UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA FRANCOIS E.M. GOUAHINGA ) ) Plaintif Case: 1:16-cv-02481 ) Assigned To : Cooper, Christopher R. : Assign. Date : 12/20/2016 ) Description: P.1,/Malpractice ALI BONGO ONDIMBA i : ) ) and ) MICHAEL MOUSSA ADAMO. ) A ) ) and ) GOVERNMENT OF THE ) GABONESE REPUBLIC ) Lb & , ) ) DefendantsCOMPLAINT 1, the undersigned, Francois E.M. Gouahinga (“Plaintiff”), on behalf of myself and all other similarly situated United States nationals of Gabonese origin, respectfully bring this action against ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO, and the GOVERNMENT OF THE GABONESE REPUBLIC (collectively, “Defendants”), and allege as follows: 1 2. Tam a national of the United States, with established residence in Maryland. 1am filing this action both as a victim and as a claimant, based on multiple instances of injury inflicted on me by Defendants jointly, severally, and in solido. Defendants are aliens of sordid notoriety; they are sued herein both in their individual capacity and as foreign officials who use diplomatic status as a cover for a variety of transnational illicit activities that include human trafficking, vote rigging, bribing of United States officials, racketeering, massive embezzlement, murder, money laundering and wire fraud. Lam seeking relief for various injuries inflicted upon me by Defendants both overseas and in the United States. In June 2007 while vacationing in Gabon I was unlawfully detained and tortured by Defendants, acting individually and in concert, as well as other co-conspirators not yet identified, and of their agents, servants and/or employees acting within and during the course and scope of their employment, authority, or apparent authority. Also, between August 31, 2016 and December 19, 2016 Defendants inflicted intentional emotional distress on me by brutally assaulting, kidnapping, maiming,torturing physically and psychologically my mother, my sisters, my brothers, my nieces, my nephews, my aunts, my uncles, my cousins, as well as childhood friends. 7. Defendants further inflicted intentional emotional distress, as well as loss of consortium, on me by unlawfully detaining two United States citizens who are friends of mine: MR. LANDRY AMIANG WASHINGTON (from Miami, Florida) and MR. BERTRAND ZIBI (from Omaha, Nebraska). 8. This is an ongoing injury, given that these two friends of mine are still unlawfully detained to this day. 9. In addition, since August 31, 2016 until the time of this filing, Defendants engaged in a garden variety of tortious acts that caused further injuries on me, such as cyberbullying and the intentional distribution of particularly shocking images in order to send the message that I am no longer welcome in the country of my birth and where my mother and siblings, and longtime friends still reside to this day. 10, Furthermore, I am also seeking compensatory relief for loss of income suffered in June 2007 as a result of Defendants’ willful, tortious acts. 11. Lam also seeking relief for loss of income suffered from August to December 2016 as aresult of Defendants’ tortious acts. 12. Up until this point Defendants were able to evade accountability by asserting the doctrine of sovereign immunity. This shield was busted on September 28, 2016 when Congress, in its infinite wisdom, enacted the Justice Against Sponsors of Terrorism ‘Act (JASTA), under which this action is brought.13. 14, 15, 16, 17. 18. 19. PARTIES Plai {f Francois E.M. Gouahinga is a national of the United States and a resident of Maryland who was born in Gabon, where his mother, siblings and other close relatives currently reside. Plaintiff, who served as spokesman for the US-based Gabonese diaspora which forcefully denounced Defendants’ it actions, was unlawfully detained and tortured at the hands of Defendants and their agents in 2007. . Defendant Ali Bongo Ondimba is the head of state of the Gabonese Republic, a position which Defendant uses to further his illegal activities, such as bribing United States officials, large-scale embezzlement, human trafficking, murder, money laundering and wire fraud, He is being sued herein both in his individual capacity and as head of state. Defendant Michael Moussa Adamo is the ambassador of Gabon to the United