defendant

Shane Adams was 17 years old), that “When I called it off he said he had met an older guy who

he was in love with”. Jeff further stated “He was in love with some girl (identified as Venessa

Rugh) and an older guy (identified as a late 40s married man) at the same time. He seemed all

fucked up in the head”. He also further stated “ I’ve never had any regrets leaving him”. See

Exhibit “EE”.

 

18. That in December 2015, Defendant Shane Adams had a multi day, multiple partner affair in

Streator, IL, while in a relationship with and engaged to Plaintiff. This affair with Donnie Killen of

Springfield, Illinois, went as far as discussing relocation to be together, despite having only

known each other for a matter of hours. This affair came just days after Plaintiff had given

Defendant Adams $396.81 in Christmas gifts. Furthermore Defendant Shane Adams had invited

this individual to his motel room in Streator, IL without  even knowing the individual’s name, as

evidenced in Exhibit “FF”.

 

19. That in May 2016, Defendant Shane Adams once again pursed additional relations with a

new individual,  Defendant Jerry McMackin while in a relationship with Plaintiff, and shortly

thereafter ended all relations with Plaintiff.

 

20. That Defendant Shane Adams behavior and choices are indicative of a selfish, careless,

and hurtful individual who has no regard for the sanctity of a relationship, who is also a

controlling and manipulative individual.

 

21. That Defendant Jerry McMackin purposely induced metal manipulation into Defendant

Shane Adams, causing Adams to have a sudden and abrupt change in demeanor toward

Plaintiff.

 

22. That due to the manipulations caused by Defendant Jerry McMackin, Plaintiff found himself

alone, overcome with emotions, and full of fear for his safety and freedom.

23. That Defendant Jerry McMackin has been a direct cause of this complaint, and due to his

actions and poor advice given to a very naive Defendant Shane Adams, Plaintiff has suffered

greatly.

 

24. That as further proof of Defendant Shane Adams mental instability, Defendant Shane

Adams wrote Plaintiff a five page letter on or about May , full of half truths and false

accusations, with some bordering on the verge of insanity. Plaintiff, a few weeks later

wrote a response to Defendant’s letter. See Exhibit “GG”.

 

25. At the conclusion of this letter, Defendant Shane Adams wrote “Because honestly for

whatever reason I still want you”, and “Regardless I love you Jason Harlow. More than I think

you will ever know”. Defendant further wrote “ Either way I will always love you”, and “ Just as

long as I have you in my life somehow. Because I don’t think I could live it without you”.

 

26. That just a few days after presenting Plaintiff with this letter, Defendant Adams approached

Plaintiff and terminated the relationship, without showing any remorse or emotion. This occurred

just days after Defendant Shane Adams met Defendant Jerry McMackin for the

first time.

 

27. That Defendant Shane R. Adams appears to have committed a collective total of three (3)

felonies, and two (2) misdemeanors against Plaintiff in Sublette County Wyoming, all of which

have not been prosecuted.

 

28. That Plaintiff was a mentally stable, happy, outgoing individual prior to meeting Defendant

Shane Adams, and that Adams reduced him to a depressed shell of his former self, requiring

counseling and daily medication to combat depression and anxiety, and now requires the use of

an Emotional Service Animal as a direct result of Defendant Shane Adams’s manipulation,

abuse, and isolation. See Exhibit “HH’

 

29. That on June 21, 2016 in Sublette County Circuit Court for a hearing pertaining to ST-2016-

003, Defendant Adams willfully released information about Plaintiff’s health without reason or

permission.

 

30. That this release of information was done in malice and in a discriminatory manner.

 

31. That at least 7 persons heard his comment about Plaintiff’s illness.

 

32. That Plaintiff does in fact have an American’s With Disabilities Act defined illness, which

limits one or more life functions, and Plaintiff does not regularly disclose this information, and in

fact, Plaintiff has informed less than 10 persons about his illness.

 

33. That it is the right of every citizen to have their medical records and information kept under

the strictest of confidence, that every American is entitled to the right to privacy, and that

multiple laws exist to safeguard this right.

 

34. That Defendant Adams only released this information in an attempt to incite, damage and

defame Plaintiff, and in a small rural community this information could lead to severe problems

for Plaintiff in the form of discrimination, hatred, and potential violence.

