pre Diana Napolis, In Pro Per 6877 Navajo Road, PMB 114 San Diego, CA. 92119-1503 (619) 462-5818 In Pro Per IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA DIANA NAPOLIS Plaintiff v. MICHAEL AQUINO, MICHELLE DEVEREAUX, TANI JANTSANG, CAROL HOPKINS, DR. ELIZABETH LOFTUS, LESLEY WIMBERLY, MARK SAUER, DAVID COPLEY, SAN DIEGO UNION-TRIBUNE, a business entity, SAN DIEGO STATE UNIVERSITY, and DOES 1-100, inclusive, Defendants ) ) ) ) ) ) ) ) ) ) Case No.: COMPLAINT FOR: 1. NEGLIGENCE; 2. DEFAMATION; 3. VIOLATION OF PLAINTIFF’S RIGHT TO PRIVACY; 4. FALSE LIGHT; 5. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; 6. CONSPIRACY TO VIOLATE PLAINTIFF’S RIGHT TO PRIVACY AND FIRST AMENDMENT RIGHT TO FREE SPEECH; 7. CONSPIRACY Plaintiff Diana Napolis is a citizen of the State of California and the United States of American and resident of San Diego County entitled to the protections of the Constitutions of the State of California and the United States of America. Plaintiff DIANA NAPOLIS alleges against Defendants as follows: PARTIES 1. Defendant Dr. Michael Aquino (hereinafter referred to as M. Aquino) founder of the satanic organization the Temple of Set is believed to be a resident of San Francisco, California. 2. Defendant Michelle Devereaux (hereinafter referred to as Devereaux) is believed to be a resident of San Francisco, California. 3 Defendant Tani Jantsang (hereinafter referred to as Jantsang) founder of the satanic organization the “Satanic Reds” is believed to be a resident of Florida. 4. Defendant Carol Hopkins (hereinafter referred to as Hopkins) is believed to be a resident of Cuernavaca, Mexico and San Diego, California. 5. Defendant Dr. Elizabeth Loftus (hereinafter referred to as Loftus) a False Memory Syndrome Foundation Advisory Board member and Professor of psychology at UC Irvine is believed to be a resident of Irvine, California. 6. Defendant Lesley Wimberly (hereinafter referred to as Wimberly) of Victims of Child Abuse Laws is believed to be a resident of Tuscon, Arizona. 7. Defendant Mark Sauer (hereinafter referred to as Sauer) reporter for the San Diego Union-Tribune is believed to be a resident of San Diego, California. 8. Defendant David Copley (hereinafter referred to as Copley) publisher of the San Diego Union-Tribune is believed to be a resident of San Diego, California. 9. Defendant San Diego State University (hereinafter referred to as SDSU) is believed to be a resident of San Diego, California. 10. Plaintiff Diana Napolis has a Masters degree in Transpersonal psychology and worked as a Court Intervention Social worker at Child Protective Services [CPS] in San Diego, California during the years 1990-1996. After resigning from CPS, Plaintiff was self-employed as a Visitation Supervisor for Family Court from 1996-2000. In the year 2000, Plaintiff received her Marriage and Family Therapy [MFT] license. GENERAL ALLEGATIONS 11. Plaintiff alleges that satanist Defendant Aquino, and his associates, conspired to violate Plaintiff’s Right to Privacy and First Amendment Rights to Free Speech on the internet between 1995-2000 after she proved the existence of the satanic ritual abuse of children, under the pseudonyms “Curio” and “Karen Jones,” which was contrary to their agenda. 12. Defendants and other Does proceeded to conspire with Defendant Devereaux and SDUT reporter Mark Sauer to identify Plaintiff, after which Defendant Devereaux enlisted the aid of Defendant San Diego State University Campus police, by fraudulent misrepresentation, to identify Plaintiff in June 2000. Despite Plaintiff cautioning Defendant SDSU campus police that dangerous individuals were seeking her identity, campus police proceeded to engage in reckless and outrageous conduct and subjected Plaintiff to invasion of privacy by inappropriately revealing her identity to San Diego Union-Tribune reporter Mark Sauer, after which he wrote an invasive and defamatory news article about Plaintiff titled, “A Web of Intrigue/The Search for Curio Leads Cybersleuths Down a Twisted Path” on September 24, 2000 which Defendant Copley published. 13. After Defendant Mark Sauer’s defamatory news article was published, Plaintiff was subjected to further invasion of privacy, threats from Defendant Jantsang, and defamation on the internet which, in combination with Mark Sauer’s article, resulted in the ruination of Plaintiff’s reputation and career as a Family Court Visitation Supervisor. 