People usually expect government to protect them from predators and criminals. Getting victimized by the criminal acts (meant literally, and not as a figure of speech) of corrupt government officials is not high on the list of what folk expect, and it certainly wasn't high on mine - until I had the misfortune of experiencing that firsthand. 

   Cest la vie, live and learn, and, this being America, go to Court.

   The legal Complaint (also copied and pasted below) does a decent job of describing the barebones of the illegalities committed by Directorate of Operations. If you're not a lawyer, a Complaint is basically a laundry list of grievances caused by illegal conduct.  However, not every wrong is illegal, and a Complaint as a legal document is not the best vessel for narrating a story.  So the rest of this website is dedicated to fleshing out the contents of the Complaint by sharing with the public the tawdrier details of CIA recruitment - I take that sunshine-of-public-disclosure-is-the-best-disenfectant-for-government-misconduct quite literally. 

   Besides, while this CIA corruption and abuses stuff can be a nightmare if you're actually forced to deal with it firsthand, it makes for an entertaining read - I always liked writing - not enough to give up my day job to become a writer, but enough to see that the silver lining in this mess is that it gave me something worthwhile to write about. 

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

COMPLAINT

   Plaintiff Khalid Elhassan ("Plaintiff"), suing on behalf of himself, complains as follows against the 

   Plaintiff Khalid Elhassan ("Plaintiff"), suing on behalf of himself, complains as follows against the Central Intelligence Agency and the above-captioned Defendants:

INTRODUCTION

   1.   This action seeks redress for illegal and/or tortuous acts stemming from the corruption and racism rife within the Central Intelligence Agency’s (“CIA”) Clandestine Service Training (“CST”) division and to which Plaintiff was subjected, that were committed by Defendants in connection with Plaintiff’s application for employment with the CIA, the security clearance processes which ensued, the harassment, hazing and discrimination to which Plaintiff was subjected, and the subsequent retaliation to which Plaintiff was subjected when he complained of said harassment, corruption, and racism. 

   2.   Plaintiff alleges that Defendants engaged in and conspired to commit tortuous and wrongful acts including violations of Plaintiff’s civil rights, violations of 42 USC § 1981, 42 USC § 1982, 42 USC § 1983, 42 USC § 1985, 42 USC § 1986, violations of rights under Title VII U.S.C., invasion of privacy, abuse of process, malicious prosecution, common law fraud, wrongful interference with business opportunities, intentional infliction of emotional distress, and violation of Plaintiff’s constitutional rights under the Fourth and Fifth Amendments so as to give rise to a Bivens action.
 
JURISDICTION 

   3.   This court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331, 1343, 1346, 1356, 1361, 2201 and 2671 et seq.; Bivens v. Six Narcotics Agents, 403 U.S. 388 (1971); and supplemental jurisdiction pursuant to 28 U.S.C. § 1367.

VENUE 

   4.   Venue in this District is proper pursuant to 28 USC §§ 1391 and 1402, as Plaintiff resides in this District, the Defendants are a federal agency and employees of a federal agency, and many of the claims arose in and/or continued in this District.

PARTIES 

   5.   Plaintiff, Khalid Elhassan, is an African American of Middle Eastern descent, residing at 182-A Rutgers Road, in the township of Piscataway, County of Middlesex, and State of New Jersey. 

   6.   Defendant Porter Goss is the director of the Central Intelligence Agency (“CIA”), a United States government agency with headquarters in Langley, Virginia, and operations worldwide. 

   7.   Defendant Wanda Mitchell is a CIA recruiter, working for the CIA’s Directorate of Operations (“DO”), Clandestine Service Training (“CST”) Division. 

   8.   Defendant Travis Close is a CIA employee or agent. 

   9.   Defendant Patrick Eager is a CIA employee or agent. 

   10.   Defendant Eric is a CIA employee or agent, and was Defendants Close’s and Eager’s immediate supervisor. 

   11.   Investigator Fox presented herself to Plaintiff as an employee of the DIA, in connection with Plaintiff’s security clearance. 

   12.   Investigator Russ or Ray presented himself to Plaintiff as an employee of the DIA, in connection with Plaintiff’s security clearance. 

   13.   David Thompson is a CIA employee or agent. 

   14.   Stella Accorinti is a CIA employee or agent. 

   15.   Thomas Gallahue is a judge in the Fairfax County General District Court. 

   16.   Meghan Matulka presented herself to Plaintiff as a public defender.
 
   17.   Agents John and Jane Doe 1-10 are employees or agents of the CIA whose identity is unknown to Plaintiff, and who acted under the direction of and concert with the named Defendants to commit the acts complained of. 

   18.   At all times material hereto, the conduct complained of herein was carried out by each Defendant acting in concert with the other Defendants.

FACTS UNDERLYING THE COMPLAINT 

   19.   Following the terror attacks of September 11, 2001, Plaintiff sent a resume and cover letter to the CIA, volunteering and seeking employment as an Operations Officer with the CIA’s Directorate of Operations ("Exhibit A").

   20.   Following a series of interviews by CIA recruiters ("Exhibits B1 through B10"), Plaintiff was offered employment in April of 2002, and asked whether he would be available for a yearlong Clandestine Service Training (“CST”) class scheduled to start in July of 2002. Plaintiff responded that he would be available in July if given one or two weeks’ notice prior to the start date, and soon thereafter received Conditional Offer of Employment Letter (“COE Letter”), dated April 16, 2002 ("Exhibit C").

   21.   On or about May of 2002, Plaintiff underwent an additional series of interviews with the CIA, including a two day interview with a CIA polygrapher-psychiatrist. 

