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

