UNITED STATES DISTRICT COURT

for the
EASTERN DISTRICT OF MICHIGAN

)
Tracy Bower Christiansen )
P.O. BOX 81241 )
Rochester Hills, MI 48308 )
Pro Se )
) Civil Action No.____________
Plaintiff )
v. )
)
Attorney General, Eric Holder, )
in his individual and official capacities, )
US Dept. of Justice )
th
10 and Pennsylvania Ave N.W. )
Washington, D.C. 20530 )
)
US Department of Justice )
211 W. Fort Street )
Detroit, MI 48226 )
)
Director Robert S. Mueller, III )
Federal Bureau of Investigation )
in his individual and official capacities, )
J. Edgar Hoover Building )
935 Pennsylvania Ave, N.W. )
Washington, D.C. 20535 )
)
Director Mark Sullivan )
Secret Service )
in his individual and official capacities, )
245 Murray Drive )
Building 410 )
Washington, D.C. 20225 )
)
)
Homeland Security )
Secretary Janet Napolitano )
in her individual and official capacities, )
Office of the General Counsel )
US Dept of Homeland Security )
Washington, D.C. 20258 )
)
 An unknown number of unknown agents )
of the Federal Bureau of Investigation, )
addresses unknown; and )
)
An unknown number of unknown agents )
of the United States Secret Service, )
addresses unknown; and )
)
An unknown number of unknown agents )
of the United States Department of )
Homeland Security; addresses unknown. )
)
An unknown number of agents of the )
Department of Justice, addresses )
unknown. )
)
Defendants )

COMPLAINT

INTRODUCTION

1. This Complaint describes how the Attorney General of the United

States, and the directors of the FBI, Secret Service, and the Secretary of

Homeland Security, individually, and through the use of their subordinates

intentionally violated the Constitutional Rights of one US Citizen, the Plaintiff,

Tracy Bower Christiansen. The miscarriage of justice carried out by the

defendants was In retaliation for Mr. Christiansen’s exercise of his First

Amendment right to free speech and his constitutionally protected right to

petition Congress for redress of grievances. For the exercise of this right Mr.

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 Christiansen would have his relationship with his wife and his teenage daughter

destroyed, and his ten year marriage dissolved at the direction of unknown

agents who had decided that his wife was “too nice to him” and who also advised

his wife that she was in danger of losing her Congressionally funded job.

BACKGROUND

2. During the Christmas holiday on or about December 24, 2008, Mr. Christiansen

spent time at his foster brothers home in Chicago. On the trip with Mr.

Christiansen was his step daughter. The pair traveled to Chicago by car from

their home in Wyoming, Ohio. During this visit, two odd things occurred. First

Mr. Christiansen’s foster brother offered him a tablet which he was told was

morphine, and was advised that “you should take it”. Mr. Christiansen declined

thinking that his brother was nuts. Mr. Christiansen and his foster brother then

went out to a bar that they had never visited together before.. During the visit Mr.

Christiansen’s foster brother then introduced him to an unknown white male of

approximately 30 years of age who Plaintiff now alleges and believes to be an

undercover agent for the Department of Homeland Security (DHS) or an

agent for the Justice Department (DOJ). Mr. Christiansen’s foster brother then

began making ludicrous claims about the morality of Mr. Christiansen. Mr.

Christiansen who has been an attorney for 8 years and had been a highly

decorated police officer and detective for 15 years was shocked and dismayed

but thought that the conversation was the result of Plaintiffs foster brother’s

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 known addiction to schedule 1 narcotics, namely cocaine. Further, Plaintiff

now alleges, believes and is informed that this foster brother is the source for

the heinous sick conduct on the part of unknown federal agents which the

Plaintiff, his former wife and daughter have had to endure for over one year and

which continues to this very day. Plaintiff assumes that this family member was

“set up” so as to provide false information against the Plaintiff which was then

used to cause as much personal grief as possible to the Plaintiff. In this

endeavor the unknown defendants were highly successful.

3. This drug fueled fantasy of Plaintiff’s foster brother who Plaintiff now has reason

to believe was arrested for either narcotic possession or illicit possession of

automatic weapons has gone on long enough. These agents acting on what is

readily evident to be nothing but lies have allowed Plaintiff, his former wife and

his very young teenage daughter to be subjected to the most evil, vile, and sick

treatment, and as to be detailed should shake the very core of the criminal

justice system. Plaintiff further alleges and has firm reason to believe that the

agent behind this fiasco is himself a literal psychopath with no regard for the law

or the truth and who quite possibly by his own actions and statements made by

others on his behalf has committed murder. This agent has not only stalked and

harassed the Plaintiff up until and including today but has also directed scores of

either DOJ or DHS personnel to do the same on his behalf. This agent and the

persons acting at his direction and under his guidance simply have no regard for

the truth or are simply not able to comprehend the possibility that someone

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 exists in their midst who is not like them. Namely honest, sane, and not

psychotic.

4. The Plaintiff as will be detailed has strong reason to suspect that the

unidentified agent(s) will make every effort to subvert justice through

attempts to improperly blackmail or influence these very courts. Plaintiff

has seen with his own eyes how when he tried to deliver a complaint to

the United States Attorney he was directed by defendants to a basement file

storage room.