   22.   During the second day of interviews with the CIA’s polygrapher-psychiatrist, Plaintiff was strapped to a chair while attached to various sensors. After many hours of repetitive and lulling questions while being instructed to keep his eyes focused on a blank wall, the polygrapher-psychiatrist tightened some straps on Plaintiff’s arm so as to cut or reduce Plaintiff’s circulation, and instructed Plaintiff to count back from ten to one as a means of inducing hypnosis – without informing Plaintiff that he was to be hypnotized or obtaining Plaintiff’s consent to same. 

   23.   Plaintiff was hypnotized for an unknown period of time. He awoke to the polygrapher-hypnotist snapping his fingers, and instructing Plaintiff by way of post-hypnotic suggestion that he “fell asleep” and “don’t tell anybody about this.” 

   24.   Plaintiff knew too little of hypnosis at the time to understand the significance of what had occurred, but nonetheless felt sullied, dirtied, and troubled by the event so as to have second thoughts about working for the CIA. 

   25.   On May 22nd, 2002, Plaintiff was interviewed in his office by a DIA investigator named Fox, who informed Plaintiff that she was conducting a security clearance background investigation on him. Investigator Fox concentrated her questions on Plaintiff’s income, and was particularly interested in the margin between Plaintiff’s income and expenditures. Investigator Fox was also interested in finding out when a public interest legal fellowship on which Plaintiff was then-employed would end, as well as his alternative future career plans should he not end up working for the U.S. government. Plaintiff informed investigator Fox that the fellowship would end in Mid-to-late November, 2002, and that should he not end up working for the U.S. government, Plaintiff would pursue his pre-9/11 plans and seek an associate’s position in a plaintiff law firm. 

   26.   The answers to investigator Fox’s questions were subsequently used, as described below, as part of the CIA recruitment process, in order to maneuver Plaintiff into financial straits, and foreclose or limit Plaintiff’s opportunities for alternative future employment so as to render Plaintiff a more vulnerable and thus more pliant recruit. 

   27.   Investigator Fox also requested that Plaintiff provide the contact information for any of his former girlfriends. On grounds of his and their privacy, Plaintiff declined that request. 

   28.   Investigator Fox then asked Plaintiff whether he had a girlfriend at the time, and Plaintiff informed her that he did not. 

   29.   Intercepting, tapping into, and manipulating Plaintiff’s telephone and other communications as well as electronic correspondence on personals websites, from 2002 through the presence, the CIA then arranged a series of CIA agent girlfriends for Plaintiff. 

   30.   Starting in late May of 2002, Plaintiff met and was entertained by a series of female CIA agents, all of whom expressed keen interest in, and quizzed Plaintiff about, his views on the topics that had been of keen interest to the CIA recruiters with whom Plaintiff had previously interviewed. They also methodically quizzed Plaintiff on the answers Plaintiff had given CIA interviewers. 

   31.   In June of 2002, Plaintiff began dating and commenced physical relationships with some of the female agents sent his way by the CIA recruiters, one of whom was Defendant Wanda Mitchell. 

   32.   Defendant Mitchell sought to act as Plaintiff’s “mentor” during the course of what she told Plaintiff would be a long and tortuous recruitment process that Plaintiff might not understand, but with which he should nonetheless be patient. She informed Plaintiff that the process entailed considerable hazing, and likened it to what she called “prags” and “pragging” – slang terms popularized at the time by a cable television series and referring to a perverted and sadomasochistic relationship between dominant and submissive prisoners. She added that to thrive in the CIA’s Directorate of Operations, one has to be a “glutton for punishment.” 

   33.   Defendant Mitchell also informed Plaintiff that his progress within the recruitment process was contingent upon Plaintiff’s maintaining and continuing the dating relationship with Mitchell. 

   34.   Defendant Mitchell grew cross when Plaintiff informed her that he thought the process she described sounded juvenile insofar as the hazing, was troubling in that it resembled induction into a cult rather than a federal agency, and had a high potential for corruption and abuse in light of the secrecy and lack transparency surrounding her work – as evinced by Mitchell informing Plaintiff, a job applicant, that his progress was contingent upon the continuation of a personal and meretricious relationship with her. 

   35.   Defendant Mitchell grew more cross when Plaintiff told her he was thinking of withdrawing his application for employment with the CIA, and refused to simply “be patient” and “just go along” as Mitchell advised. When Plaintiff explained that the CIA was, at the end of the day, “a federal agency, not God,” Mitchell began a running joke themed around the CIA actually being close to the Almighty, and began thereafter to make pointed and sinister remarks to the effect that Plaintiff would change his mind in due course. 

   36.   Mitchell grew even more cross when Plaintiff stopped sleeping with her soon thereafter. She nonetheless continued to call and visit Plaintiff until told he no longer wished to see her. 

   37.   Also in June of 2002, a DIA investigator by the name of Ray or Russ contacted Plaintiff to inquire about Plaintiff’s then-place of residence, 8205 Cooper Street, in Fairfax, Virginia. Investigator Ray or Russ asked whether Plaintiff had a personal relationship or ties with either Plaintiff’s landlord or the owner of the property in which Plaintiff dwelled, or whether the relationship was an arms’ length landlord-tenant relationship. Plaintiff told investigator Ray or Russ that the relationship and ties were simply those of landlord-tenant. Investigator Ray or Russ then asked whether Plaintiff’s name was on the lease, and was told that it was not. 

   38.   Investigator Ray or Russ then asked for the contact information of Plaintiff’s landlord as well as that of the property owner. Suspicious at the time of the motives behind that line of questions but dismissing such suspicions as far-fetched and unlikely in this modern era of an accountable and reformed government intelligence community, Plaintiff gave Investigator Ray or Russ the contact information sought. 

   39.   In the meantime, starting in late June, 2002, and over a three week period that followed, Plaintiff tried without success to contact the person described in his CIA offer of employment letter as “your Program Officer, Ann,” in order to ascertain the start date of the July Clandestine Service Training class, whether or not Plaintiff was in that class, and to discuss Plaintiff’s growing unease with Defendant Mitchell, what he had seen of the recruitment process to date, and the withdrawal of his application for employment with the CIA. 

