Civil rights lawsuit filed by Raymond Pryke of Valleywide
Newspapers

Pyke vs. Gary Penrod, Sheriff of San Bernardino County

"Defendant Chambers appeared that he was going to give Plaintiff time to retrieve
the covenants, conditions and restrictions in order to demonstrate to the Sergeant
that he had a right to perform the actions in which he had engaged.  

"Suddenly, Defendant DeFazio yelled, “he is suing the Sheriff’s wife, arrest him”.  
Defendant Chambers then said, “I have to make a phone call”.  He then called his
superiors.  After that, Defendant Chambers returned and said “I have been ordered
to arrest you”.  He then arrested Plaintiff..."

STANLEY W. HODGE
Attorney at Law
15490 Civic Drive, Suite 204
Victorville, California 92392
Attorney for Plaintiff
Raymond S. G. Pryke

THE UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA, SOUTHERN DIVISION

RAYMOND S. G. PRYKE,                                          
Plaintiff,  

vs.  

GARY PENROD,
COUNTY OF SAN BERNARDINO,
SHERIFF’S SERGEANT B. CHAMBERS,
DINO DEFAZIO,
and DOES I-X, inclusive,                            
Defendants.

Case No.:    COMPLAINT FOR FALSE ARREST, FOR FALSE IMPRISONMENT, AND UNLAWFUL
SEARCH 42 U.S.C. SECTION 1983

FIRST CAUSE OF ACTION
I
Plaintiff Raymond S. G. Pryke, is and at all times mentioned was, a resident of the City of Hesperia,
County of San Bernardino, State of California.
II
Defendant Gary Penrod was, and at all times relevant herein the Sheriff of the County of San Bernardino,
was acting as the Sheriff of the County of San Bernardino and was a resident of the County of San
Bernardino, State of California.
III
The County of San Bernardino is a public entity duly authorized under the laws of the State of California.  
The San Bernardino Sheriff Department is an agency of said County.
IV
Defendant Sheriff Sergeant B. Chambers was, and is a deputy Sheriff of the San Bernardino Sheriff’s
Department and was acting as a deputy at all times in which the events described in this Complaint took
place.
V
Defendant Dino DeFazio is, and at all times relevant was, a resident of the County of San Bernardino,
State of California.
VI
Plaintiff is informed and believes and upon such information and belief alleges that each of the
defendants sued herein by the fictitious names of DOES I-X, inclusive, is responsible in some manner
for the injury inflicted upon Plaintiff.  Plaintiff will amend this Complaint when the true identities of said
defendants are ascertained.
VII
At all times relevant herein Plaintiff was engaged in the business of the sale of
real estate and was the President of Apple valley Land Corporation.  As such,
Plaintiff was charged with the enforcement of the covenants, conditions and
restrictions applicable to All of Tract No. 6030, as per plat recorded in book 83 of
Maps, Pages 64-65 in the Office of the County Recorded of San Bernardino
County.  A true copy of said covenants, conditions and restrictions is attached
as Exhibit “A”.
VIII
On or about June 16, 2000 the wife of Defendant Penrod instituted an action for,
among other causes of action, defamation against Plaintiff for allegedly
defamatory statement published in newspapers owned by Plaintiff.  This action is
still pending before the Superior Court of the County of San Bernardino, Case
number SCVSS68062.  A copy of said Complaint is attached hereto as Exhibit
“B”.  On or about May 23 2005 Plaintiff Pryke filed an action against Defendant
Dino DeFazio for Breach of contract, Fraud and other causes of action.  A true
and correct copy of said lawsuit, Case Number VCVVS037918, is attached hereto
as Exhibit “C”.
IX
On or about May 7, 2008 Plaintiff was at a newly constructed and vacant home
built on a lot subject to the covenants, conditions and restrictions to determine
compliance with said covenants, conditions and restrictions.  

Plaintiff was permitted by said covenants, conditions and restrictions to enforce
the covenants, conditions and restrictions.  Plaintiff was at the newly built
structure to inspect the structure.

He had to have a locksmith change the lock on the building in order to conduct
his inspection.  Inside, the locksmith discovered the plans for the building and
the locksmith gathered the plans for inspection.  Plaintiff then took the plans to
his home for inspection.  

Defendant DeFazio brought Sergeant Chambers to Mr. Pryke’s home.  Plaintiff
then explained to the Defendant Chambers that he had a right to inspect the
home and plans.  

Defendant Chambers appeared that he was going to give Plaintiff time to
retrieve the covenants, conditions and restrictions in order to demonstrate to
the Sergeant that he had a right to perform the actions in which he had
engaged.  