5. Finally as an aside, Plaintiff alleges and has strong reason to believe that the

federal agent in charge of or directing this fantasy is the same person that

Plaintiff filed a congressional complaint on in 1993 for interfering with his official

police duties. One thing is certain and that is in 1993 the Plaintiff either arrested

and jailed the defendant or he somehow subverted an investigation the

defendant was working on. At that time Plaintiff was a police officer for the City

of Houston, Texas. When Plaintiff complained on the defendant thinking that he

was internal affairs, defendant went to great lengths to brand the Plaintiff

as crazy rather than admit his own misconduct. In fact defendant went on the

same insane spree that he is on and has been on, namely trying to make the

Plaintiff out as a thief or a person who has committed heinous crimes that exist

only in this agents mind. Plaintiff then as in now reported the conduct of these

agents to the United States Congress. As the court will read and come to

understand, it is one thing to suffer this indignity once in a lifetime, but twice, and

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 when the defendant is allowed to retaliate once again, except this time to

direct his anger towards Plaintiff’s daughter is just beyond the scope of

all human comprehension

6. The fact that in all probability these crimes were committed on behalf and with

the full knowledge of the Federal Bureau of Investigation or the Secret Service is

incomprehensible. This is retaliation upon retaliation for the sole reason that the

Plaintiff had the nerve to exercise his first amendment right to speak and to

redress Congress for legitimate grievances. Plaintiff then as in now is and has
th
been subjected to a roaming house arrest in violation of Plaintiff’s 5 amendment

right to not be deprived of life, liberty, or property Plaintiff has not been free to

go shopping or anywhere in public for over a year without unprofessional agents

being within several feet of him constantly. Plaintiff notes that when he was a

police officer riding with a training officer, the training officer pulled up outside

someone’s home and stated “this person filed a complaint on a fellow officer, this

is how we pay him back”. Plaintiff astonishingly sees federal agents act in this

capacity every single day up to and including 30 minutes before Plaintiff began

typing this complaint. Plaintiff has no privacy, all of his phone calls are

monitored or redirected and he has absolutely no secure communications

whatsoever. Plaintiff is unable to secure meaningful employment because either

the agents phone ahead or actually just follow him to the job site.

7. Plaintiff seeks a declaration that defendants have violated his

constitutional Rights and the very laws that they are sworn to defend.

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 Further Plaintiff would respectfully appeal to this court for an immediate

injunction to prevent these agents from interfering in Plaintiffs basic right to be

free from the brutal oppression that he and his family has suffered and continues

to suffer from. Plaintiff asks that the defendants be enjoined from their basic and

continuing abuse of Plaintiffs first and fifth amendment rights under the United

States Constitution.

Further Plaintiff asks that the court declare these agents as the criminal

elements of a criminal organization that they are.

In addition Plaintiff seeks monetary damages against the individual agents of the

DOJ and DHS, who most probably are agents of the FBI and Secret Service

acting under color of legal authority or law in their individual capacities for the

egregious violations of Plaintiff’s Constitutional Rights.

JURISDICATION AND VENUE

8. This case arises under the United States Constitution and the Laws of the

United States and presents a federal question within this courts jurisdiction

under Article III of the Constitution and 28 §§ 1331 and 1343(a)(3).

Plaintiff seeks monetary damages against federal employees acting under color

of legal authority, in their individual capacities under Bivens v. Six Unknown

Agents of Fed. Bureau of Narcotics, 403 U.S. 388, 91 S. CT. 1999, 28 L.ED. 2d

619 (1971). The court has authority to grant declaratory relief pursuant to the

Declaratory Judgment Act, 28 U.S.C. § 2201 et Seq. The court has authority to

grant injunctive relief under the federal courts inherent equitable powers.

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9. Venue is proper in the district under 28 U.S.C. § 1391 (c), Mr. Christiansen

resides in Oakland County, Rochester, Michigan in the Eastern District of

Michigan. A substantial portion of defendants ongoing and continuing conduct

giving rise to Mr. Christiansen’s claims have occurred and continue to occur in

Oakland County, the Eastern District of Michigan.

PARTIES

10. Plaintiff, Tracy Bower Christiansen is a citizen of the United States

and a resident of the Eastern District of Michigan. Mr. Christiansen was a

military police officer and detective for the United States Army. Mr. Christiansen

graduated tied for first in his Military Police Investigation (MPI) school. Plaintiff

was trained in and took part in surveillance and counter surveillance. Plaintiff

was also a member of the 82nd Airborne and cross trained as a medical

specialist. Plaintiff received 3 medals and over 20 commendations for his work

as a police officer and detective.

After the military, Plaintiff was a police officer for 5 years for the City of Houston,

Texas where he received several supervisor commendations.

After Houston, Plaintiff continued his education and graduated with a bachelor

degree in Computer Systems, he then attended Thomas Cooley Law School in

Lansing, Michigan. Plaintiff took and passed the Illinois and Michigan Bar Exams

in 2002 and 2003 respectively. Plaintiff married while in law school and

disregarded his career for that of his engineer wife and his new step-daughter to

whom he devoted a significant portion of the last 10 years. Plaintiff’s daughter

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 was and always has been an advanced place straight A student. In 2009 after

federal agents forced his wife to divorce him under threats of losing her high

paying Congressionally funded job, Plaintiff returned to Rochester, Michigan in

December of 2009 to attempt to get on with his life. However a large majority of

the psychopathic agents moved with the Plaintiff and the daily contact with

roaming out of control federal agents has left the Plaintiff virtually unemployable.

11. Defendant Attorney General Eric Holder heads the United States Department of

Justice, which is the agency of the United States responsible for enforcement of

Federal Criminal Laws. Mr. Holder has ultimate authority for supervising all of

the operations and functions of the Department of Justice. The DOJ includes

the FBI who is the principle investigatory arm of the DOJ. Mr. Holder is the

highest ranking law enforcement officer in the United States.

