Developing Updates 2:- I Erick Mango charge village-area AP, his farm-hand / son Victor and Pamela Mango with others as listed on the statement below with Criminal-Conspiracies to defeat justice and interfere with witnesses, commit misdemeanors, felonies including defilement and murder contrary to Sections 117, 393, 395, 157, 224; These charged together with "A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2), including indecent-acts / assaults as regards incestuous-and-homosexual harassments contrary to the Penal-Code CoK-2010 :- I urge the CJ in accordance with the edict in Article 10 CoK-2010 to exercise her powers under Article 161 (2) (a) as read together with provisions of the Rules of Court Section 2 (1) regarding the National Policy Guideline on the Administration of the SOA No. 3 of 2006 ; and and the Protection Against Domestic Violence Act 2015 ; and The HIV Protection and Control Act 14 of 2006.

                                                                                  

The stumbling block to my printing-out the criminal-complaints against the AP, Victor & Pamela Mango subject to the exempting Section 124 of the Evidence Act is wanting resources cause the photos-material-evidence & precedent blog testimony statement records plus the documents detailing the conspiracy jus’ needs some substantial cash. { https://startrextraterrestrials.wordpress.com/2021/08/18/lend-soft-loans-of-up-to-kshs-50000-or-jus-spare-cash-to-complete-the-drafting-and-print-out-of-my-criminal-conspiracy-and-sexual-misconducts-charges-lawsuit-to-be-repaid-with-a-50-interest-in/ { Lend soft loans of up to KShs. 50,000 { or jus’ spare cash to complete the drafting and print-out of my criminal-conspiracy and sexual assault/abuse/harassment charges lawsuit } to be repaid with a 50%-interest in one sweep once IPOA and ODPP process my Kihara Construction accident evidence-destruction/spoilation case, to replace rags, dev. eCommerce/AdSense and sustain existence: [ M-PESA 254723047863 or 254764087863 ; Equity Bank, Migori Branch, Acc. No.: 1160168298894 ]. sos

I Erick Mango charge village-area AP, his farm-hand / son Victor and Pamela Mango 

with others as listed on the statement below with Criminal-Conspiracies to defeat justice 

and interfere with witnesses, commit misdemeanors, felonies including defilement and 

murder contrary to Sections 117, 393, 395, 157, 224; These charged together with "A 

Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 Articles 162 (c), 165, 

2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2), including indecent-acts / assaults as 

regards incestuous-and-homosexual harassments contrary to the Penal-Code CoK-2010 :-
I urge the CJ in accordance with the edict in Article 10 CoK-2010 to exercise her powers
under Article 161 (2) (a) as read together with provisions of the Rules of Court Section 2 (1)
regarding the National Policy Guideline on the Administration of the SOA No. 3 of 2006 ; and
and the Protection Against Domestic Violence Act 2015 ; and The HIV Protection and Control
Act 14 of 2006.

Introduction
[1.]:- The latest turn of events has been brought forth by a conspiratorial pattern of continuous
violations of the law by the mentioned accused in the title notice-of-motion above concerning a
repeated series-of-crimes in which the most recent happened on the 5th of August 2021 for which 

I went to formally file the complaints after drafting on Saturday  the 7th August 2021 at Migori Police 

Station at a snail's pace cause of the exhausting extreme hunger-torture ritual-cycles I was still 

recovering  from; and where the Front-Desk told me to go to the crimes office who directed me to 

return on the following day  [ 8/08/2021 ] because of renovations that were taking place.

[2]:-The above was soon followed with impunity by this most recent event that occurred on 19th,
20th & 22nd August 2021 touching on the pygmy farmhand Victor briefed as harassment with
regards to stalking, pursuing and/or accosting, and sometimes while brandishing a machete
apparently under the instructions of his hire AP Police Owino; for which Pamela Mango subsequently 

retorted in asides in Luo that,"Wachadhi wate," meaning, "We're hacking you all together," echoing ex-

Chief Amara's proclamations.