14. Eight months after Plaintiff’s identity was revealed, and since May 2001, Defendant Aquino and others have caused Plaintiff to be subjected to prolonged psychological and physical torture and terrorization by the usage of nonlethal technology, such as “Voice to Skull Devices,” “Voice Synthesis Devices,” “Computer/Brain Interface” technology, psychotronics, electromagnetic, and other nonlethal technology. Because of these assaults, Plaintiff has been unable to seek gainful employment since May 2001 and receives Social Security Disability benefits. 15. In October 2002, due to threats made by Plaintiff’s perpetrators that they would kill Plaintiff by nonlethal technology, it caused Plaintiff to write a pseudo-threat to a Hollywood figure to ensure that she would be placed in the custody of law enforcement, in efforts to save her life. Due to Plaintiff’s eventual plea to “stalking” and subsequent notoriety, it resulted in further ruination of Plaintiff’s reputation and career, and revocation of her MFT license. These malicious actions by Defendant Aquino, and others, caused Plaintiff to be misdiagnosed as “mentally ill” after which she was forced by the criminal justice system to take psychotropic medication. After May of 2007, Plaintiff experienced enough psychological recovery to allow her to file a complaint against Defendants. 16. The terminology which defines Nonlethal weaponry can be found on the Center for Army Lessons Learned website http://ca..army.mil. Their Mission Statement reads, in part, that the Center for Army Lessons Learned is the home of the Combined Arms Center which provides leadership and supervision for leader development and professional military and civilian education. Nonlethal Weapons are defined on this web page as: “Weapon systems that are explicitly designed and primarily employed so as to incapacitate personnel or material, while minimizing fatalities, permanent injury to personnel, and undesired damage to property and the environment.” 17. Because this technology may or may not leave any obvious external wounds, it can be used to secretly torture. In a report titled, “Future Sub-lethal, Incapacitating and Paralyzing Technologies – Their Coming Role in the Mass Production of Torture, Cruel, Inhuman and Degrading Treatment,” by Dr. Steve Wright of the Omega Foundation, presented to the Expert Seminar On Security Equipment and the Prevention of torture, Dr. Wright wrote: ”There has been much speculation but a dearth of hard data about such psychotronic weapons which are already worrying those concerned about bioethics. Such electronic neuron-influence weapons would be in breach of the recent EU resolution regarding technologies which interact directly with the human nervous system. Voice to Skull technology has already been discussed in the literature … Without adequate international controls we may end up with weapons of mass punishment and gross human rights violations … to a capacity where one person or group can torture or deliberately debilitate and punish 1 – to many.” 18. In a July 7, 1997 U.S. News and World Report article titled, “Wonder Weapons The Pentagon’s Quest for Nonlethal Arms is Amazing. But is it Smart?” by Douglas Pasternak it states: “Weapons already exist that use laser, which can temporarily or permanently blind enemy soldiers, so-called acoustic or sonic weapons … that can vibrate the insides of humans to stun them, nauseate them or even liquefy their bowels, and reduce them to quivering diarrheic messes.” 19. Many concerns have been raised about the usage of nonlethals nationally and internationally. In a report titled, “US Electromagnetic Weapons and Human Rights – A Study of the History of US Intelligence Community Rights Violations and Continuing Research in Electromagnetic Weapons,” by Peter Phillips, Dec. 2006, the introduction reads: “This research explores the current capabilities of the US military to use electromagnetic [EMF] devices to harass, intimidate, and kill individuals and the continuing possibilities of violations of human rights by the testing and deployment of these weapons.” 20. Plaintiff believes the length of this complaint is necessary and is directly related to the serious and manifest crimes it seeks to expose. BACKGROUND 21. Beginning in 1990, Plaintiff was witness to a documented cover-up of the satanic ritual abuse of children while employed as a Court Intervention Social Worker for Child Protection Services [CPS] which was due to the efforts of a woman by the name of Defendant Carol Hopkins - a 1991-92 San Diego Grand Jury Foreman - a 1993-94 San Diego Grand Jury, the False Memory Syndrome Foundation, and two newspaper reporters, Jim Okerblom and Mark Sauer of the San Diego Union-Tribune. Plaintiff had researched and investigated the validity of ritual abuse and had handled several case assignments with negative occult themes within this agency. 