> Charles August Schlund, III
> 8520 North 54th Drive
> Glendale, Arizona 85302
> (602) 670-2017
> Plaintiff in Pro Persona

> ## IN THE UNITED STATES DISTRICT COURT
> FOR THE CENTRAL DISTRICT OF ARIZONA

> #### CHARLES AUGUST SCHLUND, III, an individual,
> Plaintiff,
> v.
> GEORGE W. BUSH, President of the United States of America, a sovereign nation; GEORGE W. BUSH, an individual; DOES 1-10, individuals; DOES 11-20, entities,
> Defendants.

> #### No. CV03-1590 PHX VAM
> NOTICE AND MOTION FOR ORDER FOR INJUNCTIVE RELIEF FROM TORTURE AND INTERFERENCE WITH FREEDOM OF SPEECH TO STOP IRREPARABLE HARM; MEMORANDUM OF POINTS AND AUTHORITIES AND AFFIDAVIT OF PLAINTIFF SCHLUND IN SUPPORT THEREOF AND ORDER THEREON;

> Charles August Schlund, III, ("Plaintiff Schlund") respectfully moves the Court for an Order for Injunctive Relief to terminate the continuous irreparable harm caused by the Defendants, the Government, including Does 1-10, individuals and Does 1-20, entities, (collectively referred to as "Government") use of electronic torture activities of using various electronic methods to egregiously cause irreparable torture to Plaintiff and cause injuries and damages to Plaintiff. The electronic based torture methods and activities result in the use of sound, vibration, heat, electric and other kinds of or energies and radiations which effect and interfere with Plaintiff's normal life activities and cause extreme pain and suffering (TORTURE) of Plaintiff Schlund.

> If the court needs evidence that torture is possible and factual, Plaintiff is prepared under the court's rulings in Siderman DeBlake v. Republic of Argentina, 865 F. 2d 699 (9th Cir. 1992) and Doran v. McGuinness 158 F.R.D. 383 (1994) to demonstrate such methods and torture. Plaintiff requests the court to order an evidentiary hearing under Doran v. McGuinness, 158 F.R.D. 383 (1994) to demonstrate precisely how various methods and techniques of remote electronic based torture and other methods of it are used on Plaintiff Schlund, as a political witness, his witnesses, family and associates, in violation of their constitutional rights and international law.

> DATED this _____ day of August, 2003

> By: ______________________________
> Charles August Schlund, III
> Plaintiff in Pro persona

> #### I. PROCEDURAL STATUS OF CASE

> Plaintiff Schlund has properly filed his Complaint on August 15, 2003 and served it on all Defendants on August 18, 2003.

> #### II. STATEMENT OF FACTS

> #### Prefatory Statement.

> Plaintiff Schlund incorporates by this reference his Verified Complaint filed August 15, 2003. No legitimate American Court would refuse to hear a Motion to Terminate the Torture of an American citizen. Siderman DeBlake v. Republic of Argentina, 865 F. 2d 699 (9th Cir. 1992) at p. 20, infra.

> Plaintiff's case and related issues of electronic invasion of privacy and electronic and other forms of torture are NOT of first impression before the Court, infra. There are similar types of torture, illegal surveillance and invasion of privacy decisions which are consistent in the various circuits of the United States, especially the 9th Circuit Court of Appeal rendering both relief and damages. Plaintiff's case is unique, raising the collective issues of torture by electronic force, and improper installation of electronic devices in Plaintiff's body, resulting in life threatening, civil rights violations, personal injuries, invasion of privacy, sleep deprivation and deprivation of freedom of speech, right to vote, freedom of religion and other human and civil rights and international law violations. This includes violations of the Protection Against Torture Act.

> The Government has taken the position that any victim of government electronic torture who complains of such torture is accused of trying to evade the Government's investigation of them by asserting they are being tortured. Plaintiff Schlund asserts he has not attempted in any manner whatsoever to avoid any investigation by the government. In fact, Plaintiff Schlund requests the court to order the following in an effort to terminate the ongoing fabricated investigation and order a real investigation subject to the following conditions:

> > 1. Order the amount of $50 million a year to start a new investigation by the U.S. Government to insure a successful conclustion of the investigation of Plaintiff Schlund.

> > 2. Order not less than 50 new agents be assigned to the new court ordered investigation as set forth in No. 1 above.

> > 3. Order Plaintiff Schlund to fully cooperate with the 50 newly assigned agents and the newly ordered legitimate investigation ordered by the court. And, Plaintiff agrees to waive any rights that the court requests of him that the court feels is necessary to successfully find the truth.

> > 4. The court is to ensure that the agents involved in this investigation are not politically motivated to frame Plaintiff Schlund. The agents should be picked by a lottery or computer program to ensure that they are not picked as political thugs to frame Plaintiff Schlund.

> As stated herein, the highest federal courts have acknowledged that torture by Government officials or agents is not new but a very well known fact. Also, a well known fact is that its known sources and the torture is never admitted by governments. Siderman v. DeBlake, infra. This is the case here.

> The Government's motive is discrimination and retaliation on grounds Plaintiff is branded as a "political witness"/"whistle blower" against powerful and political people in the Government. Plaintiff Schlund is a "political witness" whose whistle blowing activities of Government corruption based on Plaintiff Schlund's personal knowledge involving persons in the Department of Justice ("DOJ"), the Drug Enforcement Administration ("DEA"), Department of Alcohol, Tobacco and Firearms ("ATF"), the State of Arizona and other federal, state and local law enforcement agencies, also collectively referred to as "Government", is a factual reality of said known sources as more fully expressed below.

> Plaintiff Schlund was working with the FBI when he was physically gassed in his sleep and physically attacked and restrained forcibly against his will, injected with CIA designed electronic "subcutaneous implants" used by both the CIA and DEA and others. These multipurpose implants are used to severely physiologically inflict punishment and psychologically torture and disable Plaintiff Schlund with cruel and unusual punishment (TORTURE) in blatant violation of his constitutional rights.

> Plaintiff is an ex-Vietnam veteran who, upon discharge from the United States Marine Corp., was solicited by Drug Cartel members for the Central Intelligence Agency (1968) (later, the Drug Enforcement Administration - "DEA") (1977) to carry out their agenda. Due to the corruption activities of the CIA and DEA agenda, Plaintiff, after acquiring personal knowledge of the reality of such agenda, rejected and refused to work for them. Plaintiff was offered money and power including the ability to gas and torture and/or rape any girl that turned Plaintiff down for sex. All of this was offered under the color of law using warrants in drug investigations issued by the Surveillance Court and other courts.

> Upon Plaintiff Schlund's refusal, Plaintiff was targeted and placed under constant surveillance and repeatedly set-up by the corrupt Government person(s) to torture Plaintiff and to control the information substantiating the serious Government corruption which he knew about and possessed information on.

> Plaintiff was then forced by the Government to become a whistle blower due to the Government's attacks against him ("whistle blower activities"). As he began his whistle-blower efforts pertaining to the corrupt governmental activities of the CIA, and DEA, law enforcement and others, he found himself suddenly framed as being an alleged drug dealer, murderer, gun runner, smuggler and thief and placed under intense investigations (as the Government made it obvious he was being selectively targeted).

