Click to access 150324-filed%20Clinton%20RICO%20complaint.pdf
A LARRY KLAYMAN Plaintiff, v. HILLARY RODHAM CLINTON, and WILLIAM JEFFERSON CLINTON, and THE CLINTON FOUNDATION a/k/a The William J. Clinton Foundation a/k/a The Bill, Hillary & Chelsea Clinton Foundation 1271 Avenue of the Americas, 42nd Floor New York, New York 10020 Service: Chairman Bruce Lindsey or Vice-Chairman Chelsea Clinton Mezvinsky (neé Chelsea Victoria Clinton) Defendants. Civil Action No. ____________ TRIAL BY JURY DEMANDED COMPLAINT PURSUANT TO RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT AND OTHER CAUSES OF ACTION Plaintiff sues the Defendants, as individuals operating a criminal enterprise, for violating Plaintiff’s statutory rights to obtain documents under the Freedom of Information Act (“FOIA”), 5 U.S.C. § 552, for violating Plaintiff’s due process rights, vested property rights, constitutional rights, and for misappropriating property. The Defendants have systematically and continuously, over the last ten (10) years and more, conducted a corrupt C
I. JURISDICTION AND VENUE 1. This is a civil action for violations of 18 U.S.C. § 1961 et seq. (“Racketeer Influenced and Corrupt Organizations Act” or “RICO”). RICO addresses the corrupt abuse and misuse – usually covertly – of organizations, entities, businesses, institutions or even governments or government agencies, such that superficially legitimate entities actually operate for criminal purposes irrelevant to the entity’s purpose. 2. Plaintiff has filed many Freedom of Information Act (“FOIA”) requests for public records created or held by the U.S. Department of State (“State”), which records are of the public interest and importance to the citizens of the United States. 3. Considering two important FOIA requests in particular, the Defendants have withheld documents from the Plaintiff to which the Plaintiff is entitled to by law under FOIA concerning the granting of waivers by the Secretary of State for persons, companies, countries, and other interests to do business with Iran. In addition, the second FOIA at issue concerns the Defendants, and in particular Defendant Hillary Clinton, leaking Israeli war plans and cyber-warfare methods and sources to David Sanger of The New York Times. 4. As it has now been revealed, a primary reason that the Plaintiff did not receive the records to which the Plaintiff is entitled by law is that Defendant Hillary Clinton – upon information and belief together with Cheryl Mills and Defendant Bill Clinton and other Clinton “loyalists” – set up a private computer file server (“server”) operating a private, stand-alone electronic mail (“email”) system. Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 2 of 59 3 5. As admitted by Defendant Hillary Clinton and State, Secretary of State Hillary Clinton did not use any official, governmental email address or account from State or the U.S. Government, but instead used for her communications as Secretary of State her own private, ‘off the books’ email system and server secretly set up in her mansion in Chappaqua, New York, even for all of her official business as Secretary of State. 6. “I thought it would be easier to carry just one device for my work and for my personal emails instead of two,” she incredulously explained at a March 10, 2015 press conference at the United Nations, despite having staff assisting her and traveling with her. 7. Upon information and belief, the server is jointly owned, operated, and controlled by both Defendants Hillary Clinton and Bill Clinton. 8. Upon information and belief, the server was established in part for the use of Defendant The Clinton Foundation and Defendant Hillary Clinton. Defendant The Clinton Foundation and Defendant Hillary Clinton own the server in whole or in part. 9. As a result, the Defendants concealed from the Plaintiff public records to which the Plaintiff was entitled to under the FOIA Act. 10. Defendants concealed official government documents such that they were not available to be searched and produced to the Plaintiff under FOIA. Defendants intended to operate a covert enterprise of trading political favors and governmental acts in exchange for donations, which are in effect bribes, to Defendant The Clinton Foundation and/or speaking fees to Defendants Bill and/or Hillary Clinton. 