   40.   On or about July 10th, 2002, Plaintiff informed Defendant Mitchell that he intended to withdraw his application for employment as he had not heard back from the agency, and was growing frustrated with not being able to speak with his contact person despite three weeks’ worth of attempts, and that “fun as it has been,” he could not afford the uncertain wait and needed to carry on with his life and move on. Mitchell tried to talk Plaintiff out of withdrawing his application, again counseling patience and informing him that she herself had to wait a long time when it was her turn. 

   41.   On July 12th, 2002, Plaintiff finally spoke with his “Program Officer, Ann,” who put Plaintiff in touch with her supervisor when asked about the July Clandestine Service Training class. Ann’s supervisor informed Plaintiff that the July class had already started, and asked whether Plaintiff would be interested in another class scheduled for December of 2002. Plaintiff thanked Ann’s supervisor for having considered him for the job, asked her to withdraw his application, and informed her that he would send a formal letter of withdrawal by way of confirmation. 

   42.   On the same day, July 12th, 2002, Plaintiff sent the CIA a Withdrawal Letter thanking the agency for having considered him for employment, and withdrawing his application for employment ("Exhibit D").
 
   43.   On or about July 12, 2002, Defendant Mitchell, Investigator Russ and/or other CIA officials met with Plaintiff’s landlord, and instructed him to evict Plaintiff. 

   44.   The following day, July 13, 2002, Plaintiff found taped to his door an eviction notice from his landlord, stating that “due to circumstances beyond my control, I will no longer be able to sub-rent you a room,” and closing with “I regret this situation but [it] is well beyond my control.”Eviction Notice ("Exhibit E"). 

   45.   Later, on the same day, Defendant Mitchell visited Plaintiff for the weekend, and taunted him about the eviction, and asked about his future residential plans. 

   46.   On July 18th, 2002, Plaintiff inquired via email, about some room-for-rent advertisements. Defendants intercepted Plaintiff’s emails, and Defendant Travis Close, impersonating an advertiser for a room rental, emailed Plaintiff a response. ("Exhibits F1 and F2").

   47.   Defendant Close, without identifying himself at the time as a CIA agent or employee, introduced himself to Plaintiff as a computer programmer for an obscure defense contractor working on national security-related computer programs, and showed Plaintiff the room, located at 6508 Walter Drive, Alexandria, VA 22315. The monthly rent was $700, including utilities - $250 more than Plaintiff had paid at his prior place of residence. Plaintiff and Close agreed that Plaintiff would move to the new place in late August or early September of 2002. 

   48.   Soon thereafter, in late July of 2002, Defendant Mitchell, who sought to continue dating Plaintiff notwithstanding the withdrawal letter of July 12th, invited Plaintiff to go sightseeing with her at the Baltimore Inner Harbor on August 3rd, 2002, on which date Defendant Mitchell arranged for Plaintiff’s former fiancé, whom Plaintiff had not seen in over a year and who lived in Charlottesville, Virginia, about 200 miles away from the Baltimore Harbor and 120 miles away from Plaintiff, to “cross paths” with Plaintiff in order to see how Plaintiff would react. 

   49.   Plaintiff informed Defendant Mitchell that he was both offended and upset by such an intrusion in his zone of personal privacy, and that he was troubled by the fact that Mitchell and her employers were abusing their government authority to harass Plaintiff in such manner. 

   50.   Asked by Plaintiff whether that meeting was a coincidence, Wanda Mitchell informed Plaintiff that “there are no coincidences,” that it had been necessary to arrange for that meeting’s occurrence because it had been determined by the CIA that Plaintiff was “ready to move on to the nextlevel” (whatever that was), that Plaintiff’s former fiancé, a U.S. citizen of Arab descent, was the last thing holding him back, and that Plaintiff needs to “let her go” because lingering affection for her might cause problems in the future. 

   51.   Notwithstanding that it was nobody’s business whether or not he had lingering affection for his former fiancé or anybody else, Plaintiff informed Mitchell that he had not seen or spoken with his former fiancé in over a year, and had no intention of seeing or speaking with her in the future. Defendant Mitchell responded that the former fiancé was nonetheless still in Plaintiff’s “subconscious mind,” and then attempted to explain to Plaintiff the difference between the “unconscious mind” and the “subconscious” one in the context of hypnosis – such as the unconsented-to hypnotism to which Plaintiff had been subjected during his polygraph/psychiatric examination. 

   52.   Defendant Mitchell also informed Plaintiff that she had recently driven to Charlottesville, Virginia, the town where Plaintiff had attended law school and which Plaintiff had described as the site of the best three years of his life to Mitchell, his CIA interviewers and polygraph examiners, and in which Plaintiff’s former fiancé still lived, in order to visit Plaintiff’s law school, as well as the townhouse where Plaintiff had lived during law school so as to more familiarize herself with Plaintiff’s psyche. 

   53.   When Plaintiff iterated that he was deeply offended at such an intrusion into his zone of privacy, reminded Mitchell that he had withdrawn his application weeks ago and that the CIA thus had no legitimate purpose to intrude on his privacy in such manner, and that it was inappropriate for her or the CIA to continue to have anything to do with Plaintiff at all, Defendant Mitchell grew irate and asked Plaintiff “do you think you are being sought after?” 

   54.   Defendant Mitchell also told Plaintiff that his life could be in jeopardy if he made waves about what the CIA’s abusive interactions with him to date. 

   55.   When asked “so, what’s next? Where do we go from here?” Defendant Mitchell iterated that was contingent on how much effort Plaintiff “wants to put into the relationship” between Plaintiff and Mitchell. She then told Plaintiff that it was “imperative” for him to accompany her home, give her a backrub and spend the night with her. Plaintiff declined, reiterated the withdrawal letter, and the fraying of his nerves at his wishes not being respected in that matter. When Mitchell next visited Plaintiff’s home, the following week, Plaintiff broke off the relationship with Mitchell, at which point she grew extremely angry, cursed Plaintiff, did donuts with her car on the street outside Plaintiff’s home, then took off with squealing tires and burning rubber. 

