Exposing the Record: Why I Filed a Rule 54(b) Motion in My Case Against West Frankfort Officials

Public Accountability via Public-Facing Filing from Federal Court

West Frankfort, IL - Legal filings aren’t just dry paperwork—they are one of the last remaining tools for ordinary people to force accountability from those in power. What you're about to read is my official Rule 54(b) Motion, recently filed in federal court, which presents extensive new evidence that city officials—including West Frankfort’s attorney and code officer—have consistently used half-truths and selective enforcement to deflect from misconduct, deny services, and silence criticism. I want to be clear: this is not a personal grudge. This is about shining light on a pattern of abuse that affects not just me—but anyone in this community who dares to speak up.

Rule 54(b) allows a plaintiff to clarify unresolved claims and submit new, relevant evidence before final judgment is entered. This isn’t a criticism of the court—it’s part of the process. Courts can only rule based on what’s in front of them, and when powerful officials use gaslighting and misleading narratives to obscure the truth, the burden falls on people like me to lay the facts bare. That’s exactly what I’ve done here.

By sharing this filing publicly, I’m not just defending my own rights—I’m making sure the entire community sees what’s really going on inside the courtroom. The documents, emails, and city records cited here tell a different story than the officials’ polished statements and backroom deals. This is just the first in a series of filings I will be releasing publicly. The people of West Frankfort deserve to know what’s being done in their name and with their tax dollars—and I will not stop until the record is clear.

Now for transparency, all parties are presumed innocent until proven guilty. Criminal charges have not beeen filed, although I believe they should be. That is up to the state’s attorney, Abby Dinn. This is a civil suit, seeking to show how one resident has been targeted.

I publish this for transparency and to fully inform my local community what is happening in the courts that they may not know how to access. All documents are public and no personal info is provided. This document uses primarily city FOIA documents to show the truth.

I am not an attorney. There may be minor errors or typos in this document, but I am doing the best that I can. I spent a week on this, in full PTSD reactive mode, vomiting, and not sleeping - terrified. I was compelled to push back and try to show the court, that yes, I have evidence and I have way more than what is presented here should we go to trial.

I pray for my own safety, to find a way out of this harmful situation. I push to make my life whole again. I fight to make the truth come to light so my fellow neighbor will never endure this. I will begin sharing full filings here, when I can.

Full actual copy of federal filing entered into the court.

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF ILLINOIS

TINA ROSE,

Plaintiff,

v.

CITY OF WEST FRANKFORT, et al.,

Defendants.

Case No. 3:25-cv-00845-JPG

PLAINTIFF’S RULE 54(b) RESPONSE AND MOTION TO RECONSIDER IN PART

THE COURT’S JULY 2, 2025 ORDER (ECF No. 23)

Plaintiff, appearing pro se, respectfully responds to the Court’s July 2, 2025 Order

and moves, under Fed. R. Civ. P. 54(b) and the Court’s inherent power, for limited

reconsideration of the dismissal of Counts 13, 14, 15, and 16 (in part). In the alternative,

Plaintiff seeks leave to file a Second Amended Complaint pursuant to Rule 15(a)(2). Plaintiff believes the information provided herein supports her request and a reversal on these dismissed counts directly would add to judicial efficiency and not put further pressure on a disabled pro se litigant.

Plaintiff also had previously requested assignment of counsel. She believes, if granted, that these discrepancies on how much to present to the court and when, could be easily resolved. Given the intricacies of the case, the significance of its impact on a local community, that proper legal presentation would benefit everyone in the process.

The plaintiff has spent over a year fighting both mental and physical illnesses to stand up for her own safety.

The Court’s order misapprehended the existing record. Plaintiff respectfully asks this Court to reconsider, not on new evidence, but on a corrected reading of what is already in the docket—further clarified in attached Exhibits.

I. INTRODUCTION – Why Reconsideration Is Essential

The Court dismissed Counts 13–16 after finding “no pattern of illegal activity” and “no facts plausibly suggesting a criminal enterprise.” Order at 6–7. Those findings rest on an incomplete record. Four days before that Order, Plaintiff filed a Reply in Support of her Motion for Protective Relief (ECF No.__, June 30 2025). That brief—never cited in the dismissal—lays out, paragraph-by-paragraph, the dates, actors, statutes, and injuries the Court thought were missing. Each act listed in Exhibit A is directly linked to a supporting public record in Exhibit B or C, all of which are available for judicial review without discovery.

For judicial efficiency Plaintiff now attaches further evidence to clarify the exhibits she held for discovery:

• Exhibit A – Signed as an Affidavit - Timeline of Events

• Exhibit B – Chronological Predicate-Act Timeline distilled from the June 30 filing; Pulls out the “predicate acts” from Exhibit A to show that there are more than 2 acts in ten years, which is all that is required for RICO.

• Exhibit C – Evidentiary Appendix While still not fully exhaustive, but this demonstrates FOIA responses, city documents, photos, body-cam images, or other documents that the court can use to verify the truth of Exhibit B. There is additional evidence, some in video format which will be available in discovery. The amount of documentation for this is lengthy, but for judicial efficiency, primary documents to sufficiently demonstrate good faith in showing RICO and other claims are needed to be included in the complaint in order to ensure justice.
  
  

• Exhibit D – FOIA employment records proving Code Officer Thad Snell has zero safety certifications despite a hiring requirement that he be certified within six months. FOIA request, job posting, resume and application and the number of certifications on file with the city.

Together these materials show a public/private racketeering partnership in which (i) municipal officials weaponize their offices and (ii) landlord Robert Stanley—a private real-estate business owner with 30-plus local rentals—profits from illegal square-footage that trespasses on Plaintiff’s land. The abusive action and retaliation by officials have cost the plaintiff her own business and her reputation, pushing a disabled entrepreneur out of work and onto more government programs, like SNAP and medicaid. Prior, the plaintiff was able to make enough to buy her own food and did not qualify for medicaid.

II. GOVERNING STANDARD – Rule 54(b) and Pro-Se Leniency

Under Fed. R. Civ. P. 54(b) this Court may revise any interlocutory order “at any time” before final judgment. Reconsideration is proper to correct clear factual error or prevent manifest injustice. Galvan v. Norberg, 678 F.3d 581, 587 (7th Cir. 2012). Because Plaintiff proceeds pro se and in forma pauperis, her pleadings must be read “with the leniency intended by Haines v. Kerner, 404 U.S. 519 (1972),” and dismissal with prejudice is disfavored where simple clarification can cure defects. Donald v. Cook Cnty. Sheriff’s Dep’t, 95 F.3d 548, 555 (7th Cir. 1996).

III. CLARIFICATION OF THE FACTUAL RECORD

Exhibit A and B now lists over fourteen predicate acts—obstruction, witness intimidation, mail/wire fraud, retaliation under color of law—committed between 2016 and 2025 by municipal officials and private landlord Robert Stanley. RICO only requires 2 predicate acts in a ten year period, and the number of predicate acts listed here in this non-exhaustive list are more than 15 in less than a year. Highlights include:

1. Entrapment & false 911 call – Feb 14 2025 (18 U.S.C. §§ 1343, 1512).
   
   

2. False protective-order filing – Feb 20 2025 (§ 1503 obstruction).
   
   

3. Pre-dawn death-threat intimidation – May 18 2025 (§ 1512(b)).
   
   

4. Legislative sabotage – May 27 2025 (mail/wire-fraud scheme, § 1341) amending ordinances to protect Stanley’s illegal rental.
   
   

5. Untrained code-officer retention – 2019–present. FOIA records (Ex. C-1, C-2) show Code Officer Snell holds no required ICC certification years after hire, evidencing deliberate municipal indifference and a failure-to-train policy that fuels the enterprise.
   
   

6. Eight-year refusal to demolish a condemned drug house (2016 & 2024 orders ignored) culminating in the 8/16/24 home invasion (pattern element, § 1961(1)).

The plaintiff asks the court to note she asked for the most basic of protective orders. The city responded with a detailed argument why the plaintiff should not have it. The protective order asked for nothing except that the government officials follow the law. The plaintiff asked that no further threats, no actions against her, and no obstruction continue during the duration of this suit.

