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If you are a “targeted individual” and have a National Security Letter that has been falsely issued against you under the Patriot Act, we have found that there are no attorneys who will represent you.  Our research shows that the only way to get the National Security Letter removed against you is to file your own federal lawsuit. To assist you in this endeavor, the following is a guide you can use in preparing your initial document to file with the court. The process for taking your case pro se all the way up to the U. S. Supreme Court is found on our website under “How to File a Federal Suit.” As you go forward, we have found that you will not receive any publicity from mainstream media. Therefore, we strongly suggest that once you have filed your suit, post a copy on a social media website, blog, etc. for protection purposes. Please be advised that filing this type of suit may cause further harassment and that your choice to do so will be at your own risk.

 

I.  M.  Targeted                     
P.O. Box 666 
Anywhere, U.S.A.  00000
Ph:  000-000-0000
E-mail:  targetedindividual.com

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF (YOUR STATE)

I.  M.  Targeted, Individually, pro se

Plaintiff

vs.

Case No. 
United States Government, Department of Defense,
Department of Justice, Federal Bureau of
Investigation, (any other known defendants),

Defendants.

_____________________________________

 

A.   COMPLAINT

COMES NOW the plaintiff, I. M. Targeted, individually pro se, and files this complaint against the defendants as follows:

 

B.     PARTIES

  1. Plaintiff, I. M. Targeted, is an individual representing himself pro se with residence located at P. O. Box 666, Anywhere, U.S.A. 00000.  Plaintiff, I. M. Targeted, is hereinafter referred to as the same, “Mr. Targeted,” or “plaintiff.”

  2. Defendant, the United States Government, is a government entity with principle offices located in Washington, D.C.  The United States Government may be served by and through the U.S. Attorney General, Loretta Lynch, at her principle place of business, the Department of Justice, 950 Pennsylvania Avenue N.W., Washington, D.C. 20530.  Defendant, the United States Government, is hereinafter referred to as the same, “the U. S. government,” “the government,”“DOJ,” “DOD,” “FBI,” “President Barack Obama,” or any and all of the other defendant(s) referred to as well as other known/unknown state actors.

  3. Defendant, the Department of Defense, is a government entity with principle offices located in Washington, D.C.  The United States Government may be served by and through its Secretary of Defense, Ashton Carter, at his principle place of business, The Pentagon, Washington, D.C.  20301-1155.  Defendant, the Department of Defense, is hereinafter referred to as the same, “DOD,” “defendant, or “the government.”

  4. Defendant, the Department of Justice, is a government entity with principle offices located in Washington, D.C.  Defendant, the Department of Justice, may be served by and through the United States Attorney General, Loretta Lynch, at her principle place of business, the Department of Justice, 950 Pennsylvania Avenue N.W., Washington, D.C.  20530.  Defendant, the Department of Justice, is hereinafter referred to as the same, “DOJ,”“defendant,” or “the government.”

  5.  Defendant, _____________, is an individual who resides at __________________________________.  Defendant, _____________, may be served summons at his place of residence: _______________________________________. Defendant, is hereinafter referred to as the same, “Mr. ____________,” “defendant,” or the “government.”

    C.  FACTS PERTAINING TO THE PARTIES


  6. Plaintiff I. M. Targeted is a United States citizen who was born in ______________.  He is a resident of the state of ______________ and works at _____________________.

  7. Defendant, the United States Government, consists of a President, his cabinet, Congress and various local, state and national actors and entities engaged in authoritative control and governance of the United States of America.  The current president is President Barack H. Obama. 

  8.  Defendant, the United States government, is represented in this action by 23 agencies, bureaus or offices.  The principle members are the Department of Justice, the Department of Defense and the Federal Bureau of Investigation (FBI).

  9.  Defendant, the Department of Defense, is an agency under the President that is engaged in defending the United States of America against attacks by foreign countries, fighting the war on terror and trying to defeat ISIS. 

  10.    Defendant, the Department of Justice (DOJ), is a federal executive department of the U. S. government responsible for the enforcement of the law and administration of justice in the United States.