22. The general term “ritual abuse” is usually used to describe negative occult abuse, including satanic ritual abuse [SRA], because it is inclusive of all negative occult belief systems which are both evil and criminal in nature. Some people believe the occult automatically refers to Satanism, but it does not. Instead the word “occult” refers to a wide spectrum of beliefs. Historically, some people have misused occult principles for their own benefit. What differentiates the positive from the negative is that the positive occult has the goal of self-empowerment in order to become a contributing member of society. The negative occult is dedicated to the gathering of power over others so one can abuse them. Consequently negative occult practices are condemned by all occultists world-wide because they are evil. 23. Plaintiff’s Masters degree in Transpersonal Psychology and her personal disciplines encompassed positive spiritual ideologies and meditation practices from around the world, including Buddhism, Taoism, Hinduism, Esoteric Christianity, Native American teachings, and the positive occult. Transpersonal Psychology teaches how to incorporate positive spiritual beliefs and values and includes interventions which mainstream psychology has to offer in order to access higher states of consciousness. Therefore, Plaintiff considered herself to be well qualified to investigate and differentiate between harmless occult/pagan practices and those of the truly negative occult or Satanism. 24. In 1988-89 two hearings were held by the California State Advisory Board to Social Services in San Francisco and San Diego during which time 43 individuals, including law enforcement, therapists, researchers, and victims in the State of California testified to the reality of ritual abuse. These hearings resulted in a published report in April 1991 titled, “Ritualistic Abuse in California.” The Advisory Board concluded in this report that ritual abuse should be taken seriously and made recommendations to the California State Legislature, CPS, Community Care licensing, Law enforcement and all treating professionals, such as LCSW’s and MFT’s, that training about ritual abuse be offered throughout the State. 25. In the California State Advisory report, Dr. Catherine Gould, an expert in the field, provided the following definition of ritual abuse: “Ritual abuse is a brutal form of abuse of children, adolescents, and adults, consisting of physical, sexual, and psychological abuse, involving the use of rituals. Ritual does not necessarily mean satanic. However, most survivors state that they were ritually abused as part of satanic worship for the purpose of indoctrinating them into satanic beliefs and practices. Ritual abuse rarely consists of a single episode. It usually involves repeated abuse over an extended period of time. The physical abuse is severe, sometimes including torture and killing. The sexual abuse is usually painful, sadistic, and humiliating, intended as a means of gaining dominance over the victim. The psychological abuse is devastating and involves the use of ritual/indoctrination, which includes mind control techniques and mind altering drugs, and ritual/intimidation which conveys to the victim a profound terror of the cult members and of the evil spirits they believe a cult members can command. Both during and after the abuse, most victims are in a state of terror, mind control, and dissociation in which disclosure is exceedingly difficult.” 26. The only addition Plaintiff would make to this definition is that Ritual Abuse is also intended to spiritually destroy a child. 27. The outcome of the California State Advisory Board hearings was favorably reported by the San Diego Union-Tribune in their article titled, “Ritual Child Abuse: Horrible, But True,” on April 17, 1989, authored by John Gilmore. The abstract and first paragraph read: “Patricia Holladay, a Rancho Bernardo (San Diego) clinical psychologist, has treated six children aged 2 to 13 who were victims of ritualistic abuse in the past three years. She said two children were abused at a preschool, two were abused by a drug - using mother who became involved in Satanism, and two were subjected to abuse while visiting their father … Reports of babies and children being abused in ritualistic or satanic acts in San Diego County and elsewhere in the