A. JURISDICTION
1) This complaint alleges that the civil rights of the plaintiff,
Wayne Edward Manzo, who presently resides at 500 Galetti Way,
Sparks, NV, were violated by the actions of the below named individuals
which were directed against the plaintiff at Henderson Jail,
Clark County Detention Center(C.C.D.C.), and The Lakes Crossing
Center(L.C.C.)__Sparks, NV, on (dates) 11-10-92, to present
(Count I) (Count II)
Section 1983-Form
eff. 7/92
Page 1
Make a copy of this page to provide the below
information if you are naming more than five(5) defendants
2) Defendant James Goff, Henderson Police, resides at
City of Henderson Jail, Henderson, NV, and is employed as
Chief of Police, City of Henderson. This defendant is sued
in their official capacity.
Explain how this defendant was acting under color of state law:
As chief of police(and guards at Henderson Jail) acting as
agents of the U.S. Army ..........
deleted was the sentence that describes the criminal charge
against the student__the student was set-up in Las Vegas,
the charges were false
3) Defendant Sheriff John T. Moran and Metro Police(C.C.D.C.),
resides at Clark County Detention Center, 330 Casino Center,
Las Vegas, NV, and is employed as Sheriff and Metro police at
Clark County Detention Center.
4) Defendant Psychiatric staff at Clark County Detention Center,
resides at Clark County Detention Center, Las Vegas, NV, and is
employed as psychiatrist and psychologists at C.C.D.C.. This
defendant is sued in their official capacity.
Explain how the defendant was acting under color of law:
a psychiatric team at Clark County Detention Center acting as
agents of the U.S. Army and federal Bureau of Investigation.
5) Defendant Carlos Brandenburg and Staff at L.C.C. resides at
Lakes Crossing Center, 500 Galletti Way, Sparks, NV, and is
employed as Director of L.C.C. and staff. This defendant is sued
in their official capacity.
Explain how this defendant was acting under color of law:
As Director and staff at the Lakes Crossing Center for mentally
impaired criminal and as agent of the U.S. Army.
Page 2
6) Defendant John Acurio, Director, Gilbert Weden, Chief, Aero Comps.,
U.S. Army Propulsion Directorate, resides at ___ Goodfellow Road,
St. Louis, MO(this is the location of the U.S. Army System Command
in which the Propulsion Directorate operates under), and is
employed as Director and Chief Aerospace Components Division,
U.S. Army Propulsion Directorate.
7) Jurisdiction is invoked pursuant to 28 U.S.C. Section 1343(a)(3)
and 42 U.S.C. Section 1983. If you wish to assert jurisdiction under
different or additional statutes, list them below.
B. NATURE FO THE CASE
1) Briefly state the background of your case.
Plaintiff has been persecuted by U.S. Army and FBI for last five
years or filing a sexual harassment grievance against the Army
Propulsion Directorate. In August of 1992 plaintiff filed civil
rights action against the Army, Sec. of the Army, and President
George Bush, U.S.D.C. Newark, NJ, 92-cv-3553, Judege Politan, for
retaliation and wrongful termination. Plaintiff was then repeatedly
threatened and he was entrapped into ..........
(charges deleted)
The FBI and the Army were at the Henderson Jail. Plaintiff was
systematically psychologically and physically tortured while at
Henderson Jail. Plaintiff ws given blanket and clothing that caused
Page 3
section 1983 - Form
eff. 7/92
testicular pain, rupturing of surface blood vessels(bruises) and
extreme emotional and mental complacency. Plaintiff was told that
he "fucked up" with the Army and that the Army had tried and
sentenced him years ago. Plaintiff was repeatedly told that he
was going to be killed in jail.
these comments were initially made by police officers and inmates
at the Henderson jail__Colonel Weden appeared at the Henderson
jail and threatened the student__saying that he had lied to the
Army and they were going to kill him.
Similar occurenesses at the Clark County Detention Center,
plaintiff was repeatedly threatened and told he was going
to be killed. He was systematically whacked(clothes and
bedding that caused testicular and stomach pain along
with a burning sensation of the eyes)
note: once the burning sensation stopped,
when he changed clothes, the student regained some muscle
tone
and railroaded to the Lakes Crossing Center
for the mentally impaired criminal. Staff and
inmates at the Lakes Crossing Center were informed of political
overtones surrounding the plaintiff's case.
Page 4
section 1983 - Form
eff. 7/92
B. NATURE OF CASE
1b) Briefly state the background of your case.