States. Defendant is a close friend of Defendant Ali Bongo Ondimba’s. A 2010 US Senate report identified Defendant Michael Moussa Adamo as a chief facilitator of money laundering operations and other illicit activities. He is being sued herein both in his individual capacity and as an agent and representative of Gabon, Defendant Government of the Gabonese Republic is an agency or instrumentality of a foreign state within the meaning of 28 U.S.C. § 1391(f) and1603(a). Defendants jointly or individually own substantial real estate holdings in the United States, including within the jurisdictional boundaries of the District of Columbia. All three Defendants can be reached by way of the Gabonese embassy at 2034 20th Street NW, Washington, DC 20009.JURISDICTION 20. Plaintiff, a United States national, brings this action pursuant to the Anti-Terrorism Amendments to the Foreign Sovereign Immunities Act, 28 U.S.C. § 1602, et seq 21. Jurisdiction in this Court arises pursuant to 28 U.S.C. §§ 1605A, 1605B, 1330(a), 1331 and 1332(a)(2) 22, On September 28, 2016, Congress passed the Justice Against Sponsors of Terrorism ‘Act (JASTA), which provides jurisdiction to this Honorable Court in any case where damages are sought against a foreign state, its agents and representatives for injury to person, property or death caused by, infer alia, “a tortious act or acts of the foreign state, or of any official, employee, or agent of that foreign state while acting within the scope of his or her office, employment, or agency, regardless where the tortious act or acts of the foreign state occurred.” 28 U.S.C § 160SB(b). 23. Venue is proper in this District pursuant to 28 U.S.C. §1391(0(4). FACTS OF THE CASE A. Plaintiff's unlawful arrest, detention and torture by Defendants in June 2007 24, On June 8, 2007 Plaintiff Francois E.M. Gouahinga was arrested by police in Libreville, Gabon under false pretenses. Plaintiff was unlawfully detained for 4% days during which Plaintiff was subjected to physical and psychological torture, as well as cruel and unusual punishment. [see Exhibit A]2s. 26. 27. 28. 29, 30. Defendant Ali Bongo Ondimba was the minister of defense at the time and a key member of Gabon’s national security apparatus. Plaintiff was working at the time as a reporter for allAfrica.com, the leading news website dedicated to Aftican affairs Plaintiff was placed in a police van. Plaintiff then sent a text message to a longtime friend, ras informing him of Plaintiff's arrest and the location of the police precinet where Plaintiff was being taken to. es arrived at said police precinct and was immediately placed under arrest when he told officers on duty that he worked for one the local television stations. Plaintiff and his friend were reunited in a cell a while later, after being ordered to take off their clothes except underwear, Plaintiff and his friend were later moved to another cell, the existence of which was not known to the public. ‘The floor was rough, and the only source of lighting came from two openings riddled with steel bars carved high on two of the side walls. Additional narrow cylindrical openings in the walls just beneath the vertical openings were the detainees’ main source of air. . The walls were heavily soiled with dirt and mold. On one corner there was what once served as a toilet sitting on a small concrete elevation. Plastic bottles, chunks of cardboard, and excrement buildup formed a pile on top of the toilet. Lots of cockroaches crawled in and around the clogged toilet, with many more running along the walls, Much of the staining on the walls came {rom prisoners crushing cockroaches with the swing of a plastic bottle,The entire cell stank of putrefaction, rottenness, urination and other forms of human excretion. There was vomit at the bottom of the toilet, and unidentifiable residue that had long mixed with water and urine, further aggravating Plaintiff's breathing conditions. There were 16 other persons in that cell when Plaintiff was thrown in and an additional seven were added over the days that Plaintiff and his close friend Ear PE 2<~ 1cp¢ there. Detainces slept on pieces of cellophane, except a luck who had cardboard chunks. few 33. Every moming, detainees were individually called for the synthése, a daily c e review to determine those that warrant prosecution. Plaintiff and his friend Ea | told theirs was a “special case” awaiting instructions from higher authorities, including Defendant Ali Bongo Ondimba, 34. On June 11, 2007 a detainee that was released after the morning synthése called Plainti family and informed them of Plaintiff's whereabouts. 