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Kathleen M

VIEWS: 67 PAGES: 61

									Kathleen M. Dickson
Lara E. Dickson
Diane M. Dickson
David D. Dickson, et al,
And on behalf of all Families and
Children of the State of Connecticut

In the cause of a class action:

v. STATE OF CONNECTICUT                                                US DISTRICT COURT
                                                                               1 Exchange Terrace
                                                                               Providence, Rhode Island
02903

                                                                                27 JULY 2005

                                            AFFIDAVIT

    I, Kathleen M. Dickson, representing residents of the State of Connecticut, claim the following abuses
    and neglect of duty by employees of the State of Connecticut:

    Civil and human rights abuses, color of law violations, deprivation of rights, and conspiracy to deprive
    of rights, and regarding the well-known and numerous acts and examples of incompetence, perjury,
    acts of defrauding the courts, state employees defrauding the police, the police defrauding the
    courts, judicial misconduct, the State of Connecticut‘s defrauding The United States of America, the
    criminal behavior of the Department of Children and Families (DCF) and related staff, and DCF‘s well-
    documented abuse and neglect of children and families, and in default of the protections guaranteed
    by federal and state laws,

    DO HEARBY SWEAR that the following statements are truthful, sworn testimony, written as any
    reasonable person would understand, before God, as stated.


Statutes and Rules Violated
18 U.S.C. Section 241 Conspiracy Against Rights
18 U.S.C Section 242 Deprivation of Rights Under Color of Law
18 U.S.C. Section 245 Federally Protected Activities
Americans With Disabilities Act
Risk of Injury to Minor Children
Racketeering Influenced and Corrupt Organizatrions (RICO) violations


Plaintiff KM Dickson requests of the District of Rhode Island federal court to be fully respectful of the
abundantly common public knowledge of the loss of the public trust due to the indictments and criminal
racketeering behavior of the former - and now criminal- Governor John G. Rowland and his staff as
regards the Connecticut Department of Children and Families (DCF), and the fact that DCF in January
2004 was criticized by the Hartford Courant as
‖For a while, it seemed as if the Department of Children and Families belonged to the scandal of the
week club‖.


Plaintiff KM Dickson respectfully asks the court to consider and agree that the following is true and
documented, except where specified in the document to have not been delivered previously to the State
of CT in the specified datapackage (one known case):


ROWLAND RACKETEERING

1) The families of the State of Connecticut were victimized by the corrupt and abusive practices of the
CONNECTICUT DEPARTMENT OF CHILDREN AND FAMILIES and their former Commissioner KRISTINE




                                                                                                            1
RAGAGLIA, the former Governor JOHN G. ROWLAND, his chief of staff PETER ELLEF, his co-chief of staff
LAWRENCE ALIBOZEK. These individuals were criminally charged and/or prosecuted and/or sued, with
WILLIAM TOMASSO in the past year. The charges and civil allegations were theft of honest services of the
government and racketeering. This was described as depriving the public of the honest services of the
government, and Governor …―Rell said, ‗Anyone who violated the public trust must be prosecuted to the
fullest extent of the law.‘‖ [Exhibits A, B, C, D]

CT OFFICE OF POLICY AND MANAGEMENT‘S INVOLVEMENT IN THE ROWLANDGATE SCANDAL:2) The former
Manager of the Office of Policy and Management, MARC S. RYAN apparently left the state unscathed in
the criminal and civil actions of the above named individuals. The CONNECTICUT JUVENILE TRAINING
SCHOOL (CJTS) built by the TOMASSO Brothers is a CT State disgrace, as was the abuse of the pediatric
prisoners by the guards. Governor Rell ordered DCF‘s current commissioner to come up with a plan for
what to do with CJTS by July 1, 2005, to include closing it.

RYAN having been complicit in the misapplication of his duties to soundly provide for the residents from
the federal funding, under the demands of his duties as specified above, was not punished.

ABUSE OF CHILDREN PRISONERS:

3) The children were abused in this prison. Attorney General RICHARD BLUMENTHAL‘s and the CHILD
ADVOCATE‘S (Jeane Milstein) Press Release states: ―The manhandling and mistreatment of children
shown in these videos demands swift, strong steps to reform and revamp this facility.‖ [Exhibit D].

One may conclude that children are abused in DCF‘s ―care.‖

THE DCF – ROWLANDGATE BILLS:

4) JOHN G. ROWLAND sponsored the bills HB- 5021 (1998) and HB-6999 which stated ―The proposed
increases in spending are attributed to higher than expected spending requirements in federal
entitlement programs (Medicaid and Temporary Family Assistance), lower than budgeted savings from the
Early Retirement Incentive Plan, the carryover effect of current years deficiencies and the Governor‘s
new initiatives….‖

And

―An additional growth factor is the increase of termination of parental rights petition approved by the
courts, which leads to a child being defined as ―no-nexus.‖ [Exhibit E]

One might conclude that since the Rowland is in jail for his facilitating this abuse of funding and did not
provide adequately for the children of the State of Connecticut.

CT DCF DEFRAUDING THE UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES‘ AGENCY FOR
CHILDREN AND FAMILIES:

5) In “CAREENING TOWARDS CRISIS,” The Connecticut Voices for Children have determined that the
State DCF “misallocated” the UNITED STATES’ Department of Health and Human Services Agency for
Children and Families’ Temporary Aid to Needy Families (TANF funds), which were intended to go to
needy families, but were instead delivered to the salaries of State DCF employees. [EXHIBIT F]

Among their findings:

      ―Connecticut‘s budget now invests far too little in the home and community-based services that can
      prevent child abuse and neglect in the first place…

      … an increasing share of funds being spent on more costly and restrictive institutional and
      restrictive institutional out of home care.



                                                                                                              2
        DIVERSION OF TANF BLOCK GRANT funds to fund DCF staff…
        DIVERSION of Title IV-B funds to fund DCF staff…”


This report reads like an indictment of DCF in defrauding the federal government and the residents of CT
of the DHHS‘ Agency for Children and Families‘ Temporary Aid to Needy Families it received. From page
2 of this indictment:

                                             ―KEY FINDINGS

                 1. Growth in DCF‘s Budget Has Far Exceeded Growth in DCF‘s caseload

In the last decade, the number of children served by DCF increased from 7,500 children at the end of FY
94 10 12,247 children at the end of FY 04 (a 63% increase). DCF‘s General Fund budget grew faster- from
$227.6 million in FY 94 to 606.1 million in FY 04 (a 165% increase), With DCF‘s revised SFY 05 General
Fund budget at $642.6 million, there has been a 182% nominal increase since FY 94. While some of this
growth is attributed to the more complex clinical needs of children now in care and to long overdue
investments to improve the quality of care of these children, much growth is also due to skewed spending
policies that skimp funding for services that could reduce child welfare involvement while, at the same
time, increasing spending for ―back end‖ placements and services.‖




                                        “ROWLAND’s NUMBERS”




6) The former Governor JOHN G. ROWLAND made this claim on his website: “To help protect children,
Governor Rowland has hired more social workers, moved more staff into the field to work directly
with at-risk children, and made it easier to remove at-risk children from abusive homes. The number
of children in new permanent homes has jumped 445 % since 1996, while the number of children
found to have been abused or neglected has fallen 45 % since 1997."

Plaintiff(s) personally find this to appear to show that 10 times as many children were taken from their
parents as needed to be. If 1000% of children were taken, then there would be zero children found to be
abused or neglected.
Additionally, in the January 5, 2004, Hartford Courant, in ―COMPLICATED MAN AT THE CENTER OF THE
CORRUPTION PROBE—Peter Ellef was a big dreamer.‖
“As Gov. John G. Rowland’s co-chief of staff, Ellef spoke of levitating trains, hydroponics gardening,
building prisons in old stone quarries and opening trade relations with China. His plans after state
service included developing a string of juvenile detention facilities across the country, a chain of
home improvement stores and a high-end garden center.

To the casual observer, the alleged racket run out of Rowland‘s office involved increasing the termination
of parental rights because that made the ―racket‖ eligible for more federal funding, proportionate to the
increase in ―no-nexus‖ children needing to be housed in some facility (like a prison) or another. [EXHIBIT
E- the bills ]

DETENTION VS PREVENTION, the VIOLENCE IN HARTFORD:

7) ―VIOLENCE HIGHLIGHTS DCF‘s ROLE.‖ The Child Advocate Jeane Milstein said in an article dated the
20th of June 05 in The Hartford Courant,




                                                                                                        3
“The state DCF anticipates spending $762,00 on prevention programs targeting teens in the coming
year. The amount is one-tenth of 1 percent of he agency’s $762 million budget, even though
prevention is one of the agency’s four principal missions; the others being child protection, juvenile
justice and meeting children’s behavioral health needs.

 “It’s amazing that DCF has no problem spending taxpayer money to the tune of $514,000 per child,
per year at the Connecticut Juvenile Training School, but it can’t find the funds in its $700 million
budget on prevention programs targeting teens in the to help mentor troubled youth in our
communities.” [EXHIBIT G]

Plaintiff KM Dickson had made the claim that JOHN G. ROWLAND was using the DCF as a ―federal money
farm for the Tomassos.‖ It is now unclear who, if ―TREA‖ was a real entity, and if TREA is an acronym for
the names of the federally indicted, and that one cannot conclude the ―R‖ stands for ROWLAND, but may
stand for RAGAGLIA, since this was a limited liability corporation, and to my knowledge, MS RAGAGLIA is a
lawyer. A lawyer might be necessary to set up a limited liability corporation.

AN APPALLING COMBINATION OF ARROGANCE AND INEPTITUDE:

8) The CT DCF was resoundingly criticized in August 2004, by JUDGE CARMEN LOPEZ for “an appalling
combination of arrogance and ineptitude, ” in cases where DCF workers defraud the courts, in an effort
to gain custody. PAUL CHILL of UCONN Law school was quoted in the Connecticut Law Review as saying,
“ was appropriately intolerant of official malfeasance and abuses of power in the child protection
system.” Chill, who has run advocacy clinics on child protection issues for 16 years, said Lopez was the
first judge to hold DCF accountable.‖ [EXHIBIT H]

THE SETTLING OF THE 1989, 15 YEAR OLD CIVIL RIGHTS CLASS ACTION AGAINST DCF:

9) ChildrensRights.org - Juan F. case lawsuit. (2003). “In October, the state and the lawyers for thousands of
Connecticut abused and neglected children reached an unprecedented landmark agreement after the state and its
Department of Children and Families (DCF) were charged with contempt of court for failing to comply with the court
orders and improve services for children. [EXHIBIT I]

Subsequently, “CASH INFUSION IS TO PROVIDE ALTERNATIVES TO STATE’S DETENTION CELLS,” (news
article) June 27, 2005, The Hartford Courant. [EXHIBIT J]

“The 8.5 million dollar settlement “between attorneys representing hundreds of children in juvenile
detention in a federal class action lawsuit and the state agencies that manage the detention centers
and children’s mental health programs.”

“The settlement also calls for increased training and cooperation on the part of state social workers,
juvenile probation and juvenile parole officers to make sure children with serious emotional needs
have detailed treatment plans so that they can get the proper services that they deserve”.

DCF was sued for civil rights violations, which took nearly 15 years to resolve, and which concluded with increased
training and cooperation. Plaintiff KMDickson had made the claim directly to Assistant Attorney General James Kelly
that DCF staff were “cognitively and morally challenged” on January 27, 2003, and “cognitively and morally
impaired,” January 28, 2003. Reading DCF’s “records” give once the sense that the DCF staff and reality are two
entirely different universes. Plaintiff KMDickson was an analytical chemist for Pfizer, Inc, and thus record keeping,
being absolutely accurate is imperative.

Conservatively speaking, the DCF’s record-keeping indicates that mild mental retardation may be a DCF employee job
requirement, as is demonstrated by Plaintiff KM Dickson in her replies to complaints made to the Statewide Bar
Counsel and CT Commission on Human Rights, with the evidence. For examples, science does not equal insanity,
although DCF’s former New Haven principal attorney, Sarah Gibson, believes it does. A DCF “worker” Lisa
McArthur informed Plaintiff Dickson that her dog and grandfather died of Lyme disease. Plaintiff KM Dickson gave
this “worker” a great deal of scientific information about how damaging Lyme disease is to the nervous system. Later,
DCF’s McArthur and her co workers wanted to know how serious was Lyme disease. Plaintiff KM Dickson suggested
that if McArthur and her coworkers can’t read, perhaps they could visit the cemetery to see if McArthur’s grandfather
had improved.




                                                                                                                     4
APPLAUSE FOR THE PROPOSED END TO DCF’S INCOMPETENCE AND ABUSES:

10) “FORUM ADDRESSES CHILDREN, FAMILIES,” (news article) Hartford Courant June 28, 2005

“The forum focused on ways current state and federal funding needs to be changed to better protect children
and promote healthy families.”

“We need a major overhaul,” Sirry (the federal court monitor of the DCF) said to applause from the crowd of
about 100 child welfare professionals.” [EXHIBIT K]

There appears to be a broad consensus that DCF is hardly successful.


THE FAILURE OF THE MENTAL HEALTH SYSTEM:

11) The current LT. GOVERNOR KEVIN B. SULLIVAN was commissioned to uncover the source of ―the
failure of the mental health system‖ and the June 9, 2005 statement on Mr. Sullivan‘s website says the
following:

           “But make no mistake,“ Sullivan added, “this is just the beginning of what we need to do in order to
build a more effective and more efficient system of community-based mental health care that works and is less
expensive that what we are doing now. Over the next three years, we need to keep the momentum for reform
that has been lost too many times in the past. I also remain deeply troubled that the Governor, who had no
hesitation taxing nursing home patients in part to help maximize federal Medicaid funding for longterm care,
still refuses to end Connecticut‟s sad distinction as the only state in the nation not to take get back more of our
federal tax dollars by taking full financial advantage of major Medicaid funding. This would go a long way in
helping reinvest in mental health care for children and adults.”



Recent examples of the CT ―mental health system‘s‖ alleged criminal behavior:

HOSPITAL PSYCHOLOGIST FIRED (Hartford Courant) published on June 23, 2005,

”A veteran psychologist at a state-run psychiatric hospital for children has been fired after
investigators found he downloaded pornography on his work computer.

Kenneth C. Thunberg, 54, of Deep River, was on paid administrative leave from the Riverview
Hospital for Children and Youth while officials from the state Department of Children and Families,
which runs the Middletown facility, investigated.

Thunberg counseled children at Riverview for 12 years. Notified of his dismissal last.......” [EXHIBIT L]


Prominent Psychologist Faces Charges Eating Disorder Expert Inhaled Gas, Police Say
July 12, 2005, By TOM PULEO, Courant Staff Writer
WEST HARTFORD -- A prominent psychologist who specializes in eating disorders faces criminal
charges after she inhaled propellant from whipped cream cans and collapsed on a supermarket floor
in May, police say.

Lisa G. Berzins, 49, of 9 Talcott Glen Road in Farmington, was charged in a warrant Friday with
possession of a restricted substance, third-degree criminal mischief and creating a public
disturbance. She was released on $500 bail for a July 21 appearance in Superior Court in Hartford.

"These are only allegations," said Berzins' attorney, Bob Ludgin of Hartford. "My client is innocent
unless convicted. I have confidence that there will be no convictions."

Berzins, who has a practice listed at 91 S. Main St. in West Hartford, has lectured and written widely
in the areas of eating disorders, female development, sex roles and self-esteem, according to her
speaker's biography listed with the American Psychological Association.



                                                                                                                      5
Her resume includes listings as director of the eating disorders programs at the Institute of Living in
Hartford, and the former Elmcrest Psychiatric Institute in Portland. It was unclear when she held
those positions.” [EXHIBIT M]

----

Mumbo-Jumbo Syndrome.

“Munchausen‟s syndrome by proxy is a quintessential example of that most suspect of scientific theories — one
that brooks no rational argument, a closed circle we all must accept at face value.

For example, the only cure must begin by the sufferer accepting that he or she is afflicted with the condition —
which, of course, the alleged sufferer is loath to do. But if someone who is diagnosed as a sufferer vociferously
denies it, this serves to reinforce the diagnosis. A denial of the condition is, perforce, a symptom of the condition.
And then there‟s this: there is no cure but it is accepted that sufferers can sometimes continue to live among
other people without exhibiting the symptoms — murdering people or making them ill. Furthermore, there is no
agreed biological or psychological cause.

So there we have it: an illness that has no cause or cure and that is diagnosed at least partly by the alleged
victim‟s denial that he or she is so afflicted. The more the victim denies it, the more obviously the victim is
afflicted. And it is an illness that may somehow exist within a person without cause or cure or indeed any
manifestation of its symptoms.

In the medical establishment, in the law courts and in the press, why were we prepared to believe this guff for
more than a quarter of a century and send people to prison as a result?” -- TIMES ONLINE, UK


Parents who say their children have Lyme disease, are often accused of Munchausen‘s by proxy. It is not
unusual for a psychiatrist to say that the denial of the illness, is a sign of the illness. Here, the writer
questions why we accept this medical mumbo-jumbo and circular reasoning on the basis of zero evidence,
in the courts, and in the press, and in the medical establishment. [EXHIBIT N]

FALSE ACCUSATIONS OF TERRORISM
12) Plaintiff KM Dickson complained to the USDOJ and National Institute of Mental Health on November
11, 2003, that the DCF apparently falsely informed the Stonington, CT Schools and the Stonington, CT
Police that Plaintiff KM Dickson was a terrorist, or intent on murder, and the schools then had a special
terrorist drill, and ordered Plaintiff Dickson off the schools‘ grounds. This is a National Security risk,
because this distracts police from real terrorisms targets surveillance. AAG JESSICA GAUVIN listed this
communication in her second petition as evidence that Plaintiff KM Dickson was insane (Nov 11, 2003
Vigilante Justice complaint). Plaintiff KM Dickson was complaining to the USDOJ and NIMH that DCF was
insane, which is more obviously the truth. Plaintiff Dickson testified at the FDA about how Yale‘s
dangerous LymeRIX vaccine was not a vaccine. The vaccine came off the market a year later. DCF did
not help children in this way as regards Lyme disease or as regards the dangerous LymeRIX vaccine.
Instead DCF accused Plaintiff Dickson of being a terrorist. The United States Department of Justice may
find this to be criminal behavior on the part of the DCF. It appears that this all started with Donald G.
Dickson‘s false accusations that Plaintiff KM Dickson intended to drive her children into a lake. [EXHIBIT
O NIMH and ―Vigilante Justice?‖]
Plaintiff KM Dickson found outer, after Nov 21, 2003, that Donald G. Dickson was the one who filed the
false DCF accusation that Plaintiff KM Dickson of intending to kill Plaintiff‘s children from reading the
Lyme disease newsgroup. [EXHIBIT P Chuck P Adams‘ post]

       DCF’s INCOMPETENCE AND THE RHODE ISLAND TICK BORNE DISEASES MANAGEMENT PLAN

13) Plaintiff KM Dickson submitted testimony to the April 2002 Rhode Island Tick Borne Diseases
Commission regarding the fraud of Lyme disease, with substantiating documentation, entitled ‖ The
Rhode Island Tick Borne Diseases Management Plan.‖ Rhode Island passed legislation protecting
physicians from the Organized Crime and Racketeering-Influenced Corruption as regards Lyme Disease,
CT DCF staff Maureen Auger asserted that since Plaintiff KM Dickson was the author of this document



                                                                                                                    6
[EXHIBIT Q], it was meaningless. These are largely summaries of abstracts published in the scientific
literature. If these scientific articles are meaningless, DCF‘s Maureen Auger should take up her claim that
this science is meaningless with the National Library of Medicine, the publishers of these journals and the
scientists who produced these reports.
Instead of the Plaintiff KM Dickson‘s Tick Borne Diseases Management Plan being adopted by the State of
Rhode Island, it was adopted by commercial interests in Rhode Island. This is evidence of DCF‘s
incompetence.

FALSE DCF ACCUSATIONS MISHANDLED
14) The psychiatrist-diagnosed (diagnosed by J. David Ruffner, MD, Psychiatrist) ―sociopath,‖ Donald G.
Dickson, falsely claimed to the DCF that Plaintiff KM Dickson was going to drive her children into a lake.
Nancy E. Martin, 21 Redstone Way, Farmington, CT made numerous false allegations to DCF, and was not
arrested at the depositions, where these allegations were discovered to be false. Nancy Martin
proceeded to lie under oath, however, and give a vague explanation of Plaintiff KM Dickson‘s having been
talking about her grandparents, as if they were alive during Plaintiff Dickson‘s brother‘s funeral in 1977.
In fact, they all were dead for 12 years by 1977, and no such bizarre conversation happened. Nancy E.
Martin, and Donald G. Dickson further perjured themselves at Plaintiff KM Dickson‘s DCF ―trial.‖ Every
single statement made by the DCF‘s witness at Plaintiff Dickson‘s ―trial‖ was perjury, with the exception
of James Phillips saying Plaintiff Dickson was a victim of child abuse. That abuser was Carolyn Martin,
who, we found out at the depositions, invented herself, that Plaintiff KM Dickson said she would ―slit her
own throat,‖ an accusation which made its way into the DCF‘s first petition, which was thrown out, and
but was retained as part of a final statement DCF made for the court, December 23, 2004. Carolyn
Martin was also not arrested by DCF for making false allegations.

The ―sociopath‖ Donald G. Dickson made other false allegations to the DCF at least twice, and once told
the DCF falsely that Plaintiff KM Dickson ―beats the children‘s butts until they are red,‖ ―pokes them in
the face with sticks,‖ and ―screams at them non-stop for two hours.‖ Plaintiff KM Dickson is sick with the
Multiple Sclerosis presentation of Lyme Disease. If Plaintiff KM Dickson could scream for 2 hours, she
would not be disabled from Lyme Disease.

DCF’s DELIBRATE RISK OF INJURY TO MINORS
15) Plaintiff Dickson faxed DCF‘s Lisa McArthur on January 6, 2003, the extensive evidence of Donald G.
Dickson‘s abuse history, including his arrest for domestic violence (1993), a restraining granted order
against Donald G. Dickson (1996), and a letter from the Battered Women‘s Shelter in New London, CT
(1994), stating that Plaintiff KM Dickson and her 2 older children had to stay there temporarily for safety
from Donald G. Dickson. [EXHIBIT EE The alleged ―harassing communications and threatening‖] This
should have been enough evidence that Donald G. Dickson was not a reliable witness. Instead, DCF gave
the Plaintiff KM Dickson‘s children to this well-known child abuser (taken in testimony by DCF of the
children themselves) and wife beater, Donald G. Dickson, which is illegal. This is risk of injury to a minor:
―Anyone who exposes a child to harm or fails to protect a child from physical assault may be prosecuted
under the risk of injury statute.‖ Hartford Courant, July26, 2005

DCF informed Plaintiff KM Dickson‘s children that if they complained about being placed with an abusive
parent, they would be kidnapped again and placed in separate foster homes, therefore this dangerous
placement was deliberate.

The CT statute regarding false allegations to DCF stipulates a $1500 fine and up to a year in prison, yet
when Plaintiff KM Dickson tried to discover how to prosecute false allegations, the Middletown Superior
Court, and the Milford State‘s Attorney‘s office did not know whose job it was to prosecute false
allegations, because, as they told Plaintiff Dickson, no one had ever been prosecuted for false allegations
before. Thus, DCF are incompetent to an apparently unlimited number of their own statutes.

―CONFIDENTIALITY‖ AND ―IMMUNITY‖
16) ―Judge‖ John C. Driscoll stated that the ―proceedings‖ of a DCF ―trial‖ are confidential, however,
DCF‘s former New Haven principal attorney, Sarah Gibson sent Plaintiff KM Dickson a copy of Connecticut
Statute 17a-28, which clearly states that the ―person‖ who is a defendant, and who is guilty regardless of
being proven innocent, may give any information about their DCF ―case‖ to whoever they want. Plaintiff
KM Dickson, as a long time human rights activist, exposed the fraudulent and bizarre activities of CT DCF
to the entire world, so that other families may be warned and protected against their abuse, by scanning




                                                                                                           7
in evidence into her website and posting to various newsgroups, the truth about DCF‘s behaviors and
incompetence.

The only reason these DCF proceedings are kept ―confidential,‖ is to protect from criminal liability, the
perjury of the DCF, their deliberate defrauding of the courts, and the perjury they orchestrate with their
witnesses under their ―immunity.‖ That the average legislator can‘t see the reasoning behind these
combined conditions, ―confidentiality‖ and ―immunity,‖ especially in the face of the rising budget and
445% increase in children taken from their parents in contrast to a 45% reduction in child abuse, and
especially when it is well known that the mental health system is a failure, speaks to legislators‘ either
motives or incompetence. The statute clearly states that the defendant/perp may release records to
anyone they want, canceling out any confidentiality rulings.

