CLASS ACTION UPDATE
JANUARY 28, 2006
Can we wait to see if Dubya is a dictator? or a president?
MOTIONS
OF OCTOBER 11, 2005 MOTION 1, RI DISTRICT COURT CA-05-328-Torres
MOTION 2, RI DISTRICT COURT CA-05-328-Torres
MOTION
Oct 11, 2005, CT DISTRICT COURT 3:05 –CV-91 (CFD) ß Psychiatry: “Blame the victim.”
Yale Department of Psychiatry is fully aware of the valid
parameters of cognitive assessment, click this link. There are only 3 valid axes of brain
compromise: Genetic (Autism, cognitive
assessments, various learning disabilities, retardation, dyslexia), Traumatic
(all kinds of injury), and Organic
(Lyme brain, Alzheimers or HIV).
That means that that’s all that they can diagnose: Brain injury, abuse history, and medical
illness.
It
is MALPRACTICE to put to paper, any other kind of analysis.
From
the Connecticutisms:
2)
Psychiatrists call "projection" (an alleged symptom of one of their
victims), what they themselves have admitted they do, when they claim: "This involves a recognition that there is no
value-free or presuppositionless orientation in this field.
...Finally, as a practical discipline, directed toward the care of the
individual patient and allowing an inevitable plurality of perspectives in the
provision of that care, psychiatric knowledge is finite, limited, and subject
to ongoing revision." Which
means there is no such thing as an independent psychiatric evaluation or wholly
objective human perspective of any kind, completely canceling the validity of
psychiatry as anything.
In
particular, the opinion of, or a "diagnosis" by a religious scholar forensic psychiatrist is the highest
order expression of blasphemy; is a sign of delusions of
grandeur; is stating one has the ability to judge another's will- the one thing
psychiatry cannot capture but pretend they have the authority to capture
without consideration of correlates of brain function examined scientifically
(head injury, illness, genetically determined cognitive attributes, history of
abuse), in, of all things, a forensic setting- under oath.
===================================================================================
Kathleen M. Dickson
Lara E. Dickson
Diane M. Dickson
David D. Dickson, et al,
And on behalf of all Families and
Children of the State of Connecticut
In the cause of a class action:
v.
STATE OF CONNECTICUT US
DISTRICT COURT
1
Exchange Terrace
Providence,
Rhode Island 02903
27
JULY 2005
AFFIDAVIT
I,
Kathleen M. Dickson, representing residents of the State of Connecticut, claim
the following abuses and neglect of duty by employees of the State of
Connecticut:
Civil
and human rights abuses, color of law violations, deprivation of rights, and
conspiracy to deprive of rights, and regarding the well-known and numerous acts
and examples of incompetence, perjury, acts of defrauding the courts, state
employees defrauding the police, the police defrauding the courts, judicial
misconduct, the State of Connecticut’s defrauding The United States of America,
the criminal behavior of the Department of Children and Families (DCF) and
related staff, and DCF’s well-documented abuse and neglect of children and
families, and in default of the protections guaranteed by federal and state
laws,
DO
HEARBY SWEAR that the following statements are truthful, sworn testimony,
written as any reasonable person would understand, before God, as stated.
Statutes
and Rules Violated
18
U.S.C. Section 241 Conspiracy Against
Rights
18
U.S.C Section 242 Deprivation of Rights Under Color of Law
18
U.S.C. Section 245 Federally Protected
Activities
Americans
With Disabilities Act
Risk
of Injury to Minor Children
Racketeering
Influenced and Corrupt Organizatrions (RICO) violations
Plaintiff
KM Dickson requests of the District of Rhode Island federal court to be fully
respectful of the abundantly common public knowledge of the loss of the public
trust due to the indictments and criminal racketeering behavior of the former -
and now criminal- Governor John G. Rowland and his staff as regards the
Connecticut Department of Children and Families (DCF), and the fact that DCF in
January 2004 was criticized by the Hartford Courant as
”For a while, it seemed as if the Department of Children and Families belonged
to the scandal of the week club”.
Plaintiff
KM Dickson respectfully asks the court to consider and agree that the following
is true and documented, except where specified in the document to have not been
delivered previously to the State of CT in the specified datapackage (one known
case):
ROWLAND
RACKETEERING
1)
The families of the State of Connecticut were victimized by the corrupt and
abusive practices of the CONNECTICUT DEPARTMENT OF CHILDREN AND FAMILIES and
their former Commissioner KRISTINE RAGAGLIA, the former Governor JOHN G.
ROWLAND, his chief of staff PETER ELLEF, his co-chief of staff LAWRENCE
ALIBOZEK. These individuals were
criminally charged and/or prosecuted and/or sued, with WILLIAM TOMASSO in the
past year. The charges and civil
allegations were theft of honest services of the government and
racketeering. This was described as
depriving the public of the honest services of the government, and Governor
…“Rell said, ‘Anyone who violated the public trust must be prosecuted to the
fullest extent of the law.’” [Exhibits
A, B, C, D]
CT
OFFICE OF POLICY AND MANAGEMENT’S INVOLVEMENT IN THE ROWLANDGATE SCANDAL:
2)
The former Manager of the Office of Policy and Management, MARC S. RYAN
apparently left the state unscathed in the criminal and civil actions of the
above named individuals. The
CONNECTICUT JUVENILE TRAINING SCHOOL (CJTS) built by the TOMASSO Brothers is a
CT State disgrace, as was the abuse of the pediatric prisoners by the
guards. Governor Rell ordered DCF’s
current commissioner to come up with a plan for what to do with CJTS by July 1,
2005, to include closing it.
RYAN
having been complicit in the misapplication of his duties to soundly provide
for the residents from the federal funding, under the demands of his duties as
specified above, was not punished.
ABUSE
OF CHILDREN PRISONERS:
3)
The children were abused in this prison.
Attorney General RICHARD BLUMENTHAL’s and the CHILD ADVOCATE’S (Jeane
Milstein) Press Release states: “The
manhandling and mistreatment of children shown in these videos demands swift,
strong steps to reform and revamp this facility.” [Exhibit D]. One may
conclude that children are abused in DCF’s “care.”
THE
DCF – ROWLANDGATE BILLS:
4)
JOHN G. ROWLAND sponsored the bills HB- 5021 (1998) and HB-6999 which stated
“The proposed increases in spending are attributed to higher than expected
spending requirements in federal entitlement programs (Medicaid and Temporary
Family Assistance), lower than budgeted savings from the Early Retirement
Incentive Plan, the carryover effect of current years deficiencies and the
Governor’s new initiatives….”
And
“An
additional growth factor is the increase of termination of parental rights
petition approved by the courts, which leads to a child being defined as
“no-nexus.” [Exhibit E]
One
might conclude that since the Rowland is in jail for his facilitating this
abuse of funding and did not provide adequately for the children of the State
of Connecticut.
CT
DCF DEFRAUDING THE UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES’
AGENCY FOR CHILDREN AND FAMILIES:
5)
In “CAREENING TOWARDS CRISIS,” The
Connecticut Voices for Children have determined that the State DCF
“misallocated” the UNITED STATES’ Department of Health and Human Services Agency
for Children and Families’ Temporary Aid to Needy Families (TANF funds), which
were intended to go to needy families, but were instead delivered to the
salaries of State DCF employees.
[EXHIBIT F]
Among
their findings:
“Connecticut’s
budget now invests far too little in the home and community-based services that
can prevent child abuse and neglect in the first place…
… an
increasing share of funds being spent on more costly and restrictive
institutional and restrictive institutional out of home care.
DIVERSION OF TANF BLOCK GRANT funds to fund DCF staff…
DIVERSION of Title IV-B funds to fund DCF staff…”
This report reads like an indictment of DCF in defrauding the
federal government and the residents of CT of the DHHS’ Agency for Children and
Families’ Temporary Aid to Needy Families it received. From page 2 of this indictment:
“KEY FINDINGS
1. Growth in DCF’s Budget
Has Far Exceeded Growth in DCF’s caseload
In the last decade, the number of children served by DCF increased
from 7,500 children at the end of FY 94 10 12,247 children at the end of FY 04
(a 63% increase). DCF’s General Fund
budget grew faster- from $227.6 million in FY 94 to 606.1 million in FY 04 (a
165% increase), With DCF’s revised SFY
05 General Fund budget at $642.6 million, there has been a 182% nominal
increase since FY 94. While some of
this growth is attributed to the more complex clinical needs of children now in
care and to long overdue investments to improve the quality of care of these
children, much growth is also due to skewed spending policies that skimp
funding for services that could reduce child welfare involvement while, at the
same time, increasing spending for “back end” placements and services.”
“ROWLAND’s
NUMBERS”
6)
The former Governor JOHN G. ROWLAND made this claim on his website: “To help protect children, Governor Rowland
has hired more social workers, moved more staff into the field to work directly
with at-risk children, and made it easier to remove at-risk children from
abusive homes. The number of children in new permanent homes has jumped 445 %
since 1996, while the number of children found to have been abused or neglected
has fallen 45 % since 1997."
Plaintiff(s)
personally find this to appear to show that 10 times as many children were taken
from their parents as needed to be. If
1000% of children were taken, then there would be zero children found to be
abused or neglected.
Additionally,
in the January 5, 2004, Hartford Courant, in
“COMPLICATED MAN AT THE CENTER OF THE CORRUPTION PROBE—Peter Ellef was a
big dreamer.”
“As
Gov. John G. Rowland’s co-chief of staff, Ellef spoke of levitating trains,
hydroponics gardening, building prisons in old stone quarries and opening trade
relations with China. His plans after
state service included developing a string of juvenile detention facilities
across the country, a chain of home improvement stores and a high-end garden
center.
To
the casual observer, the alleged racket run out of Rowland’s office involved
increasing the termination of parental rights because that made the “racket”
eligible for more federal funding, proportionate to the increase in “no-nexus”
children needing to be housed in some facility (like a prison) or another. [EXHIBIT E- the bills ]
DETENTION
VS PREVENTION, the VIOLENCE IN HARTFORD:
7)
“VIOLENCE HIGHLIGHTS DCF’s ROLE.” The
Child Advocate Jeane Milstein said in an article dated the 20th of
June 05 in The Hartford Courant,
“The
state DCF anticipates spending $762,00 on prevention programs targeting teens in
the coming year. The amount is
one-tenth of 1 percent of he agency’s $762 million budget, even though
prevention is one of the agency’s four principal missions; the others being
child protection, juvenile justice and meeting children’s behavioral health
needs.
“It’s amazing that DCF has no problem
spending taxpayer money to the tune of $514,000 per child, per year at the
Connecticut Juvenile Training School, but it can’t find the funds in its $700
million budget on prevention programs targeting teens in the to help mentor
troubled youth in our communities.”
[EXHIBIT G]
Plaintiff
KM Dickson had made the claim that JOHN G. ROWLAND was using the DCF as a
“federal money farm for the Tomassos.”
It is now unclear who, if “TREA” was a real entity, and if TREA is an
acronym for the names of the federally indicted, and that one cannot conclude
the “R” stands for ROWLAND, but may stand for RAGAGLIA, since this was a
limited liability corporation, and to my knowledge, MS RAGAGLIA is a lawyer. A lawyer might be necessary to set up a
limited liability corporation.
AN APPALLING
COMBINATION OF ARROGANCE AND INEPTITUDE:
8)
The CT DCF was resoundingly criticized in August 2004, by JUDGE CARMEN LOPEZ
for “an appalling combination of arrogance and ineptitude, ” in cases
where DCF workers defraud the courts, in an effort to gain custody. PAUL CHILL of UCONN Law school was quoted in
the Connecticut Law Review as
saying, “ was appropriately intolerant of official malfeasance and
abuses of power in the child protection system.” Chill, who has run advocacy clinics on child protection issues
for 16 years, said Lopez was the first judge to hold DCF accountable.” [EXHIBIT H]
THE SETTLING
OF THE 1989, 15 YEAR OLD CIVIL RIGHTS CLASS ACTION AGAINST DCF:
9)
ChildrensRights.org - Juan F. case lawsuit.
(2003). “In October, the state
and the lawyers for thousands of Connecticut abused and neglected children
reached an unprecedented landmark agreement after the state and its Department
of Children and Families (DCF) were charged with contempt of court for failing
to comply with the court orders and improve services for children. [EXHIBIT I]
Subsequently, “CASH INFUSION IS TO PROVIDE ALTERNATIVES
TO STATE’S DETENTION CELLS,” (news article)
June 27, 2005, The Hartford Courant. [EXHIBIT J]
“The 8.5 million dollar settlement “between attorneys representing
hundreds of children in juvenile detention in a federal class action lawsuit
and the state agencies that manage the detention centers and children’s mental
health programs.”
“The settlement also calls for increased training and cooperation
on the part of state social workers, juvenile probation and juvenile parole
officers to make sure children with serious emotional needs have detailed
treatment plans so that they can get the proper services that they
deserve”.
DCF
was sued for civil rights violations, which took nearly 15 years to resolve,
and which concluded with increased training and cooperation. Plaintiff KMDickson had made the claim
directly to Assistant Attorney General James Kelly that DCF staff were
“cognitively and morally challenged” on January 27, 2003, and “cognitively and
morally impaired,” January 28, 2003.
Reading DCF’s “records” give once the sense that the DCF staff and
reality are two entirely different universes.
Plaintiff KMDickson was an analytical chemist for Pfizer, Inc, and thus
record keeping, being absolutely accurate is imperative.
Conservatively
speaking, the DCF’s record-keeping indicates that mild mental retardation may
be a DCF employee job requirement, as is demonstrated by Plaintiff KM Dickson
in her replies to complaints made to the Statewide Bar Counsel and CT
Commission on Human Rights, with the evidence. For examples, science does not equal insanity, although DCF’s
former New Haven principal attorney, Sarah Gibson, believes it does. A DCF “worker” Lisa McArthur informed
Plaintiff Dickson that her dog and grandfather died of Lyme disease. Plaintiff
KM Dickson gave this “worker” a great deal of scientific information about how
damaging Lyme disease is to the nervous system. Later, DCF’s McArthur and her co workers wanted to know how
serious was Lyme disease. Plaintiff KM
Dickson suggested that if McArthur and her coworkers can’t read, perhaps they
could visit the cemetery to see if McArthur’s grandfather had improved.
APPLAUSE FOR
THE PROPOSED END TO DCF’S INCOMPETENCE AND ABUSES:
10)
“FORUM ADDRESSES CHILDREN, FAMILIES,” (news article) Hartford Courant June 28, 2005
“The forum focused on ways current state and federal funding needs
to be changed to better protect children and promote healthy families.”
“We need a major overhaul,” Sirry (the federal court monitor of
the DCF) said to applause from the crowd of about 100 child welfare
professionals.” [EXHIBIT K]
There
appears to be a broad consensus that DCF is hardly successful.
THE FAILURE OF
THE MENTAL HEALTH SYSTEM:
11)
The current LT. GOVERNOR KEVIN B. SULLIVAN was commissioned to uncover the
source of “the failure of the mental health system” and the June 9, 2005
statement on Mr. Sullivan’s website says the following:
“But
make no mistake,“ Sullivan added, “this is just the beginning of what we need
to do in order to build a more effective and more efficient system of
community-based mental health care that works and is less expensive that what
we are doing now. Over the next three years, we need to keep the momentum
for reform that has been lost too many times in the past. I also remain deeply
troubled that the Governor, who had no hesitation taxing nursing home patients
in part to help maximize federal Medicaid funding for longterm care, still
refuses to end Connecticut’s sad distinction as the only state in the nation
not to take get back more of our federal tax dollars by taking full financial
advantage of major Medicaid funding. This would go a long way in helping
reinvest in mental health care for children and adults.”
Recent
examples of the CT “mental health system’s” alleged criminal behavior:
HOSPITAL
PSYCHOLOGIST FIRED (Hartford Courant) published on June 23, 2005,
”A veteran psychologist at a state-run psychiatric hospital for children has
been fired after investigators found he downloaded pornography on his work
computer.
Kenneth C. Thunberg, 54, of Deep River, was on paid administrative leave from
the Riverview Hospital for Children and Youth while officials from the state
Department of Children and Families, which runs the Middletown facility,
investigated.
Thunberg counseled children at Riverview for 12 years. Notified of his
dismissal last.......” [EXHIBIT L]
Prominent Psychologist Faces Charges Eating Disorder Expert Inhaled Gas, Police Say
July 12,
2005, By TOM PULEO, Courant Staff Writer
WEST HARTFORD -- A prominent psychologist who specializes in
eating disorders faces criminal charges after she inhaled propellant from
whipped cream cans and collapsed on a supermarket floor in May, police say.
Lisa G. Berzins, 49, of 9 Talcott Glen Road in Farmington, was charged in a
warrant Friday with possession of a restricted substance, third-degree criminal
mischief and creating a public disturbance. She was released on $500 bail for a
July 21 appearance in Superior Court in Hartford.
"These are only allegations," said Berzins' attorney, Bob Ludgin of
Hartford. "My client is innocent unless convicted. I have confidence that
there will be no convictions."
Berzins, who has a practice listed at 91 S. Main St. in West Hartford, has
lectured and written widely in the areas of eating disorders, female
development, sex roles and self-esteem, according to her speaker's biography
listed with the American Psychological Association.
Her resume includes listings as director of the eating disorders programs at
the Institute of Living in Hartford, and the former Elmcrest Psychiatric
Institute in Portland. It was unclear when she held those positions.” [EXHIBIT M]
----
Mumbo-Jumbo
Syndrome.
“Munchausen’s syndrome by proxy is a quintessential example of that
most suspect of scientific theories — one that brooks no rational argument, a
closed circle we all must accept at face value.
For example, the only cure must begin by the sufferer accepting
that he or she is afflicted with the condition — which, of course, the alleged
sufferer is loath to do. But if someone who is diagnosed as a sufferer
vociferously denies it, this serves to reinforce the diagnosis. A denial of the
condition is, perforce, a symptom of the condition. And then there’s this:
there is no cure but it is accepted that sufferers can sometimes continue to
live among other people without exhibiting the symptoms — murdering people or
making them ill. Furthermore, there is no agreed biological or psychological
cause.
So there we have it: an illness that has no cause or cure and that
is diagnosed at least partly by the alleged victim’s denial that he or she is
so afflicted. The more the victim denies it, the more obviously the victim is
afflicted. And it is an illness that may somehow exist within a person without
cause or cure or indeed any manifestation of its symptoms.
In the medical establishment, in the law courts and in the press,
why were we prepared to believe this guff for more than a quarter of a century
and send people to prison as a result?”
-- TIMES ONLINE, UK
Parents
who say their children have Lyme disease, are often accused of Munchausen’s by
proxy. It is not unusual for a
psychiatrist to say that the denial of the illness, is a sign of the illness. Here, the writer questions why we accept
this medical mumbo-jumbo and circular reasoning on the basis of zero evidence,
in the courts, and in the press, and in the medical establishment. [EXHIBIT N]
FALSE
ACCUSATIONS OF TERRORISM
12) Plaintiff KM Dickson complained to the USDOJ
and National Institute of Mental Health on November 11, 2003, that the DCF
apparently falsely informed the Stonington, CT Schools and the Stonington, CT
Police that Plaintiff KM Dickson was a terrorist, or intent on murder, and the
schools then had a special terrorist drill, and ordered Plaintiff Dickson off
the schools’ grounds. This is a
National Security risk, because this distracts police from real terrorisms
targets surveillance. AAG JESSICA
GAUVIN listed this communication in her second petition as evidence that
Plaintiff KM Dickson was insane (Nov
11, 2003 Vigilante Justice complaint).
Plaintiff KM Dickson was complaining to the USDOJ and NIMH that DCF was
insane, which is more obviously the truth.
Plaintiff Dickson testified at the FDA about how Yale’s dangerous
LymeRIX vaccine was not a vaccine. The
vaccine came off the market a year later.
DCF did not help children in this way as regards Lyme disease or as
regards the dangerous LymeRIX vaccine.
Instead DCF accused Plaintiff Dickson of being a terrorist. The United States Department of Justice may
find this to be criminal behavior on the part of the DCF. It appears that this all started with Donald
G. Dickson’s false accusations that Plaintiff KM Dickson intended to drive her
children into a lake. [EXHIBIT O NIMH
and “Vigilante Justice?”]
Plaintiff
KM Dickson found outer, after Nov 21,
2003, that Donald G. Dickson was the one who
filed the false DCF accusation that Plaintiff KM Dickson of intending to
kill Plaintiff’s children from reading the Lyme disease newsgroup. [EXHIBIT P
Chuck P Adams’ post]
DCF’s
INCOMPETENCE AND THE RHODE ISLAND TICK BORNE DISEASES MANAGEMENT PLAN
13) Plaintiff KM Dickson submitted testimony to
the April 2002 Rhode Island Tick Borne Diseases Commission regarding the fraud
of Lyme disease, with substantiating documentation, entitled ” The Rhode Island
Tick Borne Diseases Management Plan.”
Rhode Island passed legislation protecting physicians from the Organized
Crime and Racketeering-Influenced Corruption as regards Lyme Disease, CT DCF staff Maureen Auger asserted that
since Plaintiff KM Dickson was the author of this document [EXHIBIT Q], it was
meaningless. These are largely summaries
of abstracts published in the scientific literature. If these scientific articles are meaningless, DCF’s Maureen Auger
should take up her claim that this science is meaningless with the National
Library of Medicine, the publishers of these journals and the scientists who
produced these reports.
Instead
of the Plaintiff KM Dickson’s Tick Borne Diseases Management Plan being adopted
by the State of Rhode Island, it was adopted by commercial interests in Rhode
Island. This is evidence of DCF’s
incompetence.
FALSE
DCF ACCUSATIONS MISHANDLED
14) The psychiatrist-diagnosed (diagnosed by J.
David Ruffner, MD, Psychiatrist) “sociopath,” Donald G. Dickson, falsely
claimed to the DCF that Plaintiff KM Dickson was going to drive her children
into a lake. Nancy E. Martin, 21
Redstone Way, Farmington, CT made numerous false allegations to DCF, and was
not arrested at the depositions, where these allegations were discovered to be
false. Nancy Martin proceeded to lie
under oath, however, and give a vague explanation of Plaintiff KM Dickson’s having been talking about her grandparents,
as if they were alive during Plaintiff Dickson’s brother’s funeral in
1977. In fact, they all were dead for
12 years by 1977, and no such bizarre conversation happened. Nancy E. Martin, and Donald G. Dickson
further perjured themselves at Plaintiff KM Dickson’s DCF “trial.” Every single statement made by the DCF’s
witness at Plaintiff Dickson’s “trial”
was perjury, with the exception of James Phillips saying Plaintiff Dickson was
a victim of child abuse. That abuser
was Carolyn Martin, who, we found out at the depositions, invented herself,
that Plaintiff KM Dickson said she would “slit her own throat,” an accusation
which made its way into the DCF’s first petition, which was thrown out, and but
was retained as part of a final statement DCF made for the court, December 23,
2004. Carolyn Martin was also not
arrested by DCF for making false allegations.
The
“sociopath” Donald G. Dickson made other false allegations to the DCF at least
twice, and once told the DCF falsely that Plaintiff KM Dickson “beats the
children’s butts until they are red,” “pokes them in the face with sticks,” and
“screams at them non-stop for two hours.”
Plaintiff KM Dickson is sick with the Multiple Sclerosis presentation of
Lyme Disease. If Plaintiff KM Dickson
could scream for 2 hours, she would not be disabled from Lyme Disease.
DCF’s
DELIBRATE RISK OF INJURY TO MINORS
15) Plaintiff Dickson faxed DCF’s Lisa McArthur
on January 6, 2003, the extensive evidence of Donald G. Dickson’s abuse
history, including his arrest for domestic violence (1993), a restraining
granted order against Donald G. Dickson (1996), and a letter from the Battered
Women’s Shelter in New London, CT (1994), stating that Plaintiff KM Dickson and
her 2 older children had to stay there temporarily for safety from Donald G.
Dickson. [EXHIBIT EE The alleged “harassing communications and
threatening”] This should have been enough evidence that Donald G. Dickson was
not a reliable witness. Instead, DCF
gave the Plaintiff KM Dickson’s children to this well-known child abuser (taken
in testimony by DCF of the children themselves) and wife beater, Donald G.
