IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS DALLAS DIVISION

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP79M00467A000300130038-4
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 6
• Document Creation Date: December 16, 2016
• Document Release Date: May 6, 2003
• Sequence Number: 38
• Publication Date: June 1, 1976
• Content Type: COURTFILE

Approv
or Release 2004/12/20 : CIA-RDP70467A000300130038-4
IN THE UNITED STATES. DISTRICT COURT
FOR THE NORTHERN DISTRICE OF TEXAS
DALLAS DIVISION
Frances Hilliard Brown )
3248 Chapel Creek # 108 )
Dallas, Texas 75220 )
4100 Bryan
Dallas, Texas
American Telephone & Telegraph )
Company (Nation-Wide System) )
New York City, N. Y.
c/o District Manager, W.E.White ' )
L. S. Di3T 147 COURT
NORTHERN DISTRICT OF TEXAS
FiL.ED
J L I H 1 913
Plaintif Y SETH McELROY,JR.1CLERK
D 2u.
CA 3-76-0754..
Defendant
Cause of Action: Obstruction of Justice, Deprivation
of Plaintiff's Constitutional and
Civil Rights, and Illegal Monitoring
JURISDICTION
Plaintiff brings this action under Title 42, Section
1985 and 1986 U.S.C. against the American Telephone & Tele-
graph vompany's (Wat Lines) for conspiring to obstruct justice
and in collusion with it's subscribers to deprive plaintiff of
fundamental rights and freedoms guaranteed by the laws and Con-
stitution of the United States. Jurisdiction is conferred on
the Court by jXitle 28, Section 1343 U.S.C.
In addition to the afore-mentioned civil action, plain-
tiff alleges that a criminal act has been committed in violation
of Title 18, Section 2510, 2511 and subsequent sections dealing
with illegal monitoring and unlawful uses of a communication
system.
II r"n,
f
STATEMENT OF CLAIMS
(A)
The Obstruction of Justice complaint arises from.
the difficulty the plaintiff encountered in endeavoring to un-
cover facts with would have established the jurisdiction of the
OGC Has Reviewed
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Federal Court in an action against Baylor-Dallas, Baylor-
Houston, Scott & White Clinic (CA 3-74-115-E). And in simi-
lar actions against Dr. J. Hobson Crook (CA 4-75-204) and
Dr. J. E. riyers(CA 4-75-205). This failure led to a dis-
missal of the actions due to lack of jurisdiction, when had
her efforts been sucessful and the case tried on its merits,
a different outcome might have ensued. In the aforementioned
actions the plaintiff had alleged her constitutional and civil
rights hid been violated by the implanting of electronic de-
vices.
Plaintiff maintains that because of electronic moni-
toring of her thoughts and actions through the use of WAT lines
and through the use of computers utilizing A.T.& T. lines
that every effort to secure information which would sustain the
allegations met with failure
(b) Further, plaintiff alleges that A.T.& T. shares a
joint culpability with it's subscribers in the original charges
in as much as she has never at any-time given her permission to
such implantation or subsequent monitoring.
(c) Finally, the plaintiff alleges that A.T. & T. has
been guilty of a gross and unprecented violation of the Fed-
eral Statutes Title 18, Sections 2510 and 2511. And that hav-
ing been guilty of said violations did permit their lines to
be used by all those who would harass the plaintiff in an effort
to establish probable cause.
LIMITATIONS
This action is filed in the District Court within
two years of the time the original case was dismissed, May 31
1974. This to comply with the Federal Statute of Limitations
for Damages and Personal Injury, as well as the Texas Statute
as specified by Texas Civil Statutes, Title 91, Article 5526 (6).
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The plaintiff has realized for some time that private
WAT lines were involved in. her problems, but she did not,know
the specifics by which they operated. Neither did she know the
circuit in her brain was one maintained by A.T.& T.. Arrangements.
for a deposition by means of written interrogatories had been
filed seeking information from the Company but due to the dis-
missal of the Case, were never asked.
IV
OTHER PARTIES TO THE LITIGATION
As indicated in the accompanying Motion, the plain-
tiff has on file in the District Court "Obstruction of Justice"
charges against I.T.& T.(World Comm) as well as charges against
Mr. James H. Holmes, III, Mr. C. A. Searcy Miller, Mr. Ralph
Hartman, Mr. Richard Gray, Attorneys for the original defendants.
Also on file with the Court are complaints against the
Department of Health, Education & Welfare, the Department of De-
fense and the Central intelligence Agency for "obstruction of
justice" and "illegal monitoring". Accompanying the complaints
against the Federal Agehcies is a request the"obstruction of
justice" charges be combined with prior pending cases to save.
time and piecemeal litigation. A similar Motion is being sub-
mitted to the Court with this Complaint.
RELIEF REQUESTED
Plaintiff is seeking an injunction against any further
monitoring, electronic harassment of whatever nature, backed by
law enforcement. She is also seeking some $48,000 reimbursement
for monies spent in trying to obtain relief, salary retroactive-
to. 1969 and until age 65 (1980) and whatever relief is possible
medically without changing the plaintiff's brain pattern. In
addition she has asked the Court to assess whatever punitive
damages are equitable.
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VI
9ONCLUSION
Wherefore, theplaintiff prays that a speedy and just
resolution may be had to the controversy and that she may be
granted the relief to which she is entitled. And that any
parties or attorneys connected in anyway with this and pre-
vious actions be enjoined from collecting any fees or expenses
of what-so-ever nature and be restrained from any action
against the plaintiff.
Respectfully submitted,
Dated Junet 1976 Signed
Frances Hilliard Brown
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CERTIFICATE OF SERVICE
This will certify that copies of the attached Motion and
accompanying Complaint against A.T.& T. have this day been
sent by certified mail to the following:
Dr. F. David Matthews, Sec'y 330 Independence Ave. S.W.
Dept of Health, Education & Washington, D. C. 26&l
Welfare
Mr. Donald Rumsfeld, Sec'y The Pentagon
The Department of Defense Washington, D. C. 20301
Mr. George Bush, Sec'y
The Central Intelligence Agency Washington, D. C. 20505
Mr. Logan Ford, representing Mr. James Holmes, - Baylor-Dallas
1511 Fidelity Union Life Building
Dallas, Texas 75201
Mr.. L. W. Anderson representing Mr. Searcy Miller, Baylor -Houston
3100 Fidelity Union Tower
Dallas, Texas 75201
Mr. David S. Kidder, representing Mr. Richard Gray -Dr. J. E. Myer
.3200 Republic National Bank Building "J.Hobson Croo
Dallas, Texas 76201
Mr. John Skrhak representing Mr. Ralph Hartman, Scott & White
4300 First National Bank Building Clinic
Dallas, Texas 75202
Mr. R. Glen Ayers, Jr. Attorney for I.T.& T. (World-Comm)
3600 First National Bank Building
Dallas, Texas 75202 %
Dated June% 1976 Signed ,
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