Saturday, June 8, 2013

Klayman vs Obama, Holder etc

2020 Pennsylvania Ave. NW
Suite 800
Washington, DC 20006
1600 Pennsylvania Ave. NW
Washington, DC 20500
555 Fourth St. NW
Washington, DC 20530 
Director of the National Security Agency,
9800 Savage Rd. 
Fort Meade, MD 20755
Chief Executive Officer of Verizon Communications
140 West Street
New York, NY 10007
Judge, U.S. Foreign Intelligence Surveillance Court 
950 Pennsylvania Ave. NW
Washington, DC 20530
Civil Action No. 
Case 1:13-cv-00851 Document 1 Filed 06/06/13 Page 1 of 13

.. 1. This is an action for violations of the First, Fourth, and Fifth Amendments to the U.S. Constitution. 2. This is also an action for violations of violations of privacy, including intrusion upon seclusion. ... 16. Plaintiff brings this action because he has been directly affected and victimized by the unlawful conduct complained herein. Their injuries are proximately related to the egregious, illegal and criminal acts of Defendants Obama, Holder, Alexander, McAdam, Vinson, Verizon, the U.S. Department of Justice, and the NSA, each and every one of them, jointly and severely. ... 19. Defendant Vinson, in an attempt to keep his illegal acts and those of other Defendants as secret, further ordered that no person shall disclose to any other person that the FBI or NSA has sought or obtained tangible things under his order. 20. Defendant Vinson's order shows for the first time that under Defendant Obama's administration, the communication records of millions of U.S. citizens are being collected indiscriminately and in bulk - regardless of whether they are suspected of any wrongdoing. ... 28. Defendants Obama, Holder, and Alexander violated Plaintiffs' constitutional rights when they caused Defendant Vinson's order to be illegally granted, thereby giving the government unlimited authority to obtain telephone data for a specified amount of time. ... 30. These violations are compensable under Bivens v. VI Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). As a direct and proximate result of the intentional and willful actions of Defendants Obama, Holder, and Alexander, and Vinson, Plaintiff demands judgment be entered against Defendants... including an award of compensatory and actual damages, punitive damages, equitable relief, reasonable attorneys fees, pre-judgment interest, post-interest and costs, in an amount in excess of $8,000,000 and such other relief as the Court deems just and proper. ... 32. Defendants Obama, Holder, Alexander, and Vinson, acting in their official capacity, abridged and violated Plaintiff's First Amendment right of freedom of speech and association by significantly minimizing and chilling Plaintiff's freedom of expression and association. ... 39. Defendants Obama, Holder, Alexander, and Vinson, acting in their official capacities, violated the Fourth Amendment to the U.S. Constitution when they unreasonably searched and continue to search Plaintiff's phone records and millions of innocent U.S. citizens' phone records without probable cause. ... 42. The collection and production of the phone records allows the NSA to build easily and indiscriminately a comprehensive picture and profile of any individual contacted, how and when, and possibly from where, retrospectively. ... 46. Defendants'... willful acts constitute outrageous conduct insofar as they violated Plaintiffs basic democratic rights, constitutional rights, and exposed him to a beyond "Orwellian regime of totalitarianism." Plaintiff's rights are being surrendered in secret to the demands of unaccountable intelligence and other government agencies. 47... The only purpose of this outrageous and illegal procedure is to intimidate citizens and keep them from challenging a tyrannical administration and government, a government which seeks to control virtually every aspect of Plaintiff's and other American's lives, to further its own "agenda." ... 54. Defendants Obama, Holder, Alexander, McAdam, Vinson, Verizon, the DOJ, and the NSA intruded upon the seclusion of Plaintiff when they unreasonably and without probable cause obtained access to Plaintiff's phone records including but not limited to his location data, call duration, unique identifiers, and the time and duration of his calls. ... 59. Plaintiff demands equitable and injunctive relief for his injuries in the following ways: (1) a cease and desist order to prohibit this type of illegal and criminal activity against Plaintiff and other U.S. citizens from occurring now and in the future; (2) that all Plaintiff's phone records and information be returned to Verizon and expunged from federal government records; (3) a full disclosure and a complete accounting of what each Defendant and government agencies as a whole have done and allowed the DOJ and NSA to do; (4) that the egregious misconduct of Judge Roger Vinson be forwarded to judicial and other law enforcement authorities for appropriate disciplinary and other legal proceedings. ... Plaintiff reserves the right to move this Court to convert this Complaint into a class-action lawsuit. ... Plaintiff respectfully demands a jury trial on all issues so triable."
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