Dickson, which is illegal. This is risk
of injury to a minor:
“Anyone
who exposes a child to harm or fails to protect a child from physical assault
may be prosecuted under the risk of injury statute.” Hartford Courant, July26, 2005
DCF
informed Plaintiff KM Dickson’s children that if they complained about being
placed with an abusive parent, they would be kidnapped again and placed in
separate foster homes, therefore this dangerous placement was deliberate.
The
CT statute regarding false allegations to DCF stipulates a $1500 fine and up to
a year in prison, yet when Plaintiff KM Dickson tried to discover how to prosecute
false allegations, the Middletown Superior Court, and the Milford State’s
Attorney’s office did not know whose job it was to prosecute false allegations,
because, as they told Plaintiff Dickson, no one had ever been prosecuted for
false allegations before. Thus, DCF are
incompetent to an apparently unlimited number of their own statutes.
“CONFIDENTIALITY”
AND “IMMUNITY”
16) “Judge” John C. Driscoll stated that the
“proceedings” of a DCF “trial” are confidential, however, DCF’s former New
Haven principal attorney, Sarah Gibson sent Plaintiff KM Dickson a copy of
Connecticut Statute 17a-28, which clearly states that the “person” who is a
defendant, and who is guilty regardless of being proven innocent, may give any
information about their DCF “case” to whoever they want. Plaintiff KM Dickson, as a long time human
rights activist, exposed the fraudulent and bizarre activities of CT DCF to the
entire world, so that other families may be warned and protected against their
abuse, by scanning in evidence into her website and posting to various
newsgroups, the truth about DCF’s behaviors and incompetence.
The
only reason these DCF proceedings are kept “confidential,” is to protect from
criminal liability, the perjury of the DCF, their deliberate defrauding of the
courts, and the perjury they orchestrate with their witnesses under their
“immunity.” That the average legislator
can’t see the reasoning behind these combined conditions, “confidentiality” and
“immunity,” especially in the face of the rising budget and 445% increase in
children taken from their parents in contrast to a 45% reduction in child
abuse, and especially when it is well known that the mental health system is a
failure, speaks to legislators’ either motives or incompetence. The statute clearly states that the
defendant/perp may release records to anyone they want, canceling out any
confidentiality rulings.
The CT DCF and their inane statutes are
clearly organized crime and racketeering influenced, due to the obvious
intimidation attempts to commit and attempts to falsely arrest people who
complain to the proper authorities about the criminal behavior of the CT DCF
staff.
RECENT NEWS
REGARDING CT DCF’s CARE OF PEDIATRIC PRISONERS:
17) CT DCF is in charge of the juvenile justice
system in CT. In today’s (July 27,
2005) Hartford Courant, it was claimed that:
“And
some say that when 16- and 17-year-olds are added in, Connecticut has the
nation's highest incarceration rate for youths.” This news article comes on the heals of yet another child who
killed himself in DCF’s “care,” this past Sunday, July 24, 2005. The child hung himself in one of the DCF’s
prisons for children. It never ends. DCF shows no signs of willingly ending their
practices of harming children, will not do so voluntarily, and retaliate
against people who claim abuse by DCF and ask for relief and fairness.
“ROWLANDGATE”
AND NATIONAL SECURITY:
18) This extraordinary number of children
removed from parents, jailed, and mistreated by DCF may have something to do
with John G. Rowland describing himself as “a National Security Advisor” to
President George W. Bush. The criminal
enterprise run out of Rowland’s office, TREA, was about a “national string of
prisons and juvenile detention centers.”
Some people have claimed that this Bush administration plans to
incarcerate people who protest against the NeoCon abuses masterminded by Paul
Wolfowitz:
“Project
for a New American Century
Wolfowitz
however could not remain completely out of politics for long and in 1997 he became one of the charter members,
alongside Donald
Rumsfield, Dick
Cheney, Jeb Bush,
Richard Perle and
others, of the Project for a New American Century (PNAC). William Kristol and
Robert Kagan
founded this neo-conservative
think-tank with the
stated aim of "American global leadership" through military strength.
In 1998 Wolfowitz was one of the signatories of the PNAC open letter to President Bill
Clinton that was highly critical of his continued policy of
containing Iraq. The PNAC
advocated preemptive U.S.
military intervention against Iraq and other "potential aggressor
states" to "protect our vital interests in the Gulf". In 2000
the PNAC produced its magnum opus the 90-page report on Rebuilding America's Defenses:
Strategies, Forces and Resources for a New Century that
advocated the redeployment of U.S. troops in permanent bases in strategic
locations throughout the world where they can be ready to act to protect U.S.
interests abroad. The Clinton administration however remained unmoved and
pressed on with containment.=== wikipedia
Pre-emptive
military aggression, when it is clearly about oil and not national security,
may result in a national security risk to Americans. Americans might not stand for the increased terrorism, in
retaliation for a fraudulent Iraq war, directed at Americans, and Americans
might also rebel against this “administration,” or the concept of the United
States becoming the self-designated World Police. Such a rebellion could be accommodated by a national string of
prisons and juvenile detention centers.
America has little GNP or natural energy supplies of our own, and in
such an economically disadvantaged state it appears that the US has little
choice but to become a world police force.
Perhaps the plan is to pay ourselves by taxing other countries for this
unwanted service. Paul Wolfowitz is now
the head of the World Bank. Bush’s 2005
Inaugural speech contained these passages:
“A
few Americans have accepted the hardest duties in this cause - in the quiet
work of intelligence and diplomacy ... the idealistic work of helping raise up
free governments ... the dangerous and necessary work of fighting our enemies.
Some have shown their devotion to our country in deaths that honored their
whole lives - and we will always honor their names and their sacrifice.
All
Americans have witnessed this idealism, and some for the first time. I ask our
youngest citizens to believe the evidence of your eyes. You have seen duty and
allegiance in the determined faces of our soldiers. You have seen that life is
fragile, and evil is real, and courage triumphs. Make the choice to serve in a
cause larger than your wants, larger than yourself - and in your days you will
add not just to the wealth of our country, but to its character.” [EXHIBIT R]
DANGEROUS
PERJURY- DMHAS
19) DEPARTMENT OF MENTAL HEALTH AND ADDICTION
SERVICES’ (DMHAS) “Medical Director,” Kenneth Marcus, [see EXHIBIT X for more
background info on “Dr.” Marcus] came to Plaintiff Dickson’s DCF “trial,”
perjuring himself in court and said you treat an organic delirium like any
other psychosis, when that is clearly against the American Psychiatric
Associations (APA) Guidelines, due to the increased brain damage caused by this
mistreatment [EXHIBIT T ].
The
APA guidelines clearly state, “When delirium is comorbid with other psychiatric
disorders, the delirium should be treated first. “ This is a guideline that should apply to all persons with
neurologic Lyme disease. Central
nervous system Lyme disease should be treated with ceftriaxone. The guideline continues:
“Medications
for psychiatric disorders can be both the cause of delirium and exacerbate or
contribute to delirium from other causes.”
Lyme
disease is an organic brain syndrome.
[EXHIBIT U] As published by
Allen Steere in 1989, “Lyme disease may affect the central nervous system
causing organic brain syndromes suggestive of demyelination.”
In
an world uncomplicated by the perversion of dogma regarding the source of
emotional trauma, wherein sexual repression is considered to be the cause of
child abuse emotional sequelae, instead of child abuse being the cause of child
abuse sequelae, as is the case of the perverted world of James Phillips, MD,
Clinical Professor or Psychiatry at Yale and Forensic Psychiatrist for the
State of Connecticut, a mere reading of the scientific documentation given to
James Phillips, MD, regarding the science of Lyme as a brain disease, by Plaintiff
KM Dickson, would have alleviated the steps where the Plaintiff KM Dickson’s
children were traumatically removed by DCF, and Plaintiff KM Dickson went to
jail, in the end, for Carolyn Martin’s child abuse. We could have moved on to guaranteeing proper medical treatment
for Plaintiff KM Dickson and her children, and a validation of this
neuropsychiatric disease, borreliosis.
Freud is out of style. Freud
invented, in fact, his psychotic assertions that the world’s woes are due to
inadequate sex instead of inadequate care or love, because the fathers of
Freud’s female “hysteria” patients, were in fact, the sexual perpetrators
against these female children, who later grew up to be Freud’s “hysterical”
patients. The fathers did not approve
of Freud’s discoveries. Modern
Psychiatry, thanks to the bad fathers of Freud’s day, was then founded upon the
concept that the victim is the guilty, or the victim is the “bad” one. Little has changed.
DMHAS’
Kenneth Marcus also said for the DCF “court,” something to the effect that
Plaintiff KM Dickson “is so psychotic,
she does not know how psychotic she is, which is a sure sign of her psychosis.” Plaintiff had left numerous scientific
journal articles in the office of Laura Lustig, PhD, of The New Learning
Center, Westport, CT, which demonstrated the cellular brain damage and other
damage caused by most psychotropics.
These were also on Plaintiff KM Dickson’s website, ActionLyme.com. This is not only perjury and promoting
malpractice, but more psychiatric Mumbo Jumbo.
With this reasoning, Plaintiff KM Dickson could make the claim that “DCF
and DMHAS staff are so stupid, they don’t know how stupid they are, which is a
sure sign of their stupidity.”
More
seriously, it calls into question the validity of any psychiatric expert
testimony in any legal case, since this was clearly an attempt by DCF to commit
Plaintiff KM Dickson, in an attempt to falsify more records, and preventing
Plaintiff from filing malpractice lawsuits and other complaints about the
criminal behavior of the DCF, as regards Yale’s dangerous Lyme vaccine, and as
regards the Yale/Allen Steere- orchestrated apparent conspiracy to create a
fraudulent testing schema for Lyme disease to pass off their bogus Lyme
vaccine, LymeRIX, and to also guarantee a monopoly on the post-FDA approval of
Yale’s LymeRIX vaccine.
This
perjury, on the part of DMHAS’ Medical
Director, is a severe and dangerous color of law abuse, and should result,
minimally, in Kenneth Marcus’ immediate resignation. [EXHIBIT V- 3:05-CV-91
(CFD)]
Yale
and DMHAS’s Vladimir Coric fraudulently reported to the criminal court numerous
aspects of Plaintiff Dickson’s mental health.
The Plaintiff’s children’s Ad Litem, Priscilla Hammond (Old Lyme CT),
walked up to Plaintiff Dickson November 21, 2003, after the DCF depositions, in
Milford, CT, and said, “The State is watching this case very closely.”
Therefore,
it is not paranoid of Plaintiff Dickson to be saying, “The State is watching this
case very closely.” Coric also perjured
himself and stated that Plaintiff Dickson was treated with antipsychotic
medication for 5 years when she was in her twenties. Plaintiff Dickson had stated to Coric, that she was given exactly
and only 3 bottles of tranquilizers to be used as needed, over a 5 year period,
and in truthfulness, and to indicate that there was little medication involved
in Plaintiff KM Dickson’s previous psychiatric history of depression due to the
child abuse by Carolyn Martin, Plaintiff’s “mother.”
Carolyn
Martin is now responsible for destroying the lives of exactly 9 children: five of her own, and four grandchildren, due
to her abundant and bizarre lying, hatefulness, and chronic- and lifelong-
extreme physical violence to children,
which included beatings with a cat of nine tails (whip), beatings with this
whip with and without clothing, and full force kicks upon children. That Carolyn Martin is free to harm more
children is a testament to the failure of the “mental health system,” the “child protection system,” and the
“criminal justice system” in Connecticut.
[EXHIBIT W, Carolyn Martin is known by all to be a crazy person.]
REGARDING THE
DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES AND THEIR RELATIONSHIP WITH
THE DEPARTMENT OF CHILDREN AND FAMILIES:
20) DMHAS is incompetent to brain matters as
described in a lawsuit against the State of CT and Yale University. The State of Connecticut cannot handle
important epidemics such as autism and Lyme borreliosis as disclosed in 3:05
–CV- 91 (CFD). [EXHIBIT V]
DCF
hired Laura Lustig of the New Learning Center, Westport, who declared for the
court, that Plaintiff KM Dickson has Borderline Personality Disorder and
Autism, when the two disorders are mutually exclusive. Autism is defined by a lack of a
personality. Plaintiff KM Dickson was
diagnosed with High Functioning Autism and has two blood relatives with the
same cognitive strengths and deficits.
This is medical and legal incompetence.
Yale University has a Center for the Study of Autism. Yale University
also rediscovered Lyme as a brain infection, yet no Yale or DMHAS physician is
competent to either disorder that Plaintiff KM Dickson has encountered.
The
CT 54-56D competency statute assumes that DMHAS is up to date on brain
matters. Clearly for the entire
combined National Institutes to declare Chronic Lyme to be a chronic infection
of the nervous system, and for Yale and DMHAS to declare otherwise, places
DMHAS and Yale staff in default of the competency required by the CT 54-56D
competency statute.
FALSE CRIMINAL
CHARGES, CONSPIRACY AGAINST RIGHTS, FEDERALLY PROTECTED ACTIVITIES
21) Plaintiff KM Dickson was falsely criminally
charged with the bizarre perjury invented by DCF prosecutor Assistant Attorney
General JESSICA GAUVIN. The Honorable
Kevin P. Murphy ordered Plaintiff Dickson to be treated for Lyme disease, as a
condition of her release. The
prosecution subsequently switched courts to New Britain, CT, where the State
proceeded to orchestrate more perjury, and state that Plaintiff Dickson does
not have Lyme disease and that Lyme is not a brain disease (DMHAS’s Elizabeth Byron) [EXHIBIT X Scott
Murphy datasets].
Plaintiff
KM Dickson does not have “command hallucinations to kill Jessica Gauvin,” and
Plaintiff KM Dickson is not a “dangerously intelligent” “chemist” “like Ted
Kaszinski,” the Unibomber. This is the nonsense GAUVIN invented for
Plaintiff KM Dickson at Plaintiff KM Dickson’s DCF “trial,” and with which
GAUVIN then later falsely criminally charged Plaintiff Dickson.
Plaintiff
KM Dickson is a human rights activist, Lyme support group leader, and testified
at the FDA about Yale’s dangerous LymeRIX vaccine as a pharmaceutical chemist,
demonstrating for the FDA (January 31, 2001)
that LymeRIX was not qualified with a proper standard and should not be
used for children until we know what is making adults so sick from this
vaccine. These are, to Plaintiff KM
Dickson’s knowledge, not the Unibomber’s methods of activism.
The
epidemic of Lyme disease, which is “Connecticut’s disease,” has made no
progress in treatment, detection, or prevention in the past 19 years. The CONNECTICUT STATE DEPARTMENT OF HEALTH,
the STATE DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES, the STATE
DEPARTMENT OF CHILDREN AND FAMILIES have all failed their commissions including
the CT state competency statute, 54-56D, for not addressing this epidemic and
not recognizing that borreliosis is a primarily a brain and nervous system
disease.
In
fact, despite being given the published scientific evidence which clearly
demonstrates that Lyme borreliosis is a brain disease, DMHAS staff, in court,
in deliberate perjury, and despite the entire combined National Institutes’
declaring that Lyme is a borreliosis- a permanent brain infection (The NIH’s
Integrative Neural Immune Program), and despite having full knowledge that Lyme
is a brain disease (since these rediscoveries were also made at Yale
University), stated for the court that Lyme is not a brain disease and that
DMHAS was not aware of Plaintiff Dickson’s diagnosis of Lyme disease.
DMHAS
staff further perjured themselves and stated that Plaintiff KM Dickson refused
to meet with a neurologist.
Plaintiff met with Christopher
Gottschalk, later discovered to be a Yale Neurologist, who told Plaintiff that Lyme is not a permanent brain
infection, which is false. Gottschalk
told Plaintiff KM Dickson he was from Cross County Neurology Group and gave
Plaintiff the document which is EXHIBIT Y.
FAILURE OF
COMMISSIONS:
22) The commissioner of the DEPARTMENT OF SOCIAL
SERVICES is obligated to: 16) conduct, encourage and maintain research and
studies relating to social services development; (17) prepare, review and
encourage model comprehensive social service programs; (18) maintain an
inventory of data and information and act as a clearing house and referral
agency for information on state and federal programs and services; and (19)
conduct, encourage and maintain research and studies and advise municipal
officials and officials of social service agencies about forms of
intergovernmental cooperation and coordination between public and private
agencies designed to advance social service programs. (see definitions and statutes at end of this document).
DCF
was given hundreds of pages of documents related to Lyme disease and Autism, by
Plaintiff KM Dickson, from December
2002, to March 2003. Plaintiff Dickson
received her DCF “records,” in March, 2003, more than three months after
requesting them, and only with the assistance of Congressman Rob Simmons. When Plaintiff KM Dickson read these
records, she was assured she was dealing with extremely mentally defective
individuals employed by the State of Connecticut, and began filing complaints
with various agencies of the State and Federal government about CT DCF. DCF later removed Plaintiff’s children, in
November 2003, defrauding the DCF “court” in their Temporary Order of
Custody. These are color of law,
deprivation of rights, and violations against federally protected activities. Residents may file complaints with the
proper authorities, under these Federal Civil Rights Statutes (USC Title 18,
Secs 241, 242, 245). DCF is clearly
funded by federal agencies (DHHS, Agency for Children and Families, etc.), and
the latter statute specifically protects individuals from color of abuses by
federally funded organizations.
DCF’s
former Commissioner Kristine Ragaglia resigned from DCF some time in Feb or
March, 2003, but was later re-employed
by the Department of Social Services some time after March 2003. Plaintiff KM Dickson gave (emailed and
hand-delivered) Ragaglia and others employed by DCF these scientific documents
which supported that Lyme is a borreliosis- a permanent infection of the
brain, that “Lyme disease” is not a controversy,
but scientific fraud, that autism is a pervasive development disorder, and the
scientific evidence of the brain damage caused by all psychotropics. This scientific evidence was also on
Plaintiff KM Dickson’s website, ActionLyme.com.
DCF,
DSS, DPH, and DMHAS are in default of their basic commissions, which are to
know facts, serve and provide, based on the facts, the science, and the state
of the art, in care. They are not
commissioned to become a participants in the scientific fraud of Lyme disease.
FAILURE
TO ACT IN THE INTERESTS OF THE STATE BY ATTORNEY GENERAL RICHARD BLUMENTHAL:
23) AG RICHARD
BLUMENTHAL was mailed an enormous amount of information regarding the
fraud of Lyme disease by Plaintiff KM Dickson. R. Blumenthal held two public hearings on the mistreatment of
persons who have Lyme disease by insurance companies and Yale University (1999
and 2004). Richard Blumenthal did not
act to protect the residents of the State of CT even when given evidence of the
perjury which occurred at one of his hearings, and as regards the NIH Edward
McSweegan and Yale’s Durland Fish’s conspiracy to send Karen Forschner of the
Lyme Disease Foundation in Hartford, CT, “a bogus article” to publish in their
journal, The Journal of Spirochetal and Tick Borne Diseases (JSTD). Yale University is involved in the
scientific fraud of Lyme Disease.
Richard
Blumenthal’s staff lawyers referred Plaintiff KM Dickson to the US Attorney
Kevin O’Connor as the person with whom to file the complaint of scientific
fraud as regards Lyme disease (RICO) in July 2003. Kevin O’Connor’s wife worked in Rowland’s legal office and Mr.
O’Connor had to recuse himself from the investigation of the criminal former
Governor Rowland and the activities which were conducted from Rowland’s office
which involved the DCF’s Kristine Ragaglia and others defrauding the federal
government.
These
communications to Richard Blumenthal regarding the Lyme racketeering enterprise
were instead used by AAG JESSICA GAUVIN to be evidence of Plaintiff KM
Dickson’s insanity. DMHAS’s Kenneth
Marcus testified at Plaintiff KM Dickson’s DCF “trial,” “Don’t look at the content…,” of these
communications.
Plaintiff
KM Dickson is a scientist. Content is
of primary importance in any scientific report. The content specified in these reports regarding the scientific
fraud in “Lyme Disease” are why Plaintiff KM Dickson cannot get medical and
special education care for herself and her 3 children, who have Lyme disease. The “content” demonstrated the scientific
fraud in Lyme disease, and how that involved Yale’s dangerous Lyme vaccine.
Plaintiff
KM Dickson asserts that it might be either perjury or psychiatric mumbo jumbo
to be saying that because the State of CT failed to protect its citizens from
the deliberate in the denial of care for Lyme disease, and for Yale’s
attempting to pass off a bogus Lyme vaccine (for which adverse events were not
reported to the FDA), that the Plaintiff KM Dickson is insane to be reaching to
the federal level for protection.
SUMMARY
OF THE STATE OF CONNECTICUTS FAILURES TO PROMOTE AND PROTECT THE GENERAL
WELFARE:
Lyme
disease is an epidemic of a brain infection, and there is a rising epidemic of
autism, yet neither of these two illnesses are addressed even lightly by any of
the Departments of the State of Connecticut, with the possible exception of the
DEPARTMENT OF MENTAL RETARDATION (DMR) as regards autism. The State hires experts who are completely
unfamiliar with autism as a “pervasive development disorder” or Lyme as a brain
disease, despite these experts being associated with the Yale Department of
Psychiatry (VLADIMIR CORIC), which has an autism clinic, and despite a report
by the Yale Department of Pathology in which the congenital brain damage from
Lyme infection was listed as the probable cause of death in one newborn and one
stillborn infant. [EXHIBIT X - Scott Murphy dataset, June 11, 2005]
Clearly
the DMR needs to be explaining what a pervasive development disorder is to the
DCF, Yale Department of Psychiatry, and DMHAS.
It
is inherently within the commissions of the DCF, DPH, and DMHAS to have an
understanding of, and address the needs of the disabled with Lyme and/or
Autism. Thus, they have failed their
basic commissions.
The
OPM is authorized to discover federal aid sources, however, MARC S. RYAN
appears to have dominantly sought increased the spending for the DCF in House
Bills 1999 5021 and HB 2001, 6999 and as is written into the text, this
increase in state spending was required to meet increased federal spending
requirements, and RAGAGLIA appears to have added, “due to the increase in
termination of parental rights being approved by the courts…” This is inconsistent with providing aid to
needy families, and which may be another deliberate fraud against the United
States of America, the Connecticut public, and the federal government, and
which resulted in a 445% increase in children taken from their parents and the
disgrace of the pediatric jail.
[EXHIBIT Z Letter to Rell,
DMHAS’s perjury dataset, July 1, 2005]
DCF
prosecutors willfully and knowingly falsely criminally charge parents with the
false allegations, hearsay, and the perjurous testimony elicited and invented
by the DCF prosecutors themselves and their “witnesses,” and then deny the
parents access to the courts by declaring the parent insane to say they are
innocent and threaten their victims with being involuntarily committed if they
maintain their innocence. [EXHIBIT X
(eg., Scott Murphy dataset re: Christopher Gottschalk, Joseph More, Sam Donta,
Lara, Diane and David D.)]
There
is clearly a consistent pattern of criminally charging parents with whatever is
today’s flavor of inane crime if the parent/alleged “perpetrator” retaliates against
the criminal behavior of the State of CT employees by filing the proper
documents for relief from abuse and neglect with the proper agencies.
DCF
willingly and knowingly places children in dangerous homes, and informs the
children that if they complain of this abuse, they will be placed in separate
foster homes. DCF willingly and
knowingly fraudulently declares parents to be mentally ill to be filing
legitimate complaints about judges, DCF attorneys, and DCF staff to the
Commission on Human Rights and Statewide Bar Counsel, and Judicial Review
Boards, in order for the claim to be considered invalid. These are Color of Law abuses, Conspiracy Against Rights, and violations of
the rights to Federally Protected Activities.
DCF
threatens the liberties of parents, and makes it a condition of release that
the innocent parent admit guilt for the crimes they did not commit, and that
the parent may not “criticize the government,” nor “fax any state, federal, or
local agencies,” which are clearly and abundantly civil and human rights
abuses, illegal, a violation of the First Amendment, a violation of the
Americans With Disabilities Act, violations of Federally Protected Activities,
Conspiracy to Deprive of Rights, and Color of Law abuses, when the parent has
Lyme disease, and especially when the children also have Lyme disease and can
get no access to care. [EXHIBIT Z]
It
is criminal child abuse to willfully deny children access to medical care, when
the denial of medical care results in a regression of health, yet the State of
Connecticut does this consistently as regards all Lyme disease victims,
including children.
These
behaviors and actions of CT DCF staff are Title 18 Secs 241, 242, and 245
criminal civil rights violations (Title 42, Sec 1983, redundant).
