CALIFORNIA v. PEARSON

Below is a declaration made by a California lawyer, which describes the use of Zersetzung techniques, drugs to block memory, and cybernetic implantation against an officer of the court, while it names particular places, programs, and people, which all check out.  I do not know Mister Pearson, but his story sounds authentic to me, and there is no question that the scum are trying to hush this up.  His story deserves to be told, and the trash behind his abuse need to be exposed.  For those reasons, I am publishing his declaration, made to the Superior Court of California, County of Sacramento, in Case No. 22MI009261, with respect to a hearing to be held before Department 3, on September 7, 2022, at 8:30 a.m. 

                        I, Andy Donald Pearson, under penalty of perjury, declare and state as follows: 

            1.         I am an attorney in good standing with the State Bar of California and I have been an officer of the court for over 10 years. Prior to the instant matter, I have never been arrested or charged with a crime before in my life.  

2.         I have been falsely arrested and wrongfully charged with violating California Penal Code § 273.6(a), initially I was charged with violating California Penal Code §166.4. I have been advised that at my next hearing, September 7, 2022, the DA will file additional charges. I have still not been legally served with the restraining order which I have been accused of violating. There is overwhelming evidence that the Sacramento County District Attorney is aware that I was falsely arrested on 5/28/2022 and the purpose of the arrest was to get me into the criminal system for it’s clear attempts at concocting charges against me and there was an ex-parte hearing, not for a TRO, but for a restraining order held on 5/27/2022 in which testimony was provided, and there is a transcript that I can obtain, which will reveal all of the parties that testified against me and my interests, with at least one acting as my LAR, despite that I have no LAR or surrogate decision maker and I make my own decisions, and this hearing was intended to make me appear to be mentally ill, violent, and worthy of placement into an illegal “clinical study” through CIA front company RTI International and the SIREN program run between UCSF and RTI International. 

A.        On August 16, 2022, at 11:26 am I emailed – PDWebmail@saccounty.net; Zane, Courtney; daoffice@sacda.org; dept3@saccourt.ca.gov; Sacramento Sheriff Internal Affairs: 

“To Whom It May Concern:  

Today Caroline Pearson provided my mail and a copy of a restraining order dated 5/27/2022, allegedly served by the Sacramento Sheriff on 5/28/2022. I WAS NEVER SERVED WITH ANY PAPERS ON 5/28//2022. I have still never been properly served. Sheriff’s Officer J. Wilhelm (badge #435) is a LIAR and the 5/28/2022 arrest was supposedly recorded with a body camera.  

This email is being sent to Courtney Zane because she is the Public Defender on record with the court even though she has been fired. I am waiting for the new public defender to contact me.  

Andy Pearson”. 

3.         This whole criminal case, since its inception, has consisted of numerous attempted frame-ups and set-ups to silence my attempts to STOP U.S. GOVERNMENT SANCTIONED TORTURE PROGRAMS committed under the guise of “clinical studies” pursuant to contracts between the Department of Energy and the Regents of the University of California (“Board of Regents”). 

A.        The structure and composition of the Board of Regents is laid out in the California Constitution, which establishes that the University of California is a “public trust” and that the regents are a “corporation” that has been granted the power to manage the trust on the public’s behalf. The California Constitution grants the regents broad institutional autonomy, giving them “full powers of organization and government.” The Board of Regents acts with impunity for its actions and has no oversight, since according to article IX, section 9, subsection (a), the regents are “subject only to such legislative control as may be necessary to insure the security of its funds and compliance with the terms of the endowments of the university.”  

B.        Due to the clear conflict of interest created by the California Constitution between the California Superior Courts and the Board of Regents, this matter is properly brought as a federal case in the United States District Court for the Eastern District of California. This is especially so since the Board of Regents is conducting highly illegal “clinical studies” with virtually no supervision or oversight since they are self-governing.  

4.         The reason I am a target is due to my detailed knowledge of illegal human “research” programs carried out internationally, nationally, and in California between the California State and local Governments, and the U.S. Government (i.e., Department of Energy, Board of Regents, etc.). I can identify most of the private and public partners; I can identify the “investigators”; locations where it is performed; their methods, etc. There is no other way to explain clandestine / classified human medical research experimentation / torture programs, so I provide a lot of detail, and documentation, which the government does not like. The government has designed at least one “model” which drugs unsuspecting “subjects” without patient consent, rendering them unconscious, leaving the subject with amnesia, and performing whatever medical procedures (UDEs and CDEs) it can to maximize its profits since this “model” incentivizes  such conduct.  

A.        I have never claimed to be a “Targeted Individual.” But, the experiences that I have had are similar to those who claim to be “Targeted Individuals.” There are thousands of people in the United States and worldwide who claim to be Targeted Individuals (“TI”). (See ¶¶ 84-91 below.). 

B.        On August 5, 2020 at 8450 Okinawa Street, Sacramento CA, 95828 it is likely that UCSF TRACK TBI researchers (“investigators”) implanted a device in my frontal lobe, which can be surgically implanted in under 25 minutes. There are FITBIR documents proving the placement of several different types of “microdialysis” devices implanted into TRACK TBI subjects’ frontal lobes. These documents were widely available on FITBIR under the TRACK TBI PILOT, which began in 2009.  UCSF has documented, and patented, the development of numerous “minimally invasive” surgical procedures. The effects of these devices are unknown. 

5.         The Sacramento County Sheriff’s Officers have been targeting me since I became vocal about illegal human medical experimentation research programs, TRACK TBI, (a U.S. government sanctioned “torture” program) and I have documented it fully since it occurred to me on 8/5/2020 at a military base located 8450 Okinawa Street, Sacramento, CA 95828. This whole criminal case, since its inception, has consisted of multiple frame-ups and set-ups, including false allegations: of my methamphetamine use; that I carry a “big knife”; and, that I threatened Caroline Pearson with a “big knife” while committing financial elder abuse. My mother, Caroline Pearson, told Andrew Pearson that she was directed by Sacramento County Sheriff’s Officers what to write on her TRO petition and that she was told to put down that I had a “big knife.The current Restraining Order issued 5/27/2022 omits this language. 

6.         It is obvious why no action was taken to stop this illegal government human medical experimentation research, despite my numerous requests, which only resulted in the increased targeting of me as the subject and victim of illegal human medical experimentation / U.S. Government sanctioned torture.  

A.        It is clear that the Sacramento County Sheriff’s Department plays a crucial role in these illegal human medical experimentation research programs. (A true and correct copy of the UCSF TRO Petition is attached hereto as Exhibit Z, see “Declaration of Waimen Chee”; and, a true and correct copy of communications with law enforcement (Sheriff & Sacramento PD) Internal Affairs Departments is attached hereto as Exhibit X.). 

B.        It is clear that the Sacramento County District Attorney is aware of these illegal human medical experimentation research programs and partakes in these programs. (See ¶61 below for an email that I sent repeatedly to the Sacramento County District Attorney’s Office.). 

C.        It is clear that the County of Sacramento Public Defenders Office is aware of these illegal human medical experimentation research programs and partakes in these programs as demonstrated by the conduct of the Public Defender’s office and Courtney Zane.  

D.        It is clear that virtually all levels of government including the Superior Courts of California are aware of these illegal human medical experimentation research programs. (A true and correct copy of the August 16, 2021 restraining order hearing in Regents of the University of California, UCSF, on behalf of Dr. Geoffrey Manley by Kathryn Mente v. Andy D. Pearson is attached hereto as Exhibit E.). 

            7.         Based on the past conduct of State of California agencies, The Sacramento County District Attorney, Public Defender, and the Superior Court of California, San Francisco, I will never get a fair trial in the California Superior Courts. I therefore will file a federal suit in the Eastern District of California with Torture as the primary cause of action; an injunction to prevent future wrongful government conduct; and, I am filing a CCP § 404.5petition for a stay of the criminal proceedings in Case No. 22MI009261 in the Superior Court of California, County of Sacramento.  

8.         Since August 5, 2020, I have been targeted and harassed by the Sacramento County Sheriff’s Department and I was forced to make at least three separate internal affairs complaints with the Sacramento County Sheriff’s Department Internal Affairs division for its harassment, which continues to the present date. (A true and correct copy of the communications with law enforcement (Sheriff & Sacramento PD) Internal Affairs Departments is attached hereto as Exhibit X.). 

9.         The Sheriff’s illegal surveillance of me began on July 31, 2020, when a Sheriff’s Officer approached me on my driveway falsely claiming the report of a 911 call made from a landline at my home. This event was witnessed by my then girlfriend, Michelle Johnson, who now claims no recollection of it and now states that the Sheriff responded because I “was on drugs” while I was working on my vehicle, which is true to the extent that I was using prescribed Adderall. This event is available on Federal Interagency Traumatic Brain Injury Research Informatics System “FITBIR” under TRACK TBI on 7/31/2020 and recorded my response to the Sheriff’s Officer as “blunt”. 

10.       The following week, on August 5, 2020, I was the victim of an illegal human medical experimentation research program TRACK TBI (a U.S. government sanctioned “torture” program) and I have documented it fully since it occurred to me on 8/5/2020 at a military base located 8450 Okinawa Street, Sacramento, CA 95828. 

11.       On numerous occasions I made the Sacramento County Sheriff’s Department Internal Affairs Division aware of the illegal human medical experimentation / torture, via email. 

12.       On numerous occasions I sent emails to the Sacramento County District Attorney’s office requesting the prosecution of those involved in the 8/5/2020 illegal human medical experimentation research since I was able to identify several of the researchers, including: Dr. John Yue, Nsini Umoh, and Dr. Randy Merchant. (See ¶61 below for an email that I sent repeatedly to the DA and Sheriff’s Dept. I.A.). 

13.       I am aware of no action taken by the Sacramento County District Attorney’s office or the Sacramento County Sheriff’s Department regarding my complaints except action taken against me through invasive and illegal investigations. This is evidenced by the current criminal charges that have dropped off the online “Case Index System” to be replaced by new unknown charges, stemming from a massive government investigation that has infected every aspect of my life, including: it has contacted every person that I know, or have ever known; performed extensive and intrusive surveillance; recorded calls and conversations; sought damaging information to the extent that it controls the outcome of situations; and, performed numerous set-ups and frame-ups.

This Wrongful Law Enforcement Action Includes Courtney Zane, From The County Of Sacramento Public Defenders Office, Acting In Conspiracy Against Her Own Client.

 14.      On 7/30/2022 at 2:36 pm I sent an email to: daoffice@sacda.org; Internal Affairs – InternalAffairs@sacsheriff.com; Sacramento County Superior Court dept3@saccourt.ca.gov; SACRAMENTO Police SPD IAConcerns – iaconcerns@pd.cityofsacramento.org; Zane. Courtney – zanec@saccounty.net; PDWebmail@saccounty.net; John Holbus – johnholbus@gmail.com; which stated very clearly:  

IMMEDIATELY CEASE YOUR SURVEILLANCE ACTIVITIES OF ME WHILE I AM ACTING IN PREPARATION OF MY DEFENSE.  It is illegal for the cops to continue their harassment and make contact with me in the manner in which they have. I am represented by the PD still, but she has demonstrated that she is not on my side. John Holbus will not be at the hearing to sub-in, in person. Based upon the fact that Courtney Zane is still my attorney, but is working for the other side, I am left to represent myself. It is therefore, HIGHLY ILLEGAL TO CONTINUE YOUR SURVEILLANCE ON ME WHILE I AM ACTING IN PREPARATION OF MY DEFENSE. IMMEDIATELY CEASE YOUR SURVEILLANCE ACTIVITIES OF MY HOME. I legally reside with my girlfriend, (fiancée), and your activities cross the line. 

Andy Pearson”.  

A.        This email included the previous email that I sent to the Sacramento County Office of the Public Defender on Saturday, July 30th, 2022 at 2:27 pm, stating: 

“Courtney Zane did not represent me and actually worked against me. I would appreciate a call from a new PD because she has allegedly been informed by John Holbus that he is representing me, but he will not be there at my next hearing on 8/3/2022, and he did not provide me with the new attorney’s information [the substitute attorney / appearance attorney]. Nor did he sub-in in any manner. According to the court, Courtney Zane is still my attorney, but she is clearly taking actions opposed to my interests and flat out lied to me at one point, refuses documents, barely returns calls, and I believe that she is working against me, but she is still legally my attorney. I need to talk to the PD Monday morning, or retain another attorney. But, I am still represented by Courtney Zane for all purposes and she not on my side, clearly. I informed John Holbus of this situation.” 

B.        Despite numerous phone calls to Courtney Zane and her supervisor, and despite numerous emails to the Sacramento County Public Defender’s Office, I have not heard back from anyone except Courtney Zane through three emails and two phone calls. On August 10, 2022, I wrote to the Public Defender, District Attorney, Department 3, and Courtney Zane making clear that she no longer represents me, and stated: 

“Courtney: 

DO NOT TAKE ANY FURTHER ACTION ON MY CASE. You no longer represent me. I have retained other counsel. 

Andy Pearson”. 

C.        On Wednesday, August 10th, 2022 at 3:30 pm, I wrote: 

“Courtney: 

That police report is a bunch of lies, but it does not matter now. What are the new charges? Do not bump the case to an earlier date, I am going to file a federal case and will demonstrate what this case is about. It is also likely that I will be hiring a new attorney, because you have demonstrated which side you are on. 

Andy Pearson”. 

D.        Previously on Wednesday, August 10th, 2022, Courtney Zane wrote: 

 “Hi Mr. Pearson, 

Attached is the copy of the complaint and police report. The DA intends to file a new complaint with additional charges at the next court date. Once I have received the documents and reports for that new complaint, I will have it redacted and sent to you. Are you out of the hospital? If so, I’d like to advance your court date to an earlier date if the court is willing to do so. 

Courtney Zane 

Assistant Public Defender 

700 H Street, Suite 0270 

Sacramento, CA 95814 

 (916) 874-6959 desk 

 (916) 875-5680 fax 

zanec@saccounty.net”. 

15.       Nothing law enforcement has done in this matter has been legal and it has acted with full knowledge of the emotional distress under which I suffer. I have gone to appointments with several doctors, and told the doctors that I no longer wanted to live, and I would rather be dead than to live in this world, but I cannot ever kill myself because I am Catholic.   

A.        Nothing law enforcement and the U.S. government has done in this matter is legal from its 7/31/2020 fake Sheriff’s Officer visit; to its 8/5/2020 illegal clinical study; to its continued surveillance of me at my current residence; to its fabricated criminal charges. 

B.        Not only are the methods cruel, unusual, and designed to destroy a person, but the EVIDENCE GATHERED IS CLEARLY INADMISSIBLE and it is likely that no court in the U.S. would even require a 4th Amendment Constitutional analysis for suppression of ill-gotten evidence pursuant to the Exclusionary Rule and the fruits of the poisonous tree doctrine because the law enforcement violations in my case are BLATANT.  

