Bond v. United States - Joint Appendix in U.S. Fourth Circuit No. 17-2150

Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 1 of 424
2017-2150
UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT
WILLIAM C. BOND,
Appellant,
v.
UNITED STATES,
Appellee.
Appeal from the United States District Court for the

District of Maryland, Case No. 1:16-cv-02723-DAF,
Senior District Judge David A. Faber
JOINT APPENDIX
_____________________________________________________________
Allen F. Loucks Richard A. Posner

Matthew P. Phelps Office of Richard Posner
Office of the United States Attorney 1222 East 56th Street
District of Maryland Chicago, Illinois 60637
36 S. Charles Street (773) 955-1351
4th Floor rposner62@gmail.com
Baltimore, MD 21202
410-209-4800 Matthew J. Dowd
allen.loucks@usdoj.gov Dowd PLLC
matthew.phelps@usdoj.gov 1717 Pennsylvania Avenue, NW
Suite 1025
Washington, D.C. 20006
Counsel for Appellee mjdowd@dowdpllc.com
Counsel for Appellant

TABLE OF CONTENTS
District Court Docket................................................................... JA001-004
Original Complaint (ECF 1) ........................................................ JA005-036
Letter Motion (ECF 15) ............................................................... JA037-038
Defendants’ Motion to Substitute & Dismiss (ECF 16) ............ JA039-040
Defendants’ Memo in Support of Motion to Substitute and

Dismiss (ECF 16-1) ................................................................. JA041-051
Exhibit 1 to Motion to Substitute and Dismiss (ECF 16-2) ...... JA052-052
Exhibit 2 to Motion to Substitute and Dismiss (ECF 16-3) ...... JA053-053
Plaintiff’s Pro Se Motion for Discovery (ECF 18) ...................... JA054-058
Exhibit 1 to Motion for Discovery (ECF 18-1)............................ JA059-074
Defendants’ Opposition to Plaintiff’s Motions (ECF 20) ........... JA075-078
District Court Memorandum Opinion & Order

dated April 12, 2017 (ECF 22) ................................................ JA079-106
Judgment Order, dated April 12, 2017 (ECF 23) ...................... JA107-108
Plaintiff’s First Pro Se Motion to Reopen Case and File

an Amended Complaint, dated May 9, 2017 (ECF 24) ......... JA109-110
Memorandum in Support of First Pro Se Motion to Reopen

(ECF 24-1) ................................................................................ JA111-118
Plaintiff’s First Amended Complaint (ECF 24-2) ...................... JA119-150
Redline Version of Plaintiff’s First

Amended Complaint (ECF 24-3) ............................................ JA151-194
Exhibit 1 to First Amended Complaint,

City Paper Web Advertisement (ECF 24-4) .......................... JA195-196

City Paper Print Advertisement (ECF 24-5) ......................... JA197-198
Corruption Sub Curia (ECF 24-6) .......................................... JA199-205
Exhibit 4 to First Amended Complaint, Email to
U.S. Attorney’s Office (ECF 24-7) .......................................... JA206-209
Exhibit 5 to First Amendment Complaint, FOIA Documents

from U.S. Marshals Service (ECF 24-8) ................................ JA210-226

Physician’s Certificate (ECF 24-9) ......................................... JA227-229
Exhibit 7 to First Amended Complaint, Maryland Code

Section 5-133 (ECF 24-10) ...................................................... JA230-233
Exhibit 8 to First Amended Complaint, Maryland Code

Section 5-205 (ECF 24-11) ...................................................... JA234-235
Exhibit 9 to First Amended Complaint, Excerpt from

Sixth Circuit Caselaw (ECF 24-12)........................................ JA236-238
Exhibit 10 to First Amended Complaint, Letter from

Gerald Messerman (ECF 24-13)............................................. JA239-240
Exhibit 11 to First Amended Complaint, Letter from

Gerald Messerman (ECF 24-14)............................................. JA241-242
Exhibit 12 to First Amended Complaint, Memorandum and

and Order from Bond v. Blum (ECF 24-15) .......................... JA243-248
Exhibit 13 to First Amended Complaint, Listing of

Board Members of Shepard and Enoch Pratt
Foundation (ECF 24-16) ......................................................... JA249-251
Exhibit 14 to First Amended Complaint, Excerpt from

District of Maryland filing (ECF 24-17) ................................ JA252-254
Exhibit 15 to First Amended Complaint, Affidavit of

William C. Bond (ECF 24-18) ................................................. JA255-258
Exhibit 16 to First Amended Complaint, Motion for Recusal

and Transfer in Appeal No. 14-5017 (ECF 24-19) ............... JA259-269
District Court Order dismissing Motion to File

Amended Complaint, dated May 23, 2017 (ECF 25) ............ JA270-270
Plaintiff’s Second Motion to Reopen and to File a

Second Amended Complaint (ECF 26) .................................. JA271-272
Plaintiff’s Memorandum in Support of Second Motion

to Reopen (ECF 26-1) .............................................................. JA273-286
Plaintiff’s Proposed Second Amendment Complaint ................. JA287-319
Redline Version of Plaintiff’s Proposed Second

Amended Complaint (ECF 26-3) ............................................ JA320-361
Defendants’ Opposition to Plaintiff’s Second Motion to

Reopen and File Amended Complaint (ECF 27) ................... JA362-368
Defendants’ Proposed Order (ECF 27-1) .................................... JA369-369
Plaintiff’s Reply in Support of Second Motion (ECF 28) ........... JA370-382
Exhibit 1 to Plaintiff’s Reply (ECF 28-1) ................................... JA383-385
Exhibit 2 to Plaintiff’s Reply (ECF 28-2),

2001 Copyright Complaint ..................................................... JA386-390

USAO MD email chain ........................................................... JA391-393



Exhibit 7 to Plaintiff’s Reply (ECF 28-7), USAO MD letter ..... JA401-403






Exhibit 13 to Plaintiff’s Reply, Proposed Order

(ECF 28-13) ............................................................................. JA414-414
District Court Memorandum Opinion & Order ......................... JA415-416
Plaintiff’s Notice of Appeal .......................................................... JA417-418

Case: 1:16-cv-02723-DAF As of: 12/04/2017 10:33 PM EST 1 of 4
APPEAL,CLOSED,IFPPRO
U.S. District Court
District of Maryland (Baltimore)
CIVIL DOCKET FOR CASE #: 1:16−cv−02723−DAF
Bond v. United States of America Date Filed: 07/29/2016

Assigned to: Judge David A. Faber Date Terminated: 04/12/2017
Demand: $9,999,000 Jury Demand: Plaintiff
Related Case: 1:15−cv−00199−DAF Nature of Suit: 440 Civil Rights: Other
Case in other court: USCA, 17−02150 Jurisdiction: Federal Question
Cause: 28:1331 Federal Question: Other Civil Rights
Plaintiff
William C. Bond represented by William C. Bond
PO Box 4823
Baltimore, MD 21211
PRO SE
V.
Defendant
Johnny L. Hughes represented by Matthew P Phelps
United States Marshal The United States Attorney's Office
TERMINATED: 04/12/2017 36 S. Charles Street
4th Floor
Baltimore, MD 21202
4102094800
Email: Matthew.Phelps@usdoj.gov
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Allen F Loucks
Office of the United States Attorney
36 S Charles St Fourth Fl
Baltimore, MD 21201
14102094800
Fax: 14109620693
Email: allen.loucks@usdoj.gov
Defendant
Kevin Perkins represented by Matthew P Phelps
Special Agent in Charge (See above for address)
TERMINATED: 04/12/2017 LEAD ATTORNEY
Allen F Loucks
(See above for address)
Defendant
Rod J. Rosenstein represented by Matthew P Phelps
United States Attorney (See above for address)
TERMINATED: 04/12/2017 LEAD ATTORNEY
Allen F Loucks
JA001
Defendant
Unknown Named Maryland U.S.
Judges
TERMINATED: 04/12/2017
Defendant
United States of America represented by Allen F Loucks
Matthew P Phelps
Date Filed # Docket Text

07/29/2016 1 COMPLAINT against Johnny L. Hughes, Kevin Perkins, Rod J. Rosenstein, Unknown
Named Maryland U.S. Judges, filed by William C. Bond. (Attachments: # 1 Civil
Cover Sheet, # 2 Summons)(jnls, Deputy Clerk) (Entered: 07/29/2016)
07/29/2016 2 MOTION for Leave to Proceed in forma pauperis by William C. Bond (jnls, Deputy
Clerk) (Entered: 07/29/2016)
08/08/2016 3 ORDER granting 2 Motion of plaintiff for Leave to Proceed in forma pauperis;
Plaintiff IS GRANTED TWENTY−ONE (21) days from the date of this Order in
which to complete the U.S. Marshal forms and return them to the Clerk. Signed by
Chief Judge Catherine C. Blake on 8/8/2016. (c/m 8/9/16 jnls, Deputy Clerk) (Entered:
08/09/2016)
08/12/2016 4 ORDER designating and assigning the Honorable David A. Faber to this case. Signed
by Chief Judge of the USCA for the Fourth Circuit on 8/11/2016. (dass, Deputy Clerk)
(c/m 8/12/16−das) (Entered: 08/12/2016)
08/12/2016 Case Reassigned to Judge David A. Faber. Judge J. Frederick Motz no longer assigned
to the case. (dass, Deputy Clerk) (Entered: 08/12/2016)
08/12/2016 5 Summons Issued 60 days as to Johnny L. Hughes, Kevin Perkins, Rod J. Rosenstein.
(hmls, Deputy Clerk) (Entered: 08/12/2016)
08/12/2016 6 USM 285 form for Unknown Named Maryland U.S. Judges by William C. Bond.
(Rec'd 8/11/16) (hmls, Deputy Clerk) (Entered: 08/12/2016)
08/16/2016 7 SUMMONS Returned Executed. Johnny L. Hughes served on 8/15/2016. (jnls, Deputy
09/07/2016 8 SUMMONS Returned Executed. Kevin Perkins served on 8/18/2016; Rod J.
Rosenstein served on 8/19/2016, answer due 10/18/2016. (jnls, Deputy Clerk)
(Entered: 09/07/2016)
09/08/2016 9 NOTICE to the Court re service of process by William C. Bond (jnls, Deputy Clerk)
(Entered: 09/08/2016)
10/14/2016 10 MOTION for Extension of Time to File Response/Reply as to 1 Complaint by Johnny
L. Hughes, Kevin Perkins, Rod J. Rosenstein. Responses due by 10/31/2016
(Attachments: # 1 Text of Proposed Order)(Phelps, Matthew) (Entered: 10/14/2016)
10/26/2016 11 RESPONSE re 10 MOTION for Extension of Time to File Response/Reply as to 1
Complaint filed by William C. Bond. (jnls, Deputy Clerk) (Entered: 10/26/2016)
11/01/2016 12 Correspondence from plaintiff re: scheduling order(jnls, Deputy Clerk) (Entered:
11/01/2016)
11/02/2016 13 RESPONSE re 12 Correspondence filed by Rod J. Rosenstein, Kevin Perkins, Johnny
L. Hughes.(Loucks, Allen) (Entered: 11/02/2016)
12/05/2016 14 ORDER granting 10 Motion of defendants for Extension of Time to File Response to
the complaint. Signed by Judge David A. Faber on 12/5/2016. (c/m 12/5/16 jnls,
JA002
Deputy Clerk) (Entered: 12/05/2016)
12/08/2016 15 MOTION to Stay and/or Toll Plaintiff's Opposition to the Defendants' Forthcoming
Response to the Complaint by William C. Bond(jnls, Deputy Clerk) (Entered:
12/08/2016)
12/13/2016 16 MOTION to Dismiss for Lack of Jurisdiction , MOTION to Dismiss for Failure to
State a Claim, MOTION to Substitute Party by Johnny L. Hughes, Kevin Perkins, Rod
J. Rosenstein (Attachments: # 1 Appendix Memorandum of Law, # 2 Exhibit A, # 3
Text of Proposed Order)(Phelps, Matthew) (Entered: 12/13/2016)
12/14/2016 17 Rule 12/56 letter mailed to William C. Bond (c/m 12/14/16 jnls, Deputy Clerk)
(Entered: 12/14/2016)
12/20/2016 18 MOTION for Discovery filed by William C. Bond. (Attachments: # 1 Exhibit 1)(jnls,
Deputy Clerk) Modified on 12/21/2016 (jnls, Deputy Clerk). (Entered: 12/20/2016)
12/22/2016 19 Consent MOTION for Extension of Time to File Response/Reply as to 15 MOTION to
Stay, 18 MOTION for Discovery by Johnny L. Hughes, Kevin Perkins, Rod J.
Rosenstein. (Attachments: # 1 Text of Proposed Order)(Phelps, Matthew) (Entered:
12/22/2016)
01/06/2017 20 RESPONSE in Opposition re 15 MOTION to Stay, 18 MOTION for Discovery filed
by Johnny L. Hughes, Kevin Perkins, Rod J. Rosenstein. (Attachments: # 1 Text of
Proposed Order)(Phelps, Matthew) (Entered: 01/06/2017)
01/12/2017 21 REPLY to Response to Motion re 15 MOTION to Stay and/or Toll Plaintiff's
Opposition to the Defendants' Forthcoming Response to the Complaint and 18
MOTION for Discovery filed by William C. Bond. (Attachments: # 1 Exhibit 1, # 2
Exhibit 2, # 3 Exhibit 3)(jnls, Deputy Clerk) (Entered: 01/12/2017)
04/12/2017 22 MEMORANDUM OPINION AND ORDER denying 15 Motion of plaintiff to Stay
and/or Toll Plaintiffs Opposition to the Defendants Forthcoming Response to the
Complaint; granting 16 Motion of USA to Dismiss ; granting 16 Motion of USA to be
substituted in place of individual Defendants as to the Federal Tort Claims Act ;
denying 18 Motion of plaintiff for Discovery; granting 19 Consent Motion of
defendants for an Extension of Time to Respond to Pending Motions. Signed by Judge
David A. Faber on 4/12/2017. (jnls, Deputy Clerk) (Entered: 04/12/2017)
04/12/2017 23 JUDGMENT ORDER. Signed by Judge David A. Faber on 4/12/2017. (c/m 4/12/17
jnls, Deputy Clerk) (Entered: 04/12/2017)
05/09/2017 24 MOTION to Reopen Case and to file an Amended Complaint by William C. Bond
(Attachments: # 1 Memorandum in Support, # 2 Amended Complaint, # 3 Redline
Amended Complaint, # 4 Exhibit 1, # 5 Exhibit 2, # 6 Exhibit 3, # 7 Exhibit 4, # 8
Exhibit 5, # 9 Exhibit 6, # 10 Exhibit 7, # 11 Exhibit 8, # 12 Exhibit 9, # 13 Exhibit
10, # 14 Exhibit 11, # 15 Exhibit 12, # 16 Exhibit 13, # 17 Exhibit 14, # 18 Exhibit 15,
# 19 Exhibit 16)(jnls, Deputy Clerk) (Entered: 05/09/2017)
05/23/2017 25 ORDER DENYING 24 Motion to Reopen Case and to File an Amended Complaint.
DENYING Plaintiff's Request to Vacate the Court's Memorandum Opinion and Order
and Judgment Order, ECF Nos. 22−23. Signed by Judge David A. Faber on 5/23/2017.
(c/m) (hmls, Deputy Clerk) (Entered: 05/23/2017)
06/20/2017 26 MOTION to Reopen Case and for Leave to File Second Amended Complaint by
William C. Bond (Attachments: # 1 Memorandum in support, # 2 Second Amended
Complaint, # 3 Redline Amended Complaint, # 4 Exhibit 1, # 5 Exhibit 2, # 6 Exhibit
3, # 7 Exhibit 4, # 8 Exhibit 5, # 9 Exhibit 6, # 10 Exhibit 7, # 11 Exhibit 8, # 12
Exhibit 9, # 13 Exhibit 10, # 14 Exhibit 11, # 15 Exhibit 12, # 16 Exhibit 13, # 17
Exhibit 14, # 18 Exhibit 15, # 19 Exhibit 16)(jnls, Deputy Clerk) (Entered:
06/21/2017)
07/05/2017 27 RESPONSE in Opposition re 26 MOTION to Reopen Case MOTION for Leave to
File filed by Johnny L. Hughes, Kevin Perkins, Rod J. Rosenstein. (Attachments: # 1
Text of Proposed Order)(Phelps, Matthew) (Entered: 07/05/2017)
07/19/2017 28 REPLY to Response to Motion re 26 MOTION to Reopen Case and for Leave to File
Second Amended Complaint filed by William C. Bond. (Attachments: # 1 Exhibit 1, #
JA003
2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8
Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Text of
Proposed Order)(jnls, Deputy Clerk) (Entered: 07/19/2017)
08/01/2017 29 MEMORANDUM OPINION AND ORDER denying 26 Motion to Reopen Case and
for Leave to File Second Amended Complaint by William C. Bond; denying Plaintiffs
request to vacate the courts Memorandum Opinion and Order and Judgment Order
already filed; the Clerk is directed not to accept any further motions to vacate the
courts opinion and order or to reopen this action. Signed by Judge David A. Faber on
8/1/2017. (c/m 8/1/17 jnls, Deputy Clerk) (Entered: 08/01/2017)
09/29/2017 30 NOTICE OF APPEAL as to 22 Memorandum and Order,,, Order on Motion to Stay,,,
Order on Motion to Dismiss/Lack of Jurisdiction,,, Order on Motion to Dismiss for
Failure to State a Claim,,, Order on Motion to Substitute Party,,, Order on Motion for
Discovery,,, Order on Motion for Extension of Time to File Response/Reply,, 23
Judgment, 29 Memorandum and Order,, Order on Motion to Reopen Case,, Order on
Motion for Leave to File, 25 Order on Motion to Reopen Case,, Order on Motion for
Leave to File, by William C. Bond. (kos, Deputy Clerk) (Entered: 09/29/2017)
09/29/2017 31 Transmission of Notice of Appeal and Docket Sheet to US Court of Appeals re 30
Notice of Appeal,,. IMPORTANT NOTICE: To access forms which you are required
to file with the United States Court of Appeals for the Fourth Circuit please go to
http://www.ca4.uscourts.gov and click on Forms & Notices.(kos, Deputy Clerk)
(Entered: 09/29/2017)
09/29/2017 Assembled Electronic Record Transmitted to Fourth Circuit −− Initial(kos, Deputy
09/29/2017 32 USCA Case Number 17−2150 for 30 Notice of Appeal,, filed by William C. Bond.
Case Manager − J. Moore (ko, Deputy Clerk) (Entered: 10/02/2017)
JA004
Case 1:16-cv-02723-JFM Document 1 Filed 07/29/16 Page 1 of 23
IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND __l{fl-
NORTHERN DIVISION
WILLIAM C. BOND
P.O. Box 4823 *
Baltimore, Maryland 21211,
*
Plaintiff prose,
* Civil Action No.:
V. J F N\i16 CV272 3
JOHNNY L. HUGHES
United States Marshal
United States Marshals Service
District of Maryland
101 West Lombard Street
and
KEVIN PERKINS
Special Agent in Charge
Federal Bureau of Investigation
Baltimore Field Office
2600 Lord Baltimore Dr.
Windsor Mill, MD 21244,
and
ROD J. ROSENSTEIN
United States Attorney
36 S. Charles St., Fourth Floor
Baltimore, MD 21201,
and
"UNKNOWN NAMED MARYLAND U.S. JUDGES"
JA005
c/o The Hon. Catherine C. Blake

Chief Judge
United States District Court
10 I West Lombard Street
Baltimore, Maryland 2120 I,
*
Defendants.
*
* * * * * * * * *
INTRODUCTION
The reporter slowed the small speedboat, then cut the engine off.
We were about a mile out from Baltimore's Inner harbor, where
the big cargo ships dropped anchor in the Patapsco River. The
early fall 2010 day was sunny, yet windy, the crisp sort of day
where shorts and a long sleeve polo over a T-shirt felt just right.
The reporter pulled out some beers and chips from a cooler,
"Cheers!" He said. "Now, tell me all about this meeting you had
with the Fourth Circuit judge."
"Sure," 1 answered, as the boat bobbed up and down in small

waves. "But, first, can you tell me why we're meeting in the midst
of hundreds of thousands of people in the middle of the Fell's
Point Fun Festival, and why we're talking way out here in the
middle of the harbor?"
"I wanted to see who's following you - and make sure that no one
can listen in on what we say ... "
COMPLAINT WITH DEMAND FOR JURY TRIAL
Comes now plaintiff, William C. Bond, pro se, (hereinafter "Plaintiff') and brings this lawsuit
against the United States Marshal for the District of Maryland, his office & officers; the Special
Agent in Charge of the United States Federal Bureau of Investigation for the District of
Maryland, his office & officers; the United States Attorney for the District of Maryland, his
JA006
office & officers; and the "Unknown Named Maryland U.S. Judges" of the United States District
Court for the District of Maryland,' including any residing Maryland U.S. circuit judges; all
acting in their 'individual capacities' (hereinafter "Defendants").
This is a civil action for civil rights relief alleging long-standing misconduct regarding the
misuse of the U.S. Marshals Service and the FBI, acting 'under the color of law,' at the direction
ofrogue Maryland Article III judges and the Maryland U.S. Attorney's Office, to violate
plaintiffs First Amendment & due process rights - all to cover up criminal & ethical judicial
misconduct, obstruction of justice, and systemic 'fraud upon the court' perpetrated against
plaintiff by the defendants.
Plaintiff brings this action under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971),
the First Amendment & due process clauses of the U.S. Constitution, and any other applicable
laws or rules.
JURISDICTION AND VENUE
Jurisdiction of this Court is invoked pursuant to 28 U.S.C. 1331.
Venue is proper in this Court pursuant to 28 U.S.C. 1391.
FACTS
JA007
I. Plaintiff is the only known prose litigant in U.S. jurisprudence history whom the U.S. DOJ
has ever joined to unseal one of their own criminal cases. 1
2. This 'Bromwell' action received much attention, both locally in Maryland, and nationally via
the Associated Press, in 2009-2010. 2
3. Nevertheless, the district court denied plaintiff his constitutional rights re: standing, then the
Fourth Circuit remained mute as to the blatant deprivation of plaintiffs constitutional rights.
4. Later, on the telephone, the Maryland U.S. Attorney's Office (hereinafter "USAO MD") told
plaintiff they would not do anything further to champion plaintiffs civil rights deprivation battle,
as they had been thoroughly chastised by the Maryland-based federal judges.
5. Disputing that, and wishing to know exactly why he was being targeted & treated 'differently'
than other litigants, plaintiff arranged to be 'invited' to meet with the sitting U.S. Fourth Circuit
judge who had been leading the denial of his civil rights since 2001. 3
1
Please see: U.S. v. Thomas L. Bromwell, Sr., et al., 05-cr-00358-JFM (D. Md.) & CA 4
no.: 09-7572.
2
Please see these two Maryland Daily Record news stories: ( 1)
https://www.scribd.com/document/136425369/Federal-prosecutors-willing-to-unseal-more-
Bromwell-docs-Maryland-Daily-Record-April-l0-2009 & (2)
https://www .scribd.com/document/136425931 /Bromwell-documents-to-remain-sealed-
Maryland-Dail y-Record-J uly-17-2009
3
Plaintiff later memorialized these summer 2010 meetings with the sitting U.S. Fourth
Circuit judge 'in detail' in a 2014 post-judgment appellate action in the 'Bromwell' case with a
'Motion for the Circuit Court to Recuse and Transfer." Please see: CA 4 no.: 14-6017 at docket
JA008
6. Soon after those meetings, in fall 2010, plaintiff filed a federal lawsuit against the U.S. DOJ
and others in the U.S. District Court for the District of Columbia alleging civil rights violations
4
based completely upon his in-person meetings with the sitting Fourth Circuitjudge.
7. Yet, more than a year later in 2011, then D.D.C. Chief Judge Royce C. Lamberth denied all
claims against the U.S. DOJ in a 34-page-long memorandum opinion that neglected in any way
to analyze plaintiffs facts regarding his meetings with the subject Fourth Circuit judge.
8. In late summer 2012, after the D.C. court denied reconsideration, plaintiff came right back
with these same 'judicial disability' facts and attacked the judgment in the 'Bromwell' case for a
second time, this time without the help of the USAO MD.
9. Many special interests groups and news presses, such as the Reporter's Committee for
Freedom of the Press, paid notice to this action and considered its merits.
10. Nevertheless, the 'Bromwell' judge denied any new analysis and threw the matter out of
court.
nos.: 9 & 15. The primary document can also be viewed here:
https ://www.scribd.com/ doc/2002 77 080/Bond-M oti on-to- Recuse-and- Transfer
4
The following news story about that lawsuit - which inspired the 'lntroduction' to this
complaint - also contains the 20 IO D.C. federal lawsuit & an earlier 2007-8 SCOTUS petition
for certiorari: http://www.citypaper.com/bcp-cms-l-l 061490-migrated-story-cp-20101 l JO-
mobs-20101 I JO-story.html
JA009
11. Fast forward to late 2013 & early 2014 - after plaintiff's first round of public courthouse
protest were completed, as described below - plaintiff, still not giving in to provable judicial
misconduct in the 'Bromwell' case, then took the matter back to the U.S. Fourth Circuit Court of
Appeals, first under the Crime Victim's Rights Act, then by appeal.
12. Ironically, because the 'Bromwell' judge had denied plaintiff his 'constitutional' standing in
2009, he was therefore never in the 'case' to suffer any 'victimhood,' as the Fourth Circuit then
opined, while ignoring all other issues relating to the underlying provable judicial misconduct
allegations. The 2014 appeal, likewise, had its merits ignored by the court.
13. Moving back in time, from late 2012 to early 2013, many impartial legal & news observers
5
were seeing clearly that plaintiff was the victim of persecution by the judicial establishment.
14. Plaintiff then made detailed criminal & judicial complaints about these matters to the Chief
Judge of the U.S. Fourth Circuit in late 2012 & early 2013, which the Chief Judge not only
ignored, but also returned to plaintiff in a plain brown envelope.
15. Having had enough of the judicial imperturbability shown toward plaintiffs allegations re:
the deprivation ofhis constitutional rights, plaintiff then decided to publicly protest the 'provable
corruption' in the Maryland U.S. courthouse at the courthouse itself.
5
ln fact, a former AUSA MD told plaintiff on the telephone that he "thought the days of judges
treating people the way plaintiff was being treated were long over."
JA010
16. Beginning in April 2013, plaintiff created a public relations campaign called 'Baltimore
Corruption Wire.'
17. This campaign was supported by Facebook, Twitter, YouTube, Scribd, Change.org, &
Fundrazr platforms.
18. The campaign was focused around an advertising slogan "ls the 'WHITE GUERRILLA
FAMILY' running the Maryland federal court?"
19. This ad campaign slogan ran in print and web formats in Baltimore's City Paper during
summer and fall 2013 to much notice. 6
20. Plaintiff also wrote an Op-Ed for the Baltimore Sun detailing what had transpired in the
'Bromwell' case titled "CORRUPTION Sub Curia."
21. When the Op-Ed was rejected over length concerns by the Sun's editors, plaintiff then made
the Op-Ed the center of his anti-federal-court-corruption activities, as it explained in detail how
6
The ads can be seen here: (I) https://www.scribd.com/doc/296483607/Corruption-Wire-
web-ad & (2) https://www.scribd.com/doc/296483897 /Corruption-Wire-print-ad
JA011
the Maryland federal court had become an upper class version of the notorious 'Black Guerrilla
Family' prison gang. 7
22. Needless to say, these activities attracted a lot of notice by Baltimore's close-knit legal elites.
23. Then, plaintiff announced a public protest schedule to begin August 4, 2013, at the Baltimore
U.S. courthouse, and publicly solicited the same citizens who would later become the
#BlackLivesMatter movement to join him to correct the provable corruption, and double
standards for rich & poor, in the Maryland U.S. courthouse, as evidenced by the secret self-
dealing which was provable fact in the 'Bromwell' case.
COUNTI
24. The first knock on your door from government law-enforcers is something one never forgets.
25. On July 19, 2013, and July 30, 2013, plaintiff was visited at his then-apartment by one
Deputy U.S. Marshal (hereinafter "DUSM") and by one FBI agent.
26. During the July 19, 2013, meeting, the federal agents wished to come inside plaintiff's
residence to "talk." As they had no 'search warrant,' plaintiff declined that request, but he did
agree to meet with the agents in a 'common room' of his then-apartment building.
7
Please see the Op-Ed here: https://www.scribd.com/doc/136418039/William-Bond-
CORRUPTION-Sub-Curia-op-ed.
JA012
27. The agents followed plaintiff to this 'common room' and acted, on guard, as if plaintiff was a
violent criminal ready to attack them.
28. Oddly, the DUSM voiced several times how much he had been looking forward to meeting
plaintiff.
29. The FBI agent, who led the questioning, peppered plaintiff with questions regarding the
potential safety of various government officials and federal judges, some of whom were former
neighbors of plaintiff, and one whose daughter used to babysit for plaintiffs stepchildren. 8
30. Plaintiff made it clear to the agents that their line of questioning had no basis in fact, that it
bordered on fantasy, and that plaintiff had made it clear his goal was to have certain judges
removed from the federal bench by either impeachment or forced resignation.
31. Nevertheless, the FBI agent asked repeatedly what could be done to make the scheduled
courthouse protests go away?
32. The second knock on your door from government law-enforcers provokes fear.
33. Why are they back?
8
Plaintiff is 52-years-old. He has no, nor has he ever had, a criminal record.
Nevertheless, plaintiff was later told by the DUSM that he was 'profiled' by FBI 'Profilers' and
JA013
34. Before plaintiff opened his then-apartment door on July 30, 2013, he asked the federal agents
outside if they had a warrant, which they, again, did not have.
35. When plaintiff opened his then-apartment door - staying within the threshold, this is what he
saw: Standing directly across from him was the same DUSM from the first visit, whom plaintiff
would later learn was the Chief of the Maryland U.S. Marshals Service's Protective Intelligence
Unit (hereinafter "USMS PIU"). To plaintiffs direct right, in a semi-ready-to-tackle-stance was
a different FBI agent than from the first visit, whom plaintiff would later learn was the FBI's
Supervisory Special Agent in charge of the Baltimore Field Office's 'Violent Crimes Unit.'
36. The federal agents demanded plaintiffs firearms, which plaintiff denied having.
37. The federal agents again requested to come inside plaintiffs then-apartment, which plaintiff
denied them permission to do.
38. Plaintiff then agreed to go speak with the federal agents in the same 'common room' as
before once plaintiff was repeatedly assured that the federal agents had no warrant to arrest
plaintiff.
declared a 'dangerous sociopath' who presented 'grave' danger to U.S. government officials.
Obviously, an impartial observer could view this analysis as self-serving rhetoric.
10
JA014
39. Again, plaintiff was followed to the 'common room' and treated again as ifhe were a violent
criminal ready to commence mayhem with the non-existent 'gats' the law-enforcers sought.
40. The new FBI agent, whose code name was "Undertaker," led the questioning. Again, were
any federal judges or government officials in any danger from plaintiff?
41. Where were plaintiffs guns? Where were plaintiffs guns? 1,000 times it was asked.
42. As all of plaintiff's firearms were confiscated in 2001 by the State of Maryland in a
purported criminal action (charges dismissed, record expunged), plaintiff proffered that they
should damn well know where the guns were.
43. Again, the FBI agent asked- holding some of plaintiffs 'White Guerrilla Family'
promotional literature in his hand - "What would it take to make this [the planned
demonstrations] go away?"
44. Plaintiff proffered to the FBI agent that the USAO MD was the one who should be asking
that question and that plaintiff was happy to meet with them re: same.9
9
Later, in fall 2013, the FBI agent would schedule, then cancel, a meeting between the
FBI, the USMS, & the USAO MD, to be held, as a courtesy, in a major law firm's Baltimore
conference room.
11
JA015
45. The FBI agent didn't like that answer, and stated that he was sent to interview plaintiff to
gather certain information and that he had to report back immediately - to whom, he would not
10
say.
46. As the agents left, they asked for the name of plaintiffs ex-wife so as to confirm that she was
in possession of firearms they believed plaintiff still possessed.
47. The USMS PIU manuals specifically speak about the unit being prohibited from using their
resources to violate the First Amendment rights of citizens.
48. Clearly, the timing of these visits, especially the attempt to arrest plaintiff for illegal weapons
possession, was intended with one goal and one goal only in mind: to prevent and/or to
intimidate plaintiffs planned demonstrations at the Baltimore U.S. courthouse on August 4,
2013.
49. These intentional, knowing, bad-faith, and illegal acts by the defendants caused plaintiff
great worry, anxiety, fear, sleeplessness, etc., amongst many other things, as it was clear to
plaintiff that his enemies would stop at nothing to defeat his constitutional rights.
10
On information and belief, the "Unknown Named Maryland U.S. Judges" were
independently operating & controlling the subject government agents outside of the normal U.S.
DOJ 'chain-of-command.'
12
JA016
50. Wherefore, for the aforementioned illegal conduct, plaintiff seeks $15,000,000 from the
defendants for compensatory damages, and $30,000,000 from the defendants for punitive
damages.
COUNT II
51. A 'black lives matter' type activist contacted plaintiff on July 14, 2013, after plaintiff
announced his U.S. courthouse demonstration schedule on Facebook.
52. This 'activist' claimed to be interested in plaintiffs 'Baltimore Corruption Wire' entity, and
especially in plaintiffs planned U.S. courthouse demonstrations.
53. This 'activist' and plaintiff communicated via Facebook and on the telephone multiple times.
54. Of note, the 'activist' was offering to help with the planned protests, including by providing
'bodies' to protest, money for advertising, and grassroots help in the 'black' community so as to
'take down' the corrupt judges in the Maryland U.S. courthouse.
55. On July 20, 2013, the 'activist,' his 'wife,' and plaintiff met at a North Baltimore cafe for
three (3) hours to discuss plaintiffs planned U.S. courthouse demonstrations.
56. The 'activist' and his 'wife' spent much time asking plaintiff, in great detail, about his life
story, including attempting to solicit harmful intentions toward the subject U.S. judges.
13
JA017
57. The 'activist' and his 'wife' spent much time offering their time, help, money, grassroots
organizing abilities, and, most importantly, 'bodies' to protest at the planned U.S. courthouse
protests.
58. The 'activist' and his 'wife' guaranteed at least fifty (50) 'bodies' to protest, with as many as
'several hundred' to be added to that number.
59. There were many Facebook and telephone conversations with the 'activist' regarding the
upcoming protests and what his contributions would be.
60. Nevertheless, when the first planned U.S. courthouse protest day arrived, the 'activist,' his
'wife,' his 'bodies,' nor any other support, were no where to found.
61. On information and belief, the 'activist' and his 'wife' were undercover U.S. government
agents sent (1) with the clear intention to sabotage plaintiffs U.S. courthouse protests in any way
possible and (2) to criminally entrap plaintiff by attempting to engage plaintiff in discussions of
violence against federal officials, even though plaintiff has always insisted that the misbehaving
Maryland federal judges should be held accountable, publicly, under the law and rules.
14
JA018
damages.
COUNT III
64. The protests began on August 4, 2013.
65. At first, they were planned only for once a month.
66. But, after the judge for whom the 'White Guerrilla Family' gang was named actually visited
the protests to admire the protest signage he inspired, the protest schedule was moved to a mostly
weekly event at the Baltimore U.S. courthouse though late fall 2013.
67. During these protests, plaintiff was always supervised by the DUSM PIU agent and also
often by Federal Protection Service officers, sometimes in full SWAT gear.
68. Naturally, the DUSM and plaintiff became acquainted, especially as the DUSM had claimed
he had long-wanted to meet plaintiff.
15
JA019
69. Soon, the DUSM came to see that plaintiff was no 'sociopath' as the U.S. DOJ profilers had
attempted to 'mark' him, but as a "lover," not a "fighter" who just wanted to "go back to the
country club."
70. Plaintiff and the DUSM spent much time chatting at the U.S. courthouse during plaintiff's
11
demonstrations.
71. Plaintiff also learned, while chatting with federal law-enforcers during his protests, that the
'judges' were misusing the U.S. Marshal's indoor courthouse gun range. 12
72. Several times the DUSM explained that the reason he had always wanted to meet plaintiff
was because of his particular letter writing abilities, letters which acted as 'prosecutions' of
certain 'judges' and other government officials.
73. When plaintiff queried how long this desire had existed, the DUSM explained that he had
been surveilling plaintiff since 2010, since his D.C. lawsuit was filed against the Maryland U.S.
Attorney.
11
The DUSM was convinced (as the government's 'expert' on plaintiff) that plaintiff was
in the "right" and that he had "gotten f"*ked-over by the 'judges,"' which was a statement he
made many times.
12
This information became a qui tam lawsuit. Please see: 15-cv-00199-DAF (D. Md.)
16
JA020
74. Frankly, this revelation surprised plaintiff very much, as he had thought the reporter's
precautions in 2010, as 'suggested' in the introduction to this lawsuit were a joke.
75. It is a clear due process violation for a government entity to spy upon a citizen who is suing
the government.
76. This act is also a violation of the rules of court, which government attorneys must also
follow.
damages.
COUNTIV
17
JA021
79. The DUSM also told plaintiff about how his surveillance of plaintiff continued in 2012, after
plaintiff had lost his home, his dog, all his possessions, etc., and was living in an unelectrified
'squat' in a derelict building. 13
80. As this surveillance came as plaintiff was attacking the 'Bromwell' case the second time in
summer 2012, clearly the intention by the government was the unconstitutional deprivation of
plaintiffs due process and civil rights.
81. On information and belief, this continued surveillance, which, as already stated, began in
2010, and has, on information and belief, continued until this day, has consisted of electronic
monitoring of plaintiffs communications, including telephone and internet communications, all
with the intention of interfering with plaintiffs public protests and his public policy legal
activities, including lawsuits against government actors.
damages.
13
Plaintiffs then & present negative financial situation was & is the direct & intended
18
JA022
COUNTV
84. On September 29, 2015, while visiting the Baltimore U.S. courthouse, plaintiff was subjected
to an effort by the DUSM to invade his pro se litigant work product in the qui tam case
mentioned above, in violation of the rules of court.
85. That same day and time, plaintiff was also subjected to an effort by the DUSM, working in
tandem with the U.S. judge who was the model for the 'White Guerrilla Family' ad campaign, to
criminally entrap plaintiff. 14
damages.
COUNT VI
consequence of his persecution by the defendants in this case.

14
These acts are described in full in case no.: 15-cv-00199-DAF (D. Md.) at docket nos.:
16 & 20.
19
JA023
88. The defendants have at all times since 200 I until present been in an extended conspiracy to
deprive plaintiff of his First Amendment & due process rights, his liberty, and his right to his
own property, if not other constitutional deprivations.
89. This conspiracy includes a federal judge seeking out with malice aforethought to have a 2001
15
federal case assigned to him, which he planned, in advance, to sabotage.
90. At least two U.S. judges then actively participated in covering up that criminal act.
91. Those same judges then participated in sabotaging, then helped to 'fire' a sitting U.S.
attorney who, in 2004-5, was investigating the alleged crime & its related acts as described in 'l]
89.
92. When a new U.S. attorney was assigned to Maryland in 2006, part of his assignment was to
continue to ignore and/or cover-up the aforementioned conspiracy against plaintiff.
93. When plaintiff, years later in 2007, tried to correct the damages resulting from the conspiracy
against him by commencing a prose 'attack upon the judgment' of the 2001 case, the same three
16
(3) U.S. judges, at minimum, continuing the conspiracy, thwarted his actions repetitiously.
15
Please see: Case no.: Ol-cv-2600-MJG (D. Md.).
16
Please see: Case nos.: 07-cv-1385-JFM (D. Md.) & 07-cv-1188- WDQ (D. Md.).
20
JA024
94. In the 2009 'Bromwell' case, the USAO MD saw with their own eyes the result of the
continuing conspiracy against plaintiff.
95. Yet, no one in the USAO MD would act in any way to see that plaintiff's constitutional rights
were enforced.
96. In fact, as described in this lawsuit, the USAO MD, along with other U.S. DOJ agencies,
became co-conspirators against plaintiff - switching sides - then siding with the same rogue
federal judges whom the former U.S. attorney had previously investigated.
97. The judiciary, the government, and the bar, are supposed to form an adversarial triangle
based upon the rules and the law, without which our American judicial system cannot function.
98. The constitutional violations in this conspiracy against plaintiff are far bigger than plaintiff,
as they affect every single citizen of the state of Maryland.
99. That not one person in a position of power to help plaintiff would do so is a stain upon the
Maryland U.S. Court, the USAO MD, & the Maryland Bar. 17
17
Plaintiff repeatedly asked both the FBI & the USMS, who seemed, ironically, to be the
only entities with any empathy toward plaintiff, to help plaintiff, and to report the clear
constitutional violations against plaintiff to their superiors. Nevertheless, it would appear that the
"Brotherhood of the Robe" is far stronger in Maryland than anyone cares to admit. Please see:
Williams-Yulee v. Florida Bar, 575 U.S._ (2015); Scalia, J., dissenting, page 13.
21
JA025
plaintiff that his enemies would stop at nothing to defeat his constitutional rights. In addition,
plaintiff has had his reputation absolutely destroyed by the defendants' imperturbable and
unconstitutional long term treatment of him.
damages.
REQUEST FOR EXPEDITION
Civil rights actions are to be given preference in the Fourth Circuit. Because of the great length
of time these matters have continued, the great harm caused plaintiff, and the exigent harm still
existing for the general public, plaintiff requests that this court issue an expedited briefing
schedule in this case as soon as possible.
DEMAND FOR A JURY TRIAL
Plaintiff demands that this case be tried before a Jury.
Respectfully submitted,
WILLIAM C. BOND
22
JA026
Pro Se
P.O. Box 4823
Baltimore, Maryland 21211
(443) 970-2887
proselitigator@aol.com
23
JA027
JS 44 (Rev. 07116) CIVIL
Case 1:16-cv-02723-JFM COVER1-1
Document SHEET
Filed 07/29/16 Page 1 of 1
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form. approved by the Judicial Conference of the United States in September 1974, is required for the use ohhc Clerk of Coun for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THFSFORM.) :; ~ ~ ' ..:;. : '-;:;. . I (.
I. (a) PLAINTIFFS DEFENDANTS
William C. Bond JfM16CV2723 Mr. Johnny L. Hughes

2G:::i
...1~- ~)9 P:-:f2: 28
(b) County of Residence of First Listed Plaintiff Baltimore, Maryland County of Residence of First Listed Defendant Baltimore, Maryland
(EXCEPTIN U.S. PI.Afr,.TfFF CASES) ON U.S.PL4/NTJFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE 'fHE LOCATION OF
THE TRACT OF LAND INVOLVED. - .
i;-1~
(c) Attorneys (Finn Na.me. Addre.1"$.and Telephone Number) Attorneys (I/Known) d •--~- __
William C. Bond, prose, P.O. Box 4823, Baltimore, MD 21211 (443) Allen F. Loucks, U.S. Attorney's Office, District of Maryland
970-2887
II. BASIS OF JURISDICTION (P(ac,aa "X"iaOaeBoxOah') Ill. CITIZENSHIP OF PRINCIPAL PARTIES (Pfor, oe ·'X" (a Os, Bmfo, Plaintiff
( For Dil-ersity Cases Only) and One Box for Defendant)
0 J U.S. Government ~ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Gm'ernmenr Not a Pany) Citizen of This State l'X 1 0 Incorporated or Principal Place O 4 0 4
of Business In This State
0 2 U.S. Govemmem 0 4 Diversity Citizen of Another State 0 2 0 2 Incorporated and Principal Place 0 5 0 5
Defendant (fndirn1e Citi;:.enship of Parries in Item lfF> of Business ln Another St.ate
Citizen or Subject of a 0 J 0 ] Foreign Nation 0 6 0 6

Forci n Countrv
IV NATURE OF SUIT (Place an ''X'' inOneBorOnlv)
t TORTS FORFEITURE/PENALTY BANKRUPTCY OTHERSTATUTE.S I
CONTRACT
Cl 110 Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 0 375 False Claims Act
Cl 120 Marine 0 310 Airplane 0 365 Personal Injury - of Property 21 USC 881 0 423 Withdrawal 0 376 Qui Tam (31 USC
Cl 130 Miller Act 0 315 Airplane Product Product Liability 0 6900ther 28 use 151 3729(a))
Cl 140Negotiable Instrument Liability 0 367 Health Care/ Cl 400 State Reapponionment
0 150 Recovery of Overpayment 0 320 Assault. Libel & Phannaceutical p· RI 0 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 0 820 Copyrights 0 430 Banks and Banking
0 151 Medicare Act 0 330 Federal Employers· Product Liability 0 830 Patem 0 450 Commerce
0 152 Recovery of Defaulted Liability 0 368 Asbestos Personal 0 840 Trademark 0 460 Deportation
0
Studelll Loans
(Excludes Veterans)
153 Recovery of Overpayment
0 340 Marine
• 345 Marine Product
Liability
Injury Producl
Liability
PERSONAL PROPERTY
. R
0 710 Fair Labor Standards 0 861
IA EC
l-DA ( ! 395ff)
TY
0
0
470 Racketeer influenced and
Corrupt Organizations
480 Consumer Credit
ofVeteran·s Benefits O 350 Motor Vehicle 0 370 Other Fraud Act 0 862 Black Lung (923) 0 490 Cable/Sat TV
0 160 Stockholders· Suits 0 355 Mo1or Vehicle 0 371 Truth in Lending 0 720 Labor/Management 0 863 DIWC/DIWW (405{g)) 0 850 Securities/Commodities/
0 J90 Other Contracl Product Liability 0 380 Other Personal Relations 0 864 SSID Title XVI fachange
0 195 Contract Product Liability 0 360 01her Personal Property Damage 0 740 Railway Labor Act 0 865 RSI (405(g)) Cl 890 Other Statutory Actions
0 196 Franchise Injury 0 385 Property Damage 0 751 Family and Medical 0 891 Agricultural Acts
0 362 Personal Injury - Product Liabili1y Leave Act 0 893 Environmenial Matcers
Medical Mal,.....ctice 0 7900ther Labor Litigation 0 895 Freedom of lnfonnation
I REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 0 791 Employee Retircmenl FEDERAL TAX SUITS Act
0 210 Land Condemnation IX440Other Civil Rights Habeas Corpus: Income Security Ace O 870 Taxes (U.S. Plaintiff 0 896 Arbiu-ation
0 220 Foreclosure O 441 Voting 0 463 Alien Detainee or Defendanl) 0 899 Adminisu-ative Procedure
0 230 Rent Lease & Ejectment 0 442 Employment 0 510 Motions to Vacate 0 871 IRS-Third Party ActJReview or Appeal of
0 240Torts to Land 0 443 Housing/ Sentence 26USC7r:t:IJ Agency Decision
0 245 Tort Product Liability Accommodations .:J 5~0 General 0 950 Constitutionality of
0 290 All Other Real Property 0 445 Amer. w/Disabilicies • 0 535 Death Penal_ty IMMIGRATION State Statutes
Employment Other: 0 462 Naturalization Application
0 446 Amer. w/Disabilities - 0 540 Mandamus & Other 0 465 Other Immigration
0 550 Civil Rights Actions
°'""
0 448 Education 0 555 Prison Condition
0 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an "X" in One Box 011!_1·)

~I Original • 2 Removed from 0 3 Remanded from 0 4 Reinstated or 0 5 Transferred from 0 6 Multidistrict 08 Multidistrict
Proceeding State Court Appellate Court Reopened Another Distric1 Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do 11otci,!_ejurisdictionalstatuJes rurlessdiversiJy):
Bivens v. Six Unknown Named A ents, 403 U.S. 388 1971 _______________
VI. CAUSE OF ACTION i-.::::.:;:;:::::....c:..=c=::.::.::::.:.:.:..:..:..:::::.:.:.::.::.:..;;==.=..:::..:::.:....:::::.:::.:c:.:.:c..:.L _
Brief descrip1ion of cause:
Constitutional deprivation of rights under color of law by defendants toward plaintiff
Vil. REQUESTED IN 0 CHECK IF THIS IS A CLASS ACTION DEMAND$ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 225,000,000.00 JURY DEMAND: J!I:Yes O No
VIII. RELATED CASE(S)
(Set' ifLl'tnicrions):
IF ANY JUDGE Hon. David A. Faber DOCKET NUMBER 15-cv-00199-DAF (D. Md.)
DATE SIGNATURE OF ATTORNEY OF RECORD
07/29/2016
FOR OFFICI! USE ONLY
RECEIPT# AMOUNT APPLYING IFP JA028

------
JUIXiE
-----
MAG. JUDGE
--------
Case 1:16-cv-02723-JFM Document 1-2 Filed 07/29/16 Page 1 of 8
AO 440 (Rev. 06/12) Summons in a Civil Action
·, UNITED STATES DISTRICT COURT

for the
William C. Bond )
)
)
)
Plaintifft.s)
)
)
V. Civil Action No.
)
Johnny L. Hughes, et al., )
)
)
)
Defendant( s) )
SUMMONS IN A CIVIL ACTION
To: (Defendant's name and address) KEVIN PERKINS

Special Agent in Charge
FBI - Baltimore Field Office
Windsor Mill, MD 21244
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) - or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) - you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
whose name and address are:
WILLIAMC. BOND
P.O. Box 4823
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
JA029
AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This sumffions for (name of individual and title, if any)

was received by me on (date/
0 I personally served the summons on the individual at (place)

on (date) ; or
0 I left the summons at the individual's residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
-------------------
on (date) ' and mailed a copy to the individual's last known address; or
--------
0 I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of (name of organization/
on (date) ; or
0 I returned the summons unexecuted because ; or
0 Other (specifj):
My fees are$ for travel and $ for services, for a total of$ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server ·s signature
Printed name and title
Server's address
Additional information regarding attempted service, etc:
JA030
.. AO 440 (Rev. 06/12) Summons in a Civil Action
UNITED STATES DISTRICT COURT

for the
)
William C. Bond
)
)
)
Plaintiff(s)
)
)
V. Civil Action No.
)
)
)
)
Defendant(s) )
To: (Defendant's name and address) ROD J. ROSENSTEIN

36 S. Charles St., Fourth Floor
Baltimore, MD 21201
Within 2 I days after service of this summons on you (not counting the day you received it) - or 60 days if you
P. 12 (a)(2) or (3) -you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
WILLIAMC. BOND
P.O. Box 4823
You also must file your answer Ur motion with the court.
CLERK OF COURT
Date:
JA031
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
This summons for (name of individual and title, if any)

was received by me on (date)

on (date) ; or
------------------------
------------------
on (date) , and mailed a copy to the individual's last known address; or
--------

designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
---------
----------------------
0 Other (specify):
Date:
Server's signature
Printed name and tirle
Serw!r ·,\'addri!S.I'
JA032
• UNITED STATES DISTRICT COURT

for the
)
William C. Bond
)
)
)
Plaintiff( s)
)
)
V. Civil Action No.
)
)
)
)
Defendant(s) )
To: (Defendant's name and address) JOHNNY L. HUGHES

United States Marshal
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
WILLIAM C. BOND
P.O. Box 4823
CLERK OF COURT
Date:
Signalure of Clerk or Deputy Clerk
JA033
AO 440 {Rev. 06/12) Summons in a Civil Action (Page 2)
• Civil Action No.

'
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (/))
This summons for (name of individual and title, if any)

0 I personally served the summons on the individual at /place)

on (date) ; or

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

------------------
on (date) ; or
------------------------ ----------
0 Other (specify):
My fees are$ for travel and$ for services, for a total of$ 0.00
Date:
Server's signature
Server's address
JA034
• Case 1:16-cv-02723-JFM Document 1-2 Filed 07/29/16 Page 7 of 8
r
UNITED STATES DISTRICT COURT
for the
William C. Bond )
)
)
)
Pfaintif.ft.s)
)
)
V. Civil Action No.
)
)
)
)
Defendant( s) )
To: (Defendan(s name and address) "UNKNOWN NAMED MARYLAND U.S. JUDGES"
c/o The Hon. Catherine C. Blake, Chief Judge
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
WILLIAM C. BOND
P.O. Box 4823
CLERK OF COURT
Date:
JA035
• Case 1:16-cv-02723-JFM Document 1-2 Filed 07/29/16 Page 8 of 8
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (1))
This summons for (name of indh:idual and title, if any)


on (date) ; or
------------------
--------

on (date) ; or
0 Other (specify):
Date:
Sen 1er's signature
Sen er's address

1
JA036
Case 1:16-cv-02723-DAF Document 15 Filed 12/08/16 Page 1 of 2
FIL EU
., If~$.OJSTRiCT ccunr
, ,!2 l RICTDF 1-1;\FYL//-~;1
William C. Bond
Pro Se Litigation 2016
DEC-8 AM!O:34
P.O. Box 4823
443.970.2887
December 7, 2016
The Hon. David A. Faber via: FedEx

Senior United States District Judge
Clo Clerk
IOI West Lombard Street

Clo Chambers ·
2303 Elizabeth Kee Federal Building
60 I Federal Street
Bluefield, West Virginia 24701
RE: Civil Action No.: 16-02723-DAF
Dear Judge Faber:
I write to you about the above-titled case. While I believe a letter is the appropriate form for this
action, I ask that the court consider the following as a Motion to Stay and/or Toll Plaintiff's
Opposition to the Defendants' Forthcoming Response tci the Complaint.
This letter concerns the court's December 5, 2016, order at docket number 14.
The parties are by now all acquainted. The court is precise in its language in plaintiffs
experience. In its order, the court stated:" ... a scheduling order will not be entered until
defendants have responded to the complaint." (Emphasis added.)
The literal meaning of"until" as the court has used the word is "until such time as" [the]
"defendants have responded to the complaint."' Therefore, plaintiff reads the court's order as
1
Please see: https:llwww.merriam-webster.com/dictionaryluntil
JA037
stating that once the defendants have responded, the court will then issue its scheduling order as
required under FRCP 16.
Plaintiff has already stated to the court why the scheduling order is necessary in this case at
docket number I 2. The served defendants countered those arguments at docket number 13 by
pleading nonexistent 'custom' 2 and 'economy.'
The government's 'economy' stance reminds plaintiff of when rural game wardens show up one
day to tell a country homeowner his loyal dog has been out running deer with a neighborhood
pack when the man is off at work earning the dog's dinner while neglecting to tell the
homeowner - next time the dog gets put down by a bullet. The government, long used to getting
away from plaintiffs quicksand, has come to believe it is made of concrete. The government
believes it is 'economical' for an amended complaint to be filed and summons to be issued
naming numerous Maryland U.S. judges & honorable U.S. law enforcers,3 and listing their
alleged misdeeds in minute detail. The government believes that plaintiff, pro se, has not already
made a prima facie jury question as to whether government law enforcers attempted to
manufacture a handgun charge against plaintiff to prevent his 2013 U.S. courthouse
demonstrations.
Plaintiff states again to the court that the above is the antithesis of 'economy,' and the most
'economical' path the court can take in this matter is to set a discovery schedule before any
amended complaint is due. 4 Therefore, plaintiff respectfully requests that the court stay and/or
toll any opposition to the defendants' forthcoming response to his complaint until the court has
5
issued its scheduling order.
Thank you very much for your consideration.
I hope this letter finds you well.
Very truly yours,
William C. Bond
cc: Matthew P. Phelps, AUSA, USAO MD via: Email

Allen F. Loucks, Chief, Civil Division, USAO MD via: Email
2
How can such a 'custom' exist when it violates the FRCP and the Local Rules are
silent?
3
The court already knows that plaintiff is fond of several government law enforcers who
are also former military officers, despite underlying matters.
4
Plaintiff would actually welcome discovery being covered by a protective order.
5
As time is critical under the FRCP, and the holidays are fast approaching, plaintiff
requests an immediate ruling on this motion.
JA038

DISTRICT OF MARYLAND
WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
JOHNNY L. HUGHES, et al., *
*
Defendants.
*
* * * * * * * * * * * * *
DEFENDANTS’ MOTION TO SUBSTITUTE AND TO DISMISS
Defendants, Johnny L. Hughes, Kevin Perkins, and Rod J. Rosenstein, by their undersigned
attorneys and pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure,
submit this Motion to Substitute and to Dismiss, and in support thereof state as follows:
1. Plaintiff filed the instant action for “civil rights relief” pursuant to Bivens v. Six
Unknown Named Agents, 403 U.S. 388 (1971). (ECF No. 1).
2. Plaintiff’s Bivens claims fail to establish this Court’s subject matter jurisdiction,
and fail to state a claim upon which relief can be granted. Accordingly, his Complaint must be
dismissed.
3. To the extent that Plaintiff’s Complaint can be construed as alleging a tort claim
under the Federal Tort Claims Act, the United States should be substituted as the sole defendant
and the Complaint should be dismissed for lack of subject matter jurisdiction.
4. In support of its Motion, Defendants incorporate the attached Memorandum of
Law, and all of the exhibits thereto.
JA039
WHEREFORE, Defendants respectfully request that the Court dismiss Plaintiff’s
Complaint, or in the alternative, substitute the United States as the sole Defendant and dismiss the
Complaint.
Rod J. Rosenstein
_________/s/____________________
Matthew P. Phelps, No. 17933
Assistant United States Attorney
United States Attorney’s Office
36 S. Charles Street, 4th Floor
(410) 209-4800
matthew.phelps@usdoj.gov
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of December, 2016, I filed the foregoing using
the CM/ECF system and also served a copy on Plaintiff via first-class mail to the following:
William C. Bond
PO Box 4823
Baltimore, MD 21211
__________/s/_____________________
Matthew P. Phelps
JA040
Case 1:16-cv-02723-DAF Document 16-1 Filed 12/13/16 Page 1 of 11

WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
*
Defendants.
*
* * * * * * * * * * * * *
DEFENDANTS’ MEMORANDUM OF LAW IN SUPPORT OF THEIR

MOTION TO SUBSTITUTE AND TO DISMISS
Defendants, U.S. Marshal Johnny L. Hughes, F.B.I. Special Agent in Charge Kevin
Perkins 1 (“SAC Perkins”), and U.S. Attorney Rod J. Rosenstein (“U.S. Attorney Rosenstein”), by
their undersigned attorneys and pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of
Civil Procedure, submit this Memorandum of Law in Support of their Motion to Substitute and to
Dismiss.
I. INTRODUCTION
Plaintiff filed the instant action for “civil rights relief” pursuant to Bivens v. Six Unknown
Named Agents, 403 U.S. 388 (1971). Plaintiff is known to conduct protests outside the United
States District Courthouse in Baltimore, Maryland. As a result of his protests, Plaintiff alleges that
federal agents have acted to violate his First Amendment and due process rights. As discussed in
1
SAC Perkins was the Special Agent in Charge of the Baltimore Field Office from August 2015
to September 2016. SAC Perkins is now retired from the FBI.
1
JA041
detail below, Plaintiff’s Complaint must be dismissed because it fails to state a claim against the
Defendants, and it has failed to establish this Court’s subject matter jurisdiction.
II. FACTUAL BACKGROUND
For several years, Plaintiff has engaged in protests against what he claims to be “‘provable
corruption’ in the Maryland U.S. courthouse.” (Compl. ¶ 15). In April 2013, Plaintiff created a
public relations campaign called the “Baltimore Corruption Wire,” and created the phrase “White
Guerilla Family” to refer to certain members of the Maryland federal judiciary. (Id. ¶¶ 61, 18.)
As a result of his protests and allegations of corruption, Plaintiff alleges that he has been
interviewed and surveilled by federal agents. Plaintiff alleges that members of the judiciary and
other federal officials have conspired to violate his First Amendment and due process rights. (See
id. ¶ 88.) Specifically, Plaintiff alleges the following six unconstitutional acts:
• Count I – On July 19, 2013 and July 30, 2013, federal agents questioned
plaintiff “regarding the potential safety of various government officials and
federal judges,” in an attempt to “prevent and/or to intimidate plaintiff’s
planned demonstrations . . . .” (Id. ¶ ¶ 25-48.)
• Count II – Plaintiff alleges that he met with “activists” in July of 2013 to plan
a protest at the U.S. District Courthouse, but that the activists “were undercover
U.S. government agents sent (1) with the clear intention to sabotage plaintiff’s
U.S. courthouse protests in any way possible and (2) to criminally entrap
plaintiff by attempting to engage plaintiff in discussions of violence against
federal officials[.]” (Id. ¶¶ 51-61.)
• Counts III & IV – Plaintiff alleges in the fall of 2013, a Deputy U.S. Marshal
informed Plaintiff that he had been under surveillance since 2010. Plaintiff
alleges that this surveillance violated his constitutional rights. (Id. ¶¶ 64-81.)
• Count V –Plaintiff alleges that on September 29, 2015, a Deputy U.S. Marshal
“invade[d]” his pro se litigant work and attempted to criminally entrap him.”
(Id. ¶¶ 84-85.)
• Count VI – Plaintiff alleges that the Defendants “have at all times since 2001
until present been in an extended conspiracy to deprive plaintiff of his First
Amendment & due process rights,” and that “[w]hen a new U.S. Attorney was
assigned to Maryland in 2006, part of his assignment was to continue to ignore
JA042
and/or cover-up the aforementioned conspiracy against plaintiff.” (Id. ¶¶ 88-

