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. http://www.freedomwatchusa.org/pdf/130607-Klayman%20Verizon%20Complaint.pdf"
"Aristotle the Hun" was the name given to me more than 30 years ago when a friend noticed that in spite of my intellect I was still an Iowa farm boy.
Rev. Sam Sewell, is Director of Best Self USA, a Pastoral Psychotherapist, serves on the faculty of Naples Community Hospital as an instructor for Clinical Pastoral Education, President of the Theological Centeer in Naples, a member of Mensa where he serves as Gifted Youth Coordinator, a U.S. Navy Veteran, and a Member of the Association For Intelligence Officers. He is a frequent commentator on mental health and religious issues.His award winning research on family issues is published in several languages. Member of Sigma Delta Chi Honor Society
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