16.       The government continues to act against me despite the Sacramento County District Attorney repeatedly being informed that:  

“YOU ARE SUPPORTING TORTURE – If there is one thing that I have learned after being beat down and almost destroyed as a human, is that GOD, JESUS CHRIST, and the BLESSED MOTHER MARY are AWESOME and will defeat your ilk effortlessly.”Throughout my ordeal, the one and only thing that I have known, after turning to hundreds of attorneys, government agencies, reporters, organizations, and anyone I could think of to obtain help against the Juggernaut United States Government is that no man can take on the U.S. government for its horrific sin of TORTURE, this is a matter for GOD, JESUS CHRIST, and the BLESSED MOTHER MARY who are truly AWESOME and defeat evil effortlessly. And, despite losing everything, my Bond with GOD, JESUS CHRIST, and the BLESSED MOTHER MARY is undeniable and unbreakable and I would endure anything to be as Blessed as I am now. 

17.       These illegal human medical experimentation research / U.S. Government sanctioned torture programs are violations considered to be crimes against humanity, crimes so serious the Nazi doctors’ trial found such behavior punishable by death. The performance of “human medical experimentation research” which violates God-given Unalienable Rights and protected Fundamental Human Rights is not permitted, ever. Man Cannot Give, Therefore Man Cannot Take Away or Limit GOD-Given Unalienable Rights / Fundamental Human Rights. Government is expressly forbidden from attempting to infringe on these rights. The Declaration of Independence asserts that all men are endowed by their Creator with certain unalienable rights, as does Article I, Section 1 of the California Constitution. In other words, my rights to life, liberty and the pursuit of happiness are God-given, not government given. As is the right to be free from illegal human medical experimentation research / torture which uses methods that are an abhorrent violation of Human Rights, especially privacy rights. I know firsthand.  

18.       It is inexcusable for the U.S. government to engage in conduct violating constitutionally protected unalienable fundamental human rights, when its very purpose of existence is to protect those rights. There is no logical reason for the Federal Government to continue its current failed course of “human experimentation” research in which I am the subject, considering that its efforts consistently result in exacerbating the “extreme uncontrollable circumstances” it seeks to control, circumstances of its own creation which began on August 5, 2020.  

19.       The FITBIR tracking system has input my TRACK TBI case as a “Severe Adverse Event” and describes the creation of “extreme and uncontrollable circumstances” on: https://fitbir.nih.gov/content/data-dictionary. Currently, the website “https://fitbir.nih.gov/content/data-dictionary” has been updated to require an account and is no longer open to the public for viewing without pre-approved membership. 

20.       During my review of documents, I found evidence that are one or more ”hit”  contracts / ”hit”  subcontracts to cause me harm, entered into between identified individuals, to be performed on behalf of the U.S. Government. 

21.       On the evening of March 25, 2022, there was an attempted hit on me while I exited the 24 Hour Fitness in downtown Sacramento. This incident was being observed by 3 Sacramento Police Department officers in SUVs parked across the street from the gym, and an individual who I am aware is an FBI agent. When I approached for help the officers immediately dispersed. I caught one and he declined to assist me. I found a bike cop who agreed to watch me run past the threatening party into the parking garage where I flagged down an employee and security escorted me to my car. I am lucky that I got out of the parking garage safely. I truly thought that I was not going to make it home and believe that these individuals intend to cause me serious bodily harm. I made a report with the Sacramento PD IA and they responded by inquiring as to if I was able to get the officers badge numbers, which was not my priority considering that there was a clear present threat to my safety. I told the 24 Hour Fitness downtown gym location to preserve its tapes. 

22.       The State of California agencies, local governments, the U.S. Government through its agencies, in partnership with individuals, organizations, and companies etc. have surveillance programs engaged in conduct designed to harm and destroy others, including U.S. Citizens. These parties illegally engage in surveillance against target subjects gathering information, including falsifying information, to be used against the target through manipulation, control, or in any manner suiting its needs, including launching smear campaigns. The fact that it is being performed by law enforcement is particularly reprehensible and despicable, raising serious U.S. Constitutional issues especially pertaining to those individuals who become defendants in the criminal system, where even the Public Defender has demonstrated not only willingness to permit such conduct, but actual involvement in the U.S. Government sanctioned Torture Programs. 

The Criminal Charges Are Intended to Silence Me by Locking Me Up In Jail 

23.       This whole matter has been a frame-up, including false statements in the TRO, which were not even necessary for issuance of the TRO, allegedly made by Caroline Pearson and signed by John Pearson. When I asked my father, John D. Pearson, why he signed Caroline’s lies, he stated: “She’s my wife.” Those allegations include, but are not limited to: that I carry a “big knife” implying I threatened to take Caroline Pearson by her hair to the bank with the big knife;” that I use  “methamphetamine” when in reality my doctor’s nurse practitioner Anthony Cox changed my prescription for Attention Deficit Disorder from Adderall to Focalin and Caroline Pearson was fully aware that it made me “feel as if I was on PCP” (something which the pharmacist at Costco Pharmacy, 1600 Expo Parkway, Sacramento, CA 95815, had NEVER heard of before and was not a known side effect); and, I was falsely accused of financial elder abuse, which never happened.  

24.       On August 5, 2020 at 8450 Okinawa Street, Sacramento CA, 95828 it is likely that TRACK TBI put a device (microdialysis device) in my frontal lobe, which can be surgically implanted through the eye socket in under 25 minutes with a CT / MRI scan to guide the device into the frontal lobe (which is why the TRACK TBI protocol lists patients with eye implants as not eligible). According to the TRACK TBI information available at “ClinicalTrials.gov”: “Component-Specific Exclusion Criteria: MRI: Pregnant or may be pregnant; younger than 8 years old; those who have cardiac pacemakers, neural pacemakers, surgical clips in the brain or blood vessels, surgically implanted metal plates, screws or pins, cochlear implants, intrauterine devices (IUDs), or metal objects in their body, especially in the eye.” (Emphasis added.) 

A.        Dr. Geoffrey Manley, UCSF TRACK – TBI lead PI, published a three page document stating that microdialysis devices will be used in TBI patients through surgical implant into the frontal lobe. UCSF considers microdialysis as a “minimally-invasive” technique. Microdialysis is used for continuous measurement of free, unbound analyte concentrations in the extracellular fluid of virtually any tissue. Analytes may include endogenous molecules (e.g. neurotransmitter, hormones, glucose, etc.) to assess their biochemical functions in the body, or exogenous compounds (e.g. pharmaceuticals) to determine their distribution within the body. The microdialysis technique requires the insertion of a small microdialysis catheter (also referred to as microdialysis probe) into the tissue of interest. The microdialysis probe is designed to mimic a blood capillary and consists of a shaft with a semipermeable hollow fiber membrane at its tip, which is connected to inlet and outlet tubing. The probe is continuously perfused with an aqueous solution (perfusate) that closely resembles the (ionic) composition of the surrounding tissue fluid at a low flow rate of approximately 0.1-5μL/min. Once inserted into the tissue or (body) fluid of interest, small solutes can cross the semipermeable membrane by passive diffusion. The direction of the analyte flow is determined by the respective concentration gradient and allows the usage of microdialysis probes as sampling as well as delivery tools. The solution leaving the probe (dialysate) is collected at certain time intervals for analysis. 

B.        I informed my mom, Caroline Pearson, and others including several doctors, that I have had ringing ears (mainly in the right ear at various decibels), lightheadedness, headaches, and other signs (including actions taken with limited self-control while in a daze) and that there may have been a device surgically implanted on 8/5/2020.  

C.        I do not know if there is a “microdialysis” device or another sort of device in my frontal lobe or elsewhere, but since 8/5/2020 I have not been the same and I have repeatedly been declined CT /MRI requests since I realized that this device is part of the TRACK TBI protocol and is listed on FITBIR under TRACK TBI PILOT. Although Health and Life Organization did refer me for a CT scan because it needed a CT scan documented to explain why the results of a CT or MRI are in my medical records. (See ¶ 118 below; A true and correct copy of the CT referral is attached hereto as Exhibit G.). 

D.        I have never claimed to be a “Targeted Individual.” But, the experiences that I have had are similar to those who claim to be “Targeted Individuals.” There are thousands of people in the United States and worldwide who claim to be TI’s. (See ¶¶ 84-91 below.). 

25.       Several federal and California State agency “investigators” assigned to investigate my claims of human medical experimentation research / U.S. Sponsored torture repeatedly asked whether I have had a CT scan. I have requested a CT several times from my health care providers, and I have repeatedly been declined. The results of a CT scan are in my medical records, but I have no recollection of ever receiving either a CT or a MRI. A CT scan and / or MRI is part of the TRACK TBI protocol. I had a referral for a CT scan from Health and Life Organization that I did not use because I had already cancelled my insurance and I could not afford to pay out of pocket and I did not have a primary care physician to interpret the results. The CT scan referral expired on 2/9/2021, and the Sacramento Sheriff Officers attempted their first service (first of numerous aggressive attempts at service which was accomplished with six undercover law enforcement vehicles) of UCSF’s TRO on 2/10/2021, despite that the TRO was issued by SF Superior Court on 1/20/2021. 

26.       I informed my son, Andrew Pearson, of the outright lies in Caroline Pearson’s restraining order, specifically that I use meth, that I committed financial elder abuse, and that I threatened to take her by the hair and drag her to the bank implying that I carried a “big knife.” Caroline Pearson claimed to Andrew Pearson that she was “directed” what to write by the Sacramento County Sheriff’s Department and the Sheriff’s Officers asked her questions to “assist,” such as inquiring as to if I had any weapons, and directed her to put that I had a “big knife” in the section regarding being “taken to the bank by the hair” which resulted in inclusion of the TRO language “(and he has a big knife).” Although Caroline Pearson never claims to have been threatened by the big knife, the corollary can be made that I threatened her with a “big knife.” (A true and correct copy of the “final email” to Caroline Pearson addressing this matter is attached hereto as Exhibit Y.). 

27.       The 6/8/2022 arraignment did not result in a plea being entered, and it was continued to 8/3/2022 so that the Sacramento County Sheriff’s Officers and / or other “sabotage experts” could continue their attempted frame-up and set-up of criminal charges against me. On 6/8/2022, I wanted to enter a plea of “not guilty” and set it for trial. 

28.       To state that the Sacramento County Public Defender’s Office is unhelpful is an understatement. The conduct of the Public Defender assigned to my case made clear that she was not going to help me, and was extremely obstructive. I had been forced to retain private counsel because the Public Defender did not return emails, did not return phone calls, and refused to provide a copy of the Police Report and charging documents. I was not provided with the Police Report and charging documents until 8/10/2022. The Public Defender ignored my requests to propound discovery and obtain all law enforcement records, CLETS records, logs, and any other law enforcement databases particularly those that will reveal how many times the Sacramento County Sheriff’s Department investigated me since 5/1/2020.  

29.       I also requested that the Public Defender issue subpoenas for the geotracking location data for cellphones (this can be purchased but would require law enforcement or a court order to reveal the identity of the parties) for 8450 Okinawa Street, Sacramento CA 95828, on 8/5/2020, (although the data for the whole week would be preferable). I also asked to obtain the video camera footage inside 8450 Okinawa Street, Sacramento CA 95828 for the whole day of 8/5/2020. My discovery requests were never responded to by Courtney Zane, the PD assigned to my case. 

30.       On May 28, 2022, the day of my arrest, John and Caroline Pearson did not call the Sheriff on me. I was walking to my former neighbor’s house and I was passing my parents’ house on the opposite side of the street when the same two officers that were at my girlfriend’s apartment (it is our apartment, but I call it “girlfriend’s apartment” out of habit) about 10-15 minutes prior were parked outside my parents’ home and called for me to come to them. There was what I recall as a minor argument at my girlfriend’s home between me and Jim Johnson. The cops were called and approached me as I was leaving and told me to get my stuff out of my girlfriend’s home and to “boogie.” I told the Officers that I would just leave, and I left. I was again homeless, and I had nowhere else to go, so I was walking to ask my former neighbor if I could borrow a tent and sleeping bag to camp at the river, (which I have borrowed since). The arresting Sheriff Officers called me to them as they were standing on my parents’ driveway, I crossed the street and approached the Officers, and they told me that I was under arrest for violating the restraining order, and they placed me in handcuffs. The Sheriff Officers NEVER served me with any papers on 5/28/2022 while making their arrest. One of the arresting Officers’ tried to get me to comment on my former girlfriend’s father, Jim Johnson, and while I was being booked he stated “I talked to Jim, he’s a real doozy.” I merely acknowledged that Jim was drunk, and he is a different person when he is sober, as am I.  

31.       I was entrapped when I walked over to the Sheriff’s Officers and they arrested me, considering that I have been informed that had I continued walking and had I not gone to the officers that I may have actually violated the law, to willfully resist, delay or obstruct peace officers who are performing their official duties. The Sheriff Officers had already contacted John and Caroline Pearson who were standing on the driveway. The Sheriff’s officers went directly from my girlfriend’s home to my parents’ home because they saw that I was walking.  The Sheriff’s Officers had no reason to go to my parents’ house because I was not confrontational or they would have arrested me at our apartment.  

32.       I did not have a copy of the 5/28/2022 Police Report until 8/10/2022 – which I initially sought for my claims of entrapment / false arrest / and battery when one of the Sheriff’s Officers kicked the back of my leg. This is because the Police Report from the 5/28/2022 wrongful arrest was being delayed because it needed to be changed throughout the Sheriffs Department’s “investigation” and likely did change, just as there are two different “restraining Orders” that have been in circulation in which I am restrained creating confusion as to what I am and / or what I am not allowed to do, such as not have contact with my daughter, Sarah Pearson, which is absolutely ludicrous and unnecessary, but is intended as punishment and is typical of a government which has demonstrated that it is absolutely vicious and cruel towards its Citizens. 

A.        On July 25, 2022 the PD assigned to my case, Courtney Zane, informed me that in the police report the Sheriff’s Officers stated that: “They [The Sheriff Officers] received a call and when they pulled to up my parents’ home I was standing on the driveway.” I tried to tell Courtney Zane that the Sacramento County Sheriff’s Officers lied in the police report but the call cut off after about 30 seconds and my phone did not get reception for the rest of the day.  

B.        After the call, On July 25, 2022 I emailed Courtney Zane: “Hello Courtney, 

            For some reason the call kept dropping. But, what I could garner from our brief conversation is that the Sheriff has lied in the police report. My parents did not call the police. There was a minor argument at my girlfriends home between her father and I. The cops were called and approached me as I was leaving and told me to get my stuff out of my girlfriends home and leave. I told them I would just leave, and did. I was walking to my former neighbors home to borrow a sleeping bag and tent and I was passing my parents house on the opposite side of the street when the same two officers were parked outside my parents home and called me to them. I walked over to them and they arrested me. They had already contacted my parents who were standing on the driveway. They went directly from my girlfriends home to my parents home because they saw that I was walking. I had to walk because I drank alcohol and did not want to drive. They had no reason to go to my parents house because I was not even confrontational or they would have arrested me at my girlfriends house. I had nowhere else to go so I was going to camp at the river. 

They lied in the police report. I do not have a copy of the restraining order, but I have emailed my mother to address her lies and request my personal belongings. Although, I do not think the restraining order prohibits emails. But I am unsure. 

Please call me sometime before the 8/3/2022 hearing. Andy Pearson”. 