> The Government then fabricated evidence, and then arrested and charged Plaintiff for alleged conspiracy to manufacture illegal drugs. The federal prosecution of Plaintiff Schlund was extraordinarily aggressive. Its key witness was the DEA's own agent/informant/drug chemist and manufacturer, Carl Altz a.k.a. John Green.

> The Honorable Judge Lacey, who was a visiting judge to the United States District Court of the District of Arizona was assigned to the trial of Plaintiff. The Honorable Judge Lacey found that the DEA had committed perjury and obstructed justice and framed Plaintiff Schlund and demanded their arrest after acquitting Defendant Schlund. Judge Lacey called the DEA's conduct "outrageous conduct" of the United States - Plaintiff was "acquitted" on all counts. The acquittal judgment was upheld on appeal.

> The Government's surveillance, torture and other violations of Plaintiff Schlund's constitutional rights is in retaliation for Plaintiff Schlund's refusal to join the Government's corruption, has continued for twenty-five (25) years resulting in electronic monitoring and torture of Plaintiff Schlund. It has been continuous and ongoing by electronic force and other electronic systems and methods to monitor Plaintiff Schlund's daily activities, invading his and those he communicates with privately, especially where there exists normal and legally expected zones and orbits of privacy, and to harass, retaliate, torture, deprive of sleep and attempt to discredit Plaintiff as a political witness for his whistle-blowing activity of exposing the Government's corruption based on his personal knowledge and from what Plaintiff read in the CIA, DEA and other files he has always called the "Don Bolles Papers."

> #### Statements from Charles A. Schlund to the Federal Courts.

> The Court should first understand that Plaintiff has been under constant torture and surveillance and under many different investigations since reading the CIA and other files that Plaintiff has always called the "Don Bolles Papers". Plaintiff read these government files in 1977. The Bolles Papers were all the papers that George Bush Sr. had removed from the Government when Jimmy Carter was elected to the presidency. These papers were removed to stop President Jimmy Carter and those he would appoint from obtaining the contained information on Government corruption. The director of the CIA George Bush Sr. removed these documents from the government in 1976. Plaintiff has been under constant surveillance, not to collect information for the prosecution of him for some crime he purported has committed, but to authorize the use of torture and collect information to be used to discredit Plaintiff as a political witness due to his political witness status and activities. The Government has no intent on ever arresting Plaintiff Schlund.

> A very small portion of the information collected on Plaintiff Schlund is real and most of the statements or recordings taken from him were made under torture by the Government. The torture was done to force him to make the statements to the Government that it desired after he had been tortured close to death by the Justice Department and/or others. Most of these conversations were taken from Plaintiff Schlund under torture and agreed to by Plaintiff as a condition in exchange for relief from the torture or in exchange for sleep. These conversations were then submitted to the courts by the Government under perjury or falsely or out of context to reality by the DOJ, DEA and others. Many of these conversations were recorded while Plaintiff was working with the FBI setting up corrupt agents in the DEA and other federal and state departments and/or agencies and the courts.

> Many of these conversations were taken after depriving Plaintiff of sleep for years with the Government only allowing Plaintiff a few hours of sleep a week. As an aside, if the Government denies any of this, Plaintiff demands to be allowed to prove that such electronic force and technology for the use of torture is not only possible but can be demonstrated to the court. Plaintiff Schlund, by way of example, would need a human subject to demonstrate these kinds of torture on and recommends Robert C. Broomfield be one of the people used for these demonstrations. Broomfield was one of the corrupt judges that Plaintiff had been secretly supplying criminal information on to the FBI many years before he refused to recuse himself from Plaintiff's lawsuits upon challenge by recusal motions. Broomfield then decided Plaintiff's lawsuit and motions knowing that Plaintiff was a witness against him and ruled on the lawsuits using made up facts and statements that were never pled in any of Plaintiff's lawsuits or motions.

> In violation of F.R.C.P 52, Broomfield failed and refused to make findings of fact and conclusions of law as Plaintiff continuously requested in [all] of his pleadings, motions and responses. He did this to further cover-up his criminal acts as asserted by Plaintiff. These rulings were done using a federal rules decision case out of jurisdiction and off point; the case law of Doran v. McGuiness, 158 F.R.D. 383 (1994). Plaintiff Schlund now wishes to use the Doran case law to prove his case. The court is requested to authorize Plaintiff to conduct the medical procedures on Broomfield for the electronic torture demonstrations (pursuant to the Doran decision to prove electronic torture is an electronic engineering reality) as the Court has authorized similar procedures on Plaintiff's witnesses, family, friends, associates and Plaintiff. In fact, no technology is required to torture or murder people being placed under investigations. All that is required is the court's authorization to perform secret procedures on these sleeping people after placing them in a state they can not wake from while authorizing these crimes by the Government under real or created investigations. The corrupt judges of the court then only need to stop any legal proceedings from those they are torturing and pretend that they are guilty of some crime which authorized the court to secretly commit these secret medical procedures on them. The corrupt judges of the court and the corrupt agents can then continue to violate a person's Constitutional rights and cover up their illegal corruption and crimes. In the Justice Department, Surveillance Court, DEA, CIA, FBI and other files Plaintiff read were authorizations and legal opinions on the injections and/or implantation with implants of many famous and important people.

> Plaintiff believes that Broomfield as a judicial representative of the court committed deceit while using the ruling of Doran v. McGuiness, 158 F.R.D. 383 (1994) in Plaintiff's case. [Doran claimed he heard voices through "mental telepathy" connected to claims of electronic implants.] This ruling gives the impression Plaintiff Schlund agrees that mental telepathy is possible, which he does not. Let this court fully understand that Plaintiff Schlund has never asserted mental telepathy and does not believe mental telepathy is possible. Plaintiff Schlund factually knows from information supplied by the Government itself that the Government uses electronic methods and instruments, including electronic devices to conduct surveillance and other methods to conduct such information gathering, to transfer their voices, sounds and force to torture a person using such electronic system(s). The Government always asserts against such targeted persons that he/she may be a lunatic asserting "surreal and fantastic" claims, despite the claims are mathematically easy to factually prove against the individuals conducting the illegal intrusions using electronic mediums to piggyback off existing established platforms and instruments owned and paid for by others (factually proven in Koyomejian v. United States). Since the Koyomejian decision and others, the DOJ and DEA have intensely attempted to guard their electronic systems' capabilities and activities from the public while violating the rights of individuals and entities in Arizona and elsewhere in the United States. The covert nature of this fact is to mislead the public and suppress knowledge to the public and prevent individual liability to said persons who utilize the technologies for surveillance and torture activities which violates Plaintiff Schlund's and others' constitutional rights.

> The Defendants know that the use of implants to remove political witnesses is the perfect crime. It can be denied under the cover of law to protect fabricated or real investigations and the technology used cannot be reverse engineered by anyone other then governments or the corporations that secretly work with or for them. Plaintiff Schlund does not have access to super conductors or secret power sources like plutonium or other types of secret power supplies or batteries but Plaintiff can easily prove that the technology exists and can make a paper airplane to show jets can fly. Expert witnesses, eye witnesses, testimony and demonstrations are all that is required to prove that the electronic basics exist, and are being used by the Government and that the torture is real and conducted and controlled by the Government to attempt to cover-up their crimes not the crimes of Plaintiff Schlund, but their crimes and electronic gamesmanship that hurts others, as well as Plaintiff Schlund.