35.A couple of hours later, Plant's sist nd 0 other family members came tothe location where Plaintiff and his fiend A were detained, but they were not allowed to see them. They were told that evidence found on Plaintiff, consis ing of a laptop computer, a camera, a digital audio recorder, and a press card, was sufficient to establish that Plaintiff was “a spy.” 36. The police then threatened Plaintiff's family. They told them Plaintiff was guilty of a criminal offense so serious that it could cause every single member of Plaintiff's extended family to permanently lose their jobs. 37. Plaintiff's38. Plaintiff"s employer was notified of Plaintiff's detention thanks to his sister. Calls were made to Gabonese and United States officials in order to secure Plaintifi"'s release, 39. In the morning of Tuesday, June 12, 2007 Plaintiff and his close ‘ied were taken to the Préfecture, or police administrative headquarters downtown where orders were given for their release. 40. Throughout Plaintiff's and his close ven detention, they were subjected to cruel and inhumane treatment, as were the other detainees, many of whom were innocent of the allegations leveled against them. 41, Plaintiff suffered from recurring nightmares, post-traumatic stress disorder and had to seek professional counseling as a result of this ordeal suffered at the hands of Defendants. 42, In December 2015 Plaintiff's father passed away, however Plaintiff was unable to go to his father’s burial for fear of being arbitrarily detained and tortured once again by Defendants. Plaintiff has suffered additional severe emotional distress as a result, given that as a practicing animist Plaintiff is bound to religiously observe burial rituals in accordance with Bantu tradition. Failing to attend one’s father’s burial can expose Plaintiff to adverse consequences in this realm as well as in the afterlife. B, Defendants’ unlawful arrest and detention of two United States citizens in 2016 43, On August 12, 2016 Mr. Landry Amiang Washington, a United States citizen of Gabonese origin and a friend of Plaintiff's, was arbitrarily detained soon after he exited the airplane that took him from the United States to Gabon. He is being heldwithout bond in excess of the 48-hour maximum imposed by Gabonese law. Shortly before embarking on the trip, Mr. Washington had posted a video on the social media network Facebook, where he denounced Defendant Ali Bongo Ondimba and Defendant Government of the Gabonese Republic for their incompetence. To this day he remains in unlawful detention in Gabon, where his request for consular assistance has been denied, in violation of established international norms. [see Exhibit C] 44, On August 31, 2016 (3 days after the presidential election in Gabon and before official results were released) armed forces loyal to Defendant Government of the Gabonese Republic stormed the campaign headquarters of opposition candidate Jean Ping, the main challenger to then-incumbent Defendant Ali Bongo Ondimba. [see Exhibit D] 48. They arrested hundreds of unarmed Jean Ping sympathizers, including Mr, Bertrand Zibi, a United States citizen from Omaha, Nebraska. Mr Zibi, who is of Gabonese origin, is a former member of parliament whose alleged crime was to publicly confront Defendant Ali Bongo Ondimba during a gathering that was broadcast live on television. The humiliation felt by Defendant Ali Bongo Ondimba prompted him to order Mr. Zibi’s arrest and unlawful detention to this day, which is way beynod the 48 hours maximum time allowed under Gabonese law. [see Exhibit E] 46. Both detainees, Mr. Landry Amiang Washington and Mr. Bertrand Zibi were close friends of Plaintiff's, 47. Upon learning of their illegal arrest and unlawdul detention, which continues to this day, Plaintiff suffered a severe case of emotional distress, especially since realizing that Plaintiff would likely suffer the same fate — if not worse ~ for publicly calling out10 the regime led by Defendant Ali Bongo Ondimba, of which Defendants Michael Moussa Adamo and Government of the Gabonese Republic are key members. [see Exhibit F] 48, These unlawful arrests and ongoing detention caused Plaintiff to reminisce on the unlawful arrest, detention and subsequent torture endured by Plaintiff at the hands of Defendants. 