 The CT DCF and their inane statutes are clearly organized crime and racketeering influenced, due to the
obvious intimidation attempts to commit and attempts to falsely arrest people who complain to the
proper authorities about the criminal behavior of the CT DCF staff.

RECENT NEWS REGARDING CT DCF‘s CARE OF PEDIATRIC PRISONERS:
17) CT DCF is in charge of the juvenile justice system in CT. In today‘s (July 27, 2005) Hartford Courant,
it was claimed that:
―And some say that when 16- and 17-year-olds are added in, Connecticut has the nation's highest
incarceration rate for youths.‖ This news article comes on the heals of yet another child who killed
himself in DCF‘s ―care,‖ this past Sunday, July 24, 2005. The child hung himself in one of the DCF‘s
prisons for children. It never ends. DCF shows no signs of willingly ending their practices of harming
children, will not do so voluntarily, and retaliate against people who claim abuse by DCF and ask for relief
and fairness.

“ROWLANDGATE” AND NATIONAL SECURITY:
18) This extraordinary number of children removed from parents, jailed, and mistreated by DCF may
have something to do with John G. Rowland describing himself as ―a National Security Advisor‖ to
President George W. Bush. The criminal enterprise run out of Rowland‘s office, TREA, was about a
―national string of prisons and juvenile detention centers.‖ Some people have claimed that this Bush
administration plans to incarcerate people who protest against the NeoCon abuses masterminded by Paul
Wolfowitz:

“Project for a New American Century

Wolfowitz however could not remain completely out of politics for long and in 1997 he became one of the
charter members, alongside Donald Rumsfield, Dick Cheney, Jeb Bush, Richard Perle and others, of the Project
for a New American Century (PNAC). William Kristol and Robert Kagan founded this neo-conservative think-
tank with the stated aim of "American global leadership" through military strength. In 1998 Wolfowitz was one
of the signatories of the PNAC open letter to President Bill Clinton that was highly critical of his continued
policy of containing Iraq. The PNAC advocated preemptive U.S. military intervention against Iraq and other
"potential aggressor states" to "protect our vital interests in the Gulf". In 2000 the PNAC produced its magnum
opus the 90-page report on Rebuilding America's Defenses: Strategies, Forces and Resources for a New Century
that advocated the redeployment of U.S. troops in permanent bases in strategic locations throughout the world
where they can be ready to act to protect U.S. interests abroad. The Clinton administration however remained
unmoved and pressed on with containment.=== wikipedia

Pre-emptive military aggression, when it is clearly about oil and not national security, may result in a
national security risk to Americans. Americans might not stand for the increased terrorism, in retaliation
for a fraudulent Iraq war, directed at Americans, and Americans might also rebel against this
―administration,‖ or the concept of the United States becoming the self-designated World Police. Such a
rebellion could be accommodated by a national string of prisons and juvenile detention centers. America
has little GNP or natural energy supplies of our own, and in such an economically disadvantaged state it
appears that the US has little choice but to become a world police force. Perhaps the plan is to pay
ourselves by taxing other countries for this unwanted service. Paul Wolfowitz is now the head of the
World Bank. Bush‘s 2005 Inaugural speech contained these passages:




                                                                                                             8
“A few Americans have accepted the hardest duties in this cause - in the quiet work of intelligence and
diplomacy ... the idealistic work of helping raise up free governments ... the dangerous and necessary work of
fighting our enemies. Some have shown their devotion to our country in deaths that honored their whole lives -
and we will always honor their names and their sacrifice.

All Americans have witnessed this idealism, and some for the first time. I ask our youngest citizens to believe the
evidence of your eyes. You have seen duty and allegiance in the determined faces of our soldiers. You have seen
that life is fragile, and evil is real, and courage triumphs. Make the choice to serve in a cause larger than your
wants, larger than yourself - and in your days you will add not just to the wealth of our country, but to its
character.”      [EXHIBIT R]


DANGEROUS PERJURY- DMHAS
19) DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES‘ (DMHAS) ―Medical Director,‖ Kenneth
Marcus, [see EXHIBIT X for more background info on ―Dr.‖ Marcus] came to Plaintiff Dickson‘s DCF ―trial,‖
perjuring himself in court and said you treat an organic delirium like any other psychosis, when that is
clearly against the American Psychiatric Associations (APA) Guidelines, due to the increased brain damage
caused by this mistreatment [EXHIBIT T ].
The APA guidelines clearly state, ―When delirium is comorbid with other psychiatric disorders, the
delirium should be treated first. ― This is a guideline that should apply to all persons with neurologic
Lyme disease. Central nervous system Lyme disease should be treated with ceftriaxone. The guideline
continues:
―Medications for psychiatric disorders can be both the cause of delirium and exacerbate or contribute to
delirium from other causes.‖
Lyme disease is an organic brain syndrome. [EXHIBIT U] As published by Allen Steere in 1989, ―Lyme
disease may affect the central nervous system causing organic brain syndromes suggestive of
demyelination.‖
In an world uncomplicated by the perversion of dogma regarding the source of emotional trauma, wherein
sexual repression is considered to be the cause of child abuse emotional sequelae, instead of child abuse
being the cause of child abuse sequelae, as is the case of the perverted world of James Phillips, MD,
Clinical Professor or Psychiatry at Yale and Forensic Psychiatrist for the State of Connecticut, a mere
reading of the scientific documentation given to James Phillips, MD, regarding the science of Lyme as a
brain disease, by Plaintiff KM Dickson, would have alleviated the steps where the Plaintiff KM Dickson‘s
children were traumatically removed by DCF, and Plaintiff KM Dickson went to jail, in the end, for Carolyn
Martin‘s child abuse. We could have moved on to guaranteeing proper medical treatment for Plaintiff KM
Dickson and her children, and a validation of this neuropsychiatric disease, borreliosis. Freud is out of
style. Freud invented, in fact, his psychotic assertions that the world‘s woes are due to inadequate sex
instead of inadequate care or love, because the fathers of Freud‘s female ―hysteria‖ patients, were in
fact, the sexual perpetrators against these female children, who later grew up to be Freud‘s ―hysterical‖
patients. The fathers did not approve of Freud‘s discoveries. Modern Psychiatry, thanks to the bad
fathers of Freud‘s day, was then founded upon the concept that the victim is the guilty, or the victim is
the ―bad‖ one. Little has changed.

DMHAS‘ Kenneth Marcus also said for the DCF ―court,‖ something to the effect that Plaintiff KM Dickson
―is so psychotic, she does not know how psychotic she is, which is a sure sign of her psychosis.‖ Plaintiff
had left numerous scientific journal articles in the office of Laura Lustig, PhD, of The New Learning
Center, Westport, CT, which demonstrated the cellular brain damage and other damage caused by most
psychotropics. These were also on Plaintiff KM Dickson‘s website, ActionLyme.com. This is not only
perjury and promoting malpractice, but more psychiatric Mumbo Jumbo. With this reasoning, Plaintiff KM
Dickson could make the claim that ―DCF and DMHAS staff are so stupid, they don‘t know how stupid they
are, which is a sure sign of their stupidity.‖
More seriously, it calls into question the validity of any psychiatric expert testimony in any legal case,
since this was clearly an attempt by DCF to commit Plaintiff KM Dickson, in an attempt to falsify more
records, and preventing Plaintiff from filing malpractice lawsuits and other complaints about the criminal
behavior of the DCF, as regards Yale‘s dangerous Lyme vaccine, and as regards the Yale/Allen Steere-
orchestrated apparent conspiracy to create a fraudulent testing schema for Lyme disease to pass off their
bogus Lyme vaccine, LymeRIX, and to also guarantee a monopoly on the post-FDA approval of Yale‘s
LymeRIX vaccine.
This perjury, on the part of DMHAS‘ Medical Director, is a severe and dangerous color of law abuse, and
should result, minimally, in Kenneth Marcus‘ immediate resignation. [EXHIBIT V- 3:05-CV-91 (CFD)]



                                                                                                                 9
Yale and DMHAS‘s Vladimir Coric fraudulently reported to the criminal court numerous aspects of Plaintiff
Dickson‘s mental health. The Plaintiff‘s children‘s Ad Litem, Priscilla Hammond (Old Lyme CT), walked
up to Plaintiff Dickson November 21, 2003, after the DCF depositions, in Milford, CT, and said, ―The State
is watching this case very closely.‖
Therefore, it is not paranoid of Plaintiff Dickson to be saying, ―The State is watching this case very
closely.‖ Coric also perjured himself and stated that Plaintiff Dickson was treated with antipsychotic
medication for 5 years when she was in her twenties. Plaintiff Dickson had stated to Coric, that she was
given exactly and only 3 bottles of tranquilizers to be used as needed, over a 5 year period, and in
truthfulness, and to indicate that there was little medication involved in Plaintiff KM Dickson‘s previous
psychiatric history of depression due to the child abuse by Carolyn Martin, Plaintiff‘s ―mother.‖

Carolyn Martin is now responsible for destroying the lives of exactly 9 children: five of her own, and four
grandchildren, due to her abundant and bizarre lying, hatefulness, and chronic- and lifelong- extreme
physical violence to children, which included beatings with a cat of nine tails (whip), beatings with this
whip with and without clothing, and full force kicks upon children. That Carolyn Martin is free to harm
more children is a testament to the failure of the ―mental health system,‖ the ―child protection system,‖
and the ―criminal justice system‖ in Connecticut. [EXHIBIT W, Carolyn Martin is known by all to be a
crazy person.]

REGARDING THE DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES AND THEIR RELATIONSHIP
WITH THE DEPARTMENT OF CHILDREN AND FAMILIES:

20) DMHAS is incompetent to brain matters as described in a lawsuit against the State of CT and Yale
University. The State of Connecticut cannot handle important epidemics such as autism and Lyme
borreliosis as disclosed in 3:05 –CV- 91 (CFD). [EXHIBIT V]
DCF hired Laura Lustig of the New Learning Center, Westport, who declared for the court, that Plaintiff
KM Dickson has Borderline Personality Disorder and Autism, when the two disorders are mutually
exclusive. Autism is defined by a lack of a personality. Plaintiff KM Dickson was diagnosed with High
Functioning Autism and has two blood relatives with the same cognitive strengths and deficits. This is
medical and legal incompetence. Yale University has a Center for the Study of Autism. Yale University
also rediscovered Lyme as a brain infection, yet no Yale or DMHAS physician is competent to either
disorder that Plaintiff KM Dickson has encountered.

The CT 54-56D competency statute assumes that DMHAS is up to date on brain matters. Clearly for the
entire combined National Institutes to declare Chronic Lyme to be a chronic infection of the nervous
system, and for Yale and DMHAS to declare otherwise, places DMHAS and Yale staff in default of the
competency required by the CT 54-56D competency statute.


FALSE CRIMINAL CHARGES, CONSPIRACY AGAINST RIGHTS, FEDERALLY PROTECTED ACTIVITIES

21) Plaintiff KM Dickson was falsely criminally charged with the bizarre perjury invented by DCF
prosecutor Assistant Attorney General JESSICA GAUVIN. The Honorable Kevin P. Murphy ordered Plaintiff
Dickson to be treated for Lyme disease, as a condition of her release. The prosecution subsequently
switched courts to New Britain, CT, where the State proceeded to orchestrate more perjury, and state
that Plaintiff Dickson does not have Lyme disease and that Lyme is not a brain disease (DMHAS‘s
Elizabeth Byron) [EXHIBIT X Scott Murphy datasets].
Plaintiff KM Dickson does not have ―command hallucinations to kill Jessica Gauvin,‖ and Plaintiff KM
Dickson is not a ―dangerously intelligent‖ ―chemist‖ ―like Ted Kaszinski,‖ the Unibomber. This is the
nonsense GAUVIN invented for Plaintiff KM Dickson at Plaintiff KM Dickson‘s DCF ―trial,‖ and with which
GAUVIN then later falsely criminally charged Plaintiff Dickson.
Plaintiff KM Dickson is a human rights activist, Lyme support group leader, and testified at the FDA about
Yale‘s dangerous LymeRIX vaccine as a pharmaceutical chemist, demonstrating for the FDA (January 31,
2001) that LymeRIX was not qualified with a proper standard and should not be used for children until we
know what is making adults so sick from this vaccine. These are, to Plaintiff KM Dickson‘s knowledge, not
the Unibomber‘s methods of activism.

The epidemic of Lyme disease, which is ―Connecticut‘s disease,‖ has made no progress in treatment,
detection, or prevention in the past 19 years. The CONNECTICUT STATE DEPARTMENT OF HEALTH, the




                                                                                                        10
STATE DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES, the STATE DEPARTMENT OF CHILDREN
AND FAMILIES have all failed their commissions including the CT state competency statute, 54-56D, for
not addressing this epidemic and not recognizing that borreliosis is a primarily a brain and nervous system
disease.
In fact, despite being given the published scientific evidence which clearly demonstrates that Lyme
borreliosis is a brain disease, DMHAS staff, in court, in deliberate perjury, and despite the entire
combined National Institutes‘ declaring that Lyme is a borreliosis- a permanent brain infection (The NIH‘s
Integrative Neural Immune Program), and despite having full knowledge that Lyme is a brain disease
(since these rediscoveries were also made at Yale University), stated for the court that Lyme is not a
brain disease and that DMHAS was not aware of Plaintiff Dickson‘s diagnosis of Lyme disease.

DMHAS staff further perjured themselves and stated that Plaintiff KM Dickson refused to meet with a
neurologist. Plaintiff met with Christopher Gottschalk, later discovered to be a Yale Neurologist, who
told Plaintiff that Lyme is not a permanent brain infection, which is false. Gottschalk told Plaintiff KM
Dickson he was from Cross County Neurology Group and gave Plaintiff the document which is EXHIBIT Y.

FAILURE OF COMMISSIONS:
22) The commissioner of the DEPARTMENT OF SOCIAL SERVICES is obligated to: 16) conduct, encourage
and maintain research and studies relating to social services development; (17) prepare, review and
encourage model comprehensive social service programs; (18) maintain an inventory of data and
information and act as a clearing house and referral agency for information on state and federal programs
and services; and (19) conduct, encourage and maintain research and studies and advise municipal
officials and officials of social service agencies about forms of intergovernmental cooperation and
coordination between public and private agencies designed to advance social service programs. (see
definitions and statutes at end of this document).

DCF was given hundreds of pages of documents related to Lyme disease and Autism, by Plaintiff KM
Dickson, from December 2002, to March 2003. Plaintiff Dickson received her DCF ―records,‖ in March,
2003, more than three months after requesting them, and only with the assistance of Congressman Rob
Simmons. When Plaintiff KM Dickson read these records, she was assured she was dealing with extremely
mentally defective individuals employed by the State of Connecticut, and began filing complaints with
various agencies of the State and Federal government about CT DCF. DCF later removed Plaintiff‘s
children, in November 2003, defrauding the DCF ―court‖ in their Temporary Order of Custody. These are
color of law, deprivation of rights, and violations against federally protected activities. Residents may
file complaints with the proper authorities, under these Federal Civil Rights Statutes (USC Title 18, Secs
241, 242, 245). DCF is clearly funded by federal agencies (DHHS, Agency for Children and Families,
etc.), and the latter statute specifically protects individuals from color of abuses by federally funded
organizations.

DCF‘s former Commissioner Kristine Ragaglia resigned from DCF some time in Feb or March, 2003, but
was later re-employed by the Department of Social Services some time after March 2003. Plaintiff KM
Dickson gave (emailed and hand-delivered) Ragaglia and others employed by DCF these scientific
documents which supported that Lyme is a borreliosis- a permanent infection of the brain, that ―Lyme
disease‖ is not a controversy, but scientific fraud, that autism is a pervasive development disorder, and
the scientific evidence of the brain damage caused by all psychotropics. This scientific evidence was also
on Plaintiff KM Dickson‘s website, ActionLyme.com.
DCF, DSS, DPH, and DMHAS are in default of their basic commissions, which are to know facts, serve and
provide, based on the facts, the science, and the state of the art, in care. They are not commissioned to
become a participants in the scientific fraud of Lyme disease.

FAILURE TO ACT IN THE INTERESTS OF THE STATE BY ATTORNEY GENERAL RICHARD BLUMENTHAL:

23) AG RICHARD BLUMENTHAL was mailed an enormous amount of information regarding the fraud of
Lyme disease by Plaintiff KM Dickson. R. Blumenthal held two public hearings on the mistreatment of
persons who have Lyme disease by insurance companies and Yale University (1999 and 2004). Richard
Blumenthal did not act to protect the residents of the State of CT even when given evidence of the
perjury which occurred at one of his hearings, and as regards the NIH Edward McSweegan and Yale‘s
Durland Fish‘s conspiracy to send Karen Forschner of the Lyme Disease Foundation in Hartford, CT, ―a
bogus article‖ to publish in their journal, The Journal of Spirochetal and Tick Borne Diseases (JSTD). Yale
University is involved in the scientific fraud of Lyme Disease.




                                                                                                        11
Richard Blumenthal‘s staff lawyers referred Plaintiff KM Dickson to the US Attorney Kevin O‘Connor as the
person with whom to file the complaint of scientific fraud as regards Lyme disease (RICO) in July 2003.
Kevin O‘Connor‘s wife worked in Rowland‘s legal office and Mr. O‘Connor had to recuse himself from the
investigation of the criminal former Governor Rowland and the activities which were conducted from
Rowland‘s office which involved the DCF‘s Kristine Ragaglia and others defrauding the federal
government.

These communications to Richard Blumenthal regarding the Lyme racketeering enterprise were instead
used by AAG JESSICA GAUVIN to be evidence of Plaintiff KM Dickson‘s insanity. DMHAS‘s Kenneth Marcus
testified at Plaintiff KM Dickson‘s DCF ―trial,‖ ―Don‘t look at the content…,‖ of these communications.

Plaintiff KM Dickson is a scientist. Content is of primary importance in any scientific report. The content
specified in these reports regarding the scientific fraud in ―Lyme Disease‖ are why Plaintiff KM Dickson
cannot get medical and special education care for herself and her 3 children, who have Lyme disease.
The ―content‖ demonstrated the scientific fraud in Lyme disease, and how that involved Yale‘s dangerous
Lyme vaccine.

Plaintiff KM Dickson asserts that it might be either perjury or psychiatric mumbo jumbo to be saying that
because the State of CT failed to protect its citizens from the deliberate in the denial of care for Lyme
disease, and for Yale‘s attempting to pass off a bogus Lyme vaccine (for which adverse events were not
reported to the FDA), that the Plaintiff KM Dickson is insane to be reaching to the federal level for
protection.


SUMMARY OF THE STATE OF CONNECTICUTS FAILURES TO PROMOTE AND PROTECT THE GENERAL WELFARE:
Lyme disease is an epidemic of a brain infection, and there is a rising epidemic of autism, yet neither of
these two illnesses are addressed even lightly by any of the Departments of the State of Connecticut, with
the possible exception of the DEPARTMENT OF MENTAL RETARDATION (DMR) as regards autism. The State
hires experts who are completely unfamiliar with autism as a ―pervasive development disorder‖ or Lyme
as a brain disease, despite these experts being associated with the Yale Department of Psychiatry
(VLADIMIR CORIC), which has an autism clinic, and despite a report by the Yale Department of Pathology
in which the congenital brain damage from Lyme infection was listed as the probable cause of death in
one newborn and one stillborn infant. [EXHIBIT X - Scott Murphy dataset, June 11, 2005]

Clearly the DMR needs to be explaining what a pervasive development disorder is to the DCF, Yale
Department of Psychiatry, and DMHAS.

It is inherently within the commissions of the DCF, DPH, and DMHAS to have an understanding of, and
address the needs of the disabled with Lyme and/or Autism. Thus, they have failed their basic
commissions.

The OPM is authorized to discover federal aid sources, however, MARC S. RYAN appears to have
dominantly sought increased the spending for the DCF in House Bills 1999 5021 and HB 2001, 6999 and as
is written into the text, this increase in state spending was required to meet increased federal spending
requirements, and RAGAGLIA appears to have added, ―due to the increase in termination of parental
rights being approved by the courts…‖ This is inconsistent with providing aid to needy families, and
which may be another deliberate fraud against the United States of America, the Connecticut public, and
the federal government, and which resulted in a 445% increase in children taken from their parents and
the disgrace of the pediatric jail. [EXHIBIT Z Letter to Rell, DMHAS‘s perjury dataset, July 1, 2005]


DCF prosecutors willfully and knowingly falsely criminally charge parents with the false allegations,
hearsay, and the perjurous testimony elicited and invented by the DCF prosecutors themselves and their
―witnesses,‖ and then deny the parents access to the courts by declaring the parent insane to say they
are innocent and threaten their victims with being involuntarily committed if they maintain their
innocence. [EXHIBIT X (eg., Scott Murphy dataset re: Christopher Gottschalk, Joseph More, Sam Donta,
Lara, Diane and David D.)]




                                                                                                        12
There is clearly a consistent pattern of criminally charging parents with whatever is today‘s flavor of
inane crime if the parent/alleged ―perpetrator‖ retaliates against the criminal behavior of the State of
CT employees by filing the proper documents for relief from abuse and neglect with the proper agencies.

DCF willingly and knowingly places children in dangerous homes, and informs the children that if they
complain of this abuse, they will be placed in separate foster homes. DCF willingly and knowingly
fraudulently declares parents to be mentally ill to be filing legitimate complaints about judges, DCF
attorneys, and DCF staff to the Commission on Human Rights and Statewide Bar Counsel, and Judicial
Review Boards, in order for the claim to be considered invalid. These are Color of Law abuses,
Conspiracy Against Rights, and violations of the rights to Federally Protected Activities.

DCF threatens the liberties of parents, and makes it a condition of release that the innocent parent admit
guilt for the crimes they did not commit, and that the parent may not ―criticize the government,‖ nor
―fax any state, federal, or local agencies,‖ which are clearly and abundantly civil and human rights
abuses, illegal, a violation of the First Amendment, a violation of the Americans With Disabilities Act,
violations of Federally Protected Activities, Conspiracy to Deprive of Rights, and Color of Law abuses,
when the parent has Lyme disease, and especially when the children also have Lyme disease and can get
no access to care. [EXHIBIT Z]

It is criminal child abuse to willfully deny children access to medical care, when the denial of medical
care results in a regression of health, yet the State of Connecticut does this consistently as regards all
Lyme disease victims, including children.

These behaviors and actions of CT DCF staff are Title 18 Secs 241, 242, and 245 criminal civil rights
violations (Title 42, Sec 1983, redundant).

------

THE CHIEF STATE‖S ATTORNEY CHRISTOPHER MORANO AND THE PUBLIC DEFENDER‘S OFFICE ON
COMPENSATING COURT APPOINTED LAWYERS FOR CHILDREN AND FAMILIES HARASSED BY DCF:

24) In default of proper protections provided by the State to families involved with DCF in comparison to
criminal cases, as stated publicly by Chief State‘s Attorney, Christopher Morano, and the Public
Defender‘s office regarding court appointed attorneys, parents who are victims of DCF‘s abuses, in the
interest of the welfare of children and families, should expected to take humane and compassionate
action on behalf of other families who will be destroyed by the Connecticut Department of Children and
Families, without such public exposure and restraint as otherwise afforded under the US Constitution, but
denied all Connecticut residents. These incidents reveal gross incompetence, and criminal civil rights
violations, not only on the part of DCF staff, but also the police. Lawyers assigned to children victimized
DCF attack are paid a fraction of fees for court appointed representation of criminal charges. These
lawyers for children have since passed legislation protecting themselves from malpractice lawsuits by
families who they inadequately represented. [EXHIBIT AA]

There is no legislative protection for the families against this inherent, built-in, legal incompetence.


25) OTHER CASES OF THE STATE’S INCOMPETENCE, RETALIATION, ABUSE, QUESTIONS OF INTEGRITY

25- A) Daniel Scruggs: In the case of the suicide of Daniel Scruggs, the entire family was in need of
services, and had been visited by DCF. A simple $40 weekly contract with a cleaning service, in light of
the cognitive disabilities of Mrs. Scruggs and her son Daniel, provided under the Temporary Aid for Needy
Families, would have been a logical remedy. Daniel Scruggs was depressed and was said to be mildly
autistic (newspaper article), yet no one, and in particular, no one at DMHAS or Yale is competent to
Autism/Asperger‘s in adults. One can assume Daniel Scruggs inherited his cognitive disabilities from
either his mother or his father (who was notably absent), yet the father shared no liability for this
tragedy. [EXHIBIT BB]




                                                                                                             13
It appears that ―Scruggs' arrest by Meriden police came six weeks after Norris filed the notice of intent to
sue the city of Meriden for failing to protect Daniel from daily bullying.‖—not included but taken from
Hartford Advocate, November 2003, ―Everyone was at Fault‖ news article.

