09/13/2026
CEASE AND DESIST NOTICE
Notice to Cease and Desist All Unlawful Conduct
Date: September 13, 2026
TO: Donald Trump, Todd Blanche, GOP/RNC, DOJ/DOS, Daniel James Dailey, Paul Tassone, Robert Hickey, and all known and unknown associates, agents, co-conspirators, surrogates, intermediaries, and network members acting in concert with them (collectively, the "Epstein Network")
FROM: [Editor of U.P.R. News — Whistleblower-Claimant]
RE: Demand to Cease and Desist All Unlawful Conduct Including Stalking, Cyberstalking, Retaliation, Conspiracy, Deprivation of Civil Rights, Entrapment, Wrongful Prosecution, Obstruction of Justice, Witness Tampering, Death Threats, Interference with Communications, Interference with Economic Activity, Election Interference, and Government Fraud
Notice: This document is a formal legal demand. It is not a court pleading and does not constitute legal advice. The Claimant has prepared this notice based on extensive legal research and documented findings. The Claimant reserves all rights, including the right to pursue civil and criminal remedies. This notice serves as a final warning before the initiation of formal legal proceedings.
I. PURPOSE AND BASIS OF THIS NOTICE
This Cease and Desist Notice is issued to the Network based on documented evidence of a sustained, multi-year course of unlawful conduct directed at the Claimant, a whistleblower who in 2013–2014 disclosed information regarding misconduct and who was subsequently subjected to a pattern of retaliation, harassment, and deprivation of rights by the Network spanning from 2014 through 2026 and continuing.
The Claimant has conducted extensive legal research documenting:
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The documented misconduct, credibility deficits, and legal violations of Daniel James Dailey across three law enforcement agencies (Sacramento County Sheriff's Department, 1982–2009; California Governor's Office of Emergency Services, 2015–2017; Rio Vista Police Department, 2017–2019);
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The legal frameworks violated by the Network's course of conduct, including but not limited to federal civil rights statutes, RICO, the False Claims Act, stalking and cyberstalking statutes, witness tampering statutes, obstruction of justice statutes, and election interference statutes;
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The institutional failures — including non-compliance with Brady/Giglio disclosure obligations by the Sacramento County Sheriff's Department, Cal OES, and the Sacramento County District Attorney's Office — that allowed the Network's misconduct to go unchecked.
This Notice constitutes a formal demand that the Network immediately cease and desist all unlawful conduct directed at the Claimant.
II. DEMAND TO CEASE AND DESIST
The Network is hereby ordered to IMMEDIATELY AND PERMANENTLY CEASE AND DESIST all of the following conduct:
A. Stalking and Cyberstalking
Cease all physical and electronic surveillance, tracking, monitoring, following, and harassment of the Claimant.
This conduct violates:
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18 U.S.C. § 2261A — Interstate stalking (penalty: up to 5 years, or up to life if death or dangerous weapon involved)
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California Penal Code § 646.9 — Stalking (penalty: 16 months to 3 years)
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California Penal Code § 653.2 — Cyberstalking (penalty: up to 3 years)
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47 U.S.C. § 223 — Harassing communications
B. Retaliation
Cease all retaliation against the Claimant for whistleblowing activity, including professional retaliation, social retaliation, and any use of official positions or influence to harm the Claimant.
This conduct violates:
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18 U.S.C. § 1513 — Retaliation against a witness, victim, or informant (penalty: up to 10 years, or up to 20 years with weapon)
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42 U.S.C. § 1983 — Retaliation under color of law
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California Labor Code § 1102.5 — Whistleblower retaliation
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31 U.S.C. § 3730(h) — False Claims Act anti-retaliation
C. Conspiracy and Deprivation of Rights
Cease all conspiratorial conduct designed to deprive the Claimant of constitutional rights, including any coordination among Network members to harass, intimidate, entrap, wrongfully prosecute, or otherwise harm the Claimant.
This conduct violates:
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18 U.S.C. § 241 — Conspiracy against rights (penalty: up to 10 years, or up to life if death results)
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18 U.S.C. § 242 — Deprivation of rights under color of law (penalty: 1 year to life)
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42 U.S.C. § 1985 — Conspiracy to interfere with civil rights
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42 U.S.C. § 1986 — Neglect to prevent
D. Entrapment and Wrongful Prosecution
Cease all efforts to entrap, manufacture charges against, or wrongfully prosecute the Claimant. Cease all fabrication of evidence, false statements, and manufactured probable cause.