            C.        Also on July 25, 2022 I emailed Courtney Zane: Courtney: 

I will call you on 7-26-22. I have attached the last email that I sent to Caroline Pearson. Please read it. I already told her that it is the last email to her. She used my bank account to pay a credit card bill and caused it to go negative. That is fraud. She is not the innocent person that she purports to be. If the DA wants to charge me for having “mommy issues” then I will take it to trial. This is not about mommy issues, when you read the below email you will see that there are other matters, the fact that I have been targeted since 8/5/2020 and became vocal about illegal human medical experimentation / government torture programs which I WILL NEVER STOP TRYING TO EXPOSE. The DEA busted my brother in San Diego, and he convinced Caroline Pearson to aid him in framing me and was sending multiple packages of steroids to my home. Further, he was borrowing hundreds of dollars from me via Zelle, which he later told me were for steroids [and laughed about it], but I did not know at the time. Then the steroids were being shipped from Caroline’s home to him. And, Caroline was importing massive amounts of pain pills, and pain pills were also were being sent via John Pearson. When the customs seizure notices kept piling up I put a stop to it, and he called and expressed his anger that I was suing the federal government, and cut me off completely. But, I had told nobody that I was suing the federal government except the Department of Commerce. [After my EEOC complaint was closed.] I called John Pearson one night and confronted him and he called Caroline, and my parents kicked me out. Further, she refuses to return any of my property, adding to my frustration. I did not give a statement to the Sheriff’s IA investigator, and he did not agree to allow me to do it in writing. Then the Department of Family Services kept calling and informed me they were investigating a complaint regarding Caroline Pearson, and I told the investigator that I was not going to give a statement and to stop calling me.  Please read the below email. It is the truth. Andy Pearson”. (A true and correct copy of the July 23, 2022 “Final Email” that I sent to Caroline Pearson is attached hereto as Exhibit Y.). 

D.        I did not talk to the PD again until July 28, 2022 when Courtney Zane called me. On July 28, 2022, I informed Courtney Zane via her phone call that the Sacramento County Sheriff’s Officers lied in the police report, but Courtney Zane could not remember previously stating any information, and claimed to not have the police report in front of her. Since the July 28, 2022 phone call, the PD has been nearly absent. On July 28, 2022 Courtney Zane informed me that she would provide documents to me in court on 8/3/2022 despite my original request via email on June 9, 2022, when I stated: “I have been informed that you are the attorney handling my case. I need a copy of all police reports, charging documents, and would appreciate if an investigation is performed. I would appreciate a call back at 916-437-8130.” 

E.         Also on June 9, 2022 I emailed Courtney Zane: “Hello Courtney: 

You will be happy to know that it is likely that I will obtain other representation. Until I do, I am going to have to deal with your office. So I would like to take the opportunity to inform you of my IA complaint and to inform you of the real facts of why I am, and have been, a target of the Sacramento County Sheriff’s office since 8/5/2020. I am an attorney in good standing with the State of California. I went to law school with Noel Calvillo, and I have already informed him of this matter. Please read the whole email and attachments even if only for your personal knowledge of what is occurring in this country. The below human experimentation litigation that I am pursuing includes the Sacramento County Sheriffs office as a defendant. I would appreciate it if your office performed an investigation into this matter. 

Very Truly Yours, 

Andy D. Pearson”. 

F.         On July 29, 2022, after I analyzed the questionable behavior of the Public Defender and I determined that it is highly likely that I was being set-up, I emailed Public Defender Courtney Zane:  “Courtney,  

This has been an epic set-up. Apparently there is a story floating around in a police report and people from this house [1225 Bell Street #224, Sacramento CA, 95825 – my and my girlfriend’s apartment] had a story to tell. YOU SET ME UP. You should be reported to the bar. YOU BETRAYED YOUR CLIENT. I will not tell the bar. What amazes me is that this whole set up was to cover torture programs. Are you people crazy? Andy Pearson”. 

G.        On August 8, 2022 I emailed Courtney Zane: “Hello Courtney: I also assume that you received my declaration in support of my motion to stay the proceedings. Please respond to my concerns about the PD representing me. I will fix the declaration and provide you with a new one updated to the next court date. PLEASE EMAIL ME A COPY OF THE POLICE REPORT IMMEDIATELY.” Throughout the time period from the 5/28/2022 arrest to the present date, the Sheriff’s Department investigators, and other U.S. Government “investigators,” have tailored their police reports and restraining orders to fit the facts of this matter. I have addressed the facts as they were made known to me, and I have had to update and remove information from this declaration accordingly. The “Final Declaration” will be the one that is filed in federal court when I seek redress with a cause of action for “Torture” and when I seek an injunction / TRO/ restraining order prohibiting my targeting as the subject of a failed military human experimentation / U.S. Government Sanctioned Torture Program. 

H.        Also on August 8, 2022 I emailed Courtney Zane: “Courtney: On 08/03/2022 at 10:00 AM there was a Motion to Amend which was Granted. What did the motion amend? Where is my copy of the motion? Where is the Police Report? Why does it seem as if the PD is not performing its job, and is actually working against me? What have I been charged with? 

A little communication would be great. 

Do your job and represent me.  

Andy Pearson”. 

33.       When my son, Andrew Pearson, was coming home from college he had agreed to obtain some of my personal items and I made him a list. Caroline Pearson refused to allow Andrew to visit me when he came home from school and falsely told him that I was on “meth.” Andrew was going to provide items which included my computer and documents / evidence of TRACK TBI’s illegal conduct. To date, Caroline Pearson refuses to return any of my possessions, and of particular importance to this matter is my: computer, computer files, electronic file backups, medical records, various protocols, grant / funding information, thousands of FITBIR pages pertinent to me, almost two years of research on TRACK TBI and illegal human research experimentation / torture programs including: protocols, videos, documents, downloads, backups, and thousands of publications from the TRACK TBI investigators.   

34.       Caroline Pearson’s intentional refusal to return critical evidence supporting my allegations against TRACK TBI for both my federal lawsuit and as proof in this criminal matter have direct ramifications on my ability to prove my innocence and directly affects my safety in the event I am again incarcerated in the Sacramento County Jail, where callous Sheriff’s Officers roam with impunity. I live in constant fear of the Sacramento County Sheriff’s Department, and I am terrified of again being placed in their jail, where on May 28, 2022 I spent 22 miserable and terrifying hours wondering what the Sheriff Deputies would do to me next considering it was clear that I was being targeted after the Sheriff’s Officers false arrest and battery. 

            35.       It is likely that Caroline Pearson is being directed, by either the Sacramento County Sheriff’s Officers or other parties, to intentionally refuse to return critical evidence supporting my allegations against TRACK TBI for both my federal lawsuit and as proof in this criminal matter because it has direct ramifications on my ability to prove my innocence. This obstruction directly affects my safety, and the goal is not only my incarceration, but to make me vulnerable as I would be in jail or prison, mainly so that I cannot pursue any claims of government TORTURE programs run under the guise of “clinical studies.” The DEA applied force against my family members to flip against me and to cooperate in obstructing my Federal lawsuit through any means necessary, but failed. So the U.S. Government turned to the Sacramento County Sheriff’s Department and District Attorney to fabricate criminal charges. 

            36.       I am in possession of Department of Energy documents that list my outcomes and the outcomes include, but are not limited to, “incarceration.” These documents are at Caroline Pearson’s house and are electronically stored. 

The DEA’s Efforts Failed So The Sacramento County Sheriff’s Department Took Over 

            37.       John Pearson, (my brother) had been ordering massive amounts of steroids from overseas and was under multiple DEA investigations. He got popped by San Diego DEA, but he cooperated with the federal government and they went after me to stop the federal lawsuit regarding illegal human medical experimentation / U.S. sanctioned torture. John forced me to Zelle him thousands of dollars and he tricked me into paying for his steroid shipments and would ask me to pay him by Zelle. John was offering to get me drugs and to get my mom pain pills from his hookups. I declined and my mom, Caroline Pearson, accepted his offer. My brother, John Pearson, was fully aware that I am very loyal and knew that I would take the rap for him, as I did when I was 17 and he was caught smuggling steroids across the San Ysidro border crossing between San Diego and Tijuana, Mexico. I even offered to take the rap when he called me in a panic and informed me that DEA had seized two of his packages, but there was no logical way to claim that I was involved. So he simply continued his steroid shipments to Caroline Pearson’s house, paid for by John Pearson, but unbeknownst to me I was paying for the shipments by Zelle payments to John Pearson because he claimed to be broke. 

38.       One day, completely unexpected and by surprise, John had received more steroids sent to my home which had a customs notice that items were seized. I told him “Enough is enough” and he tried to negotiate for just one more order of “Clenbutoral,” and I told him again “enough is enough.” The same day I also told my mom, “Enough is enough” because it was getting ridiculous. Caroline Pearson was so loaded on Tapentadol / Aspadol that she argued with me, laughing off the customs notices, and I had to yell: “Enough is enough!”  

39.       Later in the day as I was driving to Santa Cruz to see my son Andrew, John called me, witnessed by Michelle Johnson, and John and I were cool and got along in the conversation. The same day he talked to my mom and since that call has refused to talk to me and has blocked my phone and email. When I got home Caroline Pearson was crying and stating: “I don’t want to go to jail or pay a $10,000.00 fine.” And, she was upset that John had yelled at her and she was upset that I told her that “[she] was high.” I asked her why she said that she would “go to jail or pay a $10,000.00 fine” and she told me that I told her that information, but I never said anything of the sort. Caroline Pearson said that John Pearson was furious that I was suing the federal government in the illegal human medical experimentation case.  

40.       Since my brother’s attempts at framing me for importing steroids failed, he refused to talk to me again. At the time I wondered how John Pearson knew I was going to sue the federal government considering I never talked to him about my case, and the only people who knew I was suing the federal government were employees of the Department of Commerce, Census.  John Pearson successfully got Caroline Pearson to kick me out of my own home and has rendered me homeless and with no income. Caroline Pearson also refuses to return my property which is critical to my defense and will permit me to prove the truth in this matter. Currently, I am facing continuously changing completely fabricated criminal charges and I am at the mercy of the Public Defender, Courtney Zane, who has demonstrated suspicious handling of my case, to say the least.  

41.       Since I was a victim of illegal human medical experimentation / U.S. sanctioned torture programs on August 5, 2020 at 8450 Okinawa Street, Sacramento, CA 95828 I have seen two different psychiatrists; one highly regarded well known psychologist who once served as the President of the American Psychological Association; I currently have a psychologist for counseling; and, I have seen one primary care physician. Most recently, on 8/1/2022 I required hospitalization due to increased pressure and relentless surveillance from the Federal Government which engages in conduct designed to cause the Target Subject extreme distress. This surveillance was likely from the CIA (or other intelligence agencies) because the CIA is involved in these clandestine programs through its front company RTI International. 

42.       I have provided all of my providers with documentation of the events on 8/5/2020, and not one of the providers told me that it did not happen; not one of the providers called me delusional; not one of the providers called me psychotic; not one of the providers argued with me about my version of events. But, I have been asked several times if I was ever in the military, which I was not because high school ROTC does not count as military service. Had I been in the military, currently serving, the 8/5/2020 human medical experimentation research would still be considered illegal and torture.  

43.       I see mental health providers for treatment stemming from the severe emotional distress not only caused on 8/5/2020, but I also seek treatment for severe emotional distress caused by current actions of the State of California, federal government, and at the local level by the Sacramento County Sheriff’s Department and the District Attorney.  

44.       The harm and damages suffered by the victims (subjects) in these illegal human medical experimentation programs is debilitating and includes suicide /suicidal ideation, torture through pain measuring instruments, grotesque UDE’s and CDE’s including spinal taps, illegal surveillance, and illegally infecting subjects with communicable disease such as HSV for public health monitoring purposes and/or causing shingle outbreaks through COVID 19 vaccinations being tested on the subjects. Not only is no follow up care provided, but there is no compensation for the horrific violations the subject suffers in the “clinical trial,” which causes pain that the “subject” must endure for the rest of their lives. Considering that informed consent violation statutes have extremely low damages amounts, performing illegal human experimentation without patient consent is profitable and encourages violations. 

45.       The subjects are further victimized in their daily lives, relentlessly pursued by virtually every level of government to prevent the exposure of its horrific conduct. Ultimately, as is clearly evident in my case, the despicable government employees involved in these massive illegal human experimentation research programs / U.S. sanctioned torture programs attack the family of the victim (subject), using appalling methods amounting to extortion leveraged to break the “subject.” FITBIR listed the cause of my death including, but not limited to: suicide, blunt force trauma, head injury, car accident, or heart attack. 

46.       I was notified that I am under the “Problem Policing Division” increasing my fear of the Sacramento County Sheriff’s Department considering that it has demonstrated it is not investigating the criminal perpetrators of illegal human medical research experimentation, but it is investigating me. The Sacramento County Sheriff’s Officers have demonstrated aggressiveness; have sent large Sheriff’s Officers to intimidate me by pounding on the doors and windows of my girlfriend’s apartment prompting the manager to comment; and, I have been tailgated by Sacramento County Sheriff’s Officers. I consider such conduct by the Sacramento County Sheriff’s Department to be threatening to my safety and I fear for my life. 

47.       I opened a Sacramento County Sheriff’s Department Internal Affairs investigation into my May 28, 2022 false arrest, entrapment, and the Sheriff’s Officers battery and provided a picture of a large bruise on my leg. After much back and forth, the IA investigator would not agree to allow me to provide answers in written form, and I would not provide a recorded statement during the pendency of the criminal matter. Shortly after I informed the IA investigator that I would not provide a recorded statement, I received several calls from an aggressive investigator, with the last name JOHNSON, from the California Department of Family Services (Child Protective and Adult Protective Services) for Caroline Pearson. “Investigator Johnson” called me daily and was very aggressive in his efforts at obtaining a statement from me, which I declined to provide. I had to stop investigator “Johnson’s” unwarranted contacts by forcefully stating “Don’t call or contact me again, got it Buddy?” to which he sheepishly replied “Yes”. 

48.       On June 28, 2022, I sent an email to the Sacramento County Sheriff’s IA stating:  

“I am not proceeding with the IA complaint due to the criminal charges and also since the Sacramento County Sheriff’s Department is going to be a defendant in two separate lawsuits. One stemming from 8/5/2020, and the Sheriff’s role in that matter. The other lawsuit is for false arrest and battery, from 5/28/2022. The two matters are related and the harassment from the Sacramento County Sheriff’s Department began shortly after the illegal human experimentation of which I was a victim that occurred at 8450 Okinawa Street, Sacramento, CA 95828 on 8/5/2020 and has continued, most recently evidenced through the Sheriff’s harassment on 5/28/2022.” (A true and correct copy of the communications with law enforcement (Sheriff & Sacramento PD) Internal Affairs Departments is attached hereto as Exhibit X.). 

49.       The same day I corrected the date and stated: “How many times has the Sacramento County Sheriff’s Department attempted to contact me since ‘8/5/2022?’ It should have been: ‘8/5/2020.’” On June 30, 2022, I wrote to address the date that Sheriff’s investigations likely started: “Beginning in July 2020 I was under surveillance from the Sac Sheriff. Read the attached letter documenting that the Sacramento County Sheriff sent an officer to my home to respond to a 911 call that was never made from my home since there was not even a landline operating at 1076 Clinton Road, Sacramento, CA 95825. If you have any questions I am still willing to answer in written form.” 

50.       On July 11, 2022, Sacramento County Sheriff Officer IA Investigator Jeremy Workman stated: “I will refer your allegations of illegal human experimentation to our Problem Oriented Policing team.  Unfortunately, this is outside my scope of investigation.” (Exhibit X.). 

