Docket 67 - Opposition to ICD Motion to Dismiss
No Qualified Immunity.
You can download this latest document (Docket 67 & Exhibits) from our Home page in the BLUE area.
TargetedJustice.com
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Individual Capacity Defendants
Targeted Justice is also suing the Individual Capacity Defendants (ICD). That means that we are also suing the individuals - Garland, Wray, Mayorkas, Kable, and Wainstein for violating our Constitutional rights. The government agencies violated our rights, and so did the heads of these government agencies. Under the Bivens case, which is a Supreme Court precedent case, we can sue these government criminals personally for their involvement. If we are successful, we can clean out their personal bank accounts.
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No Qualified Immunity
Qualified immunity grants government officials performing certain functions immunity from civil suits, unless it is shown that the official violated "clearly established statutory or constitutional rights of which a reasonable person would have known."
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The DOJ responded by claiming that these government criminals have qualified immunity. This is not true. Under HSPD-6, the DOJ, FBI, and DHS were authorized to place names on the TSDB where “reasonable suspicion” existed for “known and suspected terrorists.” There was no authorization or legislation passed by Congress that allowed the FBI to place non-terrorists on a terrorist list - which is a violation of the 4th Amendment.
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The FBI has admitted in government documents that 97% of the names on the TSDB have “no known ties to terrorism.” This means that the FBI operated outside of their legal authority - so they will likely be denied Qualified Immunity.
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Rule 11(b)
SANCTIONS. (1) In General. If, after notice and a reasonable opportunity to respond, the court determines that Rule 11(b) has been violated, the court may impose an appropriate sanction on any attorney, law firm, or party that violated the rule or is responsible for the violation.
Baffling
It is baffling, in light of Rule 11 of Federal Procedures, where the court may impose sanctions (financial penalties) for false statements or misleading information, that false statements were included in the DOJ’s Motion to Dismiss.
Omitting truthful information can also be considered a violation of Rule 11. This is why the Glaring Omissions are a problem for the DOJ. We can also ask for sanctions after the case has a Final Judgement.
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Plaintiff’s Names are on the TSDB
The DOJ continues to avoid any discussion on whether Plaintiff’s names appear on the TSDB. (Remember our elephant newsletter?) If our names are truly not on the list - then they can simply say it! But they don’t. The DOJ, FBI, & DHS have instant access to the latest TSDB, that is distributed everyday.
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Key Evidence
Anyone with a background in Bioethics would be interested to know that Plaintiff Dr Len Ber, MD was diagnosed with Havana Syndrome. The National Academy of Sciences have stated that “the most plausible mechanism” for Havana Syndrome is "directed, pulsed radio frequency energy" (microwave weapons). We encourage readers to view the pictures of our DEW microwave burns.
https://www.targetedjustice.com/microwave-burns1.html
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and read our tab KEY EVIDENCE, to learn how these weapons work:
https://www.targetedjustice.com/key-evidence.html
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The DOJ attorneys
representing the Individual Capacity Defendants (ICD) are:
BRIAN M. BOYNTON
Principal Deputy Assistant Attorney General
Civil Division
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C. SALVATORE D’ALESSIO, Jr.
Director
Civil Division, Torts Branch
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MARY HAMPTON MASON
Senior Trial Counsel
Civil Division, Torts Branch
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Jacob A. Bennett
JACOB A. BENNETT
Trial Attorney
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TONIGHT
TUESDAYS - GoGi's After Dinner J.A.M.
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Juneteenth Edition
The Justice Action Meeting where attendees push past their pain to PLAN, PREPARE and PROGRESS. The focus is on:
1. Preparing for the manifestation of the return of our God-given freedoms here on Earth,
2. Supporting the efforts of the Targeted Justice lawsuit, and
3. Creating a network to Empower, Enlighten and further Enhance the lives of Targeted Individuals.
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DETAILS
Tuesdays - 8:30 EDT (7:30 Central, 5:30 Pacific)
Call in: 605.313.4497
Access Code: 2832692
www.FreeConferenceCall.com/wall/gogi210
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Ana, by the grace of God, you were placed here just at the right time and place to bring down the evil empire. Thank you, Targeted Justice, for your tireless effort to put an bed to these illegal crimes against humanity. Ana, I would like to nominate you for the medal of Valor and the medal of Honor because at great risk to your life and liberty, you are protecting the citizens of the United States in the greatest civil rights lawsuit of the century.!
They all need to pay for the torture of innocent people and children. My child is being tortured every day