## Jesus Mendoza Maldonado

### E-Mail

> Request to director of CIA to cease and desist from using active electronic surviellance

> January 12, 2005

> Re, Request to Cease Active Electronic Surveillance

> Jesus Mendoza Maldonado
> 2202 E. 28th St. Mission, Texas, 78574
> Tel. 956 519 7140

> Torper Goss
> Director of the Central Intelligence Agency
> Washington, DC, 20505, Tel. 703 482 1100

> Dear Mr. Goss

> I am requesting your office to cease and desist form using any type of physically assisted active electronic surveillance on my family and on myself during any investigation of my activities, on the ground that the electromagnetic radiation has caused severe physical harm to myself, to my five-year-old daughter, to my four-year-son and is causing the same harm to my new born daughter.

> In response to evidence showing that x-rays coming into my home is causing pain and suffering to my children, Ezequiel Navarro an investigator for the Mission Police Department, in Mission, Texas, has informed me that I am under an investigation by the Central Intelligence Agency.

> Enclosed is a copy of a transcript for the Power Hour Talk Show, which explains some of the pain and suffering caused by the electronic aggression.

> Enclosed is a copy an Original Complaint that has been filed in federal Court, and which gives the factual background as to how the investigation of my activities is retaliation for bringing claims of racial discrimination and fraud of federal funds. My new born daughter exhibited symptoms of overexposure to radiation including the swelling of eyes during the drafting of the Complaint.

> Your prompt attention to this matter is highly appreciated. Should you have questions or need clarifications, please feel free to call.
> Sincerely,
> Jesus Mendoza Maldonado

> #### UNITED STATES DISTRICT COURT
> SOUTHERN DISTRICT OF TEXAS
> HOUSTON DIVISION

> #### Jesus Mendoza Maldonado, Pro-se Plaintiff

> #### Case NO. 4:05MC00003

> #### Honorable Kenneth Hoyt US District Judge V.
> Michael James Lindquist,
> Christopher T. Lohden,
> Diane K. Smedley, and
> Ruth Watkins, Defendants. Jury Demand

> #### PRO-SE PLAINTIFF’S ORIGINAL COMPLAINT

> 1. Pro-se plaintiff, Jesus Mendoza Maldonado is a citizen of the United States of America. Plaintiff is a Mexican-American with Mexico as national origin.

