Description

IN THE UNITED STATES DISTRICT COURTS

FOR THE DISTRICT OF COLUMBIA

MIREILLE TORJMAN CASE NO.:

Plaintiff

V.

FEDERAL BUREAU OF INVESTIGATIONS, et al.

935 Pennsylvania Avenue Northwest

Washington, DC 20535-0001;

CENTRAL INTELLIGENCE AGENCY

Office of Public Affairs

Washington, D.C. 20505;

NATIONAL SECURITY AGENCY

9800 Savage Road, Suite 6711

Fort Meade, MD 20755-6711;

DEPARTMENT OF JUSTICE

600 E Street, N.W.

Washington, D.C. 20530;

DEPARTMENT OF DEFENSE

1400 Defense Pentagon

Washington, DC 20301-1400;

DEPARTMENT OF ENERGY

1000 Independence Ave

Washington, DC 20585;

UNITED STATES OF AMERICA

Defendants

COMPLAINT

1. Plaintiff, Mireille Torjman hereby brings this action for injunction relief and damages based on personal knowledge and belief, as a victim and expert witness, to the information provided, as to all other matters, as to which allegations Plaintiff, without doubt or delusion, will provide proof, unrefuted evidence, overwhelming evidentiary support, witnesses, substantial facts, research, and investigation that exists as follows:

PRELIMINARY STATEMENT

2. This case is about the wiretapping, civil rights violations, privacy, communications technology, and crimes of humanity, in use by the Intelligence Community. With the advanced technology unknown to most, of shadow network of surveillance and spying under DARPA projects, defendants are, transmitting, intercepting, tampering, and blocking the content of a significant portion of the Plaintiff’s phone calls, emails, instant messaging, text messaging, www, Skype, electronic and wireless communications, and other communications, both internationally and domestic, including Plaintiff’s family and practically every American, for the past 4 years, beginning on or about January 2007.

3. Plaintiff’s records will show communications are intercepted, manipulated, tampered with, stored, (data mining), harassed, and impeded. Plaintiff will provide numerous emails hijacked, fabricated, UNREAD, manipulated, deleted, including facsimile, and internet manipulations, since 2007. Plaintiff’s numerous impeded electronic communications with all her service providers were debilitating to her work and she had no resolve available from providers who were not able to correct or detect the situations. This includes manufactured emails, phone calls, and government employee’s unwitting involvement. In 2008, Plaintiff was also accused legally of false communications during her service with Qwest, by using wiretapped calls and disconnects to create false records with her utilities company, including defamation to her character. (Kay Griggs, Military wife; whistle blow case on tampered communication CHAOS and automobile impediments not to testify).

4. Plaintiff is not delusional and has provided her records to DOJ in early 2009, with documents from many other credible sources and whistle blowers. Plaintiff requests that the Russell Tice case and Articles below § 35 is read with disclosures being made as to her allegations, Injunction relief, various separate counts, and tort damages throughout. Plaintiff has demonstrated courage, risked her reputation, risked her life, and family’s, and has been threatened, prior to receiving an anonymous email of the NSA article (below) in February 2009. Plaintiff tried to blow the whistle to the DA late 2007, and was not aware what NSA was or government corruption, but knew she had to report what was going on. As quoted by Mr. Tice and others; “Statement by NSA, “THE TIP OF THE ICEBERG and WIRETAPPING SURVEILLANCE LOOK LIKE SMALL POTATOES”. Most recently, Plaintiff was able to meet with the FBI in early 2010, and provided some information for investigation by various FBI analysts.

5. The President and other executive officials have described some activities of surveillance and spying which are conducted outside the procedures of the Foreign Intelligence Surveillance Act (“FISA”) and without authorization by the Foreign Intelligence Court, Communities, Committees, Senate, or Congress.

6. As with The Attorney General and the Director of National Intelligence having since publicly admitting that the TSP was only one particular aspect of the surveillance activities authorized by the

Programs, and are being abused. (Jewel v United States, United States v Yahoo)

7. In addition to eavesdropping on or reading specific communications, Defendants have intercepted the communications contents across the United States and overseas, and targeted the Plaintiff with intense sabotage and impediments, Electronic Stalking, Slander, including Internet Communications, and Google’s Access Portals. Plaintiff wrote to Google to let them know what was going on behind the scenes with all the tampering including remote viewing, password access, and covert data-mining in SG3 dating back prior to 911. (EFF v Google and Street View) DOD’s ELF transmitters were already in full scale by 1981 in Australia and Africa, followed by additional covert superior Projects as Combat Zones also under DARPA formerly ARPA)

ALLEGATIONS AND FACTUAL ALLEGATIONS RELATED TO ALL COUNTS

8. With suspicious FBI allegations and $122 Million Virtual Case File Project gone wrong in 2001, prior Board Members and Government Officials’, the new Parent Company SAIC’s (C I A Spacestar) servers and the (“Occult Connections”). Chief of Staff Jack E Thomas Air Force Intelligence, 1997 ties with DOD, NSA, CIA, and former Executives, Directors, Secretaries, Army Generals, all had knowledge of REMOTE VIEWING experiments spy biz, SPAWAR at the Naval Electronics System Command in San Diego and Los Alamos National Labs for Medical Oversight to American Intelligence Agencies (1996). A surge of Federal Spending raised Multi-Billion dollar Defense concerns with SAIC and Titan (moon) in 2004 (San Diego) and the mid 90’s on technology projects that REQUIRE HUMAN EXPERIMENTING as well. These BLACK BUDGETS are corruption hiding behind SSP.

9. Joseph McMoneagle, eventually revealed as such, but for the purposes of the Army’s psychic intelligence unit, he was simply Remote Viewer No. 1.” In his Memoirs of a Psychic Spy is a look at the most remarkable exploits in a most astonishing career of military service. Remote Viewer 001 in Army’s Stargate Project reports this as still classified. The top secret intelligence gathering initiative launched at height of Cold War- David Morehouse 1998. This project was first used to retrieve intentions in a criminal or terrorist’s mind. (The Lucid View, Investigations in Occultism, 2004 and included in MK ULTRA is Project “VOICE of GOD”) This is used for unexplained phenomenon and to manipulate religion and/or to compel a crime, command or order. It is undeniable that government agencies have tested citizens without permission as The Manchurian Candidates in the United States and the IRS. Cognitive Sciences Laboratories CIA research 24 years ago when Tom Beardon warned about these weapons and activities as serious dangers.

10. The core component of these Programs is Defendants’ nationwide network of sophisticated communications surveillance and spy devices installed overtly. NSA transmissions and NASA Remote Viewing have been in place and are being connected to the key facilities of telecommunications with advanced technologies like that of HAARP stations and Satellites for many years prior and covertly. As Quantum Physics (sound and/or radio WAVES) and subliminal are being used for Spying and breaching contracts with other Countries and Embassies, HAARP is used for Earth and human manipulations. (Jerry Smith, Jim Keith; Politician and Dr. Nick Begich, Alaska; “HAARP; THE ULTIMATE CONSPIRACY” 1998) The “Method of Inducing Mental Emotional and Physical States in Human Beings” was patented for the CIA in Virginia in 1993.

11. These projects of CointelPro, Psyops experiments for drones, and Surveillance/spying have continued covertly to develop weapons that were first patented by Russia and China. Since the 1950’s, first revealed to the public were the Alien UFO Projects, and the subliminal cravings of coca cola, movies and pop corn. Shortly thereafter as technology advanced, mass control continued to this day nefariously against all Americans, called NSA transmissions today. Since 1974 under the Pentagon, DOD funded the ELF radio broadcasting in conjunction with hypnotic control and prior to that Doctors Bill Nelson and Tom Beardon had their own patents at NASA on Medicinal Energy and Biofeedback, already in use in other Countries with the same remote scalar waves and frequencies. (Apollo and Whistleblowers Second craft 11, shadowing Apollo 13 and no witnesses returned after the Shuttle)

12. In early 2008, after 25 years of being an accountant, and raised in the Mediterranean, Plaintiff purchased the Non FDA device from a NASA physicist at $21,000.00 with Scalar waves, (Russian Woodpecker frequencies), and Military Patents. Plaintiff became a certified practitioner to protect herself and attempt to deprogram. Plaintiff was intercepted by this HAARP and NSA’s SIG-INT Satellites, thus became a certified hypnotist trained in NLP (Neuro-Linguistic Programming; CIA taught techniques, (Bandler and Grinder 1976) and (Project Paperclip; Dr. Strughold Space Medicine 1963)

13. In her travels, Plaintiff witnessed these transmissions used in Israel, Australia, England, European Countries, and was further impeded when attempting to whistle blow the nefarious uses and crimes of humanity, to the embassies. Plaintiff will show documents or connections to MAFIOSO, KGB, and AL Qaeda, within the CIA, as with Donald Rumsfeld and his banking ties. World Banks (1910) JP Morgan, Black Budgets, and Nikola Tesla 1940)

14. Some aspects of the Programs of MKULTRA were publicly acknowledged by President Clinton with partial apologies on October 3, 1995 as past tense and not being done currently to down play their uses. The Pentagon has new buzz words SYNTHETIC TELEPATHY-Psychotronics. However, Plaintiff spoke with many other victims today, and the latest FT Hood Mind Control soldier. Psychotronics also has a non-profit organization of former scientists and whistleblowers of same. (Lynn Surgella-Cancer; Central Nervous System diseases and Immune System-FDA drug corruptions) Furthermore, under DOD, Combat Zones That See, or CTS, project of the United States Defense Advanced Research Projects Agency (DARPA-1957) whose goal was to “track everything that moves” in a city by linking up a massive network of surveillance cameras to a centralized computer system. (Russell Tice called Spy Apparatus.) Artificial intelligence software will then identify and track all movement throughout the city. In 1958, immediately after Sputnick, DARPA began to secure our space and airways with these Directed Energy Weapons. (Project AGILE-1966 Pentagon). Plaintiff has knowledge that after this project was field-tested with experiments on Vietnam VETERANS disguised as Agent Orange. Plaintiff spoke with many suffering from ELF induced nervous central system attacks and complain of mind control. One of many victims is suing the Bar due to the VA computer systems uses. In an undisclosed report dated March 9, 2005, 8 more projects with strategic thrusts included Bio-Revolution, DIRECTED ENERGY, and Urban Operation of sensors on the existing Airborne Video Surveillance, all under the Iraq theory, also data mining all information from the Human. CTS is described by DARPA as intended for use in combat zones, to deter enemy attacks on American troops and to identify and track enemy combatants who launch attacks against American soldiers, under Martial Law for a Police State and legalize Fascism.

DARPA’s current Projects, XG, Robotic assured Military communication, CALO; Cognitive Impairment (ADDHD and Optical), and Silent Talk; A planned program attempting to identify EEG patterns for words and transmit these for covert communications. Telepathy were part of the tests the Plaintiff was sent for, including warming her blood without the Doctor’s consent and her eyes physically taken over by an MRI, data mining the Plaintiff’s optic pattern, DNA, and more. This computer-mediated telepathy allows user-to-user communication through analysis of neural signals. The research aims to detect and analyze the word-specific neural signals, using EEG, which occur before speech is vocalized, and to see if the patterns are generalizable. As of 2009 the research is focused on military uses. Plaintiff, an unwitting guinea pig of these programs went for tests, as her hair has not grown since 1996, with induced rapid loss, a skin condition from the blood unknown to the doctors. In addition, since 1962, ARPA initiated the Office of Information Processing Technique and Behavior Sciences for Artificial Intelligence, Command and Control, known today as Behavior Modification or BRAINWASH.