11. Using those concealed communications held on the private email server, upon information and belief, the Defendants negotiated, arranged and implemented the sale of influence and access to U.S. Government officials and decision-makers and official acts Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 3 of 59 4 by State and other instrumentalities of the U.S. Government in return for gratuitous and illegal payments – bribes – disguised as donations to Defendant The Clinton Foundation and extraordinarily high speaking fees paid to Defendant Bill Clinton and Defendant Hillary Clinton. This illegal conduct is consistent with pattern and practice and course of conduct of the Defendants during their administration in the 1990s. 12. As a result, Defendants unlawfully withheld documents to which Plaintiff was entitled to under FOIA law. II. JURISDICTION AND VENUE 13. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331. Jurisdiction is also proper pursuant to 18 U.S.C. § 1965, which allows for nationwide jurisdiction pursuant to the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. §§ 1961-1968. 14. This Court also has subject matter jurisdiction over this action based on diversity of citizenship pursuant to 28 U.S.C. § 1332(a)(2). 15. Jurisdiction is also proper under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), in so far as the actions violate the First and Fifth Amendments to the U.S. Constitution. 16. This Court has supplemental jurisdiction over this action pursuant to 28 U.S.C. § 1367. III. THE PARTIES 17. Plaintiff Larry Klayman is an attorney active in the public interest and is Chairman and General Counsel of Freedom Watch, Inc. Plaintiff seeks to promote openness and transparency in the public interest within the federal government and governmental actions for the benefits of the American people and citizens. Plaintiff initially signed and Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 4 of 59 5 requested, pursuant to FOIA, the records set forth with regard to the two FOIA requests at issue here. Plaintiff is a citizen of Florida. 18. The Plaintiff’s injuries, including the deprivation of his legal rights and legally protected vested property rights, are proximately related to the illegal conduct of Defendants, each and every one of them, jointly and severally. 19. Defendant The Clinton Foundation claims to be a not-for-profit organization subject to Section 501(c)(3) of the Internal Revenue Code (26 U.S.C. § 501(c)(3)). 20. Defendant The Clinton Foundation, originally created under the name of the William J. Clinton Foundation, and also known as The Bill, Hillary & Chelsea Clinton Foundation, was founded by Defendant Bill Clinton in 2001 with the stated mission to “strengthen the capacity of people throughout the world to meet the challenges of global interdependence.” 21. Numerous projects or “initiatives” such as “the Clinton Global Initiative” are subdivisions of Defendant The Clinton Foundation. However, there are also indications among the financial reports of The Clinton Foundation that major “initiatives” have been spun off and are now housed under independent corporations with additional donations. 22. Defendant Hillary Clinton is acting in all events relevant herein as an individual operating a criminal enterprise, but also served as U.S. Secretary of State from January 21, 2009 – February 1, 2013. President Barack Obama appointed Defendant Hillary Clinton to this position. She is a citizen of New York. 23. Defendant Hillary Clinton was an elected U.S. Senator from New York from January 3, 2001, through January 3, 2009, and served on many U.S. Senate committees and subcommittees involving U.S. military capabilities and activities worldwide. Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 5 of 59 6 24. Defendant Hillary Clinton was the former First Lady of the United States. 25. Defendant Hillary Clinton is on the Board of Directors of Defendant The Clinton Foundation. 26. Defendant Hillary Clinton is married to former President and Defendant William Jefferson Clinton and is the mother of Chelsea Victoria Clinton. 27. Defendant Bill Clinton is acting in all events relevant herein as an individual operating a criminal enterprise, but also was President of the United States from January 20, 1993 to January 20, 2001. He is a citizen of New York. 28. Defendant Bill Clinton is a member of the Board of Directors of Defendant The Clinton Foundation. Defendant The Clinton Foundation’s headquarters are in New York, New York and it is incorporated in Arkansas. 