Chronological Order of Events

 l.                     Vera Lena Peskan, a self-reliant, single woman,  was a capable upright citizen, self-employed in the trades as a builder, and a licensed Cosmetologist, with a general income ranging from three hundred to two thousand dollars per week, with no judgments, court orders of any nature, against her.   

 2.                    Vera Lena Peskan was in sole-ownership of acreage and home, in Perry, Fl., which she constructed from the floor up, without assistance, financial or otherwise, and indebted to no one. See Records Taylor, county, Florida.

 3.                    The same had not been in contact with the Defendant, Betty Dugan for over twenty-five years, when the Defendant came to the Plaintiffs’ home and re-introduced herself.

 4.                    In 1998, the occurrence of life-changing events began, with the indoctrination of the Plaintiff into a ministry named ‘Trinity Christian Ministries’. Exhibit A

 5.                    The vulnerability of the Plaintiff, living alone for many years, with no familial relationships, was quite evident, to one well-versed in ‘connivance’ and ‘devious’, well documented, behavior.  See Private Investigator report

  6.          She,  Betty Dugan,  said she now worked for God and after a great experience was dedicated to His Work and would erect a Shrine and place of worship at the specific sight upon which He appeared. 

Not remembering her as a godly person, I conceded, all can change and at her behest, sold my properties  and followed her instruction to move to Kissimmee, Fl., where I would live with the attorney known as Wendy Joy Carpenter.  It was suggested that we, (Joy Carpenter, Starla Caldaron,  Monica O’Reilly), were all now ‘sisters’.   This was a new and heartwarming feeling of security, for the Plaintiff.

 7.           In 2000,  the Plaintiff, Vera Lena Peskan, once again, without any financial assistance purchased and developed property in Davenport, Fl.  First Possession:

 See WARRANTY DEED  Exhibit B

8.   In 2001, Vera Peskan, our mother,  at the age of 96, was critically ill, diagnosed as mentally impaired, a danger to herself as well as others and placed in the care of the state. Exhibit C

  1. With the assistance of Wendy Joy Carpenter, as the Defendants’ attorney, the twosome, upon filling out the application for ‘Guardianship’ did commit perjury to the following questions asked of them by the Court. See Court Document Exhibit D

 On   Pursuant to Section 744.3125 of the Florida Guardianship Law, the undersigned submits this Application  for Appointment as Guardian of Vera Peskan, the ward and submits the following information,

(a)        Fraud upon the court  No. 3. Date and Place of Birth:  October 8, 1943- Detroit, Michigan..

Re:  The Defendant was born in Windsor, Ontario, Essex County. See Canadian Registrar General Documentation.

(b)        Fraud upon the court  No. 14.  Has applicant ever been judicially determined to have committed abuse or neglect against a child as defined by the Florida Statutes?  Yes- No X  . See Court Record Titled: MOTION FOR INJUNCTION PREVENTING FORMER WIFE FROM PERMITTING ELIZABETH DUGAN FROM HAVING CONTACT WITH THE PARTIES; MINOR CHILDREN

Document Case No. 91-348-CA

Div: F .  See   Exhibit E

 

(c)        Fraud upon the court  No. 29. Has applicant ever been discharged from employment?.

Yes _  No X

Re:  Betty Dugan, as she was known at the time of employment by Gayfers Department Store,  of Tallahassee, Fl circa 1965 through 74, was discharged by Gayfers, for inappropriate behavior.

 See Court Document. Exhibit F

             10.        Larceny by False Promise and Undue Influence   Upon being named guardian, Betty Dugan  took Oath to our mother to see that I had a paid for home, and never have financial hardship and the rest of the money was to be put into the hands of  the “ministry”, Trinity Christian Ministries, Inc.

