Specifically, the methods used to transfer, install, and implant
the implants into Plaintiff Schlund involves critical levels of
secrecy to the Defendants and others, involving joint
operations. Plaintiff Schlund placed in writing to various
government agencies, including the Central Intelligence Agency
("CIA"), Drug Enforcement Agency ("DEA"), FBI and others, what
could be expected of activity conducted by Defendants
individually and to accomplish fixing the presidential elections
and what their agenda would be including plundering the United
States Treasury after being placed in office by covert
operations of the CIA and others, strategic placing of various
members on the United States Supreme Court for this purpose into
the future.
It materialized exactly as Plaintiff Schlund said it would years
earlier, along with Defendant Bush individually and as finally
appointed by the United States Supreme Court into the position
of President of the United States and the CIA (Joint Operation
of the DEA) and others controlling the states of Florida, Texas,
and Arizona, which were and continue to be strategic states for
operations of a covert nature and the running of drugs and other
international and domestic associated joint operations involving
the aforesaid. These states were specifically earmarked in
writing as important in order to control the other states in
order to protect the incoming drug shipments that the CIA ran
into the United States, which involved various types of gangs
and joint government and private illegal racketeering
activities. Texas and Florida would be the key states in the
fixing of the presidential elections as Plaintiff briefed the
FBI in 1992. The gang members are the witnesses the government
is using to justify Plaintiffs injection with implants and the
torture of Plaintiff that is used with planted evidence and
false conversations taken under torture from Plaintiff by the
government and as Plaintiff agreed with the FBI to make the
conversations to prove who the corrupt agents involved were in
the overthrow of the United States by the Bush family, CIA, DEA
and others.
The illegal drugs were the common denominator that held the
gangs together. These gangs furnished the children, girls, and
boys for sex for the different corrupt judges and politicians in
said states (especially Arizona), and the strategic and
systematic use of the drugs (and allegations of a subject being
a drug manufacturer) used to authorize many of the
investigations against political witnesses (Plaintiff Schlund)
and those associated to him and other dissidents. These
investigations and torture have continued to this day even after
Plaintiff proved in trial that the government framed him and
that the government had even threatened to murder the children
of his first witness if he dared to testify. This resulted in
Plaintiff Schlund's acquittal after the government refused to
release records that their informant was really a drug
manufacturer and drug dealer. The government's informant was
really Carl Altz Special agent of the DEA who had committed
perjury before a grand jury and in trial which outraged the
judge. The drugs are and continue to be the catalyst that holds
everything together for Defendant and his agents, and the
proceeds from the drugs helped to finance many of the covert
operations, resulting in the building of a large expanse of
churches, the funding of the religious channels on T.V., and
many other illegal covert CIA, DEA, and other quasi-military
operations that were and continue to be part of the systematic
overthrow of the United States of America by the CIA, DEA and
select individuals.
The Defendants' racketeering activities were used specifically
to deprive select individuals of their United States'
constitutional rights, usurp the federal and constitutional laws
protecting individuals and those associated with select target
subjects for the purpose in part to authorize investigations and
trials which would then be used to establish new case law (such
as case law like Dorn v. McGinness, 158 F.R.D. 383-388 E.D.
Mich. 1994) ["[c]ourts need not entertain claims founded upon
beliefs of alleged implantation in his brain of a telepathic
mind control device which is so obviously bizarre and
hallucinary"] which hopefully have the effect of discrediting
the individual making claims based on reality and the ability to
prove the reality of the implants and their effects, and the
reality of proving the type of implant product(s) and the method
or procedure used to insert or install such implant into the
subject target for wireless telemetry influence and
psychological and physiological manipulation and torture by the
select individual(s) cleared for these types of aforesaid unique
investigation technique used by Defendant and his agents. The
court never denied Doran had implants, the court only ruled that
the implants were not brain implants used for telepathic
communications. Doran did not know how he heard voices and was
tortured or where the implants were in his body and Doran had no
chance of proving his case because he was in prison under the
total control of the government.
DEFENDANT'S CASES ARE DISTINGUISHED ON THE FACTS AND NOT
APPLICABLE.
Defendant cites Skolnick v. Hallett,350 F.2d 861 (7th Cir.
1965): This was a per curiam decision out of the 7th Circuit
United States Court of Appeals in 1965. The Plaintiff/Appellant
Skolnick filed a lawsuit for (1) intimidation, (2) defamation by
slander, and claimed the District Court was a "kangaroo court."