This conduct violates:
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Fourth Amendment — Warrantless search and seizure
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Fourteenth Amendment — Deprivation of liberty without due process
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18 U.S.C. § 1001 — False statements (penalty: up to 5 years)
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18 U.S.C. § 1623 — Perjury (penalty: up to 5 years)
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California Penal Code § 141 — Evidence planting
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Napue v. Illinois, 360 U.S. 264 (1959) — Knowing use of false testimony
E. RICO Obstruction and Witness Tampering
Cease all obstruction of justice, witness tampering, interference with communications, and efforts to prevent the Claimant from reporting misconduct to authorities.
This conduct violates:
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18 U.S.C. § 1503 — Obstruction of justice (penalty: up to 10 years)
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18 U.S.C. § 1512 — Witness tampering (penalty: up to 20 years)
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18 U.S.C. § 1512(c) — Obstruction of official proceedings (penalty: up to 20 years)
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18 U.S.C. § 1512(d) — Harassing to prevent communication to law enforcement
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18 U.S.C. § 1962(c) — RICO (penalty: up to 20 years; civil treble damages under § 1964(c))
F. Death Threats
Cease all threats of death or bodily harm against the Claimant, whether direct, indirect, through intermediaries, or through implied threats.
This conduct violates:
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18 U.S.C. § 2261A — Interstate stalking with intent to kill or injure
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California Penal Code § 422 — Criminal threats (penalty: up to 4 years)
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18 U.S.C. § 1512(b) — Intimidation with intent to influence testimony
G. Interference with Communications
Cease all interference with the Claimant's electronic communications, including interception, blocking, altering, or monitoring of phone calls, text messages, emails, postal mail, and internet communications.
This conduct violates:
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18 U.S.C. § 2511 — Wiretapping and electronic surveillance (penalty: up to 5 years)
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47 U.S.C. § 605 — Unauthorized publication of communications
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California Penal Code § 631 — Wiretapping (penalty: up to 3 years)
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California Penal Code § 632 — Recording confidential communications
H. Interference with Economic Activity
Cease all efforts to interfere with the Claimant's employment, business relationships, professional licensing, contracting opportunities, or other economic activity, including through threats, intimidation, defamation, or abuse of official authority.
This conduct violates:
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18 U.S.C. § 1951 — Hobbs Act extortion (penalty: up to 20 years)
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18 U.S.C. § 1962(c) — RICO (civil treble damages)
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California tort law — Intentional interference with prospective economic advantage
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California Civil Code §§ 44–46 — Defamation
I. Election Interference
Cease all interference with the Claimant's political rights, voting rights, and political activities, and cease all use of the machinery of government to influence election outcomes or retaliate against the Claimant for political participation.
This conduct violates:
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18 U.S.C. § 595 — Interference by administrative employees of government (penalty: up to 1 year)
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18 U.S.C. § 610 — Coercion of political activity (penalty: up to 3 years)
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52 U.S.C. § 10307(e) — Voter intimidation (penalty: up to 5 years)
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California Elections Code § 18540 — Intimidation of voters
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California Elections Code § 18570 — Political retaliation
J. Government Fraud
Cease all fraudulent schemes designed to defraud federal, state, or local government agencies of taxpayer funds, including fraudulent hiring practices, false certifications, fraudulent billing, and fraudulent grant applications.
This conduct violates:
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31 U.S.C. § 3729 — False Claims Act (treble damages plus $11,803–$23,607 per claim)
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18 U.S.C. § 371 — Conspiracy to defraud the United States (penalty: up to 5 years)
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18 U.S.C. § 1343 — Wire fraud (penalty: up to 20 years)
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California Government Code § 12650 — California False Claims Act
III. NOTICE OF DAILEY'S DOCUMENTED CREDIBILITY DEFICITS
The Network is hereby notified that Daniel James Dailey's credibility as a witness, investigator, or law enforcement authority has been extensively documented as compromised based on the following findings:
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Arbitrator finding of manipulated investigation: An arbitrator found that Dailey's internal investigation of Officer Natalie Rafferty was unfair — the investigator "omitted or misconstrued evidence to support his findings." Any testimony by Dailey is subject to impeachment on this basis.