   56.   Plaintiff was also informed that much of the CIA induction process was similar to the plot of a novel called the Magus, which Plaintiff was urged to read, and in which the main character is harassed by a secretive cabal who set out to destroy his life as he knew it, as a prelude to a rebirth or epiphany or the such. 

   57.   Two weeks later, in late August of 2002, Plaintiff moved into 6508 Walter Drive with Defendant Close. From the onset, Close methodically sought to recreate the conversations Plaintiff had with CIA interviewers and polygraph examiners months earlier, often asking the same questions, verbatim, that Plaintiff had been asked by his CIA interviewers and polygraph examiners. Close also methodically quizzed and sought to draw Plaintiff into conversations intended to flesh out the answers given in the formal interviews with CIA recruiters, and otherwise methodically inquire about Plaintiff’s views and attitudes on matters of relevance to the security clearance process. 

   58.   A week after moving into 6508 Walter Drive, Defendant Eager also moved to 6508 Walter Drive. Eager introduced himself to Plaintiff as a former member of a secretive biological/chemical/nuclear warfare U.S. Marine Corps unit which serves as America’s designated first-response unit in case of biological/chemical/nuclear attack on U.S. soil. Eager told Plaintiff that he had recently started a new job in the same field, but for a private contractor. 

   59.   As with Close, Eager also methodically sought to recreate the conversations Plaintiff had with CIA interviewers months earlier, often asking, verbatim, the exact same questions asked Plaintiff during the formal interviews with CIA recruiters. Similarly, Eager methodically sought to draw Plaintiff into conversations intended to flesh out the answers given in the formal interviews with CIA recruiters, and otherwise methodically inquire about Plaintiff’s views and attitudes on matters of relevance to the security clearance process. 

   60.   Defendants Eager and Close also expressed views that Plaintiff thought problematic coming from government employees, such as the view that there should be no Congressional oversight over the CIA or other intelligence agencies, and the view that intelligence agents should be left to their own devices and allowed to operate on a “trust us” basis. Defendant Eager became upset when Plaintiff disagreed with such premises and described them as “fascist.” 

   61.   When Plaintiff questioned Eager about the reason behind all the questions, Eager replied that Plaintiff was being “checked out” as part of the security clearance process, and that “they [the CIA], are looking and digging into everything until they find something.” 

   62.   Plaintiff told Eager that he was offended that the CIA had such temerity so as to intrude on Plaintiff’s life by causing Plaintiff’s eviction from his prior residence in order to steer him into a new one staffed by CIA operatives, notwithstanding that Plaintiff had withdrawn his application, and that the CIA thus had no legitimate purpose in harassing, hazing, or playing games with Plaintiff. 

   63.   Defendant Eager told Plaintiff that he had better call the CIA and tell them that he remains interested in employment with the agency. Eager then asked where Plaintiff saw himself in ten years if he was in the CIA, and when told “I don’t have a basis for comparison, but I guess somewhere at the front of the pack,” Eager urged Plaintiff to re-contact the CIA recruiters with whom Plaintiff had previously dealt and communicate that answer to them. 

   64.   Soon thereafter, Plaintiff sought further clarification from Defendant Close as to why he been manipulated and maneuvered into moving to a CIA-staffed house, and inquired whether this was simply harassment for Plaintiff’s breaking up with Defendant Mitchell, and whether Close thought there was anything corrupt about government officials, such as Close and others with whom he worked, abusing their official authority to both harass Plaintiff, as well as abuse their official authority to seek personal pecuniary gain from Plaintiff in the form of rental payments. 

   65.   Defendant Eager thought it was funny and amusing, and told Plaintiff that it was simply part of the hazing that goes with the job. When Plaintiff reiterated that he was not interested in a job with the CIA, and that he had withdrawn his application months earlier, Defendant Eager responded that Plaintiff should be patient, as they had all been patient when they were being inducted. 

   66.   Defendant Eager also informed Plaintiff that much of the process consisted of what Eager described as “mind fucking,” intended to “challenge” an inductee’s basic belief structure. 

   67.   When asked what legitimate official purpose could involve the use of official power so as to secure officials money from a prospective job applicant, let alone an applicant who had withdrawn his application months earlier, Defendant Eager responded that was simply a part of the hazing that everybody goes through during clandestine training, and that Plaintiff should be happy to contribute because his CIA supervisor had recently gotten married, had a newborn child, and “needed a new porch.” 

   68.   David Thompson also informed Plaintiff that his recruiter’s house must need repairs or some such – which is why the new CIA recruits such as Plaintiff were being charged so much “rent” this year. 

   69.   Simultaneously, Defendants interfered with Plaintiff’s job search at the end of his fellowship with Trial Lawyers for Public Justice so as to steer Plaintiff to CIA recruiters. Defendants intercepted Plaintiff’s emails to prospective legal employers, prevented those emails from reaching their intended recipients, and approached those recipients whom Plaintiff did reach and arranged to deprive Plaintiff of the opportunity to interview with any of those law firms. 

   70.   Defendant Eager then offered to introduce Plaintiff to a CIA recruiter who could give Plaintiff a highly lucrative job. Plaintiff declined. 

   71.   Soon thereafter Plaintiff demanded an explanation about the harassment to which he was being subjected by Close and other CIA officials, and told Close that he would not pay him a dime until he received an explanation. 

   72.   Defendant Close remonstrated with Plaintiff for openly mentioning the CIA – as if it were a game in which Plaintiff was not supposed to ever mention the CIA, or as if Plaintiff should care in light of the withdrawal of his application months earlier. 