15. Julianne McKinney, 1994 former Military Intelligence Officer and Director of these very PROJECTS is still battling with it today, demanding oversight and cease and desist of Microwave Harassment. (“The Classic Mind Control Operation Revealed” June 2003, surveillance and ‘neurocybernetics’ systems, which DOD refers to as ‘psychotechnologies’. (Former Pentagon Reporter, Sharon Weinberger (misfits scientists, remote viewing; internal emails, 1996)

16. John Herschel Glenn Jr., 1974-1999, former astronaut and U.S. politician who Introduced a Bill and Joint Resolutions (Page S645) Human Research Subject Protection Act, stated “In fact, our own Constitution says, ‘The right of the people to be secure in their persons . . . shall not be violated.’“, and compared it to the Nuremberg Code. His own experience and knowledge of unwitting civilians with Radiation experiments has already been proven that Directed Energy Weapons increased CANCER rates DRAMATICALLY in this COUNTRY thus far. Furthermore, patients have discovered leaving the Country for natural cures worked without further Chemotherapy. During Plaintiff’s brief work at the ACLU, Plaintiff learned that calls were made from patients complaining of being electrocuted while in Hospitals. the reason knowledgeable professionals warn against this Technology in the wrong hands; OUR CIA’s Cointelpro division of Terrorists within, and keeping their enemies close, unfortunately. Plaintiff met with FBI and Congress on two occasions and warned them of her discoveries, and the Gulf’s Red Tide in Florida before the spill as corruptions at the hands of our Shadow Government, and did same with Documentary “Un-Covered” as Marionettes. ELF Waves used in getting a war by Congress not reading full documents to invade Iraq. (Judicial Watch various lawsuits, FBI 2008 spinning their wheels)

17. Plaintiff also has knowledge of the manipulations to the media and miscommunications for the use of quashing, suppressions and propaganda to block exposing the government’s advertising corruptions with misuses in the 21st Century technology. (Operation Mockingbird Media, beginning in the 1950’s). The HAARP and HIPPA stations were set up reaching Woodpecker waves with Russia about the time space activities began 1970 when “Big Brother was watching” today known as “Big Brother gets a Brain”. Whereas Russia was in fact only deployed with these Weapons on the U.S. or on its own people. Paranoid, our Intelligence, DIA launched against its own people in 1983. Astronomical Defense budgets developed as black budgets, and SPYING nefariously went covert from media and public’s knowledge. (Jerry Smith, CARABAS Coherent All Radio Band Sensing, HAARP printed in Canada 1998)

18. Plaintiff and Plaintiff’s family members are ordinary Americans who were initially picked up in the “Big Brother radar” unwittingly in 1971, whereas Plaintiff was informed others who have ties with Military, Minorities, Government employees and buildings, all being picked up in radar with data mining human information for world domination powers. “Dumbed Down and red tape bureaucratic culture induced”

19. Plaintiff was informed that Pilots were mind controlled in advance in the U.S. and San Diego, and that 911 was created to lose our FREEDOMS and the commission investigation was sabotaged. (Naomi Wolf (Yale Journalist)-10 Steps-Freedom to Fascism, 2007- also harassed by and on no fly zone list)

“Death Ray” for planes was Tesla’s invention in 1940 and a $2,000,000,00 device to zap and melt an airplane motor 250 miles away and an Invisible Chinese Wall of defense was built around the Country, no matter how large an attack, (Teleforce, manifests energy and creates rays; zapping beams, the new invisible war). Today, this Wardencliff Tower is in full action in Long Island NY, along with 36 other stations or sites as GWEN, Globally and beam massive volume of Free Energy. (The New York Times, Sunday September 22, 1940-Science and Patents, Education News) One energy zapping causes confusion, mistakes, body temp-freeze, heat, miscommunication, fatigue, radio-sleep (Kucinich), and stalling engines.

On or about January 3, 2009, upon contacting the United Nation’s African Human Rights; provided her information of these weapons in use for mind control overseas and found Alison Des Forges, senior Africa adviser for Human Rights Watch was deceased in the Buffalo NY crash in February 2009. On or about May 2008, the same occurred after contacting Ted Kennedy for assistance and suddenly became unavailable with Cancer. Plaintiff was scheduled to testify in NY senate hearing with the help of Senator Eric Adams which was delayed with a busy nation in transition, until his second home caught fire and the hearing never occurred. Plaintiff had numerous impediments of busy delays from everyone she contacted daily to block her and has more disclosures not included in this complaint.

On or about January 2007, Plaintiff witnessed people and companies pointing the finger at each other, and creating a doubt to sabotaged lives and the LEGAL SYSTEM further. “What the courts should also know.” Today, Society’s Chief complaints are demanding OVERSIGHT and TRANSPANCY. Plaintiff has knowledge that it is the CORRUPTION and the bigger Agenda to change the Constitution, that’s HIDING behind SSP. Furthermore, testimonies made in 1977 to U.S. Courts and Congress by whistleblowers Cathy O’brien and Mark Phillips were blocked for reasons of National Security. This SSP has unwittingly allowed the crimes to continue. Today we are finally seeing the same has continued to bigger Government crimes and corruption with technology and war. Step #9 closer to legalizing Fascism, eyes wide shut: (Access Denied, Trance-formation of America 2003). The Judicial System has not connected the dots yet, on prior crimes from these technology weapons that blighted the Courts 40 years ago to bring us to this point and a corrupted culture. Plaintiff will show that smokescreens are created through propaganda to cover up what is going on in this Country from “We the People”, collectively since “Big Brother Technology” that outsiders already noticed or realize. (See § 34)

20. Plaintiff is also suing Defendants to enjoin their unlawful ABUSES of communications, records, and intrusions. Plaintiff makes demand for the inventory of records since 1971 when Defendant’s family applied to come to America. Plaintiff motions the court to compel the safety of “WE THE PEOPLE” by dismantling these Weapon Stations, and the CIA, which were born with the National Security’s Act in 1947, with criminal and punitive damages.

21. Plaintiff is also suing Defendants for treason, crimes, violations, and threats attempted on her and her family, when disseminating the information and ARTICLE, and reporting it to the Authorities.

22. Plaintiff was pre-empted with these Serious Accusations to whitewash history, brainwash the public, and keep Washington in their bubble, as being too late. (CIA techniques; Jacketing- against each other or one against the other, and changing minds, Past Presidents-Dr. Walter Bowart, False Memory Syndrome Foundation 1992, and Alzheimer’s disease-like memory loss, 1996)

23. These are unconstitutional programs under Cointelpro divisions (Operation Mind Control and DIA Remote Viewing experiments and NSA transmissions) as described to include Monarch-The New Phoenix Program, MKULTRA (Constantine-Virtual Government, CIA Mind Control Operations in America, 1997), Project Philadelphia, Echelon, Clear eyes, Mockingbird media), and Military Pandora’s Box, Voice of GOD, Operation Northwoods (creating wars), Project Stargate and Spacestar, (CIA Psychic Remote Viewing and FBI Virtual Project, 1996 respectively), Project Paperclip (Space Medicine), along with many others), and include corruption crimes of abusive powers.

24. Plaintiff is suffering from the violations of her constitutional rights, and privacy acts, (US code 5 and 18) at the hands of, the direction of or with the knowledge of, the Defendants. Defendants in concert with other Intelligence agencies and/or service providers and means are set forth in paragraphs below).

25. Plaintiff, was comatosed for 72 hours in her home and recruited for experimental remote mind control ESPIONAGE, SEXUAL SLAVERY, AND BEHAVIOR MODIFICATION, (brainwash) The Cult of Intelligence (1974) but censored in the U.S. During her research and travels, Plaintiff made acquaintance with retired government employees and other spies, using remote viewing on their target and countless victims. Plaintiff also interviewed others and found millions of victims complaining of the same tactics and tortures from electricity and Energy. Plaintiff called Lt. Col. Tom Beardon in 2007, and spoke to his wife as he was on a respirator, Kathleen Sullivan (Mind Controlled CIA child whistleblower) who was frantic about nursing her husband with CANCER. Plaintiff has many other murders to report with Automobile accidents, suicide, and offered to testify to Congress. With the use of surveillance technology, spying, and NSA Transmission conducted by top secret, Q clearance, Defendants and DIA, Plaintiff hereby makes these serious accusations against the United States Secret Government for the past 50 years on U.S. Soil.

JURISDICTION AND VENUE

26. This court has subject matter jurisdiction over the federal claims pursuant to 28 U.S.C. § 1331, 18 U.S.C. § 2712, and 5 U.S.C. § 702.

27. Plaintiffs are informed, believe and thereon allege that Defendants have sufficient contacts with this

district generally and, in particular, with the events herein alleged, that Defendants are subject to the exercise

of jurisdiction of this court over the person of such Defendants and that venue is proper in this judicial district pursuant to 28 U.S.C. § 1391.

28. Plaintiff is informed, believe and thereon allege that a substantial part of the events giving rise to the claims herein alleged occurred in this district jurisdiction, and Defendants and/or agents of Defendants may be found in this district, nationally, and internationally.

PARTIES

29. Plaintiff, Mireille Torjman is an intelligent native French speaking refugee from Marrakesh, Morocco. Plaintiff is a divorced woman of 48 years of age and was an accountant for 25 years. Plaintiff comes from a religious background, disciplined and educated, has spent 25 years in the Philadelphia area, currently in South Florida with her Mother.

30. Defendant Federal Bureau of Investigations (FBI) is an agency under the direction and control of the Department of Justice and the Pentagon that investigates and protects the Nation with Programs of CointelPro joined by CIA operating on U.S. Soil.

31. Defendant Central Intelligence Agency (CIA) is an agency that protects the Country in first line of Defense and collects information that reveals the plans, intentions and capabilities of our adversaries and provides the basis for decision and action.

32. Defendant NSA Defendant National Security Agency (NSA) is an agency under the direction and control of the Department of Defense that collects, processes, and disseminates foreign signals intelligence. It is responsible for carrying out the Programs challenged herein.

33. Defendant United States is the United States of America, its departments, agencies, and entities. Including DOJ, and Congresswoman Ginny Browne-Waite as the current Florida Congress Representative of the United States, who Plaintiff attempted to warn on numerous occasions since early 2008 and Senator Bill Nelson, currently on Florida’s Intelligence Committee.

BACKGROUND

34. Counter Intelligence Program was a series of covert, and often illegal, projects conducted by the United States Federal Bureau of Investigation (FBI) aimed at investigating and disrupting dissident political organizations within the United States. The FBI used covert operations from its inception; however formal COINTELPRO operations took place between 1956 and 1971. The FBI’s stated motivation at the time was “protecting national security, preventing violence, and maintaining the existing social and political order.” According to FBI records, 85% of COINTELPRO resources were expended on infiltrating, disrupting, marginalizing, and/or subverting groups suspected of being subversive, such as communist and socialist organizations; the women’s rights movement; militant black nationalist groups, and the non-violent civil rights movement, including individuals such as Martin Luther King, Jr. and others associated with the Southern Christian Leadership Conference, the National Association for the Advancement of Colored People, the Congress of Racial Equality, the American Indian Movement, and other civil rights groups; a broad range of organizations labeled “New Left”, including Students for a Democratic Society, the National Lawyers Guild, the Weathermen, almost all groups protesting the Vietnam War, and even individual student demonstrators with no group affiliation; and nationalist groups such as those “seeking independence for Puerto Rico.” The other 15% of COINTELPRO resources were expended to marginalize and subvert “white hate groups,” including the Ku Klux Klan and National States’ Rights Party. The directives governing COINTELPRO were issued by FBI Director J. Edgar Hoover, who ordered FBI agents to “expose, disrupt, misdirect, discredit, or otherwise neutralize” the activities of these movements and their leaders. Hoover disclosed how horrific these weapons were thus, hard to believe. MKULTRA mind control experiments began at the end of WWII and then became public in the 1970’s, however imperfectly, and went ‘black” again because of Senate hearings, but these experiments have continued to this day. The only reason that MKULTRA was ever brought into the light of day was that a dissident group stole government documents and released them to the press, which initially refused to publish them. The MKULTRA archive was destroyed because of the seriousness of the crimes perpetrated by the intelligence communities. If it became public knowledge that the intelligence agencies had allowed Nazi war criminals to experiment upon American citizens, including children, and then replicated these techniques themselves, the damage to their reputation could never be undone. The only aspects of CIA criminal activity in general, or MKULTRA in particular, that the intelligence community ever admitted to were the ones that were already public, or details that had very little to do with the current capabilities of mind control weapons and techniques. Microwave weapons and remote influence of the Human Central Nervous System are the crown jewels of the intelligence community. The DEFENDER and AGILE Programs formed the foundation of DARPA sensor, surveillance, spying, and directed energy R&D, particularly in the study of radar, infrared sensing, and x-ray/gamma ray detection. During the late 1960s, with the transfer of these mature programs to the Services, ARPA redefined its role and concentrated on a diverse set of relatively small, essentially exploratory research programs. The Agency was renamed the Defense Advanced Research Projects Agency (DARPA) in 1972, and during the early 1970s, it emphasized direct energy programs, information processing, and tactical technologies.