  11.     Defendant, the Federal Bureau of Investigation (FBI), is the domestic intelligence and security service of the United States, which simultaneously serves as the nation’s prime federal law enforcement organization. Operating under the jurisdiction of the U.S. Department of Justice, the FBI is concurrently a member of the U.S. intelligence community and reports to both the U.S. Attorney General and the Director of National Intelligence.

  12.    Defendant, ________________, is a resident who lives at____________________________________. He is employed by the government to conduct surveillance on plaintiff.

  13. All of the defendants are government actors, employees, subcontractors and/or entities of the United States government. All of the defendants had knowledge of this matter and are/were involved in the conspiracy, negligence and denial of plaintiff’s rights resulting in the outrageous government conduct toward him.

    D.  FACTS PERTAINING TO THE CASE


  14.   Plaintiff I. M. Targeted is a ___- year old [man].  He retired from______________ after working there ___ years.

  15.    Mr. Targeted is married to his wife ___________ and they have __ grown children.

  16.    Plaintiff has never been charged with any crime or misdemeanor.

  17.    Mr. Targeted’s income is approximately $______________ annually.

  18.    After retiring in 1994, _________ established his business _________ in the Ukraine with U.S. partners and the government.

  19.    From 1995 to 1998, _________traveled monthly to and from the Ukraine on business with his company on a grant for the U.S. government.

  20.    For ten years, plaintiff brought cash over to the Ukraine with him.  It was costing him $7,000 - $10,000 to live there for six months out of a year, and this money was for living expenses.

  21.    The government had cut development funds, so Mr. Targeted began to self-fund and pay his own airfare and living expenses.  For convenience, he stayed in the Ukraine 6-7 months a year.

  22.    In December 2005, plaintiff decided to open a bank account for business purposes at UBS Bank in Switzerland. He made two $10,000 wire transfers to open it.

  23.    It was approximately 2008 when plaintiff’s company began to fold and he and his partner began looking for someone to take it over. From 2008 - 2012, Mr. Targeted kept going over to the Ukraine to look for other business opportunities and continued to stay six months out of a year.

  24.    In 2008, plaintiff received a notice from UBS Bank in Switzerland that they were no longer going to deal with American customers and that he would need to close his bank account.

  25.    So that same year, plaintiff opened up an account for his business in the Ukraine at BaslerKantonalbank (BKB).  He still needed to have access to funds for business and living expenses.

  26. It was in November, 2009 that the United States government by Presidential Executive Order set up an inter-agency task force called the Federal Fraud Enforcement Task Force.  The task force was made up of 23 federal agencies, departments and bureaus, and Defendant Eric H. Holder, Jr. as Attorney General of the United States was the designated head
    of the Task Force.

  27. Defendant U.S. Attorney General Eric Holder formally announced formation of the Task Force at a press conference on December 6, 2010. The stated goal of the Task Force, at that time, was to pursue the bankers and Wall Street executives that caused the financial crisis of 2008-2009.

  28.    However, this was an apparent fraud on the American public, since not a single banker or Wall Street executive was ever indicted or prosecuted because of political expediency.

  29. It was clear that the Task Force would use clandestine operations when defendant Attorney General Holder stated at the press conference that: “The task force will implement. more sophisticated investigation techniques, including undercover operations and electronic surveillance.”

  30. It was later on that Defendant U. S. Attorney General Eric Holder added the task of pursuing U.S. citizens with undisclosed foreign bank accounts through the IRS.  This appears to be the main reason the Task Force was set up, to make it look like the government was going after the wealthy on Wall Street when they were really trying to target the average American
    taxpayer.

  31. In adding this goal, the Task Force took violations that were previously a civil matter which were settled with fines and penalties and converted them to criminal acts with DOJ prosecutors seeking harsher penalties, more severe fines and jail sentences.

  32. According to an internet article from the Financial Advisor 10/25/11, the Task Force under the direction of U. S. Attorney General Eric Holder and the DOJ aggressively pursued Swiss banks, including plaintiff’s bank, Basler Kantonalbank (BKB) (EXHIBIT A).

