IT IS BELIEVED that: A Permanently Disabled Medically Vulnerable Patient's RIGHT to: (1) REPORT Patient ABUSE: Elder ABUSE to an abuser's Govt Medical Center employer; (2) Report Domestic Violence to Law Enforcement; and to (3) REPORT Child Abuse, Firearm Violence, Stalking and attempts on victim's life; (4) PETITION the State for Protection From ABUSE (5) Alert the abuser's employer to credible threats of workplace violence made by the abuser (6) Offer Moral Support and Communicate with her abuser's Other Abuse Victims . . .

ARE ALL non-criminal ACTIVITIES that are PROTECTED by THE US CONSTITUTION—even if the exercise of the Victim's rights causes annoyance and distress for her abuser.

1. Will a Municipal Chief Law Enforcement Officer's pretext of PROBABLE CAUSE for RETALIATORY PROSECUTION of ABUSE VICTIMS automatically DEFEAT Plaintiffs constitutional claims:

Whenever a Police Chief, acting in the role of Prosecutor DECLARES (absent proof of criminal intent) that:
• Domestic Abuse VICTIMS who MAIL a copy of her COURT PROTECTION ORDER to her abuser 'Violates her own Protection From Abuse Order"

Even though NEITHER the Protection From Abuse Statute NOR the Court Orders RESTRAIN the petitioning ABUSE VICTIM

Whenever a Police Chief in the role of Prosecutor DECLARES (absent proof of criminal intent) that:
• Patient Abuse VICTIMS criminally harass their violent ABUSERS—when the VICTIM reports PATIENT ABUSE to their Treating Government Medical Center (abuser's employer) and contact the ABUSER'S previous medical center assault victim . . . thereby causing the abuser distress and annoyance

Even though the specific state criminal statute Expressly EXCEPTS Constitutional Protected Activity from its application

2. IS IT PROCEDURAL (DUE PROCESS) ERROR TO GRANT DEFENDANT'S RULE 56 SUMMARY JUDGMENT MOTION

When The Court COPIED and PASTED into the Court's Dispositive Judgment "Opinion", Defendant's Summary Judgment Motion Briefs nearly WORD-FOR-WORD (to include Defendant's Bates Document Number System) -giving undue weight to Defense Counsel's finding of fact, conclusions of law and reasoning - hence failing to conduct its OWN INDEPENDENT Balanced, Measured, Researched and Reasoned analysis; or form it's own Fully Informed Opinion. ... and

• Absent Supporting Evidence from Defendant or in the Case File
• To the Complete EXCLUSION of Plaintiffs (NON-MOVING Party) Counter-motion and Opposing Response
• Without CONSIDERING EVIDENCE in the case file and in Plaintiffs Brief and Exhibits that Counter Defendant's claims, BUT Support ALL of Plaintiffs Claims of Malicious Prosecution, Abuse of Process and State Created Danger;

Right to report abuse and seek protection