Today we know we have had the Technology as warfare and/or medicine, coupled with the Conspiracy theories of HAARP, (Dr. Hubertus Strughold, space medicine-project paperclip-The Jewish Telegraphic Agency 1995; “Dark Moon; Apollo and Whistleblowers Second craft 11, shadowing Apollo 13” and technical difficulties with no witnesses returned. Issues of Mind Control reported by Dr. Rauni-Leena Luukanen Kilde – Nyhetsspeilet.no with 50 year old technology from our government being disclosed as new, have consistently been deceiving the public, while mapping out a grid across the Country. DUPLICITOUS and INDUCED manipulations of grave mass control escalations have been documented and quashed over the decades. Experiments under MK ULTRA for Behavior Modification also became corrupted for tax gains with massive funding to LEAA Law Enforcements while Crimes were induced in major cities in 1968 by 50% (Newsweek, FBI reports) Unwitting citizens blighted the courts with lawsuits, prisons and Hospitals in this Country with complaints of mind control that the Media refused to cover. This erupted suddenly and massively over one year. Today this continues tenfold and is still uncovered by media. Forty years later the COURTS are now being blighted with cases of privacy rights, War, and Technology combined. Thus we have an agenda of larger government and agencies, created for more tax dollars and controls. CONGRESS spinning their wheels instead of meeting once a year, as intended in the Constitution. A Country is being usurped since the 1910 secret meeting on Jekyll Island and a blank check to create “The Federal Reserve”.

35. Is the NSA Conducting Electronic Warfare On Americans?

Jonas Holmes May 19, 2006 CHRONICLE ARTICLE

Russ Tice, former NSA intelligence officer and current Whistleblower, was to testify before the Senate Armed Services Committee this week. Apparently the testimony, Mr. Tice wanted to give, makes General Hayden’s phone surveillance program look like very small potatoes. Mr. Tice’s testimony is expected to reveal further illegal activity overseen by General Michael Hayden which even loyal and patriotic NSA employees view as unlawful. I think the people I talk to next week are going to be shocked when I tell them what I have to tell them. IT’S PRETTY HARD TO BELIEVE, Tice said. I hope that they’ll clean up the abuses and have some oversight into these programs, which doesn’t exist right now. According to Mr. Tice, what has been disclosed so far is only the tip of the iceberg. What in the world could Russ Tice be talking about! To figure it out let us take a look at Russ Tice’s work at the NSA.

According to the Washington Times and numerous other sources, Mr. Tice worked on special access programs related to electronic intelligence gathering while working for the NSA and DIA, where he took part in space systems communications, non-communications signals, electronic warfare, satellite control, telemetry, sensors, and special capability systems. Special Access Programs or SAPs refer to Black Budgets or Black Operations. Black means that they are covert and hidden from everyone except the participants. Feasibly there would be no arena with a greater potential for abuse and misuse than Special Access Programs. Even now Congress and the Justice Department are being denied the ability to investigate these programs because they don’t have clearance. To put it in CNN’s Jack Cafferty’s words a top secret government agency, the NSA, the largest of its kind in the world, is denying oversight or investigation by the American people because investigators lack clearance. To add a layer of irony to the Black Ops cake this travesty is occurring in America, the supposed bastion of Freedom and Democracy, which we are currently trying to export to Iraq.

It just gets scarier. The Black Ops that Mr. Tice was involved in related to electronic intelligence gathering via space systems communications, non-communications signals, electronic warfare, satellite control, telemetry, sensors, and special capability systems. For greater insight as to the impact of these programs readers should review decades old FOIA authenticated programs such as MKULTRA, BLUEBIRD, COINTELPRO and ARTICHOKE. Radar based Telemetry involves the ability to see through walls without thermal imaging. Electronic Warfare is even scarier if we take a look at the science. NSA Signals Intelligence Use of EMF Brain Stimulation. NSA Signals Intelligence uses EMF Brain Stimulation for Remote Neural Monitoring (RNM) and Electronic Brain Link (EBL). EMF Brain Stimulation has been in development since the MKUltra program of the early 1950’s, which included neurological research into “radiation” (non-ionizing EMF) and bioelectric research and development. The resulting secret technology is categorized at the National Security Archives as “Radiation Intelligence,” defined as “information from unintentionally emanated electromagnetic waves in the environment, not including radioactivity or nuclear detonation.” Signals Intelligence implemented and kept this technology secret in the same manner as other electronic warfare programs of the U.S. government. The NSA monitors available information about this technology and withholds scientific research from the public. There are also international intelligence agency agreements to keep this technology secret.

The NSA has proprietary electronic equipment that analyzes electrical activity in humans from a distance. NSA computer-generated brain mapping can continuously monitor all the electrical activity in the brain continuously. The NSA records and decodes individual brain maps (of hundreds of thousands of persons) for national security purposes. EMF Brain Stimulation is also secretly used by the military for Brain-to-computer link. (In military fighter aircraft, for example.) For electronic surveillance purposes electrical activity in the speech center of the brain can be translated into the subject’s verbal thoughts. RNM can send encoded signals to the brain’s auditory cortex thus allowing audio communication direct to the brain (bypassing the ears). NSA operatives can use this to covertly debilitate subjects by simulating auditory hallucinations characteristic of paranoid schizophrenia. Without any contact with the subject, Remote Neural Monitoring can map out electrical activity from the visual cortex of a subject’s brain and show images from the subject’s brain on a video monitor. NSA operatives see what the surveillance subject’s eyes are seeing. Visual memory can also be seen. RNM can send images direct to the visual cortex. bypassing the eyes and optic nerves. NSA operatives can use this to surreptitiously put images in a surveillance subject’s brain while they are in R.E.M. sleep for brain-programming purposes. Individual citizens occasionally targeted for surveillance by independently operating NSA personnel

NSA personnel can control the lives of hundreds of thousands of individuals in the U.S. by using the NSA’s domestic intelligence network and cover businesses. The operations independently run by them can sometimes go beyond the bounds of law. Long-term control and SABOTAGE OF TENS OF THOUSANDS OF UNWITTING CITIZENS by NSA operatives is likely to happen. NSA Domint has the ability to covertly assassinate U.S. citizens or run covert psychological control operations to cause subjects to be diagnosed with ill mental health. National Security Agency Signals Intelligence Electronic Brain Link Technology NSA SigInt can remotely detect, identify and monitor a person’s bioelectric fields. The NSA’s Signals Intelligence has the proprietary ability to remotely and non-invasively monitor information in the human brain by digitally decoding the evoked potentials in the 30-50 hz,.5 milliwatt electro-magnetic emissions from the brain. Neuronal activity in the brain creates a shifting electrical pattern that has a shifting magnetic flux. This magnetic flux puts out a constant 30-50 hz, .5 milliwatt electromagnetic (EMF) wave. Contained in the electromagnetic emission from the brain are spikes and patterns called “evoked potentials.”

Every thought, reaction, motor command, auditory event, and visual image in the brain has a corresponding “evoked potential” or set of “evoked potentials.” The EMF emission from the brain can be decoded into the current thoughts, images and sounds in the subject’s brain.

NSA SigInt uses EMF-transmitted Brain Stimulation as a communications system to transmit information (as well as nervous system messages) to intelligence agents and also to transmit to the brains of covert operations subjects (on a non-perceptible level).

EMF Brain Stimulation works by sending a complexly coded and pulsed electromagnetic signal to trigger evoked potentials (events) in the brain, thereby forming sound and visual images in the brain’s neural circuits. EMF Brain Stimulation can also change a person’s brain-states and affect motor control. Two-way Electronic Brain-Link is done by remotely monitoring neural audio-visual information while transmitting sound to the auditory cortex (bypassing the ears) and transmitting faint images to the visual cortex (bypassing the optic nerves and eyes, the images appear as floating 2-D screens in the brain). Two-Way Electronic Brain Link has become the ultimate communications system for CIA/NSA personnel. Remote Neural Monitoring (RNM, remotely monitoring bioelectric information in the human brain) has become the ultimate surveillance system. It is used by a limited number of agents in the U.S. Intelligence Community. RNM requires decoding the resonance frequency of each specific brain area. That frequency is then modulated in order to impose information in that specific brain area. The frequency to which the various brain areas respond varies from 3 Hz to 50 Hz. Only NSA Signals Intelligence modulates signals in this frequency band.

An example of EMF Brain Stimulation: Brain Area

Bioelectric Resonance Frequency Information Induced Through Modulation

Motor Control Cortex 10 HZ Motor Impulse Co-ordination

Auditory Cortex 15 HZ Sound which bypasses the ears

Visual Cortex 25 HZ Images in the brain, bypassing the eyes

Somatosensory Cortex 09 HZ Phantom Touch Sense

Thought Center 20 HZ Imposed Subconscious Thoughts

This modulated information can be put into the brain at varying intensities from subliminal to perceptible. Each person’s brain has a unique set of bioelectric resonance/entrainment frequencies. Sending audio information to a person’s brain at the frequency of another person’s auditory cortex would result in that audio information not being perceived. Additionally, A 1994 congressional hearing reported that nearly half a million Americans were subjected to some kind of cold war era tests, often without being informed and without their consent. In addition, experimentation law is well grounded in constitutional and international law. It is an under-reported fact that two major reports on human rights and torture in the U.S. recently listed illegal radiation experiments. Many more facts are documented below. Therefore, human research subject protections should be a high priority and are just as significant as current issues of torture and illegal wiretapping. IT IS TIME FOR AMERICA TO WAKE UP. It is time for America to protect its Whistleblowers who are our last line of defense against dictatorship and despotism. It is time for America to take responsibility for oversight of its tax dollars and elect leaders who will assume such responsibility now. Yes, the war on terrorism is important. It is even more important and fearful if the terrorism is from within and unknowingly funded by hard working American citizens. There is no Special Access Program beyond the oversight of political leaders elected by the people and for the people. If these political leaders jeopardize national security then that shall be handled in a court of law. But to tell America, to tell the American people, to tell the political leaders elected by the American people that America does not deserve to know what happening in the NSA’s dark, black rooms, with billions of dollars, behind closed doors, when we know that privilege has already been abused; that is the true definition of TERRORISM. That is the true definition of Communism and a Police State, no oversight. So fellow Americans, you may hem and haw in the face of truth but know that one day you will realize that your country has been USURPED from the very principles upon which it was founded.

Godspeed, Russ Tice, the Patriots are with you.

Why hasn’t the press–aside from MSNBC–covered Russell Tice’s revelations on the government’s massive spy apparatus that according to Tice illegally survey’s every US citizens’ purchasing records, emails, phone calls, bank transactions, etc. and maintains the information in massive databases for nefarious uses?

In the Interview of January 03, 2006 the following was revealed:

AMY GOODMAN: That was Sibel Edmonds. Russell Tice, you are a member of her group, the National Security Whistleblowers Coalition.

AMY GOODMAN: What do you think of the Justice Department launching an investigation into the leak, who leaked the fact that President Bush was spying on American citizens?

RUSSELL TICE: Well, I think this is an attempt to make sure that no intelligence officer ever considers doing this. What was done to me was basically an attempt to tell other intelligence officers, ‘HEY, IF YOU DO SOMETHING LIKE THIS, IF YOU DO SOMETHING TO TICK US OFF, WE’RE GOING TO TAKE YOUR JOB FROM YOU, WE’RE GONNA DO SOME UNPLEASANT THINGS TO YOU.’

So, right now, the atmosphere at N.S.A. and D.I.A., for that matter, is fear. The security services basically rule over the employees with fear, and people are afraid to come forward. People know if they come forward even in the legal means, like coming to Congress with a concern, your career is over. And that’s just the best scenario. There’s all sorts of other unfortunate things like, perhaps, if someone gets thrown in jail for either a witch-hunt or something trumping up charges or, you know, this guy who is basically reporting a crime.

AMY GOODMAN: Were you ever asked to engage in this?

