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U.S Department of Justice Civil Rights Division 950 Pennsyvania Avenue, NW
Washington, DC 20530 (202)514-2151 fax: (202)514-0293 TTY (202)514-0716 Disability
Rights Section.

Michael R. Kelly )
Claimant )
Vs. )
Rick Hilton; )
Richard Hilton; )
Paris Hilton )
William Barron Hilton of: )
Hilton Hotel(s) )
Hilton Headshop )
President George W. Bush )
Vice-President Joseph Biden )
Attorney General )
John Ash croft )


Claimant, Michael R. Kelly, Comes now with complaint for damages against said
defendant(s) Rick Hilton, Richard Hilton, Paris Hilton, William Baron Hilton, 2008
President George W. Bush, Vice-President Joseph Biden, Attorney General John
Ashcroft, and respectfully and Before the Department of Education, Office of
Civil Rights.

Statement of Claim: This action to vindicate violations of the Claimant’s Civil

Rights and to redress the unlawful and discriminatory and Cruel and Inhumane
Punishment of the Defendants. This action arises out of illegal and wrongful
Discrimination against a Disabled Person in whole or in part, upon his gender and
/or race and disability in violation of Title I and Title II of the Civil Rights
Act of 1964, 12010.Section 2(a)1.(a) 3.(a)5(b)1(b)2(b)3 and Section 12112(Section
102)(b)2(b)3a.(b)5a.and Section 12113(Section 103)(a)(d)1.and Section
12116(Section 106) and Section 12117(Section 107)(a)(b) 42 U.S.C. 200e-5note (a)
706 Americans with Disabilities Act of 1990as amended, 42 U.S.C. Sections 2000e et
seq. , amendments made by Section 3[Lilly Ledbetter fair Pay Act of 2009,PL 111-
2,123 Stat.5] shall apply to claimas of Discrimination in compensation brought
under Title I and Section 503 of the American with Disabilities Act of 1990 (42
U.S.C. 12111 et seq., 12203), pursuant to section 107(a) of such Act (42 U.S.C.
12117(a) 0, which adopte the powers, remedies and procedures set forth in section
706 of the Civil Rights Act of 1964(42 U.S.C. 2000e-5)and 42 U.S.C. 200e-
5note(a)remedies and procedures under Sections 12117,12133, and 12188 of this
Title[sections 107,203, and 308] shall be available to aggrieved persons for
violations of subsections (a) and (b) of this section, with respect to subchapter
I, subchapter II and subchapter III, respectively, of this chapter [Title I, Title
II, and Title III, respectively] and Technical Assistance of Section 12206(Section
507) Grants and Contracts(d)1, 2, and (2) subchapter IV [Title V] Section
12201(Section 501] (a)(b) Prohibition against retaliation and coercion Section
12201(Section 503)(a)(b) and Legislative Branch Coverage of the Senate Section
12209.(a)1(c)(2)a and b and c and Coverage of the House of Representatives
(b)(1)(3)(a)and(b)and © Instrumentalaties of Congress (1)(2)and Report to
Congress(3) Section 3 Title I of the ADA(42 U.S.C. 12102 and section 512 of Title
V of the ADA (42 U.S.C. 12115) amended two sections of section 7 of the
Rehabilitation Act of 1973 (29 U.S.C. 706(8))and (Section 510)(c) and the Civil
Rights Act of 1866, as amended by Civil Rights Restoration Act of 1991, 42 U.S.C.
Section 1981.

1. This Action is brought pursuant to the Federal Torts Claim Act. 2(a) U.S.C
Sections 2671 through 2680; 28 U.S.C. Section 1346(b)18U.S.C. Section 1964;42
U.S.C. Sections 1983 and 1988,Protection of Human Rights Act, the Convention
Against Torture and Cruel and Inhumane or Degrading Treatment or Punishment of
June 26,1987 and as amended thereafter; the Hague Convention ;42U.S.C.Section
1981;42U.S.C. 1982,1983,1985, and 1986 of 42U.S.C.Section 1988[Prosedeeings of
Vindication of Civil Rights],of said Title IX of Public Law 92-318{2U.S.C.(a)
Section 1681 et. Seq.),the Religious Freedom Restoration Act of 1993 [42U.S.C.
Section 2000 (b)(b),et seq.] Title VI of the Civil Rights Act of 1964 [42U.S.C.
Section 2000 (d) et. Seq.] Including Section 13981 and said Title, the Court in
its discretion may allow the prevailing party, other than the United States , a
reasonable attorneys fee as part of the cost. Also under the Courts jurisdiction
as part of the cost award in its discretion ,in awarding fees under
42U.S.C.Section 1988 (b) and
(c) in any action or proceeding to enforce a provision of Section 1981 or 1981 (a)
of said Title, the Court, in its discretion, may include expert fees in addition
to the attorneys fees after it orders an expert(s) as provided under Federal Rules
of Civil Procedure set forth infra.