51.       On Monday, July 11, 2022 Sacramento County Sheriff’s Officer IA investigator Jeremy Workman wrote: “It appears the address you provided (8450 Okinawa Street Sacramento, CA 95828) is within the City of Sacramento’s jurisdiction.” The Sacramento PD IA responded: “Thank you for contacting the Sacramento Police Department Internal Affairs Division. Your complaint has been received. The police officer with badge number 538 is not employed with the Sacramento Police Department at the date of the incident mentioned in your complaint. Please provide a report number if possible.” (See Exhibit X.).  

52.       I responded: “It is the California Highway Patrol’s jurisdiction. I informed the CHP after the illegal human experimentation (TRACK TBI) was originally done to me on 8/5/2020 since I was placed into my car by John Yue (from UCSF) in a drugged state and allowed to drive away from 8450 Okinawa Street, Sacramento CA, 95828 while intoxicated. Between the CHP, The Sacramento Sheriff’s Department, the Sac PD, and the Sac County DA action to stop this illegal human experimentation should be taken. Unless RTI International (the CIA front company performing this illegal human experimentation) is too powerful. Instead, the Sac Sheriff has been used to harass me beginning in July 2020, beginning the week before the 8/5/2020 illegal human experimentation, and continuing since. It is within the Sacramento Sheriff’s IA jurisdiction to investigate.”   

53.       On July 11, 2022 the Sacramento PD’s response did not address the complaints of illegal medical human experimentation research / U.S. sanctioned torture but did mention the Police Report that Courtney Zane had withheld and that I had reason to believe contained falsified information.  

A.        On August 10, 2022 I found out the Police Report is completely fabricated and contains numerous lies including that the Sheriff’s Officers’ claimed to have served me with the restraining order on 5/28/2022 and that I threw it up in the air. (See ¶ 2A above.). The Sheriff Officer also wrote that he was advised by Deputy Wilhelm that “the restraining order had in fact been served on 5/25/2022 by mail” which never occurred. 

B.        On August 16, 2022, Caroline Pearson provided a copy of the Restraining Order when Michelle Johnson picked up my mail from Caroline Pearson’s home, 1078 Clinton Road, Sacramento CA 95825. The restraining order is NOT the original TRO, and is missing pertinent language (the “Big Knife;” Meth use; and financial elder abuse claims have been omitted from the new restraining order issued 5/27/2022). The current Restraining Order has a “Date” of 6/20/2022 contradicted by a different filed date of 5/27/2022, and a 5/28/2022 Proof of Service fraudulently executed by Deputy J. Wilhelm badge #435, for a restraining order electronically filed in the Superior Court of California, County of Sacramento, Family Law on 6/20/2022 at 11:39 am. Due to: inconstant dates; constantly changing facts; questionable police report(s); gas lighting; and, multiple restraining orders, I can only list the dates that are contradictory and can only speculate on why there are two different restraining orders.  

C.        To speculate I can draw two conclusions: (1) Either the DA, Sac Sheriff, CIA, RTI International, etc. acting in conspiracy with the Superior Court Of California, County of Sacramento, Family Law division falsified a new restraining order and the evidence will prove that the parties including the Sacramento County Sheriff’s Department and District Attorney fraudulently falsified numerous pages of the current restraining order, and that it is likely that someone within the Superior Court of California, County of Sacramento aided the involved parties; or (2) It is my position that there was an ex-parte hearing, not for a TRO, but for a restraining order held on 5/27/2022 in which testimony was provided, and there is a transcript that I can obtain, which will reveal all of the parties that testified against me and my interests, with at least one acting as my LAR, despite that I have no LAR or surrogate decision maker and I make my own decisions, and this hearing was intended to make me appear to be violent and worthy of placement into an illegal “clinical study” through CIA front company RTI International and the SIREN program run between UCSF and RTI International. To speculate in this manner is simple, considering that on 5/28/2022 I was entrapped, set-up, framed, and the matter started at MY APARTMENT that I shared with my girlfriend, Michelle Johnson, who has lied about the events. This is likely the case because I have forwarded several emails that I wrote on the subject to PD Courtney Zane, and I stated that either I could not remember events, or I was being subjected to the ultimate gas lighting, and I have fully documented it since through emails being sent to numerous parties regarding Michelle Johnson’s re-writing of past events and outright lies to my face throughout this matter. 

D.        I made the parties aware of this matter with the following facts about the re-written events, including conduct of Michelle L. Johnson, who I intended to marry prior to the government smear campaign in which she participated: 

I.          I am aware of no action taken by the Sacramento County District Attorney’s office or the Sacramento County Sheriff’s Department regarding my complaints except action taken against me through invasive investigations. This is evidenced by the current criminal charges that have dropped off the online “Case Index System” to be replaced by new unknown charges, stemming from a massive government investigation that has infected every aspect of my life, including: it has contacted every person that I know, or have ever known; performed extensive and intrusive surveillance; recorded calls and conversations; sought damaging information to the extent that it controls the outcome of situations; performed numerous set-ups and frame-ups. And most egregiously, this wrongful law enforcement action includes Courtney Zane, from the County of Sacramento Public Defenders Office, acting in conspiracy against HER OWN CLIENT. The production of false accounts of current events that are being recorded by law enforcement (with many witnesses); and past events that are being re-written, to conform to the Sheriff’s narrative of me, and to smear my name for its criminal charges include: 

 II.       On 5/28/2022 at my former girlfriend’s apartment, I had a minor argument with my girlfriend’s father. I recall little physical contact although I had a scratch on my face from her father. I was informed that no statements were given, but apparently now there is a recording of a narrative that I “shook her father” and “punched her step-mom” (Melody Johnson) which is completely false. Michelle Johnson, my former girlfriend, (I considered her to be my fiancé and we intended to be married) was at first shocked when I called her from jail, then after the third call she began telling me a story that did not happen. I asked her “why are you doing this to me?” and she adamantly claims her version of the 5/28/2022 event is true, changing it from that I shook her father; to he hit his wife trying to hit me; to I punched Melody Johnson. I do not remember this version of events happening at all, and I remember the whole day. 

III.       On 5/4/2020 I was sitting on a couch at Michelle Johnson’s apartment when her son, behaving erratically, demanded that I leave and called 911. He was out of control and I thought he was going to pour a cup of juice on me that he had in his hand on me so I knocked it out of his hand, his girlfriend elbowed me in the chest, and in self-defense I put my hands on her upper chest, but removed them immediately stating: “look at her face” because she appeared that she wanted me to get physical. My hands were in the air when Blake Coleman came around behind me and punched me in the back of the head as hard as he could. I took him down and I was behind him, contained him, and stopped at the request of Blake’s brother, Isaac Coleman, causing Blake Coleman no harm. The event has now changed by Michelle Johnson adamantly claiming that “I choked her [Blake’s girlfriend]. And, that I was “intentionally disrespecting Blake while she was not home.” I have attempted to apologize to Blake for the unfortunate event, and Michelle has flat out refused. On 5/4/2020 Michelle Johnson agreed to be a witness to the version of events stated herein, and I sought to press criminal charges, which did not occur.  

IV.       I legally reside with Michelle Johnson in our apartment. I have contributed rent; paid a pet deposit; contributed to more than half of the living expenses; and, I considered Michelle Johnson to be the equivalent of a common law wife; we shared everything 50/50 and for the bulk of our relationship I carried the financial weight and paid for Michelle’s expenses, dental care, etc. I believed that we intend to get married. I have received mail at her apartment, but Michelle Johnson’s disposition and personality recently changed. Some time ago, Michelle Johnson would start yelling at me: “TRACK TBI did not happen!” We broke up over this, and then we got back together and resumed the relationship. Since law enforcement upped it’s targeting of me, it is likely that law enforcement has illegally installed surveillance in our apartment, and Michelle Johnson has become very argumentative, insisting several different versions of events occurred than what actually occurred, events that I remember vividly. She adamantly insists that I do things that I do not recall doing. Either it is the ultimate gas lighting, or the Department of Energy, Central Intelligence Agency, RTI International, etc. has embarked upon a massive set-up of me, completely smearing my name. Law enforcement has succeeded in successfully rewriting the 5/4/2020 event with Blake Coleman. The 5/28/2022 arrest stemmed from an event at the apartment that Michelle and I share. I left the apartment at the request of the Police because her father was demanding that either he was going to leave, or I had to go, and he was extremely drunk and could not drive. My interaction with the two Sheriff’s Officers was witnessed by a resident with a dog named “Sugar” who informed me that she had talked to Sheriff’s Officers on 5/28/2022, and later provided another statement to investigators and told them “That I was really nice to everyone in the apartments.” I also avoided Michelle’s property manager, Lou, at Michelle’s request, although Lou told me that I could legally stay here and merely wanted a copy of my I.D. Michelle Johnson is allegedly in a program that pays her rent of $995 per month, while she is attempting to obtain SSI, in reality it is paid for by other sources. I have never been provided documentation that I am not allowed to legally reside here. But, recently it seems to be an issue, particularly on 7/30/2022 when several undercover law enforcement officers were outside our apartment, as Michelle Johnson falsely accused me of issuing “threats.” Michelle Johnson has called 911 on me, and when the officers arrived I was saying my prayers and they took my side, and the female Sheriff’s officer told Michelle she was aggravating the situation. Recently Michelle Johnson wrote out a declaration after a fight that we had, and I had yelled at her. She told me that there will be numerous people checking on her safety, and when I asked “Who?’ Michelle Johnson went berserk and began yelling at me. So, I voluntarily moved out because I could not continue to live there under such stress and strain, and Michelle ripped up the lease agreement that the property manager provided to me to get on the lease since I had legally been residing with Michelle Johnson in our apartment since April 2022. 

V.        On 7/30/2022 at 2:36 pm I sent an email to: daoffice@sacda.org; Internal Affairs – InternalAffairs@sacsheriff.com; Sacramento County Superior Court dept3@saccourt.ca.gov; SACRAMENTO Police SPD IAConcerns – iaconcerns@pd.cityofsacramento.org; Zane. Courtney – zanec@saccounty.net; PDWebmail@saccounty.net; John Holbus – johnholbus@gmail.com; which stated very clearly:  

IMMEDIATELY CEASE YOUR SURVEILLANCE ACTIVITIES OF ME WHILE I AM ACTING IN PREPARATION OF MY DEFENSE.” 

I continued: “It is illegal for the cops to continue their harassment and make contact with me in the manner in which they have. I am represented by the PD still, but she has demonstrated that she is not on my side. John Holbus will not be at the hearing to sub-in, in person. Based upon the fact that Courtney Zane is still my attorney, but is working for the other side, I am left to represent myself. It is therefore, HIGHLY ILLEGAL TO CONTINUE YOUR SURVEILLANCE ON ME WHILE I AM ACTING IN PREPARATION OF MY DEFENSE. IMMEDIATELY CEASE YOUR SURVEILLANCE ACTIVITIES OF MY HOME. I legally reside with my girlfriend, (fiancé), and your activities cross the line. 

Andy Pearson” 

VI.       This email included the previous email that I sent to the Sacramento County Office of the Public Defender on Saturday, July 30th, 2022 at 2:27 pm, stating: “Courtney Zane did not represent me and actually worked against me. I would appreciate a call from a new PD because she has allegedly been informed by John Holbus that he is representing me, but he will not be there at my next hearing on 8/3/2022, and he did not provide me with the new attorney’s information [the substitute attorney / appearance attorney]. Nor did he sub-in in any manner. According to the court, Courtney Zane is still my attorney, but she is clearly taking actions opposed to my interests and flat out lied to me at one point, refuses documents, barely returns calls, and I believe that she is working against me, but she is still legally my attorney. I need to talk to the PD Monday morning, or retain another attorney. But, I am still represented by Courtney Zane for all purposes and she not on my side, clearly. I informed John Holbus of this situation.” 

E.         It is my position that to continue this case with further charges does not just demonstrate prosecutorial vindictiveness, but the DA clearly has an ulterior motive. The DA is trying to silence claims of torture in which the Sacramento County Sheriff’s Department plays a crucial role, from the Sheriff Officer’s visit the week before the 8/5/2020 illegal human medical experimentation which was documented on FITBIR, to the Sheriff’s relentless harassment after the 8/5/2020 clinical study, culminating in fabricated criminal charges with evidence and police reports that are riddled with holes. It is my position that there is evidence that the Sacramento County District Attorney: (1) is fully aware that the original TRO, or pages of it, have been replaced; (2) the current restraining order has been fraudulently created; (3) the current restraining order was NEVER served by mail on 5/25/2022 or in person on 5/28/2022 (at least not served on me on 5/25/2022 or 5/28/2022); and, (4) there is overwhelming evidence that the Sacramento County District Attorney is aware that I was falsely arrested on 5/28/2022 and the purpose of the arrest was to get me into the criminal system for it’s clear attempts at concocting charges against me and there was an ex-parte hearing, not for a TRO, but for a restraining order held on 5/27/2022 in which testimony was provided, and there is a transcript that I can obtain, which will reveal all of the parties that testified against me and my interests, with at least one acting as my LAR, despite that I have no LAR or surrogate decision maker and I make my own decisions, and this hearing was intended to make me appear to be violent and worthy of placement into an illegal “clinical study” through CIA front company RTI International and the SIREN program run between UCSF and RTI International. 

Illegal Human Medical Experimentation Research / Torture Programs Must Be Stopped 

54.       The U.S. government, illegally, unconstitutionally, and under the guise of “research” performs surveillance against target subjects (citizens) gathering information to be used for manipulation, control, or in any manner suiting its needs. These programs include elaborate government smear campaigns, targeting, and ultimately destroying those considered to be their opponents for perceived transgressions, such as speaking out against crimes against humanity committed by the U.S. government through illegal human medical experimentation research torture programs, which must be stopped.  

55.       The methods in which the U.S government engages are flawed. It is not my intent to provide advice as to how to refine the methods used in the programs performing conduct designed to harm and destroy others, but the most important error is in their information gathering and documentation practices by which, in an effort to gather as much negative information as possible, these investigators falsify documents and only seek bad facts, resulting in targeting subjects through precisely calculated methods created based upon incorrect, incomplete, and flawed facts. 

56.       Despite numerous attempts consistently failing to obtain desired or intended results, the U.S. Government relentlessly targets me continuously exacerbating the problem it seeks to control, each time enlarging the group impacted and vulnerable to extreme uncontrollable circumstances. These elaborate and complex human subject control research programs are designed and performed through human subject manipulation intended to achieve predesigned results. The US Government has failed to use the programs against me, consistently resulting in “extreme uncontrollable circumstances.” The desire to silence me, and to protect those involved in illegal human experimentation, has resulted in continued targeted attacks to which I have been subjected. The U.S. Government is now attempting to mitigate the “extreme uncontrollable circumstances” through my incarceration in an effort to prevent my pending Federal lawsuit. But, the actions taken against me have guaranteed that I will file a federal suit and the U.S. Government has only succeeded in forcing my hand. 

57.       Anyone taking part in these illegal government programs should be very concerned for everyone, including their children, the future, and themselves. By allowing illegal human medical experimentation research programs (torture) creates a world which is doomed to fail in a horrific fashion, similar to the Holocaust.   