> #### JURISDICTION AND VENUE

> 1. This Court has subject matter jurisdiction over this cause of action pursuant to 28 U.S.C. s 1331, 42 U.S.C. 1985 and 42 U.S.C. 1986.
> 2. This Court has personal jurisdiction over named defendants. Named defendants reside within the State of Texas, conduct business within the Sate of Texas, and the actionable acts and omissions stated in this complaint occurred within the Sate of Texas.
> 3. Venue is proper in the US District for the Southern District of Texas, a substantial part of the events giving rise to Plaintiff’s claims occurred within the Southern District of Texas.
> 4. Defendant Michael James Lindquist may be served with service of process at 2503 E. 28th St. Mission, Texas, 78574.
> 5. Defendant Christopher T. Lohden may be served with service of process at 2004 E. 25th St., Mission, Texas, 78574.
> 6. Defendant Diane K. Smedley may be served with service of process at 2020 E 27th St. Mission, Texas, 78574. Defendant Ruth Watkins may be served with service of process at 2217 E. 28th St., Mission, Texas, 78574.
> 7. Unless otherwise specified in this complaint, the term “defendants” refers to named defendants, and unidentified John and Mary Doe defendants.
> 8. Defendants are being sued on their individual, personal, capacity.
> 9. At several times relevant to this case plaintiff has been a party and a witness in federal court while litigating a case of discrimination on the basis of race and national origin, and fraud of federal funds against the Thomas M. Cooley Law School, some of its officers, and others, collectively the Cooley defendants.
> 10. Plaintiff law suit against the Cooley defendants included a claim that the Cooley defendants operated a scheme to defraud more than seventy- percent of minorities of their federal loans halting their education while on the other hand, the Cooley defendants were giving away law degrees to their affiliates.
> 11. At several times when plaintiff was a law student at the Thomas M. Cooley Law School, Shawn Gannon and other law students claimed to be related to prominency within the Central Investigation Agency and other federal law enforcement agencies.
> 12. Plaintiff lawsuit against the Cooley defendants included a claim that the Cooley defendants incited a federal investigation and an electronic aggression against plaintiff which caused plaintiff severe injuries including an electrical sensitivity.
> 13. Plaintiff is sensitive to electricity. Plaintiff exposure to electricity causes among other things pain, swelling of vital organs, breathing, speech and concentration problems. Plaintiff’s ability to work, to travel long distances, and to be inside a building has been substantially impaired.
> 14. At several times relevant to this case an electronic aggression has caused plaintiff to be critically ill. The electronic aggression causes plaintiff to be in pain most of the time.
> 15. The next day plaintiff attempted to file a criminal complaint against the Cooley defendants, three identified agents of the Federal Bureau of Investigation were found in a restricted area of an elementary school, and around plaintiff’s vehicle. One door of plaintiff’s vehicle was found unlocked.
> 16. The principal of the elementary school who witnessed the incident, claimed that the local FBI office had directed him to destroy the information gathered by plaintiff.
> 17. At no time the US Attorney General has engaged the evidence in support of this claims.
> 18. The case against the Cooley defendants was dismissed after aggravation of plaintiff’s condition prevented him from attending depositions.
> 19. Before the lawsuit against the Cooley defendants was dismissed, the legitimacy of plaintiff’s claims, including plaintiff’s electrical sensitivity and mental stability were established as a matter of law.
> 20. The US court of appeals affirmed the dismissal and further aggravation of plaintiff’s condition prevented plaintiff from appealing to the US Supreme Court.
> 21. Aggravation of plaintiff health condition forced plaintiff to dismiss a case of disability discrimination that had been filed in State court.
> 22. At several times relevant to this case, the intensity of non ionizing and ionizing radiation around plaintiff, (microwave and x-ray radiation, “radiation” hereafter), has increased during critical stages of federal, and State court proceedings, aggravating plaintiff’s health condition.
> 23. At several times relevant to this case, the intensity of radiation has impaired plaintiff health condition during State administrative hearings in which plaintiff has been seeking rehabilitation services.
> 24. At several times relevant to this case, the intensity of the electronic aggression has increased when plaintiff explains to others the discriminatory motive of the electronic aggression.
> 25. At several times relevant to this case, plaintiff’s three -year-old son and four -year-old daughter suffered pain with convulsions when a meter showed high intensities of radiation inside plaintiff’s home.
> 26. At several times a microwave meter has detected several beams merging on the head of plaintiff’s three- year-old son.
> 27. At several times relevant to this case, plaintiff’s three-year-old son has collapsed crying in pain when a microwave meter has shown several beams merging on his head.