[3.]:- Fast rewind to June 2012 where I was wrongfully and unlawfully arrested, detained, prosecuted, 

jailed & relocated / evicted / transported  to Migori by Uhuru’s Mombasa Municipal Council police 

conveniently-animistically called Ikenya plus Swaleh and another third one violating my rights to liberty.

Plaintiff / Complainant
Erick Mango :- Independent professional ; Analytical-theoretical researcher / Public lecturer and Private 

medical-geneticist contractor / Consultant ; French Tour Guide, Teacher, Translator ; SMM / VA ; 

Freelance science writer & blogger ; Podcaster for audio & video shows including pay-TV subscriptions ; 

Affiliate marketer ; Founder / Director : Les Misérables Activists Advocacy and Consultants ;

Defendants
[4.]:-The first defendant’s Victor the farm-hand of Administration Police of Chamkombe Kakrao ;
[5.]:-The second defendant's the Administration Police of Chamkombe-Kakrao ;
[6.]:-The third defendant's Pamela Mango ;
[7.]:-The fourth defendant's the bumper to bumper sexual-assault guy at the water kiosk ;
[8.]:-The fifth defendant's the village boiled-egg seller ;
[9.]:-The sixth defendant's the ex-Chief Amara’s herd’s boy ;
[10.]:-The seventh defendant are the KPLC Kisii neighbor, his wife, their masons and errand-boy
          / neighbor ;
[11.]:-The eighth defendant are the ex-panties seller yellow Kisii wife and his husband ;
[12.]:-The ninth defendants are two well-known touts as recorded with Safaricom then ;
[13.]:-The tenth defendant's the taxi-driver of vehicles { KCP 348F } and { KCL 749G } ;
[14.]:-The eleventh defendants are :-  {a.}:-Victor Mango ; and
                                                                {b.}:-His father Peter Mango ;

         who together with defendants {4-14.} I charge with :-

      {a.}:-Criminal-conspiracy to defeat justice and interfere with witnesses ;

      {b.}:-Criminal conspiracies to commit misdemeanors and felonies including murder ;

              all contrary to Sections 117, 157, 395, 393, 224 ; as read together with :-

      {c.}:-"A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 CoK-2010,
                   Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2),
                   including indecent-acts / assaults as regards incest and homosexual-harassments ;
[15.]:-The twelfth defendant are :-  {a.}:-OCS-1 ; and
                                                           {b.}:-OCS-2 ; who together with defendants :-   

                                                           {6.}, {14b.} and {16b.} I charge with :-

      {a.}:-Criminal-Conspiracies to defeat justice and interfere with witnesses ;

      {b.}:-Criminal-conspiracies to commit misdemeanors and felonies including murder and defilement as

                  regards sodomy contrary to Sections 117, 393, 395, 157, 224 of the Penal Code ;
                  as read together with :-

      {c.}:-"A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 CoK-2010,

                   Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2),
                   including indecent-acts / assaults as regards incest and homosexual-harassments ;

      [d.}:-Defamation contrary to the Defamation Act Cap.36 ;

[16.]:-The thirteenth defendants are {a.}:- Ex-Chief Amara (former Asst. Chief to Chief Odira) and

                                                             {b.}:- Current Chief Onyango ; both of Suna East Migori  ;
                                                             {c.}:- Ex-Chief Odira
[17.]:-The fourteenth defendants are three Mombasa Municipal Council Police including Ikenya,
          Swaleh and another all whom { i.e. defendants no. 4-17 }  I charge with :-
          {a.}:-Criminal-Conspiracies to defeat justice and interfere with witnesses ;
          {b.}:-Criminal-conspiracies to commit misdemeanors and felonies including murder and defilement as