2. Jurisdiction is proper in this Court pursuant to 28 U.S.C. Section 1331,1337

because this matter involves allegations of illegal behavior arising under the
law of the United States, including violations This is a Civil Action seeking
judgment and relief and/or damages brought pursuant to the American with
Disabilities Act 42,U.S.C. 12101 et, seq. as amended for discrimination based upon
disability and the failure to accommodate same this court has jurisdiction of this
action pursuant to Title II of the American with Disabilities Act 504 of the
Retaliation Act of 1973,24 C.F.R. part 35 28 U.S.C. 1331 and 1343 (4) PL 105-
220,1998 hr 1385 PL105-220, enacted on August 7, 1998, 112 Stat 936 codified as :
Section 504 of the Rehabilitation Act, 29 U.S.C. 794d Executive Order 12250,
Title VI of the Civil Rights Act of 1964’and Section 504 of the Rehabilitation Act
of 1973, 29 U.S.C. 794d and of Racketeer influence and Corruption Organization
(“RICO“). Furthermore, the jurisdiction is proper pursuant to RICO, 18 U.S.C.
Sections 1964 (a) and (c) and 28 U.S.C. 1651(a), The Defendants are “persons”
within the meaning of 18 U.S.C. Sections 1961(3).As to Claimant Kelly, the
jurisdiction is proper in this Court pursuant to 28 U.S.C. Section 1332 because
the matter and controversy exceeds the sum or value of $75,000. Dollars and
involves part of diverse citizenship or status under the Constitution. Claimant
Kelly is a “person”
Within the meaning of 18 U.S.C. Section 1961(3).This Court may exercise
jurisdiction over Claimants non-federal claim pursuant to 28 U.S.C. Section
1367,as this Court possesses both Federal subject matter and /or diversity
jurisdiction. Claimant reserves the right to amen paragraph.

Venue is proper in this Court pursuant to 18 U.S.C. Section 1965,(a) defendants
reside, are found, operate under authority or office, have an agent, or are
connected with or related to the afore said, or transact affairs in this district.
Venue is also proper in this Court pursuant to 18 U.S.C. Section 1965 (b) because,
to the extent any Defendant may reside outside this district, the ends of justice
require such Defendant(s) to be brought before the Court. Venue properly lies in
this Court pursuant to 28 U.S.C. Section 1391 (b)(2) or
Alternatively pursuant to 28 U.S.C. Section 1391 (a)(2).Further, certain of the
conspiratorial acts alleged herein took place and continue to take place within
this judicial district. Any and or all the Does 1-10 who are employed with
,contracted with and connected to Defendant USA, or the judicial system can be
compelled through order and/or subpoena power of this Federal court to be
subjected to discovery or otherwise appear before the Court under Federal Law,
executive order, or the Code of Federal Regulations or other process.C.


Claimant Kelly has complied with all administrative prerequisites to action under
Section 706 of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C.
Sections 2000e-
Claimant Kelly files this formal charge of Discrimination and Cruel and Inhumane
Punishment, RFID laws and R.I.C.O. with the State of Missouri.
Claimant Kelly has exhausted all available administrative remedies in accord with
the aforementioned statutes prior to instituting this Complaint and Defendant(s)
fail to comply. Claimant Kelly formally requests a Notice of Complaint and the
Right to Sue, No administrative prerequisites are required before Claimant files a
Complaint to the Civil Rights Act of 1866, as amended by Civil Rights Restoration
Act of 1991, 42 U.S.C. Section 1981.


(a) Defendant Rick Hilton of Hilton Hotels and Hilton Headshop
(b) Defendant Richard Hilton of Hilton Hotels
(c) Defendant Paris Hilton
(d) Defendant George W. Bush
(e) Defendant Vice-President Joseph Biden
(f) Defendant Attorney General John Ashcroft

Defendant Rick Hilton’s employee(s) agents

(g) Robert Wayne Smith and
(h) Kimberly Clare Smith,
(i) Lee Hefely, and
(j) Heather Hefley,
(k) preacher- Joyce Meyer
(l) Dr. Stefano Giardi

(j) The United States of America, an International sovereign nation, (hereinafter

“Defendant”USA”) empowered , limited and controlled subject to its United States
Constitution (hereafter “U.S. Constitution”), is the United States of America as
set forth by its territorial boundaries description which the Court is requested
under Federal Rules of Evidence (“F.R.E.) Rule 201, to take judicial notice of
said territorial description and boundaries commenly referred to the United States
of America., “USA”, or sometimes United States of America, herein as defined and
set forth under the United States Constitution.