> 28. At several times relevant to this case, plaintiff has recorded on videotape the electronic aggressions.
> 29. At several times relevant to this case, a microwave meter has shown several beams merging on the bed of plaintiff and on the bed of plaintiff’s children.
> 30. At several times relevant to this case plaintiff’s children have complained of pain when intense radiation has been found inside plaintiff’s home,
> 31. At several times relevant to this case plaintiff’s children have suffered convulsions while asleep.
> 32. At several times relevant to this case plaintiff’s children tremble on their sleep before the telephone rings.
> 33. At several times relevant to this case, plaintiff’s children have asked for medicine while crying in pain when intense radiation have been found inside plaintiff’s home.
> 34. At several times relevant to this case plaintiff and his children have had convulsions almost at the same time.
> 35. At several times relevant to this case the intensity of radiation increases when plaintiff approaches his children and his pregnant wife.
> 36. On December 29, 2004, the intensity of radiation increased dramatically at the time plaintiff was with his wife during surgery during the birth of plaintiff’s daughter.
> 37. At several times relevant to this case plaintiff anticipates to his wife the screaming of his children when plaintiff approaches their bed at night.
> 38. At several times relevant to this case the intensity of radiation increases when plaintiff attempts to read stories to his children.
> 39. At several times relevant to this case, a meter has registered high intensities of ionizing radiation when plaintiff is driving, or walking with his children around the neighborhood.
> 40. At several times relevant to this case, the levels of radiation increase before the telephone rings, during telephone conversations, when plaintiff has visitors, before someone enters or exits plaintiff’s home, when plaintiff moves around inside plaintiff’s home, when plaintiff’s children or wife approach plaintiff, and when plaintiff is doing legal work.
> 41. At several times relevant to this case plaintiff feels pain and his children tremble on their sleep before the telephone rings.
> 42. At several times relevant a meter has shown several beams of radiation merging on plaintiff’s workbench. 43. The electronic aggression has prevented plaintiff to work on his repair shop.
> 44. The electronic aggression has prevented plaintiff from working or staying outside of his home.
> 45. At several times relevant to this case, plaintiff has found bleeding on stool, on urine and on saliva after exposures to intense radiation.
> 46. At several times relevant to this case, the intensity of radiation has increased during critical stages of the litigation impairing plaintiff’s ability to prosecute his claims.
> 47. Plaintiff moved to the home of Gustavo Ramirez to spare pain and suffering to his children.
> 48. The level of radiation in the area around Ramirez home increased after plaintiff moved into his place.
> 49. Days after plaintiff’s health aggravated while Ramirez complained of pain, while Ramirez’ brother-in- law complained of feeling his eyes about to pop out.
> 50. On February of 2003, plaintiff filed in the US District Court for the Southern District of Texas, a cause of action against the US Attorney General seeking an order to cease and desist from directing radiation into plaintiff and his family on the ground that the electronic aggression has caused severe physical harm to plaintiff and his children, and on the ground that plaintiff’s investigation is retaliation for bringing claims of discrimination and fraud against the Cooley defendants. Jesus Mendoza Maldonado v the US Attorney General, John Ashcroft, Case No. M 03-038.
> 51. US district Judge Ricardo Hinojosa assigned the case to US Magistrate Dorina Ramos.
> 52. The US Attorney General has not denied the fact that plaintiff is the subject of an investigation and active electronic surveillance.
> 53. At several times relevant to this case the US Attorney General, has claimed that others may be involved in electronic aggression of plaintiff, and has claimed that the federal government has no duty to protect plaintiff against these aggressions.
> 54. On April 4, 2003, judge Ramos reset the hearing scheduled for the same day impairing plaintiff’s ability to present expert and lay witness in support of immediate injunctive relief.
> 55. On April 7, 2003, plaintiff filed a motion to recuse judge Ramos on the ground that judge Ramos had ignored false statements made by the Cooley defendants to defraud of venue the district court and had ignored evidence of the legitimacy of plaintiff’s disability, displaying a deep-seated favoritism toward the Cooley defendants and a deep-seated antagonism toward plaintiff that made fair judgment impossible.
> 56. Judge Ramos recused herself and judge Hinojosa reversed judge Ramos recusal.