58.       These programs began under Section 3021 of the Affordable Care Act, which created the Center for Medicare & Medicaid Innovation (CMMI), an innovation lab within the Centers for Medicare & Medicaid Services (CMS) that is testing over 20 models aimed at improving quality and reducing costs within Medicare and Medicaid, which is possibly still in operation. More likely the project is still operating, since the government is still torturing people. I have been attacked from all levels of government since August 5, 2020, because they are angry that I am vocal about stopping their torture programs. Apparently, when you are the victim of U.S. Government torture, you are not allowed to complain about your torturer.    

59.       This illegal human experimentation “model” resulted in medical delivery systems with no oversight so that it became permissible for researchers to do whatever they wanted to patients, including: signing patients up without knowledge or consent: the falsification of all records, including medical records; luring patients to locations under false pretenses, such as for employment, then drugged the patient unconscious and left the patient with amnesia; drugged patients and then directed patients to sign documents while drugged and then had signed forms notarized; stripped the patient; laughed at the patient; humiliated the patient; performed a number of unknown medical procedures, including: spinal taps; inserting probes; causing significant pain, and then testing the pain they caused with devices UCSF invented and patented for measurement of pain.    

60.       This occurred until one day, August 5, 2020, while running through one of their clinical trials for all sorts of different companies, and even for FDA approval of devices and products, being tested on subjects who would never even know this happened, I woke up and remembered and started telling everyone about horrific human medical research experimentation locations, benignly labeled as treatment centers, performing acts considered to be crimes against humanity, including the illegal organ harvesting of human brains, and torture being committed inside through the use of a pain measuring instrument called “PROMIS Pain.”  

61.       The below email was sent repeatedly to both the Sacramento County Sheriff’s Department Internal Affairs and the Sacramento County District Attorney regarding: “The U.S. Government is engaging in human experimentation research in which torture is one of the ‘medical procedures’ used.” 

“Dear Sacramento County District Attorney’s Office:  

Attached please find two documents. I write to inform you of illegal human experimentation “models”  / crimes against humanity including illegal organ harvesting (human brains) being committed at 8450 Okinawa Street, Sacramento, CA 95828, by the United States through federal agencies, state agencies, and universities across the country including UCSF, under Section 3021 of the Affordable Care Act. Specifically, I write to inform you that I have been forced to make two separate internal affairs complaints with the Sacramento County Sheriff’s Department for its harassment which continues to the present date. Although the Sheriff’s department has stopped regularly harassing me at my home and at my former girlfriend’s home (with the exception of Sunday evening, March 6, 2022, when a Sheriff parked on my driveway for approximately 15 minutes and my daughter heard him say that I was not home), I have recently been tailgated and followed by Sheriff’s officers on more than one occasion. Not only am I the victim of a crime which your office has ignored despite my requests for the prosecution of those involved, but the misuse of the Sacramento County Sheriff’s Department to harass me adds insult to injury.  

Section 3021 of the Affordable Care Act created the Center for Medicare & Medicaid Innovation (CMMI), an innovation lab within the Centers for Medicare & Medicaid Services (CMS) that is testing over 20 models aimed at improving quality and reducing costs within Medicare and Medicaid, which is currently being misused to perform illegal human experimentation. I try to tell as many people as I can about this illegal human experimentation being funded in part through the NIH, which has created human experimentation research “models” that are performed globally, including in the U.S., Canada, China, Australia, and the UK. There have been many investigations through government agencies which I assume are now closed, without communication of investigation results. The FDA, Jeff Maurice, performed a criminal investigation with no result, at least not communicated to me. Additionally, this program uses devices / drugs pending approval with the FDA on non-consenting subjects. And, this is carried out with the medical staff of the National Guard of each state, here in California through the California Army National Guard Medical Detachment (CA ARNG MED DET) of which Captain Lomboy is in charge. Captain Lomboy can be reached at (916) 854-1228.  Captain Lomboy may not have been in charge when this occurred in 2020, but he now heads up a task force on the matter, apparently to investigate me.     

I was a federal employee when I was victimized and I attempted to become a whistle blower and I was ignored. This illegal clinical study occurred at a military base on 8/5/2020 when I was supposed to be completing Census onboarding on my first and only day of employment with the Department of Commerce, Census. The Centers for Medicare and Medicaid Services Transforming Clinical Practice Initiative program was removed from the CHART model due to a serious adverse event that occurred on 8/5/2020. https://innovation.cms.gov/innovation-models/transforming-clinical-practices. This event was followed by UCSF changing and backdating several of its research programs to 2018. Those involved with TRACK TBI (and other models using the same UDEs and CDEs – 25,649 providers to be exact) currently have a lot of funding and compliance issues which resulted in HHS retroactively extending / delaying / expanding / revising certain provisions and reporting requirements for 2020. Between its loss of programs in 2020, and backdating and changing other existing research programs to 2018, it would be nearly impossible for UCSF and others to meet reporting requirements for pertinent time periods (which cover periods of time between one to three years). Fortunately for those involved in illegal human experimentation programs, under the guise of Covid 19 and through CMS-5531-IFC, HHS retroactively gave individuals and entities that provide services to Medicare, Medicaid, Basic Health Program, and Exchange beneficiaries “needed flexibilities to respond effectively to the serious public health threats posed by the spread of the coronavirus disease 2019 (COVID-19).”    

On August 5, 2020, I was a subject in an illegal clinical trial called Track – TBI, following a concussion that I had on May 4, 2020. This is global in scale through ALERT -TBI and other clinical trials done under FITBIR and INTBIR. These programs are conducted in Sacramento through universities located nationwide, including, but not limited to, University of California researchers (UCSF) and through federal agencies (under the common rule). The TRACK TBI protocol lists universities worldwide. The US Department of Energy is very involved in this matter (see the declaration). There are CDE’s and UDE’s which include spinal taps after rendering unsuspecting subjects / participants unconscious. It is also possible that there was a microdialysis device / probe implanted into my frontal lobe (or spine) according to the protocol and I have been having headaches, lightheadedness, ringing ears, and pain in my spine. I need to get a CT scan done but I have no primary care physician to refer me for one. TRACK TBI shut down after it was done to me because I became very vocal about it. Then it re-opened in June 2021. On February 22, 2022, Transformation Track was removed from the CHART model. TRACK TBI was shut down after I contacted the white house and Trump. It re-opened under Biden and he even stated in a news clip: “We support UCSF.” The program originally started when Obama was president in 2009 with the TRACK TBI Pilot clinical study model under Section 3021 of the Affordable Care Act. This has been done to over 41,000 unsuspecting U.S. citizens and humans globally, including in the U.S., Canada, Australia, China, and the UK. Internationally, the final report summary from CENTER-TBI (Collaborative European NeuroTrauma Effectiveness Research in TBI), TRACK TBI’s “sister study” which was following the same protocol as TRACK TBI, was also terminated.  

https://cordis.europa.eu/project/id/602150/reporting.

I was drugged against my will on 8/5/2020 at a military base by a researcher named Nsini Umoh, PhD, from the U.S. Army Medical Research and Materiel Command, Fort Detrick, Frederick, Maryland. Nsini Umoh was a federal liaison to UCSF / TRACK TBI at the time and worked for the DoD and VA. After being terminated for her involvement in this matter, she now works for the NIH/NINDS. I recognize several of the researchers including: Dr. John Yue, Nsini Umoh, and Dr. Randy Merchant. (I previously provided your office, the CHP, and the Sacramento County Sheriff’s internal affairs investigators with photos of these individuals.) In accordance with TRACK TBI protocol, the results of a CT or MRI are in my medical records, but to the best of my knowledge I have never had a CT or MRI. Also in conformity with the TRACK TBI protocol, my medical records were “blocked” at MD STAT Urgent Care for several months. Additionally, my medical records have been falsified at both MD STAT Urgent Care by Mike Vali (916) 678-5280, and falsified at Health and Life Organization by Gille Sumpo (916) 642-1876. (See the attached letter.) There are over 3600 subjects / control group / participants in TRACK TBI. These programs use massive spying programs on citizens, and track all of their entries on https://fitbir.nih.gov/content/data-dictionary.    

On August 5, 2020 I was lured under false pretenses to 8450 Okinawa Street, Sacramento, CA, 95828, for my first (and only) day of employment with the Department of Commerce, Census. On 8/5/2020 I was the victim of human experimentation which did not obtain my informed consent, drugged me, caused me to experience amnesia, and performed numerous medical procedures (CDEs and UDEs) including, but not limited to, a spinal tap. This was likely done because after I had a concussion on 5/4/2020, when I went to the doctor on 5/5/2020, I demonstrated regenerative genes / plasticity when I had 20/5 vision and I could read the tiny print on an eye chart. Per the TRACK TBI protocol, 90 days later, I was drugged against my will and subjected to illegal human experimentation. On August 5, 2020 I can remember feeling very dazed on drugs while documents were being notarized, likely informed consent and consent to perform an autopsy, since TRACK TBI collects brains to study the implanting of devices into the frontal lobe.   

During the 8/5/2020 “onboarding” I was provided a manila file folder which had numerous documents in it including two survey envelopes. The folder was handed to me when I entered 8450 Okinawa Street and likely had a substance on it which drugged me through transdermal delivery systems, considering that the lady who handed it to me was wearing surgical gloves. The envelopes were removed while I was unconscious because the TRACK TBI investigators fill out the surveys and submit the survey forms to CMS / HHS to make it appear that the subject / patient approved of and was satisfied with the medical intervention / treatment. In reality, the subject never knew the medical experimentation was performed because of drug induced amnesia, and would never have any indication that they were involved in medical experimentation except significant pain throughout their body especially in their joints and back, which in my case began the next day (after a very restless night of sleep). CMS then pays consultants to create lengthy reports regarding the success of the programs, and in my case all the reports omit the time period in which this was done (August 5, 2020) or otherwise omits pertinent information pertaining to my case (e.g. by limiting the dates the report covers, or limiting the scope of the report).  

These clinical trials should be reclassified as a torture programs. The Track TBI protocol includes the use of a pain instrument called the “PROMIS Pain Intensity.” The Pain Intensity short form (3a) was constructed by the domain team. Domain experts reviewed short forms to give input on the relevance of each item. Psychometric properties and clinical input were both used and likely varied in importance across domains. The Pain Intensity short form is universal rather than disease-specific. The first two items in the Pain Intensity item bank assess pain intensity utilizing a 7–day recall period (items include the phrase “the past 7 days”) while the last item asks patient to rate their pain intensity “right now.” The Pain Intensity instrument is available for adults (ages 18+) and the questionnaire is available for both adults and pediatric subjects.   

https://www.healthmeasures.net/explore-measurement-systems/promis

The TRACK TBI investigators are predators and are fully aware that they are harming subjects physically and mentally with their cruel human experimentation. Dr. Geoff Manley (Track TBI lead PI) and the Track TBI investigators published an article about suicide ideation increasing between the 3 and 6 month visit. Campbell-Sills L, Jain S, Sun X, Fisher LB, Agtarap SD, Dikmen S, Nelson LD, Temkin N, McCrea M, Yuh E, Giacino JT, Manley GT, Stein MB; TRACK-TBI Investigators. Risk Factors for Suicidal Ideation Following Mild Traumatic Brain Injury: A TRACK-TBI Study. J Head Trauma Rehabil. 2021 Jan-Feb 01;36(1):E30-E39. doi: 10.1097/HTR.0000000000000602.    

If any party / entity believes that it can contort the law retroactively to make this legal or ethical they are wrong. I cannot be the only one who is claiming that this illegal human experimentation / crime against humanity is being committed and I am sure that you are equally horrified that this is occurring. It is likely that other victims that attempted to speak out regarding this illegal human experimentation were silenced by the Sacramento County Sheriff’s Department, or their local law enforcement agency in other states and counties. I will not be silenced and I have a duty to humanity to expose this and so do you. Furthermore, you have a duty to investigate and prosecute those responsible for committing these heinous crimes and if the Sacramento County Sheriff’s Department refuses to do its job then your office should turn this matter over to the appropriate government agency to ensure that this illegal human experimentation is stopped.  

Please contact me at (916) 437-8130 if you want more details.   

Very Truly Yours,    

            /s/ 

Andy Pearson”    

The 8/5/2020 Clinical Study & UCSF’s Restraining Order 

            62.       I was drugged against my will on 8/5/2020 by numerous identifiable researchers, including a researcher named Nsini Umoh, PhD, from the U.S. Army Medical Research and Materiel Command, Fort Detrick, Frederick, Maryland. Nsini Umoh was a federal liaison to UCSF / TRACK TBI at the time and worked for the DoD and VA. 

63.       Nsini Umoh was the point person for TRACK TBI and other “clinical studies” and was the founder and CEO of a website called “Six Figure Tips”. (www.Sixfiguretips.com). 

            64.       Before it shut down, “Six Figure Tips” was a business geared towards those in the “clinical study” field by helping recent graduates and mid-career professionals achieve their financial, lifestyle, and professional goals with a submission form on the website for contact purposes to be recruited and placed in “clinical studies.” 

            65.       After being terminated for her involvement in the 8/5/2020 illegal human medical experimentation, Nsini Umoh now works for the NIH/NINDS, as a “Program Director in the Repair and Plasticity Cluster in the Division of Neuroscience.” 

            66.       I believe that a heightened interest was shown for me for my placement into TRACK TBI because when I had a concussion my vision actually improved (it was 20/5) so that I could read the tiny print on the eye chart, which has been removed from my medical records at MD STAT Urgent Care Sacramento and falsely replaced with “blurred vision” and “eye pain.” (Exhibit L, p. 7.). 

67.       UCSF obtained a workplace violence restraining order to prevent me from obtaining information under the The Privacy Act of 1974, as amended to present (5 U.S.C. 552a), and to preempt my claims against it including, but not limited to, patent fraud and conversion, as was the issue in Moore v The Regents of the University of California. (A true and correct copy of the August 16, 2021 restraining order hearing is attached hereto as Exhibit E.). 

The Judge in the case misapplied the law; started the hearing before I even stated any facts by claiming that I was delusional; asked Dr. Manley a series of direct organized questions, and then turned it over to me and then blew me off as “rambling”; concluding that she did not care whether the clinical study occurred or not, she was going to issue the restraining order.  The judge stated:  

“The matter of first impression on this case is whether, in fact, the Respondent is delusional in his belief that he was even in a trial that was handled by UCSF. I think that issue then speaks to how all the other issues are going to fall. So I would probably like to get to the issue of what are the facts in this case. If there’s no — if the facts of what the Respondent believes to be true is, in fact, not true, then there’s no SLAPP motion, there is nothing else because a SLAPP motion cannot be based on fiction. Then even if the facts were true, that would then — the other party, the Petitioner, would likely prevail in any case. I think that’s sort of putting the horse before the cart. I think we need to deal with the issue of whether, in fact, what the Respondent thinks occurred, did, in fact, occur. So I want to start with the Petitioner in this case […].” And, then the judge proceeded to ask Dr. Geoffrey Manley a set of organized questions to which he answered his rehearsed response. (Exhibit E, p.3.). Although there was no mention of the CIA, the judge stated “I’m not trying to stop him from talking to the CIA.” (Exhibit E, 23:3.). 