RUSSELL TICE: No, no, and if I did so, I did so unwittingly, which I have a feeling would be the case for many of the people involved in this. More than likely this was very closely held at the upper echelons at N.S.A., and mainly because these people knew—General Hayden, Bill Black, and probably the new one, Keith Alexander, they all knew this was illegal. So, you know, they kept it from the populace of N.S.A., because every N.S.A. officer certainly knows this is illegal.

AMY GOODMAN: What do you mean if you did so, you did so unwittingly?

RUSSELL TICE: Well, there are certain elements of the aspects of what is done where there are functionaries or technicians or analysts that are given information, and you just process that information. You don’t necessarily know the nitty gritty as to where the information came from or the—it’s called compartmentalization. It’s ironic, but you could be working on programs, and the very person sitting next to you is not cleared for the programs you’re working on, and they’re working on their own programs, and each person knows to keep their nose out of the other person’s business, because everything’s compartmentalized, and you’re only allowed to work on what you have a need to know to work on.

AMY GOODMAN: What about the telecoms, the telecommunications corporations working with the Bush administration to open up a back door to eavesdropping, to wiretapping?

RUSSELL TICE: If that was done and, you know, I USE A BIG “IF” HERE, AND, REMEMBER, I CAN’T TELL YOU WHAT I KNOW of how N.S.A. does its business, but I can use the wiggle words like “if” and scenarios that don’t incorporate specifics, but nonetheless, if U.S. gateways and junction points in the United States were used to siphon off information, I would think that the corporate executives of these companies need to be held accountable, as well, because they would certainly also know that what they’re doing is wrong and illegal. And if they have some sort of court order or some sort of paper or something signed from some government official, Congress needs to look at those papers and look at the bottom line and see whose signature is there. And these corporations know that this is illegal, as well. So everyone needs to be held accountable in this mess.

AMY GOODMAN: When you come on board at these intelligence agencies, as at the National Security Agency, what are you told? I mean, were you aware of the Church hearings in the 1970s that went into the illegal spying on monitoring, of surveilling, of wiretapping of American citizens?

RUSSELL TICE: Well, that’s something that’s really not drummed in your head. That’s more of a history lesson, I think. And the reasoning, ultimately, for the FISA laws and for what’s called USSID 18, which is sort of the SIGINTer’s bible of how they conduct their business, but the law itself is drilled into your head, as well as the tenets of USSID 18, of which the number one commandment is ‘Thou shalt not spy on Americans.’

But ultimately, when we’re using that on—if we’re using that with U.S. databases, then ultimately, once again, the American people are—their civil rights are being violated.

AMY GOODMAN: Do you expect you are being monitored, surveilled, wiretapped right now?

RUSSELL TICE: Yes, I do. As a matter of fact,

AMY GOODMAN: You’re saying in the leadership of your own agency, the National Security Agency?

RUSSELL TICE: That’s correct, yeah, because certainly General Alexander and General Hayden and Bill Black knew that this was illegal.

AMY GOODMAN: But they clearly had to have authorization from above, and Bush is not contending that he did not know.

RUSSELL TICE: Well, that’s true. But the question has to be asked: What did the President know? What was the President told about this? It’s just—there’s just too many variables out there that we don’t know yet. And, ultimately, I think Congress needs to find out those answers. If the President was fed a bill of goods in this matter, then that’s something that has to be addressed. Or if the President himself knew every aspect of what’s going on, if this was some sort of vacuum cleaner deal, then it is ultimately, I would think, the President himself that needs to be held responsible for what’s going on here.

AMY GOODMAN: This investigation that the Justice Department has launched—it’s interesting that Alberto Gonzales is now Attorney General of the United States—the latest story of The New York Times: Gonzales, when he was White House Counsel, when Andrew Card, chief of staff, went to Ashcroft at his hospital bedside to get authorization for this. Can he be a disinterested party in investigating this now, as Attorney General himself?

RUSSELL TICE: Yeah, I think that for anyone to say that the Attorney General is going to be totally unbiased about something like this, I think that’s silly. Of course, the answer is “No.” He can’t be unbiased in this. I think that a special prosecutor or something like that may have to be involved in something like this, otherwise we’re just liable to have a whitewash.

AMY GOODMAN: What do you think of the term “police state”?

RUSSELL TICE: Well, anytime where you have a situation where U.S. citizens are being arrested and thrown in jail with the key being thrown away, you know, potentially being sent overseas to be tortured, U.S. citizens being spied on, you know, and it doesn’t even go to the court that deals with these secret things, you know, I mean, think about it, you could have potentially somebody getting the wrong phone call from a terrorist and having him spirited away to some back-alley country to get the rubber hose treatment and who knows what else. I think that would kind of qualify as a police state, in my judgment. I certainly hope that Congress or somebody sort of does something about this, because, you know, for Americans just to say, ‘Oh, well, we have to do this because, you know, because of terrorism,’ you know, it’s the same argument that we used with communism years ago: take away your civil liberties, but use some threat that’s, you know, been out there for a long time.

Terrorism has been there for—certainly before 9/11 we had terrorism problems, and I have a feeling it’s going to be around for quite some time after whatever we deem is a victory in what we’re doing now in the Middle East. But, you know, it’s just something that has to be addressed. We just can’t continue to see our civil liberties degraded. Ultimately, as Ben Franklin, I think, had said, you know, those who would give up their essential liberties for a little freedom deserve neither liberty or freedom, and I tend to agree with Ben Franklin.

AMY GOODMAN: And your colleagues at the N.S.A. right now, their feelings, the National Security Agency?

RUSSELL TICE: Boy, I think most folks at N.S.A. right now are just running scared. They have the security office hanging over their head, which has always been a bunch of vicious folks, and now they’ve got, you know, this potential witch hunt going on with the Attorney General. People in the intelligence community are afraid. They know that you can’t come forward. You have no protections as a whistleblower. These things need to be addressed.

AMY GOODMAN: What do you mean you have no protection?

RUSSELL TICE: No. No, I do not. As far as—of course, I’m not witting of anyone that was told they will spy on an American. So, ultimately, when this was going on, I have a feeling it was closely held at some of the upper echelon levels. And you’ve got to understand, I was a worker bee. I was a guy that wrote the reports and did the analysis work and—you know, the detail guy. At some point, your reports have to get sent up up the line and then, you know, the management takes action at some point or another, but at my level, no, I was not involved in this.

RUSSELL TICE: I sent it to the chairs of the Senate Intelligence Committee and the House Intelligence Committee, the SSCI and the HPSCI.

The CIA and the cult of intelligence (1974) Reviewed by JamesRMacLean on 2007-04-09. Incompetence leads to Monstrosity Marchetti’s expose of the CIA was published on the eve of the Church Commission, at a moment when domestic outrage at the culture of duplicity and domestic interference had reached its peak. Since that time, successful public relations have greatly enhanced the image of intelligence services. Marchetti’s thesis is that, contrary to widespread public belief, the USA was not locked in an existential struggle with Soviet or Chinese subversion, and never really was. Soviet intelligence utterly surpassed the CIA in effectiveness, initiative, and recruitment of allied agents abroad. In fact, the CIA was effective only against 3rd world intelligence organizations, and there, spectacularly so. This extreme Soviet edge in espionage was more than offset by the superior resources of the conventional Western militaries and the impossibility of waging a direct confrontation owing to the nuclear stalemate. Worse, this advantage was not seriously mitigated by the abundance of high-tech gadgets, such as satellites; such tools merely facilitated the collection of large amounts of raw data, with virtually no practical usefulness.

Far from rendering the US intelligence community harmless, however, it made the agency focus on a campaign against 3rd world allies, and ultimately, against the US population. The CIA tried its hand at waging secret wars in Latin America, Southeast Asia, and Africa; it developed a vast group of businesses to serve as cover for illicit shipping and arms supplies; and it became utterly habituated to corrupting legislators in the Free World. The CIA became an eager tool for an unaccountable executive branch, provided that the executive had a flair for covert action; and it tended to create an echo chamber of self-deception that threatened the entire national security establishment. At the very top of its list of priorities was the urgent need to defend its mission publicly, and validate its immense budget. Marchetti spends a modest amount of time discussing the inability of the CIA to confront the Soviet KGB. When he mentions it, he avers the KGB and its allied bureaux are indeed odious, but also defensive–by necessity. He dwells in somewhat greater detail on the CIA’s structure and specialized fields of performance. He includes a broad-brush description of the overall US intelligence community, before turning to an analysis of the separate divisions and their respective behavior. This included covert operations (such as the Bay of Pigs invasion), proprietaries (such as Interarmco and Air America), propaganda and disinformation, and espionage/counterespionage. In all of these enterprises, the same motivation prevails: the CIA seeks self-perpetuation and influence WITHIN the Western world, but lacks will or ability to seriously combat the Soviets. Towards the end, he discusses the increasing tendency of the CIA to interfere in regular US politics, chiefly to ingratiate itself with the president.

Marchetti’s criticisms of the intelligence community were surprisingly mild. I should mention in passing that his book had about 170 or so passages deleted by court order; the CIA had earlier demanded well in excess of 300, and the court awarded it half of what it demanded. Some of the deletions are downright silly (as where it refers to a base in [DELETED] granted by Haile Selassie!), and elsewhere I was amused to observe the most numerous deletions in the part dealing with funding appropriations. The extreme secrecy of the intelligence community with respect to funding has greatly intensified since this book was published, and usually the motivation is quite obviously to conceal how much money these agencies actually waste. However, Marchetti concludes that the CIA is essentially past reform, useless, and so incompetent at its mission as to have become narrowly focused on extorting billions from the nation.

PSYCHOTRONIC WEAPONS

Former United States Government Physicist! 1981-Lt Col. US Army Retired, Pentagon analyst

(McRae, Ronald, Mind Wars, St. Martin’s Press, 1984, p 127)

In a slide Bearden illustrates how a Scalar War would involve a psychoenergetics attack on the operators of the enemy scalar installation, entraining their minds into hypnogogic trance and getting them to shut down their systems. And ultimately psychoenergetic warfare goes to the very heart of human identity itself. For if my thoughts might no longer be “mine,” then who and what am I? Can my very sense of being “me” be hijacked by some nefarious psychoenergetic scheme? One paper to begin with is “Mind Control and EM Wave Polarization Transductions” This is such serious stuff that Bearden includes a strong warning about misuse of this knowledge. Psychoenergetics weapons can MENTALLY MAIM AND PHYSICALLY KILL. “UNAWARE FORCED SPEECH by- passing memory, Channelled DREAMS, Split personalities etc.

SPACE PRESERVATION ACT-House Resolution (bill 2977)

Brain manipulation from a distance-2001-2002

Last year, in October, the Congressman Dennis J. Kucinich introduced in the American Congress a bill, obliging the American president to get engaged in the negotiations aimed at the ban of space based weapons. In this bill the definition of a weapon system includes: any other unacknowledged or as yet undeveloped means inflicting death or injury on, or damaging or destroying, a person (or the biological life, bodily health, mental health, or physical and economic well-being of a person) through the use of land-based, sea-based, or space-based systems using radiation, electromagnetic, psychotronic, sonic, laser, or other energies directed at individual persons or targeted populations or the purpose of information war, mood management, or mind control of such persons or populations” (12). As in all legislative acts quoted in this article the bill counts with sound, light or electromagnetic stimulation of human brain. Psychotronic weapons remain, at least for a layman uninformed of secret military research, in the sphere of science fiction, since so far none of the published scientific experiments was presented in the way which would allow for its replication. That it is feasible to manipulate human behavior with the use of subliminal, either sound or visual, messages is now generally known. This is why in most of the countries the use of such technologies, without consent of the user, is banned. Devices using light for the stimulation of the brain show another way how the light flashing in certain frequencies could be used for the manipulation of human psychic life. As for the sound, a report on the device transmitting a beam of sound waves, which can hear only persons at whom the beam of sound waves is targeted, appeared last year in the world newspapers. The beam is formed by a combination of sound and ultrasound waves which causes that a person targeted by this beam hears the sound inside of his head. Such a perception could easily convince the human being that it is mentally ill. The acts presented in this article suggest that with the development of technology and knowledge of the functioning of human brain new ways of manipulation of human mind keep emerging. One of them seems to be the electromagnetic energy.

