Complaint for Damages and Injunction and Declaratory Relief

by Stanley Hilton
June 3, 2002

Stanley G. Hilton, Bar No. 65990
Law Offices of Stanley G. Hilton
580 California Street, Suite 500
San Francisco, California 94104
Tel: (415) 439-4893

Attorney for Plaintiffs

U.S. District Court Northern District of California

Case No. C 02 2493

Complaint for Damages and Injunction and Declaratory Relief

Jury Trial Demanded

Class Action

People of the United States of America, Plaintiffs,
vs.
George W. Bush, President of US; Dick Cheney, Vice President of US: Condoleeza Rice, NSC-National Security Adviser to Bush; Donald Rumsfeld, US Secretary of Transportation; John Ashcroft, US Attorney General; Robert Mueller, FBI Director; Norman Mineta, Secretary of US Dept. of Transportation; Federal Government of United States of America.

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Introductory Allegations

1. Plaintiffs are all citizens of the US, who have been harmed by defendants' actions.

THIS IS A CLASS ACTION, PLAINTIFFS ARE A CLASS OF CITIZENS

2. Defendants are federal officials who have offices in San Francisco, CA

3. Plaintiffs demand a jury triial.

4. JURISDICTION over is conferred by federal statues 29 U.S.C. sec. 1331, and directly under the US Constitution. This court has jurisdiction to hear them.

5. Venue is proper here because, inter alia, one of the hijacked aircraft that crashed on Sept. 11, 2001 was destined to land in San Francisco, CA and crashed in Pennsylvania, due to the actions and malfeasance of defendants, and because defendants' actions have affected plaintiffs who live in Northern California, the jurisdiction of this court. Defendants all have offices here also. Said jet was designed for San Francisco, which is the venue of this court, and since plaintiffs residing inSan Francisco Bay Are were aboard that flight and had relatives on it, this venue is proper and this court can assert jurisdiction over defendants for this actions here. In addition, defendant MUELLER had an office in San Francisco, CA as US Attorney here through on or about June 2001 and operated here then.

FIRST CAUSE OF ACTION: ARISING DIRECTLY UNDER THE U.S. CONSTITUTION FOR VIOLATION OF PLAINTIFFS' CONSTITUTIONAL RIGHTS

6. Plaintiffs reallege and incororate by reference here pargraphs 1 through 5 inclusive.

7. This cause of action is brought directly under the US Constitution, as a Bivens type of action for violation of plaintiffs' constitutional rights.

8. From on or about May 23, 2001 continuously to the present date, defendants and each of them negligently failed to carry out their constitutional duties and engaged in a wanton willful and reckless disregard for the safety, rights and interests of plaintiff, by willfully and intentionally failing to act upon intelligence information they had received betweeen May 23, 2001 and Sept. 11, 2001, and the present edate, specifically an FBI memorandum dated August 6, 2001 (on that date defendant Bush received a memo from FBI and other memos and briefings which clearly informed him of the threat and intent to skyjak jets), pleas from an FBI agent in Phoenix, in July-August 2 a July 10, 2001 memo from the FBI i Phoenix to FBI Headquaerters, other information which clearly pointed to the fact that numerous Middle Eastern persons and "students" were enrolled in flight schools in Florida and elsewhere in the US and were suspiciously training to fly "heavy" commercial jets which could be used by skyjacking and slying the planes into buildings. Defendants also know that said Middle Eastern students ("MES") were in this country illegally, in violation of INS visa and immigration rules, and in fact they were allowed to stay in this country and were not monitored or expelled or placed under surveillance, when they should have been, violated their oath of office and breached their duties to plaintiffs, and breached their constitutional duties to protect plaintiffs from such threats and facts of skyjacking and destruction of lie, limb and property. This action, therefore, is brought directly under the US Constitution as a Bivens type action. Defendants had adequate knowledge of threats and dangers and deliberatly chose to "ignore" these threats, in order to deliberately allow he skyjackers to skyjack the planes on Sept. 11, 2001, and to fly them into the World Trade Center in NYC and the Pentagon. The FBI was informed by flight schools of the skyjackers' mass enrollment in flight schools, and the purpose of defendants in allowing the 9/11 bombings to occur was to boost the popularity of defendant Bush in plitical polls, and to serve as a pretext for declaring a dubious and worthless "wqr on terrorism" which defendants then used to manipulate the Congress into passing numerous restrictive laws. All this action was designed for defendant personal politicalgoals and was counter to the interests of plaintiffs. The fact that defendants then offered a financial award to families of victims who had been killed in the 9/11 attacks, clearly shows their guilt and responibility for the attacks. The 9/11 attack could and should have been prevented by defendants. Defendant Bush specifically violated his constitional oath to "preseve, protect and defend this country and plaintiffs and the Constitution from attack by foreign agents and entities. Plaintiffs maintain that by allowing the 9/11 attacks to occur,despite their knowledge and foreknowledge of this attack plans, the defendants acted in a manner just as culpable and liable and guilty as the skyjackers who actually seized control of the 9/11 jets. In addition, plaintiffs are informed and believe that defendants manipulated and used the CYCLONE ground-remote control technology available to them to directly facilitte the direction and vectors of the jets' flight paths on 9/11/01, and to crash said jets into the World Trade Center and Pentagon, solely to gain political power and tighten their grip on the machinery of goverment, restrict plaintiffs' righs and damage plaintiffs' financial, emotional and physical well-being. Plaintiffs have standing to bring this lawsuit as US taxpayers and citizens, they have a real controversy and damages.