   73.   Defendant Eager thought it was hilarious that Plaintiff was bewildered by the hazing to which he was being subjected, and told Plaintiff things such as “recruit Elhassan, here’s a knife – go ahead and stab Travis [Close]” and “you’re in the CIA.” 

   74.   Defendant Close then called Defendant Erik, whom close identified as “our boss. On a serious note, this really is my boss, the guy in charge of security.” Close then informed Plaintiff that he and Defendant Eager were part of Plaintiff’s induction process. 

   75.   Defendant Erik asked Plaintiff to “just play along,” chided Plaintiff for “exhibiting signs of independent thinking. The CIA doesn’t like independent thinkers – we’re looking for yes men,” since independent thinkers are liable to go off half-cocked, and “you know, get themselves in trouble like those guys from [the movie] Spy Game.” 

   76.   In the meantime, Eager was advising Plaintiff to “not worry about the CIA side of things for now – just enjoy life, and have as much as fun as you can,” iterated that Plaintiff should “just be cool” and “just go along,” and otherwise informed Plaintiff that this was all simple hazing. 

   77.   Plaintiff told Defendant Eager that there was nothing funny or amusing about conditioning a government agent’s performance of his official duties on the receipt by such agent of money in his private capacity, and that such abuse of official power for personal pecuniary gain was illegal and most likely criminal extortion and a “simple shakedown.” Defendant Eager ceased to think it was amusing, and told Plaintiff to “just go along” and “just be cool.” 

   78.   Plaintiff told Eager that he was not cool, that he had no intention of going along with such flagrant official corruption or allowing officials to harass him or shake him down for money as a condition for the performance of their duties, and that he intended to seek redress. Defendant Eager told Plaintiff that he would be making a serious mistake if he ever talked about the recruitment abuses, or else the CIA would really show Plaintiff “they’re God.” 

   79.   Plaintiff iterated that he intended to seek redress for the abuses to which he had been subjected, regardless, and that he thought it a shame that Eager’s supervisors had apparently allowed the clandestine training process to degenerate into a corrupt and racist fraternity in which government officials with little supervision where allowed to abuse government authority as a means for petty harassment, hazing, retaliation, and private enrichment from job applicants and potential recruits. 

   80.   As a result and by way of further harassment and retaliation, Defendants caused Plaintiff’s status to change from a sought-after recruit with a Top Secret Security Clearance ("Exhibit G"). 

   81.   Immediately thereafter, Defendant Eager began asking and taunting Plaintiff whether he knew how to make ricin and other chemicals or explosives, and whether he knew any terrorists. 

   82.   Defendant Eager also began referring to “niggers” in conversations with others, within hearing distance of Plaintiff. 

   83.   By late December, 2002, and as a result of the preceding, Plaintiff was depressed to the point of nervous breakdown and becoming suicidal. 

   84.   Defendants also arranged for Eager to cause Plaintiff’s false arrest on a weapons brandishing charge in December of 2002. 

   85.   Defendant CIA employs liaison officials to local state authorities, tasked with covering up the misconduct of CIA employees and keeping such misconduct out of the public eye. Liaison Official Letter ("Exhibit H"). 

   86.   Through their liaison officials, Defendants arranged with local authorities for Thomas Gallahue to lend his court room to a “pretend” case that did not appear on the docket, in a court room cleared of all spectators, without even a clerk, sheriff, or prosecutor, and in which Plaintiff was threatened with imprisonment unless he cooperated with the Defendants and agreed to keep silent about all the abuses to which he had been subjected by the Defendants. 

   87.   In reality, there was no case pending against Plaintiff, nor was there such a case on the docket. 

   88.   Defendants also continued to intercept Plaintiff’s correspondence and prevent it from reaching its intended recipients – particularly correspondence in which Plaintiff sought assistance in redressing the very abuses to which Defendants had subjected and were subjecting Plaintiff. 

   89.   In addition to intercepting Plaintiff’s correspondence so as to prevent it from reaching the intended recipients, Defendants also impersonated some of the people whom Plaintiff had sought to reach. Included amongst those whom Defendants impersonated are: 

      a. Staffers of Plaintiff’s then-Congressman, James Moran; 
      b. Seymour Hersh, of the New Yorker magazine; 
      c. Lynne Bernabei, an attorney; 
      d. Lynn Wood, an attorney. 

   90.   In the meantime and in addition to the interception of Plaintiff’s correspondence seeking assistance against abuses by the very Defendants intercepting Plaintiff’s correspondence, Defendants continued to threaten Plaintiff with the “pretend” case in Judge Gallahue’s court room, for a ten month period between January and November of 2003. 

   91.   When Plaintiff refused to stay silent and continued his efforts to seek redress, including redress for the corruption and abuse occurring in Judge Gallahue’s courtroom, Defendants intensified their harassment, including but not limited to: 

      a. Prank-calling Plaintiff and taunting him about what he thought of the CIA now; 
      b. Stalking and shadowing Plaintiff so as to intimidate him with uncomfortably close surveillance; 
      c. Harassing Plaintiff by frequently stopping him and asking him whether he actually was Khalid Elhassan or was known by some other name, such as “Commando”; and 
      d. Threatening Plaintiff’s life. 

   92.   The “pretend” case continued, with multiple hearings threatening Plaintiff with dire consequences unless he kept silent about the abuses to which Defendants had subjected and continued to subject Plaintiff, until Plaintiff managed to deliver a letter via hand delivery to the chambers of the Chief Justice of the Virginia Supreme Court, describing the judicial corruption and abuses occurring in that court room. CJ Hassell Letter ("Exhibit I"). 

   93.   The following day, Plaintiff was instructed to appear before Judge Gallahue for a special hearing. 

   94.   The special hearing consisted of a chagrined Judge Gallahue tersely informing Plaintiff “Mr. Elhassan – you are released. You are free to go.” 