92.)
With respect to each count, Plaintiff alleges that “[t]hese intentional, knowing, bad-faith, and
illegal acts by the defendants caused plaintiff great worry, anxiety, fear, sleeplessness, etc.,
amongst many other things, as it was clear to plaintiff that his enemies would stop at nothing to
defeat his constitutional rights.” (See, e.g., id. ¶ 100.)
III. STANDARD OF REVIEW
A. Rule 12(b)(1)
A motion to dismiss for lack of subject matter jurisdiction under Federal Rule of Civil
Procedure 12(b)(1) raises the issue of “whether the court has the competence or authority to hear
the case.” Davis v. Thompson, 367 F. Supp. 2d 792, 799 (D. Md. 2005). A federal court generally
may not reach the merits of a case without first determining that it has jurisdiction over the claim
in suit. See Sinochem Int’l Co. Ltd. v. Malaysia Int’l Shipping Corp., 549 U.S. 422, 430-31 (2007)
(citing Steel Co. v. Citizens for Better Env’t, 523 U.S. 83, 93-102 (1998)). When a defendant
moves to dismiss under Rule 12(b)(1), the plaintiff bears the burden of proving that subject matter
jurisdiction exists. Evans v. B.F. Perkins Co., 166 F.3d 642, 647 (4th Cir. 1999) (citing Richmond,
Fredericksburg & Potomac R.R. Co. v. U.S., 945 F.2d 765, 768 (4th Cir. 1991)). The requirement
that the plaintiff establish subject matter jurisdiction “as a threshold matter ‘springs from the nature
and limits of the judicial power of the United States’ and is ‘inflexible and without exception.’”
Steel Co., 523 U.S. at 94- 95 (quoting Mansfield, C. & L. M. R. Co. v. Swan, 111 U.S. 379, 382
(1884)). For that reason, “[t]he objection that a federal court lacks subject-matter jurisdiction may
be raised by a party, or by a court on its own initiative, at any stage in the litigation, even after trial
and the entry of judgment.” Arbaugh v. Y & H Corp., 546 U.S. 500, 506 (2006) (citing Fed. R.
Civ. P. 12(b)(1)).
JA043
When a defendant challenges subject matter jurisdiction, “the district court is to regard the
pleadings as mere evidence on the issue, and may consider evidence outside the pleadings without
converting the proceeding to one for summary judgment.” Evans, 166 F.3d at 647 (quoting
Richmond, Fredericksburg & Potomac R.R. Co., 945 F.2d at 768); see also Williams v. U.S., 50
F.3d 299, 304 (4th Cir. 1995) (In considering exhibits outside the pleadings, the court “is free to
weigh the evidence and satisfy itself as to the existence of its power to hear the case.”) (internal
quotation omitted). That is, upon a Rule 12(b)(1) motion, “the court may look beyond the
pleadings and the jurisdictional allegations of the complaint and view whatever evidence has been
submitted on the issue to determine whether in fact subject matter jurisdiction exists.” Khoury v.
Meserve, 268 F. Supp. 2d 600, 606 (D. Md. 2003) (quotation omitted), aff’d, 85 Fed. App’x 960
(4th Cir. 2004). The court may properly grant a motion to dismiss for lack of subject matter
jurisdiction “where a claim fails to allege facts upon which the court may base jurisdiction.” Davis,
367 F. Supp. 2d at 799 (citing Crosten v. Kamauf, 932 F. Supp. 676, 679 (D. Md. 1996)).
B. Rule 12(b)(6)
A motion under Rule 12(b)(6) challenges the legal sufficiency of a complaint. See Edwards
v. Goldsboro, 178 F.3d 231, 243 (4th Cir. 1999). To survive a Rule 12(b)(6) motion, the complaint
must assert facts sufficient to “state a claim to relief that is plausible on its face.” Bell Atlantic v.
Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff pleads
factual content that allows the court to draw the reasonable inference that the defendant is liable
for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “But where the well-
pleaded facts do not permit the court to infer more than the mere possibility of misconduct, the
complaint has alleged-but it has not ‘show[n] – ‘that the pleader is entitled to relief.’” Id. at 679
(quoting FED. R. CIV. P. 8(a)(2)).
JA044
In ruling on a 12(b)(6) motion, the Court must accept “all well-pleaded allegations in the
plaintiff’s complaint as true” and draw all reasonable inferences in plaintiff’s favor. Edwards, 178
F.3d at 244. The Court, however, does not need to accept any fact inconsistent with the
complaint’s allegations or “unwarranted inferences, unreasonable conclusions, or arguments.”
Eastern Shore Markets, Inc. v. J.D. Assoc’s, Ltd. P’Ship, 213 F.3d 175, 180 (4th Cir. 2000); see
also Iqbal, 556 U.S. at 678 (“the tenet that a court must accept as true all of the allegations
contained in a complaint is inapplicable to legal conclusions”); Twombly, 550 U.S. at 555 (a
plaintiff must provide “more than labels and conclusions, and a formulaic recitation of the elements
of a cause of action will not do”).
IV. MOTION TO DISMISS
A. Plaintiff has not stated a Bivens claim against the Defendants in their
individual capacities.
Plaintiff cited Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971) as authority for
his cause of action. In Bivens, the Supreme Court recognized a private cause of action for certain
constitutional violations because “[t]he very essence of civil liberty certainly consists in the right
of every individual to claim the protection of the laws, whenever he receives an injury.” Bivens,
403 U.S. at 397 (quoting Marbury v. Madison, 5 U.S. (1 Cranch) 137, 163, 2 L.Ed. 60 (1803)).
Plaintiff’s Bivens claim, however, must state sufficient “factual content that allows the court to
draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556
U.S. at 678. In this regard, Plaintiff “must plead that each Government-official defendant . . . has
violated the Constitution.” Id. at 676 (emphasis added). “Individual government officials ‘cannot
be held liable’ in a Bivens suit ‘unless they themselves acted [unconstitutionally].’” Wood v. Moss,
134 S. Ct. 2056, 2070 (2014) (citing Iqbal, 556 U.S., at 683); Danser v. Stansberry, 772 F.3d 340,
349 (4th Cir. 2014) (“liability may be imposed based only on an official’s own conduct.”).
JA045
Here, Plaintiff has not stated a Bivens claim against any of the Defendants. SAC Perkins
and Marshal Hughes are not identified in the body of the Complaint, and there is no factual content
in the Complaint explaining how either of these Defendants violated Plaintiff’s constitutional
rights. To the extent that they are named as supervisors of the federal agents discussed in the
Complaint, Bivens does not permit respondeat superior liability. See Trulock v. Freeh, 275 F.3d
391, 402 (4th Cir. 2001). Thus, Plaintiff has failed to state a Bivens claim as to SAC Perkins and
Marshal Hughes.
Regarding U.S. Attorney Rosenstein, Plaintiff’s Complaint states, “[w]hen [U.S. Attorney
Rosenstein] was assigned to Maryland in 2006, part of his assignment was to continue to ignore
and/or cover-up the aforementioned conspiracy against Plaintiff.” (Compl. ¶ 92.) Plaintiff,
however, has not provided any facts to support his allegation that U.S. Attorney Rosenstein,
himself, acted to violate Plaintiff’s constitutional rights. Plaintiff’s conclusory allegations
regarding a “cover-up” and a “conspiracy,” without more, are not assumed to be true and fail to
state a claim. Iqbal, 556 U.S. at 681 (citing Twombly, 55 U.S. at 554-55). Accordingly, Plaintiff
has failed to state a Bivens claim against U.S. Attorney Rosenstein. 2
B. Plaintiff may not maintain a Bivens action against the Defendants in their
official capacities.
The Fourth Circuit has stated that “a Bivens action does not lie against either agencies or
officials in their official capacity.” Doe v. Chao, 306 F.3d 170, 184 (4th Cir. 2002) (citing FDIC
v. Meyer, 510 U.S. 471, at 484-86 (1994)); see also Curtis v. Pracht, 202 F. Supp. 2d 406, 419 (D.
2
Additionally, Plaintiff’s Bivens claims carry a three-year statute of limitations. See Jersey
Heights Neighborhood Ass'n v. Glendening, 174 F.3d 180, 187 (4th Cir. 1999). If Plaintiff is
correct that U.S. Attorney Rosenstein violated Plaintiff’s constitutional rights in 2006, then such a
claim would be barred by the statute of limitations.
JA046
Md. 2002). Accordingly, to the extent that Plaintiff’s claims against the Defendants are construed
as official capacity claims, Bivens cannot apply, and this Court lacks jurisdiction over such claims.
C. Plaintiff lacks standing to bring a First Amendment claim.
Plaintiff alleges that the unnamed FBI agents interviewed him to “prevent and/or to
intimidate plaintiff’s planned demonstrations at the Baltimore U.S. courthouse on August 4, 2013.”
(Compl. ¶ 48). To have standing to bring a First Amendment claim, Plaintiff must demonstrate an
injury-in-fact. “In First Amendment cases, the injury-in-fact element is commonly satisfied by a
sufficient showing of ‘self-censorship, which occurs when a claimant is chilled from exercising
h[is] right to free expression.’” Cooksey v. Futrell, 721 F.3d 226, 235 (4th Cir. 2013) (citations
omitted). In Cooksey, the Fourth Circuit also noted:
We are mindful, however, that the chilling effect cannot “arise merely from the
individual’s knowledge that a governmental agency was engaged in certain
activities or from the individual’s concomitant fear that, armed with the fruit of
those activities, the agency might in the future take some other and additional action
detrimental to that individual.” Laird v. Tatum, 408 U.S. 1, 11, 92 S.Ct. 2318, 33
L.Ed.2d 154 (1972). In other words, “[a]llegations of a subjective ‘chill’ are not an
adequate substitute for a claim of specific present objective harm or a threat of
specific future harm [.]” Id. at 13–14, 92 S.Ct. 2318. But see Mangual v. Rotger–
Sabat, 317 F.3d 45, 56 (1st Cir.2003) (recognizing a First Amendment injury-in-
fact when a plaintiff is “chilled from exercising h[is] right to free expression or
forgoes expression in order to avoid enforcement consequences”) (internal
quotation marks omitted).
Id. at 236. Plaintiff, however, has not provided any evidence of a chilling effect on his speech.
The underlying basis for the interviews was concern about the safety of federal judges and
other government officials due to Plaintiff’s communications with them. (Compl. ¶¶ 29, 40). At
no point, however, does Plaintiff allege that the agents forbade him from protesting nor did they
take any actions to prevent the protests. Other than Plaintiff’s own speculation that the interviews
were for the purpose of preventing him from protesting, he provides no evidence that his speech
was chilled or that he self-censored himself. In fact, Plaintiff admits that he subsequently protested
JA047
for several weeks. (Compl. ¶¶ 64-66). Finally, as argued in the preceding sections, there is no
allegation that any of the named Defendants acted to restrict Plaintiff’s First Amendment rights.
Accordingly, Plaintiff’s First Amendment claim must be dismissed.
D. Plaintiff has failed to state a due process violation.
The Due Process Clause of the Fifth Amendment to the United States Constitution
provides: "nor shall any person . . . be deprived of life, liberty, or property, without due process of
law." U.S. Const. Amend. 5. There are two "categories" of due process claims: (1) procedural due
process claim which alleges a denial of fundamental procedural fairness, see Fuentes v. Shevin,
407 U.S. 67, 82 (the procedural due process guarantee protects against "arbitrary takings"); or, (2)
substantive due process, which alleges the exercise of power without any reasonable justification
in the service of a legitimate governmental objective. Rucker v. Harford County, 946 F2d 278,
281 (4th Cir. 1991), cert. denied, 502 U.S. 1097 (1992); see also Daniels v. Williams, 474 U.S.
327, 331 (1986). A violation of "substantive" due process occurs only where the government's
actions in depriving a person of life, liberty, or property are so unjust that no amount of fair
procedure can rectify them.
In the instant case, Plaintiff has asserted only conclusory allegations of perceived due
process violations. For example, although Plaintiff states that he was informed by a Deputy U.S.
Marshal that he had been under “surveillance,” there is no indication in the Complaint that, even
if had been surveilled, his due process rights were violated. There is no allegation that, for
example, the government conducted electronic surveillance of Plaintiff’s home telephone without
first obtaining a warrant. Further, as stated throughout this Motion, Plaintiff has not attributed any
unconstitutional act, including a surveillance-related act, to the named Defendants. Accordingly,
Plaintiff’s due process claim must be dismissed.
JA048
E. The Defendants are entitled to qualified immunity for any alleged

constitutional violations.
Qualified immunity shields federal officials from liability in Bivens suits unless a plaintiff
can plead “facts showing (1) that the official violated a statutory or constitutional right, and (2)
that the right was ‘clearly established’ at the time of the challenged conduct.” Ashcroft v. al-Kidd,
563 U.S. 731, 735 (2011). A necessary predicate of the first prong is that a plaintiff must allege
sufficient facts that “each Government-official defendant, through the official’s own individual
actions, has violated the Constitution.” Iqbal, 556 U.S. at 676. With respect to the second prong,
the contours of the right must be “sufficiently definite,” so “that any reasonable official in the
defendant’s shoes would have understood that he was violating it.” Plumhoff v. Rickard, 134 S.
Ct. 2012, 2023 (2014).
Here, Plaintiff cannot prove that the Defendants are not entitled to qualified immunity
because he has not sufficiently plead the first element, that any of the Defendants violated his
constitutional rights. As stated in Section IV.A, supra, Plaintiff has not articulated how any of the
named Defendants violated his constitutional rights. Accordingly, the Defendants are entitled to
qualified immunity, and the claims against them must be dismissed.
V. MOTION TO SUBSTITUTE AND TO DISMISS
Although Plaintiff identified Bivens as the basis for his suit, in an abundance of caution,
the Defendants will analyze Plaintiff’s Complaint in the context of the Federal Tort Claims Act
(“FTCA”). The FTCA permits a limited waiver of sovereign immunity by the government for an
individual to sue the United States for personal injury caused by the alleged negligence or wrongful
conduct of its employees acting within the scope of their employment. Therefore, “the
circumstances of its waiver must be scrupulously observed and not expanded by the courts.”
JA049
Kokotis v. United States Postal Serv., 223 F.3d 275, 278 (4th Cir. 2000) (citing United States v.
Kubrick, 444 U.S. 111, 117-18 (1979)).
A. The United States must be substituted as the sole defendant for any tort
claim under the FTCA.
Pursuant to the Federal Tort Claims Act (“FTCA”):
Upon certification by the Attorney General that the defendant employee was acting
within the scope of his office or employment at the time of the incident out of which
the claim arose, any civil action or proceeding commenced upon such claim in a
United States district court shall be deemed an action against the United States
under the provisions of this title and all references thereto, and the United States
shall be substituted as the party defendant.
28 U.S.C. § 2679(d)(1). Consistent with this provision, the United States is submitting the attached
Scope Certification which states that all three Defendants were acting within the scope of their
employment at all relevant times. See Scope Certification, attached hereto as Exhibit A.
Accordingly, the United States requests that it be substituted as the sole defendant with respect to
any tort claims, and that the claims against the individual Defendants be dismissed.
B. Any tort claim must be dismissed because Plaintiff failed to exhaust

administrative remedies.
Consistent with the FTCA’s limited waiver of sovereign immunity, an individual “must
file an FTCA action in careful compliance with its terms.” Kokotis, 223 F.3d at 278. Plaintiff
bears the burden of proving he has complied with the requirements of the FTCA. See Logan v.
United States, 851 F. Supp. 704, 707 (D. Md. 1994). Among its mandatory terms, the FTCA
provides that a plaintiff must exhaust administrative remedies by, inter alia, filing a claim with the
“appropriate Federal agency.” 28 U.S.C. § 2675(a). A tort claim against the United States is
“forever barred” unless it is presented in writing to such agency within two years after the claim
accrues. 28 U.S.C. § 2401(b). Here, Plaintiff has not submitted a claim to any federal agency with
respect to any tort claims. Accordingly, any tort claims are forever barred and must be dismissed.
10
JA050
VI. CONCLUSION
WHEREFORE, Defendants respectfully request that the Court dismiss Plaintiff’s
Complaint, or in the alternative, substitute the United States as the sole Defendant and dismiss the
Complaint.
Rod J. Rosenstein
_________/s/____________________
(410) 209-4800
11
JA051
IN THE UN ITED STA TES DIS TRICT COURT

DIST RICT OF MARYLAN D
WILLI AM C. BO ND,
Plaintiff , *
v. -J:
Ca se No.: l:16-cv-02723-D AF
JOHN NY L. HU GES, et al. *

Defendant s. *
* * * * * 1:
* * * *
CERTI FICATIO N
I, Step hen M . Schennin g, First Ass istant Unit ed States Attorney for the Di strict of
Maryland , act ing pur suant to 28 U.S .C. § 2679( d), and by virtu e of th e auth01it y vested in me by
the Attorney Ge nera l unde r 28 C.F.R . § 15.4 , hereby cert ify that I ha ve been made awa re of the
genera l factual allegat ions in the Comp laint, and that I have reviewed an October 6, 20 16
memora ndu m fro m Ass istant United States Attorn ey Ma tthew P. Phe lps. On the basis of the
information now ava ilab le wit h respect to the allega tions in the Co mplaint , I cert ify that the
individu al Defe ndant s Kev in Perk ins, Jo lmn y L. Hughes, and Rod J . Rose nstein were actin g within
the scope of their employment at the tim e of suc h allega tions.
Date : Octobe r 1j o16

Fir st Assis tan t United States Atto rne/
36 S. Charles Street, 4 th Floo r 7
Ba ltim ore, Ma ryland 2 120 1
(4 10) 209 -480 0
Exhibit A
JA052

WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
*
Defendants.
*
* * * * * * * * * * * * *
PROPOSED ORDER
Upon consideration of Defendants Johnny L. Hughes, Kevin Perkins, and Rod J.
Rosenstein’s Motion to Substitute and to Dismiss, and any opposition or reply thereto, it is this __
day of _______________, 2016 hereby ORDERED that the Motion is GRANTED and Plaintiff’s
Complaint is DISMISSED WITH/WITHOUT PREJUDICE.
__________________________________
The Hon. David A. Faber
United States District Judge
12
JA053
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William C. Bond
Pro Se Litigation 2Gi fi DECZO flliI I: I 5
P.O. Box 4823
443.970.2887
proselitigator@aol.com gy _____ C[?"'l~
December 19, 2016

Clo Clerk

Clo Chambers
2303 Elizabeth Kee Federal Building
60 I Federal Street
Bluefield, West Virginia 24701
Dear Judge Faber:
I write to you about the above-titled case. While I believe a letter is the appropriate form for this
action, I ask that the court consider the following under FRCP 56(d) as a Motion for Discovery.
This Jetter concerns the defendants' Motion to Substitute and to Dismiss (hereinafter "MTD") at
docket number 16.
I. INTRODUCTION
The defendants have presented a paper to the court that Jacks candor, for example, by not
discussing the standard of review a district court must use when analyzing a prose complaint.
Further, no matter how much the defendants wish it to be, there is no such thing as a legal
kaleidoscope through which a respondent can change the facts of a particular complaint. Here,
the defendants wish the court to believe that plaintiff is complaining of lawful - in the course of
employment - conduct, rather than unconstitutional and unallowed misconduct wherein an
JA054
Article III judge and others misused the Maryland U.S. Marshals Service and Maryland FBI,
amongst others, to attempt to influence and/or stop plaintiffs 2013 anti-corruption protests, and
other activities, at the Baltimore U.S. Courthouse. And, in doing so, the defendants have
introduced arguments of fact and evidence which are outside of the complaint. The defendants
have also abandoned any answer or response to any of the complaint's specific allegations listed
by count, except one outside-the-complaint argument re: Count I, one quasi-outside-the-
complaint argument re: Counts III & IV, and the conclusory 'Schenning Affidavit.'
II. ADDITIONAL STANDARD OF REVIEW
Plaintiff proceeds prose. In Gordon v. Leeke, 574 F.2d 1147, 1173 (4 Cir.1978), the Fourth
Circuit stated:
[T]he Fourth Circuit takes the position that its district courts must
be especially solicitous of civil rights plaintiffs. This solicitude for
a civil rights plaintiff with counsel must be heightened when a civil
rights plaintiff appears prose. In the great run of prose cases, the
issues are faintly articulated and often only dimly perceived. There
is, therefore, a greater burden and a correlative greater
responsibility upon the district court to insure that constitutional
deprivations are redressed and that justice is done. So, although the
Court of Appeals cannot mean that it expects the district courts to
assume the role of advocate for the prose plaintiff, radiations from
Burris strongly suggest that the district court must examine the
pro se complaint to see whether the facts alleged, or the set of
facts which the plaintiff might be able to prove, could very well
provide a basis for recovery under any of the civil rights acts or
heads of jurisdiction in the federal arsenal for redress of
constitutional deprivations. Accordingly, the Court in considering
the defendants' motion to dismiss will not permit technical
pleading requirements to defeat the vindication of any
constitutional rights which the plaintiff alleges, however inartfully,
to have been infringed." (Emphasis added.)
III. MOTION FOR DISCOVERY
Defendants have converted their MTD into an FRCP 56 motion by bringing both specific and
overly broad information outside the record into their filing while at the same time defaulting
upon certain counts in total. Nevertheless, plaintiff cannot answer their filing without discovery.
A. Count I
JA055
In Count I of the complaint, plaintiff identifies three (3) federal law enforcers. 1 Plaintiff alleged
the USMS PIU manuals prohibit the alleged conduct. 2 Plaintiff alleged that Maryland Article III
judges were misusing the federal law enforcers to protect their reputations, which is clearly not a
legitimate use of law enforcement.
Nevertheless, the defendants state: "The underlying basis for the interviews was concern
about the safety of federal judges and other government officials due to Plaintiff's
3
communications with them. (Compl. 'l['I[29, 40)." (Emphasis added.)
But clearly, plaintiff's complaint at ,r,r

29, 40, nor or at any other part, makes no mention of any
4
threat against any federal official.
Defendants have gone outside the complaint to make this statement, which clearly hinges on
false pretexts, false profiling, and/or other falsities about plaintiff. Likewise, the "Schenning
Affidavit" makes conclusory statements about facts, such as the just-listed, which require
discovery for plaintiff to respond completely to the defendants' claims. 5
B. Count II
Plaintiff requires discovery as to the true identities, statuses, and intentions of the two 'unnamed'
alleged U.S. government undercover agents.
C. Count III & IV
The defendants state: "There is no allegation that, for example, the government conducted
electronic surveillance of Plaintiff's home telephone without first obtaining a warrant."
(Emphasis added.) While the government is careful in how they make this statement - the on! y
way a reasonable person can read the implication is that the government did obtain such a
warrant, as the surveillance is an admitted, all-but-proved-true-fact as a matter of law.
Certainly, plaintiff is entitled to discovery to find out what the basis was for the warrant(s), who
1
DUSM Robert Mark Frederick, FBI Supervisory Special Agent Patrick S. Dugan, &
FBI Special Agent Chris Wood, will all be named as defendants in a future amended complaint.
2
Please see: Exhibit no.: I, the USMS Policy Directives, Judicial Security, 10.7
Protective Investigations at D. 7. (Page 2.)
3
Please see: Docket no. 16-1 at 7.
4
Plaintiff will eat his shoes if the defendants can produce even one threatening word
made by plaintiff against any federal judge or employee.
5
The defendants' proffer that the federal law enforcers' scheme to attempt to arrest
plaintiff just five (5) days before his highly-publicized first Baltimore U.S. Courthouse protest
caused plaintiff no aggravation or constitutional harm is as absurd as saying the same acts would
have no impact upon a person readying in five (5) days for a marriage, a birth of a baby, or major
surgery, etc.
JA056
signed them, and to see what the extent of the surveillance was while plaintiff was in actual
litigation(s) with the government, and/or related actors.
Further, plaintiff again states that it is a prima facie due process violation for the government to
surveil a party while litigation is ongoing.
D. Count V
Plaintiff requires discovery as to the DUSM's and the Article llljudge's intentions during the
alleged event. Plaintiff also requires production of the courthouse surveillance tapes.
E. Count VI
Plaintiff requires discovery of approximately ten individuals, both inside and outside the
government, to prove the alleged conspiracy, including how the subject 200 I case was assigned
to the subject judge.
F. The 'Schenning Affidavit'
Plaintiff requires discovery related to Mr. Schenning, Mr. Hughes, Mr. Perkins, and Mr.
Rosenstein, regarding all conversations between them regarding this matter, and the basis for Mr.
Schenning's conclusions.
IV. DEFAULT
A. Count II
Clearly, by not answering in any way, the allegations in Count II, the defendants have defaulted
as to that count.
Plaintiff is entitled to a scheduling order regarding this count, to discovery, if not outright
summary judgment under FRCP 56(e).
B. Count V
Clearly, by not answering in any way, the allegations in Count V, the defendants have defaulted
as to that count.
Plaintiff is entitled to a scheduling order regarding this count, to discovery, if not outright
summary judgment under FRCP 56(e).
V. CONCLUSION
Similar to the famous 'Duke Lacrosse Rape' case, and more recently the 'University of Virginia
JA057
Rolling Stone' case, the named and unnamed defendants have all operated from a false narrative.
The false narrative here is that somehow they are the victims, and that plaintiff is harassing and
threatening them. But the true narrative in this case is that plaintiff is the victim of the
defendants, who have gone far outside their Article III statuses and/or controlling government
rules, in violation of all canons and laws. Their false narrative has allowed them to persecute
plaintiff with impunity for more than 15 years. Plaintiff has stood straight and fought back - he
has never wavered, nor for a moment given an inch. He had every right to insist that government
law enforcers and judicial supervisors correct the illegalities done to him, including the theft of
his property under the color of law and the literal 'Bill of Attainder' put upon him by judicial
actors. Everything plaintiff has done to bring this unconstitutional misconduct to light is above
6
board, follows the Art of War, and is total and completely protected political speech.
This court must allow their scheduling order to issue, and for discovery to commence, at the end
of which, plaintiff will prove each and every of his causes of action either in an opposition to the
7
subject MTD or in an amended complaint.
8
Thank you very much for your consideration.
I hope this letter finds you well.
Very truly & respectfully yours,
wg;z,
William C. Bond
cc: Matthew P. Phelps, AUSA, USAO MD via: Emnil

Allen F. Loucks, Chief, Civil Division, USAO MD via: Email
6
The positions of conservative law professor Eugene Volokh are worth noting, as they
illustrate that even extremely rude & pervasive conduct toward public officials is protected:
https ://www. wash in gtonpost .com/news/vol okh-conspirac y/wp/2016/09/28/i nsul ting-letters-to-
po Iiti cians-home-are-con sti tuti onal Iy-prot ected-un less-they-are-I rue-
threats/?u tm term=.99e2d0e5449d
7
Plaintiff respectfully requests that this court also consider this letter motion as a
declaration under FRCP 56(d).
8
Plaintiff respectfully renews his Motion to Stay and/or Toll Plaintiffs Opposition to the
Defendants' Forthcoming Response to the Complaint at docket number 15.
JA058
,
Case 1:16-cv-02723-DAF Document 18-1 Filed 12/20/16
U.S. Department Page 1 of 16
of Justice
' United States Marshals Service
Office of General Counsel
Washington, DC 20530-/000
JAN 1 4 2016
William C. Bond
Re: Freedom of Information/Privacy Act Request No. 2015USMS27479

Subject of Request: U.S. Marshals Service Maryland Indoor/Outdoor
Gun Ranges and Protocols of the Marshals Service
Office of Protective Intelligence
Dear Mr. Bond:
As a result of the remand of your Freedom oflnformation Act (FOIA) request by the Office
oflnformation Policy, the U.S. Marshals Service is making a supplemental disclosure to you.
Enclosed is the Marshals Service Policy on Protective Investigations consisting of 14 pages. The
pages have been redacted to protect law enforcement techniques and procedures pursuant to
exemption 7(E) of the FOIA, 5 U.S.C. Section 552(b)(7)(E).
Exemption 7(E) allows an agency to withhold records or information compiled for law
enforcement purposes, to the extent that the disclosure of such records or information would
disclose guidelines or techniques or procedures for law enforcement investigations or
prosecutions, the disclosure of which could reasonably be expect to risk circumvention of the law.
If you are not satisfied with my response to this request, you may administratively appeal
by writing to the Director, Office oflnformation Policy (OIP), United States Department of
Justice, Suite 11050, 1425 New York Avenue, NW, Washington, DC 20530-0001, or you may
submit an appeal through OIP's eFOIA portal at http://www.justice.gov/oip/efoia-portal.html.
Please note that OIP is in the process of transitioning from its current eFOIA portal to the portal on
FOIAonline. Please visit the link above for instructions for submitting an appeal electronically.
JA059
,
Your appeal must be postmarked or electronically transmitted within 60 days of the date of this
response to your request. If you submit your appeal by mail, both the letter and the envelope
should be clearly marked Freedom oflnformation Act Appeal.
Sincerely,
'(fl ' 1,{j~

WILLIAM E. BORDLEY
cihAssociate General Counsel/FOIPA Officer
a Office of General Counsel
C
Enclosures
cc: OIP (Appeal 2015-03896)
JA060
ll\'CLASS!FlED//LA W ENFORCEMENT SENS!T!VE
United States Marshals Service POLICY DIRECTIVES
JUDICIAL SECURITY
10.7 PROTECTIVE INVESTIGATIONS
A. Proponent: Office of Protective Intelligence (OPI), Judicial Security Division (JSD).
B. Purpose: To ensure the safety of all federal judicial officials and proceedings, the United States
Marshals Service (USMS) identifies, assesses through investigation, mitigates, and manages all
threats, inappropriate communications, incidents, and suspicious activities that pose a threat to
USMS protected persons and facilities.
C. Authority: The Director's authority to issue written directives is derived from 28 U.S.C. § 561(g)
and 28 C.F.R. § 0.111. In addition, 28 U.S.C. § 566(e)(1)(A) establishes the USMS authority to
provide personal protection to federal jurists, court officers, witnesses, and other threatened
persons in the interests of justice where criminal intimidation impedes the judicial process or any
other official proceeding.
D. Policy:
1. Due to th,a poti;,ntio1Irisk of inj~ry or death. di$lrict man,igement shoulci place the highest
prioriiy ·on ifs tiireat management and proiedive investigations responsibiiities.
2. An evaluation should begin immediately upon receipt of any threat, inappropriate

communication, incident, or suspicious activity to determine if a protective investigation is
appropriate. All available district resources should be considered to conduct an
appropriate protective investigation. Collateral leads received should also be given the
highest priority.
3.
4. The USMS will attempt to identify, assess through investigation, mitigate, and manage all
potentially threatening situations involving its protected persons and facilities. A
comprehensive protective investigation will be conducted to mitigate risks to federal
judicial officials or other USMS protectees.
5. USMS protected persons may include but are not limited to the following officials and
their staff:
a. Justices of the Supreme Court of the United States (outside the Washington,
D.C. area, in cooperation with the United States Supreme Court Police);
b. Federal judges (circuit, district, bankruptcy, and magistrate);
c. Tax court judges;
d. Court of International Trade judges;
e. United States Deputy Attorney General;

liNCLASSIFIEDi/LA \V ENFORCEi\lENT SENSITIVE
USMS PolicyDirective10.7, ProtectiveInvestigations Page 1 of 14
EffectiveDate: 2/23/2015
JA061
T
UNCLASSIF!ED//LAW ENFORCE~!ENT SENSIT!VE
f. Director of the Office of National Drug Control Policy (through reimbursable

agreement);
g. United States Attorneys and Assistant Un~ed States Attorneys;
h. Department of Justice attorneys;
i. Federal public defenders and their assistant public defenders;
j United States clerks of court;
k. United States probation officers;
I. United States pre-trial services officers;
m. Jurors;
n. Witnesses;
o. United States trustees;
p. USMS employees;
q. Reproduction health services providers and facilities, pursuant to Attorney

General Order No. 3140-2010, February 23, 2010, and DOJ, Office of Leg,;,l
Counsel, Action Memorandum; November 12, 2009; and
r. Other threatened persons in the interests of justice where criminal intimidation

impedes on the functioning of the judicial process or any other official
proceeding.
6. Protective investigations will be conducted in accordance with the OPI Guide to

Protective Investigations and Contemporary Threat Management, USMS Pub. No. 202.
A copy of the handbook can be accessed on the OPI Intranet.
7. The USMS will not initiate an investigation or keep records on an individual or group
based solely on an exercise of their First Amendment rights. However, this does not
mean that the USMS must ignore potentially dangerous speech or activity. If an
individual or group communicates inappropriately, or if other information exists that
reasonably indicates that a danger to a USMS protected person or facility exists or may
develop, then an investigator may open an investigation to ensure that the protected
person or facility remains safe and the administration of justice is not impeded.
E. Responsibilities:
1. Districts: Implement the USMS protective investigation program. To ensure the safety
of all USMS protected persons and facilities, districts must identify, assess through
investigation, mitigate, and manage all threats, inappropriate communications, incidents,
suspicious activities, and all other triggering events that indicate a danger may exist.
a. District Management:
1) Ensure a sufficient number of district personnel are designated as

District Threat Investigators (DTls) and ensure those investigators are
given sufficient time and resources to conduct thorough protective
investigations.
UNCLASSrFIED//LA \V ENFORCEi\lENT SENSITIVE

EffectiveDate: 2123/2015
JA062
UNCLASSlFIED//LA \\' ENFORCEMENT SENSITIVE
2) Upon notification that a USMS protected person has received a threat or

inappropriate communication, immediately take steps to ensure the
protectee's safety,
3) Ensure USMS protected persons are familiar with identifying threats,

inappropriate communications, incidents, and suspicious activity and the
procedures for reporting them to the USMS. This can be accomplished
individually or during the annual security awareness training given to the
judicial family, including the United States Attorney's Office,
4) Ensure cases are entered into the Justice Detainee Information System
(JDIS) within 72 hours of receipt or development of the information that
supported the opening of a case, See the USMS District Dashboard
Protective Investigation Metrics,
5) Perform due diligence on all assigned protective investigations, including

uploading an investigative update in active cases at least once every 30
days and in suspended cases at least once every 90 days,
6) Ensure regular updates are provided to protected persons on the status

of investigations.
7) Ensure DTls provide a detailed and timely Form USM-11, Report of

Investigation, reporting all investigative activity including an initial f<;!pQrt,
case updates at least every-30 days, investigative activity updates, and a
closing report. All reports should be approved by a district supervisor,
Judicial Security Inspector (JSI), or Protective Intelligence Investigator
(PII) other than the person making the entry.
b. District Investigators:
1) JSI: If no Pl! is assigned to the district, the JSI coordinates the

protective investigations program and assigns DTls to conduct protective
investigations.
2) DTI: A collateral duty investigator charged with conducting thorough

protective investigations and mitigating threats to USMS protected
persons and faciltties. DTls must:
a) Complete the Protective Investigations Training Program (PITP);
b) Conduct and document preliminary assessments and thorough

predicated protective investigations;
c)
d) Seek concurrence with district management and OP! prior to

closing each protective investigation.
3) Pl!: In districts that have.a Pl! position, the Pl! will_ser'{e_asthe

protective intelligence and protective investigation program coordinator
for that district The Pl! should report directly to the Chief Deputy or an
UNCLASSlFIED//LA W ENFORCEl\lENT SENSITIVE

USMS PolicyDirective10.7, ProtectiveInvestigations Page 3of14
JA063
·-------
-
UNCLASSTFIEDl!Lr\ \V ENFORCEMENT SENS1n,·1c
Assistant Chief Deputy in the district. Plls have all of the responsibilities
of DTls plus:
a) Collect and analyze protective intelligence for the district; and
b} Provide guidance, assistance, and oversight to DTls during

protective investigations.
District Liaison Responsibilities: Districts, through the PII or JSI,

4)
should develop working relationships consistent with their protective
-----------------<·Atfllli9"AW-aRQ4A¥8£li9atioA.f.gspoAGibiliti8,6-":-----------------
a) Federal Bureau for Investigation (FBI);
b) Federal Protective Service;
c) United States Attorney's Office (USAO);
d) United States Secret Service;
e) Sheriffs offices and state courts;
f) State fusion centers; and
g) Local police.
2. OPI, Threat Management Center (TMC):
a. Serve as the USMS intake and coordination center for protective intelligence and
protective investigations. OPI collects, analyzes, and disseminates protective
intelligence to district offices, protective details, Office of Protective Operations
(OPO), senior leadership, and other divisions in a !im~ly f11shion.
b. Provide consistency for all USMS protective investigations ensuring investigative

quality control standards are met nationally.
c. Upon notification that a district initiated a protective investigation the TMC will:
1) Provide guidance and recommendations to the district;
2) Log the notification;
3) Review and assess all submitted material,
4)
5)
6) Provide coordination and support with other districts as needed.
d. . After the initial coordination is provided by the TMC, the case will be forwarded to
the circuit team comprised of a Senior Inspector (GS-1811) and Intelligence
Research Specialist (GS-0132) for further coordination with the district. The
UNCLASSIFIED/!LA W ENPORCE!l!ENT SENSITIVE

USMS PolicyDlrective10.7, ProtectiveInvestigations Page 4 of 14
Effective Date: 2/23/2015
JA064
..,,.·-.. :·•··,'
. . ·,
__ _____:.:::;__,'.
l'NCLASSIFIED//LA W ENFORCEMENT SENSITIVE
circuit team will provide additional investigative, analytical, and threat

management support which typically includes:
1)
2)
3)
,{
--------_,,~·4--1~------~
4)
5)
6)
e. In cases that involve protective details, circuit inspectors will maintain daily
contact with the case investigator.
f. OP! will report investigative statistics to USMS leadership for use in resource and
funding allocation. OP! will also provide investigative updates to USMS and
Department of Justice (DOJ) leadership for high priority cases.
g. Critical Incidents: At the direction of the Chief, OP!, in response to a national

critical incident, emergency, or planned National Special Security Event that
could potentially impact the protective mission of the USMS, the TMC ma be
activated to provide direct su ort to th fleeted USMS districts.
h.
i. PITP: OP! will design and conduct PITP classes in coordination with the Training
Division. This program will encompass up-to-date methodology in protective
investigation and threat management techniques. This training will be the
minimum training for JS ls, Plls, and DTls.
j. Additional Education, Training, and Outreach: OP! will conduct training on

protective investigation methodology and USMS Rrotective investigation
practices when fiscally possible. These sessions will-be conducted for events·-
---
that involve multiple districts, outside agencies, and national audiences. OP! will
also support educational outreach programs in coordination with the National
UNCLASSlFIED//LAW ENFORCEi'vJENT SENS!Tl\'E

JA065
llNCLASS!FIED!iLAW ENFORCEMENT SENSITIVE
Center for Judicial Security. OPI will also provide districts with training materials
and guidance to assist with local in-district education initiatives.
F. Procedures:
1. Each district will designate protective investigators to review, assess and, if necessary,
investigate all information or srtuations that may be of protective interest.
2. Protective investigators should be criminal investigators who have attended the USMS
PITP class. All Plls are required to attend the PITP as soon as possible and will be given
-------------rie,i~11sieerelie11-fe!'-etlePl<le11ee-,11-IRe·flel<Hl'tailalllo-Pl+P-ela-.-~~----~---·~~~
3. Consideration of Methods: When conducting protective investigations authorized by

this directive, choices will arise among a variety of operationally sound and effective
investigative methods. Investigators will consider such factors as the investigative
method's impact on privacy and civil liberties of individuals and potential damage_to
reputation. The least intrusive method feasible is to be used in such situations.
However, investigators should not hesitate to use any lawful method, even if intrusive,
where the degree of intnusiveness is warranted by the severity of the threat.
4. The OPI is the national program office that provides subject matter guidance, oversight,
management, and coordination with district offices conducting protective investigations.
The TMC serves as the USMS intake and coordination center for all protective
intelligence and protective investigations.
5. Justice Detainee Information System (JDIS): There are two modules in JDIS to store
protective information and intelligence:
a. Judicial Security Module: The Judicial Security Module (also referred to as the
Threat Module) is accessed through the Judicial Security tab in JDIS. The
Judicial Security Module is used to record predicated protective investigations
that are initiated based on a valid triggering event.
b. Suspicious Activity, Assaults, Incidents, Deaths, and Escapes (SAID)

Module: The SAID Module, accessed through the SAID tab in JDIS, will be used
to record preliminary assessments and incidents that do not require further
investigation.
6. Categories of Investigation:
a.
UNCLASSIFIED/iLA\V ENFORCEMENT SENSITIVE

JA066
ll'\JCLASSIFIE0/iLAW ENFORCEMENT SENSITIVE
1) All general intelligence collection must be in furtherance of an authorized

USMS mission.
2) Information without clear protective value may not be retained.
b.
2) During a preliminary assessment, an investigator may seek information

proactively based on a reasonable articulable belief that the investigation
will uncover infonmation related to a violation of law that the USMS has
the authority to investigate or in response to leads relating to activities
constituting violations of criminal law.
3) There is no time limtt on a preliminary assessment.
4) Preliminary assessment activity must be entered into the SAID module,

but personal and group identifiers may only be retained with a narrative
explaining why they are relevant to detenmining existence of a threat.
5) The following investigative techniques may be utilized during a

preliminary assessment:
a)
b)
c)
d)
1 e)
f)
g)
h)
6) Closure/Elevation: All preliminary assessments must eventually be

closed as either resolved or elevated to predicated protective
. __investigations depending.on.the .infonmation uncovered .._____
a) Preliminary assessments may be closed as resolved when:
U'lCLASSIFIED/iLA \V ENFORCF.~'IF:NT SENSITl\'E

USMS PolicyDireclive10.7, Protectivelnvestigalions Page 7 o, 14
Effec1iveDate: 2/23f2015
JA067
-~-: ~ ,:::..-,;~
.::: ..
llNCLASS!FIED/iLAW ENFORCEMENT SENSITl\'C
I. A determination is made that the underlying incident

does not represent a credible threat to a protected
person or facility;
II. When it becomes evident that a triggering event has not

occurred;or
Ill. When no nexus to any USMS area of responsibility

exists.
-------------~---bt---tf-information-obteined-dttring-e-pre!im~-ent-mem-----~~
the threshold for opening a predicated protective investigation
and further investigation is warranted, then the preliminary
assessment must be elevated to a predicated protective
investigation and it must be entered into JDIS using the Judicial
Security Module.
c. Predicated Protective Investigations: Predicated protective investigations

allow more investigative techniques than preliminary assessments but they
require the articulation of a triggering event and must relate to actual crimes
within USMS authorities and responsibilities. A protective investigation should
only be opened if it appears likely that further investigation could develop
valuable information about the crime or potential crime indicated by the triggering
event. If there is not a reasonable indication that a crime has occurred or may
occur or if further investigation is not likely to develop inform;;ition about a crtme,
then the information should be memorialized in the SAID module and a
predicated protective investigation should not be opened.
1) A predicated protective investigation may be opened when a triggering

event that reasonably indicates that activity constituting a federal crime
impacting the safety of a USMS protected person or facility has occurred,
is occurring, or will occur, and the investigation may obtain information
relating to that crime. Note: lt is not necessary that a crime has already
taken place. The reasonable indication that a crime may take place is
sufficient justification to support opening a predicated protective
investigation.
2) There is no time limit on a predicated protective investigation.
3) A predicated protective investigation must be fully documented in the

Judicial Security Module.
4) All lawful techniques are available during a predicated protective

investigation.
5)
6)
UNCLASSlFl ED//LAW ENFORCE:VIENTSENSITIVE

JA068
liNCLASSlflED//L.-\ W ENFORCEMENT SENS[Tl\'E
d. Predicated Proteciive Investigation Case Initiation and Entry: Threats,

inappropriate communications, and other protective intelligence triggering events.
1)
2) Protective investigations require a cooperative effort between districts

and OPI. Districts should immediately notify the TMC when a predicated
---~---1>rnt0G!i¥e-i1wo&ligotfoi,.i&-iniliot0 . --~--- ---· ~~~----------~
3) Whenever information is obtained or developed that constitutes a

triggering event it should be immediately evaluated to determine if it
warrants further investigation. If any investigation beyond a preliminary
assessment is warranted, the case should be opened in the Judicial
Security Module.
a) A predicated protective investigation will be entered into JDIS

within 72 hours of the receipt or development of the information
that supported opening the case. See the USMS District
Dashboard Protective Investigation Metrics on the OPI Intranet.
b) At the time of initial entry, a narrative summary must be included

that summarizes the facts of the case <1ndexplains the triggering
event This summary will print in JDIS Subject Reports and
should be no more than one paragraph in length. This
paragraph should briefly touch on the 'who', 'what', 'when',
'where', 'why', and 'how' of the triggering event.
c} In addition to the narrative summary, an initial USM-11 will be

completed which contains a more comprehensive description of
the facts of the case, details of all investigative and protective
activity, and the initial investigative plan.
7. Risk Assessment:
a. In conjunction with every predicated protective investigation, the district

investigator will conduct an initial risk assessment and assign a risk level in JDIS
in line with the standards in this policy. This risk level should be assi ned in
• • • I • • I ' and district managers.
il•l::llllrnr.mlll!'i!ll,!;!II
b.
c. The following standards will be utilized in determining the appropriate level of risk
and protective response. Risk assessment is divided into three categories or
levels.
1)
UNCLASSIF[ED//LA \V ENFORCE:V!ENT SENSITIVE

JA069
l'NCLASS!FIED//LA W ENFORCE~! E:NT SENSITIVE
d.
8. When a predicated protective investigation involves multiple districts, all involved districts
and OPI will discuss the case and the district with the most significant investigative
-------------ffl..,,lvemen\--,hoolel-,,pen-tlse-eese,....:f-1,ii,-wiH-eltefl-l,e-tae-eislriel-wi!Rif!-Wi,ielttl,e-,ittbjee;-------
resides if the threatener's identity is known. When appropriate and agreed upon by
involved districts and OPI, a case may be shared in JDIS between two or more districts to
allow contribution by multiple investigators. In instances of case sharing, one district will
still be designated as the lead for the case.
9. The TMC will review all new protective investigations to ensure the quality of the JDIS
entry. TMC personnel will respond to the district investigator by email within 1 business
day to review the case entry and to provide OPl's preliminary findings. As appropriate,
OPI will complete the following steps.
a.
b.
C.
I,
d.
~{,
e.
f. Prioritize a response to the case based on the risk level:
1)
2)
3)
g. An OPI circuit inspector will contact the lead investi

investi ative Ian for the case as soon a
10. Case Management:
a. Predicated prote.ctive investigation cases.wlU.(e.1)1ain

open as long _as_n;lc_ess_ary
.
to implement and monitor an effective mitigation strategy.
UNCLASSfFIED//LA \V ENFORCE\H::NT SENSITIVE

USMS PolicyDirecti\'e10.7, Proter;liveInvestigations Page 10 of 14
JA070
... ;, t: .. ,.-, ,._.._ .
li,~CLASSIFI EDI/LAW ENFORCEMENT SENSITIVE
b. An investigative update, USM-11, will be uploaded into the case file in JDIS as
an investigative update at least once every 30 days.
C.
d. All investigative activity will be documented on a USM-11 and uploaded into JDIS
within 48 hours of the activity. A USM-11 should be attached to the fugitive
identification number of the investigation SUBJECT, not the protectee(s).
e. Districts should seek OPI concurrence before closing protective investigations.

Upon closure, a USM-11 will be completed articulating the reason_swhy the case
warrants no further investi ation
f.
g. The FBI has principle jurisdiction for investigation of criminal threats against
judges and other government employees. Any time information is developed that
reasonably indicates that a criminal threat has been committed against a
protected person, the FBI should be notified immediately. This should be
documented in JDIS.
1)
o coor ma e the needs of both agencies the

USMS investigator should request to work the investigation jointly with
the FBI.
The USMS should not defer to
the FBI but should make a concerted effort, with district management
involvement when necessary, to mitigate any potential threat to the
USMS protectee through a joint investigation.
2) If an arrest is made in the FBI criminal investigation, the investigator

should immediately notify OPI.
3) If the FBI elects not to conduct an investigation and the USMS

investigator conducts a protective investigation that develops facts which
support prosecution, the investigator should present the case to the local
USAO.
h. The Director of the Executive Office of the United States Attorney (EOUSA) and
the Director of the USMS signed a Memorandum of Understanding (MOU) in
UNCLASSIFIED//LA \V ENFORCEMENT SENSITIVE

USMS PolicyDirective10.7, ProtectiveInvestigations Page 11 of14
JA071
l;:S:CL.-\SSIFIED//LA W ENFORCEMENT SENSITIVE
11. Additional District Protectees:
a. United States Circuit Court Judges: District protective investigators will conduct
investigations involving circuit court judges. All investigative activity should also
be reported to the OPO circuit inspector.
b. United States Supreme Court Justices: Protection of United States Supreme

Court Justices is a shared responsibility with the United States Su
Police Department (SCPD), OPO, and the district.
The SCPD has

pnncIpIe responsI 11 or inves Iga11ng rea s agaIns e upreme Court
. Justices; however, districts may be requested to initiate protective investigations
· in-regard to Suptenie courtJustices to support tM USMS protective mission.
OP! will coordinate all Supreme Court Justice protective investigations with the
SCPD and the district.
C. USMS Headquarters Employees: OPI will conduct an initial assessment on all

threats and inappropriate communications received by USMS Headquarters
persc,nneL The TMC will forward all pertinent information and recommendations
to the appropriate district for further evaluation and case initiation if warranted.
12. Suspended Cases: When a district investigator and the OPI Circuit Inspector agree, a
case may be suspended in JDIS. Suspended cases must be updated by USM-11 at
least once every 90 days.
13. •• . . • - -, ••• -•.•

- . , -, -
- .• •• ·-
-
- ...
•
• ..•
.-
-
- .•
•• II
-•
OP! will coordinate with other USMS

Factors for major case designation include:
a.
b.
C.
d.
UNCLASSIFIED//LAW ENFORCEi\lENT SENSITIVE

USMS PolicyDirective1O.7. ProtectiveInvestigations Page 12 of 14
JA072
.j
U~CLASSIFIED//LA \V ENFORCEMENT SENS[Tl\-"E
G. Definitions:
1. Inappropriate Communication: Any communication in any form that threatens,

harasses, or makes unsettlin overtures toward a rotected person or facility, or
otherwise causes concern.
2.
e lead investigator of the case is responsible for creating at oroug an

effective investigative plan. Advice and assistance in developing an investigative plan is
available from OPI by contacting the TMC or your district's Circuit Inspector. Examples
of investigative plans can be found on the OPI Intranet site.
3. Mitigation Plan:
4.
5. P t f M A t f t f • t f I • -
UNCLASSIFIED//LA \V ENFORCEi\lENT SENSITIVE

USMS PolicyDirective1O.7, Protectivefnvesffgations Page 13of14
JA073
UNCLASS[F!EO//LA W ENFORCEMENT SENSITIVE
6.
7.
8. Shared Case: A shared case is one in which two or more districts are able to approve
USM-11 s. This practice will only be implemented based on the agreement of the opening
district, the added district, and OPI.
--.-· ~--- -_ --- ,___------ -.. - -----··=<-· ... -- - - . - _. -------------•-_·,_,_-c-~·~~~~~
9. Threat: Any action or communication, whether explicit or implied, of intent to assault,

resist, oppose, impede, intimidate, or interfere with any member of the Federal judiciary,
or other USMS protected person. A threat may be written, verbal, or gestured, and may
be delivered directly or relayed through third parties.
10. Threat Assessment: Protective investigation threat assessments evaluate the credibilit
and seriousness of a threaten in sub·ect.
/
1/j
11. Triggering Event: A triggering event is necessary to open_a predicated protective
investigation. A triggering event is an articulable factual basis reasonably indicating that
activity constituting a federal crime has occurred, is occurring, or will occur and that
investigation may obtain information relating to the activity. Note: It is not necessary that
a crime has already taken place. The reasonable indication that a crime may take place
is sufficient justification to support opening a predicated protective investigation
H. References: None.
I. Cancellation: This policy directive supersedes USMS Policy Directive 10.3, Protective
Investigations, and remains in effect until superseded or cancelled.
J. Authorization and Date of Approval:
By Order of: Effective Date:
Isl 2/23/2015
Stacia A. Hylton
Director
U.S. Marshals Service
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE

JA074
! ;.,.::.

WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
*
Defendants.
*
* * * * * * * * * * * * *
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S MOTIONS, ECF NOS. 15 and 18
Defendants, Johnny L. Hughes, Kevin Perkins, and Rod J. Rosenstein, by their undersigned
attorneys, submit this Opposition to Plaintiff’s Motion to Stay (ECF No. 15) and Plaintiff’s Motion
for Discovery (ECF No. 18).
I. INTRODUCTION
Plaintiff filed the instant action for “civil rights relief” pursuant to Bivens v. Six Unknown
Named Agents, 403 U.S. 388 (1971). (ECF No. 1). The Defendants moved to dismiss the
Complaint for failure to state a claim and for lack of jurisdiction. (ECF No. 16). Plaintiff filed a
Motion to Stay his response to the Defendants’ Motion to Dismiss and further requesting that the
Court issue a scheduling order. (ECF No. 15). Plaintiff also filed a Motion for Discovery. (ECF
No. 18). Both motions seek discovery prior to Plaintiff having to respond to the Defendants’
Motion to Dismiss and prior to the Court’s ruling on that Motion. For the reasons set forth below,
the Court should deny Plaintiff’s Motions seeking discovery.
JA075
II. ARGUMENT
As an initial matter, courts have “broad discretion to manage the timing of discovery[.]”
Innovative Therpaies, Inc. v. Meents, 302 F.R.D. 364, 381 (D. Md. 2014) (citing Ardrey v. United
Parcel Service, 798 F.2d 679, 682 (4th Cir. 1986)); see also Baker v. Bank of America, N.A., 2013
WL 6408221, *1 (E.D.N.C. Dec. 6, 2013) (stating, “[t]he court has broad discretion to stay
discovery pending resolution of a motion to dismiss.”) (citation omitted). Here, the Court should
refrain from issuing a scheduling order until the Court has ruled on the Defendants’ pending
Motion to Dismiss. The parties should not be required to engage in time-consuming discovery
while a dispositive motion is pending, and when granting the dispositive motion would render the
discovery meaningless. Further, the Defendants’ Motion demonstrates that the Court lacks subject
matter jurisdiction, and Plaintiff has stated that intends to respond by filing an amended complaint.
The Court should not allow discovery in a suit in which it is clear that the Court lacks subject
matter jurisdiction and when Plaintiff has already stated that he will file an amended complaint
that could alter the nature of the suit, and, consequently, the scope of discovery.
Finally, none of the discovery sought in Plaintiff’s Motion would impact the Court’s ruling
on the pending Motion to Dismiss. The Defendant’s Motion to Dismiss demonstrated that Plaintiff
cannot rely upon Bivens as a basis for a claim against the named defendants. The discovery sought
by Plaintiff does not seek to show that Plaintiff can maintain the instant Bivens action against the
named defendants either factually, or as a matter of law. For this and for all of the previously-
stated reasons, the Court should refrain from issuing a scheduling order and deny Plaintiff’s
pending Motions, ECF Nos. 15 and 18.
JA076
III. CONCLUSION
WHEREFORE, Defendants respectfully request that the Court deny Plaintiff’s Motions,
ECF Nos. 15 and 18.
Rod J. Rosenstein
_________/s/____________________
(410) 209-4800
I HEREBY CERTIFY that on this 6th day of January, 2016, I filed the foregoing using the
CM/ECF system and also served a copy on Plaintiff via first-class mail to the following:
William C. Bond
PO Box 4823
Baltimore, MD 21211
__________/s/_____________________
Matthew P. Phelps
JA077

WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
*
Defendants.
*
* * * * * * * * * * * * *
PROPOSED ORDER
Upon consideration of Plaintiff’s Motion to Stay (ECF No. 15) and Motion for Discovery
(ECF No. 18), and the Defendants Johnny L. Hughes, Kevin Perkins, and Rod J. Rosenstein’s
Opposition to those Motions, it is this __ day of _______________, 2017 hereby ORDERED that
Plaintiff’s Motion ECF No. 15 is DENIED and Plaintiff’s Motion ECF No. 18 is DENIED.
__________________________________
JA078

FOR THE DISTRICT OF MARYLAND
AT BALTIMORE
WILLIAM C. BOND,
Plaintiff,
v. Civil Action No.: 1:16-02723-DAF
JOHNNY L. HUGHES, et al.
Defendants.
MEMORANDUM OPINION AND ORDER
Pending before the court is Plaintiff’s Complaint against
various federal officials in Maryland. See Doc. No. 1. The
Defendants are the United States Marshal for the District of
Maryland, the Special Agent in Charge of the Federal Bureau of
Investigation (“FBI”), and the United States Attorney for the
District of Maryland. Plaintiff alleges cover-ups, surveillance
and entrapment based on conclusory allegations and little basis
in fact or, for that matter, law. Plaintiff also seeks $15
million from Government Defendants for compensatory damages and
$30 million from them for punitive damages—and he does so 6
times. Plaintiff appears to seek a total of $270 million.
Plaintiff’s allegations are unavailing.
In addition, Plaintiff is a frequent litigant before this
court. Typically, he alleges various blanket but unspecific
JA079
violations of his legal rights. He is now admonished that his
continuing to file frivolous and vexatious lawsuits may result
in an order denying him further access to the court on such
matters.
I. FACTUAL BACKGROUND
For several years, Plaintiff has protested what he claims
to be “‘provable corruption’ in the Maryland U.S. courthouse.”
Id. In April 2013, Plaintiff created a public relations
campaign named the “Baltimore Corruption Wire.” He also created
the phrase “White Guerilla Family” to refer to certain members
of the Maryland federal judiciary. Id.
Plaintiff alleges that principally due to his protests and
corruption allegations he has been interviewed and surveilled by
federal agents. Plaintiff further alleges that members of the
judiciary and other federal officials have conspired to violate
his First Amendment and due process rights. See id. Plaintiff
premises his causes of action on the United States Supreme
Court’s decision in Bivens v. Six Unknown Named Agents, 403 U.S.
388 (1971). In particular, Plaintiff alleges the following six
unconstitutional acts:1
• Count I – On July 19, 2013 and July 30, 2013,
federal agents questioned plaintiff “regarding the

1
To the extent Plaintiff’s Complaint alleges any statutory
claims, the court addresses them in footnote 2, infra.
2

JA080
potential safety of various government officials and
federal judges,” in an effort to “prevent and/or to
intimidate plaintiff’s planned demonstrations . . ..”
Doc. No 1.
• Count II – Plaintiff alleges that he met with
“activists” in July of 2013 to plan a protest at the
U.S. District Courthouse, but that the activists “were
undercover U.S. government agents sent (1) with the
clear intention to sabotage plaintiff’s U.S.
courthouse protests in any way possible and (2) to
criminally entrap plaintiff by attempting to engage
plaintiff in discussions of violence against federal
officials[.]” Doc. No. 1.
• Counts III & IV – Plaintiff alleges in the fall of
2013, a Deputy U.S. Marshal informed Plaintiff that he
had been under surveillance since 2010. Plaintiff
alleges that this surveillance violated his
constitutional rights. See Doc. No. 1.