Charging Mrs. Scruggs appears to be retaliation by the State, and an effort to prevent legal discovery of
DCF‘s incompetence and liability in the death of this child. This appears to be another case of a
conspiracy to deprive of rights.


25- B) Baby Emily: In the case of Baby Emily, recently resolved by the State of CT, ―A state investigation
after Emily‘s death found that state child welfare workers knew of abuse within the infant‘s family and
failed to protect children in the household.‖ [EXHIBIT CC]

This is a simple evidence point of DCF‘s abundant incompetence.


25- C) Jennifer O‘Connor: Mrs. O‘Connor informed Plaintiff KM Dickson that she had asked the DCF to
come and give her parenting skills in regards to herself and her daughter Sara. Approximately April 2003.
DCF came to visit Mrs. O‘Connor, found ―no abuse or neglect,‖ and declined the request for assistance. A
few weeks later, Mrs. O‘Connor shot and killed her daughter, presumably as a result of her deficit in
parenting skills, which was not addressed by DCF despite the specific request. Plaintiff KM Dickson feel
this behavior on the part of the DCF is consistent with the DCF staff not understanding big words like
―Neuroborreliosis,‖ which the DCF staff calls ―bizarre talking,‖ and is consistent with the
acknowledgement that DCF staff needs ―increased training,‖ in the conclusion of the Juan F. case.

Mrs. O‘Connor was diagnosed with a learning disability, as was her daughter, and had had genetic
screening prior to becoming pregnant, Plaintiff KM Dickson was told by a friend of the family. Plaintiff
KM Dickson‘s experience and knowledge of Autism and Asperger‘s disorder, leaves Plaintiff KM Dickson
strongly aware that Mrs. O‘Connor was misdiagnosed as ―mentally ill,‖ when she had Asperger‘s disorder,
and may have been subject to malpractice, in addition to the incompetence of the DCF staff. This
conversation took place in the jail; Plaintiff Dickson does not have access to Mrs. O‘Connor‘s DCF records.
Plaintiff Dickson‘s understanding from reading the news reports online, is that Mrs. O‘Connor called the
DCF herself for assistance. This assistance was denied. The child is dead, and Mrs. O‘Connor is in jail
instead of in an assisted living arrangement or with assistance for herself and her daughter‘s learning
disabilities [EXHIBIT DD]

The primary problem with DCF‘s incompetence is never addressed: The fact is, they don‘t appear to
understand common English. If someone says, ―Help Me,‖ it doesn‘t mean, ―Blow me off,‖ and it doesn‘t
mean, ―Subject my children to a traumatizing kidnapping, and give them to a known –to-DCF, chronic
genitals-exposing, physically violent to others, maniac (Donald G. Dickson),‖ and it doesn‘t mean, ―‖If I
am sick, and sometimes need DCF‘s babysitting Respite Care, tell the courts I am insane, kidnap my kids
and give them to someone known to be a violent person, invent my crimes and throw me in jail.‖ If DCF
is not a child welfare agency, they should not advertise as such, and mislead the public. This is a waste
of tax dollars, not to mention children‘s lives.

25- D) The “harassing communications and threatening,” with which Plaintiff KM Dickson was falsely criminally
charged are dated 14 April 2004, and are in correspondence with the US Attorney’s office (Kevin O’Connor), and
CIGNA, Plaintiff KM Dickson’s Pfizer disability insurance carrier, and which contain more newspaper articles of
DCF’s incompetence. [EXHIBIT EE]

         -March 8, 2004 (Courant) “DCF never asked, DPH never told of hospital problems” Quote from Jeane
         Milstein (as regards DCF):

         “Common sense would tell you to pick up the phone and do your homework.”

         -March 7, 2004 (Courant) “Hospital Troubles Elude DCF” Jeane Milstein:

         “You learn from your mistakes. You learn from what you do,‟ Milstein said. „DCF needs to be a more
         responsible parent.‟”




                                                                                                                  14
          -December 18, 2003, Courant “MILSTEIN SUES DCF OVER AGENCY’S TREATMENT OF ABUSED
          CHILD”- Associated Press.

          “Milstein accused DCF of „callous and reckless indifference in caring for the youth, and she suspects
          other children may be suffering because of DCF‟s missteps.”


25- E) Christopher Kennedy: In the case of Mr. Christopher Kennedy, it is Plaintiff’s KM Dickson’s belief and
knowledge that this started out as a simple case of divorce, and ended with numerous criminal charges against a man
who had no criminal history until DCF involvement. Mrs. Leanna Kennedy was arrested for second degree assault for
stabbing Mr. Christopher Kennedy. On Friday, June 30, 2005, Mr. Kennedy was charged with perjury and the bail was
said to be requested at $500,000 but was dropped to $50,000.00. To Plaintiff KM Dickson’s understanding, Mr
Kennedy was charged with perjury for neglecting to mention that there had been issued a restraining order against Mr.
Kennedy. As Plaintiff KM Dickson informed CT Governor Jodi Rell via mail, that if the State were charged at a rate of
$50,000 per incident of perjury in Plaintiff KM Dickson’s “cases,” the State would owe a debt in the range of
$50,000,000.00. [EXHIBIT FF- 1,- 2]
Mr. Kennedy’s wife has been arrested for stabbing Mr. Kennedy. Plaintiff KM Dickson is not aware of Mr. Kennedy
stabbing Mrs. Kennedy, yet Mr. Kennedy is facing jail time for false criminal charges. DCF was “involved.”
Although Mr. Kennedy sought redress directly with the present Governor’s Chief Legal Counsel, Kevin J. Rasch, Mr.
Kennedy was instead charged with perjury.

25- F) In comparison, to the above Christopher Kennedy Perjury case, MR. JOHN G. ROWLAND defrauded the
federal court in his financial affidavit regarding his income, yet no charges were filed. Mr. Rowland’s sentence was not
compounded for nearly the same negligent “perjury” with which Mr. Kennedy is charged. [EXHIBIT GG]
         “But federal prosecutors were disappointed. On Thursday, the U.S. attorney's office had urged Dorsey
         to put Rowland in prison for up to 37 months, saying that the office had learned that Rowland had tried
         to conceal a $416,000 personal retirement account from federal officials. By portraying his financial
         condition as increasingly dire, prosecutors said, Rowland was trying to generate leniency from the
         court”--- Hartford Courant March 19, 2005

25- G) It is noteworthy that as regards Governor Rell and her son’s behaviors, from CORPORATE CRIME
REPORTER http://www.corporatecrimereporter.com/curryinterview.htm

          “CCR: If he is impeached or resigns, what is the provision in Connecticut law for an emergency
          election?

          CURRY: There isn't one. It's one of the questions I've raised with people in the last few weeks. As in
          most states, the Lt. Governor takes over. I think that's a mistake. I think we designed the offices of vice
          president and Lt. Governor with an eye to the death or incapacity of the President or Governor.

          I believe that when a chief executive is marched out of office for impeachable offenses, we should have
          an election to fill the remainder of the term. The idea that a member of Rowland's posse simply follows
          in Rowland's footsteps is a bad one.

          CCR: Has the Lt. Governor, Jodi Rell, been implicated?

          CURRY: When her son was found by state environmental officers to be running a stolen property ring
          out of her basement for Skidoos, the environmental officers who made the arrests had their careers
          threatened.

          They suffered until it hit the press and then the administration backed off. She denied any involvement
          in the retaliation. Again, Connecticut's extraordinary unwillingness to investigate the apparent
          corruption of its own elected officials saved her from further public embarrassment.

          In any event, she has been a happy, willing partner and an insider in the Rowland administration for
          nine years.”


this at least gives the suggestion that the State of Connecticut is corrupt, and to include the present Governor.
[EXHIBIT HH Corporate Crime Reporter, Curry Interview]




                                                                                                                    15
25- H) The Saraceno Case: Plaintiff KM Dickson suspects the integrity of Chief State‘s Attorney
Christopher Morano due to what we learned in the Hartford Courant‘s Northeast Magazine, Jan 9, 2005,
regarding the Saraceno boy‘s case:

         “Saraceno was convicted and imprisoned but later released after a private investigation
         discovered that the prosecutor was protecting four other young men who almost certainly
         did the crime. The chief state’s attorney’s office uncomfortably joined in the defense in a
         motion to overturn the conviction. That should have freed the youth from further jeopardy.
         Instead, in 1999, under threat of extending the legal nightmare that had already cost his
         parents $100,000, Saraceno accepted guilt for “hindering prosecution by falsely confessing.
         ” Under the statute of limitations, the state had allowed the five-year window for
         prosecuting the known suspects to close. No one except the wrong man did jail time for the
         crime. The law officer most responsible for compelling Saraceno to declare it was his fault is
         Chief State’s Attorney Christopher Morano”.

25- I) The Office of Public Integrity: Mr. Christopher Morano, the Chief State‘s Attorney has an Office of
Public Integrity, yet Morano never responded to the integrity complaints lodged by Plaintiff KM Dickson as
regards the bizarre and discriminatory behavior of DCF staff.

25- J) CHRISTOPHER MORANO‘S BIRTHDAY PARTY, FROM THE WEBSITE: CRIME AND FEDERALISM, by Norm
Pattis:

March 29, 2005 in Federal Courts | Permalink | Comments (5) | TrackBack

But the Governor did it?

Norm Pattis
Connecticut calls itself the Land of Steady Habits. In recent years, those habits have evolved to graft among its
public officials. Why just the other day, former Governor John G. Rowland was sentenced to federal prison for
a brief stretch. He couldn't keep distinct in his mind his official duties and gorging himself at the public trough.
After his guilty plea and resignation from office, he kept on grabbing cash. He raked in about $15,000 a month
as a consultant to private industry on, of all things, government. Now the Connecticut General Assembly wants
to take a look at why felons are hired as consultants. Oink, Oink, Oink
Now comes news that a prosecutor may not have been able to avoid all the fun. Supervisory Assistant State's
Attorney David Newman of New Haven is under the microscope, according to the Chief State's Attorney's
Office. Suspicions that all is not well in the historic Elm Street courthouse. According to the New Haven
Register, questions have arisen about whether Mr. Newman regards himself as a legitimate beneficiary of
charitable contributions intended to resolve minor offenses. Charity for a Day
Newman has hired criminal defense lawyer Hugh Keefe, who tried to waive off the scandal as an "internal
employment matter." Well, that's one spin. But Keefe is known for his defense of police officers in claims arising
under 42 U.S.C. Section 1983 and for defending those accused of crimes. He's no employment lawyer.I Want
Mine, Too
This comes on the heels of a report that a former prosecutor was arrested leaving the 50th birthday party of
Chief States Attorney Christopher Morano. The former lawman was drunk, was carrying a little reefer, and was
armed. He's now asking the court for a diversionary program that would permit the record of his arrest to be
erased after a brief period of probation.
Wow. I guess there's no place like home for white collar crime, and, if you know the right people it seems that
just about anything is possible.
March 29, 2005 | Permalink | Comments (2) | TrackBack


Plaintiff KM Dickson would only add the comment that the residents of the State of CT would wonder how
often these prosecutors get together to party, and what they discuss. CT State prosecutors breaking the
law is the nature of this complaint. We victims of their crimes only wish the vast majority of crimes
committed by State prosecutors and other state employees was limited to smoking marijuana.

25- K) FALSE ARREST, NOT INVOLVING DCF:        Steven G. Erickson. In the case of Steven G. Erickson, It is
Plaintiff KM Dickson‘s belief and knowledge that the testimony of Steven G. Erickson was truthful, in that



                                                                                                                16
Erickson believes that he wasn‘t getting equal protection and service being a Stafford Springs downtown
Connecticut landlord.

Mr. Erickson, formerly of Stafford, CT, wrote letters to the editor critical of police and Connecticut courts
and wrote President Bush a letter about how the economy was hurt by downtown (Stafford) property and
small business owners getting a fair shake in courts and adequate police help and service. Mr. Erickson
proposed Civilian Oversight of Police to State Senator Tony Guglielmo and former State Representative
Mordasky. Mordasky‘s aid, ―Rosemarie,‖ advised Erickson that Erickson should sell his property and leave
Connecticut before the Connecticut State Police retaliated for the laws Erickson proposed directing police
powers, and for what Mr. Erickson had written critical of police in newspapers, and for being a ―Big
Mouth.‖

Mr. Erickson also attests that the Connecticut State Police were bragging that Mr. Erickson would be going
to prison and run out of town after Erickson was attacked by Brian Caldwell on Erickson‘s property when
Erickson returned home from a double shift of work. Caldwell had told Erickson‘s tenants Caldwell would
kill Erickson when Erickson got home, and had threatened Erickson, harassed Erickson via voicemail, and
beating on Erickson door after midnight, yelling that Caldwell, would cut Erickson‘s penis off if Caldwell
caught Erickson outside Erickson‘s home.

According to Mr. Erickson, Connecticut State Troopers, Amaral and Langlais refused to take Erickson‘s
complaint against Erickson‘s assailant who had jumped Erickson and tried to rob Erickson, nor would they
take the complaint of witness Sue Johnston, nor that of Clayton Varno. Instead the police only arrested
Erickson, refusing to view Erickson‘s injuries, and then later committing perjury of these facts to get me
convicted of overreacting to being beaten during a robbery attempt using pepper spray.

Apparently, Judge Jonathan Kaplan of Rockville Connecticut Court stated that Erickson was guilty and was
going to prison before Erickson‘s trial began. A videotape was shown to the jury of how to find Erickson
guilty, but nothing about innocence or reasonable doubt, tainting them. (XXX, evidence #)

It is Erickson‘s belief that Judge Kaplan informed Erickson‘s attorney, Michael H. Agranoff (Stafford, CT),
that Agranoff was not allowed to dispute police perjury, the prosecution, nor defend Erickson.

Erickson sent an email to the former Connecticut State Police Commission Arthur L. Spada in late October
2002, the day before Erickson was to be sentenced, asking Spada to remove the US Department of Justice
webpage on Community Policing off the Connecticut State Police website, stating the policies were not
being followed. Erickson indicated that Erickson was sending a copy of the email to the US Department of
Justice.

Erickson believes the Connecticut State Police, the prosecutors, Erickson‘s lawyer, and Judge Jonathan
Kaplan were acting in collusion to ensure Erickson‘s conviction to prevent Erickson from suing for Civil
Rights violations and to keep Erickson from lodging complaints and exposing corruption within the courts
and Connecticut State Police.

Erickson further asserts that Judge Jonathan Kaplan appeared to reference the email Erickson sent to
Commissioner Spada at Plaintiff‘s sentencing, indicating to Erickson their was illegal collusion between
Judge Jonathan J. Kaplan and Connecticut State Police Officers to ensure Erickson was convicted and
given the maximum penalties allowed.

Mr. Erickson was sent to an overcrowded prison and was singled out for abuse by guards referencing
Erickson‘s feud with the Connecticut State Police. Mr. Erickson was held in prison longer than his stated
release date, wasn‘t allowed to take classes in prison as further harassment, and was told that Erickson
wasn‘t allowed in Stafford, Connecticut upon release by LT Desso, also a Stafford town police officer.

Mr. Erickson asserts that he was told by his parole officer at the Enfield Police Station, that Erickson
wasn‘t allowed to make complaints against police officers, nor contact the media regarding Erickson‘s
case or face more prison time. These are clearly federal color of law, deprivation of rights, and violation
of federally protected activities, and first amendment violations.




                                                                                                           17
When Mr. Erickson was turned over to adult probation in Manchester Connecticut, Erickson was given told
by Angela K. that she would violate Erickson‘s probation if she received any more calls regarding Erickson
and would violate Erickson‘s probation if Erickson didn‘t leave the State of Connecticut. Mr. Erickson
was given an hour to pack and leave the State of Connecticut to avoid further persecution and fraudulent
prosecution.

25-J) Jeffrey Yeaw     To Plaintiff KM Dickson‘s belief and knowledge, Mr. Yeaw was not provided equal
protection under the law, was deprived of his civil rights, as were his children. These children were not
reported as physically harmed or neglected by Mr. Yeaw in any way. This family‘s tragedy was another
color of law abuse and illegitimate traumatization to children. Mr. Yeaw was arrested, and not his wife,
when all known reports are clear and convincing, that Mrs. Yeaw was physically violent to her husband,
and initiated an altercation. Mr. Yeaw‘s children were taken by DCF, and Mr. Yeaw, being of sound mind
and familiar with DCF abuses, merely rescued these children. Instead he was charged with the ―crime‖ of
abducting his own children. [EXHIBITS II]

Plaintiff KM Dickson wishes she had the courage to rescue her own children, but it never occurred to this
Plaintiff. At that, Plaintiff Dickson never anticipated her children being taken, since there was no abuse
or neglect going on, and everyone knew it. DCF threw out their first petition against this Plaintiff and
wrote a new one.

Now Mr. Yeaw faces years in prison, because his wife attacked him, and he left the house in response.
The present Governor, Rell, publicly commented on this crime, when she did not know it was not a crime.
This is disheartening to CT residents, since we had faith that this replacement Governor, Mrs. Rell, for
Governor Rowland, was Number One, a woman, and Number Two, got rid of a number of the cronies hired
by Rowland. Rell did not get rid of DMHAS‘ or DCF‘s commissioners, however, when we know both
agencies are abundant and obvious failures.


No one should have been arrested in any of these ―cases.‖ Were it not for the incompetence and abuse by
DCF and the prosecutorial madness in the State of Connecticut, and were it not for the failure of the
mental health system, some of these cases would, from an outside observer, appear be family arguments.
Instead, they became obvious cases of discrimination and retaliation, and then numerous and extreme
civil rights violations, including false criminal charges, prison sentences and threats of permanent
incarceration, under the apparently Secret Connecticut ―We‘ll Commit You Permanently and Take Your
House and Income if You Don‘t Shut Up, by Inventing Your Crimes, and then Committing You to a
Psychiatric Hospital, Indefinitely, For Saying You Are Innocent‖ Act.

That the DCF would record family arguments as neglect of children, implies that nearly all Connecticut
children would have to be removed from their parents.


Given DCF‘s civil rights violations and false criminal charges, to known and unknown numbers of parents
and children, and the fact that the DCF is well-known to be ―arrogant and inept,‖ as regards children and
families, Jeffrey Yeaw was competent, correct, sane, protective, caring and fully within his rights to
rescue his children from the abomination known as the CT Department of Children and Families.

It is Plaintiff KM Dickson‘s belief that the evidence submitted supports that no children are safe in DCF‘s
―care,‖ and due to the presence of the Rowlandgate Appointee US Attorney Kevin O‘Connor, justice
cannot be gained in the US Department of Justice District of Connecticut.


-----------------------------------------
DAMAGES AND RELIEF REQUESTED
1) The Connecticut Department of Children and Families is to be dissolved completely and all related DCF
statutes stricken from Connecticut General Statutes.
2) $100,000,000 in pain and restitution of costs to Plaintiff Dickson and her children from the State of
Connecticut.




                                                                                                         18
3) The establishment of a research clinic and hospital for vector borne diseases, in Connecticut, to be
named the Hospital of the Immaculate Heart, with the funds recovered in the discovery of scientific fraud
committed by Yale University, the Yale Corporation, and to include the criminal prosecution of all Yale-
and Lyme-related perjury anywhere to be found in America.
Plaintiff Dickson will manage this organization, which will restore the earlier meanings of ―care‖ and
―integrity‖ to the English language.
The $100,000,000 million in damages from the State granted to the Plaintiff shall be donated to this
establishment, the Hospital of the Immaculate Heart.
4) AAG Jessica Gauvin is to be criminally charged with making false statements to police and Gauvin shall
be asked to leave the State of CT permanently after her criminal sentencing.
5) A forum for redress of all DCF perjury committed in the last 15 years, and the return of fraudulently
taken children by CT DCF.
6) The prosecution of MARC S. RYAN and KRISTINE RAGAGLIA for conspiring to defraud the federal
government as regards child welfare, and the incarceration of children as policy, over care.
7) Federal oversight of the CT Department of Justice, and the Chief State‘s Attorney‘s Office.
8) The return of Plaintiff KM Dickson‘s children to Plaintiff KM Dickson‘s care, and in sole custody.



Signed this _________ day of _____________, 2005
                                                                      ______________________
                                                                      Kathleen M. Dickson, et al
                                                                      23 Garden Street
                                                                      Pawcatuck, CT 06379

                                                                      ________________________
                                                                      Lara E. Dickson

                                                                      ________________________
                                                                      Diane M. Dickson

                                                                      _________________________
                                                                      David D. Dickson




                                                                                                      19
DEFINITIONS AND STATUTES
ADA Title II: State and Local Government Activities

 Title II covers all activities of State and local governments regardless of the government entity's size or receipt of
 Federal funding. Title II requires that State and local governments give people with disabilities an equal opportunity
 to benefit from all of their programs, services, and activities (e.g. public education, employment, transportation,
 recreation, health care, social services, courts, voting, and town meetings).

 State and local governments are required to follow specific architectural standards in the new construction and
 alteration of their buildings. They also must relocate programs or otherwise provide access in inaccessible older
 buildings, and communicate effectively with people who have hearing, vision, or speech disabilities. Public entities
 are not required to take actions that would result in undue financial and administrative burdens. They are required to
 make reasonable modifications to policies, practices, and procedures where necessary to avoid discrimination, unless
 they can demonstrate that doing so would fundamentally alter the nature of the service, program, or activity being
 provided.

                   ADA Title II: State and Local Government Activities

 Title II covers all activities of State and local governments regardless of the government entity's size or receipt of
 Federal funding. Title II requires that State and local governments give people with disabilities an equal opportunity
 to benefit from all of their programs, services, and activities (e.g. public education, employment, transportation,
 recreation, health care, social services, courts, voting, and town meetings).

 State and local governments are required to follow specific architectural standards in the new construction and
 alteration of their buildings. They also must relocate programs or otherwise provide access in inaccessible older
 buildings, and communicate effectively with people who have hearing, vision, or speech disabilities. Public entities
 are not required to take actions that would result in undue financial and administrative burdens. They are required to
 make reasonable modifications to policies, practices, and procedures where necessary to avoid discrimination, unless
 they can demonstrate that doing so would fundamentally alter the nature of the service, program, or activity being
 provided.


DEFINITIONS:

Connecticut Chapter 319 Sec. 17b-608. (Formerly Sec. 17-608). Persons with disabilities. Definition. For
the purposes of sections 17b-609 and 17b-610, "persons with disabilities" shall mean persons having
disabilities which (1) are attributable to a mental or physical impairment or a combination of mental and
physical impairments; (2) are likely to continue indefinitely; (3) result in functional limitations in one or
more of the following areas of major life activity: Self care, receptive and expressive language, learning,
mobility, self-direction, capacity for independent living or economic self-sufficiency; and (4) reflect the
person's need for a combination and sequence of special, interdisciplinary or generic care, treatment or
other services which are of lifelong or extended duration and individually planned and coordinated.

                                          CONSPIRACY AGAINST RIGHTS

Summary:

         Section 241 of Title 18 is the civil rights conspiracy statute. Section 241 makes it unlawful for two or more
         persons to agree together to injure, threaten, or intimidate a person in any state, territory or district in the free
         exercise or enjoyment of any right or privilege secured to him/her by the Constitution or the laws of the
         Unites States, (or because of his/her having exercised the same). Unlike most conspiracy statutes, Section 241
         does not require that one of the conspirators commit an overt act prior to the conspiracy becoming a crime.

         The offense is punishable by a range of imprisonment up to a life term or the death penalty, depending upon
         the circumstances of the crime, and the resulting injury, if any.

                                           TITLE 18, U.S.C., SECTION 241




                                                                                                                          20
                 If two or more persons conspire to injure, oppress, threaten, or intimidate any person in
                 any State, Territory, Commonwealth, Possession, or District in the free exercise or
                 enjoyment of any right or privilege secured to him by the Constitution or laws of the
                 United States, or because of his having so exercised the same;...

                 They shall be fined under this title or imprisoned not more than ten years, or both; and if
                 death results from the acts committed in violation of this section or if such acts include
                 kidnapping or an attempt to kidnap, aggravated sexual abuse or an attempt to commit
                 aggravated sexual abuse, or an attempt to kill, they shall be fined under this title or
                 imprisoned for any term of years or for life, or both, or may be sentenced to death.

