Free Complaint - District Court of Delaware - Delaware

Case 1 :05-cv-00345-SLR Document 1-3 Filed 05/27/2005 Page 1 of 2
_ IN THE UNITED STATES DISTRICT COURT
- FOR THE DISTRICT OF DELAWARE
_ Civil Action No. Q _ 3 A1 5 ml
. _ 1,0. The alleged discriminatory acts, in this suit, concem:
D, Other acts, which violated my civil rights (specified below)
1. Retaliation for filing the original complaint, some of the retaliatory
. i " l actions include but are not limited to the following.
A. A search of 1ny person, personal belongings and vehicle which was
not documented, photographed, logged or in any way in compliance
with even the most rudimentary guidelines. The material that was
seized was then separated, co-mingled and manipulated to present a
distorted picture. In addition, my work space was searched subsequent
to my departure and material from there appears to be included in the
summary of my personal belongings.
B. A receipt for the materials seized from my person was never provided.
C. I was not advised of any rights or recourse available to me at the time
of the search.
D. I was threatened by an Assistant United States Attorney and a
Supervisory Special Agent to resign from the Federal Bureau of
Investigation or face possible criminal charges.
E. I was accused of conveying document.s to an unnamed patty outside
the Federal Bureau of Investigation. This in effect is accusing me of
espionage and appears to be the basis for the search warrant obtained
for my residence. This accusation is an outright lie.
F. I was not allowed to have any contact with my co-workers thereby
minimizing the effectiveness of my attempts to keep my job.
G. My reputation was mined by the fact that computers from the
volunteer fire department that I am a member of were searched. There
is absolutely no basis for this type of investigative technique except to
intimidate me.
H. Persons from the Baltimore Division made false statements to federal
agents which were used as the basis for the revocation of my Top
Secret security clearance.
I. Documents that I requested to defend myself in the revocation of my
Top Secret security clearance were denied. I was therefore unable to
neither defend myself against my accusers nor know whom my
accusers were.
J. Allegations were made that I had encryption and steganography
software, as well as FBI documents on my personal computer. The
computer was returned to me with a fried hard drive. After a forensic
computer examination was perfonned at my request, none ofthe

Case 1:05-cv-00345-SLR Document 1-3 Filed 05/27/2005 Page 2 of 2
alleged material was found or determined to have ever been on the 5
system. -
` K. Statements that were known to be false or of questionable veracity
were allowed to remain inthe documents used as the basis to revoke
my security clearance. l
L. It appears that members of the Baltimore management staff conspired l
to present material and events in such a way that was fictitious and! or
misleading in order to prevent or minimize inquiries into their
handling ofmy case.
M. The Access Review Committee from DOJ did not require the F BI to
make full disclosure even though I repeatedly asked and it was stated
in the opening statements of the proceeding that full disclosure was
required.
N. These items are intended to give an example of the retaliation and in
are not meant to represent a complete list at this time.
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