Suddenly, Defendant DeFazio yelled, “he is suing the Sheriff’s
wife, arrest him”.  Defendant Chambers then said, “I have to
make a phone call”.  He then called his superiors.  After that,
Defendant Chambers returned and said “I have been ordered to
arrest you”.  He then arrested Plaintiff...
X
All the aforesaid conduct was performed by the Defendants maliciously, unlawfully and
without reasonable or probable cause and without warrant or any process of any court,
whereby the Plaintiff should be awarded punitive damages in the sum of Ten Million
dollars ($10,000,000.00).
XI
By reason of the above the Plaintiff was deprived of his liberty without due process of law
and in violation of the Fourth and Fourteenth Amendment.
SECOND CAUSE OF ACTION
XII
Plaintiff realleges and incorporates herein by reference each of the allegations contained
in Paragraphs I, II, III, IV, V, VII, VIII IX, X and XI of his First Cause of Action.
XIII
Plaintiff was taken by Sheriff Deputies to the West Valley Detention Center in Rancho
Cucamonga, California at approximately 4:00 p.m.  Bail was posted on Plaintiff’s behalf
within approximately one hour, at 5:00 p.m.  Plaintiff was told that even though bail had
been posted that he was going to receive “special treatment”.  He was then confined to
the West Valley Detention Center until approximately 4:00 a.m.  
XIV
Plaintiff was unlawfully detained under color of state law after bail had been posted in
violation of his rights not to be imprisoned without due process of law and the Fourteenth
and Fourth Amendments to the United States Constitution not to be seized and
imprisoned once bail had been posted.
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From the San Bernardino Sun:

"Lizarraga argued that Bohl
voluntarily put herself in the public
vortex when she entered a
relationship with Penrod, a public
official, in 1999. News of a possible
conflict were also covered in other
Inland Empire newspapers, he said.

"As a result of the relationship
between Bohl and Penrod, the
county had to change the
contracting process for her
business. The judge said issues
may rise to level of a public concern
but do not make her a public figure.

"Lizarraga argued that
Bohl
became at least a limited public
figure
prior to the publication of the
articles because of the vortex."

SBSun: Ruling favors
libel suit
Mike Cruz, Staff Writer
San Bernardino Sun
08/23/2010

A Superior Court judge ruled
that the wife of former Sheriff
Gary Penrod was just a private
citizen – and not a public figure
– when a High Desert
newspaper publisher ran
articles about her counseling
business during trial
proceedings Monday in her
multimillion- dollar libel lawsuit.

The ruling Monday from Judge Frank
Gafkowski appears to favor Nancy Bohl,
who filed a lawsuit in June 2000 against
Valley Wide Newspapers publisher
Raymond Pryke based on a series of
articles he ran about Bohl’s business,
The Counseling Team, and her
relationship with Penrod.

The ruling and others from the judge
stating that parts of two articles were
“libel per se” and discussing a public
concern came during lawyers’ arguments
about pretrial motions in San Bernardino
Superior Court.

“Just the fact that she is going out with
him or married to him does not make her
a public figure,” Bohl’s lawyer John
Rowell argued in court.

The judge agreed. Even Bohl’s contract
with San Bernardino County to provide
counseling services to sheriff’s deputies
was not enough to tilt the scale,
according to the court.

Rowell said his client started her
business, The Counseling Team, in
1985. The articles ran between June
1999 and April 2000 in Pryke’s
community newspapers, such as the
Hesperia Reporter and Adelanto Bulletin.

With headlines like “Sleeping with Penrod
Pays Off” and “Sheriff Penrod Spies on
Deputies,” the articles accused Bohl of
leaking confidential
details from counseling sessions to
management at the sheriff’s department
and using her relationship with Penrod to
get a county contract.

Bohl has denied the allegations.

Gafkowski said the allegations about
Bohl, her relationships and county
contract erupted during a very short
period of time and were not raised before
publicly.

“She’s drawn into this involuntarily,” the
judge said.

Pryke attended the hearing Monday,
sitting at the table before the judge and
next to his lawyer, Frank Lizarraga. Bohl
and Penrod were not present.

Lizarraga argued that Bohl voluntarily put
herself in the public vortex when she
entered a relationship with Penrod, a
public official, in 1999. News of a
possible conflict were also covered in
other Inland Empire newspapers, he said.

As a result of the relationship between
Bohl and Penrod, the county had to
change the contracting process for her
business. The judge said issues may
rise to level of a public concern but do not
make her a public figure.

