AUTHOR’S NOTE: I understand Bob Shaw is no longer among the living.




U. S. District Court for the Western District of New York at Buffalo



Robert Christopher Kettenburg, Plaintiff

389 Davison Road #4

Lockport, New York 14094

(716) 433-8611




Bob Shaw, Defendant

280 Berkley Road

Williamsville, New York 14221-7105

(716) 634-6777



COMPLAINT Under Title 18 of The United States Civil Statue Code, Part I, Chapter 13,

Section 241: Conspiracy Against Rights.

Section 242: Deprivation of Rights Under Color of Law.

Title 18 U.S. Code, Part I, Chapter 113C, Section 2340A: Torture, as defined in Section 2340.

Title 18 of the U.S. Code, Section 2236, Searched Without Warrant.



          1.) This action is brought pursuant to Title XVIII of The United States Civil Statue Code for conspiracy against rights, deprivation of rights under color of law, torture, as defined in Section 2340, and searches without warrant. Jurisdiction is specifically conferred on the Court by 42 U.S.C. section 2000e-5. Equitable and other relief are also sought under 42 U.S.C. section 2000e-5(g).


          2.) Plaintiff, Robert Christopher Kettenburg, is a citizen and honorably discharged veteran of The United States of America and resides at 389 Davison Road #4, Lockport, New York, 14094. Phone - (716) 433-8611. His address on the internet is:


          3.) Defendant, Bob Shaw, is plaintiff’s landlord.


          4.) The circumstances regarding said civil rights violations are as follows: Plaintiff moved into stated residence on January 21, 2004, because at his prior residence, the people who lived directly below him, Pearl Kloac and her husband of unknown name, 6594 Dysinger Road #9, Lockport, New York, 14094, would bang on the ceiling every hour on the hour, for months on end, preventing me from reaching deep sleep. She drives a blue Lincoln Continental with Michigan license plate XKB767. The person she claims is her husband drives a green Pontiac Bonneville with Michigan plate 3CPY81. When I confronted them about this, they would deny it. But I will state for the record right now that they’re LYING, as I could hear them snoring in the apartment right below me on a regular basis. Finally, I decided to call the New York State Police, at the corner of Dysinger and Bettie Avenue, and file a complaint. They informed me that Pearl Kloac’s drivers license said that she actually lived in apartment #10 of that building. So plaintiff would like to ask this Court, if Pearl Kloac’s driver’s license says she lives in apartment #10, why does she and her husband spend so much time in apartment #9, which is directly below where I lived, banging on the ceiling in the middle of the night every 10 minutes, for months on end?

          So finally plaintiff decides to move out of Applewood apartments on Dysinger Road to a place where he can get a good night’s sleep on January 21, 2004, without informing anyone where he lived. So you can just imagine plaintiff’s surprise when on January 22nd, 2004, defendant proceeded to bang on his ceiling, which is directly below plaintiff’s current residence, with a lead pipe, every ten minutes, for 72 hours straight. They tried to time it so every time the wind blew he would bang on the ceiling, but it’s funny how no banging ever occurred on weekends, when there was nobody in defendant’s rented property, no matter how windy it was outside. Plaintiff would like to ask the Court, and a jury, what do you suppose the odds are of that happening? Plaintiff also wants the Court to know that when he moved, he told NOBODY WHERE HE WAS GOING, except his 88 year old grandmother.

          Shortly after plaintiff took possession of defendant’s premises, plaintiff had to call the police as someone broke and entered into plaintiff’s dwelling, stole a new computer modem that just happened to be laying outside of computer as plaintiff was preparing to upgrade his computer with a faster modem, and someone also punched a hole in plaintiff’s $500.00 bed. Plaintiff wants this Court to know that there was no forced entry – meaning someone with the key to plaintiff’s apartment was responsible. Please keep that fact in mind as you read the following.

          A couple of months later, defendant WALKED RIGHT INTO PLAINTIFF’S APARTMENT WHILE HE WAS SLEEPING IN THE BACK ROOM, without even bothering to knock or give notice that he was about to enter without permission. Defendant says he was there to fix a leak in plaintiff’s bathtub. Plaintiff wants this Court to know that THERE WAS NO LEAK IN HIS BATHTUB before defendant broke and entered into his dwelling, and now that defendant has replaced plaintiff’s drain plug, IT LEAKS; meaning plaintiff can no longer sit in quiet peace while taking a bath without the steady sound of water leaking – a form of torture in plaintiff’s opinion.

          Defendant will say he has the right to enter plaintiff’s dwelling to fix his bathtub (which wasn’t broken). Plaintiff responds by saying that according to the Uniform Residential Lease and Tenant Act (URLTA), which is the binding set of rules and regulations governing landlord-tenant relations in the majority of the states, landlord is strictly FORBIDDEN from entering tenant’s dwelling, unless if it’s an emergency such as a fire or to fix a broken water pipe.

          Defendant then walked rights into plaintiff’s dwelling AGAIN about a month ago, without bothering to call and give notice or even knock, to inform plaintiff he was late on his rent. It is plaintiff’s opinion that defendant is a sexual predator and that he uses his position as landlord to prey upon his tenants for sex. Defendant has made more than one unwanted sexual advance towards plaintiff. It is also plaintiff’s opinion that defendant is a cocaine addict and that he violates plaintiff’s civil rights in exchange for drugs or drug money.

A simple investigation should show the plaintiff is telling the truth. WHY? Plaintiff directs this Court to the following internet document:

The story and links contained on said web site should be all the proof this Court needs. Plaintiff believes the information contained on said web page is sufficient evidence to convince a jury of his claims, and plaintiff seeks to exercise his right to Trial by Jury in this civil matter.


5.) The civil rights violations set forth in paragraph 4 of this statement are still being committed by the defendant to this day.


          6.) WHEREFORE, plaintiff prays that the Court grant the following relief to the plaintiff:


          Defendants be directed to pay $40,000.00 for intentional acts committed in paragraph 4 of this complaint resulting in conspiracy against the plaintiff's rights, deprivation of the plaintiff's rights under color of law, torture, solicitation to commit an act of violence, conspiracy to murder, and attempted murder ($10,000.00 per civil rights violation), and, that the Court grant other relief as may be appropriate, including injunctive orders, damages, costs, and any attorney's fees.


          7.) I certify that all of the information contained herein is true to the best of my knowledge and that a copy of this complaint was hand delivered to the defendant’s lawyer, Matthew P. Pynn, 272 East Avenue, Lockport, New York, 14094, on October 4th, 2004.


Robert Christopher Kettenburg Pro Se

389 Davison Road #4

Lockport, New York 14094

(716) 433-8611