12. It is Mr. Holder’s responsibility not only to enforce the laws but also to follow

them. Mr. Holder is sued in his individual capacity for money damages and in his

individual and official capacity for declaratory and injunctive relief.

13. The true names and capacities of the individual defendants sued as

unknown employees of the DOJ and unknown agents of the FBI are

unknown to the Plaintiff (herein referred to as unknown federal agents). The

identities of the DOJ and unknown agents of the FBI will be determined after a

reasonable opportunity for discovery. At all times relevant to this complaint said

defendants were acting under color of legal authority and in their official

capacities as employees of the DOJ or agents of the FBI. These agents are

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 sued in their individual and official capacities.

14. Defendant Janet Napolitano is the Secretary of Homeland Security which is

tasked with securing this Country from unknown threats whether terrorist related

or natural. The Secret Service is one department under the Homeland Security

umbrella. The true names and capacities of the individual defendants sued as

unknown agents of the Department of Homeland Security are unknown to the

Plaintiff. (these agents are also herein referred to as unknown federal agents).

The identities of the unknown employees of the Department of Homeland

Security and the Secret Service will be determined after a reasonable

opportunity for discovery. At all times relevant to this complaint said defendants

were acting under color of legal authority and in their official capacities as

employees of the Department of Homeland Security and the Secret Service.

These agents are sued in their individual and official capacities.

FACTS

15. During the Christmas holiday on or about December 24, 2008, Mr. Christiansen

spent time at his foster brothers home in Chicago. On the trip with Mr.

Christiansen was his step daughter. The pair traveled to Chicago by car from

their home in Wyoming, Ohio. During this visit, two odd things occurred. First

Mr. Christiansen’s foster brother offered him a tablet which he was told was

morphine and was advised that “you should take it”. Mr. Christiansen declined

thinking that his brother was nuts. Mr. Christiansen and his foster brother then

went out to a bar that they had never visited together before. During the visit Mr.

10
 Christiansen’s foster brother then introduced him to an unknown white male of

approximately 30 years of age who Plaintiff now alleges and believes to be an

undercover agent for the Department of Homeland Security (DHS) or an

agent for the Justice Department (DOJ). Mr. Christiansen’s foster brother then

began making ludicrous claims about the morality of Mr. Christiansen. Mr.

Christiansen who has been an attorney for 8 years and had been a highly

decorated police officer and detective for 15 years was shocked and dismayed

but thought that the conversation was the result of Plaintiffs foster brother’s

known addiction to schedule 1 narcotics, namely cocaine. Further, Plaintiff

now alleges, believes and is informed that this foster brother is the source for the

heinous sick conduct on the part of unknown federal agents which the Plaintiff,

his former wife and daughter have had to endure for over one year and which

continues to this very day.

16. On approximately December 27, 2008, on the return home from Chicago,

Plaintiff while driving on an interstate through Indiana was suddenly pulled over

by an Indiana State Trooper. Plaintiff was informed that he had been following

too closely and was asked to step out of his vehicle and into the troopers car.

<Plaintiff had in fact moved to the left lane to give the trooper room who was on

a traffic stop. The trooper suddenly and abruptly left his stop to pull over

Plaintiff>. Plaintiff in the troopers car explained his actions and the trooper

suddenly stated “don’t you ever do anything wrong?” When the Plaintiff

explained that he had received a ticket for littering when he was 18 the trooper

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 bust out laughing. The theme “doesn’t the Plaintiff do anything wrong” has lasted

for well over 1 year and four months and counting. Another theme is “why can’t

we set you up for a crime like all our other victims?”

These themes and the illegal attempts to prosecute them no matter what laws

are violated still directly affect the Plaintiff every single day of his life not to

mention the serious harm and psychological damage done to the Plaintiffs

former wife and young daughter.

The trooper released the Plaintiff with a written computer generated warning. Not

realizing that Plaintiff had come under the watch of an out of control federal

agent, he discarded same. Plaintiff makes note of a police vehicle for

harassment as it will continue for months, increase, decrease and then happen

off and on up until including this very day while driving through the City of Troy,

Michigan.

17. Let the show begin.

In approximately Feb 2009 Plaintiff went to a Waffle House on Sharon Road in

Cincinnati, Ohio. Plaintiff off and on had stopped there for breakfast. Plaintiff sat

down to order his meal and 3 waitresses (who by the way were unusually

relatively attractive) began gabbing loudly. One of them had the same name as

Plaintiff’s cat “meowf”. She was pregnant and she also claimed to have a voice

disorder similar to one Plaintiff had at the time where the waitress sometimes

could not speak above a whisper. This conversation went on and on with the

one waitress demonstrating how she could not talk properly. Plaintiff quickly

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 realized having had been a detective that someone had gone into his medical

records with his speech therapist whom the Plaintiff had stopped seeing the

previous December in 2008. It also appears clear now looking back that either

of these white females of about 22 years of age were undercover agents of the

DOJ or DHS and that they were trying to entice Plaintiff into either talking to

them or trying more likely to entice the Plaintiff to return to his speech therapist

where he had freely spoken about just about anything and the Plaintiff looking

back now notes that this therapist spent 40 minutes writing down every single

word he said and 5 minutes trying to help Plaintiff’s voice. Plaintiff also notes

that he had more or less playfully told the therapist that he was afraid of police

officers, something that will become more important as this complaint proceeds.