> Plaintiff Schlund reminds the Defendants and the courts that when the Nazis under Hitler injected the Jews in their necks after taking them into custody, that the Nuremberg trials convicted these criminals for Crimes Against Humanity. It was never determined what they injected but only that the injections were done under the cover of law against the will of those being injected and that the injections made them sick or resulted in their torture or suffering at the hand of the government. This is what happened to Plaintiff Schlund and the same words can be used that convicted the Nazis of similar crimes. Plaintiff Schlund understands that laws are only used against the enemies of the government and never against those protected by the government. In other words, if Plaintiff Schlund was to commit this same crime, he would be prosecuted and imprisoned but the government employees are above any laws because they commit their crimes under the authority of a warrant. The Government's employees are protected and are above any laws as they offered Plaintiff Schlund if he joined them.

> Let this court and the Defendants fully understand that Plaintiff Schlund read the Nazi research from the concentration camps using sounds to torture, this was in the CIA files in the Don Bolles Papers and Plaintiff understands how and why the government designed these torture devices to destroy the lives of innocent whistle blowers and political witnesses like Plaintiff. Plaintiff Schlund had all the research and the designing and manufacturing files from the CIA, DEA and NSA and all the files from the Surveillance Court, Justice Department and others on the use of these weapons under the cover of law against innocent Americans.

> > 1 "Injection" is used here as a general description of intrusion upon, in and on the human body by physical insertion or which intrinsically naturally absorbs energy whether exposed to sound, chemical, radioactive, electronically generated, etc.

> All of this is provable in a trial but not before a corrupt judge who is being paid to stop a trial or any other legal proceedings to protect the corrupt judges and agents and those they work for, like George W. Bush. In a fair trial before a non-corrupt judge, the government would have no chance of disproving assertions made by Plaintiff.

> From what Plaintiff Schlund has learned and understands, he was, and continues to be, under a fabricated investigation for alleged drug manufacturing, drug smuggling, drug dealing, mass murder, gun running, thievery and for other crimes. In truth, Plaintiff Schlund has never made any drugs nor has he ever smuggled any drugs or chemicals into the United States. Plaintiff Schlund is not a drug dealer and has never killed anyone. He has never run any guns or sold any guns that were, to Plaintiff's knowledge, to be used or sold illegally to anyone. Plaintiff Schlund does not steal and is as good of a citizen as he can possibly be while he is under torture by the corrupt judges and corrupt agents of the federal and state government.

> Let the court fully understand that Plaintiff Schlund does not possess the knowledge to make any drugs and never has and only knows what the DEA had Carl Altz/John Green who worked for them tell Plaintiff. Plaintiff Schlund has been framed and already tried in a federal trial with the federal court acquitting him and the Judge calling the government's activities of framing him outrageous conduct of the United States. The federal court demanded the arrest of the agents involved in Plaintiff Schlund's arrest and prosecution for obstruction of justice and perjury in the framing of Plaintiff to remove him as a political witness.

> In Plaintiff Schlund's 1978 trial, the DEA and Sheriff's Office did threaten to murder the children and wife of Plaintiff's first witness, Bob Snow, if he dared to testify for Plaintiff and had also threatened Plaintiff's second witness, William Schlund with prosecution if he dared to testify. These threats against Plaintiff Schlund's witnesses continue to present with the courts and government agents continuously making threats by various means, including the use of electronic force for the intended purpose of selectively targeting such witnesses, including continuous threats against Plaintiff and his witnesses and their children.

> Plaintiff Schlund's witnesses and their children have been electronically monitored and physically trespassed upon, threatened and tortured through electronic and other used technologies designed for this and other purposes. These corrupt agents threaten such witnesses and Plaintiff Schlund by using electronic implants and torture.

> Other witnesses of Plaintiff Schlund have been assassinated. Only a Nazi court could allow this kind of Obstruction of Justice and Witness Tampering under the cover of law. Many of Plaintiff Schlund's witnesses are now in fear for their lives or their wife's and children's life and the government continues to harass witnesses and dissidents that are threatening to them to protect the Bush family and others as they plunder the treasury of the United States and use the Justice Department to remove the political witnesses and dissidents, as set forth in the Bolles Papers.

> The court should further understand that others, including the DEA, have repeatedly threatened to murder Plaintiff Schlund if he dares continue these lawsuits and have tortured him continually for the past 25 years since Plaintiff refused to join the DEA and help in the many political assassinations and the running of the drugs and the fixing of elections.

> The DEA solicited Plaintiff Schlund to kill some young girls they had been providing to Federal Judge William P. Copple for sex. This was in 1977, after the DEA had offered Plaintiff Schlund a position in the DEA. When Plaintiff refused, the government targeted and tortured him. After Plaintiff Schlund's arrest, Judge Copple was assigned to Plaintiff's trial. Judge Copple then removed himself the day before Plaintiff was to file the recusal against him for being a corrupt judge detailing what Plaintiff had read in Judge Copple's CIA file in the files Plaintiff has always called the Don Bolles Papers.

> Let the Defendants fully understand that Plaintiff Schlund was briefing the FBI on the CIA and DEA plans to fix the presidential elections of the United States when Plaintiff was injected with CIA designed implants to torture him. The surveillance court and other courts refer to these devices as monitoring devices and pretends they are using these devices in real investigations. Any witness complaining of torture is discredited and the Government claims that their claims of torture are only their attempts at escaping the Government's investigation. If the court chooses to deny this, Plaintiff Schlund demands under the ruling of Doran v. McGuiness, supra, to be allowed to remove two of the devices in trial or under the supervision of the Court and videotape the removal to prove that the devices are real. Plaintiff Schlund does not know the location of other devices that were also installed in Plaintiff by the government. The removal of only two devices will not stop all of Plaintiff's torture and other devices were also installed and if Plaintiff removes the devices that he knows of, others will be injected under the protection of corrupt judges of the court. The court can subpoena the DEA and person(s), including Agent John Albano, into court to testify to their injection of Plaintiff Schlund and can subpoena the FBI, including Agent Adam S., into court to testify to the devices being CIA devices.

> Plaintiff Schlund has found that the court always runs from the truth and never looks for the truth and always just tries to make the person being tortured look like they are crazy or involved in some crime. Justice and the truth are easy to find. It is easy for the court to subpoena the government agencies into court to document the truth. The court can also just call George W. Bush's corrupt appointees into court to do the cover up.

> Further, Defendants and the courts are on notice to understand that many records held by the DEA and others are not real and do not represent the truth and were obtained by the DEA committing perjury to the court to obtain the warrants. Plaintiff Schlund believes the same to be true with regard to the ATF and other files. Plaintiff Schlund believes that the ATF files were generated to protect the DEA and cover up the DEA's taking of Plaintiff's guns while Plaintiff was working with the FBI and the guns were then used in assassination attempts against Plaintiff and were to be used as "throw down" weapons after Plaintiffs assassination by the government. When Plaintiff called the police to report these guns missing, the Phoenix police called the FBI and then called back Plaintiff and told Plaintiff that they could not take a police report because the guns were taken by federal agents of the DEA and that they were above the authority of local police and that this was a federal matter that the FBI was aware of. The FBI could not act on these crimes because Janet Reno was secretly working for the Bush family and protected the DEA as John Ashcroft now does. The FBI, IRS and the other agencies stopped all of the assassination attempts against Plaintiff but the torture of Plaintiff continues because the torture is done under the cover of law in surreal and fantastic investigations authorized under perjury and conversations obtained from Plaintiff while being tortured for the conversations or in exchange for relief from torture. These conversations were then submitted to the court under perjury.