49. This has caused Plaintiff to suffer from sleepless nights, a high number of telephone calls overseas, and emergency money transfers. 50. All of these actions caused Plaintiff to suffer monetary loss, both in the form of forced expenditure and missing days from work. BACKGROUND AND CONTEXT 51. Gabon gained independence in 1960. In 1967, Defendant Ali Bongo Ondimba’s father, the late Omar Bongo, became president. 52. Shortly upon becoming president, Omar Bongo outlawed all political parties, except his own. At the time of his death in 2009, Omar Bongo had achieved the unenviable distinction of being the person who stayed in power the longest in the whole world. 53, Defendant Ali Bongo Ondimba took the reins of Gabon upon his father’s passing. He further concentrated power in his own hands and those of his family members and other cronies such as Defendant Michael Moussa Adamo, 54. Defendant Ali Bongo Ondimba has been the subject of several criminal investigations in many countries, however he has managed to escape accountability as a result of his status as a head of state. [see Exhibit G]55. 56. 37. 58. 59, 60. 61. uN In 2010, a United States Senate report on money laundering identified Defendant Michael Moussa Adamo as a chief facilitator of the Bongo family’s various criminal enterprises, including transnational money laundering. [see Exhibit H] ‘On August 27, 2016 Gabonese citizens had an opportunity to vote in the country’s first presidential election where Defendant Ali Bongo Onadimba’s father was not on the ballot Ahead of the election, Mr. Landry Amiang Washington, a United States citizen of Gabonese origin, traveled from his residence in Miami, Florida to Libreville, Gabon where he was hoping to help tum the page of half a century of the Bongo family’s clamp down on Gabon. Prior to his departure, Mr. Washington published a video on YouTube, a social media channel where he maintains a sizable following. In the video Mr. Washington called out Defendant Ali Bongo Ondimba and his cronies for their incompetence and lack of care for the poor in Gabon. The video went viral in Gabon. On August 12, 2016 Mr. Landry Amiang Washington, a florida-based United States citizen, was arrested at the airport and taken into custody, where he remains to this, day. Under Gabonese law, a suspect may be detained only for up to 48 hours without, charge. On August 31, 2016 Defendant Government of Gabon declared Defendant Ali Bongo Ondimba the winner of the August 27, 2016 presidential election. [see Exhibit I]12 62. These results were rejected by the European Union election observation mission in Gabon in a formal report that was postponed twice at the request of Defendant Government of Gabon. [see Exhibit J] 63. Likewise, the United States embassy in Libreville, Gabon challenged Defendant Government of Gabon to publish the tally sheets that allowed Defendant Ali Bongo Ondimba to claim victory. [see Exhibit K] 64, In an unprecedented move, Congressman Ed Royce (R-CA), the House Foreign Affairs Committee chair, called on Defendant Government of Gabon to initiate a transparent vote recount, [see Exhibit L] 65. Defendant Government of Gabon denounced both the European Union and the United States, accusing them of undue interference in the internal affairs of a sovereign state, 66. Hundreds of thousands of Gabonese citizens took to the streets to demand that Defendant Ali Bongo Ondimba reverse course and concede defeat to his challenger Jean Ping, who by all accounts was the rightful winner. [see Exhibit M] 67. In response, Defendant Ali Bongo Ondimba, aided and abetted by Defendant Government of Gabon, ordered a brutal crackdown on protesters. [see Exhibit B] 68. On August 31, 2016 Defendant Government of Gabon stormed the campaign headquarters of Jean Ping with heavy military weaponry, maiming and killing dozens of Jean Ping’s sympathizers. Up to 1,100 people were taken into custody on one night. 