                  regards sodomy contrary to Sections 117, 393, 395, 157, 224 of the Penal Code ;
                  as read together with :-
          {c.}:-"A Series of Sexual-Crimes" contrary to the Sexual-Offenses Act Cap.63 CoK-2010,
                   Articles 162 (c), 165, 2 (4), 23 (3) (d), 145 (1), 144 (1) (3), 5, 12, 20 (1 ) (2),
                   including indecent-acts / assaults as regards incest and homosexual-harassments
          {d.}:-Threat to life contrary to Section 223 (1) of the Penal Code ;
[18.]:- Additionally for defendants {no. 17} I charge them with :-
          {a.}:-Wrongful and unlawful arrest, detention, prosecution, jail, & bail contrary to Articles
                 29 (1) and 39 (1) ;
          While for Ikenya additionally I also charge him with :-
          {a1.}:-Threat to life contrary to Section 223 (1) of the Penal Code ;
          {a2.}:-Forced transportation to Migori ; contrary to Articles 29 (1) and 39 (1) ; plus
          {a3.}:-Witchcraft contrary to Section 2 of the Witchcraft Act Cap. 67 ;
[19.]:- The fifteenth defendants are brothers Paul Mango and Joseph Olala whom I charge with :-
            {a.}:-Threat to life contrary to Section 223 (1) of the Penal Code ; and
            {b.}:-Criminal-conspiracies to commit the felony of murder contrary to Section 224 ;
            {c.}:-Criminal-conspiracy to defeat justice and interfere with witnesses contrary to Section 117 ;
            {c.}:- Attempted human-trafficking contrary to the 'Counter-Trafficking in Persons Act' No. 8
                    of 2010 Cap. 61 CoK-2010 and the UN Convention Against Organized Crime
                    supplemented by the 'Palermo Protocol'
[20.]:-The sixteenth defendants are the alleged
            {a.}-GoK GSU on-leave of the Bell's Pub attack ;
            {b.}-His eight-or-so bouncers / attendants of Bell's Pub, and accomplices ;
            {c.}-Engineer Emmanuel Edgar Sirma ;
            {d.}-Engineer Benjamin Anambo ; who together with defendants
            {16a.}:- ex-Chief Amara and/or
            {16c.}:- ex-Chief Odira I charge with :-
              {a.}:-Criminal-conspiracies to defeat justice and interfere with witness ;
              {b.}:-Criminal conspiracy to commit misdemeanors and felonies including murder ;
                      all contrary to Sections 117, 393, 395, 224.
              {c.}:- Attempted robbery with violence contrary to Section 296 (2) CoK-2010.
[21.]:-The seventeenth defendants are Owade Advocates and Commissioner for Oaths
          who together with defendants {6.} and {14b.} I charge with :-
          {a.}:- Attempted deliberate, willful forced marriage contrary to Article 45 (2) CoK-2010
          {b.}:- Attempted deliberate, willful transmission of HIV / AIDS ;
                  contrary to the HIV Protection and Control Act 14 of 2006 Section 24 (2) ;
          {c.}:-Criminal-conspiracies to defeat justice and interfere with witnesses contrary to Section 117,
          {d.}:-Criminal conspiracies to commit misdemeanors and felonies including murder contrary
                  to Section 395 and 393 ;


Submissions
[22.]:-Comparative-analysis archaeological material-culture evidence :-
Sodom and Gomorrah have been used historically and in modern discourse as metaphors for homosexuality, 

and are the origin of the English words sodomite, a pejorative term for male homosexuals, and sodomy, which 

is used in a legal context under the label "crimes against nature" to describe anal or oral sex (particularly homosexual) and bestiality. Genesis 18–19 :-  Three men come to Abraham in the plains of Mamre. After the angels receive the hospitality  of Abraham and Sarah, the Lord reveals to Abraham that he would confirm what he had heard against Sodom  and Gomorrah, "and because their sin is very grievous. "The angels are met by Abraham's nephew Lot, who convinces them to lodge with him, and he serves them a meal. But before they lay down, the men of the city, even the men of Sodom, compassed the house round,  both young and old, all the people from every quarter. And they called unto Lot, and said unto him: 'Where are the men that came into thee this night? Bring them out unto us, so that we may know them.' (NRSV: know them, NIV: can have sex with them, NJB: can have intercourse with them). Lot refused to give his guests to the inhabitants of Sodom and, instead, offered them his two virgin daughters  "who have not known man" and to "do ye to them as [is] good in your eyes". They refused this offer, complained about this alien, namely Lot, judging them, and then came near to break down the door.... You know how the story goes ;