> While Plaintiff Schlund's family was asleep in their home and also while in Mexico on fishing trips, the DEA used a gas on Plaintiff and his family to place them in a state that they could not wake up from. This gas was used on the small children of Plaintiff and others which resulted in placing them in a state where they were unable to resist or awaken that allowed the government to violate them as they pleased.

> The DEA would then inject drugs into the bodies of Plaintiff's family and him. These drugs kept them in a drugged state where the government could hypnotize Plaintiff and his family and others and then make them perform certain tasks for the government to take photos of them so the government could generate fabricated and false evidence against them to discredit them to cover-up the crimes committed by the government. This was done to cover-up crimes that Plaintiff Schlund and his wife had witnessed or had personal knowledge of. These crimes were committed by the government.

> Sometimes Plaintiff and his family would be kidnapped by force from their home and would be drugged and kept in a drugged state by the DEA for up to three days at a time. During these kidnappings the government would repeatedly and continually work on them with drugs and hypnotize them to make them perform acts for the government as needed to force them to do things so the government could take photos and films of them to discredit them and remove them as credible witnesses against the Bush family and those that worked under the Bush family doing political assassinations, running drugs, money laundering and fixing public elections.

> After these photo and film sessions Plaintiff and his family would be returned to their home and would wake up in their beds like nothing had happened. Sometimes, upon waking up, Plaintiff would still have the cotton ball on his arm where the IV had been removed from his arm. Other times, he would be injected in his foot with the antidote to the drugs that he was kept on during these drugged interrogation and/or filmed sessions.

> Plaintiff's innocent children would miss school and he would miss work during these political kidnappings and they would all wake up at the same time. Sometimes they would wake up in the morning and other times they would all wake up at 6:00 p.m. or 9:00 p.m. with up to three (3) days having expired while they were in this drugged state held by the government.

> In Mexico, Plaintiff and family did wake up on the beach at 1:00 p.m. on an August day with the temperature around 120 degrees. They would be suffering from dehydration and unable to account for any of the missed and elapsed time. Friends that were on the fishing trip with them would also wake up at the same time and ask what happened. We were all gassed that night by the DEA. All of their personal items and things would be gone and they would later receive them back in the mail after returning to the United States.

> During these drugged programmings and interrogations by the government, Plaintiff would be hypnotized and directed to make a statement when a key word was later spoken. This allowed the government to record these statements to attempt to prove he was guilty of things which in truth he had no knowledge of or part in.

> If the court claims such procedures are impossible, Plaintiff would be happy to demonstrate these procedures and gas, drug and hypnotize someone for the court and have them make a conversation for the Court. The ruling of Doran v. McGuiness, supra, gives Plaintiff the right to do such demonstrations. Plaintiff does not claim that such procedures are safe or legal but they are possible especially when they are done by the government with the power of the Justice Department behind them and the cover of law to stop any lawsuits if the people die or are injured during these Nazi like procedures. In the CIA files we had in the Don Bolles Papers many people had died during these procedures and were continuing to die under the protection of corrupt judges of the court.

> The kidnapping of Plaintiff's family and Plaintiff stopped in 1991 after Plaintiff went to the FBI and asked them to monitor him. At the same time, Plaintiff gave the FBI permission to monitor him without a warrant. Plaintiff found this necessary after the Glendale Police Department and Phoenix Police Department refused to accept murder reports from Plaintiff after the government had people murdered in Plaintiff home to threaten his wife if she continues to try to help Plaintiff. These murders were done under the surveillance and direction of the government. The DEA and others still would gas Plaintiff and his family and friends for implant injections but he would no longer be removed from his home for photo sessions. In the 1990's, the use of torture replaced the programming and instead of programming Plaintiff to make conversations for the DEA or police, they would torture him to force him under torture to do similar conversations. All of Plaintiff witnesses and family and friends were also injected and some were threatened, stimulated, manipulated or tortured so the government could cover-up it's Nazi like crimes.

> During the 1990's, Plaintiff telephoned the DEA over one thousand (1,000) times and wrote them many letters, complaining of the torture of his witnesses and himself. During these telephone calls, the DEA agents fully admitted injecting Plaintiff. Agent John Albano of the DEA even gave Plaintiff permission to remove the implants to stop his torture but his authorization was overruled by higher-ups in the chain of command in the DEA and Plaintiff was not allowed to remove the implants.

> During this same time, the FBI called Plaintiff Schlund and informed him that the implants torturing him were CIA implants. The Court can contact the Phoenix office of the FBI and demand to have Agent Adam S. appear before the Court to testify that the implants are CIA designed torture devices for the removal of political witnesses and political prisoners of the United States.

> Plaintiff Schlund began to file medical, electrical and engineering patents and evidence into the Arizona District Court of scientific proof and data confirming these high tech CIA designed and DEA used electronic implants. The government fabricated evidence and moved for summary judgment and increased the torture.

> Plaintiff Schlund filed with the District Court undisputed evidence of "implant" electronic technology now commonly used for medical and other purposes. Also filed was electronic technology used for the purpose of tracking almost every kind of animal life form roaming the globe. Specifically, he submitted information as an example of wireless technology devices embedded in the collar worn by a hunting dog which roams freely while hunting mountain lions. When the dog's owner wishes the dog to return to base camp, he presses a button on his transmitter which sends a shock signal to the dog, compelling it to immediately return to the base camp. If the dog does not respond, a longer shock signal is transmitted to the dog collar, resulting in a harsher and more punishing shock stimulus to the physical body of the dog in the form of physical punishment. The shock punishment is a form of operant conditioning which the dog learns that in order to eliminate the shock, he must immediately return to the base camp when commanded to do so by the person who holds the shock transmitter and is inflicting the punishment. Because the technology is wireless in nature, the dog owner can be at any remote location and inflict the punishment on the dog. If the collared receiver was embedded subcutaneously under the dog's skin, you would not see it. If you did not know the dog was embedded with the "implant" and suddenly the implant received a transmitted shock signal inflicting the punishment on the dog, you would see the outward manifestations of the punishment in the dog's eyes and his physical reactions to it while not knowing what's causing it. You would erroneously conclude the dog is crazy or perhaps has some mental illness when the reality is; the animal is being tortured through means of wireless electronic force technology, in a covert manner from many miles away. Plaintiff Schlund set forth the various types of wireless integrated technologies which can be used for such purpose, all of which are scientifically accepted in the electrical and biomedical engineering community. He never mentioned the word of "mental telepathy," which has no scientific basis at all.