Lizarraga argued that Bohl became
at least a limited public figure prior
to the publication of the articles
because of the vortex.
VVDailyPress:
Newspaper publisher’s
attorney claims right to
free speech
August 30, 2010 6:12 PM
Tomoya Shimura

SAN BERNARDINO • Attorneys
delivered opening statements
Monday morning in a multi-million
dollar libel lawsuit filed by former
San Bernardino County Sheriff
Gary Penrod’s wife against a
controversial local publisher...
Ray Pryke: Publish free
or die
May 11, 2007
By BEAU YARBROUGH
Staff Writer

During World War II, when Hesperia
Resorter publisher Ray Pryke was
still just a young Englishman from
East Anglia, he joined the British
Army, Royal Air Force and finally
the Royal Navy.

"I loved to fight," he said
Wednesday.

Today, 84 years old and an
American for 53 years, that hasn't
changed.

On May 5, a California
Appellate Court judge
overturned a $3 million
judgment against Pryke's
company, ValleyWide
Newspapers.

Nancy Bohl, the wife of San
Bernardino County Sheriff Gary
Penrod, had sued ValleyWide in
June 2000 for libel, based on a
series of articles published between
1999 and 2000.

The articles alleged Bohl and her
company, the Counseling Team,
including "sleeping with the sheriff
to obtain the service contracts,
cheating the County of San
Bernardino on the bills for such
services and breaching the
confidentiality of therapeutic
dialogue by disclosing the content
with the sheriff or other law
enforcement brass," according to
court documents.

Bohl's attorney alleged ValleyWide
reporter Mark Gutglueck had
fabricated the stories and his
anonymous sources were
non-existent.

Pryke says he took a page from
Watergate-era Washington Post
editor Ben Bradlee and had
Gutglueck write down the names of
his sources in an envelope, which
remains locked in a safe.

"Americans always think they have
freedom of the press, but they don't
know what that is and you can't tell
them," Pryke said. "I knew I was
going to get sued, but I kind of
looked forward to that."

"I want to see where it goes"

He's received more than one
settlement offer from Penrod and
Bohl, he says.

"If I would sell the newspapers, have
dinner with Gary and Nancy and I'd
give them $25,000," Pryke says was
the latest settlement offer, with no
trace of an English accent. "Why
would I want this dismissed? I like
this suit. I want to see where it
goes."

The potential financial downside
doesn't seem to bother him.

"I have 135 pieces of land. What am
I going to do with it? You can't eat
it," Pryke said. "What's $3 million [in
damages] when I have $20 million?"

Bohl has not yet decided if she will
appeal the decision and potentially
carry it to the California Supreme
Court, according to her attorney
John Rowell. A decision will be
made before May 19.

San Bernardino County Sheriff
Gary Penrod was unavailable for
comment for this article, according
to department representatives...
Local publisher to pay
$332,500 after jury trial
Jurors find Pryke defamed former
Sheriff's wife
October 07, 2010
Tomoya Shimura

SAN BERNARDINO • A jury has
determined that the publisher of a
local weekly is responsible for
publishing false articles about
former San Bernardino County
Sheriff Gary Penrod’s wife and
awarded her $332,500 in damages.

Raymond Pryke published articles
in the Hesperia Resorter, Apple
Valley News and Adelanto Bulletin
in 1999, claiming that Nancy Bohl
had leaked confidential patient-
client information to her then-
boyfriend Penrod. Bohl is a
psychologist and owns The
Counseling Team, a firm that
provides crisis intervention services
to Sheriff’s deputies.

And in April 2000, Pryke published
an article claiming that Bohl took
advantage of her relationship with
Penrod so that her firm could obtain
a contract with the San Bernardino
County Sheriff’s Department.

All 12 jurors agreed that such
statements were false and that
Pryke failed to use reasonable care
to determine whether the
statements were true or false. It
took the jury nearly a week to reach
the verdict Monday in San
Bernardino Superior Court.
Publisher’s past service to Victor Valley incalculable
Letters 5-11-08
Daily Press
vvdailypress.com
May 12, 2008
So Ray Pryke, publisher of the Hesperia Resorter, in his 85th year of life, has been
arrested for commercial burglary and held in the county jail on $50,000 bail, according to
the front page of the May 8, 2008 Daily Press.