------
THE
CHIEF STATE”S ATTORNEY CHRISTOPHER MORANO AND THE PUBLIC DEFENDER’S OFFICE ON
COMPENSATING COURT APPOINTED LAWYERS FOR CHILDREN AND FAMILIES HARASSED BY DCF:
24) In default of proper protections provided by
the State to families involved with DCF in comparison to criminal cases, as
stated publicly by Chief State’s Attorney, Christopher Morano, and the Public
Defender’s office regarding court appointed attorneys, parents who are victims
of DCF’s abuses, in the interest of the welfare of children and families,
should expected to take humane and compassionate action on behalf of other
families who will be destroyed by the Connecticut Department of Children and
Families, without such public exposure and restraint as otherwise afforded
under the US Constitution, but denied all Connecticut residents. These incidents reveal gross incompetence,
and criminal civil rights violations, not only on the part of DCF staff, but
also the police. Lawyers assigned to
children victimized DCF attack are paid a fraction of fees for court appointed
representation of criminal charges.
These lawyers for children have since passed legislation protecting
themselves from malpractice lawsuits by families who they inadequately
represented. [EXHIBIT AA]
There
is no legislative protection for the families against this inherent, built-in,
legal incompetence.
25) OTHER CASES OF THE STATE’S INCOMPETENCE,
RETALIATION, ABUSE, QUESTIONS OF INTEGRITY
25-
A) Daniel Scruggs: In the case of the suicide of Daniel Scruggs, the entire family
was in need of services, and had been visited by DCF. A simple $40 weekly contract with a cleaning service, in light of
the cognitive disabilities of Mrs. Scruggs and her son Daniel, provided under the
Temporary Aid for Needy Families, would have been a logical remedy. Daniel Scruggs was depressed and was said to
be mildly autistic (newspaper article), yet no one, and in particular, no one
at DMHAS or Yale is competent to Autism/Asperger’s in adults. One can assume Daniel Scruggs inherited his
cognitive disabilities from either his mother or his father (who was notably
absent), yet the father shared no liability for this tragedy. [EXHIBIT BB]
It
appears that “Scruggs' arrest by Meriden police came six weeks after Norris
filed the notice of intent to sue the city of Meriden for failing to protect
Daniel from daily bullying.”—not included but taken from Hartford Advocate,
November 2003, “Everyone was at Fault” news article.
Charging
Mrs. Scruggs appears to be retaliation by the State, and an effort to prevent
legal discovery of DCF’s incompetence and liability in the death of this
child. This appears to be another case
of a conspiracy to deprive of rights.
25-
B) Baby Emily: In the case of Baby Emily,
recently resolved by the State of CT,
“A state investigation after Emily’s death found that state child
welfare workers knew of abuse within the infant’s family and failed to protect
children in the household.”
[EXHIBIT CC]
This
is a simple evidence point of DCF’s abundant incompetence.
25-
C) Jennifer O’Connor: Mrs. O’Connor informed Plaintiff KM Dickson that she had asked
the DCF to come and give her parenting skills in regards to herself and her
daughter Sara. Approximately April
2003. DCF came to visit Mrs. O’Connor, found
“no abuse or neglect,” and declined the request for assistance. A few weeks later, Mrs. O’Connor shot and
killed her daughter, presumably as a result of her deficit in parenting skills,
which was not addressed by DCF despite the specific request. Plaintiff KM Dickson feel this behavior on
the part of the DCF is consistent with the DCF staff not understanding big
words like “Neuroborreliosis,” which the DCF staff calls “bizarre talking,” and
is consistent with the acknowledgement that DCF staff needs “increased
training,” in the conclusion of the Juan F. case.
Mrs.
O’Connor was diagnosed with a learning disability, as was her daughter, and had
had genetic screening prior to becoming pregnant, Plaintiff KM Dickson was told by a friend of the family. Plaintiff KM Dickson’s experience and knowledge of Autism and
Asperger’s disorder, leaves Plaintiff KM Dickson strongly aware that Mrs.
O’Connor was misdiagnosed as “mentally ill,” when she had Asperger’s disorder,
and may have been subject to malpractice, in addition to the incompetence of
the DCF staff. This conversation took
place in the jail; Plaintiff Dickson does not have access to Mrs. O’Connor’s
DCF records. Plaintiff Dickson’s
understanding from reading the news reports online, is that Mrs. O’Connor
called the DCF herself for assistance.
This assistance was denied. The
child is dead, and Mrs. O’Connor is in jail instead of in an assisted living
arrangement or with assistance for herself and her daughter’s learning
disabilities [EXHIBIT DD]
The
primary problem with DCF’s incompetence is never addressed: The fact
is, they don’t appear to understand common English. If someone says, “Help Me,” it doesn’t
mean, “Blow me off,” and it doesn’t
mean, “Subject my children to a traumatizing kidnapping, and give them to a
known –to-DCF, chronic genitals-exposing, physically violent to others, maniac
(Donald G. Dickson),” and it doesn’t mean, “”If I am sick, and sometimes need
DCF’s babysitting Respite Care, tell
the courts I am insane, kidnap my kids and give them to someone known to be a
violent person, invent my crimes and throw me in jail.” If DCF is not a child welfare agency, they
should not advertise as such, and mislead the public. This is a waste of tax dollars, not to mention children’s lives.
25-
D) The “harassing communications and threatening,” with which Plaintiff KM Dickson was falsely criminally charged
are dated 14 April 2004, and are in correspondence with the US Attorney’s
office (Kevin O’Connor), and CIGNA, Plaintiff KM Dickson’s Pfizer disability
insurance carrier, and which contain more newspaper articles of DCF’s
incompetence. [EXHIBIT EE]
-March
8, 2004 (Courant) “DCF never asked, DPH never told of hospital problems” Quote
from Jeane Milstein (as regards DCF):
“Common
sense would tell you to pick up the phone and do your homework.”
-March
7, 2004 (Courant) “Hospital Troubles Elude DCF” Jeane Milstein:
“You
learn from your mistakes. You learn
from what you do,’ Milstein said. ‘DCF needs to be a more responsible parent.’”
-December
18, 2003, Courant “MILSTEIN SUES DCF OVER AGENCY’S TREATMENT
OF ABUSED CHILD”- Associated Press.
“Milstein
accused DCF of ‘callous and reckless indifference in caring for the youth, and
she suspects other children may be suffering because of DCF’s missteps.”
25-
E) Christopher Kennedy: In the case of Mr. Christopher Kennedy, it is Plaintiff’s KM
Dickson’s belief and knowledge that this started out as a simple case of
divorce, and ended with numerous criminal charges against a man who had no
criminal history until DCF involvement.
Mrs. Leanna Kennedy was arrested for second degree assault for stabbing
Mr. Christopher Kennedy. On Friday,
June 30, 2005, Mr. Kennedy was charged with perjury and the bail was said to be
requested at $500,000 but was dropped to $50,000.00. To Plaintiff KM Dickson’s understanding, Mr Kennedy was charged
with perjury for neglecting to mention that there had been issued a restraining
order against Mr. Kennedy. As Plaintiff
KM Dickson informed CT Governor Jodi Rell via mail, that if the State were
charged at a rate of $50,000 per incident of perjury in Plaintiff KM Dickson’s
“cases,” the State would owe a debt in the range of $50,000,000.00. [EXHIBIT FF- 1,- 2]
Mr.
Kennedy’s wife has been arrested for stabbing Mr. Kennedy. Plaintiff KM Dickson is not aware of Mr.
Kennedy stabbing Mrs. Kennedy, yet Mr. Kennedy is facing jail time for false
criminal charges. DCF was “involved.”
Although
Mr. Kennedy sought redress directly with the present Governor’s Chief Legal
Counsel, Kevin J. Rasch, Mr. Kennedy was instead charged with perjury.
25-
F) In comparison, to the above
Christopher Kennedy Perjury case, MR. JOHN G. ROWLAND defrauded the federal court in his financial affidavit regarding
his income, yet no charges were filed.
Mr. Rowland’s sentence was not compounded for nearly the same negligent
“perjury” with which Mr. Kennedy is charged.
[EXHIBIT GG]
“But
federal prosecutors were disappointed. On Thursday, the U.S. attorney's office
had urged Dorsey to put Rowland in prison for up to 37 months, saying that the
office had learned that Rowland had tried to conceal a $416,000 personal
retirement account from federal officials. By portraying his financial
condition as increasingly dire, prosecutors said, Rowland was trying to
generate leniency from the court”--- Hartford Courant March 19, 2005
25-
G) It is noteworthy that as regards
Governor Rell and her son’s behaviors, from CORPORATE CRIME REPORTER http://www.corporatecrimereporter.com/curryinterview.htm
“CCR: If he is impeached or resigns, what is the
provision in Connecticut law for an emergency election?
CURRY: There isn't one. It's one of the questions I've raised with people
in the last few weeks. As in most states, the Lt. Governor
takes over. I think that's a mistake. I think we designed the offices of vice
president and Lt. Governor with an eye
to the death or incapacity of the President or Governor.
I believe that when a chief executive is marched out of office for impeachable
offenses, we should have an election to fill the remainder of the term. The
idea that a member of Rowland's posse simply follows in Rowland's footsteps is
a bad one.
CCR: Has the Lt. Governor, Jodi
Rell, been implicated?
CURRY: When her son was found by state environmental officers to be
running a stolen property ring out of her basement for Skidoos, the environmental officers who made the arrests had
their careers threatened.
They suffered until it hit the press and then the administration backed off.
She denied any involvement in the retaliation. Again, Connecticut's
extraordinary unwillingness to investigate the apparent corruption of its own
elected officials saved her from further public embarrassment.
In any event, she has been a happy, willing partner and an insider in the
Rowland administration for nine years.”
this
at least gives the suggestion that the State of Connecticut is corrupt, and to
include the present Governor. [EXHIBIT
HH Corporate Crime Reporter, Curry Interview]
25-
H) The Saraceno Case: Plaintiff KM Dickson suspects the integrity of Chief State’s
Attorney Christopher Morano due to what we learned in the Hartford Courant’s
Northeast Magazine, Jan 9, 2005, regarding the Saraceno boy’s case:
“Saraceno was convicted and imprisoned but later
released after a private investigation discovered that the prosecutor was
protecting four other young men who almost certainly did the crime. The chief state’s attorney’s office
uncomfortably joined in the defense in a motion to overturn the
conviction. That should have freed the
youth from further jeopardy. Instead,
in 1999, under threat of extending the legal nightmare that had already cost
his parents $100,000, Saraceno accepted guilt for “hindering prosecution by
falsely confessing. ” Under the
statute of limitations, the state had allowed the five-year window for
prosecuting the known suspects to close.
No one except the wrong man did jail time for the crime. The law officer most responsible for
compelling Saraceno to declare it was his fault is Chief State’s Attorney
Christopher Morano”.
25-
I) The Office of Public Integrity: Mr.
Christopher Morano, the Chief State’s Attorney has an Office of Public
Integrity, yet Morano never responded to the integrity complaints lodged by
Plaintiff KM Dickson as regards the bizarre and discriminatory behavior of DCF
staff.
25-
J) CHRISTOPHER MORANO’S BIRTHDAY PARTY,
FROM THE WEBSITE: CRIME AND FEDERALISM, by Norm Pattis:
March
29, 2005 in Federal Courts | Permalink | Comments (5) | TrackBack
But
the Governor did it?
Norm Pattis
Connecticut
calls itself the Land of Steady Habits. In recent years, those habits have
evolved to graft among its public officials. Why just the other day, former
Governor John G. Rowland was sentenced to federal prison for a brief stretch.
He couldn't keep distinct in his mind his official duties and gorging himself
at the public trough.
After
his guilty plea and resignation from office, he kept on grabbing cash. He raked
in about $15,000 a month as a consultant to private industry on, of all things,
government. Now the Connecticut General Assembly wants to take a look at why
felons are hired as consultants. Oink, Oink, Oink
Now
comes news that a prosecutor may not have been able to avoid all the fun.
Supervisory Assistant State's Attorney David Newman of New Haven is under the
microscope, according to the Chief State's Attorney's Office. Suspicions that
all is not well in the historic Elm Street courthouse. According to the New
Haven Register, questions have arisen about whether Mr. Newman regards himself
as a legitimate beneficiary of charitable contributions intended to resolve
minor offenses. Charity for a Day
Newman
has hired criminal defense lawyer Hugh Keefe, who tried to waive off the
scandal as an "internal employment matter." Well, that's one spin.
But Keefe is known for his defense of police officers in claims arising under
42 U.S.C. Section 1983 and for defending those accused of crimes. He's no
employment lawyer.I Want Mine, Too
This
comes on the heels of a report that a former prosecutor was arrested leaving
the 50th birthday party of Chief States Attorney Christopher Morano. The former
lawman was drunk, was carrying a little reefer, and was armed. He's now asking
the court for a diversionary program that would permit the record of his arrest
to be erased after a brief period of probation.
Wow.
I guess there's no place like home for white collar crime, and, if you know the
right people it seems that just about anything is possible.
March
29, 2005 | Permalink | Comments (2) | TrackBack
Plaintiff
KM Dickson would only add the comment that the residents of the State of CT
would wonder how often these prosecutors get together to party, and what they
discuss. CT State prosecutors breaking
the law is the nature of this complaint.
We victims of their crimes only wish the vast majority of crimes
committed by State prosecutors and other state employees was limited to smoking
marijuana.
25-
K) FALSE ARREST, NOT INVOLVING
DCF: Steven G. Erickson. In the case of Steven G. Erickson, It is Plaintiff KM Dickson’s
belief and knowledge that the testimony of Steven G. Erickson was truthful, in
that Erickson believes that he wasn’t
getting equal protection and service being a Stafford Springs downtown
Connecticut landlord.
Mr.
Erickson, formerly of Stafford, CT, wrote letters to the editor critical of
police and Connecticut courts and wrote President Bush a letter about how the
economy was hurt by downtown (Stafford) property and small business owners
getting a fair shake in courts and adequate police help and service. Mr. Erickson proposed Civilian Oversight of
Police to State Senator Tony Guglielmo and former State Representative
Mordasky. Mordasky’s aid, “Rosemarie,”
advised Erickson that Erickson should sell his property and leave Connecticut
before the Connecticut State Police retaliated for the laws Erickson proposed
directing police powers, and for what Mr. Erickson had written critical of
police in newspapers, and for being a “Big Mouth.”
Mr.
Erickson also attests that the Connecticut State Police were bragging that Mr.
Erickson would be going to prison and run out of town after Erickson was
attacked by Brian Caldwell on Erickson’s property when Erickson returned home
from a double shift of work. Caldwell
had told Erickson’s tenants Caldwell would kill Erickson when Erickson got
home, and had threatened Erickson, harassed Erickson via voicemail, and beating
on Erickson door after midnight, yelling that Caldwell, would cut Erickson’s
penis off if Caldwell caught Erickson outside Erickson’s home.
According
to Mr. Erickson, Connecticut State Troopers, Amaral and Langlais refused to take
Erickson’s complaint against Erickson’s assailant who had jumped Erickson and
tried to rob Erickson, nor would they take the complaint of witness Sue
Johnston, nor that of Clayton Varno.
Instead the police only arrested Erickson, refusing to view Erickson’s
injuries, and then later committing perjury of these facts to get me convicted
of overreacting to being beaten during a robbery attempt using pepper spray.
Apparently,
Judge Jonathan Kaplan of Rockville Connecticut Court stated that Erickson was guilty
and was going to prison before Erickson’s trial began. A videotape was shown to
the jury of how to find Erickson guilty, but nothing about innocence or
reasonable doubt, tainting them. (XXX, evidence #)
It
is Erickson’s belief that Judge Kaplan informed Erickson’s attorney, Michael H.
Agranoff (Stafford, CT), that Agranoff
was not allowed to dispute police perjury, the prosecution, nor defend
Erickson.
Erickson
sent an email to the former Connecticut State Police Commission Arthur L. Spada
in late October 2002, the day before Erickson was to be sentenced, asking Spada
to remove the US Department of Justice webpage on Community Policing off the
Connecticut State Police website, stating the policies were not being followed. Erickson indicated that Erickson was sending
a copy of the email to the US Department of Justice.
Erickson
believes the Connecticut State Police, the prosecutors, Erickson’s lawyer, and
Judge Jonathan Kaplan were acting in collusion to ensure Erickson’s conviction
to prevent Erickson from suing for Civil Rights violations and to keep Erickson
from lodging complaints and exposing corruption within the courts and
Connecticut State Police.
Erickson
further asserts that Judge Jonathan Kaplan appeared to reference the email
Erickson sent to Commissioner Spada at Plaintiff’s sentencing, indicating to
Erickson their was illegal collusion between Judge Jonathan J. Kaplan and
Connecticut State Police Officers to ensure Erickson was convicted and given
the maximum penalties allowed.
Mr.
Erickson was sent to an overcrowded prison and was singled out for abuse by
guards referencing Erickson’s feud with the Connecticut State Police. Mr. Erickson was held in prison longer than
his stated release date, wasn’t allowed to take classes in prison as further
harassment, and was told that Erickson wasn’t allowed in Stafford, Connecticut
upon release by LT Desso, also a Stafford town police officer.
Mr.
Erickson asserts that he was told by his parole officer at the Enfield Police
Station, that Erickson wasn’t allowed to make complaints against police
officers, nor contact the media regarding Erickson’s case or face more prison
time. These are clearly federal color
of law, deprivation of rights, and violation of federally protected activities,
and first amendment violations.
When
Mr. Erickson was turned over to adult probation in Manchester Connecticut,
Erickson was given told by Angela K. that she would violate Erickson’s
probation if she received any more calls regarding Erickson and would violate
Erickson’s probation if Erickson didn’t leave the State of Connecticut. Mr. Erickson was given an hour to pack and
leave the State of Connecticut to avoid further persecution and fraudulent
prosecution.
25-J) Jeffrey Yeaw To Plaintiff KM Dickson’s belief and knowledge, Mr. Yeaw was not
provided equal protection under the law, was deprived of his civil rights, as
were his children. These children were
not reported as physically harmed or neglected by Mr. Yeaw in any way. This family’s tragedy was another color of
law abuse and illegitimate traumatization to children. Mr. Yeaw was arrested, and not his wife, when
all known reports are clear and convincing, that Mrs. Yeaw was physically
violent to her husband, and initiated an altercation. Mr. Yeaw’s children were taken by DCF, and
Mr. Yeaw, being of sound mind and familiar with DCF abuses, merely rescued
these children. Instead he was charged
with the “crime” of abducting his own children. [EXHIBITS II]
Plaintiff
KM Dickson wishes she had the courage to rescue her own children, but it never
occurred to this Plaintiff. At that,
Plaintiff Dickson never anticipated her children being taken, since there was
no abuse or neglect going on, and everyone knew it. DCF threw out their first petition against this Plaintiff and
wrote a new one.
Now
Mr. Yeaw faces years in prison, because his wife attacked him, and he left the
house in response. The present
Governor, Rell, publicly commented on this crime, when she did not know it was
not a crime. This is disheartening to
CT residents, since we had faith that this replacement Governor, Mrs. Rell, for
Governor Rowland, was Number One, a woman, and Number Two, got rid of a number
of the cronies hired by Rowland. Rell
did not get rid of DMHAS’ or DCF’s commissioners, however, when we know both
agencies are abundant and obvious failures.
No
one should have been arrested in any of these “cases.” Were it not for the
incompetence and abuse by DCF and the prosecutorial madness in the State of
Connecticut, and were it not for the failure of the mental health system, some
of these cases would, from an outside observer, appear be family
arguments. Instead, they became
obvious cases of discrimination and retaliation, and then numerous and extreme
civil rights violations, including false criminal charges, prison sentences and
threats of permanent incarceration, under the apparently Secret Connecticut
“We’ll Commit You Permanently and Take Your House and Income if You Don’t Shut Up, by Inventing Your Crimes,
and then Committing You to a Psychiatric Hospital, Indefinitely, For Saying You
Are Innocent” Act.
That
the DCF would record family arguments as neglect of children, implies that
nearly all Connecticut children would have to be removed from their parents.
Given
DCF’s civil rights violations and false criminal charges, to known and unknown
numbers of parents and children, and the fact that the DCF is well-known to be
“arrogant and inept,” as regards children and families, Jeffrey Yeaw was
competent, correct, sane, protective, caring and fully within his rights to
rescue his children from the abomination known as the CT Department of Children
and Families.
It
is Plaintiff KM Dickson’s belief that the evidence submitted supports that no
children are safe in DCF’s “care,” and due to the presence of the Rowlandgate
Appointee US Attorney Kevin O’Connor, justice cannot be gained in the US
Department of Justice District of Connecticut.
-----------------------------------------
DAMAGES
AND RELIEF REQUESTED
1)
The Connecticut Department of Children and Families is to be dissolved
completely and all related DCF statutes stricken from Connecticut General
Statutes.
2)
$100,000,000 in pain and restitution of costs to Plaintiff Dickson and her
children from the State of Connecticut.
3)
The establishment of a research clinic and hospital for vector borne diseases,
in Connecticut, to be named the Hospital of the Immaculate Heart, with the
funds recovered in the discovery of scientific fraud committed by Yale
University, the Yale Corporation, and to include the criminal prosecution of
all Yale- and Lyme-related perjury anywhere to be found in America.
Plaintiff
Dickson will manage this organization, which will restore the earlier meanings
of “care” and “integrity” to the English language.
The
$100,000,000 million in damages from the State granted to the Plaintiff shall
be donated to this establishment, the Hospital of the Immaculate Heart.
4) AAG Jessica Gauvin is to be criminally
charged with making false statements to police and Gauvin shall be asked to
leave the State of CT permanently after her criminal sentencing.
5) A
forum for redress of all DCF perjury committed in the last 15 years, and the
return of fraudulently taken children by CT DCF.
6) The
prosecution of MARC S. RYAN and KRISTINE RAGAGLIA for conspiring to defraud the
federal government as regards child welfare, and the incarceration of children
as policy, over care.
7)
Federal oversight of the CT Department of Justice, and the Chief State’s
Attorney’s Office.
8)
The return of Plaintiff KM Dickson’s children to Plaintiff KM Dickson’s care,
and in sole custody.
Signed
this _________ day of _____________, 2005
______________________
Kathleen
M. Dickson, et al
23
Garden Street
Pawcatuck,
CT 06379
________________________
Lara
E. Dickson
________________________
Diane
M. Dickson
_________________________
David
D. Dickson
DEFINITIONS
AND STATUTES
ADA Title
II: State and Local Government Activities
Title
II covers all activities of State and local governments regardless of the
government entity's size or receipt of Federal funding. Title II requires that
State and local governments give people with disabilities an equal opportunity
to benefit from all of their programs, services, and activities (e.g. public
education, employment, transportation, recreation, health care, social
services, courts, voting, and town meetings).
State and local governments are required to follow specific architectural
standards in the new construction and alteration of their buildings. They also
must relocate programs or otherwise provide access in inaccessible older
buildings, and communicate effectively with people who have hearing, vision, or
speech disabilities. Public entities are not required to take actions that
would result in undue financial and administrative burdens. They are required
to make reasonable modifications to policies, practices, and procedures where
necessary to avoid discrimination, unless they can demonstrate that
doing so would fundamentally alter the nature of the service, program, or
activity being provided.
ADA
Title II: State and Local Government Activities
Title
II covers all activities of State and local governments regardless of the
government entity's size or receipt of Federal funding. Title II requires that
State and local governments give people with disabilities an equal opportunity
to benefit from all of their programs, services, and activities (e.g. public
education, employment, transportation, recreation, health care, social
services, courts, voting, and town meetings).
State and local governments are required to follow specific architectural
standards in the new construction and alteration of their buildings. They also
must relocate programs or otherwise provide access in inaccessible older
buildings, and communicate effectively with people who have hearing, vision, or
speech disabilities. Public entities are not required to take actions that
would result in undue financial and administrative burdens. They are required
to make reasonable modifications to policies, practices, and procedures where
necessary to avoid discrimination, unless they can demonstrate that
doing so would fundamentally alter the nature of the service, program, or
activity being provided.
DEFINITIONS:
Connecticut
Chapter 319 Sec. 17b-608. (Formerly Sec. 17-608). Persons with disabilities.
Definition. For the purposes of sections 17b-609 and 17b-610, "persons
with disabilities" shall mean persons having disabilities which (1) are
attributable to a mental or physical impairment or a combination of mental and
physical impairments; (2) are likely to continue indefinitely; (3) result in
functional limitations in one or more of the following areas of major life
activity: Self care, receptive and expressive language, learning, mobility,
self-direction, capacity for independent living or economic self-sufficiency;
and (4) reflect the person's need for a combination and sequence of special,
interdisciplinary or generic care, treatment or other services which are of
lifelong or extended duration and individually planned and coordinated.