Plaintiff was again threatened repeatedly at L.C.C. and systematic
torture both psychologically and physicallly(clothes causing
testicular pain and burning of the eyes and food causing severe
testicular and gastrointestinal pain).
|
|
Body of Evidence
|
(While at the Lakes Crossing Center the student was used in an
illegal radiation experiment where he was given food that was
treated with radioactive isotopes_____the inmates taunted the
student calling the substance heavy metal and hot sauce.
The substance resulted in extreme burning sensation of the
testicles, eyes, softening of the muscle tissue, softening of
the hair texture, burning of the under-side of the hands causing
all callouses to fall off, change of the bodily
odor from musky to a more feminine sent.
The student wrote a letter to a local physician describing
the symptoms__the physician recommended an endocrynologist__
saying the condition was not normal and there was reason for
conern.
Note the deformed shoulder muscles and the absence of any
noticible back muscles, also, the bicep muscles have
deteriorated to a size smaller than that of the forearm
muscle. The student was involve in physical fitness and body
building since he was a youth__his body was muscular with large
biceps, tapazoidal, pectoral, lats, and shoulder muscles.
Staff and clients aware
of hits and tried to bait plaintiff into aggressively responding.
Psychiatrist and psychologist fabricated competency evaluations of
plaintiff. Staff at L.C.C. blatantly lied about behavior of plaintiff.
Plaintiff ruled incompetent because of governmental politics -
The student called attorneys in the area
(Reno), all of whom stated the student sounded competent to
stand trial
mental health system prostituted for political reasons.
Page 5
Section 1983 - Form
eff. 7/92
C. CAUSE OF ACTION
COUNT I
The following right has been violated: Constitutional right against
punishment that is cruel and unusual.
Supporting Facts: [Include all facts you consider important. State
the facts clearly, in your own words, and without citing legal
authority or argument. Be certain you describe exactly what each
defendant(by name) did to violate your rights].
11-10-92 arrest in Henderson after entrapped .......
Army and FBI at Henderson jail. Plaintiff physically and
psychologically tortured. Guard called it "guerrilla psychological
warefare". Plaintiff given a blanket causing severe testicular pain,
blood vessel damage, mental complacency, and sleepnessness. Plaintiff
always kept in rooms with video cameras; when he would finally fall
asleep, guards would quickly bang on the steel cell walls___ i.e.
"sleep deprivation". Plaintiff was threatened on a daily basis: that
he would be killed in Henderson jail. Shortly after plaintiff left
the Henderson jail(he was moved to C.C.D.C) a young man committed
suicide in Henderson jail. Plaintiff suspects the young man did
not have the mental toughness to tolerate the psychological and
physical abuse. Plaintiff suspects that his behavior was video taped
Page 7
Section 1983 - Form
eff. 7/92
COUNT II
Supporting Facts: [Include all facts you consider important. State
the facts clearly, in your own words, and without citing legal
authority or argument. Be certain you describe exactly what each
defendant(by name) did to violate your rights].
Physical and psychological terrorism continued at the Clark County
Detention Center. 11-18-92 thru 3-5-93. Modules 3F,2B,2C,%B. Plaintiff
given clothing and bedding which caused severe testicular, chest,
gastrointestinal, cardiovascular, and eye pain. In addition to
mental disorientation and loss of muscle tone. Authorities and
inmates knew of hits.
Authorities and inmates know that the plaintiff is a political
prisoner and are assisting the Army and FBI in their attempt to
slowly poison the plaintiff.
Page 9
Section 1983 - Form
eff. 7/92
COUNT III
The following civil right has been violated:
Constitution - God given right to procreation
Supporting Facts: [Include all facts you consider important. State
the facts clearly, in your own words, and without citing legal
authority or argument. Be certain you describe exactly what each
defendant(by name) did to violate your rights].
Acts by authorities at Henderson and Clark County Detention Center
along with acts at the Lakes Crossing Center hae resulted in the
premeditated emasculation - castration of the plaintiff and is
probably the most atrocious example of cruel and unusual punisment
ever inlficted on man. When plaintiff compainted ot staff at
Lakes Crossing Center he was told by the head nurse, David Crowfoot,
that they could emasculate him faster if he wished. A Dr. Hahrt(?)
examined the plaintiff and fraudulently claimed there was nothing
wrong. Plaintiff then wrote to the director of Nevada Mental Health
(Mr. Zadny). A Dr. Fitting was called to examine the plaintiff.