29. Though not named as a Defendant at this time, as a relevant actor Chelsea Victoria Clinton is the daughter of Defendants Bill and Hillary Clinton. Chelsea Clinton is a member of the Board of Directors of Defendant The Clinton Foundation and serves as the Vice Chair of the Board of Directors. 30. Though not named as a Defendant at this time, as a relevant actor Bruce Lindsey is The Clinton Foundation’s Chairman of the Board, and previously Deputy White House Counsel for Defendant President Bill Clinton during the Clinton administration and a leader in Defendant Bill Clinton’s campaign for president. 31. Though not named as a Defendant at this time, as a relevant actor Cheryl Mills is a member of the Board of Directors of Defendant The Clinton Foundation. 32. Cheryl Mills was Chief of Staff to U.S. Secretary of State Defendant Hillary Clinton and Counselor for State. Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 6 of 59 7 33. Cheryl Mills was Associate Counsel to the President under Defendant President Bill Clinton. IV. FACTS COMMON TO ALL COUNTS 34. Defendants have misappropriated – that is, stolen – the documents which are U.S. Government property under relevant records management and archive laws governing U.S. Government officials. 35. Defendants have misappropriated – that is, stolen – the documents which the Plaintiff is entitled to as a vested property right and property pursuant to FOIA law. 36. Plaintiff filed a FOIA request to State on May 21, 2012, asking in the public interest for: Any and all documents that refer or relate in any way to the final decisions to grant waivers to all countries and other interests doing business with the Islamic Republic of Iran pursuant to the Comprehensive Iran Sanctions, Accountability, and Divestment Act, 22 U.S.C. § 8501, et. seq. or Executive Order 13533. 37. These sanctions were established by Congress to hinder Iran’s development of nuclear weapons capable of doing massive damage to cities in the United States and Israel and other western allies by limiting financial transfers to Iran and Iranian interests and to discourage Iran’s military build-up and march to nuclear weapons of mass destruction. 38. Decisions by then Defendant Secretary of State Hillary Clinton to waive these sanctions are likely to directly undermine the Congressionally-established foreign policy of limiting Iran’s financial abilities to develop nuclear weaponry that can threaten the United States, Israel and its western allies. 39. However, State has not produced any documents in response to this FOIA request. 40. Plaintiff also filed another FOIA request to several agencies including State, asking in the public interest for: Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 7 of 59 8 Any and all information that refers or relates to The New York Times article entitled “Obama Order Sped Up Wave of Cyber attacks Against Iran” by David E. Sanger on Friday, June 1, 2012, and which information was provided and leaked to Mr. Sanger and The New York Times; Any and all information that refers or relates in any way to information released to David E. Sanger and/or made available to him; The names of the persons, employers and job titles, and addresses of those who “leaked” the above information to David E. Sanger; Communications with The White House and/or Office of the President and/or Vice President that refer or relate in any way to the “leaked” information and/or the reasons for “leaking” the information; Any and all information that refer or relate to the decision to “leak” the above previously classified information; Any and all information that refers or relates to government agencies deciding to investigate who “leaked” the above previously classified information. 41. Reporter David Sanger published information in The New York Times clearly leaked from State that included information about Israeli and U.S. programs and efforts to sabotage Iran’s nuclear weapons development programs and facilities. 42. Public reports about plans to counter Iran’s nuclear weapons development programs undermined the effectiveness of those plans by revealing them to Iran and other terrorist organizations and states. 