68.       The judge also stated that we could have conducted discovery and that “Clinical Studies” are transparent, ignoring Maryland case law restricting discovery in a case against the National Institute of Health; that information is limited by NIH issued confidentiality certificates which purport to be for the protection the subjects; and, the legislative intent of governing laws hold that the industry is self-regulating. 

69.       In the Workplace Violence Restraining Order hearing the San Francisco Superior Court was not provided with the pertinent facts, such as that TRACK TBI and UCSF underwent a major audit and TRACK TBI lost its funding and had to transfer everything to other universities. The attorney representing me in the Workplace Violence Restraining Order did not raise the facts of my case, conducted no discovery, and answered with an ANTI SLAPP suit. The attorney was more interested in having the hearing over skype because it could then be observed by other parties and it also served as the one year follow up per the TRACK TBI protocol. 

70.       One piece of relevant discovery evidence is the cell phone geolocation tracking data which would prove all parties who were at 8450 Okinawa Street, Sacramento, CA 95828 on 8/5/2020 between 8:00 am and 12:00 pm.  

71.       Another relevant piece of discovery evidence would be the video surveillance footage of 8450 Okinawa Street, Sacramento, CA 95828 on 8/5/2020. 

72.       UCSF’s ex-parte TRO should have failed and its workplace violence restraining order should have been dismissed because it failed to meet the standard of “clear and convincing” proof that I engaged in a “course of conduct” that actually and reasonably causes substantial emotional distress to Dr. Geoffrey Manley, and that my communications had “no legitimate purpose,” and were not “constitutionally protected activity.”  

73.       UCSF waited over five months to file their restraining order on January 20, 2021, then had the Sacramento County Sheriff’s Department attempt its first service 21 days after the TRO issued, on February 10, 2021, the day after my referral for a CT scan expired on February 9, 2021. This is odd behavior considering that Kate Mente sought an ex-parte workplace violence restraining order for Dr. Geoff Manley’s “safety.” UCSF must not have perceived me as much of a threat. The restraining order was based on two phone calls and one email to Dr. Geoff Manley in August 2020, and three emails Between August 2020 and December 2020 to 196 individuals listed as IRB / clinical study contacts on UCSF’s website, a public forum.  

            74.       The August 5, 2020 “clinical study” was conducted when I appeared for my first and only day of employment with the U.S. Department of Commerce, Census. I was subjected to illegal and unethical human experimentation pursuant to the scientific partnership / contracts between the University of California and the U.S. Department of Energy, supported by numerous government agencies and law firms including Baker Botts, and also supported by RTI International, a Central Intelligence Agency front company which is associated with UCSF in the operation of the SIREN study. I sent an email to RTI International on April 25, 2022, shortly after an onslaught of attacks began, to which I have been subjected, resulting in the instant criminal charges. 

75.       Baker Botts L.L.P. is an American law firm of around 725 lawyers. Headquartered in One Shell Plaza in Downtown Houston, Texas, the firm has a major list of energy and technology related clients.  

76.       A Census pamphlet was provided to me on August 5, 2020 with a photo of Baker Botts attorney Daniel Jung identified by facial recognition software. (A true and correct copy of the Census Pamphlet and Daniel Jung’s profile with Baker Botts is attached hereto as Exhibit W.).  

77.       On August 5, 2020 I was drugged and rendered unconscious, my body was stripped of all clothing, a spinal tap was performed, a computed tomography (“CT”) scan and/or MRI was performed to see if I had intracranial lesions and for placement of a “microdialysis” or other device into my frontal lobe (which UCSF can perform in under 25 minutes), and, I experienced one hour of amnesia with limited recollection of events. I can recall Nsini Umoh present while documents were being notarized while I was very dazed and intoxicated from drugs provided by researchers, and clearly lacked the legal capacity to execute forms. I was subjected to a multitude of tests, both physical and cognitive, according to CDEs and UDEs from the list that NINDS maintains pertaining to Mild TBI / Concussion Research.  

            78.       UCSF’s Dr. John Yue sat with me at a table while I received my iPhone, pretending to be a new hire that was there for Census enumerator onboarding. Dr. John Yue assisted me in entering my iPhone password and fingerprint. Dr. John Yue and Nsini Umoh walked behind me on my way out of the building where the clinical study was performed, one on each side directly behind me. Dr. John Yue followed me all the way to my car, was parked right next to me, and asked me “what are the odds that I would be parked right next to you?” Dr. John Yue also informed me that we were in the same conference call scheduled for 2:00 pm on August 5, 2020. Dr. John Yue was driving a Toyota truck that appeared to be a silver color. Dr. John Yue observed me get into my car and watched me drive away from 8450 Okinawa Street, Sacramento, CA 95828. Dr. John Yue did not leave the parking lot but likely returned to the building.  

79.       While walking to my car with John Yue there was an African American man standing next to my car. When he saw me coming he got into a red vehicle with no license plates and an “Army” bumper sticker, and proceeded to sit in his car while observing me. He is captured on my dash-cam video. 

80.       On August 22, 2020, I emailed Dr. John Yue and asked him: “Were you the individual sitting at the table with me when I received the iPhone who walked to my car with me? Please provide me with the information I have requested.” Dr. John Yue never responded to my email. The information that I requested was included in two emails which I forwarded to him on August 22, 2020, (one on August 20, 2020, and one on August 22, 2020) which requested all information regarding my participation in Track – TBI. (A true and correct copy the August 22, 2020 email is attached hereto as Exhibit A.). 

            81.       UCSF’s Dr. John Yue was the Clinical Trial Manager of the prospective multicenter “Transforming Research and Clinical Knowledge in Traumatic Brain Injury (TRACK-TBI) U01” (2014-2020), and previously the “TRACK-TBI Pilot RC2” (2010-14), funded by NIH and NINDS with the goals of developing, testing, and implementing the NIH Common Data Elements for TBI. TRACK-TBI is among the first prospective population-based TBI studies to incorporate clinical presentation, medical history, acute care treatment, genetics and proteomics, advanced neuroimaging, and multidimensional neurocognitive outcomes into a single, integrated, longitudinal data repository. The rich phenotypic information from TRACK-TBI will serve to standardize and improve existing classification systems as well as inform and initiate multivariable prognostic approaches for future work in the field. Transforming Research and Clinical Knowledge in Traumatic Brain Injury (TRACK-TBI) Precision Medicine Phase 2 Option 1 had a start date of April 1, 2021. 

            82.       I was not a threat to anyone in this matter that would have warranted a restraining order, particularly Dr. Geoff Manley. Dr. Geoff Manley is, as he said in one video, “a talking head.” He is merely the face of the UCSF research program. Dr. Geoff Manley did not perform the procedures, or Common Data Elements (“CDE”) and Unique Data Elements (“UDE”), in the clinical study / human experimentation, of which I complain. Dr. Geoffrey Manley merely supervised while student trainees performed the UDEs and CDEs and it was videotaped for “training purposes.” 

83.       The emotion that I expressed was rational and reasonable under the circumstances: when one discovers that they were unknowingly, without consent, drugged and exposed to illegal and unethical human experimentation through clinical studies. I have more of an issue with my former medical clinic, HALO, for lying about me and becoming my LAR / surrogate decision maker and consenting me to be in a study that drugged and battered me, than I have with those involved in the August 5, 2020 study. And even then, I am not a threat to anyone at HALO. 

84.       I have never claimed to be a “Targeted Individual.” It is possible that UCSF perceives me as a threat because they know what their program entails, and the experiences that I have are similar to those who claim to be “Targeted Individuals.” There are thousands of people in the United States and worldwide who claim to be Targeted Individuals (“TI”).  

85.       TI’s claim: to be targeted by others particularly law enforcement; believe that they are under clandestine government mind control programs similar to MK ULTRA and DARPA; describe “voices” in their head that no one else can hear; lack control of their own thoughts; lack control of their actions; believe that they are the victim of radio wave (RFID) and other attacks similar to those documented as “Havana Syndrome”; and, there is a pattern of those claiming to be TI’s carrying out mass shootings after first killing either their mother or another family member. 

86.       According to therapist Kim Whiting: “[M]any of those writing in TI blogs [believe], ‘the government’ engages in invasive mental torture for the purpose of research that will not only give it the upper hand in war, but ultimately give it total mental control of the masses. They say they’re being fed harmful, hurtful and painful thoughts to make them appear delusional—so that no one will give their claims credibility and conclude they’re simply crazy.” (Government Guinea Pigs? Investigating the Claims of ‘Targeted Individuals’ Who Insist They’re Being Stalked, Tortured. June 2021, Whiting, Kim. https://thereporters.org/letter/government-guinea-pigs/.). 

87.       Havana syndrome is an alleged set of medical symptoms with unknown causes experienced mostly abroad by U.S. government officials and military personnel. The symptoms range in severity from pain and ringing in the ears to cognitive difficulties and were first reported in 2016 by U.S. and Canadian embassy staff in Havana, Cuba. Beginning in 2017, more people, including U.S. intelligence and military personnel and their families, reported having these symptoms in other places, such as China, New Delhi, India, Europe, and Washington, D.C. The cause and validity of the illness have yet to be determined. The U.S. Department of State has referred to the events as “unexplained health incidents”, while Central Intelligence Agency director William Burns has publicly called them attacks. 

88.       DARPA is the Pentagon’s research arm, the Defense Advanced Research Projects Agency, which has made public in recent years that it’s developing brain implant chips and computer-to-brain communication technology with the aim to “develop an implantable neural interface able to provide unprecedented signal resolution and data-transfer bandwidth between the brain and the digital world.” 

89.       DARPA also aims to develop and test “a wireless, fully implantable neural-interface medical device for human clinical use. The device would facilitate the formation of new memories and retrieval of existing ones in individuals who have lost these capacities as a result of traumatic brain injury or neurological disease.” 

90.       DARPA’s “Next-Generation Nonsurgical Neurotechnology (N3)” program aims to develop a “safe, portable neural interface system capable of reading from and writing to multiple points in the brain at once. Whereas the most advanced existing neurotechnology requires surgical implantation of electrodes, N3 is pursuing high-resolution technology that works without the requirement for surgery.” 

91.       I have experienced: painful ringing ears; pain in my spine; light headedness; unexplainable severe pain causing me to double over in a cold sweat; episodes of severe rage occurring while I am in a “daze” that feel as if I have little to no control; and, I have been targeted relentlessly by the Sacramento County Sheriff’s Department and other State of California and federal agencies since 8/5/2020. 

            92.       When I asked questions and sent revocations of any authorizations to the individuals who may have been acting in reliance upon the authorizations, as I was required to do by law and told to do by the U.S. Department of Health and Human Services, UCSF responded with a TRO. (A true and correct copy of the December 2, 2020 HHS email is attached hereto as Exhibit C.). The emails that I have sent were of little use in gathering information, although UCSF’s response speaks volumes.  

            93.       On August 15, 2020, changes were made to the Track – TBI study on https://clinicaltrials.gov/. The Contacts/Locations were changed to delete the “Central Contact:” John Yue, BA, CCRC, Telephone: 415-206-4457, Email: yuej@neurosurg.ucsf.edu. Changes deleted: “Central Contact Backup:” Mary Vassar, RN, MS, Telephone: 415-206-8300, Email: vassarm@neurosurg.ucsf.edu. And, twelve study officials were added under Dr. Manley, University of California, San Francisco. Track – TBI has an Actual Study Start Date of March 2, 2014; Actual Primary Completion Date of June 22, 2019; and, and Actual Study Completion Date of August 31, 2020. (A true and correct copy of the changes / deletions on Track – TBI study on https://clinicaltrials.gov/ is attached hereto as Exhibit B, p.3, 17.). 

            94.       All of my communications used in the declarations that UCSF attached in support of its TRO were taken out of context, intentionally misleading, omit pertinent parts of my statements, and mislead the court as to whether I was a subject / participant in Track – TBI or any other study including ALERT – TBI, which uses technology to simulate a concussion. It was disingenuous for Dr. Geoff Manley to deny UCSF’s involvement, selecting his words carefully and telling half-truths, considering that the individuals who perform these human experimentation studies are all from a small pool of researchers / investigators. (A true and correct copy of the NINDS Roster is attached hereto as Exhibit D, p. 2, 4.).  

            95.       The declarations that UCSF attached in support of its TRO misrepresent my communications; Dr. Manley and Waimen Chee’s declarations are intentionally misleading; and, Dr. Manley’s declaration omits pertinent parts of my statements. For example, Dr. Manley stated in his declaration that I said that I was coming after him: “and said he would be coming after me. I was immediately afraid for the safety of myself, my family, and my colleagues.” Dr. Manley intentionally omitted that the message that I left on his voicemail stated that I was coming after him, which was followed immediately by “Legally, of course.” The fear that I caused Dr. Manley to experience is that of being exposed for his unethical and criminal human medical experimentation and participation in U.S. sanctioned torture programs. 

            96.       The government has made it clear that they will do anything to stop me from pursuing TRACK TBI’s illegal human medical experimentation and exposing U.S. Government sanctioned torture programs. UCSF’s restraining order attempted to prevent me from communicating and chills my free speech with requests that I not be able to communicate with the “UCSF community” and Dr. Manley’s “colleagues across the country.” I notified UCSF’s attorney on March 30, 2021 that, although I have no intention of further communications, this section was a clear violation of my right to freedom of speech per the U.S. Constitution and California Constitution. (Exhibit E.). On December 10, 2020, I notified UCSF’s Susan Smith that UCSF was encroaching on my constitutionally protected free speech. (A true and correct copy of the December 10, 2020 email to Susan Smith is attached hereto as Exhibit O, p. 2.).  

            97.       UCSF works regularly with QuesGen Systems, which is the Data Management platform for TRACK-TBI. Michael A. Kohn, MD, MPP, the Chief Medical Officer of QuesGen is also a professor at UCSF. He is a professor of Epidemiology and Biostatistics at UCSF where he provides study design consultations to clinical investigators. Dr. Kohn is an expert on database management for clinical research, both setting up study databases and extracting data from the electronic health record. QuesGen Systems is responsible for my placement into the clinical study, by directly contacting MD Stat Urgent Care and Health and Life Organization, Sacramento Community Clinic, for my placement into the clinical study, and to have HALO execute a LAR for surrogate decision making purposes.  

98.       In UCSF’s TRO, Dr. Manley’s claimed to feel “threatened, stalked, and unsafe” because of 3 emails to 196 individuals in the clinical study field and was not supported by facts. None of my emails contain any threatening language. I sent two emails requesting information and providing facts, one on August 22, 2020 and one on December 1, 2020.  The third email on December 3, 2020 corrected facts in the December 1, 2020 email and included the opportunity to opt out of future emails. 

99.       Between December 1, 2020 and December 3, 2020, I informed multiple parties to cease and desist from using my property, including, but not limited to: bodily fluids (blood, cerebrospinal fluid, etc.), MRI, CT, medical records; I informed multiple parties that I give/gave no past, present, or future consent to be in any clinical studies; and, I reiterated that any authorizations were revoked. In response, UCSF’s Susan Smith informed me that UCSF was considering a workplace violence restraining order and I told her that would infringe upon my free speech. (A true and correct copy of the December 10, 2020 and December 11, 2020 emails to Susan Smith are attached hereto as Exhibit O.). I also gave the opportunity to the community to which Dr. Manley refers to stop receiving my emails, and only 5 email recipients out of 196 opted out by replying “STOP.” 