  33. This article stated that “the U.S. Justice Department may bring criminal charges or civil enforcement actions against any of the 11 financial institutions.” It also said that people with accounts in these Swiss banks could avoid prosecution by separately paying fines, admitting wrongdoing and disclosing data.”

  34. The DOJ had requested statistical data from the 11 financial institutions about their U.S. accounts, which the government received and was analyzing.  At the end of 2011, a handful of Swiss banks turned over millions of e-mails and documents to the U.S. government - information that was supposed to remain encrypted until a global settlement was reached on the
    treatment of the banks, including Credit Suisse, Julius Baer, and Basler Kantonalbank [plaintiff’s bank].

  35.    On or about January 16, 2012, defendants used state actors to intercept a letter from Basler Kantonalbank (BKB) addressed to plaintiff (EXHIBIT B). This gave them information they needed that he had an account with them.

  36. Seizure of the letter by the defendants prevented plaintiff from receiving time criticalnotification and legal information regarding closure of his bank account at BKB. However, he received a second letter and was eventually able to close his account.

  37.   On March 30, 2012, Mr. Targeted was at a restaurant that he normally frequented in ___________, Florida.  Several friends including a man from Ireland all met there.

  38.   Plaintiff chatted with a heavy-set man at the bar who said he was an international airline pilot. He brought up the fact that he had more than one passport, and Mr. Targeted remarked that he also had an Irish passport in addition to his American passport.

  39.   This was part of the government’s “sting” operation to justify issuing a National SecurityLetter or FISA Court order against Mr. Targeted and conduct illegal surveillance on him. This violated plaintiff’s rights under Color of Law 42 USC 1983, the 4th and 14th Amendments to the U.S. Constitution, FISA and the Patriot Act.

  40.   While traveling in early 2012, plaintiff was subjected to electronic surveillance and harassment when he was in the Ukraine and Europe, and also when he stayed in hotels and rental apartments in Massachusetts.   

  41.   His health began deteriorating as a result of the harassment, which included:  bones cracking, flatulence, blurred vision, heart palpitations, breathing problems, pulsing above his left ear, exhaustion, back pain and hand cramps.

  42.    The last time that Mr. Targeted returned from the Ukraine in July, 2012, this was also when the defendants began to increase surveillance on him.  They installed 10-15 cameras in the laundry room, hallways and on the sides of the building at his apartment complex.

  43.    Shortly after this, Mr. Targeted told his lawyer, _________________, about everything that was happening to him.  Attorney _______________ told him the government would not waste such resources on him, that he must be dreaming and should go see his doctor.

  44.    However, on behalf of plaintiff, Attorney_____________ sent a letter to the FBI on August 6, 2012 requesting information as to whether plaintiff was being targeted by the government for money-laundering.  Plaintiff also sent a FOIA request on August 14, 2012.

  45. Due to the emotional distress caused by the unwarranted surveillance directed at plaintiff by the defendants, Mr. Targeted developed prostate cancer in August, 2012.  He underwent radiation treatment for this illness several months later.


  46.    In February 2013, the FBI sent plaintiff a letter with information relating to his secret clearance from 1979 which had nothing to do with his FOIA request.

  47.    In July 2013, plaintiff went to his doctor of ten years and told her that he was being harassed and under surveillance by the defendants to cause him sleep deprivation.

  48.    Plaintiff’s doctor told him to go see a psychiatrist who put him on a drug that he didn’t like.  Plaintiff began taking sleeping pills so that he could try and get rest.

  49.    On January 8, 2014, plaintiff went back to see his doctor, and was attended by a nurse that he had never seen before. 

  50.    The nurse was a state actor working for the government who told him he needed his ears cleaned out. It was during this procedure that a microchip was implanted in plaintiff’s ear.        

  51. It was in January 2014 that plaintiff noticed that his upstairs neighbor,__________, began to conduct surveillance to harass him and cause sleep deprivation.  He experienced heart pain, audible noises that would wake him up, flatulence, pain in his buttocks and blurred vision.

  52.    On March 26, 2014, due to exhaustion from the defendants causing him to be sleep deprived, plaintiff fell on his face coming out of his apartment and suffered lacerations and broken front teeth.