43. State produced very few documents, and withheld and redacted many documents inappropriately and without providing a Vaughn index. State’s Compliance with FOIA Harmed and Corrupted by RICO Enterprise 44. As a result of the following facts and circumstances below, State’s search did not find all responsive documents because they were hidden from Departmental scrutiny in the Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 8 of 59 9 basement of Defendant Hillary Clinton’s personal mansion on a private computer file server managing her private, ‘off-the-books’ email account. 45. Departmental personnel could not locate responsive documents that were intentionally and knowingly kept hidden within Defendant Hillary Clinton’s personal email system for the very purpose of Defendant Hillary Clinton preventing their discovery, and especially those emails already deleted from her private server. 46. It is suggested that other State employees with whom she was corresponding would have captured Defendant Hillary Clinton’s emails. 47. In fact, according to the Inspector General of State, the employees of State generated more than 1 Billion emails in 2011, yet only 61,156 were retained as public records. 48. As a result of State employees preserving only 61,156 emails out of over 1 Billion emails, State did not fully produce documents in response to various FOIA requests. 49. In the aforementioned report, the Inspector General of State conducted a review and issued a report “Review of State Messaging and Archive Retrieval Toolset and Record Email” publicly released on March 11, 2015.1 50. The Inspector General’s report reads like an interim report and explicitly acknowledges that review is on-going and recommends that a working group on improving recordkeeping should continue. 51. Nevertheless, the U.S. Department of State’s Inspector General’s report found concerning email operations and use at State: Some employees do not create record emails because they do not want to make the email available in searches or fear that this availability would inhibit debate about pending decisions. Page 1 1 Accessible at http://oig.state.gov/system/files/isp-i-15-15.pdf Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 9 of 59 10 Every employee in the Department has the responsibility of preserving emails that should be retained as official records. Page 2 Most mission and bureau employees who did not use record emails as intended told OIG they were usually unaware of what types of information should be saved as record emails. Page 5 Some employees were under the impression that record emails were only a convenience; they had not understood that some emails were required to be saved as records. Page 5 The Department’s deficiencies in preserving appropriate emails cannot be changed unless the actions of individual employees change. Page 6 The Department of State (Department) and its employees need official records for many purposes: reference in conducting ongoing operations; orientation of successors; defending the U.S. Government’s position in disputes or misunderstandings; holding individuals accountable; recording policies, practices, and accomplishments; responding to congressional and other enquiries; and documenting U.S. diplomatic history. Record preservation is particularly important in the Department because Foreign Service officers rotate into new positions every 2 or 3 years. Federal law requires departments, agencies, and their employees to create records of their more significant actions and to preserve records according to Government wide standards. Page 2 52. Indeed, in responding to the subject FOIA request and suppressing responsive documents, State, its then Chief of Staff Cheryl Mills, and its then Secretary, Defendant Hillary Clinton, lied to the lower court, as they claimed that there were no responsive documents from the Defendant Secretary’s office. 53. As a result, State performed an inadequate search for records responsive to the Plaintiff’s FOIA requests. Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 10 of 59 11 54. State’s search for records responsive to the Plaintiff’s FOIA requests were inadequate because the Defendants knowingly and intentionally concealed approximately 62,490 records from official State record-keeping until around two years after Hillary Clinton left office and admittedly destroyed over 32,000 of those records. 