 

35. That such release of information was irrelevant to the subject matter at the hearing, and that

Plaintiff immediately objected to the court.

 

36. That Plaintiff had gone to great lengths to ensure his medical information was kept out of the

community by using a pharmacy two hours away for medication, and visiting a doctor about four

hours away.

 

37. That while shopping at Ridley’s Family Market in Pinedale, WY on July 14, 2016, an

unknown middle aged white male passed Plaintiff in aisle 8, and said “fucking aids infested

faggot go away”, causing great emotional distress, a feeling of helplessness to Plaintiff, and

proves that someone present within the courtroom on June 21, 2106 repeated Defendant

Adams’s statement to at least one additional person.

 

38. That Defendant Shane R. Adams’s actions were negligent, and violated Plaintiff’s right to

privacy, and have placed knowledge of Plaintiff’s illness into the community in which he resides

 

39. That Magistrate Judge Lauretta Welch did nothing to condone Defendant Shane Adams’s

behavior, and did not strike it from the court record nor have the information sealed.

 

40. That the suffering and harm caused by all Defendants has been immense, and will likely

take many years to recover from the collective actions of said Defendants, as they have left

Plaintiff depressed with feelings of anger, fear and resentment.

 

THEREFORE, Plaintiff hereby prays this Honorable Court for relief from the intentional affliction

of mental distress brought on by Defendant’s actions as follows: Defendant Shane R Adams

$1,500,000, Defendant Jerry McMackin $ 750,000, Defendant Russell K. Adams $100,000,

Defendant Sublette County Wyoming $2,000,000, and Defendant Sublette County School

District #1 $1,000,000.

 

COUNT VIII

DEFAMATION OF CHARACTER

 

Now comes Plaintiff Jason R. Harlow, complaining about Defendant Shane R. Adams and    

Jerry L. McMackin, and alleges as follows:

 

1. That Plaintiff and Defendant Shane Adams shared a home and life together in a domestic

partnership from October 30, 2014, until June 13, 2016.

 

2. That on or about June 9, 2016, Plaintiff noticed Defendant Adams laptop open, turned on,

and had a Facebook message to Defendant Adams from Defendant McMackin. Plaintiff out of

the corner of his eye noticed his name was being mentioned in this message, and chose to read

it.

 

3. That Plaintiff discovered multiple derogatory, utterly false, and malicious statements had been

made about him by both Defendant Adams and Defendant McMackin.

 

4. That a vast majority of the statements made about Plaintiff were half truths in a pitiful attempt

to make Defendant Adams look superior and to try and impress Defendant McMackin.

 

5. Plaintiff discovered there was a love affair occurring for quite some time, even before Plaintiff

and Defendant had ended their relationship, with each Defendant calling each other “babe”,

stating how they should take more photographs of them together, and stating how they “couldn’t

wait to get in that ass again”, and how Defendant Adams “should quit his job, move here, and  

get a meaningless job for benefits” among many other statements.

 

6. That some of the statements made by Defendant Adams to McMackin included such phrases

as “Jason’s ex still supports him, and so I do. He is a leach.”

 

7. That such a statement about Plaintiff is blatantly false.

 

8. That Defendant Adams told Defendant McMackin via telephone conversation, overheard by

Plaintiff on or about June 9, 2016 about Plaintiff’s medical condition without permission, and

stated how Plaintiff “wanted to intentionally infect him”, and indicated to McMackin that it was

some sort of assault and / or attempted murder.

 

9. That Plaintiff told Defendant Adams about his medical condition via text message on July 16,

2014, well prior to meeting for the first time on July 23, 2014, and well prior to any type of sexual

relations. See Exhibit “II”.

 

10. That despite knowing that Plaintiff had a life threatening, sexually transmittable disease,

Defendant Adams still requested that Plaintiff have unprotected sex with him, and that

Defendant Adams considered himself a “bug chaser”, which is defined as someone trying to

intentionally become infected with the HIV virus, as evidenced by text messages on October 24,

2014. Defendant Shane Adams on multiple occasions pleaded with Plaintiff to “make me poz”

and attempted to glorify Plaintiff’s illness. On October 12, 2014, Defendant Adams states to

Plaintiff in part that he planned to be “Planting my hot poz seed making that ass mine”, implying

that Defendant Shane Adams was  HIV positive himself, while misleading Plaintiff.