-This same prehistoric-descendant-culture prevails since time immemorial and it's very much pronounced in Kenya's Lamu and Kisumu ( for which the latter leads Kenya in homosexuality as per pollsters ) as regards the 'married-but-gay' sexual-orientation to which defendant (14b.) Peter Mango of Chamkombe Kakrao village Suna East belongs and for which together with their witches'-nest has been and is still trying to coerce me to align-to with regards to gender-conformity as is entailed in my series of sexual-crimes explicitly-and-implicitly; Any Lamu authority as is common knowledge to Mombasa habitants will tell you how it's the custom in Lamu to keep young boys indoors while the market-less girls go roaming up-and-about simply cause the boys will be homosexually seduced, beckoned or harassed like the above defendants have been trying since Ikenya's unlawful forced-transportation to Migori in June 2012.

[23.]:-Migori Police Station sent me to the Crimes-Office for the Officer investigating my case a Mr. Maroko { 0721447996 } who also deridely called me a mlevi as he consulted with the OCS } who asked me the particulars of my case and upon deliberations asked for witnesses whom I clarified there were basically none apart from me since most of the neighborhood is part-and-parcel of the larger conspiracy. Thus in collaboration with the OCS they referred my case to DAPC Migori since It touched on AP police Owino. DAPC listened and clarified that first of all they got no AP called Owino in their Suna database but that nonetheless Migori Police Station should arrest the individual Victor booked in the OB regarding the latest crime in the series of the criminal-conspiracy and thereafter if there's any conspiracy it'll be for them the Police to determine. The In-Charge of Crime and the OCS  said they couldn't start to arrest Victor, the alleged offender without any witness!

[24.]:-So I cited "Section 24 of the Evidence Act" which provides that :- Notwithstanding provisions of Section 19 of the 'Oaths and Statutory Declaration Act Cap. 15, where the evidence of the alleged victim's admitted in accordance with that Section on behalf of the prosecution in proceedings against any person for an offence, the accused shall not be liable to be convicted of such evidence unless it's corroborated by other material-evidence in support thereof implicating him, provided that where in a criminal case involving a sexual-offence the only evidence is that of the alleged victim of the offence; the court shall receive the evidence of the alleged victim and proceed to convict the accused person, if for reasons to be recorded in the proceedings the court's satisfied that the alleged victim's telling the truth.

[25.]:-Thus I told them I'll seek audience with the ODPP Migori on how to go about the matter of bringing the culprits to book and stop this continuous violations of a series of crimes with impunity since the same excuse has been given repeatedly whenever I went to complain against the conspiracy criminals including Peter and Pamela Mango who repeatedly exploit the fact of there being only three of us in their house except for the maids who pop in-and-out severally. Hence I urged concerned authorities to have the cited Section above implemented and start the wheels-of-justice moving; as I went to consult with the ODPP Migori on the way forward.

[26.]:-Criminal sexual conducts in families is rarely discussed for the stigma & taboo 'cept for evident pregnancy cases like in Makadara Law Courts Nairobi where a Pastor successfully impregnated one of his two daughters he'd been sleeping-with for nights-on-end.

[27.]:-In 1531 Martin Luther revealed Pope Leo X had vetoed a measure that Cardinals restrict the no. of boys they kept for pleasure for otherwise, it would've spread globally how openly & shamelessly the Pope & Cardinals in Rome practice sodomy. Thus the difficulty in measuring sexual harassments or abuse cause of human nature to not generally discuss the sticky-issue for the stigma & shame ; hence in Chile Pope Francis first unacceptingly accused victims of fabricating allegations before apologizing for his tragic-error & finally later expressing shame-&-horror for the tragic history. I urge the CJ Maraga to not let community & church leaders plus the police fail to stop criminal sexual misconducts including assaults, gender-underminings, humiliations, incestuous-&-homosexual harassments.
Quote from :- { https://erick-mango.blogspot.com/2019/10/urgings-to-cj-maraga-to-extend-review.html }.