Regardless, Plaintiff played deaf, dumb and stupid, ate his meal and never

returned to that restaurant. Plaintiff makes note that these agents acting in their

undercover capacity think nothing of going behind a counter and handling your

food. This includes places like Burger King, etc. Plaintiff has also seen these

agents go behind the counters of pharmacies, Kroger and CVS for example.

Plaintiff cannot stress how dangerous and irresponsible this type of conduct is.

18. Closely related to the Waffle House incident was when Plaintiff was on I-75

traveling southbound almost directly passing by the same restaurant. Plaintiff a

the time was in the curb lane following a large enclosed truck when suddenly

and abruptly a new small mattress (twin possibly) suddenly appeared perfectly

placed in the roadway while Plaintiff was traveling approximately 60 mph.

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 Plaintiff successfully passed over the mattress safely. However he is sure

someone else had to hit it. Plaintiff has noted in the past in Houston and will

detail further later on that this is a common tactic of these agents, especially if

they cannot arrest you for something. They will make every effort to harm you,

your job, your family, or your children. Plaintiff is a model example of what

happens when these agents become frustrated with their ability to “set you up”

for a crime. This court can well wonder how these agents feel now, 1 year and

four months later as Plaintiff types this letter in front of them in the public library

where one aisle over they have someone continually banging on a shelf for the

past 2 hours.

19. Early March, 2009 Plaintiff was building a large garden wall which required

numerous bricks and mulch. During these frequent trips, Plaintiff noticed

frequent occurrences, meaning every single time. This generally involved

unknown agents of the DOJ or DHS planting themselves directly wherever

Plaintiff was headed and then acting in the most obnoxious manner possible. In

addition to being as totally obnoxious as possible, these agents would block,

meander, loiter, and when they failed to raise any response out of the Plaintiff

because he is still a professional human being after all these years, then these

agents out of total frustration and utter disregard for anything normal and decent

in society would start having their children come up to and either try and start a

conversation or simply just have them grab Plaintiff’s crotch. This was not

simply a mistake or an accident, again this is normal everyday conduct for these

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 agents which literally gives new meaning to the phrase “take your children to

work”; this activity continues up to and until this present day. Plaintiff is simply

unable to engage in any manner of Interstate Commerce without these out of

control agents, stalking, harassing, or simply attempting to intimidate him with

their limited grasp of the proper functions within human society.

20. At around the same time that all of this was going on, Plaintiff ran an errand for

his daughter at a nearby CVS or Walgreen. Plaintiff observed as he stood in

line to check out that a black female agent of about 28 years of age stood in

front of him holding a greeting card. She opened the card and a police siren

went off. Plaintiff laughed not realizing he was insulting a federal agent. This

agent then pretending to talk on her phone stating “he better stop laughing and

save up for bail”. Plaintiff at about this time seriously began to think he was in a

bad Twilight Zone episode and began to fear for his and his family’s safety. This

too the Plaintiff notes is a common them for these agents. They will get as close

as possible to you and then assume what Plaintiff describes as the indirect

moron approach. A strong feature of this is that every single time Plaintiff’s

teenage daughter texted him to run an errand, that these agents would already

be set up on location waiting. Plaintiff notes that for a month or two Plaintiff was

not sure and still is not sure if the texts were simply intercepted or if his daughter

provided them freely which Plaintiff strongly doubts. As stated this activity which

still continues to this day simply makes completing a commercial transaction as

arduous as can be imagined. The sad simple truth is that these agents think that

15
 they are somehow funny when the actual concept of what is true humor truly

escapes them. Just brief examples of their conduct should inform the court and

the general public just how sick and out of control these people truly are.

Plaintiff has no doubt that a large portion of these agents are simply mentally ill.

It is almost as if Plaintiff is actually talking about “little green people” from

another planet.

21. During March 2009 and continuing to this very day, Plaintiff an experienced

detective trained in the art of surveillance and counter surveillance noticed a

surge in vanity plates surrounding him at all times. As noted previously how

some police officers like to harass civilians, rest assured that apparently a great

benefit of the creation of the Department of Homeland Security is the ability of

their agents to commandeer police, ambulance and fire vehicles to harass the

common man. But most definitely is their ability to have state run facilities run

off custom license plates for them, Such as “take 5th”, DNA, etc. The day

Plaintiff’s wife came home and told him she was divorcing him after ten years,

Plaintiff went outside for a drive. Immediately a vehicle pulled in front of him with

a license plate that read “she’s weak”.

22. Plaintiff prefers to call the agents who are meandering, loitering, and just

obnoxious human beings….zombies. Plaintiff after realizing he had come under

heavy duty scrutiny and observed that everywhere he went suddenly looked like

a war zone. Cars broken down everywhere, people walking down off ramps

towards Plaintiff and generally people just walking in the middle of the street

16
 directly towards Plaintiffs car. This continues to this very day.

23. In May 2009 Plaintiff went to a Sears Store at Tri-County Mall in Cincinnati.

When Plaintiff walked in he was the only person in the store minus the cashier.

Plaintiff had taken a round about way to the mall and no one knew where he was

going so there was a natural delay in the presence of zombies. Plaintiff

estimates that within 5-10 minutes however they had caught up with him. At this

time Plaintiff was about 40 feet from the cashier, when a black male of about 30

years of age approached the cashier and began to talk as loud as possible so

Plaintiff could unmistakably hear him. This male then went on to state “since the

father isn’t cooperating, we are going to have to arrest his teenage daughter”.