69. Those taken into custody included Mr. Bertrand Zibi, a United States citizen of Gabonese origin who had gained fame by publicly accusing Defendant Ali Bongo Ondimba of attempting to plunge Gabon into a civil war. Mr. Zibi remains in70. a nR. B. 74, 75. B detention to this day, well in excess of the maximum time allowed under Gabonese Jaw prior to a trial. ). Despite being United States citizens, neither Mr. Washington nor Mr. Zibi have been afforded the right of consular notification, access and due process. To this day several thousand Gabonese have been injured, maimed, imprisoned or killed, In protest of Defendants’ brutality and recklessness, the Attorney General of Gabon at the time, Dr. Séraphin Moundounga, resigned and fled the country fearing for his life. {see Exhibit P] Defendants’ actions are so outrageous that even the usually nonchalant International Criminal Court initiated a preliminary probe within days. [see Exhibit N] Defendants’ actions criminal in nature and outside the scope of the exercise of discretion that is traditionally granted to a sovereign. [see Exhibit O] Because by these outrageous actions Defendants caused injury to Plaintiff, a United States citizen, this suit is brought so that Defendants may finally be held to account and proper remedies applied for the benefit of Plaintiff.14 COUNTI DEFENDANTS ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO AND THE GOVERNMENT OF THE GABONESE REPUBLIC’S LIABILITY FOR UNLAWFUL DETENTION AND TORTURE OF PLAINTIFF IN JUNE 2007 76. Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs. 77. Plaintiff Francois E.M. Gouahinga is a national of the United States. 78. From June 8, 2007 to June 12, 2007 Plaintiff Francois E.M. Gouahinga was arbitrarily placed under arrest while vacationing in Gabon. 79. While under arrest, Plaintiff was subjected to physical and psychological torture at the hands of Defendants, their agents or employees, while acting within the scope of their office, employment or agency. 80. Defendants’ actions were the proximate cause of the injury sustained by Plaintiff, WHEREFORE Plaintiff, who is a U.S. national, demands judgment in his favor against Defendants and demands damages in an amount to be determined by a jury for damages arising out of unlawful detention and torture, plus interest, costs, punitive damages and such other monetary and equitable relief as this Honorable Court deems,15 COUNT I DEFENDANTS ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO AND THE GOVERNMENT OF THE GABONESE REPUBLIC’S LIABILITY FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS ON PLAINTIFF IN JUNE 2007 81. Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs. 82, Plaintiff Francois E.M. Gouahinga is a national of the United States. 83. From June 8, 2007 to June 12, 2007 Plaintiff Francois E.M. Gouahinga was arbitrarily placed under arrest while vacationing in Gabon. 84. While under arrest, Plaintiff was subjected to physical and psychological torture at the hands of Defendants, their agents or employees, while acting within the scope of their office, employment or agency. 85, Plaintiff's unlawful detention under horrendous conditions for 4 % days in June 2007 at the hands of Defendants caused Plaintiff to experience recurring nightmares, persistent flashbacks, and other symptoms indicative of post-traumatic stress disorder. 86. Upon release, Plaintiff sought medical care and counseling from a licensed psychiatrist. 87. Defendants’ actions were the proximate cause of the injury sustained by Plaintiff. WHEREFORE Plaintiff, who is a U.S. a ids judgment in his favor against Defendants and demands damages in an amount to be determined by a jury for damages arising out of intentional infliction of emotional distress in June 2007, plus interest, costs,16 punitive damages and such other monetary and equitable relief as this Honorable Court deems. COUNT III DEFENDANTS ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO AND THE GOVERNMENT OF THE GABONESE REPUBLIC’S LIABILITY FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS ON PLAINTIFF IN 2016 88. Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs. 89, Plaintiff Francois E.M. Gouahinga is a national of the United States. 