In his In Pro Se Complaint which was gutted with scurrilous,
offensive, and objectionable allegation principally leveled at
the Northern District of Illinois judge, Honorable Joseph Samuel
Perry, and the attorney for the defendant, Harry G. Fins, a
long-time member of the Illinois Bar with offices in Chicago,
Illinois, the justification for the dismissal and striking of
Plaintiff's Complaint. Notably, the case was actually against
the state court Judge Hallett and Attorney Fin. Moreover, the
case did not denote specifically what scurrilous, offensive, or
objectionable allegations were actually leveled at the judge in
the decision.
In short, Plaintiff Schlund has leveled the detailed facts of
Defendant's individual (pre-appointment as President by the U.S.
Supreme Court) racketeering acts and conduct resulting in the
deprivation of Plaintiff's constitutional rights, required to be
pled, and the United States Constitutional and federal laws
supporting his claims. See Complaint, pgs. 1-26 incorporated
hereat. The nature, degree, and type of Defendant's acts and
conduct alleged by Plaintiff Schlund are of his own personal
knowledge and personal involvement with said Defendants and
their agents and the gangs they ran and controlled, which have
been continuous and ongoing. He has reported the details of such
acts and conduct, and the nature and extent of his injuries and
damages as the result of such conduct in his Verified Complaint.
He has also expressed in a general manner the methodology of
wireless telemetry product(s) used in an integrated manner to
invade his privacy, trespass on his property and other rights,
harass him, persecute him and torture him, his family, and
witness tamper in the aforesaid regards, in detail. In fact, his
specific allegations of the acts and conduct of said Defendants
and the result of the injury and damage to him from such conduct
is required to be pled under F.R.C.P. Rule 8.
See also, Shaveriat v. Williams Pipeline Co., 11 F.3d 1420, 1430
(7th Cir. 1993) [noting increasing trend toward greater
specificity in complaints], supported by Swierkiewicz v. Sorema,
N.A., 534 U.S. 506, 512, 122 S.Ct. 992, 998, 152 L.Ed. 2d 1
(2002). F.R.C.P. Rule 9(b) requires detailed pleading on claims
involving Defendant's acts and conduct, a product of malice,
intent, knowledge, and other conditions of mind of a person, and
F.R.C.P. Rule 9(f) and (g) of time and place which are material
and "shall" be considered like all other averments of material
matter connected to time and place as set forth in the
Complaint. Plaintiff Schlund is a witness whose declaration
under oath is direct evidence which supports the Complaint, also
construed as an affidavit under penalty of perjury to support
his claim under F.R.C.P. Rule 43(a). As an aside, Defendant
squawks about Plaintiff not naming the specific surnames of the
individuals involved with Defendants acting in joint effort to
harass, persecute, torture, and invade his privacy, claiming the
case should be dismissed on those grounds, which is frivolous.
The unknown "agents" are not necessary to be named specifically
for the claims to be valid. See, Central Intelligence Agency v.
John Kerry Sims and Sydney M. Wolfe, 471 U.S. 159 (1965).
Moreover, Plaintiff Schlund is being egregiously and
intentionally harassed, persecuted, and tortured by the most
unethical, immoral, and criminal individuals, violating the law
and his Constitutional Rights in a vile and evil manner, as set
forth in the Complaint, which is and of itself indecent,
abusive, coarse, vulgar, and demonstrates a gross conscious and
reckless disregard for Plaintiff as a human being and the
protections afforded against such conduct under the United
States Constitution. See Plaintiff's Complaint. The 9th Circuit
Court of Appeals itself held that "official torture constitutes
a causable violation of the law of nations and described the
prohibition against official torture as 'universal, obligatory,
and definable.' The same 9th Circuit Court of Appeals also
defined such torture as: 'To subject a person to such horrors is
to commit one of the most egregious violations of the personal
security and dignity of a human being.'"
Further, the 9th Circuit Court of Appeals, which controls on the
decisions of the District Court of Arizona, states that all
relevant material averments constitutes evidence admissible on
the issue of Plaintiff Schlund's physical and mental pain and
suffering, supporting his special damages claim. Defendant's
specific acts and conduct averred to by Plaintiff Schlund and
the resulting injury and damages is required to be pled under
F.R.C.P. Rule 9(f) and 9(g). Browning v. Clinton, 292 F.3d 235,
245-46 D.C. Cir. (2002) and Marseilles Hydro Power, LLC v.
Marseilles Land & Water Co., 2003 W.L. 259142, at *6(ND Ill.
2003). In fact, F.R.C.P. Rule 9(g) absolutely requires the
specificity of pleading the acts and conduct causing the
violation of Constitutional Rights and the physical and
emotional harm to Plaintiff Schlund or the justification for
punitive damages and the "causal connection" between the
aforesaid. And, the manner of the specificity of connecting the
two has not been "reducable to formula." Marseilles Hydro supra.
