CIA Civil Complaint Draft

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA



JOHN ERIN BINNS
Plaintiff

Vs.

CENTRAL INTELLIGENCE AGENCY
WASHINGTON DC, 20505

REPUBLIC OF TURKEY
Ministry of Foreign Affairs
Dr. Sadık Ahmet Cad. No:8
Balgat, Ankara
TURKEY

kbo-Isar-Amper-Klinikum Taufkirchen (Vils)
Bräuhausstr. 5
84416 Taufkirchen,Vils
GERMANY

John Does 1-10
Defendants




COMPLAINT
1. This is an action under 18 USC Code § 241 (conspiracy against rights), 18 USC Code § 2340A (torture) and 18 USC § 2332A (use of weapons of mass destruction). Plaintiff John Erin Binns challenges attempts by the Central Intelligence Agency (“CIA”) to get Plaintiff extrajudicially killed by the Republic of Turkey by falsely communicating to Turkey’s National Intelligence Organization (“MIT”) that Plaintiff was a supporter or member of the Islamic State (“ISIS”).

JURISDICTION AND VENUE
3. This court has jurisdiction over this action pursuant to 5 USC. § 552(a)(4)(B).
The court also has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331, 2201(a), and 2202. Venue lies in this district under 5 U.S.C. § 552(a)(4)(B).

PARTIES

4. Plaintiff John Erin Binns is a 19 year old citizen of the United States who is under investigation by the Federal Bureau of Investigation (“FBI”) for alleged blackhat hacking and computer fraud offenses. Plaintiff was previously the target of attempted recruitment into the CIA through blackmail, and under physical surveillance by CIA contractors operating in Karsiyaka, Izmir, Turkey, who broke into vacant apartments belonging to Turkish citizens in order to surveil Plaintiff. Plaintiff was also the target of a “gangstalking” and severe harassment campaign in which CIA contractors would shine laser pointers into his room as a harassment tactic (“dazzling”), point modified microwave ovens with the door removed at his bedroom from a balcony (Plaintiff observed a western male performing this act on one occasion), and use portable solid-state microwave weapons to remotely give Plaintiff panic attacks, tachycardia, and manipulate his emotional state. Agent provocateurs belonging to the CIA would also encourage Plaintiff to commit serious crimes such as murder so that Plaintiff would get arrested and go to prison. Plaintiff’s cellular phone was infected with malware and he would additionally receive up to 5 death threats daily from surveillance role-players (paid street thugs) hired by MIT. One domestic CIA informant named Azaiah Crosswhite was given private pictures from Plaintiff’s bedroom taken by CIA contractors, which he used to gaslight Plaintiff.

5. Defendant CIA is an agency within the meaning of 5 U.S.C. § 552(f) and 5 U.S.C. § 701. The CIA is the federal agency with possession and control of the requested records and is responsible for fulfilling Plaintiff’s FOIA request.

FACTS
6. On July 1, 2019, Plaintiff was the target of an extrajudicial killing in Izmir, Turkey by MIT as the CIA had falsely communicated to MIT that Plaintiff was a member of or supporter of the Islamic State (“ISIS”).

7. Plaintiff hid in Alsancak Nevvar Salih Isgoren Hospital from Turkish state-sponsored hitmen, and Plaintiff’s name appeared in an unknown anti-terrorism database connected to the emergency room computer. The name of Azaiah Crosswhite, an FBI confidential human source and domestic CIA informant, appeared in the database, and the hospital doctors were talking about this. Plaintiff’s name was also changed to “Cock Sucker” in the anti-terrorism database.

8. The emergency room doctors called the Turkish police, who then swarmed the hospital and interrogated Plaintiff.

9. On July 7, 2019, Plaintiff was abducted from the Munich Airport police station by fake German police officers (MIT) and taken to a fake mental hospital building used as an anti-terrorism detention facility by MIT and located at 48.345941, 12.137753 on the territory of Germany (“KBO Haus 10”).

10. The MIT agent who came with Plaintiff in the ambulance to KBO Haus 10 told the staff at the facility to fry Plaintiff’s brain with gas.

11. Plaintiff was put in the suicide watch room/neurotoxic gas room, and a staff member activated a metal fan emitting a substance smelling similar to ammonia.

12. After Plaintiff would be successfully given brain damage using a neurotoxic gas room, Delta Force would extraordinary render Plaintiff to Anchorage International Airport to face trial on federal charges, where Plaintiff would be found mentally incompetent and forced into a plea deal for over 10 years in prison.

13. Plaintiff’s time in the neurotoxic gas room of KBO Haus 10 was recorded and live-streamed to domestic CIA informants as a “destruction video” over the internet anonymity service Tor.