  53. At about this same time, plaintiff was “gang-stalked” by the defendants.  When he would visit the library where he liked to read and study, a group of people would sit nearby and make loud noises to disrupt him. When he went to the theatre, a group would sit near him and cough throughout, just to harass him.


  54. On June 14, 2014, a surveillance device was put on the roof of plaintiff’s apartment building using a crane. Within four days of this occurrence, the defendants acted through _______________ to cause Mr. Targeted further emotional distress which included but is not limited to:  popping sounds in his ears, voices talking to him that repeatedly said, “F-U-, _______!”, severe headaches, sneezing attacks, unusual dreams and nightmares, chest pain, numbness in his legs and cold feet, “halo” vision affecting his sight, eye and hand twitching, severe acid reflux and the emission of an electronic odor.


  55.   To try and avoid the electromagnetic microwave surveillance by the defendants, Mr. Targeted slept his couch or floor instead of his bed. He would also sleep with an MP3 player and ear buds and a motor running, but could not completely drown out the voices and sounds.

  56.   From August, 2012 -  October, 2015, plaintiff sent as many as 18 letters to the DOJ, FBI and also to Florida Senator Marco Rubio about what was occurring to him in an effort to get the illegal surveillance and harassment to stop.  They all did nothing.

  57.   On October 22, 2015, plaintiff sent a “cease & desist” letter to Defendant _________ to try and get him to stop his illegal surveillance/harassment.  He did not respond and the torture continued.

  58.   On October 24, 2015, Mr. Targeted made a complaint to his local sheriff’s office about the sleep deprivation and harassment caused by the defendants, especially _____________. 

  59.   Spying on U.S. citizens is illegal under Section 215 of the Patriot Act and FISA, but the defendants illegally initiated covert surveillance anyway and deprived plaintiff of his rights.

  60.   The defendants initiated a “sting” operation against plaintiff to find out if he had a separate passport and this began the illegal surveillance which has continued for over four years.

  61.   Defendants issued a National Security Letter or FISA Court order and authorized surveillance and electronic harassment against plaintiff, even after having access to all of his phone calls, financial transactions, correspondence with his lawyer and letters to government officials which showed he was innocent of any wrongdoing.

  62.   This violated his 4th Amendment right to privacy under the U.S. Constitution, as well as his right to due process of law and equal protection under the 14th Amendment.

  63.   However, plaintiff was not aware that his rights were being violated until he spoke witha pre-litigation consultant in April, 2016.

  64. Mr. Targeted did not become aware of the Task Force or any of its activities until approximately November, 2015.  Even if he had, there was no reason for him to come forth since he had not done anything wrong.  

  65.    The defendants have subjected the plaintiff to uncontrolled, unregulated and reckless harassment by day and night using a range of sounds and electromagnetic energy, posing a dangerous and life-threatening risk to plaintiff’s health.

  66.    Through plaintiff’s microchip implant, defendants used state actor ____________to harass plaintiff and cause him to suffer sleep deprivation by means of combined mechanical and electronic harassment.   

  67.    Defendants have illegally invaded Mr. Targeted’s living space, automobile, telephone, cell phone, computer and monitored his travels for over four years.    

  68.    Even plaintiff’s friends were exposed to microwave surveillance suffered by Mr. Targeted which resulted in hyperventilation and emergency medical treatments.

  69.    The targeting of plaintiff through a National Security Letter or FISA Court order was initiated without any consideration of his background in working with the U.S. government or his innocence in this matter.

  70.    As a result, Mr. Targeted has been unable to pursue day-to-day and business activities which have been constrained due to the defendants’ actions.  Plaintiff was forced to discontinue his financial investments and business efforts.

  71.    Plaintiff has suffered severe emotional distress and bodily harm as the result of defendants’ actions to illegally put him under surveillance and violate his rights.

  72.    Defendants used news articles and press conferences to try and coerce elderly people into admitting they had money in Swiss banks and foreign accounts. They then used the IRS to try and tax them as much as 50% on their money while never really charging them with any wrongdoing.

