48.  Defendants intentionally exercised unauthorized dominion and control over funds  paid by Kilman and Class to obtain the release of their animals.  FOURTH CLAIM – Outrage (as to Kilman only)   50.  Morgan acted under color of state law in violating Kilman’s rights under the Fourth,  Fifth, and Fourteenth Amendments by seizing Max and withholding him from Kilman by  extracting, attempting to extract, and extorting funds without any lawful basis, and compelling  Kilman to execute unconscionable, unconstitutional, and unlawful Claim Forms in order to recover  Max. Morgan also intentionally gave Max to a third party over Kilman’s objection, knowing the  anguish it would cause her and her children.    51.  Such unconstitutional acts were performed intentionally, recklessly, and/or with  deliberate indifference.   52.  Morgan’s actions and inactions in seizing Max, extracting funds from Kilman,  withholding Max from Kilman, and thereafter giving Max away to a third party, shocked the  conscience and interfered with her liberty and property interests in Max, thus constituting an  impermissible seizure in violation of the Fourth Amendment and procedural and substantive  dimensions of the Fifth Amendment’s due process clause.    54.  Whether construed as willful conversion or trespass to chattels, Morgan  intentionally exercised unauthorized dominion and control over Max, withholding and converting  him by extorting money from Kilman and compelling her to execute unconscionable and illegal  contracts, causing damage.  55.  Morgan intentionally exercised unauthorized dominion and control over funds paid  by Kilman to obtain the release of Max.  FOURTH CLAIM – Outrage (as to Kilman only)   56.  Morgan recklessly or intentionally caused severe emotional distress to Kilman by  outrageously extracting illegal sums from her and then refusing to release Max altogether, giving  him to another individual without any lawful basis, constituting theft..  JESSICA KILMAN, individually and on  behalf of all similarly situated;  Plaintiffs,  vs.  Ongoing Violation of Federally-Protected Constitutional and Statutory Rights, and  Monetary Damages (42 U.S.C. § 1983, Ch. 7.40 and 7.24 RCW)   and Monetary Damages (42 U.S.C. § 1983) (as to Kilman only)  