Though in the open scientific literature only some 30 experiments were published, supporting this assumption (1),(2), already in 1974, in the USSR, after successful testing with military unit in Novosibirsk, the installation Radioson (Radiosleep) was registered with the Government Committee on the Matters of Inventions and Discoveries of the USSR, described as a method of induction of sleep by means of radio waves (3), (4), (5)…

Dear Senator-Attorney Letter included:

We seek your office’s assistance in initiating hearings and a fact-finding congressional inquiry into the government agencies and/or private companies that are targeting citizens. Many citizens are desperate to be freed from the disturbing, intrusive and oppressive targeting.

Evidence supports the conclusion that weapons exist that could be used against individuals, based on U.S. Patent and Trademark Office filings, public releases by agencies, and other technologies that indicate the level of technological sophistication. The weapons are believed to be based on electromagnetism, microwaves, sonic waves, lasers and other types of directed energy, and were characterized as “psychotronic” in Rep. Dennis Kucinich’s draft of House Resolution 2977, the Space Preservation Act of 2001. Furthermore, it is undeniable that government agencies have tested citizens without permission in the past; for example, the CIA’s human experimentation discussed in Orlikow v. U.S., 682 F.Supp. 77 (D.D.C. 1988), secretly administered lysergic acid diethylamide discussed in United States v. Stanley, 483 U.S. 669 (1987), and military chemical experimentation as discussed in Congressional Committee Report 103-97, 103d Congress, 2d Session, S. Prt. 103-97 (Dec. 8, 1994). Lastly, the sheer numbers of people complaining of being targeted, including people with post-graduate degrees and a lifetime of achievements, and the similarities in symptoms tend to outweigh a dismissive response based on charges of anecdotal evidence or group paranoia.

there is a certain risk of sounding too conspiratorial, however, common denominators such as physical symptoms and medical reports, surveillance scenarios, harassment techniques, and more can be readily established.

Very truly yours,

36. Around January 2003, the NSA designed and implemented a program “THE DRAGNET” in collaboration with AT&T to build a surveillance operation at AT&T’s Folsom Street Facility, inside a secret room known as the “SG3 Secure Room”. In February 2003, the “Splitter Cabinet” split diverting to and from Qwest, XO, PAIX, Allegiance, and many more Service Providers at the SG3 Location.

37. As some “X or zero” files kept covertly in Silicon Valley and NSA and “Data Mining” with SIG-INT Satellites used as the scapegoat of illegal covert spying of 50 years. Plaintiff received communication through Qwest and T-Mobile, and many other carriers that were tampered with, Plaintiff found her computer files wiped out for over one year (2007-2008 of all her Government research and email communications to the public, since she began attempts for help, and notified Qwest of the activities behind the scenes as they had found them undetectable. Plaintiff’s communications verbally and electronically, including facsimiles, muting one party in conversation to sabotage meaning, emails were intercepted and manipulated, as destroyed documents, videos, and photographs, preventing the reporting her story and the torture and abuse to non-conspiring authorities and individuals.

38. Defendant’s daily tortures are being done without judicial, statutory, or other lawful authorization, in violation of statutory and constitutional limitations, and in excess of statutory and constitutional authority.

39. Defendants’ daily tortures are being done without probable cause or reasonable suspicion to believe that Plaintiff has committed or are about to commit any crime or engage in any terrorist activity.

40. Defendants’ daily tortures are being done without probable cause or reasonable suspicion to believe that Plaintiff is of foreign powers or agents thereof and these activities are crimes of humanity.

41. Defendants’ daily tortures are being done without any reason to believe that the information is relevant to an authorized criminal investigation or to an authorized investigation to protect against international terrorism or clandestine intelligence activities.

42. Plaintiff was targeted in 1996 for 5 years of her life, unwittingly after calling the FBI from her work place and was told “They were already on it”. On another experiment for war allies, Plaintiff, UNREALIZED, was told she was free and arrived in San Diego 5 days later on 9/11/01. Plaintiff flew to Atlanta wondering why she was invited to sit in a co-pilot’s chair on the runway, while waiting to take off from snow on the ground, in the height of the new steel door installation climate and high security. This information was sent to the U.N. BEFORE the Buffalo crash. In her Florida home, early 2007, naive and without knowledge of corruptions, wars, or weapons, Plaintiff was comatosed for 72 hours and her memory began to be wiped out each night and corrupted with transmissions in each day. Plaintiff ran away TERRORIZED after being transmitted to start “THE PROCESS”, which today she knows was to brainwash her into the cult of intelligence and experiments. Plaintiff left her home terrorized and traveled around the world programmed to keep copious notes. Plaintiff was attacked for no reason on the streets, by UNREALIZED doctors, by kids, dogs, on planes (International Airways), and was held hostage in a food establishment in Nice when on her way to whistle blow the information to other embassies. Plaintiff had her house contents hijacked from AZ, leaving her homeless numerous times to sabotage her life and work and was falsely detained upon each attempt to whistle blow. Plaintiff was transmitted to send a letter to FBI Director Mueller, demanding to cease and invert her family, when she returned from AZ in February of 2008. Plaintiff was informed that it was too late as they had already “gotten to him” and she would never be believed. Not until one year later in February 2009, someone sent Plaintiff an email of the Russell Tice article and Plaintiff IMMEDIATELY came to DC in April 2009 to talk with DOJ Officials and their Attorneys. Plaintiff’s many computers and car batteries, etc were zapped the same day again while en route. Plaintiff’s communication chaos with NSA transmissions sabotaged her life, and others with unwitting false memories. In January 2010 Plaintiff was told her surveillance/spying recordings could be sold overseas and that the FBI had joined forces with the Shadow Government to suppress her further from whistle blowing. Plaintiff’s behavior was modified and resembled what she found on u-tube in the 911 brainwashing process to the public for Weapons of Mass Destruction (the opposite of most news reports). Plaintiff was jacketed (against each other) and isolated during the 4 years Defendants’ daily tortures against her will and religion is directly performed, and/or aided, abetted, counseled, commanded, induced or procured, by Defendants. On information and belief, Defendants will continue to directly target the Plaintiff and the Public and /or will continue to aid, abet, counsel, command, induce or procure that conduct. (Mind Control and the American Government; “Prevailing Winds” 1994) On information and belief, since Tesla’s Directed Energy Weapons were invented and launched or picked up by DOD covert ops, The United States unlike the rest of the Globe, rapidly began down a culture of Cancer, corruptions, crimes (another experiment in 1968 on crimes in major cities hidden behind LSD like aliens) paranoia, immoral behaviors, AIDS, ANTHRAX, obesity, division, Trash TV, paranormal phenomenon, and a greater necessity of guinea pigs for TECHNOLOGY experimentation and corruptions.

“When even one American -who has done nothing wrong- is forced by fear to shut his mind and close his mouth, then all Americans are in peril.” Harry S. Truman

43. Plaintiff seeks costs, legal fees, and damages applicable by law with protective measures for all COUNTS. Plaintiff was represented under a class suit, before transmissions sabotaged the attorney and his contact information has been disconnected and tampered with. On information and belief, the former attorney may have had brain surgery from Migraines while preparing the Complaint funded by and San Francisco University, after my visit with him to Denver and may be overseas at this time.

ALLEGATIONS also included in Plaintiff’s NSA and/or Electronic Communications

44. Pursuant to Federal Rules of Civil Procedure, Title 5, 22, 42, 142, 18, 18a, and 50, Plaintiff Mireille Torjman brings this action on behalf of herself, and to attest to her family and the public’s victimization, unwittingly and/or unrealized:

(a) TITLE 18 PART I CHAPTER 37 § 793. Gathering, transmitting or losing defense information,

(b) 18 U.S.C. § 241. Conspiracy against rights,

(c) 18 U.S.C. § 373. Solicitation to commit a crime of violence,

(d) 18 U.S.C. § 1091. Genocide,

(e) 18 U.S.C. § 1341. Mail fraud,

(f) 18 U.S.C. § 1512. Tampering with a witness, victim, or an informant,

(g) 18 U.S.C. § 1513. Retaliating against a witness, victim, or an informant,

(h) 18 U.S.C. § 1583 (2). Enticement into slavery,

(i) 18 U.S.C. § 1692. Foreign mail as United States mail,

(j) 18 U.S.C. § 1801. Video voyeurism,

(k) 18 U.S.C. § 1812. Statement of exclusive means by which electronic surveillance and interception of certain communications may be conducted,

(l) 18 U.S.C. § 2242. Sexual abuse,

(m) 18 U.S.C. § 2332 (a) Terrorism, and (h). Use of weapons of mass destruction,

(n) 18 U.S.C. § 2339. Harboring or concealing terrorists,

(o) 18 U.S.C. § 2422. Coercion and enticement, or are currently doing so;

(p) Defendants have subjected the public to electronic surveillance, in violation of 50 U.S.C. § 1809 and 1810, or are currently doing so;

(q) Defendants are intercepting communications in violation of 18 U.S.C. § 2510 and 18 U.S.C. § 2511;

(r) Defendants have transmitted Plaintiff and the public in violation of 18 U.S.C. § 2703, Required Disclosure of communications records, or are currently doing so;

(s) Defendants have transmitted civilians, and non civilians, in violation of 18 U.S.C. § 2381. Treason, or are currently doing so;

(t) Defendants have harassed and transmitted the public to stalk and harass the Plaintiff inclusive of electronically and tangibly, in violation of 18 U.S.C. § 2261: US Code – 2261A: Stalking

(u) Plaintiff was falsely detained and sabotaged with the use of mind control transmissions violating 18a U.S.C. Rule 41. Search and Seizure

(v) Defendants have violated the Administrative Procedures Act, 5 U.S.C. §§ 701 et seq., or are currently doing so;

(w) Defendants have violated the constitutional principle of separation of powers, or are currently doing so;

(x) Defendants have Tortured Plaintiff, her family, and the public electronically in violation of 18 U.S.C. § 2340A, or currently doing so:

(y) Plaintiff is entitled to injunctive, declaratory, and other equitable relief against defendants and freedom from further threats, family, accidents, psychological and physical harm, illnesses, sabotage, bribes, and blackmail;

(z) Defendants have Tortured Plaintiff, her family and the public electronically in violation of 18 U.S.C. § 2422, or currently doing so:

(aa) Plaintiff is entitled to Civil Damages 18 U.S.C. § Rule 2520 in violations of her First, Third, Fifth, and Thirteenth Amendments; 18 U.S.C. § 2510, 18 U.S.C. § 2511, and 18 U.S.C. § 2512.

(ab) Plaintiff is entitled to Grants and Health Care Assistance as a victim in accordance to 22 U.S.C. § 2152: US Code – Section 2152: Assistance for victims of torture.

(ac) United Nations Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, G.A. res. 39/46, annex, 39 U.N. GAOR Supp. (No. 51) at 197, U.N. Doc. A/39/51 (1984), entered into force June 26, 1987; Universal Declaration of Human Rights, G.A. res. 217A (III), U.N. Doc. A/810 at 71 (1948); International Convention on Civil and Political Rights, G.A. res. 2200A (XXI), 21 U.N. GAOR Supp. (No. 16) at 52, U.N. Doc. A/6316 (1966), 9.99 U.N.T.S. 171, entered into force Mar. 23, 1976.

(ad) Defendants have Tortured Plaintiff, her family and the public and the prohibitions against torture and other cruel, inhuman, or degrading treatment and the conspiracy to oppress, torture, rape, suppress, is a violation under 142 U.S.C.§ 1985. Conspiracy to interfere with United States Civil Rights.

(ae) Defendants have Tortured Plaintiff, her family and the public and the prohibitions against malicious intent to torture, rape privacy rights, brainwash, and enslave with severe psychological in-humane damages to one’s spirit, and libel is actionable under Tort Claims of damages found under civil and criminal trials.

(af) Plaintiff has made at least 2 requests to the FOIA and both dossiers were denied under the violation of 5 U.S.C. § 552; claims under and 18 U.S.C. § 2707 and 5 U.S.C. § 702

42. Adequacy: Plaintiff and family members are suffering great harm arising from Defendants’ violations of law, as alleged herein. Plaintiff intends to prosecute this action vigorously. Plaintiff hereby demands injunctive relief and damages.

