2. The instant case is a further retaliation against

Defendant/Counterclaimant by the City in a continuing conspiracy

that has occurred over the past ten (10) years by members of an

elite group of men and women in Chattanooga bent on allowing and

protecting the illegal dumping of hazardous wastes. This group

consists of members of the City government and its Public Works

Department, members of three (3) of Chattanooga's largest law

firms, members of the Tennessee State government and the local

office of the State Solid Waste Manager, and judges of the State

and Federal Courts. There are over one hundred (100) companies in

the Chattanooga Area being allowed to give their wastes to Hydro-

Vac Services, Inc.(hereinafter "HVSI") and its owner, William

Foxworth ("Foxworth").  As bazaar as the above allegations may

seem, Defendant/Counterclaimant can prove every allegation of this

conspiracy and especially the subsequent retaliations by members of

said conspiracy against Defendant/Counterclaimant for his whistle

blowing activity, via tape recorded conversations, photographs,

video tape, state and federal documents, and state and federal

court records. This conspiracy has been allowed to continue

protected by the state and federal court systems over the past ten

(10) years. Fraudulent opinions issued by Federal Judge James H.

Jarvis and by Tennessee State Circuit Court Judge Samuel H. Payne

against Oliver (as Plaintiff) have allowed the dumping to go

unchecked. In both cases no discovery was ever allowed. However, in

the instant case before this Honorable Court, Oliver is a Defendant 


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