1. IN THE CIRCUIT COURT OF NICHOlAS COUNTY, WEST VIRGINIA
Mark Halburn
Vs.
Dolores
John Parsons
Mervyn Smith
Arik Paraschos
Nazarene Camp of Summersville, WV
Nazarene Church Southern District, WV
Nazarene Church Northern District, WV
Patricia Keller
John Does 1-50
Jane Does 1- 50, Et. AI.
In May and June of 2017, the Respondents committed Conspiracy, Defamation of Character, Intentional
Affliction of Emotional Distress, Deception of the Court, Lies and Intentionally and Unlawfully Kept Mark
Halburn from Halburn by filing a False and Deceptive Emergency, then Permanent Domestic
Violence Protection Order and Renewed Such Order, all without Due Process as guaranteed by the 14th
Amendment of the United States Constitution.
1) In number 49 and number 50 of her final order, Keller LIES and says that Mark Halburn went to
's camp and "created a disturbance." In fact, on June 21, 2017, Petitioner Halburn
contacted law enforcement about a LAWFUL welfare check, arranged to meet them off the
camp property, and was directed to meet two Nicholas County Sheriff Sergeants at the camp
where a non-disruptive meeting was held as they promised to make the welfare check. Halburn
voluntarily left, without incident. However a camp official came out and acted erratically and in
an intimidating manner, including taking photos of Mark and his rental vehicle and license plate,
2. further verifying Mark Halburn's concern about being exposed to the erratic behavior
of camp officials. When Mark Halburn arrived at home, hours later, he was served with a
temporary DVP, despite doing nothing illegal or unethical with the welfare check. This
temporary DVP was secured by Dolores , Arik Paraschos and camp manager John Parsons
conspiring against Mark Halburn in retaliation for his legal reporting about the camp's 15
Nicholas County Health Department Violations and his lawful request of a welfare check. Keller
repeats her lie that FALSELY accuses Mark Halburn of going into a dorm to take photos and
falsely accuses Mark Halburn of having the health department conduct an inspection. Mark
Halburn has NO authority to order an inspection and did not order any inspection. In fact, PRIOR
to all of this the health department inspected the camp, in May, and found a whopping 15
violations! (the 2018 report was worse: 18 violations!) The fact that Keller LIED about this
situation, in her final order, shows continues bias against Mark Halburn and her MENTAL
INSTABILITY which DISQUALIFIES HER AS A JUDGE IN THIS AND ALL OTHER CASES!
Furthermore, Parsons and Paraschos lied in Family Court Hearings about Mark Halburn entering
a girls dormitory to take photos and about the addition of a security system specifically to
monitor Mark Halburn's activities. The truth is that Mark Halburn made an appointment with
Nicholas County Health Department Administrator, Rodney Boyce, to meet him at the camp,
June 2", 2017, where Mark stayed outside the dorms while Boyce met with camp officials.
Boyce has provided and affidavit proving this and disproving the false allegations of Parsons and
Paraschos.
Mervyn Smith has failed to take corrective action to reverse all of the above and has been rude,
arrogant and repulsive in his reaction to Mark Halburn's request for justice and replacement of
all lost parenting time and expungement and reversal of the illegal DVP's.
3. Due to the gross misconduct of Dolores Dingess, John Parsons, Mervyn Smith, Arik Paraschos
Nazarene Camp of Summersville, WV, Nazarene Church Southern District, WV, Nazarene Church
Northern District, WV, John Does 1-50 and Jane Does 1- 50, et aI., Mark Halburn asks the court for an
immediate and permanent injunction reversing and expunging the Domestic Violence Protection Order,
including the Emergency Order which was issued without Due Process to Mark Halburn and the Equal
Protection of an Emergency Hearing, full makeup parenting time, with - in TRIPLICATE,
makeup and a replay of all lost events including the July 4 parades, of 2017 and 2018, 's 10th
and 11th birthdays, Labor Day Weekends of 2017 and 2018, Thanksgiving, Christmas Eve and New
Year's Day, 2018, and the replay ofthe summer of 2017. The above is to include all lost time between
Mark and due to the respondent's gross misconduct. The camp official was retaliating for Mark
Halburn's lawful reporting of the camp's 1S Nicholas County Health Department violations, recorded by
a Nicholas County Sanitarian in May of 2017. This retaliation violated Mark Halburn's civil rights as the
Publisher of .com.