> 57. On May 15, 2003, plaintiff’s wife testified before judge Ramos to the swelling, pain, and breathing difficulties caused on plaintiff by exposure to electricity and how this has affected daily activities, to the suffering of their children when they are exposed to electromagnetic radiation inside their home, and as to how high readings on radiation meters inside the home decrease when plaintiff attempts to record the occurrence in a video camera.
> 58. Plaintiff’s brother testified as to the pain and suffering, experienced by Ramirez and Ramirez brother-in- law after plaintiff moved into Ramirez place.
> 59. Plaintiff’s wife, daughter, and brother testified before judge Ramos to plaintiff’s mental stability and law- abiding conduct. (Maldonado v Ashcroft, case No. M 03-038, Audiotape of hearing, Docket No. 29).
> 60. During the telephonic hearing, a dramatic increase of radiation aggravated plaintiff’s condition and plaintiff sought a continuance on defendant’s motion to dismiss.
> 61. Without a hearing on defendant’s motion to dismiss judge Ramos issued a Report and Recommendation to dismiss plaintiff’s claims as frivolous.
> 62. Judge Ramos modified the testimony of plaintiff’s wife in which she testified to how high readings on radiation meters inside the home decrease when plaintiff attempts to record the occurrence in a video camera into: “Silvia Mendoza, who is Plaintiff’s wife, testified that Plaintiff’s has trouble breathing, among other things. She also testified that Plaintiff’s difficulty seems to subside when he operates a camera.” (Docket No. 32, at five, Statement of Evidence, Affidavit of plaintiff’s wife in which she denies giving that testimony, Docket No. 40, and audiotape of hearing, Docket No. 29 ).
> 1. Judge Hinojosa adopted the recommendation to dismiss plaintiff’s claims and plaintiff appealed.
> 2. Plaintiff’s appeal was based on the claim that a district judge cannot adopt a Report and Recommendation to dismiss a case when the disqualification of the magistrate judge has been established as a matter of law.
> 3. Judge Hinojosa and judge Ramos declined an invitation by the Judicial Council of the US Court of Appeals for the Fifth Circuit to engage plaintiff’s complaint of judicial misconduct.
> 4. The US Attorney General did not object to the claims and evidence supporting plaintiff’s claims of judicial disqualification.
> 5. In support of a motion to expedite the appeal, plaintiff filed on the Court of Appeals videotape showing the pain and suffering caused on plaintiff and on plaintiff’s children by the malicious exposure to radiation inside plaintiff’s home. The US Attorney General did not challenge the evidence.
> 6. Plaintiff filed a petition for hearing in banc after a panel of the US Court of Appeals for the Fifth Circuit did not address the issue presented to the Court.
> 7. On an Order dated December 13, 2004, the Panel of the Court denied plaintiff’s petition for hearing in banc.
> 8. On November 17, of 2004, defendant Christopher T. Lohden attempted to ram on the rear plaintiff’s vehicle.
> 9. Plaintiff asked defendant Lohden why Lohden attempted to ram plaintiff’s vehicle.
> 10. Defendant Lohden answered by saying that he was to call the police.
> 11. After defendant Lohden called the police on a cellular telephone, a lady came from the front door of the house and asked defendant Lohden what was going on.
> 12. Defendant Lohden answered “I called the police, this guy says that I tried to ram his car.”
> 13. The lady said, “You did! Why are you calling the police?! Don’t call the police!” The lady then walked back inside the house.
> 14. Plaintiff then asked Lohden to tell the police that plaintiff was coming back.
> 15. At that time defendant Lohden asked where plaintiff lived.
> 16. Plaintiff said ”You know where I live, and you know me, this is not the first time that you engage in this kind of harassment.”
> 17. Defendant Lohden did not reply to plaintiff’s statement.
> 18. Plaintiff returned when a police car was parked at the home of defendant Lohden.
> 19. Plaintiff explained to Mr. Hernandez and to Mr. Paniagua, officers of the Mission Police Department, the fact that Mr. Lohden had attempted to ram plaintiff’s vehicle.
> 20. Defendant Lohden did not deny plaintiff’s claim and instead said that plaintiff was doing thirty miles an hour on the road.
> 21. Officer Paniagua asked plaintiff to come across the street.
> 22. There, plaintiff explained to officer Paniagua and to officer Hernandez about the defendant’s attempts to ram plaintiff’s car; about the statements made by the lady that came out of the house; about the fact that defendant Lohden had attempted to run over plaintiff and plaintiff’s children when they were crossing the street; about the fact that everyday plaintiff was subjected to this type of harassment; about the fact that other individuals in the neighborhood have engaged in the same harassment; and about the fact that this harassment was the result of racism.
> 23. At several times relevant to this case defendant Ruth Watkins has come into convenience sores, followed by other individuals, who engage in acts of intimidation against plaintiff and then leave leaving without buying anything.
> 24. A several times relevant to this case defendant Watkins has led the way to a number of individuals who have engaged in harassing and intimidating acts against plaintiff and his children including the pushing, placing their hands on plaintiff’s vehicle while looking at plaintiff’s children seated inside plaintiff’s vehicle.