   95.   Notwithstanding, Defendants sought to further intimidate Plaintiff by falsely informing him that the case had been “appealed,” and further threatening him with dire consequences on the “appeal” if he did not “stop trying to cause trouble.” 

   96.   In reality, there never was such an “appeal,” and Plaintiff was eventually, and falsely, informed by Defendants and Meghan Matulka that the case had been “dismissed.” There was no dismissal because there never had been a case on the docket to begin with, as described in Addendum to CJ Hassell Letter ("Exhibit J"). 

   97.   Defendants similarly arranged for another fixed in the same court, in which the courtroom was again cleared of all except Plaintiff and the Defendants, in which Plaintiff was prevented from testifying, and when Plaintiff sought to exercise his appeal-by-right, he was prevented from doing so by the presiding judge, notwithstanding that a litigant’s right to appeal in such cases is mandatory by statute rather than resting within the discretion of any judge. 

   98.   Defendants similarly interfered with Plaintiff’s attempts to seek redress in federal Court, Judge Luttig Letter ("Exhibit K"), intercepting Plaintiff’s correspondence seeking assistance in vindicating his rights, including the impersonation of attorneys and others whose assistance Plaintiff had sought. 

   99.   Following the “dismissal,” Defendants attempted to convince Plaintiff that what he had been put through was not simply a group of corrupt officials attempting to cover up their malfeasances, but rather an esoteric CIA test, and that it had been necessary to put Plaintiff through what they described as the “pressures of fire and hell” so as to forge him into a suitable instrument. This notwithstanding that Plaintiff had withdrawn his application long before most of the aforementioned abuses took place, or that Plaintiff had never asked or consented to be put through anything. 

   100.   Plaintiff was also informed by U.S. government officials, 106, infra, that Defendants had subjected Plaintiff to various psychological pressures as a means of “conditioning” him. This, notwithstanding that Plaintiff had never asked or consented to being “conditioned.” 

   101.   Plaintiff was also informed by a CIA instructor that Defendants initially “were fucking with you because you dumped their girl (Defendant Mitchell).” 

   102.   Plaintiff was also informed by an agent of the Defendants that the Defendants were operating on the assumption that Plaintiff had less legal and civil rights because of Plaintiff’s ethnicity and alienage. 

   103.   Throughout, Defendants repeatedly sought to recruit Plaintiff into their East African intelligence network, and Plaintiff repeatedly declined to have anything to do with that. 

   104.   Also following the “dismissal,” David Thompson told Plaintiff that he would finally be informed about the reasons behind all that Defendants had put Plaintiff through. 

   105.   Instead, David Thompson, who had previously coached Plaintiff on marksmanship, gave Plaintiff a scope mounted assault rifle and pointed him at the President – something which passes for funny by the standards of CIA humor. 

   106.   The Secret Service did not think it was funny when that was brought to their attention. Letter Draft ("Exhibit L"), and asked Plaintiff to help them set a sting for David Thompson. 

   107.   The day after the sting, CIA Director George Tenet announced his sudden “resignation,” as did the head of the CIA’s Directorate of Operations. 

   108.   Soon thereafter, in July of 2004, Defendants seized Plaintiff’s laptop computer, without a warrant. Defendants, who were interested in the computer because it contained many documents narrating the illegal actions and abuses to which Plaintiff had been subjected by the very Defendants who seized his computer, asked Plaintiff’s permission to read the contents of the computer. Plaintiff refused and replied that they should either get a warrant, if they could, or return his computer. When Defendants did neither and Plaintiff asked for his laptop back, he was informed by the seizing official “I’ll give it back when I get around to getting a warrant, and I’ll call you then.” To date, Defendants have not returned Plaintiff’s computer. 

   109.   In April of 2005, Defendants again intercepted Plaintiff’s correspondence, and again arranged for a CIA girlfriend, Stella Accorinti, to “meet” and attempt to seduce him as a prelude to recruitment. 

   110.   As with Defendant Mitchell, Accoriniti grew extremely angry when Plaintiff, upon realizing who had sent her and what she wanted, told her that he was interested in neither the CIA nor Accorinti. Among other things, she threatened Plaintiff that others in the CIA “want to hurt” Plaintiff, and told Plaintiff that he was a fool for breaking up with her “because I am the only person who can save you from the people in the CIA trying to hurt you.” 

   111.   Plaintiff thus finds himself in the unenviable position of a person who has faced a long term pattern of official misconduct, and who will continue to face a long term pattern of official misconduct at the hands of a group of criminally corrupt CIA officials who, under the guise of national security and the secrecy associated with the intelligence services, had subjected Plaintiff to egregious harassment for inappropriate reasons ranging from Plaintiff’s breaking off a dating relationship with one of those officials, to abuse of the CIA’s recruitment process as a means for extorting money from Plaintiff for those official’s personal pecuniary gain. When Plaintiff refused to go along and sought redress, those same officials, again under the guise of national security and secrecy, escalated and intensified their harassment in an attempt to intimidate Plaintiff into silence.

COUNT I
42 U.S.C.A. § 1981 VIOLATIONS 

   112.   Plaintiff hereby repeats and incorporates 1 through 111 as if fully set forth at length. 

   113.   Defendants, acting and continuing to act as aforesaid, wantonly, willfully, recklessly, outrageously and intentionally discriminated against and impaired Plaintiff’s rights under 42 USCA § 198, including but not limited to the right to enforce or pursue judicial enforcement of Plaintiff’s rights under 42 USCA § 1981, and did so on the basis of Plaintiff’s race and alienage. 

   114.   Plaintiff is a member of a racial minority, and acting as aforesaid, Defendants discriminated against and intended to discriminate against Plaintiff on the basis of his race and alienage; and said discrimination concerned Plaintiff’s rights as enumerated under 42 USCA § 1981. 