Mr. Pryke was once sued by Nancy Bohl, Sheriff Gary Penrod’s wife,
[Maura Larkins'
note: indeed, the Sheriff's wife continued that lawsuit after this date, subsequent to
her first victory being overturned by the Court of Appeal]
for printing that, as a
psychotherapist she gave Penrod confidential information about sheriff’s employees
undergoing treatment. And while Judge Christopher Warner ordered Pryke to pay $3
million for impugning Bohl’s integrity, an appellate court overturned the award.

The day before Mr. Pryke was arrested, by pure coincidence, I dropped off a letter to him
at his Hesperia office which included these words: “For the years that the Hesperia
Resorter was the only media voice in the county daring to report unpleasant truths about
county government officials, thank you. We certainly miss those days.” And I should have
added “unpleasant truths about High Desert city and regional governments” as well.

Mr. Pryke’s free press exercise path has been a path the Daily Press and the San
Bernardino Sun feared to tread. During periods when I regularly attended county board of
supervisor meetings it was my custom to distribute the latest Hesperia Resorter to select
individuals in attendance, leaving copies in the media room. And they were always gone
at day’s end.

As someone who was once booked into the county jail and held on bail for the totally false
charge of maliciously interfering with a public safety radio frequency after a quiet board of
supervisors meeting arrest on June 29, 2004, I read the Daily Press account with great
skepticism.

The charge against me was made up to justify holding me on bail because at the time,
due to serious jail overcrowding, the sheriff was releasing individuals on their own
recognizance who should have been held on up to $50,000 bail. And an arrest for
disturbing a public meeting does not even warrant being booked into the county jail, much
less being held on bail when people arrested for grand theft auto, assault with a deadly
weapon other than a firearm, and such, were being released on their own recognizance.
But hey, in the “Wild West of ethics,” what does inconvenient truth matter?

The worth of Mr. Pryke’s past service to the High Desert as a fearless media voice is
incalculable. What a shame that in the winter of his life he has been subjected to such
treatment.

Bob Nelson


Conservative voice of Daily Press appreciated

I wish to commend the paper on publishing such a politically incorrect story (Woman
pregnant with 18th child,” May 10), on the front page no less.

That is one of the reasons I continue to read this paper as it is not afraid to be a
conservative voice in the liberal media of today. As a mother of seven and having home-
schooled three of my children from kindergarten to high school graduation, I say
“continued blessings to the Duggar family.” How nice to see a family that has the courage
to go against the popular trends and follow their hearts.
I’m sure that those children will not be in a street gang or some other unsavory situation.
They are being taught a genuine work ethic and will be positive contributors to our ever
floundering society. They are not being cloistered from society either; they are being
taught the principles that our nation was founded upon. “Do unto others as you would
have them do unto you” worked then and it will work now if we would only get off the
selfish horse that so many of us tend to ride nowadays.
Please continue to publish the positive side of going against the flow. I’m impressed.

Yvonne Van Brimmer
Victor Valley
No charges filed against
local publisher
Prosecutor's office claims lack of
evidence
May 23, 2008
RYAN ORR Staff Writer
Daily Press

VICTORVILLE — No charges will be
filed against a local newspaper
publisher who was arrested earlier
this month on suspicion of
residential burglary, Chief
Supervising Deputy District Attorney
Gary Roth said Friday.

“We have declined to file criminal
charges and decided there was
insufficient evidence to prove the
‘intent to steal,’ element of the crime
beyond a reasonable doubt,” Roth
said.

Raymond Pryke, publisher of Valley
Wide newspapers, was arrested on
May 8, for allegedly breaking into a
house owned by Artisan Real
Estate, a company he is currently
suing.

Employees of Artisan Real Estate
were checking on a house when
they discovered Pryke and a
locksmith attempting to change the
locks, said Cindy Beavers,
spokeswoman for the San
Bernardino County Sheriff’s
Department.

According to officials, after the locks
were changed, Pryke entered the
home in the 25800 block of Rancho
Street and took undisclosed
property from within the vacant
home.

Pryke, 85, said he could not
comment on the case, but that he
was planning on checking himself
into to Loma Linda University
Medical Center next week.

“I’m under a lot of stress and am
going into Loma Linda for a
physical examination because my
blood pressure is way too high,”
Pryke said.

Pryke was ordered to pay $3 million
after San Bernardino County Sheriff
Gary Penrod’s wife, Nancy Bohl,
sued him for libel relating to articles
about her and her company in
Pryke’s newspapers.

The judgment was overturned
in the 4th District court of
appeals and the case was sent
back to the superior court to be
tried again. It is slated to start
July 7.
If you think you can publicly
criticize the wife of a former
County Sheriff and not get
arrested, think again.