United States District Court for the Northern District of Texas

Rusty Donelson, Plaintiff

v

City of Amarillo, Defendant

v

Undisclosed Catalyst Project

Investors, Defendants

Civil Action No. ___2-18CV-036-D___

Complaint

Plaintiff;

  1. worked on the City of Amarillo CoC ad hoc committee partially funded by the federal government and said ad hoc committee recommended that the City of Amarillo create a low barrier shelter and that the City of Amarillo has failed to do so and the City of Amarillo has failed to consider the recommendations of their ad hoc committee. Plaintiff is entitled to relief, and plaintiff;
  2. worked on the federally funded City of Amarillo Downtown Revitalization CoC sub-committee and that the recommendation of said subcommittee was the creation of a low-barrier shelter and that said recommendation is pending and that City of Amarillo decisions to compel unsheltered individuals into shelters not designated as low barrier is premature. Plaintiff is entitled to relief and;
  3. work on the federally funded CoC Downtown Revitalization sub-committee indicates that downtown revitalization projects are entering their final phase while the City of Amarillo is simultaneously withholding the names of secret investors in downtown revitalization (catalyst) projects. Plaintiff is entitled to relief and;
  4. that the City of Amarillo was attempting to compel unsheltered individuals (particularly from the Christ Church Camp of New Beginnings) into a shelter not designated as low barrier shelter while at the exact same moment hostages at said shelter were being seized, shot and denied the right of the people to be secure in their persons and further denying any persons within its jurisdiction the equal protection of the laws. Plaintiff is entitled to relief and has;
  5. interviewed and performed preliminary intake and assessment of individuals that have been assaulted in shelters that the City of Amarillo is attempting to compel unsheltered individuals into, particularly from Christ Church Camp of New Beginnings, thereby denying unsheltered individuals the right of the people to be secure in their persons and further denying any person within its jurisdiction the equal protection of the laws. Plaintiff seeks relief and has;
  6. interviewed and performed preliminary intake and assessment of individuals whose property was stolen while in shelters which the City of Amarillo is attempting to compel unsheltered individuals into, particularly from Christ Church Camp of New Beginnings, thereby denying the right of people to be secure in their effects further denying any person within its jurisdiction the equal protection of the laws. Plaintiff is entitled to relief and has;
  7. volunteered during numerous activations of a warming-station which protected many individuals (including the plaintiff) that were sickened by exposure to airborne communicable diseases spread in the confined spaces of shelters. The City of Amarillo is attempting to compel unsheltered individuals, particularly from Christ Church Camp of New Beginnings, into shelters. This creates a serious public health hazard and denies any and all persons within its jurisdiction the equal protection of the laws. Plaintiff seeks relief and has;
  8. interviewed and performed preliminary intake and assessment of unsheltered individuals unwilling and unable to reside in the faith-based shelters the City of Amarillo is attempting to compel unsheltered individuals into, thereby creating an establishment of religion. Plaintiff seeks relief and fundamentally challenges the integrity of;
  9. the business director of a shelter receiving federal funds, which in testimony before the Amarillo City Council, indicated that homelessness was a personal choice and that homelessness can be solved by making the homeless even more uncomfortable. The plaintiff is entitled to relief and demands that;
  10. the City of Amarillo stop compelling unsheltered individuals to reside in faith-based shelters, terminate legal proceedings against Christ Church Camp of New Beginnings, take concrete steps to establish a municipal low-barrier shelter and identify catalyst project investors driving the homeless round-up.

Date: 02/27/2018____________                _______________________________________

                                                Signature of the attorney or unrepresented party

                                                Rusty Donelson__________________________

                                                Printed name

                                                1918 S Crockett__________________________

                                                Address

                                                Rusty.Donelson.FNB@gmail.com____________

                                                E-mail Address

                                                _______________________________________

                                                Telephone Number