What was the city afraid of? One thing - the plaintiff asked that no further obstruction occur. Her safety and the safety of her home are on the line. Tim Arview, Thad Snell and the entire city council have obstructed the plaintiff from addressing safety and zoning issues before the zoning board for over a year.

The plaintiff is the only resident in history denied access to the zoning board in West Frankfort.

In January 2025, the plaintiff reached out to the Illinois Public Access Counselor’s office and they responded, stating that zoning board meetings were open to the public and they had to let her attend.

Immediately Tim Arview began doing everything possible to obstruct the plaintiff from the zoning board meeting - including making criminal threats to her, threatening her home and life - and participating and an entrapment scheme to attempt to have the plaintiff arrested prior to the zoning board meeting so she could not attend. Tim Arview used his position and tried to intimidate the plaintiff under the color of law.

When the entrapment scheme went terribly wrong on Friday, February 14, 2025, Tim Arview was running out of time. On Monday February 17, 2025, Tim Arview used his position and emailed all city officials and the zoning board - to not address the plaintiff’s safety issues.

The plaintiff went to the zoning board meeting on February 18, 2025 and she brought a friend, Ralph Hill, a recently retired Navy intelligence officer. The plaintiff attempted to address the zoning board, but no one was speaking to her and it was highly unprofessional. When the plaintiff pulled out images of the safety issues she faced, Tim Arview stood up and screamed “WHISTLEBLOWER! WHISTLEBLOWER!” Tim Arview prevented the plaintiff from further speaking.

Ralph Hill did speak. He stated that he had observed what appeared to be the weaponization of code enforcement to cause harm to the plaintiff and although he had recently moved here with intentions to invest in local business, his observation of the actions of city officials means he will never invest a dime in West Frankfort.

A full recording of this meeting will be available during discovery. The recording of the above zoning board meeting was recorded by the city of West Frankfort and will be delivered in discovery in its unaltered form. Ralph Hill has stated he is available to testify in future hearings.

Concrete business/property injury:

• Market-value loss – An appraiser’s letter and MLS analysis (Ex. B-10, B-11) document a $27,500 equity drop tied to the encroachment and persistent nuisance.

• Constructive imprisonment / loss of use – Trespassing structure violates fire-setback and egress codes; Plaintiff cannot safely leave, sell, or insure her home.

• Unjust enrichment to Robert Stanley – Lease copy (Ex. B-12) shows $700/month rent derived from square-footage that physically occupies Plaintiff’s lot.

• Interference with Plaintiff’s Writing Business: Plaintiff, a self-employed writer, has suffered significant loss of income and business opportunity due to the defendants’ pattern of harassment, obstruction, retaliatory legal filings, and unsafe neighborhood conditions. As a direct result of the sustained emotional trauma, public endangerment, and the necessity of constant legal self-representation, Plaintiff’s capacity to take on paid writing work has been severely impaired, causing economic damages and interruption of ongoing contracts and publishing efforts.
  
  

These sworn, dated facts demonstrate the continuity, enterprise structure, predicate pattern, and property injury the Court believed absent and Plaintiff held the bulk of the evidence was for discovery and had only listed the pattern in previous documents. Reconsideration—or leave to amend—will prevent manifest injustice and align the pleadings with the full evidentiary record now before the Court.

Unified Defense Counsel as Evidence of Enterprise Conduct

In addition to the predicate acts set out in Exhibit A, Plaintiff notes that every named defendant—whether sued in official or individual capacity—is represented by the same law firm, Heyl Royster, and specifically attorney Keith Hill. That includes state cases where:

• The complaint explicitly states defendants are sued as individuals (e.g., Clerk Andrea Bolen and Mayor Arview),
  
  

• The acts occurred off duty, at home, or outside scope (e.g., Bolen's false 911 call while off work),
  
  

• Yet West Frankfort City Council voted to use city resources through city insurance (Ex. B-13, FOIA record).
  
  

This arrangement consolidates control over every actor, every deposition, and every responsive document. The very act of one lawyer covering every individual actor and the municipality implies a “joint defense privilege” in response to informal discovery requests and emails.

The plaintiff confirmed through FOIA and court dockets showing appearance that all defendants—official and individual—are represented by the same counsel, Keith Hill of Heyl Royster, and that legal fees are being paid via city insurance. This is a vote that happened during a city council meeting. Later it includes defense of off-duty conduct committed at private homes, not during municipal functions. That legal arrangement consolidates control and constitutes further evidence of enterprise coordination and municipal policy of obstruction, satisfying Monell’s requirement of an official policy/custom or deliberate indifference (see Gable, 296 F.3d at 537).

In RICO terms, this constitutes active enterprise participation. Unified legal defense that obscures internal communications, protects predicate actors from liability, and prevents factual development is itself an act of ongoing obstruction, see Fund of Funds, Ltd. v. Arthur Andersen, 435 F. Supp. 84, 90 (S.D.N.Y. 1977); U.S. v. Gotti, 771 F. Supp. 552 (E.D.N.Y. 1991). It further satisfies Monell, showing that the city not only failed to prevent retaliation, but affirmatively funded its legal cover-up.

Under Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) and Ashcroft v. Iqbal, 556 U.S. 662 (2009), a complaint must allege facts that, taken as true, “plausibly suggest an entitlement to relief.” Plaintiff respectfully submits that the attached sworn affidavit (Ex. A), predicate timeline (Ex. B), and evidentiary appendix (Ex. C) meet and exceed that standard. The facts are not speculative; they are anchored in authenticated government documents, including city-issued FOIA records, official emails, police transcripts, and zoning ordinances. These materials, now properly labeled and submitted, show a pattern of unlawful conduct that is both plausible and concrete — satisfying Twombly/Iqbal and curing any defects noted in the prior dismissal.

IV. ARGUMENT

A. Count 13 (Monell – Failure-to-Train & Custom)

Plaintiff now identifies two independent municipal failings:

1. Express policy/custom of selective enforcement. On May 27 2025 city officials—Arview, Snell, Cantrell, and the council—voted to exempt favored landlords from mandatory safety inspections (Ex. A, line 10). They also refused to carry out demolition orders issued in 2016 and 2024 despite written findings that the structures were dangerous (Ex. A, lines 1-2). That long standing, well-documented pattern is enough by itself to satisfy Gable v. City of Chicago, 296 F.3d 531, 537 (7th Cir. 2002).
   
   

2. Complete failure to train or qualify the Code-Enforcement Officer. FOIA records show:
   
   

   • Exhibit C-1 (FOIA resume file): Thad Snell’s personnel file lists no certifications, licenses, or prior experience in building inspection, fire safety, or zoning.
     
     

   • Exhibit C-2 (Job-posting FOIA): The 2019 hiring advertisement expressly required any new code officer to “obtain ICC Property Maintenance & Housing Inspector certification within six months of hire.”
     
     

Snell has now held the position for more than four years and still lacks the mandated credential listed as his hiring requirement.. [See Exhibit D.] The City has provided zero documented training hours in building-code enforcement. In the Seventh Circuit, such deliberate indifference to obvious training needs states a Monell claim. See City of Canton v. Harris, 489 U.S. 378, 390-91 (1989); Sornberger v. City of Knoxville, 434 F.3d 1006, 1029-30 (7th Cir. 2006).

Taken together, the inspection exemption (policy/custom) and the City’s knowing retention of an untrained officer (failure-to-train) are the “moving force” behind the constitutional and statutory deprivations alleged here. The Court should therefore reinstate Count 13 or, at minimum, grant leave to amend so these facts appear on the face of the complaint.

B. Count 14 (§ 1985(2)/(3) Conspiracy)

The Court dismissed Count 14 under the intracorporate conspiracy doctrine, which bars conspiracy claims among employees of the same public entity. That doctrine does not apply here, because Plaintiff alleges a coordinated agreement between public officials and private parties—including landlord Robert Stanley, his associate Jonathan Stanley, and tenant Lauren Hawkins.