CONSPIRACY
AGAINST RIGHTS
Summary:
Section
241 of Title 18 is the civil rights conspiracy statute. Section 241 makes it
unlawful for two or more persons to agree together to injure, threaten, or
intimidate a person in any state, territory or district in the free exercise or
enjoyment of any right or privilege secured to him/her by the Constitution or
the laws of the Unites States, (or because of his/her having exercised the
same). Unlike most conspiracy statutes, Section 241 does not require that one
of the conspirators commit an overt act prior to the conspiracy becoming a
crime.
The
offense is punishable by a range of imprisonment up to a life term or the death
penalty, depending upon the circumstances of the crime, and the resulting
injury, if any.
TITLE
18, U.S.C., SECTION 241
If
two or more persons conspire to injure, oppress, threaten, or intimidate any
person in any State, Territory, Commonwealth, Possession, or District in the
free exercise or enjoyment of any right or privilege secured to him by the
Constitution or laws of the United States, or because of his having so
exercised the same;...
They
shall be fined under this title or imprisoned not more than ten years, or both;
and if death results from the acts committed in violation of this section or if
such acts include kidnapping or an attempt to kidnap, aggravated sexual abuse
or an attempt to commit aggravated sexual abuse, or an attempt to kill, they
shall be fined under this title or imprisoned for any term of years or for
life, or both, or may be sentenced to death.
--------------------------------
DEPRIVATION
OF RIGHTS UNDER COLOR OF LAW
Summary:
Section
242 of Title 18 makes it a crime for a person acting under color of any law to
willfully deprive a person of a right or privilege protected by the
Constitution or laws of the United States.
For
the purpose of Section 242, acts under "color of law" include acts
not only done by federal, state, or local officials within the their lawful
authority, but also acts done beyond the bounds of that official's lawful
authority, if the acts are done while the official is purporting to or
pretending to act in the performance of his/her official duties. Persons acting
under color of law within the meaning of this statute include police officers,
prisons guards and other law enforcement officials, as well as judges, care
providers in public health facilities, and others who are acting as public
officials. It is not necessary that the crime be motivated by animus toward the
race, color, religion, sex, handicap, familial status or national origin of the
victim.
The
offense is punishable by a range of imprisonment up to a life term, or the
death penalty, depending upon the circumstances of the crime, and the resulting
injury, if any.
TITLE
18, U.S.C., SECTION 242
Whoever,
under color of any law, statute, ordinance, regulation, or custom, willfully
subjects any person in any State, Territory, Commonwealth, Possession, or
District to the deprivation of any rights, privileges, or immunities secured or
protected by the Constitution or laws of the United States, ... shall be fined
under this title or imprisoned not more than one year, or both; and if bodily
injury results from the acts committed in violation of this section or if such
acts include the use, attempted use, or threatened use of a dangerous weapon,
explosives, or fire, shall be fined under this title or imprisoned not more
than ten years, or both; and if death results from the acts committed in
violation of this section or if such acts include kidnaping or an attempt to
kidnap, aggravated sexual abuse, or an attempt to commit aggravated sexual
abuse, or an attempt to kill, shall be fined under this title, or imprisoned
for any term of years or for life, or both, or may be sentenced to death.
http://www.usdoj.gov/crt/crim/crimhome.html
FEDERALLY
PROTECTED ACTIVITIES
Summary:
The
portion of Section 245 of Title 18 which is primarily enforced by the Criminal
Section makes it unlawful to willfully injure, intimidate or interfere with any
person, or to attempt to do so, by force or threat of force, because of that
other person's race, color, religion or national origin and because of his/her
activity as one of the following:
A student at or applicant for
admission to a public school or public college
A participant in a benefit,
service, privilege, program, facility or activity provided or administered by a
state or local government
An applicant for private or
state employment; a private or state employee; a member or applicant for membership
in a labor organization or hiring hall; or an applicant for employment through
an employment agency, labor organization or hiring hall
A juror or prospective juror
in state court
A traveler or user of a
facility of interstate commerce or common carrier
A patron of a public
accommodation or place of exhibition or entertainment, including hotels,
motels, restaurants, lunchrooms, bars, gas stations, theaters, concert halls,
sports arenas or stadiums.
This
statute also prohibits wilful interference, by force or threat of force, with a
person because he/she is or was participating in, or aiding or encouraging
other persons to participate in any of the benefits or activities listed above
without discrimination as to race, color, religion, or national origin.
The
offense is punishable by a range of imprisonment up to a life term, or the
death penalty, depending upon the circumstances of the crime, and the resulting
injury, if any.
TITLE
18, U.S.C., SECTION 245
(a)(1)Nothing
in this section shall be construed as indicating an intent on the part of
Congress to prevent any State, any possession or Commonwealth of the United
States, or the District of Columbia, from exercising jurisdiction over any
offense over which it would have jurisdiction in the absence of this section,
nor shall anything in this section be construed as depriving State and local
law enforcement authorities of responsibility for prosecuting acts that may be
violations of this section and that are violations of State and local law. No
prosecution of any offense described in this section shall be undertaken by the
United States except upon the certification in writing of the Attorney General,
the Deputy Attorney General, the Associate Attorney General, or any Assistant
Attorney General specially designated by the Attorney General that in his
judgment a prosecution by the United States is in the public interest and
necessary to secure substantial justice, which function of certification may
not be delegated.
(2)
Nothing in this subsection shall be construed to limit the authority of Federal
officers, or a Federal grand jury, to investigate possible violations of this
section.
(b)Whoever,
whether or not acting under color of law, by force or threat of force willfully
injures, intimidates or interferes with, or attempts to injure, intimidate or
interfere with--
(1)any
person because he is or has been, or in order to intimidate such person or any
other person or any class of persons from--
(A)
voting or qualifying to vote, qualifying or campaigning as a candidate for
elective office, or qualifying or acting as a poll watcher, or any legally
authorized election official, in any primary, special, or general election;
(B)
participating in or enjoying any benefit, service, privilege, program,
facility, or activity provided or administered by the United States;
(C)
applying for or enjoying employment, or any perquisite thereof, by any agency
of the United States;
(D)
serving, or attending upon any court in connection with possible service, as a
grand or petit juror in any court of the United States;
(E)
participating in or enjoying the benefits of any program or activity receiving
Federal financial assistance; or
(2)
any person because of his race, color, religion or national origin and because
he is or has been--
(A)
enrolling in or attending any public school or public college;
(B)
participating in or enjoying any benefit, service, privilege, program, facility
or activity provided or administered by any State or subdivision thereof;
(C)
applying for or enjoying employment, or any perquisite thereof, by any private
employer or any agency of any State or subdivision thereof, or joining or using
the services or advantages of any labor organization, hiring hall, or employment
agency;
(D)
serving, or attending upon any court of any State in connection with possible
service, as a grand or petit juror,
(E)
traveling in or using any facility of interstate commerce, or using any
vehicle, terminal, or facility of any common carrier by motor, rail, water, or
air;
(F)
enjoying the goods, services, facilities, privileges, advantages, or
accommodations of any inn, hotel, motel, or other establishment which provides
lodging to transient guests, or of any restaurant, cafeteria, lunchroom, lunch
counter, soda fountain, or other facility which serves the public and which is
principally engaged in selling food or beverages for consumption on the
premises, or of any gasoline station, or of any motion picture house, theater,
concert hall, sports arena, stadium, or any other place of exhibition or
entertainment which serves the public, or of any other establishment which
serves the public and (i) which is located within the premises of any of the
aforesaid establishments or within the premises of which is physically located
any of the aforesaid establishments, and (ii) which holds itself out as serving
patrons of such establishments; or
(3)
during or incident to a riot or civil disorder, any person engaged in a
business in commerce or affecting commerce, including, but not limited to, any
person engaged in a business which sells or offers for sale to interstate
travelers a substantial portion of the articles, commodities, or services which
it sells or where a substantial portion of the articles or commodities which it
sells or offers for sale have moved in commerce; or
(4)
any person because he is or has been, or in order to intimidate such person or
any other person or any class of persons from--
(A)
participating, without discrimination on account of race, color, religion or
national origin, in any of the benefits or activities described in
subparagraphs (1)(A) through (1)(E) or subparagraphs (2)(A) through (2)(F); or
(B)
affording another person or class of persons opportunity or protection to so
participate; or
(5)
any citizen because he is or has been, or in order to intimidate such citizen
or any other citizen from lawfully aiding or encouraging other persons to
participate, without discrimination on account of race, color, religion or
national origin, in any of the benefits or activities described in
subparagraphs (1)(A) through (1)(E) or subparagraphs (2)(A) through (2)(F), or
participating lawfully in speech or peaceful assembly opposing any denial of
the opportunity to so participate--
shall
be fined under this title, or imprisoned not more than one year, or both; and
if bodily injury results from the acts committed in violation of this section
or if such acts include the use, attempted use, or threatened use of a
dangerous weapon, explosives, or fire shall be fined under this title, or
imprisoned not more than ten years, or both; and if death results from the acts
committed in violation of this section or if such acts include kidnaping or an
attempt to kidnap, aggravated sexual abuse or an attempt to commit aggravated
sexual abuse, or an attempt to kill, shall be fined under this title or
imprisoned for any term of years or for life, or both, or may be sentenced to
death. As used in this section, the term "participating lawfully in speech
or peaceful assembly" shall not mean the aiding, abetting, or inciting of
other persons to riot or to commit any act of physical violence upon any
individual or against any real or personal property in furtherance of a riot.
Nothing in subparagraph (2)(F) or (4)(A) of this subsection shall apply to the
proprietor of any establishment which provides lodging to transient guests, or
to any employee acting on behalf of such proprietor, with respect to the
enjoyment of the goods, services, facilities, privileges, advantages, or
accommodations of such establishment if such establishment is located within a
building which contains not more than five rooms for rent or hire and which is
actually occupied by the proprietor as his residence.
(c)
Nothing in this section shall be construed so as to deter any law enforcement
officer from lawfully carrying out the duties of his office; and no law
enforcement officer shall be considered to be in violation of this section for
lawfully carrying out the duties of his office or lawfully enforcing ordinances
and laws of the United States, the District of Columbia, any of the several
States, or any political subdivision of a State. For purposes of the preceding
sentence, the term "law enforcement officer" means any officer of the
United States, the District of Columbia, a State, or political subdivision of a
State, who is empowered by law to conduct investigations of, or make arrests
because of, offenses against the United States, the District of Columbia, a
State, or a political subdivision of a State.
(d)
For purposes of this section, the term "State" includes a State of
the United States, the District of Columbia, and any commonwealth, territory,
or possession of the United States.
DEFINITIONS:
Connecticut
Chapter 319 Sec. 17b-608. (Formerly Sec. 17-608). Persons with disabilities.
Definition. For the purposes of sections 17b-609 and 17b-610, "persons
with disabilities" shall mean persons having disabilities which (1) are
attributable to a mental or physical impairment or a combination of mental and
physical impairments; (2) are likely to continue indefinitely; (3) result in
functional limitations in one or more of the following areas of major life
activity: Self care, receptive and expressive language, learning, mobility,
self-direction, capacity for independent living or economic self-sufficiency;
and (4) reflect the person's need for a combination and sequence of special,
interdisciplinary or generic care, treatment or other services which are of
lifelong or extended duration and individually planned and coordinated.
CONNECTICUT
STATUTES
Connecticut
Chapter 368a Sec. 19a-6. (Formerly Sec. 19-4a). Commissioner to plan and
administer programs for control and treatment of lung disease and chronic illness
and for medical rehabilitation. (a) The commissioner shall be responsible for
planning state-wide programs for the control and treatment of lung diseases;
the treatment of persons affected with other chronic illness, and the medical
rehabilitation of chronically ill, physically disabled and handicapped persons.
The commissioner shall provide and maintain facilities and personnel for the
diagnosis or detection and treatment of such diseases or enter into contracts
for the provision of diagnostic and treatment programs for such diseases with
persons or organizations capable in his judgment of providing such services.
Chapter
50* Office of Policy and Management Sec. 4-66a. Secretary to advise Governor
and General Assembly on matters concerning local government and matters
affecting the state. Planning, management and technical assistance for local
governments. Federal financial assistance and funds, and financial assistance
and aid from private sources. (a) The Secretary of the Office of Policy and Management
shall advise the Governor on matters concerning local government including
state laws relating to local government, the impact of federal actions or
proposed federal actions on local government, the financial needs and resources
of local government and the allocation of program and financial responsibility
between local government and the state.
(b)
The secretary shall advise the Governor regarding potential federal actions
affecting state government and the citizens of the state and shall advise the
joint standing committees of the General Assembly having cognizance of matters
relating to appropriations and relating to the subject area of each federal
policy initiative, including the allocation of resources in the federal budget,
federal public assistance policy, federal economic policy and the distribution
of federal assistance and facilities among regions and states.
(c)
The secretary may provide planning and management assistance to local
governments utilizing such state and federal funds as may be appropriated for
such purpose. …
Sec.
17b-3. Commissioner of Social Services: Powers and duties. (a) The Commissioner
of Social Services shall administer all law under the jurisdiction of the
Department of Social Services. The commissioner shall have the power and duty
to do the following: (1) Administer, coordinate and direct the operation of the
department; (2) adopt and enforce regulations, in accordance with chapter 54,
as are necessary to implement the purposes of the department as established by
statute; (3) establish rules for the internal operation and administration of
the department; (4) establish and develop programs and administer services to
achieve the purposes of the department as established by statute; (5) contract
for facilities, services and programs to implement the purposes of the
department as established by statute; (6) process applications and requests for
services promptly; (7) make no duplicate awards for items of assistance once
granted, except for replacement of lost or stolen checks on which payment has
been stopped; (8) promote economic self-sufficiency where appropriate in the
department's programs, policies, practices and staff interactions with
recipients; (9) act as advocate for the need of more comprehensive and coordinated
programs for persons served by the department; (10) plan services and programs
for persons served by the department; (11) coordinate outreach activities by
public and private agencies assisting persons served by the department; (12)
consult and cooperate with area and private planning agencies; (13) advise and
inform municipal officials and officials of social service agencies about
social service programs and collect and disseminate information pertaining
thereto, including information about federal, state, municipal and private
assistance programs and services; (14) encourage and facilitate effective
communication and coordination among federal, state, municipal and private
agencies; (15) inquire into the utilization of state and federal government
resources which offer solutions to problems of the delivery of social services;
(16) conduct, encourage and maintain research and studies relating to social
services development; (17) prepare, review and encourage model comprehensive
social service programs; (18) maintain an inventory of data and information and
act as a clearing house and referral agency for information on state and
federal programs and services; and (19) conduct, encourage and maintain
research and studies and advise municipal officials and officials of social
service agencies about forms of intergovernmental cooperation and coordination
between public and private agencies designed to advance social service
programs. The commissioner may require notice of the submission of all applications
by municipalities, any agency thereof, and social service agencies, for federal
and state financial assistance to carry out social services. The commissioner
shall establish state-wide and regional advisory councils.
(b)
The Commissioner of Social Services is authorized to do all things necessary to
apply for, qualify for and accept any federal funds made available or allotted
under any federal act for social service development, or any other projects,
programs or activities which may be established by federal law, for any of the
purposes or activities related thereto, and said commissioner shall administer
any such funds allotted to the department in accordance with federal law. The
commissioner may enter into contracts with the federal government concerning
the use and repayment of such funds under any such federal act, the prosecution
of the work under any such contract and the establishment of and disbursement
from a separate account in which federal and state funds estimated to be
required for plan preparation or other eligible activities under such federal
act shall be kept. Said account shall not be a part of the General Fund of the
state or any subdivision of the state.
Section
1983. Civil action for deprivation of rights
Every person who, under color of any
statute, ordinance, regulation, custom, or usage, of any State or Territory or
the District of Columbia, subjects, or causes to be subjected, any citizen of
the United States or 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, except that in any action brought against a judicial
officer for an act or omission taken in such officer's judicial capacity,
injunctive relief shall not be granted
unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable
exclusively to the District of Columbia shall be considered to be a statute of
the District of Columbia.
· United States Code TITLE 42 - THE PUBLIC HEALTH AND
WELFARE
SUBCHAPTER V - FEDERALLY ASSISTED
PROGRAMS
Section 2000d-4a. ''Program or
activity'' and ''program'' defined
For the purposes of this subchapter, the
term ''program or activity'' and the
term ''program'' mean all of the operations of –
(1)(A) a department, agency, special
purpose district, or other
instrumentality of a State or of a local government; or
(B) the entity of such State or local
government that distributes such assistance and each such department or agency
(and each other State or local government entity) to which the assistance is
extended, in the case of assistance to a State or local government;
(2)(A) a college, university, or other
postsecondary institution, or a public system of higher education; or
(B) a local educational agency (as
defined in section 7801 of title 20),
system of vocational education, or other school system;
(3)(A) an entire corporation,
partnership, or other private organization, or an entire sole proprietorship -
(i) if assistance is extended to
such corporation, partnership, private organization, or sole proprietorship as
a
whole; or
(ii)
which is principally engaged in the business of providing education, health
care, housing, social services, or parks and recreation; or
(B) the entire plant or other
comparable, geographically separate facility to which Federal financial
assistance is extended, in the case of any other corporation, partnership, private
organization, or sole proprietorship; or
(4) any other entity which is
established by two or more of the entities described in paragraph (1), (2), or
(3);
any part of which is extended Federal
financial assistance.
Kathleen
M. Dickson, and
on
behalf of Lara E. Dickson,
Diane
M. Dickson, David D. Dickson, et al,
and
on behalf of all Families and
Children
of the State of Connecticut
In
the cause of a class action: CA
05- 328 T
v. STATE OF CONNECTICUT US DISTRICT COURT
1
Exchange Terrace
Providence,
Rhode Island 02903
August
3, 2005
AMENDED
COMPLAINT AND MOTION
1) Plaintiff KM Dickson motions for the
appointment of counsel to represent the victims represented in this class
action against the State of Connecticut from the federal court, due to the
pervasive retaliation by the CT Justice system mentioned in the original
complaint. No CT lawyer is willing to
sue the State of Connecticut or Yale University due to Retaliation Syndrome in
the CT justice system, and the conditions listed cited below in section 4) of
this amended complaint.
Plaintiff
KM Dickson is disabled from High Functioning Autism and Lyme Disease, the
latter of which is a chronic infection of the nervous system and which only rarely
affects joints (transcript, January 31, 2001, FDA meeting regarding LymeRIX;
the testimony of Raymond Dattwyler, SUNY Stony Brook). Plaintiff’s children have been diagnosed
with Lyme disease. Autism is a
pervasive development disorder, although no one in the State of Connecticut
appears to know what that means. The
Plaintiff KM Dickson had to forward the information regarding what “pervasive
development disorder” and “Neuroborreliosis” are to the current Governor of
Connecticut from correspondence sent to the Plaintiff KM Dickson from the
National Institute of Neurological Disorders and Stroke.
Under
the Americans With Disabilities Act, access to the courts is not limited to
physical access, and persons disabled with communication problems, such as
autism, must be accommodated. As
described in the original complaint, CA 05-328 T, the State of Connecticut
Department of Mental Health and Addiction Services blatantly does not recognize
Lyme neuroborreliosis or Autism, which are among the reasons this complaint was
moved to another US federal district court.
Plaintiff KM Dickson requests procedural advice in order to make
efficient use of the Rhode Island federal court.
2) The counsel appointed should be familiar with
United States Racketeering and Corrupt Organizations prosecution and preferably
is a US Attorney. The corruption in
Connecticut, labeled “The Corruption Virus” by Attorney General Richard
Blumenthal, is deeply intertwined within the CT state courts. The CT Department of Mental Health, the CT
Department of Health, the CT Department of Children and Families, CT court
“experts,” CT “forensic experts” are both “experts” for the defendant Yale
University in 3:05- CV- 92 (CFD), as regards Lyme disease and other brain
disease states, as well as the “experts” for the State of Connecticut, which is
a defendant also in that civil action.
The US Attorney Kevin O’Connor was formerly a State of CT prosecutor. O’Connor would then have to prosecute his
own former criminal “experts,” which would mean yet another recusal on the part
of the US Attorney’s office in Connecticut.
3)
Under the Fifth Amendment “No person shall be held to answer for a capital, or
otherwise infamous crime, unless on a presentment or indictment of a grand
jury, except in cases arising in the land or naval forces, or in the militia,
when in actual service in time of war or public danger; nor shall any person be
subject for the same offense to be twice put in jeopardy of life or limb; nor
shall be compelled in any criminal case to be a witness against himself, nor be
deprived of life, liberty, or property, without due process of law; nor shall
private property be taken for public use, without just compensation.
In
the criminal case against Plaintiff KM Dickson all appearances of the
above-listed protections of Constitutional law were abandoned: Due process, a
threat to deprive of property if Plaintiff KM Dickson did not plead guilty to
the crimes she did not commit, deprivation of natural children, and deprivation
of their mother to Plaintiff’s natural children. Plaintiff KM Dickson committed no crimes and was given no
opportunity for due process of law.
Plaintiff KM Dickson did not know what she was being charged with until
after 9 weeks in prison. Plaintiff KM
Dickson was not allowed the opportunity to prove innocence, and was threatened
with permanent involuntary committal to a psychiatric hospital if she persisted
in maintaining her innocence, and the State was to take all of Plaintiff KM Dickson’s
assets to pay for Plaintiff KM Dickson’s treatment for AAG Jessica Gauvin’s
psychosis.
These
rights are also routinely denied in all DCF cases, rendering all DCF cases of
abuse and neglect completely illegitimate in the eyes of the public, causing
citizens to reasonably suspect any “parental kidnappings” as real kidnappings
or child abuse as child abuse. These
kidnappings are far likelier to be fraudulently court-rendered abuse and
neglect via termination of parental rights.
This causes serious jeopardy to children who really are being abused or
neglected, but that is the handiwork, crime, and legacy of DCF alone. Recently a CT DCF supervisor (Valerie Miles)
was arrested for tampering with a witness and fabricating evidence.
The
Unibomber, Ted Kaszinski, was a domestic terrorist. To falsely assert that the Plaintiff KM Dickson is like the
Unibomber, is falsely accusing someone of being a terrorist. These three conditions, 1) taking an
excessive number of children from their parents under fraudulent pretenses, 2)
falsely accusing people of being terrorists, and 3) witness tampering and
fabricating evidence, puts everyone at risk because of the obvious dangers of
“crying wolf,” to us all.
4) The Lyme disease scientific fraud and
racketeering complaint involves the following collection of related and
possibly-related conditions which hinder the prosecution of these crimes in
Connecticut, be it in federal or state court:
a)
) The Yale Corporation is in New Haven,
Connecticut; “the Medical School Endowment
Fund.”
b) L2 Diagnostics is a private biotechnology
firm spinoff from Yale’s former Lyme and Lupus Clinic.
c) Allen C. Steere is now working at Harvard,
and who is who masterminded the current and fraudulent Centers for Disease
Control’s IgG blood testing standard for Lyme. This scam involved using the high passage Lyme spirochete strain
G39/40, which lost plasmid DNA expression.
A result of being high-passage, or culture too many times in a Petri
dish, before being recycled through an animal host, which would allow the
organisms to maintain the expression of virulence factors or antigens. Thus, high passage G39/40 lost expression of
OspA and B. OspA and B are encoded on
the same plasmid (small, extrachromosomal DNA, which is vectored by bacteriophages,
or viruses that infect bacteria). OspA is the vaccine LymeRIX and
ImmuLyme. ImmuLyme was not approved by
the FDA for use in humans. Yale owns
the patent for LymeRIX. LymeRIX was
removed from the market due to the unreported adverse events, which took place
during the vaccine trial, but were not reported to the FDA during the vaccine
trial. Adverse events were later
reported, but not until the vaccine was on the market. Osps A and B were left out of the CDC’s
blood testing standard for Lyme, as a result of this scientific fraud by Allen
Steere. LymeRIX 1) never prevented
borreliosis is lab animals, and 2)
never should have gone to human trials, 3) it did not disinfected ticks
but rather made the infection expand in ticks, and 4) LymeRIX did not prevent
asymptomatic Lyme infection- it apparently made asymptomatic Lyme
symptomatic. Every single claim Yale
and SmithKLine made about LymeRIX was false.
d)
L2 Diagnostics, in partnership with Corixa Corporation (Washington State),
Imugen (Norwood Mass), and SmithKline (now Glaxo-SmithKline), share rights to
the diagnostic test for Lyme which is now the current CDC IgG standard: Corixa’s David Persing patented a test for
Lyme from a Lyme spirochete which was missing the OspA-B plasmid. The “partnership” involves Imugen and L2
Diagnostics getting all the national testing for Lyme disease, since they are
the only ones licensed to use this fraudulent method, while sending this free
blood to Corixa Corporation, which looks for new tick borne diseases to patent
for more vaccines and test kits. During
the vaccine trial of Yale’s Lyme vaccine, SmithKline used strain B31, which
does not express much, if any, OspC, the neurotropism-associated antigen. Neurotropism means the ability to
specifically be attracted to nerve tissue.