Parenting time between a father and son is priceless.
Respondents must also pay for Mark and to visit James Halburn, Sherilynn Thompson and her
family and all Southern California tourist attractions that missed out on due to their conspiracy
and gross misconduct.
Judge Keller's final order must be permanently expunged and reversed due to the Respondents lies and
4. conspiracy that contributed to the order. Keller and the Respondents must, all, be permanently
imprisoned for violating Mark and 's civil rights, retroactively to June 21, 2017.
Because the illegal DVP is a part of Keller's final order, in Putnam County case 11-0-516, the final order
must be expunged and reversed and all copies and reproductions and blog reproductions of said order
must be retrieved by the court and destroyed at Keller's expense.
Ownership of the Nazarene Camp must permanently be given to Mark and Halburn,
retroactively, to June 21, 2017. The Nazarene Church must be ordered to pay for all expenses, operating
costs, staff and manager costs, maintenance and mortgages related to the camp while it is owned by
Mark and Halburn.
Due to their Gross Misconduct, Keller must be permanently removed from the bench with all of her
prior orders reversed and expunged. Paraschos must be permanently disbarred with all of his Guardian
ad Litem reports reversed and expunged and all fees returned to litigants and the State of West Virginia.
Keller and Paraschos must be stripped of their law licenses and not be allowed to practice law again and
be permanently banned from all United States courtrooms.
The 14th Amendment of the United States Constitution clearly states that everyone is entitled to "Equal
Protection under the law." Therefore, Judicial immunity is clearly UNCONSTITUTIONAL Therefore Keller
and Paraschos are liable for their gross misconduct in the Halburn cases. Furthermore, the 9
th
Circuit
recently ruled that court officials are liable for lying in court, leaving Paraschos liable for his deception
and gross misconduct!
5. Time between a father and son is priceless. Because of the Respondent's gross misconduct, they must
each be ordered to, immediately, pay the discounted rate of $1 trillion in Compensatory damages, $10
trillion in Punitive damages and $1 trillion, trillion in damages for violating the civil rights of Mark and
Halburn. These damages are due from each of the Respondents to Mark and
Halburn, individually. Judge Keller has already proved that she is Mentally Deranged by criticizing such
damages. Therefore, due to her negative, mentally deranged comments, the nutcase judge is liable for
treble the amounts! Effective the moment that this lawsuit is mailed, the Respondents must, each,
IMMEDIATELY direct deposit these funds into Mark Halburn's Woodforest Bank account and create such
an account for Halburn and, IMMEDIATELY create an account for Halburn and
directly deposit the funds in 's account.
Also, effective IMMEDIATELY, the Respondents must, IMMEDIATELY, turn over PERMANENT AND FULL
CUSTODY of Halburn to Mark Halburn and transport to Mark's location and allow
Mark and to permanently live together outside of West Virginia and its impeached Supreme
Court! Such transportation of is to be at the Respondent's expense.
Because of Dolores continued deception of the court, all child support, paid by Mark
Halburn and all sanctions must be repaid, to Mark Halburn, in TRIPLICATE, RETROACTIVE to 2012.
Dolores must also pay child support, to Mark Halburn, in TRIPLICATE, to 2012, and from
this day forward. She must also pay all of 's medical insurance and expenses. All of this must be
6. in perpetuity!
Because Dolores lied about transferring to Winfield Elementary School, Mark Halburn must be,
IMMEDIATELY, allowed to transfer to the school of Mark Halburn's choice and that Dolores
must be ordered to recreate s first day of school so that Mark may attend and that all events
that Mark missed, due to Dolores' deception, must be recreated so that Mark and can enjoy
them together and so that can enjoy the normal childhood that evil Dolores and the evil courts
deprived them of.
In 2012, Dolores and deranged Family Court Judge Mike Kelly conspired to keep from visiting
his terminally ill grandmother, Nancy Halburn. Dolores had her lawyer, Henry Glass, fax a FABRICATED
email, ex-parte, to Kelly's office. This is an example of mentally deranged behavior by, evil, mentally
deranged people. Nancy died in 2012. In the best interests of a child, cannot continue to be
exposed to Dolores' mental instability and her attacks on his, normal, childhood as well of the attacks,
011 Mark and , by the West Virginia courts. Mentally deranged Judge Keller has made fun of
Mark's PROPER desire for and Nancy Halburn to have a final visit. Therefore, this court must
order Dolores Mike Kelly and Patricia Keller to put Mark and on a charter jet,
immediately, upon receipt of this filing, for a final visit. Whatever extraordinary means that , Kelly
and Keller must undertake to make Nancy Halburn available for the final visit are the problems of
Kelly and Keller and must be paid for at their expense! The Respondents were strong enough to
prevent the final visit. They must be held accountable to be strong enough to create that final visit,
7. immediately! and Nancy Halburn did not choose for Dolores to cheat and file for a divorce.