COUNT I

Violation of 18 U.S.C. and 50 U.S.C. Crimes and Criminal Procedures AND War and National Defense Including Titles 5, 22, 42, 142, 18, 18a, and 50 U.S.C. and International Conventional

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

43. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

44. Plaintiff is seeking protection for her and for all family members under the law TITLE 18 U.S.C. § 3521. Witness relocation and protection.

COUNT II

Violation of First and Fourth Amendments, 42 U.S.C and 18 U.S.C. and 50 U.S.C. Crimes and Criminal Procedures AND War and National Defense Including Titles 22, 42, 142, 18, 18a, and 50 U.S.C. and International Conventional

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

45. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

46. Plaintiff motions the COURTS and Defendants to cease and desist and/or injunction for relief, immediately from grave dangerous damaging electronic harassments and that of a religious and personal nature, all other allegations of surveillance, spying, manipulations, torture, censorships, daily sabotage, and blocks electronically and otherwise, retaliations, death threats, thereby violating the constitution and privacy acts, (US code 22, 42, 142, 18, 18a, and 50) at the hands of, the direction of, or with the knowledge of, any and all government and affiliations. Plaintiff seeks declaratory relief against all allegations and all counts. Defendant’s actions described herein violated Plaintiff’s rights under the Free Exercise and Free Speech Clauses of the United States Constitution, the Religious Freedom Restoration Act of 1993, 42 U.S.C. § 2000bb et seq., the Privacy Act, 5 U.S.C. § 552a, and Air Force Instruction 37-132; and all other freedoms and rights under the Law.

COUNT III

Violation of 18 U.S.C. and 50 U.S.C. Crimes and Criminal Procedures AND War and National Defense Including Titles 5, 22, 42, 142, 18, 18a, and 50 U.S.C. and International Conventional

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

47. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

48. Plaintiff numerous attempts sabotaged, hereby requests to compel the court for Defendants to conduct proper and thorough investigations (not failing to include fundamental steps of interviews and psyops techniques on U.S. Soil) even when seemingly undetectable and/or prior to 2008, with all accusations and agencies with full cooperation, including Sports, Cloning, ENGINEERED Poverty-Bankruptcies with individuals with Cancer, also to sabotage economies, under the Law.

COUNT IV

Violation of First Amendment—Declaratory, Injunctive, and Other Equitable Relief

Violation of 18 U.S.C. and 50 U.S.C. Crimes and Criminal Procedures AND War and National Defense Including Titles 22, 42, 142, 18, 18a, and 50 U.S.C. and International Conventional

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

49. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

50. Plaintiff has been sabotaged with proper coverage to expose and warn the public. Plaintiff requests to compel the court for Defendants to provide the Constituents “WE THE PEOPLE” with un-tampered accurate news, APPROPRIATE WARNINGS with Main Stream Media: to heed caution, and be AWARE with knowledge, and choice of action or recourse, under the law of Constituents rights and United States Constitution.

COUNT V

Violation of Fourth Amendment—Declaratory, Injunctive, and Equitable Relief 108.

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

51. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law and aforementioned Amendments of the Constitution, as stated above.

52. Plaintiff is seeking protection for her and for all family members under the law.

53. Plaintiff and have a reasonable expectation of privacy in their communications and/or records, mail communications, as forementioned above, DNA, brain waves, brain activities, brain manipulations, brain recordings, data mining, collected, and/or stored by these activities.

54. Plaintiff have expectations of complete privacy to the intrusions of their minds and bodies, threats and fears, blackmail and choice, thus freedom of thought, emotion, will, and destiny.

55. Defendants have directly performed, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of the above-described acts of spying, torture, interception, and/or use of Plaintiff and her activities, by Intelligence, covertly without judicial or other lawful authorization, probable cause, and/or individualized suspicion, in violation of statutory and constitutional limitations, and in excess of statutory and constitutional authority.

56. At all relevant times, Defendants committed, knew of and/or acquiesced in all of the above-described acts, and failed to respect the Constitutional rights of the Plaintiff by obtaining judicial or other lawful authorization and by conforming their conduct to the requirements of the respective Amendments, under the Law of the United States Constitution.

57. By the acts alleged herein, Defendants have violated Plaintiffs’ reasonable expectations of privacy and denied Plaintiff her right to be free from unreasonable searches and seizures as guaranteed by the Fourth Amendment to the Constitution of the United States. By the acts alleged herein, as a victim of the Programs, Defendants violated Plaintiff’s rights of the Fourth Amendment to be free from unreasonable searches and seizures, as guaranteed by the Fourth Amendment of the United States Constitution.

58. By the acts alleged herein, Defendants’ conduct has caused harm to Plaintiff and her family.

59. Defendants’ conduct was done intentionally, with malice and deliberate indifference, against her will and religion, and/or with reckless disregard of, negligent, forceful, trickery, pleasure, premediated conspiracy, in gross violations of Plaintiff constitutional rights.

60. On information and belief, the Count V and all other pertaining Counts Defendants are now engaging in and will continue to engage in the above-described violations of Plaintiffs’ constitutional rights, and are thereby irreparably harming Plaintiff. Plaintiff have no adequate remedy at law for the Count V and all other pertaining Counts to Defendants’ continuing unlawful conduct, and the Count V and all other pertaining Counts Defendants will continue to violate Plaintiffs’ legal rights unless enjoined and restrained by this Court.

61. Plaintiff seeks that this Court declare that Defendants have violated their rights and the rights of the public; enjoin the Count V Defendants, their agents, successors, and assigns, and all those in active concert and participation with them from violating the Plaintiffs’ rights under the Fourth Amendment and respective Amendments, to the United States Constitution; and award such other and further equitable relief as is proper.

COUNT VI

Violation of Fourth Amendment—Damages

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

62. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

63. Plaintiff have a reasonable expectation of privacy in their communications and/or records, mail, communications, Transmissions, intrusions, spying, by all means including electronics and waves as forementioned by Defendants.

64. Plaintiff have expectations of privacy to the atrocious intrusions and gross negligence.

65. Defendants have directly performed, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of the above-described acts of acquisition, interception, disclosure, divulgence and/or use of communications, contents of communications, and records pertaining to their communications transmitted, collected, DNA and brain waves from Data Mining and remote transmissions, and/or stored, spying, torture, by Defendants without judicial or other lawful judicial or other lawful authorization, probable cause, and/or individualized suspicion, in violation of statutory and constitutional limitations, and in excess of statutory and constitutional authority.

66. Defendants, and/or the use of electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of interceptions, disclosure and/or use of Plaintiff mind and body, DNA and brain waves from Data Mining and remote transmissions, communications, contents of communications, and records pertaining to their transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and/or individualized suspicion of Plaintiff’s records or other information.

67. At all relevant times, Defendants committed, knew of and/or acquiesced, enjoyed all of the above-described acts, and failed to respect the Fourth Amendment rights of Plaintiffs by obtaining judicial or other lawful authorization, and by conforming their conduct to the requirements of the requirements of the respective Amendments.

68. By the acts alleged herein, Defendants have violated Plaintiffs’ reasonable expectations of privacy and denied Plaintiffs their right to be free from unreasonable searches and seizures as guaranteed by the Fourth Amendment to the Constitution of the United States.

69. By the acts alleged herein, Defendants’ conduct has caused harm to Plaintiff.

70. Defendants’ conduct is being done intentionally and with malice, with deliberate indifference, or with reckless disregard of, Plaintiffs’ constitutional rights.

71. Plaintiff seeks an award of her actual damages and punitive damages against the Counts III and V Defendants, and such other or further relief as is proper.

COUNT VII

Violation of First Amendment—Declaratory, Injunctive, and Other Equitable Relief

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

72. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

73. Plaintiff use of communications anonymously and to associate privately and securely with freedoms as their Constitution Rights.

74. Defendants have directly performed, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to negligently contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of the above-described acts of acquisition, interception, disclosure, divulgence and/or use of Plaintiff and Plaintiff’s communications, contents of communications, and records pertaining to their communications transmitted, collected, DNA and brain waves from any Data Mining and remote transmissions, and/or stored, spying, torture, by Defendants without judicial or other lawful judicial or other lawful authorization, probable cause, and/or individualized suspicion, in violation of statutory and constitutional limitations, and in excess of statutory and constitutional authority.

75. Defendants, and/or the use of electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of acquisition interception, disclosure, divulgence, and/or use of Plaintiff and communications, mind and body, DNA and brain waves, Data Mining and remote transmissions, contents of communications, and records pertaining to their communications transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and/or individualized suspicion of Plaintiff’s records or other information without judicial or other lawful authorization, probable cause, and/or individualized suspicion.

76. By the acts alleged herein, Defendants’ violated Plaintiff’s rights to speak and receive speech anonymously and associate privately under the First Amendment.

77. By the acts alleged herein, Defendants’ conduct proximately caused harm to Plaintiff.

78. Defendants’ conduct was done intentionally, with malice and intent, with deliberate indifference, with reckless disregard, and negligence, Plaintiff constitutional rights were grossly violated.

79. On information and belief, the Count VII Defendants are now engaging in and will continue to engage in the above-described violations of Plaintiff’s constitutional rights, and are thereby irreparably harming Plaintiff. Plaintiff has no adequate remedy at law for the Count VII Defendants’ continuing unlawful conduct, and the Count VII Defendants will continue to violate Plaintiff legal rights unless enjoined and restrained by this Court.

80. Plaintiffs seek that this Court declare that Defendants have violated their rights; enjoin the Count VII Defendants, their agents, successors, and assigns, and all those in active concert and participation with them from violating the Plaintiff rights under the First Amendment to the United States Constitution; and award such other and further equitable relief as is proper.

COUNT VIII

Violation of First Amendment—Damages

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

81. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

82. Plaintiff use of communication with privacy to speak or receive speech anonymously and to associate privately.

83. Defendants have directly performed, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to negligently contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of the above-described acts of acquisition, interception, spying, disclosure, divulgence and/or use of Plaintiff and Plaintiff’s communications, contents of communications, and records pertaining to their communications transmitted, collected, DNA and brain waves from any Data Mining and remote transmissions, and/or stored, spying, torture, by Defendants without judicial or other lawful judicial or other lawful authorization, probable cause, and/or individualized suspicion, in violation of statutory and constitutional limitations, and in excess of statutory and constitutional authority.

84. By the acts alleged herein, Defendants violated Plaintiffs’ rights to speak and receive speech anonymously and associate privately under the First Amendment.

85. By the acts alleged herein, Defendants’ conduct proximately caused harm to Plaintiff.

86. Defendants’ conduct was done intentionally, with malice and sadistic pleasure, with deliberate indifference, or with reckless disregard of, Plaintiff constitutional rights.

87. Plaintiff seeks an award of her actual damages and punitive damages against the Counts IV and VIII Defendants, and for such other or further relief as is proper.

COUNT IX

Violation of Foreign Intelligence Surveillance Act—Declaratory, Injunctive and Other Equitable Relief

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

88. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

89. In relevant part, 50 U.S.C. § 1809 provides that:

(a) Prohibited activities—A person is guilty of an offense if he intentionally—(1) engages in electronic surveillance under color of law except as authorized by this chapter, chapter 119, 121, or 206 of Title 18 or any express statutory authorization that is an additional exclusive means for conducting electronic surveillance under section 1812 of this title; or (2) discloses or uses information obtained under color of law by electronic surveillance, knowing or having reason to know that the information was obtained through electronic surveillance not authorized by this chapter, chapter 119, 121, or 206 of Title 18 or any express statutory authorization that is an additional exclusive means for conducting electronic surveillance under section 1812 of this title.

90. In relevant part 50 U.S.C. § 1801 provides that:

(f) “Electronic surveillance” means – (1) the acquisition by an electronic, mechanical, or other surveillance device of the contents of any wire or radio communication sent by or intended to be received by a particular, known United States person who is in the United States, if the contents are acquired by intentionally targeting that United States person, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes; (2) the acquisition by an electronic, mechanical, or other surveillance device of the contents of any wire communication to or from a person in the United States, without the consent of any party thereto, if such acquisition occurs in the United States, but does not include the acquisition of those communications of computer trespassers that would be permissible under section 2511(2)(i) of Title 18; (3) the intentional acquisition by an electronic, mechanical, or other surveillance device of the contents of any radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes, and if both the sender and all intended recipients are located within the United States; or (4) the installation or use of an electronic, mechanical, or other surveillance device in the United States for monitoring to acquire information, other than from a wire or radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes.