Typical conduct.

24. Again in May 2009 Plaintiff went to an Office Max to buy some micro cassettes to

give the impression that he was recording conversations to discourage illegal

activity on the part of the agents. Plaintiff while checking out, had the cashier

bend completely over his hand and then either truly sneeze or spit snot all over

Plaintiffs hand. Typical conduct. One asset Plaintiff learned in Houston when

under this same surveillance by the same psychopath was to watch for agents

rushing in to go behind counters either ahead of him or as in the Sears store,

after him.

25. Again in about May 2009, Plaintiff noticed that everywhere he went

there was a police car. Again Plaintiff notes the innocuous comments made to

his speech therapist some 5 months earlier. Things at this time started to turn

17
 even more remarkably disturbing then they already were. First Plaintiff’s

daughter asked him to take her to the mall to shop at Forever21. Plaintiff being

a good father agreed but went to a different mall to avoid the aforementioned

zombies at the Sears store. Arrival at said mall was a great success with a lack

of zombies or agents present.

Secondly: Five minutes later Plaintiffs daughter appeared ashen faced and

stated that she wanted to go to the zombie mall. Plaintiff agreed. On the way

there, near an exit ramp there was a police car facing the wrong way towards

Plaintiff’s vehicle. Plaintiff’s daughter stated “I wonder why he is there?”

Thirdly: Arrival at the zombie mall. Plaintiff took his position just outside the store

on a bench and waited for the show to begin. Within several minutes, females of

various ages began to bend over directly in front of Plaintiff. Within minutes of

that several giggling girls came and stood directly by Plaintiff. Minutes later a

uniformed police officer and a security guard rushed into the store and

then….came and stood directly by Plaintiff and started talking about how they

were “looking for a suspicious male”. Then Plaintiff’s daughter asked him to

come into the store and complete her purchase. At this point several small

children began grabbing at Plaintiff’s crotch, obviously trained in the art by some

concerned parents.

26. Plaintiff and his family lived in Wyoming, Ohio, a tiny town about 2 square miles

in either direction with a total of maybe 3 police cars. Plaintiff had lived there

since June 2005. His duties mainly consisted of driving his daughter to and from

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 school, shopping and running errands. In around May 2009 Plaintiff observed

that everytime he dropped off or picked up his daughter in Wyoming that a

police car was lurking nearby. These police cars Plaintiff believes were there at

the direction of unknown federal agents with the sole purpose to harass and

intimidate Plaintiff into compliance and agreement to commit whatever crimes

these agents had dreamed up to justify their existence on this great earth. There

can be no other explanation.

27. Late May 2009, Plaintiff went to mail a letter. Wanting to avoid the land of the

dead, Plaintiff drove a round about way. To get to this particular post office,

Plaintiff had to exit a freeway. After driving the approximate 3 blocks to mail his

letter, Plaintiff went to get back on the freeway. At the deserted entrance ramp to

the freeway, Plaintiff noted as if expected that someone had neatly placed large

pieces of iron across the entire ramp. Typical behavior.

28. During the same month, Plaintiff went to his mailbox and received a notice from

his insurance company that his claim to his speech therapist had been paid,

which was a total lie as none of the persons services were ever covered at any

time. Further at this time Plaintiff’s daughter remarked to him that “all her friends

think that Plaintiff needed a speech therapist.” And also at about this same time

after it was common knowledge that Plaintiff knew his daughter was being used

by these defendants, Plaintiff went to a Chinese restaurant to pick up some

takeout. A black female, possibly the same agent from the CVS or Walgreen’s

above stood directly in front of Plaintiff and stated loudly into her cell phone “I

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 don’t care if I ruined his relationship with his daughter, he never really had one

to begin with”.

29. During the first week of June 2009 with growing concern for his daughter and the

obvious fact that his wife was being terrorized by these same agents as often

she came home with tears in her eyes, Plaintiff had had enough. Plaintiff knew

that the tactics of these out of control agents is to swear persons to secrecy.

Plaintiff however directly asked his wife one question “should he file a

complaint?” Plaintiff’s wife answered “yes they are insane”. Plaintiff typed up a 4

page letter and made about 8 copies. He targeted the Wyoming Police

Department, and several local police departments as well as the Indiana State

Police Officer and the Ohio State Police who Plaintiff had observed participate in

this blatant harassment on at least one occasion. Plaintiff at this time did not

fathom that the true defendant would be a psychotic federal agent with an axe to

grind because in all probability Plaintiff had arrested him years ago. (Plaintiff

also notes that during this time when he had questioned his wife, that these

undercover agents had gotten wind of Plaintiff’s anger. Plaintiff knows this to be

a fact because the agents started having vehicles with license plates park

directly or nearby his home. Some of these plates read “relaxx”, and “Redd

FOXX2” making reference to Plaintiff’s ability to make people relax and be at

ease. Another plate parked directly near Plaintiff’s home read “ABIGG BOSS”,

apparently to make Plaintiff feel more comfortable with the harassment he and

his family were enduring at the hands of these psychotic agents. Again these

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 plates and these agents did nothing to ease Plaintiff’s fear and in face

exuberated them. Plaintiff also makes mention that it should seem common

knowledge that having been a police officer and detective for 15 years that a

certain amount of healthy paranoia surrounds the job and that Plaintiff was

trained to and had to deal with these feelings, however….by the intentional

conduct of these unknown agents described throughout this complaint, these

agents purposely breed fear and distrust of the very law enforcement agents that

were sworn to uphold the laws of this great nation and the United States

Constitution. Not only did these agents intentionally inflict emotional distress

upon the Plaintiff and his family, they did it every single day with that being their

sole purpose and motive as they had no other single legitimate law enforcement

purpose or recourse of any kind whatsoever, this should be blatantly

obvious to even the most casual observer.)

