Supreme Court Precedent

FBI cannot place non-terrorists on the TSDB list

This Supreme Court ruling completely destroys the Defendant’s claim that our case lacks standing. There is no more discussion… Please hand over the TSDB list!

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The text of our 2 page Motion for Judicial Notice:

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PLAINTIFFS’ REQUEST FOR JUDICIAL NOTICE OF SUPREME COURT PRECEDENT

TO THE HONORABLE COURT:

NOW COME the Plaintiffs, through their undersigned counsel, and respectfully allege and pray:

1. The Second Amended Complaint alleges, inter alia, that Defendants’ dissemination of the Terrorist Screening Database containing subcategories Handling Codes 3 and 4 with the names of non-investigative subjects such as Plaintiffs to over 18,000 law enforcement agencies and over 1440 non-government entities and 533 private entitites violated their rights under the Privacy Act and the United States Constitution and caused them damages.

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2. Plaintiffs respectfully request that the Court take judicial notice of the case TransUnion, LLC v. Ramirez, 141 S.Ct. 2190 (2021). In this case, the United States Supreme Court ruled on the viability of plaintiffs’ claims against defendant TransUnion for sending to third parties as part of their credit reports Office of Foreign Assets Control (OFAC) information erroneously labeling them as terrorists.

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3. The Supreme Court concluded that plaintiffs had standing to sue and had sustained injury-in-fact deriving from defendants’publication to third parties of false information classifying them as terrorists. In so doing, the Court held as follows:

“Under longstanding American law, a person is injured when a defamatory statement “that would subject him to hatred, contempt, or ridicule is published to a third party.”

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TransUnion provided third parties with credit reports containing OFAC alerts that labeled the class members as potential terrorists, drug traffickers, or serious criminals. The 1853 class members therefore suffered a harm with a “close relationship” to the harm associated with the tort of defamation. We have no trouble finding that the 1,853 class members suffered a concrete harm that qualifies as an injury in fact.” (TransUnion LLC v. Ramirez, supra, 141 S. Ct. at 2208-2209)

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3. Discussing the damage being falsely labeled a terrorist on a government list, the Supreme Court expressed:

The harm from being labeled a “potential terrorist” bears a close relationship to the harm from being labeled a “terrorist”. In other words, the harm from a misleading statement of this kind bears a sufficiently close relationship to the harm from a false and defamatory statement.” (TransUnion LLC v. Ramirez, supra, 141 S. Ct. 2209, emphasis ours.

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4. This case does away with Defendants’ claims that Plaintiffs lack standing.

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5. Plaintiffs also request that this Court take judicial notice of the fact that OFAC derives its terrorist list from the consolidated Terrorist Screening Database (TSDB). Pursuant to Homeland Security Presidential Directive 6 (Dkt. 14, Exh. 1), the terrorist information used by all screening agencies derives from the TSDB.

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6. Plaintiffs apologize to the Court for having had to file yet another motion, but the relevance and importance of the case brought to the Court’s attention herein is germane to the controversies pending before the Court carries sufficient weight as to warrant the filing of this motion to request that the Court take judicial notice of this case.

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WHEREFORE, Plaintiffs respectfully request that this Court GRANT this motion and consequently take judicial notice of the Supreme Court’s decision in TransUnion, LLC v. Ramirez, 141 S.Ct. 2190 (2021) as supplemental authority of Plaintiffs’ “Opposition to Motion to Dismiss”.

Respectfully submitted,

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What does this mean for the Government criminals?

1. DOJ, FBI, & DHS willfully and deliberately ignored this Supreme Court ruling in 2021, and ignored our CEASE & DESIST letters sent in 2019.

   https://www.targetedjustice.com/fbi--doj---cease--desist.html

2. Personal Defendants Wray, Garland, Mayorkas, Kable, & Wainstein - willfully and deliberately ignored this Supreme Court ruling, and exercised GROSS NEGLIGENCE.

3. FBI & DHS exercised GROSS NEGLIGENCE by failing to alter their methods according to the Supreme Court ruling, and remove non-terrorist from any distribution list.

4. DOJ exercised GROSS NEGLIGENCE by failing to supervise and properly audit FBI.

5. Personal Defendants Wray, Garland, Mayorkas, Kable, & Wainstein - violated their oath of office, which is a Federal crime.

6. Violation of Federal Civil Rights rights under the Bivens case.

   Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971)

7. Intentional infliction of emotional distress (IIED) by Defendants Wray, Garland, Mayorkas, Kable, & Wainstein.

8. Have already violated numerous Federal laws, including:

   
   -  18 U.S. Code § 241;  Conspiracy to Deprive Constitutional Rights.
   -  18 U.S. Code § 242;  Deprivation of Constitutional Rights.

   -  18 U.S. Code § 1961; Organized Crime Control Act of 1980. (RICO)
   -  18 U.S. Code § 2381;  Treason.
   -  18 U.S. Code § 2382;  Misprision of Treason.
   -  18 U.S. Code § 2384;  Seditious Conspiracy.
   -  18 U.S. Code § 2389;  Recruiting for service against the United States.
   -  18 USC § 2261A;  Interstate Stalking.
   -  18 USC § 875(c);  Interstate Communications.

   -  18 USC § 1512; Intimidating a witness, victim, or an informant

   -  18 USC § 1513: Retaliating against a witness, victim, or an informant

   -  18 USC § 2511; Interception and disclosure of wire, oral, or electronic communications

   -  18 USC § 2517: Authorization for disclosure and use of intercepted communications

   -  18 USC § 1001; Knowingly and willfully concealed

   -  18 USC § 3771; Crime Victims’ Rights Act

   -  34 USC § 20141; Victims’ Rights and Restitution Act

   - 42 USC § 10607(c); Victims’ Rights and Restitution Act of 1990
   
   -  Numerous State laws concerning civil rights.

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Contains opinions of Targeted Justice, Inc.