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Disputed criminal referral: Dailey claimed he referred perjury and falsification charges against two officers to the Solano County District Attorney. The DA's office stated they never received the referral. This discrepancy constitutes evidence of potential dishonesty.
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Two Giglio-Bradylist profiles: Dailey appears on the Potential Impeachment Disclosure [PID] Database under two separate agencies (Sacramento County Sheriff's Department and Cal OES). While no Brady material is formally on file (due to institutional non-compliance), the presence of profiles indicates that his name was submitted for potential impeachment disclosure tracking.
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Federal civil rights lawsuit: Dailey is a named defendant in a federal civil rights lawsuit filed November 20, 2018.
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Documented pattern of retaliation: Multiple officers filed complaints alleging Dailey is "very vindictive and will often retaliate against you if he thinks you are in any way challenging his power."
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Unauthorized background check scheme: Dailey allowed Paul Tassone — who was not authorized or licensed — to conduct his background investigation for the Rio Vista PD Chief position, creating a conflict of interest and potential fraud upon the City of Rio Vista.
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Department collapse: The Rio Vista Police Department was entirely dissolved under Dailey's leadership.
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Institutional non-compliance: Both the Sacramento County Sheriff's Department and Cal OES are flagged as "not in compliance with Brady disclosure obligations." The Sacramento County DA's office admits it does not maintain a Brady/Giglio list. The absence of formally disclosed Brady material is a systemic failure, not an exoneration.
Under Giglio v. United States, 450 U.S. 150 (1972), and Strickler v. Greene, 527 U.S. 263 (1999), any prosecutor who calls Dailey or any Network member as a witness is obligated to disclose this impeachment material to the defense. Failure to do so constitutes a Brady/Giglio violation requiring reversal of any conviction.
IV. NOTICE OF POTENTIAL LEGAL CONSEQUENCES
The Network is hereby notified that if the conduct described in this Notice does not immediately and permanently cease, the Claimant intends to pursue all available civil and criminal remedies, including but not limited to:
A. Civil Actions
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Civil RICO action under 18 U.S.C. § 1964(c) seeking treble damages, costs, and attorney's fees for injury to business or property caused by the Network's pattern of racketeering activity;
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Civil rights action under 42 U.S.C. § 1983 for deprivation of constitutional rights under color of law, including Fourth Amendment violations (warrantless search), First Amendment violations (retaliation for protected speech), and Fourteenth Amendment violations (deprivation of liberty without due process);
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Civil rights conspiracy action under 42 U.S.C. §§ 1985 and 1986;
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False Claims Act qui tam action under 31 U.S.C. § 3730 for recovery of defrauded government funds, with the Claimant as relator entitled to 15–30% of the recovery;
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California False Claims Act action under Government Code § 12651;
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Malicious prosecution action under California tort law and § 1983;
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Defamation action under California Civil Code §§ 44–46;
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Tortious interference with economic relations under California common law;
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Intentional infliction of emotional distress under California common law;
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Invasion of privacy under California Civil Code § 1798 and common law;
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Stalking civil action under California Civil Code § 1708.7;
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Whistleblower retaliation action under California Labor Code § 1102.5 and 31 U.S.C. § 3730(h).
B. Criminal Referrals
The Claimant intends to refer the Network's conduct to the following authorities for criminal investigation and prosecution:
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Federal Bureau of Investigation (FBI) — for violations of 18 U.S.C. §§ 241, 242, 2261A, 1512, 1513, 1503, 1951, 371, 1001, 1030, 1623;
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U.S. Department of Justice, Civil Rights Division — for violations of 18 U.S.C. §§ 241, 242 and 42 U.S.C. §§ 1985, 1986;
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U.S. Department of Justice, Criminal Division, Public Integrity Section — for violations of 18 U.S.C. §§ 595, 610 and election interference;
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U.S. Department of Justice, Civil Division — for False Claims Act violations;
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California Attorney General — for violations of California Penal Code §§ 646.9, 653.2, 422, 141, 118, 182, 136.1, 631, 632 and related statutes;
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California Commission on POST (Peace Officer Standards and Training) — for decertification of all peace officer certifications held by Network members;
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California State Auditor — for continuation of whistleblower investigations under the California Whistleblower Protection Act;
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Solano County District Attorney — for state-level criminal violations;
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Sacramento County District Attorney — for state-level criminal violations;
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U.S. Office of Special Counsel — for whistleblower retaliation under 5 U.S.C. § 2302;
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Securities and Exchange Commission — if applicable, for whistleblower retaliation under SOX § 806;
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California Fair Political Practices Commission — for election interference violations.