30. As noted Plaintiff typed up his complaint and he then took the complaint to the

State Capital in Columbus some 90 miles away. Along the way Plaintiff was

followed, harassed, and tailgated by the same assortment of agents with their

same ridiculous license plates. Just outside of Columbus there is a prison in a

desolate area. As Plaintiff approached the exit, the vehicle in front of him turned

on his turn signal and kept going straight. Plaintiff arrived at the State Capital.

He took one copy to the federal building where he was informed by federal

police officer that “I don’t know where the FBI is”. Plaintiff then proceeded to the

United States District Court for the Southern District of Ohio where again typical

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 behavior occurred. Plaintiff’s goal was to deliver a copy to the United States

Attorney. Upon entrance to the vacant courthouse, a security guard directed

Plaintiff to a room that was obviously just a file room. There was a hastily

constructed note on the door that read “temporary US Attorney Office”. One

person was standing inside.

A prisoner was then paraded by the Plaintiff. Then Plaintiff gave his complaint to

this person standing inside the file room, a white male of about 45 years of age

who stated “I will give this to the US Attorney”. Plaintiff asked where the FBI was

located and this person loudly exclaimed “FBI”? But he did know the address off

the top of his head. As Plaintiff exited the file room he noted the board which
rd th
said “US ATTORNEY 3 or 4 floor”. Plaintiff then walked up the stairs. At the

doorway to the US Attorney office was a copy of the same note. However it

being lunch time, Plaintiff noted that that office had a drop box and was properly

padlocked. Plaintiff placed a copy of his complaint there while two middle aged

men lurked nearby. Plaintiff then proceed to the FBI where he was instructed by

intercom to leave his complaint at an unattended window. Plaintiff then

proceeded to the State Capital where he was refused admission to drop off his

complaint with the govenors secretary. A police officer asked that the complaint

be left with him, Plaintiff thought the request was reasonable but declined.

Plaintiff then left several copies in various offices of the State Legislature,

however Plaintiff is not sure in fact if anyone properly received his complaint.

31. Plaintiff knows for a fact that at least one complaint was improperly received

22
 because as Plaintiff left the State Capital he parked his car to check his map and

at that time, someone somewhere on a car speaker stated “oh my God Bowser”,.

using Plaintiff’s middle name “Bower”. Plaintiff returned home and that evening

his wife in bed stated “its over” and “you can sell your story to Hollywood but are

not to tell anyone what you have seen or experienced”, .Plaintiff unconvinced

having seen the depth and depravity of the persons involved in this. The

following day Plaintiff faxed a copy of his complaint to members of the judiciary

committee of the United States Congress and Senate. Plaintiff noted that for

several days after his trip that the persons conducting surveillance actually

made an attempt to stay out of his way whether by vehicle or in person.

However several days later after it became common knowledge that Plaintiff had

faxed Congress, the surveillance turned wicked again and has since and

continues to be pure harassment for the sole purpose to punish complainant for

exercising his first amendment right to free speech and to petition Congress. In

fact Plaintiff would be called crazy by his wife and his daughter would tell him

“now everybody hates you”. This harassment, this intimidation which continues

to this day in Rochester, Michigan and surrounding communities is done by

agents without any fear of repercussion whatsoever, they do it because they

think it is fun and for retaliation. Much like I believe a serial killer would kill. No

sense of right and wrong, just pure unadulterated evil.

33. At around this same time, Plaintiff’s wife had planned a trip to Europe and

Plaintiffs wife stated that he had to take his daughter to stay with a friend and

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visit Boston so his daughter could see various colleges. Plaintiff with all that had

been going on was very skeptical to take any long trip, however his wife

threatened to divorce him if he did not. Apparently before Plaintiff had

complained to Congress this trip to an obvious “safe house” was meant to clear

Plaintiff from wrong doing. Meaning Plaintiff would take his daughter there, not

steal, rob, or murder someone, and everyone would be clear. BUT Plaintiff had

complained and faxed Congress. What to do? Almost one year later, non-stop

harassment and torture is your answer. It was during this week long trip the
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approximate 2 week in June 2009 that Plaintiff realized that he was dealing

with federal agents as they continued to follow, stalk and harass him everywhere

he went. Plaintiff in 1993 when he made a complaint against this federal agent

incorrectly identified the problem as the Internal Affairs Department of the

Houston Police Department and in 2009 Plaintiff accused the Wyoming Police

Department. Plaintiff then as in now has a hard time accepting that federal

agents in all probability FBI or Secret Service Agents could be behind such an

utter fiasco. Sure Plaintiff saw a lot as a detective and police officer, but never

such wanton utter criminal corruption. These agents, these officers are

supposed to be the ones you can depend on when all else fails, when there is

nothing else. Let the Plaintiff tell you, there is no one else. During the trip to

Boston you would think these agents would attempt to disguise their exploits, but

one would be sadly mistaken. During the trip in the evening in possibly PA or

NY, again a huge large dead animal appeared directly in Plaintiff’s path. Plaintiff

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 laughed, thinking “here we go again”. Within minutes a black Escalade

appeared beside Plaintiff with the side door open. A group of white males were

inside dressed in SWAT like gear. A male then leaned outside and waved at

Plaintiff until he responded. Again typical behavior. Plaintiff asks where is the

mentality that thinks this type of behavior is normal, ok, or even funny?