55. As a result, the concealment of approximately 62,490 emails to and from the Secretary of State directly harmed the Plaintiff in the availability of the most relevant and the most important records of State, given that the Secretary would be informed about or giving orders concerning the high-level issues and policies addressed by Plaintiff’s FOIA requests and the similar FOIA requests of other requesters. 56. Even those emails returned to State were concealed for two years after Defendant Hillary Clinton’s separation from State, and all during her tenure as Secretary of State. 57. Relying on these false representations, the lower court granted summary judgment in lawsuits by Freedom Watch seeking these documents. 58. These false representations worked a fraud upon the Courts and Plaintiff and are an obstruction of justice. State Did Not Comply with FOIA as Defendants Concealed Public Records on Private Server 59. The position of Inspector General at State, charged with overseeing compliance with laws and regulations at State, was vacant for nearly 2,066 days from the resignation of Howard J. Krongard on December 7, 2007, until the U.S. Senate confirmed Steve A. Linick on September 30, 2013. 60. Defendant Hillary Clinton formally resigned as Secretary of State on February 1, 2013. 61. Therefore, during Defendant Hillary Clinton’s entire term as Secretary of State – including her separation procedures as she departed – State had no Inspector General Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 11 of 59 12 compliance officer responsible to oversee State’s compliance with laws, regulations, and Departmental procedures. 62. Meanwhile, Defendant Hillary Clinton (together with Defendant Bill Clinton and The Clinton Foundation) set up a private, off-the-books, email system approximately nine (9) days before she was sworn in as U.S. Secretary of State as uncovered, revealed, and reported by The New York Times. 2 63. Department of State officials and Defendant Hillary Clinton herself have confirmed that Defendant Hillary Clinton exclusively used a personal account, instead of a government e-mail address, during her time in office. 64. Defendant Hillary Clinton conducted U.S. Government business through a private, unofficial email account secretly housed and maintained on a computer file server located in Defendant Hillary Clinton’s private mansion in Chappaqua, New York operating email addresses (accounts) such as at “@clintonemail.com.” 65. On hundreds of occasions Secretary of State Defendant Hillary Clinton was photographed by news media on the job, at official meetings, on official travel, at official events, and on official business conspicuously reading emails on her hand-held “smart phone.” 66. Defendant Hillary Clinton admitted in a press conference at the United Nations on March 10, 2015, that she had turned over 30,490 emails to State in December 2014, nearly two years after leaving office. But, she also said she had deleted nearly 32,000 other email messages from that private email server at her mansion in Chappaqua, New York, claiming those emails are “private.” 2 “Hillary Clinton Used Personal Email Account at State Dept., Possibly Breaking Rules,” Michael Schmidt, The New York Times, March 2, 2015. Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015 Page 12 of 59 13 67. As renowned ethics professor Ronald D. Rotunda writes, “By her own admission, Mrs. Clinton destroyed more than 30,000 emails once the subpoenas started coming in. She claims that she only destroyed personal records.”3 68. That is, Defendant Hillary Clinton destroyed the email records after many Congressional subpoenas and a flurry of FOIA requests from various requesters, including Plaintiff, had already been issued, including in the wake of the September 11, 2012, terrorist attack on the U.S. Consulate in Benghazi, Libya. 