---
• Count V – Plaintiff alleges that on September 29,
2015, a Deputy U.S. Marshal “invade[d]” his pro se
litigant work and attempted to criminally entrap him.”
Doc. No 1.
• Count VI – Plaintiff alleges that the Defendants
“have at all times since 2001 until present been in an
3

JA081
extended conspiracy to deprive plaintiff of his First
Amendment & due process rights,” and that “[w]hen a
new U.S. Attorney was assigned to Maryland in 2006,
part of his assignment was to continue to ignore
and/or cover-up the aforementioned conspiracy against
plaintiff.” Doc. No 1.
With respect to each count, Plaintiff alleges that “[t]hese
intentional, knowing, bad-faith, and illegal acts by the
defendants caused plaintiff great worry, anxiety, fear,
sleeplessness, etc., amongst many other things, as it was clear
to plaintiff that his enemies would stop at nothing to defeat
his constitutional rights.” Doc. No 1. Subsequently, the
United States filed its Motion to dismiss Plaintiff’s Complaint,
or, in the alternative, substitute the United States as the sole
Defendant and dismiss the Complaint. See Doc. No. 16.
II. APPLICABLE LEGAL STANDARDS
Next, the court articulates the legal standards pertinent
to Rules 12(b)(1), 12(b)(6) and 8(a)(2) of the Federal Rules of
Civil Procedure (“Civil Rules”), respectively.
A. Rule 12(b)(1)
The court commences its analysis with subject matter
jurisdiction. A motion to dismiss for lack of subject matter
jurisdiction under Federal Rule of Civil Procedure 12(b)(1) asks
“whether the court has the competence or authority to hear the
4

JA082
case.” Davis v. Thompson, 367 F. Supp. 2d 792, 799 (D. Md.
2005). Prior to reaching the merits of a case, a federal court
first must determine that it has jurisdiction over the claim
presented. See Sinochem Int’l Co. Ltd. v. Malaysia Int’l
Shipping Corp., 549 U.S. 422, 430-31 (2007) (citing Steel Co. v.
Citizens for Better Env’t, 523 U.S. 83, 93-102 (1998)). When a
defendant moves to dismiss under Rule 12(b)(1), the plaintiff
bears the burden of proving that subject matter jurisdiction
exists. See Evans v. B.F. Perkins Co., 166 F.3d 642, 647 (4th
Cir. 1999) (citing Richmond, Fredericksburg & Potomac R.R. Co.
v. U.S., 945 F.2d 765, 768 (4th Cir. 1991)). The requirement
that the plaintiff establish subject matter jurisdiction “as a
threshold matter ‘springs from the nature and limits of the
judicial power of the United States’ and is ‘inflexible and
without exception.’” Steel Co., 523 U.S. at 94—95 (quoting
Mansfield, C. & L. M. R. Co. v. Swan, 111 U.S. 379, 382 (1884)).
Hence, “[t]he objection that a federal court lacks subject-
matter jurisdiction may be raised by a party, or by a court on
its own initiative, at any stage in the litigation, even after
trial and the entry of judgment.” Arbaugh v. Y & H Corp., 546
U.S. 500, 506 (2006) (citing Fed. R. Civ. P. 12(b)(1)).
In circumstances where a defendant challenges subject
matter jurisdiction, “the district court is to regard the
pleadings as mere evidence on the issue, and may consider
5

JA083
evidence outside the pleadings without converting the proceeding
to one for summary judgment.” Evans, 166 F.3d at 647 (quoting
Richmond, Fredericksburg & Potomac R.R. Co., 945 F.2d at 768);
see also Williams v. U.S., 50 F.3d 299, 304 (4th Cir. 1995)
(When considering exhibits beyond the pleadings, the court “is
free to weigh the evidence and satisfy itself as to the
existence of its power to hear the case.”) (internal quotation
omitted). Under such circumstances, “the court may look beyond
the pleadings and the jurisdictional allegations of the
complaint and view whatever evidence has been submitted on the
issue to determine whether in fact subject matter jurisdiction
exists.” Khoury v. Meserve, 268 F. Supp. 2d 600, 606 (D. Md.
2003) (quotation omitted), aff’d, 85 F. App’x 960 (4th Cir.
2004). The court may properly grant a motion to dismiss for
lack of subject matter jurisdiction “where a claim fails to
allege facts upon which the court may base jurisdiction.”
Davis, 367 F. Supp. 2d at 799 (citing Crosten v. Kamauf, 932 F.
Supp. 676, 679 (D. Md. 1996)).
Dismissal for lack of subject matter jurisdiction tests
whether the court has the authority to hear a case or
controversy. After all, the “[f]ederal courts are courts of
limited jurisdiction, constrained to exercise only the authority
conferred by Article III of the Constitution and affirmatively
granted by federal statute.” Gill v. PNC Bank et al., Civil
6

JA084
Action No. TDC-14-0677, 2015 WL 629004, at *3 (D. Md. Feb. 11,
2015) (quoting In re Bulldog Trucking, Inc., 147 F.3d 347, 352
(4th Cir. 1998)) (internal quotation marks omitted). The
federal courts are not like the state courts, which retain
general jurisdiction. It follows that this court, as a federal
court, is empowered to exercise jurisdiction only when the
Constitution and federal law so permit.2
There is a constitutional provenance at the heart of this
principle. Article III limits the subject matter jurisdiction
of federal courts to “cases” and “controversies.” See Allen v.
Wright, 468 U.S. 737, 750 (1984). Consistent with the “cases”
and “controversies” requirement, plaintiffs must demonstrate
that they have standing to bring, and maintain, suit in federal
court throughout the duration of litigation. In fact, the
United States Supreme Court has cast the doctrine of mootness as
intertwined with standing: “the doctrine of standing set in a

2
Generally speaking, courts should not be in the
philosopher-king business of worrying about consequences so long
as the law commands their behavior. In fact, “judges should . .
. strive (if humanly and so imperfectly) to apply the law as it
is, focusing backward, not forward, and looking to text,
structure, and history to decide what a reasonable reader at the
time of the events in question would have understood the law to
be—not to decide cases based on their own moral convictions or
the policy consequences they believe might serve society best.”
Neil M. Gorsuch, Of Lions and Bears, Judges and Legislators, and
the Legacy of Justice Scalia, 2016 Sumner Canary Lecture at Case
Western Reserve University School of Law (Apr. 7, 2016), in 66
CASE W. RES. L. REV. 905, 906 (2016).
7

JA085
time frame: The requisite personal interest that must exist at
the commencement of the litigation (standing) must continue
throughout its existence (mootness).” Arizonans for Official
English v. Arizona, 520 U.S. 43, 68 n. 22 (1997). This is
because the federal courts “are not permitted to render an
advisory opinion.” Herb v. Pitcairn, 324 U.S. 117, 125—26
(1945). So true is this that “[t]he Supreme Court has made
clear that standing is an essential and unchanging part of that
case-or-controversy requirement, one that states fundamental
limits on federal judicial power in our system of government.”
Doe v. Obama, 631 F.3d 157, 160 (4th Cir. 2011) (quoting Lujan
v. Defenders of Wildlife, 504 U.S. 555, 560 (1992); Allen, 468
U.S. at 750) (citations and internal quotation marks omitted).
To satisfy the standing requirement, a plaintiff must
demonstrate:
(1) that he has suffered an “injury in fact”

that is (a) particularized and (b) actual or
imminent, not conjectural or hypothetical;
(2) the injury is fairly traceable to the
challenged action of the defendant; and (3)
it is likely, as opposed to merely
speculative, that the injury will be
redressed by a favorable decision.
Doe, 631 F.3d at 160 (citing Friends of the Earth, Inc. v.
Laidlaw Envtl. Servs. (TOC), Inc., 528 U.S. 167, 180—81 (2000)).
Furthermore, a plaintiff cannot demonstrate standing by
stating that he or she brings suit on behalf of the general
8

JA086
public. “Plaintiffs may not establish their standing to bring
suit merely because they disagree with a government policy or
because they share the ‘generalized interest of all citizens in
constitutional governance.’” Moss et al. v. Spartanburg Cnty.
Sch. Dist. Seven, 683 F.3d 599, 604–05 (4th Cir. 2012) (quoting
Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208,
217 (1974)). Therefore, a plaintiff may not predicate her
standing to sue “upon an interest . . . which is held in common
by all members of the public, because of the necessarily
abstract nature of the injury all citizens share.” Raffety v.
Prince George’s Cnty. et al, 423 F. Supp. 1045, 1052 (D. Md.
1976) (quoting Schlesinger, 418 U.S. at 220) (internal quotation
marks omitted).
B. Rule 12(b)(6)
“[An] important mechanism for weeding out meritless
claims,” dismissal for failure to state a claim upon which
relief can be granted is premised on Rule 12(b)(6) of the Civil
Rules. Fifth Third Bancorp v. Dudenhoeffer, 134 S. Ct. 2459,
2471 (2014). A Rule 12(b)(6) defense asserts that even if all
the factual allegations in a complaint are true, they still
remain insufficient to establish a cause of action. This might
be because prevailing law governing the adjudicator is set
against such a cause of action. This court is also mindful that
“[w]hether a particular ground for opposing a claim may be the
9

JA087
basis for dismissal for failure to state a claim depends on
whether the allegations in the complaint suffice to establish
that ground, not on the nature of the ground in the abstract.”
Jones v. Bock, 549 U.S. 199, 215 (2007).
“The purpose of a Rule 12(b)(6) motion is to test the
[legal] sufficiency of a complaint; importantly, [a Rule
12(b)(6) motion] does not resolve contests surrounding the
facts, the merits of a claim, or the applicability of defenses.”
Edwards v. City of Goldsboro, 178 F.3d 231, 243–44 (4th Cir.
1999) (citations and internal quotation marks omitted). A
plaintiff must allege “‘enough facts to state a claim to relief
that is plausible on its face’” and “‘raise a right to relief
above the speculative level.’” Wahi v. Charleston Area Med.
Ctr., Inc., 562 F.3d 599, 615 n.26 (4th Cir. 2009) (quoting Bell
Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)).
The United States Supreme Court has maintained that
“[w]hile a complaint . . . does not need detailed factual
allegations, . . . a plaintiff’s obligation to provide the
grounds of his entitle[ment] to relief requires more than labels
and conclusions, and a formulaic recitation of the elements of a
cause of action will not do.” Twombly, 550 U.S. at 555
(citations and internal quotation marks omitted). The court
need not “accept as true unwarranted inferences, unreasonable
conclusions, or arguments.” E. Shore Mkts., Inc. v. J.D.
10

JA088
Assocs. Ltd P’ship, 213 F.3d 175, 180 (4th Cir. 2000). Courts
must also take care not conflate the veracity or even accuracy
underlying the allegations that a plaintiff has leveled against
a defendant with the allegations’ likelihood of success. While
“the pleading must contain something more . . . than . . . a
statement of facts that merely creates a suspicion [of] a
legally cognizable right of action,” 5 C. WRIGHT & A. MILLER, FEDERAL
PRACTICE AND PROCEDURE § 1216, pp. 235–236 (3d ed. 2004),
“assum[ing]” of course “that all the allegations in the
complaint are true (even if doubtful in fact),” Twombly, 550
U.S. at 555, it is also the case that “Rule 12(b)(6) does not
countenance . . . dismissals based on a judge’s disbelief of a
complaint’s factual allegations.” Neitzke v. Williams, 490 U.S.
319, 327 (1989). Therefore, courts must allow a well-pleaded
complaint to proceed even if it is obvious “that a recovery is
very remote and unlikely.” Scheuer v. Rhodes, 416 U.S. 232, 236
(1974). This is the United States Supreme Court’s teaching in
Twombly. See Twombly, 550 U.S. at 555.
C. Rule 8(a)(2)
Rule 8(a)(2) of the Civil Rules provides that “a pleading
must contain a ‘short and plain statement of the claim showing
that the pleader is entitled to relief.’” Ashcroft v. Iqbal,
556 U.S. 662, 677—78 (2009) (citing Federal Rule of Civil
Procedure 8(a)(2)). Rule 8(a)(2) requires plaintiffs to furnish
11

JA089
only “a short and plain statement of the claim showing that the
pleader is entitled to relief,” so that “the defendant [might
have] fair notice of what the . . . claim is and the grounds
upon which it rests.” Conley v. Gibson, 355 U.S. 41, 47 (1957).
Thus, it is clear that Rule 8(a)(2) tends to interplay with Rule
12(b)(6) of the Civil Rules, which governs motions to dismiss.
Cognizant of these principles, the court advances to
analyze Plaintiff’s claims.
III. DISCUSSION
A. Plaintiff Has Stated No Bivens Action Against Defendants in

their Individual Capacities; Plaintiff May Not Maintain a Bivens
Action Against Defendants in their Official Capacities.
(1) Individual Capacities
Plaintiff bases his case on Bivens. In Bivens, the United
States Supreme Court recognized a private cause of action for
certain kinds of constitutional violations. In the Supreme
Court’s words, “[t]he very essence of civil liberty certainly
consists in the right of every individual to claim the
protection of the laws, whenever he receives an injury.”
Bivens, 403 U.S. at 397 (quoting Marbury v. Madison, 5 U.S. 137,
163 (1803)). But Plaintiff must still satisfy the requirement
that a Bivens claim has to state sufficient “factual content
that allows the court to draw the reasonable inference that the
defendant is liable for the misconduct alleged.” Iqbal, 556
U.S. at 678. As such, Plaintiff “must plead that each
12

JA090
Government-official defendant . . . has violated the
Constitution.” Id. at 676 (emphasis added). The Supreme Court
also has asserted that “[i]ndividual government officials
‘cannot be held liable’ in a Bivens suit ‘unless they themselves
acted [unconstitutionally].’” Wood v. Moss, 134 S. Ct. 2056,
2070 (2014) (citing Iqbal, 556 U.S. at 683); Danser v.
Stansberry, 772 F.3d 340, 349 (4th Cir. 2014) (“liability may be
imposed based only on an official’s own conduct.”) (emphasis
added).
Here, Plaintiff has not stated a Bivens claim against any
of the Defendants. The body of the Complaint fails to identify
SAC Perkins and Marshal Hughes. The Complaint contains no
content explaining how either of these Defendants may have
violated Plaintiff’s constitutional rights. To the extent that
they are named as supervisors of the federal agents discussed in
the Complaint, Bivens does not permit respondeat superior
liability. See Trulock v. Freeh, 275 F.3d 391, 402 (4th Cir.
2001) (“In a Bivens suit, there is no respondeat superior
liability.”); Estate of Rosenberg v. Crandell, 56 F.3d 35, 37
(8th Cir. 1995) (“[T]here is no respondeat superior liability
under Bivens. Defendants are liable for their personal acts
only.”). Thus, Plaintiff plainly has failed to state a Bivens
claim as to SAC Perkins and Marshal Hughes.
13

JA091
With respect to U.S. Attorney Rod Rosenstein, Plaintiff’s
Complaint states: “[w]hen [Rosenstein] was assigned to Maryland
in 2006, part of his assignment was to continue to ignore and/or
cover-up the aforementioned conspiracy against Plaintiff.” Doc.
No. 1. Plaintiff, however, has supplied no facts at all to
support his allegation that Rosenstein, himself, did anything to
violate Plaintiff’s constitutional rights. Plaintiff’s
conclusory allegations—he calls it a “cover-up” and a
“conspiracy” but nothing more, Doc. No. 1,—fail to state a
claim. See Iqbal, 556 U.S. at 681 (citing Twombly, 55 U.S. at
554-55). Therefore, Plaintiff has failed to state a Bivens
claim against U.S. Attorney Rosenstein.
(2) Official Capacities
The United States Court of Appeals for the Fourth Circuit
maintains that “a Bivens action does not lie against either
agencies or officials in their official capacity.” Doe v. Chao,
306 F.3d 170, 184 (4th Cir. 2002) (citing FDIC v. Meyer, 510
U.S. 471, at 484-86 (1994)); see also Curtis v. Pracht, 202 F.
Supp. 2d 406, 419 (D. Md. 2002). Accordingly, to the extent
that Plaintiff’s claims against the Defendants are deemed to be
based on their official capacities, Bivens is not helpful to
Plaintiff. Consequently, this Court lacks jurisdiction over
such claims. In order to comprehensively treat the claims
14

JA092
presented, the court will address the remaining salient
questions.
B. Plaintiff has No Standing to Bring a First Amendment Claim.
Plaintiff alleges that the unnamed FBI agents interviewed
him to “prevent and/or to intimidate plaintiff’s planned
demonstrations at the Baltimore U.S. courthouse on August 4,
2013.” Doc. No. 1. Under Fourth Circuit jurisprudence, an
indispensable element of standing for purposes of First
Amendment claims is that a plaintiff must demonstrate some
injury-in-fact. “In First Amendment cases, the injury-in-fact
element is commonly satisfied by a sufficient showing of ‘self-
censorship, which occurs when a claimant is chilled from
exercising h[is] right to free expression.’” Cooksey v.
Futrell, 721 F.3d 226, 235 (4th Cir. 2013) (citations omitted).
In that context, “the chilling effect cannot ‘arise merely from
the individual’s knowledge that a governmental agency was
engaged in certain activities or from the individual’s
concomitant fear that, armed with the fruit of those activities,
the agency might in the future take some other and additional
action detrimental to that individual.’” Id. at 236 (quoting
Laird v. Tatum, 408 U.S. 1, 11 (1972)). Indeed, the Fourth
Circuit impresses upon us that “‘[a]llegations of a subjective
‘chill’ are not an adequate substitute for a claim of specific
15

JA093
present objective harm or a threat of specific future harm [.]’”
Cooksey, 721 F.3d at 236 (quoting Laird, 408 U.S. at 13—14).
There is a raison d’être behind all this. This court’s
adjudicative competence has limits. One of those limits is that
our Nation’s federal courts may not be “transform[ed] . . . into
forums for taxpayers’ generalized grievances about the conduct
of government.” Hein v. Freedom from Religion Found., Inc., 551
U.S. 587, 612 (2007) (plurality opinion) (citations and internal
quotation marks omitted). Such a drastic move “would open the
Judiciary to an arguable charge of providing government by
injunction.” Id. (citations and internal quotation marks
omitted). This aperture “would [also] deputize federal courts
as virtually continuing monitors of the wisdom and soundness of
Executive action, and that, most emphatically, is not the role
of the judiciary.” Id. (citations and internal quotation marks
omitted). This course of conduct would not satisfy Article III,
which limits the jurisdiction of the federal courts to “cases”
and “controversies.”
Plaintiff has furnished this court with no evidence of a
chilling effect on his speech. Plaintiff does not seriously
contest that the reason for the interviews was concern about the
safety of federal judges and other government officials due to
Plaintiff’s communications with them. See Doc. No. 1. However,
never does Plaintiff allege that the agents forbade him from
16

JA094
protesting nor did they take any actions to prevent the
protests. Other than Plaintiff’s own speculation that the
interviews were for the purpose of preventing him from
protesting, he provides no evidence that his speech was chilled
or that he self-censored himself. He certainly did not do the
latter. Quite the contrary, Plaintiff appears to admit that
subsequently he protested for several weeks. See Doc. No. 1.
There is no allegation whatsoever that any of the named
Defendants did anything at all to restrict Plaintiff’s First
Amendment rights.
Accordingly, Plaintiff’s First Amendment claim should be,
and now is, dismissed.
C. Plaintiff Fails to State a Due Process Transgression.
The Due Process Clause of the Fifth Amendment states: “nor
shall any person . . . be deprived of life, liberty, or
property, without due process of law.” U.S. Const. Amend. 5.
There are two types of due process claims: (1) procedural due
process claim which alleges a denial of fundamental procedural
fairness, see Fuentes v. Shevin, 407 U.S. 67, 82 (1972); or (2)
substantive due process, which alleges the exercise of power
without any reasonable justification in the service of a
legitimate governmental objective. See Rucker v. Harford Cty.,
946 F.2d 278, 281 (4th Cir. 1991), cert. denied, 502 U.S. 1097
(1992); see also Daniels v. Williams, 474 U.S. 327, 331 (1986).
17

JA095
Under prevailing jurisprudence, substantive due process
remains a fluid and flexible concept. Violations of substantive
due process take place only in circumstances where the
government’s actions in depriving a person of life, liberty, or
property are so unjust that no amount of fair procedure can
redeem their constitutionality. “[T]he substantive due process
guarantee protects against government power arbitrarily and
oppressively exercised.” Cty. of Sacramento v. Lewis, 523 U.S.
833, 846 (1998). “Asserted denial is to be tested by an
appraisal of the totality of facts in a given case.” Betts v.
Brady, 316 U.S. 455, 462 (1942). This means that “[something]
which may, in one setting, constitute a denial of fundamental
fairness, shocking to the universal sense of justice, may, in
other circumstances, and in the light of other considerations,
fall short of such denial.” Id. In one of those rare dissents
that subsequently gained much currency, the second JUSTICE Harlan
once explained:
[T]he full scope of the liberty guaranteed

by the Due Process Clause . . . is a
rational continuum which, broadly speaking,
includes a freedom from all substantial
arbitrary impositions and purposeless
restraints, . . . and which also recognizes,
what a reasonable and sensitive judgment
must, that certain interests require
particularly careful scrutiny of the state
needs asserted to justify their abridgment.
18

JA096
Poe v. Ullman, 367 U.S. 497, 543 (1961) (Harlan, J., dissenting
from dismissal on jurisdictional grounds) (adopted by joint
opinion in Planned Parenthood of Se. Pa. v. Casey, 505 U.S. 833,
848—49 (1992)). Plaintiff has asserted only conclusory
allegations of perceived due process violations. For example,
even though Plaintiff states that he was informed by a Deputy
U.S. Marshal that he was being surveilled, Plaintiff does not
indicate how, if at all, his due process rights were violated.
Moreover, there also exists no allegation that the government
conducted electronic surveillance of Plaintiff’s home telephone
without obtaining a warrant. Additionally, Plaintiff fails to
attribute any unconstitutional act (or omission) to the named
Defendants. Accordingly, Plaintiff’s due process claim is not
meritorious.
As discussed below, none of the counts alleged by Plaintiff
suffices to state a claim for violating due process.
Count I: Plaintiff alleges several law enforcement visits
to him, “especially [an] attempt to arrest [P]laintiff for
illegal weapons possession.” Doc. No. 1. Plaintiff further
alleges that “the timing” of these alleged actions was “intended
with [only] one goal . . . in mind: to prevent and/or to
intimidate [P]laintiff’s planned demonstrations at the [United
States Courthouse in Baltimore].” Doc. No. 1. Notably,
Plaintiff does not mention a specific legal violation.
19

JA097
Plaintiff’s Count I must be dismissed for both Rule
12(b)(6) and Rule 8(a)(2) deficiencies. With respect to Rule
12(b)(6), Plaintiff fails to state a claim upon which relief can
be granted because Plaintiff quite simply states no claim. He
refers vaguely to blanket “constitutional rights” at one point
but no more. Doc. No. 1. Moreover, whether a complaint must be
dismissed for failure to state a claim “depends on whether the
allegations in the complaint suffice to establish [a requisite]
ground, not on the nature of the ground in the abstract.”
Jones, 549 U.S. at 215 (emphasis added). Neither in the
abstract nor in the allegations contained in the Complaint has
Plaintiff stated a claim on whose basis relief might be
available.
This brings the court to the Rule 8(a)(2) deficiency: “a
pleading must contain a ‘short and plain statement of the claim
showing that the pleader is entitled to relief.’” Iqbal, 556
U.S. at 677—78 (citing Federal Rule of Civil Procedure 8(a)(2)).
Here, “the allegations are conclusory and not entitled to be
assumed true.” Iqbal, 556 U.S. at 681. The alleged law-
enforcement visits might have been supported with ample probable
cause and/or compelling governmental interests, not necessarily
conducted, if conducted they were, with the goal of intimidating
Plaintiff (as he alleges). See Doc. No. 1. The Complaint is
speculative and it glosses over that legitimate possibility.
20

JA098
Just like in Ashcroft, Plaintiff’s omission as to the reasons
impelling the alleged governmental conduct render his complain
deficient. 556 U.S. at 680—81.
Furthermore, if there exist “more likely explanations [for
alleged defendant actions or omissions],” then “the[] [conduct
alleged] do[es] not plausibly establish th[e] purpose[s],”
motives and/or reasons that a plaintiff alleges guided the
defendant(s). Id. at 681. Here it is more likely that
Defendants visited Plaintiff and/or sought to arrest him because
of bona fide and perfectly lawful concerns about illegal conduct
on Plaintiff’s part, rather than any retaliation Defendants
wanted to inflict on Plaintiff. Accordingly, Count I is
dismissed for both Rule 12(b)(6) and Rule 8(a)(2) deficiencies.
Count II: Plaintiff alleges that “[a] ‘black lives matter’
type activist contacted [him]” and then proceeded to “offer[] to
help with the planned protests, including by providing ‘bodies’
to protest, money for advertising, and grassroots help in the
‘black’ community . . ..” Doc. No. 1. But then, Plaintiff
alleges, on the appointed protest day neither this “activist”
nor his “wife” nor the 50 or more “bodies” Plaintiff had been
promised showed up. Doc. No. 1. Plaintiff points to his own
“[i]nformation and belief” that this “‘activist’ and his ‘wife’
were undercover U.S. government agents sent . . . with the clear
intention to sabotage” the planned protests and “to criminally
21

JA099
entrap Plaintiff by attempting to engage [P]laintiff in
discussions of violence against federal officials . . ..” Id.
Plaintiff states no actual legal claim. Consequently,
Count II is dismissed for failure to state a claim under Rule
12(b)(6) of the Civil Rules. Moreover, for reasons similar to
the court’s Count I analysis, here Plaintiff states only
“conclusory” allegations that are grounded solely in conjecture
and speculation without any basis in fact. Ashcroft, 556 U.S.
at 681. Plaintiff’s Complaint neglects to consider the distinct
possibility, and one that is far likelier than the conspiracy
theory Plaintiff advances, that a genuine or even impersonator
of a “Black Lives Matter” activist did interact with Plaintiff
prior to the protest’s appointed hour but, for reasons
unbeknownst to Plaintiff, turned out to be a no-show on the
protest’s appointed hour.
This court has no warrant to hale federal officials, or for
that matter any defendants, before the judicial system on such
flimsy and legally deficient bases. This is impermissible under
Rule 8(a)(2) of the Civil Rules. As a result, Plaintiff’s Count
II must be dismissed for both Rule 12(b)(6) and Rule 8(a)(2)
deficiencies.
Count III: Plaintiff alleges that a deputy U.S. marshal
(DUSM) was “spy[ing]” on Plaintiff since Plaintiff filed a
similar suit against the U.S. Attorney for the District of
22

JA100
Maryland in 2010. Doc. No. 1. Here, Plaintiff mentions due
process as the basis for Count III. However, it is the Fourth
Amendment, instead of due process, that is the appropriate basis
for challenging governmental acts of surveillance. “Substantive
due process analysis is . . . inappropriate in . . . [a] case
only if . . . [a] claim is covered by the Fourth Amendment.”
Lewis, 523 U.S. at 843; see also Katz v. United States, 389 U.S.
347 (1967); Klayman v. Obama, 957 F. Supp. 2d 1 (D.D.C. 2013).
Thus, Count III does not survive the standard required by Rule
12(b)(6).
In addition, once again Plaintiff states only “conclusory”
allegations that are grounded solely in conjecture and
speculation without any basis in fact. Ashcroft, 556 U.S. at
681. This is quite like the court’s aforementioned observations
concerning Counts I and II. Count III thus falls short of
satisfying Rule 8(a)(2) as well. Count III must be dismissed on
account of both Rule 12(b)(6) and Rule 8(a)(2) deficiencies.
Count IV: Plaintiff alleges that the same DUSM “told
[P]laintiff about how his surveillance of [P]laintiff continued
in 2012, after [P]laintiff had lost his home, his dog, all his
possessions, etc., and was living in an unelectrified ‘squat’ in
a derelict building.” Doc. No. 1. Plaintiff mentions “due
process and civil rights” as the bases for this count. For the
reasons given in the court’s Count III analysis, Plaintiff’s
23

JA101
Count IV must be dismissed for both Rule 12(b)(6) and Rule
8(a)(2) deficiencies.
Count V: Plaintiff alleges that the same DUSM endeavored
“to invade [Plaintiff’s] pro se litigant work product” in a qui
tam action Plaintiff had filed against various Government
Defendants earlier. Doc. No. 1. Plaintiff further alleges that
the DUSM “work[ed] in tandem with [a] U.S. judge . . . to
criminally entrap” Plaintiff. Id. Here, Plaintiff does not
even state a single legal basis for the claim. Moreover, the
allegations are just “conclusory.” Ashcroft, 556 U.S. at 681.
For reasons materially indistinguishable from the ones already
given in the earlier analyses, Count V must be dismissed for
both Rule 12(b)(6) and Rule 8(a)(2) deficiencies.
Count VI: Plaintiff alleges that “a federal judge [acted]
with malice aforethought to have a 2001 federal case assigned to
him, which he planned, in advance, to sabotage.” Doc. No. 1.
Two other federal judges are alleged to have helped in covering
this up. Id. According to Plaintiff, there was also a vast
judicial conspiracy to “thwart his actions [repeatedly.]” Id.
Here, while Plaintiff alleges that certain Government Defendants
“have at all times since 2001 until present been [involved] in
an extended conspiracy to deprive [P]laintiff of his First
Amendment [and] due process rights, his liberty, and his right
to his own property, if not other constitutional deprivations,”
24

JA102
Plaintiff does not assert a cognizable legal right this alleged
conspiracy actually violates. For reasons materially
indistinguishable from the ones already given in the earlier
analyses, Count VI must be dismissed for both Rule 12(b)(6) and
Rule 8(a)(2) deficiencies.
Consequently, all of Plaintiff’s due process claims fail.
They must be dismissed. The same, the court already has
explained, is true of the First Amendment claim—on the basis of
standing. In short, all of Plaintiff’s claims are to be
dismissed.3
D. Defendants are Entitled to Qualified Immunity.
Qualified immunity protects federal officials from
liability in Bivens suits unless a plaintiff can plead “facts
showing (1) that the official violated a statutory or
constitutional right, and (2) that the right was ‘clearly

3
It is difficult to understand whether Plaintiff's
Complaint incorporates any claim under the Federal Tort Claims
Act (“FTCA”), 28 U.S.C. § 2679(d)(1). The court grants the
United States’ motion to be substituted in place of individual
Defendants as to the FTCA claim. (Doc. No. 16-1.) Any tort
claim must be dismissed because Plaintiff failed to exhaust
administrative remedies. The FTCA provides that a plaintiff
must exhaust administrative remedies by, inter alia, filing a
claim with the “appropriate Federal agency.” 28 U.S.C. §
2675(a). A tort claim against the United States is “forever
barred” unless it is presented in writing to such agency within
two years after the claim accrues. 28 U.S.C. § 2401(b).
Plaintiff has not submitted a claim to any federal agency with
respect to any tort claims. Consequently, Plaintiff’s FTCA
claim incorporating tort causes of action shall be forever
barred.
25

JA103
established’ at the time of the challenged conduct.” Ashcroft
v. al-Kidd, 563 U.S. 731, 735 (2011). In order to satisfy the
first prong, a plaintiff must allege sufficient facts that “each
Government-official defendant, through the official’s own
individual actions, has violated the Constitution.” Iqbal, 556
U.S. at 676 (emphasis added). As for the second prong, the
right’s delineations must be “sufficiently definite,” so “that
any reasonable official in the defendant’s shoes would have
understood that he was violating it.” Plumhoff v. Rickard, 134
S. Ct. 2012, 2023 (2014). The reason is simple: Before
subjecting a federal official who was trying her mortal best to
suit for actions committed in the course and/or pursuit of duty,
the law must be certain that she had had adequate notice that
her conduct was ultra vires.
Here, Plaintiff cannot show that Defendants are not
entitled to qualified immunity because he has not sufficiently
pleaded the first element—that any of the Defendants violated
his constitutional rights. Indeed, Plaintiff has not expressed
how any named Defendants trampled on his constitutional rights.
Thus, Defendants are entitled to qualified immunity. The claims
leveled against them must be dismissed.
IV. CONCLUSION
This Complaint reads rather like a political thriller. And
like other novels, in this Complaint there seem to be far too
26

JA104
much fiction, precious little fact, and copious innuendo—in
short, too many conclusory allegations—to commend it for its
veracity or even its plausibility. This is not a salutary
feature.
Plaintiff, it seems, is intent on draining the Federal
Judiciary of our “limited resources.” Zatko v. California, 502
U.S. 16, 18 (1991) (per curiam). The court, therefore, repeats
its admonition that Plaintiff should take care not to lose
credibility by filing vexatious and frivolous complaints. The
reason is simple: “[E]very paper filed with the Clerk of this
[c]ourt, no matter how repetitious or frivolous, requires some
portion of the institution’s limited resources. A part of the
[c]ourt’s responsibility is to see that these resources are
allocated in a way that promotes the interests of justice.” In
re McDonald, 489 U.S. 180, 184 (1989) (per curiam); see also
Martin v. District of Columbia Court of Appeals, 506 U.S. 1, 1
(1992) (per curiam) (applying this principle to “notorious
abuser[s]” of the judicial system). Plaintiff’s becoming such a
notorious abuser helps no one, least of all Plaintiff himself.
The United States’ Motion to be substituted in place of
individual Defendants as to the Federal Tort Claims Act (“FTCA”)
claim is GRANTED. See Doc. No. 16. The United States’ Motion
to Dismiss this Complaint is GRANTED in full. See id.
Plaintiff having provided the court with no convincing reasons,
27

JA105
Plaintiff’s Motion to Stay and/or Toll Plaintiff’s Opposition to
the Defendants’ Forthcoming Response to the Complaint is DENIED.
See Doc. No. 15. Plaintiff’s Motion for Discovery is DENIED.
See Doc. No. 18. Defendants’ Consent Motion for an Extension of
Time to Respond to Pending Motions Doc. Nos. 15 and 18 is
GRANTED. See Doc. No. 19. The court DIRECTS the Clerk to remove
this case from the court’s docket.
The Clerk is further directed to forward a copy of this
Memorandum Opinion and Order to counsel of record and Plaintiff,
pro se.
IT IS SO ORDERED this 12th day of April, 2017.
Enter:
David A. Faber
28

JA106

AT BALTIMORE
WILLIAM C. BOND,
Plaintiff,
Defendants.
JUDGMENT ORDER
For reasons expressed in the Memorandum Opinion and Order
filed this day, the court hereby GRANTS the United States’
Motion to be substituted in place of individual Defendants as to
the Federal Tort Claims Act (“FTCA”) claim, see Doc. No. 16;
GRANTS in full the United States’ Motion to Dismiss this
Complaint, see id.; DENIES Plaintiff’s Motion to Stay and/or
Toll Plaintiff’s Opposition to the Defendants’ Forthcoming
Response to the Complaint, see Doc. No. 15; DENIES Plaintiff’s
Motion for Discovery, see Doc. No. 18; GRANTS Defendants’
Consent Motion for an Extension of Time to Respond to Pending
Motions Doc. Nos. 15 and 18, see Doc. No. 19. The court DIRECTS
the Clerk to remove this case from the court’s docket.
The Clerk is directed to forward a certified copy of this
Judgment Order to counsel of record and Plaintiff, pro se.
JA107
IT IS SO ORDERED this 12th day of April, 2017.
Enter:
David A. Faber
2

JA108
•
' . ,:::;_-
2Dl7fFtY-9 Pi:/2: 3 I

FOR THE DISTRICT OF MARYLAND 13Y
----J1EFU1 y
NORTHERN DIVISION
WILLIAM C. BOND, *
Plaintiff pro se, *
v. Civil Action No.: 16-02723-DAF
*
JOHNNY L. HUGHES, et al.,
*
Defendants.
*
* * * * * * * * *
PLAINTIFF'S MOTION TO REOPEN CASE AND TO FILE AN AMENDED

COMPLAINT
Comes now, plaintiff prose, William C. Bond, pursuant to Fed. R. Civ. P. 59(e), and hereby files
this motion to reopen the case and to file an amended complaint. For the reasons set forth in the
memorandum in support filed simultaneously herewith, plaintiff respectfully requests that the
court's order of April 12, 2017, dismissing and closing the above captioned case be vacated, the
case be reopened, and the Amended Complaint attached hereto as Exhibit I be deemed filed.
WHEREFORE, for the aforementioned reasons, plaintiff prays the court grants the requested
relief expeditiously.
WILLIAM C. BOND
JA109
Appeal:
' 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 115 of 424
Pro Se
P.O. Box 4823
(443) 970-2887
I HEREBY CERTIFY that on the 9th day of May 2017, copies of PLAINTIFF'S MOTION TO
REOPEN CASE AND TO FILE AN AMENDED COMPLAINT were served by Email to:
ALLEN F. LOUCKS, AUSA, U.S. Attorney's Office, District of Maryland, 36 S. Charles St.,
4 th FL, Baltimore, Maryland 21201, allen.loucks@usdoj.gov; and to: MATTHEW P. PHELPS,
th
AUSA, U.S. Attorney's Office, District ofMaryland, 36 S. Charles St., 4 Fl., Baltimore,
Maryland 21201, matthew.phelps@usdoj.gov; and by hand delivery to: CLERK, United States
District Court for the District of Maryland, Baltimore Division, 101 West Lombard Street,
Baltimore, Maryland 21201. The required judge's courtesy copy was also served by FedEx
Overnight Delivery, postage prepaid, to: Hon. DAVID A. FABER, Senior United States District
Judge, 2303 Elizabeth Kee Federal Building, 601 Federal Street, Bluefield, WV 24701.
WILLIAM C. BOND
JA110
l , C' ,~
,' I
~ •. , ..
." ....' '
ZDIJf;A'{-GP"12 "I
J " : .;

NORTHERN DIVISION BY___ _
WILLIAM C BOND, *
Plaintiff pro se, *
V, Civil Action No,: 16-02723-DAF
*
JOHNNY L HUGHES, et aL,
*
Defendants,
*
* * * * * * * * *
MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION TO REOPEN CASE AND
TO FILE AN AMENDED COMPLAINT
Plaintiff prose, William C Bond, pursuant to Fed, R. Civ, P, 59(e), hereby files this
memorandum in support of his motion to reopen the case and to file an amended complaint. For
the reasons set forth herein, plaintiff respectfully requests that the court's order of April I 2,
2017, dismissing and closing the above captioned case be vacated, the case be reopened, and the
Amended Complaint attached hereto as Exhibit I be deemed filed, 1 Counsel for the defendants
were consulted per Local Rule 103,6(d), but did not consent to the relief sought herein,
I. INTRODUCTION
This court dismissed plaintiffs complaint by memorandum opinion & order on April 12,2017,
1
A 'redlined' copy of the Amended Complaint showing the revisions to the original
Complaint per Local Rule J 03,6(c) is also attached hereto as Exhibit 2,
JA111
(See docket entry number 22.) This memorandum opinion was bereft of any mention of
plaintiffs prose status, his filings at docket entry numbers 15, 18, & 21, which offered actual
evidence, nor any discussion of the standard of review a district court must conduct regarding
prose complaints. See, Erickson v. Pardus, 551 U.S. 89, 94 (2007). See also, Gordon v. Leeke,
574 F.2d 1147, 1173 (4 Cir.1978). In addition, while the United States Court of Appeals for the
Fourth Circuit has a "strong policy that cases be decided on the merits" United States v. Shaffer
Equip. Co., 11 F.3d 450, 453 (4th Cir. 1993), this court terminated this case mid-stride and both
denied plaintiff the right to answer the defendants' FRCP 12 motion and also denied plaintiff his
right under the rules to file an amended complaint.
The court appeared nonplussed by the meat of plaintiff's allegations -that he had been
persecuted by federal judges for personal, non-legal reasons, and that those same judges had
violated plaintiff's First & Second Amendment rights, as well as other constitutional rights, to
prevent plaintiff from bringing to light the subject misconduct by public protest at the Baltimore
U.S. Courthouse. Instead, the court called plaintiffs allegations "conclusory" with "little basis in
fact or, for that matter, law." The court then appeared to make sport of plaintiff's financial
demands that were based upon more than 15 years of abuse by federal actors misusing their
positions. Moving on, the court then claimed "plaintiff is a frequent litigant before this court"
even though this case was just plaintiff's second appearance. The court then chilled plaintiff and
warned, "(plaintifl] is now admonished that his continuing to file frivolous and vexatious
lawsuits may result in an order denying him further access to the court on such matters." (See
memorandum and order at 1-2.)
JA112
Not finished, the court went on to say plaintiffs "Complaint reads rather like a political thriller,"
compared it to a "novel[]," and claimed, "in this Complaint there seem to be far too much fiction,
precious little fact, and copious innuendo-in short, too many conclusory allegations-to
commend it for its veracity or even its plausibility." (See memorandum and order at 26-27.)
Importantly, the court had no patience with plaintiff not naming the proper defendants. This
deficiency has now been corrected.
II. THE STANDARD OF REVIEW TO FILE AN AMENDED COMPLAINT AFTER A

FINAL JUDGMENT
Recently, Maryland U.S. District Judge James K. Bredar stated the standard of review for cases
such as this: 2
In order to grant a motion to amend a complaint in a case in which

it previously entered a final judgment, a court must first vacate said
judgment according to Rule 59(e) or Rule 60(b) of the Federal
Rules of Civil Procedure. Laber v. Harvey. 438 F.3d 404, 427 (4th
Cir. 2006). However, in such a case, the district court need not
focus on the legal standards applicable to those rules, but "need
only ask whether the amendment should be granted, just as it
would on a prejudgment motion to amend pursuant to Fed. R. Civ.
P. IS(a)." Katyle v. Penn Nat. Gaming. Inc., 637 F.3d 462,471
(4th Cir. 2011). Accordingly, a party may amend its complaint
only if doing so avoids "prejudice, bad faith, [and] futility." Id.
"Futility is apparent if the proposed amended complaint fails to
state a claim under the applicable rules and accompanying
standards." Id.
2
Please see: case no.: I: I 6-cv-00749-JKB (D. Md.) at docket entry no.: 27.
3
JA113
A complaint must contain "sufficient factual matter, accepted as

true, to 'state a claim to relief that is plausible on its face."'
Ashcroft v. Igbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic
Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Facial plausibility
exists "when the plaintiff pleads factual content that allows the
court to draw the reasonable inference that the defendant is liable
for the misconduct alleged." Igbal, 556 U.S. al 678. An inference
of a mere possibility of misconduct is not sufficient to support a
plausible claim. Id. at 679. As the Twombly opinion stated,
"Factual allegations must be enough to raise a right to relief above
the speculative level." 550 U.S. at 555. "A pleading that offers
'labels and conclusions' or 'a formulaic recitation of the elements
of a cause of action will not do.' ... Nor does a complaint suffice
if it tenders 'naked assertion[ s]' devoid of 'further factual
enhancement."' Iqbal, 556 U.S. at 678 (quoting Twombly. 550
U.S. at 555, 557). Although when considering a motion to dismiss
a court must accept as true all factual allegations in the complaint,
this principle does not apply to legal conclusions couched as
factual allegations. Twombly. 550 U.S. at 555.
III. ARGUMENT
In light of the above standard, it is clear that the proposed Amended Complaint would not be
prejudicial to Defendant, is not being filed in bad faith, and is not futile.
A. The Proposed Amendment is Not Prejudicial or in Bad Faith
With respect to prejudice, it is well settled that where the defendants are fully aware of the nature
of the action or the events giving rise to the action from the very outset of the litigation, an
amendment to the claim does not create prejudice. Davis v. Piper Aircraft Corp., 615 F.2d 606,
613 (4th Cir. 1980) ("Because defendant was from the outset made fully aware of the events
giving rise to the action, an allowance of the amendment could not in any way prejudice the
preparation of the defendant's case."). Here, there is no unfair surprise which would result in
JA114
•'
prejudice for the defendants,
First, the substitution of defendants offers no surprise or prejudice as Fed, R, Civ. P.
15(c)(l)(C)(i) & (ii) and 15(c)(2) are satisfied. 3 The Amended Complaint presents identical
claims as the original Complaint, albeit Counts IV & V have been eliminated as unnecessary and
Count II has been eliminated because, at this time, plaintiff cannot prove the identities of the
subject actors due to his limited resources and abilities, The Amended Complaint does not add
new claims, expand the scope of the claims, 4 present new legal bases for recovery, or pursue new
legal remedies from the defendants. Rather, the proposed amendment is designed solely to
supplement and bolster the factual allegations regarding the three remaining causes of action to
specifically address the deficiencies identified by the court in its memorandum. Further, the new
facts (and the relevance thereof) have been known to the defendants for some time, mostly
because they committed them first-hand, and/or were raised in other legal or complaint-style
venues over the course of this long-running litigation, Thus, the defendants cannot argue unfair
surprise with respect to the new allegations in the amended complaint.
Moreover, there has not been any undue delay to prejudice defendants, This case is still in its
infancy; the only substantive actions thus far have been the filing of the original complaint and
the filing and ruling upon the defendants' motion to dismiss without the benefit of plaintiffs
3
As the district court, itself made the decision not to order service upon the "unnamed
judges" (now the "Three Maryland U.S. Judges") representative should offer no surprise or
prejudice as clearly, they were on notice of the complaint, and, in fact, received courtesy copies
of same. Further, said officers are subject to FRCP 15(c)(2).
4
Count I clearly implied Second Amendment violations in the original complaint.
5
JA115
opposition. The parties have not engaged in any discovery or taken any other steps beyond the
pleadings stage. Likewise, plaintiff has acted promptly since the court's order of April 12, 2017.
Plaintiff promptly reviewed, investigated further, and confirmed his factual and legal bases for
bringing this case and promptly filed the present motion, all within the 28 days allowed under
FRCP 59. Thus, there has been no delay in seeking leave to amend prejudicing the defendants. In
this same regard, plaintiff has not acted in bad faith. The matter was not delayed, plaintiff acted
diligently in pursuing the amendment, and the claims find adequate basis in both fact and law.
B. The Proposed Amendment is Not Futile
Plaintiffs request for leave to amend to bolster the factual and legal basis for his three remaining
claims is not futile and, therefore, should be permitted. The court, clearly, in their memorandum
found plaintiff had not sued the proper parties, had made conclusory allegations that were not
factually supported, that his law was suspect, and his damages unclear.
In the Amended Complaint, plaintiff adds extensive factual allegations to support all three of his
remaining Counts. First, plaintiff names two U.S. government law-enforcers who he alleges
violated his constitutional rights. Plaintiff then goes on to offer specific factual allegations that
are both plausible and true. Plaintiff also discusses the damages rendered by his alleged
constitutional violations by the defendants. Finally, plaintiff explains the connection and motive
of the "unnamed" defendants to the constitutional violations against him.
As the foregoing discussion demonstrates, the Amended Complaint addresses the deficiencies in
JA116
the original Complaint. Accordingly, granting the amendment would not be futile. To the extent
the defendants would argue otherwise, that argument would be properly addressed by a separate
motion to dismiss with full briefing by the parties. For the purposes of the amendment analysis, it
is clear that the standard has been satisfied and plaintiff should be granted leave to amend.
IV. CONCLUSION
For the foregoing reasons, plaintiff respectfully requests that the court reopen the case and accept
plaintiffs Amended Complaint as filed.
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
prose Iitigator@aol .com
I HEREBY CERTIFY that on the 9th day of May 2017, copies of MEMORANDUM IN
SUPPORT OF PLAINTIFF'S MOTION TO REOPEN CASE AND TO FILE AN
AMENDED COMPLAINT were served by Email to: ALLEN F. LOUCKS, AUSA, U.S.
Attorney's Office, District of Maryland, 36 S. Charles St., 4 th Fl., Baltimore, Maryland 21201,
allen.loucks@usdoj.gov; and to: MATTHEW P. PHELPS, AUSA, U.S. Attorney's Office,
District of Maryland, 36 S. Charles St., 4 th Fl., Baltimore, Maryland 21201,
matthew.phelps@usdoj.gov; and by hand delivery to: CLERK, United States District Court for
the District of Maryland, Baltimore Division, 101 West Lombard Street, Baltimore, Maryland
21201. The required judge's courtesy copy was also served by FedEx Overnight Delivery,
JA117
,
postage prepaid, to: Hon. DAVID A. FABER, Senior United States District Judge, 2303
Elizabeth Kee Federal Building, 601 Federal Street, Bluefield, WV 24701.
WILLIAM C. BOND
JA118
, Case 1:16-cv-02723-DAF Document 24-2 Filed 05/09/17 Page 1 of 32
:::,
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IN THE UNITED STATES DISTRICT COURT -< __,
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FOR THE DISTRICT OF MARYLAND ::-, ::~: ~·
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NORTHERN DIVISION -:
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WILLIAM C. BOND
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P.O. Box 4823 * (.,)
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*
Plaintiff prose,
* Civil Action No.: 16-02723-DAF
v.
ROBERT MARK FREDERICK

Deputy United States Marshal
and
PATRICK S. DUGAN
Supervisory Special Agent
and
"THREE MARYLAND U.S. JUDGES"

Chief Judge
*
Defendants.
*
* * * * * * * * *
JA119
AMENDED COMPLAINT WITH DEMAND FOR JURY TRIAL
Comes now plaintiff, William C. Bond, pro se, (hereinafter "Plaintiff') and brings this lawsuit
against Deputy United States Marshal for the District of Maryland Robert Mark Frederick;
Supervisory Special Agent of the United States Federal Bureau of Investigation for the District
of Maryland Patrick S. Dugan; and 'Three Maryland U.S. Judges" of the United States District
Court for the District of Maryland, including residing Maryland U.S. circuit judges; all acting in
their 'individual capacities' (hereinafter "Defendants").
misuse of the U.S. Marshals Service and the FBI, acting at the direction of three Maryland
Article III judges outside the scope of their authority and immunity, to violate plaintiff's
constitutional rights, including his First Amendment, Second Amendment, & due process rights
-all to cover up judicial misconduct, obstruction of justice, and systemic 'fraud upon the court'
perpetrated against plaintiff by the defendants.
the First Amendment, the Second Amendment, & due process clauses of the U.S. Constitution,
and any other laws, rules, or applicable parts of the constitution.
JA120
INTRODUCTION
This action concerns a long-term dispute over a valuable item of personal property, a literary
manuscript of high monetary and artistic value, which was taken and kept from plaintiff for no
legitimate reason.
FACTS
1. Plaintiff has been involved in significant Maryland federal court litigation, both through
counsel and prose, since 2001. Plaintiff has lost motions and cases in ways that not only seemed
1
unfair, but unconstitutional.
2. Having had enough of the judicial imperturbability shown toward plaintiffs allegations
regarding the deprivation of his constitutional rights, plaintiff then decided to publicly protest
what he saw as 'provable corruption' in the Baltimore U.S. Courthouse at the courthouse itself.
Corruption Wire.'
4. This campaign was supported by several social media platforms.
1
Plaintiffs litigation history is summarized in Count VJ.
3
JA121
r
2
summer and fall 2013 to much notice. The first ads appeared on July 17, 2013.
7. Plaintiff also wrote an Op-Ed for The Baltimore Sun detailing what had recently transpired in
the "Bromwell" public corruption case titled "CORRUPTION Sub Curia." When the Op-Ed was
rejected over length concerns by The Sun's editors, plaintiff then made the Op-Ed the center of
his anti-federal-court-corruption activities. The Op-Ed explains the background for plaintiffs
3
First Amendment objections as to what he saw going on at the Baltimore U. S. Courthouse.
U.S. Courthouse.
COUNTI
2
Please see: Exhibit nos.: I & 2. The ads can also be seen here: (I)
https:/ /www .scribd.com/doc/296483607 /Corruption-Wire-web-ad & (2)
https: //www .scri bd. com/ doc/296483 897/Corruption-Wire-print-ad
3
Please see: Exhibit no.: 3, the subject Op-Ed, which may also may be viewed here:
https://www .scribd.com/doc/ 136418039/William-Bond-CORRUPTION-S uh-Curia-op ed
4
JA122
11. During the July 19, 2013, meeting, the federal agents wished to come inside plaintiffs
12. The agents followed plaintiff to this 'common room' and acted, on guard, as if plaintiff were
a physical threat to them.
13. The DUSM, whose name was Robert Mark Frederick, voiced several times how much he had
been looking forward to meeting plaintiff.
14. The FBI agent, whose name was Special Agent Chris Wood, who led the questioning,
peppered plaintiff with questions regarding the potential safety of various government officials
and federal judges, some of whom were former neighbors of plaintiff, and one whose daughter
used to babysit for plaintiffs stepchildren.
15. Plaintiff was alarmed by the agents' line of questioning because he had never physically
threatened any government officials or federal judges in any way. Plaintiff made it clear his only
goal was to have certain judges judicially reprimanded and/or sanctioned, and for his stolen
property and resultant damages in a long-running case returned to him.
JA123
•
16. FBI Special Agent Wood asked repeatedly what could be done to make the scheduled
17. The next day, on July 20, 2013, plaintiff memorialized this meeting in writing and put the
Maryland U.S. Attorney's Office, including several of their top officers, on direct notice that
these alleged concerns by government law-enforcers over nonexistent and never explained
'threats' allegedly attributed to plaintiff were fabricated by the government and had no basis in
fact. 4
18. The second knock on your door from government law-enforcers provokes fear. Why are they
back?
saw: Standing directly across from him was the same DUSM from the first visit, Robert Mark
Frederick, whom plaintiff would later learn was the Chief of the Maryland U.S. Marshals
4
Please see: Exhibit no. 4, plaintiff's July 20, 2013, email to the USAO MD with noted
sections highlighted for the court's convenience and email addresses redacted. The court should
also note that while this communication is somewhat rambling because plaintiff was very angry
about what had just been done to him by the government, it clearly shows plaintiffs state of
mind at the exact time in question, and that his injuries were real.
6
JA124
•
Service's Protective Intelligence Unit (hereinafter "USMS PIU"). To plaintiffs direct right, in a
semi-ready-to-tackle-stance was a different FBI agent than from the first visit, Patrick S. Dugan,
whom plaintiff would later learn was the FBI's Supervisory Special Agent in charge of the
Baltimore Field Office's 'Violent Crimes Unit.'
21. The federal agents demanded plaintiff's firearms, which plaintiff denied having.
22. The federal agents again requested to come inside plaintiff's then-apartment, which plaintiff
plaintiff.
24. Again, plaintiff was followed to the 'common room' and treated again as ifhe were a
physical threat.
any government officials or federal judges in any danger from plaintiff? Plaintiff's answers were
repeatedly "no" and "no."
JA125
26. Where were plaintiff's guns? Where were plaintiffs guns? Many times, it was asked.
Plaintiff even had to stand up, raise his shirt, and turn around to show the agents that he had no
handguns on his person.
27. As plaintiff's firearms were confiscated in 2001, as described in detail in Count VI, by the
State of Maryland in a criminal action (charges dismissed, record expunged), plaintiff proffered
that they should know where the guns were. Yet, the agents claimed the state gun database still
showed plaintiff owning firearms. Plaintiff told the agents that all his former guns were either
with his ex-wife or unreturned by the State of Maryland.
28. Again, as FBI Special Agent Wood had earlier asked, FBI Supervisory Special Agent Dugan
asked-holding some of plaintiff's 'White Guerrilla Family' promotional literature in his hand -
"What would it take to make this [the planned demonstrations] go away?"
29. Plaintiff proffered to Agent Dugan that the United States Attorney was the one who should
be asking that question and that plaintiff was happy to meet with him re: same. 5
30. The FBI agent didn't like that answer, and stated that he was sent here and had to
immediately report back - to whom, he would not say. 6 At that point, many of the same issues
discussed in Count VI were discussed with a focus on what the government could offer as a
5
FBI, USMS, & the USAO MD, to be held, as a courtesy, in a major law firm's conference room.
6
On information and belief, the "Three Maryland U.S. Judges" were independently
operating & controlling the government agents outside of the normal 'chain-of-command.'
8
JA126
resolution of plaintiffs greater complaints regarding the underlying long-running litigation.
Agent Dugan didn't fully understand the back story of the long-running litigation and how·the
"Bromwell" public corruption case fit into the picture. DUSM Frederick calmly explained to
Agent Dugan that the "Bromwell" case was like a "domino," and that if plaintiff was able to be
victorious in that action, it would create a "domino-effect" and thus cause plaintiff to run the
table and win all his long-running litigations very quickly.
in possession of firearms they believed plaintiff still possessed. Plaintiff was warned that if they
found him to still be in possession of firearms that they would come back and "slap the bracelets
[handcuffs] on his writs and take him straight to Central Booking [Baltimore City Jail]."
32. The USMS PIU manuals specifically speak about the unit being prohibited from using their
resources to violate the First Amendment rights of citizens. 7
33. Yet, the timing of these visits, especially the attempt to arrest plaintiff for illegal weapons
possession, was intended with one goal and one goal only in mind: to prevent and/or intimidate
plaintiffs planned demonstrations at the Baltimore U.S. Courthouse on August 4, 2013.
34. Clearly, as alleged later in this complaint, the government was surveilling plaintiff since
2010. If government officials and/or federal judges were in such physical danger from plaintiff
7
Please see: Exhibit no.: 5, the USMS Policy Directives, Judicial Security, 10.7
Protective Investigations at D. 7. (See, Page 2.)
9
JA127
why would the government law-enforcers wait so long to make contact with plaintiff and contest
his supposed actions?
35. Clearly, as well, ii is simply implausible to say that after three years of surveillance, now, just
two (2) days after plaintiffs first City Paper ads - ads which received much notice in Baltimore
- the law enforcers suddenly found exigent reasons to attempt to intimidate and influence
plaintiffs First Amendment rights. For example, because of this first visit by the law-enforcers,
plaintiff was forced to consult a criminal defense lawyer, other lawyers and business people,
numerous friends, to worry and lose much sleep, and to be greatly distracted when he was on an
abbreviated time line and had much still to do to organize the August 4, 2013, protests, amongst
many other things.
36. It is also implausible that the reason the law enforcers came back a second time to arrest
plaintiff for alleged illegal weapons possession just five (5) days before his planned
demonstrations was out of fear for the safety of government officials or federal judges - as those
manufactured fears had already been allayed by their first visit and plaintiffs letter to the USAO
MD - and that this second act was not anything but another effort to stop plaintiffs planned
demonstrations and to violate his First Amendment rights. Otherwise, why bring up detailed talk
of 'settlement'? This second visit caused plaintiff the same injuries as just recounted above, only
they were exacerbated, as plaintiff now only had five (5) days left before his first protest at the
Baltimore U.S. Courthouse.
10
JA128
37. But, there is another reason to believe the government agents acted unconstitutionally: In
8
2013, plaintiff was legally allowed, both by state and federal law, to possess firearms.
38. The reason for this was Congress, since at least 2007, had ceded restoration of certain
firearms rights to participating states, Maryland being one of them, via the NICS Improvement
Amendments Act of 2007. See, Tyler v. Hillsdale Cty. Sheriff's Dep't, 837 F.3d 678 (6th Cir.
2016) (en banc). 9
39. Further, the Maryland United States Attorney's Office knew that plaintiff was not in
violation of any firearms laws, as plaintiff's former Maryland criminal defense lawyer - again,
plaintiff's litigation history is discussed in more detail in Count VI- had discussed plaintiffs
firearms qualifications with Barbara S. Sale, the USAO MD's Chief, Criminal Division, in 2006-
2007.
40. Not only has the government been threatening plaintiff with illegal arrest should he reacquire
firearms since at least 2006-7, but they actually tried to do exactly that on July 30, 2013, both in
violation of plaintiffs Second Amendment rights, and to misuse the law to violate plaintiff's
First Amendment rights.
8 Please see: Exhibit nos.: 6, 7, & 8; plaintiff's 2001 physician's certificate and the 2013
Maryland law.
9 Please see: Exhibit no.: 9, the subject Tyler opinion, page 4, which can also be viewed
here: http://www.opn.ca6.uscourts.gov/opinions.pdf/16a0234p-06.pdf
11
JA129
I •
41. After the July 30, 2013, threats, DUSM Frederick continued the threats by seeking
information from plaintiff's ex-wife to arrest plaintiff sometime before the August 4, 2013,
initial protest. These acts continued as described later in this complaint.
plaintiff that the federal officials who had wronged him would stop at nothing to defeat his
constitutional rights.
damages.
[ COUNTS II, IV, & V from the original Complaint are deleted from this Amended
Complaint.]
COUNT III
45. During these protests, plaintiff was always supervised by the DUSM PIU agent and often by
Federal Protection Service officers, sometimes in full SW AT gear.
12
JA130
•
46. Naturally, the DUSM agent and plaintiff became acquainted, especially as DUSM Frederick
had claimed he had long-wanted to meet plaintiff.
47. DUSM Frederick continued to probe plaintiff regarding his alleged possession of illegal guns
and wondered if plaintiff had any guns "buried." At one protest in early fall 2013, DUSM
Frederick told plaintiff about a conversation he had just had with Agent Dugan. Agent Dugan
had "asked him ifwe need to have the [FBI] SWAT Team come and arrest Bill [plaintiff]?" He
then recited more of the conversation he had with Agent Dugan as to whether plaintiff"would
survive a night in Central Booking [Baltimore City Jail]?"
48. Yet soon, DUSM Frederick came to see that plaintiff was no "sociopath" as he insinuated the
U.S. DOJ profilers had attempted to "mark" him, but was instead, in his words, a "lover," not a
"fighter," who just wanted to "go back to the country club," which was how DUSM Frederick -
a big football fan - saw former tennis players such as plaintiff.
49. Plaintiff and DUSM Frederick spent much time chatting at the Baltimore U.S. Courthouse
during plaintiffs demonstrations. IO
IO The DUSM was convinced (as the government's 'expert' on plaintiff) that plaintiff was
in the "right" and that he had "gotten f'*ked-over by the 'judges,"' which was a statement he
made many times.
13
JA131
11
'judges' were misusing the U.S. Marshal's indoor courthouse gun range.
51. Several times DUSM Frederick explained that the reason he had always wanted to meet
plaintiff was because of his particular letter writing abilities, letters which acted as 'prosecutions'
of certain judges and other government officials' reputations. Apparently, plaintiff had really
gotten under the skin of certain judges and officials.
been surveilling plaintiff since 2010.
53. This revelation surprised plaintiff very much, as plaintiff had wondered many times how the
government always seemed to be one step ahead in many parts of his continuing litigations.
the government. And it is implausible to say that plaintiff must plead specifics on this allegation
when only the government knows what information they gained by the surveillance of plaintiff
that they then used against him in the continuing litigations. In short, the spying upon plaintiff, if
used in litigation, as opposed to legitimate law enforcement purposes, is a gross constitutional
violation by the government.
55. This continual surveillance is also a violation of the rules of court, which government
11
This information became a qui tam lawsuit. Please see: 15-cv-00199-DAF (D. Md.).
14
JA132
attorneys are required to follow. That no government attorney ever notified any federal judge
supervising federal litigations before them of this issue, either ex parte or under seal, shows
impermissible intent on behalf of the defendants.
56. Further, because of this admitted governmental surveillance of plaintiff, plaintiff was forced
to limit and curtail the freedom of his expression to others via the telephone, the internet, and by
other means, from 2013 forward.
damages.
COUNT VI
59. Plaintiff is the author of the unpublished fictionalized copyrighted manuscript titled Self-
Portrait of a Patricide.
15
JA133
60. In the spring of 2001, plaintiff discovered that a copy- one of only two in known existence -
of his manuscript had been stolen from the law offices of his deceased attorney by actors in a
child custody proceeding in Baltimore City, Maryland.
61. The custody case pitted plaintiffs ex-wife's ex-husband and her father (hereinafter the
"custody case opponents") against plaintiffs ex-wife and him.
62. These custody case opponents had earlier been investigated, indicted, and prosecuted by the
Maryland U.S. Attorney's Office in a multi-district action. This action resulted in convictions
and fines.
63. In the late spring of 2001, plaintiff discovered that a handgun had been stolen from a locked
gun safe in his home. Plaintiff made a police report about this incident to the Baltimore City
Police Department.
64. On May 25, 2001, plaintiffs and his ex-wife's home was raided by a Maryland State Police
SW AT team and plaintiff was charged with illegal handgun possession. Plaintiff spent one night
in Central Booking, Baltimore's notorious & very dangerous jail.
65. The basis of the charges was that plaintiff had spent more than 30 days in a mental health
facility due to an Ohio 1981 juvenile delinquency adjudication, and thus was prevented by
Maryland law from possessing firearms.
16
JA134
66. Plaintiff immediately retained the "dean" of the Maryland criminal defense bar, one Richard
M. Karceski, Esq.
67. The first thing Karceski did was to call plaintiffs former Ohio attorney named Gerald A.
Messerman. Messerman had always told plaintiff that his juvenile record would be expunged at a
certain date and then later wrote plaintiff a formal letter stating that his juvenile record was
expunged. Nevertheless, the State of Maryland was using plaintiffs Ohio juvenile record to
prosecute him and Karceski asked Messerman how that was possible if the subject record was
12
expunged?
68. Turned out plaintiffs juvenile record - despite the Messerman letter to the contrary- was
never expunged.
69. Plaintiff was in very big trouble. The State of Maryland was seeking a 10-year-prison-
sentence for a misdemeanor, and was not even hiding the fact that they were trying to re-punish
plaintiff for his juvenile act, according to the Maryland Assistant Attorney General who was
prosecuting the case.
12
Please see: Exhibit nos.: 10 & 11, Gerald A. Messerman, Esq., 1986 & 1994 letters to
plaintiff.
17
JA135
70. Both the custody case opponents and the State of Maryland then sought to use plaintiffs
stolen manuscript in their respective cases - to rip plaintiff's ex-wife's children from her custody
and to imprison plaintiff for 10 years.
71. Plaintiff hired a top First Amendment lawyer who then filed a copyright action to gain the
return of the manuscript, all copies made, and to prevent its further unauthorized use in the U.S.
District Court for the District of Maryland on August 29, 2001. This case was assigned to U.S.
District Judge Marvin J. Garbis.
72. Karceski had many conversations in 2001 & 2002 with Messerman. The book was a big
subject, especially as Messerman had read an earlier draft in the early 1990's. Messerman knew
in the late spring and early summer of 2001 that the copyright case was coming. When it was
filed, Messerman asked Karceski who the judge was? Karceski told him it was Judge Garbis.
Messerman then told Karceski that he knew Judge Garbis, but did not say why or how.
73. Importantly, Messerman knew at this time that he was subject to a malpractice action based
upon his false representation to plaintiff that his juvenile record was expunged, a false
representation that had actually gotten plaintiff charged with a crime. In speaking with Karceski,
Messerman acted more like a prosecutor toward plaintiff and defended himself that there was no
malpractice if plaintiff was convicted of the handgun charges due to the vagaries of malpractice
liability. Messerman was also very worried about his high-profile and spotless reputation, as he
claimed to have never been sued before for malpractice.
18
JA136
74. Despite the clear error, Messerman adamantly refused to come to Maryland and testify
truthfully in the criminal case as to his incorrect and false representations to plaintiff.
75. On November 20, 2001, Judge Garbis held a TRO hearing in the copyright case. Information
- for the first time - was introduced into the court record regarding Messerman' s contacts in the
late J980's with one of the copyright case defendants.
76. Ruling from the bench, and after making a very brief reference to knowing Messerman and
complimenting his legal acumen, Judge Garbis refused to order the return - ever - of any or all
copies of plaintiffs property and ordered plaintiff to pay the individual defendants' legal fees. In
essence, Judge Garbis ordered plaintiff to pay the thieves for their efforts expended to steal his
property.
77. Soon after this order, plaintiff flew to Cleveland, Ohio for an unpleasant meeting with
Messerman. At this meeting, Messerman told plaintiff that Judge Garbis and he were graduate
school classmates in 1961 at an exclusive 8-member program run by Georgetown University
Law School called the E. Barrett Prettyman Fellowship. When accepted at this program, the
graduate law students all lived together in a Washington, D.C., row home under the supervision
of a professor who also directed them in providing legal defense for low-income city residents.
In short, Judge Garbis and Messerman were housemates in post-graduate Jaw school. Later, they
19
JA137
would visit each other both in Ohio and, on information and belief, when Judge Garbis held a bat
mitzvah for one of his daughters in Maryland, amongst other contacts.
78. The criminal case against plaintiff (See again 'l['l[65-66 above) was dismissed by Baltimore
City Circuit Court Judge John C. Themelis, after almost one year of intense litigation, on April
22, 2002, based upon the expert opinion of noted Maryland forensic psychiatrist Michael K.
Spodak who provided a 'certificate' to the court, required under Maryland law, testifying as to
13
plaintiff's 'capability' to possess firearms at all times in question.
79. On January 24, 2003, the U.S. Fourth Circuit issued a published opinion in the appealed
copyright case. Writing for the court, U.S. Circuit Judge Paul V. Niemeyer stated that Judge
Garbis had not gone far enough and ordered that the law firm defendants, who were self-
represented, could now seek attorneys' fees from plaintiff. Judge Niemeyer also suggested that
the remedy to the conversion of plaintiff's copyrighted property lay in a state action despite
federal copyright law preempting state law.
80. On remand, Judge Garbis awarded the full set of copyright actors more than $181,000 in
attorneys' fees.
13
Please see, again: Exhibit no.: 6.
20
JA138
81. Soon after, Judge Garbis' recusal was sought. Judge Garbis responded with an order denying
• · 14
that request, an d state d , m pertment part:
"When assigned this instant case in August of 2001, I noted that