9. Plaints are informed ad believe and allege, that defendants had in their possession on 9/11/01 the technical means and computer programs necessary to enable them to disable the pilot conrols of the planes (by remote control) that crashed into buildings on 9/11/01 (this technical means is hereby designated CYCLONE. The CYCLONE program was in place and defendants acted negligently and in violation of plaintiff constitutional rights by failing toemploy it to disable the skyjackers' controls of their planes, and to substitute instead a "remote control" of the aircraft from a nearby plane, military base and/or conrol tower and airline office. The CYCLONe program was in place and defendants knew he three jetliners had strayed from their directed path (flight path from Boston to Los Angeles and from Neward to San Francisco and from Boston to te Penagon), and defendants had over an hour of warningtime to use CYCLONE to take over control of the jets and land them harmlessly, but they inexcusably failed to do so. Defendants then set up an illegal "shadow government," under he direction of defendants Bush and Cheney, in secret and without even briefing theCongress, and setthis shawdow goverment up with the intent to deprive plaintiffs of their constitutional rights, as the shadow goverment would be made up of persons and entities possession unconstitutional and dictatorial power, pursuant to the contrived and manufactured pseudo "crisis" which defendants planned to manufacture. On or about 9/11/01, defendants also vioated teir constitutional duties by willfully escorting, providing transportation means for, and permittingmembers of Osama bin Laden's family to jet across the US and fly out of the country, even while defendants claimed publicly that bin Laden was rewsponsible for the 9/11 terrorist jet attacks. In so doing, defendant Bush acted in sch a manner as to place his own family's financial ties to the bin Laden family and Saui oil interets, above the interests of plaintiffs, as Bush and his father in particular have had many financial and personal ties to the bin Laden family and other Saudi oil interests which were responsible, allegedly, for the 9/11 terror attacks against plaintiffs and their interests. Defendants then so negligently and draudultly ran a military campaign in afghanistan, and particularly in the area of tora bora, Afghanistan, in or about December 2001, that they deliberately and intentionally and/or negligently allowed bin Laden to escape Afghanistan and go into hiding. Defendants then falsely claimed they did not need to capture him, even after forcing military personnel to engage in a dubious "war" for the alleged original purpose of capturing bin Laden and Al Quada. Defendants Rumsfeld, Cheney and Bush intentionally let bin Laden and Al Quaeda forces escape, in order to further damage plaintiffs and create more terror attacks and to whip up hysterical fears among plaintiffs, so that defendants could tighten their grip on the US political and military and government apparatus, all in gross violation of the constitution and plaintiffs' constitutional rights.

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