90. Between August 31, 2016 and December 19, 2016 Defendants inflicted intentional emotional distress on Plaintiff by brutally assaulting, kidnapping, maiming, torturing physically and psychologically Plaintiff's mother, sisters, brothers, nieces, nephews, aunts, uncles, cousins, as well as childhood friends. 91. This happened in the aftermath of the 2016 Gabonese presidential election, which Defendant Ali Bongo Ondimba lost, but instead of conceding defeat like normal people do, Defendant Ali Bongo Ondimba inflated his score in the southeastern province of Haut Ogooué, where he obtained a staggering 95% vote count with a voter turnout of 97%. 92. These ox restrial results eked many, including Defenda: own supporters, causing protracted protests across the country and abroad. 93. Defendants, their agents or employees, while acting within the scope of their office, ‘employment or agency, unleased a brutal crackdown on protesters, pursuing them7 into their neighborhoods, torturing and killing many, including by the use of chemical ‘weapons. 94, Plaintiff's family members sustained injuries and lived in a state of terror as a result. of that extreme and outrageous conduct on the part of the Defendants, Many are still unaccounted for to this day. 95. The images of Defendants’ victims’ mutilated bodies, which have been circulating on social media, have reignited severe emotional distress in Plaintiff. 96. Defendants’ actions were so extreme and outrageous that even the ever nonchalant International Criminal Court launched an inquest into the matter within days. 97. Because of such extreme, atrocious and outrageous conduct by Defendants, their agents or employees, while acting within the scope of their office, employment or agency, Plaintiff suffered an acute form of anxiety, fearing for his family and friends. WHEREFORE Plaintiff, who is a U.S. national, demands judgment in his favor against Defendants and demands damages in an amount to be determined by a jury for damages arising out of intentional infliction of emotional distress in 2016, plus interest, costs, punitive damages and such other monetary and equitable relief as this Honorable Court deems.18 COUNT IV DEFENDANTS ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO AND THE GOVERNMENT OF THE GABONESE REPUBLIC’S LIABILITY FOR TORTIOUS ACTS THAT CAUSED PLAINTIFF TO SUFFER LOSS OF CONSORTIUM IN 2016 98. Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs. 99, Plaintiff Francois E.M. Gouahinga is a national of the United States who suffered from loss of consortium as a result of the arbitrary arrest and subsequent unlawful detention of two friends of Plaintiff's, MR. LANDRY AMIANG WASHINGTON (a United States citizen from Miami, Florida) and MR. BERTRAND ZIBI (a United States citizen from Omaha, Nebraska). 100. In addition, several members of Plaintiff's family, as well as childhood friends who reside in Gabon, have been subjected to arbitrary arrest, unlawful detention and torture. Many are missing to this day, and some are feared dead. 101 By these unlawful actions, which violate 18 U.S.C. § 956, Defendants inflicted loss of consortium on Plaintiff, who has been deprived of precious relationships, presence and comfort. WHEREFORE Plaintiff, who is a U.S. national, demands judgment in his favor against Defendants and demands damages in an amount to be determined by a jury for damages atising out of loss of costs, pu ive damages and such other monetary and equitable relief as this Honorable Court deems.19 COUNT V DEFENDANTS ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO AND THE GOVERNMENT OF THE GABONESE REPUBLIC’S LIABILITY FOR TORTIOUS ACTS THAT CAUSED PLAINTIFF TO SUFFER LOSS OF INCOME IN JUNE 2007 102, _Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs. 103, Plaintiff Francois E.M. Gouahinga is a national of the United States. 104, Plaintiff suffered income loss during the time that Plaintiff was arbitrarily arrested in June 2007 and unlawfully detained in Gabon for 4 % days by Defendants. 105. __Attthe time of the events, June 2007, Plaintiff was working as a paid journalist for allAfrica.com, the leading news website dedicated to African affairs, out of its office located in the Navy Yard section of Washington, D.C. 106. By unlawfully keeping Plaintiff in detention, Defendants denied Plaintiff the opportunity to earn money. 