                 --------------------------------

                 DEPRIVATION OF RIGHTS UNDER COLOR OF LAW

Summary:

       Section 242 of Title 18 makes it a crime for a person acting under color of any law to willfully
       deprive a person of a right or privilege protected by the Constitution or laws of the United
       States.

       For the purpose of Section 242, acts under "color of law" include acts not only done by federal, state, or local
       officials within the their lawful authority, but also acts done beyond the bounds of that official's lawful
       authority, if the acts are done while the official is purporting to or pretending to act in the performance of
       his/her official duties. Persons acting under color of law within the meaning of this statute include police
       officers, prisons guards and other law enforcement officials, as well as judges, care providers in public health
       facilities, and others who are acting as public officials. It is not necessary that the crime be motivated by
       animus toward the race, color, religion, sex, handicap, familial status or national origin of the victim.

       The offense is punishable by a range of imprisonment up to a life term, or the death penalty, depending upon
       the circumstances of the crime, and the resulting injury, if any.

                                            TITLE 18, U.S.C., SECTION 242

                 Whoever, under color of any law, statute, ordinance, regulation, or custom, willfully
                 subjects any person in any State, Territory, Commonwealth, Possession, or District to the
                 deprivation of any rights, privileges, or immunities secured or protected by the
                 Constitution or laws of the United States, ... shall be fined under this title or imprisoned
                 not more than one year, or both; and if bodily injury results from the acts committed in
                 violation of this section or if such acts include the use, attempted use, or threatened use of
                 a dangerous weapon, explosives, or fire, shall be fined under this title or imprisoned not
                 more than ten years, or both; and if death results from the acts committed in violation of
                 this section or if such acts include kidnaping or an attempt to kidnap, aggravated sexual
                 abuse, or an attempt to commit aggravated sexual abuse, or an attempt to kill, shall be
                 fined under this title, or imprisoned for any term of years or for life, or both, or may be
                 sentenced to death.

                                                                         http://www.usdoj.gov/crt/crim/crimhome.html

                                      FEDERALLY PROTECTED ACTIVITIES

Summary:

       The portion of Section 245 of Title 18 which is primarily enforced by the Criminal Section makes it unlawful
       to willfully injure, intimidate or interfere with any person, or to attempt to do so, by force or threat of force,




                                                                                                                     21
    because of that other person's race, color, religion or national origin and because of his/her activity as one of
    the following:

    A student at or applicant for admission to a public school or public college


   A participant in a benefit, service, privilege, program, facility or activity provided or
administered by a state or local government


    An applicant for private or state employment; a private or state employee; a member or
applicant for membership in a labor organization or hiring hall; or an applicant for employment
through an employment agency, labor organization or hiring hall


    A juror or prospective juror in state court


    A traveler or user of a facility of interstate commerce or common carrier


    A patron of a public accommodation or place of exhibition or entertainment, including hotels,
motels, restaurants, lunchrooms, bars, gas stations, theaters, concert halls, sports arenas or
stadiums.

    This statute also prohibits wilful interference, by force or threat of force, with a person because
    he/she is or was participating in, or aiding or encouraging other persons to participate in any of
    the benefits or activities listed above without discrimination as to race, color, religion, or
    national origin.
    The offense is punishable by a range of imprisonment up to a life term, or the death penalty, depending upon
    the circumstances of the crime, and the resulting injury, if any.

                                      TITLE 18, U.S.C., SECTION 245

              (a)(1)Nothing in this section shall be construed as indicating an intent on the part of
              Congress to prevent any State, any possession or Commonwealth of the United States, or
              the District of Columbia, from exercising jurisdiction over any offense over which it
              would have jurisdiction in the absence of this section, nor shall anything in this section be
              construed as depriving State and local law enforcement authorities of responsibility for
              prosecuting acts that may be violations of this section and that are violations of State and
              local law. No prosecution of any offense described in this section shall be undertaken by
              the United States except upon the certification in writing of the Attorney General, the
              Deputy Attorney General, the Associate Attorney General, or any Assistant Attorney
              General specially designated by the Attorney General that in his judgment a prosecution
              by the United States is in the public interest and necessary to secure substantial justice,
              which function of certification may not be delegated.

              (2) Nothing in this subsection shall be construed to limit the authority of Federal officers,
              or a Federal grand jury, to investigate possible violations of this section.

              (b)Whoever, whether or not acting under color of law, by force or threat of force willfully
              injures, intimidates or interferes with, or attempts to injure, intimidate or interfere with--

              (1)any person because he is or has been, or in order to intimidate such person or any other
              person or any class of persons from--

              (A) voting or qualifying to vote, qualifying or campaigning as a candidate for elective
              office, or qualifying or acting as a poll watcher, or any legally authorized election
              official, in any primary, special, or general election;




                                                                                                                   22
(B) participating in or enjoying any benefit, service, privilege, program, facility, or
activity provided or administered by the United States;

(C) applying for or enjoying employment, or any perquisite thereof, by any agency of the
United States;

(D) serving, or attending upon any court in connection with possible service, as a grand
or petit juror in any court of the United States;

(E) participating in or enjoying the benefits of any program or activity receiving Federal
financial assistance; or

(2) any person because of his race, color, religion or national origin and because he is or
has been--

(A) enrolling in or attending any public school or public college;

(B) participating in or enjoying any benefit, service, privilege, program, facility or
activity provided or administered by any State or subdivision thereof;

(C) applying for or enjoying employment, or any perquisite thereof, by any private
employer or any agency of any State or subdivision thereof, or joining or using the
services or advantages of any labor organization, hiring hall, or employment agency;

(D) serving, or attending upon any court of any State in connection with possible service,
as a grand or petit juror,

(E) traveling in or using any facility of interstate commerce, or using any vehicle,
terminal, or facility of any common carrier by motor, rail, water, or air;

(F) enjoying the goods, services, facilities, privileges, advantages, or accommodations of
any inn, hotel, motel, or other establishment which provides lodging to transient guests,
or of any restaurant, cafeteria, lunchroom, lunch counter, soda fountain, or other facility
which serves the public and which is principally engaged in selling food or beverages for
consumption on the premises, or of any gasoline station, or of any motion picture house,
theater, concert hall, sports arena, stadium, or any other place of exhibition or
entertainment which serves the public, or of any other establishment which serves the
public and (i) which is located within the premises of any of the aforesaid establishments
or within the premises of which is physically located any of the aforesaid establishments,
and (ii) which holds itself out as serving patrons of such establishments; or

(3) during or incident to a riot or civil disorder, any person engaged in a business in
commerce or affecting commerce, including, but not limited to, any person engaged in a
business which sells or offers for sale to interstate travelers a substantial portion of the
articles, commodities, or services which it sells or where a substantial portion of the
articles or commodities which it sells or offers for sale have moved in commerce; or

(4) any person because he is or has been, or in order to intimidate such person or any
other person or any class of persons from--

(A) participating, without discrimination on account of race, color, religion or national
origin, in any of the benefits or activities described in subparagraphs (1)(A) through
(1)(E) or subparagraphs (2)(A) through (2)(F); or

(B) affording another person or class of persons opportunity or protection to so
participate; or




                                                                                               23
                  (5) any citizen because he is or has been, or in order to intimidate such citizen or any
                  other citizen from lawfully aiding or encouraging other persons to participate, without
                  discrimination on account of race, color, religion or national origin, in any of the benefits
                  or activities described in subparagraphs (1)(A) through (1)(E) or subparagraphs (2)(A)
                  through (2)(F), or participating lawfully in speech or peaceful assembly opposing any
                  denial of the opportunity to so participate--

                  shall be fined under this title, or imprisoned not more than one year, or both; and if bodily
                  injury results from the acts committed in violation of this section or if such acts include
                  the use, attempted use, or threatened use of a dangerous weapon, explosives, or fire shall
                  be fined under this title, or imprisoned not more than ten years, or both; and if death
                  results from the acts committed in violation of this section or if such acts include
                  kidnaping or an attempt to kidnap, aggravated sexual abuse or an attempt to commit
                  aggravated sexual abuse, or an attempt to kill, shall be fined under this title or imprisoned
                  for any term of years or for life, or both, or may be sentenced to death. As used in this
                  section, the term "participating lawfully in speech or peaceful assembly" shall not mean
                  the aiding, abetting, or inciting of other persons to riot or to commit any act of physical
                  violence upon any individual or against any real or personal property in furtherance of a
                  riot. Nothing in subparagraph (2)(F) or (4)(A) of this subsection shall apply to the
                  proprietor of any establishment which provides lodging to transient guests, or to any
                  employee acting on behalf of such proprietor, with respect to the enjoyment of the goods,
                  services, facilities, privileges, advantages, or accommodations of such establishment if
                  such establishment is located within a building which contains not more than five rooms
                  for rent or hire and which is actually occupied by the proprietor as his residence.

                  (c) Nothing in this section shall be construed so as to deter any law enforcement officer
                  from lawfully carrying out the duties of his office; and no law enforcement officer shall
                  be considered to be in violation of this section for lawfully carrying out the duties of his
                  office or lawfully enforcing ordinances and laws of the United States, the District of
                  Columbia, any of the several States, or any political subdivision of a State. For purposes
                  of the preceding sentence, the term "law enforcement officer" means any officer of the
                  United States, the District of Columbia, a State, or political subdivision of a State, who is
                  empowered by law to conduct investigations of, or make arrests because of, offenses
                  against the United States, the District of Columbia, a State, or a political subdivision of a
                  State.

                  (d) For purposes of this section, the term "State" includes a State of the United States, the
                  District of Columbia, and any commonwealth, territory, or possession of the United
                  States.




DEFINITIONS:

Connecticut Chapter 319 Sec. 17b-608. (Formerly Sec. 17-608). Persons with disabilities. Definition. For
the purposes of sections 17b-609 and 17b-610, "persons with disabilities" shall mean persons having
disabilities which (1) are attributable to a mental or physical impairment or a combination of mental and
physical impairments; (2) are likely to continue indefinitely; (3) result in functional limitations in one or
more of the following areas of major life activity: Self care, receptive and expressive language, learning,
mobility, self-direction, capacity for independent living or economic self-sufficiency; and (4) reflect the
person's need for a combination and sequence of special, interdisciplinary or generic care, treatment or
other services which are of lifelong or extended duration and individually planned and coordinated.

CONNECTICUT STATUTES
Connecticut Chapter 368a Sec. 19a-6. (Formerly Sec. 19-4a). Commissioner to plan and administer
programs for control and treatment of lung disease and chronic illness and for medical rehabilitation. (a)
The commissioner shall be responsible for planning state-wide programs for the control and treatment of
lung diseases; the treatment of persons affected with other chronic illness, and the medical rehabilitation
of chronically ill, physically disabled and handicapped persons. The commissioner shall provide and




                                                                                                                  24
maintain facilities and personnel for the diagnosis or detection and treatment of such diseases or enter
into contracts for the provision of diagnostic and treatment programs for such diseases with persons or
organizations capable in his judgment of providing such services.

Chapter 50* Office of Policy and Management Sec. 4-66a. Secretary to advise Governor and General Assembly on
matters concerning local government and matters affecting the state. Planning, management and technical assistance for
local governments. Federal financial assistance and funds, and financial assistance and aid from private sources. (a)
The Secretary of the Office of Policy and Management shall advise the Governor on matters concerning local
government including state laws relating to local government, the impact of federal actions or proposed federal actions
on local government, the financial needs and resources of local government and the allocation of program and financial
responsibility between local government and the state.

    (b) The secretary shall advise the Governor regarding potential federal actions affecting state
        government and the citizens of the state and shall advise the joint standing committees of the
        General Assembly having cognizance of matters relating to appropriations and relating to the
        subject area of each federal policy initiative, including the allocation of resources in the federal
        budget, federal public assistance policy, federal economic policy and the distribution of federal
        assistance and facilities among regions and states.

    (c) The secretary may provide planning and management assistance to local governments utilizing
         such state and federal funds as may be appropriated for such purpose. …


Sec. 17b-3. Commissioner of Social Services: Powers and duties. (a) The Commissioner of Social Services shall
administer all law under the jurisdiction of the Department of Social Services. The commissioner shall have the power
and duty to do the following: (1) Administer, coordinate and direct the operation of the department; (2) adopt and
enforce regulations, in accordance with chapter 54, as are necessary to implement the purposes of the department as
established by statute; (3) establish rules for the internal operation and administration of the department; (4) establish
and develop programs and administer services to achieve the purposes of the department as established by statute; (5)
contract for facilities, services and programs to implement the purposes of the department as established by statute; (6)
process applications and requests for services promptly; (7) make no duplicate awards for items of assistance once
granted, except for replacement of lost or stolen checks on which payment has been stopped; (8) promote economic
self-sufficiency where appropriate in the department's programs, policies, practices and staff interactions with
recipients; (9) act as advocate for the need of more comprehensive and coordinated programs for persons served by the
department; (10) plan services and programs for persons served by the department; (11) coordinate outreach activities
by public and private agencies assisting persons served by the department; (12) consult and cooperate with area and
private planning agencies; (13) advise and inform municipal officials and officials of social service agencies about
social service programs and collect and disseminate information pertaining thereto, including information about
federal, state, municipal and private assistance programs and services; (14) encourage and facilitate effective
communication and coordination among federal, state, municipal and private agencies; (15) inquire into the utilization
of state and federal government resources which offer solutions to problems of the delivery of social services; (16)
conduct, encourage and maintain research and studies relating to social services development; (17) prepare, review and
encourage model comprehensive social service programs; (18) maintain an inventory of data and information and act as
a clearing house and referral agency for information on state and federal programs and services; and (19) conduct,
encourage and maintain research and studies and advise municipal officials and officials of social service agencies
about forms of intergovernmental cooperation and coordination between public and private agencies designed to
advance social service programs. The commissioner may require notice of the submission of all applications by
municipalities, any agency thereof, and social service agencies, for federal and state financial assistance to carry out
social services. The commissioner shall establish state-wide and regional advisory councils.

    (b) The Commissioner of Social Services is authorized to do all things necessary to apply for, qualify for and accept
any federal funds made available or allotted under any federal act for social service development, or any other projects,
programs or activities which may be established by federal law, for any of the purposes or activities related thereto, and
said commissioner shall administer any such funds allotted to the department in accordance with federal law. The
commissioner may enter into contracts with the federal government concerning the use and repayment of such funds
under any such federal act, the prosecution of the work under any such contract and the establishment of and
disbursement from a separate account in which federal and state funds estimated to be required for plan preparation or
other eligible activities under such federal act shall be kept. Said account shall not be a part of the General Fund of the
state or any subdivision of the state.




                                                                                                                       25
Section 1983. Civil action for deprivation of rights

    Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or
the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the
jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws,
shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that
in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive
relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the
purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to
be a statute of the District of Columbia.

· United States Code TITLE 42 - THE PUBLIC HEALTH AND WELFARE
CHAPTER 21 - CIVIL RIGHTS,
SUBCHAPTER V - FEDERALLY ASSISTED PROGRAMS


             Section 2000d-4a. ''Program or activity'' and ''program'' defined

     For the purposes of this subchapter, the term ''program or activity'' and the term ''program'' mean all of the
operations of –
      (1)(A) a department, agency, special purpose district, or other      instrumentality of a State or of a local
government; or
      (B) the entity of such State or local government that distributes such assistance and each such department or
agency (and each other State or local government entity) to which the assistance is extended, in the case of assistance to
a State or local government;
      (2)(A) a college, university, or other postsecondary institution, or a public system of higher education; or
      (B) a local educational agency (as defined in section 7801 of title 20), system of vocational education, or other
school system;
      (3)(A) an entire corporation, partnership, or other private organization, or an entire sole proprietorship -
       (i) if assistance is extended to such corporation, partnership, private organization, or sole proprietorship as a
      whole; or
(ii) which is principally engaged in the business of providing education, health care, housing, social services, or parks
and recreation; or
      (B) the entire plant or other comparable, geographically separate facility to which Federal financial assistance is
extended, in the case of any other corporation, partnership, private organization, or sole proprietorship; or
      (4) any other entity which is established by two or more of the entities described in paragraph (1), (2), or (3);
   any part of which is extended Federal financial assistance.




                                                                                                                          26
Kathleen M. Dickson, and
on behalf of Lara E. Dickson,
Diane M. Dickson, David D. Dickson, et al,
and on behalf of all Families and
Children of the State of Connecticut

In the cause of a class action:                                                             CA 05- 328 T

v. STATE OF CONNECTICUT                                                        US DISTRICT COURT
                                                                                                         1 Exchange
Terrace
                                                                                                         Providence,
Rhode Island 02903


             August 3, 2005

                                        AMENDED COMPLAINT AND MOTION


1) Plaintiff KM Dickson motions for the appointment of counsel to represent the victims represented in
this class action against the State of Connecticut from the federal court, due to the pervasive retaliation
by the CT Justice system mentioned in the original complaint. No CT lawyer is willing to sue the State of
Connecticut or Yale University due to Retaliation Syndrome in the CT justice system, and the conditions
listed cited below in section 4) of this amended complaint.


Plaintiff KM Dickson is disabled from High Functioning Autism and Lyme Disease, the latter of which is a
chronic infection of the nervous system and which only rarely affects joints (transcript, January 31, 2001,
FDA meeting regarding LymeRIX; the testimony of Raymond Dattwyler, SUNY Stony Brook). Plaintiff‘s
children have been diagnosed with Lyme disease. Autism is a pervasive development disorder, although
no one in the State of Connecticut appears to know what that means. The Plaintiff KM Dickson had to
forward the information regarding what ―pervasive development disorder‖ and ―Neuroborreliosis‖ are to
the current Governor of Connecticut from correspondence sent to the Plaintiff KM Dickson from the
National Institute of Neurological Disorders and Stroke.

Under the Americans With Disabilities Act, access to the courts is not limited to physical access, and
persons disabled with communication problems, such as autism, must be accommodated. As described in
the original complaint, CA 05-328 T, the State of Connecticut Department of Mental Health and Addiction
Services blatantly does not recognize Lyme neuroborreliosis or Autism, which are among the reasons this
complaint was moved to another US federal district court. Plaintiff KM Dickson requests procedural
advice in order to make efficient use of the Rhode Island federal court.

2) The counsel appointed should be familiar with United States Racketeering and Corrupt Organizations
prosecution and preferably is a US Attorney. The corruption in Connecticut, labeled ―The Corruption
Virus‖ by Attorney General Richard Blumenthal, is deeply intertwined within the CT state courts. The CT
Department of Mental Health, the CT Department of Health, the CT Department of Children and Families,
CT court ―experts,‖ CT ―forensic experts‖ are both ―experts‖ for the defendant Yale University in 3:05-
CV- 92 (CFD), as regards Lyme disease and other brain disease states, as well as the ―experts‖ for the
State of Connecticut, which is a defendant also in that civil action. The US Attorney Kevin O‘Connor was
formerly a State of CT prosecutor. O‘Connor would then have to prosecute his own former criminal
―experts,‖ which would mean yet another recusal on the part of the US Attorney‘s office in Connecticut.


3) Under the Fifth Amendment “No person shall be held to answer for a capital, or otherwise infamous crime, unless on
a presentment or indictment of a grand jury, except in cases arising in the land or naval forces, or in the militia, when in
actual service in time of war or public danger; nor shall any person be subject for the same offense to be twice put in
jeopardy of life or limb; nor shall be compelled in any criminal case to be a witness against himself, nor be deprived of




                                                                                                                        27
life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just
compensation.

In the criminal case against Plaintiff KM Dickson all appearances of the above-listed protections of Constitutional law
were abandoned: Due process, a threat to deprive of property if Plaintiff KM Dickson did not plead guilty to the crimes
she did not commit, deprivation of natural children, and deprivation of their mother to Plaintiff’s natural children.
Plaintiff KM Dickson committed no crimes and was given no opportunity for due process of law. Plaintiff KM
Dickson did not know what she was being charged with until after 9 weeks in prison. Plaintiff KM Dickson was not
allowed the opportunity to prove innocence, and was threatened with permanent involuntary committal to a psychiatric
hospital if she persisted in maintaining her innocence, and the State was to take all of Plaintiff KM Dickson’s assets to
pay for Plaintiff KM Dickson’s treatment for AAG Jessica Gauvin’s psychosis.

These rights are also routinely denied in all DCF cases, rendering all DCF cases of abuse and neglect completely
illegitimate in the eyes of the public, causing citizens to reasonably suspect any “parental kidnappings” as real
kidnappings or child abuse as child abuse. These kidnappings are far likelier to be fraudulently court-rendered abuse
and neglect via termination of parental rights. This causes serious jeopardy to children who really are being abused or
neglected, but that is the handiwork, crime, and legacy of DCF alone. Recently a CT DCF supervisor (Valerie Miles)
was arrested for tampering with a witness and fabricating evidence.

The Unibomber, Ted Kaszinski, was a domestic terrorist. To falsely assert that the Plaintiff KM Dickson is like the
Unibomber, is falsely accusing someone of being a terrorist. These three conditions, 1) taking an excessive number of
children from their parents under fraudulent pretenses, 2) falsely accusing people of being terrorists, and 3) witness
tampering and fabricating evidence, puts everyone at risk because of the obvious dangers of “crying wolf,” to us all.