14. Plaintiff was previously assigned codename “BLACKBIRD” by the CIA.

15. Neurotoxic gas rooms are used by intelligence agencies worldwide, including the CIA, against terror suspects and individuals who learn government secrets, to give the target permanent brain damage and schizophrenia. The target is usually taken to a fake mental hospital operated by an intelligence agency, where they are put in a gas room for several hours.

16. Portable directed energy weapons are devices which use solid-state microwave amplification technology to deliver a pulsed beam which can cause tachycardia, paranoia, confusion, seizures, or drowsiness in a target.


COUNT I  - CONSPIRACY AGAINST RIGHTS – CIA
17. This Count realleges and incorporates by reference all of the preceding paragraphs.

18. Unknown officers of the Central Intelligence Agency knowingly falsely communicated to the Republic of Turkey that Plaintiff was a member or supporter of ISIS and made him the target of an extrajudicial killing by MIT, in violation of the Fifth Amendment’s due process clause: “No person shall ... be deprived of life, liberty, or property, without due process of law.".

COUNT II  - TORTURE – REPUBLIC OF TURKEY
19. This Count realleges and incorporates by reference all of the preceding paragraphs.

20. Commercial activities were being carried out by agents of the Republic of Turkey at KBO Haus 10, meaning that pursuant to 28 USC § 1605(A)(2), the Republic of Turkey is not immune from the jurisdiction of the United States.

21. Staff members at KBO Haus 10 acting in official capacity as agents of MIT and the Republic of Turkey played back audio recordings on a loop in the hallways of Turkish words such as “gerizekali” (the Turkish word for mentally retarded), screaming noises, and one staff member would repeatedly point to an image of a man with down syndrome in a newspaper and say to Plaintiff: “This is you, it’s finished, it’s over”, after Plaintiff was released from the neurotoxic gas room.

22. Another staff member would use a portable microwave weapon the size of a desktop computer speaker to remotely give Plaintiff epileptic seizures.

23. The conduct by agents of the Republic of Turkey was extreme and outrageous.

COUNT III – USE OF WEAPONS OF MASS DESTRUCTION – REPUBLIC OF TURKEY
24. This Count realleges and incorporates by reference all of the preceding paragraphs.

25. Pursuant to 18 USC § 2332A(C)(2)(B), agents of the Republic of Turkey used a weapon of mass destruction (neurotoxic gas room) intended to cause serious bodily injury (brain damage) against Plaintiff in Germany, who is a US Citizen.

COUNT IV -  EXTORTION BY EMPLOYEES OF THE UNITED STATES – CIA
26. This Count realleges and incorporates by reference all of the preceding paragraphs.
27. On or about July 2018, contractors working for the CIA recorded a video of Plaintiff’s private area in his bedroom in Karsiyaka, Izmir, Turkey, after breaking into a vacant apartment across from the bedroom.
28. Kenneth Currin Schuchman and Azaiah Chadrick Crosswhite were both shown this video.
29. Azaiah Chadrick Crosswhite, acting as an agent and informant of the CIA, attempted to extort Plaintiff into working for the CIA using the video.
COUNT V – ASSAULT WITH A DANGEROUS WEAPON – CIA
30. This Count realleges and incorporates by reference all of the preceding paragraphs.
31. On or about February 2019, contractors working for the CIA broke into a vacant apartment across from Plaintiff’s bedroom and pointed a modified microwave oven with the door interlock switch bypassed at Plaintiff’s bed while he was half awake. Plaintiff observed a western male bringing an extension cord for the oven to the balcony, and pressing buttons on the microwave oven to switch it on while it was aimed directly at Plaintiff.
32. On or about September 2018, Plaintiff began to experience symptoms ranging from tachycardia to paranoia, and went outside to the balcony of his apartment.
33. Plaintiff observed two western males holding a microwave neuroweapon the size of a desktop computer directly at his head, which was likely responsible for his symptoms. 34. Plaintiff observed that his cell phone camera was blurred and could not reliably take a photograph of the neuroweapon, most likely due to interference on the CMOS/CCD imaging sensor of the camera by microwaves. Plaintiff also observed buttons on the device and a microphone connected to a jack, which was most likely used for synthetic telepathy through “voice to skull”/the Frey effect.
35. When Plaintiff attempted to take a photograph of the device, both western males started laughing and quickly went indoors.

PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court:

(1) Declare Defendant’s failure to comply with FOIA to be unlawful.

(2) Order Defendant to immediately process Plaintiff’s FOIA request and produce any non-exempt, responsive records.

(3) Grant Plaintiff such other and further relief which the Court deems proper.