Plaintiffs criminal counsel in Cleveland had been Mr. Messerman.
This fact was of no moment to me whatsoever." (Emphasis
added.)[Judge Garbis Memorandum and Order, April 23, 2003.]
It is clear from this statement, as plaintiffs copyright action was filed on August 29, 2001, and
made no mention of Messerman, that Messerman was having secret, clandestine conversations
with either Judge Garbis, or someone on his behalf.
82. Plaintiff then sued all the copyright actors, Messerman, and others, in three different
Maryland state actions that lasted from 2003 until 2006. All of these state actions were
dismissed, except for one settlement, with both trial and state appellate courts relying almost
wholly upon the federal rulings of Judges Garbis & Niemeyer.
83. Later, in 2008, plaintiff met with a very prominent Baltimore lawyer in his/her office. (This
person's identity is being withheld at this time to protect him/her from unnecessary exposure to
retaliation.)
84. This lawyer knew Judge Garbis very well.
14
Please see: Exhibit no.: 12, Judge Garbis Memorandum & Order re: Recusal at docket
entry no.: 108 in case no.: I :01-cv-02600-MJG (D. Md ..). The court should also note how Judge
Garbis substituted the word "criminal" for ')uvenile."
21
JA139
85. Sometime in 2004-2006, the prominent Baltimore lawyer spoke to Judge Garbis about
plaintiff. During this conversation, Judge Garbis made many highly disparaging remarks about
plaintiff. These remarks surprised the prominent Baltimore lawyer because, familiar with
plaintiff and his issues, he saw plaintiff to be in the right.
86. Judge Garbis told the prominent Baltimore lawyer that plaintiff was a "very bad man," that
"plaintiff was very dangerous," that "[the prominent Baltimore lawyer] should stay away from
[plaintiff]," and many other things that all showed pervasive bias toward plaintiff. The prominent
lawyer told plaintiff that Judge Garbis had actual "bias" against him. The prominent lawyer also
suggested that, if plaintiff could not correct what Judge Garbis had done to him in the copyright
case, that plaintiff should hold "public protests" at the U.S. courthouse against Judge Garbis,
which is when plaintiff first got the idea for the protest schedule he would later undertake in
2013.
87. The Maryland mental health facility where plaintiff was sent in 1981 by an Ohio juvenile
court was also sued in Maryland state court for handing out plaintiffs complete medical &
mental health records, absent a subpoena, in summer 2001 to the Maryland Attorney General's
Office, who, as already stated, was prosecuting the criminal case relating to plaintiffs firearms.
88. Sometime between 2003-2005, the lawyer representing The Sheppard and Enoch Pratt
Hospital, Daniel J. Moore, told plaintiffs lawyers in that case that a board member, who was
22
JA140
also a lawyer, was "adamantly outraged" that plaintiff had sued the hospital and had ordered Mr.
Moore to "under no circumstances" settle plaintiffs claims. This was very odd considering the
claimed violations were of federally protected records. 15 These statements were allegedly made
in front of other board members and/or witnesses.
89. On information and belief, that lawyer was also a U.S. District Judge named J. Frederick
Motz. Judge Motz, and his father before him, were very long-term Board of Trustees members &
16
chairs of the hospital and took a very personal and protective interest in the institution.
90. During discovery in the three state lawsuits, plaintiff discovered that the copyright case
actors, at the direction of copyright case lawyers, had not turned over reams of subpoenaed
documents and had committed perjury under oath regarding material facts, such as not producing
documents that showed they knew in advance that they were going to plaintiffs deceased
lawyer's office to attempt to gain plaintiffs property. 17 These three state cases which plaintiff
pursued because he was sent in that direction by federal court orders in the copyright case
consumed an extraordinary amount of resources.
15
Later, before the case was taken to Maryland's highest court, a nuisance settlement
would be left not fully consummated.
16
Please see: Exhibit no.: 13, the SEPH Board of Trustees as of 2017.
17
In July 2004, the USAO MD opened a criminal investigation into these matters led by
the office's Chief, Criminal Division, Barbara S. Sale. Coincidentally, as a young AUSA, Mrs.
Sale had led the aforementioned prosecution of the custody case opponents. Nevertheless,
prosecution was declined and the investigation was closed in May 2005.
23
JA141
91. On August 30, 2005, plaintiff was struck by a car while riding his bicycle in Baltimore's
rural countryside and suffered catastrophic injuries. Plaintiff spent more than a year in recovery,
during which time he exceeded the best prognosis. Constantly on his mind the entire time was all
of which was just stated above.
92. Beginning in 2007, plaintiff began his pro se efforts to gain justice in the copyright case and
related issues by filing three (3) separate prose actions in the Maryland U.S. District Court.
93. First, plaintiff challenged Judge Garbis' recusal and other orders under FRCP 60.
94. Then plaintiff filed a FRCP 60 "Independent Action" seeking tort damages against the
copyright actors. The district court assigned this action to Judge Motz. This assignment was
troublesome to plaintiff for several reasons, most immediately, the above-mentioned Sheppard &
Enoch Pratt Hospital situation.
95. Plaintiff also sued under the FOIA the Maryland U.S. Attorney's Office for their criminal
investigative files from their 2004-6 investigation regarding the copyright case and the Maryland
U.S. District Court for information about one of the copyright case actors that was 'under seal' in
the "Bromwell" public corruption case.
96. Judge Garbis again refused to answer substantively as to any of the recusal issues, i.e., how
did he know about Messerman's and plaintiffs relationship before he was assigned the copyright
24
JA142
case? Clearly, the basic fact regarding recusal motions is that a subject judge is frequently in
unique possession of the information sought and, thus, has a special obligation to come forward
and disclose all relevant facts to the parties, fully and robustly. Certainly, federal law, the judicial
canons, and abundant case law, are all clear: federal jndges dealing with recnsal should err on the
side of facts that will support recusal. Further, it is inappropriate for a federal judge to conceal or
fail to disclose recusal related facts known to the judge, like here, with the later-discovered
intensity of the prior relationship between Judge Garbis and Messerman.
97. Importantly, Judge Garbis also never mentioned his pervasive bias against plaintiff as
recounted above to the prominent Baltimore lawyer.
98. Judge Motz refused to entertain any substantive analysis of the FRCP 60 allegations, instead
relying upon res judicata of Judge Garbis' 2001 opinion as defeating later discovered fraud upon
the court allegations.
99. Importantly, Judge Motz never put upon the record that he hated plaintiff and that he had
intervened to prevent the Sheppard & Enoch Pratt Hospital, of which, as discussed above, he was
a long-term board member and chair, from fairly financially settling the obvious wrong they had
committed against plaintiff.
I 00. The FOIA case was litigated to a settlement conference, at which point the settlement judge
informed plaintiff that ifhe wished the "Bromwell" records, that he could not get those records
25
JA143
under the FOIA from the court, but instead plaintiff had to go back to the presiding judge and
make a proper request to him.
101. Plaintiff then took these three prose actions lo the U.S. Fourth Circuit, who ordered the
defendants to answer in the primary copyright case FRCP 60 action. Nevertheless, all three
actions were dismissed without any substantive review at the direction of Judge Niemeyer and
other panel members.
102. Plaintiff then took all three matters to the U.S. Supreme Court, which dismissed plaintiffs
petitions for certiorari in early 2009.
103. Heeding the settlement judge's instructions, plaintiff then moved in March 2009 to unseal
the "Bromwell" attorney disqualification records before the correct U.S. district judge. The name
of that judge was Judge Motz, who again never brought up his pervasive bias issues against
plaintiff as discussed above.
104. Surprisingly, the Maryland U.S. Attorney's Office now joined plaintiff in his efforts to
18
unseal the "Bromwell" records. This act made local and national news.
18
Please see these two Maryland Daily Record news stories: (1)
https:/ /www. scri bd. corn/document/ 1364 25 369/Federal-prosecutors-will in g-to-unseal-more-
Bromwell-docs- Maryl and- Daily-Record-A pri 1-10-2009 & (2)
https://www.scribd.com/document/136425931/Bromwell-documents-to-remain-sealed-
Maryland-Daily-Record-July-l 7-2009.
26
JA144
105. But, Judge Motz ignored all efforts to unseal the subject documents.
106. Plaintiff then took the matter to the U.S. Fourth Circuit where he was joined again by the
Maryland U.S. Attorney's Office. Again, in an unpublished opinion, Judge Niemeyer and fellow
panel members dismissed the case without any analysis of the substantive issues.
107. All matters now dismissed, an intermediary prompted an informal meeting between Judge
Niemeyer and plaintiff. Plaintiff's goal was to find out what the basis was for the denial of all his
rights before Judge Niemeyer over many years.
108. Plaintiff met twice with Judge Niemeyer in the summer of 2010. Judge Niemeyer told
plaintiff that his litigations "should have never been brought," that "they would never let him
win," and that "if you don't stop [your litigations], you will be destroyed," amongst many other
things. 19
109. In fall 2010, seeking shelter from the Maryland and Fourth Circuit courts, plaintiff filed a
lawsuit against the Maryland U.S. Attorney's Office and The Washington Post newspaper in the
U.S. District Court for the District of Columbia. The lawsuit was based upon statements made to
plaintiff by Judge Niemeyer that allegedly reset the statute of limitations against the U.S. DOJ
for declining to prosecute the copyright case actors in 2004-6 for non-allowed reasons. The D.C.
19
Please see: Exhibits nos.: 14, 15, & 16; the memorandum, pages 12-13, and the
affidavit, at docket no. 239 in 01-cv-2600-MJG (D. Md ..), and the motion to recuse filed in
Fourth Circuit case no.: 14-6017.
27
JA145
court dismissed the case in summer 2012, all the while refusing to acknowledge plaintiff's
evidence regarding his meetings with Judge Niemeyer.
110. Not backing down, in August 2012, plaintiff came right back to Judge Motz in the
"Bromwell" case and filed a new recusal motion, including, in detail, the information gained
20
from Judge Niemeyer. This time the Maryland U.S. Attorney's Office was silent.
111. Again, not only did Judge Motz not answer the newly-learned recusa1 issues, he again
neglected to reveal his past conduct against plaintiff in the earlier described Maryland state
lawsuit.
112. In late 2012 and early 2013, plaintiff complained about the above-mentioned judicial
disabilities to the Chief Judge of the U.S. Fourth Circuit, who returned the complaint to plaintiff,
and to U.S. Senator Barbara Mikulski, who referred the matter to U.S. DOJ, where it died in a
procedural Catch-22.
113. Plaintiff's decision to publicly protest what he believed to be long term corruption at the
Baltimore U.S. Courthouse in 2013 was no lightly undertaken matter, but one considered after
some then-12-years-of-non-stop litigation where plaintiff's inability to recover his own property
and damages resulting from same was both nonsensical and legally unjustified.
20
Please see, again: Exhibit nos.: 14, 15, & 16.
28
JA146
114. The motive in this long story is simple, Judge Garbis set out to protect his old classmate,
housemate, and friend Messerman in any way he could from 2001 forward.
115. Judge Garbis' conduct, by stating in his 2003 recusal order that he knew, when assigned the
copyright case, information that was in none of the papers filed, would strongly suggest that the
assignment of the case to Judge Garbis was not random. Later, information not provided by
Judge Garbis at assignment, or immediately when it should have been at the TRO hearing,
showed that Judge Garbis and Messerman had a long-term, very close relationship. Clearly, the
issues Messerman was facing in 2001 were not just some little annoyance, but one where his
entire reputational life was on the line because of the false and wrong misrepresentations he had
previously made to plaintiff. And clearly, Judge Garbis went far outside of the copyright issues
in his order to assure that plaintiffs unpublished manuscript would be used against him in the
pending criminal and custody cases, which was eerily like the tact Messerman had used with
Karceski. Finally, Ohio and Maryland have some 18 million people combined, and yet two
people, associated by an 8-member 1961 graduate law school program, come together at the
exact moment in time that Messerman sought the exact help he needed to save his reputation.
Not only is this coincidence implausible, given all the facts listed above, it would be implausible
to suggest anything but that the copyright case was defiled.
116. Judge Garbis clearly spread negative opinions about plaintiff to others, opinions he had
allegedly learned unethically from Messerman and/or others on his behalf in their secret
29
JA147
conversations before the copyright case was filed, so as to make sure no judge in the Baltimore
U.S. Courthouse would give him any benefit of the doubt.
117. While it is not known why, Judge Motz joined Judge Garbis, and together they eviscerated
plaintiffs rights under 28 U.S.C. 144 & 455. Further, the individual and collected acts by these
defendants go far from simple ethics violations and become, by their length and stubbornness,
violations of plaintiff's constitutional rights to due process and his own property, and in the
process, became an actual, albeit unstated, Bill of Attainder put upon plaintiffs head by the
defendants.
118. Plaintiff has been forced to live with the stress and strain of litigation going on now 16
years because of the defendants' illegal and unconstitutional acts. During these 16 years, plaintiff
has lost two homes, all his money, all his personal property, two prized & beloved pets, his wife,
his step-children, most if not all his friends & neighbors, his physical health, has been subjected
to gross scorn and ridicule, and the prime years of his middle-age have been consumed by
interests that should have been resolved long ago except for malice and hatred toward him by the
defendants.
119. These intentional, knowing, bad-faith, unfair, and wrong acts by the defendants have caused
plaintiff great worry, anxiety, fear, sleeplessness, large financial losses, etc., amongst many other
things, as it was clear to plaintiff that the federal officials who had wronged him would stop at
30
JA148
nothing to defeat his constitutional rights. In addition, plaintiff has had his reputation absolutely
destroyed by the defendants' imperturbable and unconstitutional long-term treatment of him.
120. Judge Garbis, by all that has been learned, should have immediately recused himself from
the copyright case in 2001, and at all times afterward, because of his connection to Messerman,
which he still has never fully disclosed. Why Judge Garbis involved Judges Motz & Niemeyer is
unknown. But, clearly, plaintiff has been procedurally blocked at every tum since 2001, with not
one substantive review of the facts that was not defiled. All the circumstances and inexplicable
decisions recounted in this complaint, when taken together, suggest an aggregate of acts that
were corruptly taken - that the underlying behavior itself was corrupt.
121. And as defendant DUSM Frederick said in Count I of this complaint, the "Bromwell" case
was the "domino" that could knock over all the other "dominos," i.e., expose all the unethical
rulings against plaintiff. Therefore, the defendants, now greatly worried by plaintiff's 'White
Guerrilla Family' advertisements and planned 'Baltimore Corruption Wire' demonstrations at the
Baltimore U.S. Courthouse - just days away at the time - had great & plausible motive to seek
plaintiffs wrongful & illegal arrest to prevent same at all costs.
122. Further, it doesn't matter that the defendants were unable to arrest plaintiff on July 30,
2013. What matters is that they tried. Just as they tried and succeeded in diluting plaintiffs
demonstration planning and execution. Clearly, their reasons were that they were trying to make
plaintiffs planned demonstrations go away by any means possible. By any means.
31
JA149
123. Wherefore, for the aforementioned wrongful & unconstitutional conduct, plaintiff seeks,
$20,000,000 from the defendants for compensatory damages, and $40,000,000 from the
defendants for punitive damages.
Civil rights actions are given preference in the Fourth Circuit. Because of the great length of time
these matters have continued and the great harm caused plaintiff, plaintiff prays that this court
issue an expedited briefing schedule in this case as soon as possible.
WILLIAMC. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
proselitigator@aol .com
32
JA150
'"_., ..,_'Jr.
~ · _ I,~•- l
\Z:22
.,-.l :1 '- ,,.,_

FOR THE DISTRICT OF MARYLAND ____ .
= .· •---
NORTHERN DIVISION
WILLIAM C. BOND
P.O. Box 4823 *
*
-Plaintiff pro se,
V.
JOHl'INY L HUGHeSROBERT MARK FREDERICK

Baltimore, Maryland 2 I 20 I,
and
KeVIN PeRKI~IS
PATRICK S. DUGAN
Supervisory Special Agent iA Charge
and
ROD J. ROSeNSTelN
"THREE MARYLAND U.S. JUDGES''

Chief Judge
United States Atterney
Office ef theDistrict Court UAited States Atterney
JA151
36 S. Cl,arles St., Fsm1A Flesr
Baltimsre, MD 21201,
and
Baltimore, Marvland 21 ?0 1.
*
Defendants.
"UNKNOWN NAMED MARYLAND U.S. JUDGES"

ele The Hsn. Catl,erine C. Blake
C!,iefJudge;;;
United States Distriet Csurt

Distriet sf Maryland
IOI West Lsmeard Street
Ballimsre, Maryland 21201,
Defendants.
*
* * * * * * * * *
INTRODUCTION
The FePoFteF slowed the small speedboat, then eut the engine off. "Ve YleFeabout a mile out
from BaltimoFe's lnneF harbor, where the big eaFgo ships drnpped enehoF in the .Patepseo
Rh,eF. The eaFly fall 2010 dav was sunny, yet windy, the eFisp soFt of day wheFe shoFts and
a long sleeve polo 0YeFa T shiFt felt just Fight. The Feporter pulled out some beers and
ehips from a eooler, "Cl,eers!" He said. "Now, tell me all about this meeting you had with
the Fourth Cireuit judge."
"Sure," I answered, as the boot bobbed up and down in small weyes. "But, first, eon vou
tell me why ','fe're meeting in the midst of hundreds of thousands of people in the middle of
the Fell's Point Fun Festi'iel, and why we're talking way out here in the middle of the
harbor?"
"I wanted to see who's fellowing you and make sure that no one ean listen in on what we
say ... "
JA152
AMENDED COMPLAINT WITH DEMAND FOR JURY TRIAL
Comes now plaintiff, William C. Bond, prose, (hereinafter "Plaintiff") and brings this lawsuit
against theDeputv United States Marshal for the District of Maryland, his offiee & offieers; lclie
Robert Mark Frederick· Supervisory Special Agent in Charge of the United States Federal
Bureau of Investigation for the District of Maryland, his office & officers; the United States
Attorney for the District of Maryland, his office & officers; aHd the "Unknown Named Patrick S.
Dugan· and "Three Maryland U.S. Judges" of the United States District Court for the District of
Maryland, including-ilfl3/ residing Maryland U.S. circuit judges; all acting in their 'individual
capacities' (hereinafter "Defendants").
misuse of the U.S. Marshals Service and the FBI, acting 'tmder the eolor of law,' at the direction
of rog1IBthree Maryland Article III judges aoooutsid~ the Mar)·laml U.S. Atterne)·'s Offices_c_pJ2e
of their authoritv and immunity, to violate plaintiffs conslitutional rights, including his First
Amendment. Second Amendment. & due process rights - all to cover up criminal & ethical
judicial misconduct, obstruction of justice, and systemic 'fraud upon the court' perpetrated
against plaintiff by the defendants.
the First Amendment. the Second Amendment_ & due process clauses of the U.S. Constitution,
and any other laws. rules, or applicable lawsparts of--ftllesf the constitution.
JA153
INTRODUCTION
This action concerns a long-term dispute over a valuable item of personal property. a literary
manuscript of hif!h monetary and artistic value, which was taken and kept from plaintiff for no
le!!itimare reason.
FACTS
1. Plaintiff is the e!lly lmewn {Jrese litigant in U.S. juris13rudenee history whom the U.S. DOJ
has ever joined to unseal ene ef their own eriminal eases.+
2. This 'Bromwell' aetion reeeived mueh attentien, lloth loeally in Maryland, and nationally via
the Ass0eiated Press, in 2009 2010.~
3. J>levertheless, the diurict eourt denied plaintiff his constitutional rights re: standing, then the
Fourth Circuit remained mute as lo the slatant deprivation of13laintiffs constitutional rights.
JA154
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JA156
-7

Bhas been involved in si£:nificant Maryland federal court litigation. both through counsel and
prose, since 200 I. Plaintiff has lost motions and cases in ways that not only seemed unfair. but
1
unconstitutional.
;/,.Having had enough of the judicial imperturbability shown toward plaintiffs allegations
recregarding the deprivation of his constitutional rights, plaintiff then decided to publicly protest
!hewhat he saw as 'provable corruption' in the MarylaAdBaltimore U.S. ei;.;ourthouse at the
courthouse itself.
¼J Beginning in April 2013, plaintiff created a public relations campaign called 'Baltimore
Corruption Wire.'
.J-+:1.
This campaign was supported by Faeebook, Twit!er, YmiT11be,Seribd, ChaAge.org, &
F11Adrazrsevcralsocial media platforms.
+&;'j,.The campaign was focused around an advertising slogan "Is the 'WHITE GUERRILLA
.J-9!,.This ad campaign slogan ran in print and web formats in Baltimore's City Paper during
2
summer and fall 2013 to much notice. The first ads atmeared on July 17. 2013.
1
Plaintiffs litigation history is summarized in Count VI.
JA157
±91.Plaintiff also wrote an Op-Ed for tLhe Baltimore Sun detailing what had recently transpired
in the 'Brnmwell"'Bromwell"' public co1Tuption case titled "CORRUPTION Sub Curia."
±-h When the Op-Ed was rejected over length concerns by tLhe Sun's editors, plaintiff then made
the Op-Ed the center of his anti-federal-court-corruption activities, as it m,plaiAed iA detail how
the MarylaAd federal c01c1rt

had heeeme aA 1c1pper
class versieA of Hie Aotori01c1s'Black G1c1errilla
family' prisoA gaAg.+
22. :Needless ts say, mese activities attracted a lot ofAotice hy Baltimore's close lmit legal elites.
H~Tl1e Op-Ed explains the background for plaintiffs First Amendment objections as t.o what he
3
saw rwing on at the Baltimore U.S. Courthmi,<,_e.
Ji.Then, plaintiff announced a public protest schedule to begin August 4, 2013, at the Baltimore
U.S. courthouse, aAd publicly solicited the same citi2oeAsviho '>vouldlater become the
#BlackbivesMatter movemeAt to jeiA him ts correct the prnvable cerruptieA, aAd double
staAdards for rich & poor, iA the MarylaAd U.S. courthouse, as evideAced by the secret self
dealiAg ,vhich was prnvable fact iA the 'Brnm·Nell' case.
2
Please see: Exhibit nos.: 1 & 2. The ads can also be seen here: (I)
https://www .scribd.com/doc/296483607 /Corruption-Wire-web-ad & (2)
https ://www .scribd.com/doc/296483 897 /Corruption-Wire-print -ad
3
https:/ /www .scribd.com/doc/ 136418039/Wil liam-Bond-CORR UPTION-Sub-Curia-op-ed
JA158
COUNTI
;¾Courthouse.
COUNTI
2. The first knock on your door from government Jaw-enforcers is something one never forgets.
~I 0. On July 19, 2013, and July 30, 2013, plaintiff was visited at his then-apartment by one
±61 I. During the July 19, 2013, meeting, the federal agents wished to come inside plaintiffs
12. The agents followed plaintiff to this 'common room' and acted, on guard, as if plaintiff was a
viole1lt erimiAal ready lo a!laek !hem.
2g_ Oddly, !he DUSMphysical threat lo them.
10
JA159
13. The DUSM. whose l}ame was Robert Mark Frederick. voiced several times how much he had
±914. The FBI agent. whose name was Special Agent Chris Wood, who led the questioning,
used to babysit for plaintiff's stepchildren. 8
15. Plaintiff was alarmed by the agents' line of questioning because he had never physicallv
threatened any government officials or federal iudgcs in any way. Plaintiff made it clear t&the
agents that their line of questioning had no basis in fact, that it bordered on fantaS)', and that
13laintiffhad made it clear hishis only goal was to have certain judges remoYed from the federal
bench by either im13eachment or forced resignation.
31. l'levertheless, the FBI agentjudicially reprimanded and/or sanctioned. and for his stolen
property and resultant dama2:cs in a long-runnin>! case returned to him.
16. FBI Special AQ:entWood asked repeatedly what could be done to make the scheduled
11
JA160
:+;!17.Tge r1ext day, on July 20. 7013, plaintilTmcmorialized this meetin2 in writin2 and put the
Mar,,land U.S. Attorney's Office. includinu scveLal of their top officers. on dirccJr)l}tice that
thcs_calleged concerns bv govermnc.nUaw-c_nforcers over nonexistent_ and never expluin!=-cl
'threats' alleKedlv attributed to plaintiff were fabricated by the government and had no basis in
l.S_.The second knock on your door from government law-enforcers provokes fear.
J,h Why are they back?
341.2. Before plaintiff opened his then-apartment door on July 30, 2013, he asked the federal
agents outside if they had a warrant, which they, again, did not have.
~20. When plaintiff opened his then-apartment door - staying within the threshold, this is what
he saw: Standing directly across from him was the same DUSM from the first visit. Robert Mark
Service's Protective Intelligence Unit (hereinafter "USMS PIU"). To plaintiff's direct right, in a
Please see: Exhibit no. 4, plaintiff's July 20, 2013, email to the USAO MD with noted sections
4
highlighted for the court's convenience and email addresses redacted. The court should also note
that while this communication is somewhat rambling because plaintiff was very angry about
what had just been done to him by the government, it clearly shows plaintiffs state of mind at
the exact time in question, and that his injuries were real.
12
JA161
whom plaintiff would later learn was the FBJ's Supervisory Special Agent in charge of the
¾21. The federal agents demanded plaintiff's firearms, which plaintiff denied having.
:J:7-22.
The federal agents again requested to come inside plaintiffs then-apartment, which
plaintiff denied them permission to do.
~23. Plaintiff then agreed to go speak with the federal agents in the same 'common room' as
plaintiff.
'.W24.Again, plaintiff was followed to the 'common room' and treated again as ifhe were a
violeot eriminal ready to eommeoee mayhem wit-Ii the noo eJ,isteot 'gats' I-Ilelaw eoforeers
sought.
4-0physical threat.
any federal judges or government officials or federal iudges in any danger from plaintiff?
Plaintiffs answers were repeatedly "no" and "no."
13
JA162
4+26. Where were plaintiffs guns? Where were plaintiffs guns? 1.000 times it was asked.
4'.1.As all ofl\1any times. it was asked. Plaintiff even had to stand up. raise his shirt. and turn
around 10 show 1he agents that he had 119handguns on his person.
27. As plaintiffs firearms were confiscated in 2001. as described in detail in Count VI, by the
State of Maryland in a !JHfflOFtedcriminal action (charges dismissed, record expunged), plaintiff
proffered that they should damR well know where the guns were. Yet. the agents claimed the
state gun database still showed plaintiff owning fireanns. Plaintiff told the agents that all his
forrn_e_i:_guns
were either with his ex-wife or unreturned by the State of Maryland.
~28. Again, the.as FBI aSpccial Agent Wood ha.clearlier asked, FBI SupcrvisoJY.5.pecial Agent
Du£an asked-holding some of plaintiffs 'White Guerrilla Family' promotional literature in his
hand - "What would it take to make this [the planned demonstrations] go away?"
4429. Plaintiff proffered to meFBI a:\gent Dugan that the USAO MDUnited States Attorney
was the one who should be asking that question and that plaintiff was happy to meet with
themhirn re: same. 5
5
Later, in fall 2013, the FBI agent would schedule, then cancel, a meeting between the FBI, the
USMS, & the USAO MD, to be held, as a courtesy, in a major law firm's BaltimoFe conference
room.
14
JA163
~30. The FBI agent didn't like that answer, and stated that he was sent to iRterview 13laiRtiffte
galher certaiR iRfermatioR aRa that lie liaa te report back immeaiatelyhere and had to
6
immediately report back - to whom, he would not say.
4e At that point, many of the same issues discussed in Count VI were discussed with a focus on
what the government could ofter as a resolution of plaintiffs greater complaints regarding the
underlying long-running litigation. Agent Dugan didn't fully understand the back storv of the
long runnim, litioation and how the "Bromwell" public corruption case fit into the picture.
DUSM Frederick calmly explained to Agent Dugan that the "Bromwell" case was like a
"do1)lino." and that if plaintiff was able to be victorious in that action. it would create a "domino-
effect" and thus cause__plaintiffto run the table and win all his long-running litigations very
quickly.
3 I. As the agents left, they asked for the name of plaintiffs ex-wife so as to confirm that she was
in possession of firearms they believed plaintiff still possessed. Plaintiff was warned that if thev
[handcuffs) on his writs and take him strail!ht to Central Booking [Baltimore City Jail).'"
4+32. The USMS PIU manuals specifically speak about the unit being prohibited from using
their resources to violate the First Amendment rights of citizens.
6
On information and belief, the "Unlrnewa J>lamed"Three Maryland U.S. Judges" were
independently operating & controlling the s11bject government agents outside of the normal-ti-£
9ill 'chain-of-command.'
15
JA164
4&
33. ClearlyYet, the timing of these visits, especially the attempt to arrest plaintiff for illegal
weapons possession, was intended with one goal and one goal only in mind: to prevent and/or Ee
intimidate plaintiffs planned demonstrations at the Baltimore U.S. eJ;;ourthouse on August 4,
2013.
34. Clearly. as alle(!ed later in this complaint. the government was surveilling plaintiff since
?0JO. If government officials and/or federal iud!!es were in such physical danger from plaintiff
why would the government law-enforcers wait so long lo make con_t_11cJ

with plaintiff and contest
his supposed actions''
35. Clearly. as well. it is simply imp]_<JJJSible

to S<JY.Jhat
after three vears of surveillance. now. iust
two (2) days after plaintiffs first Ciry Paper ads ads which received much notice in Baltimore
~ the law enforcers suddenly found exigent reasons to attempt to intimidate and influence
plaintiffs First Amendment rights. For example. because of this first visit by the law-enforcers.
plaintiff was forced to consult a criminal defense lawyer. other lawyers and business people.
numerous friends. to worry and lose much sleep. and to be greatly distracted when he was on an
abbreviated time line and had much still to do lo organize the August 4. 2013. protests. amongst
many other things.
7
Please see: Exhibit no.: 5, the USMS Policy Directives, Judicial Security, 10.7 Protective
16
JA165
36. It is also implausible that the reason the law enforcers came back a second lime to anest
plaintiff for alleged illegal weapons possession iusl five (5) days before his planned
demonstrations was out of fear for the safetv of government officials or federal judges - as those
manufactured fears had al.ready been allaved by their first visit and plaintiffs letter to the USAO
MD - and that this second act was not anvthing but another effort to stop plaintiffs planned
demonstrations and to violate his First Amendment rights. Otherwise. why bring up detailed talk
9
of 'settlement' This second visit caused plaintiff the same injuries as just recounted above, only
they were exacerbated, as plaintiff now only had five (Si days left before his first protest at the
Baltimore U.S. Courthouse.
37. But. there is another reason to believe the government a2:ents acted unconstitutionally: In
8
2QlJ, plai_nliff w;is le1m!ly <)llowed. both by state and federal law. lo possess firearms.
38. The reason for this was Congress. since al least ?007. had ceded restoration of certain
firearms rights to participating stales, Maryland being one of them. via the NICS Improvement
Amendments Act of 2007. See. Tvler v. Hillsdale Ctv. Sheriffs Dep't. 837 F.3d 678 (6th Cir.
?016) (en banc). 9
Investigations at D. 7. (See, Page 2.)

8
Please see: Exhibit nos.: 6, 7, & 8; plaintiffs 2001 physician's certificate and the 2013
Maryland law.
9
Please see: Exhibit no.: 9, the subject Tyler opinion, page 4, which can also be viewed here:
http://www.opn.ca6.useourts.gov/opinions.pdf/l 6a0234p-06.pdf
17
JA166
39. Further, the Marvland United States Attorney's Office knew that plaintiff was not in
violation of any firearms laws. as plaintiffs former Marvland criminal defense lawver - again.
plaintiffs litigation historv is discussed in more detail in Count VI - had discussed plaintiffs
firearms gual~tions with Barbara S. Sale. th? USAO MD's Chief. Criminal Division, iu_2.D.llii.:
40. Not only has the oovernment been threatening plaintiff with illegal arrest should he reacquire
firearms since at least 2006-7. but thev actuallv tried to do exactlv that on Julv 30 2013, both in
violation of plaintiffs Second Amendment rights. and to misuse the law to violate plaintiffs
41. After the J_uly30. 2013, threats. DUSM Fre.ili:lids continuc:d_tb.e...t!ii:.e_ats

by seeking
infurmmiml.JIOJJJ
plaintiff's ex-wife to arrest plaintiff sometime before the August 4, 2011,_
491,. These intentional, knowing, bad-faith, and illegal acts by the defendants caused plaintiff
plaintiff that his eRemiesthe federal officials who had wronged him would stop at nothing to
defeat his constitutional rights.
18
JA167
§G43. Wherefore, for the aforementioned illegal conduct, plaintiff seeks $+5,000,000 from the
defendants for compensatory damages, and $Jl0,000,000 from the defendants for punitive
damages.
COUNT II
Sl. A 'blaek liYes matter' tyjle aetiYist eontaeted jllaintiff on July 14, 20B, al'ter jllaintiff
announced his U.S. courthouse demonstration schedule on Facebook.
S2. This 'acth•ist' elaimed to be interested in jllaintiff's 'Baltimore Corrujltion \!.'ire' entity,
and esjlecially in jlleintiff's jllanned U.S. courthouse demonstrations.
S3. This 'ectkist' and jlleintiff eommunieeted Yin Feeebool. end on the telejlhone multijlle
times.
S4. Of note, the 'aeth<ist' wes oflt>ring to heljl 'l.'ith the jllanned jlrotests, ineluding 11,,
jlroviding 'bodies' to jlrotest, money fur ad~•ertising, and grassroots heljl in the 'bled,'
community so es to 'tel,e down' the eorrujlt judges in the Maryland U.S. courthouse.
SS. On Jul)' 20, 2013, the 'aetiYist,' his 'wife,' end jllaintiff met et e North Baltimore eere
fur three (3) hours to discuss jlleintiff's jllenned U.S. eourthouse demonstrations.
S6. The 'activist' end his 'wire' Sjlent mueh time asking jllaintiff, in greet detail, about his
lire story, including attcmjlting to solieit harmful intentions toward the subject U.S. judges.
S+.The 'actiYist' end his 'wire' Sjlent mueh time ofrering their time, heljl, mone~•,
grassroots organizing abilities, end, most imjlortently, 'bodies' to jlrotest et the jllanned
U.S. courthouse. jlrotests.
S8. The 'activist' end his ,.,..,ire'guerentced at least fifty (SO) 'bodies' to jlFOtest, with as
many es 'severe! hundred' to be added to that number.
S9. There were many fecebook end telejlhone conversations with the 'aeth•ist' regarding
the UjlCOmingjlrotests and what his contributions would be.
60. NeYertheless, 'lihcn the first planned U.S. courthouse jlFOtest dey arriYcd, the 'ecth•ist,'
his '·.vilt>,'his 'bodies,' nor any other support, were no where.to be round.
61. On infurmetion end belief, the 'ectiYist' end his 'wire' were undereover U.S.
goYernment agents sent(]) with the clear intention to sabotage jlleintiff's U.S. courthouse
19
JA168
pretests in any way pessible and (2) te eFimieally eetFap plaietiff b.t attemptieg ta eegage
plaietiff ie diseussiens ef vielenee against federal effieials, e,;en theugh 11laiHtiffhad always
iesisted that the misbehaYing Maryland federal judges should be held aeeeuntable,
publiely, ueder the law aed rules.
Gl. These ieteetieeal, lmewieg, bad faith, aed illegal aets by the defeedants eaused 11laintiff
great weFFy, anxiety, fear, slee11lessness,ete., amongst many ether things, as it was elear te
11laintiff that his enemies weuld st011at nothing ta defeat his e0nstiiuti0nal rights.
G3. ~ 1herefore, for the aforementioned illegal eenduet, 11laintiffseel,s $1S,000,000 frem the
defendants for e0m11ensat0Fydamages, and $30,000,000 fFem the defendants for 11unitive
damages.
COUNTIII
"4[ COUNTS II. IV, & V from the original Complaint are deleted from this Amended
Complaint.]
COUNT III
65. At first, they were plam,ed ottly for ottee a moH!h.
66. But, after the judge fur whom the 'White Guerrilla family' gaAg was Hamed aetually visited
the pretests te admire the pretest sigAage he iAspired, the pretest sehedule was moved te a mostly
thrmigl, late fall 2013.

weekly eveAt at the Baltimore U.S. e01c1rtho1c1se
6745. During these protests, plaintiff was always supervised by the DUSM PIU agent and--alw
often by Federal Protection Service officers, sometimes in full SW AT gear.
20
JA169
0&46. Naturally, the DUSM agent and plaintiff became acquainted, especially as the-DUSM
Frederick had claimed he had long-wanted to meet plaintiff.
69. SssR, tile DUSM47. DUSM Frederick continued to probe plainJiff regarding his alleged
possession of illegal guns and wondered if plaintiff had anv guns "buried." At one protest in
early fall 7013, DUSM Frederick told plaintiff about a conversation he had iust had with Agent
Dugan. Agent Dugan had "asked him ifwe need to have the [FB]J SWAT Team come and arrest
Bill [plaintiffi"" He then recited more of the conversation he had with Agent Dugan as to
whether plaintiff "would survive a night in Central Booking rBaltimore Citv .laill0 "
48. Yet soon. DUSM Frederick came to see that plaintiff was no 's0ei0]3Ertl!"'sociopath" as he
insinuated the U.S. DOJ profilers had attempted to 'mark'"mark" him, but aswas instead. in his
words. a "lover," not a "figllter""fighter." who just wanted to "go back to the country club.,"
which was how DUSM Frederick~ a big football fan~ saw former tennis players such as
plaintiff.:.'
+G49. Plaintiff and the-DUSM Frede1ick spent much time chatting at the Baltimore U.S.
10
ei:;;ourthouse during plaintiffs demonstrations.
+l50. Plaintiff also learned, while chatting with federal law-enforcers during his protests, that the
10 The
DUSM was convinced (as the government's 'expert' on plaintiff) that plaintiff was
in the "right" and that he had "gotten f'*ked-over by the 'judges,"' which was a statement he
made many times.
21
JA170
11
'.7±51.Several times the-DUSM Frederick explained that the reason he had always wanted to
meet plaintiff was because of his particular letter writing abilities, letters which acted as
'prosecutions' of certain 'jttElges'jud~ and other government effieialsofllcials' reputations.
Apparentlv. plaintiff had really gotten under the skin of certain judges and officials.
+J52. When plaintiff queried how long this desire had existed, the DUSM explained that he had
been surveilling plaintiff since 2010, siAee his D.C. lav,·s1c1il

was fileElagaiAst the Mar)faAElU.S.
Atterney.
74. FraAkly, this.
53. This revelation surprised plaintiff very much, as he haElthought the reporter's preeautions in
20 I 0, as 'suggesteEl' in the intreEluetien to this lawsuit, were a jeke.
Hplaintiff had wondered many times how the 2overnment always seemed to be one step ahead
in many parts of his continuing liti2ations.
the government.
11
This information became a qui tam lawsuit. Please see: 15-cv-00199-DAF (D. Md.),
22
JA171
70. This aet And it is implausible lO sav that plaintiff must plead specifics on this alle~
when onlv the government knows what infonnation thev gained by the surveillance of plaintiff
that they then used against him in the continuing litigations. In short. the spying upon plaintiff. if
usc_din litigation. as opnosed lO Legitimate law enforcen1ecnLwrposes. is a gross constitutional
attorneys must also follow.
+I-are required to follow. That no government atlorney ever notified any federal jud~
hl!]2ervising federal litig,!Jions before them of this issue. either es pa rte or under seal. shows
56. Further. because of this admitted governmental surveillance of plaintiff. plaintiff was forced
to limit and curtail the freedom of his expression to others via the telephone. the internet, and by
other means. from 2013 forward.
plaintiff that llis eHemiesthe federal officials who had wronged him would stop at nothing to
23
JA172
the
+&58.Wherefore, for the aforementioned illegal conduct, plaintiff seeks $+5,000,000 from
defendants for compensatory damages, and $Jl0,000,000 from the defendants for punitive
damages.
COUNT I¥
79. The DUSl\4 also VI
59. Plaintiff is the author of the unpublished fictionalized copvri2hted manuscript titled Self~
Portrai1 ofa Patricide.
e-
60. In the spring of 2001. plaintiff discovered that a copv - one of only two in known existenc
in a
of his manuscript had been stolen from the law offices of his deceased attornev by actors
child custodv proceedin2 in Baltimore Citv. Maryland.
61. The custody case pitted plaintiffs ex-wife's ex-husband and her father (hereinafter the
"custodv case opponents") against plaintiffs ex-wife and him.
bv the
67. These custody case opponents had earlier been investigated, indicted. and prosecuted
ons
Maryland U.S. Attornev's Office in a multi-district action. This action resulted in convicti
and fines.
24
JA173
63. ln the late spring of 7001, plaintiff discovered that a handimn had been stolen from a locked
Police Department.
64. On May 25 2001. plaintiffs and his ex-wife's home was raided by a Maryland State Police
SWAT team and plaintiff was chanred with ille£al handgun possession. Plaintiff spent one night
in Central Booking. Baltimore's notorious & very daneerous jail.
65. The basis of the charges was that plaint.iff had spent more than 30 days in a mental health
66. Plaintiff immediately retained the "deaiJ" of the Maryland criminal defense bar, one Richard
M. Karceski. Esq.
67. The first thing Karceski did was to call plaintiff's fonncr Ohio attornev named Gerald A.
Mcsserman. Messennan had always told plaintiff a00111howthat his s11rveillaHeeof plaiHtiff
eontiH11ediH 20! 2, after plaiHtiff had lost his home, his dog, all his possessions, ele., aHd was
liYiHgiH aH 11Heleetrified 'sEJ11at'in a dereliet IJ11ilding_H
25
JA174
80. As tllis surveillaHce came as plaiRtiffwas attackiHg tile 'Bremwell' case tile seeoHd time iH
summer 2012, clearly tile iHteAtioHby tile governmeHt was tile UACOHStitutioHal
deprivalioH of
plaiHtiffs d1c1e
process aHd eivil rigllts.
81. OH iHfermatioA aAd belief, tllis coHliHHedsun·eillaHee, wlliell, as already stated, begaH iH
2010, aHd llas, OHiAfemiatioH aHd belief, eoAtiAued HHliltllis day, llas eoHsisted of electroHic
moHitoriHg ofplaiHtiffs commuHieatioHs, iHcludiHg teleplloHe and internet eomm1c1nications,all
witll tile inteHtioH of iHterfering witll plaiAtiffs p1c1blieprotests aRd llis p1c10licpolicy legal
actiYities, including lawsuits against governmeAt actors.
82. Tllese iHteHtional, lmowiAg, sad faitll, and illegal acts by tile defeAdaAts ea1c1sedplaiAtiff
great worry, aAxiety, fear, sleeplessAess, etc., amoAgst maHy otller tlliAgs, as it was elearjuvenile
record would be expunged at a certain date and then later wrote plaintiff a formal letter stating
that his juvenile record was expunged. Nevertheless. the State of Maryland was using plaintiffs
Ohio juvenile record to prosecute him and Karceski asked Messerman how that was possible if
the subject record was expunged?"
68. Turned out plaintiffs juvenile record - despite the Messerman leller to the contrarv - was
never expunged.
sentence for a misdemeanor, and was not even hidin!! the fact that they were trying to re-punish
12
Please see: Exhibit nos.: 10 & 11, Gerald A. Messerman, Esq., 1986 & 1994 letters to plaintiff.
26
JA175
plaintiff for his iuvenile act, according to the Maryland Assistant Attorney General who was
70. Both the_,ustody case opponents and the State of Maryland then sought to use plaintiffs
stolen manuscript in their respective cases~ to rip plaimiffs ex-wife's children from her custody
and to imprison plaintiff for IO years.
71. Plaintiff hired a top First Amendment lawyer who then filed a copvright action to gain the
return of the manuscript. all copies made. and to prevent its further unauthorized use in the U.S.
District Court for the District of Maryland on August 79, 2001. This case was assizned to U.S.
Distric_t Jud~arvin J. Garbis.
77. Karceski had many conversations in 2001 & 2002 with Mcsserman. The book was a big
subject. especiallv as .Messerman had read an earlier draft in the early I990's. Messcnnan knew
in the late spting and carlv summer of 2001 that the copyri!!ht case was cominz. When it was
filed, Messcnnan asked Karceski who the iudge was° Karceski told him it was Judge Garbis.
Mcsserman then told Karccski that he knew Judzc Garbis. but did not say why or how.
73. Importantly. Mcssennan knew at this time that he was subject to a malpractice action based
upon his false representation to plaintiff that his eHemies would slop al HOthiHgto defeat his
constitutional rigl!ls.
27
JA176
83. Wherefore, for !he aforemeHlieHed illegal ceHdHCI,plaiHtiff seeks $15,000,000 frem the
deJ'eHElaHtsfor cempeHsatery damages, afld $30,000,000 frem the deJ'eHdaHts for pHHitive
Elamages.
COUNTV
84. OH September 29, 2015, while visitiHg !he Baltimere U.S. c0Hrlh0Hse, plaiHtiffwas s1c1Bjeeted
le afl effert by the DUSM le iHvade his prose liligaHI ,.,,·orkpreEluet in the qHi lam ease
mentioneEI abeve, ifl violatiofl of the rules of comt.
85. Thal same Elay aHEIlime, plaiHliff was alse s1c1Bjeetedle an effort by tile DUSM, werkiHg ifl
taHdem with the U.S. jHdge who was the model for the "Nhit~Girerrilla Family' ad campaigH, to
erimiHally eHtrap plaiHtiff.+4
80. These intentional, lmewiHg, baEI faith, afld illegal acts by the deJ'eHElantscaHseEIplaiHtiff
great worry, am,iety, rear, sleeplessness, etc., amoHgst maHy ether thiHgs, as it was clear
tojuvenile record was expunged. a false representation that had actuallv 2otten plaintiff charged
with a crime. In speaking with Karceski. Messennan acted more like a prosecutor toward
plaintiff and defended himself that there was no malpractice if plaintiff was convicted of the
handgun charges due to the vagaries of malpractice liability. Messerman was also very worried
28
JA177
about his high-profile and spotless reputation. as he claimed to have never been sued before for
malpractice.
74_ Despite the cle_are_rror,Messerrnanadamantly refused to co111_e

to Maryland and testify
75. On November 20, 200 I, Judge Garbis held a TRO hearing in the copyright case. Information
-for the first time- was introduced into the coun record regarding Messerman's contacts in the
late I 980's with one of the copvri ght case defendants.
76. Ruling from the bench. and after making a very brief reference to knowing Messcrrnan and
complimenting his le_g;tl_acunJen._Jud~eGarbis refused to order the return - ever- of any or all
copies of plaintiffs property and ordered plaintiff to pav the individual defendants' legal fees. In
essence. Judge Garbis ordered plaintiff to pav the thieves for their efforts expended to steal his
propertv.
77. Soon after this order, plaintiff flew to Cleveland. Ohio for an unpleasant meeting with
Messennan. At this meeting, Messerman told plaintiff that his enemies would slop al nolhing lo
defeal his eonslitlllional righls.
87. Wherefure, fur the aforementioned illegal e011duet,plaintiff seeks $15,000,000 from lhe
defendants for eompensalory damages, and $30,000,000 from Ille defendants for puni1ive
damages.
29
JA178
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JA179
94. IA tile 2009 'BF0mwell' ease, tile USAO MD saw v,itll tlleir owA eyes tile result of the
eontiAuing conspiracy against plaintiff.
95. Yet, no oAe in tile USAO MD would act in any way to see tllat plaintiffs constitutional rigllts
were enforeed.
96. In fact, as described in tllis lavo'suit,the USAO MD, aloAg witll otller U.S. DOJ agencies,
became co conspirators agaiAst plaintiff switelling sides tllen siding witll tile same F0gue
federal judges 'NHOHl tile former U.S. attorney llad previously iAvestigated.
97. Tile judiciary, tile g0\'ernment, and tile bar, are supposed to form an adversarial triangle
based upon tile rules and tile law, witlleat ,,vlliell our American jadicial system cannot fonetion.
98. Tile eonstitatioAal violations in ttlis conspiracyJudge Garbis and he were 2:raduate school
classmates in 1961 al an exclusive 8-member program run by Georgetown University Law
School called the E. Barrell Prettvman Fellowship. When accepted al this pro2:ram. the graduate
law students all lived together in a Washington, D.C.. row home under the supervision of a
professor who also directed them in providing legal defense for low-income citv residents. ln
short, Judge Garbis and Messcrman were housemates in posH,raduate law school. Later. they
would visit each other both in Ohio and. on information and belief, when Judge Garbis held a bat
mitzvah for one of his daughters in Marvland, amongst other contacts.
31
JA180
78. The criminal case against plaintiff arn fur bigger tllaH plaiHtiff, as tl!ey affeet every siHgle
citizeH sf me state of MarylaHd.
99. Tl!at Hot oHe persoH iH a positioH of power to l!elp plaiHtiff WOHiddo so is a staiH HpoH(See
a2:ain Sl'll
65-66 above) was dismissed by Baltimore City Circuit Court Judge John C. Themelis.
after almost one year of intense litigation. on April ?2. 2002. based upon the expert opinion of
noted Maryland forensic psychiatrist Michael K. Spodak who provided a 'certificate' to the
court. required under Maryland law. testifyin2: as to plaintitTs 'capability' to possess fireanns at
13
all times in question.
79. On January 24. ?()03, the U.S. Fourth Circuit issued a published opinion in the appealed
copyright case. Writin° for the court. U.S. Circuit Judge Paul V. Niemever stated that Judl.!e
Garbis had not gone far enoul.!h and ordered that the law firm defendants. who were self-
represcnted. could now seek attorneys' fees from plaintiff. Jud!Ie Niemeyer also suggested that
the remedy to the conversion ofplaintilT's copvrighted propertv !av in a state action despite
80. On remand. Judge Garbis awarded the full set of copyright actors more than $181.000 in
attorneys' fees.
13
32
JA181
r--
81. Soon after. Judge Garbis' recusal was sought. Jud~ Garbis respond.sellwith an order denying
th at request, an d state d, ·111pertinent

· part: 14
"When assigned this instant case in August of 200 I. I noted that

Plaintiffs criminal counsel in Cleveland had been Mr. Mcsserman.
added.)(Judge Garbis Memorandum and Order, April 73, 2003.j
It is clear from this statement. as plaintiffs copyright action was filed on August 29, 200 I. and
made no mention of Messennan. that Mcsserman was having secret. clandestine conversations
82. Plaintiff then sued all the copyright actors. Messerman, and others,Jn three different
Mm:wm.d state actions that lasted from 2003 un.til 2006. Al.Iof these stale actions were
dismissed, except for one sett!l'.lnent with both trial and state appellate courts relying almost
wholly upon the federnl rulings of Judges Garbis & Niemever.
83. Later, in 2008, plaintiff met with a very prominent Baltimore lawyer in his/her office. /This
person's identitv is being withheld at this time to protect him/her from unnecessarv exposure to
retaliation.)
84. This lawver knew Judge Garbis very well.
14
Please see: Exhibit no.: 12, Judge Garbis Memorandum & Order re: Recusal at docket entry
no.: 108 in case no.: 1:01-cv-02600-MJG (D. Md ..). The court should also note how Judge
33
JA182
,-
85. Sometime in 2004-?006. the prominent Baltimore lawver spoke to Judge Garbis about
plaintiff. During this conversation. Judge Garbis made many highly disparagin!.! remarks about
plaintiff. These remarks sumriscd the prominent Baltimore lawyer because, familiar with
plaintiff and his issues. he saw plaintiff to be in the right.
86 . .lud!!e Garbis told the prominent Baltimore lawver that plaintiff was a "verv bad man." that
"plaintiff was verv dangerous." that ''l"the prominent Baltimore lawverl should stay away from
lplaintifD." and many other things that all showed pervasive bias toward plaintiff. The prominent
la,,-yer told plaintiff that Jud!.!e Garbis had actual "bias" against him. The prominent lawver also
suggested that, if plaintiff could not correct what Jude:c Garbis had done to him in the copvrigh[
case. that plaintiff should hold;'.public protests" at the U.S. comihouse against Jud!.!e Garbis.
which is when plaintiff first got the idea for the protest schedul~ he would later undertake in
87. The Maryland mental health facility where plaintiff was sent in 1981 by an Ohio iuvenilc
court was also sued in Marvland state court for handing out plaintiff's complete medical &
Office. who. as already stated, was prosecuting the criminal case relatin!! to plaintiffs firearms.
Garbis substituted the word "criminal" for ')uvenile."
34
JA183
88. Sometime between ?003-2005. the lawyer representing The Sheppard and Enoch Pratt
Hospital. Daniel J. Moore. told plaintiffs lawvers in that case that a board member. who was
also a lawyer. was "adamantly outraged'' that plaintiff had sued the hospital and had ordered Mr.
Moore to "under no cir_c_umstances"settle plaintiffs claims. This was verv odd considering the
claimed violations were of federally protected records. 15 These statements were allegedlv made
in front of other board members and/or witnesses.
89. On information and belief. that lawyer was also a U.S. District Judge named J. Frederick
Motz. Judge Motz. and his father before him. were verv long-term Board of Trustees members &
16
chairs of the hospital and took a verv personal and protective intere..filiu_theinstitution.
2lLD_uring discovery in the three sJate lawsuits. plaintiff d_iscoveredthat the copyright case
actors. at the direction of copyright case lawyers. had not turned over reams of subpoenaed
documents and had committed periury under oath regarding material facts. such as not producing
documents that showed thev knew in advance that they were going to plaintiffs deceased
17
la,,yer's office to attempt to gain plaintiffs propeny. These three state cases which plaintiff
15
Later, before the case was taken to Maryland's highest court, a nuisance settlement
would be left not fully consummated.
16
17
In July 2004, the USAO MD opened a criminal investigation into these matters led by the
office's Chief, Criminal Division, Barbara S. Sale. Coincidentally, as a young AUSA, Mrs. Sale
had led the aforementioned prosecution of the custody case opponents. Nevertheless, prosecution
was declined and the investigation was closed in May 2005.
35
JA184
91. On August 30. 7005, plaintiff was struck by a car while riding his bicvcle in Baltimore's
rural countryside and suffered catastrophic iniuries. Plaintiff spelll more than a year in recovery,
durin~h time he exceeded the best prognosis. Constantly on his mind the entire time was a.II
92. Beginning in 2007. plaintiff be2an his prose efforts to gain iustice in the copyri2ht case and
related issues by filing three (3) separate oro se actions in the Maryland U.S. Co~rt. !he USAO
MD, & the Maryland Bar.++
+ooDistrict Court.
93. First. plaintiff challenged Judge Garbis' recusal and other orders under FRCP 60.
copyright actors. The district court assizned this action to Judze Motz. This assiznmcnt was
troublesome to plaintiff for several reasons. most immediately. the above-mentioned Sheppard &
36
JA185
96. Judge Garbis a!!ain refused to answer substant_iy~)yas to any of tb~ recusal issues, i.e.,how
did he know about Messennan's and plaintiffs relationship before he was assic:ned the copyri2:ht
case" Clearlv, the basic fact regardin!! recusal motions is that a subiect iudge is frequently in
unique possession of the information sought and. thus, has a special obligation to come forward
and disclose all relevant facts to the parties. fully and robustly. Certainly. federal law. the iudicial
canons and abundant case law. are all clear: federal jud2:_esdealing with recusal should err on the
side of (acts that will support recusal. Further. it i_sinappropriate for a federal iudge to conceal or
fail to disclose recusal related facts known to thejudge. like here. with the later-discovered
intensitv of the prior relationship between Judge Garbis and Messennan.
97. Importantly. Judge Garbis also never mentioned his pervasive bias against plaintiff as
98. Judge Motz refused to entertain any substantive analysis of the FRCP 60 allegations. instead
relying upon res iudicata of.Judge Garbis' 2001 opinion as defeating !mer discovered fraud upon
the court alle2:ations.
intervened to prevent the Sheppard & Enoch Pratt Hospital. of which. as discussed above. he was
37
JA186
a long-term board member and chair. from fairly financially settling the obvious wrong they had
committed mrninst plaintiff.
point the settlement i.Mg~

I 00. The FOTA case was liti 0 ated to a settlement conference. al w.hi.cJ:i
infonned plaintiff that ifhe wished the "Bromwell'" records. that he could not get those records
under the FOlA from the coun. but insread plaintiff had to go back to the presiding jud!:'e and
101. Plaintiff then took these three prose actions to the U.S. Fourth Circuit. who ordered the
defendants to answer in the primary copyri 0 ht case FRCP 60 action. Nevertheless. all three
actions were dismissed without any substantive review at the direction of Jud~ Niemever and
I 0). Plaintiff then took all three matters to the U.S. Supreme Court. which dismissed plaintiffs
petitions for certiorari in earl v 2009.
103. Heeding the settlement judge's instructions. plaintiff then moved in March 2009 to unseal
the "Bromwell" attorney disqualification records before the correct U.S. district judge, The name
38
JA187
I 04. Surprisinglv, the Maryland U.S. Attornev's Office now joined plaintiff in his efforts to
15
1Q5.But, Judge Motz ignored all efforts to unseal the subject gocuments.
I06. Plaintiff then took the matter to the U.S. Fourth Circuit where he was ioined again by the
Maryland U.S. Attorney's Office. A2:ain. in an unpublished opinion. Judge Niemeyer and fellow
panel members dismissed the case without any analvsis of the substantive issues.
107. All matters now dismissed. an intermediary prompted an inrormal meeting between Judge.
Nie.m~_yerand plaintiff. Plaintiffs goal was to fine! out what the basis was for the denial of all his
rights before Judg_cNien1e$r over many years.
108. Plaintiff met twice with Judge Niemeyer in the summer of 20 I 0. Judge Niemeyer told
plaintiff that his litigations "should have never been brought,'' that "thev would never let him
win," and that "if you don't stop [your litintionsj. you will be destroyed." amongst manv other
thin~
18
Please see these two Maryland Daily Record news stories: (I)
https ://www.scribd.com/ document/ 1364? 5 369/Federal-prosecu tors-wil Iing-to-unseal-more-
Brom well-docs-Maryl and- Daily- Record-April- 10-2009 & (2)
https:/ /www .scribd.com/document/136425931 /Bromwell-documents-to-remain-sealed-
Maryland-Daily-Record-J uly-17-2009.
39
JA188
I 09. In fall 2010. seeking shelter from the Maryland and Fourth Circuit courts. plaintiff filed a
lawsuit against the Marvland U.S. Attornev's Office and 77ie Washington Post newspaper in the
for declinine lo prosecute the copyright case actors in 2004-6 for non-allowed reasons. The D.C.
court dismissed ihe case in summer 7012, all the while refusine to acknowledge plaintiffs
l 10. Not backing down, in Auoust 2017. plaintiff came right back to Jude:e Motz in the
"Bromwell" case and filed a new recusal motion. including, in detail, the inforniation g;mJ_ed
20
from Judge Niemeyer. This time the Maryland U.S. AtJorney's Office was silent.
111. A!!.i!in.not only did Judr:e Motz not answer the newly-learned recusal issues. he again
neglected to reveal his past conduct against plaintiff in the earlier described Marvland state
lawsuit.
112. In late 2017 and early 7013. plaintiff complained about the above-mentioned iudicial
disabilities to the Chief Judge of the U.S. Fourth Circuit. who returned the complaint to plaintiff.
and to U.S. Senator Barbara Mikulski. who referred the matter to U.S. DO.1. where it died in a
19
Please see: Exhibits nos.: 14, 15, & 16; the memorandum, pages 12-13, and the affidavit, at
docket no. 239 in 01-cv-2600-MJG (D. Md ..), and the motion to recuse filed in Fourth Circuit
case no.: 14-6017.
40
JA189
113. Plaintiffs decision lo publicly protest what he believed to be l01m term cotTuption at the
Baltimore U.S. Counhouse in ?013 was no lightly undertaken matter, but one considered after
some then-12-vears-of-non-stop litigation where plaintiffs inability to recover his own propertv
114. The motive in this long story is simple. Judge Garbis set out to protect his old classmate,
housemate, and friend Messennan in any wav he could from 200 I forward.
115. Judge Garbis' conduct, by stating in his ?003 recusal order that he knew when assigned the
wnvright case information that was in none of the pqjicrs filed. would strongly suggest that the
assignment of the case lo Judge Garbis was no! random. Later, information not provided by
Judge Garbis at assignment or immediately when it should have been al the TRO hearing.
showed that Judge Garbis and Messerrnan had a long-term. very close relationship. Clearly, the
issues Messerman was facing in 200 I were not just some little annoyance, but one where his
previouslv made 10 plaintiff. And clearly. Judf!e Garbis wen! far outside of the copvrighl issues
pending criminal and custodv cases. which was eerilv like the tact Messerman had used with
Karceski. Finally. Ohio and Marvland have some 18 million people combined. and vet two
people. associated by an 8-member 1961 graduate law school program, come together at the
20
41
JA190
Not only is this coincidence implausible. given all the facts listed above. it would be implausible
to suggest anything but that the copvright case was defiled.
I I 6. Judee Garbis clearly spread negative opinions about plaintiff lo others. opinions he had
alle2edly learned unethically from Messcrman and/or others on his behalf in their secret
conversations before the copvri2ht case was filed, so as to make sure no iud2e in the Baltimore
U.S. Courthouse would give him any benefit of the doubr.
117. While it is not known why, Judge Motz ioined J udec Garbis. and together thev eviscerated
plaintiffs rights under 28 U.S.C. 144 & 455. Further. the individual and collected acts bv these
defend;mJs_gQJar from simple ethics violations and become.jzy their l_cnp.Jhand sti.1bbornncss,
violations of plaintiffs constitutional rigim;_Jo duc_process and his own property. and in the
process. became an actual, albeit unstated, Bill of Atiainder put upon plaintiffs head by the
defendants.
118. Plaintiff has been forced to live with the stress and strain of litigation 2oirn, on now 16
years because of the defendants' illegal and unconstitutional acts. During these 16 vears, plaintilf
has lost two homes. all his money. all his personal property. two prized & beloved pets. his wife,
his step-children, most if not all his friends & neighbors. his physical health. has been subjected
togross scorn and ridicule, and the prime years of his rniddle-a~e have been consumed by
42
JA191
defendants.
119. These intentional, knowing, bad-faith, unfair. and illegalwrong acts by the defendants have
caused plaintiff great worry, anxiety, fear, sleeplessness, lar(Lefinancial losses. etc .• amongst
many other things, as it was clear to plaintiff that his enemiesthe federal officials who had
wronged him would stop at nothing to defeat his constitutional rights. In addition, plaintiff has
had his reputation absolutely destroyed by the defendants' imperturbable and unconstitutional
long-;term treatment of him.
170. Judge Garbis. by all that has been learned. should have immediately recused himself from
the copyright case in 2001 and at all times afterward, because of his connection to Messerman.
unknown. But. clearly. plaintiff has been proccdurallv blocked at every turn since 2001. with not
decisions recounted in this complaint. when taken together. suggest an aggregate of acts that
were corruptly taken~ that the underlving behavior itself was con-upl.
121. And as defendant DUSl\.1 Frederick said in Count l of this complaint, the "Bromwell" case
was the "domino" that could knock over all the other "dominos," i.e .. expose all the unethical
rulings against plaintiff. Therefore. the defendants, now greatly worried by plaintiffs 'White
43
JA192
Baltimore U.S. Courthouse jµst davs away at the time - had great & plausible motive to seek
plaintiffs wrongfol & ille11alatTest to prevent same at all costs.
122. Further it doesn 'l matter that the defendants were unable to arrest plaintiff on July 30.
2013. What matters is th!ll th_evtried. Just as they tried and succeeded in dilutjmu2J'1i.JJliJI:.s
demonstration plannin2 and execution. Clearly. their reasons were that they were Irving to make
Rlaintiffs planned demonstrations go awav bv anv means possible. By any means.
123. Wherefore, for the aforementioned illegalwrongfol & unconstitutional conduct, plaintiff
seeks, $B20,000,000 from the defendants for compensatory damages, and $B;!0,000,000 from
the defendants for punitive damages.
Civil rights actions are te-be-given preference in the Fourth Circuit. Because of the great length
of time these matters have continued, and the great harm caused plaintiff, aAd the e1,igeAtharm
still e1,istiAg fer the geAeral p1c1blie,plaintiff reEJHestspraysthat this court issue an expedited
briefing schedule in this case as soon as possible.
DEMAND FOR A .JURY TRIAL
44
JA193
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
45
JA194
EXHIBIT 1
JA195
JA196
EXHIBIT 2
JA197
• ,,,- "'it-1:t
'
~I!! Q_filroptlon_:@!:~
JA198
EXHIBIT 3
JA199
CORRUPTION SUB CURIA
A Brief History of the Still-Sealed Attorney Disqualification Matters in the Thomas L.