By the symptoms given Dr. Fitting said there was definite need for
concern.
Dr. Fitting took blood and urine samples, after about a week the
student was asked to give another urine sample___the inmates at
L.C.C. were commenting that the student was given too much heavy
metal and that his urine samples came back "dirty"
Also, a private specialist recommended an endocrinologist.
The Nevada Department of Mental Health was trying to cover up the slow
castration of the plaintiff__The Nevada M.H. system is trying to cover
up the emasculation by blaming it on disease or a so called natural
health problem as opposed to the truth - involuntary emasculation -
genocide - and slow death.
Page 10
section 1983 - Form
eff. 7/92
COUNT IV
The following civil right has been violated:
Article VI. The accused shall enjoy the right to a
speedy and public trial
Supporting Facts: [Include all facts you consider important. State
the facts clearly, in your own words, and without citing legal
authority or argument. Be certain you describe exactly what each
defendant(by name) did to violate your rights].
Authorities of Clark County(Law Enforcements and Judicial) involved
in premeditated activities preventing the plaintiff(accussed) from
taking his case to trial. Plaintiff has been incarcerated for over
120 days; plaintiff, has of yet, been to a pre-trial hearing.
Metro police at C.C.D.C.(modules 3F,2B,2C,5B) acting as agents for the
Army and FBI, over the period of 11-18-92 to present, have attempted
to coerce bizarre behavior from the plaintiff by utlizing psychological
and chemical warefare. Authorities then exploited plaintiff's response
to railroad him into being fraudulently diagnosed as mentally
incompetent. Said diagnosis used as legal diversionary tactic to
prevent plaintiff (accused) from defending himself in court. Actions
by authorities constitute a gross obstruction of justice.
Page 11
section 1983 - Form
eff. 7/92
COUNT V
The following civil right has been violated:
Article V. No person shall be deprived of life, liberty,
or property withoud due process of law.
Supporting Facts: [Include all facts you consider important. State
the facts clearly, in your own words, and without citing legal
authority or argument. Be certain you describe exactly what each
defendant(by name) did to violate your rights].
Mr. John Acurio, Col Gilbert Weden, Mr. Peter Meitner, and Ms. Teresa
Kline of the U.S. Army Propulsion Directorate(U.S. Aviation System
Command - St. Louis, MO) are responsible for utilizing the federal
government(FBI, etc...) and agents of the federal government to
control the plaintiff's life and cause intense physical, psychological,
social, and monetary hardship. Since the plaintiff was terminated from
a civilian engineering Army position in 1988 he has been treated as
a "whistle-blower" and blackballed from the work force. All employment
obtained since then has been short term and under the control of the
federal government. Plaintiff was a victim of defamatory media coverage
in 1989 by Army. Federal government's actions(including current
entrapment) purposely resulted in the deprivation fo life, liberty,
and property without due process of law.
Page 12
section 1983 - form
eff. 7/92
D. PREVIOUS LAWSUITS AND ADMINISTATIVE RELIEF
1) Have you begun other lawsuits in state or federal courts dealing with
the same or simialr facts involved in this action? If your answer is yes,
describe each lawsuit.
a) Parties to pervious lawsuit:
Plaintiffs: Wayne Manzo
Defendants: U.S. Army Propulsion Directorate, Sec of Army,
Dick Cheney, President George Bush.
b) Name of court adn docket number: U.S.D.C. 3rd District,
Newark, NJ
cv-92-3553(NHP)
Note: cv-92-3553 was the real reason the
student was incarcerated and tortured in Nevada
c) Disposition(for example, was the case dismissed, appealed or
still pending?): Pending.
d) Issues raised: Retaliation by federal government for plaintiff
filing EEO grievance and civil rights action.
e) Approximate date it was filed: August of 1992
2) I ahve previously sought informal or formal relief from the proper
administrative officials regarding the acts alleged in Part C.
Briefly describe.
Authorities and other participants are working together to violate
the plaintiff's civil rights. Plaintiff is using the courts to try
and stop the defendants from continuing their draconian tactics.
E. REQUEST FOR RELIEF
I believe that I am entitled to the following relief:
1) Punitive and compensatory damages of $100,000,000
2) Dismissal of state charges resulting from premediated federal
entrappment.
3) Opening of "classified" files pertaining to surveillance
and behavior control of plaintiff.
______________________
Signature of Plaintiff
April 23, 1993
|