   115.   Defendants acted so as to deprive Plaintiff of the full and equal benefit of all laws. 

   116.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT II
42 U.S.C.A. § 1983 VIOLATIONS 

   117.   Plaintiff hereby repeats and incorporates 1 through 116 as if fully set forth at length. 

   118.   Defendants, acting and continuing to act as aforesaid, and as described in 84 through 97 specifically, wantonly, willfully, recklessly, outrageously and intentionally acted and conspired to act under color of state law so as to deprive Plaintiff of civil rights protected by 42 USCA § 1983. 

   119.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT
III 42 U.S.C.A. § 1985 VIOLATIONS 

   120.   Plaintiff hereby repeats and incorporates 1 through 119 as if fully set forth at length. 

   121.   Defendants, acting and continuing to act as aforesaid and as described in 84 through 97specifically, wantonly, willfully, recklessly, outrageously and intentionally acted and conspired to act under the color of state law so as to deprive Plaintiff of the equal protection of the laws, to deprive Plaintiff of equal privileges and immunities under the law, and to obstruct the course of justice in violation of 42 USCA § 1983, resulting in injury Plaintiff’s person and property, and preventing Plaintiff from exercising rights and privileges of a United States citizen. 

   122.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT IV
42 U.S.C.A. § 1986 VIOLATIONS 

   123.   Plaintiff hereby repeats and incorporates 1 through 122 as if fully set forth at length. 

   124.   Defendants, acting and continuing to act as aforesaid, knew of the conspiracy to deprive Plaintiff of civil rights in violation of 42 USCA § 1985, know and knew of the continued actions in furtherance thereof, and having the power to prevent same, wantonly, willfully, recklessly, outrageously and intentionally neglected or refused to do so, thereby violating Plaintiff’s rights under 42 USCA § 1986. 

   125.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper. 

COUNT V
42 U.S.C.A. § 1982 VIOLATIONS 

   126.   Plaintiff hereby repeats and incorporates 1 through 125 as if fully set forth at length. 

   127.   Defendants, acting and continuing to act as aforesaid, and as described in 108 specifically, wantonly, willfully, recklessly, outrageously and intentionally acted and conspired to act so as to violate Plaintiff’s rights under 42 USCA § 1982. 

   128.   Plaintiff is a member of a racial minority, and acting as aforesaid, Defendants discriminated against and intended to discriminate against Plaintiff on the basis of his race and alienage; and said discrimination concerned Plaintiff’s rights as enumerated under 42 USCA § 1982. 

   129.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT VI
BIVENS ACTION UNDER THE FOURTH AMENDMENT OF THE UNITED STATES CONSTITUTION 

   130.   Plaintiff hereby repeats and incorporates 1 through 129 as if fully set forth at length. 

   131.   Defendants, acting and continuing to act as aforesaid, wantonly, willfully, recklessly, outrageously and intentionally violated Plaintiff’s constitutional rights under the Fourth Amendment, giving rise to a cause of action for monetary damages separate and apart from statutory causes of action pursuant to Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). 

   132.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT VII
BIVENS ACTION UNDER THE FIFTH AMENDMENT OF THE UNITED STATES CONSTITUTION 

   133.   Plaintiff hereby repeats and incorporates 1 through 132 as if fully set forth at length. 

   134.   Defendants, acting and continuing to act as aforesaid, wantonly, willfully, recklessly, outrageously and intentionally violated Plaintiff’s constitutional rights under the Fifth Amendment, giving rise to a cause of action for monetary damages separate and apart from statutory causes of action pursuant to Bivens v. Six Unknown Federal Narcotics Agents, 403 U.S. 388 (1971). 

   135. Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT VIII
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

   136.   Plaintiff hereby repeats and incorporates 1 through 135 as if fully set forth at length. 

   137.   Defendants, acting and continuing to act as aforesaid, wantonly, willfully, recklessly or intentionally subjected Plaintiff to outrageous conduct so severe that no reasonable person could be expected to endure it, causing and intending to cause Plaintiff severe mental anguish and emotional distress. 

   138.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT IX
INVASION OF PRIVACY 

   139.   Plaintiff hereby repeats and incorporates 1 through 138 as if fully set forth at length. 

   140.   Defendants, acting and continuing to act as aforesaid, wantonly, willfully, outrageously, intentionally and unreasonably intruded upon Plaintiff’s solitude and private affairs in a manner highly offensive to a reasonable person. 

   141.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper. 

COUNT X
TORTIOUS INTERFERENCE WITH PROSPECTIVE ECONOMIC ADVANTAGE 

   142.   Plaintiff hereby repeats and incorporates 1 through 141 as if fully set forth at length. 

   143.   Defendants, acting and continuing to act as aforesaid, and as described in 69 and 70 specifically, wantonly, willfully, recklessly, outrageously and intentionally and recklessly interfered with and deprived Plaintiff of prospective economic advantage, and did so without excuse or justification. 

   144.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for $133,612.50, consequential and expectancy damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper. 

COUNT XI
COMMON LAW FRAUD 

   145.   Plaintiff hereby repeats and incorporates 1 through 144 as if fully set forth at length. 

   146.   Defendants, acting and continuing to act as aforesaid, and as described in 43 through 47 and 67 through 68 specifically, wantonly, willfully, recklessly, outrageously and intentionally made material misrepresentations which they knew at the time to be false, upon which misrepresentations Plaintiff reasonably relied, and otherwise abused their office for private pecuniary gain so as to defraud and extort from Plaintiff the sum of $2025. 

   147.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, restitution, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XII
BATTERY 

   148.   Plaintiff hereby repeats and incorporates 1 through 147 as if fully set forth at length. 

   149.   Defendants, acting and continuing to act as aforesaid, and as described in 22 through 24 specifically, wantonly, willfully, recklessly, outrageously and intentionally committed an unauthorized and offensive invasion of Plaintiff’s person. 