  73.    An example of this legalized extortion and fraud by the government is when the defendants (except for _____________) sought to put an 80-year old woman named Mary Estelle Curran in jail for IRS regulations imposed by this Task Force (Exhibit C).

  74.   In an estimate of 12-20 people watching plaintiff around the clock, defendants have spent an estimated four million dollars in four years of surveillance of an innocent man.

  75.   Defendants have denied plaintiff his rights under Color of Law 42 USC 1983, violated his right to privacy under the 4th Amendment as applied to the states through the 14th Amendment, his right to due process and equal protection under the 14th Amendment, as well as FISA and the Patriot Act.

  76.    Mr. Targeted has exhausted all administrative efforts to try and stop the illegal and unwarranted surveillance against him.

  77.    It should be noted that several federal judges have recently ruled that National Security Letters are unconstitutional.

  78.  Mr. Targeted is well within the statute of limitations for the time allowed for him to sue the defendants for damages in this matter.

  79. Plaintiff has demanded that defendants take action to make him whole for his losses.Defendants have refused plaintiff’s demands.

 

D.  LAW AND ANALYSIS

            Defendants violated numerous national laws, statutes, ordinances and regulations, including but not limited to:  Denial of Rights Under Color of Law (42 USC 1983), right to privacy under the 4th Amendment (as incorporated to the states through the 14th amendment) and plaintiff’s right to due process and equal protection under the 14th Amendment to the United States Constitution and intentional emotional distress.  Denial of Rights Under Color of Law 42 USC 1983 states:

“Every person who, under color of any statute, ordinance, regulation, custom or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States or any other person within the jurisdiction thereof to the deprivation of any rights, privileges or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.”

           This applies to the plaintiff through the states under the 14th Amendment, since “all persons shall not be deprived of .life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws." U.S. Const., Amdt. 14, § 1.  The federal court has jurisdiction in this matter under 28 U.S.C. 1331, since the plaintiff is suing the United States government and various departments, agencies and state actors, known and unknown, thereof. The overt acts of fraud by commission and collusion in this matter which were engaged in by the defendants to deprive plaintiff of his rights include but are not limited to:  setting up a task force for the stated purpose of going after big banks when the main purpose was to extort money from elderly people such as plaintiff who had money in Swiss banks, setting up a “sting” operation to identify plaintiff by his Irish passport as an individual worthy of government targeting when he had done nothing wrong, denying him due process and the right to be heard prior to issuing a National Security Letter against him, illegally monitoring his activities around the clock and using his neighbor to spy on him to deny his right to privacy, and using electromagnetic surveillance to cause him mental anguish and bodily harm. Their ltimate goal was to deprive plaintiff of his property for their own benefit.

            This case warrants claims involving tort of outrage, bad faith, outrageous government conduct and manifest injustice.  The defendants acts are indicative of legalized stealing/ extortion and harassment of plaintiff to violate his rights. Accordingly, plaintiff is justified in alleging each of the following claims against the defendants.           

 Violations of Plaintiff’s 4th Amendment Right to Privacy
(as incorporated to the States through the 14th Amendment)

  1. Plaintiffs incorporate by reference paragraphs 1 through 85 of this Complaint.

  2. The conduct of all of the defendants (the government, the President, DOD, DOJ, FBI, _____________ and other known/unknown state actors) to engage in unwarranted and illegal domestic surveillance and issue a National Security Letter against Mr. Targeted without good cause violated his right to privacy under the 4th Amendment to the United States Constitution, as incorporated to the States through the 14th Amendment.

  3. The conduct of the above named defendants to engage in unwarranted and illegal domestic surveillance, electronic harassment and to issue a National Security Letter against Mr. Targeted deprived him of his rights under the Constitution pursuant to 42 USC 1983.

  4. The above named defendants owed Mr. Targeted a duty not to violate his right to privacy under the aforementioned laws.