Bromwell Political Corruption Prosecution.
By: William C. Bond
Date: March 15, 2013
Introduction:
Sub Curia is a Latin term which means "under law." Sometimes a court may hold a matter under
consideration, awaiting something to happen, like waiting for parties' filing of some documents
or to write an opinion.
But, there is another 'legal slang' version of the term - when a judge holds a matter undecided,
seemingly forever, because the judge does not like a party or a party's position. This technique is
particularly insulting in this case because the hidden documents at issue would surely cause one
or more highly-connected lawyers to be disbarred and for several federal judges to be judicially
reprimanded or worse.
Back story:
The prosecution of former Maryland State Senator Thomas L. Bromwell, Sr., in 2007 by the
Maryland U.S. Attorney's Office concerned a highly-publicized Maryland political corruption
case in the U.S. District Court for the District of Maryland. Nine people were ultimately
prosecuted and convicted by the Government. During the case, presiding U.S. District Judge J.
Frederick Motz ordered a large amount of the filings sealed. Motz also disqualified the five
attorneys serving as primary counsel to the three primary defendants on the eve of the trial on
March 14, 2007, at the urging of the U.S. Attorney's Office. The trial was then postponed. Mr.
Bromwell and his wife subsequently pleaded guilty and were sentenced to prison.
Leading up to that non-trial, The Baltimore Sun Company intervened in the case by hiring a top
Washington, D.C. law firm to move to unseal the record. On March 9, 2007, the district court
held a hearing on The Baltimore Sun's action. After the hearing, the soon-to-be-disqualified
attorneys and Judge Motz assembled in his chambers for further discussions in camera - in
private. Surprisingly, the counsel for The Baltimore Sun Company declined an invitation to
attend this chambers conference, of which there is no record of on the docket. Finally, on March
16, 2007, the court unsealed and/or un_sealedin redacted form some of the documents at issue.
The documents unsealed then became the fodder for several articles in The Sun which focused on
Mr. Bromwell' s uncouth conduct, but otherwise lacked much real substance.
Importantly, in his order, Judge Motz declined to release the 'attorney disqualification' and
'prosecutorial misconduct' documents which detailed the dispute continue/le between the U.S.
Attorney's Office and the now disqualified attorneys, stating that the matter was now before a
JA200
federal grand jury. Later in 2007, the grand jury failed to deliver an indictment against any of the
disqualified attorneys. Nevertheless, the attorney disqualification papers remained sealed.
Disputing that - two years later, on March 9, 2009, this writer intervened in this case as a private
citizen moving without benefit of counsel to unseal the 'attorney disqualification' and
'prosecutorial misconduct' documents, as well as any documents related to those matters. My
reasoning was simply to obtain information about one of the disqualified attorneys with whom I
had been in a long-running legal dispute in another case. The Government filed papers not
opposing this request which was unprecedented in the history of DOJ criminal prosecutions. The
media coverage was national in scope via the Associated Press - heady indeed.
Judge Motz, now not having the federal grand jury as an excuse to not release the subject
documents, wrote a new order stating "IT]his court will not permit itself to be a medium
through which unsubstantiated allegations of wrongdoing made by a convicted felon would
be publicized, causing irreparable damage to the reputations of third parties who are the
subject of the allegations," and declined to release the requested documents "lu]nless
otherwise ordered to do so" [by the Fourth Circuit] - even though there is no body of case law
precedent which sanctions sealing attorney disqualification papers. Presumably, Motz was
referring in his order to a Government witness, a convicted felon, who had supplied the
Government with the information they used to attempt to prosecute the disqualified attorneys.
This writer then appealed to the U.S. Court of Appeals for the Fourth Circuit where the
Government again filed papers not opposing the release of the primary documents sought.
Nevertheless, the Fourth Circuit, by unpublished opinion, declined to see any reversible error by
Judge Motz.
Later, in the Summer of 20 I 0, after the Fourth Circuit appeal of this case was concluded, this
writer then had two meetings with the Fourth Circuit Judge, Paul V. Niemeyer, who had issued
the unpublished opinion totaling six hours in length in which he was told many things which
were very surprising.
The law on sealing court records:
The U.S. Supreme Court beginning in 1980 in Richmond Newspapers. Inc. v. Virginia,
-http://www.law.cornell.edu/supct/html/historics/USSC CR 0448 0555 ZS.html, began to issue
a string of cases which form the precedent regarding the sealing of court records in the United
States. While lawyers like to make the law into some unknowable magic force, any lay person
reading this opinion would see that the Supreme Court carefully reconstructed the history of
openness in court proceedings from the time of early England to the present day, and explained
why the concept is the cornerstone of our justice system. The U.S. Court of Appeals for the
Fourth Circuit, which controls the precedent followed by our Maryland District Court, then
issued an opinion in 1984 In re Knight Publishing Co.,
http://law.justia.com/cases/federal/appellate-courts/F2/7 43/23 l /364616/, wherein they instructed
district judges, such as Judge Motz, on how to handle sealing court records, including a non
discretionary, mandatory check list they must follow.
JA201
Facts:
Central to this case is the fact that there is a FBI 302 document submitted as evidence under seal
which describes the alleged criminal misconduct of at least one of the disqualified attorneys in
relation to actions taken with a 'felonious witness.' This FBI 302 document was the genesis for
the Government to file their 'attorney disqualification' paper(s) with the court, for the soon-to-
be-disqualified attorneys to accuse the Government of 'prosecutorial misconduct,' for the
Government to take the disqualified attorney(s) before a federal grand jury investigating the
alleged criminal misconduct, and for Judge Motz to disqualify the attorneys on the eve of the
trial in 2007.
Evidence in this case has been hard to come by, but a prime piece of evidence was provided by
The Baltimore Sun's prior intervention, although none of their reporters picked up on the key
information contained therein. This evidence was a transcription of a private teleconference
between Judge Motz, the Government, and the soon-to-be-disqualified attorneys dated March 6,
2007.
This 2007 in camera teleconference, which was presented to the Fourth Circuit in the previous
appeal of this matter, when coupled with Judge Motz's July 16, 2009, order denying my previous
motion to intervene and unseal the record shows clear partiality for the disqualified attorneys'
reputations which have a clear economic value as to their professions and law firms - partiality
which is unlawful. (The docket in this case does not indicate that this March 6, 2007, in camera
teleconference even exists.) In fact, Judge Motz clearly admits to "old relationships" with the
soon-to-be-disqualified attorneys. To wit, in small part:
"I have been trying to humor defense counsel [a]long. I've tried to,
sort of feeling that things were far overheated, drawing upon old
relationships, tried to say, come on, just, you know, take it easy a
little bit ... "
Judge Motz has never followed the non-discretionary Fourth Circuit directives for the sealing of
the court records in this case. Judge Motz has also refused on multiple times to explain his
relationships with the disqualified attorneys whom he is still protecting from having their
misdeeds made public. This would give a reasonable person cause for concern that unacceptable
partiality has flavored these proceedings, including not putting certain documents and events
onto the docket which would cause more public curiosity. For example, what happened in the
non-docketed in camera chambers hearing held on March 14, 2007, after which the attorneys
were disqualified and the trial postponed?
1n fact, Federal law is clear: "Any justice,judge, or magistrate judge of the United States shall
disqualify himself in any proceeding in which his impartiality might reasonably be
questioned."
U.S. Circuit Judge Paul V. Niemeyer:
JA202
I am probably the only living person in the U.S. who has ever had an in-person review of his
cases and matters with an appellate judge who decided same. Gaining such meetings are
extremely difficult. But Judge Niemeyer views himself as a born-again Christian, and thus was
the spirit his audience was granted, which this writer found so hypocritical it was laughable had
the corruption revealed not been so dangerous and insulting.
To put it mildly, Judge Motz and Judge Niemeyer have an extremely close friendship which
spans decades, and includes playing tennis, as doubles partners, every Monday for 27-odd years,
or more, dining and traveling together, etc. So, when Judge Motz made the declaration, "Unless
otherwise ordered to do so" in his July I 6, 2009, order in this case, that was as clear a message
as could be sent to his old friend and tennis partner that 'Hey, you better not correct this ruling of
mine because I and other people are going to look like fools.' This is especially noteworthy
considering I had previously asked both Judge Motz and all Maryland Fourth Circuit judges to
recuse themselves from ruling in this case, as well as made an ethical challenge to Judge Motz in
my 2009 intervention that the mandatory federal attorney misconduct reporting rules were not
being followed in this case.
In simplest terms, had the previous rulings in this case been overturned on appeal, Judge Motz
himself could have faced judicial discipline. In that light, Judge Niemeyer should not have heard
the 2009 appeal in this matter because of his too close friendship with Judge Motz and the fact
that he would never judicially reprimand his too close friend in ways that would cause public
embarrassment, nor subject him to judicial discipline. And, this is exactly what Judge Niemeyer
told me in person in 2010.
The 2012 Second Motion to Intervene and Unseal the Record:
I filed a Second Post Judgment Motion to Intervene in this case on August 22, 2012. This motion
presented the Court with (I) new evidence, listed above, which was not known in 2009, that
would give a reasonable person cause to believe that the 2009 order in this case should be
vacated and the Court recused from any further considerations in this matter. The 2012 Motion
also presented the Court with several continuing facts which are related to the recusal issues: (2)
that the Fourth Circuit's non discretionary proscriptions for sealing court records in this case
have never been followed, (3) that the docket is not whole nor accurate - a fact admitted to by
the Government in their 2009 Fourth Circuit filings (citizens are not even allowed to see the
2007, 2009, & 2012 intervention filings on PACER), and (4) that the federal taxpayers are owed
restitution by the disqualified attorneys in this case because the Federal Public Defender's Office
had to come in and clean up their mess at huge expense.
Nevertheless, this second action to unseal the record was denied by Judge Motz twice with zero
explanation or answer as to the above allegations as to his ethical conflicts, the last order coming
on December 5, 2012. Judge Motz was free to do this because, this time around, the Maryland
U.S. Attorney's Office watched the battle from the sidelines without taking any action.
Rather than waste more time and money on appeals which Judge Niemeyer admitted in person
were 'fixed', this writer decided instead to make a criminal/ judicial complaint to the following
people who had authority to rectify the alleged misconduct: The Chief Judge of the Fourth
JA203
Circuit, U.S. Sen. Barbara Mikulski, U.S. Attorney Rod. J. Rosenstein, and Deputy Associate
Attorney General of the United States David Margolis (who is the no. 4 person, de facto 'most
powerful', and the highest ranking non-political appointee at U.S. DOJ).
Well, here's a small slice of what happened: The Chief Judge returned the complaint in a plain
brown envelope, as if an old-fashioned order of prophylactics. The U.S. Attorney never
responded. The DOJ had its Crim.inal Division write that I should contact the local FBI (who was
under direction of the non-responding U.S. Attorney). Mikulski's office contacted me to ask
permission to forward my complaint to U.S. Attorney General Eric Holder, permission which
was granted - and which they confirmed in writing as having so done. But, some two months
later, Mikulski's office, after several very testy emails, then sent me a letter with no postmark
retracting that they had in fact referred the matter to AG Holder. Finally, the Deputy Associate
AG told me on more than one occasion to go jump in the lake, albeit politely. While some people
think it is an accomplishment and amazing that I can get all these people on the phone or
communicate directly by email - I say it means nothing. But, what was most startling to me was
that, even at the highest levels, none of these supposed 'good people' wants to do the right thing
- no matter how hard. Nor do they really care about their oaths, especially if it means they have
to admit and rectify a mistake. They only appear to care about their next career move.
Most troubling, when hearing the above nonsense, I contacted a former neighbor, whose
daughter used to babysit for my stepchildren and who had somehow - despite her benign
intelligence - become a federal bench mate to Judge Motz, about what was going on down at
our federal courthouse. The result, a semi-form letter . . . l kid thee not ... I guess it didn't help
that she used to work for him.
Status quo:
I have done a lot of investigation of Judge Motz - who is this man? Well, he's the kind of guy
who was born to wealth and still goes to country clubs whose records of inclusion are spotty. He
went to Wesleyan College, then law school at U.Va. He has only worked for one prestigious
Maryland law firm or for the Government his entire career. Judge Motz is married to one of our
three allotted Maryland Fourth Circuit Judges, and, as stated above, he is a very close friend of
another of our Fourth Circuit Judges. Importantly, he was a prior U.S. Attorney for Maryland
from 1981-1985. I have found there is strong anecdotal evidence that he has placed many, many
persons in DOJ jobs, including participating in selecting and firing U.S. Attorneys for Maryland.
There is also ample evidence that he has been directly involved in stacking the Maryland federal
bench with hand-picked judges who do his bidding - a highly disallowed judicial ethical
violation which would demand resignation in and of itself if it was ever formally investigated
and proved.
Judge Motz was described to me by a former employee as a "very nice man." An opinion which
is shared, at least superficially, by many people. While that may well be, he was also described
to me as a man who has an explosive temper both on the tennis court and in the court room. Most
important, he is described as an Episcopalian version of the 'Godfather' - he goes after and gets
what he wants. And what he appears to want is to be the 'decider', as George W. Bush used to
say, for Baltimore and Maryland.
JA204
The disqualified attorneys all were and/or are associates or cronies of Judge Motz at one time or
another. Further, they all belong to one of the most restricted club memberships in the world, that
of former Assistant United States Attorneys (AUSAs) - something which has special meaning to
Motz. Judge Motz and I have a history as well which he should have taken more seriously,
including that he sat on the board of a hospital I once sued and made statements about that matter
to third-parties, with seeming impunity. But, this is his way. People he doesn't like are nothing.
And he will 'decide' if a lawyer (or lawyers), who should have been disbarred long ago, will
continue to make an income into the millions every year. He 'decides' if his friend on the Fourth
Circuit rules one way or another, as he did in this case - the law be dammed. And he will
'decide' when a case goes to another judge whom he put on the bench what the resolution will
be in advance.
The citizens of Maryland should look hard at how this alleged behavior by U.S. District Judge J.
Frederick Motz opposes what happens to many non-connected, ordinary Maryland citizens every
day who are prosecuted as non-violent drug offenders by the U.S. Attorney's Office in federal
court, who then suffer 8, I 0, 12 year sentences in federal prison for possession convictions with
no empathy from the court as to how harsh that result is.
Right now, down at the U.S. Courthouse is a large file with the sealed documents I sought in it.
Every single honest citizen and every single institution which preaches law, order, and fairness
should go down to that courthouse and demand to know why rich, white, connected lawyers get
to keep their careers, lives, and large incomes while the poor and disenfranchised are paying
these very same lawyers - who were disqualified in the Bromwell matter - to shepherd them to
prison for significant terms before Judge Motz and/or the other judges he has put onto the
Maryland bench?
I am always amazed at how many people in and outside of Baltimore blame David Simon for
accurately portraying our city's caste structure, as if somehow, he has told a lie. But, I say, David
Simon didn't come close to describing the real problem of Baltimore:
Corruption is part of the law ...
- William C. Bond is twice the movant-intervenor in United States of America v. Thomas L.

Bromwell, Sr., et al., in the U.S. District Court for the District of Maryland.
His email is proselitigator@aol.com
JA205
EXHIBIT4
JA206
From: -BillBond
To: barbara.sal
CC: rod.rosenstein , marcia.murph~
Sent: 7/20/2013 9:44:45 P.M. Eastern Daylight Time
Subj:Yourefforis at intimidation~ .. .'
Dear Mrs. Sale,
•n-Friciay, ji:ily 19, 2013, at @ 11 AM, two federal agents knocked on the door cit my apaitinerif:: FBI
;igent Chris Wood & US Marshal & intelligence operative Robert Frederick. They were courteous;_
pleasant, and polite. Unfortunately, they both didn't seem to know much, while claiming to have read all
sorts of things. For example, they didn't know about your United Healthcare case, about DiBiagio or
~ervis Finney, whom Hodgson is, that I was hit by a car, etc. I don't believe any of it.'
Further, while we have beenin contemns and/or disputes since 2007, it is only wlifiTri2ciays ol'a'
newspaper ad attacking your clients, the Maryland judiciary, that your officers show up at my door wiih
the most phoney intimidation BS I, nor any of the reporters I have since discussed it with,have ever seen'.
This was a very big mistake on your part.
Remember, it was you who wrote in 'declining to prosecute' in 2005 that a federal judge can speak to
whomever they wish ... I certainly have that letter, and further, I have been speaking to whomever I wish,
public servants who are either criminals or have fallen down on the job -- and if they didn't like what was
being spoken to them, they could do what any person can and should do -- put the party on notice and
say -- don't write again. As you well know, no letter of that type exists. Further, most, if not all of said
letters are/were written during litigation, as part of privilege, and with particular strategic interests in mind -
- which is not up to me to explain.
But, because: you and/or your officers and /or your judges do not understand my sirategy does notgive
you the excuse to, again, misuse governmental resources to defend your own, personal self-interests
Which_ar_eseparate from that of the actual government In fact, what you have just done is the almost
exact definition of a Bivens case, which you just got finished being sued for, and only didn't suffer
consequences because the judge said I waited too long to sue (out of misplaced courtesy to you).
Further, the iciei"a-thatan-yfederal officer could file an affidavit that they are pliysfcaify
afraid ofme"is a
:fairy tail,' to quote David Margolis. I don't remember Ellen Hollander being afraid to hug me in the lobby of
a hotel this past Fall with a witness present, nor to be ungrateful as to the familial help I offered her a_s'
described in my letter to_ll~r, nor Paul Niemeyer being afraid to meet with me a second ti111e,etc ...?
'1 have advised your office cif continued tRCP 60 actions when I was done with the "'Bromwell' matter. Did
¥OU forget that? Now, your officers have flat out told me I have been under constant surveillance and
electronic surveillance during 3 years of litigation wherein you and/or your office & officers were future
defendants. Are you kidding? ;You know that prose litigants are the same as 'attorneys'under work
product and privilege matters: Not only are you going to be sued for this recent-matter in a new action,
you are very much making me think about going back to Judge Lamberth in DC with a post judgment
motion and/or new claim, in addition to the long coming, above-mentioned, 2nd FRCP 60 actions against
Motz/Garbis in the copyright case.
Your office has made a very serious mistake here in both tactics and strategy. I assure you this is not just
my opinion either.
i also don't appreciate non lawyers trying to influence me as to their opiniori ifiat tliereis7no merit'to my
'Bromwell' action: Again, are you kidding? Do you think Gavin or Leotta believe that? I could giveyc>u a
list of another 20 or more very high level lawyers, former judges, investigators, former DOJ officers, etc.,
who cannot believe the facts & allegations in this case. And, I'll tell you this, for the FBI to try to tell me to
JA207
come out to their office -- that I should cross one more of your mirage-style investigative deserts is
outrageous.
You, Rod (Remember his Sun interview focusing on the words "When the records are unsealed"), and
Ms. Gavin are on the hook here. Specifically, no FBI investigation is needed when counsel in a case
becomes aware of judicial misconduct. It is your case. All the facts you need are in my 2010 criminal
complaint and 2012 affidavit.
And, I find it interesting that the FBI feels they are independent and that their public corruption
investigators should have had this matter -- and the book matter, in their words -- but, that your office
actually sent the 201 o criminal complaint to the DOJ's Civil Rights Division instead ... Frankly, there is only
so mu·chcitfzeris can do in making proper complaints if the U.s: Attorney's-Oiiice·fs actually engaged iri
the level of legal obfuscation as exists in my matters over a very long time. I will not accept any blame for
how the complaints have been handled or to whom they could or should have been made. _Thatis you~
arena.' - --- - - -
l'lltell-you·something else. Both you and Rod could liave picked up the phone. I am aseriouslitigani.-Yoi.i
know that. And it never stopped Mr. Loucks from having a conversation with me. It is _very bad strategy_to
disrespect an opponent like this. - - - --
In closing, the FBI seems unaware of what is in the USAM or what the US Attorney can do. I am not. The
US Attorney is the Government's representative in Maryland, period. You know I am sorry this problem,
created wholly by your inaction and the illegal conduct of Motz, Niemeyer, Garbis, el al, was not taught at
Harvard or Wharton, but this is the situation you are in: You are risking several federal judges careers &
reputations, as well, as your office's & officers' careers & reputations. And, I am sure I have been 'crystal
clear' re: the only way these matters will ever finish, no matter how long you delay eventualities -- I want
prosecutions, impeachments, retirements, resignations, etc. -- vindication & restitution. That is it, and you
know it. Further, once Motz declined to follow the law in 2012 and recuse, it is well within my right as a
citizen to demand and insist that he be removed from his Article Ill status. (Toward that end, again, the
notiorithat ( would wish any harm on Fred Motz, and/or his fellow conspirators, is not only a 'fairy tail,' but
it would defeat all I pray for. My goal is for him to be publicly removed from office, prosecuted, put in ·
prison, to lose his friends and family, to lose his inheritances in civil fines and penalties, to have his
pension taken away, on and on .. I assure you I am doing every single thing in my power to see that
happens as a pubTiccitizen prosecuting this most important public interest matter. 'For youroffice to
attempt to intimidate not only my First A-mendmenl righfs, but to attempt to influence my citizen's rightsto
hold corrupt governmental officers accountable is so outrageous, it is unJJre_c_edented in this state.)
In The Art of War-- Sun Tzu speaks about ground. Fight on your ground. I played by your rules and the
perversion of what passes for justice at 101 West Lombard Street for how many years? Now, I changed
the ground. You and your clients are fighting a reputational battle. And you cannot win, as in your words --
"I have right on my side."
I am speaking with the manager of the US Courthouse Monday morning to obtain the permit(s) for my
demonstration on August 6 -- the 'White Guerrillas' ruling upon the 'Black Guerrillas.' Once I have that
permit in hand, the demonstration will not be canceled. I would say that will be by Tuesday morning latest.
If, on the other hand, you orchestrate/ play games with the permit process, I'll just have the demonstration
anyway -- under public notice of 'objection' -- and dare your officers to continue this nonsense in full view
of the public and the press.
I have been living the legal version of the black man dragged behind the pick up truck in Texas many
years ago. You know full well that Garbis and the Blum crowd, along with their lawyers, should be just
getting out of prison about this time. I never asked Judge Motz to become a criminal, but he did so before
your eyes. Once that happened -- character is revealed by action. I am at confident in mine.
That you and your office has allowed this to get to this point, as I have repeatedly said, is very poor
judgment.
JA208
Respectfully yours,
Bill
William C. Bond
Pro Se Litigation
P.O. Box 4823
443.970.2887
All informationcontained in this communicationand attachmentsis CONFIDENTIAL under the work productand/or settlement
communicationprivilege.
JA209
EXHIBIT 5
JA210
Case 1:16-cv-02723-DAF Document 24-8 Filed 05/09/17
U.S. Department Page 2 of 17
of Justice
Office of General Counsel
1\',:,shington,DC 20530-/000
JAN 1 4 20i6
William C. Bond
Re: Freedom of Information/Privacy Act Request No. 2015USMS27479

Subject of Request: U.S. Marshals Service Maryland Indoor/Outdoor
Gun Ranges and Protocols of the Marshals Service
Office of Protective Intelligence
Dear Mr. Bond:
As a result of the remand of your Freedom of Information Act (FOIA) request by the Office
oflnformation Policy, the U.S. Marshals Service is making a supplemental disclosure to you.
Enclosed is the Marshals Service Policy on Protective Investigations consisting of 14 pages. The
pages have been redacted to protect law enforcement techniques and procedures pursuant to
exemption 7(E) of the FOIA, 5 U.S.C. Section 552(b)(7)(E).
Exemption 7(E) allows an agency to withhold records or information compiled for Jaw
enforcement purposes, to the extent that the disclosure of such records or information would
disclose guidelines or techniques or procedures for law enforcement investigations or
prosecutions, the disclosure of which could reasonably be expect to risk circumvention of the Jaw.
If you are not satisfied with my response to this request, you may administratively appeal
by writing to the Director, Office oflnformation Policy (OIP), United States Department of
Justice, Suite I 1050, 1425 New York Avenue, NW, Washington, DC 20530-0001, or you may
submit an appeal through OIP's eFOIA portal at http://www.justice.gov/oip/efoia-portal.html.
Please note that OIP is in the process of transitioning from its current eFOIA portal to the portal on
FO!Aonline. Please visit the link above for instructions for submitting an appeal electronically.
JA211
Your appeal must be postmarked or electronically transmitted within 60 days of the date of this
response to your request. If you submit your appeal by mail, both the letter and the envelope
should be clearly marked Freedom of Information Act Appeal.
Sincerely,
·t n .1,cJµ-J._,J
WILLIAME. BORDLEY
~ Associate General CounseVFOIPA Officer
(j • Office of General Counsel
Enclosures
cc: OIP (Appeal 2015-03896)
JA212
liNCLASS!FlED//LAW ENFORCEMENT SENS[T!VE
United States Marshals Service POLICY DIRECTIVES
JUDICIAL SECURITY
10.7 PROTECTIVE INVESTIGATIONS
A. Proponent: Office of Protective Intelligence (OPI). Judicial Security Division (JSD}.
8. Purpose: To ensure the safety of all federal judicial officials and proceedings, the United States
Marshals Service (USMS) identifies, assesses through investigation, mitigates, and manages all
threats, inappropriate communications, incidents, and suspicious activities that pose a threat to
USMS protected persons and facilities.
C. Authority: The Director's authority to issue written directives is derived from 28 U.S.C. § 561(g)
and 28 C.F.R. § 0.111. In addition, 28 U.S.C. § 566(e)(1)(A) establishes the USMS authority to
provide personal protection to federal jurists, court officers, witnesses, and other threatened
persons in the interests of justice where criminal intimidation impedes the judicial process or any
other official proceeding.
D. Policy:
1. Due to the p,;,tenti,!Irisk of injyry or death, district mam,gement should place the highest
prioriifon ifs lfueai management and proieciive investigations respons,biiitles.
2. An evaluation should begin immediately upon receipt of any threat, inappropriate

communication, incident, or suspicious activity to detenmine if a protective investigation is
appropriate. All available district resources should be considered to conduct an
appropriate protective investigaiion. Collateral leads received should also be given the
highest priority.
3.
4. The USMS will attempt to identify, assess through investigation, mitigate, and manage all
potentially threatening situations involving its protected persons and facilities. A
comprehensive protective investigation will be conducted to mitigate risks to federal
judicial officials or other USMS protectees.
5. USMS protected persons may include but are not limited to the following officials and
their staff:
a. Justices of the Supreme Court of the United States (outside the Washington,
D.C. area, in cooperation with the United States Supreme Court Police);
b. Federal judges (circuit, district, bankruptcy, and magistrate);
c. Tax court judges;
d. Court of International Trade judges;
e. United States Deputy Attorney General;

UNCLASSIFIEDi/LAW ENFORCEi\lENT SENSITIVE
Effective Date: 2/2312015
JA213
UNCLASSIF!ED//LA W ENFORCEMENT SENSITIVE
f. Director of the Office of National Drug Control Policy (through reimbursable

agreement);
g. United States Attorneys and Assistant United States Attorneys;
h. Department of Justice attorneys;
i. Federal public defenders and their assistant public defenders;
j. United States clerks of court;
k. United States probation officers;
I. United States pre-trial services officers;
m. Jurors;
n. Witnesses;
0. United States trustees;
p. USMS employees;
q. Reproduction health services providers and facilities, pursuant to Attorney

General Order No. 3140-2010, February 23, 2010, and DOJ, Office of Legal
Counsel, -Action Memorandum; November 12, 2009; and
r. Other threatened persons in the interests of justice where criminal intimidation

impedes on the functioning of the judicial process or any other official
proceeding.
6. Protective investigations will be conducted in accordance with the OP! Guide to

Protective Investigations and Contemporary Threat Management, USMS Pub. No. 202.
A copy of the handbook can be accessed on the OPI Intranet.
7. The USMS will not initiate an investigation or keep records on an individual or group
based solely on an exercise of their First Amendment rights. However, this does not
mean that the USMS must ignore potentially dangerous speech or activity. If an
individual or group communicates inappropriately, or if other information exists that
reasonably indicates that a danger to a USMS protected person or facility exists or may
develop, then an investigator may open an investigation to ensure that the protected
person or facility remains safe and the administration of justice is not impeded.
E. Responsibilities:
1. Districts: Implement the USMS protective investigation program. To ensure the safety
of all USMS protected persons and facilities, districts must identify, assess through
investigation, mitigate, and manage all threats, inappropriate communications, incidents,
suspicious activities, and all other triggering events that indicate a danger may exist.
a. District Management:
1) Ensure a sufficient number of district personnel are designated as

District Threat Investigators (DTls) and ensure those investigators are
given sufficient time and resources to conduct thorough protective
investigations.
U"<CLASSIFIED//LA \V E;-.iFORCE,:VlENT SENSlTl\'E

EffectiveDale: 2/23/2015
JA214
UNCLASS! FIED//LA \\' ENFORCEo·IENT SENS!Tl \T
2) Upon notification that a USMS protected person has received a threat or

inappropriate communication, immediately take steps to ensure the
protectee's safety.
3) Ensure USMS protected persons are familiar with identifying threats,

inappropriate communications, incidents, and suspicious activity and the
procedures ior reporting them to the USMS. This can be accomplished
individually or during the annual security awareness training given to the
judicial family, including the United States Attorney's Office.
4) Ensure cases are entered into the Justice Detainee Information System
(JOIS) within 72 hours of receipt or development of the information that
supported the opening of a case. See the USMS District Dashboard
Protective Investigation Metrics.
5) Perform due diligence on all assigned protective investigations, including

uploading an investigative update in active cases at least once every 30
days and in suspended cases at least once every 90 days.
6) Ensure regular updates are provided to protected persons on the status

of investigations.
7) Ensure DTls provide a detailed and timely Form USM-11, Report of

Investigation, reporting all investigative activity including an initial report,
case updaies at least every 30 days, investigative activity updates, and a
closing report. All reports should be approved by a district supervisor,
Judicial Security Inspector (JSI), or Protective Intelligence Investigator
(PII) other than the person making the entry.
b. District Investigators:
1) JSI: If no PII is assigned to the district, the JSI coordinates the

protective investigations program and assigns DTls to conduct protective
investigations.
2) DTI: A collateral duty investigator charged with conducting thorough

protective investigations and mitigating threats to USMS protected
persons and faciltties. DTls must:
a) Complete the Protective Investigations Training Program (PITP);
b) Conduct and document preliminary assessments and thorough

predicated protective investigations;
c)
d) Seek concurrence with district management and OPI prior to

closing each protective investigation.
3) PII: In districts that have_,aPII position, the PII will sery~,as the
protective intelligence and protective investigation program coordinator
for that district. The PII should report directly to the Chief Deputy or an
liNCLASSl FlED//LAW ENFORCEl\!Ei\T SENSITIVE

JA215
L1NCLASSIF!ED//LA \V ENFORCEMENT SENSITIVE
Assistant Chief Deputy in the district. Pl Is have all of the responsibilities

of DTls plus:
a) Collect and analyze protective intelligence for the district; and
b) Provide guidance, assistance, and oversight to DTls during

protective investigations.
4) District Liaison Responsibilities: Districts, through the PII or JSI,

should develop working relationships consistent with their protective
------------------l·Rtem91>ru:0 :md inve,1i9"~"R-+0spomibi@01,;·----------------
a) Federal Bureau for Investigation (FBI);
b) Federal Protective Service;
c) United States Attorney's Office (USAO);
d) United States Secret Service;
e) Sheriffs offices and state courts;
f) State fusion centers; and
g) Local police.
2. OPI, Threat Management Center (TMC):
a. Serve as the USMS intake and coordination center for protective intelligence and
protective investigations. OPI collects, analyzes, and disseminates protective
intelligence to district offices, protective details, Office of Protective Operations
{OPO), senior lead!3rship,and other division,; in <1timely fashion.
b. Provide consistency for all USMS protective investigations ensuring investigative

quality control standards are met nationally.
c. Upon notification that a district initiated a protective investigation the TMC will:
1) Provide guidance and recommendations to the district;
2) Log the notification;
3) Review and assess all submitted material,
4)
5)
6) Provide coordination and support with other districts as needed.
d. After the initial coordination is provided by the TMC, the case will be forwarded to
the circuit team comprised of a Senior Inspector (GS-1811) and Intelligence
Research Specialist (GS-0132) for further coordination with the district. The
UNCLASSIFIED//LAW ENFORCEi\lENT SENSITIVE

JA216
l!NCLASSlFIED//LA \\' ENFORCEi\'lENT SENSITIVE
circuit team will provide additional investigative, analytical. and threat

management support which typically includes:
1)
2)
3)
✓I 4)
5)
6)
e. In cases that involve protective details, circuit inspectors will maintain daily
contact with the case investigator.
f. OPI will report investigative statistics to USMS leadership for use in resource and
funding allocation. OPI will also provide investigative updates to USMS and
Department of Justice (DOJ) leadership for high priority cases.
g. Critical Incidents: At the direction of the Chief, OPI, in response to a national

critical incident. emergency, or planned National Special Security Event that
could potentially impact the protective mission of the USMS, the TMC ma be
activated to provide direct su ort to th ffected USMS districts.
h.
i. PITP: OPI will design and conduct PITP classes in coordination with the Training
Division. This program will encompass up-to-date methodology in protective
investigation and threat management techniques. This training will be the
minimum training for JS ls, Plls. and DTls.
j. Additional Education, Training, and Outreach: OPI will conduct training on

protective investigation methodology and USMS_Rrotective investigation
practices when fiscally possible. These sessions will be conducted for events·~··-··
that involve multiple districts, outside agencies. and national audiences. OPI will
also support educational outreach programs in coordination with the National
UNCLASSIF!ED//LAW ENFORCEiVJENT SENSITIVE

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Appeal: 17-2150
'<"••·
Doc: 25 Filed: 03/19/2018 Pg: 223 of 424
liNCLASSlF!ED//LAW ENFORCEMENT SENSlTIVE
Center for Judicial Security. OPI will also provide districts with training materials
and guidance to assist with local in-district education initiatives.
F. Procedures:
1. Each district will designate protective investigators to review, assess and, if necessary,
investigate all information or situations that may be of protective interest.
2. Protective investigators should be criminal investigators who have attended the USMS
PITP class. All Plls are required to attend the PITP as soon as possible and will be given
-----------~·•e,,ily-eeA<!iderelieA-feHl!eAdeRee·iR-llle-,,eJ<HJ¥a~ablc-Pl+P-ole~- ··~·--------
3. Consideration of Methods: When conducting protective investigations authorized by

this directive, choices will arise among a variety of operationally sound and effective
investigative methods. Investigators will consider such factors as the investigative
method's impact on privacy and civil liberties of individuals and potential damage_to
reputation. The least intrusive method feasible is to be used in such situations.
However, investigators should not hesitate to use any lawful method, even if intrusive,
where the degree of intrusiveness is warranted by the severity of the threat.
4. The OPI is the national program office that provides subject matter guidance, oversight,
management, and coordination with district offices conducting protective investigations.
The TMC serves as the USMS intake and coordination center for all protective
intelligence and protective investigations.
5. Justice Detainee Information System (JDIS): There are two modules in JDIS to store
protective information and intelligence:
a. Judicial Security Module: The Judicial Security Module (also referred to as the
Threat Module) is accessed through the Judicial Security tab in JDIS. The
Judicial Security Module is used to record predicated protective investigations
that are initiated based on a valid triggering event.
b. Suspicious Activity, Assaults, Incidents, Deaths, and Escapes (SAID}

Module: The SAID Module, accessed through the SAID tab in JDIS, will be used
to record preliminary assessments and incidents that do not require further
investigation.
6. Categories of Investigation:
a.
UNCLASSIFIEDI/LAW ENFORCE;\lf:NT SENSITIVE

JA218
llNCLASSIFIED/iLAW ENFORCEMENT SENSITIVE
1} All general intelligence collection must be in furtherance of an authorized

USMS mission.
2) Information wtthout clear protective value may not be retained .
. b.
2) During a preliminary assessment, an investigator may seek information

proactively based on a reasonable articulable belief that the investigation
will uncover information related to a violation of law that the USMS has
the authority to investigate or in response to leads relating to activities
constituting violations of criminal law.
3) There is no time limtt on a preliminary assessment.
4) Preliminary assessment activity must be entered into the SAID module,

but personal and group identifiers may only be retained with a narrative
explaining why they are relevant to determining existence of a threat.
5) The following investigative techniques may be utilized during a

preliminary assessment:
a)
b}
c)
d}
/
/1t, e)
f}
g)
h}
6) Closure/Elevation: All preliminary assessments must eventually be

closed as either resolved or elevated to predicated protective
... -·· investigations depending.on.the information uncovered ..______ _
a) Preliminary assessments may be closed as resolved when:
UNCLASSIFIED/ILA \V ENFORcr:,•IENT SENSITIVE

Effec:ive Date: 2/23/2015
JA219
;,,;.,,, Case 1:16-cv-02723-DAF Document 24-8 Filed 05/09/17 Page 11 of 17
liNCLASS!FIED/iLA W ENFORCEMENT SENSIT!\'E
I. A determination is made that the underlying incident

does not represent a credible threat to a protected
person or facility;
II. When it becomes evident that a triggering event has not

occurred;or
Ill. When no nexus to any USMS area of responsibility

exists.
--------------~---i,t----lf-inlormeticm-obteineEl-dtll'ing-e,-pretimi~~ent-me""°-------
the threshold for opening a predicated protective investigation
and further investigation is warranted, then the preliminary
assessment must be elevated to a predicated protective
investigation and it must be entered into JDIS using the Judicial
Security Module.
c. Predicated Protective Investigations: Predicated protective investigations

allow more investigative techniques than preliminary assessments but they
require the articulation of a triggering event and must relate to actual crimes
within USMS authorities and responsibilities. A protective investigation should
only be opened if it appears likely that further investigation could develop
valuable information about the crime or potential crime indicated by the triggering
event. If there is not a reasonable indication that a crime has occurred or may
.occur or if further investigation is not likely to develop informo1tionabout a crime,
then the inforrnation·should be memorialized in the SAib module and a
predicated protective investigation should not be opened.
1) A predicated protective investigation may be opened when a triggering

event that reasonably indicates that activity constituting a federal crime
impacting the safety of a USMS protected person or facility has occurred,
is occurring, or will occur, and the investigation may obtain information
relating to that crime. Note: It is not necessary that a crime has already
taken place. The reasonable indication that a crime may take place is
sufficient justification to support opening a predicated protective
investigation.
2) There is no time limit on a predicated protective investigation.
3) A predicated protective investigation must be fully documented in the

Judicial Security Module.
4) All lawful techniques are available during a predicated protective

investigation.
5)
6)
UNCLASSIFIED/IL..\. W ENFORCE:VIENT SENSITIVE.

USMS PolicyDirective1D.7, ProtectiveInvestigations Page 8 of 14
Effective Dale: 2/2312015
JA220
liNCLASSIFIED//LAW ENFORCEMENT SENS!T!\T
d. Predicated Protective Investigation Case Initiation and Entry: Threats,

inappropriate communications, and other protective intelligence triggering events.
1)
2) Protective investigations require a cooperative effort between districts