state, often dismissed by authorities as too heinous to be true, must be taken seriously, social workers and psychologists say.” 28. On April 2, 1991, Plaintiff wrote an internal memo to CPS Assistant Deputy Director Sherry Paul requesting permission to set up support systems for social workers who were addressing allegations of ritual abuse on their caseload. [Exhibit 1] She wrote: April 2, 1991 To: Sherry Paul From: Diana Napolis PSW, Court Intervention RITUAL ABUSE CASE CONSULTATION There have been a growing number of ritual child abuse cases in the past few years. Social services & police agencies around the country are endeavoring to isolate & identify this phenomena and disseminate helpful information as quickly as possible. There are difficulties meeting the demands for information because there are few experts in the field and so much to learn. Due to the prevalence of cult groups and their propensity to horribly abuse young children (often the younger the better), I feel that CPS needs to have support systems firmly in place ready to fill the needs of the community & individual social workers. We are faced with the responsibility of recognizing, investigating and protecting children in an area where there is so little known and often associated with denial & fear. I would like to help set up such a recognition, identification & treatment guide for court intervention workers. I am suggesting a weekly time commitment devoted to case consultation & peer support. Eventually, we could set up a library and network with others community agencies to best address this unfortunate growing problem in San Diego. 29. Plaintiff was authorized to proceed with this ritual abuse project from Assistant Deputy Director Sherry Paul in her memo dated April 10, 1991 which she sent to the top Administration of Social Services. Plaintiff’s supervisor, Joyce Wakefield, proceeded to assign Plaintiff ritual abuse cases to investigate in Court Intervention which was a specialized unit which presents evidence of child abuse to Juvenile Court. The following is an example of one of Plaintiff’s cases that she investigated during her tenure at CPS: Plaintiff filed a 300 (d) sexual molest petition on behalf of a six-year-old boy named Jimmy. The mother could not protect him due to emotional problems and the father was never located. Jimmy evidenced severe emotional disturbance so he was placed in a group home with professionals who were skilled in treating this population. Jimmy had an older sister, 19, named Maria, who had been a dependent of the court a year earlier, but her case was closed after she reached adult status. Plaintiff visited Jimmy in his group home due to reports that he was “acting out.” Plaintiff sat down in his room and spoke with him about what was on his mind. Jimmy said he was experiencing nightmares about what had happened to him in real life. He remembered his friend taking him to a cave, where he saw someone “laying on a star,” screaming. He enacted this. He then asked plaintiff to draw a “star” on a blank piece of paper. Plaintiff asked him to draw it, but he was adamant that she draw it. She drew a star, then he proceeded to draw on the paper to tell her the story about what happened to him. He drew pictures, stating, “These were the Spirits”… he drew a picture of a body placed on the star…“My friend started reading from a book” (Jimmy started chanting words in an unknown language) … “My friend would read out of a book … There’s a white book and a black book. The white book is the secret words of the Devil, the black book is the secret life of the kid.” Jimmy said he heard the laugh of the “devil,” saying ‘I will destroy you.'” Due to Plaintiff’s occult studies, she knew that a “star” is usually referred to as a five pointed star or pentagram, which is a benign pagan symbol which symbolizes the natural "elements" – earth, air, water and fire - with the point at the top signifying "spirit" over matter, but when this symbol is turned upside down, it has an explicit satanic meaning - the two points signifying "horns"- also known as the Baphomet - symbolizing "matter" over spirit. Plaintiff decided to interview Jimmy’s sister who was living in a border town, and they met at a McDonalds in San Ysidro. Plaintiff asked her whether she knew if Jimmy had ever been exposed to Satanism. She said, “Yes, so have I.” She described running away from her foster placements when she too was a ward of the Juvenile Court, and meeting with other children and adults in La Jolla, in a “cabin,” near Soledad Mountain (which