34. Upon arrival in Boston when Plaintiff got off the expressway and was ready to

pay his toll, the toll attendant told Plaintiff that his fare had already been paid

and then a group several rows away began to cheer and clap. Again not funny.

35. Upon arrival at the house in Boston it was readily apparent that Plaintiff and his

daughter were in some sort of government hell. First off the male and female

whom we had never met were typically rude and obnoxious questioning

Plaintiff’s daughter about their relationship within earshot of the Plaintiff. This

after arrival and attempting to get Plaintiff and his daughter agree to sleep in the

same bed. Several days went by with these agents talking about all the drugs

they had done and in front on Plaintiffs daughter no less. Plaintiff then was

peppered with questions about his attitudes towards former President Bush,

Senator Mccain and Sarah Palin, Plaintiff had to check the date and year

because last he heard Obama won. Plaintiff then was questioned about

attitudes towards Muslims and Iran, just generally offensive stuff to someone

who spent over 8 years in the military and had a top-secret clearance. Plaintiff

greatly disappointed all present except his daughter by affirming his loyalty to

the United States of America.

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36. As noted previously Plaintiff had to deal with this exact same circumstances in

1993 when he filed a complaint against this same unknown agent.

37. Upon successful return home to Wyoming, Ohio, without “yet” having been

thrown into Guantanamo Bay for daring to write Congress, Plaintiff wrote up a

detailed 11 page letter and personally hand carried it to Capital Hill where he

hand delivered it to about 130 members of Congress and the Senate. Plaintiff

made the trip mainly because of their sick refusal to stop texting his daughter

during the entire trip, attempting to always be one step ahead of Plaintiff. Fail.

For instance Plaintiff took a side trip to visit New York City during the trip to

Boston with his daughter where Plaintiff pointed out the former site of the World

Trade Centers…..text…..daughter “too bad for them”. The entire trip, the

conduct of these agents was at par with this comment. Also but almost equally

amazing was the fact that when Plaintiff went to Capital Hill, he was greeted by

the site of a former co-worker from Houston who was used many times to harass

Plaintiff after Plaintiff had complained to Congress in 1993. Plaintiff is not sure

why the defendants thought the presence of this person sitting outside one of

the House of Representatives Office Building would impress him now when it

clearly had no effect in 1993. However Plaintiff reports that he was duly awed,

shocked, and quite impressed.

38. Plaintiff wife returned home shortly thereafter completely happy, then the next

day came home from work almost a zombie herself, telling Plaintiff that he was

insane for going to Congress and that her Congressionally funded job was being

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 threatened as a result.

39. Plaintiff is not a big fan of conspiracy theories unless they can be

completely proven. Plaintiff states these facts. Plaintiff wrote his second letter

to Congress on June 26. And personally delivered it June 27. Michael Jackson

was murdered June 25 one or two days after Plaintiff returned from Boston,

while these agents were still and continue to be in an absolute panick. Plaintiffs

foster brother who had previously attempted to drug him with morphine the

previous Christmas arrived at Plaintiff’s door step, around June 29 or so. He only

stayed a few hours though he drove in from Chicago. Foster Brother was

obviously programmed to tell Plaintiff he was “crazy”. The exact same thing

happened in 1993 with this same psychotic agent. Rather than admit wrong

doing, he attempted to make out Plaintiff as “crazy”. Foster Brother also advised

Plaintiff that if he was not careful he was going to end up on the Secret Service

watch list. Further Foster Brother stated “maybe your investigation is like

Michael Jackson’s. As this was the same person who tried to give Plaintiff

morphine and was only several days after the death of same, Plaintiff wondered.

Plaintiff would again go to a bar in KY with Foster Brother and would again meet

with an undercover agent. Hilarity ensued.

40. Apparently Plaintiff had struck a nerve with the unknown defendant agents who

thought that it was best to send a drug addicted attorney to attempt to convince

Plaintiff that he was crazy. Defendants also thought that it was in their best

interests to have the murder of another human being only a few days earlier

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 mentioned as a possible solution to their problems. Plaintiff draws no

conclusions but will state that he has volunteered to the Office of Professional

Responsibility of the Justice Department to take a polygraph on the subject. Of

course Plaintiff has heard nothing of his complaints and in fact the only time it is

acknowledged is when defendants make obviously poor decisions.

41. Shortly after this visit, Plaintiff’s wife informed him that she was divorcing him

after 10 years of marriage. When Plaintiff’s wife came home to take him to sign

the divorce papers, a couple of agents thought it would be funny to park just at

the outskirt of Plaintiff’s driveway and stare. Perhaps they were wondering

whether Plaintiff was yet upset enough to attempt to do some serious bodily

harm to sick parasites who wouldn’t be welcome on any other planet in the

Universe, green people or not. As is readily apparent this agent and the people

who support him have no earthly fears. They are not afraid of the laws of man,

and they are not afraid of God. Plaintiff fears that they are not afraid of the

courts either. Plaintiff also makes note that his wife was a product of China and

English is her second language. A Naturalized Citizen. Taken advantage of by

the sickest people money can buy.

42. Plaintiff’s brother would make one more appearance at Plaintiff’s home at

direction of defendants mainly to tell Plaintiff that his wife of ten years was a no

good rotten ‘CU*T” and should be forgotten. This because Plaintiff was obviously

and continues to be highly upset.