and OPI. Districts should immediately notify the TMC when a predicated
~~~-~-,,rnt.iGli¥e--m¥06ti9atigJ+-io.initiated'".---- ------
3) Whenever information is obtained or developed that constitutes a

triggering event it should be immediately evaluated to determine if it
warrants further investigation. If any investigation beyond a preliminary
assessment is warranted, the case should be opened in the Judicial
Security Module.
a) A predicated protective investigation will be entered into JDIS

within 72 hours of the receipt or development of the information
that supported opening the case. See the USMS District
Dashboard Protective Investigation Metrics on the OPI Intranet.
b) At the time of initial entry, a narrative summary must be included

that summariz_esthe facts of ths>case <1nd!;!)(Jllainsths, triggering
event: This summary will print in JDIS Subject Reports and
should be no more than one paragraph in length. This
paragraph should briefly touch on the 'who', 'what', 'when',
'where', 'why', and 'how' ol the triggering event.
c) In addition to the narrative summary, an initial USM-11 will be

completed which contains a more comprehensive description of
the facts of the case, details of all investigative and protective
activity, and the initial investigative plan.
7. Risk Assessment:
a. In conjunction with every predicated protective investigation, the district

investigator will conduct an initial risk assessment and assign a risk level in JDIS
in line with the standards in this policy. This risk level should be assi ned in
I and district managers.
b.
C. The following standards will be utilized in determining the appropriate level of risk
and protective response. Risk assessment is divided into three categories or
levels.
1)
/
1~ UNCLASSIF[ED//LA \V E:\FORCE:VJENT SENSITIVE
USMS PolicyDireclive10.7, ProtectiveInvestigations Page 9 of 14
JA221
l'NCLASS!FIED//LAW ENFORCEMENT SENSITIVE
d.
8. When a predicated protective investigation involves multiple districts, all involved districts
and OPI will discuss the case and the district with the most significant investigative
--------------1·,,..,,1veme-i,t-•lwul,i-epe1tthe-easec-=r.J,i9-wi!l~l!e,tt,e-;l,e-<li•!,ie1-Wi!001-wlsieh !l,e subjeeo!-------
resides if the threatener's identity is known. When appropriate and agreed upon by
involved districts and OPI, a case may be shared in JDIS between two or more districts to
allow contribution by multiple investigators. In instances of case sharing, one district will
still be designated as the lead for the case.
9. The TMC will review all new protective investigations to ensure the quality of the JOIS
entry. TMC personnel will respond to the district investigator by email within 1 business
day to review the case entry and to provide OP l's preliminary findings. As appropriate,
OPI will complete the following steps.
a.
b.
C.
d.
e.
f. Prioritize a response to the case based on the risk level:
g.
10. Case Management:
a. Predicated prote.ctive investigation casesy,[U_r.e.mainopen as long .as.neces.s.ary

to implement and monitor an effective mitigation strategy.
UNCLASSI Fl EDI/LAW ENFORCE'\!ENT SENSITIVE

JA222
U:'!CLASSIFIED//LA W ENFORCEMENT SENSITIVE
b. An investigative update, USM-11, will be uploaded into the case file in JDIS as
an investigative update at least once every 30 days.
C.
d. All investigative activity will be documented on a USM-11 and uploaded into JDIS
within 48 hours of the activity. A USM-11 should be attached to the fugitive
identification number of the investigation SUBJECT, not the protectee(s).
e. Districts should seek OPI concurrence before closing protective investigations.

Upon closure, a USM-11 will be completed articulating the reason_swhy the case
warrants no further investi ation
f.
g. The FBI has principle jurisdiction for investigation of criminal threats against
judges and other government employees. Any time information is developed that
reasonably indicates that a criminal threat has been committed against a
protected person, the FBI should be notified immediately. This should be
documented in JDIS.
1)
o coor ma e the needs of both agencies the

USMS investigator should request to work the investigation jointly with
the FBI.
The USMS should not defer to
the FBI but should make a concerted effort, with district management
involvement when necessary, to mitigate any potential threat to the
USMS protectee through a joint investigation.
2) If an arrest is made in the FBI criminal investigation, the investigator

should immediately notify OPI.
3) If the FBI elects not to conduct an investigation and the USMS

investigator conducts a protective investigation that develops facts which
support prosecution, the investigator should present the case to the local
USAO.
h. The Director of the Executive Office of the United States Attorney (EOUSA) and
the Director of the USMS signed a Memorandum of Understanding {MOU) in
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE

USMS PolicyDirective10.7, ProtectiveInvestigations Page1iof14
Effecllve Dale: 2123/2015
JA223
.: . .;:
F:';'.<--,.
~- Case 1:16-cv-02723-DAF Document 24-8 Filed 05/09/17 Page 15 of 17
l•:S:CLASSlf!ED//LAW ENFORCEMENT SENSITIVE
11. Additional District Protectees:
a. United States Circuit Court Judges: District protective investigators will conduct
investigations involving circuit court judges. All investigative activity should also
be reported to the OPO circuit inspector.
b. United States Supreme Court Justices: Protection of United States Supreme

Court Justices is a shared responsibility with the United States Su
Police Department (SCPD), OPO, and the district.
/\ i
c. USMS Headquarters Employees: OPI will conduct an initial assessment on all

threats and inappropriate communications received by USMS Headquarters
personnel. The TMC will forward all pertinent information and recommendations
to the appropriate district for further evaluation and case initiation if warranted.
12. Suspended Cases: When a district investigator and the OPI Circuit Inspector agree, a
case may be suspended in JDIS. Suspended cases must be updated by USM-11 at
least once every 90 days.
13.
OPI will coordinate with other USMS

Factors for major case designation include:
a.
b.
C.
d.
UNCLASSIFIED//LAW ENFORCEi\JE:NT SENSITIVE

USMS PolicyDirective 10.7, ProtectiveInvestigations Page 12 of 14
JA224
l'NCLASS!FIED//LA W ENFORCEMENT SENSITIVE
G. Definitions:
1. Inappropriate Communication: Any communication in any form that threatens,

harasses, or makes unsettlin overtures toward a rotected person or facility, or
otherwise causes concern.
2.
e lead investigator of the case is responsible for creating at oroug an

effective investigative plan. Advice and assistance in developing an investigative plan is
available from OPI by contacting the TMC or your district's Circuit Inspector. Examples
of investigative plans can be found on the OPI Intranet site.
3. Mitigation Plan:
4.
5. p M A
•
f . .. ~
/\ G.
____
.
UNCLASSIF!ED//LAW ENFORCEi\lENT SENSITIVE
JA225
llNCLASS!F!E0//LA W ENFORCEMENT SENSITIVE
6.
7.
8. Shared Case: A shared case is one in which two or more districts are able to approve
USM-11 s. This practice willonly be implemented based on the agreement of the opening
district, the added district, and OPI.
9. Threat: Any action or communication, whether explicit or implied, of intent to assault,

resist, oppose, impede, intimidate, or interfere with any member of the Federal judiciary,
or other USMS protected person. A threat may be written, verbal, or gestured, and may
be delivered directly or relayed through third parties.
10. Threat Assessment: Protective investigation threat assessments evaluate the credibilit
and seriousness of a threaten in sub·ect.
11. Triggering Event: A triggering event is necessary to open a predicated protective

investigation. A triggering event is an articulable factual basis reasonably indicating that
activity constituting a federal crime·has occurred; is occurring, or will occur and that
investigation may obtain information relating to the activity. Note: It is not necessary that
a crime has already taken place. The reasonable indication that a crime may take place
is sufficient justification to support opening a predicated protective investigation
H. References: None.
I. Cancellation: This policy directive supersedes USMS Policy Directive 10.3, Protective
Investigations, and remains in effect until superseded or cancelled.
J. Authorization and Date of Approval:
By Order of: Effective Date:
Isl 2/23/2015
Stacia A. Hylton
Director
U. S. Marshals Service
UNCLASSIFIED//LA W ENFORCEMENT SENSITIVE

JA226
EXHIBIT 6
JA227
MICHAEL K. SPODAK, M.D., P.A.

26 WEST PENNSYLVANIA AVENUE
TOWSON, MARYLAND 2 1 204
TELEPHONE (41 0) 337-0343
FAX (41 0) 321-0337
September 17, 2001
RE: William Bond

DOB:
ss u,,
••• l/l/64
4496
PHYSICIAN'S CERTIFICATE
Please be advised that the above named individual

was seen for a psychiatric evaluation in my office on
SeµLelllLer 17, 2001.
As a result of that evaluation, it is my opinion,
to a reasonable degree of medical probability, that Mr.
Bond is capable of possessing a regulated firearm, without
undue danger to himself or to others and was equally so
capable dating back to at least April, 2001.
MKS:pr
JA228
AFFIDAVIT OF AUTHENTICATION
My name is Michael K. Spodak. I am a board certified
psychiatrist licensed to practice under the laws of Maryland. My
offices are located at 26 W. Pennsylvania Avenue, Towson, Maryland.
The attached certification regarding my patient, William C.
Bond, is a business record prepared by me. It contains my opinion.
It was prepared by me; kept in the ordinary course of my practice;
and it is the regular business of my practice to keep such records.
I am the custodian of this record and state that it was prepared by
me at or ne·ar the time of the occurrence of the matters set forth
in it and based on information provided by a person or persons with
knowledge of these matters.
MICHAELK. SPODAK, M
JA229
EXHIBIT7
JA230
2013 Maryland Code:: PUBLIC SAFETY::§ 5-133 - Restrictions on possession ofregulated

firearms
§5-133.
(a) This section supersedes any restriction that a local jurisdiction in the State imposes on the
possession by a private party of a regulated firearm, and the State preempts the right of any local
jurisdiction to regulate the possession of a regulated firearm.
(b) A person may not possess a regulated firearm if the person:
(I) has been convicted of a disqualifying crime;
(2) has been convicted of a violation classified as a common law crime and received a term of
imprisonment of more than 2 years;
(3) is a fugitive from justice;
(4) is a habitual drunkard;
(5) is addicted to a controlled dangerous substance or is a habitual user;
(6) suffers from a mental disorder as defined in§ I0~I0l(f)(2) of the Health - General Article and
has a history of violent behavior against the person or another, unless the person has a
physician's certificate that the person is capable of possessing a regulated firearm without undue
danger to the person or to another;
(7) has been confined for more than 30 consecutive days to a facility as defined in § 10-101 of
the Health - General Article, unless the person has a physician's certificate that the person is
capable of possessing a regulated firearm without undue danger to the person or to another;
(8) except as provided in subsection (e) of this section, is a respondent against whom a current
non ex parte civil protective order has been entered under § 4-506 of the Family Law Article; or
(9) if under the age of 30 years at the time of possession, has been adjudicated delinquent by a
juvenile court for an act that would be a disqualifying crime if committed by an adult.
(c) ( 1) A person may not possess a regulated firearm if the person was previously convicted of:
(i) a crime of violence;
(ii) a violation of§ 5-602, § 5-603, § 5-604, § 5-605, § 5-612, § 5-613, or§ 5-614 of the
Criminal Law Article; or
(iii) an offense under the laws of another state or the United States that would constitute one of
JA231
the crimes listed in item (i) or (ii) of this paragraph if committed in this State.
(2) (i) Subject to paragraph (3) of this subsection, a person who violates this subsection is guilty
of a felony and on conviction is subject to imprisonment for not less than 5 years and not
exceeding 15 years.
(ii) The court may not suspend any part of the mandatory minimum sentence of 5 years.
(iii) Except as otherwise provided in§ 4-305 of the Correctional Services Article, the person is
not eligible for parole during the mandatory minimum sentence.
(3) At the time of the commission of the offense, if a period of more than 5 years has elapsed
since the person completed serving the sentence for the most recent conviction under paragraph
(l)(i) or (ii) of this subsection, including all imprisonment, mandatory supervision, probation,
and parole:
(i) the imposition of the mandatory minimum sentence is within the discretion of the court; and
(ii) the mandatory minimum sentence may not be imposed unless the State's Attorney notifies the
person in writing at least 30 days before trial of the State's intention to seek the mandatory
minimum sentence.
(4) Each violation of this subsection is a separate crime.
(d) (I) Except as provided in paragraph (2) of this subsection, a person who is under the age of
21 years may not possess a regulated firearm.
(2) Unless a person is otherwise prohibited from possessing a regulated firearm, this subsection
does not apply to:
(i) the temporary transfer or possession of a regulated firearm if the person is:
1. under the supervision of another who is at least 21 years old and who is not prohibited by State
or federal law from possessing a firearm; and
2. acting with the permission of the parent or legal guardian of the transferee or person in
possess10n;
(ii) the transfer by inheritance of title, and not of possession, of a regulated firearm;
(iii) a member of the armed forces of the United States or the National Guard while performing
official duties;
(iv) the temporary transfer or possession of a regulated firearm if the person is:
JA232
I. participating in marksmanship training of a recognized organization; and
2. under the supervision of a qualified instructor;
(v) a person who is required to possess a regulated firearm for employment and who holds a
permit under Subtitle 3 of this title; or
(vi) the possession of a firearm for self-defense or the defense of others ag;iinst a trespasser into
the residence of the person in possession or into a residence in which the person in possession is
an invited guest.
( e) This section does not apply to a respondent transporting a regulated firearm if the respondent
is carrying a civil protective order requiring the surrender of the regulated firearm and:
(I) the regulated firearm is unloaded;
(2) the respondent has notified the law enforcement unit, barracks, or station that the regulated
firearm is being transported in accordance with the civil protective order; and
(3) the respondent transports the regulated firearm directly to the law enforcement unit, barracks,
or station.
Disclaimer: These codes may not be the most recent version. Maryland may have more current or
accurate information. We make no warranties or guarantees about the accuracy, completeness, or
adequacy of the information contained on this site or the information linked to on the state site.
Please check official sources.
JA233
EXHIBITS
JA234
2013 Maryland Code:: PUBLIC SAFETY::§ 5-205 - Possession by person with mental
disorder
§5-205.
(a) Unless the person possesses a physician's certificate that the person is capable of possessing a
rifle or shotgun without undue danger to the person or to another, a person may not possess a
rifle or shotgun if the person:
(1) suffers from a mental disorder as defined in§ 10-I0l(f)(2) of the Health - General Article and
has a history of violent behavior against the person or another; or
(2) has been confined for more than 30 consecutive days in a facility as defined in § I 0-10 I of
the Health - General Article.
(b) A person who violates this section is guilty of a misdemeanor and on conviction is subject to
imprisonment not exceeding 3 years or a fine not exceeding $1,000 or both.
Disclaimer: These codes may not be the most recent version. Maryland may have more current or
accurate information. We make no warranties or guarantees about the accuracy, completeness, or
adequacy of the information contained on this site or the information linked to on the state site.
Please check official sources.
JA235
EXHIBIT 9
JA236
could have devastating consequences for innocent citizens if the wrong decision is made." S.
Rep. No. 102-353, at 19 (1992). Congress has reaffirmed its appropriations restrictions
numerous times since then. See Bean, 537 U.S. at 75 n.3 (listing subsequent appropriations
decisions); Mullis v. United States, 230 F.3d 215, 219 (6th Cir. 2000). Moreover, the Supreme
Court has held that Congress's decision to defund the program stripped the federal courts of
jurisdiction to review claims arising under§ 925(c). Bean, 537 U.S. at 78 ("[T]he absence of an
actual denial of [a] respondent's petition by ATF precludes judicial review under § 925( c)").
Still, in early 2008, Congress renewed the possibility that certain prohibited individuals
could have their right to possess a gun restored. Seeking to remedy weaknesses in the
national instant criminal background check system (NICS), Congress authorized federal
grants to encourage the states to supply accurate and up-to-date information to federal
firearm databases. See NICS Improvement Amendments Act of 2007, Pub. L. No. 110-180,
§ 103, 121 Stat. 2559, 2567 (2008). Eligibility for the grants is based, in part, on the
creation of a relief-from disabilities program that allows individuals barred by § 922(g)(4)
1
to apply to have their rights restored. Id. at §§ 103, 105, 121 Stat. at 2568--69. Under
qualifying programs, "a State court, board, commission, or other lawful authority shall
grant the relief ... if the circumstances regarding the disabilities ... and the person's
record and reputation, are such that the person will not be likely to act in a manner
dangerous to public safety and that the granting of the relief would not be contrary to the
public interest." Id. § 105(a)(2), 121 Stat. at 2569-70. The state program must also
"permit[] a person whose application ... is denied to file a petition with the State court of
appropriate jurisdiction for a de novo judicial review of the denial." Id. § 105(a)(3), 121
Stat. at 2570. The government represented in its supplemental brief that thirty-one states
have created qualifying relief programs. 2 Tyler's home state of Michigan is not one of
them. (Emphasis added.)
1
Unlike the federal relief-from-disabilities program, which offered relief to all persons prohibited from gun
possession under federal law, the state programs need only provide relief to individuals "who [have] been
adjudicated as a mental defective or who [have] been committed to a mental institution." § 922(g)(4); see
Pub. L. No. 110-180§ 105(a)(l).
2
The actual number of states with qualifying relief-from-disabilities programs is uncertain. While the
government puts the number at thirty-one, the Bureau of Justice Statistics states that as of September 2015. twenty-
nine states have enacted qualifying programs. The Bureau also notes that only twenty-two states received NICS
JA237
Improvement Act funding in 2015. Bureau of Justice Statistics, The NICS Improvement Amendments Act of 2007,
http://www.bjs.gov/index.cfm?ty;tp&tid=49#20l 1 (last visited March 17, 2016).
JA238
EXHIBIT 10
JA239
MESSERMAN & MESSERMAN CO., L.F!A.

ATTORNEYS AT LAW
11525 OHIO SAVINGS ?LAZA· 1801 EAST 9T" STF=tE:£T
CLEVELAND, OHIO 44114

GE:RALO A. MESSE:RMAN TELEPHONE
GALE S. MESSERMAN 216/157'4-9990
January 17, 1986
Mr. William C. Bond

901 St. Paul Street
Dear Bill:
I'm sorry I missed you during the Christmas holidays.
Things just got very hectic.
I assume you have already been advised that your
--probation status has been officially terminated.
If not, you may accept a copy of the official notice I
received as formal notice of your current status.
Please remind me in two years to file an application

for expungement and I will do so.
Warmest regards,
,j
Gerald
l<'l.'
• • Messerman
GAM:mk
Enclosure
JA240
EXHIBIT 11
JA241
LAW OFF'tCES OF
ERi EVI EW TOWER
DUVIN. CAHN. BARNARD & MESSERMAN 20TH FLOOR

STREET
1301 EAST NINTH
A LEGAL PROFESSIONAL ASSOCIATION
CLEVELAND, OHIO 44114
GERALD A. MESSERMAN
216/623·608S 216/696·7600
OIRECT OIAL:
TELECOPIER: 216/696·2828
May 16, 1994
Mr. William C. Bond

14529 Cuba Road
Cockeysville, MD 21030-1011
Dear Bill:
I am glad to hear that you are healthy and creative.
I would be delighted to review your book. Is it finished?
I don't have transcripts of your sentencing. We never ordered any transcripts. I know
of none currently available.
There is no procedure for expunging your juvenile record. It is automatically

"expunged" in the sense that it is private, confidential and sealed. It is not a criminal record.
You don't have to worry about it.
I look forward to hearing from you.
Very truly yours,
a. c)1&-e~
,___J~
Gerald A. Messerman
GAM:tmw
JA242
EXHIBIT 12
JA243

WILLIAM C. BOND *
Plaintiff *
vs. <CIVIL ACTION NO. MJG-01-2600
KENNETH BLUM, SR., et al. *

Defendants *
* * * * * * * * *
MEMORANDUM
AND ORDER
The Court has before it Plaintiff's Motion to Recuse and the
materials submitted relating thereto. The Court finds that a hearing
is unnecessary.
I. FACTS
In 1961, the second year of the E. Barrett Prettyman Fellowship
program, Georgetown Law School selected eight law school graduates
for a "legal internship." The legal interns practiced law as public
defenders in a storefront office on Fifth Street in Washington D.C.
under the supervision of a then-young professor, George Shadoan. The
interns had the great benefit of trying cases as court-appointed
counsel in the D.C. courts under the supervision of George Shadoan
and attending formal classes at the law school leading to a post
graduate L.L. M. degree. The undersigned Judge, Gerald Messerman of
JA244
. '
u
Cleveland, Ohio and six others were fortunate enough to be the
Prettyman Fellows for the 1961-62 year.
During that year, the interns worked together on cases,
observed each others• trial performances, and learned from each
other. In the 41 years since graduation from Georgetown in 1962, I
have seen Mr. Messerman on rare occasions, only which I can
specifically recall was not part of a law school reunion.' While in
practice, I had infrequent professional contact with Mr. Messerman. I
always had the highest respect for him and made reco=endations of
him to people who, from time to time, needed to engage counsel in
Cleveland. In sum, Mr. Messerman is one of the many excellent
lawyers with whom I have. had the privilege of practicing during my
career. Many of those former colleagues have practiced before me 2
and, should occasion arise, Mr. Messerman would be welcome to do so
also.
When assigned the instant case in August of 2001, I noted that
Plaintiff's criminal counsel in Cleveland had been Mr. Messerman.
This fact was of no moment to me whatsoever.
1 In the mid-1990's, on an occasion when my wife and I were

meeting a family member in Akron, Ohio, we had dinner and saw a show
with Mr. Messerman and his wife. This is my only non law school
related post graduation social contact with Mr. Messerman that I
recall.
2 Including Joseph Kaufman of Schulman and Kaufman, counsel for
Plaintiff in the instant case.
JA245
Case 1:16-cv-02723-DAF
._____) c·-.
Document 24-15 Filed 05/09/17 Page 4 of 6
On November 26, 2001, I entered Judgment for Defendants based
upon my rulings on the merits of the case. I note, from Plaintiff's
papers, that on approximately November 27, 2001, Plaintiff met with
Mr. Messerman who told Plaintiff of his connection with me. On
December 27, 2001, I denied Plaintiff's Motion to Alter or Amend
Judgment. On February 6, 2002 I held that the individual Defendants
would recover legal fees from Plaintiff, stated that I would have
awarded legal fees to the law firm Defendants had I believed I had
discretion to do so, and denied Rule 11 sanctions.
The case was appealed to the United States Court of Appeals for
the Fourth Circuit. On January 24, 2003, the Fourth. Circuit
affirmed judgment for the Defendants on the substantive merits. Bond
v. Blum, 317 F.3d 385 (4th Cir. 2003). The appellate court further
held that I did have discretion to award legal fees to the Defendant
law firms and should reconsider the denial of sanctions in light of a
recent decision.
On approximately January 31, 2003, Plaintiff sued Mr. Messerman
in the Circuit Court for Baltimore City. In broad terms, Plaintiff
claimed that Mr.Messerman had not properly represented him.
The instant case is now before me on remand to decide upon a
legal fee award for the law firm Defendants and the award of any
sanctions under Rule 11.
JA246
0
II. DISCUSSION
The Court will disregard any issues presented by virtue of the
timing of the instant motion. See~ Satterfield v. Edenton-Chowan
Bd. of Ed., 530 F.2d 567, 575-75 (4 th Cir. 1975) (" [o)ne must raise
the disqualification of the . [judge] at the earliest moment
after knowledge of the facts [allegedly evincing bias)").
Accordingly, the Court will assume that the alleged disqualifying
event occurred on January 31, 2003 when Plaintiff sued Mr. Messerman
and, therefore, the instant motion was timely filed.
The disqualification statute, 28 U.S.C. § 455, provides, in
pertinent part:
(a) Any justice, judge, or magistrate of the United

States shall disqualify himself in any proceeding in
which his impartiality might reasonably be
questioned.
Recusal pursuant to Section 455(a) is required "if a reasonable man,
cognizant of the relevant circumstances surrounding a judge's failure
to recuse would harbor legitimate doubts about the judge's
impartiality.• _s_e_eUnited States v. Bremers, 195 F.3d 221, 226 (5 th
Cir. 2000).
The instant case does not present a close question. The fact
that Mr. Messerman had been Plaintiff's counsel in the underlying
criminal case had no effect, nor the appearance of any effect, on
this judge's decision prior to the appeal. Most judges who had been
JA247
0
in an active law practice regularly decide cases in which the parties
include present (and former) clients of former colleagues.
The fact that Plaintiff has sued Mr. Messerman in regard to his
representation of Plaintiff in the criminal case does not change the
situation. Mr. Messerman is not a party to the instant case.
Moreover, the Court's decision on the only issues presented - the
making of any award for legal fees and sanctions - would have no
effect whatsoever on Mr. Messerman. In sum, this Court is not
influenced, and would not appear to a reasonable informed person to
be influenced, by the fact that the Plaintiff has sued an attorney
with whom the judge had practiced law for one year more than forty
years ago and who the judge has seen socially approximately once
every five years or so since then.
III. CONCLUSION
For the foregoing reasons:
1. Plaintiff's Motion to Recuse is DENIED.
2. The Court shall proceed to decide the pending

matters.
SO ORDERED, on Thursday, April 23, 2003.
s
Marvin J. Garbis
JA248
EXHIBIT 13
JA249
https: I!www.sheppardpratt.org/ about/board- members/
Board Members IMental Health
Sheppard Pratt Health System has been guided for more than 161 years by a volunteer Board of
Trustees. This board governs the Health System's activities to help ensure that we are providing
quality, compassionate mental health treatment.
To this day, the board still upholds the original guidelines set in place for The Sheppard Asylum
by founder Moses Sheppard in 1853. To ensure the humane treatment of the mentally ill these
guidelines include:
Courteous treatment and comfort of all patients

No patient to be confined below ground; all to have privacy, sunlight, and fresh air
A curative environment, combining science, and experience for the best possible results
Only the income of the endowment, not principal, is to be spent to build and operate the
Health System
The Sheppard and Enoch Pratt Foundation, Inc. is the parent corporation for The Sheppard Pratt
Health System and its affiliates, as well as for The Sheppard Pratt Physicians, P.A., and is the
entity that conducts fundraising. The Board of Trustees governing our Health System includes:
Trustees
The Honorable J. Frederick Motz (Chair)

Margaret Allen
Emile A. Bendit, M.D.
S. Winfield Cain
Penelope Cordish
Alan Evans
Susan Fenimore
Alan Gamse
Philip H. Grantham
Dr. Robert Hamilton
Bonita Hearn
Joshua Kake!
Norma Peden Killebrew
Robert Kresslein
Brian Le Gette
William Morton
Robert Schaftel
Gail L. Shawe
Alfred Singer
John W. Steele, III
Gary Talles
Pamela P. Young, Ph.D.
JA250
Associate Trustees
Timothy R. Hearn, CCIM

Kenneth Jones
Holly Lanigan
Richard A. Lamond
Wayne Lingafelter
Wyatt Lee
Susan Gay Williams
JA251
EXHIBIT 14
JA252
because of his too close friendship with the district court and the fact that he would never
judicially reprimand his too close friend in ways that would cause public embarrassment, nor
subject him to judicial discipline.
c) As evidenced from the beginning of this paper, the Fourth Circuit judge was aware of
'confidential and privileged communication(s)' written in 2009 to defense counsel for some of
the disqualified attorneys and some of its subject matter. Not only is this an immediate reason for
the Orders in this case to be vacated, but there appears to be criminal obstruction of justice in this
matter which should be investigated.
2. Pervasive issues: 12
Movant's interviews with the Fourth Circuit judge included statements made to Movant such as,
"You are very clever," "Your litigations should never have been brought," and "If you don't stop,
you will be destroyed."
The Fourth Circuit judge told Movant, concerning another ofMovant's litigations whom he had
also presided over, that it appeared that Movant's "enemies had done everything they could do to
destroy your life," that "if he was to return the case - i.e., that if he was to grant FRCP 60 relief
12
The unbelievable procedural violations allowed in favor of the disqualified attorney., in
the prior appeal of this matter are entirely germane to the present recusal issues. Please see:
Fourth Circuit case no. 09-7572, docket nos. 29 & 37.
12
JA253
- it would cause too many problems [for his cronies]," and that the money plaintiff was mulcted
out of"wasn't that much money" to rectify for "all the trouble it would cause" [again, to his
cronies]. 13
The Fourth Circuit judge made many other statements that were either against his interest,
against the interest of the district court, and/or were just plain embarrassing.
D. The Docket & Suppression Thereof
The docket in this case is neither whole, complete, nor accurate. For example, the in camera
proceedings on January 30, 2007, March 6, 2007, and March 14/15, 2007, are missing from the
docket. Movant alleges that there are more than these items missing from the docket as well as
misstatements of dates re: various documents, etc.
The March 6, 2007, in camera teleconference appears to be the reason why the Fourth Circuit
Court would appear to be sealing Movant' s filings at docket nos. 15 & I 7 even though this
document was given to Movant by the district court clerk in 2009. That there is no Order
explaining this action is just one of many underhanded and hidden ways that Movant has been
overtly and covertly thwarted by the court( s) in this action.
13
The Fourth Circuit judge thought Movant's damages in that case were $250,000 when
in actuality they were $450,000 plus interest. Either way, to him that was "not that much money."
13
JA254
EXHIBIT 15
JA255
AFFIDAVIT OF WILLIAM C. BOND
I. My name is William C. Bond. I reside at 1031 West 36 th Street, P.O. Box 4823, Baltimore,
Maryland 21211. I am over 21 years of age. I am competent to testify. I have personal knowledge
of the matters set forth herein.
2. I met with sitting U.S. Fourth Circuit Judge Paul. V. Niemeyer on June 18, 2010 and July 19,
2010, for approximately 6 hours at a Baltimore coffee shop named 'Common Ground.'
3. My primary motivation to meet with the judge was to discover how the judge could allow me
to have been ordered to pay the legal fees to the individuals who had stolen a manuscript which
belonged to me from my deceased attorney's legal files, and who had actually put their name on
1
the stolen property?
4. I also wanted to know what the judge's basis was for not reversing the district court as to this
property 'not being stolen?''
5. The judge told me that it "wouldn't have made any difference if the defendants in that case had
stolen my manuscript from the vaults of the Bank of America," which I found to be an incredible
statement.
1
Please see: Affidavit Exhibit # I which is a photo of the actual evidence produced in
Maryland District Court case no. 01-2600-MJG, and a photo which was part of the evidence
produced to this district court in 07-1385-JFM.
2
Please see: Maryland District Court cases 01-2600-MJG & 07-1385-JFM and Fourth
Circuit cases 07-1720 & 08-1171.
JA256
6. The judge also told me that "I should not have brought the litigation to gain the return of my
property," and insinuated that a person of my social stature could not challenge the attorneys and
individuals who had been involved in its theft. Further, the judge did not think my damages were
"that much money."
7. While the judge told me many other things, many of which were either against his interest,
against the interest of the district court, and/or were just plain embarrassing; one thing I took as a
threat: "If you don't stop [your litigations], you will be destroyed."
8. The judge also told me about his long-standing personal friendship spanning decades with this
district court, including that the two judges play tennis doubles every Monday for 27-odd years,
about traveling and dining often, etc. In short, this district court and the Fourth Circuit Judge are
very, very close and old friends.
9. Of most note, referring to this case, the judge proffered that "You can't make money off a
public records case."
10. I believe that disqualified attorneys' counsel David B. Irwin and/or someone on his behalf
with access to the documents, discussed the contents of 'confidential and privileged settlement
communication( s)' with the judge or someone who relayed that information to him.
11. I have no doubt in my mind, after meeting with the judge, that partiality by him toward me in
JA257
all my litigations has been thrown out the window and that defeating me and helping his fellow
judges and attorney cronies has become something of a sport which has nothing to do with the
law as it is written whatsoever.
Pursuant to 28 U.S.C. 1746, I declare under the penalty of perjury that the above is true and
correct.
William C. Bond
August 22, 2012
Date
JA258
EXHIBIT 16
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" )V\-ti'·
-~
for the
FOURTH CIRCUIT
UNITED STATES OF AMERICA, *
V. *
WILLIAM C. BOND * No.: 14-6017
Movant-Intervenor/ *
Appellant pro se
*
* * * * * * * * *
MOTION FOR THE CIRCUIT COURT TO RECUSE AND TRANSFER
1. This case concerns allegations of judicial misconduct and disability which are
novel in this court's litigation history-that a U.S. circuit court judge and a U.S.
district court judge are conspiring to obstruct justice in a prominent Maryland
public corruption case to not only protect their friends and cronies, but also to
deprive this appellant of his constitutional rights to due process and other
protections.
---------------------~
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2. This case also concerns facts which are novel: (1) that the U.S. DOJ actually
joined a pro se party to unseal their own criminal case in both the district and
circuit courts in 2009, but now in 2013/2014 are using the FBI and the U.S.
Marshals Service to attempt to thwart that very same goal; (2) and that the base
information regarding the alleged judicial misconduct and disability came from
appellant's in-person meetings in 2010 with sitting U.S. Circuit Court Judge Paul
V. Niemeyer, who has been on this circuit court since 1990.
3. Some of this information was previously put before the district court by affidavit
1
in 2012, which was uncontested.
4. Recently, this circuit court was challenged with some of these same allegations
in a 2013 petition for writ of mandamus, but declined to exercise any review, as
apparently appellant was not a 'crime victim' in the underlying case according to
2
thi s court.
5. ln addition to the district court 2012 affidavit, which was specific to that case
and action, appellant made other allegations regarding the alleged judicial
1
Please see: The district court's docket no. 239.
----- --------- --- ---
2
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misconduct and disability in a 2010 federal lawsuit against the U.S. DOJ, which
was dismissed under a 'statute oflimitations' ruling in 2012, which stated that the
same two Article III judges at issue in this appeal were part of the conspiracy to
have former U.S. Attorney for the District of Maryland, Thomas M. DiBiagio,
fired in late 2004, in part, because of appellant's criminal referral to that office,
which was being acted on at that very time, regarding some of the disqualified
attorneys in the case underlying this appeal, and a third Maryland Article III judge,
3
Marvin J. Garbis.
6. The U.S. Constitution at Article 1, Section 9, Clause 3, bans 'Bills of Attainder.'
7. Yet that is the essence of what Judge Niemeyer told appellant that he was being
subjected to in meetings totaling 6 hours in the summer of 2010. In fact, Judge
Niemeyer told appellant that his litigations "should never have been brought"
because of who the targets were and that "they would never let him win."
8. Judge Niemeyer told appellant that he had no right to his property which was
2
Please see: CA 4 no.: 13-2462.
3
Please see: U.S. District Court for the District of Columbia case no.: 1: 1O-
cv-01617-RCL, docket nos.: 6 & 26.
3
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stolen from him, nor to the attorneys' fees he was ordered to pay the criminals who
stole it.4 Further, Judge Niemeyer continued to wrongly tell appellant to seek state
remedies for his stolen copyrighted works, even though the Copyright Act
. 5
preempts any state so Iut10n.
9. Judge Niemeyer also told appellant that he never read the manuscript he
liberally quoted from in his 2003 reported opinion, which is wrongly being used as
6
case law precedent in many other U.S. courts of appeal.
10. Judge Niemeyer spent much time speaking to appellant in person about two
books: The Genesee Diary by Henri Nouwen and Crime and Punishment by
Fyodore Dostoevsky.
11. While grossly misunderstanding The Genesee Diary, and the fact that it was
written by a closeted homosexual too cowardly to face himself, Judge Niemeyer
seemed fascinated with the author's vows of poverty and the story of the Abbey's
4
Please see: CA 4 case nos.: 02-1139, 07-1720, 08-1171, 08-1320.
5
The United States Attorneys' Manual clearly states this fact. Please see:
USAM 9-71.010.
6
Please see: https://www.courtlistener.com/ca4/513H/wi11iam-c-bond-v-
kenneth-blum-sr-kenneth-blum-jr-d/cited-by/
4
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monks making him carry rocks from the river to the monastery, even though the
writer was only on a 'sabbatical,' and his story was really just about short term
vacation, rather than a real lifestyle. Judge Niemeyer used this book anecdote to
illustrate his justification to appellant for depriving him of his money and property.
12. In regard to Crime and Punishment, Judge Niemeyer wanted appellant to know
that appellant's life would 'only' begin when he reentered prison a second time, for
a second punishment, for the act of killing his father, for which appellant was
already adjudicated a delinquent in 1981 in Ohio. For an Article III judge to make
such a statement to a person whose life he had already ruined is such a grossly
unconstitutional thing to say that it defies words of further description.
13. Judge Niemeyer told appellant about his fascination with reading criminal pre
sentencing reports as "the first thing he did with each criminal appeal before him."
14. Appellant found Judge Niemeyer's tone and fascination with these documents
disturbing, especially in relation to his many times quoted references to Jesus and
biblical interpretation of the law. Especially insulting to appellant was Judge
Niemeyer's justification to impose a 'double jeopardy sentence' upon appellant
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while ignoring that he was ignoring one of the.Ten Commandments: Thou shalt not
steal.
15. Judge Niemeyer told appellant that, in regard to appellant's earlier cases, that it
"appeared that [appellant's] enemies had done everything they could do to destroy
[his] life." Appellant countered with the obvious fact that Judge.Niemeyer had
made a serious mistake in his earlier ruling, based upon prejudice and wrong facts,
and that appellant would not be able to live a full life without a correction of the
wrong judgments against him, as the economic and social damage done to
appellant by Judge Niemeyer's acts was impossible to solve. Judge Niemeyer's
answer was that appellant should "pray to Jesus" even though it was only through
7
the stroke of Judge Niemeyer's pen that his mistakes could be rectified.
16. Appellant has found many enemies in this world based upon dislike of
appellant's juvenile past. Interestingly, most of these enemies either had similar
problems with their own fathers and/or caused similar damage to their own
children. Judge Niemeyer fits into this category given his own history with his
7
Judge Niemeyer was made well-aware of the facts presented, by affidavit,
to the U.S. District Court for the District of Columbia case no.: l:10-cv-01617-
RCL, docket no. 13, Exhibit B.
--·------------------
6
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immediate family, including issues of severe drug addiction.
17. Litigants do not come to U.S. courts as one may come for admittance to a
country club. Appellant has his constitutional rights to due process, to his ovvn
property, and to the prohibition of 'Bills of Attainder.' Further, 28 U.S.C. 455 is
mandatory, as are the U.S. Court's Judicial Canons.
18. In an earlier appeal of this case, this court ordered the government to respond
to appellant's recusal motion. Appellant is not throwing stones at the government
for their answer at that time, but he certainly does for their non action since that
time. But Judge Niemeyer knew all along what he had done overtly and covertly to
thwart this appellant and, ifhe was honest, he would have recused from the case at
that time, nor did he ever attempt to rectify the wrongs he had committed, not only
8
to this appellant, but to the citizens of Maryland in this underlying case.
19. Therefore, because Judge Niemeyer is an active member of this court, this
court must recuse itself in toto from any further considerations in this matter and
transfer this case to another court of appeals which has zero contacts or association
8
Please see: CA 4 appeal no.: 09-7572, docket nos.: 14, 16, 23, & 35.
7
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with the Maryland federal court and its judges. 9
20. ln the alternative, this court should simply vacate all post judgment 'public
records requests' district court orders in this case, remand this case to a visiting
judge, and order the Maryland U.S. Attorney's Office to be disqualified from any
further action in this matter. 10
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
9
The point of this motion is not to do a line-by-line list of all the illegal
and/or offensive things Judge Niemeyer said to appellant in-person, nor to list each
and every thing Judge Niemeyer and other Maryland Article III judges have done
to conspire against appellant's rights from 2001 to present. But this court should be
clear that there is much more, including matters complained of in multiple criminal
referrals to U.S. DOJ, some of which were closely investigated over a long period
of time.
10
Certainly, the Judicial Council of the Fourth Circuit should conduct an
investigation into both what is going on in the U.S. District Court for the District of
Maryland and why the Maryland U.S. Attorney's Office has allowed matters to
reach the boiling point where a motion such as this arrives with much prior
warning on this court's doorstep?
8
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CERTIFICATE OF FILING AND SERVICE
I HEREBY CERTIFY that on the 13th day of January, 2014, the required
number of copies of Appellant's MOTION FOR THE CIRCUIT COURT TO
RECUSE AND TRANSFER were sent via U.S. Mail, postage prepaid, to the
CLERK, U.S. Court of Appeals for the Fourth Circuit, 1100 East Main Street,
Suite 501, Richmond, Virginia 23219; and to KATHLEEN O'CONNELL GAVIN,
Office of the United States Attorney, 36 S. Charles St., Fourth Floor, Baltimore,
MD 21201.
l1\i~-/~
..,
WILLIAM C. BOND
--~--~---------- ·--------------------~
9
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..
F-
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JA269

AT BALTIMORE
WILLIAM C. BOND,
Plaintiff,
Defendants.

ORDER
and Judgment Order already filed, see Doc. Nos. 22—23, the court
hereby DENIES Plaintiff’s Motion to Reopen Case and to File an
Amended Complaint. Consequently, the court also DENIES
Plaintiff’s request to vacate the court’s Memorandum Opinion and
Order and Judgment Order already filed. See Doc. Nos. 22—23.
The Clerk is directed to forward a copy of this Order to
counsel of record and Plaintiff, pro se.
IT IS SO ORDERED this 23rd day of May, 2017.
Enter:
David A. Faber
JA270
..
• Case 1:16-cv-02723-DAF Document 26 Filed 06/20/17 Page 1 of 2
2u:/,:._;~;
20 f,; fl:?'>~- L.
,, • '
IN THE UNITED STATES DISTRK::tGOURT .

FOR THE DISTRICT OF MAR'tLANi)lc'.~c',.:.
NORTHERN DIVISIQN~----DE ?:Jl'
WILLIAM C. BOND, *
Plaintiff pro se, *

V. Civil Action No.: 16-02723-DAF
*
*
Defendants.
*
* * * * * * * * *
PLAINTIFF'S SECOND {2nd) MOTION TO REOPEN CASE AND TO FILE A SECOND

(2 nd) AMENDED COMPLAINT
Comes now, plaintiff prose, William C. Bond, pursuant to Fed. R. Civ. P. 59(e) and/or Fed. R.
Civ. P. 60(b), and hereby files this second motion to reopen the case and to file a second
amended complaint. 1 For the reasons set forth in the memorandum in support filed
simultaneously herewith, plaintiff respectfully requests that the court's order of April 12,2017,
dismissing and closing the above captioned case be vacated, the case be reopened, and the
Second Amended Complaint attached hereto as Exhibit I be deemed filed.2
WHEREFORE, for the aforementioned reasons, plaintiff prays the court grants the requested
1
This motion is filed within the 28-day period allowed under FRCP 59 regarding the
court's denial of plaintiffs first motion to reopen and amend that was entered upon the docket at
number 25 on May 23, 2017.
2
A 'redlined' copy of the Second Amended Complaint showing the revisions to the
original Complaint per Local Rule I 03.6( c) is also attached hereto as Exhibit 2.
JA271
relief expeditiously. 3
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
I HEREBY CERTIFY that on the 20th day of June 2017, copies of PLAINTIFF'S SECOND
nd
(2nd) MOTION TO REOPEN CASE AND TO FILE A SECOND (2 ) AMENDED
COMPLAINT were served by Email to: ALLEN F. LOUCKS, AUSA, U.S. Attorney's Office,
District of Maryland, 36 S. Charles St., 4th FL, Baltimore, Maryland 21201,
allen.loucks@usdoj.gov; and to: MATTHEW P. PHELPS, AUSA, U.S. Attorney's Office,
District of Maryland, 36 S. Charles St., 4th Fl., Baltimore, Maryland 21201,
matthew.phelps@usdoj.gov; and by hand delivery to: CLERK, United States District Court for
the District of Maryland, Baltimore Division, 101 West Lombard Street, Baltimore, Maryland
21201. The required judge's courtesy copy was also served by FedEx Overnight Delivery,
postage prepaid, to: Hon. DAVID A. FABER, Senior United States District Judge, 2303
Elizabeth Kee Federal Building, 601 Federal Street, Bluefield, WV 24701.
WILLIAM C. BOND
3
Counsel for the defendants were consulted per Local Rule 103.6(d), but did not consent to
the relief sought herein.
2
JA272
"
'°'Q
... - ''I
LC"
r• •.,
•. •~ .. '- f,::II: 22
IN THE UNITED ST ATES DISTRICT COURT 1,,-1·r,~,r.1··,.-,... -
u__
, :·.. ·l
LM:..,i I 11~1·.L_
NORTHERN DIVISION GY..__ _ .C[ VU1Y
WILLIAM C. BOND, *
Plaintiff pro se, *

*
*
Defendants.
*
* * * * * * * * *
nd
MEMORANDUM IN SUPPORT OF PLAINTIFF'S SECOND (2 ) MOTION TO
nd
REOPEN CASE AND TO FILE A SECOND (2 ) AMENDED COMPLAINT
"Of course, the grant or denial of an opportunity to amend is

within the discretion of the District Court, but outright refusal to
grant the leave without any justifying reason appearing for the
denial is not an exercise of discretion; it is merely abuse of that
discretion and inconsistent with the spirit of the Federal Rules."
Foman v. Davis, 371 U.S. 178, 182, (1962).
I. INTRODUCTION
Count VI in the second amended complaint, which is far different from Count VI in the original
complaint, recounts some 16 years of litigation and wrongs suffered by plaintiff at the hands of
federal actors that have evaded substantive merits review throughout a tortuous listing of
proceedings.
Plaintiff has now - by now naming all five (5) known individual defendants by name - fully met
JA273
the standard to reopen a case and to file an amended complaint, the prose standard of analysis,
and the Igbal FRCP 12 standard, all of which he lists in this second memorandum in support of
his second motion to reopen.
This court must now do as the district court did at the beginning of this case: order the named
defendants served. And it is only right that any defense of this action comes from them, not the
court, and is based upon the merits.
II. FACTS
This court dismissed plaintiff's original complaint by memorandum opinion & order on April 12,
2017. (See docket entry number 22.) This memorandum opinion was bereft of any mention of
plaintiff's prose status, his filings at docket entry numbers 15, 18, & 21, which offered actual
evidence, nor any discussion of the standard of review a district court must conduct regarding
prose complaints. See, Erickson v. Pardus, 551 U.S. 89, 94 (2007). See also, Gordon v. Leeke,
574 F.2d 1147, 1173 (4 Cir. 1978). In addition, while the United States Court of Appeals for the
Fourth Circuit has a "strong policy that cases be decided on the merits" United States v. Shaffer
Equip. Co .. 11 F.3d 450,453 (4th Cir. 1993). this court terminated this case mid-stride and both
denied plaintiff the right to answer the defendants' FRCP 12 motion and his right under the rules
to file an amended complaint. Importantly. the court had no patience with plaintiff not naming
the proper defendants.
JA274
Plaintiff filed his first motion to reopen the case and to file a first amended complaint on May 9,
2017. This first amended complaint differed dramatically from the original complaint. First,
Counts JI, JV, & V, were deleted. Second, the individual government agents were identified and
named as defendants, while the "U.S. judge" defendants were left unnamed. Third, plaintiffs
first & second amendment claims were more properly pleaded. Finally, Counts I, III, & VI, were
extensively expanded with detailed explanation supported by sixteen exhibits. Nevertheless, on
the final day the served defendants had to respond, May 23, 2017, the court dismissed plaintiffs
first motion to amend with a brief order stating:
"For reasons expressed in the Memorandum Opinion and Order

and Judgment Order already filed, see Doc. Nos. 22-23, the court
hereby DENIES Plaintiff's Motion to Reopen Case and to File an
Amended Complaint." (See docket entry number 25.)1
As the only conceivable overlap between plaintiffs original and first amended complaints was
the fact that plaintiff had still not named all the known defendants as named parties, plaintiff now
brings this second motion to reopen the case and to file a second amended complaint in which he
now adds the individual U.S. judges acting in their individual capacities and also further expands
upon his first amendment damages.
A. The Standard of Review to File an Amended Complaint after a Final .Judgment
1
Importantly, this order came without prejudice.
3
JA275
Recently, Maryland U.S. District Judge James K. Bredar stated the standard of review for cases
such as this: 2
In order to grant a motion to amend a complaint in a case in which

it previously entered a final judgment, a court must first vacate said
judgment according to Rule 59(e) or Rule 60(b) of the Federal
Rules of Civil Procedure. Laber v. Harvey, 438 F.3d 404, 427 (4th
Cir. 2006). However, in such a case, the district court need not
focus on the legal standards applicable to those rules, but "need
only ask whether the amendment should be granted, just as it
would on a prejudgment motion to amend pursuant to Fed. R. Civ.
P. 15(a)." Katy le v. Penn Nat. Gaming, Inc., 637 F.3d 462, 471
(4th Cir. 2011). Accordingly, a party may amend its complaint
only if doing so avoids "prejudice, bad faith, [and] futility." Id.
"Futility is apparent if the proposed amended complaint fails to
state a claim under the applicable rules and accompanying
standards." Id.
A complaint must contain "sufficient factual matter, accepted as

true, to 'state a claim to relief that is plausible on its face."'
Ashcroft v. Igbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic
Corp. v. Twombly, 550 U.S. 544,570 (2007)). Facial plausibility
exists "when the plaintiff pleads factual content that allows the
court to draw the reasonable inference that the defendant is liable
for the misconduct alleged." Igbal, 556 U.S. at 678. An inference
of a mere possibility of misconduct is not sufficient to support a
plausible claim. Id. at 679. As the Twombly opinion stated,
"Factual allegations must be enough to raise a right to relief above
the speculative level." 550 U.S. at 555. "A pleading that offers
'labels and conclusions' or 'a formulaic recitation of the elements
of a cause of action will not do.' ... Nor does a complaint suffice
if it tenders 'naked assertion[ s]' devoid of 'further factual
enhancement."' Igbal, 556 U.S. at 678 (quoting Twombly. 550
U.S. at 555, 557). Although when considering a motion to dismiss
a court must accept as true all factual allegations in the complaint,
this principle does not apply to legal conclusions couched as
factual allegations. Twombly. 550 U.S. at 555.
2
Please see: case no.: I: 16-cv-00749-JKB (D. Md.) at docket entry no.: 27.
4
JA276
B. The Standard of Review for a District Court Denying Leave to Amend
Rule 15(a) declares that leave to amend 'shall be freely given when
justice so requires'; this mandate is to be heeded. See generally, 3
Moore, Federal Practice (2d ed. 1948), 15.08, 15.10. If the
underlying facts or circumstances relied upon by a plaintiff may be
a proper subject of relief, he ought to be afforded an opportunity to
test his claim on the merits. In the absence of any apparent or
declared reason-such as undue delay, bad faith or dilatory motive
on the part of the movant, repeated failure to cure deficiencies by
amendments previously allowed, undue prejudice to the opposing
party by virtue of allowance of the amendment, futility of
amendment, etc.-the leave sought should, as the rules require, be
'freely given.' Of course, the grant or denial of an opportunity to
amend is within the discretion of the District Court, but outright
refusal to grant the leave without any justifying reason
appearing for the denial is not an exercise of discretion; it is
merely abuse of that discretion and inconsistent with the spirit
of the Federal Rules. Foman v. Davis, 371 U.S. 178, 182, (1962).
th
See, Edwards v. City of Goldsboro, 178 F. 3d 231 (4 Cir. 1999).
See also, Scott v. Family Dollar Stores, Inc., 733 F.3d 105 (4th Cir.
2013).
IV. ANALYSIS
A. What did the Court's First Memorandum Opinion & Order (docket number 22) say?
1. The primary reason the court gave in their original opinion and order, which took up
the first fifteen pages of the opinion, was that plaintiff had not named the proper parties
as defendants, and thus had not satisfied FRCP 12(b)(l) & (6) and FRCP 8(a)(2). (See
docket number 22, pages 1-15.)
.
2. Next, the court claimed plaintiff had not properly pleaded a first amendment violation
because he had not made "sufficient showing of 'self-censorship, which occurs when a
JA277
claimant is chilled from exercising h[is] right to free expression."' Cooksey v. Futrell,
721 F.3d 226, 235 (4th Cir. 2013) (citations omitted)." (See docket entry number 22 at
page 15.)
3. Most troubling to plaintiff, the court accepted as fact the defendants' proffer, which
was unsupported by the complaint, that plaintiff was threatening governmental officials,
rather than vice-versa. To wit: "Plaintiff does not seriously contest that the reason for the
interviews was concern about the safety of federal judges and other government officials
due to Plaintiffs communications with them." (See docket entry number 22 at page 16-
17.)
4. Then the court concluded, 'There is no allegation whatsoever that any of the named
Defendants did anything at all to restrict Plaintiff's First Amendment rights." (See docket
entry number 22 at page 17.)
5. The court conducted zero analysis in its memorandum opinion regarding plaintiff's
second amendment claims.
6. Regarding allegations of due process violations, the court again accepted outside of the
record proffers from the defendants in ruling upon Count I of plaintiff's original
complaint. "Here it is more likely that Defendants visited Plaintiff and/or sought to arrest
him because of bona fide and perfectly lawful concerns about illegal conduct on
JA278
Plaintiffs part, rather than any retaliation Defendants wanted to inflict on Plaintiff." (See
docket entry number 22 at page 21.)
7. Finally, the court had this to say about the original complaint's Count VI due process
& conspiracy allegations: "Plaintiff alleges that 'a federal judge [acted] with malice
aforethought to have a 2001 federal case assigned to him, which he planned, in advance,
to sabotage.' Doc. No. I. Two other federal judges are alleged to have helped in covering
this up. Id." And, in closing, the court added, "Plaintiff does not assert a cognizable legal
right this alleged conspiracy actually violates." (See docket entry number 22 at pages 24-
25.)
B. What did the Court's Second Order (docket number 25) say?
All the court added to their second order in this case denying plaintiffs first amended complaint
was that they were dismissing it for the exact same reasons that the original complaint was
dismissed, i.e., "For reasons expressed in the Memorandum Opinion and Order and Judgment
Order already filed ... " (See docket entry number 25.)
C. How did the First Amended Complaint Differ from the Original Complaint?
As recounted above in this memorandum at part II, the first amended complaint differed
dramatically from the original complaint. First, Counts II, IV, & V, were deleted. Second, the
individual government agents were identified and named as defendants, while the "U.S. judge"
defendants were left unnamed. Third, plaintiffs first & second amendment claims were more
JA279
properly pleaded. Finally, Counts I, Ill, & VI, were extensively expanded with detailed
explanation supported by sixteen exhibits.
D. How does the Second Amended Complaint Differ from the First Amended Complaint &
the Original Complaint?
In addition to what was just described above, the second amended complaint now adds the names
of three (3) Maryland U.S. judges. The second amended complaint also further enhances
35, 36, & 122.

plaintiffs first amendment damages pleading at '1['1[
For example, at i! 35, plaintiff discusses his 'self-censorship' because of the government agents'
visits and threats: "This worry and distraction chilled and curtailed the robustness of plaintiffs
first amendment activity~ as one would expect following visits from interrogating law
enforcement personnel asking, 'What will it take to get you to shut up?'"
The second amended complaint also emphasizes the significance of the government agents'
second visit to plaintiffs then-home on July 30, 2013, which no reasonable person would think
was for any other purpose than to intimidate plaintiff, and which also went far beyond satisfying
the government agents' 'purported' concerns that plaintiff was a cause of worry to any
government employee.
V.ARGUMENT
Clearly, the court violated clear U.S. Supreme Court and U.S. Fourth Circuit precedents by
dismissing plaintiffs first amended complaint, which differed dramatically from the original
JA280
complaint, as described above, without any meaningful comment or explanation, and whose
reasons would not be obvious upon the face of the proposed amended filing.
A. The Proposed Second Amended Complaint is Not Prejudicial or in Bad Faith
With respect to prejudice, it is well settled that where the defendants are fully aware of the nature
of the action or the events giving rise to the action from the very outset of the litigation, an
amendment to the claim does not create prejudice. Davis v. Piper Aircraft Corp., 615 F.2d 606,
613 (4th Cir. 1980) ("Because defendant was from the outset made fully aware of the events
giving rise to the action, an allowance of the amendment could not in any way prejudice the
preparation of the defendant's case."). Here, there is no unfair surprise which would result in
prejudice for the defendants.
First, the substitution of defendants offers no surprise or prejudice as Fed. R. Civ. P.
15(c)(l)(C)(i) & (ii) and 15(c)(2) are satisfied. 3 The second amended complaint presents
identical claims as the original complaint, albeit Counts IV & V have been eliminated as
unnecessary and Count II has been eliminated because, at this time, plaintiff cannot prove the
identities of the subject actors due to his limited resources and abilities. The second amended
complaint does not add new claims, expand the scope of the claims, 4 present new legal bases for
recovery, or pursue new legal remedies from the defendants. Rather, the proposed amendment is
3
As the district court, itself, made the decision not to order service upon the "unnamed
judges" representative should offer no surprise or prejudice as clearly, they were on notice of the
complaint, and, in fact, received courtesy copies of same. Further, said officers are subject to
FRCP 15(c)(2). (See also, docket entry number 6.)
4
Count I clearly implied Second Amendment violations in the original complaint.
9
JA281
designed solely to supplement and bolster the factual allegations regarding the three remaining
causes of action to specifically address the deficiencies identified by the court in its controlling
memorandum. Further, the new facts (and the relevance thereof) have been known to the
defendants for some time, mostly because they committed them first-hand, and/or were raised in
other legal or complaint-style venues over the course of this long-running litigation. Thus, the
defendants cannot argue unfair surprise with respect to the new allegations in the amended
complaint.
Moreover, there has not been any undue delay to prejudice defendants. This case is still in its
infancy; the only substantive actions thus far have been the filing of the original complaint and
the filing and ruling upon the defendants' motion to dismiss without the benefit of plaintiffs
opposition. Similarly, the court also dismissed plaintiffs proposed first amended complaint
without any opposition by the defendants and any substantive explanation by the court. The
parties have not engaged in any discovery or taken any other steps beyond the pleadings stage.
Likewise, plaintiffhas acted promptly since the court's controlling order of April 12, 2017.
Plaintiff promptly reviewed, investigated further, and confirmed his factual and legal bases for
bringing this case and promptly filed his first motion to amend, all within the 28 days allowed
under FRCP 59. Again, plaintiff has filed this present second motion to amend within the 28
days allowed under FRCP 59 from the court's second order on May 23,2017. Thus, there has
been no delay in seeking leave to amend prejudicing the defendants. In this same regard, plaintiff
has not acted in bad faith. The matter was not delayed, plaintiff has acted diligently in pursuing
the amendments, and the claims find adequate basis in both fact and law.
10
JA282
B. The Proposed Amendment is Not Futile
Plaintiffs second request for leave to amend to bolster the factual and legal bases for his three
remaining claims is not futile and, therefore, should be permitted. The court, clearly, in their
controlling memorandum found plaintiff had not sued the proper parties, had made conclusory
allegations that were not factually supported, that his law was suspect, and his damages unclear.
In the second amended complaint, plaintiff adds extensive factual allegations to support all three
of his remaining Counts. First, plaintiff names two U.S. government law-enforcers and three
U.S. judges who he alleges violated his constitutional rights. Plaintiff then goes on to offer
specific factual allegations that are both plausible and true. Plaintiff also discusses the damages
rendered by his alleged constitutional violations by the defendants. Finally, plaintiff explains the
connection and motive of the "judicial" defendants to the constitutional violations against him.
As the foregoing discussion demonstrates, the second amended complaint addresses the
deficiencies in the original complaint. Accordingly, granting the amendment would not be futile.
To the extent the defendants would argue otherwise, that argument would be properly addressed
by a separate motion to dismiss with full briefing by the parties. For the purposes of the
amendment analysis, it is clear that the standard has been satisfied and plaintiff should be granted
leave to amend.
VI. CONCLUSION
11
JA283
The court appeared nonplused and hostile to plaintiff's Count VI allegations in its controlling
memorandum. (See docket entry number 22.) These allegations - greatly expanded in the first &
now second proposed amended complaints - include obstruction of justice, fraud upon the court,
grave due process violations, the figurative and literal stamping of plaintiff by the judicial
defendants with a "Bill of Attainder" upon his head, and the unlawful long-term seizing and
keeping of plaintiff's property without his permission.
It is worth repeating the court's earlier words regarding Count VI:
"Plaintiff does not assert a cognizable legal right this alleged

conspiracy actually violates." (See docket entry number 22 at
pages 24-25.)
Yet, in plaintiff's proposed first amended complaint, plaintiff clearly answered in extensive
detail to the court's above challenge. And it is irrelevant whether the court undertakes a
copyright or a chattel analysis regarding plaintiff's property that has been stolen and wrongly
kept from him because the simple fact is plaintiff does not to this day, some 16 years after the
fact, hold and control his own property. Therefore, the court's idea that there is not a continuing
tort harming plaintiff concerning his property - and all that has been done to keep it from him -
is simply factually and legally untrue. In short, converted property can never transfer title when
the subject title has been contested and never waived. See,~, Republic of Austria v. Altmann,
541 U.S. 677 (2004).
12
JA284
Clearly, Count VI in the second amended complaint recounts some 16 years of litigation and
wrongs suffered by plaintiff at the hands of federal actors that have evaded substantive merits
review throughout a tortuous listing of proceedings.
This court must now do as the district court did at the beginning of this case: order the named
defendants served. And it is only right that any defense of this action comes from them, not the
court, and is based upon the merits.
Should this court remain somehow still dissatisfied with plaintiff's second amended complaint,
plaintiff is entitled to detailed reasons as to why and proffers that he is also entitled to a final
opportunity for leave to amend to attempt to cure any identified deficiencies.
For the foregoing reasons, plaintiff respectfully requests that the court reopen this case and
accept plaintiff's Second Amended Complaint as filed.
WILLIAM C. BOND
Pro Se
P.O. Box 4823
Baltimore, Maryland 2121 I
(443) 970-2887
13
JA285
I HEREBY CERTIFY that on the 20th day of June 2017, copies of plaintiffs
MEMORANDUM IN SUPPORT OF PLAINTIFF'S SECOND (2 nd) MOTION TO
REOPEN CASE AND TO FILE A SECOND (2nd) AMENDED COMPLAINT were served
by Email to: ALLEN F. LOUCKS, AUSA, U.S. Attorney's Office, District of Maryland, 36 S.
Charles St., 4 th Fl., Baltimore, Maryland 21201, allen.loucks@usdoj.gov; and to: MATTHEW
P. PHELPS, AUSA, U.S. Attorney's Office, District ofMaryland, 36 S. Charles St., 4 th Fl.,
Baltimore, Maryland 21201, matthew.phelps@usdoj.gov; and by hand delivery to: CLERK,
United States District Court for the District of Maryland, Baltimore Division, 101 West Lombard
Street, Baltimore, Maryland 2120 I. The required judge's courtesy copy was also served by
FedEx Overnight Delivery, postage prepaid, to: Hon. DAVID A. FABER, Senior United States
District Judge, 2303 Elizabeth Kee Federal Building, 601 Federal Street, Bluefield, WV 24701.
WILLIAM C. BOND
14
JA286
;
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WILLIAM C. BOND
P.O. Box 4823 *
*
Plaintiff pro se,
* Civil Action No.: I 6-02723-DAF
V.
ROBERT MARK FREDERICK

and
PATRICK S. DUGAN
Supervisory Special Agent
and
The Hon. MARVIN J. GARBIS

and
The Hon. J. FREDERICK MOTZ

JA287
and
The Hon. PAUL V. NIEMEYER

United States Circuit Judge
910 United States Courthouse
*
Defendants.
*
* * * * * * * * *
SECOND AMENDED COMPLAINT WITH DEMAND FOR ,JURY TRIAL
Comes now plaintiff prose, William C. Bond, (hereinafter "Plaintiff') and brings this lawsuit
against Deputy United States Marshal for the District of Maryland Robert Mark Frederick;
Supervisory Special Agent of the United States Federal Bureau of Investigation for the District
of Maryland Patrick S. Dugan; and Senior United States District Judge Marvin J. Garbis and
Senior United States District Judge J. Frederick Motz, both of the United States District Court
for the District of Maryland; and United States Circuit Judge Paul V. Niemeyer of the United
States Court of Appeals for the Fourth Circuit; all acting in their 'individual capacities'
(hereinafter "Defendants").
misuse of the U.S. Marshals Service and the FBI, acting at the direction of three Maryland
Article III judges outside the scope of their authority and immunity, to violate plaintiff's
constitutional rights, including his First Amendment, Second Amendment, & due process rights
JA288
- all to cover up judicial misconduct, obstruction of justice, and systemic 'fraud upon the court'
perpetrated against plaintiff by the defendants.
the First Amendment, the Second Amendment, & due process clauses of the U.S. Constitution,
and any other laws, rules, or applicable parts of the constitution.
,JURISDICTION AND VENUE
INTRODUCTION
This action concerns a long-term dispute over a valuable item of personal property, a literary
manuscript of high monetary and artistic value, which was taken and kept from plaintiff for no
legitimate reason.
FACTS
1. Plaintiff has been involved in significant Maryland federal court litigation, both through
counsel and prose, since 2001. Plaintiff has lost motions and cases in ways that not only seemed
1
unfair, but unconstitutional.
1
Plaintiffs litigation history is summarized in Count VI.
3
JA289
2. Having had enough of the judicial imperturbability shown toward plaintiffs allegations
regarding the deprivation of his constitutional rights, plaintiff then decided to publicly protest
what he saw as 'provable corruption' in the Baltimore U.S. Courthouse at the courthouse itself.
Corruption Wire.'
4. This campaign was supported by several social media platforms.
2
summer and fall 2013 to much notice. The first ads appeared on July 17, 2013.
7. Plaintiff also wrote an Op-Ed for The Baltimore Sun detailing what had recently transpired in
the "Bromwell" public corruption case titled "CORRUPTION Sub Curia." When the Op-Ed was
rejected over length concerns by The Sun's editors, plaintiff then made the Op-Ed the center of
2
Please see: Exhibit nos.: I & 2. The ads can also be seen here: (I)
htlps://www.scribd.com/doc/296483607/Corruption-Wire-web-ad & (2)
https://www.scribd.com/doc/296483897 /Corruption-Wire-print-ad
4
JA290
his anti-federal-court-corruption activities. The Op-Ed explains the background for plaintiffs
First Amendment objections as to what he saw going on at the Baltimore U.S. Courthouse. 3
U.S. Courthouse.
COUNTI
11. During the July 19, 2013, meeting, the federal agents wished to come inside plaintiffs
12. The agents followed plaintiff to this 'common room' and acted, on guard, as if plaintiff were
a physical threat to them.
13. The DUSM, whose name was Robert Mark Frederick, voiced several times how much he had
3
https:/ /www.scribd.com/doc/ 136418039/W ill iam-Bond-CORR UPTI ON-S ub-Curia-op-ed
5
JA291
14. The FBI agent, whose name was Special Agent Chris Wood, who led the questioning,
used to babysit for plaintiffs stepchildren.
15. Plaintiff was alarmed by the agents' line of questioning because he had never physically
threatened any government officials or federal judges in any way. Plaintiff made it clear his only
goal was to have certain judges judicially reprimanded and/or sanctioned, and for his stolen
property and resultant damages in a long-running case returned to him.
I 6. FBI Special Agent Wood asked repeatedly what could be done to make the scheduled
17. The next day, on July 20, 2013, plaintiff memorialized this meeting in writing and put the
Maryland U.S. Attorney's Office, including several of their top officers, on direct notice that
these alleged concerns by government law-enforcers over nonexistent and never explained
'threats' allegedly attributed to plaintiff were fabricated by the government and had no basis in
fact. 4
4
Please see: Exhibit no. 4, plaintiffs July 20, 2013, email to the USAO MD with noted
sections highlighted for the court's convenience and email addresses redacted. The court should
also note that while this communication is somewhat rambling because plaintiff was very angry
about what had just been done to him by the government, it clearly shows plaintiffs state of
mind at the exact time in question, and that his injuries were real.
6
JA292
18. The second knock on your door from government law-enforcers provokes fear. Why are they
back?
saw: Standing directly across from him was the same DUSM from the first visit, Robert Mark
Service's Protective Intelligence Unit (hereinafter "USMS PilJ''). To plaintiff's direct right, in a
whom plaintiff would later learn was the FBI's Supervisory Special Agent in charge of the
21. The federal agents demanded plaintiff's firearms, which plaintiff denied having.