100.     Initially, on December 1, 2020, I only informed the U.S. Department of Health and Human Services of my revocations. On December 2, 2020, HHS told me to inform the parties directly, so I informed everyone that needed be informed. (A true and correct copy of the HHS email is attached hereto as Exhibit C.). It was at that point that UCSF told me to stop communications and threatened me with a workplace violence restraining order. (Exhibit O.). The contact information for all 196 people that I emailed was obtained from the UCSF website which invited viewers who are seeking information to contact the IRB members / contacts with any questions 

101.     Most of my communications were to UCSF’s Susan Smith, who was communicating with me and sending emails for Kate Mente. My communications were always polite and forthcoming, such as: “Hello: I look forward to seeing you, and those responsible for TRACK TBI drugging me and performing a spinal tap, in court. I recognize Randy Merchant, John Yue, and Nsini Umoh from the 8/5/2020 clinical trial. I do have one question. How do my emails equal any sort of violence or threats of violence? I understand that Geoff Manley runs UCSF, but he does not control the outcome in court and there has been no threat of violence. I only called Dr. Manley once, and believe that I accurately called him a “piece of shit” and a “Nazi doctor.” I went on to state that I was not surprised that he worked for Zuckerberg Hospital, considering what everyone knows of Zuckerberg. I bet the courts will agree. You need to give Dr. Manley a primer on the 1st Amendment. Although, your whole clinical study, conducted with numerous government agencies, was unconstitutional. One way or another we will end up in court regarding this matter, so do whatever you want. I’ll see you in court. Very Truly Yours, Andy Pearson.”  

            102.     The last communication that I had with Susan Smith, prior to being served with the TRO, was on January 25, 2021 when I inquired where to send my tort claims. On January 27, 2021, I sent my 6-month notice that I have tort claims against the UC Regents. (A true and correct copy of the January 27, 2021 notice of tort claims and January 25, 2021, January 26, 2021, and February 19, 2021 communications with Susan Smith are attached hereto as Exhibit F.).  

            103.     UCSF admits that it was directing the Sacramento County Sheriff’s Department’s harassing actions and targeting by admission of “notice” documents left by the Sheriff and “welfare checks” performed by the Sheriff. According to UCSF’s Waimen Chee’s declaration, Waimen Chee is responsible for the Sacramento County Sheriff’s Department being sent to my home on at least five separate occasions, under the guise of “welfare checks.” In reality, the Sheriff’s visits were to investigate me for seeking information and becoming vocal regarding what is the most unethical and illegal human medical experimentation / clinical studies ever conducted in this country, by sending emails to 196 email addresses which were listed on UCSF’s website as contacts for those seeking information regarding clinical studies.  

104.     UCSF’s Waimen Chee requested a “welfare check” and requested the Sacramento County Sheriff to provide a “formal notice to cease respondent’s harassing conduct” is likely a defensive tactic UCSF employs when it is caught in illegal human experimentation. (A true and correct copy of the September 10, 2020 and November 5, 2020 email sent to the UCSF Police Department and August 24, 2020 UCSF PD email is attached hereto as Exhibit P.).  

105.     UCSF’s Waimen Chee directed the Sacramento County Sheriff’s Department to communicate “notices” and at all times the Sheriff’s Department was aware of the illegal human medical experimentation. Waimen Chee’s declaration stated: “I am aware that the Respondent received the Notice because he responded to UCSF Police on November 5, 2020 regarding the content of the Notice.” 

106.     UCSF attempted to hide the involvement of the Sacramento County Sheriff’s Department in this matter and issue was made of “notice” letters delivered by the Sheriff. UCSF’s Susan Smith provided multiple Proof of Service stating that she mailed me the “Notice” that was actually sent Fed Ex. (A true and correct copy of UCSF letters from Dr. Manley and the UCSF Human Research Protection Program dated December 10, 2020 and December 11, 2020 are attached hereto as Exhibits U, V.). Waimen Chee concludes that a request for an internal affairs investigation amounts to harassment citing to my request for an internal affairs investigation as “proof of ongoing harassment.” (Exhibit P.). 

            107.     Internal affairs are supposed to investigate law enforcement for numerous reasons and I have the right to request an internal affairs investigation into any law enforcement entity that is not performing its job correctly, which is harassing me, and that is engaged in illegal human medical experimentation research / U.S. Government sanctioned torture. I opened three internal affairs complaints with the Sacramento County Sheriff’s department and they were in direct communication with the UCSF Police Department. I wanted to know why I was being harassed by the Sacramento County Sheriff’s Department on a regular basis, at the request of the UCSF Police Department. The Sacramento County Sheriff’s Department was causing my family to experience stress due to their repeated attempts at contacting me at multiple residences.  

            108.     UCSF’s conduct speaks volumes. It is significant that the first attempt at service of the TRO by the Sacramento County Sheriff’s Department was 21 days after it was issued, on February 10, 2021, the day after the referral from HALO for a CT exam expired. (A true and correct copy of the referral from HALO is attached hereto as Exhibit G.).  

            109.     I have been asked from several different government agency employees whether I obtained the CT scan, and despite my best efforts I am unable to find a provider who will provide a referral for a CT scan at this juncture.  

            110.     Effective April 1, 2021 TRACK- TBI resumed, making clear: the purpose of the restraining order was to protect UCSF against my property / patent claims; to chill my free speech and prevent me from communicating with others about UCSF’s illegal human medical experimentation / torture; and, the TRO was to prevent me from being able to obtain information to which I am entitled pursuant to the Privacy Act, in which I can obtain clinical study records including records detailing to whom my medical records were disclosed, thereby obstructing evidence of the parties in the “clinical study” preventing evidence of Dr. Manley’s and TRACK – TBI’s roles in this matter.  

A.        Per the Privacy Act, a covered entity may deny an individual access to all or a portion of PHI requested in only very limited circumstances, including if it determines in the exercise of professional judgment that the access requested is reasonably likely to endanger the life or physical safety of the individual or another person. Dr. Manley’s claims to be threatened are intended to form the basis for the denial of records revealing to whom my medical records have been disclosed.  

B.        This demonstrates UCSF’s willingness to resort to the Superior Court of California for improper purpose, as does the Sacramento Sheriff’s Departments and Sacramento County DA’s conduct in bringing charges through entrapment. 

C.        Once I declined to provide a verbal statement to IA Investigator Jeremy Workman, the government wrongfully resorted to investigations performed by additional California Government Agencies including the Department of Family Services.  

            111.     Dr. Manley’s claim that I was not in Track – TBI is a distinction without a difference, considering the clinical studies overlap with CDE’s and UDE’s and the researchers / investigators are all from the same identifiable groups. This clinical study / human experimentation network is global in scale. The TRACK-TBI Pilot dataset was the first to populate the Federal Interagency Traumatic Brain Injury Research (FITBIR) repository and with the current TRACK-TBI data, is compatible with the International Initiative for Traumatic Brain Injury (InTBIR), a collaborative effort of the European Commission (EC), the Canadian Institutes of Health Research (CIHR) and the National Institutes of Health (NIH). The global aim of this project is to test and refine Common Data Elements (CDEs), neuroimaging standards, and best practices for genetics and proteomics in Traumatic Brain Injury (TBI) studies.  The TBI Endpoints Development (“TED”) Metadataset contains granular data on over 6,000 mild-moderate and severe TBI study participants across eight individual studies conducted at different study sites. The constituent studies include TRACK-TBI, TRACK-TBI Pilot, COBRIT, TBICare, Concussion Research Consortium, ProTECT III, Mission Connect, and an NIH-funded neuroimaging study led by TED Investigator Dr. Pratik Mukherjee. TRACK-TBI also forms one of the core datasets of the Department of Defense-funded TBI Endpoints Development (TEC) Initiative, which has established an interrogatable Metadataset of high quality studies across civilian, sports, and military populations. TED’s goals, aligned with TRACK-TBI, are to identify and validate the FDA regulatory readiness of candidate clinical outcome assessments and proteomic and neuroimaging biomarkers and technologies that may serve as endpoints in the design of precision clinical trials. Clinical, imaging, proteomic, genomic and clinical outcome databases will be linked into a shared platform that will promote a model for collaboration among scientists within InTBIR and elsewhere, which was originally funded by the Grand Opportunity Grant (GO study). TRACK-TBI is built from the foundational NINDS-funded TRACK-TBI Pilot study, which collected clinical data from 3 sites and 600 subjects.

            112.     I figured out that I was in TRACK – TBI by process of elimination and by identification of the researchers. Although I cannot access all of the available data, the entries at https://fitbir.nih.gov/content/data-dictionary with the: Status “Awaiting Publication” and “Published”; the Element Type: “Common Data Element” and “Unique Data Element”; for the Disease: “Traumatic Brain Injury”; with the Population: “Adult” and “Preclinical” for all dates reveals that Track – TBI has left its imprint on numerous entries since my May 4, 2020 concussion. Track – TBI created entries, including entries in March 2021 on https://fitbir.nih.gov/ content/data-dictionary, which is strange for a program with an Actual Study Completion date of August 31, 2020. There is an entry with “Event End Date” of 12/01/2020 which coincides with my revocation of medial releases / authorizations, and when I made it clear that there is no past, present, or future consent for me to be in any clinical studies under any circumstances. Track – TBI has left its imprint on numerous entries since my May 4, 2020 concussion which have been changed from “TRACK TBI” to “COVID 19”.  

            113.     There are several entries both Published and Unpublished on FITBR that are particular to me by both “Modified Date” and a “Creation Date” including, but not limited to, a Creation Date of “2020-07-28” which reference: “https://tracktbi.ucsf.edu/transforming-research-and-clinical-knowledge-tbi” and were modified after the August 5, 2020 clinical trial. Additionally, the researchers / investigators that I can identify from the FITBIR search engine are specific to my case and pertain to regenerative research and anesthesia, relevant topics. These dates line up with Census activity.  

A.        On July 21, 2020, the Census emailed me that I had seven days to complete fingerprinting. (A true and correct copy of the July 21, 2020 Census email is attached hereto as Exhibit H.).  

B.        On July 28, 2020, the Census contacted me to inform me that I passed the background check and that I would begin training on July 31, 2020. On July 30, 2020, Rosalina L. Gallardo emailed me, with Harmohinder S. Atwal, Robert G. Bugarin Jr., Robert K. Phelps, and Kelly V. Haynes being cc’d, that my training would be on August 5, 2020. (A true and correct copy of the July 28, 2020 Census email is attached hereto as Exhibit H.). 

            114.     Considering that I was consented to be in a clinical study / human experimentation by a LAR / surrogate decision maker, I believe that the purpose of the tests / experimentation that were performed while I was filling out Census paperwork was to make the subject appear to be incompetent to support the use of a Legal Authorized Representative / surrogate decision maker on which UCSF relies for consent of subjects in Track TBI and its other clinical studies. (A true and correct copy of UCSF’s surrogate consent forms and guidance memo updated on February 16, 2021 is attached hereto as Exhibit I.). The direct deposit form has boxes that are not in a straight line and numerous forms had text running off the line. (A true and correct copy of the Census onboarding direct deposit form (not my account information) is attached hereto as Exhibit J, p.2.). I informed the FDA criminal investigator, Jeff Maurice, that the forms: “looked like a kindergartner filled them out.” On 8/5/2020, Nsini Umoh had me fill out portions of the same forms up to three times, and did not accept the ones that I filled out on my home computer, only accepting the direct deposit form. The tax withholding form was filled out in a chaotic setting with people yelling, and I was approached by two different investigators who told me to “put all zeros” and argued with me about my dependents and deductions, revealing that one investigator had knowledge of my son’s age. (A true and correct copy of the Census onboarding tax withholding form is attached hereto as Exhibit J, p.1.).  

            115.     I had a concussion on May 4, 2020 when I was punched in the back of the head by my girlfriend’s 22 year-old son. I was diagnosed with a concussion on May 5, 2020 by Mark Robinson, NP, at MD STAT Urgent Care Sacramento, 391 Howe Avenue, Sacramento, CA 95825. I filed a HIPAA complaint with the U.S. Department of Health and Human Services, Office of Civil Rights, (“HHS”) because MD STAT Urgent Care Sacramento “locked” and would not provide my PHI / medical records in accordance with the Track – TBI Protocol. HHS closed my complaint informally through the provision of technical assistance to MD STAT. (A true and correct copy of the October 27, 2020 HHS letter is attached hereto as Exhibit K.). When I finally received my medical records from MD STAT, there were errors and omissions, my 20/5 vision is omitted, and there is a false statement of the facts exaggerating the events surrounding the May 4, 2020 concussion. (A true and correct copy of my MD STAT medical records page 1 is attached hereto as Exhibit L, p. 7.). 

            116.     The August 5, 2020 clinical trial occurred at the Army National Guard building located at 8450 Okinawa Street, Sacramento, California 95828. There are 3,668 subjects in Transforming Research and Clinical Knowledge in Traumatic Brain Injury (“Track – TBI”), whom UCSF claims consented to spinal taps to remove Tau Protein biomarkers, and it is carried out with the DoD. Track – TBI ceased when I became vocal about the August 5, 2020 clinical study, shutting down and restricting access to its website, yet TRACK TBI is currently operating under “Precision Medicine – Option 1” and TRACK TBI has left recent entries on https://fitbir.nih.gov/content/data-dictionary. As of 8/12/2020, FITBIR perversely boasts that it has 69,762 Subjects in 72 studies and has imported all TRACK TBI data. 

            117.     There was/is someone operating as my Legal Authorized Representative / surrogate for consent purposes to enroll me in the clinical trial. I believe that it is Gille Sumpo at Sacramento Community Clinic, Health and Life Organization, even though she cannot legally be my LAR. The May 4, 2020 concussion exacerbated my Attention Deficit Disorder. For the first 20 days following the concussion it was extremely difficult to focus or do anything requiring attention. I went to the doctor on June 22, 2020 to get back on Adderall, which I was prescribed since 2007 and have been on and off since. Adderall helps me focus and perform tasks requiring concentration, including thinking, reading, writing, etc. My June 22, 2020 medical records from Health and Life Organization, Sacramento Community Clinic, located at 3030 Explorer Dr. Sacramento, CA 95827, state that “my son” punched me in the back of the head resulting in a concussion. In reality, my girlfriend’s son, Blake Coleman, punched me in the back of the head. (A true and correct copy of the first page of HALO medical records is attached hereto as Exhibit L, p.6.). 

            118.     HALO has taken the position that it will not correct the records. Initially, I believed that HALO intentionally denied and obstructed two referrals, one of which was for a CT scan because I was being stalled to fit into the parameters of Track – TBI. Once I called and inquired with HALO, upon discovery of the clinical trial in which I was an unwilling subject, on August 13, 2020, HALO processed expedited referrals which were approved on August 14, 2020, one of which was for a CT scan which expired on February 9, 2021. (A true and correct copy of the CT referral is attached hereto as Exhibit G.). A male employee at HALO told me “I did not know that they were going to do that to you” when I called and expressed my anger that I was placed into a clinical study and violated on 8/5/2020. The same HALO employee is the one who refused to correct my medical records to reflect that my son did not punch me. 