> Plaintiff Schlund also pled, in great detail a specific itemization of his injury and damages, supporting the irreparable harm to him personally and economically. He pled the government's conduct has resulted in creating life-threatening injuries, including, however not limited to, sleep deprivation, electric shocks, torture with unnatural horrible, extremely loud sounds, loss of a thumb, extreme and crippling pain in his head and on or about his body, types of caustic burn from the heat or radiation generated from the electronic and other forces on impact. And during the duration of time of exposure, loss of earning capacity, Plaintiff became diabetic from being deprived of thousands of nights of sleep year after year, loss of earning ability, destruction of his peace of mind, harmony and the right to be left alone, a burgeoning lack of trust in the government and the judicial system, loss of consortium, injury to his children, incurred medical and other personal and business expenses, and continues to experience pain and suffering (TORTURE) and will continue to suffer physically, psychologically and emotionally, resulting in irreparable permanent harm from the torture which detrimentally affects his freedom of speech, privacy and other civil rights. Injuries suffered from the torture of Plaintiff Schlund are to date great enough that Plaintiff will die from these injuries. During one of Plaintiff Schlund's doctor's visits, his blood pressure was 223 over 121. Let the court fully understand that Plaintiff Schlund's blood pressure was normal when he was injected with the implants.

> Plaintiff Schlund's extraordinarily high blood pressure, while on massive doses of blood pressure control medication, has damaged Plaintiff's internal organs. This degree of torture is an act of terrorism. Any time Plaintiff Schlund says anything the government doesn't like, Plaintiff is tortured resulting in extreme pain and his high blood pressure and further damage to his body.

> Let the court fully understand that Plaintiff Schlund's blood pressure returns to normal during the time the government reduces its torture of him. This type of terrorism is more than just outrageous conduct of the United States; it is murder and cruel and unusual punishment.

> #### III. LEGAL DISCUSSION

> #### A. Injunctive Relief is required to terminate the government's torture, intrusion and violation of Plaintiff by the use of electronic forces that violate Plaintiff's Constitutional Rights.

> #### 1. Torture

> No government activity justifies implants and torture to succeed. It has been proven in Plaintiff Schlund's case that such use of torture and implants has stopped any chance of the government successfully concluding their fabricated investigation.

> The Ninth Circuit Court of Appeals, as Plaintiff Schlund has reminded it, issued harsh warnings and deeply rooted concerns that the present status of sophisticated scientific and technologically advanced devices used by the government under color of authority, such electronic force excessively intrudes and trespasses to grossly violate rights to privacy, especially as to other person(s) coming in contact with the subject target of the surveillance/torture activity - U.S. v. Koyomejian, 97 F 2d 536 (9th Cir. en banc), cert. denied, 946 F. 2d 1450 (1991) [Koyomejian prevailed in the criminal context as well.]. In Plaintiff Schlund's case, privacy means nothing because torture has overcome all other concerns despite federal law protects against both.

> The United States Supreme Court itself acknowledges the fact that any individual can be placed under 24-hour surveillance anywhere in this country, without judicial knowledge, supervision, or consent (search warrants); it does not necessarily suggest abuse by the government, citing its decision in Zurcher v. Stanford Daily, 436 U.S. 547, 566 (1978). The same Supreme Court issued its confirmation of the sophisticated electronic abilities over 25 years ago (1978-2003). In the same breath, the Supreme Court responsibly tells the government through its decision that "If such dragnet-type law enforcement practices has responded and visions should eventually occur, there will be time enough then to determine whether different constitutional principals may be applicable." (Ibid.) Plaintiff Schlund was acquitted because of just the exact type of "dragnet-type law enforcement practices" referenced by this honorable Supreme Court as "being without judicial knowledge of supervision" United States v. Knotts, 460 U.S. 276 (1983). Moreover, this Court stated that such sophisticated signs and technologically advanced devices used by the government under color of authority for the purpose of intrusion/trespass have been dealt with on a limited basis in the case United States v. Lee, 274 U.S. 559 (1927), as cited in the Knotts case. It also cited its Zurcher v. Stanford Daily, 436 U.S. 547, 566 (1978) conclusion as such enhanced surveillance succeeds fortuitously and unreasonably into the private sphere protected by the Fourth Amendment without control, at 662 F 2d at p. 518. Despite these Supreme Court decisions, and the Ninth Circuit Court of Appeals' own decisions, the advanced and sophisticated level of the technology, which is wireless in nature, is used to systematically and covertly retaliate and torture a person, especially when motivated by vengeance or even pure delight of having the power to do so - believing that they are protected by the courts under the law. And if caught, as acknowledged by the Ninth Circuit Court of Appeals, the Government always denies it intentionally tortured its own citizenry. See, Siderman DeBlake v. Republic of Argentina. 965 F 2d 699 (9th Cir. 1992) [The court acknowledged, no doubt, with the onslaught of advances in technology, new devices will be created which the government will use as well for less than honorable purposes.] The old cliché, "Where there's a will there's a way." or whatever the government's justification is for the need and use of electronic force technology to torture a person, is in existence today and is widely used to torture political witnesses, such as Plaintiff Schlund. The Appellate Court also took notice that devices of torture are already in existence for some beneficial purpose and then converted to a torturing device (i.e., cattle prodder). The same is true with these implants.

> There is no dispute that electronic force is destructive, especially when used in a manner to inflict serious physical and psychological harm, as revealed in detail by Plaintiff Schlund. "Electronic force" is a general means of power, strength, impetus, intense effort, an artificially enhanced increase in strength, power, or influence, causing a change in the motion, body, object, or substance of intensity of energy in the make (a way) by force to penetrate, join, separate, or integrate with, to add or extract something from the original source, cause, produce, or obtain by effort, seek quick results from voluntarily or involuntarily, accelerate (energy), etc. (Oxford Dictionary of current English, 1998).

> Plaintiff Schlund's verified complaint is relevant, signed under oath per Federal Rules of Civil Procedure, Rule 11, that he has experienced the extreme physical and emotional pain and suffering of the torture and the violation of his Constitutional Rights. That the government's activities of using the sophisticated electronic technologies/devices have hurt, injured and caused him "extreme" pain and suffering both physically and psychologically (Verified Complaint) including loss of trust in the United States government which is especially hurtful for depriving him of serious constitutional rights.

> He expresses in detail in his Complaint that the individual officers have used "improper, excessive, and unjustified force", violating his United States and Arizona constitutional rights. He asserts that the government's "improper, excessive, and unjustified force" is the "direct and proximate cause" of his "sustaining intermittent life-threatening injuries".

> Plaintiff Schlund, in layman terms, has expressed that during the torture sessions of him, he is able to utilize his innate natural senses to allow him to feel, smell, see, hear, touch and physically be aware of when his physical body is being touched and affected by an outside energy stimulus which has the capabilities to transfer energy, including sound, which has the severe result of psychological and physiological deterioration of his mind and body when the Government is torturing him in that manner. "The Ninth Circuit Court of Appeals' clear understanding that the sophisticated and complex electronic surveillance and other electronic [devices] can be 'used in tandem with surveillance technologies' and 'other electronic devices' or 'other sophisticated electronic surveillance devices ought not be permitted in a free society." (Id. Koyomejian) Plaintiff Schlund alleges the United States has not yet become Nazi Germany, but if this is allowed by the Court to continue, we will be no different than that of Nazi Germany. Plaintiff Schlund has also detailed that during the torture sessions he suffers from, included however not limited to, forced sleep deprivation, pain and suffering throughout his body, headaches, nausea, screaming in his ears, violent shaking of his body and intra-cranial cavity, his eyes extremely ache and feel like they're going to explode, experiences severe diarrhea, expectorates blood and experiences blood coming from his anus. His teeth have cracked from the sound and electronic force vibration and fell apart and he has been blinded and so psychologically distracted due to intolerable and joint inflictions of the torture and surveillance distraction that his left thumb was torn off by a machine he was working on, causing the immediate primitive amputation of his thumb. This happened after Plaintiff Schlund repeatedly informed the government that the electronic mode they were using was blinding him when it was turned on. After arriving at the hospital in Phoenix, Arizona, the on-staff physician polished up the primitive amputation of his thumb by the machine, exacerbating the excruciating pain and suffering experienced by him as well. The aforesaid is irrefutable, irreparable harm to him. Plaintiff Schlund leaves here to supplement this motion with his affidavit.