4. The Defendant(s) U.S.A Vice President Joseph Biden and President George W.
Bush, pursuant to the United States Constitution, Article I,II,and III,
establishes the legislative powers, executive power and the power of the United
States respectively. Claimant alleges under the Constitution that defendant Rick
Hilton and entity under his own personal gain to establish a Government Grant of
Science for the purpose to unlawfully torture said Claimant with said Tag. Under
the Right to Know Act 2003, 15 U.S.C. 1453 Ch. 94 Section 6. Amendments to Title
15,CH. 94--Privacy is amended (1) by inserting the following under Subchapter II.
Subchapter III. Aggregation of Non-public Personal Information and Radio Frequency
Identification Tag Identification Information 6831, Privacy Protection for
Consumers. (a) (1) A Business shall not combine or link an individuals nonpublic
personal information with RFID tag identification, beyond what is required to
manage inventory.(2) A business shall not, directly or through an affiliate,
disclose to an nonaffiliated third party an individuals nonpublic information
personal information in association with RFID tag identification information.(3) A
business shall not, directly or through an affiliate or nonaffiliated third party,
use RFID tag identification information to identify an
individual.(b)(1),(2),(3)and (4), regulates the TAG, RFID illegal Neurochip,
Microchip implant for illegal surveillance, Privacy Act, illegal use of such
device.and unauthorized access to personal records and personal information.

5. Defendant Rick Hilton is an individual who is a citizen of the United States

who acted within his own power under the United States Constitution. Acting
individually and in concert with one another as support therein caused this injury
to Claimant.

6. Claimant Kelly as a citizen of the United States of America USA, and a

domiciled/resident of the State of Missouri, has a legal duty to counter fraud and
any other illegal activities affecting his personal, financial interest, welfare,
safety, or security as a Citizen of the State of Missouri through Whistle blowing

7. Further it is the Defendants duty imposed upon said Defendant to protect

Claimant Kelly from harm personally and to his financial interest related to
Defendants use of the Tag RFID, Neurochip Microchip Implant.

8. The Defendant posses additional duties and authority that has been conferred
to him by said compliance with Federal Law.

9. Wherein the areas of their compliancy and jurisdiction, Defendant of the United
States of America through its Federal Judicial System and State counterparts have
legal duty and responsibility to provide Claimant Kelly to exercise his procedural
and substantive due process right to have access, objectiveness, impartiality and
fairness by and through the judicial system and protect his use of judicial system
without the court engaging in or engaging in corruption , unfairness, lack of
objectivity or impartiality, favoritism all in a matter equating to or giving the
appearance of obstruction of justice and tampering for the purpose to protect
Defendant Rick Hilton using influential government figures to protect him.
Government figures as Vice-President Joseph Biden, and George W. Bush, and
Missouri Attorney General John Ashcroft. They had obstructed justice when Claimant
Kelly called the FBI Federal Bureau of Investigation. Also to prevent the
interference ,obstruction or loss of Claimant Kelly right to a jury trail on
ultimate facts supported by reasonable evidence and protection of his rights of
due process and equal protection through such access and use of judicial system as
a witness.


10. Claimant Kelly reserves the right to amend all paragraphs.

11. Claimant Kelly makes the following allegations on his information and belief
and on those grounds.


Claimant Kelly alleges:

11. Rick Hilton co-owner of Hilton Hotels and working out of WASHU

Washington Memorial Hospital, in St. Louis, Missouri, and is directly

responsible for this Complaint and cause of action, and damages arises

out of and during the course of unlawful employed Claimant Michael R.

Kelly without pay for and to obtain a United States Grant for Science

and is using Chronic Pain Sufferers, and used a Radio Frequency

Identification Tag and for discrimination against a Disabled Person, and

Religious persecution and for torture, cruel and inhumane punishment.

12. Rick Hilton put a Neurochip, Microchip, RFID Radio Frequency

Identification Tag, neural Implant, under the scalp (body) of Claimant

Michael R. Kelly without Claimant Kelly’s consent, knowledge, doctors

prescription, a writ warrant to willfully and wonton cause pain and


13. Rick Hilton has been Illegally surveillance and wire tapping Michael R.

Kelly since March 3rd.2008, thru and to the present twenty-four hours a


Claimant Kelly alleges:

14. Rick Hilton is the owner and co-maker of Hilton Hotels and is a

resident of the United States of America, and the United States Patient

7209788, April, 24th. 2007, Tag Neurochip, Microchip. (see exhibits)

15. Rick Hilton is using via a Tag, two-way communication Neurochip,

Microchip for two way communication device to torture, harass,

and sexually harass Claimant Kelly.

16. Rick Hilton performed neural brain surgery on and operated on without

a Missouri Physicians License and put the Neurochip, Microchip, Tag

neural implant in said Plaintiff’s Michael R. Kelly’s scalp at Open MRI

of Potosi, Missouri on or about on March 3rd.2008

Dr. Stefano Girardi
Perdue, Italy.