This left OspA, B and C, the “primary, immunodominant antigens,” out
of the standard for the assessment of LymeRIX. These antibodies, if a person had them and was infected with
Lyme, would not be reported and recorded as a case of infection, as explained
by Plaintiff KM Dickson to the FDA LymeRIX vaccine committee in Bethesda
Maryland, in January, 2001. The
internet link to Plaintiff’s FDA presentation is below, on the FDA’s website
is:
http://www.fda.gov/ohrms/dockets/ac/01/slides/3680s2_11.pdf
This
is scientific fraud and a monopoly on testing and vaccines, apparently
orchestrated by Allen Steere and Yale University. It is organized crime, because this testing is fraudulent, and
misses the vast majority of cases, and yet meanwhile Yale’s Erol Fikrig and
Richard Flavell own a patent for an early and accurate test for Lyme under US
patent number 5,618,533 (application date, Dec 10, 1993). The accuracy of Fikrig’s early and accurate
test for Lyme was 17/18 cases detected, or 94.4% accurate. The accuracy of the Steere fraudulent method
is between 13 and 25%, depending on the spirochete strains used in the testing,
when, in the course of the illness, the test is performed, and the patient’s
own immune competence to borrelial antigens.
Some people can be infected and test positive and have no symptoms; a
few rare people can be infected and have an inflammatory response - which was
what brought this particular borreliosis to the attention of
Mrs. Polly Murray – arthritis; but most often, people are testing
negative and have neurologic Lyme symptoms because borrelia are stealth
infections, and in the bioweapons class of “chronic disablers.”
If
known “chronic disablers” are not detectable on purpose, this is obviously a national
security risk.. Someone could
deliberately release a chronic disabler in a Lyme endemic area, and due to the
fraud of Lyme disease, a serious WMD disease could be spread undetected and
unchecked.
e) If Lyme is not detectable, it is not
treatable, and thus, Lyme is “controversial,” which is a political word
meaning fraud, and which we learned about from the USDOJ lawsuits against
the tobacco companies. The tobacco
companies’ claim was that it was also “subject to opinion” rather than fact,
that nicotine was addictive, while these
tobacco companies were meanwhile allegedly spiking cigarettes with
nicotine. For the 2001 American Lyme
Disease Foundation’s GALA, “a memorial tribute was made to S. Donald Ripley,
former Secretary Emeritus, the Smithsonian Instution, by his daughter,
Rosemanry Ripley, Vice President of corporate Business Development at Philip
Morris Companies. “
f) Soon it will be “controversial,” or, a
“difference of opinion” whether or not all psychotropics are brain damaging,
even though the published science has long proven that they are, and Pfizer
has published treatments for the brain damage caused by antidepressants, which
they simultaneously say does not exist.
Soon it will be controversial whether or not the DSM is an actual
medical document, since the new antipsychotic Abilify is a dopamine agonist,
the complete opposite of 60 years of thought on psychosis, after the accident
of a phenothiazine dye caused the brain anesthesia which resulted the subjects
of this experiment having a “complete disregard for their surroundings.” This meant “improvement” to
psychiatrists. The science of
psychiatric “medicine” would actually be humorous if it were not so brain
damaging, especially to people who already suffer the brain-toxic state of
Neuroborreliosis.
g)
The State of Connecticut does not want to admit to the impact of forced
psychotropic drugging of the children the DCF kidnaps in rendering these
children even more brain damaged and incompetent despite being given the
scientific evidence that this is so by the Plaintiff KM Dickson. Still they wonder why children kill
themselves in DCF’s “care,” when it is already well-known, and scientifically
well-established, that psychotropics increase dementia and agitation. The last child who killed himself in DCF’s
“care,” was diagnosed with bipolar. An
educated guess from the newspaper reports was that he refused to take these
brain-numbing drugs, which was the reason the DCF placed him back in jail
(“refused state services”). Having taken
these brain damaging drugs before, rendered the child more agitated than ever,
since that’s what these drugs do. Since
the child then got sucked backed into the clutches of the diabolical DCF again,
only this time, for their prison, he killed himself. Children cannot take this much abuse. His family said he wanted to be home. Apparently DCF would not allow that. DCF is responsible for homicide in this case, if the above
hypothetical conditions did in fact, occur.
According to the Hartford Courant:
“Children can refuse services at any time and the agency can do little
to stop them.” Plaintiff KM Dickson
wonders why didn’t they leave the boy alone, and if this action is an
indication that DCF is desperate for bodies.
The
DCF’s and DMHAS’ very ignorant and very arrogant “solutions” cause these
problems. If you numb someone’s brain,
there is an equilibrium response adjustment.
Although it might be fine for the DCF to have brain-numbed the children
in their “care,” since numbness of the brain results in less movement and less
neurotransmission, when these children are no longer brain-numbed children,
they are demented adults, who then end up in the adult prisons. In the vast majority of the cases of
incarceration (94%), it is because they later self-medicate their DCF-induced
and other- abuse-related traumas with illegal mind altering substances. The State of Connecticut employees know
absolutely nothing about care or love, and neither does psychiatry. This could be the reason they don’t even
know where to start as regards fixing DCF.
One suggestion would be the removal of all psychiatric terminology from
their vocabularies, since none of it is valid, outside of the terms which
represent scientifically identifiable genetic, organic, cognitive, and
traumatic compromise. As previously
demonstrated in the original complaint, DMHAS and DCF are incompetent to even
the CT competency statute
h)
Yale University had an accurate and early test for Lyme disease in 1991, yet
this was not deployed in their vaccine trial.
In fact, Yale’s Durland Fish conspired to discredit the Lyme Disease
Foundation (LDF) when the Lyme Disease Foundation discovered that people should
be treated with antibiotics upon tick attachment in 1995. He, Durland Fish, conspired with the
NIH’s Edward McSweegan to send the Lyme disease Foundation “a bogus article” to
discredit them, as a result of the LDF’s finding that tick attachment should be
treated, and people should not wait for the rash to show up to treat with
antibiotics. If people are treated upon
tick attachment, as a matter of standard health protocol (which it now is),
then during the fraudulent vaccine trials, it would not be known whether or not
persons who were bitten by ticks had their potential Lyme disease prevented via
the vaccine or the antibiotic.
Therefore these “researchers” withheld this information from the public
for 9 years, allowing untold hundreds of thousands of people to become infected
with this permanent brain infection, when it may have been avoided in the cases
where people knew they were bitten by a tick.
i)
The dimensions and range of death and disability caused by this fraud is
unknown, but must be addressed by the federal court as medical negligence
and likely, homicide, given Yale’s and the other RICO entities’ insistence
that Lyme magically disappears after 30 days of antibiotic treatment and the
disease suddenly becomes psychosomatic, which is according to the plans of this
scientific medical scam, first laid out by Allen Steere in “The Overdiagnosis
of Lyme Disease,” in 1993. In 47% of
the cases of Lou Gerhig’s disease in a Lyme endemic area, the victims had
evidence of exposure to borrelia. (This
is a scientific fact.) Thus, borreliosis
is deadly.
j)
The looser partnership or associated companies in the Lyme disease racket also
includes Kaiser Permanente, Yale, CastleConnolly.com, and the American Lyme
Disease Foundation (Somers, NY), whose chairman was the late David Weld, the
brother of former Massachusetts Governor William Weld. Under the USDOJ racketeering statutes, one
only has to have the appearance of collusion, and not an actual record,
documentary evidence or audio-taped evidence, that these companies sat down
together and said, ”Okay, Here’s how we are going to cheat people out of
treatment for Lyme: First we’ll make it
almost undetectable, by changing the blood test. Then we’ll call them crazy and destroy their credibility. We can get away with it, because central
nervous system Lyme causes physiological depression, which we know from all the
brain damage in Lyme we discovered.
General practice physicians will readily buy into an opportunity to
declare people crazy and that their patients’ complaints not legitimate because
of their innate and acquired arrogance, we teach them at medical school. Besides, Lyme patients are whiney, nobody
wants them, and they never stop being sick once the disease has
progressed. Uncle Sam can pick up the
tab. They’re easy to fool…. Meanwhile,
all the doctors who currently treat Lyme?
We’ll get them for malpractice or something, and take them out of
commission….”
k) William Weld, while Governor of
Massachusetts wanted to “reintroduce prisoners to the joys of busting rocks.”
l)
The Rowlandgate scandal involved Rowland’s Chief of Staff, Peter Ellef, and
Deputy Chief of Staff, Lawrence Alibozek, both of whom were former CIGNA
employees. Rowland’s family owned an
insurance company (presumably, insurance sales).
m)
Mr. Peter Ellef had visions of building a national chain of high-end garden
centers and a national string of prisons and juvenile detention centers in old
stone quarries. Mr. Ellef Junior, a
defendant in the federal indictment against Ellef, Alibozek, Ellef and Tomasso,
owned a landscaping company. Landscaping
companies buy, sell, and use rocks for ornamental stone retaining walls,
borders, driveways, and the like. High-end garden centers also sell rocks. If Mr. Peter Ellef Senior had access to
rocks at a discount, since the consummate ideology of the Welds and the alleged
Rowlandgate criminals appears to be to put prisoners to work (slave labor)
busting rocks, Senior Ellef’s vision, in combination with Mr. John Rowland
bragging about being a national security advisor to Mr. President George W.
Bush, and given the close association of the Bushs and the Welds to Yale, gives
the appearance that all of them are fond of incarceration as a solution to
poverty, and even chronic illness, especially given the racial profiling, which
cannot be denied.
n)
August 1, 2005, the present CT Governor Rell announced the closure of the
scandal- and abuse-laden pediatric prison known as CJTS “managed” by DCF. The new proposal is for more, but smaller
incarceration units, when the real solution is to get rid of the DCF. If a child commits a murder or something
that serious, they belong in protective custody, like a hospital (childhood is an undeniable condition of
incompetence) until the condition which bread the violence is worked out. In the majority of such cases, the child was
treated violently previously. Thus child murderers are usually doubly
mitigated, and triply mitigated, if they are also DCF victims, and again,
quaduply mitigated if they were given psychotropics.
o)
The Lyme disease racketeering crime involved insurance companies’ denial of
care for chronic Lyme, which was also masterminded by Allen Steere when he
defrauded the public by stating that late chronic nervous system Lyme was “some
psychiatric disorder,” and wrote the “bogus article,” “Overdiagnosis [sic] of Lyme disease.” In this “bogus” (a word used by Yale’s Durland Fish in
correspondence with the NIH’s Edward McSwegan) scientific report, Steere also
used the bogus high-passage strain G39/40, to not find Lyme. Not finding Lyme saves insurance companies a
great deal of money, since the relapsing-remitting treatment for this relapsing
borreliosis, Lyme disease, which results in a Multiple Sclerosis-like syndrome
according to Allen Steere (1991 Rheumatology News) costs $12,000 a month,
minimally, as is the wholesale cost of the drug (the discounted price, where
the pharmacy makes no profit). However,
the malpractice treatment of late nervous system Lyme, which is treatment with
psychotropics, increases the dementia. This malpractice is even clearly against
the American Psychiatric Associations’ Guidelines for the treatment of a
delirium, as previously demonstrated with the evidence submitted in the
original complaint CA 05-328T, so it is not a matter of opinion, how to treat
Central Nervous System Lyme.
p)
The (President) Bush’s family (G. H. Walker & Co.) sold an
investment firm to the Weld family (Weld White).
q) A federal judge in Connecticut is John M.
Walker, and who is related to the Walker-Bush family and who is a Yale
graduate. He is the cousin of the first
president Bush, Mr. George H. Walker Bush.
r)
The President Mr. George W. Bush’s uncle Mr. Jonathan Bush was a member of the
Yale Corporation, and his investment firm was associated with the Riggs
Bank. The Riggs bank was fined 25
million dollars by the federal government for money laundering and hiding the
assets of the Chilean Dictator Pinochet, in addition to holding funds for 150
Saudi families. Osama bin Laden is a
Saudi, whose family owns a construction firm, and it is believed that bin
Laden’s own money was contributed to the terrorism executed against the United
States on 9/11/01. Judge Walker and Mr.
Jonathan Bush live in Killingworth Connecticut. Mr. Jonathan Bush owns a company called JBush & Co, and from
their website:
“J.
Bush & Company manages $700 million in assets for high net worth
individuals and families, corporate benefit plans, and foundations. We seek to
build wealth for our clients by investing in high-quality, growth stocks.”
s)
President George W. Bush did not attack Saudi Arabia for funding
terrorism. He instead attacked Iraq,
and we later found out that 1) “the
facts were being fixed around the policy,” that 2) Dr. David Kelly of Great
Britain and British Intelligence laughed at the notion that Iraq could place a
biological warhead on a weapon in 45 minutes since there were no such WMDs in
Iraq, and that 3) Mr. Karl Rove was one of the leakers of the CIA agent whose
husband, Mr. Joseph Wilson, revealed that Iraq was not trying to buy yellow
cake uranium from Niger, rendering all of the hype about the dangerousness of
Iraq to be clearly fraudulent.
t)
On or about 9/13/01, Mr. Paul Wolfowitz suggested lopping off the lower portion
of Iraq to the Bush administration.
Iraq is an oil producing country close to Israel. It has the second largest oil reserves in
the world and had a human rights abusing government, as does Saudi Arabia. Perhaps it would look a little better if we
invaded Iraq for their oil, since Saddam committed genocide against the Kurds,
and the US had earlier sold Iraq some WMDs to be used against Iran. Mycoplasmal infections carried by ticks can
infect livestock, such as cattle, goats and sheep, rendering them sick with
pneumonia, lameness, or unable to produce milk. Mycoplasmal infections are usually resistant to antibiotics
(except macrolides), and treating mycoplasmal infections are said to make these
infections worse by killing off other bacteria, allowing the mycoplasmal
infection to spread, however, it might be likelier that mycoplasmal infections
simply suppress the immune system, allowing the other infections to
spread. This appeared to be the case
with the illnesses caused by Yale’s LymeRIX vaccine, which was of myco origin.
A
Plum Island director at first denied working with mycoplasmas on Plum Island,
but then when shown the evidence that we knew they had, she retracted that
denial. If it is true that the Iraqi
scientist who was given these mycoplasmas to take back to Iraq from Plum Island
was killed by the Israelis (he was run over while changing a tire, much like
the Don C. Wiley case), and these Israelis were from the Mossad (who also are accused by some as being
responsible for the Kennedy assassination by some groups, because of Kennedy’s
stance on Israel having nuclear weapons), one can suspect the reasons Mortimer
Zuckerman attempted to attend the ALDF’s 2001 “GALA” at the Pierre Hotel in New
York City. Zuckerman was also a
candidate for ambassador to Israel.
Israel depends on US Military might for protection from people who
believe Israel has no rights to the Holy Land.
Because of Yale and their fraud on Lyme, which involves Zuckerman (who
owns Newsday and the US News and World Report), one would suspect
that any information Yale and the ALDF have about vector borne disease and
animal diseases, which are also bioweapons and chronic disablers like Lyme
disease, may have been given or sold to Israel as well as Iraq. Plaintiff KM Dickson has long suspected that
the reason George H. W. Bush did not finish off Saddam in 1991, was because of
the bioweapons he knew Iraq had, because we sold them to Iraq to use against
Iran.
Whatever
we have, as “chronic Lyme,” that the people named in the RICO case insist we
don’t need treatment for, may be some accidental release of an animal disease
other than Lyme, carried by ticks. All
one has to do, is study the work of Tully TG
on MedLine.
u)
Mr. Paul Wolfowitz is also a chemist, and chemists understand the principals of
thermodynamics: Energy equals Power, and
in order to be the world police, the United States must have jet fuel. Oil is also essential to the US
auto-motorized economy.
v)
Presidents Bush I and II attended Yale.
w)
Mr. Paul Wolfowitz was an instructor lecturer at Yale. Mr. Lewis Libby, the other CIA Plame
name-leaker, was a student of Mr. Wolfowitz’.
From Wikipedia: “From 1970-72
Wolfowitz taught at Yale
University where one of his students was Lewis Libby who would
become a long-term political associate.”
x)
The State of CT made an “illegal loan,” according to Attorney General Richard
Blumenthal, to
ENRON,
while former Governor Rowland was a member of the Yale Corporation, and should
have known how to invest for the State better.
Yale earned 8 billion dollars during the 10 years of the Lyme scam, from
$2.5 billion to $10.5 billion, for the Yale Corporation. The illegal loan was for 220 million
dollars, but to the best of the Plaintiff KM Dickson’s knowledge, AG Richard
Blumenthal was able to recover a significant percent of those losses. Connecticut could have invested in
Equatorial Guinea or the Sudan, for example, instead, and had a significant
stake in oil and timber assets globally, as the Yale Corporation now does.
y) Mr. William Weld’s brother Mr. David Weld
was chairman of the American Lyme disease Foundation and which is the central
RICO entity involved in the fraud in “Lyme disease.”
z)
Hartford is known as the insurance capital of the world. Since Kaiser-Permanente knows Lyme is a
permanent brain infection, requiring repeat treatment with ceftriaxone, one can
assume other insurance companies do as well.
One of the founders of the American Lyme Disease Foundation (1990), the
former president of New York Medical College, Mr. John J. Connolly, now owns
CastleConnolly.com, which publishes an internal HMO industry newsletter. In 1989, the Infectious Diseases Society of
America published that Lyme is a permanent nervous system infection, like other
known spirochetal infections, and the treatment endpoint was not known. New York Medical College was failing
financially, and Kaiser is now there training General Practitioners. The New York Office of Professional Medical
Conduct, had until recently gotten their experts on Lyme from this Insurance
Industry source - Kaiser at New York Medical College - to declare the perjury
that Lyme is cured with 30 days of antibiotics, and that the CDC’s case
definition, which is Allen Steere’s fraudulent blood test definition of Lyme
disease, is the only kind of Lyme disease there is, in an attempt to remove the
medical licenses of Lyme treating specialists.
aa)
Yale’s Ms. Janine Evans, of Yale, is one of the entities involved in the fraud
of Lyme disease, and was or is the Yale Physicians Group’s managed care
liaison. Yale is often sent patient
records by insurance companies for second opinions on whether or not a person
should be treated for Lyme. It even
occurs that people who have the false positive criteria of Allen Steere are
denied treatment, since Yale can say this is post-Lyme, since it is all IgG
antibodies (late occurring) and not active, treatable Lyme. Part of Steere’s fraud was to leave out the
vast majority of IgM antibodies in the standard for Lyme, although he earlier
included them as evidence of active infection, and specifically reported that
this was his reasoning, in 1986, in the earlier testing scheme for Lyme
disease.
bb)
It appears former Governor John G. Rowland benefited from the ENRON transaction
by being made the president of the Republican Governors’ Association.
cc)
Vice President Dick Cheney is a former CEO of Halliburton, whose industries
include the dismantling of nuclear power plants and oil recovery.
dd)
The specific documentation of this scientific fraud in Lyme disease is in the
office of the US Attorney Kevin O’Connor, in New Haven, CT. Mr. Kevin O’Connor had to recuse himself
from the federal investigation of the crimes in the Connecticut Governor’s
(Rowland) office, because Mr. O’Connor’s wife worked in Rowland’s legal office
apparently while the crimes took place.
The crimes involve the CT Department of Children and Families’ (DCF’s)
policies of abuse rather than assistance to families. What the DCF calls “services,” is actually organized trafficking
in humans (regarded as “removals”), for the 1) federal tax dollars brought into
the State of CT, 2) for the criminal entity known as “TREA,” a
limited liability corporation, 3) into
the salaries of DCF “workers” and corrections officers, 4) for foster care parents, many of whom
provide foster care just for the money.
Mr. O’Connor, to the Plaintiff KM Dickson’s knowledge, was a former
State of Connecticut New Britain prosecutor, and has a record for the most
death penalty convictions in Connecticut.
The Assistant US Attorney Nora Dannehy and Deputy US Attorney John H.
Durham likely experience discomfort working under Mr. Kevin O’Connor and around
Mr. Christopher Morano, the Chief State’s Attorney, and in regards to all of
the sitting judges who were appointed by Mr. John G. Rowland. Mr. Morano was asked to stay out of the way
of the investigation of the corruption in Mr. Rowland’s office.
Thus,
due to the total corruption in the State of Connecticut, which is to include
some of the people in the District of Connecticut’s US Attorney’s office, the
Department of Justice and their relationship to Yale University, and via the
presence of various Yale-Bush-Weld banks or investment firms and insurance
companies, this complaint must be prosecuted from another jurisdiction of the
federal government. Mr. O’Connor was
quoted in one of the online newspapers that, “When we worry about Nora, it is
because she is working too hard.”
Plaintiffs
et al request assistance from the federal court in Rhode Island to include
representation by counsel appointed by the federal court. That counsel should have experience
prosecuting organized crime. The
indigency of the Plaintiffs is inherent, since the victims of “Rowlandgate” are
fully exhausted of personal resources, after having dealt with the corrupt DCF
and corrupt judicial system. The
primary purpose of this action is to arrest the crimes committed by employees
of the State of Connecticut, and their paid “experts,” against unsuspecting,
innocent, private persons.
The
Plaintiff KM Dickson called the DCF and complained about Mr. John G. Rowland
exposing his children to lying, cheating, and stealing, and thus corrupting
them, since in addition to lying to the press and the public about who paid for
what, Mr. Rowland blamed his son for the robbery of a CT state warehouse where
they helped themselves to camping equipment, but to the plaintiff KM Dickson’s
knowledge, Mr. Rowland’s children were not removed. Obviously it was a valid complaint of abuse and neglect. Mr. Rowland was removed instead.
The
Plaintiff KM Dickson, as a former employee and analytical chemist with Pfizer,
has nearly expired all savings and 401(K) funds due to the harassment by the
State of Connecticut and their hired Yale “experts.” The little that remains in Plaintiff KM Dickson’s 401 (K) from
Pfizer must be used in the case that CIGNA drops her long term disability
coverage again, which they obviously threatened to do in 2004, which resulted
in the alleged “harassing communications and threatening” response by the
Plaintiff KM Dickson. The Plaintiff KM
Dickson had told CIGNA basically that if they were looking for truly crazy people to drop the long term
disability coverage for, they should look no further than the CT DCF. Lyme is a brain disease and Autism is a
brain order.
Plaintiff
KM Dickson had testified at the FDA meeting in Bethesda regarding the fraudulent
Yale Lyme in January 2001, exposing the entire fraud of the testing for
Lyme. CIGNA continues to harass the
Plaintiff Dickson, as is demonstrated in the alleged “harassing communications
and threatening” of AAG Jessica Gauvin.
The Plaintiff Dicksons, Kathleen, Lara, Diane and David, cannot get
adequate care for Lyme disease, due to the Lyme disease racketeering condition
and the DCF racketeering condition.
The Lyme disease racketeering complaint filed with the US Attorney’s
office and copied to CT Attorney General Richard Blumenthal, AAG Jessica Gauvin
asserted for the DCF “court,” was evidence of Plaintiff KM Dickson’s
insanity.
Science
does not equal insanity, unless one is a psychiatrist, as is the case with
DCF’s, Yale’s and DMHAS’ “experts,” Kenneth Marcus and Patricia Leebens, or
unless one is a social worker like DCF’s Maureen Auger, or unless one is a DCF
attorney like the fired New Haven Principal Attorney, Sarah Gibson, or an
Assistant Attorney General for the DCF like Jessica Gauvin, rendering all these
opinions, and the classes of people they represent to be utter nonsense:
Psychiatrist, “social worker,” or lawyer for the State of Connecticut or Yale.