4) The Lyme disease scientific fraud and racketeering complaint involves the following collection of
related and possibly-related conditions which hinder the prosecution of these crimes in Connecticut, be it
in federal or state court:

a) ) The Yale Corporation is in New Haven, Connecticut; ―the Medical School Endowment Fund.‖

b) L2 Diagnostics is a private biotechnology firm spinoff from Yale‘s former Lyme and Lupus Clinic.

c) Allen C. Steere is now working at Harvard, and who is who masterminded the current and fraudulent
Centers for Disease Control‘s IgG blood testing standard for Lyme. This scam involved using the high
passage Lyme spirochete strain G39/40, which lost plasmid DNA expression. A result of being high-
passage, or culture too many times in a Petri dish, before being recycled through an animal host, which
would allow the organisms to maintain the expression of virulence factors or antigens. Thus, high passage
G39/40 lost expression of OspA and B. OspA and B are encoded on the same plasmid (small,
extrachromosomal DNA, which is vectored by bacteriophages, or viruses that infect bacteria). OspA is the
vaccine LymeRIX and ImmuLyme. ImmuLyme was not approved by the FDA for use in humans. Yale owns
the patent for LymeRIX. LymeRIX was removed from the market due to the unreported adverse events,
which took place during the vaccine trial, but were not reported to the FDA during the vaccine trial.
Adverse events were later reported, but not until the vaccine was on the market. Osps A and B were left
out of the CDC‘s blood testing standard for Lyme, as a result of this scientific fraud by Allen Steere.
LymeRIX 1) never prevented borreliosis is lab animals, and 2) never should have gone to human trials, 3)
it did not disinfected ticks but rather made the infection expand in ticks, and 4) LymeRIX did not prevent
asymptomatic Lyme infection- it apparently made asymptomatic Lyme symptomatic. Every single claim
Yale and SmithKLine made about LymeRIX was false.

d) L2 Diagnostics, in partnership with Corixa Corporation (Washington State), Imugen (Norwood Mass), and
SmithKline (now Glaxo-SmithKline), share rights to the diagnostic test for Lyme which is now the current
CDC IgG standard: Corixa‘s David Persing patented a test for Lyme from a Lyme spirochete which was
missing the OspA-B plasmid. The ―partnership‖ involves Imugen and L2 Diagnostics getting all the
national testing for Lyme disease, since they are the only ones licensed to use this fraudulent method,
while sending this free blood to Corixa Corporation, which looks for new tick borne diseases to patent for
more vaccines and test kits. During the vaccine trial of Yale‘s Lyme vaccine, SmithKline used strain B31,
which does not express much, if any, OspC, the neurotropism-associated antigen. Neurotropism means
the ability to specifically be attracted to nerve tissue. This left OspA, B and C, the ―primary,
immunodominant antigens,‖ out of the standard for the assessment of LymeRIX. These antibodies, if a




                                                                                                                           28
person had them and was infected with Lyme, would not be reported and recorded as a case of infection,
as explained by Plaintiff KM Dickson to the FDA LymeRIX vaccine committee in Bethesda Maryland, in
January, 2001. The internet link to Plaintiff‘s FDA presentation is below, on the FDA‘s website is:
http://www.fda.gov/ohrms/dockets/ac/01/slides/3680s2_11.pdf

This is scientific fraud and a monopoly on testing and vaccines, apparently orchestrated by Allen Steere
and Yale University. It is organized crime, because this testing is fraudulent, and misses the vast majority
of cases, and yet meanwhile Yale‘s Erol Fikrig and Richard Flavell own a patent for an early and accurate
test for Lyme under US patent number 5,618,533 (application date, Dec 10, 1993). The accuracy of
Fikrig‘s early and accurate test for Lyme was 17/18 cases detected, or 94.4% accurate. The accuracy of
the Steere fraudulent method is between 13 and 25%, depending on the spirochete strains used in the
testing, when, in the course of the illness, the test is performed, and the patient‘s own immune
competence to borrelial antigens. Some people can be infected and test positive and have no symptoms;
a few rare people can be infected and have an inflammatory response - which was what brought this
particular borreliosis to the attention of Mrs. Polly Murray – arthritis; but most often, people are testing
negative and have neurologic Lyme symptoms because borrelia are stealth infections, and in the
bioweapons class of ―chronic disablers.‖

If known ―chronic disablers‖ are not detectable on purpose, this is obviously a national security risk..
Someone could deliberately release a chronic disabler in a Lyme endemic area, and due to the fraud of
Lyme disease, a serious WMD disease could be spread undetected and unchecked.

e) If Lyme is not detectable, it is not treatable, and thus, Lyme is ―controversial,‖ which is a political
word meaning fraud, and which we learned about from the USDOJ lawsuits against the tobacco
companies. The tobacco companies‘ claim was that it was also ―subject to opinion‖ rather than fact,
that nicotine was addictive, while these tobacco companies were meanwhile allegedly spiking cigarettes
with nicotine. For the 2001 American Lyme Disease Foundation‘s GALA, ―a memorial tribute was made to
S. Donald Ripley, former Secretary Emeritus, the Smithsonian Instution, by his daughter, Rosemanry
Ripley, Vice President of corporate Business Development at Philip Morris Companies. ―


f) Soon it will be ―controversial,‖ or, a ―difference of opinion‖ whether or not all psychotropics are brain
damaging, even though the published science has long proven that they are, and Pfizer has published
treatments for the brain damage caused by antidepressants, which they simultaneously say does not exist.
Soon it will be controversial whether or not the DSM is an actual medical document, since the new
antipsychotic Abilify is a dopamine agonist, the complete opposite of 60 years of thought on psychosis,
after the accident of a phenothiazine dye caused the brain anesthesia which resulted the subjects of this
experiment having a ―complete disregard for their surroundings.‖ This meant ―improvement‖ to
psychiatrists. The science of psychiatric ―medicine‖ would actually be humorous if it were not so brain
damaging, especially to people who already suffer the brain-toxic state of Neuroborreliosis.


g) The State of Connecticut does not want to admit to the impact of forced psychotropic drugging of the
children the DCF kidnaps in rendering these children even more brain damaged and incompetent despite
being given the scientific evidence that this is so by the Plaintiff KM Dickson. Still they wonder why
children kill themselves in DCF‘s ―care,‖ when it is already well-known, and scientifically well-
established, that psychotropics increase dementia and agitation. The last child who killed himself in
DCF‘s ―care,‖ was diagnosed with bipolar. An educated guess from the newspaper reports was that he
refused to take these brain-numbing drugs, which was the reason the DCF placed him back in jail
(―refused state services‖). Having taken these brain damaging drugs before, rendered the child more
agitated than ever, since that‘s what these drugs do. Since the child then got sucked backed into the
clutches of the diabolical DCF again, only this time, for their prison, he killed himself. Children cannot
take this much abuse. His family said he wanted to be home. Apparently DCF would not allow that. DCF
is responsible for homicide in this case, if the above hypothetical conditions did in fact, occur. According
to the Hartford Courant: ―Children can refuse services at any time and the agency can do little to stop
them.‖ Plaintiff KM Dickson wonders why didn‘t they leave the boy alone, and if this action is an
indication that DCF is desperate for bodies.




                                                                                                           29
The DCF‘s and DMHAS‘ very ignorant and very arrogant ―solutions‖ cause these problems. If you numb
someone‘s brain, there is an equilibrium response adjustment. Although it might be fine for the DCF to
have brain-numbed the children in their ―care,‖ since numbness of the brain results in less movement and
less neurotransmission, when these children are no longer brain-numbed children, they are demented
adults, who then end up in the adult prisons. In the vast majority of the cases of incarceration (94%), it is
because they later self-medicate their DCF-induced and other- abuse-related traumas with illegal mind
altering substances. The State of Connecticut employees know absolutely nothing about care or love, and
neither does psychiatry. This could be the reason they don‘t even know where to start as regards fixing
DCF. One suggestion would be the removal of all psychiatric terminology from their vocabularies, since
none of it is valid, outside of the terms which represent scientifically identifiable genetic, organic,
cognitive, and traumatic compromise. As previously demonstrated in the original complaint, DMHAS and
DCF are incompetent to even the CT competency statute


h) Yale University had an accurate and early test for Lyme disease in 1991, yet this was not deployed in
their vaccine trial. In fact, Yale‘s Durland Fish conspired to discredit the Lyme Disease Foundation (LDF)
when the Lyme Disease Foundation discovered that people should be treated with antibiotics upon tick
attachment in 1995. He, Durland Fish, conspired with the NIH‘s Edward McSweegan to send the Lyme
disease Foundation ―a bogus article‖ to discredit them, as a result of the LDF‘s finding that tick
attachment should be treated, and people should not wait for the rash to show up to treat with
antibiotics. If people are treated upon tick attachment, as a matter of standard health protocol (which it
now is), then during the fraudulent vaccine trials, it would not be known whether or not persons who
were bitten by ticks had their potential Lyme disease prevented via the vaccine or the antibiotic.
Therefore these ―researchers‖ withheld this information from the public for 9 years, allowing untold
hundreds of thousands of people to become infected with this permanent brain infection, when it may
have been avoided in the cases where people knew they were bitten by a tick.

i) The dimensions and range of death and disability caused by this fraud is unknown, but must be
addressed by the federal court as medical negligence and likely, homicide, given Yale‘s and the other
RICO entities‘ insistence that Lyme magically disappears after 30 days of antibiotic treatment and the
disease suddenly becomes psychosomatic, which is according to the plans of this scientific medical scam,
first laid out by Allen Steere in ―The Overdiagnosis of Lyme Disease,‖ in 1993. In 47% of the cases of Lou
Gerhig‘s disease in a Lyme endemic area, the victims had evidence of exposure to borrelia. (This is a
scientific fact.) Thus, borreliosis is deadly.

j) The looser partnership or associated companies in the Lyme disease racket also includes Kaiser
Permanente, Yale, CastleConnolly.com, and the American Lyme Disease Foundation (Somers, NY), whose
chairman was the late David Weld, the brother of former Massachusetts Governor William Weld. Under
the USDOJ racketeering statutes, one only has to have the appearance of collusion, and not an actual
record, documentary evidence or audio-taped evidence, that these companies sat down together and
said, ‖Okay, Here‘s how we are going to cheat people out of treatment for Lyme: First we‘ll make it
almost undetectable, by changing the blood test. Then we‘ll call them crazy and destroy their
credibility. We can get away with it, because central nervous system Lyme causes physiological
depression, which we know from all the brain damage in Lyme we discovered. General practice
physicians will readily buy into an opportunity to declare people crazy and that their patients‘ complaints
not legitimate because of their innate and acquired arrogance, we teach them at medical school.
Besides, Lyme patients are whiney, nobody wants them, and they never stop being sick once the disease
has progressed. Uncle Sam can pick up the tab. They‘re easy to fool…. Meanwhile, all the doctors who
currently treat Lyme? We‘ll get them for malpractice or something, and take them out of commission….‖

k) William Weld, while Governor of Massachusetts wanted to ―reintroduce prisoners to the joys of busting
rocks.‖


l) The Rowlandgate scandal involved Rowland‘s Chief of Staff, Peter Ellef, and Deputy Chief of Staff,
Lawrence Alibozek, both of whom were former CIGNA employees. Rowland‘s family owned an insurance
company (presumably, insurance sales).




                                                                                                          30
m) Mr. Peter Ellef had visions of building a national chain of high-end garden centers and a national string
of prisons and juvenile detention centers in old stone quarries. Mr. Ellef Junior, a defendant in the
federal indictment against Ellef, Alibozek, Ellef and Tomasso, owned a landscaping company.
Landscaping companies buy, sell, and use rocks for ornamental stone retaining walls, borders, driveways,
and the like. High-end garden centers also sell rocks. If Mr. Peter Ellef Senior had access to rocks at a
discount, since the consummate ideology of the Welds and the alleged Rowlandgate criminals appears to
be to put prisoners to work (slave labor) busting rocks, Senior Ellef‘s vision, in combination with Mr. John
Rowland bragging about being a national security advisor to Mr. President George W. Bush, and given the
close association of the Bushs and the Welds to Yale, gives the appearance that all of them are fond of
incarceration as a solution to poverty, and even chronic illness, especially given the racial profiling, which
cannot be denied.


n) August 1, 2005, the present CT Governor Rell announced the closure of the scandal- and abuse-laden
pediatric prison known as CJTS ―managed‖ by DCF. The new proposal is for more, but smaller
incarceration units, when the real solution is to get rid of the DCF. If a child commits a murder or
something that serious, they belong in protective custody, like a hospital (childhood is an undeniable
condition of incompetence) until the condition which bread the violence is worked out. In the majority of
such cases, the child was treated violently previously. Thus child murderers are usually doubly mitigated,
and triply mitigated, if they are also DCF victims, and again, quaduply mitigated if they were given
psychotropics.




o) The Lyme disease racketeering crime involved insurance companies‘ denial of care for chronic Lyme,
which was also masterminded by Allen Steere when he defrauded the public by stating that late chronic
nervous system Lyme was ―some psychiatric disorder,‖ and wrote the ―bogus article,‖ ―Overdiagnosis
[sic] of Lyme disease.‖ In this ―bogus‖ (a word used by Yale‘s Durland Fish in correspondence with the
NIH‘s Edward McSwegan) scientific report, Steere also used the bogus high-passage strain G39/40, to not
find Lyme. Not finding Lyme saves insurance companies a great deal of money, since the relapsing-
remitting treatment for this relapsing borreliosis, Lyme disease, which results in a Multiple Sclerosis-like
syndrome according to Allen Steere (1991 Rheumatology News) costs $12,000 a month, minimally, as is
the wholesale cost of the drug (the discounted price, where the pharmacy makes no profit). However,
the malpractice treatment of late nervous system Lyme, which is treatment with psychotropics, increases
the dementia. This malpractice is even clearly against the American Psychiatric Associations‘ Guidelines
for the treatment of a delirium, as previously demonstrated with the evidence submitted in the original
complaint CA 05-328T, so it is not a matter of opinion, how to treat Central Nervous System Lyme.


p) The (President) Bush‘s family (G. H. Walker & Co.) sold an investment firm to the Weld family (Weld
White).

q) A federal judge in Connecticut is John M. Walker, and who is related to the Walker-Bush family and
who is a Yale graduate. He is the cousin of the first president Bush, Mr. George H. Walker Bush.

r) The President Mr. George W. Bush‘s uncle Mr. Jonathan Bush was a member of the Yale Corporation,
and his investment firm was associated with the Riggs Bank. The Riggs bank was fined 25 million dollars
by the federal government for money laundering and hiding the assets of the Chilean Dictator Pinochet, in
addition to holding funds for 150 Saudi families. Osama bin Laden is a Saudi, whose family owns a
construction firm, and it is believed that bin Laden‘s own money was contributed to the terrorism
executed against the United States on 9/11/01. Judge Walker and Mr. Jonathan Bush live in Killingworth
Connecticut. Mr. Jonathan Bush owns a company called JBush & Co, and from their website:
―J. Bush & Company manages $700 million in assets for high net worth individuals and families, corporate
benefit plans, and foundations. We seek to build wealth for our clients by investing in high-quality,
growth stocks.‖

s) President George W. Bush did not attack Saudi Arabia for funding terrorism. He instead attacked Iraq,
and we later found out that 1) ―the facts were being fixed around the policy,‖ that 2) Dr. David Kelly of
Great Britain and British Intelligence laughed at the notion that Iraq could place a biological warhead on a




                                                                                                           31
weapon in 45 minutes since there were no such WMDs in Iraq, and that 3) Mr. Karl Rove was one of the
leakers of the CIA agent whose husband, Mr. Joseph Wilson, revealed that Iraq was not trying to buy
yellow cake uranium from Niger, rendering all of the hype about the dangerousness of Iraq to be clearly
fraudulent.

t) On or about 9/13/01, Mr. Paul Wolfowitz suggested lopping off the lower portion of Iraq to the Bush
administration. Iraq is an oil producing country close to Israel. It has the second largest oil reserves in
the world and had a human rights abusing government, as does Saudi Arabia. Perhaps it would look a
little better if we invaded Iraq for their oil, since Saddam committed genocide against the Kurds, and the
US had earlier sold Iraq some WMDs to be used against Iran. Mycoplasmal infections carried by ticks can
infect livestock, such as cattle, goats and sheep, rendering them sick with pneumonia, lameness, or
unable to produce milk. Mycoplasmal infections are usually resistant to antibiotics (except macrolides),
and treating mycoplasmal infections are said to make these infections worse by killing off other bacteria,
allowing the mycoplasmal infection to spread, however, it might be likelier that mycoplasmal infections
simply suppress the immune system, allowing the other infections to spread. This appeared to be the
case with the illnesses caused by Yale‘s LymeRIX vaccine, which was of myco origin.

A Plum Island director at first denied working with mycoplasmas on Plum Island, but then when shown the
evidence that we knew they had, she retracted that denial. If it is true that the Iraqi scientist who was
given these mycoplasmas to take back to Iraq from Plum Island was killed by the Israelis (he was run over
while changing a tire, much like the Don C. Wiley case), and these Israelis were from the Mossad (who
also are accused by some as being responsible for the Kennedy assassination by some groups, because of
Kennedy‘s stance on Israel having nuclear weapons), one can suspect the reasons Mortimer Zuckerman
attempted to attend the ALDF‘s 2001 ―GALA‖ at the Pierre Hotel in New York City. Zuckerman was also a
candidate for ambassador to Israel. Israel depends on US Military might for protection from people who
believe Israel has no rights to the Holy Land. Because of Yale and their fraud on Lyme, which involves
Zuckerman (who owns Newsday and the US News and World Report), one would suspect that any
information Yale and the ALDF have about vector borne disease and animal diseases, which are also
bioweapons and chronic disablers like Lyme disease, may have been given or sold to Israel as well as Iraq.
Plaintiff KM Dickson has long suspected that the reason George H. W. Bush did not finish off Saddam in
1991, was because of the bioweapons he knew Iraq had, because we sold them to Iraq to use against Iran.

Whatever we have, as ―chronic Lyme,‖ that the people named in the RICO case insist we don‘t need
treatment for, may be some accidental release of an animal disease other than Lyme, carried by ticks.
All one has to do, is study the work of Tully TG on MedLine.

u) Mr. Paul Wolfowitz is also a chemist, and chemists understand the principals of thermodynamics:
Energy equals Power, and in order to be the world police, the United States must have jet fuel. Oil is also
essential to the US auto-motorized economy.

v) Presidents Bush I and II attended Yale.

w) Mr. Paul Wolfowitz was an instructor lecturer at Yale. Mr. Lewis Libby, the other CIA Plame name-
leaker, was a student of Mr. Wolfowitz‘. From Wikipedia: ―From 1970-72 Wolfowitz taught at Yale
University where one of his students was Lewis Libby who would become a long-term political associate.‖

x) The State of CT made an ―illegal loan,‖ according to Attorney General Richard Blumenthal, to
ENRON, while former Governor Rowland was a member of the Yale Corporation, and should have known
how to invest for the State better. Yale earned 8 billion dollars during the 10 years of the Lyme scam,
from $2.5 billion to $10.5 billion, for the Yale Corporation. The illegal loan was for 220 million dollars,
but to the best of the Plaintiff KM Dickson‘s knowledge, AG Richard Blumenthal was able to recover a
significant percent of those losses. Connecticut could have invested in Equatorial Guinea or the Sudan,
for example, instead, and had a significant stake in oil and timber assets globally, as the Yale Corporation
now does.

y) Mr. William Weld‘s brother Mr. David Weld was chairman of the American Lyme disease Foundation
and which is the central RICO entity involved in the fraud in ―Lyme disease.‖




                                                                                                         32
z) Hartford is known as the insurance capital of the world. Since Kaiser-Permanente knows Lyme is a
permanent brain infection, requiring repeat treatment with ceftriaxone, one can assume other insurance
companies do as well. One of the founders of the American Lyme Disease Foundation (1990), the former
president of New York Medical College, Mr. John J. Connolly, now owns CastleConnolly.com, which
publishes an internal HMO industry newsletter. In 1989, the Infectious Diseases Society of America
published that Lyme is a permanent nervous system infection, like other known spirochetal infections,
and the treatment endpoint was not known. New York Medical College was failing financially, and Kaiser
is now there training General Practitioners. The New York Office of Professional Medical Conduct, had
until recently gotten their experts on Lyme from this Insurance Industry source - Kaiser at New York
Medical College - to declare the perjury that Lyme is cured with 30 days of antibiotics, and that the CDC‘s
case definition, which is Allen Steere‘s fraudulent blood test definition of Lyme disease, is the only kind
of Lyme disease there is, in an attempt to remove the medical licenses of Lyme treating specialists.

aa) Yale‘s Ms. Janine Evans, of Yale, is one of the entities involved in the fraud of Lyme disease, and was
or is the Yale Physicians Group‘s managed care liaison. Yale is often sent patient records by insurance
companies for second opinions on whether or not a person should be treated for Lyme. It even occurs
that people who have the false positive criteria of Allen Steere are denied treatment, since Yale can say
this is post-Lyme, since it is all IgG antibodies (late occurring) and not active, treatable Lyme. Part of
Steere‘s fraud was to leave out the vast majority of IgM antibodies in the standard for Lyme, although he
earlier included them as evidence of active infection, and specifically reported that this was his
reasoning, in 1986, in the earlier testing scheme for Lyme disease.

bb) It appears former Governor John G. Rowland benefited from the ENRON transaction by being made
the president of the Republican Governors‘ Association.

cc) Vice President Dick Cheney is a former CEO of Halliburton, whose industries include the dismantling of
nuclear power plants and oil recovery.

dd) The specific documentation of this scientific fraud in Lyme disease is in the office of the US Attorney
Kevin O‘Connor, in New Haven, CT. Mr. Kevin O‘Connor had to recuse himself from the federal
investigation of the crimes in the Connecticut Governor‘s (Rowland) office, because Mr. O‘Connor‘s wife
worked in Rowland‘s legal office apparently while the crimes took place. The crimes involve the CT
Department of Children and Families‘ (DCF‘s) policies of abuse rather than assistance to families. What
the DCF calls ―services,‖ is actually organized trafficking in humans (regarded as ―removals‖), for the 1)
federal tax dollars brought into the State of CT, 2) for the criminal entity known as ―TREA,‖ a limited
liability corporation, 3) into the salaries of DCF ―workers‖ and corrections officers, 4) for foster care
parents, many of whom provide foster care just for the money. Mr. O‘Connor, to the Plaintiff KM
Dickson‘s knowledge, was a former State of Connecticut New Britain prosecutor, and has a record for the
most death penalty convictions in Connecticut. The Assistant US Attorney Nora Dannehy and Deputy US
Attorney John H. Durham likely experience discomfort working under Mr. Kevin O‘Connor and around Mr.
Christopher Morano, the Chief State‘s Attorney, and in regards to all of the sitting judges who were
appointed by Mr. John G. Rowland. Mr. Morano was asked to stay out of the way of the investigation of
the corruption in Mr. Rowland‘s office.

Thus, due to the total corruption in the State of Connecticut, which is to include some of the people in
the District of Connecticut‘s US Attorney‘s office, the Department of Justice and their relationship to Yale
University, and via the presence of various Yale-Bush-Weld banks or investment firms and insurance
companies, this complaint must be prosecuted from another jurisdiction of the federal government. Mr.
O‘Connor was quoted in one of the online newspapers that, ―When we worry about Nora, it is because she
is working too hard.‖

Plaintiffs et al request assistance from the federal court in Rhode Island to include representation by
counsel appointed by the federal court. That counsel should have experience prosecuting organized
crime. The indigency of the Plaintiffs is inherent, since the victims of ―Rowlandgate‖ are fully exhausted
of personal resources, after having dealt with the corrupt DCF and corrupt judicial system. The primary
purpose of this action is to arrest the crimes committed by employees of the State of Connecticut, and
their paid ―experts,‖ against unsuspecting, innocent, private persons.

The Plaintiff KM Dickson called the DCF and complained about Mr. John G. Rowland exposing his children
to lying, cheating, and stealing, and thus corrupting them, since in addition to lying to the press and the




                                                                                                         33
public about who paid for what, Mr. Rowland blamed his son for the robbery of a CT state warehouse
where they helped themselves to camping equipment, but to the plaintiff KM Dickson‘s knowledge, Mr.
Rowland‘s children were not removed. Obviously it was a valid complaint of abuse and neglect. Mr.
Rowland was removed instead.

The Plaintiff KM Dickson, as a former employee and analytical chemist with Pfizer, has nearly expired all
savings and 401(K) funds due to the harassment by the State of Connecticut and their hired Yale
―experts.‖ The little that remains in Plaintiff KM Dickson‘s 401 (K) from Pfizer must be used in the case
that CIGNA drops her long term disability coverage again, which they obviously threatened to do in 2004,
which resulted in the alleged ―harassing communications and threatening‖ response by the Plaintiff KM
Dickson. The Plaintiff KM Dickson had told CIGNA basically that if they were looking for truly crazy
people to drop the long term disability coverage for, they should look no further than the CT DCF. Lyme
is a brain disease and Autism is a brain order.


Plaintiff KM Dickson had testified at the FDA meeting in Bethesda regarding the fraudulent Yale Lyme in
January 2001, exposing the entire fraud of the testing for Lyme. CIGNA continues to harass the Plaintiff
Dickson, as is demonstrated in the alleged ―harassing communications and threatening‖ of AAG Jessica
Gauvin. The Plaintiff Dicksons, Kathleen, Lara, Diane and David, cannot get adequate care for Lyme
disease, due to the Lyme disease racketeering condition and the DCF racketeering condition. The Lyme
disease racketeering complaint filed with the US Attorney‘s office and copied to CT Attorney General
Richard Blumenthal, AAG Jessica Gauvin asserted for the DCF ―court,‖ was evidence of Plaintiff KM
Dickson‘s insanity.

Science does not equal insanity, unless one is a psychiatrist, as is the case with DCF‘s, Yale‘s and DMHAS‘
―experts,‖ Kenneth Marcus and Patricia Leebens, or unless one is a social worker like DCF‘s Maureen
Auger, or unless one is a DCF attorney like the fired New Haven Principal Attorney, Sarah Gibson, or an
Assistant Attorney General for the DCF like Jessica Gauvin, rendering all these opinions, and the classes of
people they represent to be utter nonsense: Psychiatrist, ―social worker,‖ or lawyer for the State of
Connecticut or Yale.

That the Plaintiff KM Dickson was declared insane was the State of Connecticut‘s and Yale‘s only
recourse, since the science of the scientific fraud and racketeering in Lyme, and the malpractice
treatment of Lyme dementia described in the perjury by James Phillips and Kenneth Marcus, (Yale and
DMHAS) is published and is beyond dispute. AAG Jessica Gauvin brought no ―expert‖ to prove that the
Plaintiff KM Dickson‘s assertions that organize crime in ―insurance medicine,‖ ―bogus articles,‖ and the
scientific fraud in ―Lyme disease,‖ which became ―LymeRIX disease,‖ were not scientifically valid. In
fact, no one has yet, at all.

