THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF INDIANA

Kay Kim,
Plaintiff, )
)
v. )
) Cause No. 1:08-cv-1644-SEB-DML
State of Indiana Attorney General, et al. )
Defendants. )

AFFIDAVIT OF CHARLES CHUANG

DURATION OF 1999 THRU PRESENT
IN SUPPORT OF PLAINTIFF’S MOTION AND COMPLAINT

1. My name is Charles Chuang. I am over the age of eighteen and reside in Marion County,
Indiana.

2. I, Charles Chuang have personal knowledge of the matters contained in this affidavit.

3. The Plaintiff, Kay Kim is a non violent and law abiding person. We moved into the
Village at Eagle Creek Home Owners Association (VECHOA) in February 1999. The VECHOA
has about 215 owners who each holds a title to a distinct unit and share all the common area such
as clubhouse, swimming pool, lake, and grass area. Except for the problems with the defendants
mentioned we have lived harmoniously with the other owners during the entire 10 years. We
wanted to live a quiet and peaceful life but the defendants will not stop bugging us. Unless there
are crimes committed any disputes between owners must be resolved by the VECHOA. The
police should not be involved in civil matters.

4. In 1999, the maintenance man told us bluntly to move out on the very day we moved in.
Soon after that we noticed that the VECHOA was replacing the roofs on several blocks and
repainting the entire property. The Buildings are less than 10 years old and the plaintiff wanted
to know if the roof replacement and painting should be covered by the builder's and/or
manufacturer's warranty. She also liked to check the accounts and books kept by the VECHOA.
The Office Manager at that time called the Plaintiff crazy and barred her from going to the Office
to check the books. While the Plaintiff was in jail the Office Manager tried but failed to get a
restraining order to prevent the Plaintiff from going to the VECHOA Office. The Office
Manager started giving problems to my dogs and sending many people to fish right outside my
unit till late at night. When we complained to the VECHOA, the Office Manager reprimanded us
for disturbing people in the common area. We were also banned from using the VECHOA
common area and facilities for a year. The Police were called on many occasions but nothing
much was done because no crimes occurred.

5. The VECHOA collected over $300,000 in association fees each year from the owners.
After 18 years the VECHOA has only $30,000 left in the reserved fund. The owners are not
allowed to see the accounts and books kept by the VECHOA. Since 2000 Defendant James

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FED1 AFFIDAVIT of Charles Chuang Dru1999tPresent Refiling 10JAN09 in Supp of Plaintiff’s Motion&Complaint 10JAN09&26DEC08
Waters has been paid to work as security for VECHOA. Under his watch, Sarah Wilson the
Office Manager stole $300,000 from the VECHOA in 2003 and Sharon Overley was dismissed
from the position of Office Manager for misappropriation and mismanagement of VECHOA
funds.

6. The President of the Board of Directors of the VECHOA in 1999 was Chris Meloy who
works as a prison warden at the Plainfield Federal Jail. He owns several units in the Community
but lives in Hendericks County. He summoned Scott Scales, a Marion County Policeman to his
house at 11.30 pm. They plotted and concocted an affidavit to accuse the Plaintiff who is a petite
handicapped Asian for threatening to slit his throat over the telephone. Chris Meloy claimed that
his life was threatened and afraid of the Plaintiff. There was no 911 call but the policemen came
to my house without a warrant and arrested the Plaintiff. The Honorable Judge Baker requested
for an evaluation on the mental health of the Plaintiff. The Doctor certified that there is no
evidence of psychosis. Chris Meloy and Scott Scales failed to show in court on numerous
occasions the Honorable Judge Baker dismissed the case.

7. In 1999, Linda Handlon and Patricia Landenthin called the Animal Control on numerous
occasions. They claimed that foul odor is coming out of my house. The Animal Control came
and verified that there was no smell.