  1. Upon the appointment of ‘guardian’, the duo of  Dugan and Carpenter, had a ‘re-evaluation’ to declare the person of Vera Peskan,  ‘Competent’.  They created a ‘will’ for the formerly incompetent, intestate, to sign  her estate to the ministry of Trinity Christian Ministry’.   See Exhibit G
  1. Fraud upon the court.  Upon gaining control of the estate, my property, was,  ‘under color of law’, transferred into the estate as a holding of the deceased, by the same entities, Dugan and Carpenter.  The  mortgage was ‘satisfied’ by said estate.    See Exhibit H
  1. The property in question was then transferred back into the name of the Plaintiff.  See Exhibit I.
  1.  I,  the Plaintiff,  became the primary care-giver to our mother.  She was on her death-bed when we arrived, but after the Defendant’s wrestling of the guardianship  from the court-appointed group, with my care, she regained some of her strength.  The co-horts of the ‘ministry’, most of which are attorneys, had Vera’s trust put entirely in Betty’s hands.  Mike Garlington, of Northern Trust, an attorney and ‘ministry partner’, against his better judgment, put all the monies and holdings, solely in the hands of Betty Dugan, which he stated ‘was unlawful and he wanted to ‘wash his hands’ of the transactions’.  Material Witness For Subpoena
  1.   Within months, in fear that my children would interfere with plans and influence me to not give up my inheritance, (they all reside in Tallahassee, Fl., where my mother resided),  Betty moved my mother to my home in Davenport, Fl.  The abuse, which was in the form of ridicule, debasement, sleep deprivation, lack of privacy, alienation, deception and complete control, was continual.  Material witnesses to abuse and control, to be subpoenaed and are also in the form of notarized statements. Exhibit J
  1. Fraud upon the court  The next instrument created was the fraudulent Quit Claim Deed referred to by the Defendant as a WARRANTY DEED.  While under duress and undue influence and subsequently of ‘diminished capacity’ the instrument, with fraud on its face, was put before the Plaintiff. . Without ‘meeting of the minds’, no mutual assent and misrepresentation.  see  Exhibit K & B
  1.             Assault and Battery upon my granddaughter, Dulcie Porter, while on my premises.  Threats upon the life of my granddaughter by slapping, punching and physically throwing her off my property, were also perpetrated by the Defendant. Her threat was “Your Grandmother owns nothing here! It all belongs to me and my MINISTRY!  I have connections from here to Washington, DC and can make anyone disappear, and will!” See Exhibit L
  1.            Assault and battery was committed against me and I was physically  thrown from my home, my entrance to it was barred by Jerry Hendrix, the Defendants’ hired-man.  She ordered him to install dead-bolts and change all locks.. My possessions were thrown to the street. Material Witnesses:  Jerry Hendrix and Mike Hamilton, who was, at that time, a renter of mine.
  1.             With  threats that the group of attorneys, Joy Carpenter and Starla Caldaron, of Joy-Star PA. would have me seized and Baker Acted, as well as given shocks treatments, I left, in fear for my very life and freedom.
  1.             My home was paid off by the estate, as promised.  No money was allotted me from the estate, as promised and I was reminded daily that I should be grateful, because I certainly was not worth anything and that I had never had anything before they came into my life.  After a while, I actually succumbed to the verbiage used against me daily,  that I was a ‘psycho-babbler’ and accepted all as my punishment and/or retribution. Exhibit M
  1.             On or about 9/10/03 weeks after obtaining my name on said instrument,  I saw a three page ‘warranty deed’  lying on my kitchen counter, which I incredulously read as follows:  It conveyed everything I owned, even the furniture and window treatments I made, entirely to the ministry and upon Betty’s death, all went to her DAUGHTER!   Joy Carpenter told me I had 24 hours to state a claim to whatever I thought was mine, after that, it went entirely to them.  When I questioned Betty she told me I was a psycho babbler, crazy and was calling the authorities to have me Baker Acted.  Her threats were inclusive of shock treatments as well as being removed in a straitjacket!  See Affidavit of Truth From material witnesss, Victoria Porter Exhibit N
  1.             The series of unfortunate events that followed are detailed in the Complaints against Polk County, Dept. Of Children and Families and State Attorney Jerry Hill, etc.

I reserve the right to add Defendants, as necessary, in the interest of Justice.

 Further, the Affiant sayeth naught.