Allegation of injury at Open MRI of Potosi, Missouri

17. Open MRI of Potosi, Missouri.

Open MRI of Potosi,
#20-Southtowne Drive, Potosi, Missouri 63664
Defendant, Rick Hilton paid the Open MRI of Potosi, Technician to allow

him and Dr. Strefano Girardi to operate on Claimant Kelly during an MRI:

To take MRI Magnetic Resonance Images of the Tag, neural brain implant

during said Operation.

Claimant Kelly alleges:

18. Claimant Michael Ray Kelly is a Resident of Potosi, Missouri

17115 South

State Highway 21# Potosi, Missouri 63664 in Washington County;

at the

time Defendant Hilton put the Tag, Neurochip, Microchip

Implant in

Claimant Kelly’s head., at Open MRI of Potosi, Missouri

Claimant Kelly is

now a Resident of Arnold, Missouri 4550 Sky-View Dr. 63010 in


County; and was at Open MRI of Potosi, Missouri for a MRI in


County; on or about on March 3rd. 2008.

19. Plaintiff , Michael R. Kelly is described as a disabled person

and is on
Social Security Disability, #487-90-3603 and has been disabled


20. Defendant Rick Hilton refuses to turn off Tag, RFID Radio

Identification Neurochip, Microchip without Federal


21. Defendant Hilton put the tag Neurochip,Microchip Brain Implant in


Kelly’s head without the Claimants knowledge, Consent ,

Prescription or

Volunteering under Hilton Headshop.

(a) Defendant Rick Hilton is a Resident of Los Angeles California,

2445 Whispering Willows,90011, Santa Cruz County;
Hilton Head Island;
35 DeAllyon Drive
29938, Hilton Head Island, SC,USA
Office: 617-583-1122 Fax: 617-583-1298
E-Mail: villa

And allegedly claims that the United States Government Grant officer Defendant

Hilton permission to murder Chronic Pain Sufferer patients, the Government

gave Defendant Rick Hilton permission to “Compensate” Chronic Pain Sufferer

patients, not to cut open their brain and kill the patient(s) subjects.

(b) In the U.S.Patient# No: US7209788 it states chronic brain cultivation, as


Hilton stated “Chronic Brain Cultivation means they killed the patient subject,

scareing them the neuronons go into and or on the Tag, Neurochip Microchip

Implant they murdered patients to re-cultivate the neurochip brain implant. The

Defendant Rick Hilton tolClaimant Kelly that he personally via two way

communication has thright murder patients from “Dr. Tom Hilton” and the United

States Government Grant Program.. Claimant Kelly respectfully requests that Rick
Hilton turn over all Grant(s) as stated so in this Complaint under the Challenge

Grant Hilton Neurochip Project Documents for Discovery, evidence and forensic

evaluation , patients and or subject(s) whom are and or where involved with the

project, deceased (murdered) cases re-opened Conspiracy to commit murder and /or

Felony I formally request Federal intervention for Cruel and Inhumane


Defendant Rick Hilton refers to Claimant Kelly as his monkey for inhumane

experimentation, Defendant Rick Hilton is trying to brain wash Claimant

Kelly, and is trying to convince him to plea guilty to false charges so he can
kill him by

cutting a two by two inch square out of his skull. That is the rules that the

Grant under co-owner Defendant Rick Hilton’s Headshop,

(a) NIH Challenge Grant -OD-09-003 Challenge in Health and

Science as part of American Recovery and Reinvestment Act of

2009, Recovery Act) Pub.L.No.111-5 by Dr. Tom Hilton. 15-DA-112 3-DA-101,3-DA-104Biomarkers for Pain, 04-


111Clinical Neurobiology of Chronic Opioid use and misuse,.05-


103Intergrated vs. Separate Treatment of Substance Abuse and

Co morbid Conditions,05-DA-105Comparing Episodic and Continuous

Care for Drug Abuse Treatment, 08-DA-101 An Epigenetic

“NEUROCHIP”, 01-DA-101 New

Tools for Neuroscience and Neurofeedback,15-DA-101 New Models


Measures in Pre-Clinical Chronic Pain Research,15-RR-101Applied

Transitional technology development. for hiring employees

see exhibit II.

(b)Rick Hilton’s Neurochip U.S. Patient (http://www.Patient

No: 5517600

(c) the allegations and statements made are an exemption under the

rule because they were out-of-court statements made via two-way

communication by The Tag,Neurochip,Microchip Brain Implant.

Fed.Rule of Evid.802,Cal.Evid. Code 1200,NY Code of Evid.802,and

Texas Civ.Rule of Evid.802.

22. Defendant Rick Hilton and hired employees Robert Wayne Smith of South

St. Louis, Missouri, Wilburn Lee Hefley of South St. Louis, Missouri, and

Scott Pinkerton of Fenton Missouri , at $20 dollars an hour to $40 dollars

per hour,

including hiring Joyce Meyer Preacher on Trinity Broadcasting Network,


Duplantis of Louisianna from Trinity Broadcasting Network, Creflo Dollar of


Broadcasting Network, at $400 dollars per hour, and that they were hired to
aid in

brain washing and Cruel and Inhumane Punishment.