8. In 2000, my vehicle was broken into while parked in the VECHOA property. I installed a
parameter sensor and alarm in the van. The parameter sensor went off but not the alarm, and
Linda Handlon called the defendant James Waters who is working as security for the VECHOA.
He came and banged on my door at 3 am in the morning. James Waters came and gave a traffic
ticket the following day. The Environmental Magistrate dismissed the ticket.

9. In 2004, the Plaintiff wanted to check the VECHOA books. The new Office Manager
Sharon Overlay refused and claimed that the Plaintiff is crazy. When the Plaintiff was sitting on
the grass in the common area outside Sharon Overley's patio, she contacted James Waters who
called and got the police to arrest the plaintiff for "trespassing" on the common property. The
arresting officer told me that the Plaintiff needed to have a mental evaluation and the charges will
be dropped. She was sent to the Wishard Mental Ward and released with no evidence of mental
disorder. James Waters and Sharon Overley told the Judge outside the Court's Session that the
Plaintiff is crazy. Her case is still pending in the court.

10. In 2006, Sharon Overley was fired for mismanagement and misappropriation of the
VECHOA funds. Sharon Overley owns three units in the Community. James Waters is currently
renting an unit from Sharon Overley.

11. In 2006, the Plaintiff filed in the Indiana Civil Court against the upstairs owner for
allowing her dog to urinate and poop on the balcony and the toilet waste water to overflow into
my unit. The Plaintiff mailed her filings to the Court but the Civil Superior Clerk claimed that
they have not received it. So she went the court to file her motions again. On one Friday, the
Police was called to the Clerk's office while the Plaintiff was filing her motions. The police
asked the Plaintiff to hurry up and leave the City County Building without giving any reasons.
She tried to make a complaint in Room 101, but the police gave her an ultimatum to leave the
building or be arrested. She chose to leave the building without filing the complaint. I was with
her at this time and the policeman asked me to leave too. The following Monday, the Plaintiff
went back to the Clerk Office of the Superior Civil Court to check if her motions has been filed
properly. This time the Judge came to the office and asked to police to take the Plaintiff out of
the City County Building. The Plaintiff asked the Judge for permission to go Room 101 before
leaving the Building. The Judge told her she will be allowed her to complete her paperwork in
Room 101. However the Policeman escorting the Plaintiff would not allow her to enter Room
101 to file her complaint. She was arrested for "trespassing" in the City County Building. The
Police Lieutenant brought her personal property to my vehicle that was parked along Delaware
Street. She ordered me to leave right away or be arrested for trespassing. This criminal case is
still pending in Court.

12. The Indiana Civil Court awarded judgment for the Defendants. A few days later the
Plaintiff received by mail an envelope containing over 50 pages of the missing and unfiled
motions and documents.

13. In 2006, Linda Handlon put a bottle of scent next to my unit door. The Plaintiff has
allergy. The Plaintiff tried and failed to remove the material from the plastic container. She then
took a garden knife to scrape the stuff out of the container. She left contents on the inside of the
cap and placed next Linda Handlon’s unit door (which is directly opposite my unit) and threw the
empty container into the trash bin, which is located outside the building. Linda Handlon and
Patricia Ladenthin then called James Waters who called 911 and requested for "a wagon to
transport a female." The Police came and arrested the Plaintiff for "trespassing". Half an hour
later, the arresting officer returned and he apologized to me personally for the arrest because he
has no choice. He asked if I know where James Waters is. I told him James was in Linda
Handlon's house. He was with James Waters for about an hour. Later he left after changing the
charges in the Probable Cause Affidavit to disorderly conduct and possession of a "butcher"
knife. In addition to a mental evaluation the Plaintiff was given an urine and blood test. The
Plaintiff was found to have no mental problem and the urine and blood test were both negative.
No witnesses signed on the Probable Cause Affidavit. This criminal case is still pending in Court.

14. In December 2006, the Plaintiff took some photos of the roof contractors disposing debris
from the Plaintiff's unit roof (without a safety net) in a hazardous and unprofessional manner.
The defendant Laura Ritter (current Office Manager) came banging at my door told us that she
will make sure that we move out of our unit. Since then our property and vehicles has been
vandalized many times and on multiple occasions. We complained to the Board of Directors but
have no responses.

