Disorder in the Court!
The 3 Stooges...
The 3 Stooges & False Statements…
The DOJ claims our pleadings should be dismissed for lack of jurisdiction, and failure to state a claim for which relief can be granted. Both are laughably false.
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True uncontroverted fact: USDOJ acknowledged that Defendant FBI approves nominations to the TSDB without complying with any requirements.
“The National Counter Terrorism Center is receiving nominations for non-investigative subjects directly from FBI field personnel. Because this nomination practice is not covered in FBI Policy, there are no requirements for FBI personnel to ensure that any resulting watchlist records are updated or removed as appropriate. There is likewise no mechanism to ensure that the nominations directly passed to NCTC by field personnel are appropriate and that the information is complete and accurate.” (DOJ/Inspector General Audit Report, 2008)*
https://oig.justice.gov/reports/plus/a0816/index.htm
The DOJ/OIG openly admit that the FBI is violating our Constitutional rights. And our rights under the Privacy Act are also being violated by the dissemination of our names as “suspected terrorists’ on a list. These are plausible, factual allegations according to the Mottley Rule.
Targeted Individuals - pay attention. The FBI Field Offices are responsible for most of your nominations to the TSDB.
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Second true uncontroverted fact - Former Terrorist Screening Center Operations Director, Timothy Groh’s specific words in his statement under penalty of perjury (Exhibit 2 of the SAC):
“Additionally, the TSDB includes identifying information of certain individuals who are not categorized as known or suspected terrorists.” (Emphasis ours). “Limited exceptions to the reasonable suspicion standard exist for the sole purpose of supporting certain screening functions of DHS and State (such as determining eligibility for immigration to the U.S.). Individuals included in the TSDB pursuant to such exceptions are not considered “known or suspected terrorists” and are not screened as such. As a result, any U.S. person who is in the TSDB pursuant to an exception to the reasonable suspicion standard would not be required to undergo heightened aviation security screening at airports on that basis but could be selected for other unrelated reasons such as random selection.”
All Plaintiffs are U.S. Citizens/Legal Residents - Immigration has nothing to do with it. The FBI openly admits they are violating our Constitutional rights. And our rights under the Privacy Act are also being violated. These are plausible, factual allegations which the court accepts as correct, while considering a Motion to Dismiss.
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RULINGS FROM THE 5th CIRCUIT COURT OF APPEALS:
“[C]ourts must …accept all factual allegations in the complaint as true. Stratta v. Roe, supra. “A MTD for lack of subject matter jurisdiction should be granted only if it appears certain that the plaintiff cannot prove a plausible set of facts that establish subject matter jurisdiction.” Venable v. La. Workers’ Comp. Corp., 740 F.3d 937, 941 (5th Cir. 2013).
“When examining a factual challenge to subject-matter jurisdiction under Rule 12(b)(1), which does not implicate the merits of a plaintiff’s cause of action, the district court has substantial authority ‘to weigh the evidence and satisfy itself as to the existence of its power to hear the case.’” Wilmington v. Purifoy, 2022 WL 861509 (S.D. Texas 2022) quoting Garcia v. Copenhaver, Bell & Assocs., M.D.’s P.A., 104 F.3d 1256, 1261 (11th Cir. 1997) (citation omitted); Clark v. Tarrant Cty., 798 F.2d 736, 741 (5th Cir. 1986).
“A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” IM v. Houston Independent School District, 2021 WL 2270271 (S.D. Tex 2021). “A complaint ‘does not need detailed factual allegations,’ but the facts alleged ‘must be enough to raise a right to relief above the speculative level.’ Id., quoting Cicalese v. Univ. Tex. Med. Branch, 924 F.3d 762, 765 (5th Cir. 2019).
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More & More False Statements…
DOJ asserts that Plaintiffs coined the term “non-investigative subject (NIS)” Another false statement from the DOJ. Official DOJ/FBI documents mention and discuss NIS in the TSDB, since at least 2008.
How many false statements should we tolerate? Is that considered “candor with the court?”
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*”Audit of the Department of Justice Terrorist Watchlist Nomination Processes,” Office of the Inspector General, Audit Report 08-16, March 2008.
https://oig.justice.gov/reports/plus/a0816/index.htm
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The FBI, DOJ, CIA, ADL, are all criminal organizations. They shouldn't exist. What good do they do? None. They're criminals who were placed there to facilitate their communist agenda. They are responsible for billions of murders, that go back decades, and still they continue to operate. They should all be in jail, and dismantled. They pose as investigators but are the ones who need to be investigated. Bioweapons come from biolabs, biolabs get orders for these bioweapons to be created, they do it using our DNA. Everything they do has a link. Who's going to investigate them. How are we supposed to win a case if there is no investigation? I know i have bioweapons in my body. I sure didn't buy them at Walmart. When bioweapons end up in a hospital, someone with a name sent them there specificially for named targets. We need a professional investigator to trace all connections. There's always a paper trail or digital trail, and everything that is deleted can be retrieved.
I think you have them Ana. They don't have arguments to present.