Furthermore, the 9th Circuit Court of Appeals in Siderman De
Blak v. Republic of Argentina, 965 F.2d 699 (9th Cir. 1992)
specifically noted that technology, as it advances, is used for
intrusion, causing injury and damages through the use of
wireless integrated telemetry to conduct illegal surveillance
and torture by the government. Appellant Court loudly echoed in
its judicial decision, after solidly recognizing the realities
of torture through use of such technology, specifically
surveillance and the government's pattern of always denying such
activity, despicable in design and nature as the most egregious
inhumane crimes against an individual (humanity), domestic and
internationally, such as that pled by Plaintiff Schlund.
Moreover, the 9th Circuit Court of Appeals analysis dealt
specifically with the atrocities, injuries, pain, and suffering
a person experiences during the various acts and conduct it
noted as "torture" by the government; and, especially noted that
all governments "that engage in torture, denying it, and no
state claims a sovereign right to torture its own citizens," and
the factual causal connection is pled in Plaintiff Schlund's
Complaint. See Complaint and Tel-Oren v. Libian Arab Republic,
726 F.2d 774, 781 (D.C. Cir. 1984) (opinion of Edwards J.),
cert. denied 470 U.S. 1003, 105 S.Ct. 1354, 84 L.Ed. 2d 377
(1985).
Even the 9th Circuit judges note in the Siderman case, "Judge
Kaufman's survey of the universal condemnation of torture
provides much support for the view that torture violates jus
kogens." In Judge Kaufman's words, "[a]mong the rights
universally proclaimed by all nations (including the USA), as we
have noted, is the right to be free of physical torture" (630
F.2d at 890).
Supporting this case law, which also recognizes the prohibition
against official torture as one of only a few jus kogens norms.
Restatement 702 Comment n, also identifying jus kogens norms
"prohibiting genocide, slavery, murder, or causing disappearance
of individuals, prolonged arbitrary detention, and systematic
racial discrimination."
The 9th Circuit confirms that the prohibition against official
torture on any level has achieved the status of jus kogens norm
(Id.) (citations omitted in the interest of judicial economy).
Plaintiff's Complaint is not mere speculation, conjecture, or
scurrilous statements made against Defendants but are of his
personal knowledge of nearly 30 years. In that nearly 30 years,
his personal knowledge includes personal contact and exposure to
inappropriate and illegal acts of high ranking officials,
including the Honorable Judge Broomfield, with all due respect.
Judge Broomfield was promoted to the Surveillance Court to
protect him and because Judge Broomfield got ride of the threat
against the Bush family by stopping Plaintiff's lawsuit which
would have gone all the way to the Bush family. Judge Broomfield
failed to rule on the motion for relief from torture and the 9th
Circuit failed to rule on the motion for relief from torture and
the Supreme Court ruled that they did not have to rule on the
motion for relief from torture because it was not filed in the
lower court. It was properly filed in the lower courts and was
properly before the courts through the entire legal process.
Thus, because Attorney Patrick has no individual personal
knowledge of the facts set forth in this case, his impressions,
opinions, and conclusions are worthless and to be given no
evidentiary weight, State v. Bridges, 134 Ariz. 59 (1982).
Likewise, the Skolnick v. Hallett, is void of any factual
content supporting Attorney Patrick misplaced conclusions and
must be disregarded.
Defendants cite Chew Wing Luk v. Dulles, 268 F.2d 824, 827 (9th
Cir. 1959) is factually distinguishable and not controllable.
In the Chew Wing Luk v. Dulles case, 9th Circuit Court of
Appeals dealt with Plaintiff Chew Luk, who filed with the
American Consul General ("A.C.G.") in Hong Kong an application
for a passport to come into the United States. Chew lied in the
affidavit supporting the application for the passport, claiming
to be a citizen of the U.S. through Chew Tai Cam, a native-born
citizen of the United States, who he claimed was his father. The
A.C.G. required Plaintiff/ Appellant to produce a Certificate of
Identity allowing him to come to the United States for the
purpose of prosecuting his lawsuit pursuant to Section 503 of
the Nationality Act of 1940 (8 U.S.C. Sec. 903). After producing
the Certificate of Identity, his application was granted, and
Petitioner based the jurisdiction of the District Court for his
lawsuit under Section 503 of the Act.
The lawsuit was then filed in the United States District Court
for the Northern District of California. It was then transferred
to the United States Court for the Southern District of
California, Central Division, whereupon Chew filed an Amended
Complaint for declaratory judgment, alleging that he was an
American citizen, as the "illegitimate son" of Chew Fong Shew
(formerly claimed by Appellant to be his aunt, a native-born
citizen of the United States at the time of Plaintiff's birth).
Trial was had before the District Court solely on the issue of
jurisdiction, and the District Court dismissed the amended
complaint on the grounds that the court did not have
jurisdiction of the subject matter of the acti