23. Defendant Rick Hilton, explains in vivid detail child molestation

of Claimant

Kelly‘s Daughter Lauren Madry (step-daughter) and son Michael


Smith, what a penis tastes like, how to suck on it, what a

little girls vagina

tastes like, they said a young female child’s vagina tastes

like and smells like

fish, and how it feels to have intercourse with children,

Defendant Rick

Hilton explains what it feels like a fist on your penis, their

using pictographs

and photographs, pornographic pictures and video taping of Robert Wayne

Smith’s and Kimberley Clare Smith’s two year old naked son to try to get me
to think of molesting them , raping Comedian Fran Drescher, killing Union

Painter co-workers in Iowa , killing former late Mel Carnahan in Missouri, is

responsible for 911 and know Osama Bin Ladin, also wants to use my son

Nicholas Ryan Kelly and put the Neurochip Tag in his brain to brainwash him
just for

revenge because I’m filing a lawsuit he said that he was going to put him in
his grant

program as a chronic pain sufferer,also trying to convince Claimant Kelly that

I have or

poses an IDE bomb and how to make one they said you have to pack the gun powder

with a press, tried to kill George Bush Senior in 1994, Also Defendant Hilton

that he is going to pay off Federal Judges using also had investor Vice-

Joseph Biden call the FBI (Federal Bureau of Investigations) and had them
refuse to

investigate my complaint and that what I say that it was a hoax. Defendant Rick

Hilton’s employee(s) The computer reads neurosignals that appear red and blue,

allegedly means that your telling the truth and blue means that your lying,
although it is

an incomplete science. Defendant Rick Hilton tried different experiments with


names and different explanations and seen that the neurochip science was

with errors; turn the gain (blue side of the brain) to the left to say that
Claimant Kelly is


22. Defendant Rick Hilton is recording the proceedings twenty-four

hours a day

since March 3rd. 2003 thru and to the present.

23. The Defendant Rick Hilton stated that there are forty-six
Investors involved
in U.S. Grant No:7209788, each investor contributed $1,000
dollars to get a

$1 Million dollar return. And Defendant Rick Hilton, Defendant


Hilton and Defendant Paris Hilton split the rest of the Grant

24. Defendant Rick Hilton is using Chronic Pain Sufferers because he

says that

they have no reason to live.

25.How microchip works.

(a) an wireless implant able Tag,Neurochip,Microchip,BCI brain computer

interface implanted on the brain of the Celebelum nerve which collects


recieves and sends visual and hearing signals via communication between

Tag,Neurochip,Microchip brain Implant by a computer. The microwire which

works in real-time (the Tag, Neurochip,Microchip can communicate to the

patient(s) microwire implant inside the patients head by neural signals

and can

interoperate human voice, and visual cortex during real-time as the


Hilton(s) technician (Stefano Girardi) via the Technician can communicate


voice commands, and video cameras connected to the Defendant Hilton(s)


to visually communicate with the Tag,Neurochip, Microchip and send


graphics, pictures, video(s), with the actuator that interoperates and

sends real-time

communication(s) to the Tag, Neurochip, Microchip(s) wireless sensory


command] via electrical signals directly to the subjects brain through the

microwire electrode microchip that Defendant Hilton has been using to


Claimant Kelly. (see exhibit III.pdf and web.)

(b) Tag,Neurochip, Microchip brain Implant is a wireless Closed loop brain

interface (BCI, Brain Computer Interface) comprises TEFLON.RTM. Platinum,


tungsten, Coated stainless steel microwires receives motor command


algorithms comprised of an artificial neural network extracted microchip

implant able

in the brain of an human patient subject.Wherein the implant able Tag,


and the motor command can communicate wirelessly between the patient subject

the computer. Defendant Hilton has been using this Devise to give me

memories of Child molestation, like showing me in real time; sucking on a


year olds penis and describing what it tastes like (he said it tastes like a

chip and kind of rubbery they have also trained my mind to feel artificially

description them explicitly) Murders, Robberies, and Thefts, Defendant

Hilton broke and entered into Claimant Kelly’s home in Potosi, Missouri

a warrant as they told Claimant Kelly’s neighbors that they were the DEA Drug

Enforcement Agency and that they were investigating him for drug trafficking

and use, and stole several photographs of his family and he’s making pictures

naked children to frame Claimant Kelly with inwhich they are making and then

stating that these are Claimant Kellys which they allegedly stole or
confiscated. .