That
the Plaintiff KM Dickson was declared insane was the State of Connecticut’s and
Yale’s only recourse, since the science of the scientific fraud and
racketeering in Lyme, and the malpractice treatment of Lyme dementia described
in the perjury by James Phillips and Kenneth Marcus, (Yale and DMHAS) is
published and is beyond dispute. AAG
Jessica Gauvin brought no “expert” to prove that the Plaintiff KM Dickson’s
assertions that organize crime in “insurance medicine,” “bogus articles,” and
the scientific fraud in “Lyme disease,” which became “LymeRIX disease,” were not scientifically valid. In fact, no one has yet, at all.
Plaintiff
KM Dickson was an analytical methods development chemist for a pharmaceutical
company, which seems to be the primary point of irritation for all participants
in Plaintiff Dickson’s various fraudulent prosecutions, yet that this is
irritating to others is beyond Plaintiff’s understanding or ability to
analyze. Plaintiff KM Dickson has high
functioning autism, which is the furthest thing from a brain “disorder” that
there is. All one has to do, is read
the DCF’s “records” to know what a real brain disorder is. One would suspect that since there is an
identifiable difference in brain morphology in autistic people (the right side,
or visual side, is bigger), and autistic people never lie, one would expect the
brain morphology of these outrageous liars, all of the DCF staff, would also
show a difference, however the DCF hasn’t asked for any mental health
help. People with antisocial
personality disorder (are “sociopaths”) are beyond fixing, and this is a
general consensus among psychiatrists.
From
MentalHealth.com:
Antisocial Personality Disorder
American
Description Diagnostic Criteria
There
is a pervasive pattern of disregard for and violation of the rights of others
occurring since age 15 years, as indicated by three (or more) of the following:
failure
to conform to social norms with respect to lawful behaviors as indicated by
repeatedly performing acts that are grounds for arrest
deceitfulness,
as indicated by repeated lying, use of aliases, or conning others for personal
profit or pleasure
impulsivity
or failure to plan ahead
irritability
and aggressiveness, as indicated by repeated physical fights or assaults
reckless
disregard for safety of self or others
consistent
irresponsibility, as indicated by repeated failure to sustain consistent work
behavior or honor financial obligations
lack
of remorse, as indicated by being indifferent to or rationalizing having hurt,
mistreated, or stolen from another
The
individual is at least age 18 years.
There
is evidence of Conduct Disorder with
onset before age 15 years.
The
occurrence of antisocial behavior is not exclusively during the course of
Schizophrenia or a Manic Episode.
Differential
Diagnosis
Substance-Related
Disorder; Schizophrenia; Manic Episode; Narcissistic Personality Disorder;
Histrionic Personality Disorder; Borderline Personality Disorders; Paranoid
Personality Disorder; Adult Antisocial Behavior.
If
CT DMHAS would concentrate 100% of their failed mental health system
“treatments” exclusively on DCF staff, both abominable agencies, DCF and DMHAS,
would cancel out, and would no longer be a threat to the rest of the residents
of the State of Connecticut who are “normal,” based upon the sole virtue of not
being a DCF employee.
=========
_____________________
Plaintiffs
Kathleen
M. Dickson, et al
23
Garden Street
Pawcatuck,
CT 06379
COMPLAINT
Kathleen
M. Dickson, and
on
behalf of Lara E. Dickson,
Diane
M. Dickson, David D. Dickson, et al,
and
on behalf of all Families and
Children
of the State of Connecticut
In
the cause of a class action: CA
05- 328 T
v. STATE OF CONNECTICUT US DISTRICT COURT
1
Exchange Terrace
Providence,
Rhode Island 02903
August
22, 2005
MOTION
TO AMEND COMPLAINT
Contents:
CORRECTIONS
– page 1
SUMMARY
OF COMPLAINTS, AMENDMENTS AND MOTIONS – page 2
CASES
– page 3
THE
SCIENCE - page 11
THE
NON-SCIENCE - page 17
THE
NOV 20, 2003 DATABINDERS –page 19
STATUS –page 23
ABUSE
AS POLICY- THE 10-FOLD INCREASES- page 25
THE
REALITY OF FORENSIC PSYCHIATRY- page 28
CORRECTIONS: To Amendment and motion dated August 3, 2005. Plaintiff Dickson was mistaken about Mr.
Kevin O’Connor, the present US Attorney for the District of CT, as having been
a former New Britain State prosecutor, having a reputation for the highest
number of death penalty convictions in the history of the State.
The
Plaintiff Dickson should have known better than to assume this statement had
any legitimacy, since a prison guard or judicial martial informed Plaintiff of
this untrue history as we drove into the parking lot of the New Britain
courthouse, during one the Plaintiff’s many trips to courthouses to listen to
even more nonsense, false criminal charges, and perjury.
Plaintiff
KMDickson apologizes to Mr. O’Connor for this gross lapse in
fact-checking. Plaintiff Dickson would
still like to be informed of the history of Mr. O’Connor’s placement as US
Attorney in Connecticut, since one of the secretaries in Mr. O’Connor’s New
Haven office also informed Plaintiff Dickson that Mr, O’Connor’s wife worked on
former Governor John Rowland’s re-election campaign. We should all know better than to believe anything any state and
federal employees say, and especially the Plaintiff Dickson should know this.
SUMMARY
The
original complaint Docket Number 5 328T filed in Rhode Island Federal Court was
a summary of examples of incompetence and abuse of CT residents illegitimately
caught up in “the system,” who essentially needed assistance from the
State. They ended up being victims of
the crimes of CT State employees, and then had their lives and their families
lives ruined under various federal civil rights violations, violations of the
Americans with Disabilities Act, First Amendment, Fifth Amendment, and the
failure of the State’s various commissions to understand what duties they are
commissioned to perform. The only
service the State evidently provides is abuse or neglect. This was substantiated in the CT VOICES FOR
CHILDREN report regarding the CT Department of Children and Families (DCF),
entered as Exhibit F, Docket 5-328 T.
The
first amendment to this complaint, dated August 3, 2005, contains a motion for
appointment of counsel who is competent to be a US Attorney, due to the
racketeering and organized crime surrounding State agencies and as regards the
scientific fraud of “Lyme disease.”
Plaintiff retracts the statement made about Kevin O’Connor in section of
this document, in item, “dd” which states:
“Mr. O’Connor, to the Plaintiff KM Dickson’s knowledge, was a former
State of Connecticut New Britain prosecutor, and has a record for the most
death penalty convictions in Connecticut.”
AMENDED
COMPLAINT:
This
current Plaintiffs motion to amend the class action against the State of Connecticut
is to now include all people abused and neglected by the Department of Mental
Health and Addiction Services, the Department of Mental Retardation, and the CT
Division of Criminal Justice - persons who have documented mental impairments,
and as represented by the following cases of cognitive or mental disability:
mental retardation, Alzheimer’s and Parkinson’s and other dementias, the
neuropsychiatric disease Multiple Sclerosis, and the brain damage incurred by
psychotropics.
The
CT competency statute 54-56D assumes the State DMHAS staff is competent to
brain matters. DMHAS is not competent,
as previously described, and as will be demonstrated below in this second
amendment to the class action complaint 05-328 T.
Other
statutes violated include the virtual declaration of non-human status for CT’s
alleged defendant John M, which is clearly a violation of every known USA civil
rights statute, and UN’s international human right declarations, as previously
mentioned (Deprivation of Rights, Color of Law, Conspiracy to Deprive of
Rights, United States Civil Code: Titles 18, Secs 241, 242, 245, Americans With
Disabilities Act.)
CASE
EXAMPLES:
1) John M. is a young adult with mental
retardation, yet he has been housed in a CT prison since February 2005 for 2
counts of sexual assault 4th degree and risk of injury to a
minor.. His family has been denied the
right to see the warrant and specific charges against him, because they involve
a minor boy. John M. has been
determined competent to stand trial, although his family states that he was
given a competency evaluation, which the family has not seen, and their request
to see it has not been granted by the State.
The family was only told verbally that John M. is competent to stand
trial. John M. has been kept in prison
these last 6 months.
The
family states John M. was raped in prison, and that it took almost a month for
the prison doctor to investigate. John
M. was raped in one prison, and was examined in another. Naturally, the guards denied it happened.
A
letter written by Annette Rose, DMR Case Manager, which is EXHIBIT KK, dated
October 22. 2004, states:
To Whom It May Concern:
Please be advised that John M., date
of birth 11-07-80, was determined eligible for Department of Mental Retardation
Services by H. Steven Zuckerman, PhD.,
Supervising Psychologist 2.
According to Elibigibilty Determination document signed by Mr. Zuckerman
and dated 08-14-98, John M. “falls withing the Mild range of Mental
Retardation.” This document can be
found in Mr. M.’s Department of Mental Retardation case record.
In
the letter on behalf of John M. was written by Brian O’Rourke and Ellen Gilman
of the Office of protection and Advocacy for Persons with Disabilities,
Hartford, CT, [EXHIBIT 5-328T LL], they state:
“Mr.
M’s habilitation cannot be addressed in a correctional facility. His cognitive limitations combined with a
history of behavior adjustment difficulties increases the serious risk prison
incarceration posess to his personal safety and psychological well-being. As you are aware, prisons can be especially
dangerous environments for individuals being held on (or convicted of) charges
of the nature he is facing.
Mr.
M.’s past psychological reports cite significant language processing
deficits. His language processing
becomes further compromised when John becomes anxious. This factor does interfere with his ability
to cope with his current situation. Mr.
M’s mild retardation, in addition to these deficits places him at a serious
disadvantage as he attempts to work with his attorney in defense of these
charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple
conversation about his present circumstances.
Mr.
M’s history shows that he needs significant support to reinforce his awareness
and acquisition of appropriate social skills.
The Department of Mental Retardation should have reevaluated Mr. M’s
service and support needs over a year ago, when allegations of criminal conduct
were first made. The development and
implementation of an individualized service plan needed to occur at that time.
As a
resolution to this Programmatic Aministrative Review request, we ask that the
DMR immediately identify an emergency (short term), community based residential
placement for Mr. M., and that Mr. M.’s attorney, Mr. John Coccio be informed
of this option. Once in placement, we
request that the DMR complete any relevant assessments and develop a
well-designed community-based support propgram to meet Mr. M’s long term
needs.”
This
letter was written April 11, 2005, and is a comprehensive and adequate attempt
to have a rational grasp of the needs and the urgency that Mr. M’s be treated
as a person with mental retardation.
Again, they state:
Mr. M’s
mild retardation, in addition to these deficits places him at a serious
disadvantage as he attempts to work with his attorney in defense of these
charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple
conversation about his present circumstances.
This
would appear to resoundingly dispute any legal competency of Mr. M. that the State’s attorney’s office has
arbitrarily - and without producing the
documentation of - asserts exists.
Further follow up with the Department of Mental Retardation suggests
strongly that there is no alternative housing for John M., yet the State also
claims to have 16,000 residents in CT with mental retardation and that 1% of the population has mental
retardation (IQ of 70 or below). The website of the DMR states that:
“Unlike
other agencies, its supports and services (with the exception of Birth to
Three), are not an entitlement for people with mental retardation and the
majority of its services are provided by private non-profit organizations in
local communities.
This
gives the appearance that like the DCF, the DMR provides no real services,
other than the pay checks of the employees.
There is no housing available for these people, when one would think
such would be a priority, since one thing there is no denying exists is mental
retardation. Autistic people belong to this department.
Autism
is an epidemic, yet instead of planning for this epidemic or Lyme disease, and
seeking appropriate federal funding, the State planned for an increase in
prison cells, as previously mentioned.
In
an email to Ms. Ellen Gilmartin, Gino DeMaio, Forensic Coordinator, State of CT
Department of Mental Retardation, states that “John has asked DMR to not attend
these hearings and has not wanted his case manager to be involved.” [EXHIBIT
MM]
The
family who had been the guardians of John M. state that no such conversation
took place. They state that John cannot
even make change, and once bought a pack of gum from a child for 5 dollars, not
knowing that a pack of gum costs nowhere near 5 dollars.
H.
Steven Zuckerman, PhD. Of DMR on September 14, 1998, [EXHIBIT NN] states that
as regards John M.,
“Based on the information presented to me,
this individual does meet the definition of mental retardation as defined in
CGS Section 1-1g, and is therefore eligible for Department of Mental
Retardation services. This individual
falls within the Mild Range of Mental Retardation.”
Listed
as requirements for this condition are under Connecticut General Statutes 1-1G.
“For
the purposes of sections 4a-60,. 17a-274, 17a-281, 38a-816, 45a-668, 45a-684
inclusive, and sections 46a-51, mental retardation means a significantly
subaverage general level of functioning existing concurrently with deficits in
adaptive behavior and manifested during the development period.”
The
family of John M. state that the incident for which he is in jail took
allegedly took place on November 1, 2003, yet it wasn’t until the summer of
2004, when John M. and his cousin tried to attain a minor position either in
the local fire department, or be volunteers or trainees, did anyone take any
legal action. John M. went to jail in
February 2005 and has been there since, without his family being allowed to
know exactly what he is being charged with, who performed the competency
evaluation, or any of the important details of the case. The family states that they don’t even know
how the case was transferred from Norwich, where the family lives to the New
London courthouse.
There
was apparently another nephew involved, and the State prosecutor combined cases
with no explanation as to how all these events took place.
Years
before, apparently, the retarded boy’s uncle proposed citizen oversight of the
police. John M. was apparently involved
in an incident at Walmart where a child was in the men’s room and could not get
his pants down to go to the bathroom, and the parent was nowhere around, so
John M. helped. Walmart hires retarded
people and are familiar with the difficulties of retarded people, and of course
were willing to let the whole event drop, to the best of this Plaintiff’s
knowledge. There is little
documentation of events available, and that would be because the public does
not know what they are up against, if they become the arbitrary victims of
crazy people who know how to use the DCF and the police to their
advantage. Hopefully this complaint
will alert the residents of Connecticut to the hazards of being a Connecticut
residents, before the adequate resolution of these crimes, as described as
relief and damages in the original complaint Docket 5- 328 T, dated July 27,
2005.
One
can see how this Walmart event would get mixed up, and that it is impossible to
tell what happened if John is mentally retarded, and as is known of him:
“Mr.
M.’s past psychological reports cite significant language processing
deficits. His language processing
becomes further compromised when John becomes anxious. This factor does interfere with his ability
to cope with his current situation. Mr.
M’s mild retardation, in addition to these deficits places him at a serious
disadvantage as he attempts to work with his attorney in defense of these
charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple
conversation about his present circumstances.”
It
was after this Walmart incident that John M. uncle proposed citizen oversight
of the police. One can see that what we
have is in reality, two sets of parents of young children, only one looks a lot
older. Both are equally concerned about their children.
It
appears as though there is a tremendous tug-of-war over bodies, between the
Department of Criminal Justice, the Department of Children and Families, the
Department of Mental Health and Addiction Services, but oddly, not the
Department of Mental Retardation. Each
has their own set of statutes, and the only mediator, the Department of
Protection and Advocacy for Persons with Disabilities, appears to be
powerless.
There
are numerous free assistance agencies in the State of Connecticut but they
don’t actually do anything for anyone, even if one is lucky enough to get one
of them to call back. This is not only
the Plaintiff Dickson’s experience, but was the experience of every single
person who was dragged through the Connecticut Valley Hospital as
“incompetent.” Not too many of the
“criminals” were incompetent, if they knew how to look for help. The help was incompetent, and one wonders of
these non-profits take federal funding to provide no service. It did not take long before we “prisoners”
we all joking about what a waste of advertising and publishing these alleged
non-profit legal help groups expend, and especially, about our coins for the
pay phone, which were wasted. It is
well known that a CT public defender is called a “public pretender,” and the
only people who can emerge from this potentially permanent trap are those who
have family support on the outside.
Frequently
enough to be a recognizable phenomenon, as in the evidence of many of the women
in prison, whoever goes to jail, in family disputes, is a matter of who called
the police first. Then of course, once
one person has a record, those persons are always assumed to be guilty in
subsequent disputes, which involve altercations and then the police. One prison guard told the Plaintiff that
people routinely place their relatives in prisons just to get rid of them
because they are a nuisance. Plaintiff
Dickson only heard abundant evidence to support that this is true from
listening to a vast number of the inmates at York.
It
appears that just as it is well-known that the DCF can be used as a weapon, so
to can the police be used as a weapon.
Hearsay is plenty good enough for DCF to fraudulently take anyone’s
children away. No one has ever been
prosecuted for false allegations of child abuse or neglect in Connecticut. The DMHAS employees also refer to CT as a
“Meat Grinder.” They have seen this
abuse enough times. Lower level DMHAS
employees are remarkably more sane than their supervisors and more sane than
the DMHAS “doctors.” They are more sane
than corrections officers, police, and DCF “social workers,” to their credit. These mental health workers and nurses at the
CVH “competency restoration unit” should all get the salaries of the police and
corrections officer and DCF workers, while all of the latter 3 groups should be
fired. DMHAS mental health workers and
nurses are in a class unto themselves in the state of Connecticut (at the
present time).
2) Marsha Hoggan, 55, is an Alzheimer’s patient
who also has Parkinson’s disease.
(These two disorders of brain damage also occur in Lyme borreliosis.)
Ms. Hoggan is accused of stuffing tissues in her roommate’s mouth and cotton
balls in her nose, where they lived together in a nursing home. The roommate’s name was Eleanor
Mazzarella. Mazzarella died in March
2005 from unrelated causes and was 74 at the time of her death. Ms. Hoggan has claimed she did not know what
crime she committed and is now in the York Women’s prison where she is
mistreated and is treated to more medical and nutritional neglect, since the
nutrition in the prison is grossly inadequate.
The inmates in the mental health wing cannot buy vitamins or
coffee. Stimulants are known to be
helpful for people with, dementia, cognitive decline, and the associated
depression.
None
of the inmates at York get adequate exercise, since the only two exercise bikes
in the prison are broken and there is no other recreational equipment except
balls, basketball hoops, and sometimes a volleyball net. The guards are forever looking for a reason
for the prisoners not to go to the gym or to the library. Prisoners are not allowed to jog on the
grass. Prisoners can only go to the
library, once a week and only approximately 5 out of 20 get to go, they are
picked randomly, and some never get to go to the library. Some of the ward TVs are broken, and some
have no reading materials. Thus, there
is no intellectual stimulation whatsoever for a great many inmates. These combined conditions contribute to
dementia. In the prison there is no
education about nutrition, no nutrition, no education about diet and exercise,
and no exercise, when clearly all these
are needed to restore many of these women in the prison.
Most
of them are drug addicts and in poor health.
A great majority of these prisoners go over to “mental health” to get
some kind of drug to sleep their sentences away, but this increases the
illegal-drug induced dementia.
Thus,
no prisoners will improve in any way, under
“corrections.” There is no
incentive on the part of corrections officers, for the prisoners to not be
prisoners, because of all the overtime pay these guards get. Therefore the cycle of abuse is perpetuated
by the guards and their union.
Prisoners return to prison after having been arrested again for
self-medicating too often. How prisons
are managed does not make any sense for dealing with human beings in any way,
with the exception of mass murderers, who are rare.
The
most adverse treatment for older women in cognitive decline are central nervous
system depressants such as antipsychotics and this announcement was made in
2005 by the National Institute of Mental Health. A trial of Seroquel for agitation in dementia was halted because
it was observed that this treatment accelerated the dementia. The monograph for risperidone states that
this medication is associated with greater extrapyramidal effects
(extrapyramidal brain damage) in older women, especially.
It
would appear to the casual observer that the liability in this Hoggan case was
more the nursing home’s, rather than the incompetent patient’s.
3) Leslie Andino a 23 year old woman with multiple
sclerosis, dementia and depression - which sounds very much misdiagnosed Lyme
Neuroborreliosis - was arrested and charged with arson in a nursing home fire
that killed 16 other residents in Connecticut in May 2003. After several periods of “treatment” to
restore competency for trial for a crime she never should have been charged
with in the first place, she returned to the courthouse in January 2005,
“heavily sedated,” to learn she would be committed to the Whiting Psychiatric
Prison.
Heavy
sedation is malpractice for a neuropsychiatric disease, and likely contributed
to her increasing dementia. The
American Psychiatric Associations Guidelines on the treatment of a delirium
state that: “Medications for psychiatric disorders can be both the cause of
delirium and exacerbate or contribute to delirium from other causes.”
This
Andino case should be investigated by a competent independent federal health
official and expert, which would obviously not be one from Connecticut.
It
would appear to the casual observer that the liability was more the nursing
home’s, rather than the incompetent patient’s.
THE
SCIENCE
Conditions
associated with Multiple Sclerosis, according to the United States National
Institute of Health are:
“Symptoms Return to top
weakness of one or more
extremities
paralysis of one or
more extremities
tremor of one or more
extremities
muscle spasticity
(uncontrollable spasm of muscle groups)
movement, dysfunctional
- slowly progressive; beginning in the legs
numbness or abnormal
sensation in any area
extremity pain
loss of vision --
usually affects one eye at a time
uncontrollable rapid eye movements
eye symptoms worsen on
movement of the eyes
decreased ability to control
small or intricate movements
muscle spasms
(especially in the legs)
urinary hesitancy,
difficult to begin urinating
strong urge to urinate
(urinary urgency)
frequent need to urinate
(urinary frequency)
incontinence (leakage
of urine, loss of control over urination)
decreased memory
decreased spontaneity
decreased judgment
loss of ability to think
abstractly
loss of ability to generalize
decreased attention span
difficulty speaking or
understanding speech
fatigue, tired easily
Additional symptoms that may be
associated with this disease:
constipation
positive Babinski's reflex
Note: Symptoms may vary with each
attack. They may last days to months, then reduce or disappear, then recur
periodically. With each recurrence, the symptoms are different as new areas are
affected. Fever can trigger or worsen attacks, as can hot baths, sun exposure,
and stress.”
Symptoms associated with Dementia,
from NIH MedLine Plus include:
“Disorders that contribute to
confusion should also be treated. These include heart failure, decreased oxygen (hypoxia ), thyroid disorders, anemia, nutritional disorders, infections, and
psychiatric conditions such as depression. Correction of co-existing medical
and psychiatric disorders often greatly improves mental functioning.”
Symptoms associated with Neurologic
Lyme disease, as listed by the National Institute of Neurological Disorders and
Stroke:
“Neurological
complications most often occur in the second stage of Lyme disease, with
numbness, pain, weakness, Bell's palsy (paralysis of the facial muscles),
visual disturbances, and meningitis symptoms such as fever, stiff neck, and
severe headache. Other problems, which may not appear until weeks, months, or
years after a tick bite, include decreased concentration, irritability, memory
and sleep disorders, and nerve damage in the arms and legs.”
The hypoxic state of Lyme and
multiple sclerosis is often assessed with brain SPECT scanning, and often shows
a deficit, and which is known to be associated with an organic delirium. According to Allen Steere:
“Lyme
disease may affect the central nervous system causing organic brain disease or
syndromes suggestive of demyelination.”
PubMed ID 2742551
The same symptoms as those in
neurologic Lyme disease occur in Multiple Sclerosis and Alzheimer’s disease. In
fact, in a recent report:
“The cause, or causes, of the
vast majority of Alzheimer's disease cases are unknown. A number of
contributing factors have been postulated, including infection. It has long
been known that the spirochete Treponema pallidum, which is the infective agent
for syphilis, can in its late stages cause dementia, chronic inflammation,
cortical atrophy and amyloid deposition. Spirochetes of unidentified types and
strains have previously been observed in the blood, CSF and brain of 14 AD
patients tested and absent in 13 controls. In three of these AD cases
spirochetes were grown in a medium selective for Borrelia burgdorferi.” [Pubmed ID 15665404 Miklossy, et al]
The proper term for the entire scope of disease manifestations is “Lyme
borreliosis.” “Lyme disease” refers to
72% of the late Lyme arthritis cases only, and only as compared to this Lyme
arthritis case blood to the high passage strain G39/40. “Lyme Disease” is thus an imaginary entity
as previously described.
The CDC and NIH expressed a request
not to use high passage strains of borrelia and not to use strain G39/40 to use
for the determination of Lyme disease because it did not express enough of an
antigen of diagnostic value at the 1994, Dearborn Michigan, CDC meeting on
serodiagnosis (blood tests) of Lyme, yet this is the strain and conditions of
the strain which now represents the CDC’s IgG serodiagnostic standard. CDC and the NIH have not responded adequately
to Plaintiff’s complaint that this is deliberate scientific fraud. To the Plaintiff’s knowledge, the FBI is
still investigating this complaint.