Robert Stanley is not merely a citizen; he operates a for-profit real estate business owning 30 to 40 properties in West Frankfort, many obtained through trustee deeds and non-transparent transactions. Several of these properties violate safety codes and zoning laws, including the illegal conversion that encroaches upon Plaintiff’s home. Rather than enforcing municipal code, the City has repeatedly altered ordinances to shield Stanley’s business—most notably on May 27, 2025, when the City Council passed a targeted amendment exempting landlords like Stanley from mandatory inspections by claiming familial tenancy (see Ex. A, line 10; Ex. B-10).

This public-private alignment is not hypothetical:

• On February 18, 2025, Mayor Arview shouted "She's a whistleblower!" at the zoning board to silence Plaintiff’s attempt to expose Stanley’s violations;
  
  

• On May 18, 2025, Jonathan Stanley arrived at Plaintiff’s property screaming the names "Tim Arview" and "Thad Snell" while issuing a pre-dawn death threat—clear retaliation for Plaintiff’s lawsuit against Stanley;
  
  

• On multiple occasions, officials including Snell, Arview, and Cantrell have refused to investigate or cite Stanley’s building, despite direct complaints and known trespass.
  
  

Each of these overt acts was intended to retaliate against Plaintiff for protected federal activity, including court filings and zoning participation. That satisfies § 1985(2)’s prohibition against conspiracies to intimidate or deter a federal litigant, and § 1985(3)’s prohibition on conspiracies motivated by invidious class-based animus (here, targeting Plaintiff as a disabled female whistleblower).

This public-private alliance defeats any claim of internal immunity under the intracorporate doctrine. The Seventh Circuit has made clear that § 1985 liability exists where "conspirators are not all public employees." Hartman v. Board of Trustees, 4 F.3d 465, 470 (7th Cir. 1993); Fairley v. Andrews, 578 F.3d 518, 525 (7th Cir. 2009).

Plaintiff has therefore pled all required elements:

• A meeting of the minds between public and private actors;
  
  

• One or more overt acts (false filings, threats, zoning obstruction);
  
  

• Injury to property and person as a result;
  
  

• And protected status under the law (disability and whistleblower).
  
  

The Court should therefore vacate the dismissal of Count 14, or in the alternative, grant leave to amend so these facts are presented with formal labels.

C. Count 15 (Civil RICO)

1. Enterprise – The Complaint (¶¶ 77–85) and Exhibit B (actor column) detail an ongoing association-in-fact enterprise comprising municipal officials — including the mayor, code officer, clerk, and council members — and private landlords, notably Robert Stanley and his associates. This enterprise functions with a shared purpose: to shield unlawful rental practices and suppress whistleblowers, including the Plaintiff, who raise safety and code violations. The group has a clear structure, with public officials wielding their regulatory authority (e.g., code enforcement, zoning board access, protective orders) in coordination with private actors who financially benefit from properties that violate zoning and trespass laws. The officials provide protection and obstruction, while the landlords profit from illegal rentals — forming a continuing unit with a common objective. This satisfies the enterprise requirement under 18 U.S.C. § 1961(4), as interpreted by Boyle v. United States, 556 U.S. 938, 946 (2009), which held that an association-in-fact need not have a formal hierarchy but must demonstrate purpose, relationships, and longevity. The enterprise here is not hypothetical; it is documented through FOIA records, public meeting footage, policy changes benefiting the landlords, coordinated legal defenses, and acts of retaliation against the Plaintiff.

2. Pattern – To satisfy the “pattern” requirement under 18 U.S.C. § 1961(5), a plaintiff must allege at least two predicate acts within ten years. Here, Plaintiff has identified not just two, but more than twelve discrete predicate acts spanning 2016 to 2025 — all detailed in Exhibit A (timeline) and charted in Exhibit B (predicate index). These acts include obstruction of justice, mail and wire fraud, witness intimidation, and retaliation under color of law — each tied to specific individuals within the enterprise. This list is not exhaustive, but was strategically limited to avoid overwhelming the initial pleadings. Importantly, Plaintiff now submits verifiable supporting records in Exhibit C, consisting of official city documents, police reports, FOIA responses, emails, and meeting transcripts — many of which were previously reserved for discovery. These are not personal allegations; they are confirmed by the defendants’ own documentation, meeting the plausibility standard of Twombly and Iqbal, and satisfying both “closed-ended” continuity (2016–2025) and “open-ended” threat of ongoing harm under H.J. Inc. v. Northwestern Bell, 492 U.S. 229, 242 (1989). The pattern is not speculative — it is structured, repeated, and now evidentially grounded.

Unified Defense as Pattern Evidence of Enterprise

Further evidence of the enterprise comes from defendants' litigation conduct itself. Despite clear conflicts of interest, attorney Keith Hill of Heyl Royster has filed appearances for every municipal defendant—both official and individual capacity—including for off-duty criminal conduct. The City Council voted to provide insurance coverage for purely personal acts, including Clerk Bolen's false 911 call made from her home while off duty. This arrangement prevents any defendant from testifying against another, ensures coordinated responses, and demonstrates the City's official endorsement of the criminal enterprise. No legitimate municipality funds the personal criminal defense of employees' off-duty crimes. This joint defense agreement is itself an act of ongoing obstruction under 18 U.S.C. § 1503.

3. Continuity – Ongoing Criminal Conduct with No End in Sight

The RICO pattern in this case satisfies both “closed-ended” continuity, reflecting a consistent scheme of misconduct from 2016 to the present, and “open-ended” continuity, due to the clear threat that this conduct will continue. See H.J. Inc. v. Northwestern Bell, 492 U.S. 229, 242–43 (1989). The enterprise’s unlawful acts — including obstruction of justice, false filings, witness intimidation, and misuse of public office — have continued even after this lawsuit was filed. In May 2025, Plaintiff was subjected to a pre-dawn death threat, with the assailant invoking city officials by name; this followed false protective orders filed in retaliation for whistleblowing. Robert Stanley continues to profit from an illegally constructed building that encroaches on Plaintiff’s land — a structure that generates rental income while trespassing, all with the active protection of city officials who refuse to enforce demolition orders or zoning laws. The enterprise’s purpose is clear: to harm disabled and low-income residents, to shield politically connected landlords, and to retaliate against anyone who speaks up. The Plaintiff has now submitted a sworn timeline of criminal obstruction (Exhibit A) tied to her efforts to reach the zoning board, and has documented multiple threats to her home and life made by public officials acting under color of law. These are not isolated events — they form a systematic campaign of coercion, concealment, and obstruction. The risk of continued harm is not hypothetical; it is active, ongoing, and evidenced by both public documents and recent events.

4. Business or Property Injury —The enterprise’s conduct has damaged Plaintiff’s “business or property” in distinct, measurable ways:

• LOSS OF BUSINESS INCOME: Plaintiff is disabled and is on social security. Unlike many, the plaintiff still chooses to work as much as she can. The small nature of her business activity does not diminish it or its importance in her life. The plaintiff lives on minimal means, yet owns her home outright, and her car is paid off. She works as a writer as a gig worker. The plaintiff did not earn much, but was able to pay her own groceries, and to pay her utilities. Since the start of the targeted harassment against the plaintiff, she has been able to work less and less.

  • The plaintiff was earning approximately $300-$400 a month to allow her to live on her own. The plaintiff now earns $0 per month.

  • The plaintiff used any additional time which fluctuates due to flare ups, for volunteer work. Tim Arview testified in the Franklin County Circuit Court Case 2025OP56 that when he met the plaintiff, it was due to her offering to volunteer to help with grant writing and creative writing projects the city might need help with.

  • The plaintiff now makes no extra money writing and creating. She has been forced to go further onto government assistance and now receives SNAP allotments and medicaid.

  • Friends and family have had to assist in paying utilities for the last several months.

• LOSS OF VOLUNTEER ACTIVITY Plaintiff has spent most of her adult life volunteering. Her illness has flare ups which make scheduling a challenge or the ability to commit to deadlines. The plaintiff believes in giving back to her community, and did not want her disability to make her feel like she contributes less than others. It has been a large part of her healing and mental health care to do for others.