22. The federal agents again requested to come inside plaintiff's then-apartment, which plaintiff
JA293
plaintiff.
24. Again, plaintiff was followed to the 'common room' and treated again as ifhe were a
physical threat.
any government officials or federal judges in any danger from plaintiff? Plaintiffs answers were
repeatedly "no" and "no."
26. Where were plaintiffs guns? Where were plaintiffs guns? Many times, it was asked.
Plaintiff even had to stand up, raise his shirt, and turn around to show the agents that he had no
handguns on his person.
27. As plaintiffs firearms were confiscated in 2001, as described in detail in Count VI, by the
State of Maryland in a criminal action (charges dismissed, record expunged), plaintiff proffered
that they should know where the guns were. Yet, the agents claimed the state gun database still
showed plaintiff owning firearms. Plaintiff told the agents that all his former guns were either
with his ex-wife or umeturned by the State of Maryland.
JA294
28. Again, as FBI Special Agent Wood had earlier asked, FBI Supervisory Special Agent Dugan
asked-holding some of plaintiffs 'White Guerrilla Family' promotional literature in his hand-
"What would it take to make this [the planned demonstrations] go away?"
29. Plaintiff proffered to Agent Dugan that the United States Attorney was the one who should
5
be asking that question and that plaintiff was happy to meet with him re: same.
30. The FBI agent didn't like that answer, and stated that he was sent here and had to
immediately report back - to whom, he would not say. 6 At that point, many of the same issues
discussed in Count VI were discussed with a focus on what the government could offer as a
resolution of plaintiffs greater complaints regarding the underlying long-running litigation.
Agent Dugan didn't fully understand the back story of the long-running litigation and how the
"Bromwell" public corruption case fit into the picture. DUSM Frederick calmly explained to
Agent Dugan that the "Bromwell" case was like a "domino," and that if plaintiff was able to be
victorious in that action, it would create a "domino-effect" and thus cause plaintiff to run the
table and win all his long-running litigations very quickly.
5
FBI, USMS, & the USAO MD, to be held, as a courtesy, in a major law firm's conference room.
6
On information and belief, "Judge Motz" was independently operating & controlling the
government agents outside of the normal 'chain-of-command.'
9
JA295
[handcuffs] on his wrists and take him straight to Central Booking [Baltimore City Jail]."
32. The USMS PlU manuals specifically speak about the unit being prohibited from using their
7
resources to violate the First Amendment rights of citizens.
33. Yet, the timing of these visits, especially the attempt to arrest plaintiff for illegal weapons
possession, was intended with one goal and one goal only in mind: to prevent and/or intimidate
plaintiffs planned demonstrations at the Baltimore U.S. Courthouse on August 4, 2013.
34. Clearly, as alleged later in this complaint, the government was surveilling plaintiff since
his supposed actions?
35. Clearly, as well, it is simply implausible to say that after three years of surveillance, now, just
two (2) days after plaintiffs first City Paper ads - ads which received much notice in Baltimore
- the law enforcers suddenly found exigent reasons to attempt to intimidate and influence
plaintiffs First Amendment rights. For example, because of this first visit by the law-enforcers,
plaintiff was forced to consult a criminal defense lawyer, other lawyers and business people,
numerous friends, to worry and lose much sleep, and to be greatly distracted when he was on an
7
Please see: Exhibit no.: 5, the USMS Policy Directives, Judicial Security, 10.7
Protective Investigations at D. 7. (See, Page 2.)
10
JA296
I •
abbreviated time line and had much still to do to organize the August 4, 2013, protests, amongst
many other things. This worry and distraction chilled and curtailed the robustness of plaintiffs
first amendment activity - as one would expect following visits from interrogating law
enforcement personnel asking 'What will it take to get you to shut up?'
demonstrations was out of fear for the safety of government officials or federal judges - as those
manufactured fears had already been allayed by their first visit and plaintiffs letter to the USAO
MD - and that this second act was not anything but another effort to stop plaintiffs planned
demonstrations and to violate his First Amendment rights. Otherwise, why bring up detailed talk
of 'settlement'? This second visit caused plaintiff the same injuries and curtailed speech as just
recounted above, only they were exacerbated, as plaintiff now only had five (5) days left before
his first protest at the Baltimore U.S. Courthouse.
37. But, there is another reason to believe the government agents acted unconstitutionally: In
2013, plaintiff was legally allowed, both by state and federal law, to possess firearms. 8
38. The reason for this was Congress, since at least 2007, had ceded restoration of certain
firearms rights to participating states, Maryland being one of them, via the NICS Improvement
8
Please see: Exhibit nos.: 6, 7, & 8, plaintiffs 2001 physician's certificate and the 2013
Maryland law.
11
JA297
Amendments Act of 2007. See, Tyler v. Hillsdale Cty. Sheriff's Dep't, 837 F.3d 678 (6th Cir.
2016) (en banc). 9
39. Further, the Maryland United States Attorney's Office knew that plaintiff was not in
violation of any firearms laws, as plaintiff's former Maryland criminal defense lawyer - again,
plaintiff's litigation history is discussed in more detail in Count VI - had discussed plaintiff's
firearms qualifications with Barbara S. Sale, the USAO MD's Chief, Criminal Division, in 2006-
2007.
firearms since at least 2006-7, but they actually tried to do exactly that on July 30, 2013, both in
violation of plaintiff's Second Amendment rights, and to misuse the law to violate plaintiff's
41. After the July 30, 2013, threats, DUSM Frederick continued the threats by seeking
information from plaintiff's ex-wife to arrest plaintiff sometime before the August 4, 2013,
9
Please see: Exhibit no.: 9, the subject Tyler opinion, page 4, which can also be viewed
here: http://www.opn.ca6.uscourts.gov/opinions.pdf/l 6a0?34p-06.pdf
12
JA298
damages.
[ COUNTS II, IV, & V from the original Complaint are deleted from this Second Amended
Complaint.]
COUNT III
45. During these protests, plaintiff was always supervised by the DUSM PIU agent and often by
Federal Protection Service officers, sometimes in full SWAT gear.
46. Naturally, the DUSM agent and plaintiff became acquainted, especially as DUSM Frederick
had claimed he had long-wanted to meet plaintiff.
47. DUSM Frederick continued to probe plaintiff regarding his alleged possession of illegal guns
and wondered if plaintiff had any guns "buried." At one protest in early fall 2013, DUSM
Frederick told plaintiff about a conversation he had just had with Agent Dugan. Agent Dugan
had "asked [him] if we need to have the [FBI] SWAT Team come and arrest Bill [plaintift]?" He
13
JA299
then recited more of the conversation he had with Agent Dugan as to whether plaintiff "would
survive a night in Central Booking [Baltimore City Jail]?"
48. Yet soon, DUSM Frederick came to see that plaintiff was no "sociopath" as he insinuated the
U.S. DOJ profilers had attempted to "mark" him, but was instead, in his words, a "lover," not a
"fighter," who just wanted to "go back to the country club," which was how DUSM Frederick -
a big football fan - saw former tennis players such as plaintiff.
49. Plaintiff and DUSM Frederick spent much time chatting at the Baltimore U.S. Courthouse
during plaintiffs demonstrations. IO
11
51. Several times DUSM Frederick explained that the reason he had always wanted to meet
plaintiff was because of his particular letter writing abilities, letters which acted as 'prosecutions'
of certain judges and other government officials' reputations. Apparently, plaintiff had really
gotten under the skin of certain judges and officials.
IO The DUSM was convinced (as the government's 'expert' on plaintiff) that plaintiff was
in the "right" and that he had "gotten f"*ked-over by the 'judges,"' which was a statement he
made many times.
11
This information became a qui tam lawsuit. Please see: 15-cv-00199-DAF (D. Md.).
14
JA300
been surveilling plaintiff since 20 I 0.
53. This revelation surprised plaintiff very much, as plaintiff had wondered many times how the
government always seemed to be one step ahead in many parts of his continuing litigations.
the government. And it is implausible to say that plaintiff must plead specifics on this allegation
that they then used against him in the continuing litigations. In short, the spying upon plaintiff, if
used in litigation, as opposed to legitimate law enforcement purposes, is a gross constitutional
attorneys are required to follow. That no government attorney ever notified any federal judge
supervising federal litigations before them of this issue, either ex parte or under seal, shows
56. Further, because of this admitted governmental surveillance of plaintiff, plaintiff was forced
to limit and curtail the freedom of his expression to others via the telephone, the internet, and by
15
JA301
damages.
COUNT VI
59. Plaintiff is the author of the unpublished fictionalized copyrighted manuscript titled Self-
Portrait of a Patricide.
60. In the spring of 2001, plaintiff discovered that a copy - one of only two in known existence -
of his manuscript had been stolen from the law offices of his deceased attorney by actors in a
child custody proceeding in Baltimore City, Maryland.
61. The custody case pitted plaintiff's ex-wife's ex-husband and her father (hereinafter the
"custody case opponents") against plaintiff's ex-wife and him.
62. These custody case opponents had earlier been investigated, indicted, and prosecuted by the
and fines.
16
JA302
63. In the late spring of 2001, plaintiff discovered that a handgun had been stolen from a locked
Police Department.
64. On May 25, 2001, plaintiffs and his ex-wife's home was raided by a Maryland State Police
SWAT team and plaintiff was charged with illegal handgun possession. Plaintiff spent one night
in Central Booking, Baltimore's notorious & very dangerous jail.
65. The basis of the charges was that plaintiff had spent more than 30 days in a mental health
66. Plaintiff immediately retained the "dean" of the Maryland criminal defense bar, one Richard
M. Karceski, Esq.
67. The first thing Karceski did was to call plaintiffs former Ohio attorney named Gerald A.
Messerman. Messerman had always told plaintiff that his juvenile record would be expunged at a
certain date and then later wrote plaintiff a formal letter stating that his juvenile record was
expunged. Nevertheless, the State of Maryland was using plaintiffs Ohio juvenile record to
17
JA303
prosecute him and Karceski asked Messerman how that was possible if the subject record was
12
expunged?
68. Turned out plaintiffs juvenile record - despite the Messerman letter to the contrary - was
never expunged.
sentence for a misdemeanor, and was not even hiding the fact that they were trying to re-punish
plaintiff for his juvenile act, according to the Maryland Assistant Attorney General who was
70. Both the custody case opponents and the State of Maryland then sought to use plaintiffs
stolen manuscript in their respective cases - to rip plaintiffs ex-wife's children from her custody
and to imprison plaintiff for IO years.
71. Plaintiff hired a top First Amendment lawyer who then filed a copyright action to gain the
return of the manuscript, all copies made, and to prevent its further unauthorized use, in the U.S.
District Court for the District of Maryland on August 29, 2001. This case was assigned to U.S.
District Judge Marvin J. Garbis.
12
Please see: Exhibit nos.: IO & 11, Gerald A. Messerman, Esq., 1986 & 1994 letters to
plaintiff.
18
JA304
72. Karceski had many conversations in 2001 & 2002 with Messerman. The book was a big
subject, especially as Messerman had read an earlier draft in the early l 990's. Messerman knew
in the late spring and early summer of 2001 that the copyright case was coming. When it was
filed, Messerman asked Karceski who the judge was? Karceski told him it was Judge Garbis.
Messerman then told Karceski that he knew Judge Garbis, but did not say why or how.
73. Importantly, Messerman knew at this time that he was subject to a malpractice action based
upon his false representation to plaintiff that his juvenile record was expunged, a false
representation that had actually gotten plaintiff charged with a crime. In speaking with Karceski,
Messerman acted more like a prosecutor toward plaintiff and defended himself that there was no
malpractice if plaintiff was convicted of the handgun charges due to the vagaries of malpractice
liability. Messerman was also very worried about his high-profile and spotless reputation, as he
claimed to have never been sued before for malpractice.
74. Despite the clear error, Messerman adamantly refused to come to Maryland and testify
75. On November 20, 2001, Judge Garbis held a TRO hearing in the copyright case. Information
-for the first time - was introduced into the court record regarding Messerman's contacts in the
late l 980's with one of the copyright case defendants.
19
JA305
76. Ruling from the bench, and after making a very brief reference to knowing Messerman and
complimenting his legal acumen, Judge Garbis refused to order the return - ever - of any or all
copies of plaintiffs property and ordered plaintiff to pay the individual defendants' legal fees. In
essence, Judge Garbis ordered plaintiff to pay the thieves for their efforts expended to steal his
property.
77. Soon after this order, plaintiff flew to Cleveland, Ohio for an unpleasant meeting with
Messerman. At this meeting, Messerman told plaintiff that Judge Garbis and he were graduate
school classmates in 1961 at an exclusive 8-member program run by Georgetown University
Law School called the E. Barrett Prettyman Fellowship. When accepted at this program, the
graduate law students all lived together in a Washington, D.C., row home under the supervision
of a professor who also directed them in providing legal defense for low-income city residents.
In short, Judge Garbis and Messerman were housemates in post-graduate law school. Later, they
would visit each other both in Ohio and, on information and belief, when Judge Garbis held a bat
mitzvah for one of his daughters in Maryland, amongst other contacts.
78. The criminal case against plaintiff (See again 'l['l[65-66 above) was dismissed by Baltimore
City Circuit Court Judge John C. Themelis, after almost one year of intense litigation, on April
22, 2002, based upon the expert opinion of noted Maryland forensic psychiatrist Michael K.
Spodak who provided a 'certificate' to the court, required under Maryland law, testifying as to
13
plaintiffs 'capability' to possess firearms at all times in question.
13
20
JA306
79. On January 24, 2003, the U.S. Fourth Circuit issued a published opinion in the appealed
copyright case. Writing for the court, U.S. Circuit Judge Paul V. Niemeyer stated that Judge
Garbis had not gone far enough and ordered that the law firm defendants, who were self-
represented, could now seek attorneys' fees from plaintiff. Judge Niemeyer also suggested that
the remedy to the conversion of plaintiff's copyrighted property lay in a state action despite
80. On remand, Judge Garbis awarded the full set of copyright actors more than $181,000 in
attorneys' fees.
81. Soon after, Judge Garbis' recusal was sought. Judge Garbis responded with an order denying
· pertment
th at request, an d state d , m · part: 14
"When assigned this instant case in August of 200 I, I noted that

Plaintiff's criminal counsel in Cleveland had been Mr. Messerman.
added.) [Judge Garbis Memorandum and Order, April 23, 2003.]
It is clear from this statement, as plaintiff's copyright action was filed on August 29, 2001, and
made no mention of Messerman, that Messerman was having secret, clandestine conversations
14
Please see: Exhibit no.: 12, Judge Garbis Memorandum & Order re: Recusal at docket
entry no.: 108 in case no.: I :0l-cv-02600-MJG (D. Md.). The court should also note how Judge
Garbis substituted the word "criminal" for ''.juvenile."
21
JA307
82. Plaintiff then sued all the copyright actors, Messerman, and others, in three different
Maryland state actions that lasted from 2003 until 2006. All of these state actions were
dismissed, except for one settlement, with both trial and state appellate courts relying almost
wholly upon the federal rulings of Judges Garbis & Niemeyer.
83. Later, in 2008, plaintiff met with a very prominent Baltimore lawyer in his/her office. (This
person's identity is being withheld at this time to protect him/her from unnecessary exposure to
retaliation.)
84. This lawyer knew Judge Garbis very well.
85. Sometime in 2004-2006, the prominent Baltimore lawyer spoke to Judge Garbis about
plaintiff. During this conversation, Judge Garbis made many highly disparaging remarks about
plaintiff. These remarks surprised the prominent Baltimore lawyer because, familiar with
86. Judge Garbis told the prominent Baltimore lawyer that plaintiff was a "very bad man," that
"plaintiff was very dangerous," that "[the prominent Baltimore lawyer] should stay away from
[plaintifl]," and many other things that all showed pervasive bias toward plaintiff. The prominent
lawyer told plaintiff that Judge Garbis had actual "bias" against him. The prominent lawyer also
suggested that, if plaintiff could not correct what Judge Garbis had done to him in the copyright
22
JA308
case, that plaintiff should hold "public protests" at the U.S. courthouse against Judge Garbis,
2013.
87. The Maryland mental health facility where plaintiff was sent in 1981 by an Ohio juvenile
court was also sued in Maryland state court for handing out plaintiffs complete medical &
Office, who, as already stated, was prosecuting the criminal case relating to plaintiffs firearms.
88. Sometime between 2003-2005, the lawyer representing The Sheppard and Enoch Pratt
Hospital, Daniel J. Moore, told plaintiffs lawyers in that case that a board member, who was
also a lawyer, was "adamantly outraged" that plaintiff had sued the hospital and had ordered Mr.
claimed violations were of federally protected records. These statements were allegedly made in
front of other board members and/or witnesses.
89. On information and belief, that lawyer was also a U.S. District Judge named J. Frederick
Motz. Judge Motz, and his father before him, were very long-term Board of Trustees members &
15
chairs of the hospital and took a very personal and protective interest in the institution.
15
23
JA309
90. During discovery in the three state lawsuits, plaintiff discovered that the copyright case
actors, at the direction of copyright case lawyers, had not turned over reams of subpoenaed
documents and had committed perjury under oath regarding material facts, such as not producing
documents that showed they knew in advance that they were going to plaintiffs deceased
lawyer's office to attempt to gain plaintiffs property. 16 These three state cases which plaintiff
91. On August 30, 2005, plaintiff was struck by a car while riding his bicycle in Baltimore's
rural countryside and suffered catastrophic injuries. Plaintiff spent more than a year in recovery,
during which time he exceeded the best prognosis. Constantly on his mind the entire time was all
92. Beginning in 2007, plaintiff began his pro se efforts to gain justice in the copyright case and
related issues by filing three (3) separate prose actions in the Maryland U.S. District Court.
93. First, plaintiff challenged Judge Garbis' recusal and other orders under FRCP 60.
copyright actors. The district court assigned this action to Judge Motz. This assignment was
16
In July 2004, the USAO MD opened a criminal investigation into these matters led by
the office's Chief, Criminal Division, Barbara S. Sale. Coincidentally, as a young AUSA, Mrs.
24
JA310
troublesome to plaintiff for several reasons, most immediately, the above-mentioned Sheppard &
96. Judge Garbis again refused to answer substantively as to any of the recusal issues, i.e., how
did he know about Messerman's and plaintiffs relationship before he was assigned the copyright
case? Clearly, the basic fact regarding recusal motions is that a subject judge is frequently in
unique possession of the information sought and, thus, has a special obligation to come forward
and disclose all relevant facts to the parties, fully and robustly. Certainly, federal law, the judicial
canons, and abundant case law, are all clear: federal judges dealing with recusal should err on the
side of facts that will support recusal. Further, it is inappropriate for a federal judge to conceal or
fail to disclose recusal related facts known to the judge, like here, with the later-discovered
intensity of the prior relationship between Judge Garbis and Messerman.
97. Importantly, Judge Garbis also never mentioned his pervasive bias against plaintiff as
25
JA311
98. Judge Motz refused to entertain any substantive analysis of the FRCP 60 allegations, instead
relying upon res judicata of Judge Garbis' 2001 opinion as defeating later discovered fraud upon
the court allegations.
intervened to prevent the Sheppard & Enoch Pratt Hospital, of which, as discussed above, he was
a long-term board member and chair, from fairly financially settling the obvious wrong they had
I 00. The FOIA case was litigated to a settlement conference, at which point the settlement judge
informed plaintiff that if he wished the "Bromwell" records, that he could not get those records
under the FOIA from the court, but instead plaintiff had to go back to the presiding judge and
101. Plaintiff then took these three prose actions to the U.S. Fourth Circuit, who ordered the
defendants to answer in the primary copyright case FRCP 60 action. Nevertheless, all three
actions were dismissed without any substantive review at the direction of Judge Niemeyer and
102. Plaintiff then took all three matters to the U.S. Supreme Court, which denied plaintiffs
petitions for certiorari in early 2009.
26
JA312
103. Heeding the settlement judge's instructions, plaintiff then moved in March 2009 to unseal
the "Bromwell" attorney disqualification records before the correct U.S. district judge. The name
104. Surprisingly, the Maryland U.S. Attorney's Office now joined plaintiff in his efforts to
17
I 05. But, Judge Motz ignored all efforts to unseal the subject documents.
106. Plaintiff then took the matter to the U.S. Fourth Circuit where he was joined again by the
Maryland U.S. Attorney's Office. Again, in an unpublished opinion, Judge Niemeyer and fellow
panel members dismissed the case without any analysis of the substantive issues.
107. All matters now dismissed, an intermediary prompted an informal meeting between Judge
Niemeyer and plaintiff. Plaintiff's goal was to find out what the basis was for the denial of all his
rights before Judge Niemeyer over many years.
17
Please see these two Maryland Daily Record news stories: (I)
https://www.scribd.com/document/136425369/Federal-prosecutors-willing-to-unseal-more-
Bromwell-docs-Maryland-Daily-Record-April-l 0-2009 & (2)
https://www.scribd.com/document/136425931/Bromwell-documents-to-remain-sealed-
Marvland-Daily-Record-J uly-17-2009.
27
JA313
I 08. Plaintiff met twice with Judge Niemeyer in the summer of 2010. Judge Niemeyer told
plaintiff that his litigations "should have never been brought," that "they would never let him
win," and that "if you don't stop [your litigations], you will be destroyed," amongst many other
. 18
th mgs.
109. In fall 2010, seeking shelter from the Maryland and Fourth Circuit courts, plaintiff filed a
lawsuit against the Maryland U.S. Attorney's Office and The Washington Post newspaper in the
for declining to prosecute the copyright case actors in 2004-6 for non-allowed reasons. The D.C.
court dismissed the case in summer 2012, all the while refusing to acknowledge plaintiffs
110. Not backing down, in August 2012, plaintiff came right back to Judge Motz in the
"Bromwell" case and filed a new recusal motion, including, in detail, the information gained
19
from Judge Niemeyer. This time the Maryland U.S. Attorney's Office was silent.
111. Again, not only did Judge Motz not answer the newly-learned recusal issues, he again
neglected to reveal his past conduct against plaintiff in the earlier described Maryland state
lawsuit.
18
Please see: Exhibits nos.: 14, 15, & 16; the memorandum, pages 12-13, and the
affidavit, at docket no. 239 in 0l-cv-2600-MJG (D. Md.), and the motion to recuse filed in
Fourth Circuit case no.: 14-6017.
19
28
JA314
112. In late 2012 and early 2013, plaintiff complained about the above-mentioned judicial
disabilities to the Chief Judge of the U.S. Fourth Circuit, who returned the complaint to plaintiff,
and to U.S. Senator Barbara Mikulski, who referred the matter to U.S. DOJ, where it died in a
113. Plaintiffs decision to publicly protest what he believed to be long term corruption at the
Baltimore U.S. Courthouse in 2013 was no lightly undertaken matter, but one considered after
some then-12-years-of-non-stop litigation where plaintiffs inability to recover his own property
114. The motive in this long story is simple, Judge Garbis set out to protect his old classmate,
115. Judge Garbis' conduct, by stating in his 2003 recusal order that he knew, when assigned the
copyright case, information that was in none of the papers filed, would strongly suggest that the
assignment of the case to Judge Garbis was not random. Later, information not provided by
Judge Garbis at assignment, or immediately when it should have been at the TRO hearing,
showed that Judge Garbis and Messerman had a long-term, very close relationship. Clearly, the
issues Messerman was facing in 2001 were not just some little annoyance, but one where his
previously made to plaintiff. And clearly, Judge Garbis went far outside of the copyright issues
29
JA315
pending criminal and custody cases, which was eerily like the tact Messerman had used with
people, associated by an 8-member 1961 graduate law school program, come together at the
Not only is this coincidence implausible, given all the facts listed above, it would be implausible
to suggest anything but that the copyright case was defiled.
116. Judge Garbis clearly spread negative opinions about plaintiff to others, opinions he had
conversations before the copyright case was filed, so as to make sure no judge in the Baltimore
U.S. Courthouse would give him any benefit of the doubt.
117. While it is not known why, Judge Motz and Judge Niemeyer joined Judge Garbis, and
together they eviscerated plaintiffs rights under 28 U.S.C. 144 & 455. Further, the individual
and collected acts by these defendants go far from simple ethics violations and become, by their
length and stubbornness, violations of plaintiffs constitutional rights to due process and his own
property, and in the process, became an actual, albeit unstated, Bill of Attainder put upon
plaintiffs head by the defendants.
118. Plaintiff has been forced to live with the stress and strain of litigation going on now 16
years because of the defendants' illegal and unconstitutional acts. During these 16 years, plaintiff
30
JA316
_J
has lost two homes, all his money, all his personal property, two prized & beloved pets, his wife,
his step-children, most if not all his friends & neighbors, his physical health, has been subjected
to gross scorn and ridicule, and the prime years of his middle-age have been consumed by
defendants.
119. These intentional, knowing, bad-faith, unfair, and wrong acts by the defendants have caused
plaintiff great worry, anxiety, fear, sleeplessness, large financial losses, etc., amongst many other
things, as it was clear to plaintiff that the federal officials who had wronged him would stop at
nothing to defeat his constitutional rights. In addition, plaintiff has had his reputation absolutely
destroyed by the defendants' imperturbable and unconstitutional long-term treatment of him.
120. Judge Garbis, by all that has been learned, should have immediately recused himself from
the copyright case in 2001, and at all times afterward, because of his connection to Messerman,
unknown. But, clearly, plaintiff has been procedurally blocked at every tum since 2001, with not
decisions recounted in this complaint, when taken together, suggest an aggregate of acts that
121. And as defendant DUSM Frederick said in Count I of this complaint, the "Bromwell" case
was the "domino" that could knock over all the other "dominos," i.e., expose all the unethical
31
JA317
rulings against plaintiff. Therefore, the defendants, now greatly worried by plaintiffs 'White
Baltimore U.S. Courthouse - just days away at the time - had great & plausible motive to seek
plaintiffs wrongful & illegal arrest to prevent same at all costs.
122. Further, it doesn't matter that the defendants were unable to arrest plaintiff on July 30,
2013. What matters is that they tried. Just as they tried and succeeded in diluting plaintiffs
demonstration planning and to curb the robustness of his speech/protest and execution. Clearly,
their reasons were that they were trying to make plaintiffs planned demonstrations go away by
any means possible. By any means.
123. Wherefore, for the aforementioned wrongful & unconstitutional conduct, plaintiff seeks,
$20,000,000 from the defendants for compensatory damages, and $40,000,000 from the
defendants for punitive damages.
Civil rights actions are given preference in the Fourth Circuit. Because of the great length of time
these matters have continued and the great harm caused plaintiff, plaintiff prays that this court
issue an expedited briefing schedule in this case as soon as possible.
32
JA318
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
33
JA319
..,I,, .. :'.,,,
!ff '.Jt.L,L ;·__
,,....:.
IN THE UNITED ST ATES DISTRICT COURT
.FOR THE DISTRICT OF MARYLAND fJY____ [c :'Ul '<
NORTHERN DIVISION
WILLIAM C. BOND
P.O. Box 4823 *
*
--~·Plaintiff prose,
V.
JOHNNY L. HUGHESROBERT MARK FREDERICK

and
KEVIN PERKil'JS
PATRICK S. DUGAN
Supervisory Special Agent in Cllarge
and
ROD J. ROSENSTEIN
The Hon. MARVIN J. GARBIS

United States Auorney
Offiee of tlleDistrict Court United Stales :\llorney
36 S. Cllarles St., Fourtll Floor
Baltimore, .MD
Baltimore. Marvland 21201,
JA320
•.
and
"UNKN0\1/N NAMED MARYLAND U.S. JUDGES"

e,o The Hon. Catherine C. Blake
Ghleffhe Hon. J. FREDERICK MOTZ
Baltimore, Maryland ? l 20 I.
and
The Hon. PAUL V. NIEMEYER

United States Circuit Jud~
910 United States Com1house
IO I West Lombard Street
*
Defendants.
*
* * * * * * * *
JNTRODUCTJON
The FePoFteFslowed the small speedboat, then cut the engine off. ,¥e were about a mile out
from Baltimore's Inner ht!l'bor, where the big cargo ships dropped anchor in the Patapsc0
Rher. The eaFly fall 2010 dav vias sunny, yet windy, the cFisp soFt of dav wheFe shoFts and
a Ieng sleeYe polo aver a T shiFt felt just Fight. The FePoFteFpulled out some beers and
chips from a c0oleF, "Cheers!" He said. "No•N, tell me all ab0ut this meeting you hall with
the Fourth Circuit judge."
"Sure," I answered, as the boat bobbed up and down in small waves. "But, first, can y0u
tell me why we'Fe meeting in the midst 0f hunllFells of th0usanlls 0f pe0ple in the middle 0f
the Fell's Paint Fun FestiYal, and whv we're talking way 0ut here in the middle of the
barber?"
"I wanted ta see who's fallowing y0u and mal,e suFe that no 0ne can listen in on what we
sav ... "
SECOND AMENDED COMPLAINT WITH DEMAND FOR JURY TRIAL
JA321
Comes now plaintif(nro se, William C. Bond, pre se, (hereinafter "Plaintiff') and brings this
lawsuit against theDeput)'. United States Marshal for the District of Maryland, l,i:; office &
officers; tl,e Robert Mark Frederick: Supervisory Special Agent iH Cic!argeof the United States
Federal Bureau of Investigation for the District of Maryland. I,is offiee & officers: tRe United
States Attorney fer lfle District ofMar)faHd, his office & officers; m1d !Re "Unknown Named
Maryland U.S. JHdges" Patrick S. Duoan· and Senior United States District Jud~e Marvin J.
Garbis and Senior United States District Judge J. Frederick Motz. both of the United States
District Court for the District of Maryland, including any residing Maryland U.S. circuit judges;
and United States Circuit Judge Paul V. Niemever of the United States Court of Appeals for the
Fourth Circui1; all acting in their 'individual capacities' (hereinafter "Defendants").
misuse of the U.S. Marshals Service and the FBI, acting 'uHder the color of law,• at the direction
of FegHethree Maryland Article III judges ilflGOutsidethe MarylaHd U.S. Attorney's Offieescope
of their authority and im111unity.to violate plaintiffs constitutional rights. includin2' his First
Amendment. Second Amcnd111ent.& due process rights~ all to cover up criminal & etic!ical
judicial misconduct, obstruction of justice, and systemic 'fraud upon the court' perpetrated
against plaintiff by the defendants.
the First Amendment. the Second Amendment. & due process clauses of the U.S. Constitution,
and any other laws, rules. or applicable lawsparts of--Rflesfthe constitution.
JA322
INTRODUCTION
This action concerns a lone-term dispute over a valuable item of personal propeJtv. a literarv
manuscript of hieh monetarv and artistic value. which was taken and kept from plaintiff for no
leeitimatc reason.
FACTS
I. Plaintiff 1s the only known pre se litigant in U.S. jHris13rudeneehistory ·.vhom the U.S. DOJ
hns e,·er joined to Hnseal one of their own eiiminal eases.•
2. This 'Bromwell' aetion reeeivee nrneh alte11tion,IJet]qleeally in Marylane, ans nationally via
the , 4S"''Ci€1EC'
.JV ,u 1 ,:0 ,eH , in 1099
..., 10JG ;!
......
J. Nernrtheless. the distriet eoHn denies 13laintiffhis eenstiWtional rights re: standing, then the
Fourth Cirrnit remainee mHte as to the '3latant de13rivatio11

of13lai111iff'seo11stiwtio11al
rights.
JA323
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JA324
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- ·o[
JA325
Bhas been involved in significant Maryland federal court liti!!ation, both throu!!h counsel and
prose. since 200 I. Plaintiff has lost motions and cases in ways that not only seemed unfair. but
1
unconstitutional.
2..Having had enough of the judicial imperturbability shown toward plaintiff's allegations
recregardin£ the deprivation of his constitutional rights, plaintiff then decided to publicly protest
llIBwhat he saw as 'provable corruption' in the MarylaRllBaltimore U.S. ei;:::ourthouseat the
courthouse itself.
¼J Beginning in April 2013, plaintiff created a public relations campaign called 'Baltimore
Corruption Wire.'
++;!. This campaign was supported by Faeeeoolc, TwiHer. Yot1Tt1ee,Seried, ClaaHge.org, &
F1mdrazr:;evcral social media platforms.
+8~. The campaign was focused around an advertising slogan "Is the 'WHITE GUERRILLA
+9l;i.This ad campaign slogan ran in print and web formats in Baltimore's City Paper during
2
summer and fall 2013 to much notice. The first ads appeared on July 17. 20 I 3.
1
5.J11feet. a ferate_rA:Ll:.£6...MJ2.±e:l..d H=ie1eleph0Aethat he ''theugflttfle El_avs
plaiHtiff 01-1 Bf iwfaes tre_ating
people ~he
~lnirtiff,,,,y hniru 1rwl1Pd urprp ln11gp,rrr.''
Plaintiffs litigation historv is summarized in Count VI.
2
Please see: Exhibit nos.: J & J_ The ads can also be seen here:(])
7
JA326
?Jl7. Plaintiff also wrote an Op-Ed for tLne Baltimore Sun detailing what had recentlv transpired
in the 'Bremwell"'Bromwell" public corruption case titled "CORRUPTION Sub Curia."
±-h When the Op-Ed was rejected over length concerns by tLhe Sun's editors, plaintiff then made
the Op-Ed the center of his anti-federal-court-corruption activities, as it explained in detail how
the Maryland federal court has become an upper class version ofthe notorious 'Black Guerrilla
2
Family' prison gang.
22. ~/eesless to say, tliese activities atlracles a lot of notice by Baltimore's close knit legal elite, ..
±J. The Op-Ed ex_plainsthe background for plaintiffs First Amendment objections as to what he
3
saw !!oimr on at the Baltimore U.S. Counhouse.
~- Then, plaintiff announced a public protest schedule to begin August 4, 2013, at the Baltimore
U.S. courthouse, anEIpublicly soliciteEIthe same citizens who woulEIlater become the
#BlackLivesMalter movement 10 join him to correct the provable corruption, anEIEloullle
stanElarElsfor rich & poor. in the MarylanEI U.S. courthouse, as e\·iEleneeEIby the secret self
sealing v.-Jiichwas provallle fact in the 'Bro1m•,ell' ease.
https:/ /www .scribd.com/doc/296483607 /Corruption-Wire-web-ad & (2)

https://www .scribd.com/doc/296483897 /Corruption-Wire-print-ad
3
Please see: Exhibit no.: 3. the subject Op-Ed, which may also may be viewed here:
ht1ps://www.scribd.com/doc/ 13641 8039/Will iam-Bond-CORR UPTI ON-S ub-Curia-op-ed
8
JA327
COUNTI
±4-Courthouse.
COUNTI
~l.Q. On July 19, 2013, and July 30, 2013, plaintiff was visited at his then-apartment by one
~JJ .. During the July 19, 2013, meeting, the federal agents wished to come inside plaintiffs
12. The agents followed plaintiff to this 'common room' and acted, on guard, as if plaintiff was-a
vieleAt eriminal ready te atlack ttlem.
28. Oddly. lAeDUSMwere a physical threat lo them.
13. The DUSM. whose name was Robert Mark Frederick. voiced several times how much he had
JA328
;!.914. The FBI agent, whose name was Special Agent Chris Wood, who led the questioning,
used to babysit for plaintiff's stepchildren."
15. Plaintiff was alarmed bv the agems' line of questioning because he had never phvsicallv
threatened any government officials or federal jud£es in any wav. Plaintiff made it clear te-tlte
ageAls that their line of q1c1estioniAg

had AObasis iA fuet, that it bonlered ORfantafy, and that
rlaiAtiff lrnd made it dear hishis only goal was to have certain judges removed from the federal
beneh by either imreaehmeAI or forced resigAation.
31. ~levertheless, the FBI ageAtjudicially reprimanded and/or sanctioned, and for his stolen
propcnv and resultant damaQes in a long-running case returned to him.
16. FBI Special Agent Wood asked repeatedly what could be done to make the scheduled
;P-17. The next dav. on Julv 20. 2013, plaintiff memorialized this meeting in writing and put the
Maryland U.S. Attorney's Office. including several of their top officers. on direct notice that
these alle!!ed concerns by government law-enforcers over nonexistent and never explained
'threats' allegedly attributed to plaintiff were fabricated hv the government and had no basis in
10
JA329
- 4
1act.
18. The second knock on your door from government law-enforcers provokes fear.
:,J, Why are they back?
3419. Before plaintiff opened his then-apartment door on July 30, 2013, he asked the federal
agents outside if they had a warrant, which they, again, did not have.
±)20. When plaintiff opened his then-apartment door - staying within the threshold, this is what
he saw: Standing directly across from him was the same DUSM from the first visit, Robert Mark
Service's Protective Intelligence Unit (hereinafter "USMS PIU"). To plaintiffs direct right, in a
semi-ready-to-tackle-stance was a different FBI agent than from the first visit, Patrick S. Dug@,
whom plaintiff would later learn was the FBl's Supervisory Special Agent in charge of the
¾21. The federal agents demanded plaintiffs firearms, which plaintiff denied having.
;,+22. The federal agents again requested to come inside plaintiffs then-apartment, which
4
- Please see: Exhibit no. 4. plaintiffs July 20. 2013. email to the USAO MD with noted sections
highlighted for the court's convenience and email addresses redacted. The court should also note
that while this communication is somewhat rambling because plaintiff was very angry about
what had just been done to him by the government, it clearly shows plaintiffs state of mind at
the exact time in question, and that his injuries were real.
II
JA330
plaintiff denied them permission to do.
;,&23. Plaintiff then agreed to go speak with the federal agents in the same 'common room' as
plaintiff.
;;924. Again, plaintiff was followed to the 'common room' and treated again as ifhe were a
violeflt crimillal ready to commence mayhem with the non existent 'gats' the law enforcers
sought.
49physical threat.
any federal judges or government officials or federal judges in any danger from plaintiff?
Plaintiffs answers were repeatedly "no" and "no.•·
4+26. Where were plaintiff's guns? Where were plaintiffs guns? 1,000 times it was asked.
'12. As all ofMany times. it was asked. Plaintiff even had to stand up. raise his shirt. and turn
around to show the as>entsthat he had no handguns on his person.
?7. As plaintiffs firearms were confiscated in 2001. as described in detail in Count VI, by the
State of Maryland in a purported criminal action (charges dismissed, record expunged), plaintiff
proffered that they should damn well know where the guns were. Yet. the agents claimed the
12
JA331
slate gun database still showed plaintiff own in!! firearms. Plaintiff told the agents that all his
fonner guns were either with his ex-wife or unreturned by the State of Maryland.
4+28. Again, theas FBI aSpecial Agent Wood had earlier asked, FBI Supervisorv Special Agent
Duzan asked- holding some of plaintiff's 'White Guerrilla Family' promotional literature in his
hand- "What would it take to make this [the planned demonstrations] go away?"
4429. Plaintiff proffered to !he FBI a/I.gent Dugan that the USAO MD United States Attornev
was the one who should be asking that question and that plaintiff was happy to meet with
lhemhirn re: same. 5
#30. The FBI agent didn't like that answer, and stated that he was sent lo ifllerview 13laifltiffto
gather cenain inforniatiofl af!d that he had lo re13ortsack immedimelyhere and had to
immediately report back - to whom, he would not say. 6
% At that point, rnanv of the same issues discussed in Count VI were discussed with a focus on
what the irnvernmenl could offer as a resolution of plaintiffs greater complaints reirardine the
underlying long-running litigation. Aeent Dugan didn't fullv understand the back story of the
long-running litigation and how the "Bromwell'' public corruption case fit into the picture.
5
9 Later, in fall 2013, the FBI agent would schedule, then cancel, a meeting between the FBI, the
USMS, & the USAO MD, to be held, as a courtesy, in a major law firm's Baltimore conference
room.
6
-Hl On information and belief, t!cie"UAlmowf! Named Maryland U.S. h1dges" were''Judge Motz··
was independently operating & controlling the SHIJjeclgovernment agents outside of the normal
U.S. DOJ 'chain-of-command.'
13
JA332
DUSM Frederick calmlv explained to Agent Dwzan that the "Bromwelr' case was like a
"domino." and that if plaintiff was able to be victorious in that action. it would create a "dornino-
effect"' and thus cause plaintiff to run the table and win all his long-running liti2:ations very
quicklv.
[handcuffs) on his wrists and take him straight to Central Booking IBaltimore Citv Jail)."'
47-32. The USMS PIU manuals specifically speak about the unit being prohibited from using
their resources to violate the First Amendment rights of citizens.

7
33. ClearlyY et, the timing of these visits, especially the attempt to arrest plaintiff for illegal
weapons possession, was intended with one goal and one goal only in mind: to prevent and/or te
intimidate plaintiffs planned demonstrations at the Baltimore U.S. eCourthouse on August 4,
2013.
34. Clcarlv. as alle2:ed later in this complaint. the government was survcillin2: plaintiff since
7
Please see: Exhibit no.: 5, the USMS Policy Directives, Judicial Security, 10.7 Protective
Investigations at D. 7. (See, Page 2.)
14
JA333
his supposed actions''
35. Clearlv. as well. it is simply implausible to say that after three years of surveillance. now. just
two(?) davs after plaintiffs first Cin· Paper ads - ads which received much notice in Baltimore
- the law enforcers suddenlv found exigent reasons to attempt to intimidate and influence
plaintiffs First Amendment rights. For example. because of this first visit bv the law-enforcers.
plaintiff was forced to consult a criminal defense lawver. other lawyers and business people.
numerous friends. to worry and lose much sleep. and to be greatly distracted when he was on an
abbreviated time line and had much still to do to organize the August 4. ?O13. protests. amongst
many other things, This worrv and distraction chilled and curtailed the robustness of plaintiffs
first amendment activitv - as one would expect following visits from interrogating law
enforcement personnel asking 'What will it take to get you to shut up 0 '
demonstrations was out of fear for the safety of government officials or federal judges - as tho5e
manufactured fears had alreadv been allaved by their first visit and plaintiffs letter to the USAO
MD- and that this second act was not anvthin,r but another effort to stop plaintiffs planned
demonstrations and to violate his First Amendment rights. Otherwise. why brinz up detailed talk
of 'settlemeni'O This second visit caused plaintiff the same iniuries and curtailed speech as iust
recounted above. only they were exacerbated. as plaintiff now only had five (5) days left before
his first protest at the Baltimore U.S. Courthouse.
15
JA334
37. But. there is another reason to believe the government agents acted unconstitutionallv: In
2013. plaintiff was legally allowed. both by state and federal law. to possess firearms. 8
38. The reason for this was Congress, since at least 2007. had ceded restoration of certain
firearms rights to participating states. Maryland being one of them. via the NICS Improvement
Amendments Act of 2007. See. Tyler v. Hillsdale Cty. Sheriffs Dep't. 837 F.3d 678 (6th Cir.
2016) {en banc). 9
39. Further. the Marvland United States Attornev's Office knew that plaintiff was not in
violation of any firearms laws. as plaintiffs former Marvland criminal defense lawyer - again.
plaintiffs litigation historv is discussed in more detail in Count VT- had discussed plaintiffs
firearms qualifications with Barbara S. Sale, the USAO MD's ChieL Criminal Division in 2006-
firearms since at least 2006-7. but thev actually tried to do exactlv that on Julv 30. 2013. both in
violation of plaintiffs Second Amendment rights, and to misuse the law to violate plaintiffs
8
Please see: Exhibit nos.: 6, 7, & 8, plaintiffs 2001 physician's certificate and the 2013
Maryland law.
9
Please see: Exhibit no.: 9, the subject Tyler opinion, page 4, which can also be viewed
here: http://www.opn.ca 6.uscourts. gov/opinions.pdf/16a0234p-06. pdf
16
JA335
41. After the July 30.2013. threats. DUSM Frederick continued the threats bv seeki1w
information from plaintiffs ex-wife to arrest plaintiff sometime before the Au!!ust 4. ?0 13.
491,. These intentional, knowing, bad-faith, and illegal acts by the defendants caused plaintiff
plaintiff that his e!lemiesthe federal officials who had wron!!ed him would stop at nothing to
50'13. Wherefore, for the aforementioned illegal conduct, plaintiff seeks $+5,000,000 from the
defendants for compensatory damages, and $;;10,000,000 from the defendants for punitive
damages.
COUNT II
SJ. ,•. 'hlaek liws matter' type aetivist eontaeted plaintiff on July 14, 20B, after plaintiff
announced his U.S. courthouse demonstration schedule 011 Facebook.
S2. This 'acth·ist' claimed to he interested in plaintiff's 'Baltimore Corruption \Vire' entit~-,
aed especially ie plaintiff's planned U.S. courthouse demonstrations.
S3. This 'acth·ist' and plaintiff communieated via Faeehoolr and on the telephone multiple
times.
S4. Of note, the 'aetivist' was offering to help with the planned protests, including by
providing 'bodies' to protest, moAey fer ad..-ertising, and grassroots help in the 'hlaek'
eommunity so as to 'talie down' the eorrnf1! judges in the Maryland U.S. courthouse.
SS. On July 20, 2013, the 'aeth·ist,' his 'wife,' and plaintiff met at a North Baltimore eafe
fer three (3) hours to discuss plaintiff's planned U.S. courthouse demonstrations.
SG.The 'acthist' and his 'wife' spent much time asking plaintiff, in great detail, about his
life story, includieg attemptieg to solicit harmful ieteetions toward the subjeet U.S. judges.
17
JA336
§7. Tbe 'aeth·ist' and bis 'wife' spent mueb time effeFing tbeiF time, help, meney,
grassrnets eFgani,dng abilities, and, mast impeFtantl~·, 'bodies' te prntest at tbe planned
U.S. eeuFtbeuse prntests.
§8. The 'aetiYist' and bis 'viife' guaranteed at least fifty (§0) 'bodies' te prntest, with as
many as 'sHeral bundFed' te be added te that number.
59. There weFe many Faeebeal, and telephone eanversati0ns with the 'aetiYist' rega,·ding
tbe upe0ming prntests and what bis e0ntributi0ns weuld be.
60. NeveFtheless, when tbe first planned U.S. eeurtheuse pretest day arri'ied, the 'aetiYist,'
bis 'wife,' bis 'bodies,' neF any ether support, were n0 where te be feund.
61. On infermati0n and belief, tbe 'aetiYist' and bis 'wife' were undereaYer U.S.
g0Hrnment agents sent (1) with tbe elear intention te sabotage plaintiff's U.S. c0urtb0use
pretests in any way possible and (2) te eriminally entrap plaintiff by attempting le engage
plaintiff in diseussiens ef Yielenee against federal effieials, even though plaintiff had always
insisted that the misbehaYing Maryland federal judges should be held aeeeuntable,
publiely, under the law and rules.
62. These intentional, !mewing, bad faith, and illegal aets by the defendants eaused plaintiff
gFeat ·NeFry, anxiety, feaF, sleeplessness, ete., amongst many ether things, as it was elear te
plaintiff that his enemies weuld step at nothing te defeat bis eonstitutienal rights.
63. WherefeFe, fer the afurementioned illegal eenduet, plaintiff seeks $1§,000,000 from the
defendants fur eempensatery damages, and $30,000,000 frem the defendants fur punitiYe
damages.
COUNTIII
64[ COUNTS II. IV. & V from the original Complaint are deleted from this Second
Amended Complaint.)
COUNTIII
65. At first, the~· were 13lanned enly for enee a mentli.
18
JA337
66. But, after the jusge fer whom the 'White Guerrilla family' gang was names actually vi sites
the protes!s to asmire the pro!esl sigAage he iAspires, the protest schedule was moves to a mosEly
weekly eveAt at the Baltimore U.S. courthouse through !ale fall ?OJ3.
&145. During these protests, plaintiff was always supervised by the DUSM PIU agent and-ake
often by Federal Protection Service officers, sometimes in full SWAT gear.
6846. Naturally, the DUSM agent and plaintiff became acquainted, especially as tlre-DUSM
Frederick had claimed he had long-wanted to meet plaintiff.
69. SooH, the DUSl\447. DUSM Frederick continued to probe plaintiff regarding his alleged
possession of illegal guns and wondered if plaintiff had anv guns "buried." At one protest in
early fall 2013. DUSM Frederick told plaintiff about a conversation he had just had with As:ent
Dugan. Agent Dugan had "asked fhiml ifwc need to have the fFBIJ SWAT Team come and
arrest Bill fplaintift] 9 " He then recited more of the conversation he had with Agent Dugan as to
whether plaintiff"would survive a night in Central Bookin,:,:[Baltimore Citv Jaill?"
48. Yet soon. DUSM Frederick came to see that plaintiff was no 'sociepath'"sociopath" as he
insinuated the U.S. DOJ profilers had attempted to 'mark"'mark" him, but aswas instead. in his
words. a "lover," not a "figl'lter""fighter." who just wanted to "go back to the country club.,:'
which was how DUSM Frederick~ a big football fan~ saw former tennis plavers such as
plaintiff."
+G49. Plaintiff and tlre-DUSM Frederick spent much time chatting at the Baltimore U.S.
19
JA338
10
es:;ourthouse during plaintiff's demonstrations.
++50. Plaintiff also learned, while chatting with federal law-enforcers during his protests, that the
11
:J..±51.Several times me-DUSM Frede1ick explained that the reason he had always wanted to
meet plaintiff was because of his particular letter writing abilities, letters which acted as
'prosecutions' of certain 'judges'iud2:es and other government officialsofficials' reputations.
Apparently, plaintiff had real! v 2:otlen under the skin of certain i L1dgesand officials.
+;52. When plaintiff queried how long this desire had existed, the DUSM explained that he had
been surveilling plaintiff since 2010, since his D.C. lawsuit was filed agaiAst the Maryland U.S.
:'.tterney.
74. Frankly. this,
53. This revelation surprised plaintiff very much, as he had thmight the reperter's precmHiens iH
2010, as 'suggested' in the introduction to this ]av.suit, were a joke.
Bplaintiff had wondered rnanv times how the government always seemed to be one step ahead
in many parts of his continuin£ litigations.
10- The DUSM was convinced (as the government's 'expert' on plaintiff) that plaintiff
was in the "right" and that he had "gotten f'*ked-over by the 'judges,"' which was a statement
he made many times.
11- This information became a qui tam lawsuit. Please see: 15-cv-0O199-DAF (D. Md.t
20
JA339
the government.
7s.This aet And it is implausible lo say that plaintiff must plead specifics on this allegation
that they then used against him in the continuing litigations. In short. the spvi1w upon plaintiff. if
used in litigation. as opposed to le2itimate law enforcement pumoses. is a gross constitutional
~5. This continual surveillance is also a violation of the rules of court, which government
attorneys nrnst also follow.
+/-are required to follow. That no government attorney ever notified any federal judge
supervising federal litigations before them of this issue. either ex pane or under seal. shows
56. Further. because of this admitted governmental surveillance of plaintiff, plaintiff was forced
to limit and curtail the freedom of his expression to others via the telephone. the internet. and bv
21
JA340
plaintiff that His eHemiesthe federal officials who had wro112edhim would stop at nothing to
+&58. Wherefore, for the aforementioned illegal conduct, plaintiff seeks $+5,000,000 from the
defendants for compensatory damages, and $'>10,000,000 from the defendants for punitive
damages.
COUNT I¥
79. The DUSM alseVI
59. Plaintiff is the author of the unpublished fictionalized copyrighted manuscript titled Se/(
Portrait o(a Pa1ricide.
60. In the spring of 200 I. plaintiff discovered that a copy - one of only two in known existence -
of his manuscript had been stolen from the law offices of his deceased auorney by actors in a
child custody proceeding in Bahimore Cilv. Marvland.
61. The custody ease pitied plaintifrs ex-wife's ex-husband and her father (hereinafter the
'·custody case opponents"') against plaintiffs ex-wife and him.
62. These custody case opponents had earlier been investigated. indicted. and prosecuted by the
and fines.
22
JA341
63. In the late spring of 2001. plaintiff discovered that a handgun had been stolen from a locked
Police Department.
64. On Mav 25. 2001, plaintiffs and his ex-\\ife·s home was raided by a Marvland State Police
SWAT team and plaintiff was charn:ed with ille,ral handgun possession. Plaintiff spent one night
in Central Booking_ Baltimore's notorious & very dangerous jail.
65. The basis of the charges was that plaintiff had spent more than 30 davs in a mental health
facility due to an Ohio 1981 juvenile delinquency adjudication. and thus was prevented by
l\faryland law from possessin2: firearms.
66. PlaintifTimmediatelv retained the "dean" of the Marvland criminal defense bar. one Richard
M. Karccski. Esq.
67. The first thing Karceski did was to call plaintiffs former Ohio attornev named Gerald A.
Messennan. Messerman had alwavs told plaintiff about howthat his surveillaAee of plaiALiff
EOHtiAuediA 1012. after plaintiff had lost his home. his doe. all his possessioAs. ele .. and was
livine in an 1meleetrified 'sguat' in a eereliet buileine ..µ
go_As this surveillai,ee eanie as plaintiff was attaeking the 'Bremwell' ease the see011d time in
summer 2012. elearly the ii,teHtien by the government was the uneonstitutional deprivatioA of
plaintiffs due preeess and ei,il rights.
23
JA342
g 1. On infurFRatien ans belief. tRis cenlimies s,uveillance. wRich. as alreasy states. began in
1010. ans Ras. en infurFRatien ans llelief. eenlim,es until this say. Ras censisles sf electrenie
meni10rin2 sf plaintiffs c01mmmicati011s. inchc1singtelephene ans internet eemm~mieatiens. all
with the intentiefl sf ifllerferiHg with plaintiffs public prntests ans his pul31icpelicy leeal
activities. inelusing lawsuits aeainst 20\'ernment aeters.
82. TRese ifllemienal. kne·.ving. llas faith. aHs illegal acts by the sefensants causes plaintiff
great werry. anJciety, fear. sleeplessness, etc .. amenest many etRer thines. as it was clearjuvenile
record would be expunged at a certain date and then later wrote plaimiff a formal letter stating
that his juvenile record was expun!.!ed. Nevertheless. the State of Marvland was using plaintiffs
Ohio juvenile record to prosecute him and Karceski asked Messerman how that was possible if
12
the subject record was expunged?
68. Turned out plaintiff's juvenile record- despite the Messennan letter to the contrary- was
never expunged.
69. Plaintiff was in verv big trouble. The State of Marvland was seeking a I 0-year-prison-
scntcnce for a misdemeanor. and was not even hiding the fact that thev were trying to re-punish
plaintiff for his juvenile act. according to the Marv land Assistant Allorney General who was
12
- Please see: Exhibit nos.: JO & 11, Gerald A. Messerman, Esq., 1986 & 1994 letters to
plaintiff.
24
JA343
70. Both the custody case opponents and the State of Marvland then sought to use plaintiffs
stolen manuscript in their respective cases - to rip plaintiffs ex-wife's children from her custodv
and to imprison plaintiff for IO vears.
71. Plaintiff hired a top First Amendment lawver who then filed a copyright action to gain the
return of the manuscript. all copies made. and to prevent its further unauthorized use. in the U.S.
District Court for the District of Marvland on August ?9. ?()()I. This case was assigned to U.S.
District Judge Marvin J. Garhis.
72. Karccski had many conversations in ?(JOI & 200? with Messerman. The book was a big
subject. especially as Messcrman had read an earlier draft in the earlv l 990's. Messerman knew
in the late spring and earlv summer of ?()()l that the copyright case was coming. When it was
filed. Messerman asked Karceski who the judge was· 1 Karceski told him it was Judge Garbis.
Messennan then told Karceski that he knew .Judge Garbis. but did not sav whv or how.
73. Importantly. Messerman knew at this time that he was subject to a malpractice action based
upon his false representation to plaintiff that his eAemies weuld ste!l at AethiAg ts defeat his
60AStilulieAal ri gilts.
83. Wherefore. fer the aferementiened illegal eeAduet. elaintiff seeks $15.000.000 frem the
defendaAts fer eemeeAsatery damages. and $30,000.000 frem the defondants fer e,mitive
damages.
25
JA344
COUNT V
84. OH SefJlember 29, 2015, while visitiAg the Baltimere U.S. ceHrtheuse, fJlaiAliff was sHbjected
le aA effort by the DUSM te i,ivade his prose litigant werk predHet in the E)Hitam case
mentieAed abern. iA vielatioA ef the rules ef coHrt.
85. That same day aAd time. fllaintiff was alse s~1bjected to aA effurt by the DUSM. working iA
tandem with the U.S. jHdge who was tl~e model fur the '\l/hite GHerrilla Family' ad campaign, te
criminally entrap plaintiff.+4
86. These inteAtioAal, knowing, bad faith, and illegal acts by the defeAdants caHsed plaintiff
great werry. anxiety, fear, sleeplessnes.;, etc., amengst maAy ether tAiAgs, as it was clear
teiuvenj_le record was cxpunw~alsc representation that had actually £Otten plaintiff charged
with a crime. In speaking with Karceski. Messerman acted more like a prosecutor toward
plaintiff and defended himself that there was no malpractice if plaintiff was convicted of the
handgun char2:es due to the vagaries of malpractice liability. Mcsserrnan was also very worried
about his hi2:h-profile and spotless reputation. as he claimed to have never been sued before for
malpractice.
74. Despite the clear error. Mcsserman adamantly refused to come to Maryland and testify
75. On November ?O. ?001. Judge Garbis held a TRO hearing in the copyright case. Information
26
JA345
- for the first time - was introduced into the court record regarding Messerman 's contacts in the
late l 980's with one of the copyright case defendants.
76. Ruling from the bench. and after making a verv brief reference to knowing Messerman and
complimenting his legal acumen. Judge Garbis refused to order the return - ever- of anv or all
copies of plaintiffs propertv and ordered plaintiff to pav the individual defendants' legal fees. In
essence. Judge Garbis ordered plaintiff to pay the thieves for their efforts expended to steal his
propertv.
77. Soon after this order. plaintiff flew to Cleveland. Ohio for an unpleasant meeting with
Mcsserman. At this meeting_ Messerrnan told plaintiff that his ettemies WOHids10p at Hothing to
defeat his eottstit1c1tionalrights.
87. '.Nherefore, for the aforementioned illegal cottdHct. 13laitttiff seeks $ I 5.000,000 from the
defendants for rnm13ensatory damages. and $30,000,000 from the defendants for 13,mitive
damages.
COUNT VI
gg_ Ti'le defettdants i'lave at all times since 200 I Hotil 13resent been in an CJ(tended cons13iracy to
de13rive 13laintiff of his First Amendment & due 13rocess rights, his libeny, and his rigi'lt to his
own 13ro13e11y,
if not oti'ler constitutional de13riYatiotts.
gg. This co1-JSJ3iracyincludes a federal jHdge seeking out with malice aforethoHght to have a 2001
27
JA346
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JA347
federal judges whsm the former U.S. attsmey had previsusly inwstigated.
97. The judiciary. rhe govemmenl, and the bar, are suppssed ts form an adversarial triaugle
based upsn the rules aud the law, withsut which eur American judicial system cannst funelisn.
9g_ The csusritutisnal violatisns in this csuspiracyJ udge Garbis and he were araduate school
classmates in 1961 at an exclusive 8-member program run by Georzetown Universitv Law
School called the E. Barrett Prettvman Fellowship. When accepted at this proaram. the graduate
law students all lived together in a Washington. D.C.. row home under the supervision of a
professor who also directed them in providing legal defense for low-income city residents. In
short. .ludge Garbis and Messcrman were house.mates in posH!Taduate law school. Later. thev
would visit each other both in Ohio and. on information and belief. when Judge Garbis held a bat
mitzvah for one of his daughters in Marvland. amongsr other contacts.
78. The criminal case against plaintiff are far bigger than plaiutiff, a, they affect every single
citi£en sf the stale sf Maryland.
99. That nst one person in a position of power to help plaintiff would do so is a staiu Hpon(See
again '.II'II
65-66 above) was dismissed bv Baltimore Citv Circuit Court Judge John C. Thernelis.
after almost one vear of intense litigation. on April 22. 2002. based upon the expert opinion of
noted Maryland forensic psychiatrist Michael K. Spodak who provided a 'certificate' to the
court. required under Maryland law. testifvin!.! as to plaintiffs 'capabilitv' to possess fiream1s at
29
JA348
11
all times in question.
79. On January 74. 2003. the U.S. Fourth Circuit issued a published opinion in the appealed
copyright case. Writing for the court. U.S. Circuit Judge Paul V. Niemeyer stated that Judge
Garbis had not gone far enough and ordered that the law firm defendants. who were self-
represented, could now seek attomevs· fees from plaintiff. Jud!.!e Niemever also suggested that
the remedv to the conversion of plaintiffs copvrighted prope11y !av in a state action despite
80. On remand. Judoe Garbis awarded the full set of copyright actors more than $181.000 in
attorneys• fees.
81. Soon after. Judge Garbis" recusal was sought. Judge Garbis responded with an order denyin!:!
- · 14
th at request, an d state d , m pertment part:
"When assigned this instant case in August of 7001. I noted that

Plaintiffs criminal counsel in Cleveland had been Mr. Messerman.
added.) [Judge Garbis Memorandum and Order. April 23, 2003.l
It is clear from this statement. as plaintiffs copyright action was filed on Au>1ust 29, 2001. and
made no mention of Messennan. that Messerman was havin!l: secret. clandestine conversations
13
- Please see, again: Exhibit no.: 6.
14- Please see: Exhibit no.: 12, Judge Garbis Memorandum & Order re: Recusal at docket
entry no.: 108 in case no.: l:Ol-cv-02600-MJG (D. Md.l. The court should also note how Judge
Garbis substituted the word "criminal" for "juvenile."
30
JA349
with either Judge Garbis. or someone on his behalf.
82. Plaintiff then sued all the copyright actors. Messerman. and others. in three different
Marvland state actions that lasted from 2003 until 7006. All of these stale actions were
dismissed. except for one settlement. with both uial and state appellate courts relying almost
wholly upon the federal rulings of Judaes Garbis & Niemever.
83. Later. in 7008. plaintiff met with a very prominent Baltimore lawyer in his/her office. /This
person "s identity is bei1m withheld at this time to protect him/her from unnecessary exposure to
retaliation.)
84. This lawvcr knew Judge Garbis verv well.
85. Sometime in 7004-2006. the prominent Baltimore lawver spoke to Judze Garbis about
plaintiff. Durinz this conversation. Judge Garbis made many highly disparaging remarks about
plaintiff. These remarks sumrised the prominent Baltimore lawver because. familiar with
86. Judge Garb is told the prominent Ba Iii more lawyer that plaintiff was a "verv bad man," that
"plaintiff was verv dangerous." that "[the prominent Baltimore lawyer) should stay away from
[plaintifO,"' and manv other things that all showed pervasive bias toward plaintiff. The prominent
lawver told plaintiff that Judge Garbis had actual "bias" against him. The prominent lawver also
suggested that. if plaintiff could not coITect what Judge Garbis had done to him in the copvright
31
JA350
case, that plaintiff should hold "public protests·· at the U.S. courthouse a!!ainst Judge Garbis.
87. The Maryland mental health facility where plaintiff was sent in 1981 bv an Ohio iuvenile
court was also sued in Marvland state court for handing out plaintiffs complete medical &
mental health records. absent a subpoena. in summer 200 I to the Marvland Attorney General's
Office. who. as already stated. was prosecuting the criminal case relating to plaintiffs firearms.
88. Sometime between 2003~)005. the lawyer representing The Sheppard and Enoch Pratt
Hospital, Daniel J. Moore. told plaintiffs lawyers in that case that a board member, who was
also a lawver. was "adamantlv outraged·' that plaintiff had sued the hospital and had ordered Mr.
claimed violations were of federally protected records. These statements were allegedly made in
front of other board members and/or witnesses.
89. On information and belief. that lawver was also a U.S. District Judge named J. Frederick
Motz. Jud!le Motz. and his father before him. were very lon!l-term Board of Trustees members &
15
chairs of the hospital and look a very personal and protective interest in the institution.
90. During discovery in the three state lawsuits. plaintiff discovered that the copyright case
actors. at the direction of copvri gin case lawvers. had not turned over reams of subpoenaed
15
- Please see: Exhibit no.: 13. the SEPH Board of Trustees as of 2017.
32
JA351
documems and had committed periurv under oath regarding material facts. such as not producing
documents ihat showed thev knew in advance that thev were goins<to plaintiffs deceased
16
lawyer's office to attempt to s<ainplaintiffs propenv. These three state cases which plaintiff
pursued because he was sent in that direction bv federal court orders in the copyright case
consumed an extraordinarv amount of resources.
91. On August 30. 7005. plaintiff was struck bv a car while riding his bicycle in Baltimore's
rural countrvside and suffered catastrophic iniuries. Plaintiff spent more than a vear in recoverv.
during which t.ime he exceeded the best prognosis. Constantly on his mind the entire time was all
97. Beginning in ?007. plaintiff began his urnse effo11sto gain justice in the copvright case and
related issues by filing three (3) separate uro se actions in the Maryland U.S. Cami. tile USAO
MD, & tile MarylanEI Bar.++
-1-00DistrictCourt.
93. First. plaintiff challenQed .Judge Garbis' recusal and other orders under FRCP 60.
94. Then plaintiff filed a FRCP 60 ''Independent Action" seeking tort damages against the
16
In July 2004, the USAO MD opened a crim.inal investigation into these matters led by
the office's Chief. Criminal Division, Barbara S. Sale. Coincidentally. as a young AUSA. Mrs.
33
JA352
,;_gp
__yri2:htactors. The district court assi!med this action to Judge Motz. This assignment was
troublesome to plaintiff for several reasons. most immediately, the above-mentioned Sheppard &
investigative files from their 2004-6 investi2:ation regarding the copyright case and the Maryland
U.S. District Coun for information about one of the copyright case actors that was 'under seal' in
96. Judge Garbis aQain refused to answer substantively as to anv of the recusal issues. i.e., how
did he know about Messennan's and plaintiffs relationship before he was assigned the copyright
case·, Clearly. the basic fact reQardin2: recusal motions is that a subject judge is frequently in
unique possession of the information sou'llll.l!lli1,Jhl!£,Jias a :';pecial obli2:ation to come forward
and disclose all relevant facts to the parties. fully and robustly. Certainly. federal law. the judicial
canons, and abundant case law, are all clear: federal judges dealing with rccusal should err on the
side of facts that will support recusal. Further. it is inamiropriatc for a federal iud~e to conceal or
fail to disclose recusal related facts known to the judge. like here. with the later-discovered
intensity of the prior relationship between Judge Garb is and Messerman.
97. Importantly . .Judge Garbis also never mentioned his pervasive bias ae:ainst plaintiff as
34
JA353
98. Judge Motz refused to entertain anv substantive analysis of the FRCP 60 allegations. instead
relving upon res iudicota of Judge Garbis' 1 001 opinion as defeati,rn later discovered fraud upon
the coun allegations.
intervened to prevent the Sheppard & Enoch Pratt Hospital. of which. as discussed above. he was
a long-term board member and chair. from fairly financiallv settling the obvious wrong thev had
100. The FOIA case was liti !!ated to a settlement conference. at which point the settlement iud!!e
infonncd plaintiff that if he wished the "Bromwell" records. that he could not get those records
under the FOIA from the court. but instead plaintiff had to go back to the presiding iud2:e and
l 01. Plaintiff then took these three prose actions to the U.S. Fourth Circuit. who ordered the
defendants to answer in the primarv copvright case FRCP 60 action. Nevertheless. all three
actions were dismissed without any substantive review at the direction of Jud2:e Niemever and
102. Plaintiff then 100k all three matters to the U.S. Supreme Court. which denied plaintiffs
petitions for certiorari in earlv 2009.
103. Heeding the settlement iudge's instructions plaintiff then moved in March 2009 to unseal
the "Bromwell" attomev disqualification records before the correct U.S. district judge. The name
35
JA354
of that judge was Judge Motz. who again never brought up his pervasive bias issues against
104. Surprisinglv, the Marvland U.S. Attorney's Office now joined plaintiff in his efforts to
17
105. But. Judge Motz ignored all efforts to unseal the subject documents.
I 06. Plaintiff then took the matter to the U.S. Fourth Circuit where he was joined again bv the
Maryland U.S. Attorney's Office. Again. in an UIJ])ublished opinion. Judf!e Niemever and fellow
panel menJbers dismissed the case without any analysis of the substantive issues.
I 07. All matters now dismissed, an intermediary prompted an informal meeting between Judge
Ni em ever and plaintiff. Plainti f"f s goal was to find out what the basis was for the denial of all his
rights before Judge Niemeyer over manv years.
108. Plaintiff met twice with Judge Niemeyer in the summer of 2010. Judge Niemeyer told
plaintiff that his litigations "should have never been brought." that "they would never let him
win,'' and that "if you don't stop !your litigations). vou will be destroved," amongst manv other
17
- Please see these two Maryland Daily Record news stories: /1)
https://www.scribd.com/documcnt/136425369/Federal-prosecutors-willing-to-unseal-more-
Bromwell-docs-Maryland-Daily-Record-April- l 0-2009 & (2)
https://www .scribd.com/documem/ 1364? 5931 /Bromwell-documents-to-remain-sealed-
Marvland- Dail y-Reeord-J uly-17-2009.
36
JA355
· IS
t I1111gs.
I 09. In fall 2010. seeking shelter from the Marvland and Founh Circuit courts. plaintiff filed a
lawsuit against the Marvland U.S. Attorney's Office and The Washi11v1011Post newspaper in the
U.S. District Comt for the District of Columbia. The lawsuit was based upon statements made to
plaintiff bv Judge Niemever that allegedlv reset the statute of limitations a!!ainst the U.S. DOJ
for declining to prosecute the copvright case actors in 2004-6 for non-allowed reasons. The D.C.
court dismissed the case in summer 2012. all the while refusing to acknowledge plaintiffs
evidence regarding his meetins<s with Juds<e Niemeyer.
I I 0. Not backing down. in Aus<ust ?OI 2. plaintiff came ri)!ht back to Judge Motz in the
''Bromwell" case and filed a new rec_usalmotion. including. in detail. the information gained
19
from Judg_eNicmeyer. This time the Maryland U.S. Attomev's Office was silent.
111. Again. nol only did Judge Motz not answer the newly-learned rccusal issues. he airnin
neglected to reveal his past conduct against plaintiff in the earlier described Marvland state
lawsuit.
112. In late ?OI? and t,arly ?OJ3. plaintiff complained about the above-mentioned iudicial
disabilities to the Chief Judec of the U.S. Fourth Circuit. who returned the complaint to plaintiff.
8
' ~Please see: Exhibits nos.: 14. 15. & 16: the memorandum. pages 12-13, and the affidavit. at
docket no. 239 in 01-cv-2600-MJG (D. Md.), and the motion to recuse filed in Fourth Circuit
case no.: 14-6017.
19
~ Please see. again: Exhibit nos.: 14, 15. & 16.
37
JA356
and to U.S. Senator Barbara Mikulski. who referred the matte_rto U.S. DOJ. where it died in a
113. Plaintiffs decision to publiclv protest what he believed to be long term corruption at the
Baltimore U.S. Courthouse in ?013 was no lightly undertaken matter, but one considered after
some then-12-vears-of-non-stop litigation where plaimiffs inability to recover his own propertv
114. The motive in this long story is simple. Judge Garbis set out to protect his old classmate.
115. Jud~arbis' conduct. by stating in his 2003 rccusal order that he knew. when assigned the
copy1ight case. information that was in none or the papers filed. would strongly suggest that the
assignment or the case to Judge Garbis was not random. Later. information not provided by