Lyme borreliosis has been associated
with the two haplotypes or genetic markers that occur in multiple sclerosis,
narcolepsy and lupus (HLA-DQB1*0602), but the public is not allowed to know
this, because this form of Lyme is also “seronegative.” “Seronegative” really
means the testing for Lyme is fraudulent, and this is discussed in greater
detail in 3:05 CV 91 (CFD), as regards the racketeering-influenced and corrupt
organization’s control of what we are told about “Lyme disease.” The second haplotype discovery was made by
Mark Klempner of Boston University and that haplotype is HLA-DQB1*0602. The State of CT is in possession of the July
2001 audio-taped Mark Klempner conference, during which this scientific data
about the susceptibility to chronic Neurologic Lyme/MS and a copy is the US
Attorney’s office in New Haven, CT.
There are numerous and conflicting
protocols for the treatment of Lyme borreliosis. The Centers for Disease
Control supports the fraudulent one developed by the RICO entities, the
American Lyme Disease Foundation and Yale University, even though the CDC knows
this protocol is not supported in the literature with the scientific
facts. The elements of these crimes are
described in greater detail previously in 05-328 T, District of Rhode Island
and in 3:05-CV-91 (CFD), District of Connecticut.
It is not known what other
“treatments” Ms. Andino were given by Connecticut Valley “Hospital,” but given
the Plaintiff’s experience with CT DMHAS, Plaintiff is seriously concerned
about how DMHAS treats any of their victims.
DMHAS perjured themselves in the false criminal case against Plaintiff
KM Dickson does not have Lyme disease, and that Lyme is not a brain
disease.
James Phillips, MD was given the
scientific substantiation that Lyme is a neuropsychiatric disease. Plaintiff KM
Dickson’s website “The Lyme Disease Dilemma,” was given to James Phillips, MD,
in full hard copy in November 2000.
The Lyme Disease Dilemma website has
not been touched (not been modified at all) since November 2000, and
ActionLyme.50megs.com has not been touched (not been modified at all) since
November 2001. The URLs for these
websites are:
http://www.geocities.com/kmdickson0308/lyme-dilemma.html and
A sampling of their content:
“NEWS-
The new information that confirms the pathophysiology of MS and Lyme has not
been published, yet this data was collected during the 1997-2000 NIH Chronic
Lyme Disease treatment trial by Tufts: The high incidence of the presence
of HLA-DQB1*0602 on Chronic Lyme patients. To quote Dr. Klemper:
"It turns out that if you look at the first 51 patients with post-
treatment chronic Lyme disease, the patient population that participated in our
study, there was a very high incidence of DQB0602 with an odds ratio of
770%. So it may well be that exposure to THAT organism with THAT
background of HLA haplotype may lead you to develop chronic symptoms.
That is a hypothesis that needs to be tested. It would obviously lead to
an entirely new form and approach to therapy."
The non-reporting of objective data over the reporting of subjective, invalid
data (the assessment tools FIQ and SF-36), calls into question integrity in
reporting scientific data, and the validity of further and previous conclusions
from such analysts. The FIQ was never validated for Lyme disease.
The SF-36 is not to be used in cases of cognitive impairment.
The
record of this presentation by Mark Klempner is EXHIBIT OO. The rebuttal to Klempner’s “study” on the treatment
of chronic Lyme disease is Exhibit PP, and can be found online at
http://www.ilads.org/files/position2.pdf
Plaintiff
Dickson was the original author of this rebuttal, but at that earlier time,
looked more like a point-by-point rebuttal to the validity of 1) Klempner’s
inclusion and exclusion criteria; the validity of the CDC’s blood testing
standard for Lyme disease, 2) a refutation that the FIQ had been validated (the
validation showed a difference between Lyme and Fibromyalgia, so by definition,
the FIQ was not valid to assess Lyme patients), 3) Mark Klempner most certainly
is aware of the various markers of disease such as matrix-metalloproteinases
(MMP) in the spinal fluid of Lyme borreliosis patients, and should have been
looking for these and other known objective markers of disease since Klempner
discovered and reported this MMPs analysis in Neuroborreliosis patients, 4) Mark Klempner published that
intracellularity of the Lyme spirochete and the availability of host cells in
other ways provided protection for the Lyme spirochetes from being killed by
ceftriaxone, 5) Mark Klempner discovered the reason people who are the most ill
with Lyme disease are seronegative:
They don’t have the hypersensitivity reaction of people who have the
genetic predisposition to Lyme arthritis (hypersensitivity or allergy reaction)
discovered by Allen Steere (and was the basis of the class action lawsuits
against SmithKline, and about which Attorney Steve Sheller had to say of the
CDC: “The CDC is a disgrace. It is a corrupt organization. The drug companies
have them on their payroll.”), because they tend to have these
immune-incompetent haplotypes associated with persistent central nervous system
infections, and 6) Mark Klempner refused to tell the Plaintiff KM Dickson which
primers he used to determine that among his 2000 patients, none had a positive
Borrelia burgdorferi positive DNA analysis of their spinal fluid. 7) Lyme neuroborreliosis is usually an aseptic
meningitis, so looking for increased cells, which was what Mark Klempner did,
in the spinal fluid of these patients was a waste of taxpayers’ money. 8) Some of the known and published markers
of disease process (the reason there are clinical signs of illness) are
described in the RI Tick Borne Diseases Management Plan, entered as Exhibit Q
in the original complaint dated July 27, 2005.
Therefore Klempner’s “Breaking News” published early from the New
England Journal of Medicine June 12, 2001, was utterly insulting silliness.
The
full transcript of Klempner’s 2001 South County RI “Diseases of Summer”
conference is Exhibit QQ. The secret
MS-haplotype data is on page 7.
Klempner later goes on to describe patients’ illness complaints, which
were relapsing and remitting (like relapsing fever borreliosis and like
relapsing remitting MS), as possibly due to placebo effect.
“So,
in part, this validates exactly what patients have been saying right
along. And that is, “Some of us get
better when we take antibiotics.” It’s
absolutely true. Uh, it’s also true the
same number of patients get better when they take placebo.”
What
Mark Klempner should have said was that unless we know what people are infected
with by using the correct primers, and unless we know who has a susceptibility
to chronic central nervous system infections, and unless we are allowed to know
what are the valid, objective, markers of disease, victims of these infections
and the related medical crime of Lyme borreliosis can continue to be abused,
denied treatment, and labeled hypochondriacs.
The same system of abuse applies to people who have Chronic Fatigue
Syndrome and Fibromyalgia: use invalid
medical tools to assess and use invalid psychiatric terms and invalid
questionnaires rather than take real biological samples and determine if there
are objective, scientific signs and EVIDENCE that something is really wrong.
Klempner’s
fraudulent study of the treatment of chronic Lyme is sometimes referred to as
Evidence-Based Medicine. Hopefully the
public will now have a better idea of what “Evidence-Based Medicine” means and
not become victims of it.
One
can artfully and deliberately not find the targeted DNA in borreliosis if one
is targeting plasmid and not chromosomal DNA, and which is done routinely when
anyone uses an OspA or other plasmid primer.
Anyone who pays for a DNA test for Lyme should not pay for the test
unless the DNA targeted is from the chromosome, preferably the flagellin DNA.
THE
NON-SCIENCE
James
Phillips is an associate clinical professor of psychiatry for Yale University
and is a forensic psychiatrist for the State of Connecticut, yet perjured
himself as regards Lyme and the Plaintiff KM Dickson in order to avoid a
malpractice lawsuit. Subsequent to
that, the DMHAS “Medical Director,” Kenneth Marcus, testified at Plaintiff
Dickson’s DCF “trial” and co-perjured himself saying you treat Lyme delirium
the same way you treat any other psychosis.
The
American Psychiatric Association’s Guidelines state that:
“Medications
for psychiatric disorders can be both the cause of delirium and exacerbate or
contribute to delirium from other causes.”
This
was an extremely detrimental act of deliberate harm against not only CT Lyme victims,
child and adult, but all victims of Lyme borreliosis, as well as Multiple
Sclerosis, and all organic delirium patients around the world, since the
American Psychiatric Association’s guideline say otherwise, as do the
monographs for these “drugs.” However
the 1) value of Phillips’ and Marcus’s testimony, and 2) the psychiatrist
Patricia Leebens having defrauded the court over the Plaintiff’s 11-16-03
databinders, and 3) then having left the country so that she could not be
cross-examined in Plaintiff’s DCF case, regarding the temporary which became
permanent order of custody, through again, total perjury, and 4) for the CT
Department of Mental Health and Addiction services’ Vladimir Coric and Betsy
Byron to have perjured themselves with abandon is an extremely important lesson
to all Americans regarding what they are potentially dealing with, when they
are dealing with psychiatrists.
Psychiatrists blame the patient for the damage that they cause and
psychiatric diagnoses are every bit as harmful as the older terminology which
they replaced: Psychiatric terminology
can define for the world that anyone is a “bad” person, not only with no
evidence, but made-up (psychotic, scientifically invalid) terminology (neologisms)
and with the intent to harm.
Psychiatrists
try very hard for the public to not be made aware that psychiatry is not a
medical or scientific practice, but all one has to do is consider what they do
with their time. Psychiatrists are not
in laboratories. The pharmaceutical
chemists are in the laboratories, the pharmaceutical sales people tell the
psychiatrists what they found, and whoever objects is called “crazy” or is
threatened- a convenient little arrangement.
This is almost as convenient as calling people who have a permanent brain
infection like Lyme borreliosis, “crazy,” and not sick.
The
pathophysiological markers of disease in Lyme borreliosis were given to the
State of CT on numerous occasions, as well as was the Management Plan for the
State of Rhode Island Tick Borne Diseases Commission in a hearing held in Rhode
Island in April 2002 [EXHIBIT Q]
The
published scientific documentation of the various Pathophysiologies of
Psychotopics-Induced Brain Damage were also given to the State of CT on
numerous occasions, most particularly on November 20, 2003, when they
were given to Laura Lustig of the New Learning Center, Westport, in person, by
Plaintiff KM Dickson, in a 1-1/2 inch databinder, along with the 11-16-03
databinders. The 11-16-03 and
11-20-03 databinders are in evidence in 3:05-CV-91 (CFD). The State of CT is in possession of
them (DCF and Patricia Leebens), and
Yale, a defendant in 3:05- CV-91 (CFD), has them, since Patricia Leebens works
also for Yale in the Yale Child Study Center and she mentioned them in the Order
of Custody, November 26, 2003.
Plaintiff’s
children were kidnapped 6 days later by the CT Department of Children and
Families, who defrauded the court over these, the Plaintiff Dickson’s
substantiated replies (the content of 11-16-03
databinders) to complaints to the
CT Commission on Human Rights and Opportunities and Statewide Bar Counsel (CT
attorney ethics/grievance committee) Gerald P. Dwyer, Esq. and 5 others. On November 20, 2003, both databinders were
hand-delivered by the Plaintiff Dickson to Laura Lustig. Lustig’s second ranking administrator in her
private organization, “The New Learning Center,” Westport, CT, was a former DCF
commissioner named Mark Marcus. It is
not known if Mr. Marcus violated the State’s revolving door policy, since Laura
Lustig also had a contract to train DCF “workers.”
These
11-16-03 3 inch thick databinders
contained data regarding Lyme disease and the Plaintiff’s attempts to get
assistance from the State, and communicate with the State of Connecticut, as
regards Plaintiff Dickson’s and her children’s Lyme disease, and as regards
which the CT DCF then again perjured themselves. Plaintiff Dickson first asked for DCF’s assistance, because she
was mistakenly thinking the DCF was a child welfare agency, in 1996. DCF denied helping then, and then DCF denied
that they denied helping the Plaintiff KM Dickson. Plaintiff now knows no one wants DCF’s “help,” because the vast
majority of the DCF staff are criminally insane. The majority of DCF employees fully meet the criteria of
sociopaths, as previously demonstrated in the Amended complaint dated August 3,
2005, and who constantly violate CT state and federal law, as described in the
original complaint Docket Number 5-328 T, US Court, District of Rhode Island.
THE
NOVEMBER 20, 2003 DATABINDERS
The
content of the following reports, contained in the 11-20-03 databinders,
is extremely significant, and presents numerous domains of liability to the
State of CT DCF and DMHAS. Among those
scientific reports are:
1) 1989 Infectious Disease Reviews, Supplement,
Lyme Disease and Other Spirochetal Diseases, Various Titles.
The
content of that Infectious Diseases Society Supplement essentially states that
Lyme is a borreliosis, and the treatment endpoint is still not known. This is because Lyme is a borreliosis, which
is a relapsing fever organism, and borrelia permanently infect the brain. Explained another way, by Alan Barbour, the
owner of the ImmuLyme vaccine patent:
“Lyme
disease and relapsing fever. These tick-borne infections are notable for
multiphasic antigenic variation through DNA recombinations in the case of
relapsing fever, the occurrence of chronic arthritis in the case of Lyme
disease, and invasion of and persistence in the brain in the case of both
diseases. – from Alan Barbour’s website.
2) Genetic animal models: focus on
schizophrenia, Gainetdinov, RR., et al. TRENDS in Neuroscience, Vol 24., No. 9,
September, 2001.
At
this point in history, these psychiatrists have no idea what the drugs targets
are and are leaning towards considering the scientifically valid in their
future approach.
3)
"Loss of striatal cholinergic neurons as a basis for tardive and
L-dopa-induced dyskinesias, neuroleptic-induced supersensitivity psychosis and
refractory schizophrenia."
Miller R, Chouinard G., Biol Psychiatry. 1993 Nov 15;34(10):713-38.
Abstract:
In the first section of this paper several aspects of tardive dyskinesia (TD)
(clinical, epidemiological, pharmacological) are reviewed. We propose that this
syndrome is not the consequence of dopamine receptor proliferation, but results
from damage or degeneration of striatal cholinergic interneurons. We suggest
that this cellular damage is caused by prolonged overactivation of these
neurons, which occurs when they are released from dopaminergic inhibition
following neuroleptic administration.
Brain
cells die and are damaged by these psychotropics.
4)
Psychiatric research in the 21st Century; Opportunities and Limitations,
GR, Heninger, Millenium Article, Molecular Psychiatry (1999) 4, 429-436
The
above is a report which points out that psychiatric “research” will be based in
Neurology, psychiatry may start becoming scientific, with the intent NOT to
cause brain damage, and they mention neurotrophins several times. Neurotrophins are associated with nerve
protection and nerve growth, unlike the entire spectrum of psychotropics on the
market today, with the exception of Lithium, which is not a drug, but is
neuroprotective.
Lithium
only costs approximately 15 US dollars per month, and which is why it is not
prescribed very often. It can’t be
patented, it is not a drug, it is extremely inexpensive, it is also
neuroprotective and treats many so-called psychiatric disorders - probably
because it is neuroprotective, and protects brain cells from demise from many
mechanisms, including infection and stroke.
5)
"Akathisia and Exacerbation of Psychopathology; A Preliminary
Report", Dunca, et al. Clinical Neuropharmacology, Vol 23, No. 3, pp.
169-173 Department of Psychiatry, New
York University School of Medicine, New York, USA.
6) ”Akathisia has previously been reported to exacerbate psychopathology and to
be associated with noncompliance, suicidality, and violence. “
This
means drug-induced brain damaged makes people more deranged, agitated and
violent, in addition to more physically miserable as a result of
psychotropics-induced brain damage, as do the next two listed here:
7)
"Subjective Emotional Experience and Cognitive Impairment in Drug-Induced
Akathisia", Jong-Hoon Kim, et al, Comprehensive Psychiatry, Vol.43, No. 6
(November/DEcember), 2002: pp 456-462
8) "Correlations Between Akathisia and
Residual Psychopathology: A By-product of Neuroleptic-Induced Dysphoria",
Newcomer, et al. Br J Psychiatry. 1994 Jun;164(6):834-8.
Among
the other data submitted to Laura Lustig November 20, 2003 was the
following abstract and full text article:
9) Neuroleptic-induced akathisia and violence:
a review. Center for Forensic Services,
Western State Hospital, Tacoma, WA 98498-7213, USA. leonggb@dshs.wa.gov
”Surprisingly, the association of neuroleptic-induced akathisia and aggressive
behavior was not formally recognized until nearly two and one-half decades of
antipsychotic prescribing had passed. Using a search of the anglophonic
literature, this phenomenon is reviewed. Advances in psychopharmacology have
reduced neuroleptic-induced akathisia and hold promise to eliminate it
altogether. Nonetheless, important clinical and forensic aspects of
neuroleptic-induced akathisia and aggression remain and are explored.”
PMID: 12570226 [PubMed - indexed for MEDLINE]
In
the body of the report is the following statement:
“Although
there is an optimistic picture for the possible extinction of NIA associated
violence, we do not anticipate that this will happen in the next few years. As
such, there remains the spector of neuroleptic-associated aggression as a
relevant factor when considering a criminal defendant’s mental state at the
time of an alleged crime.”
Pfizer
has published the following article on how to treat antidepressants-induced
akathisia (agitation), which they simultaneously deny exists:
10) SSRI-induced extrapyramidal side-effects and
akathisia: implications for treatment.
Pfizer Inc., New York, NY 10017, USA. laner@pfizer.com
The selective serotonin reuptake inhibitors (SSRIs) may occasionally induce
extrapyramidal side-effects (EPS) and/or akathisia.This may be a consequence of
serotonergically-mediated inhibition of the dopaminergic system. Manifestations
of these effects in patients may depend on predisposing factors such as the
presence of psychomotor disturbance, a previous history of drug-induced
akathisia and/or EPS, concurrent antidopaminergic and/or serotonergic therapy,
recent monoamine oxidase inhibitor discontinuation, comorbid Parkinson's
disease and possibly deficient cytochrome P450 (CYP) isoenzyme status. There is
increasing awareness that there may be a distinct form of melancholic or
endogenous depression with neurobiological underpinnings similar to those of
disorders of the basal ganglia such as Parkinson's disease. Thus, it is not
surprising that some individuals with depressive disorders appear to be
susceptible to developing drug-induced EPS and/or akathisia. In addition, the
propensity for the SSRIs to induce these effects in individual patients may
vary within the drug class depending, for example, on their selectivity for
serotonin relative to other monoamines, affinity for the 5-HT2C receptor,
pharmacokinetic drug interaction potential with concomitantly administered
neuroleptics and potential for accumulation due to a long half-life. The
relative risk of EPS and akathisia associated with SSRIs have yet to be clearly
established. The potential risks may be reduced by avoiding rapid and
unnecessary dose titration. Furthermore, early recognition and appropriate
management of EPS and/or akathisia is required to prevent the impact of these
effects on patient compliance and subjective well-being. It is important that
the rare occurrence of EPS in patients receiving SSRIs does not preclude their
use in Parkinson's disease where their potentially significant role requires
more systematic evaluation.
PMID: 9694033 [PubMed - indexed for MEDLINE]
STATUS
The
State of Connecticut has long been in possession of this data and this science,
which shows that nearly all, if not all, psychotropics are brain damaging. This data was also on Plaintiff Dickson’s
website www.ACTIONLYME.com , from the summer of 2003
until December 23, 2004, when the former John Rowland pleaded guilty to his
crimes related to an alleged prison-building enterprise. The alleged criminal enterprise, which was
allowed to operate from John Rowland’s office, involved DCF’s former
commissioner Kristine Ragaglia, and which involved the CT prison children,
CJTS, which will close and not be used as a prison at all.
The
State of Connecticut is therefore liable for any violent deaths or violence
associated with any medications they have prescribed for their victims,
especially children, and especially children who have killed themselves in
DCF’s “care,” if the DCF has insisted they take these brain-damaging
psychotropics, when they knew better, and have known of these factual
scientific details since 11-20-03.
The
State of CT in no way is competent to brain matters, matters of trauma, matters
of children, matters of health, matters of epidemics, and matters of basic
human civil rights, despite being given the evidence by the Plaintiff Dickson,
and despite laws regulating the behavior of all citizens, not exclusively
persons who are not employed by the State or federal government.
The
First Amendment:
"Congress
shall make no law respecting an establishment of religion, or prohibiting the
free exercise thereof; or abridging the freedom of speech, or of the press; or
the right of the people peaceably to assemble, and to petition the government
for a redress of grievances."
When
the plaintiff Dickson tried to redress grievances and express free speech, and
under no violation of law, was falsely charged with harassing communications
and threatening and was not allowed access to the courts. This is an abuse of power, as is the case of
John M. and his family. John M. is entitled
to no assistance in defense, according to the State of Connecticut; his family
is not allowed to know the specific details of his charges; he has been
long-declared incompetent; no evidence of a competency evaluation having been
performed has been granted to his family subsequent to his arrest; and the DMR
stated that John M. refused involvement of the DMR, yet the family refutes that
claim.
The
State of CT is incompetent to all brain matters, as demonstrated above and in a
previous motion dated Aug 3, 2005, and in the original complaint under this
docket number, and therefore can pass no criminal judgment on this person, John
M., who has been effectively declared a non-person.
Plaintiff
KM Dickson should not have to be filing a complaint in the federal district of
Rhode Island about the incompetence of the entire State of CT on all brain
matters: Autism, Lyme borreliosis,
mental retardation, well-known neuropsychiatric diseases such as Alzheimers’s,
Multiple Sclerosis, Lupus, and should not have to explain to CT what is in the
drug monographs for such common psychotropics as risperidone, since it would be
inherent in the commissions of the various departments of the State to act in
the best interests of the State, and the State is its residents.
John
M. has been declared competent but was formerly “developmentally” incompetent,
has been incarcerated 6 months on a class 4 misdemeanor, is considered a ward
of the State, but is in a jail instead of a group home or some other housing
which should be provided by the State for all persons who are mentally
incompetent or meet the criteria of a non-recoverable neuropsychiatric
disease. Ms. Hoggan and Ms. Andino
should not be in prisons. Plaintiff
has heard from others and read in the newspapers that prisons are being used to
warehouse the mentally ill, but also clearly now, prisons are being used to
warehouse chronically ill people and people with mental retardation.
There
is no entity in the State to qualify any person’s mental status as demonstrated
in all of the above examples. The State of Connecticut, rather than accept the
liability of the science that demonstrates that all psychotropics are brain
damaging, kidnapped Plaintiff Dickson’s children, and falsely criminally
charged plaintiff Dickson with the insanity invented for her at her DCF
“trial,” and which is a product of AAG Jessica Gauvin’s pathological
imagination and is the perjury of James Phillips, Kenneth Marcus, and others.
ABUSE
AND NEGLECT AS POLICY- THE 10-FOLD INCREASES
These
are gross, across the board, abuses and misuse of all state agencies and
departments to effect an end to civil rights in Connecticut, because there is
little no other real work, and there is no money in the State budget to provide
for people who really need it, while the DCF’s budget increased 266%. Thus, the unions of State employees acted to
form the government in their own interest, rather than the people the State
employees serve. The State prosecutor’s
office and the DCF spend all of their time conspiring to put people away who
are a nuisance and ruining their lives, regardless of whether their victims can help being a nuisance or
not. This policy formally started in
1995, as soon as Governor John Rowland took office as can be seen in the
announcement which is executive Order Number Two:
WHEREAS,
the taxpayers of Connecticut deserve a state welfare system that is sound and
secure from fraud and abuse; and
WHEREAS, the beneficiaries of our state welfare system deserve a method of
assistance that can truly help lift them out of poverty, not keep them there;
and
WHEREAS, State Superior Court Judge Arthur L. Spada conducted a State Grand
Jury investigation that uncovered wide-spread welfare fraud and abuse
facilitating an insidious link between our current welfare system and the
illicit drug trade; and
WHEREAS, Judge Spada's report contained findings and recommendations that must
be given serious attention if the current abuse of our welfare system is to
end.
This
“policy” resulted in nearly 10 times the number of inmates in the York women’s
prison since 1994, according to a reliable source inside the prison, who
is also a Republican. DCF’s budget
grew, as previously mentioned in the original complaint, from $227.6 million in
1994 to $606.1 million in 2004. This a
266% increase and not a 165% increase:
1. Growth in DCF’s Budget Has Far Exceeded
Growth in DCF’s caseload
In
the last decade, the number of children served by DCF increased from 7,500
children at the end of FY 94 to 12,247 children at the end of FY 04 (a 63%
increase). DCF’s General Fund budget
grew faster- from $227.6 million in FY 94 to 606.1 million in FY 04 (a 165%
increase), With DCF’s revised SFY 05
General Fund budget at $642.6 million, there has been a 182% nominal increase
since FY 94. While some of this growth
is attributed to the more complex clinical needs of children now in care and to
long overdue investments to improve the quality of care of these children, much
growth is also due to skewed spending policies that skimp funding for services
that could reduce child welfare involvement while, at the same time, increasing
spending for “back end” placements and services.”