> 25. At several times relevant to this case defendant Watkins has communicated to these individuals by gestures and hand signals to some of these individuals.
> 26. At several times relevant to this case, defendant Watkins has acted in concert with other individuals in a course of repeated physical proximity and threatening behavior against plaintiff and his children.
> 27. At several times relevant to this case defendant Watkins has claimed that this conduct is not harassment.
> 28. At several times relevant to this case defendant Watkins has refused to identify others involved in this harassment.
> 29. At several times relevant to this case high intensifies of radiation have been detected when plaintiff is approaching and passing by Watkins’ home.
> 30. At several times relevant to this case, furtive high intensities of radiation have been detected to come from the direction of Watkins’ home into plaintiff’s home.
> 31. At several times relevant to this case defendant Diane K. Smedley has attempted to run over plaintiff and his children when plaintiff and his children were crossing the street.
> 32. At several times relevant to this case defendant Smedley has engaged in street harassment of plaintiff and his children.
> 33. On or about December 6, 2004, plaintiff complained to the Chief of Police of the Mission Police Department Lio Longoria about named defendants gang stalking, and Longoria claimed starting an investigation of plaintiff’s claims.
> 34. The road harassment ceased afterward.
> 35. On December 10, 2004, an ionizing meter collected a dramatic increase in ionizing radiation inside plaintiff’s home, causing on plaintiff among other things swelling, and pain.
> 36. The same day plaintiff showed to Jose Gonzales, investigator of the Mission Police department, video tapes of the increase in ionizing radiation inside plaintiff’s home, and the pain and suffering caused by the radiation to plaintiff’s three-year-old son.
> 37. On or about December 20, 2004, Ezquiel Navarro an investigator of the Mission Police Department notified to plaintiff that the Federal Bureau of Investigation had instructed Navarro not to disclose any information about the investigation because of a pending investigation of plaintiff by the Central Intelligence Agency.
> 38. Navarro claimed knowing about agents that take x- ray devices home.
> 39. The levels of ionizing radiation at points around the neighborhood resumed, while the intensity of radiation inside and outside plaintiff’s home increased.
> 40. Plaintiff’s ability to be with his family became more limited.
> 41. Defendant Michael James Lindquist calls himself Apostle of the congregation.
> 42. At several times relevant to this case defendant Lindquist has led the way to some individuals who have been engaged in gang stalking of plaintiff and his children.
> 43. At several times relevant to this case, plaintiff has notified defendant that some individuals on the congregation and running team have been involved in gang stalking of plaintiff and his children.
> 44. At several times relevant to this case, plaintiff has asked defendant Lindquist to identify and to ask those who have been engaged in this wrongdoing to cease and desist from this type of harassment, and Lindquist has refused to do so.
> 45. On January 2, 2005, during worshiping services, an individual that has been harassing plaintiff walked into Lindquist’s office after he realized plaintiff had identified him. Plaintiff was not allowed to enter the office.
> 46. At the end of the service the individual stayed at Lindquist office while his companions left without him.
> 47. At several times relevant to this case high intensifies of radiation have been detected when plaintiff is passing across Lindquist’s home.
> 48. At several times relevant to this case, furtive high intensities of radiation have been detected to come from the direction of Lindquist’s home into plaintiff’s home.
> 49. Ruben Luna, plaintiff’s neighbor and a former government agent claims spending a week on the hospital after attesting before others to the legitimacy of plaintiff’s claims of electronic aggression.
> 50. At several times Luna has claimed to feel the effects of an electronic aggression.
> 51. Luna claims spending two weeks on the hospital with internal bleeding.
> 52. Luna had reassured plaintiff by telephone his willingness to testify in court as to the legitimacy of plaintiff’s claims of electronic aggression before reassuring plaintiff of his willingness to testify as to the legitimacy of plaintiff’s claims.
> 53. Luna lives across the street from defendant Watkins.
> 54. Lunas’ affidavit attesting to the legitimacy of plaintiff’s claims about an electronic aggression is part of the federal record.
> 55. At several times relevant to this case plaintiff’s mother has been critically ill exhibiting the typical symptoms of an electronic aggression including sleep deprivation, loss of concentration, swelling of eyes, unexplained pain and fatigue, erratic blood pressure, and severe dizziness.
> 56. At several times relevant to this case, meters have read intense amounts of non-ionizing and ionizing radiation inside the home of plaintiff’s mother.