   150.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XIII
ASSAULT 

   151.   Plaintiff hereby repeats and incorporates 1 through 150 as if fully set forth at length. 

   152.   Defendants, acting and continuing to act as aforesaid, and as described in 91 specifically, wantonly, willfully, recklessly, outrageously and intentionally assaulted Plaintiff by intending to cause apprehension of an unauthorized and offensive contact, and impaired Plaintiff’s interest in freedom from a harmful or offensive contact. 

   153.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XIV
MALICIOUS PROSECUTION 

   154.   Plaintiff hereby repeats and incorporates 1 through 153 as if fully set forth at length. 

   155.   Defendants, acting and continuing to act as aforesaid, and as described in 84 through 97 specifically, wantonly, willfully, recklessly, outrageously and intentionally brought suit against Plaintiff without cause, actuated by malice, which suit was terminated in Plaintiff’s favor, and Plaintiff suffered a special grievance thereby. 

   156.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XV
ABUSE OF PROCESS 

   157.   Plaintiff hereby repeats and incorporates 1 through 156 as if fully set forth at length. 

   158.   Defendants, acting and continuing to act as aforesaid, and as described in 84 through 97 specifically, wantonly, willfully, recklessly, outrageously and intentionally committed an improper, unwarranted, and perverted use of process, for the ulterior purposes of coercing and oppressing Plaintiff, and committed acts in furtherance thereof that reveal such ulterior purposes. 

   159.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XVI
FALSE IMPRISONMENT AND FALSE ARREST 

   160.   Plaintiff hereby repeats and incorporates 1 through 159 as if fully set forth at length. 

   161.   Defendants, acting and continuing to act as aforesaid, and as described in 84 through 97 specifically, unlawfully, wantonly, willfully, recklessly, outrageously and intentionally detained and confined the Plaintiff against his will, without legal authority or justification, by employing force and the threat of force and causing a reasonable apprehension of force. 

   162.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XVII
CONVERSION 

   163.   Plaintiff hereby repeats and incorporates 1 through 162 as if fully set forth at length. 

   164.   Defendants, acting and continuing to act as aforesaid, and as described in 108 specifically, wantonly, willfully, recklessly, outrageously and intentionally exercised dominion and control over Plaintiff’s property in a manner inconsistent with Plaintiff’s rights as owner. 

   165.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XVIII
PRIVATE DEFAMATION 

   166.   Plaintiff hereby repeats and incorporates 1 through 165 as if fully set forth at length. 

   167 Defendants, acting and continuing to act as aforesaid, and as described in 69 through 70 and 84 through 97 specifically, wantonly, willfully, recklessly, outrageously and intentionally communicated defamatory statements of fact concerning Plaintiff that were false, with actual knowledge that the statements were false, or with reckless disregard as to the statements’ truth or falsity, or with negligence in failing to determine the statements’ falsity. 

   168.   Plaintiff suffered economic and physical damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants for all damages, pre-judgment and post-judgment interest, punitive damages, costs and expenses of this litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

COUNT XIX
INJUNCTIVE RELIEF 

   169.   Plaintiff hereby repeats and incorporates 1 through 168 as if fully set forth at length. 

   170.   Defendants, acting and continuing to act as aforesaid, have abused the colors of office and law so as to intentionally deprive Plaintiff of numerous constitutional, statutory, and common law rights, have retaliated against and attempted to coerce and intimidate Plaintiff when he sought to vindicate said rights, including interference with and obstruction of the very process of justice intended to prevent officials such as Defendants from engaging in the conduct complained of herein. Defendants will continue to so act and retaliate so as to intimidate and coerce Plaintiff into foregoing said rights – including the right to seek the instant redress before this Court. 

   WHEREFORE, Plaintiff seeks injunctive relief preventing the Defendants from interfering with this litigation except through counsel, or further interfering with or retaliating against Plaintiff for seeking to vindicate his rights in this litigation, and other relief as this Court deems just and proper.

COUNT XX
WRIT OF MANDAMUS 

   171.   Plaintiff hereby repeats and incorporates 1 through 170 as if fully set forth at length. 

   172.   Defendants, acting and continuing to act as aforesaid, and as described in 22 through 24, 51, and 99 through 100 specifically, wantonly, willfully, recklessly, outrageously and intentionally subjected and attempted to subject Plaintiff to intensive and long term behavioral modification, conditioning, and other unsafe and hazardous psychological processes without Plaintiff’s consent; without providing Plaintiff with information regarding the harmful side-effects arising from such processes; and without providing Plaintiff with information necessary to undo the harm inflicted upon Plaintiff by the Defendants. 

   173.   Plaintiff suffered and will continue to suffer physical and economic damages thereby. 

   WHEREFORE, Plaintiff demands judgment against the Defendants and the issuance of a writ of mandamus directing Defendants to disclose any and all documents and records relating to the psychological processes to which Plaintiff was subjected, and the disclosure of any and all documents and records relating to the testing, efficacy, and safety of such processes, costs and expenses of litigation, reasonable attorneys’ fees, and other relief as this Court deems just and proper.

PRAYER FOR RELIEF 

   Plaintiff prays as follows against the Defendants: 

a.    For statutory and common law damages; 
b.    For injunctive relief restraining the Defendants from further retaliation or interference with Plaintiff’s life or livelihood; 
c.    For lost economic advantage in the amount of $133,615.50; 
d.    For consequential and expectancy damages according to proof; 
e.    For pain and suffering damages in the amount of $5,000,000; 
f.    For exemplary and punitive damages in the amount of $5,000,000; 
g.    For the restitution of all monies paid by Plaintiff to the Defendants; 
h.    For costs; i. For reasonable attorney’s fees and litigation expenses; 
j.    For the setoff of all debts owed the United States government against judgment; and 
k.    For such other and further relief as this Court deems just and proper.

JURY DEMAND

Plaintiff demands trial of all issues by jury.