> He voices that the extreme nature and degree of the infliction of torture punishment on him by the government prevents him from handling his normal business duties and responsibilities. The torture of Plaintiff Schlund was so heavy on Election Day that Plaintiff was unable to vote because he was prevented from voting by the use of torture.

> Plaintiff is right now being forcibly stopped by the Justice Department from serving on jury duty. Plaintiff was called for jury duty just the other day and the torture of plaintiff is forcing plaintiff under torture to not be able to serve on jury duty.

> It has also violated his freedoms of association and privacy and those associations, including speech, protected under the First Amendment, and in direct violation of his privileges between his attorney, doctors, clergy, religion, violation of equal protection under the law, violation of his freedom of privacy to his personal papers, effects and things from governmental intrusion, and violation of his rights to political and commercial free speech, also protected under the Constitution.

> The Supreme Court has issued prior decisions which support the issuing of injunctive relief for Plaintiff Schlund which involve a wide range of scientific and other electronic force technologies admittedly used not only by the United States Government, but others as well. See, Central Intelligence Agency v. John Cary Sims and Sidney M. Wolfe, 471 U.S. 159, 85 L Ed. 2d 185 S.Ct. 1881 (1965).

> 2. Torture and banishment allowed by the court if not stopped results in Plaintiff Schlund being beyond the reach of all of the protecting clauses of the United States Constitution, resulting in irreparable harm.

> Irrefutably, torture is extreme punishment whether physiologically, psychologically or both. The government's illegal activities of torturing Plaintiff Schlund are done in an electronic manner unseen by the untrained human eye. The government's electronic torture and surveillance of Plaintiff Schlund is conducted in a manner in which Plaintiff cannot defend himself against such egregious invasions of his privacy or torture having the effect of placing him outside and beyond the reach of any of the protecting clauses of the United States Constitution - banishing him from such protections guaranteed thereunder. In other words, it strips him of all the rights which are given to him as a United States citizen and by God. Use of electronic torture and surveillance devices and systems on Plaintiff forcibly banishing him from the constitutional protections is a type of torture called banishment. Banishment is a severe form of torture recognized by the United States Supreme Court. United States vs. Ju Toy, 198 U.S. 253 (1905) at pgs. 258 and 259.

> The United States in the U.S. v. Ju Toy, case held government activities which place a person (Plaintiff Schlund) beyond the ability to use his United States Constitutional protections to stop illegal or pretextually legal (under color of authority or office) torture or banishment is punishment. (Id. p. 269). It went further clarifying that such activity is the most severest punishment,

> > " It is inflicted principle upon political offenders ………….. usually punishment on criminals whether real or pretended". (Id.)

> In the case before the bench, Plaintiff Schlund has been and is pretextually and judicially branded as a criminal and was set-up by sloppy, dirty, and corrupt government agents who got caught by the Honorable Federal Judge Lacey who held they committed "outrageous" acts of fabrication of evidence, witness tampering, obstruction of justice and other severe and repetitive acts of immoral and grossly unethical conduct under color of authority and office. The officials themselves were radical and uncivilized criminals violating federal law. They should have been jailed.

> The Honorable Federal Judge Lacey after acquitting plaintiff while standing and beating on his desk demanded that the corrupt federal agents be arrested for perjury and yelled that no one commits perjury in his court.

> See a similar recent example attached hereto as Exhibit "A", as self-authenticated evidence per F.R.C.P. 902(6).

> The corrupt agents nearly ended up in jail themselves on sua sponte contempt charges vigorously voiced on bedrock of anger by United States District Court Judge Lacey. The judge's clear expressions were in essence that the corrupt and dirty cops were the actual criminals not Plaintiff Schlund who was merely painted as a criminal in the bogus and fabricated proceedings marshaled against him by the DOJ and DEA. (Id.) Plaintiff Schlund is a whistle blower on dirty law enforcement activities anchored in corruption. Plaintiff Schlund, in reality, is a political witness despised by those who are steeped in government corruption. The DOJ, DEA and judges under their influence, in a concerted effort, have and continue to have, exiled or banished (to the extent of their influence) Plaintiff Schlund from the effective use of the judicial system or use of other departments and agencies of the state/federal government. He is subject to the species of torture called judicial banishment or exile. He has been placed in the status of a political witness and tortured as well in this fashion. United States vs. Ju Toy, 198 U.S. 253 (1905) at pg. 258:

> > > "Banishment of a citizen not merely removes him from the limits of his native land, but puts him beyond the reach of any of the protecting clauses of the Constitution. In other words, it strips him of all the rights which are given to a citizen. I cannot believe that Congress intended to provide that a citizen, simply because he belongs to an obnoxious race, can be deprived of all the liberty and protections which the Constitution guarantees; and if it did so intend, I do not believe that it had the power to do so."

> Plaintiff Schlund is a person of the obnoxious race or status of a whistle blower of corruption - a political witness against government corruption. Therefore, the court ordering the termination of the violations of Plaintiff Schlund's rights, the torturing of Schlund and the equal access to the use of the law, will level the playing field of due process, equal protection and uphold the ends of justice. U.S. v. Ju Toy; Article 3 of the United Nations Convention Against Torture and Other Cruel, Inhumane or Degrading Treatment or Punishment and In. Re. the Matter of S-V, Interim Decision No. 3430 (BIA 2000); 8 C.F.R. § 208.17(a)(2001)[defining torture], by way of example. Torture of political witnesses or for [other government motive] is not new and fully acknowledged by the judicial decisions Siderman DeBlake v. Republic of Argentina, 965 F. 2d 699 (9th Cir. (1992), supra; F.R.C.P. 706.

> The result of this court not granting the requested relief will be that the court will be procedurally authorizing the use of torture and banishment and aiding/abetting in the cover-up of wireless electronic trespass, torture, murder and treason. 18 U.S.C. § 238 [Treason Against the United States]. Plaintiff Schlund's testimony as to the severity and extreme harm of the injuries and damages he has sustained and continues to sustain must be adopted as truthful, especially in light of no conflicting evidence to the contrary. See, Allen Scribner, 812 F 2d 426, 430, 437 (9th Cir. 1987) ["[A] Plaintiff's testimony, standing alone, is sufficient to sustain a verdict."] Plaintiff Schlund's statements have been consistently reliable for over twenty-five (25) years since he was acquitted. He has passed two (2) independent lie detector tests, despite the proof is not admissible in court. Also, his Verified Complaint is construed as an affidavit, which is acknowledged under Rule 56(e), which can be relied upon for purposes of granting injunctive relief.

> As to the nature of the technology and the raw reality of the government torturing its citizenry, here for Plaintiff Schlund, as bizarre as it may seem, the reality of torture has been firmly recognized in the Siderman DeBlake case supra. The 9th Circuit Court of Appeals expended great effort to give strong and credible weight to the factual reality of torture of citizens by the government under its reliable pattern of always denying it.