While the plaintiff is not saying that any volunteer position has been purposely lost. The plaintiff had quit her previous volunteer positions prior to moving to West Frankfort. The first thing she did on arrival to West Frankfort, was to offer to help the city and the police department.

There is no animosity that the city chose to not accept her offer. However, due to ongoing battles to save her life and home by attempting to go to court for solutions - the plaintiff has been unable to commit her time to other volunteer projects that others have reached out to her for help.

• The plaintiff now does not do any volunteer writing projects, as all time is focused on saving her life and home.

  • The plaintiff volunteered for several years writing memorial articles for every law enforcement officer in the US who died in the line of duty.

  • By volunteering for many years for law enforcement, the plaintiff was gifted her service dog, a trained German Shepherd. Jonathan Stanley - who verbally stated to the plaintiff that his threats were directly related to Tim Arview and Thad Snell - threatened to kill the plaintiff’s service dog.

• POSSIBLE LOSS OF FUTURE INCOME: Plaintiff has three non-fiction books she has worked on over the past 5 years. She had hope of settling into her new home and working on finishing these books. The plaintiff has been belittled, targeted, harassed, and devalued - publicly. The plaintiff has lost the ability to work on these books, but also her reputation as a writer has been impacted. Tim Arview has publicly bashed and belittled the plaintiff in public forums online and used his position to imply negative associations to her work.

• LOSS OF MARKET VALUE OF HOME. An MLS analysis (Ex. B-11) show a $27,500 decline in the home’s resale value directly attributable to (a) the illegal encroachment and (b) the adjacent nuisance structure the City refuses to abate. Lost equity is a classic RICO injury. See Med. Marijuana, Inc. v. Horn, 145 S. Ct. 931, 936 (2025) (recognizing property-value diminution as cognizable).
  
  

• Loss of use and enjoyment (“constructive imprisonment”). Because Robert Stanley’s structure trespasses within inches of Plaintiff’s wall—violating fire-setback and egress codes—the house no longer meets minimum safety standards for insurance or resale.

The plaintiff is at further risk for fire, while the tenants in Robert Stanley’s building may not escape a fire as most all windows are not “escapable” with the majority glass-blocked shut. The city council voted in May 2025, after receiving a complaint of a new tenant in the illegal building, that Robert Stanley (and all landlords) do not have to pass safety inspections for a non-owner occupancy certificate as long as they tell them that it's a relative. (Video available in discovery)

Plaintiff is effectively imprisoned by seclusion and intrusion — trapped in her own home by an illegal structure trespassing within inches of her wall, and by repeated acts of retaliation, surveillance, and threat. She cannot safely leave her property, work outside the home, or seek medical care without risking further harassment, vandalism, or arrest. The structure violates fire egress and setback codes, and the City’s refusal to enforce those laws has made her home legally unsellable and uninsurable.

This is not just constructive eviction — it is constructive imprisonment, imposed through the abuse of public authority and coordination with a private landlord. This satisfies both the “business or property” injury under RICO, and the deprivation of liberty and property under the Fourteenth Amendment.

The Plaintiff fears she cannot safely leave for any reason, including medical care without fearing demolition threats, trespass, or another break-in (Exhibit B lines 8/20/24, 5/18/25). Courts treat the loss of real-property use as an injury to property under § 1964(c). See Stachon v. United Consumers Club, 229 F.3d 673, 676 (7th Cir. 2000).

The plaintiff has been physically and psychologically attacked inside her home, outside her home and endured threats from city officials to demolish her home. This abuse targeted at the plaintiff, a disabled widow, has cost her all sense of safety and left without the ability to sell her home and leave because the landlord is trespassing on her lot. She is effectively imprisoned by fear caused by the city’s actions and inactions.

• Unjust enrichment to a protected business. Allows one business to profit under protection of city officials in order to cause harm and abuse to another resident. Robert Stanley collects rent every month on a square-footage that physically occupies Plaintiff’s lot. That unlawful rental income is “business property” obtained by racketeering acts and supports the injury prong. Cf. Humphrey v. GlaxoSmithKline PLC, 905 F.3d 694, 706 (3d Cir. 2018) (lost economic opportunity counts as property injury).

  • The plaintiff’s business is not an LLC, but it is a sole proprietorship — and I am actively developing long-term works including non-fiction books, articles, and a newsletter with measurable future economic potential. My ability to work has been crippled by the defendants’ actions, and I ask the Court to recognize that self-employment is a business entitled to the same protection under civil RICO and due process.

Taken together, loss of business income and loss of property value, these losses far exceed the $5,000 jurisdictional floor, are concrete and quantifiable, and flow directly from the predicate acts detailed in Exhibit A.

D. Count 16 (Illinois Hate Crime – non-intimidation bases)

Ex A, 5/18/25 entry documents assault and threat of killing a service dog motivated by

Plaintiff’s disability advocacy. Those acts satisfy 720 ILCS 5/12-7.1(a)(1) (battery) and

(a)(6) (trespass). The Court already held intimidation plausible; the added acts complete

the statutory list.

Acts Meet and Exceed Hate Crime Statutes

The coordinated campaign by municipal actors—including Mayor Arview, Code Officer Snell, and landlord Robert Stanley—targeted Plaintiff, a known disabled woman, with a sustained pattern of threats, harassment, retaliation, and physical harm. This conduct falls squarely under 18 U.S.C. § 249(a)(2), which prohibits willful acts of violence or attempted violence based on a person’s actual or perceived disability or gender. Plaintiff was publicly identified as disabled through court filings and ADA accommodation requests known to all defendants. She was then subjected to stalking, retaliatory enforcement, selective obstruction of public services, and threats against her registered service animal, including an explicit death threat (Ex A, 5/18/25). These actions, particularly when committed under color of law by public officials, constitute willful harm and intimidation on the basis of federally protected characteristics. Federal jurisdiction is further supported by the use of interstate communications, coordinated retaliation following protected ADA activity, and the involvement of city actors operating under the cloak of official authority.

Additionally, these same acts violate 720 ILCS 5/12-7.1(a)(1) and (a)(6) under Illinois hate crime law, which includes battery and criminal trespass motivated by a victim’s protected status. But more critically, the totality of defendants’ actions—including coordinated harassment across multiple departments, malicious legal filings, and enabling of a known nuisance property that resulted in physical assault—demonstrate an intentional, sustained pattern of discrimination targeting Plaintiff’s disability, gender, widowhood, and social isolation. These facts strengthen the federal claims brought under both § 249 and 42 U.S.C. § 1983, as well as the broader pattern of racketeering activity and civil rights conspiracy alleged in the RICO count.

E. Pro-Se Leniency and IFP Context

Plaintiff believed, in good faith, that the Federal Rules required only notice pleading

and that voluminous evidence would be exchanged in discovery. She now understands

the Court’s heightened screening under 28 U.S.C. § 1915(e). Consistent with Donald v.

Cook County Sheriff’s Dept., 95 F.3d 548, 555 (7th Cir. 1996), dismissal with prejudice is

premature where a pro se litigant can cure by simple clarification.

The Discriminatory Impact of Heightened IFP Scrutiny

Plaintiff respectfully submits that the heightened evidentiary burden placed on IFP litigants creates a discriminatory two-tier justice system. While wealthy plaintiffs need only plead facts sufficient to state a plausible claim under Twombly/Iqbal, poor plaintiffs face immediate demands for concrete proof under § 1915(e) scrutiny. This disparity is particularly harsh for disabled pro se litigants who lack resources for attorneys, investigators, or litigation support. Plaintiff—a disabled widow surviving on Social Security—has spent months gathering FOIA documents, organizing evidence, and learning federal procedure while battling serious health conditions and ongoing harassment.

To demand more proof from her than from a represented party, simply because poverty forced her to seek IFP status, violates the fundamental promise of equal justice under law. The courthouse doors should not open wider for those who can afford to pay filing fees. Plaintiff has demonstrated extraordinary diligence in documenting her claims with authenticated evidence that many counseled parties would not provide until discovery.