            119.     I wrote a letter to Medi-Cal requesting cancellation of my insurance and I requested that an investigation be performed into my allegations. (A true and correct copy of the August 30, 2020 and September 6, 2020 Medi-Cal letters are attached hereto as Exhibit L.). By stating that my son was my abuser, disclosure requirements pursuant to 45 CFR § 164.512(c)(2)(ii) were circumvented, especially since my 19 year-old son is listed as my representative on forms and as an emergency contact. Since disclosures to victims of abuse, neglect, or domestic violence, must promptly inform the victim that such a report has been or will be made, my medical records were likely altered / falsified so that an exception under 45 CFR § 164.512(c)(2)(ii) existed. Accordingly, I was not entitled to disclosure since the covered entity would be informing a personal representative (my son), and the covered entity created the appearance that it had a reasonable belief my personal representative was responsible for the abuse, neglect, or other injury, and that informing such person would not be in the best interests of the individual as determined by the covered entity, in the exercise of professional judgment.  

            120.     HALO was paid to fabricate my medical records so that it could become my LAR, and it was paid to provide surrogate consent and place me into Track – TBI / clinical studies. Dr. Manley states in his Track – TBI training video, Part 1 at 10:27, that: “This is essentially a pay for performance strategy.” The pay for performance strategy incentivizes illegal conduct on the part of the researchers and others who are paid to falsify medical records and provide surrogate consent for patients / subjects. (A true and correct copy of Track – TBI training video Part 1 screenshot is attached hereto as Exhibit Q; See https://www.youtube.com/watch?v=6E5pd756hRw at 10:27.) 

            121.     I never authorized HALO, or any of its employees, to represent me in a surrogate capacity as my legally authorized representative. I would not allow someone, who I do not even know, to dictate the terms of my health and place me into a clinical study that drugged me and performed a spinal tap after being lured, under false pretenses, to 8450 Okinawa Street, Sacramento, CA 95828.  

122.     After close scrutiny of the releases for my medical records that I provided to the California Medical Board and California Board of Registered Nurses, I believe that not only was there someone claiming to be my LAR for medical decision making purposes, but that both the California Medical Board and Board of Registered Nurses knew that the LAR / Surrogate decision maker was an issue / potential defense for UCSF and tailored their releases for my medical records accordingly. (A true and correct copy of California Medical Board and Board of Registered Nurses medical authorizations / releases are attached hereto as Exhibit M.).  

            123.     I gave an hour-long statement to Jeff Maurice, an FDA criminal investigator. I have sent out FOIAs with inadequate responses. I have submitted FOIA’s to the Department of Commerce, Census; VA; DoD / Army / Fort Detrick; California Army National Guard; HHS; FDA; and, the Department of Energy communicated with me through the California Army National Guard. (A true and correct copy of the EEO Complaint, Declaration of Andy D. Pearson, Department of Energy contact is attached hereto as Exhibit N, p. 13-17.). I submitted an EEO complaint to the Department of Commerce, Census, which was investigated by David Jones, an investigator who regularly works with the Department of Energy, (A true and correct copy of the EEO Complaint, Declaration of Andy D. Pearson, is attached hereto as Exhibit N.); I submitted a HIPAA complaint with the HHS Office of Civil Rights; I requested over three internal affairs investigations take place with the Sacramento County Sheriff’s Department due to its continued harassment throughout this ordeal; I notified the California Highway Patrol that human experimentation was being conducted at 8450 Okinawa Street, Sacramento, CA 95828, since that location is within CHP jurisdiction, and I informed the CHP that intoxicated subjects were being placed into their automobiles and driving unaware that they had been drugged; I notified the Sacramento County District Attorney and have kept them informed of criminal conduct throughout; and, I submitted a complaint with the California Department of Health Care Services. Additionally, I have contacted numerous politicians, including, but not limited to: Senator Kamala Harris, Senator Dianne Feinstein, Governor Gavin Newsom, President Donald Trump, and, Congresswoman Doris Matsui. I informed these politicians of the illegal and unethical human experimentation and sought any help that they could offer. I informed Doris Matsui that she would be a defendant. I believe that one or more investigations were opened, but I only heard back from Senator Kamala Harris and Senator Dianne Feinstein, and did not obtain resolution. 

            124.     On October 20, 2020, the California Department of Health Care Services contacted me via email and informed me that it does not have access to my medical records, cannot change my medical records, and directed me to my Managed Care Health Plan, Anthem Blue Cross. As of March 11, 2021, Anthem Blue Cross was more interested in whether I was going to be satisfied with the results of the various government agency investigations, or if I would be pursuing other recourse, demonstrating concern for its clear insurance company bad faith liability (breach of the covenant of good faith and fair dealing).  

A.        Anthem Blue Cross informed me that it cannot view my records and could only provide the dates and services submitted in claims, which reveal: (1) on May 5, 2020 MD Stat submitted a claim for an office visit / examination and two shots, one therapeutic and one prophylactic (although I only received one shot); (2) on May 6, 2020 DRI performed two x-rays: one cervical x-ray and one shoulder x-ray (no CT or MRI); (3) on May 7, 2020, MD STAT submitted a claim for an office visit / phone call; and, (4) on June 22, 2020 Quest Diagnostic submitted a claim, but there was no claim for an office visit submitted by Sacramento Community Clinic, Health and Life Organization, on June 22, 2020. This is because, based on California law, one who is operating as a LAR / surrogate decision maker is prohibited from receiving compensation unless it is through the clinical study. (A true and correct copy of UCSF’s policy on surrogate consent is attached hereto as Exhibit I, p.5.). 

            125.     On November 29, 2020, I revoked my medical authorizations, informing the parties that any use of my medical records except for the limited use for which they were obtained would be illegal, and I closed the California Medical Board complaint against Dr. Geoff Manley and I closed the California Board of Registered Nurses complaint against Gille Sumpo. I closed these complaints because on November 9, 2020 when I spoke with Kristy Whitmire, the special investigator with the Department of Consumer Affairs, Board of Registered Nurses, asked questions which revealed that she had knowledge that the results of the August 5, 2020 CT scan and clinical study were in my medical records at HALO. Ms. Whitmire also asked questions which revealed that she had knowledge that UCSF had a potential issue / defense to my claims of lack of consent based on the LAR / surrogate decision maker. Ms. Whitmire elicited from me that I have had at least 4 – 5 concussions in my life, and when I told her that my vision was 20/5 at MD STAT Urgent Care on May 5, 2020, she said the exact same thing as the FDA criminal investigator: “That’s interesting.” On January 10, 2020, I emailed and asked Kristy Whitmire: “Were you gathering facts (TRACK TBI 6 month follow up) which were reported back to any individuals / organizations associated with TRACK TBI?” Ms. Whitmore responded: “N o.” The BRN closed my complaint on January 13, 2021 (A true and correct copy of the January 13, 2021 BRN letter closing my complaint is attached hereto as Exhibit T.). 

            126.     On August 5, 2020, UCSF did not want to miss out on its cut of the global clinical trials market size which at the time was estimated at $44.3 billion in 2020 and was expected to reach $47.0 billion in 2021.  This figure does not account for the market size of the cerebrospinal fluid industry. One of the complaints from the Track TBI pilot program was that the use of commercial cerebrospinal fluid provided by vendors for the control group did not provide enough information regarding the subject from whom it was extracted. Track – TBI dealt with this issue by enrolling a large control group and further expanded this group by enrolling additional participants as the “friends” group to investigate and track individuals who are associated with subjects who had TBI’s. Track – TBI, and other TBI clinical studies which follow CDEs and UDEs, perform spinal taps to remove cerebrospinal fluid not only to examine the CSF, but to reduce costs and increase profit in the cerebrospinal fluid industry. 

            127.     The Traumatic Brain Injury Endpoints Development (TED) Initiative is a 5-year, Department of Defense (DoD) funded project that is working toward the ultimate goal of developing better designed clinical trials leading to effective treatments for traumatic brain injury (TBI). TED is comprised of leading academic clinician scientists, along with innovative industry leaders in biotechnology and imaging technology, patient advocacy organizations, and philanthropies, working collaboratively with regulators, specifically the US Food and Drug Administration. The TED Initiative Contact Principal Investigator is Geoffrey T. Manley, MD PhD of the University of California, San Francisco. (A true and correct copy of pages 1 and 2 of AWARD NUMBER: W81XWH-14-2-0176 is attached hereto as Exhibit S.). 

            128.     In 2017, the TED Initiative secured an FDA Letter of Recognition of Research Importance regarding TBI from the Center for Devices & Radiologic Health, as well as a Letter of Support from the FDA’s Center for Drug Evaluation and Research to further explore neuroimaging biomarkers. The Letter of Support, signed by Dr. Janet Woodcock, Director of FDA’s Center for Drug Evaluation and Research explicitly calls for further exploration of neuroimaging prognostic biomarkers to identify patients who are likely to develop persistent disability during the course of mild traumatic brain injury clinical trials. (A true and correct copy of letters dated March 31, 2017 and January 10, 2018 are attached hereto as Exhibit R.).  It is highly likely that subjects involved in these types of studies developed persistent disability and possibly worse, including suicidal ideation and behavior.  

            129.     The manner in which this study is carried out is cruel and amounts to torture. To: hire a job applicant for federal employment; subject the new hire to unethical, illegal, and intrusive human experimentation; execute and notarize legal documents while the subject is incapacitated from drugs provided by researchers; and, when things do not go as planned to invoke defensive measures including denial, obstruction of information and evidence, abusing its relationship with law enforcement through repeated harassing visits to the subject’s home,  perjury in declarations, abusing its power with the courts through an ex-parte TRO that should have been dismissed, and ultimately aggressive pursuit of criminal charges through the Sacramento County Sheriff’s department after federal attempts failed.  

            130.     Further, the researchers / investigators are predators who know that their conduct causes severe harm to the subjects, even to the point of suicidal ideation and behavior. The NINDS website lists Prospective Assessments for Suicidal Ideation and Behavior, and directs investigators to review the FDA’s “Guidance for Industry: Suicidal Ideation and Behavior: Prospective Assessment of Occurrence in Clinical Trials” for the most up-to-date information about suicidal ideation and behavior. The Track – TBI clinical study protocol on ClinicalTrials.gov directs one to an article written by Dr. Geoff Manley and the Track – TBI investigators: Campbell-Sills L, Jain S, Sun X, Fisher LB, Agtarap SD, Dikmen S, Nelson LD, Temkin N, McCrea M, Yuh E, Giacino JT, Manley GT; TRACK-TBI Investigators. Risk Factors for Suicidal Ideation Following Mild Traumatic Brain Injury: A TRACK-TBI Study. J Head Trauma Rehabil. 2021 Jan-Feb 01;36(1):E30-E39. doi: 10.1097/HTR.0000000000000602. 

            131.     I know first-hand the harm that occurs from such a clinical study. It is unconscionable to purport to hire someone for a Census job, but in reality the subject is placed into a clinical study, which: directs medical providers to falsify medical records so that a surrogate decision maker is created to consent the patient / subject into the clinical study; the falsification of employment records to create the appearance of an incompetent employee; a study which performs tests on intoxicated subjects to get the result the investigator wants and predicted; uses drugs to cause amnesia; employs researchers / investigators who de-humanize subjects and even laugh at the subject while the subject struggles with an iPhone in a drug induced state; humiliates the subject; and, in the best case scenario leaves the subject confused as to what even transpired, in what amounts to nothing more than a cruel human experiment for the profit of those involved in this clinical study / human experimentation which receives hundreds of millions of dollars in funding from private and government sources annually and is TORTURE. 

            I declare under penalty of perjury under the laws of the State of California, and in accordance with 28 U.S.C. § 1746, that the foregoing is true and correct.  

Executed this 20th Day of August 2022, in Sacramento, California. 

                                  _______________________________________ 

             ANDY D. PEARSON, Declarant­­­­­­­­­­ 

4 thoughts on “CALIFORNIA v. PEARSON”

  1. Wow. I was able to read through the first 31 sections (I have to go teach in a few moments). His story is very intense and troubling. But of course, we know what kind of cruel, insane programs are instituted and continued through gov’t and its minions. It’s just tragic. Take good care of yourself, too, Tim.

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    1. It gets more interesting as he goes on when he describes particular brain surgeons who committed crimes against him, drugging him at a federal facility.

      Below are the references I checked out, while I decided this guy is authentic–while he remains a lawyer in good standing and so, presumably, an officer of the California Supreme Court.

      Okinawa Armory (which mentions something called the CyberDawn Exercise as well as How To Survive Interrogation):

      https://m.facebook.com/profile.php?id=173227206098200&_mn_=11

      Track-TBI (where the University of California is messing with people’s brains):

      https://tracktbi.ucsf.edu/transforming-research-and-clinical-knowledge-tbi

      Randall Merchant (a neurosurgeon with connections to Virginia Commonwealth University and Switzerland):

      https://anatomy.vcu.edu/directory/faculty/randall-e-merchant-phd.html

      John Yue (a neurosurgery resident working, in part, on predictive modeling):

      https://www.linkedin.com/in/john-k-yue-md-448aa17b

      Nsini Umoh (a neuroscientist who studied at Yale and the U.S. Army Institute of Surgical Research before she worked for the U.S Department of Defense (DoD) Medical Research and Development Command (MRDC)):

      https://www.ninds.nih.gov/about-ninds/who-we-are/staff-directory/nsini-umoh

      Geoffrey Manley (chief of neurosurgery at the Zuckerberg Hospital and the contact principal investigator of TRACK-TBI):

      https://profiles.ucsf.edu/geoffrey.manley

      All research facilities are suspicious, and I knew about Stanford and CIT, not to mention Pepperdine, but UCSF seems also to be a significant programming hub.

      Otherwise, you’ve probably read them, but, for others, I have posted some of my articles on California below:

      https://fightingmonarch.com/2020/07/17/mapping-mk-ultra-in-l-a/

      https://fightingmonarch.com/2019/08/04/california-targeted-by-the-new-world-order/

      https://fightingmonarch.com/2021/08/13/firenado/

      https://fightingmonarch.com/2021/12/13/stop-the-train/

      Meanwhile, my own experiences at Pomona College, which Lady Rothschild, Roy Disney, and Kris Kristofferson attended, while it takes its name from the Goddess of the Harvest, are described in my second book, available, for free, while you, my friend, have one of the few hardback copies.

      https://fightingmonarch.com/2021/03/24/hokahey-press-releases-for-new-books-at-fighting-monarch/

      Can you believe my local library just threw out the copies I gifted to them, while they could have just called me up to return them?

      I got my first big-person library card there back in 1979, but now I’m going to sue them in small claims court!

      The town where that library lies is full of satanic markers, and the library used to be named for a local diplomat, travel writer, and spy, while the largest battle of the Revolutionary War was fought here on September 11, 1777, after troops gathered at the Sign of the Unicorn, and a time capsule was buried under a capstone on September 11, 1998, next to the Genesis Building, on whose other side, in the pavement, you can find the Star of Ishtar.

      https://fightingmonarch.com/2019/11/21/kennett-square-cia-central/

      Lots of gang signs, and they don’t belong to the Bloods or the Crips!

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    1. Yep. I grew up brainwashed to respect and enjoy libraries, but when you look at their use and ownership through the ages by the Roman Catholic Church, Andrew Carnegie, and schools used for brainwashing, perhaps they’re not all that….

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