(c) The communication between the tag,neurochip and the motor command extraction,

the sensory information, and visual information and sensory feedback


acquired in realtime to the subjects brain and communicates to the Tag,

neurochip by

amplified signals adapted to communicate with the plurality of electrodes

signals from Defendants Hiltons computer wirelessly from a distance up to

Miles. Abbreviations ANN artificial neural network DPS digital signal


EEG electroencephalograph fMRI functional magnetic resonance imaging LAN


area network M1 primary motor cortex NMAP many neuron acquistion processor

dorsal premotor cortex PP posterior parietal cortex RMS root mean square SRAM

static random access memory TCP/IP transmission control protocal/ Internet


device, which collects data to a data acquisition module (computer) by extra


electrical signals. (exhibit VI: US patient No:7209788 MRI March 3rd.2008)

(d) Tag microchip is wireless. The closed loop brain-machine interface that

Brain -derived signals and is advance beyond prior art apparatuses BCI brain

Tag,(RFID) Radio Frequency Identification Neurochips,interface inventions,


and propositions in the field of brain-machine interface which provides

communication between the patient and technician talking, and relaying video

through the computer, much like the internet communication devices between

people communicating via the internet wireless.

(e) MEMS (Micro-Electro-Mechanical-System) The Neurochip is a Integrated Circuits

(IC) microchip involve several million Micro-Transistors on a (Tag).which have

Micro-sized parts and IC, which are used in-vivo (human or primate tolerant
which can

be put in the brain) and have sensors and actuators that are mechanical
devices that

form integrated circuits to (bio-medical) micro machines that capture neurons

in a
micro cavity to obtain the electrical signal between neurons which makes it
possible in-

vivo receive neuron signals in-vivo by inserting micro neuron probes into the
brain via

are read by the motor command center, the data TCP/IP Transmission total

protocal/Internet protocal SRAM in the technicians computer (Exhibit III).

(f) Before Defendant Hilton started using Human Patients, he was using Primates,

so stated in the US patient No: 7209788 and other US patients as stated.

the Defendant Stated” well pay off court witnesses $10,000 dollars each.

Defendant Hilton stated” that they were DEA, agents to Claimant Kelly’s
neighbors in

Potosi, Dan and Val Burns of Arrow Graphics,.

17 143 South State Highway 21
Potosi, Missouri, 63664-3041


(26) Claimant Kelly further alleges that Defendant Hilton did use electronic
implants to

Claimant Kelly to disable Claimant Kellys Constituiional, and Civil Rights

for the

purpose to limit, control and stop this lawsuit by executive means using
George W.

Bush and Vice-President Joseph Biden, Donald Rumsfeld, and Attorney General

Ashcroft to control the Federal Government by unlawful,bribes,and select

aquainenances to influence Judicial decisions and control the FBI Federal



(27) Claimant Kelly alleges that his life was threatened and that he was tortured
and brain

washed by Defendant Rick Hilton, and Government official(s)and Hilton’s

employee(s) to murder him at WASHU Washington Memorial Hospital in St. Louis,

Missouri for obtainment of a U.S.Grant and for filing this lawsuit. Claimant

son Nicholas Ryan Kelly and daughter Brittany Morgan Kelly lifes were
threatened by

Defendant Hilton stating that he was going to put a Tag,Neurochip Microchip


in this head and brain wash and torture them because Claimant Kelly is filing

lawsuit.These threats were done remotely and electronically so they could and
would be

denied by the Government and corrupt judges that protect Defendant Rick Hilton

corrupt agents in the Government under Vice-President Joseph Biden and George

Bush that work under their direction of his appointees.This outrageous conduct

Defendant Rick Hilton continues even today since March 3rd. 2008, thru and to

present and Defendant Rick Hilton uses these Government authorities to torture,

oppress, and corrupt Claimant Kelly.

(28) As Direct and proximate cause of Claimant Kelly’s loss of trust in the

Government, capacity, and continuous mental and physical torture sustained by

Defendant Rick Hilton. Claimant Kelly has been deprived of his standard of

desired by him and lead a happy and satisfying life and family life and his
privacy, due

process, peace and right of association provided by Claimant Kelly’s family and

friends. And has further deprived of and loss of benefit of his family and

love,affection,companionship,confort,sex,guidance,economixc stability, security,


trust in the Government, and further Claimant Kelly Claimant Kelly incurred

and other personal effects stolen from him (family photos) on information and
belief on
those grounds.

(29) As further direct and proximate cause of the acts and conduct of the

while engaging in violating in Claimant Kelly’s Constitutional Rights Claimant


Believes Defendant Rick Hilton and the other Defendants failed to use reasonable

and reckless and negligent selection, hiring and said police officer(s) Neno and

continues to threaten life in threatening situations, abuse and legal process

and gross

violation of Claimant Kelly’s Federal and State Constitutional Rights.

(30) The United States of America and Vice-President Joseph Biden and George W.

had a duty to protect and prevent the violation of Claimant Kelly’s federal and

Constitutional Rights, and further to protect Claimant Kelly from dangers and

inadequately trained, educated and skilled agents, police officer(s) employees


Defendant Rick Hilton’s and negligent acts of the afore said.