[28.]:-Hence, the Chamkombe-Kakrao witches-nest' Gays and Horny-wives Network's is led by the self-bleaching, indecent--exposure, quickie-prostitute-witch sex-pervert and the 'Married but gay'-witch [ substantiated ] for which I think chances are the rude bleaching witch could be  exploiting her Uriri-Oyani- Stella-Rapogi-Kanyamkago Chief's-lineage including Governor Okoth Obado's kinship since he's her uncle, to call the shots on the ground. Indeed during one of the cases referred to Asst. Chief Onyango I met a woman who'd come to collect her ID or Kid's Birth-Certificate from Oyani which she told me was like a one kilometer's trek away! And former Migori Councilors Chairman John Odhiambo an elder brother to the gay- dodo once remarked whether 'he married or he got-married' given the stone's throw distance from his in- laws  at Oyani-Maasai.

[29.]:-Civil remedies can't bar the filing of criminal charges cause one set of facts can be the foundation of a criminal charge & the basis for a civil action as is expressly contemplated by Statute in Section 193A of the Criminal Procedure Code titled "Concurrent Criminal and Civil Proceedings" which states that: 'Notwithstanding the provisions of  any other written law, the fact that any matter in issue in any criminal proceedings is also directly or substantially an issue in any pending civil proceedings and thus shall not be a ground for any stay, prohibition or delay of the criminal proceedings

[30.]:-Subject to the Discovery-Rule as read together with the 'Limitation of Actions Act' Cap. 22 as regards events of 'continuous-violations-of-the-law' such as in my case, the Statute of Limitations provides for the last possible date a violation might have occurred meaning the first-crime wouldn't expire and the series-of- crimes therefore are charged as one crime with the Statute-of-Limitations beginning after the last crime has been committed.

[31.]:-I therefore urge the CJ in accordance with the edict in Article 10 CoK-2010 to exercise her powers under Article 161 (2) (a) as read together with provisions of the Rules of Court Section 2 (1) regarding the National Policy Guideline on the Administration of the SOA ; and the Protection Against Domestic Violence Act 2015 ; and The HIV Protection and Control Act 14 of 2006.

Particulars of the charges

[32.]:-The fifth-defendant { no. 8 }, the boiled egg-seller entered the scene between March and April 2021 taking from the KPLC-Kisii's errand-neighbor boy whereby the first encounter was from behind as I went to fill my 1.5 liters bottle down the slope and heard somebody singing-walking along with like metal-clashing and when I turned there he was taking to his penis like somebody who wanted to urinate would { as is depicted in the indecent-exposure photo-evidence of Peter Mango defendant 14b. }. This was on the same track-path defendants no. 10 had their errand-neighbor take in the first encounter ; the path that stands between Pamela and Peter Mangos' house, the KPLC-Kisii and the tall house-help's residence's quarter's of the "Nitakuua"-asides who's a friend to Victor; hence did the boiled-egg seller take to insultingly hold-touching to his penis suggestively whenever he saw me thenceforth; leaving no doubt as to where he was taking his instructions from.

-This boiled egg-seller on 9th August 2021 was there again { came and waited } at the water-hole / kiosk scene-of-crime to ogle at me as I bowed to fill my 1.5l bottle and standing besides him was one of the shop attendants { apart from Sonia, the husband and another third tall accomplice / colleague } ;

[33.]:- The first defendant { no. 4 }, Victor the AP cop's farm-hand on August 10, 2021 mark-timed me to wonna borrow a knife from the kiosk he wanted to cut a 30l bottle's neck { when he said for my ears "Mistaki kujua," meaning, "I don't care," } for which as I filled my 1.5l bottle, he got finished and wanted to brush past my 'buttocks' as he passed behind me insultingly suggestively like the conspirators members have premonitioned; forcing me to duck thrusting my waist forward as I stood-upright quickly to avoid any touches. ;

-On 19th August 2021 is when this rude stump of a Victor begun his confrontational accosting wanting to walk straight into my path for a physical brush-up so as to trigger the heinous murderous plans the witches'-nest has. Thus the additional charge regards the stalking harassments contrary to the Protection Against Domestic Violence Act 2015 as regards threats of violence or imminent danger by someone including people who live together; as was indicated by ex-Chief Amara.