15. When people related to Linda Handlon visited her they purposely pushed my buzzer to
harass us. People related to Patricia Ladenthin and Susan Sclipcea also pushed my buzzer many
times. The pizza deliveryman buzzed my house when Defendant Mae and Scott Perry ordered a
pizza delivery with my address on the order. On numerous occasions unknown people buzzed
my unit and drove away before we can come out. Some of the buzzing occurred late at night.
The policeman came into my unit and banged on the door several times to arrest the Plaintiff.
The Plaintiff is so traumatized by the buzzing and Police intrusions that we labeled our buzzer
"#2: DO NOT TRESSPASS".

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FED1 AFFIDAVIT of Charles Chuang Dru1999tPresent Refiling 10JAN09 in Supp of Plaintiff’s Motion&Complaint 10JAN09&26DEC08
16. From May 2007 to October 2008, Linda Handlon moved out of her unit. We do not have
any problems with the new people staying in her unit during the entire period. In September
2008, the defendant Scott Perry shouted at the Plaintiff for closing the unattended main door,
which must be kept, locked at all times. There were several follow-up arguments with the
Plaintiff. Scott Perry gave Patricia Ladenthin an old TV and wanted her to baby-sit his newborn
baby. Patricia Ladenthin started to call the police on the Plaintiff more than ten times over
frivolous matters. Patricia was heard shouting on parking lot that she had found the knife and
telling Scott and the Policemen that the Plaintiff was vandalizing her own car. She called the
police when the Plaintiff was touching up the paints and working on the vehicle. The Police
threatened to arrest the Plaintiff on many occasions even though she has not committed any
crimes. While the Plaintiff was calling the Police in the common area outside her unit she called
the police. On other an occasion, Scott and the other defendant, son of Susan Sclipcea joined
Patricia Ladenthin to harass the Plaintiff when she was in the common area. The Police came and
threatened to arrest the Plaintiff if she did not leave the common property area.

17. Linda Handlon moved back on October 2008. Patricia Ladenthin began to cohort with
policemen. She was taking video when the policemen was questioning the Plaintiff. She offered
her access card to VECHOA club facilities to a policeman. On October 10, 2008 (between 10am
and 12.30pm) James Waters convened a meeting with all my "enemies" in the City County
Building. Linda Handlon, Patricia Ladenthin, Mae Perry, Son of Susan Sclipcea and others
attended a meeting to work out a plan to "get" the Plaintiff. After the meeting both Linda
Handlon and Patricia Ladenthin made many separate calls to the police on the Plaintiff. On three
of these calls they both alleged that the Plaintiff has hidden knife and weapons on her. The
police officers dispatched often got phone instructions from James Waters. Patricia Ladenthin
called the animal control alleging that my dogs were running loose. An anonymous policeman
from the North West Division called the health department to check "foul odor" that apparently
comes out of my unit. All complaints were frivolous and unfounded. Since 2005 only 30 percent
of 911 calls and runs from my block were recorded in the dispatch file. For some reasons the
other calls cannot be located by Dispatch.