The Plaintiff respectfully asks this Court to recognize that she has far exceeded what Twombly/Iqbal requires of any plaintiff, rich or poor, and that further dismissal based on her economic status would perpetuate the very injustice the federal courts exist to remedy. The evidence attached herein—gathered despite disability, poverty, and active retaliation—proves these claims are not merely plausible but demonstrably true. And, as true - do demonstrate a RICO enterprise and do demonstrate that criminal acts and obstruction have occurred and it does demonstrate that harm financial, business, property, are harmed as well as physical and psychological injury.

V. ALTERNATIVE REQUEST FOR LEAVE TO AMEND

Should the Court decline to reinstate Counts 13-16 based on the existing record, Plaintiff

respectfully moves under Rule 15(a)(2) for leave to file a Second Amended Complaint

incorporating this filing and all attached exhibits. Alternatively, the Court could allow this as a supplemental motion to deliver evidence to the court for judicial efficiency. If unable to incorporate the filing as a supplemental, Leave should be “freely” granted at this early stage. Runnion v. Girl Scouts of Greater Chicago, 786 F.3d 510, 519 (7th Cir. 2015).

VI. CONCLUSION

Wherefore Plaintiff respectfully requests that the Court reconsider its dismissal of Counts 11–14. The attached Exhibits clarify the predicate acts, show clear enterprise coordination between municipal and private actors, and supply public records that were previously described but not appended. No new claims are introduced; rather, this filing merely ensures that the Court has a complete and accurate view of the record before final judgment.

For the foregoing reasons, Plaintiff asks the Court to:

1. Vacate the dismissal of Counts 13, 14, 15, and the non-intimidation portion of Count 16;

2. Direct Defendants to answer those counts within 14 days;

or, in the alternative

Recognize that unified legal defense and public funding for individual-capacity acts constitutes further circumstantial evidence of enterprise coordination and Monell liability.

3. Grant Plaintiff leave to file a Second Amended Complaint that incorporates Exhibit A

and identifies supporting documents in Exhibit B; and

4. Grant such other relief as justice requires.

Respectfully submitted,

____________________________

Tina Rose, Pro Se

Dated: July 11, 2025

Certificate of Service

I, Tina Rose, certify that on this 11th day of July 2025, I served a true and correct copy of the attached document, including all exhibits, via email to the following parties:

Keith Hill, Attorney for Defendants

Respectfully,

Tina Rose

Declaration of Authenticity of Exhibits
Pursuant to 28 U.S.C. § 1746

I, Tina Rose, also known as Lenore T. Rose, declare under penalty of perjury that the documents attached and labeled as Exhibits A, B, and C in this filing are true and correct to the best of my knowledge. These documents consist of city records, FOIA responses, public meeting transcripts, photographs, communications, and other official materials obtained directly from governmental sources or created contemporaneously by me in the course of the events described.

This declaration is submitted to authenticate the exhibits as genuine, accurate, and materially relevant to the claims asserted in the accompanying filing.

Executed on this 11th day of July, 2025.

Signature: __________________________
Tina Rose Plaintiff
Pro se

Exhibit A - Affidavit with details …………………………….…page 16

Exhibit B - Chart of Predicate Acts……………………………page 24

Exhibit C - Documents proving predicate acts ………………page 27

Exhibit D - Evidence Code Office has no qualifications…..

EXHIBIT A Plaintiff’s Affidavit

I, Tina Rose, present the following information as an affidavit and swear, under penalty of perjury that it is correct to the best that I know. I have collected city documents to support what I state here. The information here is not meant to be exhaustive, but declarative of the extent of harm and deliver evidence to the court needed to verify the amended complaint, or other information needed by the court for this case.

Respectfully,

/s/ Tina Rose 7/8/2025

BACKGROUND

● 2016 – 2024: Neglect and Setup In 2016, the City of West Frankfort issued an abatement order for a drug-infested nuisance property near Plaintiff’s home.

• In the reply given by the defendants, a statement implied that the plaintiff was asking for other homes to be demolished. It seemed to imply that the plaintiff was asking for something extraordinary and to cause harm to others - both homes which the plaintiff had asked the city to remove were causing harm to the neighborhood, creating reckless endangerment to all surrounding properties and the key thing – were already ordered to be abated and the city failed to follow its own orders, municipal code, or enforce any safety for surrounding residents. .See exhibit A-C

• For eight years , The city of West Frankfort refused to enforce their own orders and laws and had knowledge that both properties were dangerous and that one property at 406 N Bryan was a known “drug house.” See Police Report See Exhibit C.

• The owner tried to donate 406 N Bryan to the city for demolition on a number of occasions and even with the dangers to surrounding residents and the building being used for the distribution of drugs the city chose to take no action and not accept the property for demolition. See Code Officer Reports

• No demolition occurred for either property, no safety codes were enforced, and the structures remained a documented hazard.

• The plaintiff was not the only neighbor filing complaints on both properties which includes 406 N Bryan Street and 1109 (with 1109 ½) E Lindell Street.

  • 406 N Bryan Street was half dilapidated and the plaintiff noted foot traffic of 20-30 visitors per day.

  • 1109 has been boarded for nearly 15 years, is dilapidated, and an extreme fire hazard. 1109 ½ is a garage/structure built with no permits. Originally used as a residential business, now converted to residence against zoning and city ordinances. The unpermitted structure encroaches and trespasses on the plaintiff’s property as well as city property.

  • 1109 is such a hazard - even residents at 1109 ½ called complaints into the city

EXHIBIT A: AFFIDAVIT PAGE 2

• September 2023 - Plaintiff called city of West Frankfort Code Officer Thad Snell and spoke about the lot at 1109 E Lindell and 406 N Bryan. Both dilapidated, Thad Snell stated these buildings were already on list to be torn down spring 2024.

• October 2023 - Again, plaintiff called Thad Snell and asked about the buildings and Thad Snell assured her the city was moving forward and cleaning up this very neighborhood and these homes were already ordered down. He did state I should be a squeaky wheel and help ensure the project moves to top of the list.

• November 2023 - Purchased 403 N Bryan.

• December 2023 - Plaintiff discovers someone is living in the garage at 1109 E Lindell. The tenant, Lauren Hawkins, (1109 ½) also called and complained of the hazards at 1109. The plaintiff made complaints about the amount of foot traffic going in and out of 406 N Bryan and about the fire hazard of 1109 ½ to the code officer.

• May 2024 - The plaintiff went to the city council meeting and gave a speech about how blight impacts her neighborhood and increases the dangers to all persons. Plaintiff formally asked for help, asked for a safe neighborhood and gave evidence from studies that showed neglecting this would cause harm.

OBSTRUCTION AND VIOLENCE BEGIN

This case does not arise from a singular dispute. It arises from a sustained, escalating pattern of retaliation, obstruction, and threats directed at a disabled resident after she attempted to seek lawful remedies from her municipal government. The following timeline sets forth the coordinated chain of events

June 2024 - Plaintiff continues to speak at city council meetings and meets with city officials privately. Ralph Hill attended this meeting.

The plaintiff was approved to put up a fence by the city council. She saved for months and had volunteers to come help her install the fence.

Once the plaintiff used paint to mark off the fence and had her construction supplies delivered, everything changed.

August 2024 - The tenant in 1109 ½ E Lindell, Lauren Hawkins began to relentlessly call the police every time the plaintiff walked outside with her dog. Lauren Hawkins began opening the back window of the building which is trespassing in the plaintiff’s yard - to scream at her and tell her to “Go back inside her house.” See police reports in Exhibit C

EXHIBIT A: AFFIDAVIT PAGE 3

● On August 16, 2024 , a violent home invasion occurred. The assailant, Samuel Williams, used the long-neglected structure that every neighbor had begged to be addressed for cover. Samuel Williams was staying in the building at 406 N Bryan St where the city had ordered it torn down in 2016. Samuel Williams crossed the street and committed a violent home invasion.The plaintiff was physically assaulted in her kitchen. This incident forms the first direct injury and is the predictable result of the City’s years-long dereliction. The result of leaving such buildings without abatement leading to violent crime was told to the city council and officials in May 2024, when the plaintiff begged for help. This incident forms the first direct injury and is the predictable result of the City’s years-long dereliction.