There
was also a 445% increase in children taken from their parents during this time
period, while, as Rowland claimed, there was a 45% reduction of “abuse.” A 10 fold increase in families wrecked, and
a 10 fold increase in incarcerated women, seems to be the result of this Arthur
Spada policy of racism and
criminalizing poverty. This appears to
be the same thinking as former Massachusetts Governor William Weld. Cut welfare. Weld wanted to “reintroduce prisoners to the joys of busting
rocks.”
Reported
in the August 20th, 2005 edition of the New York Daily News, Weld is
: A fiscal conservative who cut taxes and curbed
welfare in Massachusetts….” This
sounds scarily like John Rowland’s policies, which did not result in the
reduction in the size of the government, but merely was a platform for the
friends of these Republicans to establish a federal funding feeding trough, at
the expense of human lives. This can’t
have been the intention of the US Constitution, Declaration of Independence,
and Bill of Rights, and so it is laughable that the United States would want to
violently bring this sort of “freedom” to other countries, especially when the
United States is bankrupt and their allegedly human rights abusing opponents
are sitting on the second largest world oil reserves.
On a
more local level, most of the cases mentioned in this entire combined complaint
give the appearance that the liabilities lie elsewhere, yet the sick, innocent
or incompetent victim was blamed. Just
as it is well-known that the DCF can be used as a weapon, and that the DCF
staff are extremely ignorant, so too, does it appear that the liabilities for
the nursing home crimes, and the non-crimes of the retarded were shifted by
people who knew how to abuse the ignorance of the police. The prosecutors are only after simple cases
they can win and have no incentive to tangle with people who have the money to
present the challenge of a difficult trial, as would be the case with the
nursing home owners.
In
the case of the mentally retarded, who all will eventually be wards of the
State, the State obviously has a policy of the cheapest solution. They simply declared a clearly incompetent
man to be competent so that he could be prosecuted as a criminal (John M.).
Steven
Erickson and Christopher Kennedy and other like them who suggested a way to
effect fairness is to have citizen oversight of the police, were clearly
persecuted. Both are very intelligent
men. Not so the police, from Plaintiff
Dickson’s local police experience.
Naturally such people, such as the police, feel threatened by people who
are more educated than they are, especially if the police and DCF staff are
involved in drug-related crime, and other crime, which clearly some are. John Rowland also helped himself to State
goodies, but blamed his son. What
Rowland did was not considered burglary, but if he was black and not the
governor, it most certainly would have been considered burglary. This appears to be true also of the present
governor’s son, if the report in Corporate Crime Reporter was true about the
stolen skidoos.
In
the case of people who have Lyme disease, it was much more convenient to
prosecute the Plaintiff, and destroy her family, than for the truly guilty, in
this case, Nancy Martin, Carolyn Martin, Donald Dickson, the State of
Connecticut, the DCF, Yale University and James Phillips, to be prosecuted. Plaintiff Dickson represented a threat to
DCF, DMHAS, Yale, the State Health Department, and the criminal justice system
simply for revealing that evidence is evidence and that hearsay is hearsay. This would clearly upset the entire State
and federal justice system and put a lot of mental health “experts” out of
business, not to mention the effect on the pharmaceutical industry.
THE
REALITY OF FORENSIC PSYCHIATRY
Psychiatric
“expertise” is in no way evidence or expertise. Psychotropics contribute to violence and dementia, mitigating
every single case where a person who had been taking psychotropics committed a
violent or demented act. Forensic
science actually points to the prescriber of these drugs, and the reality of
what is “forensic psychiatry,” is completely different from what everyone
thinks.
Such
a revelation, psychiatry fights very hard to suppress. They also would like the world not to know
that psychiatry is not a medical practice, except in cases where psychiatrists
try every available method to discover if there is actually something
medically, or mechanically wrong with a person’s brain. They rarely do. Forensic Psychiatrists even
more rarely do so before offering a paid opinion. We should never expect to see a Forensic Psychiatrist testify
that in a child who commits a violent act, but who also had been taking
psychotropics, was at least doubly mitigated.
This is from the members of the
“helping” profession.
James
Phillips had said to Plaintiff Dickson in December 2002, after trying 10
different drugs, some of which increased agitation and made Plaintiff Dickson’s
neurological disease worse, “I think you need to be on medication, I just don’t
know what kind.” Plaintiff Dickson had
first asked for ProVigil for alertness before the subsequent 10 or 11 drug
experiment, none of which were ProVigil.
This is obvious medical malpractice since Lyme borreliosis results in a
delirium and Plaintiff Dickson has this objectively documented delirium as
demonstrated in the reduced blood flow to the brain as shown in a brain SPECT
scan.
In
the case of John M., we would all like to know who determined John M. was
competent because that person should be behind bars.
Therefore,
there are a lot of innocent people in prisons, since blaming the victim and
selectively prosecuting “crime” is an yet another unique Connecticut
epidemic. The founders of this country
thought we should have God-given human rights-based laws, and constitution, and
bill of rights intended to prevent the abuses of an autocracy.
Exhibits
RR and SS, now entered as evidence in this complaint are these November 16 and
November 20, 2003 databinders, respectively.
Mr. Blumenthal has access to the Nov 16 and Nov 20, 2003
databinders. Mr. Blumenthal was sent
the 11-16-03 databinder. The 11-16-03
databinders were mentioned in the “Temporary Order of Custody” (TOC) written by
Yale’s and DCF’s Patricia Leebens, but were not described to the court as what
they were, and proving that she defrauded the court in her “TOC.” Both
databinders were left with Laura Lustig on Nov 20, 2003. Lustig had a contract to train DCF social
workers. Mr Blumenthal also has access
to the audiotape of Mark Klempner’s July 2001 RI Conference since the Plaintiff
mailed it to his staff (AAG Thomas Ryan) approximately two years go (Exhibit OO).
Jeanne
Milstein, the Child Advocate was mailed the November 20, 2003 databinders
on May 6, 2004.
CERTIFICATION
This
document and the evidence was sent by certified mail on August 22, 2005 to:
Connecticut
Attorney General Richard Blumenthal
55
Elm Street
Hartford,
CT 063106
It
is certified that the Defendant does not need another
copy
of this evidence: RR, SS and OO.
_______________________________
Plaintiff’s
Kathleen M. Dickson, et al
23
Garden Street
Pawcatuck,
CT 06379
AMICUS CURIAE AFFIDAVIT filed
by the on behalf of John M. by Kathleen M. Dickson, et al
------------------------------------------------------------------------------------------------
State
of Connecticut Vs John M.
DOCKET
_______________________________
Norwich
Superior Court
Courthouse
Square
Norwich,
CT 06360
August
22, 2005
AMICUS
CURIAE BRIEF ON BEHALF OF CONNECTICUT VICTIMS OF FEDERAL CIVIL RIGHTS
VIOLATIONS BY THE STATE OF CONNECTICUT AND IN SUPPORT OF A MOTION TO DISMISS
I,
Kathleen Dickson, do HEARBY SWEAR that the following statements are truthful,
sworn testimony, written as any reasonable person would understand, before God,
as stated, and regarding the known incompetence, perjury, acts of defrauding
the both the courts and The United States of America, the criminal behavior of
the Department of Criminal Justice and the CT Department of Children and
Families (DCF) and related staff, and are in support of dismissal of charges against John M.
I
have permission from the family to be in possession of the records of John M.,
which are to be submitted as evidence with this complaint. Inasmuch as John M. is incompetent and
mentally retarded, I have treated his case and his name as though he were a
juvenile and respected his privacy, referring to him as John M.
In
the cause of a class action for numerous federal civil rights violations,
including Title 18, secs 241, 242, and 245, Conspiracy to Deprive of Rights,
Color of Law abuses, Deprivation of Rights, Deprivation of Rights to federally
protected activities, persecution of persons seeking redress, disregard for the
Americans with Disabilities Act, acts of perjury, false arrests, State
employees deliberately defrauding the courts, conspiring to commit perjury with
State’s “experts,” deliberate medical malpractice, acts in violations of the
first and fifth amendments, against citizens of Connecticut, I, Kathleen
Dickson, representing numerous cases of civil rights violations, abuse and
neglect of CT citizens, have filed a
complaint, docket number 5-328 T (Hon. Torres), in the District of Rhode
Island.
In
the deepest respect for human dignity as a human rights and health rights
activist, I plead and request of the Superior Court in Norwich CT that the
charges against John M be dropped. John
M. is a man with a clear lifelong history of mental retardation, and who has
been incarcerated 6 months. John M. was
declared Mildly mentally retarded by the State of Connecticut in 1998, and the
statement regarding his disability states that he was developmentally impaired.
In
an amended complaint to the federal court in Rhode Island dated August 22,
2005, and included as evidence along with the exhibits in support of dismissal
of charges against John M. and in excerpt of that claim are the following:
CASE
EXAMPLES:
1) John M. is a young adult with mental retardation,
yet he has been housed in a CT prison since February 2005 for 2 counts of
sexual assault 4th degree and risk of injury to a minor.. His family has been denied the right to see
the warrant and specific charges against him, because they involve a minor
boy. John M. has been determined
competent to stand trial, although his family states that he was given a
competency evaluation, which the family has not seen, and their request to see
it has not been granted by the State.
The family was only told verbally that John M. is competent to stand
trial. John M. has been kept in prison
these last 6 months.
The
family states John M. was raped in prison, and that it took almost a month for
the prison doctor to investigate. John
M. was raped in one prison, and was examined in another. Naturally, the guards denied it happened.
A
letter written by Annette Rose, DMR Case Manager, which is EXHIBIT KK, dated
October 22. 2004, states:
To Whom It May Concern:
Please be advised that John M., date
of birth 11-07-80, was determined eligible for Department of Mental Retardation
Services by H. Steven Zuckerman, PhD.,
Supervising Psychologist 2.
According to Elibigibilty Determination document signed by Mr. Zuckerman
and dated 08-14-98, John M. “falls withing the Mild range of Mental
Retardation.” This document can be
found in Mr. M.’s Department of Mental Retardation case record.
In
the letter on behalf of John M. was written by Brian O’Rourke and Ellen Gilman
of the Office of protection and Advocacy for Persons with Disabilities,
Hartford, CT, [EXHIBIT 5-328T LL], they state:
“Mr.
M’s habilitation cannot be addressed in a correctional facility. His cognitive limitations combined with a
history of behavior adjustment difficulties increases the serious risk prison
incarceration posess to his personal safety and psychological well-being. As you are aware, prisons can be especially
dangerous environments for individuals being held on (or convicted of) charges
of the nature he is facing.
Mr.
M.’s past psychological reports cite significant language processing
deficits. His language processing
becomes further compromised when John becomes anxious. This factor does interfere with his ability
to cope with his current situation. Mr.
M’s mild retardation, in addition to these deficits places him at a serious
disadvantage as he attempts to work with his attorney in defense of these
charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple
conversation about his present circumstances.
Mr.
M’s history shows that he needs significant support to reinforce his awareness
and acquisition of appropriate social skills.
The Department of Mental Retardation should have reevaluated Mr. M’s
service and support needs over a year ago, when allegations of criminal conduct
were first made. The development and
implementation of an individualized service plan needed to occur at that time.
As a
resolution to this Programmatic Aministrative Review request, we ask that the
DMR immediately identify an emergency (short term), community based residential
placement for Mr. M., and that Mr. M.’s attorney, Mr. John Coccio be informed
of this option. Once in placement, we
request that the DMR complete any relevant assessments and develop a
well-designed community-based support propgram to meet Mr. M’s long term
needs.”
This
letter was written April 11, 2005, and is a comprehensive and adequate attempt
to have a rational grasp of the needs and the urgency that Mr. M’s be treated
as a person with mental retardation.
Again, they state:
Mr.
M’s mild retardation, in addition to these deficits places him at a serious
disadvantage as he attempts to work with his attorney in defense of these
charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple
conversation about his present circumstances.
This
would appear to resoundingly dispute any legal competency of Mr. M. that the State’s attorney’s office has
arbitrarily - and without producing the
documentation of - asserts exists.
Further follow up with the Department of Mental Retardation suggests
strongly that there is no alternative housing for John M., yet the State also
claims to have 16,000 residents in CT with mental retardation and that 1% of the population has mental
retardation (IQ of 70 or below). The website of the DMR states that:
“Unlike
other agencies, its supports and services (with the exception of Birth to
Three), are not an entitlement for people with mental retardation and the
majority of its services are provided by private non-profit organizations in
local communities.
This
gives the appearance that like the DCF, the DMR provides no real services,
other than the pay checks of the employees.
There is no housing available for these people, when one would think
such would be a priority, since one thing there is no denying exists is mental
retardation. Autistic people belong to this department.
Autism
is an epidemic, yet instead of planning for this epidemic or Lyme disease, and
seeking appropriate federal funding, the State planned for an increase in
prison cells, as previously mentioned.
In
an email to Ms. Ellen Gilmartin, Gino DeMaio, Forensic Coordinator, State of CT
Department of Mental Retardation, states that “John has asked DMR to not attend
these hearings and has not wanted his case manager to be involved.” [EXHIBIT
MM]
The
family who had been the guardians of John M. state that no such conversation
took place. They state that John cannot
even make change, and once bought a pack of gum from a child for 5 dollars, not
knowing that a pack of gum costs nowhere near 5 dollars.
H.
Steven Zuckerman, PhD. Of DMR on September 14, 1998, [EXHIBIT NN] states that
as regards John M.,
“Based on the information presented to me,
this individual does meet the definition of mental retardation as defined in
CGS Section 1-1g, and is therefore eligible for Department of Mental
Retardation services. This individual
falls within the Mild Range of Mental Retardation.”
Listed
as requirements for this condition are under Connecticut General Statutes 1-1G.
“For
the purposes of sections 4a-60,. 17a-274, 17a-281, 38a-816, 45a-668, 45a-684
inclusive, and sections 46a-51, mental retardation means a significantly
subaverage general level of functioning existing concurrently with deficits in
adaptive behavior and manifested during the development period.”
The
family of John M. state that the incident for which he is in jail took
allegedly took place on November 1, 2003, yet it wasn’t until the summer of
2004, when John M. and his cousin tried to attain a minor position either in
the local fire department, or be volunteers or trainees, did anyone take any
legal action. John M. went to jail in
February 2005 and has been there since, without his family being allowed to
know exactly what he is being charged with, who performed the competency
evaluation, or any of the important details of the case. The family states that they don’t even know
how the case was transferred from Norwich, where the family lives to the New
London courthouse.
There
was apparently another nephew involved, and the State prosecutor combined cases
with no explanation as to how all these events took place.
Years
before, apparently, the retarded boy’s uncle proposed citizen oversight of the
police. John M. was apparently involved
in an incident at Walmart where a child was in the men’s room and could not get
his pants down to go to the bathroom, and the parent was nowhere around, so
John M. helped. Walmart hires retarded
people and are familiar with the difficulties of retarded people, and of course
were willing to let the whole event drop, to the best of this Plaintiff’s
knowledge. There is little
documentation of events available, and that would be because the public does
not know what they are up against, if they become the arbitrary victims of
crazy people who know how to use the DCF and the police to their
advantage. Hopefully this complaint will
alert the residents of Connecticut to the hazards of being a Connecticut
residents, before the adequate resolution of these crimes, as described as
relief and damages in the original complaint Docket 5- 328 T, dated July 27,
2005.
One
can see how this Walmart event would get mixed up, and that it is impossible to
tell what happened if John is mentally retarded, and as is known of him:
“Mr.
M.’s past psychological reports cite significant language processing
deficits. His language processing
becomes further compromised when John becomes anxious. This factor does interfere with his ability
to cope with his current situation. Mr.
M’s mild retardation, in addition to these deficits places him at a serious
disadvantage as he attempts to work with his attorney in defense of these
charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple
conversation about his present circumstances.”
It
was after this Walmart incident that John M. uncle proposed citizen oversight
of the police. One can see that what we
have is in reality, two sets of parents of young children, only one looks a lot
older. Both are equally concerned about their children.
It
appears as though there is a tremendous tug-of-war over bodies, between the Department
of Criminal Justice, the Department of Children and Families, the Department of
Mental Health and Addiction Services, but oddly, not the Department of Mental
Retardation. Each has their own set of
statutes, and the only mediator, the Department of Protection and Advocacy for
Persons with Disabilities, appears to be powerless.
There
are numerous free assistance agencies in the State of Connecticut but they
don’t actually do anything for anyone, even if one is lucky enough to get one
of them to call back. This is not only
the Plaintiff Dickson’s experience, but was the experience of every single
person who was dragged through the Connecticut Valley Hospital as
“incompetent.” Not too many of the
“criminals” were incompetent, if they knew how to look for help. The help was incompetent, and one wonders of
these non-profits take federal funding to provide no service. It did not take long before we “prisoners”
we all joking about what a waste of advertising and publishing these alleged
non-profit legal help groups expend, and especially, about our coins for the
pay phone, which were wasted. It is
well known that a CT public defender is called a “public pretender,” and the
only people who can emerge from this potentially permanent trap are those who
have family support on the outside.
Frequently
enough to be a recognizable phenomenon, as in the evidence of many of the women
in prison, whoever goes to jail, in family disputes, is a matter of who called
the police first. Then of course, once
one person has a record, those persons are always assumed to be guilty in
subsequent disputes, which involve altercations and then the police. One prison guard told the Plaintiff that
people routinely place their relatives in prisons just to get rid of them because
they are a nuisance. Plaintiff Dickson
only heard abundant evidence to support that this is true from listening to a
vast number of the inmates at York.
It
appears that just as it is well-known that the DCF can be used as a weapon, so
to can the police be used as a weapon.
Hearsay is plenty good enough for DCF to fraudulently take anyone’s
children away. No one has ever been
prosecuted for false allegations of child abuse or neglect in Connecticut. The DMHAS employees also refer to CT as a
“Meat Grinder.” They have seen this
abuse enough times. Lower level DMHAS
employees are remarkably more sane than their supervisors and more sane than
the DMHAS “doctors.” They are more sane
than corrections officers, police, and DCF “social workers,” to their
credit. These mental health workers and
nurses at the CVH “competency restoration unit” should all get the salaries of
the police and corrections officer and DCF workers, while all of the latter 3
groups should be fired. DMHAS mental
health workers and nurses are in a class unto themselves in the state of
Connecticut (at the present time).
2) Marsha Hoggan, 55, is an Alzheimer’s patient
who also has Parkinson’s disease.
(These two disorders of brain damage also occur in Lyme borreliosis.)
Ms. Hoggan is accused of stuffing tissues in her roommate’s mouth and cotton
balls in her nose, where they lived together in a nursing home. The roommate’s name was Eleanor
Mazzarella. Mazzarella died in March
2005 from unrelated causes and was 74 at the time of her death. Ms. Hoggan has claimed she did not know what
crime she committed and is now in the York Women’s prison where she is
mistreated and is treated to more medical and nutritional neglect, since the
nutrition in the prison is grossly inadequate.
The inmates in the mental health wing cannot buy vitamins or
coffee. Stimulants are known to be
helpful for people with, dementia, cognitive decline, and the associated
depression.
None
of the inmates at York get adequate exercise, since the only two exercise bikes
in the prison are broken and there is no other recreational equipment except
balls, basketball hoops, and sometimes a volleyball net. The guards are forever looking for a reason
for the prisoners not to go to the gym or to the library. Prisoners are not allowed to jog on the
grass. Prisoners can only go to the
library, once a week and only approximately 5 out of 20 get to go, they are
picked randomly, and some never get to go to the library. Some of the ward TVs are broken, and some
have no reading materials. Thus, there
is no intellectual stimulation whatsoever for a great many inmates. These combined conditions contribute to
dementia. In the prison there is no
education about nutrition, no nutrition, no education about diet and exercise,
and no exercise, when clearly all these
are needed to restore many of these women in the prison.
Most
of them are drug addicts and in poor health.
A great majority of these prisoners go over to “mental health” to get
some kind of drug to sleep their sentences away, but this increases the
illegal-drug induced dementia.
Thus,
no prisoners will improve in any way, under
“corrections.” There is no
incentive on the part of corrections officers, for the prisoners to not be
prisoners, because of all the overtime pay these guards get. Therefore the cycle of abuse is perpetuated
by the guards and their union.
Prisoners return to prison after having been arrested again for
self-medicating too often. How prisons
are managed does not make any sense for dealing with human beings in any way,
with the exception of mass murderers, who are rare.
The
most adverse treatment for older women in cognitive decline are central nervous
system depressants such as antipsychotics and this announcement was made in
2005 by the National Institute of Mental Health. A trial of Seroquel for agitation in dementia was halted because
it was observed that this treatment accelerated the dementia. The monograph for risperidone states that
this medication is associated with greater extrapyramidal effects
(extrapyramidal brain damage) in older women, especially.
It
would appear to the casual observer that the liability in this Hoggan case was
more the nursing home’s, rather than the incompetent patient’s.
3) Leslie Andino a 23 year old woman with
multiple sclerosis, dementia and depression - which sounds very much
misdiagnosed Lyme Neuroborreliosis - was arrested and charged with arson in a
nursing home fire that killed 16 other residents in Connecticut in May 2003. After several periods of “treatment” to
restore competency for trial for a crime she never should have been charged
with in the first place, she returned to the courthouse in January 2005,
“heavily sedated,” to learn she would be committed to the Whiting Psychiatric
Prison.
Heavy
sedation is malpractice for a neuropsychiatric disease, and likely contributed
to her increasing dementia. The
American Psychiatric Associations Guidelines on the treatment of a delirium
state that: “Medications for psychiatric disorders can be both the cause of
delirium and exacerbate or contribute to delirium from other causes.”
This
Andino case should be investigated by a competent independent federal health
official and expert, which would obviously not be one from Connecticut.
It
would appear to the casual observer that the liability was more the nursing
home’s, rather than the incompetent patient’s.
These
are three cases which are in addition to the several other cases of incompetence
and abuse and wrongful imprisonment, denial of access to the courts, false
criminal charges, perjury and alleged judicial misconduct listed in the
original complaint about the State of CT in docket 5- 328 T, originally filed
July 27, 2005, and amended August 3 and August 22, 2005.
I
respectfully ask the Norwich Superior Court to acknowledge this condition and
the facts presented in John M.’s case and release John M. to his family, who
would like to assist in his placement in a proper facility, which the family
has been made aware will take him. The
Department of Mental Retardation’s website makes it clear that they have no
state funded housing available for any new needy families. Participants in the class action against the
State of CT believe the DCF is over-funded and abused funding, and so too it
appears, has the Division of Criminal Justice.
I
believe a disabled person like John M. should have his needs addressed, rather
than be thrown away into a prison, which is merely the least costly solution to
persons with disabilities. I agree with
his case manager, Ellen Gilmartin, that he does not belong in a prison where
the threat of abuse is not only accelerated but confirmed in John’s case, as
was predicted by his case manager.
John M. is a human being, deserving of protection as a disabled person,
and by the definition of a person with mental retardation, is not competent and
not a criminal.
John
has already served 6 months and it seems pointless to the casual observer to
pursue this case in a trial against John M, since the cost could be better
spent for his care.
Care
for the disabled may or may not be a State mandate. It may not be a funded mandate.
However, the original complaint against the State asserts that it was
the responsibility of Marc S. Ryan, the Director of the Office of Policy and
Management, to seek sources of federal funding to provide for the needs of the
State’s residents. All that we know
that was accomplished was the construction of the multimillion dollar Tomasso
pediatric prison, and which spent $514,000 per year, and per child, to
incarcerate children, but will now close.
Part of the resolution of the disaster of misallocation of funding,
racketeering, fraud, and theft of honest services, was that the former Governor
John G. Rowland went to jail and several high-level State employees are facing
federal indictment or a lawsuit brought by the Attorney General.
Many
legislators and citizens of the State agree that children do not belong in
prison. Neither do the mentally
retarded, since there is little technical difference. Both classes of people are incompetent.
Signed
this ____ day of August, 2005
_______________________________
Kathleen
M. Dickson, et al
23
Garden Street
Pawcatuck,
CT 06379
860-599-5451