91. 18 U.S.C. § 2511(2)(f) further provides in relevant part that “procedures in this chapter or chapter 121 and the Foreign Intelligence Surveillance Act of 1978 shall be the exclusive means by which electronic surveillance, as defined in section 101 [50 U.S.C. § 1801] of such Act, and the interception of domestic wire, oral, and electronic communications may be conducted.” (Emphasis added.)

92. 50 U.S.C. § 1812 further provides in relevant part that:

(a) Except as provided in subsection (b), the procedures of chapters 119, 121, and 206 of Title 18 and this chapter shall be the exclusive means by which electronic surveillance and the interception of domestic wire, oral, or electronic communications may be conducted.

(b) Only an express statutory authorization for electronic surveillance or the interception of domestic wire, oral, or electronic communications, other than as an amendment to this chapter or chapters 119, 121, or 206 of Title 18 shall constitute an additional exclusive means for the purpose of subsection (a).

(Emphasis added.)

93. Defendants intentionally acquired, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, negligently contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of such acquisition, by means of a surveillance and spying devices, the contents of one or more wire and wireless communications to or from Plaintiff or other information in which Plaintiff has a reasonable expectation of privacy, without the consent of any party thereto, and such acquisition occurred in the United States and overseas.

94. Defendants, and/or other electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of acquisition of Plaintiffs’ communications, interceptions, disclosure and/or use of Plaintiff mind and body, DNA and brain waves from Data Mining, remote transmissions, communications records, and contents of communications, pertaining to their transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and individualized suspicion of Plaintiff’s records and information.

95. By the acts alleged herein, Defendants acting in excess of their statutory authority and in violation of statutory limitations have intentionally engaged in, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, negligently contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of, electronic surveillance (as defined by 50 U.S.C. § 1801(f)) under color of law, not authorized by any statute, to which Plaintiff were subjected in violation of 50 U.S.C. § 1809.

96. Additionally or in the alternative, by the acts alleged herein, Defendants acting in excess of their statutory authority and in violation of statutory limitations have intentionally disclosed or used information obtained under color of law by electronic surveillance, knowing or having reason to know that the information was obtained through electronic surveillance and spying not authorized by statute, including information pertaining to Plaintiff, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of such acts.

97. Defendants did not notify Plaintiff of the above-described electronic surveillance, disclosure, and/or use, nor did Plaintiffs or class members consent to such.

98. Plaintiff have been and are aggrieved by Defendants’ electronic surveillance, and spying , disclosure, and/or use of their wire communications.

99. On information and belief, the Count IX Defendants are now engaging in and will continue to engage in the above-described acts resulting in the electronic surveillance, spying, disclosure, and/or use of Plaintiff wire communications, acting in excess of the Count IX Defendants’ statutory authority and in violation of statutory limitations, including 50 U.S.C. § 1809 and 18 U.S.C. § 2511(2)(f), and are thereby irreparably harming Plaintiff and Plaintiff’s family. Plaintiffs has no adequate remedy at law for the Count IX Defendants’ continuing unlawful conduct, and the Count IX Defendants will continue to violate Plaintiff legal rights unless enjoined and restrained by this Court.

100. Pursuant to Larson v. United States, 337 U.S. 682 (1949) and to 5 U.S.C. § 702,

Plaintiff seeks that this Court declare that Defendants have violated their rights and the rights of the class; enjoin the Count IX Defendants, their agents, successors, and assigns, and all those in active concert and participation with them from violating the Plaintiff’s statutory rights, including their rights under 50 U.S.C. §§ 1801 et seq.; and award such other and further equitable relief as is proper.

COUNT X

Violation of 50 U.S.C. § 1809, actionable under 50 U.S.C. § 1810—Damages

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

101. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

102. In relevant part, 50 U.S.C. § 1809 provides that:

(a) Prohibited activities—A person is guilty of an offense if he intentionally—(1) engages in electronic surveillance under color of law except as authorized by this chapter, chapter 119, 121, or 206 of Title 18 or any express statutory authorization that is an additional exclusive means for conducting electronic surveillance under section 1812 of this title; or (2) discloses or uses information obtained under color of law by electronic surveillance, knowing or having reason to know that the information was obtained through electronic surveillance not authorized by this chapter, chapter 119, 121, or 206 of Title 18 or any express statutory authorization that is an additional exclusive means for conducting electronic surveillance under section 1812 of this title.

103. In relevant part 50 U.S.C. § 1801 provides that:

(f) “Electronic surveillance” means – (1) the acquisition by an electronic, mechanical, or other surveillance device of the contents of any wire or radio communication sent by or intended to be received by a particular, known United States person who is in the United States, if the contents are acquired by intentionally targeting that United States person, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes; (2) the acquisition by an electronic, mechanical, or other surveillance device of the contents of any wire communication to or from a person in the United States, without the consent of any party thereto, if such acquisition occurs in the United States, but does not include the acquisition of those communications of computer trespassers that would be permissible under section 2511(2)(i) of Title 18; (3) the intentional acquisition by an electronic, mechanical, or other surveillance device of the contents of any radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes, and if both the sender and all intended recipients are located within the United States; or (4) the installation or use of an electronic, mechanical, or other surveillance device in the United States for monitoring to acquire information, other than from a wire or radio communication, under circumstances in which a person has a reasonable expectation of privacy and a warrant would be required for law enforcement purposes.

104. 18 U.S.C. § 2511(2)(f) further provides in relevant part that “procedures in this chapter or chapter 121 and the Foreign Intelligence Surveillance Act of 1978 shall be the exclusive means by which electronic surveillance, as defined in section 101 [50 U.S.C. § 1801] of such Act, and the interception of domestic wire, oral, and electronic communications may be conducted.” (Emphasis added.)

105. 50 U.S.C. § 1812 further provides in relevant part that:

(a) Except as provided in subsection (b), the procedures of chapters 119, 121, and 206 of Title 18 and this chapter shall be the exclusive means by which electronic surveillance and the interception of domestic wire, oral, or electronic communications may be conducted.

(b) Only an express statutory authorization for electronic surveillance or the interception of domestic wire, oral, or electronic communications, other than as an amendment to this chapter or chapters 119, 121, or 206 of Title 18 shall constitute an additional exclusive means for the purpose of subsection (a). (Emphasis added.)

106. Defendants intentionally acquired, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, (negligent), facilitated, directed, controlled, assisted in, or conspired in the commission of such acquisition, by means of a surveillance and spying devices, the contents of one or more wire and wireless communications to or from Plaintiff or other information in which Plaintiff has a reasonable expectation of privacy, without the consent of any party thereto, and such acquisition occurred in the United States.

107. Defendants, and/or other electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of acquisition of Plaintiffs’ communications, interceptions, disclosure and/or use of Plaintiff mind and body, DNA and brain waves from Data Mining and remote transmissions, communications, contents, and records pertaining to their transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and/or individualized suspicion of Plaintiff’s records or other information.

108. By the acts alleged herein, Defendants have intentionally engaged in, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, (negligent), facilitated, directed, controlled, assisted in, or conspired in the commission of, electronic surveillance (as defined by 50 U.S.C. § 1801(f)) under color of law, not authorized by any statute, to which Plaintiffs were subjected in violation of 50 U.S.C. § 1809.

109. Additionally or in the alternative, by the acts alleged herein, Defendants have intentionally disclosed

or used information obtained under color of law by electronic surveillance, knowing or having reason to know that the information was obtained through electronic surveillance and spying not authorized by statute, including information pertaining to Plaintiffs, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, willfully caused, participated in, enabled, contributed to, facilitated, directed, controlled, assisted in, or conspired in the commission of such acts.

110. Defendants did not notify Plaintiff of the above-described electronic surveillance, spying, disclosure, and/or use, nor did Plaintiffs consent to such.

111. Plaintiffs have been and are aggrieved by Defendants’ electronic surveillance, spying, disclosure, and/or use of their wire communications.

112. Pursuant to 50 U.S.C. § 1810, which provides a civil action for any person who has been subjected to an electronic surveillance and spying or about whom information obtained by electronic surveillance of such person has been disclosed or used in violation of 50 U.S.C. § 1809, Plaintiff seeks from the Count X Defendants for each Plaintiff their statutory damages or actual damages; punitive damages as appropriate; and such other and further relief as is proper.

COUNT XI

Violation of 18 U.S.C. § 2510, 18 U.S.C. § 2511, and 18 U.S.C. § 2512—Declaratory, Injunctive, and Other Equitable Relief

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

113. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

114. In relevant part, 18 U.S.C. § 2510, 18 U.S.C. § 2511, and 18 U.S.C. § 2510 provides that:

(1) Except as otherwise specifically provided in this chapter any person who – (a) intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to intercept, any wire, oral, or electronic communication . . . (c) intentionally discloses, or endeavors to disclose, to any other person the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection . . . [or](d) intentionally uses, or endeavors to use, the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection . . . shall be punished as provided in subsection (4) or shall be subject to suit as provided in subsection (5).

115. 18 U.S.C. § 2511 further provides that:

(3)(a) Except as provided in paragraph (b) of this subsection, a person or entity providing an electronic communication service to the public shall not intentionally divulge the contents of any communication (other than one to such person or entity, or an agent thereof) while in transmission on that service to any person or entity other than an addressee or intended recipient of such communication or an agent of such addressee or intended recipient.

116. 18 U.S.C. § 2511(2)(f) further provides in relevant part that “procedures in this chapter or chapter 121 and the Foreign Intelligence Surveillance Act of 1978 shall be the exclusive means by which electronic surveillance, as defined in section 101 [50 U.S.C. § 1801] of such Act, and the interception of domestic wire, oral, and electronic communications may be conducted.” (Emphasis added.)

117. 50 U.S.C. § 1812 further provides in relevant part that:

(a) Except as provided in subsection (b), the procedures of chapters 119, 121, and 206 of Title 18 and this chapter shall be the exclusive means by which electronic surveillance and the interception of domestic wire, oral, or electronic communications may be conducted.

(b) Only an express statutory authorization for electronic surveillance or the interception of domestic wire, oral, or electronic communications, other than as an amendment to this chapter or chapters 119, 121, or 206 of Title 18 shall constitute an additional exclusive means for the purpose of subsection (a). (Emphasis added.)

118. By the acts alleged herein, Defendants have intentionally and willfully intercepted, endeavored to intercept, or procured another person to intercept or endeavor to intercept, Plaintiff’s wire or electronic communications in violation of 18 U.S.C. § 2511(1)(a); and/or

119. By the acts alleged herein, Defendants have intentionally and willfully disclosed, or endeavored to disclose, to another person the contents of Plaintiff wire or electronic communications, knowing or having reason to know that the information was obtained through the interception of wire or electronic communications in violation of 18 U.S.C. § 2511(1)(c); and/or

120. By the acts alleged herein, Defendants have intentionally and willfully used, or endeavored to use, the contents of Plaintiff wire or electronic communications, while knowing or having reason to know that the information was obtained through the interception of wire or electronic communications and spying in violation of 18 U.S.C. § 2511(1)(d).

121. By the acts alleged herein, Defendants have intentionally and willfully caused, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, participated in, contributed to, negligently contributed to, facilitated, directed, controlled, assisted in, or conspired to cause unwitting subjects, Plaintiff, and the public, divulgence of Plaintiff wire or electronic communications to Defendants while in transmission by various service providers, and there of tampering with, in violation of 18 U.S.C. § 2511(2)(3)(4)(5).

122. Defendants have committed these acts of interception, disclosure, divulgence and/or use of Plaintiff communications directly or by aiding, abetting, counseling, commanding, inducing, procuring, encouraging, promoting, instigating, advising, willfully causing, participating in, enabling, contributing to, facilitating, directing, controlling, assisting in, or conspiring in their commission. In doing so, Defendants have acted in excess of their statutory authority and in violation of statutory limitations.

123. Defendants, and/or other electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of interceptions, disclosure and/or use of Plaintiff’s mind and body, DNA and brain waves from Data Mining and remote transmissions, communications, contents of communications, and records pertaining to their transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and/or individualized suspicion of Plaintiff’s records or other information.