107. Defendants” actions outlined here are not a proper exercise of governmental discretion, as these actions are in violation of Gabonese law, United States laws (18 U.S.C. § 2340A and 18 U.S.C. §1201), as well as decency standards in the 21* century. WHEREFORE Plaintiff, who is a U.S. national, demands judgment in his favor against ndants and demands damages in an amou arising out of loss of income caused by Defendants in June 2007, plus interest, costs, punitive damages and such other monetary and equitable relief as this Honorable Court deems.20 COUNT VI DEFENDANTS ALI BONGO ONDIMBA, MICHAEL MOUSSA ADAMO AND THE GOVERNMENT OF THE GABONESE REPUBLIC’S LIABILITY FOR TORTIOUS ACTS THAT CAUSED PLAINTIFF TO SUFFER LOSS OF INCOME IN 2016 108, Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs. 109. Plaintiff Francois E.M. Gouahinga is a national of the United States. 110. Plaintiff suffered loss of income as a result of unlawful actions taken by Defendants Ali Bongo Ondimba, Michael Moussa Adamo and Government of the Gabonese Republic in the fall of 2016. 111, Defendant Ali Bongo Ondimba refused to concede that he lost the presidential election to challenger Jean Ping, and instead launched a very brutal assault on civilians, including Plaintiff's family members. 112, While Defendant Government of the Gabonese Republic actively assisted Defendant Ali Bongo Ondimba in carrying out these reprehensible, outrageous and extremely cruel acts, Defendant Michael Moussa Adamo aided and abetted by engaging in lobbying efforts aimed at shielding Defendants from any form of accountability abroad. 113, On multiple occasions, Plaintiff had to send money overseas to pay for food, medical expenses, funerals, and other unbudgeted costs. 114, Plaintiff furthered suffered loss of income in the aftermath of the 2016 Gabonese election by repeatedly making expensive intemational phone calls to inquire about, reassure and otherwise commiserate with family members and friends21 who were subjected to Defendants’ particularly brutal assault on anyone suspected of endorsing opposition candidate Jean Ping, who is the rightful winner of the 2016 presidential election in Gabon. 115 Defendants’ murderous rampage was the proximate cause of these financial losses. 116. Defendants’ actions outlined here are not a proper exercise of governmental discretion, as these actions are in violation of Gabonese law, United States laws, as well as decency standards in the 21* century. WHEREFORE Plaintiff, who is a U.S. national, demands judgment in his favor against Defendants and demands damages in an amount to be determined by a jury for damages arising out of loss of income and unplanned emergency expenditure caused by Defendants since the fall of 2016, plus interest, costs, punitive damages and such other monetary and equitable relief as this Honorable Court deems. COUNT VII DEFENDANT MICHAEL MOUSSA ADAMO’S LIABILITY FOR FAILURE TO WARN 117, Plaintiff incorporates herein by reference the averments contained in all 1g paragraphs. 118. Defendant Michael Moussa Adamo is the ambassador of Gabon to the United States and a close friend of Defendant Ali Bongo Ondimba. 119. Defendant Michael Moussa Adamo’s ties to Defendant Ali Bongo Ondimba go back decades. A 2010 report by the United States senate singles out Defendant22 Michael Moussa Adamo as a chief facilitator of the Bongo family’s various illegal schemes, including money laundering. 120. Because of their ties, Defendant Michael Moussa Adamo knew very well that his friend, Defendant Ali Bongo Ondimba, is a ruthless maniac who would seize every opportunity to exact revenge on those who, like MR. LANDRY AMIANG. WASHINGTON (a United States citizen from Miami, Florida), dare to challenge their unlawful deeds. 