Video available in discovery. Police Reports below in Exhibit C.

August 20, 2024: Retaliation in City Hall

● The plaintiff was summoned to a meeting under the pretense of receiving assistance after the assault. Instead, Thad Snell threatened demolition of Plaintiff’s own home , citing a front-yard easement issue known to be inapplicable (the home is a 1905 grandfathered structure). He threatened her over mere inches, yet refused to address the 12 foot easement issue on Robert Stanley’s residence. Not notice was ever made he attempted to measure it on Robert Stanley’s residence and Robert Stanley testified in (2025OP Franklin County Circuit Court).

● Mayor Tim Arview and Clerk Andrea Bolen witnessed the threat and took no corrective action. This moment marks the first instance of coordinated, in-person retaliation by city officials—retaliation made in the presence of the very individuals now named in this suit.

August 27, 2024: Evidence of Coordination a Week After Threat by City Official: The plaintiff was subject and witness to multiple instances where coordination between actors was present.

• Police were called to the plaintiff’s residence because the tenant, Lauren Hawkins, had trespassed onto her property, snuck up behind the plaintiff and sprayed her with bed bug spray.

  • The West Frankfort Police Department - Deputy Chief Clint Willis apologized later that the police report from the chemical battery above - was altered by his department. Every time the word “assault” was in the written statement by the plaintiff, the typed version by the department - that word was changed to “adult.”

  • The West Frankfort Police Department - Deputy Chief Clint Willis apologized later that the police report was never sent to the state’s attorney’s office for prosecution.

EXHIBIT A: AFFIDAVIT PAGE 4

• The Plaintiff attended the city council meeting at 6:00 PM at city hall. Video available for full meeting.

  • Robert Stanley, his tenant Lauren Hawkins and the elderly neighbors Donna and William Green all attended the city council meeting.

  • Robert Stanley flatly tells the city council that he “knows his building is out of code” but asked for the city to take easement out of the plaintiff’s property.

  • Robert Stanley attempted to make it appear that my fence was causing the fire hazard and that his tenant could not escape in a fire - never does he say all the windows are not escapable and most are glass blocked shut.

  • City council members begin to gaslight and intimidate the plaintiff with comments that it is “neighborly” for the plaintiff to give away her yard to the one breaking the law.

  • Thad Snell is heard on the video telling the city council and mayor that he would look for and find some safety regulation to help Robert Stanley.

  • Lauren Hawkins and the Greens followed with commentary about how terrible a neighbor the plaintiff is, in an effort to convince the city council to take easement from the plaintiff’s yard.

  • At no point does any city official address that Robert Stanley stated clearly he knows his building is out of code.

  • At the end of the meeting, before the city cut off the cameras and audio, Robert Stanley threatened to use his trespassing structure to cause harm to the plaintiff.

• August 29, 2024 - Tenant. Lauren Hawkins placed a tablet in the window and began 24 hour - 7 day a week surveillance and electronic eavesdropping on the plaintiff’s property.

  • The plaintiff called police, began constructing an attachment to her fence to hang a curtain or some other item to block the direct recording.

  • While the plaintiff was hanging the curtain, tenant Lauren Hawkins assaulted physically the plaintiff hitting her hand. The tenant’s boyfriend then launched a fence post towards the plaintiff attempting to strike her foot.

  • Officers from the West Frankfort Police Department took a report. The plaintiff gave a written report. The West Frankfort Police Department in process, again changed every word of the plaintiff’s written complaint “assault” to “adult” and again the department did not send this report to the state’s attorney office for prosecution. This is the second time, different officers, different day but same result. This shows protection to the property of Robert Stanley, and through this his tenant Lauren Hawkins is also protected.

• Stalking through video surveillance and electronic eavesdropping over the top of the plaintiffs fence and pointed at the windows of her home continued until the tenant moved and was out May 1, 2025.

EXHIBIT A: AFFIDAVIT PAGE 5

OBSTRUCTION TO SAFETY, CODE ENFORCEMENT, ZONING REVIEW BOARD

The plaintiff was not being helped by the code officer or city council. According to the municipal code, when there is a disagreement a resident can request an independent review by the zoning board. The Plaintiff is the only resident of West Frankfort per FOIA who has ever been refused access to the zoning board. The plaintiff began asking to go to the zoning board in July 2024.

The plaintiff received harassment from Tim Arview regarding this request. Tim Arview demanded that I “cite the code” for every thing wrong with the building in my yard and if I could not “cite the code” I would not be allowed to go before the board.

Tim Arview harassed the plaintiff in public forums on Facebook also demanding her to “cite the code.”

In December 2024 and January 2025, the plaintiff reached out to the Illinois Public Access Counselor’s office in Chicago and asked for help to go to the zoning board meetings and to stop the obstruction to access safety measures.

February 2025, during the first few days of February, the Public Access Counselor’s office sent an email and stated that the city had to make zoning board meetings publicly available and they could not block the plaintiff from attending or speaking. This statement from a higher office to no longer obstruct the plaintiff from the zoning board was followed by what appears to be criminal conduct by city officials against the plaintiff to prevent her further access to the zoning board.

February 10–18, 2025: Zoning Sabotage & False Arrest Plot

● Plaintiff called the City from home on Monday February 10, 2025 while waiting for furnace installers and was told the zoning board would meet on February 18 . She intended to present evidence regarding the encroachment and safety violations tied to Robert Stanley's property.

● On February 14 , Plaintiff requested a copy of the zoning agenda. Mayor Arview refused to email it, demanding she come in person. ● While Plaintiff waited quietly at City Hall that day, Mayor Arview became hostile and threatening . Plaintiff disengaged and left.

February 10–18, 2025: Zoning Sabotage & False Arrest Plot

• Plaintiff called the City and was told the zoning board would meet on February 18. She intended to present evidence regarding the encroachment and safety violations tied to Robert Stanley's property.

• On February 14, Plaintiff requested a copy of the zoning agenda. Mayor Arview refused to email it, demanding she come in person.

• While Plaintiff waited quietly at City Hall that day, Mayor Arview became hostile and threatening. Plaintiff disengaged and left.

EXHIBIT A: AFFIDAVIT PAGE 6

• Moments later, Clerk Andrea Bolen, who was off duty, called Deputy Chief Clint Willis and falsely reported that Plaintiff was “terrorizing” the Mayor.

• Willis, also off duty, called 911, dispatching police units. Body cam footage later confirmed that Plaintiff had already left, and Arview was red-faced and laughing upon their arrival.

This was a coordinated, deliberate false-arrest setup, clearly timed to interfere with Plaintiff’s upcoming zoning-board appearance.

• On February 17, FOIA emails confirmed that Mayor Arview directed City staff and zoning board members to ignore Plaintiff and not engage with her issue.

• On February 18, at the zoning board meeting, Plaintiff attempted to speak. Arview publicly shouted “She’s a whistleblower!” several times, drowning her out. Zoning board members refused to hear her or review evidence.

This meeting represents a direct denial of civic participation and public humiliation intended to intimidate and silence.

February 20, 2025: False Filing and Judicial Abuse

• Mayor Arview filed a petition for a No-Contact Stalking Order (NCSO) against Plaintiff, relying on false statements. This included false statements about the phone call placed on 2/10/2025 and the events in city hall on 2/14/2025. He used his title and position to convince the Franklin County Circuit Court that his signed statement was true.

March 2025: Plaintiff forced to find a friend to assist in paying her water bill. She was blocked by a falsely obtained document by Tim Arview from going into a public building and paying her water bill.

April 10, 2025: Arview Admits On Stand He “Thought it up.”

• In court, Arview admitted under oath that he had fabricated the allegations, stating he “made it up.”

• The petition was revoked. However, its purpose had already succeeded: to bar Plaintiff from City Hall and public services in retaliation for seeking zoning relief.

• Tim Arview used the falsified petition for protection to block the plaintiff from accessing the zoning board.

EXHIBIT A: AFFIDAVIT PAGE 7

May 2025: Federal Filing Triggers Witness Intimidation

• On May 5, 2025, all Defendants and their counsel received service of the federal complaint via email. Formal Marshal service was May 21, 2025.