124. Defendants did not notify Plaintiff of the above-described intentional interception, disclosure, divulgence and/or use of their wire or electronic communications, nor did Plaintiff consent to such.

125. Plaintiff have been and are aggrieved by Defendants’ intentional and willful interception, disclosure, divulgence and/or use of their wire or electronic communications.

126. On information and belief, the Count XI Defendants are now engaging in and will continue to engage in the above-described acts resulting in the intentional and willful interception, disclosure, divulgence and/or use of Plaintiff’s wire or electronic communications, acting in excess of the Count XI Defendants’ statutory authority and in violation of statutory limitations, including 18 U.S.C. § 2511, and are thereby irreparably harming Plaintiff. Plaintiffs have no adequate remedy at law for the Count XI Defendants’ continuing unlawful conduct, and the Count XI Defendants will continue to violate Plaintiff’s legal rights unless enjoined and restrained by this Court.

127. Pursuant to 18 U.S.C. § 2520, which provides a civil action for any person whose wire or electronic communications have been intercepted, disclosed, divulged or intentionally used in violation of 18 U.S.C. § 2511, to Larson v. United States, 337 U.S. 682 (1949), and to 5 U.S.C. § 702, Plaintiff seek equitable and declaratory relief against the Count XI Defendants.

128. Plaintiffs seek that this Court declare that Defendants have violated their rights and the rights of the class; enjoin the Count XI Defendants, their agents, successors, and assigns, and all those in active concert and participation with them from violating the Plaintiff statutory rights, including their rights under 18 U.S.C. § 2511; and award such other and further equitable relief as is proper.

COUNT XII

Violation of 18 U.S.C. § 2510, 18 U.S.C. § 2511, and 18 U.S.C. § 2512 actionable under 18 U.S.C. § 2520—Damages

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

129. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

130. In relevant part, 18 U.S.C. § 2510, 18 U.S.C. § 2511, and 18 U.S.C. § 2510 provides that:

(1) Except as otherwise specifically provided in this chapter any person who – (a) intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to intercept, any wire, oral, or electronic communication . . . (c) intentionally discloses, or endeavors to disclose, to

any other person the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection . . . [or](d) intentionally uses, or endeavors to use, the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection . . . shall be punished as provided in subsection (4) or shall be subject to suit as provided in subsection (5).

131. 18 U.S.C. § 2511 further provides that:

(3)(a) Except as provided in paragraph (b) of this subsection, a person or entity providing an electronic communication service to the public shall not intentionally divulge the contents of any communication (other than one to such person or entity, or an agent thereof) while in transmission on that service to any person or entity other than an addressee or intended recipient of such communication or an agent of such addressee or intended recipient.

132. 18 U.S.C. § 2511(2)(f) further provides in relevant part that “procedures in this chapter or chapter 121 and the Foreign Intelligence Surveillance Act of 1978 shall be the exclusive means by which electronic surveillance, as defined in section 101 [50 U.S.C. § 1801] of such Act, and the interception of domestic wire, oral, and electronic communications may be conducted.” (Emphasis added.)

133. 50 U.S.C. § 1812 further provides in relevant part that:

(a) Except as provided in subsection (b), the procedures of chapters 119, 121, and 206 of Title 18 and this chapter shall be the exclusive means by which electronic surveillance and the interception of domestic wire, oral, or electronic communications may be conducted.

(b) Only an express statutory authorization for electronic surveillance or the interception of domestic wire, oral, or electronic communications, other than as an amendment to this chapter or chapters 119, 121, or 206 of Title 18 shall constitute an additional exclusive means for the purpose of subsection (a). (Emphasis added.)

134. By the acts alleged herein, Defendants have intentionally and willfully intercepted, endeavored to intercept, or procured another person to intercept or endeavor to intercept, Plaintiff’s and Plaintiff’s family members’ wire or electronic communications in violation of 18 U.S.C. § 2511(1)(a); and/or

135. By the acts alleged herein, Defendants have intentionally and willfully disclosed, or endeavored to disclose, to another person the contents of Plaintiff’s wire or electronic communications, knowing or having reason to know that the information was obtained through the interception of wire or electronic communications in violation of 18 U.S.C. § 2511(1)(c); and/or

136. By the acts alleged herein, Defendants have intentionally and willfully used, or endeavored to use, the contents of Plaintiff’s wire or electronic communications, while knowing or having reason to know that the information was obtained through the interception of wire or electronic communications in violation of 18 U.S.C. § 2511(1)(d).

137. By the acts alleged herein, Defendants have intentionally and willfully caused, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, participated in, contributed to, facilitated, directed, controlled, assisted in, or conspired to cause divulgence of Plaintiff’s and Plaintiff’s family members wire or electronic communications to Defendants while in transmission by various service providers, and there of tampering with, in violation of 18 U.S.C. § 2511(2)(3)(4)(5).

138. Defendants have committed these acts of interception, disclosure, divulgence and/or use of Plaintiff’s communications directly or by aiding, abetting, counseling, commanding, inducing, procuring, encouraging, promoting, instigating, advising, willfully causing, participating in, enabling, contributing to, facilitating, directing, controlling, assisting in, or conspiring in their commission.

139. Defendants, and/or other electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of interceptions, disclosure and/or use of Plaintiff mind and body, DNA and brain waves from Data Mining and remote transmissions, communications, contents of communications, and records pertaining to their transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and/or individualized suspicion of Plaintiff’s records or other information.

140. Defendants did not notify Plaintiff of the above-described intentional interception, disclosure, divulgence and/or use of their wire or electronic communications, nor did Plaintiff consent to such.

141. Plaintiff have been and are aggrieved by Defendants’ intentional and willful interception, disclosure, divulgence and/or use of their wire or electronic communications.

142. Pursuant to 18 U.S.C. § 2520, which provides a civil action for any person whose wire or electronic communications have been intercepted, disclosed, divulged or intentionally used in violation of 18 U.S.C. § 2511, Plaintiff seeks from the Count XII Defendants for Plaintiff’s statutory damages or actual damages; punitive damages as appropriate; and such other and further relief as is proper.

COUNT XIII

Violation of 18 U.S.C. § 2511, actionable under 18 U.S.C. § 2712—Damages

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

143. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

144. In relevant part, 18 U.S.C. § 2511 provides that:

(1) Except as otherwise specifically provided in this chapter any person who – (a) intentionally intercepts, endeavors to intercept, or procures any other person to intercept or endeavor to intercept, any wire, oral, or electronic communication . . . (c) intentionally discloses, or endeavors to disclose, to any other person the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection . . . [or](d) intentionally uses, or endeavors to use, the contents of any wire, oral, or electronic communication, knowing or having reason to know that the information was obtained through the interception of a wire, oral, or electronic communication in violation of this subsection . . . shall be punished as provided in subsection (4) or shall be subject to suit as provided in subsection (5).

145. 18 U.S.C. § 2511 further provides that:

(3)(a) Except as provided in paragraph (b) of this subsection, a person or entity providing an electronic communication service to the public shall not intentionally divulge the contents of any communication (other than one to such person or entity, or an agent thereof) while in transmission on that service to any person or entity other than an addressee or intended recipient of such communication or an agent of such addressee or intended recipient.

146. 18 U.S.C. § 2511(2)(f) further provides in relevant part that “procedures in this chapter or chapter 121 and the Foreign Intelligence Surveillance Act of 1978 shall be the exclusive means by which electronic surveillance, as defined in section 101 [50 U.S.C. § 1801] of such Act, and the interception of domestic wire, oral, and electronic communications may be conducted.”(Emphasis added.)

147. 50 U.S.C. § 1812 further provides in relevant part that:

(a) Except as provided in subsection (b), the procedures of chapters 119, 121, and 206 of Title 18 and this chapter shall be the exclusive means by which electronic surveillance and the interception of domestic wire, oral, or electronic communications may be conducted.

(b) Only an express statutory authorization for electronic surveillance or the interception of domestic wire, oral, or electronic communications, other than as an amendment to this chapter or chapters 119, 121, or 206 of Title 18 shall constitute an additional exclusive means for the purpose of subsection (a).

(Emphasis added.)

148. By the acts alleged herein, Defendants have intentionally and willfully intercepted, endeavored to intercept, or procured another person to intercept or endeavor to intercept, spy, Plaintiff wire or electronic communications in violation of 18 U.S.C. § 2511(1)(a); and/or

149. By the acts alleged herein, Defendants have intentionally and willfully disclosed, or endeavored to disclose, to another person the contents of Plaintiff wire or electronic communications, knowing or having reason to know that the information was obtained through the interception of wire or electronic communications in violation of 18 U.S.C. § 2511(1)(c); and/or

150. By the acts alleged herein, Defendants have intentionally and willfully used, or endeavored to use, the contents of Plaintiff wire or electronic communications, while knowing or having reason to know that the information was obtained through the interception of wire or electronic communications in violation of 18 U.S.C. § 2511(1)(d).

151. By the acts alleged herein, Defendants have intentionally and willfully caused, or aided, abetted, counseled, commanded, induced, procured, encouraged, promoted, instigated, advised, participated in, contributed to, facilitated, spied, directed, controlled, assisted in, or conspired to, negligently conspired to, cause unwitting subjects, Plaintiff, and the public, divulgence of Plaintiff’s wire or electronic communications to Defendants while in transmission by various service providers, and there of tampering with, in violation of 18 U.S.C. § 2511(2)(3)(4)(5).

152. Defendants have committed these acts of interception, disclosure, divulgence and/or use of Plaintiff’s communications directly or by aiding, abetting, counseling, commanding, inducing, procuring, encouraging, promoting, instigating, advising, willfully causing, participating in, enabling, contributing to, facilitating, directing, controlling, assisting in, or conspiring in their commission.

153. Defendants, and/or other electronic communication services acted as the agent in performing, participating in, enabling, contributing to, negligently contributing to, facilitating, at the hands of, direction of, or knowledge of, or assisting in the commission of the above-described acts of interceptions, disclosure and/or use of Plaintiff mind and body, DNA and brain waves from Data Mining and remote transmissions, communications, contents of communications, and records pertaining to their transmissions, collected, and/or stored without judicial or other lawful authorization, probable cause, and/or individualized suspicion of Plaintiff’s records or other information.

154. Defendants did not notify Plaintiffs of the above-described intentional interception, disclosure, divulgence and/or use of their wire or electronic communications, nor did Plaintiff consent to such.

155. Plaintiff have been and are aggrieved by Defendants’ intentional and willful interception, disclosure, divulgence and/or use of their wire or electronic communications.

156. Title 18 U.S.C. § 2712 provides a civil action against the United States and its agencies and departments for any person whose wire or electronic communications have been intercepted, disclosed, divulged or intentionally used in willful violation of 18 U.S.C. § 2511. Plaintiff has complied fully with the claim presentment procedure of 18 U.S.C. § 2712. Pursuant to 18 U.S.C. § 2712, Plaintiff seeks from the Count XIII Defendants for Plaintiff’s statutory damages or actual damages, and such other and further relief as is proper.

COUNT XIV

Violation of 18 U.S.C. § 2703(a) & (b)—Declaratory, Injunctive, and Other Equitable Relief

(Plaintiff vs. Defendants) and parties, inclusive of all affiliations

157. Plaintiff repeats and incorporates herein by reference the allegations in the preceding paragraphs of this complaint, as if set forth fully herein; and all allegations under the law, as stated above.

158. In relevant part, 18 U.S.C. § 2703 provides that:

(a) Contents of Wire or Electronic Communications in Electronic Storage.— A governmental entity may require the disclosure by a provider of electronic communication service of the contents of a wire or electronic communication, that is in electronic storage in an electronic communications system for one hundred and eighty days or less, only pursuant to a warrant issued using the procedures described in the Federal Rules of Criminal Procedure by a court with jurisdiction over the offense under investigation or equivalent State warrant. A governmental entity may require the disclosure by a provider of electronic communications services of the contents of a wire or electronic communication that has been in electronic storage in an electronic communications system for more than one hundred and eighty days by the means available under subsection (b) of this section.

(b) Contents of Wire or Electronic Communications in a Remote Computing Service.—

(1) A governmental entity may require a provider of remote computing service to disclose the contents of any wire or electronic communication to which this paragraph is made applicable by paragraph (2) of this subsection—

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