-On  August 20th, 2021 between 1000hrs-1100hrs as I was chatting with some neighbor chap after filling my 1.5l bottle, AP police { defendant no. 5 } passed us waving a greeting at the chap as he went to his tenants rentals; from where Victor emerged later to come passing behind us in an { encircling manner as opposed to AP Owino who'd passed in front } his eyes directed at me which scaringly made me suspicious ever since his kin Linet had called him for a machete he often wields as he hedges the fence or on his ups and downs about the farm as he crosses my path subliminally keeping the threat constant; and like he'd asked Sonia the water-kiosk woman to pass him a knife as recorded. I stuck to him from the corner of my eye ascertaining he wasn't gonna pull a surprise on me from behind with a knife-stub or something! A fact that was echoed by the Pamela Mango { defendant no. 6 } when she later retorted in asides that evening that, "Wachadhi wate," meaning "We're hacking you all of us," thus echoing ex-Chief Amara's proclamations. Remember in the precedent record I'd to duck his indecent-assault at the Kiosk as he said,"Mistaki kujua," meaning, "He doesn't care," though ambiguously the 'Mistaki' also is a lament referring to my having reported the AP in two complaints now.

- On August 22nd, 2021 between 1650hrs-1700hrs, Victor the AP police farm-hand and alleged son [ as per whispers ] threatened me again via the now repetitive behavior-pattern of accosting, stalking and encircling me, like he wanted to march right  through in-front of my path for a physical confrontation [ in spite of his short pygmy stump  physique signaling the broader conspiracy back-up of co-conspirators / accomplices ] as I  made a corner at the kiosk from filling my 1.5l bottle of complimentary piped water; before he side-stepped to enter the adjacent barber's rubbing his hands together like he was brushing-off dirt. He was lying across the path initially as came for the water leering at me forcing me to spit in response as I passed by ;

-This harassment he's sometimes done while brandishing a machete { under the excuse of being a farm-hand } apparently under the instructions of his hire AP Police Owino; for which Pamela Mango has retorted in asides that,"Wachadhi wate," meaning, "We're hacking you all together.";

-Still on August 28, 2021 at around 1930hrs rude Victor still accosted me as I came from filling my 1.5l bottle at the water-kiosk waiting till I was done before rushing up the road-side behind me with a long rod pointedly mumbling / murmuring some words I couldn't get as I looked behind to see what commotion was coming up.

Retributions-and-Protections / Reliefs-and-Restitutions Sought
-The costs of this complaints / suit / petition be provided for ;
-Declaration that crimes were committed and rights-and-freedoms violated continuously since 2012 ;
-Court and investigators interrogate the doctored-charges  and the circumstances with the rationale and justification     to demonstrate they were framed ;
-Declaration be issued that the manufactured-charges by defendants (17)  up to forced transportation  to Migori and   OB booking at Migori Police Station By MMC police Ikenya violated my constitutional rights, was an abuse of the   court process, and therefore wrongful, unlawful, null and void ab initio;
-An order of certiorari be issued to quash the framed-charges and proceedings ;
-Maximum sentences and fines for convicts ;
-An order of protection from the defendants ;
-An order of prohibition be issued prohibiting the defendants from proceeding with the consequences of the status-   quo arising from the wrongful, unlawful arrest to forced transportation to Migori since June 2012 ;
-Injunctions barring further violations, discriminations, infringements ;
-Compensatory and punitive damages ;
-Compensatory redress for aggravated-damages for defamation / injury to my reputation ;
-Full and unqualified apology and amends plus withdrawals of slanders ; including statements in the widest possible   circulation and an unconditional  admissions of liabilities for slanders ;
-Lost pay ;
-Pre-and post-judgement interest ;