  5. The above named defendants breached the duty owed the plaintiff.

  6. As a result of the defendants’ conduct in violating Mr. Targeted’s privacy, plaintiff has suffered harm and damages in excess of $75,000.00.  WHEREFORE, plaintiff respectfully requests judgments of the court against all of the defendants awarding to plaintiff (i) damages in excess of $75,000.00 for each defendant; (ii) pre- and post-judgment interest; (iv) costs, including reasonable attorney fees for this action; (v) injunctive relief enjoining the above named defendants from continuing the invasion of plaintiff’s privacy; and (vi) any other relief deemed just and equitable by the court.

    2.  Violations of Plaintiff’s 14th Amendment Right to Due Process
    and Equal Protection Under the Law


 

  1. Plaintiff incorporate by reference paragraphs 1 through 91 of this Complaint.

  2. The conduct of the defendants (the government, the President, the DOD, DOJ, FBI,____________, and other known/unknown state actors) to engage in unwarranted and illegal domestic surveillance and harassment and issue a National Security Letter against Mr. Targeted without good cause violated his right to due process of law and equal protection under the 14th Amendment to the United States Constitution.

  3. The conduct of the above named defendants to engage in unwarranted and illegal domestic surveillance, electronic harassment and to issue a National Security Letter against Mr. Targeted deprived him of his rights under the Constitution pursuant to 42 USC 1983.

  4. The above named defendants owed Mr. Targeted a duty not to violate his right to due process and equal protection under the aforementioned laws.

  5. The above named defendants breached the duty owed Mr. Targeted.

  6. As a result of the defendants’ conduct in violating Mr. Targeted’s right to due processand equal protection, plaintiff has suffered harm and damages in excess of $75,000.00.      WHEREFORE, plaintiff respectfully requests judgments of the court against all of the defendants awarding to plaintiff (i) damages in excess of $75,000.00 for each defendant; (ii) pre- and post-judgment interest; (iv) costs, including reasonable attorney fees for this action; (v) injunctive relief enjoining the above named defendants from continuing the invasion of plaintiff’s privacy; and (vi) any other relief deemed just and equitable by the court.

 

3.  Violations of FISA and the Patriot Act

  1. Plaintiff incorporates by reference paragraphs 1 through 97 of this complaint.

  2. The conduct of the defendants (the government, the President, DOD, DOJ, FBI, Mr. ____________, and other known/unknown state actors) to issue a National Security Letter against Mr. Targeted and conduct unwarranted and illegal domestic, physical and electronic surveillance and harassment of him constitutes a violation of the Foreign Intelligence Surveillance Act of 1978 and the USA Patriot Act.

  3. Under the National Security Letter (NSL), the above named defendants caused to be conducted willful and intentional electronic and electromagnetic surveillance of Mr. Targeted without good cause and without a warrant (i.e., phone calls, remote voices, computer monitored, gang-stalking at library/theatre/restaurants and sleep deprivation.)

  4. The above named defendants conduct was an invasion of Mr. Targeted’s privacy.

  5. The above named defendants owed Mr. Targeted a duty not to conduct unwarranted surveillance of him, to invade his privacy, or to cause him mental anguish and bodily harm.

  6. The above named defendants breached their duty owed the plaintiff in this matter.

  7. As a result of the defendants’ unwarranted surveillance and invasion of privacy, plaintiff suffered harm in excess of $75,000.00.       WHEREFORE, plaintiff respectfully requests judgments of the court against all of the defendants awarding to plaintiff (i) damages in excess of $75,000.00 for each defendant; (ii) pre- and post-judgment interest; (iv) costs, including reasonable attorney fees for this action; (v) injunctive relief enjoining the above named defendants from continuing the invasion of plaintiff’s privacy; and (vi) any other relief deemed just and equitable by the court.

 

4.  Outrageous Government Conduct Causing Intentional
Infliction of Emotional Distress/Tort of Outrage

  1. Plaintiff incorporates by reference paragraphs 1 through 104 of this Petition.

  2. The conduct of the defendants (the government, the President, DOD, DOJ, FBI, IRS,____________, and other known/unknown state actors) in participating in the Task Force to illegally extort money from plaintiff and other elderly people was extreme and outrageous.