• On May 9, 2025, plaintiff informed the city about the new tenant moving into the building that is still trespassing and has no non owner occupancy permit as it is unsafe. No answer was given until the city council meeting on May 27, 2025.

• On May 18, 2025, at 5:30 a.m., Jonathan Stanley—a known associate and family member of Robert Stanley—arrived outside the plaintiff’s residence. Jonathan Stanley - a stranger to the plaintiff began yelling at her about her court cases and Tim Arview and Thad Snell. Jonathan Stanley followed with multiple explicit death threats against Plaintiff and her service dog.

• This threat was reported and documented. It occurred 13 days after electronic service of this case and twelve days before a mediation status hearing was scheduled in the Franklin County Circuit Court—a clear, timed act of witness intimidation that supports Plaintiff’s RICO and § 1985(2) claims.

May 27, 2025: Legislative Retaliation on Video

• In full view of the public, Mayor Arview, Thad Snell, City Attorney Cantrell, Clerk Bolen, and several others voted to amend city rental ordinances.

• The amendment created a new exemption allowing landlords to avoid safety inspections and licensing if they claim to rent to “relatives.”

• This exemption directly benefits Robert Stanley, whose structure is the subject of multiple safety and zoning violations—and an active lawsuit.

• This vote, taken during federal litigation, is strong evidence of a coordinated legislative act to shield a defendant and punish a whistleblower.

These events—starting with the City’s refusal to abate a known hazard, escalating through threats, entrapment, humiliation, false legal filings, and finally coordinated threats of violence—form an uninterrupted sequence of abuse. Each event was:

• Retaliatory for protected activity;

• Coordinated among the same core officials;

• Escalating in scope, from civil to physical to legislative obstruction;

• And corroborated by public records, video, emails, sworn testimony, and police reports.

EXHIBIT A: AFFIDAVIT PAGE 8

This chronology shows a pattern of enterprise behavior, not mere misconduct. It satisfies multiple predicate acts under 18 U.S.C. § 1961(1) including:

• Witness intimidation

• Obstruction of justice

• Retaliation under color of law

• Use of false public filings

• Legislative manipulation for concealment

Signature

I, Tina Rose, swear that the above 8 pages of this affidavit are true to the best of my knowledge and ability under penalty of perjury. I sign this giving this statement as testimony of what I know to be the facts of this case.

_________________________________ 7-11-2025

Tina Rose Date

Exhibit B Chronology of Predicate Acts, Enterprise Conduct, and Supporting Evidence

This is an abbreviated list of predicate acts from Exhibit A and referencing which predicate act statute would apply. The “Evidence Ref” column on the far right gives details of the evidential documents organized under Exhibit C. A page number is provided to make reference easier. The documents provided are actual emails, FOIA responses, city documents and police reports. Some images are provided. Any video listed will be provided during discovery and can be delivered to the court earlier if requested. A link is provided for any publicly posted videos that are posted as official business on the Facebook publication page for the City of West Frankfort.

#

Date

Actor(s)

Act / Predicate Statute

Injury to Plaintiff

Evidence Ref. (Ex. C)

1

2016 - 2024

Snell & City

Eight-year refusal to enforce 2016 demolition order → pattern of official neglect (18 U.S.C. § 1503 obstruction)

Unsafe home - ordered abated 2016, drug house used in assault

C-1 thru C-3

2

08-16-24

Assailant aided by city neglect

Home invasion & battery (§ 1512(b) witness intimidation)

Physical injuries, PTSD, exacerbated illness.

C-4 Police Report.

3

08-20-24

Snell, Arview,

Bolen

Threat to demolish Plaintiff’s home after assault → retaliation under color of law (§ 1512)

Emotional distress, property threat

Plan to subpoena all attendees including Attorney Kate Renick who was present.

4

8-27-24

Snell, Arview, City Council members, R. Stanley, and Hawkins

Chemical battery (Hawkins),

Threats, intimidation, retaliation (R. Stanley), coordinated abuse under color of law by all city actors.

Physical injuries, PTSD, intimidation, official misconduct

Full video available in discovery.

Link to city page with video.

5

9-2024 to present

Arview, City Council, Cantrell

Complete denial of access to zoning board review, including harassment, intimidation under color of law.

Property damage, distress, property threat

Video of several requests. Emails, FB posts by Arview.

5

02-14-25

Arview, Bolen, Willis

False 911 call / entrapment; wire fraud & obstruction (§§ 1343, 1503)

Fear of arrest, chilled speech, abuse of power, official misconduct, felony intimidation.

Police report,

Emails, FOIA responses. C-5 thru C-12 Video from 3 angles in city hall - police body cam video will be available for discovery. Images provided for context.

6

02-17-25

Arview

E-mail gag order to zoning board (wire fraud, § 1343)

Denied zoning access

C-9: FOIA emails

7

02-18-25

Arview, Zoning Board

Public shouting “She’s a whistle-blower” to drown testimony (witness intimidation § 1512)

ADA/access violation

Awaiting FOIA response with full recording

8

02-20-25

Arview, Cantrell

False stalking petition → perjury & obstruction (§§ 1621, 1503, witness intimidation § 1512)

Banned from City Hall

Court Docket

C-10 a typed verbatim of written statement. Full copy available 2025OP56.

9

05-03-25

All Defs. served

Service of this lawsuit (context for subsequent acts)

—

Proof of service C-13

10

05-09-2025

Snell, Arview, Cantrell

city knowingly fails to perform a duty (like enforcing zoning or safety code) to help Stanley profit — this is a criminal violation of Illinois law that also qualifies under RICO via § 1961(1)(A) incorporation of state crimes.

Reckless endangerment, fear, living with fire risk, property devaluation.

Email c-14 that the plaintiff informed that one tenant moved out illegal structure and another moved in.

10

05-18-25

Jonathan Stanley (invoking Arview & Snell)

5:30 a.m. death threat re litigation (§ 1512(b))

Severe PTSD, dog safety

C-15: Police incident report. Testimony given under oath 2025OP175 - Admits threats

11

05-27-25

City Council, Cantrell, Arview

Ordinance change creating inspection loophole to shield Robert Stanley (mail/wire fraud scheme § 1341)

Continuation of nuisance next door

Ordinance video; full video will be provided, and minutes of meeting.

12

Continuous

Unified defense counsel

Joint-representation obstruction (predicate § 1503) Obstruction of Justice – 18 U.S.C. § 1503
Conspiracy to Obstruct Justice – 18 U.S.C. § 371
Wire Fraud – 18 U.S.C. § 1343

Discovery impairment

C-16 dockets from state court Hill reps all defendants and City, Tim Arview, and Thad Snell in federal court.

13

Ongoing

WFPD

Altered police reports (“assault”→“adult”) (§ 1519)

Loss of evidence

Will provide at discovery

Notation: Each “B-” tag corresponds to a document, video clip, or sworn statement placed in Exhibit B.

Exhibit C-1 Referencing line B-1 - Evidence of multi-year pattern of official neglect. Refusal to enforce its own orders, and leaving the plaintiff and community at large in danger.

• 406 N Bryan was known to be dangerous as early as 2013.

Exhibit C-1 page 2 Referencing line B-1 This is page 2 of document above.

Exhibit C-2 Referencing line B-1 in chart. This document shows the address of 406 N Bryan Street was ordered abated in 2016.

• Defendant's counsel’s filing insinuated the plaintiff was angry because she asked to tear down two homes and the code officer threatened her home - the homes she was asking to be torn down were both ordered down years prior.

• Threatening a homeowner in retaliation for asking for safety is a felony in Illinois but no police officer will prevent the code officer from breaking the law.

Exhibit C - 3 Referencing line B-1 This document shows Thad Snell, City of West Frankfort Code Officer, refusing the homeowner’s request to donate the home to the city for removal. It also shows Thad Snell knew squatters were in the building and he never reported it to police. FOIA records show no police report made. Thad Snell ignores all neighbors begging for safety and cites the home for grass.

• Complaint made 11/23 by Jamie Pruett, showing multiple neighbors complained other than Tina Rose.