They must not be, continued, to be damaged by Dolores' immoral behavior and decision!
Only MENTALLY-DERANGED people keep a dying grandmother from her grandchild. Therefore, Dolores
, Henry Glass, Mike Kelly, Patricia Keller and Arik Paraschos must be,lMMEDIATELY, ordered to
undergo, intense, DAILY, mental therapy with a masters-degree educated therapist.
It must be noted that Kelly, Keller and Paraschos are NOT law-abiding court officials. In fact, they are
EVIL! EACH submitted their reports days and MONTHS late from the state requirements. Therefore,
Kelly and Keller's orders must be REVERSED AND EXPUNGED. Paraschos' report also violated Keller's
order deadline and the state deadline so it must ALSO be EXPUNGED!
Mark Halburn also requests that the court order , Paraschos, Parsons, Smith, et. AI., to,
IMMEDIATELY email ALL emails.notesandcorrespondence.et.AI. between all respondents as
DISCOVERY for this lawsuit to MarkHalburn@gmail.com.
8. · .
GLASS LAW OFFICES
Henry R. Glass, Attorney
~bit I
Glass Law Offices
5215 MacCorldeAvenue, S.w.
South Charleston, WV 25309
Phone (304) 766-8858 Fax (304) 766-8853
Email: Glasslaw@Suddenlinkmail.com
Website: Glasslawoffices.com
FACSIMILE TRANSMITTAL SHEET
TO: Honorable Mike Kelly
FACSIMILE
NUMBER: (304) 558-5803
FROM: Henry R. Glass, ill
DATE: May 30, 2012
No. PAGES
(With Cover): 2
COMMENTS: Re: Dolores Jean Halburn and Mark Vance Halburn
Putnam Civil Action No. ll-D-516
We are forwarding an exhibit for consideration regarding Mark Halburn's
Emergency Motion, being an email from Mark Halburn to Delores Halburn dated May 28, 2012.
IF PROBLEMS OCCUR IN RECEIVING TIDS FAX, PLEASE CALL (304) 766-8858
The information contained in thisfacsimile transmission is intended onlyfor the use ofthe indNidual or entity named
above and may contain information that is privileged, confidential or exempt or protected from disclosure under
applicable law. Ifthe reader ofthis transmission is not the intendedreCipient or the employee or agent responsiblefor
delivering it to the intended recipient, you are hereby notified thaI any dissemination, distribution or copying a/this
communication is strictlyprohibited. lfyou have receivedthis communication in error, please immediately notifyUS by
telephone andreturn the original message to us by mail. Thank you.
9. • Nicholas County Health Department
One Stevens Road, Suite 201, Summersville, WV 26651
Telephone: (304) 872-5329 - Fax: (304) 872-5362
www.nicholashealthwv.com
AFFIDAVIT
On June 2, 2017, i met with Mr. Mark Halburn upon request for a media-related interview at the
:::hurch of the Nazarene Campground located at 5461 West Webster Road, Summersville,
Nicholas County, West Virginia. Nazarene Campground staff and I entered a dormitory on the
northern edge ofthe property near the campground careteria to review violations recently noted
during a routine inspection. This abbreviated inspection comprised a period of approximately
ten minutes. We entered the building at an eastern ground floor exterior door and exited
through a western ground floor exterior door.
Mr. Hajburn did not enter the buiiding when we entered as directed by camp staff. Upon exit, I
observed Mr. Halburn walking away from the building, but I did not observe him in the building.
I did not observe Mr. Halburn taking photographs of the building. However, I was not in the
company of Mr. Halburn during the ten-minute inspection period, so I can attest to neither Mr.
Halburn's whereabouts !lor actions during that time.
Date
Subscribed and sworn to before me in said County and State this ~day of ~tli"7
My commission expires: ~ /;;~dOl!
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