Plaintiff KM Dickson was an analytical methods development chemist for a pharmaceutical company,
which seems to be the primary point of irritation for all participants in Plaintiff Dickson‘s various
fraudulent prosecutions, yet that this is irritating to others is beyond Plaintiff‘s understanding or ability to
analyze. Plaintiff KM Dickson has high functioning autism, which is the furthest thing from a brain
―disorder‖ that there is. All one has to do, is read the DCF‘s ―records‖ to know what a real brain disorder
is. One would suspect that since there is an identifiable difference in brain morphology in autistic people
(the right side, or visual side, is bigger), and autistic people never lie, one would expect the brain
morphology of these outrageous liars, all of the DCF staff, would also show a difference, however the DCF
hasn‘t asked for any mental health help. People with antisocial personality disorder (are ―sociopaths‖)
are beyond fixing, and this is a general consensus among psychiatrists.
From MentalHealth.com:

Antisocial Personality Disorder

American Description      Diagnostic Criteria

    A.   There is a pervasive pattern of disregard for and violation of the rights of others occurring since
         age 15 years, as indicated by three (or more) of the following:
             1. failure to conform to social norms with respect to lawful behaviors as indicated by
                  repeatedly performing acts that are grounds for arrest




                                                                                                            34
              2.  deceitfulness, as indicated by repeated lying, use of aliases, or conning others for
                  personal profit or pleasure
             3. impulsivity or failure to plan ahead
             4. irritability and aggressiveness, as indicated by repeated physical fights or assaults
             5. reckless disregard for safety of self or others
             6. consistent irresponsibility, as indicated by repeated failure to sustain consistent work
                  behavior or honor financial obligations
             7. lack of remorse, as indicated by being indifferent to or rationalizing having hurt,
                  mistreated, or stolen from another
    B.   The individual is at least age 18 years.
    C.   There is evidence of Conduct Disorder with onset before age 15 years.
    D.   The occurrence of antisocial behavior is not exclusively during the course of Schizophrenia or a
         Manic Episode.




Differential Diagnosis
Substance-Related Disorder; Schizophrenia; Manic Episode; Narcissistic Personality Disorder; Histrionic Personality
Disorder; Borderline Personality Disorders; Paranoid Personality Disorder; Adult Antisocial Behavior.


If CT DMHAS would concentrate 100% of their failed mental health system ―treatments‖ exclusively on
DCF staff, both abominable agencies, DCF and DMHAS, would cancel out, and would no longer be a threat
to the rest of the residents of the State of Connecticut who are ―normal,‖ based upon the sole virtue of
not being a DCF employee.


=========




                                                                                                                  35
          _____________________

          Plaintiffs
                                  Kathleen M. Dickson, et al
                                                       23
Garden Street

          Pawcatuck, CT 06379




                                                         36
           COMPLAINT
Kathleen M. Dickson, and
on behalf of Lara E. Dickson,
Diane M. Dickson, David D. Dickson, et al,
and on behalf of all Families and
Children of the State of Connecticut

In the cause of a class action:                                                  CA 05- 328 T

v. STATE OF CONNECTICUT                                               US DISTRICT COURT
                                                                                             1 Exchange
Terrace
                                                                                             Providence,
Rhode Island 02903


           August 22, 2005

                                      MOTION TO AMEND COMPLAINT

Contents:
CORRECTIONS – page 1
SUMMARY OF COMPLAINTS, AMENDMENTS AND MOTIONS – page 2
CASES – page 3
THE SCIENCE - page 11
THE NON-SCIENCE - page 17
THE NOV 20, 2003 DATABINDERS –page 19
STATUS –page 23
ABUSE AS POLICY- THE 10-FOLD INCREASES- page 25
THE REALITY OF FORENSIC PSYCHIATRY- page 28


CORRECTIONS: To Amendment and motion dated August 3, 2005. Plaintiff Dickson was mistaken about
Mr. Kevin O‘Connor, the present US Attorney for the District of CT, as having been a former New Britain
State prosecutor, having a reputation for the highest number of death penalty convictions in the history
of the State.

The Plaintiff Dickson should have known better than to assume this statement had any legitimacy, since a
prison guard or judicial martial informed Plaintiff of this untrue history as we drove into the parking lot of
the New Britain courthouse, during one the Plaintiff‘s many trips to courthouses to listen to even more
nonsense, false criminal charges, and perjury.

Plaintiff KMDickson apologizes to Mr. O‘Connor for this gross lapse in fact-checking. Plaintiff Dickson
would still like to be informed of the history of Mr. O‘Connor‘s placement as US Attorney in Connecticut,
since one of the secretaries in Mr. O‘Connor‘s New Haven office also informed Plaintiff Dickson that Mr,
O‘Connor‘s wife worked on former Governor John Rowland‘s re-election campaign. We should all know
better than to believe anything any state and federal employees say, and especially the Plaintiff Dickson
should know this.


SUMMARY
The original complaint Docket Number 5 328T filed in Rhode Island Federal Court was a summary of
examples of incompetence and abuse of CT residents illegitimately caught up in ―the system,‖ who
essentially needed assistance from the State. They ended up being victims of the crimes of CT State
employees, and then had their lives and their families lives ruined under various federal civil rights




                                                                                                           37
violations, violations of the Americans with Disabilities Act, First Amendment, Fifth Amendment, and the
failure of the State‘s various commissions to understand what duties they are commissioned to perform.
The only service the State evidently provides is abuse or neglect. This was substantiated in the CT
VOICES FOR CHILDREN report regarding the CT Department of Children and Families (DCF), entered as
Exhibit F, Docket 5-328 T.

The first amendment to this complaint, dated August 3, 2005, contains a motion for appointment of
counsel who is competent to be a US Attorney, due to the racketeering and organized crime surrounding
State agencies and as regards the scientific fraud of ―Lyme disease.‖ Plaintiff retracts the statement
made about Kevin O‘Connor in section of this document, in item, ―dd‖ which states: ―Mr. O‘Connor, to
the Plaintiff KM Dickson‘s knowledge, was a former State of Connecticut New Britain prosecutor, and has
a record for the most death penalty convictions in Connecticut.‖

AMENDED COMPLAINT:

This current Plaintiffs motion to amend the class action against the State of Connecticut is to now include
all people abused and neglected by the Department of Mental Health and Addiction Services, the
Department of Mental Retardation, and the CT Division of Criminal Justice - persons who have
documented mental impairments, and as represented by the following cases of cognitive or mental
disability: mental retardation, Alzheimer‘s and Parkinson‘s and other dementias, the neuropsychiatric
disease Multiple Sclerosis, and the brain damage incurred by psychotropics.

The CT competency statute 54-56D assumes the State DMHAS staff is competent to brain matters. DMHAS
is not competent, as previously described, and as will be demonstrated below in this second amendment
to the class action complaint 05-328 T.

Other statutes violated include the virtual declaration of non-human status for CT‘s alleged defendant
John M, which is clearly a violation of every known USA civil rights statute, and UN‘s international human
right declarations, as previously mentioned (Deprivation of Rights, Color of Law, Conspiracy to Deprive of
Rights, United States Civil Code: Titles 18, Secs 241, 242, 245, Americans With Disabilities Act.)


CASE EXAMPLES:

1) John M. is a young adult with mental retardation, yet he has been housed in a CT prison since February
2005 for 2 counts of sexual assault 4th degree and risk of injury to a minor.. His family has been denied
the right to see the warrant and specific charges against him, because they involve a minor boy. John M.
has been determined competent to stand trial, although his family states that he was given a competency
evaluation, which the family has not seen, and their request to see it has not been granted by the State.
The family was only told verbally that John M. is competent to stand trial. John M. has been kept in
prison these last 6 months.

The family states John M. was raped in prison, and that it took almost a month for the prison doctor to
investigate. John M. was raped in one prison, and was examined in another. Naturally, the guards denied
it happened.
A letter written by Annette Rose, DMR Case Manager, which is EXHIBIT KK, dated October 22. 2004,
states:
            To Whom It May Concern:
         Please be advised that John M., date of birth 11-07-80, was determined eligible for Department
         of Mental Retardation Services by H. Steven Zuckerman, PhD., Supervising Psychologist 2.
         According to Elibigibilty Determination document signed by Mr. Zuckerman and dated 08-14-98,
         John M. ―falls withing the Mild range of Mental Retardation.‖ This document can be found in Mr.
         M.‘s Department of Mental Retardation case record.

In the letter on behalf of John M. was written by Brian O‘Rourke and Ellen Gilman of the Office of
protection and Advocacy for Persons with Disabilities, Hartford, CT, [EXHIBIT 5-328T LL], they state:

        ―Mr. M‘s habilitation cannot be addressed in a correctional facility. His cognitive limitations
        combined with a history of behavior adjustment difficulties increases the serious risk prison
        incarceration posess to his personal safety and psychological well-being. As you are aware,




                                                                                                          38
        prisons can be especially dangerous environments for individuals being held on (or convicted of)
        charges of the nature he is facing.

        Mr. M.‘s past psychological reports cite significant language processing deficits. His language
        processing becomes further compromised when John becomes anxious. This factor does
        interfere with his ability to cope with his current situation. Mr. M‘s mild retardation, in addition
        to these deficits places him at a serious disadvantage as he attempts to work with his attorney in
        defense of these charges. When we met with Mr. M., we found that he had a great deal of
        difficulty participating in a simple conversation about his present circumstances.

        Mr. M‘s history shows that he needs significant support to reinforce his awareness and acquisition
        of appropriate social skills. The Department of Mental Retardation should have reevaluated Mr.
        M‘s service and support needs over a year ago, when allegations of criminal conduct were first
        made. The development and implementation of an individualized service plan needed to occur
        at that time.

        As a resolution to this Programmatic Aministrative Review request, we ask that the DMR
        immediately identify an emergency (short term), community based residential placement for Mr.
        M., and that Mr. M.‘s attorney, Mr. John Coccio be informed of this option. Once in placement,
        we request that the DMR complete any relevant assessments and develop a well-designed
        community-based support propgram to meet Mr. M‘s long term needs.‖

This letter was written April 11, 2005, and is a comprehensive and adequate attempt to have a rational
grasp of the needs and the urgency that Mr. M‘s be treated as a person with mental retardation. Again,
they state:

        Mr. M‘s mild retardation, in addition to these deficits places him at a serious disadvantage as he
        attempts to work with his attorney in defense of these charges. When we met with Mr. M., we
        found that he had a great deal of difficulty participating in a simple conversation about his
        present circumstances.

This would appear to resoundingly dispute any legal competency of Mr. M. that the State‘s attorney‘s
office has arbitrarily - and without producing the documentation of - asserts exists. Further follow up
with the Department of Mental Retardation suggests strongly that there is no alternative housing for John
M., yet the State also claims to have 16,000 residents in CT with mental retardation and that 1% of the
population has mental retardation (IQ of 70 or below). The website of the DMR states that:

        ―Unlike other agencies, its supports and services (with the exception of Birth to Three), are not
        an entitlement for people with mental retardation and the majority of its services are provided
        by private non-profit organizations in local communities.

This gives the appearance that like the DCF, the DMR provides no real services, other than the pay checks
of the employees. There is no housing available for these people, when one would think such would be a
priority, since one thing there is no denying exists is mental retardation. Autistic people belong to this
department.

Autism is an epidemic, yet instead of planning for this epidemic or Lyme disease, and seeking appropriate
federal funding, the State planned for an increase in prison cells, as previously mentioned.

In an email to Ms. Ellen Gilmartin, Gino DeMaio, Forensic Coordinator, State of CT Department of Mental
Retardation, states that ―John has asked DMR to not attend these hearings and has not wanted his case
manager to be involved.‖ [EXHIBIT MM]

The family who had been the guardians of John M. state that no such conversation took place. They state
that John cannot even make change, and once bought a pack of gum from a child for 5 dollars, not
knowing that a pack of gum costs nowhere near 5 dollars.


H. Steven Zuckerman, PhD. Of DMR on September 14, 1998, [EXHIBIT NN] states that as regards John M.,




                                                                                                         39
       ―Based on the information presented to me, this individual does meet the definition of mental
      retardation as defined in CGS Section 1-1g, and is therefore eligible for Department of Mental
      Retardation services. This individual falls within the Mild Range of Mental Retardation.‖

Listed as requirements for this condition are under Connecticut General Statutes 1-1G.

         ―For the purposes of sections 4a-60,. 17a-274, 17a-281, 38a-816, 45a-668, 45a-684 inclusive, and
         sections 46a-51, mental retardation means a significantly subaverage general level of functioning
         existing concurrently with deficits in adaptive behavior and manifested during the development
         period.‖


The family of John M. state that the incident for which he is in jail took allegedly took place on November
1, 2003, yet it wasn‘t until the summer of 2004, when John M. and his cousin tried to attain a minor
position either in the local fire department, or be volunteers or trainees, did anyone take any legal
action. John M. went to jail in February 2005 and has been there since, without his family being allowed
to know exactly what he is being charged with, who performed the competency evaluation, or any of the
important details of the case. The family states that they don‘t even know how the case was transferred
from Norwich, where the family lives to the New London courthouse.

There was apparently another nephew involved, and the State prosecutor combined cases with no
explanation as to how all these events took place.

Years before, apparently, the retarded boy‘s uncle proposed citizen oversight of the police. John M. was
apparently involved in an incident at Walmart where a child was in the men‘s room and could not get his
pants down to go to the bathroom, and the parent was nowhere around, so John M. helped. Walmart
hires retarded people and are familiar with the difficulties of retarded people, and of course were willing
to let the whole event drop, to the best of this Plaintiff‘s knowledge. There is little documentation of
events available, and that would be because the public does not know what they are up against, if they
become the arbitrary victims of crazy people who know how to use the DCF and the police to their
advantage. Hopefully this complaint will alert the residents of Connecticut to the hazards of being a
Connecticut residents, before the adequate resolution of these crimes, as described as relief and damages
in the original complaint Docket 5- 328 T, dated July 27, 2005.

One can see how this Walmart event would get mixed up, and that it is impossible to tell what happened
if John is mentally retarded, and as is known of him:

         ―Mr. M.‘s past psychological reports cite significant language processing deficits. His language
         processing becomes further compromised when John becomes anxious. This factor does
         interfere with his ability to cope with his current situation. Mr. M‘s mild retardation, in addition
         to these deficits places him at a serious disadvantage as he attempts to work with his attorney in
         defense of these charges. When we met with Mr. M., we found that he had a great deal of
         difficulty participating in a simple conversation about his present circumstances.‖

It was after this Walmart incident that John M. uncle proposed citizen oversight of the police. One can
see that what we have is in reality, two sets of parents of young children, only one looks a lot older. Both
are equally concerned about their children.


It appears as though there is a tremendous tug-of-war over bodies, between the Department of Criminal
Justice, the Department of Children and Families, the Department of Mental Health and Addiction
Services, but oddly, not the Department of Mental Retardation. Each has their own set of statutes, and
the only mediator, the Department of Protection and Advocacy for Persons with Disabilities, appears to be
powerless.

There are numerous free assistance agencies in the State of Connecticut but they don‘t actually do
anything for anyone, even if one is lucky enough to get one of them to call back. This is not only the
Plaintiff Dickson‘s experience, but was the experience of every single person who was dragged through
the Connecticut Valley Hospital as ―incompetent.‖ Not too many of the ―criminals‖ were incompetent, if
they knew how to look for help. The help was incompetent, and one wonders of these non-profits take




                                                                                                          40
federal funding to provide no service. It did not take long before we ―prisoners‖ we all joking about what
a waste of advertising and publishing these alleged non-profit legal help groups expend, and especially,
about our coins for the pay phone, which were wasted. It is well known that a CT public defender is
called a ―public pretender,‖ and the only people who can emerge from this potentially permanent trap
are those who have family support on the outside.

Frequently enough to be a recognizable phenomenon, as in the evidence of many of the women in prison,
whoever goes to jail, in family disputes, is a matter of who called the police first. Then of course, once
one person has a record, those persons are always assumed to be guilty in subsequent disputes, which
involve altercations and then the police. One prison guard told the Plaintiff that people routinely place
their relatives in prisons just to get rid of them because they are a nuisance. Plaintiff Dickson only heard
abundant evidence to support that this is true from listening to a vast number of the inmates at York.

It appears that just as it is well-known that the DCF can be used as a weapon, so to can the police be
used as a weapon. Hearsay is plenty good enough for DCF to fraudulently take anyone‘s children away.
No one has ever been prosecuted for false allegations of child abuse or neglect in Connecticut. The
DMHAS employees also refer to CT as a ―Meat Grinder.‖ They have seen this abuse enough times. Lower
level DMHAS employees are remarkably more sane than their supervisors and more sane than the DMHAS
―doctors.‖ They are more sane than corrections officers, police, and DCF ―social workers,‖ to their
credit. These mental health workers and nurses at the CVH ―competency restoration unit‖ should all get
the salaries of the police and corrections officer and DCF workers, while all of the latter 3 groups should
be fired. DMHAS mental health workers and nurses are in a class unto themselves in the state of
Connecticut (at the present time).


2) Marsha Hoggan, 55, is an Alzheimer‘s patient who also has Parkinson‘s disease. (These two disorders
of brain damage also occur in Lyme borreliosis.) Ms. Hoggan is accused of stuffing tissues in her
roommate‘s mouth and cotton balls in her nose, where they lived together in a nursing home. The
roommate‘s name was Eleanor Mazzarella. Mazzarella died in March 2005 from unrelated causes and was
74 at the time of her death. Ms. Hoggan has claimed she did not know what crime she committed and is
now in the York Women‘s prison where she is mistreated and is treated to more medical and nutritional
neglect, since the nutrition in the prison is grossly inadequate. The inmates in the mental health wing
cannot buy vitamins or coffee. Stimulants are known to be helpful for people with, dementia, cognitive
decline, and the associated depression.

None of the inmates at York get adequate exercise, since the only two exercise bikes in the prison are
broken and there is no other recreational equipment except balls, basketball hoops, and sometimes a
volleyball net. The guards are forever looking for a reason for the prisoners not to go to the gym or to the
library. Prisoners are not allowed to jog on the grass. Prisoners can only go to the library, once a week
and only approximately 5 out of 20 get to go, they are picked randomly, and some never get to go to the
library. Some of the ward TVs are broken, and some have no reading materials. Thus, there is no
intellectual stimulation whatsoever for a great many inmates. These combined conditions contribute to
dementia. In the prison there is no education about nutrition, no nutrition, no education about diet and
exercise, and no exercise, when clearly all these are needed to restore many of these women in the
prison.
Most of them are drug addicts and in poor health. A great majority of these prisoners go over to ―mental
health‖ to get some kind of drug to sleep their sentences away, but this increases the illegal-drug induced
dementia.

Thus, no prisoners will improve in any way, under ―corrections.‖ There is no incentive on the part of
corrections officers, for the prisoners to not be prisoners, because of all the overtime pay these guards
get. Therefore the cycle of abuse is perpetuated by the guards and their union. Prisoners return to
prison after having been arrested again for self-medicating too often. How prisons are managed does not
make any sense for dealing with human beings in any way, with the exception of mass murderers, who are
rare.

The most adverse treatment for older women in cognitive decline are central nervous system depressants
such as antipsychotics and this announcement was made in 2005 by the National Institute of Mental
Health. A trial of Seroquel for agitation in dementia was halted because it was observed that this
treatment accelerated the dementia. The monograph for risperidone states that this medication is




                                                                                                         41
associated with greater extrapyramidal effects (extrapyramidal brain damage) in older women,
especially.

It would appear to the casual observer that the liability in this Hoggan case was more the nursing home‘s,
rather than the incompetent patient‘s.


3) Leslie Andino a 23 year old woman with multiple sclerosis, dementia and depression - which sounds
very much misdiagnosed Lyme Neuroborreliosis - was arrested and charged with arson in a nursing home
fire that killed 16 other residents in Connecticut in May 2003. After several periods of ―treatment‖ to
restore competency for trial for a crime she never should have been charged with in the first place, she
returned to the courthouse in January 2005, ―heavily sedated,‖ to learn she would be committed to the
Whiting Psychiatric Prison.

Heavy sedation is malpractice for a neuropsychiatric disease, and likely contributed to her increasing
dementia. The American Psychiatric Associations Guidelines on the treatment of a delirium state that:
―Medications for psychiatric disorders can be both the cause of delirium and exacerbate or contribute to
delirium from other causes.‖

This Andino case should be investigated by a competent independent federal health official and expert,
which would obviously not be one from Connecticut.

It would appear to the casual observer that the liability was more the nursing home‘s, rather than the
incompetent patient‘s.



THE SCIENCE

Conditions associated with Multiple Sclerosis, according to the United States National Institute of Health
are:

                    “Symptoms   Return to top

         weakness of one or more extremities


         paralysis of one or more extremities


         tremor of one or more extremities


         muscle spasticity (uncontrollable spasm of muscle groups)


         muscle atrophy


         movement, dysfunctional - slowly progressive; beginning in the legs


         numbness or abnormal sensation in any area


         tingling


         facial pain


         extremity pain




                                                                                                         42
loss of vision -- usually affects one eye at a time


double vision


eye discomfort


uncontrollable rapid eye movements


eye symptoms worsen on movement of the eyes


decreased coordination


loss of balance


decreased ability to control small or intricate movements


walking/gait abnormalities


muscle spasms (especially in the legs)


dizziness


vertigo


urinary hesitancy, difficult to begin urinating


strong urge to urinate (urinary urgency)


frequent need to urinate (urinary frequency)


incontinence (leakage of urine, loss of control over urination)


decreased memory


decreased spontaneity


decreased judgment


loss of ability to think abstractly


loss of ability to generalize


depression


decreased attention span




                                                                  43
        slurred speech


        difficulty speaking or understanding speech


        fatigue, tired easily

              Additional symptoms that may be associated with this disease:


        constipation


        hearing loss


        positive Babinski's reflex

              Note: Symptoms may vary with each attack. They may last days to months, then reduce or
              disappear, then recur periodically. With each recurrence, the symptoms are different as
              new areas are affected. Fever can trigger or worsen attacks, as can hot baths, sun
              exposure, and stress.‖


Symptoms associated with Dementia, from NIH MedLine Plus include:

        ―Disorders that contribute to confusion should also be treated. These include heart failure,
        decreased oxygen (hypoxia ), thyroid disorders, anemia, nutritional disorders, infections, and
        psychiatric conditions such as depression. Correction of co-existing medical and psychiatric
        disorders often greatly improves mental functioning.‖

Symptoms associated with Neurologic Lyme disease, as listed by the National Institute of Neurological
Disorders and Stroke:

        ―Neurological complications most often occur in the second stage of Lyme disease, with
        numbness, pain, weakness, Bell's palsy (paralysis of the facial muscles), visual disturbances, and
        meningitis symptoms such as fever, stiff neck, and severe headache. Other problems, which may
        not appear until weeks, months, or years after a tick bite, include decreased concentration,
        irritability, memory and sleep disorders, and nerve damage in the arms and legs.‖


The hypoxic state of Lyme and multiple sclerosis is often assessed with brain SPECT scanning, and often
shows a deficit, and which is known to be associated with an organic delirium. According to Allen Steere:
        ―Lyme disease may affect the central nervous system causing organic brain disease or syndromes
        suggestive of demyelination.‖ PubMed ID 2742551


The same symptoms as those in neurologic Lyme disease occur in Multiple Sclerosis and Alzheimer‘s
disease. In fact, in a recent report:

        ―The cause, or causes, of the vast majority of Alzheimer's disease cases are unknown. A number
        of contributing factors have been postulated, including infection. It has long been known that
        the spirochete Treponema pallidum, which is the infective agent for syphilis, can in its late
        stages cause dementia, chronic inflammation, cortical atrophy and amyloid deposition.
        Spirochetes of unidentified types and strains have previously been observed in the blood, CSF
        and brain of 14 AD patients tested and absent in 13 controls. In three of these AD cases
        spirochetes were grown in a medium selective for Borrelia burgdorferi.‖ [Pubmed ID 15665404
        Miklossy, et al]




                                                                                                         44
The proper term for the entire scope of disease manifestations is ―Lyme borreliosis.‖ ―Lyme disease‖
refers to 72% of the late Lyme arthritis cases only, and only as compared to this Lyme arthritis case blood
to the high passage strain G39/40. ―Lyme Disease‖ is thus an imaginary entity as previously described.

The CDC and NIH expressed a request not to use high passage strains of borrelia and not to use strain
G39/40 to use for the determination of Lyme disease because it did not express enough of an antigen of
diagnostic value at the 1994, Dearborn Michigan, CDC meeting on serodiagnosis (blood tests) of Lyme, yet
this is the strain and conditions of the strain which now represents the CDC‘s IgG serodiagnostic standard.
CDC and the NIH have not responded adequately to Plaintiff‘s complaint that this is deliberate scientific
fraud. To the Plaintiff‘s knowledge, the FBI is still investigating this complaint.