> 57. At several times relevant to this case, intense amounts of non ionizing and ionizing radiation have been found inside the home of plaintiff’s in-laws.
> 58. Plaintiff’s father-in-law has been critically ill, displaying symptoms of overexposure to radiation including sleep deprivation, unexplained pain and fatigue, and erratic blood pressure.
> 59. At several times relevant to this case plaintiff’s mother-in-law has been displaying symptoms of overexposure to radiation, including sleep deprivation, loss of concentration, and unexplained pain and fatigue. She is now terminally ill.
> 60. At several times relevant to this case plaintiff’s neighbors have claimed suffering of sleep deprivation, pain and loss of concentration.
> 61. Plaintiff’s next-door neighbor has been critically ill several times.
> 62. At several times relevant to this case plaintiff’s pain has made plaintiff to walk out of the house in the middle of the night only to hear screams of joy coming from the neighborhood.
> 63. At several times relevant to this case the gang stalking and electronic aggression against plaintiff and his children has intensified during the times plaintiff has filed complains describing the misconduct of judge Hinojosa and judge Ramos.
> 64. Plaintiff has heard the same screams of joy from speeding vehicles attempting to run over plaintiff and his children.
> 65. At several times relevant to this case, the lights on the side of the street turn off during the night and on during the day when plaintiff is driving or walking with his children.
> 66. Plaintiff’s oldest daughter has witnessed streetlights turning off as plaintiff is driving by.
> 67. At several times relevant to this case, family members of named defendants have engaged in harassing of plaintiff.
> 68. At several times relevant to this case, named defendants have shared information to use in furtherance of the conspiracies to injure plaintiff and his children.
> 69. At several times relevant to this case vehicles have darted to plaintiff and to plaintiff’s children when plaintiff and his children have been walking around the neighborhood.
> 70. At several times relevant to this case, plaintiff has been thrown of the road by unidentified vehicles. At several times relevant to this case, plaintiff has been the subject of gang and electronic harassment by named defendants.
> 71. At several times relevant to this case speeding vehicles have attempted to ram plaintiff’s vehicle running red lights to avoid identification.
> 72. At several times relevant to this case defendant has darted her vehicle towards plaintiff and his children when they are walking around the neighborhood.
> 73. At several times relevant to this case, unidentified vehicles have attempted to ram the rear of plaintiff’s vehicle.
> 74. At several times relevant to this case plaintiff has been subjected to electronic harassment by named, unnamed, and unidentified individuals.
> 75. Two shots have been fired into plaintiff’s direction, and plaintiff filed a report with the Hidalgo County Sheriff’s Department.
> 76. At several times relevant to this case high levels of ionizing radiation have occurred when plaintiff is attending church services on minority congregations, while the same intensities do not occur when plaintiff attends non-minority congregations.
> 77. At several times relevant to this case the street and electronic harassment compelled plaintiff to leave the state of Michigan, and the State of Texas.
> 78. The gang stalking and electronic aggression is more intense when plaintiff is with his children.
> 79. At several times relevant to this case, plaintiff has found lose or over tight lug nuts on the front wheels of plaintiff’s car.
> 80. The harassment has intensified during and after critical stages of litigation.
> 81. At several times relevant to this case, defendant engaged in electronic surveillance of plaintiff with intent of harassing, intimidate and cause harm to plaintiff.
> 82. At several times plaintiff has heard racial slurs by speeding vehicles when he is with his children around the area.
> 83. On January 2, of 2004, around 1:30 a.m., another sudden dramatic increase of radiation occurred a the time plaintiff approached the bed of his children and wife.
> 84. Plaintiff warned his wife about the increase in radiation seconds before plaintiff’s newborn daughter and five-daughter year old started to cry.
> 85. The aggression has intensified during the drafting of this complaint.
> 86. Furtive high densities of directed radiation is a daily occurrence at plaintiff’s home.
> 87. COUNT ONE. VIOLATION OF 42 U.S.C. 1985(2).
> 88. Plaintiff incorporates hereby all paragraphs of this complaint.
> 89. Defendants conspired to deter plaintiff by force, intimidation, and threat, form attending courts of the United States, as a party and witness.
> 90. Defendants conspired to deter by force, intimidation and force, from testifying freely and fully in courts of the United States,
> 91. Defendants conspired by force, intimidation, and threat, to injure plaintiff in his person and property on account of plaintiff being a party, having attended and testified in a court of the United States.