 

11. That Plaintiff was portrayed as a crazed, abusive, psychotic, poor, invalid who had no life,

no successes in life, and was a burden on society, all of which could not be further from the

truth, In all actuality it was Defendant Shane Adams who was willingly attempting to become

infected with the HIV virus by having unprotected sex with multiple persons infected with HIV,

which would be considered by most to be a true act of someone deeply mentally disturbed.

 

12. There were multiple additional false and defamatory statements which will be revealed at a

later time.

 

13. That Plaintiff has owned multiple successful small businesses, has volunteered his time as a

firefighter and emergency medical responder, has donated his time as a commercial pilot to

introduce people to the sport of hot air ballooning, has been a superb ambassador for the US

Forest Service, has personally organized and executed an airshow in Kansas  in coordination

with local and federal officials for five years, and is a well known professional wildlife

photographer who is generally held in high regard by the people he meets as evidenced by

numerous character letters sent to Plaintiff.

 

14. That Defendants uttered multiple false, misleading, and untrue statements about him, and

that in finding out these statements were made, caused severe anger, multiple panic attacks

which resembled  heart attacks, and severe anxiety to Plaintiff.

 

15. That during the hearing regarding ST-2016-003, Defendant Shane R Adams falsified

evidence, and committed perjury by deleting nearly 12 text messages from his sworn submitted

transcript, and wrote two additional false statements, proven false through audio recordings and

due diligence.

 

16. That also during the hearing regarding ST-2016-003, Defendant Shane Adams also falsely

accused Plaintiff in having a spare key to his 2016 Jeep, and went into great detail on how

Plaintiff had supposedly made a fake online persona to intimidate him, both of which are

unsubstantiated, false, slanderous, and malicious.

 

17. That in recent weeks, Defendant Adams has been spreading false and malicious information

about Plaintiff on various internet web sites. See Exhibit “JJ”.

 

18. That many false and degrading statements about Plaintiff were told to multiple individuals by

Defendant Shane Adams, including Jason Boyden of Little America, Wyoming, Brandi Panter

of Layton, Utah, & Vanessa Rugh of Pinedale, Wyoming.

 

19. That Defendant Shane Adams had told Plaintiff about various abuses and traumas he had

incurred in his childhood, and Plaintiff had vowed to never intentionally harm Defendant Shane

Adams, and did his best to never breach that promise.

 

20. That Plaintiff never once raised a hand to harm Defendant Shane Adams, as evidenced by

his written testimony while seeking an order of protection against Plaintiff.

 

21. That in his written petition in obtaining a Stalking order of protection against Plaintiff,

Defendant Shane Adams made multiple false, misleading, and slanderous statements about

Plaintiff.

 

22. That these statements included on Page 1: “ Mr. Harlow believed in taking things just one

step further to a level that some including myself seem threatening and almost crazy”, Mr.

Harlow hacked into my text messages”, “He then proceeded to threaten my livelihood”.

 

23. That no threat was ever made to Defendant Shane Adams by Plaintiff, That Plaintiff never

“hacked” into Defendant’s text messages, as Defendant had given him the password for the

Verizon account, and had on multiple occasions instructed Plaintiff to call Verizon on his behalf

to fix issues with the service, and that Plaintiff never once threatened Defendant’s livelihood as

it would be foolish when Defendant was responsible for half of rent and utilities.

 

24. On Page 2, these false statements include: “ Mr. Harlow then proceeded to post on

Facebook about his hatred for me which was deleted before it could be screenshotted”, “When

the fake profile Mr. Harlow created was spotted on Grindr only a few miles from my location”,

“Where he began to harass myself and Mr. McMackin”.

 

25. That Facebook does not automatically update a downloaded timeline feed so any such

posts would have been clearly visible on Defendant’s screen and able to have been captured, if

in fact such a post was actually made, which it was not. That Plaintiff never created a

“fake profile”, and that Plaintiff never harassed anyone through a “fake profile”.

26. On Page 3 these false statements include: “ Mr. Harlow took it upon himself to allow his

mother Kathy Diamond of Lincoln, Illinois and Kristina Rose of Topkea, Kansas to begin illful

slander in his favor over Facebook”.

 

27. That the individuals named are free to do as they wish and Plaintiff has no control over

another person’s actions.