  3. Defendants’ conduct in illegally issuing a National Security Letter (NSL) against Mr. Targeted to put him under surveillance andcause him emotional distress and bodily harm without good cause was extreme and outrageous. 

  4. At all relevant times, the defendants’ participation in the illegal goals of the Task Force to cause him electronic/electromagnetic surveillance, sleep deprivation, gang stalking, and the like was intentional and with full knowledge that their conduct was substantially certain to result in severe emotional distress and bodily harm to plaintiff.

  5. By participating in the plan to use a National Security Letter (NSL) to cause severe emotional distress, mental anguish and bodily harm, the defendants breached their duty owed the plaintiff.  Their conduct was grossly disproportionate under such circumstances, and amounted to an abuse of power that shocks the conscience of any reasonable person.

  6. The conduct of the defendants and others to participate in the Task Force to target plaintiff through the use of a National Security Letter for over four years, knowing he was innocent, was in bad faith and violated the duties of good faith and fair dealing toward the plaintiff.

  7. Due to the defendants’ acts and failures to act, plaintiff suffered severe emotional distress and bodily harm as a result of their participation in the Task Force under the National Security Letter to cause him extreme pain and suffering, including, but not limited to:  prostate cancer, sleep deprivation, heart pain, headaches, numbness in legs and feet, ears popping, blurred vision, twitching in hands and eyes, broken teeth and lacerations from falling down, flatulence and nightmares.

  8. The conduct of the defendants was so outrageous in character, and so extreme in degree, as to go beyond all bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized society.  Reciting the facts in this matter to an average person causes resentment toward all defendants, and leads them to exclaim: “Outrageous!”

  9. The outrageous conduct of the defendants constitutes intentional infliction of emotional distress/bodily harm and liability to plaintiff for his injuries.

  10. As a result of the outrageous conduct by all defendants, plaintiff has been damaged in excess of $250,000.00.   WHEREFORE, plaintiff respectfully requests judgments of the court against all of the defendants awarding to plaintiff (i) damages in excess of $250,000.00 for each defendant; (ii) pre- and post-judgment interest; (iii) costs, including reasonable attorney fees, for this action; (iv) injunctive relief enjoining all defendants from continuing the intentional infliction of emotional distress; and (v) any other relief deemed just and equitable by the court.

           Respectfully submitted,

By:_______________________________
I.  M.  Targeted                
P.O. Box 666 
Anywhere, U.S.A.  00000
Ph:  000-000-0000
E-mail:  targetedindividual.com

 


DESIGNATION OF TRIAL

          Plaintiff designates Big City, U.S.A. as the location for the trial in this matter.

           Respectfully submitted,

By:_______________________________
I.  M.  Targeted                
P.O. Box 666 
Anywhere, U.S.A.  00000
Ph:  000-000-0000
E-mail:  targetedindividual.com

 

 

 

DEMAND FOR JURY TRIAL

 

           Plaintiff respectfully requests that the issues in this matter be heard by a jury.

           Respectfully submitted,

By:_______________________________
I.  M.  Targeted                
P.O. Box 666 
Anywhere, U.S.A.  00000
Ph:  000-000-0000
E-mail:  targetedindividual.com

 

CERTIFICATE OF SERVICE

            I  hereby certify that on this _____day of July, 2016, a copy of the above and foregoing Complaint and Summonses were filed with the United States District Court for the Southern District of Florida, and copies deposited in the United States mail, certified, return receipt and properly addressed, to:

Secretary Ashton Carter Attorney General Loretta Lynch            FBI Headquarters
Department of Defense  Department of Justice                             Attn: Mr. James Comey     
The Pentagon                 950 Pennsylvania Ave., NW                  935 Pennsylvania Ave., NW      
Washington, D.C.  20301                 Washington, D.C.   20530                      Washington, D.C.  20535  

 

Additional Defendant(s) U. S. Attorney [your state]
Address        Address
City, State    City, State

 

_______________________________
I.  M.  Targeted                
P.O. Box 666 
Anywhere, U.S.A.  00000
Ph:  000-000-0000
E-mail:  targetedindividual.com

 

 

 

 


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