> Modernly, the technology almost has no limits and it is not logical that the government would use old technology when it can be using the most updated modernized technology for "surveillance" and other purposes which are less costly, more effective and efficient.

> Plaintiff Schlund's Complaint avers the government needs this pretext of claiming he is engaged in criminal activity to justify obtaining a probable cause warrant in order to continuously conduct the surveillance activities as aforesaid. He claims the CIA/DEA utilizes "corrupt" judges that Plaintiff Schlund had been working with the FBI against, to obtain these warrants, or otherwise the government just simply conducts the investigation without a warrant, hoping he will commit a criminal act and then use that as a justification for the probable cause to seek legitimate warrants, while the judge turns a blind eye to the perpetuation of illegal surveillance and torture activities, in violation of his civil rights and those that associate with him. This is exactly what the Honorable Circuit Judge Kozinski greatly feared, as he expressed in his powerful dissent in the Kovomejian decision. However, because Koyomejian was a criminal matter, when the government is believed to be conducting illegal or otherwise improper investigations utilizing said technologies, it would be proper for the court to grant injunctive relief to protect Plaintiff Schlund's constitutional rights. Plaintiff Schlund has never been convicted of anything and is not guilty of any crime.

> Plaintiff Schlund is seeking injunctive relief to restrain the actual and threatened acts of irreparable injury which are in fact cruel and unusual punishment to him personally and to his constitutional rights, as expressed above. Even minor deprivation or violation of an individual's freedom of speech is always protected by injunctive relief against the violator. Plaintiff Schlund requests the relief as a preventive and protective measure to allow him to have relief from the torture which causes him irreparable harm, injury, and damages, as set forth in this motion. It is the rule, rather than the exception, that an injunction is not restricted to acts "contrary to law" but may also issue to restrain acts contrary to fairness. See, Standard Oil Co. v. United States, 283 U.S. 163, 75 L.Ed. 926, 51 S.Ct. 421 (1982); Swift and Co. v. United States, 276 U.S. 311, 72 L.Ed. 587, 48 S.Ct. 311 (1981). For the court to deny this Motion and stop the lawsuits from going forward by the use of torture would result in the court becoming a co-conspirator to the cover-up of murder and the claims listed in the Complaint. This includes the court's participation in the overthrow of the United States - treason.

> Plaintiff has stressed the resulting psychological and physiological injury and damages, including but limited to, his feelings, sensibility, honor, personal reputation, deprivation of his children's love, affection and companionship, and the torturous interference with his personal guaranteed rights under the United States Constitution. All of these are appropriate for the court to issue an injunctive relief order terminating the government's torture activity causing irreparable harm in those regards.

> > > "The interests protected by an injunction against torts are not limited to those in property or to those of an economic character. They include all interests defined and discussed in the restatement of this subject. Thus. injunctive relief is available for the protection of interests of personality, even though the harm done or threatened consists of nothing more to injury to feelings, sensibility, or honor. Examples are interests in privacy, in personal reputation, and in the domestic relations." See, Restatement, Torts, Section 973, comment (a); Koyomejian and Siderman DeBlake.

> Torture is defined as a criminal act subject to relief in the World Court if relief cannot be obtained in the subject country (USA). If the court allows such violations, it gives the appearance the court is no different than the violator, which results in a chilling effect of the public trusting their own government. (See Exhibit "A", a current reality.)

> Normally, Plaintiff Schlund would seek the protections enunciated under criminal law enforced by the police against the violators of his constitutional rights, but such options are not available under the present circumstances. Plaintiff has tried to file 1,000's of complaints for the use of torture. The Justice Department, Attorney General John Ashcroft, Janet Reno and the Inspector Generals Office have refused to even answer the complaints. The Federal Rules of Civil Procedure, Rule 65, provides that in appropriate cases, to prevent irreparable harm, the court may issue an injunctive relief order in its discretion.

> #### NOTICE OF INTENT TO EXERCISE UNITED STATES CONSTITUTIONAL RIGHTS UNDER TORTURE AND THREAT OF DEATH BY THE GOVERNMENT

> Plaintiff Schlund while under torture and under the threat of death by the government must place the United States on notice that the Justice Department and courts by allowing the use of terrorist acts and torture against Plaintiff Schlund has resulted in injuries that Plaintiff will in time die from. Plaintiff Schlund under the torture by the government will never be able to get married or pursue happiness in any way. Plaintiff Schlund has been driven out of business by the governments use of torture and has been forced under torture to not be able to maintain records resulting in forcing Plaintiff Schlund under torture to not be able to file taxes. Anytime Plaintiff tried to file taxes he was punished and tortured and at times was knocked out with the pain from the torture of him as the government tried to stop him.

> The Government has threatened to murder Plaintiff's children and has tortured Plaintiff for the past 25 years and has framed Plaintiff for every crime they could to justify the Government's Nazi-like criminal conduct. The torture of Plaintiff Schlund has now so damaged him that in time he will no longer be able to defend himself or be able to work or even feed himself or his grandchildren. Social Security has been mostly destroyed by Plaintiffs inability under torture to file taxes.

> The courts issued warrants that were used to take Plaintiffs passports for 12 years before returning them and then took them again. The government used these passports to open bank accounts in Plaintiff Schlund's name to frame him as being involved in drugs.

> Acts which are continuous and ongoing by the Government are electronic intrusions and trespasses in, on and upon Plaintiff Schlund's home and/or vehicles for the purpose of planting new evidence every time Plaintiff executed his freedom of speech and redress of rights and complains to the Justice Department, police or the courts the torturing of Plaintiff is increased and new evidence against Plaintiff is again planted.

> This process of obstruction of justice and witness tampering by the Government has continued each day for 25 years and may never stop without this court assisting with the requested relief. Plaintiff has repeatedly offered the Government while under the torture to plead guilt to any crime they wish in exchange for relief from the torture.

> Plaintiff has confessed to every crime that he can think of while under torture in exchange for some relief from torture or in exchange for sleep.

> The government has no interest in trying or convicting Plaintiff for any purported crime, the government's only interest is to torture plaintiff to limit his freedom of speech and whistle-blowing activities. To imprison Plaintiff would look like the government was imprisoning him as a political witness. In fact Plaintiff Schlund would be a political prisoner of the United States. To give the illusion of freedom Plaintiff Schlund is allowed to appearingly remain free while in reality he is held prisoner electronically and controlled to a degree more horrible then possible in any prison without the use of the electronic implants used to torture Plaintiff Schlund.

> The Justice Department and the Courts to date have acted like Plaintiff has no rights of any kind and, in fact, have intentionally violated Plaintiffs rights. The Government has asserted by its acts and conduct Plaintiff is presumed to be guilty and, accordingly, the court has based its decisions on the presumption of guilt rather than the constitutional duty imposed on it to act on the constitutional presumption Plaintiff Schlund is innocent until proven guilty in a court of law. They have acted like Nazis. Because of this plaintiff has been stopped with torture from voting, owning a home or even being allowed to work or to run a business. Plaintiff Schlund has also been deprived of the exercise of his right to freedom of religion, of going to church and, in fact, has been tortured forcing Plaintiff out of church violating his Constitutional rights of freedom of religion and association.