 

28. On Page 4 these false statements include: “Telling me he has going after my job and would

do anything he could to get me fired because karma is a bitch”.

 

29. That Plaintiff never said such things, as clearly evidenced in text messages.

 

30. That Defendants should be held fully accountable for their choice in causing disruption to

Plaintiff’s life and creating extreme turmoil for him, while degrading his character by stating

false, malicious, and untruthful statements to multiple individuals.

 

THEREFORE Plaintiff Jason R. Harlow prays this Honorable Court for relief from the actions of

Defendants Shane Adams in the Amount of $350,000 and Defendant Jerry McMackin in the

amount of $200,000.

 

COUNT IX

FORGERY

 

Now comes Plaintiff Jason R. Harlow, complaining about Defendant Shane R. Adams and

alleges as follows:

 

1. That on June 10, 2016, Plaintiff had symptoms of a heart attack, and Defendant Shane

Adams took him to the Sublette County Rural Health Care District Emergency Room in

Pinedale, Wyoming.

 

2. That Plaintiff requested that Defendant Shane Adams not enter the ER area with him, and

stated “you chose not to be my partner anymore, and this is something reserved for those sorts

of relationships”.

 

3. That Defendant Adams chose to enter the ER area with Plaintiff despite his request and

wishes that Defendant not enter with him.

 

4. That while Plaintiff was receiving medical care including intravenous injections, an EKG,

nitroglycerin, and more, Defendant Adams began filling out the intake paperwork for the clinic.

 

5. That Defendant Adams filled out a majority of these forms, as evidenced by the handwriting

differences. See Exhibit “KK”.

 

6. That the patient information form includes a space for an authorization for release of

information.

 

7. That Defendant Adams placed his name into this box, instead of Plaintiff’s mother, despite

having no longer been involved in a relationship, and never inquired on whom should be

designated.

 

8. That Plaintiff did not sign this form personally, and never reviewed it prior to it’s submission to

the clinic staff.

 

9. That Defendant informed Plaintiff that there were only two forms to sign, when in fact there

were three.

 

10. That Defendant Adams willfully and negligently forged Plaintiff’s signature on this document,

making himself able to discuss Plaintiff’s financial and medical information with the clinic staff.

 

12. That Plaintiff never authorized Defendant Shane Adams to sign this form for him.

 

13. That Defendant forged Plaintiff’s name while Plaintiff was under medical duress, and while

under the influence of medically administered nitroglycerin, which cased Plaintiff severe

headache, weakness, dizziness, and drowsiness.

 

14. That Plaintiff was not aware of this forgery until August 2, 2016, effectively giving Defendant

Shane Adams access to Plaintiff’s medical information for nearly two months.

 

15. That on June 13, 2016 while moving from the residence at 435 Onyx, Defendant stated “I’m

your emergency contact, bitch” in a harsh negative tone, as evidenced by audio recording.

 

16. That also on this date, Defendant Adams started how he called the clinic to receive

information about Plaintiff.

 

17. That Plaintiff never authorized Defendant Adams to place himself into this position, and

Defendant willfully chose to assert control over Plaintiff by making himself an emergency

contact, and signing it into effect, knowing full well this was against Plaintiff’s wishes, thus

committing forgery against Plaintiff.

 

THEREFORE Plaintiff Jason R. Harlow hereby prays this Honorable Court for the sum of

$25,000 due to Defendant Shane Adams willful forgery of a medical document.

 

Plaintiff requests a jury of six (6) for the trial of this matter.

 

Plaintiff requests a change of venue from Sublette County Wyoming to Teton County Wyoming

in order to ensure a fair trial.

 

Plaintiff acknowledges that there will likely be extensive media interest in this case, and

respectfully requests the court to allow audio and / or video recordings by the media to occur.

 

FILED THIS ____ DAY OF AUGUST, 2016 IN THE DISTRICT COURT OF THE NINTH JUDICIAL DISTRICT, COUNTY OF SUBLETTE, STATE OF WYOMING, PINEDALE WYOMING

 

Filed For & By:  __________________________________

Jason R. Harlow

PO Box 81

Pinedale, WY  82941

417-848-5095

 

 

 

 

IN THE DISTRICT COURT OF THE NINTH JUDICIAL DISTRICT,

COUNTY OF SUBLETTE, STATE OF WYOMING