Lyme borreliosis has been associated with the two haplotypes or genetic markers that occur in multiple
sclerosis, narcolepsy and lupus (HLA-DQB1*0602), but the public is not allowed to know this, because this
form of Lyme is also ―seronegative.‖ ―Seronegative‖ really means the testing for Lyme is fraudulent, and
this is discussed in greater detail in 3:05 CV 91 (CFD), as regards the racketeering-influenced and corrupt
organization‘s control of what we are told about ―Lyme disease.‖ The second haplotype discovery was
made by Mark Klempner of Boston University and that haplotype is HLA-DQB1*0602. The State of CT is in
possession of the July 2001 audio-taped Mark Klempner conference, during which this scientific data
about the susceptibility to chronic Neurologic Lyme/MS and a copy is the US Attorney‘s office in New
Haven, CT.

There are numerous and conflicting protocols for the treatment of Lyme borreliosis. The Centers for
Disease Control supports the fraudulent one developed by the RICO entities, the American Lyme Disease
Foundation and Yale University, even though the CDC knows this protocol is not supported in the
literature with the scientific facts. The elements of these crimes are described in greater detail
previously in 05-328 T, District of Rhode Island and in 3:05-CV-91 (CFD), District of Connecticut.

It is not known what other ―treatments‖ Ms. Andino were given by Connecticut Valley ―Hospital,‖ but
given the Plaintiff‘s experience with CT DMHAS, Plaintiff is seriously concerned about how DMHAS treats
any of their victims. DMHAS perjured themselves in the false criminal case against Plaintiff KM Dickson
does not have Lyme disease, and that Lyme is not a brain disease.


James Phillips, MD was given the scientific substantiation that Lyme is a neuropsychiatric disease.
Plaintiff KM Dickson‘s website ―The Lyme Disease Dilemma,‖ was given to James Phillips, MD, in full hard
copy in November 2000.

The Lyme Disease Dilemma website has not been touched (not been modified at all) since November
2000, and ActionLyme.50megs.com has not been touched (not been modified at all) since November 2001.
The URLs for these websites are:
http://www.geocities.com/kmdickson0308/lyme-dilemma.html      and
http://actionlyme.50megs.com/

A sampling of their content:
        ―NEWS-

         The new information that confirms the pathophysiology of MS and Lyme has not been published,
         yet this data was collected during the 1997-2000 NIH Chronic Lyme Disease treatment trial by
         Tufts: The high incidence of the presence of HLA-DQB1*0602 on Chronic Lyme patients. To
         quote Dr. Klemper:

         "It turns out that if you look at the first 51 patients with post- treatment chronic Lyme
         disease, the patient population that participated in our study, there was a very high
         incidence of DQB0602 with an odds ratio of 770%. So it may well be that exposure to THAT
         organism with THAT background of HLA haplotype may lead you to develop chronic
         symptoms. That is a hypothesis that needs to be tested. It would obviously lead to an
         entirely new form and approach to therapy."

         The non-reporting of objective data over the reporting of subjective, invalid data (the
         assessment tools FIQ and SF-36), calls into question integrity in reporting scientific data, and the




                                                                                                          45
         validity of further and previous conclusions from such analysts. The FIQ was never validated for
         Lyme disease. The SF-36 is not to be used in cases of cognitive impairment.


The record of this presentation by Mark Klempner is EXHIBIT OO. The rebuttal to Klempner‘s ―study‖ on
the treatment of chronic Lyme disease is Exhibit PP, and can be found online at
http://www.ilads.org/files/position2.pdf
Plaintiff Dickson was the original author of this rebuttal, but at that earlier time, looked more like a
point-by-point rebuttal to the validity of 1) Klempner‘s inclusion and exclusion criteria; the validity of the
CDC‘s blood testing standard for Lyme disease, 2) a refutation that the FIQ had been validated (the
validation showed a difference between Lyme and Fibromyalgia, so by definition, the FIQ was not valid to
assess Lyme patients), 3) Mark Klempner most certainly is aware of the various markers of disease such as
matrix-metalloproteinases (MMP) in the spinal fluid of Lyme borreliosis patients, and should have been
looking for these and other known objective markers of disease since Klempner discovered and reported
this MMPs analysis in Neuroborreliosis patients, 4) Mark Klempner published that intracellularity of the
Lyme spirochete and the availability of host cells in other ways provided protection for the Lyme
spirochetes from being killed by ceftriaxone, 5) Mark Klempner discovered the reason people who are the
most ill with Lyme disease are seronegative: They don‘t have the hypersensitivity reaction of people who
have the genetic predisposition to Lyme arthritis (hypersensitivity or allergy reaction) discovered by Allen
Steere (and was the basis of the class action lawsuits against SmithKline, and about which Attorney Steve
Sheller had to say of the CDC: ―The CDC is a disgrace. It is a corrupt organization. The drug companies
have them on their payroll.‖), because they tend to have these immune-incompetent haplotypes
associated with persistent central nervous system infections, and 6) Mark Klempner refused to tell the
Plaintiff KM Dickson which primers he used to determine that among his 2000 patients, none had a
positive Borrelia burgdorferi positive DNA analysis of their spinal fluid. 7) Lyme neuroborreliosis is usually
an aseptic meningitis, so looking for increased cells, which was what Mark Klempner did, in the spinal
fluid of these patients was a waste of taxpayers‘ money. 8) Some of the known and published markers of
disease process (the reason there are clinical signs of illness) are described in the RI Tick Borne Diseases
Management Plan, entered as Exhibit Q in the original complaint dated July 27, 2005. Therefore
Klempner‘s ―Breaking News‖ published early from the New England Journal of Medicine June 12, 2001,
was utterly insulting silliness.

The full transcript of Klempner‘s 2001 South County RI ―Diseases of Summer‖ conference is Exhibit QQ.
The secret MS-haplotype data is on page 7. Klempner later goes on to describe patients‘ illness
complaints, which were relapsing and remitting (like relapsing fever borreliosis and like relapsing
remitting MS), as possibly due to placebo effect.
          “So, in part, this validates exactly what patients have been saying right along. And that is,
          “Some of us get better when we take antibiotics.” It’s absolutely true. Uh, it’s also true the
          same number of patients get better when they take placebo.”

What Mark Klempner should have said was that unless we know what people are infected with by using
the correct primers, and unless we know who has a susceptibility to chronic central nervous system
infections, and unless we are allowed to know what are the valid, objective, markers of disease, victims
of these infections and the related medical crime of Lyme borreliosis can continue to be abused, denied
treatment, and labeled hypochondriacs. The same system of abuse applies to people who have Chronic
Fatigue Syndrome and Fibromyalgia: use invalid medical tools to assess and use invalid psychiatric terms
and invalid questionnaires rather than take real biological samples and determine if there are objective,
scientific signs and EVIDENCE that something is really wrong.

Klempner‘s fraudulent study of the treatment of chronic Lyme is sometimes referred to as Evidence-Based
Medicine. Hopefully the public will now have a better idea of what ―Evidence-Based Medicine‖ means
and not become victims of it.

One can artfully and deliberately not find the targeted DNA in borreliosis if one is targeting plasmid and
not chromosomal DNA, and which is done routinely when anyone uses an OspA or other plasmid primer.
Anyone who pays for a DNA test for Lyme should not pay for the test unless the DNA targeted is from the
chromosome, preferably the flagellin DNA.

THE NON-SCIENCE




                                                                                                           46
James Phillips is an associate clinical professor of psychiatry for Yale University and is a forensic
psychiatrist for the State of Connecticut, yet perjured himself as regards Lyme and the Plaintiff KM
Dickson in order to avoid a malpractice lawsuit. Subsequent to that, the DMHAS ―Medical Director,‖
Kenneth Marcus, testified at Plaintiff Dickson‘s DCF ―trial‖ and co-perjured himself saying you treat Lyme
delirium the same way you treat any other psychosis.

The American Psychiatric Association‘s Guidelines state that:

         “Medications for psychiatric disorders can be both the cause of delirium and exacerbate or
         contribute to delirium from other causes.”


This was an extremely detrimental act of deliberate harm against not only CT Lyme victims, child and
adult, but all victims of Lyme borreliosis, as well as Multiple Sclerosis, and all organic delirium patients
around the world, since the American Psychiatric Association‘s guideline say otherwise, as do the
monographs for these ―drugs.‖ However the 1) value of Phillips‘ and Marcus‘s testimony, and 2) the
psychiatrist Patricia Leebens having defrauded the court over the Plaintiff‘s 11-16-03 databinders, and 3)
then having left the country so that she could not be cross-examined in Plaintiff‘s DCF case, regarding the
temporary which became permanent order of custody, through again, total perjury, and 4) for the CT
Department of Mental Health and Addiction services‘ Vladimir Coric and Betsy Byron to have perjured
themselves with abandon is an extremely important lesson to all Americans regarding what they are
potentially dealing with, when they are dealing with psychiatrists. Psychiatrists blame the patient for the
damage that they cause and psychiatric diagnoses are every bit as harmful as the older terminology which
they replaced: Psychiatric terminology can define for the world that anyone is a ―bad‖ person, not only
with no evidence, but made-up (psychotic, scientifically invalid) terminology (neologisms) and with the
intent to harm.

Psychiatrists try very hard for the public to not be made aware that psychiatry is not a medical or
scientific practice, but all one has to do is consider what they do with their time. Psychiatrists are not in
laboratories. The pharmaceutical chemists are in the laboratories, the pharmaceutical sales people tell
the psychiatrists what they found, and whoever objects is called ―crazy‖ or is threatened- a convenient
little arrangement. This is almost as convenient as calling people who have a permanent brain infection
like Lyme borreliosis, ―crazy,‖ and not sick.

The pathophysiological markers of disease in Lyme borreliosis were given to the State of CT on numerous
occasions, as well as was the Management Plan for the State of Rhode Island Tick Borne Diseases
Commission in a hearing held in Rhode Island in April 2002 [EXHIBIT Q]


The published scientific documentation of the various Pathophysiologies of Psychotopics-Induced Brain
Damage were also given to the State of CT on numerous occasions, most particularly on November 20,
2003, when they were given to Laura Lustig of the New Learning Center, Westport, in person, by Plaintiff
KM Dickson, in a 1-1/2 inch databinder, along with the 11-16-03 databinders. The 11-16-03 and 11-20-03
databinders are in evidence in 3:05-CV-91 (CFD). The State of CT is in possession of them (DCF and
Patricia Leebens), and Yale, a defendant in 3:05- CV-91 (CFD), has them, since Patricia Leebens works
also for Yale in the Yale Child Study Center and she mentioned them in the Order of Custody, November
26, 2003.

Plaintiff‘s children were kidnapped 6 days later by the CT Department of Children and Families, who
defrauded the court over these, the Plaintiff Dickson‘s substantiated replies (the content of 11-16-03
databinders) to complaints to the CT Commission on Human Rights and Opportunities and Statewide Bar
Counsel (CT attorney ethics/grievance committee) Gerald P. Dwyer, Esq. and 5 others. On November 20,
2003, both databinders were hand-delivered by the Plaintiff Dickson to Laura Lustig. Lustig‘s second
ranking administrator in her private organization, ―The New Learning Center,‖ Westport, CT, was a
former DCF commissioner named Mark Marcus. It is not known if Mr. Marcus violated the State‘s revolving
door policy, since Laura Lustig also had a contract to train DCF ―workers.‖

These 11-16-03 3 inch thick databinders contained data regarding Lyme disease and the Plaintiff‘s
attempts to get assistance from the State, and communicate with the State of Connecticut, as regards
Plaintiff Dickson‘s and her children‘s Lyme disease, and as regards which the CT DCF then again perjured




                                                                                                          47
themselves. Plaintiff Dickson first asked for DCF‘s assistance, because she was mistakenly thinking the
DCF was a child welfare agency, in 1996. DCF denied helping then, and then DCF denied that they denied
helping the Plaintiff KM Dickson. Plaintiff now knows no one wants DCF‘s ―help,‖ because the vast
majority of the DCF staff are criminally insane. The majority of DCF employees fully meet the criteria of
sociopaths, as previously demonstrated in the Amended complaint dated August 3, 2005, and who
constantly violate CT state and federal law, as described in the original complaint Docket Number 5-328
T, US Court, District of Rhode Island.

THE NOVEMBER 20, 2003 DATABINDERS
The content of the following reports, contained in the 11-20-03 databinders, is extremely significant, and
presents numerous domains of liability to the State of CT DCF and DMHAS. Among those scientific reports
are:

         1) 1989 Infectious Disease Reviews, Supplement, Lyme Disease and Other Spirochetal Diseases,
         Various Titles.

 The content of that Infectious Diseases Society Supplement essentially states that Lyme is a borreliosis,
 and the treatment endpoint is still not known. This is because Lyme is a borreliosis, which is a relapsing
 fever organism, and borrelia permanently infect the brain. Explained another way, by Alan Barbour, the
 owner of the ImmuLyme vaccine patent:

         “Lyme disease and relapsing fever. These tick-borne infections are notable for multiphasic
         antigenic variation through DNA recombinations in the case of relapsing fever, the
         occurrence of chronic arthritis in the case of Lyme disease, and invasion of and persistence
         in the brain in the case of both diseases. – from Alan Barbour‘s website.




         2) Genetic animal models: focus on schizophrenia, Gainetdinov, RR., et al. TRENDS in
         Neuroscience, Vol 24., No. 9, September, 2001.

At this point in history, these psychiatrists have no idea what the drugs targets are and are leaning
towards considering the scientifically valid in their future approach.

         3) "Loss of striatal cholinergic neurons as a basis for tardive and L-dopa-induced dyskinesias,
         neuroleptic-induced supersensitivity psychosis and refractory schizophrenia."
         Miller R, Chouinard G., Biol Psychiatry. 1993 Nov 15;34(10):713-38.

         Abstract: In the first section of this paper several aspects of tardive dyskinesia (TD) (clinical,
         epidemiological, pharmacological) are reviewed. We propose that this syndrome is not the
         consequence of dopamine receptor proliferation, but results from damage or degeneration of
         striatal cholinergic interneurons. We suggest that this cellular damage is caused by prolonged
         overactivation of these neurons, which occurs when they are released from dopaminergic
         inhibition following neuroleptic administration.

Brain cells die and are damaged by these psychotropics.

         4) Psychiatric research in the 21st Century; Opportunities and Limitations, GR, Heninger,
         Millenium Article, Molecular Psychiatry (1999) 4, 429-436

The above is a report which points out that psychiatric ―research‖ will be based in Neurology, psychiatry
may start becoming scientific, with the intent NOT to cause brain damage, and they mention
neurotrophins several times. Neurotrophins are associated with nerve protection and nerve growth,
unlike the entire spectrum of psychotropics on the market today, with the exception of Lithium, which is
not a drug, but is neuroprotective.




                                                                                                           48
Lithium only costs approximately 15 US dollars per month, and which is why it is not prescribed very
often. It can‘t be patented, it is not a drug, it is extremely inexpensive, it is also neuroprotective and
treats many so-called psychiatric disorders - probably because it is neuroprotective, and protects brain
cells from demise from many mechanisms, including infection and stroke.

         5) "Akathisia and Exacerbation of Psychopathology; A Preliminary Report", Dunca, et al. Clinical
         Neuropharmacology, Vol 23, No. 3, pp. 169-173 Department of Psychiatry, New York University
         School of Medicine, New York, USA.

         6) ‖Akathisia has previously been reported to exacerbate psychopathology and to be associated
         with noncompliance, suicidality, and violence. ―

This means drug-induced brain damaged makes people more deranged, agitated and violent, in addition
to more physically miserable as a result of psychotropics-induced brain damage, as do the next two listed
here:

         7) "Subjective Emotional Experience and Cognitive Impairment in Drug-Induced Akathisia", Jong-
         Hoon Kim, et al, Comprehensive Psychiatry, Vol.43, No. 6 (November/DEcember), 2002: pp 456-
         462

         8) "Correlations Between Akathisia and Residual Psychopathology: A By-product of Neuroleptic-
         Induced Dysphoria", Newcomer, et al. Br J Psychiatry. 1994 Jun;164(6):834-8.




Among the other data submitted to Laura Lustig November 20, 2003 was the following abstract and full
text article:

         9) Neuroleptic-induced akathisia and violence: a review. Center for Forensic Services, Western
         State Hospital, Tacoma, WA 98498-7213, USA. leonggb@dshs.wa.gov

         ‖Surprisingly, the association of neuroleptic-induced akathisia and aggressive behavior was
         not formally recognized until nearly two and one-half decades of antipsychotic prescribing
         had passed. Using a search of the anglophonic literature, this phenomenon is reviewed.
         Advances in psychopharmacology have reduced neuroleptic-induced akathisia and hold
         promise to eliminate it altogether. Nonetheless, important clinical and forensic aspects of
         neuroleptic-induced akathisia and aggression remain and are explored.”

         PMID: 12570226 [PubMed - indexed for MEDLINE]

In the body of the report is the following statement:

         “Although there is an optimistic picture for the possible extinction of NIA associated
         violence, we do not anticipate that this will happen in the next few years. As such, there
         remains the spector of neuroleptic-associated aggression as a relevant factor when
         considering a criminal defendant’s mental state at the time of an alleged crime.”




Pfizer has published the following article on how to treat antidepressants-induced akathisia (agitation),
which they simultaneously deny exists:

         10) SSRI-induced extrapyramidal side-effects and akathisia: implications for treatment.
         Pfizer Inc., New York, NY 10017, USA. laner@pfizer.com

         The selective serotonin reuptake inhibitors (SSRIs) may occasionally induce extrapyramidal




                                                                                                             49
          side-effects (EPS) and/or akathisia.This may be a consequence of serotonergically-mediated
          inhibition of the dopaminergic system. Manifestations of these effects in patients may
          depend on predisposing factors such as the presence of psychomotor disturbance, a previous
          history of drug-induced akathisia and/or EPS, concurrent antidopaminergic and/or
          serotonergic therapy, recent monoamine oxidase inhibitor discontinuation, comorbid
          Parkinson's disease and possibly deficient cytochrome P450 (CYP) isoenzyme status. There is
          increasing awareness that there may be a distinct form of melancholic or endogenous
          depression with neurobiological underpinnings similar to those of disorders of the basal
          ganglia such as Parkinson's disease. Thus, it is not surprising that some individuals with
          depressive disorders appear to be susceptible to developing drug-induced EPS and/or
          akathisia. In addition, the propensity for the SSRIs to induce these effects in individual
          patients may vary within the drug class depending, for example, on their selectivity for
          serotonin relative to other monoamines, affinity for the 5-HT2C receptor, pharmacokinetic
          drug interaction potential with concomitantly administered neuroleptics and potential for
          accumulation due to a long half-life. The relative risk of EPS and akathisia associated with
          SSRIs have yet to be clearly established. The potential risks may be reduced by avoiding
          rapid and unnecessary dose titration. Furthermore, early recognition and appropriate
          management of EPS and/or akathisia is required to prevent the impact of these effects on
          patient compliance and subjective well-being. It is important that the rare occurrence of EPS
          in patients receiving SSRIs does not preclude their use in Parkinson's disease where their
          potentially significant role requires more systematic evaluation.
          PMID: 9694033 [PubMed - indexed for MEDLINE]




STATUS

The State of Connecticut has long been in possession of this data and this science, which shows that
nearly all, if not all, psychotropics are brain damaging. This data was also on Plaintiff Dickson‘s website
www.ACTIONLYME.com , from the summer of 2003 until December 23, 2004, when the former John
Rowland pleaded guilty to his crimes related to an alleged prison-building enterprise. The alleged
criminal enterprise, which was allowed to operate from John Rowland‘s office, involved DCF‘s former
commissioner Kristine Ragaglia, and which involved the CT prison children, CJTS, which will close and not
be used as a prison at all.

The State of Connecticut is therefore liable for any violent deaths or violence associated with any
medications they have prescribed for their victims, especially children, and especially children who have
killed themselves in DCF‘s ―care,‖ if the DCF has insisted they take these brain-damaging psychotropics,
when they knew better, and have known of these factual scientific details since 11-20-03.

The State of CT in no way is competent to brain matters, matters of trauma, matters of children, matters
of health, matters of epidemics, and matters of basic human civil rights, despite being given the evidence
by the Plaintiff Dickson, and despite laws regulating the behavior of all citizens, not exclusively persons
who are not employed by the State or federal government.

The First Amendment:

   "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or
 abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the
                                      government for a redress of grievances."

When the plaintiff Dickson tried to redress grievances and express free speech, and under no violation of law, was
falsely charged with harassing communications and threatening and was not allowed access to the courts. This is an
abuse of power, as is the case of John M. and his family. John M. is entitled to no assistance in defense, according to
the State of Connecticut; his family is not allowed to know the specific details of his charges; he has been long-declared
incompetent; no evidence of a competency evaluation having been performed has been granted to his family
subsequent to his arrest; and the DMR stated that John M. refused involvement of the DMR, yet the family refutes that
claim.




                                                                                                                      50
The State of CT is incompetent to all brain matters, as demonstrated above and in a previous motion dated Aug 3, 2005,
and in the original complaint under this docket number, and therefore can pass no criminal judgment on this person,
John M., who has been effectively declared a non-person.

Plaintiff KM Dickson should not have to be filing a complaint in the federal district of Rhode Island about the
incompetence of the entire State of CT on all brain matters: Autism, Lyme borreliosis, mental retardation, well-known
neuropsychiatric diseases such as Alzheimers’s, Multiple Sclerosis, Lupus, and should not have to explain to CT what
is in the drug monographs for such common psychotropics as risperidone, since it would be inherent in the
commissions of the various departments of the State to act in the best interests of the State, and the State is its residents.

John M. has been declared competent but was formerly “developmentally” incompetent, has been incarcerated 6
months on a class 4 misdemeanor, is considered a ward of the State, but is in a jail instead of a group home or some
other housing which should be provided by the State for all persons who are mentally incompetent or meet the criteria
of a non-recoverable neuropsychiatric disease. Ms. Hoggan and Ms. Andino should not be in prisons. Plaintiff has
heard from others and read in the newspapers that prisons are being used to warehouse the mentally ill, but also clearly
now, prisons are being used to warehouse chronically ill people and people with mental retardation.

There is no entity in the State to qualify any person’s mental status as demonstrated in all of the above examples. The
State of Connecticut, rather than accept the liability of the science that demonstrates that all psychotropics are brain
damaging, kidnapped Plaintiff Dickson’s children, and falsely criminally charged plaintiff Dickson with the insanity
invented for her at her DCF “trial,” and which is a product of AAG Jessica Gauvin’s pathological imagination and is
the perjury of James Phillips, Kenneth Marcus, and others.

ABUSE AND NEGLECT AS POLICY- THE 10-FOLD INCREASES

These are gross, across the board, abuses and misuse of all state agencies and departments to effect an
end to civil rights in Connecticut, because there is little no other real work, and there is no money in the
State budget to provide for people who really need it, while the DCF‘s budget increased 266%. Thus, the
unions of State employees acted to form the government in their own interest, rather than the people the
State employees serve. The State prosecutor‘s office and the DCF spend all of their time conspiring to
put people away who are a nuisance and ruining their lives, regardless of whether their victims can help
being a nuisance or not. This policy formally started in 1995, as soon as Governor John Rowland took
office as can be seen in the announcement which is executive Order Number Two:

WHEREAS, the taxpayers of Connecticut deserve a state welfare system that is sound and secure from fraud
and abuse; and

   WHEREAS, the beneficiaries of our state welfare system deserve a method of assistance that can truly help
lift them out of poverty, not keep them there; and

  WHEREAS, State Superior Court Judge Arthur L. Spada conducted a State Grand Jury investigation that
uncovered wide-spread welfare fraud and abuse facilitating an insidious link between our current welfare
system and the illicit drug trade; and

   WHEREAS, Judge Spada's report contained findings and recommendations that must be given serious
attention if the current abuse of our welfare system is to end.

This “policy” resulted in nearly 10 times the number of inmates in the York women’s prison since 1994, according to a
reliable source inside the prison, who is also a Republican. DCF’s budget grew, as previously mentioned in the original
complaint, from $227.6 million in 1994 to $606.1 million in 2004. This a 266% increase and not a 165% increase:

                        1. Growth in DCF’s Budget Has Far Exceeded Growth in DCF’s caseload

          In the last decade, the number of children served by DCF increased from 7,500 children at
          the end of FY 94 to 12,247 children at the end of FY 04 (a 63% increase). DCF’s General
          Fund budget grew faster- from $227.6 million in FY 94 to 606.1 million in FY 04 (a 165%
          increase), With DCF’s revised SFY 05 General Fund budget at $642.6 million, there has been




                                                                                                                          51
         a 182% nominal increase since FY 94. While some of this growth is attributed to the more
         complex clinical needs of children now in care and to long overdue investments to improve
         the quality of care of these children, much growth is also due to skewed spending policies
         that skimp funding for services that could reduce child welfare involvement while, at the
         same time, increasing spending for “back end” placements and services.”