> The only time that the torture was terminated was when Plaintiff was arrested for a contractor code violation. While he was in jail, all torture was stopped. Plaintiff reached the point while under torture that he would gladly go to jail for the rest of his life in exchange for not being further tortured.

> Plaintiff Schlund places the court on notice that he will exercise his rights to civil protest to be arrested in protest of his never ending torture by the Government. The Government uses electronic stalking, violence and terrorism and Plaintiff Schlund will use peaceful civil protest as his response to the Government's outrageous and despicable conduct and acts of evil and terrorism. Plaintiff Schlund has no problem with the government conducting any investigation but will no longer allow the government to torture him further without civilly protesting the Government's use of torture.

> The Government in its criminal conspiracy and paranoid delusions will claim that this is a threat against the Government and that the Government does not respond to threats. Nazis. In truth, the Government is the one violating Plaintiffs rights by electronic stalking, torture and threats and is threatening Plaintiff with further torture, sleep deprivation and further cruel and unusual punishment.

> Plaintiff will 90 days from the filing of this motion start peaceful civil protest of his torture which is being committed under the authority of the courts. If the U.S. Supreme Court, in its decisions, says it is legal to burn American flags as an expression of free speech, then it is legal to do other kinds of peaceful protest. Plaintiff will protest by burning copies of the Constitution at the Sandra Day O'Connor Court House in protest of his torture to get arrested and tried for his peaceful protest to the Government's use of torture. The Government has reduced the American Constitution in Plaintiff's situation into a worthless piece of paper with their corruption. Plaintiff will force the Government to hold Plaintiff in prison for the rest of his life or until the Government agrees to terminate the torture of Plaintiff. Anytime the Government tries to release Plaintiff from prison and again tortures Plaintiff he will again go straight to the court house and again burn new copies of the Constitution until he is again arrested. If Plaintiff is released from jail on his own recognizance or for any other reason he will again return to the court house and again burn new copies of the Constitution as soon as he is tortured again.

> As the Government fully knows, Plaintiff will be tortured as long as the Government has implants in his body or on his body or in proximity to his body capable of torturing him. Anyone with any electronic knowledge can design implants or other monitoring devices that are not capable of torture and that is all that Plaintiff Schlund asking for with the paranoid and delusional Government insisting that they have a right to use torture against him as a political witness, in violation of his rights.

> Let the court fully understand how evil the government has acted in its use of torture against Plaintiff as an electronic political prisoner of the United States. Plaintiff alleges that while working and driving from job to job in his truck he has to drive through school zones where children cross the street. As Plaintiff Schlund would enter these areas, the Government would torture Plaintiff Schlund making him scream in agony as the Government tried to force Plaintiff Schlund to run over these innocent children. These crimes were committed by the Government to try to force Plaintiff Schlund to possibly injure or kill innocent children so the government could blame Plaintiff Schlund and prosecute him as a horrible evil criminal. Then when Plaintiff Schlund would get to his intended job site the torture would be reduced by millions of times for the filming of Plaintiff to show that he can work and is in good shape.

> As soon as Plaintiff would leave the job and get on the freeway the Government would then again torture Plaintiff as abovesaid and make him scream in agony trying to force Plaintiff into an accident to possibly kill or injure some innocent person(s) so the Government could try to justify prosecuting him for the hoped for accident by the Government.

> Plaintiff Schlund will no longer tolerate these crimes by the Government. He will not allow the Government to force the death of innocent people so the Government can target Plaintiff as abovesaid. To stop these crimes by the Government, Plaintiff Schlund has no other choice other then to force his incarceration as a political prisoner of the United States.

> Plaintiff alleges that if this court does not grant his reasonable motion for relief of torture on the grounds set forth herein, he may begin the expression of his constitutional rights as stated in this motion despite he would prefer the relief he is entitled to under settled law set forth herein.

> #### CONCLUSION

> Based on the above said, Plaintiff Schlund respectfully requests the court to issue the appropriate injunctive relief order terminating the government's various types of torture of him, to maintain the status quo of the parties and protect his constitutional rights as follows:

> > 1. The court order the government to cease and desist all activities of every nature and kind which result in the torture of Plaintiff Schlund and his witnesses;

> > 2. The government cease and desist utilizing any type of electronic or other devices which emit any form of electronic force utilized by it to influence, control, inflict pain or suffering to any degree whatsoever, whether psychologically or physiologically to Plaintiff Schlund;

> > 3. The court order the government to cease and desist all activities of every nature and kind whatsoever which result or may result in the torture and witness tampering of Plaintiff Schlund's family, friends and his witnesses;

> > 4. That the government cease and desist all activity which directly or indirectly, irrespective of degree, which does or may cause pain and/or suffering, whether physiological or psychological to Plaintiff Schlund's family, friends and witnesses;

> > 5. The court order the removal and documentation of all implants in Plaintiff Schlund;

> > 6. The court order an independent expert knowledgeable of the nature and types of electronic integrated systems used by the government for surveillance and torture of American citizens to advise the court of the government's ability to torture Plaintiff Schlund electronically;

> > 7. That independent experts F.R.C.P. 706 and a magistrate or reference be ordered by the court to conduct an in-depth Evidentiary Hearing relating to the methods and systems of surveillance and torture of Plaintiff Schlund as set forth in his Complaint and Motion herewith, for a determination of the factual basis asserted by Plaintiff Schlund and findings of fact and conclusions of law, with the expert's and magistrate's or references' report, of findings being submitted directly to this court immediately upon the conclusion of the hearing;

> > 8. That the government and any other person or entity shall also be restrained, and it is the obligation of the government to notify said individual/entity of the injunctive order terminating the torture of Plaintiff Schlund;

> > 9. Any and all such further relief in the court's discretion that is fair, just and equitable under the circumstances.

>     Date: _____________________		By: _____________________________
>     						Charles August Schlund, III
>     			                     	Plaintiff Pro Per

>     COPIES of this Motion mailed this
>     _______ day of August, 2003 to:

>     George W. Bush, an individual; and as
>     President of the United States
>     White House
>     1600 Pennsylvania Avenue N.W.
>     Washington, D.C.	20500

>     Mr. John Ashcroft
>     Attorney General of the United States
>     950 Pennsylvania Avenue N.W.
>     Washington, D.C. 20530-0001

>     Office of the Solicitor General
>     United States of America
>     Department of Justice
>     950 Pennsylvania Avenue N.W.
>     Washington, D.C. 20530-0001

>     U. S. Attorney's Office
>     Department of Justice
>     555 Fourth Street, NW, 10th Floor
>     Washington, D.C. 20001

>     Office of the Inspector General
>     United States of America
>     Department of Justice
>     950 Pennsylvania Avenue N.W.
>     Suite 4322
>     Washington, D.C. 20530-0001

>     U.S. Department of Justice
>     Federal Bureau of Investigation
>     J. Edgar Hoover Building
>     935 Pennsylvania Avenue
>     Washington, D.C. 20535-0001

>     United States Department of Justice
>     Drug Enforcement Administration
>     Department of Justice
>     Mail Stop:  AXS
>     2401 Jefferson Davis Highway
>     Arlington, Virginia  22301

>     United States Department of Justice
>     Drug Enforcement Administration
>     P.O. Box 28128
>     Washington, D.C. 20005
>     U.S. Department of Homeland Security
>     Washington, D.C. 20528

>     By: ____________________________

> Received 09-02-2003