69. As explained by Professor Ronald D. Rotunda, Defendant Hillary Clinton’s actions were an intentional and pre-mediated effort, in violation of the law, to evade Congressional subpoenas and other legal accountability: Mrs. Clinton was worried that communicating through email would leave a trail that might be subject to subpoena. “As much as I’ve been investigated and all of that,” she said in 2000, “why would I ever want to do email?” But when she became secretary of state, she didn’t have much choice. So she set up a private server in her house. That way, in the event of an investigation, she could control which emails would be turned over.4 70. Thus, in her own words, as an admission by a party-opponent, Defendant Hillary Clinton announced her reasons for avoiding traditional email as being to avoid providing information to official, government, judicial or Congressional investigations under the nation’s rule of law. This places her actions of setting up a private ‘off the books’ email system parallel to the U.S. Department of State’s own computer system in the light of her announced intentions to avoid providing information to lawful requests for information. 3 Accessible at: http://www.wsj.com/articles/ronald-d-rotunda-hillarys-emails-and-thelaw-1426547356. 4 “Hillary’s Emails and the Law,” Professor Ronald D. Rotunda, Esq., The Wall Street Journal, March 16, 2015, accessible at: http://www.wsj.com/articles/ronald-d-rotunda-hillarysemails-and-the-law-1426547356 Case 9:15-cv-80388-XXXX Document 1 Entered on FLSD Docket 03/24/2015
this goes to page PAGE 13 and there are MANY MORE PAGES. THE MORE OF THESE LYING STEALING CRIMINALS TAKEN OUT OF WORLD CONTROL THE BETTER FOR US. NOT TO MENTION, MANY OF THESE PEOPLE STEAL LARGE AMOUNTS OF MONEY THAT DOES NOT BELONG TO THEM. NEVER! THE B.S. SOMEONE SAID SEVERAL YEARS AGO ABOUT THE QUEEN, THAT YOU CAN”T BE CHARGED FOR MORE THAN 1 CRIME A BUNCH OF HOOEY, I SAY. IF YOU HAVE DONE THE DAMN CRIME, THEN YOU SHOULD DO THE DAMN TIME, I DON”T CARE WHAT WORLDLY “HIGH AND MIGHTY NAMES THESE “SELF-SELECTED” INDIVIDUALS GIVE THEMSELVES. TO THE ILLUMINATI, IT’S ALL ABOUT “PRESTIGE LABELS,” HEY, I HAVE A FEW LABELS FOR YOU, AND THEY ARE “ABOVE THEIR STATION” HOW ABOUT “GALACTIC CON ARTISTS OF THE CENTURY” “GALACTIC CRIMINALS,” IN GOD’S COURT, HOW ABOUT THOSE “PRESTIGE LABELS,” HERE THEY ARE CALLED CRIMINALS, LIARS AND THIEVES. AS YOU CAN SEE THE PAGES DON’T COPY TO WELL, GO AND READ THE PDF YOURSELVES IF YOU ARE INTERESTED. – MANY WILL WANT TOO!
CAN’T WAIT FOR THE DAY WE SEE BILL AND MELINDA GATES WITH THEIR LIES AND B.S IN COURT FOR MURDER, ATTEMPTED MURDER THROUGH VACCINATIONS. SPREADING LIES AND RUMORS THAT “US USELESS EATERS” SUCK UP TO MUCH OXYGEN IN THE WORLD, THAT WE GIVE OFF CARBON? THAT IS THE BIGGEST PILE OF CRAP I HAD TO WITNESS. WE ARE MOVING FROM A CARBON BASED BODY – TO A CRYSTALLINE BODY, KIND OF BLOWS HIS B.S. THEORY – OUT THE DAMN WINDOW -WHERE IT BELONGS!!! THE BILL GATES CARBON – SCAM FROM HUMANS IS A JOKE IN ITSELF, NEVER MIND GATES AGENDA 21 TO KILL US ALL. YOU FIRST, BILL GATES, WHILE YOUR AT IT, GO AND INJECT YOUR OWN FAMILY WITH {VACCINE POISON} THEN THERE WILL BE A FEW LESS REPTILIAN-ILLUMINATI MURDERERS ON THE PLANET! IF I KNEW ABOUT THAT STUPID SHOW HE DID TRYING TO SELL THE ELITES TO KILL US ALL. I WOULD HAVE RIPPED THROUGH HIM VERBALLY AND HE WOULD HAVE REMEMBERED IT. THERE IS NOT “ONE” SOUL ON THIS PLANET THAT HAS A RIGHT TO “OWN” YOU OR TELL YOU WHAT TO DO OR HOW TO THINK. COMPASSION CAN ONLY GO SO FAR. IT IS ONE THING TO FORGIVE PEOPLE, BUT DON’T LET IT MAKE YOU SOFT -EITHER. THERE IS A FINE LINE BETWEEN, JUSTICE AND THESE PEOPLE TRYING TO WEASEL OUT OF ACCOUNTABILITY. MOST OF US, WOULD RATHER THEY BE ROUNDED-UP FIRST. HELP ACCOUNTABLE AND CHARGED FOR THEIR CRIMES. I HAVE FORGIVEN MOST OF THEM, BUT IT DOESN’T MEAN THEY GET A FREE TICKET INTO “NON-PUNISHMENT.” “IF ANY “HUMAN” EVEN DID ANYTHING REMOTE OR EVEN SLIGHTLY LIKE THE THINGS THESE GUYS DID, WE WOULD BE LOCKED-UP FOR LIFE. SO THEN WHY SHOULDN’T THEY BE. THEY COULD HAVE TRIED TO WALK AWAY AND GET OUT OF IT. MANY HAVE “GOTTEN OUT” OF THE ILLUMINATI AND SURVIVED. MANY KILL TO BECOME PRESIDENTS – OH BUT DON’T JUDGE THAT-THEY WERE FORCED. WERE THEY REALLY? IF THEY WERE FORCED, THE LIGHT BEINGS WILL KNOW, AND IF THEY WEREN’T THE LIGHT BEINGS ALSO KNOW. SO LET’S SEE WHAT HAPPENS TO SOME OF THESE GUYS AND THEN WE WILL SEE IF THEIR’S IS JUST. THE WHOLE COURT SYSTEM IS SET-UP AS “2 AGAINST1” MOST LAWYERS KNOW THIS AND DON’T CARE. EVERYTHING ON THIS PLANET IS ROTTEN TO CORE, THIS IS WHY THE LIGHT HAD TO COME HERE AND RIP THE SYSTEMS OPEN TO EXPOSE THE EVIL AND DISGUSTING TRUTHS! JUSTICE WILL PREVAIL. LET’S HOPE THIS CALIFORNIA COURT – DOES RIGHT BY MANKIND!