C. Additional Consequences
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POST Decertification: Under California AB 955 (2021) and SB 2 (2021), any peace officer with sustained findings of serious misconduct may have their POST certification revoked, permanently barring them from law enforcement employment in California;
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Brady/Giglio listing: The documented findings in this matter may be submitted to the Giglio-Bradylist and to prosecuting agencies for formal Brady/Giglio disclosure purposes, ensuring that any future testimony by Network members is subject to mandatory impeachment disclosure;
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Professional licensing consequences: Any professional licenses held by Network members (including but not limited to POST certifications, private investigator licenses, security consultant licenses, and any other professional credentials) may be subject to revocation proceedings;
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Civil rights consent decree monitoring: If the Network's conduct involved a law enforcement agency, the Claimant may seek DOJ intervention leading to consent decree monitoring of the agency.
V. FINAL DEMAND
The Network is hereby given notice that:
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All conduct described in Section II of this Notice must cease immediately and permanently. This includes all stalking, cyberstalking, retaliation, surveillance, harassment, interference with communications, interference with economic activity, election interference, threats, entrapment, wrongful prosecution, obstruction of justice, witness tampering, and government fraud.
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All evidence of the Network's unlawful conduct must be preserved. No documents, communications, electronic data, or other evidence may be destroyed, altered, or concealed. Such destruction would constitute additional violations of 18 U.S.C. § 1512(c) (obstruction of proceedings) and 18 U.S.C. § 1503 (obstruction of justice).
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This Notice constitutes a formal demand. The Claimant has documented the Network's conduct extensively and has prepared comprehensive legal research supporting the claims set forth herein. This Notice is a final warning before the initiation of formal civil and criminal proceedings.
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The Claimant reserves all rights. Nothing in this Notice constitutes a waiver of any claim, defense, or remedy available to the Claimant under federal, state, or local law. The Claimant reserves the right to amend, supplement, or modify this Notice and to pursue any and all additional remedies that may become available.
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Time is of the essence. The Network's failure to cease the conduct described herein within ten (10) days of receipt of this Notice will be construed as a willful and deliberate decision to continue the unlawful course of conduct, and will be used as evidence of the Network's bad faith and intent to continue the pattern of racketeering activity in any subsequent legal proceedings.
VI. AFFIRMATION
The Claimant affirms under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of their knowledge, ability, skill, disability, understanding, and that the conduct described herein has been documented through public records, court filings, news reports, arbitration findings, FOIA responses, and other verifiable sources. That said, the truth needs to be regularly tested with more evidence, and so the Editor of U.P.R. News reserves the right to correct any record at any time with evidence of a need to do so.
Dated: September 13, 2026
Respectfully,
Editor of U.P.R. News
Notice to Recipient: This Cease and Desist Notice is a serious legal document. It is not a bluff, a threat, or an idle warning. The Claimant has conducted extensive legal research and documented the factual and legal basis for all claims set forth herein. Recipients are advised to retain legal counsel immediately and to take this Notice with the utmost seriousness. The continued commission of any conduct described in this Notice after receipt will be treated as willful and deliberate, and will be used as evidence of the Network's intent and bad faith in all subsequent proceedings.
This document is prepared for informational and legal notice purposes. It does not constitute legal advice. Recipients should consult with qualified legal counsel regarding their rights and obligations.
ADDITIONAL LEGAL BASIS
Here is the most recent application of artificial intelligence for our legal matter, which corroborated our legal analysis of about a million pages of Epstein evidence we gave to the DOJ in 2024, which have been disappeared from Congressional EFTA release, concealed from Judge E. Sullivan, destroyed, altered, tainted, subject to estoppel, equitable tolling, and continuous RICO obstruction for 24 years, and in a manner that A.I. concluded our legal matter has lost the ability to apply statutes of limitations because of the level of harm by government employees operating outside of legal capacity and outside of qualified immunity.
They've also been disqualified from office and none of their changes to the government are legal concludes A.I.
A.I. has also concluded that we need to file bar complaints against those RICO obstructing.