43. Plaintiff makes note again that he has strong reason to believe that all his

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 communications are monitored meaning cell phone and Internet. This should be

obvious. The question is whether it is being done properly and legal which is

highly doubtful. Plaintiff to this date will apply for a job, get a call, be told he’s

hired, and then be told nothing period. Over and over like a bad broken record.

Plaintiff because of his situation recently applied for food stamps and was

approved.

44. Upon relocation back to Rochester, Michigan, Plaintiff sent a letter to every

judge in Oakland County requesting to be placed on their court appointment list.

The only time Plaintiff received a phone call from any court was the day he went

in to The Thomas Cooley Law School in January 2010 to start work on this

lawsuit. At that moment at that exact same time, Plaintiff received two phone

calls at the same time for court appointments. <one same one did call back once

a month ago>

…….. These defendants are the definition of the word cowards……….

45. As alleged in paragraphs 1-46, Plaintiff states that the ongoing harassment

outlined above continues to this date minus figuring in his former wife and

daughter. This includes the use of police, fire, and ambulance vehicles if

defendants think that they think they can get away with it. Plaintiff simply cannot

shop, cannot work, cannot apply for work, and cannot do anything a normal

human being can do without the stigma and the shadow of these persons

following him for the sole purpose of retaliation.

46. Plaintiff admits his error. He plainly relied on the FBI and the Department of

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 Justice to correct an imbalance in time. Plaintiff foolishly lost a wife and daughter

and had a brother attempt to dose him with morphine on behalf of agents all

while believing that a federal agent was going to come to his rescue. Plaintiff

notes that he was under the same delusion in 1993. At that time while under the

same surveillance, Plaintiff made a cash deposit into a bank drop box of

approximately $450.00. The deposit was subsequently stolen. Plaintiff notified

the FBI who on at least this one occasion did telephone him and tell him they

were too busy to get involved.

47. Defendants actions and clear retaliation were made without good

cause, maliciously, and with the attempt to simply and finally punish the

defendant for exercising his First and Fifth Amendment Rights under the

Constitution of the United States of America.

CAUSES OF ACTION

COUNT I

(Violation of First Amendment Right to Free Speech and

to Petition the Government for Redress of Grievances)

48. Paragraphs 1 through 47 are realleged and incorporated herein.

49. The First Amendment guarantees the right to free speech and to petition the

government for redress of grievances. Government officials may not interfere

with these rights directly, punish an individual for exercise of those rights, or

engage in retaliatory conduct aimed at chilling future exercise of those rights.

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 Unknown agents of the DHS, DOJ, FBI, and Secret Service with the knowledge,

encouragement, acquiescence, and complicity of Mr. Holder, and Janet

Napolitano, sought to punish and retaliate against Mr. Christiansen for the

exercise of his First Amendment rights. Through this retaliatory behavior, they

sought to chill Mr. Christiansen’s further exercise o those rights.

All individual defendants were acting under color of legal authority and are sued

for money damages in their individual capacities pursuant to Bivens, and for

injunctive and declaratory relief in their individual and official capacities.

Count II

(Violation of 5th Amendment Due Process, Life, Liberty, and Property

50. Paragraphs 1 through 49 are realleged and incorporated herein.

51. It is clearly established Supreme Court law that the Fifth Amendment to the U.S.

Constitution encompasses the “right of the individual to contract [and] … to

engage in any of the common occupations of life. “Board of Regents of State

Colleges v. Roth, 408 U.S. 564, 572 (1972). Thus, “where a person’s good

name, reputation, honor, or integrity is at stake because of what the government

is doing to him, notice and an opportunity to be heard are essential.” Id. at 573

(internal quotation marks omitted).

52. In this case, Mr. Holder, and Janet Napolitano, and the individual defendants

knowingly, willfully, and intentionally violated and continue to violate Mr.

Christiansen’s Fifth Amendment rights to life, liberty, property without due

process of law

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53. These actions were undertaken by unknown federal agents of the FBI, DOJ, or

the DHS with the knowledge, encouragement, acquiescence and complicity of

Mr. Holder and Janet Napolitano. Individual defendants were acting under color

of legal authority and are sued for money damages in their individual capacities

pursuant to Bivens, and for injunctive and declaratory relief in their individual

and official capacities.

PRAYER FOR RELIEF

Plaintiff respectfully requests that the court:

A. Issue a declaratory judgment that defendant’s conduct as

described above have violated Plaintiff’s constitutional

rights;

B. Issue a permanent and/or an immediate injunction

prohibiting defendants from further violation of Plaintiff’s

Constitutional rights;

C. Declare defendants actions to be one of a criminal element

of a criminal organization;

D. Award equitable relief to Plaintiff, as appropriate and

reasonable for defendants interference with Plaintiff’s right

to work;

E. Award reasonable and appropriate compensatory damages

to Plaintiff, in an amount to be ascertained at trial, for

defendants’ unlawful acts described above;

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 F. Award exemplary and punitive damages to Plaintiff in an

amount to be ascertained at trial, to deter similar unlawful

acts in the future;

G. Award Plaintiff’s costs, expenses, and reasonable attorneys’

fees (if used); and

H. Award such other and further relief as this Court deems

necessary and proper.

JURY TRIAL REQUESTED

Date: April 28, 2010

________________________________________
Tracy Bower Christiansen
P.O. BOX 81241
Rochester, Michigan 48308
tbclaw@hotmail.com

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