There was also a 445% increase in children taken from their parents during this time period, while, as Rowland
claimed, there was a 45% reduction of “abuse.” A 10 fold increase in families wrecked, and a 10 fold increase in
incarcerated women, seems to be the result of this Arthur Spada policy of racism and criminalizing poverty. This
appears to be the same thinking as former Massachusetts Governor William Weld. Cut welfare. Weld wanted to
“reintroduce prisoners to the joys of busting rocks.”

Reported in the August 20th, 2005 edition of the New York Daily News, Weld is : A fiscal conservative who cut taxes
and curbed welfare in Massachusetts….” This sounds scarily like John Rowland’s policies, which did not result in the
reduction in the size of the government, but merely was a platform for the friends of these Republicans to establish a
federal funding feeding trough, at the expense of human lives. This can’t have been the intention of the US
Constitution, Declaration of Independence, and Bill of Rights, and so it is laughable that the United States would want
to violently bring this sort of “freedom” to other countries, especially when the United States is bankrupt and their
allegedly human rights abusing opponents are sitting on the second largest world oil reserves.

On a more local level, most of the cases mentioned in this entire combined complaint give the
appearance that the liabilities lie elsewhere, yet the sick, innocent or incompetent victim was blamed.
Just as it is well-known that the DCF can be used as a weapon, and that the DCF staff are extremely
ignorant, so too, does it appear that the liabilities for the nursing home crimes, and the non-crimes of the
retarded were shifted by people who knew how to abuse the ignorance of the police. The prosecutors
are only after simple cases they can win and have no incentive to tangle with people who have the money
to present the challenge of a difficult trial, as would be the case with the nursing home owners.

In the case of the mentally retarded, who all will eventually be wards of the State, the State obviously
has a policy of the cheapest solution. They simply declared a clearly incompetent man to be competent
so that he could be prosecuted as a criminal (John M.).

Steven Erickson and Christopher Kennedy and other like them who suggested a way to effect fairness is to
have citizen oversight of the police, were clearly persecuted. Both are very intelligent men. Not so the
police, from Plaintiff Dickson‘s local police experience. Naturally such people, such as the police, feel
threatened by people who are more educated than they are, especially if the police and DCF staff are
involved in drug-related crime, and other crime, which clearly some are. John Rowland also helped
himself to State goodies, but blamed his son. What Rowland did was not considered burglary, but if he
was black and not the governor, it most certainly would have been considered burglary. This appears to
be true also of the present governor‘s son, if the report in Corporate Crime Reporter was true about the
stolen skidoos.

In the case of people who have Lyme disease, it was much more convenient to prosecute the Plaintiff,
and destroy her family, than for the truly guilty, in this case, Nancy Martin, Carolyn Martin, Donald
Dickson, the State of Connecticut, the DCF, Yale University and James Phillips, to be prosecuted.
Plaintiff Dickson represented a threat to DCF, DMHAS, Yale, the State Health Department, and the
criminal justice system simply for revealing that evidence is evidence and that hearsay is hearsay. This
would clearly upset the entire State and federal justice system and put a lot of mental health ―experts‖
out of business, not to mention the effect on the pharmaceutical industry.

THE REALITY OF FORENSIC PSYCHIATRY
Psychiatric ―expertise‖ is in no way evidence or expertise. Psychotropics contribute to violence and
dementia, mitigating every single case where a person who had been taking psychotropics committed a
violent or demented act. Forensic science actually points to the prescriber of these drugs, and the
reality of what is ―forensic psychiatry,‖ is completely different from what everyone thinks.




                                                                                                                    52
Such a revelation, psychiatry fights very hard to suppress. They also would like the world not to know
that psychiatry is not a medical practice, except in cases where psychiatrists try every available method
to discover if there is actually something medically, or mechanically wrong with a person‘s brain. They
rarely do. Forensic Psychiatrists even more rarely do so before offering a paid opinion. We should never
expect to see a Forensic Psychiatrist testify that in a child who commits a violent act, but who also had
been taking psychotropics, was at least doubly mitigated. This is from the members of the ―helping‖
profession.

James Phillips had said to Plaintiff Dickson in December 2002, after trying 10 different drugs, some of
which increased agitation and made Plaintiff Dickson‘s neurological disease worse, ―I think you need to be
on medication, I just don‘t know what kind.‖ Plaintiff Dickson had first asked for ProVigil for alertness
before the subsequent 10 or 11 drug experiment, none of which were ProVigil. This is obvious medical
malpractice since Lyme borreliosis results in a delirium and Plaintiff Dickson has this objectively
documented delirium as demonstrated in the reduced blood flow to the brain as shown in a brain SPECT
scan.

In the case of John M., we would all like to know who determined John M. was competent because that
person should be behind bars.

Therefore, there are a lot of innocent people in prisons, since blaming the victim and selectively
prosecuting ―crime‖ is an yet another unique Connecticut epidemic. The founders of this country thought
we should have God-given human rights-based laws, and constitution, and bill of rights intended to
prevent the abuses of an autocracy.

Exhibits RR and SS, now entered as evidence in this complaint are these November 16 and November 20,
2003 databinders, respectively. Mr. Blumenthal has access to the Nov 16 and Nov 20, 2003 databinders.
Mr. Blumenthal was sent the 11-16-03 databinder. The 11-16-03 databinders were mentioned in the
―Temporary Order of Custody‖ (TOC) written by Yale‘s and DCF‘s Patricia Leebens, but were not
described to the court as what they were, and proving that she defrauded the court in her ―TOC.‖ Both
databinders were left with Laura Lustig on Nov 20, 2003. Lustig had a contract to train DCF social
workers. Mr Blumenthal also has access to the audiotape of Mark Klempner‘s July 2001 RI Conference
since the Plaintiff mailed it to his staff (AAG Thomas Ryan) approximately two years go (Exhibit OO).

Jeanne Milstein, the Child Advocate was mailed the November 20, 2003 databinders on May 6, 2004.




                                                                                                        53
CERTIFICATION


This document and the evidence was sent by certified mail on August 22, 2005 to:

Connecticut Attorney General Richard Blumenthal
55 Elm Street
Hartford, CT 063106


It is certified that the Defendant does not need another
copy of this evidence: RR, SS and OO.




           _______________________________
                                                                                   Plaintiff‘s
Kathleen M. Dickson, et al
                                                                                   23 Garden
Street
                                                                                   Pawcatuck, CT
06379




                                                                                                 54
              AMICUS CURIAE AFFIDAVIT filed by the on behalf of John M. by Kathleen M. Dickson, et al

              ------------------------------------------------------------------------------------------------

                                          State of Connecticut Vs John M.

                                  DOCKET _______________________________


                                               Norwich Superior Court
                                                 Courthouse Square
                                                 Norwich, CT 06360

                                                   August 22, 2005

AMICUS CURIAE BRIEF ON BEHALF OF CONNECTICUT VICTIMS OF FEDERAL CIVIL RIGHTS VIOLATIONS BY THE
                  STATE OF CONNECTICUT AND IN SUPPORT OF A MOTION TO DISMISS

    I, Kathleen Dickson, do HEARBY SWEAR that the following statements are truthful, sworn testimony,
    written as any reasonable person would understand, before God, as stated, and regarding the known
    incompetence, perjury, acts of defrauding the both the courts and The United States of America, the
    criminal behavior of the Department of Criminal Justice and the CT Department of Children and
    Families (DCF) and related staff, and are in support of dismissal of charges against John M.

    I have permission from the family to be in possession of the records of John M., which are to be
    submitted as evidence with this complaint. Inasmuch as John M. is incompetent and mentally
    retarded, I have treated his case and his name as though he were a juvenile and respected his
    privacy, referring to him as John M.


In the cause of a class action for numerous federal civil rights violations, including Title 18, secs 241, 242,
and 245, Conspiracy to Deprive of Rights, Color of Law abuses, Deprivation of Rights, Deprivation of Rights
to federally protected activities, persecution of persons seeking redress, disregard for the Americans with
Disabilities Act, acts of perjury, false arrests, State employees deliberately defrauding the courts,
conspiring to commit perjury with State‘s ―experts,‖ deliberate medical malpractice, acts in violations of
the first and fifth amendments, against citizens of Connecticut, I, Kathleen Dickson, representing
numerous cases of civil rights violations, abuse and neglect of CT citizens, have filed a complaint, docket
number 5-328 T (Hon. Torres), in the District of Rhode Island.


In the deepest respect for human dignity as a human rights and health rights activist, I plead and request
of the Superior Court in Norwich CT that the charges against John M be dropped. John M. is a man with a
clear lifelong history of mental retardation, and who has been incarcerated 6 months. John M. was
declared Mildly mentally retarded by the State of Connecticut in 1998, and the statement regarding his
disability states that he was developmentally impaired.




In an amended complaint to the federal court in Rhode Island dated August 22, 2005, and included as
evidence along with the exhibits in support of dismissal of charges against John M. and in excerpt of that
claim are the following:




         CASE EXAMPLES:

         1) John M. is a young adult with mental retardation, yet he has been housed in a CT prison since
         February 2005 for 2 counts of sexual assault 4th degree and risk of injury to a minor.. His family
         has been denied the right to see the warrant and specific charges against him, because they




                                                                                                                 55
involve a minor boy. John M. has been determined competent to stand trial, although his family
states that he was given a competency evaluation, which the family has not seen, and their
request to see it has not been granted by the State. The family was only told verbally that John
M. is competent to stand trial. John M. has been kept in prison these last 6 months.

The family states John M. was raped in prison, and that it took almost a month for the prison
doctor to investigate. John M. was raped in one prison, and was examined in another.
Naturally, the guards denied it happened.
A letter written by Annette Rose, DMR Case Manager, which is EXHIBIT KK, dated October 22.
2004, states:
   To Whom It May Concern:
   Please be advised that John M., date of birth 11-07-80, was determined eligible for
Department of Mental Retardation Services by H. Steven Zuckerman, PhD., Supervising
Psychologist 2. According to Elibigibilty Determination document signed by Mr. Zuckerman
and dated 08-14-98, John M. “falls withing the Mild range of Mental Retardation.” This
document can be found in Mr. M.’s Department of Mental Retardation case record.

In the letter on behalf of John M. was written by Brian O‘Rourke and Ellen Gilman of the Office
of protection and Advocacy for Persons with Disabilities, Hartford, CT, [EXHIBIT 5-328T LL],
they state:

“Mr. M’s habilitation cannot be addressed in a correctional facility. His cognitive limitations
combined with a history of behavior adjustment difficulties increases the serious risk prison
incarceration posess to his personal safety and psychological well-being. As you are aware,
prisons can be especially dangerous environments for individuals being held on (or convicted
of) charges of the nature he is facing.

Mr. M.’s past psychological reports cite significant language processing deficits. His language
processing becomes further compromised when John becomes anxious. This factor does
interfere with his ability to cope with his current situation. Mr. M’s mild retardation, in
addition to these deficits places him at a serious disadvantage as he attempts to work with
his attorney in defense of these charges. When we met with Mr. M., we found that he had a
great deal of difficulty participating in a simple conversation about his present
circumstances.

Mr. M’s history shows that he needs significant support to reinforce his awareness and
acquisition of appropriate social skills. The Department of Mental Retardation should have
reevaluated Mr. M’s service and support needs over a year ago, when allegations of criminal
conduct were first made. The development and implementation of an individualized service
plan needed to occur at that time.

As a resolution to this Programmatic Aministrative Review request, we ask that the DMR
immediately identify an emergency (short term), community based residential placement for
Mr. M., and that Mr. M.’s attorney, Mr. John Coccio be informed of this option. Once in
placement, we request that the DMR complete any relevant assessments and develop a well-
designed community-based support propgram to meet Mr. M’s long term needs.”

This letter was written April 11, 2005, and is a comprehensive and adequate attempt to have a
rational grasp of the needs and the urgency that Mr. M‘s be treated as a person with mental
retardation. Again, they state:

Mr. M‘s mild retardation, in addition to these deficits places him at a serious disadvantage as he
attempts to work with his attorney in defense of these charges. When we met with Mr. M., we
found that he had a great deal of difficulty participating in a simple conversation about his
present circumstances.

This would appear to resoundingly dispute any legal competency of Mr. M. that the State‘s
attorney‘s office has arbitrarily - and without producing the documentation of - asserts exists.
Further follow up with the Department of Mental Retardation suggests strongly that there is no
alternative housing for John M., yet the State also claims to have 16,000 residents in CT with




                                                                                                56
mental retardation and that 1% of the population has mental retardation (IQ of 70 or below).
The website of the DMR states that:

“Unlike other agencies, its supports and services (with the exception of Birth to Three), are
not an entitlement for people with mental retardation and the majority of its services are
provided by private non-profit organizations in local communities.


This gives the appearance that like the DCF, the DMR provides no real services, other than the
pay checks of the employees. There is no housing available for these people, when one would
think such would be a priority, since one thing there is no denying exists is mental retardation.
Autistic people belong to this department.


Autism is an epidemic, yet instead of planning for this epidemic or Lyme disease, and seeking
appropriate federal funding, the State planned for an increase in prison cells, as previously
mentioned.

In an email to Ms. Ellen Gilmartin, Gino DeMaio, Forensic Coordinator, State of CT Department of
Mental Retardation, states that ―John has asked DMR to not attend these hearings and has not
wanted his case manager to be involved.‖ [EXHIBIT MM]

The family who had been the guardians of John M. state that no such conversation took place.
They state that John cannot even make change, and once bought a pack of gum from a child for
5 dollars, not knowing that a pack of gum costs nowhere near 5 dollars.


H. Steven Zuckerman, PhD. Of DMR on September 14, 1998, [EXHIBIT NN] states that as regards
John M.,

 “Based on the information presented to me, this individual does meet the definition of
mental retardation as defined in CGS Section 1-1g, and is therefore eligible for Department
of Mental Retardation services. This individual falls within the Mild Range of Mental
Retardation.”

Listed as requirements for this condition are under Connecticut General Statutes 1-1G.

“For the purposes of sections 4a-60,. 17a-274, 17a-281, 38a-816, 45a-668, 45a-684
inclusive, and sections 46a-51, mental retardation means a significantly subaverage general
level of functioning existing concurrently with deficits in adaptive behavior and manifested
during the development period.”


The family of John M. state that the incident for which he is in jail took allegedly took place on
November 1, 2003, yet it wasn‘t until the summer of 2004, when John M. and his cousin tried to
attain a minor position either in the local fire department, or be volunteers or trainees, did
anyone take any legal action. John M. went to jail in February 2005 and has been there since,
without his family being allowed to know exactly what he is being charged with, who performed
the competency evaluation, or any of the important details of the case. The family states that
they don‘t even know how the case was transferred from Norwich, where the family lives to the
New London courthouse.

There was apparently another nephew involved, and the State prosecutor combined cases with
no explanation as to how all these events took place.

Years before, apparently, the retarded boy‘s uncle proposed citizen oversight of the police.
John M. was apparently involved in an incident at Walmart where a child was in the men‘s room
and could not get his pants down to go to the bathroom, and the parent was nowhere around, so
John M. helped. Walmart hires retarded people and are familiar with the difficulties of retarded




                                                                                                57
people, and of course were willing to let the whole event drop, to the best of this Plaintiff‘s
knowledge. There is little documentation of events available, and that would be because the
public does not know what they are up against, if they become the arbitrary victims of crazy
people who know how to use the DCF and the police to their advantage. Hopefully this
complaint will alert the residents of Connecticut to the hazards of being a Connecticut residents,
before the adequate resolution of these crimes, as described as relief and damages in the
original complaint Docket 5- 328 T, dated July 27, 2005.

One can see how this Walmart event would get mixed up, and that it is impossible to tell what
happened if John is mentally retarded, and as is known of him:

“Mr. M.’s past psychological reports cite significant language processing deficits. His
language processing becomes further compromised when John becomes anxious. This factor
does interfere with his ability to cope with his current situation. Mr. M’s mild retardation, in
addition to these deficits places him at a serious disadvantage as he attempts to work with
his attorney in defense of these charges. When we met with Mr. M., we found that he had a
great deal of difficulty participating in a simple conversation about his present
circumstances.”

It was after this Walmart incident that John M. uncle proposed citizen oversight of the police.
One can see that what we have is in reality, two sets of parents of young children, only one looks
a lot older. Both are equally concerned about their children.


It appears as though there is a tremendous tug-of-war over bodies, between the Department of
Criminal Justice, the Department of Children and Families, the Department of Mental Health and
Addiction Services, but oddly, not the Department of Mental Retardation. Each has their own set
of statutes, and the only mediator, the Department of Protection and Advocacy for Persons with
Disabilities, appears to be powerless.

There are numerous free assistance agencies in the State of Connecticut but they don‘t actually
do anything for anyone, even if one is lucky enough to get one of them to call back. This is not
only the Plaintiff Dickson‘s experience, but was the experience of every single person who was
dragged through the Connecticut Valley Hospital as ―incompetent.‖ Not too many of the
―criminals‖ were incompetent, if they knew how to look for help. The help was incompetent,
and one wonders of these non-profits take federal funding to provide no service. It did not take
long before we ―prisoners‖ we all joking about what a waste of advertising and publishing these
alleged non-profit legal help groups expend, and especially, about our coins for the pay phone,
which were wasted. It is well known that a CT public defender is called a ―public pretender,‖
and the only people who can emerge from this potentially permanent trap are those who have
family support on the outside.

Frequently enough to be a recognizable phenomenon, as in the evidence of many of the women
in prison, whoever goes to jail, in family disputes, is a matter of who called the police first.
Then of course, once one person has a record, those persons are always assumed to be guilty in
subsequent disputes, which involve altercations and then the police. One prison guard told the
Plaintiff that people routinely place their relatives in prisons just to get rid of them because they
are a nuisance. Plaintiff Dickson only heard abundant evidence to support that this is true from
listening to a vast number of the inmates at York.

It appears that just as it is well-known that the DCF can be used as a weapon, so to can the
police be used as a weapon. Hearsay is plenty good enough for DCF to fraudulently take
anyone‘s children away. No one has ever been prosecuted for false allegations of child abuse or
neglect in Connecticut. The DMHAS employees also refer to CT as a ―Meat Grinder.‖ They have
seen this abuse enough times. Lower level DMHAS employees are remarkably more sane than
their supervisors and more sane than the DMHAS ―doctors.‖ They are more sane than corrections
officers, police, and DCF ―social workers,‖ to their credit. These mental health workers and
nurses at the CVH ―competency restoration unit‖ should all get the salaries of the police and
corrections officer and DCF workers, while all of the latter 3 groups should be fired. DMHAS




                                                                                                 58
mental health workers and nurses are in a class unto themselves in the state of Connecticut (at
the present time).

2) Marsha Hoggan, 55, is an Alzheimer‘s patient who also has Parkinson‘s disease. (These two
disorders of brain damage also occur in Lyme borreliosis.) Ms. Hoggan is accused of stuffing
tissues in her roommate‘s mouth and cotton balls in her nose, where they lived together in a
nursing home. The roommate‘s name was Eleanor Mazzarella. Mazzarella died in March 2005
from unrelated causes and was 74 at the time of her death. Ms. Hoggan has claimed she did not
know what crime she committed and is now in the York Women‘s prison where she is mistreated
and is treated to more medical and nutritional neglect, since the nutrition in the prison is grossly
inadequate. The inmates in the mental health wing cannot buy vitamins or coffee. Stimulants
are known to be helpful for people with, dementia, cognitive decline, and the associated
depression.

None of the inmates at York get adequate exercise, since the only two exercise bikes in the
prison are broken and there is no other recreational equipment except balls, basketball hoops,
and sometimes a volleyball net. The guards are forever looking for a reason for the prisoners not
to go to the gym or to the library. Prisoners are not allowed to jog on the grass. Prisoners can
only go to the library, once a week and only approximately 5 out of 20 get to go, they are picked
randomly, and some never get to go to the library. Some of the ward TVs are broken, and some
have no reading materials. Thus, there is no intellectual stimulation whatsoever for a great
many inmates. These combined conditions contribute to dementia. In the prison there is no
education about nutrition, no nutrition, no education about diet and exercise, and no exercise,
when clearly all these are needed to restore many of these women in the prison.
Most of them are drug addicts and in poor health. A great majority of these prisoners go over to
―mental health‖ to get some kind of drug to sleep their sentences away, but this increases the
illegal-drug induced dementia.

Thus, no prisoners will improve in any way, under ―corrections.‖ There is no incentive on the
part of corrections officers, for the prisoners to not be prisoners, because of all the overtime pay
these guards get. Therefore the cycle of abuse is perpetuated by the guards and their union.
Prisoners return to prison after having been arrested again for self-medicating too often. How
prisons are managed does not make any sense for dealing with human beings in any way, with
the exception of mass murderers, who are rare.

The most adverse treatment for older women in cognitive decline are central nervous system
depressants such as antipsychotics and this announcement was made in 2005 by the National
Institute of Mental Health. A trial of Seroquel for agitation in dementia was halted because it
was observed that this treatment accelerated the dementia. The monograph for risperidone
states that this medication is associated with greater extrapyramidal effects (extrapyramidal
brain damage) in older women, especially.

It would appear to the casual observer that the liability in this Hoggan case was more the nursing
home‘s, rather than the incompetent patient‘s.


3) Leslie Andino a 23 year old woman with multiple sclerosis, dementia and depression - which
sounds very much misdiagnosed Lyme Neuroborreliosis - was arrested and charged with arson in a
nursing home fire that killed 16 other residents in Connecticut in May 2003. After several periods
of ―treatment‖ to restore competency for trial for a crime she never should have been charged
with in the first place, she returned to the courthouse in January 2005, ―heavily sedated,‖ to
learn she would be committed to the Whiting Psychiatric Prison.

Heavy sedation is malpractice for a neuropsychiatric disease, and likely contributed to her
increasing dementia. The American Psychiatric Associations Guidelines on the treatment of a
delirium state that: ―Medications for psychiatric disorders can be both the cause of delirium and
exacerbate or contribute to delirium from other causes.‖

This Andino case should be investigated by a competent independent federal health official and
expert, which would obviously not be one from Connecticut.




                                                                                                  59
         It would appear to the casual observer that the liability was more the nursing home‘s, rather
         than the incompetent patient‘s.




These are three cases which are in addition to the several other cases of incompetence and abuse and
wrongful imprisonment, denial of access to the courts, false criminal charges, perjury and alleged judicial
misconduct listed in the original complaint about the State of CT in docket 5- 328 T, originally filed July
27, 2005, and amended August 3 and August 22, 2005.


I respectfully ask the Norwich Superior Court to acknowledge this condition and the facts presented in
John M.‘s case and release John M. to his family, who would like to assist in his placement in a proper
facility, which the family has been made aware will take him. The Department of Mental Retardation‘s
website makes it clear that they have no state funded housing available for any new needy families.
Participants in the class action against the State of CT believe the DCF is over-funded and abused funding,
and so too it appears, has the Division of Criminal Justice.


I believe a disabled person like John M. should have his needs addressed, rather than be thrown away into
a prison, which is merely the least costly solution to persons with disabilities. I agree with his case
manager, Ellen Gilmartin, that he does not belong in a prison where the threat of abuse is not only
accelerated but confirmed in John‘s case, as was predicted by his case manager. John M. is a human
being, deserving of protection as a disabled person, and by the definition of a person with mental
retardation, is not competent and not a criminal.

John has already served 6 months and it seems pointless to the casual observer to pursue this case in a
trial against John M, since the cost could be better spent for his care.




Care for the disabled may or may not be a State mandate. It may not be a funded mandate. However,
the original complaint against the State asserts that it was the responsibility of Marc S. Ryan, the Director
of the Office of Policy and Management, to seek sources of federal funding to provide for the needs of the
State‘s residents. All that we know that was accomplished was the construction of the multimillion dollar
Tomasso pediatric prison, and which spent $514,000 per year, and per child, to incarcerate children, but
will now close. Part of the resolution of the disaster of misallocation of funding, racketeering, fraud,
and theft of honest services, was that the former Governor John G. Rowland went to jail and several high-
level State employees are facing federal indictment or a lawsuit brought by the Attorney General.




Many legislators and citizens of the State agree that children do not belong in prison. Neither do the
mentally retarded, since there is little technical difference. Both classes of people are incompetent.




Signed this ____ day of August, 2005




                                                                                                          60
           _______________________________
                                             Kathleen M.
Dickson, et al
                                             23 Garden
Street
                                             Pawcatuck, CT
06379
                                             860-599-5451




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