> 92. Defendants conspired for the purpose of impeding, hindering obstructing, and defeating in several manners the due course of justice in the State of Texas and a court of the State of Texas.
> 93. Defendants conspired with intent to deny plaintiff the equal protection of the laws, and injured plaintiff and his property for lawfully enforcing and attempting to enforce the right of plaintiff and the right of plaintiff as a citizen of the United States and member of a class of persons, to the equal protection of the laws.
> 94. Defendants conspired to interfere with plaintiff’s family relationship.
> 95. Plaintiff suffered injury as proximate result of defendants’ misconduct.
> 96. Therefore, defendants are liable to plaintiff.
> 97. Therefore, named defendants are liable to plaintiff.
> 98. COUNT TWO VIOLATION OF 42 U.S.C. 1985(3).
> 99. Plaintiff incorporates hereby all paragraphs of this complaint.
> 100. Defendants conspired to deprive plaintiff of the equal protection of the laws and of the equal privileges as described by 42 U.S.C. 1985 because plaintiff’s race and national origin.
> 101. Defendants conspired with the purpose of preventing and hindering the constituted authorities of the State of Texas from giving and securing persons within the State of Texas the equal protection of the laws. The purpose of defendants’ conspiracy is to influence the activity of the State.
> 102. Defendant’s conspired to injure plaintiff on his person and property because of plaintiff’s race and national origin.
> 103. Defendant’s engaged in a course of conduct which purpose is to injure plaintiff and plaintiff’s children.
> 104. Defendants’ conspired to retaliate against plaintiff for plaintiff litigating claims of racial and national origin discrimination.
> 105. Defendants’ conspired to deprive plaintiff of right to access the courts.
> 106. Defendants’ conspired to interfere with plaintiff’s right to interstate travel.
> 107. Defendants’ conspired to violate plaintiff’s right to be free from public and private racist violence.
> 108. Defendants’ conspired to deprive plaintiff of the right to be free from the conduct described by 42 U.S.C. 1985(2).
> 109. Defendants’ engaged in several overts acts in furtherance of the conspiracy to deprive plaintiff’s rights described by 42 U.S.C. 1985(2)(3).
> 110. Defendants reached a conspiratorial agreement to violate plaintiff’s protected rights.
> 111. Defendants caused acts in furtherance of the object of the conspiracy to violate plaintiff’s rights, whereby plaintiff was injured in his person and property and plaintiff was deprived of having exercised rights and privileges of a citizen of the United States.
> 112. Defendants conspired to retaliate against plaintiff for plaintiff bringing claims of discrimination and retaliation pursuant to 42 U.S.C. 1985, and 42 U.S.C. 1986.
> 113. Defendants engaged in racist conspiracies to deprive plaintiff of his right to obtain reasonable accommodations because of his disability.
> 114. Plaintiff suffered injury as proximate result of defendants’ conspiracies.
> 115. Therefore, defendants are liable to plaintiff.
> 116. COUNT THREE VIOLATION OF 42 U.S.C. 1986.
> 117. Plaintiff incorporates hereby all paragraphs of this complaint.
> 118. Defendants have actual knowledge of a conspiracy to violate plaintiff’s rights as described by 42 U.S.C. 1985.
> 119. Defendants breached a duty to disclose to plaintiff the identity of those by failing to prevent the conspiracy.
> 120. Defendants knew or had reasons to know about a conspiracy to injure plaintiff and failed to prevent a conspiracy.
> 121. Defendants have a duty and the power to prevent or aid in preventing the commission of the conspiracies described by 42 U.S.C. 1985, and defendants failed to do so.
> 122. Plaintiff suffered damages caused by the misconduct of defendants.
> 123. Defendants are joint and severally liable to plaintiff.
> 124. JURY DEMAND
> 125. Plaintiff hereby demands for trial by jury of all disputed issues of fact.
> 126. RELIEF
> 127. Plaintiff respectfully asks this Court for an Order compelling defendants to cease and desist form engaging in the conduct described herein.
> 128. Plaintiff respectfully asks this Court to compel named defendants to disclose to plaintiff the identities of individuals and entities that have engaged, participated encouraged, supported directly or indirectly in any way in the conduct described herein.
> 129. Plaintiff respectfully ask this Court to render judgment in favor of plaintiff and find defendants jointly and severally liable for all relief, in law and in equity to which plaintiff may be entitled including general and special damages, aggravation of preexisting condition, cost of technology to accommodate impairment, past and future pain and suffering, past and future mental anguish, past and future medical expenses, past and future loss of earning capacity, loss of consortium, loss of household services, loss of companionship and society, loss of enjoyment of life, punitive damages, prejudgment and post- judgment interest, interest, court costs, and cost of expert witnesses.
> Respectfully Submitted
> ______________________________
> Pro se Plaintiff
> Jesus Mendoza Maldonado
> 2202 E. 28th St.
> Mission, TX 78572
> 956/ 519 7140

> Received 01-13-2005