• Shows 2/22/24 Owner of property attempted to donate to city for abatement to stop the drugs and danger - city and code officer refused.

• Shows 3/18/24 - Code officer and fire department responded to squatters burning garbage - shows only a verbal warning, no report made to police department.

• Shows 9/11/24 - Code officer again writes that owner will donate for demolition - only after Tina Rose was beaten and injured

Exhibit C-4 Referencing line B-2. Police Reports from home invasion committed by Samuel Williams who was staying at 406 N Bryan. After beating the plaintiff in her kitchen, the West Frankfort Police Department had a standoff outside 406 N Bryan. Williams is incarcerated and was found guilty.

Exhibit C-4 Page 2 Referencing Line B-2

Exhibit C- 4 Page 3 Police report continued.

Exhibit C-5 Referencing B-5 - This exhibit shows something essential. This is the police call made that states that Tina Rose was terrorizing Tim Arview at City Hall.

• Call placed by Deputy Chief Clint Willis who was NOT at or near city hall.

• Call placed by officer who was off work on 2/14/2025 at time of call.

EXHIBIT C-5 PAGE 2

EXHIBIT C 6 Referencing B-5 Who from city hall called Deputy Chief Willis? If Deputy Chief Willis was not present at city hall and he called the police report into the police station - question is - who called deputy chief Clint Willis. The answer is City Clerk Andrea Bolen - who also was off work and not present at city hall.

Exhibit C 7 Referencing B-5. This shows that City Clerk Andrea Bolen called Deputy Chief Clint Willis on her day off. She states she was not present in city hall on 2/14/2025.

So - how would Andrea Bolen know to call Deputy Chief Willis? She was nearly five miles away from City Hall. Someone told her that Tina Rose was at city hall because Tina Rose had no appointment and was only inside city hall for ten minutes. Security footage shows Tina Rose was sitting quietly the entire time. Someone called Andrea Bolen and this may be found in witness testimony. It also shows the ethical issue of Keith Hill representing the city, Tim Arview, Andrea Bolen, Thad Snell and Jonathan Cantrell. Each will need to testify against the other.

Exhibit C -7 page 2

Exhibit C-8 IMAGE This image was taken from police body cam footage. It shows that when the police rushed to city hall over reports of “terrorizing” that they found Tim Arview, red faced, embarrassed, and laughing. Full video of both body cams from West Frankfort Police Department will be available for Discovery. Full video of city hall security cameras from three different angles will also be available for discovery. All three angles show the plaintiff sitting and Tim Arview standing over her threatening her. The opposite of what was reported to police.

Full video of security cameras in city hall are available. The city would not release any audio with these videos. The plaintiff believes a subpoena during discovery will allow the audio to be on these security cameras in court and if recording is present, it will further show the extent these officials will go to in a coordinated fashion.

The plaintiff has footage for her entire presence in city hall on 2/14/2025. The only act that occurred was when Tim Arview threatened Tina Rose that he would demolish her home. There are movements indicative after Tina Rose leaves showing coordination and officials laughing in the background because their scheme did not work.

The plaintiff has body cam footage from two officers showing Tim Arview laughing and red faced and under no form of duress. The footage will be made available during discovery or prior, as the plaintiff determines the correct form to deliver video files to the court.

Exhibit C-9 On February 17, 2025 Tim Arview sent this email to prevent the zoning board from addressing any issues presented by Tina Rose on February 18, 2025.

Exhibit C-10 The verbatim statement handwritten on the no stalking contact order (OP) filed by Tim Arview. I, Tina Rose, declare this to be a verbatim typed copy for the court, and will provide original in discovery. /s/ Tina Rose

“I am requesting a Stalking No Contact Order because on or about February 10, 2025 at 9:30 am.

The following occurred: Ms Rose claimed on Facebook that I’m never in the office. Yet, On Monday, February 10, I arrived at 9:15 a.m., and she called at 9:30 a.m. While not proof, it seemed she knew I’d be there, making me believe she saw me leave my house. She called about a neighbor’s alleged code violation, but our codes officer had already deemed it unfeasible. I explained she had no adverse action against her, so the zoning board had nothing specific for her. I advised her to speak during public comments. She became loud and aggressive, so I ended the call. I felt threatened and later had a mild anxiety attack.

On or about February 14, 2025, 11:15, at my workplace the following occurred: Ms. Rose came to City Hall for a zoning board agenda and saw she wasn’t on it. I reiterated she could speak during public comments. She argued about needing to be on the agenda, and I told her those concerns were best for the meeting. She kept pressuring me, accusing me of a hate crime due to her age and disability. I referenced her Facebook posts attacking me, my family, and our codes officer. She dismissed it as speculation. Her tone and interruptions made me and others uncomfortable. An employee called the police at 11:30. I ended the conversation, and she left just before officers arrived. They later advised me to get a restraining order.”

Exhibit C-10a

The plaintiff asserts that during the hearing of this action 2025OP56 in the Franklin County Circuit Court that Tim Arview admitted under oath that he thought it up.

Full transcript can be provided during discovery.

Exhibit C-11 Email from Crosswalk Community Action Center regarding Tim Arview’s claim made in court that the plaintiff was outside his home or followed him to work on the morning of 2/20/2025.

Exhibit C-12 Images taken from City Hall security cameras.

Image of Tim Arview threatening Tina Rose he will come after her and demolish her home. Plaintiff believes a subpoena from the court for the full video that includes all audio recorded - that this will be more evident. Currently she has footage from three angles.

Exhibit C-12 page 2 Images of February 14 interaction at city hall.

After the plaintiff leaves the building, Tim Arview runs around city hall oddly, then lifts his arms like “where are they?” before the police arrive. The official he is speaking with is laughing at him.

C12 page 3

Here, Arview is talking with officers. The officials in the background are all laughing. Laughing in itself is not criminal, but here the context of the video is hard to show in a single image. The plaintiff will bring all video, three angles of security footage showing the ENTIRE time she is present at city hall. Subpoena may get the audio. Plaintiff also has copies of both police body cam videos.

C-13 PROOF OF E- SERVICE OF FEDERAL COMPLAINT 25-CV-845-JPG

Exhibit C14 Email showing the city is informed about the new tenant and questioned how a new tenant is being permitted with the building as a trespass and also in midst of court issues. Also why is it occupied if the building cannot pass state required inspections to get a non-owner-occupancy certificate, which it cannot pass to obtain.

C-15 Police Reports from FOIA showing death threats before 7am outside the plaintiff’s back door. Jonathan Stanley began by yelling about Tim Arview and Thad Snell. However he is a cousin of Robert Stanley and was parked at Robert’s rental property. The plaintiff had never met Jonathan Stanley prior to the instant death threats.

C-15 page 2 showing additional parties at incident.

C-15 page 3 Additional Police Report of same report.

C-15 page 4 of same police report

C-15 page 5 of police reports

C-16 Dockets from State Court Keith Hill represents all conspirator defendants—Arview, Snell, and the City—in both state and federal court, despite RICO allegations involving individual criminal conduct. This creates an irreconcilable conflict of interest under Illinois Rule of Professional Conduct 1.7, as it obstructs independent defenses and discovery. In the RICO context, such coordinated legal defense is not merely unethical—it furthers the enterprise by concealing misconduct and impeding justice.

Here Keith Hill represents Thad Snell.

C-16 page 2 Keith Hill represents Andrea Bolen in state court.

C 16 page 3 Keith Hill represents Jonathan Cantrell

C-16 page 4 Keith Hill Represents Tim Arview. Due to the ethical conflict, Keith Hill cannot fully represent the city’s interest, as the best defense is that it was the officials or employees fault, He cannot fully represent Tim Arview’s interests and allow him to testify about Thad Snell while fully representing Thad Snell. He has created a circle of obstruction.

Exhibit D The following documents help support multiple areas but especially the Monell count. Thad Snell had no previous building or construction experience, was hired based on gaining certification in 6 months but to date - after four plus years, he has not obtained certification.

Exhibit D-2 Thad Snell Foia says not certified.

Exhibit D-2 page 2