is a landmark with a cross on it) during which time they would read out of the Satanic Bible. She mentioned being drugged and “passing out” after one of these events, eventually to awaken with a human body part next to her. She gave graphic descriptions of this event. Plaintiff thought this information had credibility because she had received information earlier from a cult investigator by the name of Rick Post (murdered) that Anton LaVey, founder of the Church of Satan, had moved from San Francisco to La Jolla. The information gathered was given to Jimmy's therapist and Plaintiff then transferred his case to the Family Maintenance and Reunification Department as was required 30. After successfully addressing several cases with allegations of ritualistic abuse, Plaintiff wrote a series of internal memos dated May 7, 1991, Sept. 26, 1991, and October 8, 1991 about her findings. In these memos, Plaintiff suggested ways in which CPS might address ritual abuse allegations at every level of the system. She informed management that some social workers were too frightened to investigate ritual abuse and case assignments should be handled judiciously. Plaintiff also advised that because children of satanic abuse often have only one chance to disclose, if these cases weren’t assigned to an investigator trained in ritual abuse, it might lead to harm to the child and a societal “backlash.” 31. CPS San Diego ultimately acted on the State Advisory Boards recommendations. In September 1991 a Ritual Abuse Protocol titled, “Ritual Abuse, Treatment, Intervention, and Safety Guidelines,” was submitted to CPS - which Plaintiff’s supervisor asked her to contribute to - by the San Diego Ritual Abuse Task Force, Linda Walker, who was Executive Director of the Commission on Children and Youth, and Napolean Jones who was at that time Presiding Judge of the Juvenile Court and Chairperson of the Commission on Children and Youth. In the introduction to the protocol, the authors cited the 1988-89 hearings which were held by the California State Advisory Board to Social Services about the reality of ritual abuse. 32. Napolean Jones sent a survey to many professionals in San Diego which resulted in the finding that a total of one third (or 134) of those professionals who responded reported that they had treated at least one client who claimed to be a victim of satanic cult activity. This is of course a huge number. They noted that the majority of SRA victims suffer from Multiple Personality Disorder [MPD], now called Dissociative Identity Disorder [DID]. MPD/DID is created by extreme child abuse perpetrated at an early age. It is due to a creative function of the mind which survives by “splitting” one’s identity into alternate personalities so that the core personality can avoid being overwhelmed by having to experience the horrific trauma they experienced as children. MPD/DID’s usually spontaneously switch between identities in response to changes in the physical or social environment. The Ritual Abuse Protocol only touched on these themes, focusing on the reality of satanic victimization, and proved that this topic was a real phenomena in San Diego which needed to be formally addressed. 33. In 1991-92 a Grand Jury was convened with Defendant Hopkins appointed as Chairperson of the Social Services Committee. She was investigating the District Attorney Ed Miller’s Child Abuse Unit as well as CPS. A grand jury is a court appointed authority that is mandated to objectively investigate the operations of governmental programs of the County, cities and special districts. The 1991-92 Grand Jury failed to meet that requirement and instead Plaintiff believes that Defendant Hopkins used the Grand Jury as a means to promote the views of the False Memory Syndrome Foundation [FMSF] which Plaintiff believed placed children at risk of harm. 34. Specifically, in Grand Jury report No. 8, dated June 29, 1992 titled, “Child Sexual Abuse, Assault, and Molest Issues,” Hopkins quoted from and referenced the FMSF as a legitimate authority. These views included the FMSF’s positions about the alleged ability of therapists to “create abuse in the minds of children and adults” which they attributed to “inappropriate” therapy. 35. Unfortunately, over the years, the FMSF have become widely known as an organization which denies the fact that satanic ritual abuse occurs, without good cause, questions the validity of repressed memory based on misrepresentations, and provides what many people believe is a fraudulent defense for accused child molesters. pre/>