121. When Mr. Washington requested a visa to travel to Gabon in the fall of 2016, Defendant Michael Moussa Adamo knew that Mr. Washington would be ensnared ‘once in Gabon but failed to warn him, which led to Mr. Washington’s arbitrary arrest and unlawful detention in Gabon, which continues to this day. 122, Inso doing, Defendants violated 18 U.S.C. § 2340A, 18 U.S.C. §1201, and 18 US.C. $956. WHEREFORE Plaintiff, who is a U.S. national, demands judgment in his favor against Defendants and demands damages in an amount to be determined by a jury for damages arising out of failure to warn by Defendant Michael Moussa Adamo, plus interest, costs, punitive damages and such other monetary and equitable relief as this Honorable Court deems. COUNT VIII PUNITIVE DAMAGES 123. Plaintiff incorporates herein by reference the averments contained in all preceding paragraphs.23 124, Asset forth more fully above, all Defendants, known and unknown, unlawfully, wilfully and knowingly combined, conspired, confederated and agreed, tacitly and/or expressly, to unlawfully arrest, detain, torture, and/or inflict personal injuries upon the Plaintiff, his friends, and family members. 125. Asset forth above, Defendants unlawfully detained Plaintiff for 4 % hours in July 2007. 126. Defendants also killed a lot of Gabonese citizens who are close to Plaintiff, and continue to detain unlawfully two United States citizens who are friends of Plaintiff's, causing Plaintiff loss of consortium. 127, Defendants, a head of state, an ambassador and a government, conspired, ordered, and executed a cynical plot to kill hundreds of their own citizens in order to remain in power; these actions by Defendants are so outrageous and outside the norms of a civilized society that they cannot be tolerated and must be met with the harshest condemnation of our ordered legal system, 128. _Asaresult of the Defendants’ tortious acts, Plaintiffs suffered damages as fully set forth in the paragraphs above which are incorporated herein by reference. DAMAGES: 129. Asa direct and proximate result of the intentional, willful, reckless, and careless actions of the Defendants, Plaintiff has suffered severe and permanent personal injuries, damages, and losses, including the following: (@) the physical psychological torture endured while Plaintiff was unlawfully detained in 2007;24 (b) the physical psychological torture endured by Plaintiff in 2016; (©) the severe mental anguish suffered by Plaintiff in June 2007; (@) the severe mental anguish suffered by Plaintiff since the fall of 2016; (©) the severe pain and suffering suffered by Plaintiff in 2007; (Othe severe pain and suffering suffered by Plaintiff since the fall of 2016; (g) the loss of Plaintiff's earnings while in custody in June 2007; (h) the loss of Plaintiff's discretionary income that was diverted to care for family members and friends in Gabon since the fall of 2016; () costs relating to international phone calls, press conferences, as well as social ‘media marketing campaigns to sound the alarm on Defendants, who were killing with impunity; and (i) economic damages, pain and suffering, and punitive damages. 130. The aforementioned personal injuries, torture and losses incurred by the Plaintiff were caused by the intentional outrageous acts, recklessness, and carelessness of Defendants, acting individually and in concert, as well as other co- conspirators not yet identified, and of their agents, servants and/or employees acting within and during the course and scope of their employment, authority, or apparent authority. 131. Plaintiff demands judgment in his favor in general damages against all Defendants, jointly, severally, and in solido. 132, Plaintiff also requests an award of legal interest, costs, and such other relief as this Honorable Court deems appropriate.PRAYER FOR RELIEF WHEREFORE, Plaintiff prays that the Court grant judgment in his favor and against the Defendants, jointly, severally, and in solido and grant to Plaintiff: (a) Compensatory and punitive damages in favor of Plaintiff and against Defendants jointly, severally, and in so ido, in the amounts demanded in this Complaint for Damages; (b) Prejudgment interest or other appropriate interest; (©) Costs and expenses: (A) Legal fees; and (e) Such other and further relief as this Honorable Court may determine to be just and appropriate under the circumstances. Because Defendant Michael Moussa Adamo is a nonresident alien, may it please this Honorable Court to issue an injunction compelling Defendant to surrender his passport to USS. authorities so as to prevent him from fleeing the country and escape accountability DEMAND FOR JURY TRIAL Plaintiff demands trial by jury on all issues. PLAINTIFF pro se Boon .M. Gouahinga