Judge Garbis at assignment. or immediatelv when it should have been at the TRO hearing,
showed that Judge Garbis and Mcssennan had a long-term. very close relationship. Clearly, the
issues Messerman was racing in 7001 were not just some little annovance. but one where his
previously made to plaintiff. And clearlv. Judge Garbis went far outside of the copvright issues
pending criminal and custody cases. which was eerily like the tact Messerman had used with
people. associated by an 8-member 1961 graduate law school program. come together at the
38
JA357
exact moment in time that Messerman souzht the exact help he needed to save his reputation.
Not only is this coincidence implausible. given all the facts listed above, it would be implausible
to suggest anything but that the copvri£ht case was defiled.
116. Judge Garbis clearlv spread negative opinions about plaintiff to others. opinions he had
conversations before the copyrizht case was filed. so as to make sure no judge in the Baltimore
U.S. Courthouse would give him anv benefit of the doubt.
117. While it is not known why. Judge Motz and Judge Niemeyer joined Judge Garbis. and
together they eviscerated plaintiffs rights under 28 U.S.C. 144 & 455. Fut1her. the individual
and collected acts by these defendants 20 far from simple ethics violations and become. by their
length and stubbornness, violations of plaintiffs constitutional rights to due process and his own
propertv. and in the process. became an actual. albeit unstated. Bill of Attainder put upon
plaintiffs head by the defendants.
118. Plaintiff has been forced to live with the stress and strain of litiirntion going on now 16
vears because of the defendants' i lle2al and unconstitutional acts. During these 16 years. plaintiff
has lost two homes. all his money. all his personal property. two prized & beloved pets. his wife.
his step-children. most if not all his friends & neighbors. his physical health. has been subiected
to gross scorn and ridicule. and the prime years of his middle-age have been consumed bv
interests that should have been resolved Ion£ ago except for malice and hatred toward him by the
defendants.
39
JA358
119. These intentional, knowing, bad-faith, unfair, and illegalwron° acts by the defendants have
caused plaintiff great worry, anxiety, fear, sleeplessness, large financial losses. etc., amongst
many other things, as it was clear to plaintiff that his enemiestbe federal officials who had
wronged him would stop at nothing to defeat his constitutional rights. In addition, plaintiff has
had his reputation absolutely destroyed by the defendants' imperturbable and unconstitutional
long-;term treatment of him.
120. Judge Garbis, by all that has been learnell. should have immediately r~cused himself from
the copyright case in 2001. and at all times afterward. because of his connection to Messennan.
}\'filC.b..be
still has never fullv disclosed. Why Judge Garbis involved Judges Motz & Nieme~
unknown. But. clearly. plaintiff has been procedurally blocked al every turn since )()01. with not
decisions recounted in this complaint. when taken together. su2gest an aggregate of acts that
121. And as defendant DUSM Frederick said in Count I of this complaint. the "Bromwell" case
was the "domino·· that could knock over all the other ''dominos,'' i.e., expose all the unethical
rulings against plaintiff. Therefore, the defendants, now greatly worried by plaintiffs 'White
Baltimore U.S. Courthouse - iust days away at the time - had great & plausible motive to seek
40
JA359
plaintiffs wrongful & illeirnl arrest to prevent same at all costs.
122. Fu11her, it doesn't matter that the defendants were unable to arrest plaintiff on .lulv 30.
?013. What matters is that thev tried. Just as they tried and succeeded in dilutine plaintiffs
demonstration plannine and to curb the robustness of his speech/protest and execution. Clearlv.
their reasons were that thev were trving to make plaintiffs planned demonstrations eo away bv
any means possible. By any means.
123. Wherefore, for the aforementioned illegalwron;efu] & unconstitutional conduct, plaintiff
seeks, $~20,000,000 from the defendants for compensatory damages, and $+§10,000,000 from
the defendants for punitive damages.
Civil rights actions are t&-be-given preference in the Fourth Circuit. Because of the great length
of time these matters have continuedc and the great harm caused plaintiff, a1-1dthe exige1-1tharm
still existi1-1gfor the ge1-1eralp1c1blie,plaintiff Feq1c1estsprays

that this court issue an expedited
briefing schedule in this case as soon as possible.
DEMAND FOR A .JURY TRIAL
41
JA360
WILLIAM C. BOND
Pro Se
P.O. Box 4823
Baltimore, Maryland 2 I 2 I I
(443) 970-2887
42
JA361

WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
*
Defendants.
*
* * * * * * * * * * * * *
DEFENDANTS’ OPPOSITION TO PLAINTIFF’S SECOND MOTION TO REOPEN

CASE AND TO FILE AN AMENDED COMPLAINT
Defendants, Johnny L. Hughes, Kevin Perkins, and Rod J. Rosenstein, submit this
Opposition to Plaintiff’s Motion to Reopen Case and to File an Amended Complaint.
I. INTRODUCTION
The Court dismissed Plaintiff’s Complaint for “civil rights relief” on April 12, 2017 (ECF
Nos. 22, 23), and the Court further dismissed Plaintiff’s first Motion to Re-Open and file an
Amended Complaint on May 23, 2017. (ECF No. 25). Plaintiff again seeks to re-open this case
amend his Complaint to, among other things, identify the federal agents who allegedly violated his
civil rights, and who were not named in the original Complaint. 1 As explained below, the Court
should deny Plaintiff’s second Motion as the amendment would be futile.
1
A federal employee who has been sued in his individual capacity has a right to be represented by
private counsel, or may request representation from the United States in accordance with the
guidelines found in 28 C.F.R. §§ 50.15, 50.16. Because plaintiff is now seeking to add new federal
employees, but has not yet been permitted to do so, no representational requests have been
submitted, and the undersigned is not appearing on behalf of the newly-identified defendants.
Further, any arguments made herein should not prejudice the newly-named defendants from
making any arguments if the amendment is allowed and once they are served.
1
JA362
II. FACTUAL AND PROCEDURAL BACKGROUND
For several years, Plaintiff has engaged in protests against what he claims to be “‘provable
corruption’ in the Baltimore U.S. courthouse….” (ECF No. 26-2 ¶ 2). As a result of his protests
and allegations of corruption, Plaintiff alleges that he has been interviewed and surveilled by
federal agents. Specifically, Plaintiff’s proposed amended complaint alleges the following
unconstitutional acts:
• Count I – On July 19, 2013 and July 30, 2013, Deputy United States Marshal
Robert Frederick (“DUSM Frederick”) and FBI Special Agent Chris Wood, and
FBI Supervisory Special Agent Patrick Dugan questioned plaintiff “regarding
the potential safety of various government officials and federal judges,” in an
attempt to “prevent and/or to intimidate plaintiff’s planned demonstrations . . .
.” (Id. ¶¶ 14-33.)
• Counts III (second count) – Plaintiff alleges in the fall of 2013, DUSM
Frederick informed him that he had been under surveillance since 2010.
Plaintiff alleges that this surveillance violated his constitutional rights. (Id.
¶¶ 51-58.)
With respect to each count, Plaintiff alleges that “[t]hese intentional, knowing, bad-faith, and
illegal acts by the defendants caused plaintiff great worry, anxiety, fear, sleeplessness, etc.,
amongst many other things, as it was clear to plaintiff that his enemies would stop at nothing to
defeat his constitutional rights.” (See, e.g., id. ¶ 42.)
Count VI (third count) of Plaintiff’s proposed amendment alleges constitutional violations
committed by members of the judiciary. Those claims are not discussed in this Opposition.
A. Standard for Amending the Complaint
A district court may not grant a post-judgment motion to amend a complaint unless the
judgment is set aside or vacated pursuant to Fed. R. Civ. P. 59(e) or 60(b). Laber v. Harvey, 438
F.3d 404, 427 (4th Cir. 2006) (en banc) (internal quotation marks omitted). The Fourth Circuit
JA363
has indicated that “a post-judgment motion to amend is evaluated under the same legal standard
as a similar motion filed before judgment was entered – for prejudice, bad faith, or futility.” Id.;
see also Katyle v. Penn Nat’l Gaming, Inc., 637 F.3d 462, 471 (4th Cir. 2011) (in determining
whether to vacate a judgment in the face of a proposed amendment, the court need not focus on
the legal standards of Rules 59(e) or 60(b), but rather only on Rule 15(a)). As explained below,
the Court should not allow Plaintiff to amend his Complaint, as any amendment would be futile.
B. 12(b)(6)
As explained below, Plaintiff’s Motion is futile as it would not survive a 12(b)(6) motion
to dismiss, if filed. Thus, the 12(b)(6) standard of review is provided herein. A motion under Rule
12(b)(6) challenges the legal sufficiency of a complaint. See Edwards v. Goldsboro, 178 F.3d 231,
243 (4th Cir. 1999). To survive a Rule 12(b)(6) motion, the complaint must assert facts sufficient
to “state a claim to relief that is plausible on its face.” Bell Atlantic v. Twombly, 550 U.S. 544, 570
(2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the
court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”
Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “But where the well-pleaded facts do not permit the
court to infer more than the mere possibility of misconduct, the complaint has alleged-but it has
not ‘show[n] – ‘that the pleader is entitled to relief.’” Id. at 679 (quoting FED. R. CIV. P. 8(a)(2)).
IV. ARGUMENT
A. Plaintiff lacks standing to bring a First Amendment claim.
The Defendants previously argued, and the Court held, that Plaintiff lacked standing to
bring a First Amendment claim. (ECF No. 16-1 at 7-8); (ECF No. 22 at 15-17). Specifically, the
Court held as follows:
Under Fourth Circuit jurisprudence, an indispensable element of standing for

purposes of First Amendment claims is that a plaintiff must demonstrate some
JA364
injury-in-fact. “In First Amendment cases, the injury-in-fact element is commonly

satisfied by a sufficient showing of ‘self-censorship, which occurs when a claimant
is chilled from exercising h[is] right to free expression.’” Cooksey v. Futrell, 721
F.3d 226, 235 (4th Cir. 2013) (citations omitted). In that context, “the chilling effect
cannot ‘arise merely from the individual’s knowledge that a governmental agency
was engaged in certain activities or from the individual’s concomitant fear that,
armed with the fruit of those activities, the agency might in the future take some
other and additional action detrimental to that individual.’” Id. at 236 (quoting Laird
v. Tatum, 408 U.S. 1, 11 (1972)). Indeed, the Fourth Circuit impresses upon us that
“‘[a]llegations of a subjective ‘chill’ are not an adequate substitute for a claim of
specific present objective harm or a threat of specific future harm [.]’” Cooksey,
721 F.3d at 236 (quoting Laird, 408 U.S. at 13-14).
* * *
Plaintiff has furnished this court with no evidence of a chilling effect on his
speech. Plaintiff does not seriously contest that the reason for the interviews was
concern about the safety of federal judges and other government officials due to
Plaintiff’s communications with them. See Doc. No. 1. However, never does
Plaintiff allege that the agents forbade him from protesting nor did they take any
actions to prevent the protests. Other than Plaintiff’s own speculation that the
interviews were for the purpose of preventing him from protesting, he provides no
evidence that his speech was chilled or that he self-censored himself. He certainly
did not do the latter. Quite the contrary, Plaintiff appears to admit that subsequently
he protested for several weeks. See Doc. No. 1. There is no allegation whatsoever
that any of the named Defendants did anything at all to restrict Plaintiff’s First
Amendment rights.
(ECF No. 22 at 15-17). This analysis has not been affected by the proposed amendment. As the
Court previously highlighted, Plaintiff engaged in protests following his questioning by federal
agents, and the proposed amendment does not otherwise provide any evidence of self-censorship.
To the contrary, Plaintiff’s proposed Count III (second count) begins with, “[t]he protests began
on August 4, 2013.” (ECF No. 26-2 ¶ 44). Thus, Plaintiff’s renewed First Amendment claim fails
for the same reasons as his original claim, and the proposed amendment should be denied as futile.
JA365
B. Plaintiff’s proposed amended complaint fails to state a due process claim.
Defendants further argued, and the Court further concluded, that Plaintiff’s original
Complaint failed to state a due process violation. (ECF No. 16-1 at 8); (ECF No. 22 at 17-25). In
its holding, the Court stated as follows:
Plaintiff’s Count I must be dismissed for both Rule 12(b)(6) and Rule
8(a)(2) deficiencies. With respect to Rule 12(b)(6), Plaintiff fails to state a claim
upon which relief can be granted because Plaintiff quite simply states no claim. He
refers vaguely to blanket “constitutional rights” at one point but no more. Doc. No.
1. Moreover, whether a complaint must be dismissed for failure to state a claim
“depends on whether the allegations in the complaint suffice to establish [a
requisite] ground, not on the nature of the ground in the abstract.” Jones, 549 U.S.
at 215 (emphasis added). Neither in the abstract nor in the allegations contained in
the Complaint has Plaintiff stated a claim on whose basis relief might be available.
This brings the court to the Rule 8(a)(2) deficiency: “a pleading must
contain a ‘short and plain statement of the claim showing that the pleader is entitled
to relief.’” Iqbal, 556 U.S. at 677-78 (citing Federal Rule of Civil Procedure
8(a)(2)). Here, “the allegations are conclusory and not entitled to be assumed true.”
Iqbal, 556 U.S. at 681. The alleged law enforcement visits might have been
supported with ample probable cause and/or compelling governmental interests, not
necessarily conducted, if conducted they were, with the goal of intimidating
Plaintiff (as he alleges). See Doc. No. 1. The Complaint is speculative and it glosses
over that legitimate possibility. Just like in Ashcroft, Plaintiff’s omission as to the
reasons impelling the alleged governmental conduct render his complain deficient.
556 U.S. at 680-81.
Furthermore, if there exist “more likely explanations [for alleged defendant

actions or omissions],” then “the[] [conduct alleged] do[es] not plausibly establish
th[e] purpose[s],” motives and/or reasons that a plaintiff alleges guided the
defendant(s). Id. at 681. Here it is more likely that Defendants visited Plaintiff
and/or sought to arrest him because of bona fide and perfectly lawful concerns
about illegal conduct on Plaintiff’s part, rather than any retaliation Defendants
wanted to inflict on Plaintiff. Accordingly, Count I is dismissed for both Rule
12(b)(6) and Rule 8(a)(2) deficiencies.
* * *
Count III: Plaintiff alleges that a deputy U.S. marshal (DUSM) was
“spy[ing]” on Plaintiff since Plaintiff filed a similar suit against the U.S. Attorney
for the District of Maryland in 2010. Doc. No. 1. Here, Plaintiff mentions due
process as the basis for Count III. However, it is the Fourth Amendment, instead of
due process, that is the appropriate basis for challenging governmental acts of
JA366
surveillance. “Substantive due process analysis is . . . inappropriate in . . . [a] case

only if . . . [a] claim is covered by the Fourth Amendment.” Lewis, 523 U.S. at 843;
see also Katz v. United States, 389 U.S. 347 (1967); Klayman v. Obama, 957 F.
Supp. 2d 1 (D.D.C. 2013). Thus, Count III does not survive the standard required
by Rule 12(b)(6).
In addition, once again Plaintiff states only “conclusory” allegations that are
grounded solely in conjecture and speculation without any basis in fact. Ashcroft,
556 U.S. at 681. This is quite like the court’s aforementioned observations
concerning Counts I and II. Count III thus falls short of satisfying Rule 8(a)(2) as
well. Count III must be dismissed on account of both Rule 12(b)(6) and Rule 8(a)(2)
deficiencies.
(ECF No. 22 at 20-23). Plaintiff’s proposed amended complaint suffers from the same deficiencies
identified above. Regarding Count I, Plaintiff adds new details regarding the substance of his
conversations with the federal agents, and he identifies the federal agents, but the proposed
amendment does not offer any evidence that the questioning was unlawful. Regarding Count III,
Plaintiff’s proposed amended complaint does not offer any evidence of unlawful surveillance.
Plaintiff continues to allege unconstitutional “spy[ing],” but only in conclusory statements. Thus,
Plaintiff’s proposed amended complaint would fail for the same reasons that his original Complaint
failed, and the Court should deny Plaintiff’s Motion on futility grounds.
C. Plaintiff has failed to state a claim for a Second Amendment violation.
Plaintiff lists the Second Amendment in one of the opening lines of his proposed amended
complaint, but he does not otherwise articulate a Second Amendment claim. (ECF 26-2 at 2). The
Second Amendment protects “the right of law-abiding, responsible citizens to use arms in defense
of hearth and home.” District of Columbia v. Heller, 554 U.S. 570, 634-35 (2008). Federal agents
allegedly questioned Plaintiff about firearms; however, this questioning does not amount to a
Second Amendment violation. Further, Plaintiff admits that his firearms were confiscated in a
2001 criminal action by the State of Maryland.
JA367
V. CONCLUSION
WHEREFORE, Defendants respectfully request that the Court deny Plaintiff’s Motion to
Reopen case and to File an Amended Complaint.
Stephen M. Schenning
Acting United States Attorney
_________/s/____________________
(410) 209-4800
I HEREBY CERTIFY that on this 5th day of July, 2017, I filed the foregoing using the
CM/ECF system and also served a copy on Plaintiff via first-class mail to the following:
William C. Bond
PO Box 4823
Baltimore, MD 21211
__________/s/_____________________
Matthew P. Phelps
JA368

WILLIAM C. BOND, *
Plaintiff, *
v. * Case No.: 1:16-cv-02723-DAF
*
Defendants.
*
* * * * * * * * * * * * *
PROPOSED ORDER
Upon consideration of Plaintiff’s Second Motion to Reopen Case and to File an Amended
Complaint, and the Defendants’ Opposition thereto, and any further reply, it is this __ day of
_______________, 2017 hereby ORDERED that the Motion is DENIED.
__________________________________
JA369
FILE@
1JS. DISTRICT
COURT
lllSTRICTOFMARYi.ANO
JUL19 PM12:38
2017
IN THE UNITED ST ATES DISTRICT COURT CLERK'SQFF1GE
FOR THE DISTRICT OF MARYLAND AT/BALTIHORE
NORTHERN DIVISION BY "JA,/1- ~EPU!Y
WILLIAM C. BOND, *
Plaintiff pro se, *
*
*
Defendants.
*
* * * * * * * * *
PLAINTIFF'S REPLY TO THE DEFENDANTS' OPPOSITION TO PLAINTIFF'S

SECOND (2nd) MOTION TO REOPEN CASE AND TO FILE A SECOND {2 )
nd
AMENDED COMPLAINT
I. INTRODUCTION
• What is this case about?
• This case is about an Article III judge and his "miraculous assignment" to
plaintiffs underlying 2001 copyright case, which the judge planned to sabotage
either before assignment or directly afterward. 1
• This case is about another Article III judge - an appellate judge - who told
plaintiff in person in 2010 that "if you don't stop [your litigations], you will be
destroyed," amongst many other things. 2
• This case is about a third Article III judge - a judge who controlled the Maryland
district court's assignments in 2001 - who forbade a lawyer whom he had control
1
Please see: Count VI in the proposed second amended complaint (docket 26-2),
especially'!l'll 81, 96, 97,115,116,120, & 121.
2
Please see: Count VI in the proposed second amended complaint (docket 26-2),
especially'l['l[ 107,108,110,117, & 121.
JA370
3
over from settling plaintiff's claims in an independent Maryland state lawsuit.
• This case is about how the Maryland U.S. Attorney's Office extensively
criminally investigated the allegations underlying Count VI of this complaint
from 2004-2006 only to decline prosecution, which its former Criminal Chief
later admitted was neither an "easy or quick decision." 4
• This case is about how plaintiff has suffered through some 16 years of litigation
because the now named judicial & government officers clearly felt free to
discriminate against plaintiff under the guise of his now three-plus-decades-old
juvenile record and/or a more than fifteen-year-old expunged adult charge that
was soundly defeated, but - in clear fact - they only did so because of unethical &
hidden personal interests; and how plaintiff's allegations have never once seen a
scintilla of substantive examination in the civil arena.
II. THE GOVERNMENT'S OPPOSITION
The government has twice now put this court in an inappropriate and awkward position - first,
by not defending at all plaintiff's first motion to amend his complaint, and now by its opposition
to plaintiff's second motion to amend wherein it explicitly tells the court that it will not discuss
plaintiff's Count VI. Clearly, the government lawyers wish for the court to do their job for them
regarding Count VI. But, were the court to act in place of counsel and on behalf of the newly
named and still unserved defendants, the entire reason for the district court's recusal in whole
and for the personal and special assignment of this court to this very case would be turned upon
its head, i.e., to prevent the appearance of 'judges protecting judges. ' 5
3
Please see: Counts I & VI in the proposed second amended complaint (docket 26-2),
especially 'l]'l] 30, 88, 89, 99, 110, 110, 117, & 121.
4
Please see: The 'Conclusion' to this paper, especially Exhibit No.: 8, an email from
Barbara S. Sale, Chief, Criminal Division, USAO MD.
5
Please see: Exhibit no.: I, U.S. Fourth Circuit Chief Judge Gregory's special
assignment order that was entered in this case at docket entry number 4.
2
JA371
To be clear, the government cannot possibly be asking this court to assume the defense of the
judicial defendants because to do so would create grave "appearance" questions for the public -
such as why are the merits of these allegations against Article III judges not being tested? Surely,
as well, the government cannot possibly be proposing that the court should open itself up to such
obvious public questioning for no reason, especially when the Supreme Court has offered its
precise guidance many times. "What matters is not the reality of bias or prejudice but its
appearance." Liteky v. United States, 510 U.S. 540,548 (1994).
Otherwise, the government's opposition dwells upon and quotes extensively from the court's
original memorandum that was based upon plaintiffs original complaint, which is now rendered
moot by his dramatically different and factually enhanced proposed second amended complaint.
Plaintiff will not spend any additional time on the government's opposition except to state that
one important and unwanted prejudice against plaintiff must again be objected to and confronted:
the absurd idea that the government had any reason to threaten and intimidate plaintiff in the first
place in July 2013, because of plaintiffs planned Baltimore U.S. courthouse demonstrations.
Why the court bought into the government's outside-of-the-complaint affirmative statement that
"The underlying basis for the interviews was concern about the safety of federal judges and other
government officials due to Plaintiffs communications with them" (docket 16 at 7) is beyond
plaintiffs understanding. But now that the government again brings this issue back up in its
opposition (docket 27 at 4) by quoting the court's earlier opinion (docket 22 at 15-17), plaintiff
has the right to call this allowed tactic for what it is - outright discrimination against plaintiff
JA372
based upon a three-plus-decades-old juvenile record and/or a more than fifteen-year-old
expunged adult charge that was soundly defeated. Not only does the government not possess one
conceivable 'threat' made by plaintiff against any public official, should it claim to have one, it
should have been produced to the court in its opposition.
Plaintiff respectfully requests that the court strike the government's reckless & unsupported
statement about plaintiff, which it has repeated, as just described.
III. PLAINTIFF'S SECOND AMENDED COMPLAINT IS PLAUSIBLE -AND INDEED

TRUE
The U.S. Marshals Service's own policy directives 6 preclude its protective intelligence officers
from being misused to violate citizens' first amendment rights, yet that is exactly what Maryland
judicial officers did to attempt to defeat plaintiffs planned demonstrations at the Baltimore U.S.
courthouse beginning in August 2013. And when their initial efforts failed, the proposed
defendants then attempted to have plaintiff arrested for gun charges based upon information that
the government knew was wrong. These acts greatly scared plaintiff and chilled his conduct at a
critical & irreplaceable point in time. This chilling of plaintiff made his protests not as robust as
7
they could and would have been without the government's interference.
6
Please see, again: Exhibit no.: 7, attached to the proposed second amended complaint.
(See docket entry number 26-2 at 'I[32.)
7
This court must note under an Erickson v. Pardus, 551 U.S. 89, 94 (2007) analysis, i.e.,
"All pleadings shall be so construed as to do substantial justice," that plaintiff clearly, in now
deleted Count II, stated that he relied upon two persons who did not supply the "bodies" needed
to obtain the major media attention needed to publicize what he saw as broken and corrupt at the
Baltimore U.S. courthouse. Certainly, as plaintiff has argued in his proposed second amended
complaint at'l['I[35, 36, & 122, if not other places, his concentration and judgment was greatly
4
JA373
Underlying this entire case are fundamental due process & First Amendment violations - the
"miraculous assignment" of Judge Garbis to the 2001 copyright case. Clearly, in summer 2001,
Messerman knew the 'copyright case' was coming. (See docket 26-2 at 'lI73.) And Messerman
knew he was in trouble:
I 15. Judge Garbis' conduct, by stating in his 2003 recusal order

that he knew, when assigned the copyright case, information that
was in none of the papers filed, would strongly suggest that the
assignment of the case to Judge Garbis was not random. Later,
information not provided by Judge Garbis at assignment, or
immediately when it should have been at the TRO hearing, showed
that Judge Garbis and Messerman had a long-term, very close
relationship. Clearly, the issues Messerman was facing in 2001
were not just some little annoyance, but one where his entire
reputational life was on the line because of the false and wrong
misrepresentations he had previously made to plaintiff. And
clearly, Judge Garbis went far outside of the copyright issues in his
order to assure that plaintiff's unpublished manuscript would be
used against him in the pending criminal and custody cases, which
was eerily like the tact Messerman had used with Karcesk:i.
Finally, Ohio and Maryland have some 18 million people
combined, and yet two people, associated by an 8-member 1961
graduate law school program, come together at the exact moment
in time that Messerman sought the exact help he needed to save his
reputation. Not only is this coincidence implausible, given all the
facts listed above, it would be implausible to suggest anything but
that the copyright case was defiled. (See docket 26-2 at 'lI I 15.)
(Emphasis added.)
Importantly, as just stated, the 200 I copyright complaint made no mention of Messerman. 8
distracted by the government's illegal visits to intimidate his protests. Therefore, it is clearly
plausible that plaintiff may not have relied upon these two persons in the way he did without the
government's interference.
8
Please see: Exhibit No.: 2, plaintiffs copyright complaint filed August 29, 2001, in case
number 0l-cv-2600-MJG (D. Md.).
5
JA374
Therefore, there are only two ways Judge Garbis could possibly have learned ofMesserrnan's
involvement in the copyright case at assignment: (1) Messerrnan had called his good friend
Judge Garbis and discussed plaintiff with him before the copyright case was filed or, (2)
immediately after the case was assigned to Judge Garbis, Messerman called Judge Garbis and
discussed plaintiff with him. Either way, Judge Garbis should have immediately disclosed these
contacts and recused himself from the case. But, instead, Judge Garbis covered up his actions
and obfuscated the Messerman information many times over many years of questioning.
These uninvited acts by Judge Garbis, in addition to what plaintiff describes in Count VI, created
a situation where plaintiffs absolute First Amendment rights to first publication and to first
publicity regarding his unpublished manuscript were stolen by and/or greatly affected by Judge
Garbis' misconduct.
Therefore, the continuing nature of the theft of plaintiffs manuscript and its due process & First
Amendment implications pervade all that the judicial defendants did in 2013 to seek to stop
and/or manipulate plaintiffs protests. 9
The judicial defendants knew plaintiff was getting close, that he was closing in, that important
people were talking about his dramatic ads in the newspaper and on the internet, and that with
one more - media - fuse lit that plaintiff could expose their alleged corruption.
9
Please see, again: Count VI in the proposed second amended complaint (docket 26-2) at
'l]'l] 120 & 121.
6
JA375
Importantly, this alleged judicial corruption is not covered by immunity, both because the acts
involved numerous ex parte contacts and because it just is not part of any Article III judge's job
to conspire with U.S. Marshals Service & FBI employees to thwart attacks upon their own
personal reputations.
Plaintiff is entitled to a complete merits test and substantive merits review of the 16 years of
abuse he has suffered at the hands of the proposed defendants.
IV. PLAINTIFF'S SECOND AMENDED COMPLAINT IS LEGALLY SOUND
A. Count I
The court in its controlling memorandum (docket 22 at 14-15) challenged plaintiffs First
Amendment standing under FRCP 8 & 12. Further, the court stated:
Under Fourth Circuit jurisprudence, an indispensable element of

standing for purposes of First Amendment claims is that a
plaintiff must demonstrate some injury-in-fact. "In First
Amendment cases, the injury-in-fact element is commonly
satisfied by a sufficient showing of 'self-censorship, which occurs
when a claimant is chilled from exercising h[is] right to free
expression."' Cooksey v. Futrell, 721 F.3d 226, 235 (4th Cir.
2013) (citations omitted). In that context, "the chilling effect
cannot 'arise merely from the individual's knowledge that a
governmental agency was engaged in certain activities or from the
individual's concomitant fear that, armed with the fruit of those
activities, the agency might in the future take some other and
additional action detrimental to that individual."' Id. at 236
(quoting Laird v. Tatum, 408 U.S. I, 11 (1972)). Indeed, the
Fourth Circuit impresses upon us that '"[a]llegations ofa
subjective 'chill' are not an adequate substitute for a claim of
specific present objective harm or a threat of specific future
harm[.]'" Cooksey. 721 F.3d at 236 (quoting Laird, 408 U.S. at
JA376
13-14). (Emphasisadded.)
Plaintiff has met the court's challenge in the following ways:
1. In 'l['I[35, 36, & 122 of the proposed second amended complaint, plaintiff discusses his injuries.
2. In 'I[ 28 of the proposed second amended complaint, the government's talk of"settlement" is a
clear indication of its intent to violate plaintiffs First Amendment rights, as that act has no
legitimate law enforcement purpose.
28. Again, as FBI Special Agent Wood had earlier asked, FBI
Supervisory Special Agent Dugan asked - holding some of
plaintiffs 'White Guerrilla Family' promotional literature in his
hand - "What would it take to make this [the planned
demonstrations] go away?" (Emphasis added.)
3. Likewise, that the government came back for a second visit is fatal to the government's
position.
4. The manufactured and illegal reasons to attempt to arrest and intimidate plaintiff for gun
possession had a clear intent to violate plaintiffs First Amendment rights, i.e., by taking away
his physical freedom to prevent the planned protests.
5. Clearly, plaintiffs allegations at ,i 47 of the proposed second amended complaint are a threat
JA377
of specific future harm:
47. DUSM Frederick continued to probe plaintiff regarding his

alleged possession of illegal guns and wondered if plaintiff had any
guns "buried." At one protest in early fall 2013, DUSM Frederick
told plaintiff about a conversation he had just had with Agent
Dugan. Agent Dugan had "asked [him] ifwe need to have the
[FBI] SWAT Team come and arrest Bill [plaintiff]?" He then
recited more of the conversation he had with Agent Dugan as to
whether plaintiff "would survive a night in Central Booking
[Baltimore City Jail]?"
6. Likewise, the~ 41 threat of investigation of plaintiffs purported gun possession with
plaintiffs ex-wife so as to effectuate an arrest of plaintiff before his first planned protest on
August 4, 2013, certainly speaks to "specific future harrn."
7. Finally, the illegal and invented basis to attempt to arrest plaintiff for illegal gun possession is
also a de facto 2nd Amendment violation.
B. Count III
The court in its memorandum (docket 22 at 22-23) also misunderstood plaintiffs due process
claim - that the government, by surveilling plaintiff while several times opposing plaintiff in
federal litigations, was violating plaintiffs due process rights. Plaintiff can find no case citation
dealing with this specific subject.
JA378
The court then claimed that plaintiffs claims in Count III were actually 4 th Amendment claims
that he had not properly pleaded:
However, it is the Fourth Amendment, instead of due process, that

is the appropriate basis for challenging governmental acts of
surveillance. "Substantive due process analysis is ... inappropriate
in ... [a] case only if ... [a] claim is covered by the Fourth
Amendment." Lewis, 523 U.S. at 843; see also Katz v. United
States, 389 U.S. 347 (1967); Klayman v. Obama, 957 F. Supp. 2d
1 (D.D.C. 2013). Thus, Count III does not survive the standard
required by Rule 12(b)(6).
Plaintiff has met the court's challenge in the following ways:
& 55 of the proposed second amended complaint, plaintiff discusses the federal court
1. In '11'1154
rules violations and due process violations against plaintiff by the government.
2. In '1156of the proposed second amended complaint plaintiff lists his 4 th Amendment damages:
that because of"this admitted governmental surveillance of plaintiff, plaintiff was forced to limit
and curtail the freedom of his expression to others via the telephone, the internet, and by other
means, from 2013 forward."
3. Finally, it simply was premature for the court to have concluded that the government's
admitted 4 th Amendment violations and admitted invasion of plaintiffs privacy were kosher and
legal when no search warrant had been examined, when no search warrant 'probable cause'
affidavit had been examined, and when the signing judge or judges of the long-term warrants are
IO
JA379
still unknown, including the 'scope' of those warrants. It is the government who freely admitted
to these violations. Plaintiff has the right under both United States v. Jones, 132 S. Ct. 945
(2012) and Katz v. United States, 389 U.S. 347 (1967) to see whether the government complied
with the law before the court dismissed Count III.
C. Count VI
The government has defaulted in opposing Count VI. Therefore, plaintiff refers the court to his
conclusion in his second memorandum to reopen (docket 26-1 at 11-13) and to Count VI in the
proposed second amended complaint (docket 26-2 at 'l['l[59-123) and only adds the following:
1. The harms committed against plaintiffs property and due process rights are continuing and
not abandoned.
2. The judicial defendants are not immune from the alleged acts.
3. As stated above in Part III: There are only two ways Judge Garbis could possibly have learned
ofMesserman's involvement in the copyright case at assignment: (1) Messerman had called his
good friend Judge Garbis and discussed plaintiff with him before the copyright case was filed or,
(2) immediately after the case was assigned to Judge Garbis, Messerman called Judge Garbis and
discussed plaintiff with him. Either way, Judge Garbis should have immediately disclosed these
contacts and recused himself from the case. But, instead, Judge Garbis covered up his actions
and obfuscated the Messerman information many times over many years of questioning.
11
JA380
V. CONCLUSION
The government wrongly pleads to this court that plaintiffs proposed second amended complaint
is "futile" when the government itself is in possession of much information such as the attached
10
emails to and from its former Chief, Criminal Division, Barbara S. Sale. The government well-
knows that plaintiff's complaints as recounted in Count VI are not only plausible, but deserve to
be taken seriously. Likewise, there is no way the court can read these emails and then try to
imagine plaintiff ever threatening any government official.
For the foregoing reasons, plaintiff respectfully requests that the court vacate its earlier orders at
docket entry numbers 22 & 23, reopen this case, and accept plaintiff's Second Amended
Complaint as filed.
Plaintiff respectfully requests that the court order the newly named defendants substituted and/or
served. 11 And it is only right that any defense of this action comes from them, not the court, and
is based upon the merits.
Finally, plaintiff respectfully requests that the court establish a scheduling and discovery order.
10
Please see: Exhibit nos.: 3-12, a series of 2004-2006 emails to and from the USAO
MD's Chief, Criminal Division, Barbara S. Sale regarding the office's criminal investigation into
the matters underlying Count VJ in the second amended complaint. These emails were earlier
entered in 07-cv-01188-WDQ (D. Md.) at docket entry number 15. (Please note: plaintiff's
private email address has been redacted, but Mrs. Sale's has not because she no longer works at
U.S. DOJ and the referenced email address for her is now inactive.)
11
The Clerk's Office has summonses and copies of the second amended complaint for all
five (5) proposed newly named defendants.
12
JA381
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
prose Iitigator@aol.com
I HEREBY CERTIFY that on the 19th day of July 2017, copies of PLAINTIFF'S REPLY TO
THE DEFENDANTS' OPPOSITION TO PLAINTIFF'S SECOND (2nd) MOTION TO
REOPEN CASE AND TO FILE A SECOND (2 nd) AMENDED COMPLAINT were served
by Email to: ALLEN F. LOUCKS, AUSA, U.S. Attorney's Office, District of Maryland, 36 S.
Charles St., 4 th Fl., Baltimore, Maryland 21201, allen.loucks@usdoj.gov; and to: MATTHEW
P. PHELPS, AUSA, U.S. Attorney's Office, District of Maryland, 36 S. Charles St., 4 th Fl.,
Baltimore, Maryland 21201, matthew.phelps@usdoj.gov; and by hand delivery to: CLERK,
United States District Court for the District of Maryland, Baltimore Division, 101 West Lombard
Street, Baltimore, Maryland 21201. The required judge's courtesy copy was also served by
FedEx Overnight Delivery, postage prepaid, to: Hon. DAVID A. FABER, Senior United States
District Judge, 2303 Elizabeth Kee Federal Building, 601 Federal Street, Bluefield, WV 24701.
WILLIAM C. BOND
13
JA382
•. Case 1:16-cv-02723-DAF Document 28-1 Filed 07/19/17 Page 1 of 3
EXHIBIT 1
JA383
Appeal:
; 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 389 of 424
Case1:16-cv-02723-DAF
Case 1:16-cv-02723-DAF Document
Document28-1
4 Filed 08/12/16
Filed 07/19/17 Page
Page12
ofof
23
'
FOR THE FOURTH CIRCUIT
Lewis F. Powell. Jr. United States Courthouse

I000 East Main Street
Suite 212
Richmond, Virginia 23219•3517
Chnmhersof
ROGER L. GREGORY Telephone (804) 916-2607
Chier Judge Fax (804) 916-3055
August 11, 2016
Honorable David A. Faber

Senior District Judge - SDWV
601 Federal Street
Bluefield, WV 24701
Re: Designation to the United States District Court

for the District of Maryland
William C. Bond v. Johnny L. Hughes et al.
No. l:16-cv-2723
Dear Judge Faber:
Enclosed is a Designation for you to sit with the

United States District Court for the District of Maryland.
The designation is made pursuant to 28 U.S.C. § 294(c) in
connection with the above-referenced case.
I very much appreciate your willingness to assist the

district court in this manner.
Sincerely,
cc: Honorable Catherine C. Blake, Chief District Judge-DMD

Honorable Robert C. Chambers, Chief District Judge-SDWV
Samuel Phillips, Circuit Executive
Patricia Connor, Clerk-4th Circuit
Felicia Cannon, Clerk-DMD
Teresa Deppner, Clerk-SDWV
JA384
Appeal:
• 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 390 of 424
Case1:16-cv-02723-DAF
Case 1:16-cv-02723-DAF Document
Document28-1
4 Filed 08/12/16
Filed 07/19/17 Page
Page23
of of
23
DESIGNATION OF A SENIOR UNITED STATES JUDGE

FOR SERVICE IN ANOTHER DISTRICT WITHIN THE CIRCUIT
WHEREAS, in my judgment the public interest so requires:
Now, therefore pursuant to the authority vested in me by Title
28, United States Code, Section 294 (c), I do hereby designate
and assign the Honorable David A. Faber, Senior United States
District Judge for the Southern District of West Virginia, to
hold a district court in the District of Maryland in the case of
William C. Bond v. Johnny L. Hughes et al., No. l:16-cv-2723,
filed July 29, 2016, and for such time as needed in advance to
prepare and thereafter as required to complete unfinished
business in the matter.
~0-Q,AB~7 .-'--7chief ud~e Y

Fourth Circuit
Dated ~lu.}u""'--'ldl".,_,,_:r""'-, ~\...:.\ __ , 2016
JA385
EXHIBIT2
JA386
FILED
· U.S. DISTR!L:LC.OURT
IN THE UNITED STATES DISIIllUffF C0'4.~'11YLAMD
NORTHERN DM~N\UG 29 p 3: / (i)
WILLIAM C. BOND * C!.~_F:(/·~·s

0:-::7ft::~·
4214 Greenway Af B/\LT/r/ORE-
BY -.DEPUTY
Baltimore, Maryland 21218-1134, *
Plaintiff *
v. *
KENNETH BLUM, SR. *
7 Halcyon Court
Pikesville, Maryland 21208 *
and *
KENNETH BLUM, JR. *
12639 Waterspout Court
Owings Mills, Maryland 21117 *
and *
DUDLEY F. B. HODGSON *
D. Hodgson Associates, Inc.
6210 Ebenezer Road *
*
and
*
WILLIAM SLAVIN
225 E. Montgomery Street *
*
and
*
McDANIEL, BENNETT & GRIFFIN
118 W. Mulberry Street *
Baltimore, Maryland 21201-3600
*
JA387
()
and *
ADELBERG, RUDOW, DORF & *

HENDLER, LLC
600 Mercantile Bank & Trust Building *
2 Hopkins Plaza
Baltimore, Maryland 21201-2927 *
and *
CHRISTOPHER W. NICHOLSON *
The Exchange, Suite 113
1122 Kenilworth Drive *
Towson, Maryland 21204-2141
*
Defendants
*
* * * * * * * * *
COMPLAINTFOR COPYRIGHTINFRINGEMENT
Now comes the Plaintiff, William C. Bond, by his attorneys, Howard J.
Schulman and Schulman & Kaufman, LLC, and states:
COUNT!
1. This is a civil action for copyright infringement brought under the copyright
laws of the United States, i.e., 17 U.S.C., §§ 501, et seq. Jurisdiction of this Court is
invoked pursuant to 28 U.S.C. §1338(a). Venue is proper in this Court pursuant to
28 U.S.C. §§139I(b),(c) and 1400(a).
2. Plaintiff is the owner and copyright holder of a manuscript andrelated
materials. The Register of Copyrights has issued a Certificate of Registration,
bearing the Registration No. TXu 991-583. A true and accurate copy of the
·2
JA388
------------------------------··--·----

registration certificate is attached hereto. The subject works contain material wholly
original with the Plaintiff that is copyrightable subject matter under the laws of the
United States. Plaintiff is currently and at all relevant times has been the sole
proprietor of all right, title and interest in and to the copyright in the subject works.
3. Plaintiff entrusted possession of the manuscript and related materials to his
attorney, Norman Pessin, who represented Plaintiff with regard to these works. The
copyrighted works were maintained, so Plaintiff understood, in Pessin's professional
files. On or about April 16, 2001, the Defendant Dudley F.V. Hodgson, who had
been retained and employed by the Defendant Kenneth Blum, Sr., went to the home
of Pessin's widow, Miriam Pessin, and took the copyrighted papers without Bond's
knowledge or authorization. The Defendant Hodgson made copies of the manuscript
and related papers and gave them to Defendant Kenneth Blum, Sr., who in tum,
distributed the copyrighted works to the other named Defendants in this action
without the knowledge or authorization of the Plaintiff.
4. The 1976CopyrightAct, 17U.S.C. §106etseq.,providesthatthe
copyright owner has the exclusive right in the copyrighted work, including the
exclusive right to reproduce, to create derivative works, to distribute, and to display
the copyrighted work to the public. The Act, 17 U.S.C. §50l(a), defines an
infringer:" [aJnyone who violates any of the exclusive rights of the copyright owner
as provided by sections 106 through [122] ... is an infringer of the copyright or right
of the author, as the case may be." A copyright owner, as provided in 17 U.S.C.,
JA389
()
§§502, 503, is entitled to injunctive relief to restrain the in.fiingemen

t of the
copyright and the impoundment and destruction of all copies of the copyr
ighted work
made or used in violation of the copyright owner's exclusive rights.
5. Defendant Hodgson's taking, copying and distributing of the copyr

ighted
works violates Plaintiff's exclusive right as the copyright owner.
6. Defendant Kenneth Blum's taking, copying and distributing of the
copyrighted works violates Plaintiff's exclusive right as the copyright

owner.
7. The other Defendants are also in.fiingers of the Plaintiff's exclusive
right as
a copyright owner, because they have possessed, displayed and used Plaint
iff's works
without his authorization or permission.
WHEREFORE, Plaintiff, William C. Bond, demands:
A. That this Court issue an injunction to restrain the Defendants from

further
infringement of the copyright; and
B. That the Court Order that all copies of the copyrighted works in the
possession of the Defendants or any other person to whom Defendants

have supplied
a copy of the copyrighted works be given to the Plaintiff for destruction.
Schulman & Kaufinan, LLC

Suite 700, 100 Light Street
(301) 576-0400
Attorneys for Plaintiff
JA390
~···--·-

I ,·
EXHIBIT 3
JA391
f· Case 1:16-cv-02723-DAF Document 28-3 Filed 07/19/17 Page 2 of 3Page 1 of2
I
I
I Thanks. I appreciate the precise chronology. Please let me know what happens on the 17th, and if you hear
anything form the4 Court of Special Appeals .
.:..-Original Message-
I From: nc'@... 11[mailto

Sent: Fliday, November 26, 2004 12:22 PM
To: Sale, Barbara
Bond@
Subject: William bond

r
Dear Mrs. Sale:
Thank you again for meeting with me this past Tuesday. I could see how busy
you are. Therefore, I greatly appreciate the extra amount of time you allowed
me.
I want to clarify a few things we discussed:
1) Judge Murdock dismissed Counts 1, 3, & 4 (Malicious Prosecution, Invasion

of Privacy, & Conversion) of my lawsuit Bond v. Blum Sr. et al. on August 23,
2004 with prejudice. She gave us 15 days to amend Count 2 (Abuse of Process)
stating that she believed that there was an abuse of process, but asking that
the a/legations against the many defendants be more specific.
2) Judge Joseph H. H. Kaplan dismissed the Amended Count 2 against Blum Sr.
et al on November 1, 2004. He contradicted Murdock, and said he found no abuse
of process after a more than two hour hearing.
3) Bond v. Blum Sr. et al. was appealed to the Maryland Court of Special
Appeals on November 12, 2004.
4) The second round of Motions to Dismiss filed by Miriam and David Pessin is
scheduled to be heard by Judge Lynn Stewart on December 17, 2004 in Baltimore
City Circuit Court. The defendants are trying to get the various charges of
Negligence, Conversion, Breach of Fiduciary Duty, Invasion of Privacy, & Legal
Malpractice dismissed. Like the Blum camp, they are seeking to have the
perjured testimony in the Copyright Case stand as fact in this case.
5) You asked a question about why we didn't just decamp and move away from
the Slums. My answer was about finishing this litigation and recouping my and
Alyson's losses. It is also my strong belief that I may be better off in the
area where I am presently known and have a somewhat salvaged reputation than to
venture elsewhere, where the Blum camp may attempt to use their resources to
again invade my privacy and ruin my reputation. I have no doubt that, left
unimpeded, the Slums would follow me to the end of the earth out of spite.
Therefore, it is my strong belief that I have had, and must continue, to make a stand
and attempt to stop what they have done to me, otherwise I am vulnerable to
this kind of attack for the rest of my life.
6) Sometime in the near future, the juvenile law expert I have hired in Ohio
15
gorng to attempt to have my juvenile record formally sealed, as it should
have been many years ago.
JA392
Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 398 of 424 Page 2 of2
~- ·-
~
Again, thank you for meeting with me. I look forward to hearing what the
Piranha has to say. Please let me know when I can drop off the rest of the copies
I made for you.
Sincerely yours,
Bill
I
•
•
•I
I
I
I
I
JA393
I
Appeal:
' 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 399 of 424
EXHIBIT4
JA394
Page I of I
,.Appeal: 17-2150 Case
Doc: 25 Filed: 03/19/2018 Pg: 400 of 424
1:16-cv-02723-DAF Document 28-4 Filed 07/19/17 Page 2 of 2
F',ubj:----iie:'-billbond ~- - ·- --- ·------...- --·---·~..- ____ ,
!Date: 1/11/2005 3:25:26 PM Eastern Standard nme

)From: !larbara.Sal,;,_@usdoj,.gov
fTo: tp-nd.§il!L I _1
/sent from. the .Internet. (Details) .....................

..............................................................................................................................................
.
Bill - just so there's no misunderstanding - my intention was and is to have another AUSA review the case with
NO recommendation from me. I want fresh eyes, and no preconceived notions. I will be back in touch after the
dust settles.
---Original Message--
From: and@ [mailla. I P .J@ &
Sent: Monday, January 10, 2005 3:30 PM
To: Sale, Barbara
Subject: bill bond
Dear Mrs. Sale:
Thank you for speaking with me, again, today.
When we last met, you told me that you were going to refer my complaints to a
subordinate. I understood that you were going to make a recommendation as
well.
You made me no promises regarding when your office would get to my complaint,
although I gave it my best effort to get you to do so.
While I understand that my complaint is not an emergency in that it is not a

murder or arson, I'm sure you won't be surprised that it is an emergency to me
and my family. In my opinion, what the Blums did in US District Court is a
kind of emergency because a message needs to be sent to the bar and society at
large that this type of behavior will not be tolerated.
The Plums, in a sense, lit a fire to my life and resulting litigation and
burned our whole family down. I very much would like to see some justice
delivered while my wife is still in good health so that her children, who have
literally been stolen from her, have a chance to see the evil which exists in their
family.
I very much hope that when your move is completed that you can put my
complaint on some sort of track which will result in your office making a
determination as to what they are going to do.
Tomorrow, I have a hearing.before Judge Holland in Baltimore City Circuit

Court regarding my banking case which was remanded by the Court of Special
Appeals. This case was about Bank of America giving all of my joint banking
documents to Slavin's counsel ex-parte re: custody case number two. The MSA opinion by
Judge Murphy has basically set a new precedent to stop this behavior by the
bar, which is not a bad little victory, considering how many people were
negatively affected by it in the past.
I hope you have an uneventful move and that you get a very nice, new office!
Respectfully yours,
Bill
JA395
EXHIBITS
JA396
Appeal:
, 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 402 of 424 Pagel of 2
fsub( RE: bill bond ..,______________________ __
lDate: 3/4/2005 6:22:27 PM Eastern Standard Time

'From: Barbara.Sale@usdoi.go.JL
!To: ~ond@
l.~~fl_l__from
__
the Internet (Defc;ils)
Thanks, Bill. I am mystified by the County proceedings. I am passing all this on to the prosecutor I asked to look
into it.
Thanks.
--Original Message-
From: £ IDg I [mailto:~IBonJ@
Sent: Friday, March 04, 2005 12:38 PM
To: Sale, Barbara
Subject: bill bond
Dear Mrs. Sale:
I called today to see if you have any new information regarding the progress
of the review ofmy complaint. I would appreciate any new information.
On Monday, February 28, Judge Kaplan in Baltimore City Circuit Court heard a
renewed Motion to Dismiss or to Change Venue filed by Miriam Pessin in Bond v.
Pessin et al. Although I had already earlier won the Venue Motion before
Judge Murdock, and won Summary Judgment before Judge Stewart, inexplicably Judge
Kaplan, in violation of Md. Rule 2-322(f) and the fact that Miriam Pessin's
time to file had expired, moved my case to Montgomery County. In this latest
Motion, Miriam Pessin again committed perjury, stating under oath in an affidavit
that she had lived in Montgomery County continuously since 2000, even though
the whole episode regarding her giving my manuscript to Hodgson occurred at her
former residence in Howard County in April 2001.
Kenneth Blum, Jr., was sentenced in Baltimore County Circuit Court for 2nd
degree assault in a plea arrangement before Judge Turnbull on October 12, 2004.
At the hearing, the prosecutor, Rachel Cogin, twice (2) mentioned the
legitimacy of Blum, Jr's possession of handguns by referring to the fact of his "carry
permit." But Ms. Cogin was provided by Alan Wagner complaints and documents
submitted to the Maryland Handgun Permit Review Board which raised very
legitimate questions about the legality of Kenneth Blum, Jr's "carry permit"
application and his applications to purchase handguns based upon the fact that he was
previously charged with domestic violence and was Court Ordered to alcohol
rehab. Ms. Cogin knew that The Maryland Handgun Permit Review Board had referred
the matter back to the Maryland State Police for investigation. Ms. Cogin also
referred to Mr. Blum, Jr's wife as being a Baltimore County police officer
and that there would be guns in his house, but that he would have nothing to do
with them. As this statement of facts was being read into the record, neither
Mr. Blum, Jr., nor his attorney, Gerard Martin, bothered to inform the Court
that, in fact, Mr. Blum was long separated from his wife and was already in the
process of getting divorced, a divorce which would become final in early
2005.
Clearly, Blum, Jr., given special treatment by Baltimore County Prosecutors

for unknown reasons.
My appeal before the Maryland Court of Special Appeals in Bond v. Messerman

and SEPH is being heard sometime between April 4-15, 2005. ·
My appeal to the Maryland Court of Special Appeals in Bond v. Blum, Sr. et
JA397
Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 403 of 424 !'age " 01 "

al. is being heard September 6-15, 2005.
look fo,ward to hearing from you. And, as you know, I have a box of
1
documents for you as well as new documents concerning the above.
Best - Bill
JA398
r
C . Case 1:16-cv-02723-DAF Document 28-6 Filed 07/19/17 Page 1 of 2
EXHIBIT6
JA399
Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 405 of 424 Page I of I
l,
I
r--·~•--,---~-... ------~
1Subj: RE: bill bond
jDate: 4/6/2005 5:42:22 PM Eastern Daylight Time
1From: Barbara.Sajg@usdoj.gov
ffa: allliBoncl@. I
!se-nt_
from.the_lnternet_(Details)
..
One attorney (the pirhana)has looked at every single scrap of paper and is preparing a report and
recommendation for me which I expect to ahve by the end of the week; another attorney is going through it as we
speak for a second opinion.
--Original Message--
From: 'il•IBond@. [mailto. and@
Sent: Wednesday, April 06, 2005 12:45 PM
To: Sale, Barbara
Subject: bill bond
Hi Mrs. Sale:
Can you give me just a little hint as to where you are with my complaint? It
would be greatly appreciated.
Karceski, Gunning and I are off to the Court of Special Appeals on Friday to
argue the Messerman and SEPH appeal.
Best - Bill
JA400
EXHIBIT7
JA401
Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 U.S.
Pg:Department
407 of 424 of Justice
r Case 1:16-cv-02723-DAF Document 28-7 Filed 07/19/17 Page 2 of 3
•
United States A/lorney
r District of Maryland
Northern Division
Allen F. Loucks 36 South Charles Street 4/0-209-4800

United SlatesAttorney Fourlh Floor TTYffDD:4/0-962-4462
Baltimore,Maryland 21201 4/0-209-4902
Barbar{}.S. Sale FAX 4/0-96l-J/24
Chief, Criminal DMsion Barbara.Sale@usdoj.gov
May 31, 2005
Mr. William C. Bond

4214 Greenway
Baltimore, MD 21218
Re: Criminal Refetral
Dear Mr. Bond:
I realize that this project has taken far longer than you would have liked, but I wanted to be sure
this Office gave your complaint the fairest and most detailed consideration. After I met with you and
your counsel, Rich Karceski, I personally reviewed the box of documents you submitted.
As I told you, since I have both prior professional and to some extent personal connections with
the Blum family (having prosecuted Allen Cohn and.United HealthCare, and one of my children having
been kindergarten friends with Ian Slavin), I thought it preferable to have the case reviewed by someone
with no preconceptions about any of the persons involved. Accordingly, I gave the box of documents
to an Assistant United States attorney in whose discretion and judgment I had the utmosr confidence.
I asked her to review it carefully and to report back to me what provable crimes she saw that merited
federal investigation and/ or prosecution. I also contacted the SEC about their alleged investigation of
Rent-as Wreck, to see if there was some scope for criminal prosecution there.
The first AUSA has completed her review and has firmly recommended that we decline
prosecution of any and all matters covered by your referral. I next had one other attorney in this office
take a look at your materials, and he agreed 100%.
Accordingly, in the exercise of my discretion, I am declining any further investigation or

prosecution of the matters you brought to our attention. I am returning all original documents to you
herewith; I have shredded the rest - all of which were either copies or appeared to be computer-
generated.
Thank you for bringing these matters to our attention.
JA402
Very truly yours,
Allen F. Loucks
~.cd,°)>
l arbarn S. Sale
=ntUnitcd States Attorney
cc: Richard M. Karceski, Esq.
Encl.
JA403
' Case 1:16-cv-02723-DAF Document 28-8 Filed 07/19/17 Page 1 of 2
EXHIBIT 8
JA404
Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 410 of 424 .1:'age1 of I --,
Subj: RE: bill bond

Date: 6/2/2005 6:10:36 PM Eastern Daylight Time
From: Barbars1.Sale@usdoj.gov
To: Bone'.)@
not at my desk much.

Bill - Sorry I missed your calls. Busy day, and I was
s or this office's practice to detail our
You have the results in the letter 1. sent. It is not DOJ'
d.
deliberative processes, as I'm sure you can understan
as I said, I appreciate your patience as we reached
This wasn't an easy or quick decision, and,
the decision.
----Original Message---
From:11•Eond@ a••[mailto:
1 7 3ond@
Sent: Thursday, June 02, 2005 5:03 PM
To: Sale, Barbara
Subject: bill bond
Dear Mrs. Sale:

pted to contact you
Thank you for your letter dated May 31, 2005. I attem
today by telephone, but was unable to do so.
has invested on my
I greatly appreciate the time and expense your office
shown me. Still, I must say
complaint. I also appreciate the courtesy you have
quite a different result.
that after so much time having passed, I expected
ive that at least some of my
Although my complaint was quite broad, I am posit
allegations have merit.
able to come back to your
When we first met, you promised me that I would be
very grateful if we
office to hear the results of your review. I would be
rably sooner rather than
could, in fact, meet at your earliest convenience, prefe
later. I am available at any and all times.
rd to hearing from you.
Thank you again for your consideration. I look forwa
Sincerely yours,
Bill
JA405
EXHIBIT9
JA406
Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 412 of 424 Page 1 of 1
Subj: RE: bill bond

Daylight Time
Date: 6/21/2006 8:48:38 AM Eastern
From: Barbara',SE!!fil@u'sdoj.gov
To: J Ion~@ I
istant I do not know
e,ia ls con cern ing you r cas es was on the desk of the First J\ss
111e last I knew, the mat l speak to
t timc1,1blcthere may be., but 1 wil
what he has decided, if he has
him.
arri ved at any dec isio n, or wha
I
From: ond@j [mailto. Bond@ l I
y, Jun e 20, 200 6 7:21 PM
Sent: Tuesda
To: Sale, Barbara (USAMD)
Subject: bill bond I
Dear Mrs. Sale: f
I hope you are well.
Judge Krauser yesterday,
d v. Blu m Sr. et al. was handed down by
The Court of Special Appeals
dec isio n in Bon soning; and don't agree that the
we disa gree with the opinion and its rea rt of J
unfortunately not to my ben efit. Nat ura lly, that we will proceed to the Cou
tem sho uld be use d to man ipulate a custody battle. I'm sure laug hing all the way .
criminal justice sys y with almost everything,
and his minions seem to get awa
Appeals. But it is trying, Blum
t-a-Wreck Corp. They
n is the Cou rt's ratio nal for dismissing defendant Ren
Possibly of note to you in the
dec isio on company payroll to be
loym ent duti es to hire a private investigator
said that ii could not be in Blu m's emp monies, stolen money lrom
law 's side of the cus tody cas e. Clearly, he used company
involved in his son-in-
personal aims.
shareholders, to further his own
enstein about the
som etim e ago , you said that you had not spoken to Mr. Ros
When we last spoke, which was ewed interest?
te to you both . Wo uld you let me know if there is any ren
Blum issue about which I wro
Respectfully yours -Bill
JA407
., " Case 1:16-cv-02723-DAF Document 28-10 Filed 07/19/17 Page 1 of 2
EXHIBIT 10
JA408
; Case 1:16-cv-02723-DAF Document 28-10 Filed 07/19/17 Page 2 of 2 Page I of I
Subj:
Date:
From:
To:
He is overseas right now, and I will speak to him about it when he returns. I believe he has reviewed all the
materials, but I will check. Thanks.
'•"'•••·•"'• •'••••·•----L•••''', ••• ,..__ •• .- . ., ,-, ,•, , , ,, •" ,_, ,,•," r,,,.-",.,_,• ••• ,,,,,, . ••••••••'••"••• ,.,,.,. •.•,•,•·"·'"''"'·''·'••••,W,•.•,w , ••"- ••, ••, •• ' • ,_,._,.,, •••• -- •••••• ,,-S'•••••••"'••••·•·• ••• -•··•• •••· ··· ,c., »• ,,p,_ --<'- • -N-'••••'••·' ••-•'-'.".'v
From: llf)nd@ 3 [mailto 9 Bonac7 l

Sent: Monday, August 07, 2006 3:06 PM
Subject: bill bond
Dear Mrs. Sale:
I hope you are well and staying cool.
In reply.to my last email, you said that my materials were on the desk of Mr. Rosenstein's First Assistant, Mr.
Goldberg. I wonder if you can tell me if there has been any movement and whether this matter is under renewed
consideration?
Respectfully yours - Bill
I
.~1
JA409
EXHIBIT 11
JA410
Case 1:16-cv-02723-DAF Document 28-11 Filed 07/19/17 Page 2 of 2 Page 1 of 1
--
Subj: RE: bill bond
Date: 10/2/2006 12:18:57 PM Eastern Daylight Time
From: 8 a rb a ra .SaI~d..9j .g9_11_
To: a•s,nc'D
J3ill - Our front office has looked at the case and is sticking with the decision to decline prosecution.
Best,
B;1rb;1ra
Barbara S. Sale
Chief, Criminal Division
410-209-4902
FAX 410-962-3124
•.W,"S'.·/•.•.,•\•.•, ......... , ... ,,,• ,• ................................ ,-..m., .... n,,,. ·.·.··.•-•,•.·.<W.._._.,._

••,•.•,•.·.,,,
•.._.,.,.,••,•,-•,•.·-··- ...·•---••·-·'····'···•'·'"·''·····-· ··,..,...
From: end@ [mailto Bond@ J

Sent: Friday, September 29, 2006 1:44 PM
Subject: bill bond
I
Dear Mrs. Sale: I
Attached is an article which ran in today's Daily Record. This case was a sub-component of Alyson's Custody
case number 2. Basically, Bank of America in custody cases was giving out clients banking records en masse
outside of subpoenas. I
The Court of Special Appeals denied our request for Rehearing en Banc regarding Judge Krauser's Unpublished
Opinion in Bond v. Blum Sr. et al. This case was about Malicious Prosecution, Abuse of Process, Invasion of
Privacy, and Conversion. Initially, Judge Murdock found an abuse of process but granted defendants' request for
I
a more definitive statement as to each party. Judge Kaplan then dismissed the whole matter. We are now off to
The Court of Appeals. I know you know what Blum did to me and how. It is frustrating to let this guy beat me this
bad. I
I hope you are well. Please let me know the status of my letter to you and Mr. Rosenstein once you speak with
Mr. Goldberg.
Respectfully yours,
Bill
JA411
EXHIBIT 12
JA412
(USAMD)
From: Sale, Barbara (USAMO)
Sent: Wednesday, May 09, 2007 12:10 PM
To: .b-1C. ;USAMD)
Subject: FW: bill bond
Here is the only email 1 have. I'm looking for the declin memo now.
-----Original Message-----
From: Sale, Barbara
Sent: Friday, November 04, 2005 7:32 PM
•
To: lll l]ltBond@ ..
Subject: RE: bill bond
lln' ••
Dear Bill - l am sorry to hear of your awful accident!
see what his thoughts were concerning your letter. My view

l will check with Rod to
although I am most interested to see that the Ct of Appeals will hear
hasn't changed,
argument in your case on 12/6. Good luck!
And thanks for the addess update.
-----Original Message-----
From: J ? £ ond@··•• [mailto: Bond@
Sent: Fric!ay, November 04, 2005 2:39 PM
To: Sale, Barbara:
Subject: bill bond
Dear Mrs. Sale:
Its been a while since we spoke. I hope you are well. I

out of a back brace, the result of being hit from behind while riding my bike
I just got
near Sagamore
teeth, and received
tarms on August 30. I broke
a whopper of a concussion.
3 vertebrae,
Luckily,
my leg,
I will
multiple
be fine.
ribs, my hand,
I
We are st.Lll waiting
case which was argued
for the opinion
September
of the Court of Special
7. The Maryland Court of
Appeals
Appeals
for
granted
December
decision
6.
cert.
My
in the Blum
case
for my
against
I
appeal of the Messerrnan case. That argument is scheduled
for trial in late spring of 2006. Mrs. Pessin has just filed her
Pessin is scheduled
Summary Judgment and Sanctions based in part, on her perjured testimony
fourth Motion for 1
and the results thereof in the Garbis decision. 1

if you can tell me if my letter to Mr. Rosenstein and you dated July
I wonder they are
caused any reconsideration by your office of my allegations, or whether
26 has
still dead in the water? 1
Respectfully yours,
Bill I
PS -- Please note my new address if necessary:
William C. Bond
309 Suffolk Road
I
410.243.3806
JA413

NORTHERN DIVISION
WILLIAM C. BOND, *
Plaintiff pro se, *
v. Civil Action No.: 16-02723-DAF
*
*
Defendants.
*
* * * * * * * * *
ORDER
For the reasons expressed in the accompanying memorandum opinion:
1. The court's memorandum opinion and order and judgment order of April 12, 2017,
(docket nos.: 22-23) are VACATED.
2. The clerk is DIRECTED to REOPEN the case and to DOCKET the Proposed Second
Amended Complaint (docket no.: 26-2) as the SECOND AMENDED COMPLAINT.
3. Plaintiff's second motion to reopen the case and to file a second amended complaint
(docket no.: 26) is GRANTED.
4. The clerk is DIRECTED to instruct the U.S. Marshal to serve plaintiff's provided
summonses & complaints upon the five (5) newly named defendants.
5. The defendants SHALL RESPOND within fourteen days after service of the second
amended complaint.
6. A separate SCHEDULING ORDER will be issued in this case.
IT IS SO ORDERED this __ day of __ , 2017.
Enter:

JA414

AT BALTIMORE
WILLIAM C. BOND,
Plaintiff,
Defendants.

MEMORANDUM OPINION AND ORDER
and Judgment Order already filed, see Doc. Nos. 22—23, and in
the Order denying the re-opening of this case, see Doc. No. 25,
yet again the court DENIES Plaintiff’s Motion to Reopen Case and
to File an Amended Complaint. See Doc. No. 26. Therefore, the
court also DENIES Plaintiff’s request to vacate the court’s
Memorandum Opinion and Order and Judgment Order already filed.
See id.
Plaintiff already has been “admoni[shed]” that “[he] should
take care not to lose credibility by filing vexatious and
frivolous complaints.” Doc. No. 25. This is because “every
paper filed with the Clerk of this [c]ourt, no matter how
repetitious or frivolous, requires some portion of the
institution’s limited resources. A part of the [c]ourt’s
JA415
[stewardship] responsibility is to see that these resources are
allocated in a way that promotes the interests of justice.” In
re McDonald, 489 U.S. 180, 184 (1989) (per curiam); see also
Martin v. District of Columbia Court of Appeals, 506 U.S. 1, 1
(1992) (per curiam) (applying this principle to “notorious
abuser[s]” of the judicial system). This is the second time
that Petitioner has asked the court to re-open this case. The
court has again refused to do so. Petitioner’s repeatedly
unmeritorious supplications are squandering the Third Branch’s
limited resources; the aggregation principle informs the court
that were Petitioner’s conduct repeated on a nationwide scale,
the work of the Federal Judiciary might come to a grinding halt.
Additionally, Petitioner’s conduct is damaging his own
interests.
The Clerk is directed to forward a copy of this Memorandum
Opinion and Order to counsel of record and Plaintiff, pro se.
The Clerk is directed not to accept any further motions to
vacate the court’s opinion and order or to reopen this action.
IT IS SO ORDERED this 1st day of August, 2017.
Enter:
David A. Faber
2

JA416
J \! '
. . Fft E:l:J
. !J:S.1J!STillCT
tcl'C'.,.'l"-1/r'f ..~
CCTU"',·T
lit
:,
• I •.At~m
tciL,); r,; '-' Or ML'1r"'1VI ,,1¥i,
2017
SEP
29 AH10:l 6
IN THE UNITED STATES DISTRICT COURT CL_~?H\"S
$Ffi0E
FOR THE DISTRICT OF MARYLAND ATiid"TIM\1/flli:
NORTHERN DIVISION 18Y, ,l!t/Itl Y r
WILLIAM C. BOND, *
Plaintiff pro se, *
*
*
Defendants.
*
* * * * * * * * *
NOTICE OF APPEAL
Comes now plaintiff pro se, William C. Bond, and hereby appeals to the U.S. Court of Appeals
for the Fourth Circuit the orders entered in this case at docket entry numbers 22 & 23 on April
12, 2017; at docket entry number 25 on May 23, 2017; and at docket entry number 29 on August
1, 2017.
Respectfully submitted this 28 th day of September 2017,
WILLIAM C. BOND
Pro Se
P.O. Box 4823
(443) 970-2887
JA417
Fil E[i)
:) S. t11STi'<ICT
CGUl!lT:
rJJST~iCf CFM.n..RYl.'/;N~
William C. Bond
Pro Se Litigation
P.O. Box 4823
2frl7SEP29 AH10:15
443.970.2887
September 28, 2017
Clerk of the Court via: FedEx

United States District Court for the District of Maryland
Baltimore Division
4 th Floor
JOI West Lombard Street
Dear Sir or Madam Clerk:
Please find two copies each of the following being filed in the above case.
I. PLAINTIFF'S NOTICE OFAPPEAL.
Please time and date stamp plaintiff's copies and return in the enclosed SASE.
Thank you,
William C. Bond
JA418
I hereby certify that on this day, March 19, 2018, the foregoing
was electronically filed and therefore served electronically via the
court’s ECF/CM system on all counsel of record.
I further certify that paper copies of the foregoing will be delivered to

the Court on March 20, 2018.
/s/ Matthew J. Dowd

Matthew J. Dowd
Dowd PLLC
1717 Pennsylvania Avenue, NW
Suite 1025
Washington, D.C. 20006
(202) 573-3853
mjdowd@dowdpllc.com
Dated: March 19, 2018

Bond v. United States - Joint Appendix in U.S. Fourth Circuit No. 17-2150

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Bond v. United States - Joint Appendix in U.S. Fourth Circuit No. 17-2150

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Appeal: 17-2150 Doc: 25 Filed: 03/19/2018 Pg: 1 of 424

UNITED STATES COURT OF APPEALS

Appeal from the United States District Court for the

Allen F. Loucks Richard A. Posner

Counsel for Appellant

District Court Docket................................................................... JA001-004

Original Complaint (ECF 1) ........................................................ JA005-036

Letter Motion (ECF 15) ............................................................... JA037-038

Defendants’ Motion to Substitute & Dismiss (ECF 16) ............ JA039-040

Defendants’ Memo in Support of Motion to Substitute and

Exhibit 1 to Motion to Substitute and Dismiss (ECF 16-2) ...... JA052-052

Exhibit 2 to Motion to Substitute and Dismiss (ECF 16-3) ...... JA053-053

Plaintiff’s Pro Se Motion for Discovery (ECF 18) ...................... JA054-058

Exhibit 1 to Motion for Discovery (ECF 18-1)............................ JA059-074

Defendants’ Opposition to Plaintiff’s Motions (ECF 20) ........... JA075-078

District Court Memorandum Opinion & Order

Plaintiff’s First Pro Se Motion to Reopen Case and File

Memorandum in Support of First Pro Se Motion to Reopen

Plaintiff’s First Amended Complaint (ECF 24-2) ...................... JA119-150

Redline Version of Plaintiff’s First

Exhibit 1 to First Amended Complaint,

Exhibit 2 to First Amended Complaint,

Exhibit 5 to First Amendment Complaint, FOIA Documents

Exhibit 6 to First Amended Complaint,

Exhibit 7 to First Amended Complaint, Maryland Code

Exhibit 8 to First Amended Complaint, Maryland Code

Exhibit 9 to First Amended Complaint, Excerpt from

Exhibit 10 to First Amended Complaint, Letter from

Exhibit 11 to First Amended Complaint, Letter from

Exhibit 12 to First Amended Complaint, Memorandum and

Exhibit 13 to First Amended Complaint, Listing of

Exhibit 14 to First Amended Complaint, Excerpt from

Exhibit 15 to First Amended Complaint, Affidavit of

Exhibit 16 to First Amended Complaint, Motion for Recusal

District Court Order dismissing Motion to File

Plaintiff’s Second Motion to Reopen and to File a

Plaintiff’s Memorandum in Support of Second Motion

Plaintiff’s Proposed Second Amendment Complaint ................. JA287-319

Redline Version of Plaintiff’s Proposed Second

Defendants’ Opposition to Plaintiff’s Second Motion to

Defendants’ Proposed Order (ECF 27-1) .................................... JA369-369

Plaintiff’s Reply in Support of Second Motion (ECF 28) ........... JA370-382

Exhibit 1 to Plaintiff’s Reply (ECF 28-1) ................................... JA383-385

Exhibit 2 to Plaintiff’s Reply (ECF 28-2),

Exhibit 3 to Plaintiff’s Reply (ECF 28-3),

Exhibit 4 to Plaintiff’s Reply (ECF 28-4),

Exhibit 5 to Plaintiff’s Reply (ECF 28-5),

Exhibit 6 to Plaintiff’s Reply (ECF 28-6),

Exhibit 7 to Plaintiff’s Reply (ECF 28-7), USAO MD letter ..... JA401-403

Exhibit 8 to Plaintiff’s Reply (ECF 28-8),

Exhibit 9 to Plaintiff’s Reply (ECF 28-9),

Exhibit 10 to Plaintiff’s Reply (ECF 28-10),

Exhibit 11 to Plaintiff’s Reply (ECF 28-11),

Exhibit 12 to Plaintiff’s Reply (ECF 28-12),

Exhibit 13 to Plaintiff’s Reply, Proposed Order

District Court Memorandum Opinion & Order ......................... JA415-416

Plaintiff’s Notice of Appeal .......................................................... JA417-418

Bond v. United States of America Date Filed: 07/29/2016

Date Filed # Docket Text

IN THE UNITED STATES DISTRICT COURT

"UNKNOWN NAMED MARYLAND U.S. JUDGES"

c/o The Hon. Catherine C. Blake

"Sure," 1 answered, as the boat bobbed up and down in small