Organized stalking ?

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Quote: 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

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