(31) Defendant Rick Hilton and the United States of America and Vice -President

Biden and George W. Bush had a common law and statutory duty to protect

Kelly pursuant to the Constitution of the United States of America and the

Statutes, including 28 U.S.C. 2674 and regulations pertaining to law enforcement

and its

relative investigative activities and management of agents and police officer(s)


conducting Defendant Rick Hilton’s U.S.Grant(s).

(32) In addition to liability imposed on Defendant Hilton and the United States

America due to its respective breach of duty common law and statutory duties

violation of Claimant Kelly’s federal and Constitutional Rights to protect him


torturous acts. The United States of America and Vice -President Joseph Biden

George W. Bush is also liable to Claimant by virtue of respondent superior due


wrongful and torturous acts.

(33) Defendant Rick Hilton was reckless and negligent and failed to exercise

care in both its common law and statutory duty to protect Claimant Kelly.

(a) Right to Know Act of 2003 15 U.S.C 1453 Section 6 (6831.CH.94--Privacy


to comply with a Court Order. A Municipal entity or Public Offical who does not

comply promply with a Court Order under Right-to-Know-law is subject to criminal

penalties of $500 Dollars per day until public record is provided by Defendant

Hilton. This Court may impose Sanctions 2. Bad Faith Denial. A Court may impose

Civil Penalty of not more than $1,500 if a Municipal entity denied access to

record in bad Faith.65 P.S. Section 67.1305(a).Under Federal law 42 U.S.C.1988


include monetary damages.

(34) The United States of America was reckless and negligent and failed to

reasonable care in both common law and statutory duty to protect Claimant

Constitutional Rights under Federal Law.

(35) From March 3rd.,2008 and continuing thereafter to present, the Defendant(s)

Vice-President Joseph Biden, and George W. Bush and respective Defendant(s)and


respective agents, police officer(s) and employee(s) of Defendant Rick

Hilton had no reasonable suspicion or probably cause of criminal activity to


such torture, or fabrication of evidence, or gross negligence in violation of


Kelly’s Constitutional Rights and Common Law Rights.

(36) From March 2008, and continuing thereafter to the present, Defendant Hilton

the United States of America, and their respective agents, police officer(s)

Defendant Rick Hiltons employees had a duty under the Forth and Fourteenth

Amendment to the Constitution of the United States to properly provide such


protections so as not to violate Claimant Kelly’s Constitutional Rights, and

due process

rights. Each and all of the afore said Defendants did not provide adequate

and violated Claimant Kelly’s First,Second,Fourth,Fifth,Seventh,Ninth, and


Amendment Rights under the Constitution.

(37) From March 2008 and continuing thereafter to present, Defendants and each of

used improper, excessive and illegal surveillence activities, fabrication of


abuse of process and implanted torturing device(s) in Claimant Kelly’s body,


caused Claimant to sustain life threatening physiological and psychological


pain and suffering. They failed to remove the torture device(s) from Claimant

body or provide adequate medical care to Claimant by negligently failing to


Claimant’s psychological and physical condition which has resulted in extreme


and physical distress.

(38) The Defendant Rick Hilton and the United States of America, and each of the

Defendants individually, are directly liable for deprivation and violations of


civil rights on grounds that Defendant Rick Hilton and the United States of

and each Defendant individually continue to violate such rights, and


indifference and with conscious disregard for Claimant’s life and

Constitutional Rights

and personal rights and safety of public guaranteed under Federal Rules and

Regulations pertaining to the lawful use and illegal surveillance, force,

medical needs

and provisions of care to Claimant, who has been psychologically and physically

injured from such unlawful conduct. The Vice-President, Joseph Biden and

George W. Bush have disregard for the Claimants Constitutional Rights and
safety of

public guarantee in which the Defendant(s), agents, police officer, and

Defendant Rick

Hilton’s employee(s) employ excessive and illegal activities, violence which

results in

the denial and violation of Claimant’s and other personal rights within its

protection of their Federal and State Constitutional Rights/or basic medical

care for

serious injuries or illnesses caused by torture in belief that such wrongful

acts will not

stop on the grounds that the violation of rights and deliberate indifference

conscious disregard for Claimant’s Constitutional Rights, personal rights and

safety will

continue by Defendant Rick Hilton.

(39) As further Direct and proximate result of violation of Claimant Kelly’s

rights to

privacy, violation of Claimants rights to due process, Claimant has and will
continue to

suffer significant grief, sorrow, shock, depression, pain and suffering, both

psychological and emotional, humiliation and other general damages for which he

entitled to a fair and just compensation in an amount of $20 Million Dollars or

according to proof of trial.