18. On November 6, 2008 at about 10am while I was walking my dogs I saw Ronda Heath
parked her car at the first lot besides the trash bin far away from my building. She walked behind
the garages and went to Linda's House. At about the same time I saw the Son of Susan Sclipcea
arriving in Linda's SUV. He then proceeded to Linda's house. When I was getting into my unit I
saw Patricia Ladenthin going into Linda's House. They were having a meeting in the house for a
while. At about noon, the son of Susan Sclipcea was upstairs with his cellular phone. Ronda
Heath was outside the building main door. She continuously pressed my buzzer, which is clearly
marked "#2 DO NO TRASPASS". several times. Linda Handlon's doorbell is marked "L
Handlon" in bold blue letters. The Plaintiff went out to check who is at the main door. I stayed
at my door to see who is coming. Ronda then abruptly pulled the door outward but the Plaintiff
wanted to close the door because she did not recognize the person at the door. Ronda then forced
the door open and claiming that she has the right to get in. He pushed the Plaintiff so that she can
get inside the door. She started to shout and call the Plaintiff crazy. The Plaintiff did not hit her
because her hands were on the door all the time. Then Linda and Patricia came out. Linda asked
the person upstairs for "camera". I did not know if the Son of Susan Sclipcea had video taped the
entire incident. Linda started calling the Plaintiff "psycho bitch" and tried to hit the Plaintiff with
her fists many times but was suppressed by Ronda and Patricia. The Son of Susan Sclipcea
called James Waters. Within minutes defendant Gregory Wilkes arrived at the site. The officer
who was dispatched by 911 was not there at that time. When the Plaintiff was getting into her
house Gregory followed her and repeatedly asked if she called 911. He also asked if the Plaintiff
was on any medications. I answered no twice to his questions. He then forcefully pushed his
foot inside my door and his hand was on the doorknob. The Plaintiff asked him to get out of her
property. He refused to leave and claimed that he has a right to come into my apartment. While
this was going on, Linda opened her door. Ronda and Patricia were standing next to her. In
unison, the three of them alleged that the Plaintiff hit Rhonda. At that instant Gregory grasped
the Plaintiff and lifted her out of the house and threw her down on the floor. The plaintiff
suffered a severe concussion and appeared to have lost consciousness. The Plaintiff was in pain
but Gregory intentionally pressed his knee on the back of the Plaintiff to cause bodily harm. He
continued to handcuff her. The Plaintiff has never resisted arrest before and did not resist on this
occasion. Her face was numb for several days and is still suffering from the headache. Gregory
pulled and dragged the Plaintiff outside the building. Gregory claimed that the Plaintiff was
faking and could walk normally. He handed her to another police officer. When asked by the
other officer Gregory told him that the wagon was already ordered at this point of time. Gregory
then went back to Linda's house to investigate. At the car park the Son of Susan Sclipcea called
James Waters again on his cellular phone and James wanted to talk to the police officer present.
The officer later conveyed the James messages to Gregory. Patricia Ladenthin walked passed the
Plaintiff on the way to the trash bin. On her way back she "winked" to the policeman. Five other
policemen arrived and they "high five" each other for the arrest. When Gregory came out, he has
three empty sheets of Provable Cause Affidavit. He told me that the Plaintiff is arrested for (1)
Resisting arrest, (2) Assault and (3) Discharging bodily fluids. He stayed in his cab to complete
his records. I was with him till he left the property. I did not see the EMT and Ronda Heath
were still with Linda. This case and the three other pending cases have been given to a special
judge.

19. The statue of limitations has expired on the three previous criminal cases. If the Plaintiff
has committed any crimes the Police would have pressed charges and convict her in a hurry.

20. The Plaintiff did not want me to be involved in these cases for fear of retaliations from
James Waters, IMPD officers, VECHOA Board Members, Office Manager and neighbors. We
have already made official compliant to the Citizen Police Complaint Office and other Police
Departments. This is a case of discrimination, corruption, embezzlement and cover-up. It is a
case of illegal use of police and other government departments to intimidate and harass. The
Plaintiff was arrested five times since 1999 and stayed a total 12 days in jail. Apart from the
financial expenses in jail bonds, court hearings, legal research she has suffered untold emotional
stress and trauma. I could no longer stand by and watch all the conspiracy and deceit going on
against the Plaintiff.

I affirm under the penalty for perjury that the representations contained in this affidavit are true
to the best of my information and belief.

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FED1 AFFIDAVIT of Charles Chuang Dru1999tPresent Refiling 10JAN09 in Supp of Plaintiff’s Motion&Complaint 10JAN09&26DEC08
Januanry 07, 2009 ______
By Charles Chuang
Phone# (317) 522-5721 & Address: 4250 Village Pkwy Cir e unit 2, Indpls., IN 46254