(40) The actions of the Defendants deprived Claimant Kelly of the following
rights under

the Constitution of the United States of America, including the

First, Second, Fourth, Seventh, Ninth and Fourteenth amendments; (a) freedom

the use of unreasonable and excessive force; (b) freedom from the deprivation
of life a

and liberty without due process; (c) freedom to be secure in his person; (d)

from the unnecessary and wonton infliction of pain and suffering; (e) freedom
from the

deliberate indifference to his serious medical and psychological needs due to

torture; (f)

equal protection under the law; and (g) freedom of his personal papers, effects

things from government intrusion and (h) freedom to have right to privacy.

(41) As a result of foresaid actions of Defendant Rick Hilton and the United
States of

America, Vice-President Joseph Biden, and President George W. Bush Defendant


Hilton’s employee(s) agents and officers, being a citizen of the United States

America and a resident of the State of Missouri, Claimant Kelly was and
continues to

be deprived of his rights and inalienable rights, privlages, and immunities

secured by

the Constitution of the United States of America, Claimants personal liberty

has been

violated, he has and continues to suffer physical, mental and emotional harm,

durness ,fear, and humiliation, torture and general pain and suffering in, on
and upon

Claimant’s body in the amount according to proof at time of trial. Claimant


leaves here to amend same when ascertained.

(42) Claimant Kelly is entitled to costs of suit, including reasonable attorney


investigation and other fees pursuant to 42 U.S.C. 1988, however not limited

under Federal Private Attorney Act in the amount according to proof.

(43) To the extent available under Federal Law, Claimant Kelly is entitled to

Punitive Damages in the amount sufficient to punish the Defendant (s) and

and Defendant Vice-President Joseph Biden and George W. Bush and Defendant Rick

Hilton’s employee(s) in order deter similar despicable conduct in the future in


amount according to proof under Federal Law, 150 Anz. 326 (1986). Claimant

here to amend this paragraph according to proof.

(b) Defendant Rick Hilton was told by the United States Government to compensate

Patient, subjects and Defendant Kelly according to Grant specifications and


refused such payment to compensate.

( c) To the extent under Federal Law Claimant Kelly is entitled to Punitive

Damages, under the Title II American with Disabilities Act and

(44) WHEREFORE, Claimant prays for judgment against Defendants and each of them,
individually; jointly and severally as follows:

1. For all compensatory damages for pain and suffering, ect. In the amount of $20
Million Dollars or according to proof.

2. For all costs of suit, including attorney fees, investigators, and other fees
and costs pursuant to 42 U.S.C. 1988 or/ and the Private Attorney General Act or
according to proof.

3. For all special damages in the amount of $40 Million Dollars according to

4. For all treble damages based on compensatory damages per RICO statute
according to proof.

5. For all costs incurred in this action according to proof.

6. The Court is hereby demanded to make specific findings of fact and conclusion
law, pursuant to Federal Code of Civil Procedures, Rule 52, on each and all issues

Of specific and ultimate facts raised in this Complaint, Claimant hereby reserves
the right to amend all paragraphs. [This demand shall constitute a continuing
demand and shall not be deemed waived unless specially done so by Claimant in
writing in a separately filed pleading with the court entitiled “Notice of waiver
of Finding of Fact and Conclusion” notarized.

7. For all pre-judgment interest in the amount according to proof; And

8. For all such other further relief as the Court deems just, fair and proper
under the circumstances.


Michael R. Kelly
4550 Sky-View Dr.
Arnold, Mo. 63010
PH# (636)296-819 CELL# (314)723-4249


Copies of Notice of Government Claim

Mailed by certified mail this___________ day of ______________________.

Rick Hilton (of Hilton Hotels and Hilton Headshop and Hyland Real Estate of
Beverly Hills California)
Los Angels California
Whispering Willows

Ph# (310)278-3311
Hilton Head Island;
35 DeAllyon Drive
29938, Hilton Head Island, SC,USA
Office: 617-583-1122 Fax: 617-583-1298
E-Mail: villa
And: William Baron Hilton, Richard Hilton (of Hilton Hotels), Paris Hilton

Vice-President: Joseph Biden

White House
1600 Pennsylvania Ave. N.W.
Washington, D.C. 205000
Switchboard: 202-456-1414
Fax: 202-456-2461

Attorney General: John Ashcroft

950 Pennsylvania Ave. N.W.
Washington, D.C. 20530-0001
Switchboard: 202-456-1414
Fax: 202-456-2461

President: George W. Bush (in the year of 2008)

1600 Pennsylvania Ave. N.W.
Washington, D.C. 20500
Fax: 202-456-2461

Rick Hilton’s employee (s)

Robert Wayne Smith
And Kimberly Clare Smith
9921 Musick Rd.
St.Louis,Mo. 63123

Lee Hefley (Wilburn Lee Hefley)

Heather Hefley
Preacher- Joyce Meyer
U.S. Headquarters
P.O.BOX 655,
Fenton,Mo. 63026