10/11/2026

The following is a federal and civil lawsuit pending filing against Jeffrey Epstein's crime syndicate still operating in Northern CA, where Epstein and others operated Edge Foundation.

In order to get away with decades of treasonous child sex trafficking and the murder of little kids, Sacramento Area and other law enforcement played a key role in what eventually destroyed America.

On 09/21/2014, they were presented with the choice to protect little kids from being trafficked into illegal medical experiments at Epstein's Roche/CHORI, or to actually do their jobs. Unfortunately, they chose to align with treasonous child sex traffickers. Criminal corruption of California's law enforcement community is so bad the state had to pass laws to address their carnage against citizens. https://post.ca.gov/SB-2-FAQs

FEDERAL FILING PACKAGE — THE LAWSUIT AGAINST THE FOUR AGENCIES

This package is the filing-ready layer. The working draft (the federal complaint canvas) keeps the tier labels, falsification annex, and drafting notes; this package strips all of that into what the Court and the clerk actually receive, plus the forms, the service map, and the pre-filing gates. Placeholders appear as [FILL: ...] and decision points as [DECIDE: ...]. Nothing here is legal advice; counsel review is recommended before filing.

PART ONE — PRE-FILING GATES (all must clear before the clerk's window)

1. [FILL: the current CHP Commissioner's name] — needed for the official-capacity defendant.

2. [DECIDE: IFP vs. fee payment. If filing in forma pauperis under 28 U.S.C. § 1915, first count prior federal dismissals that count as "strikes" under § 1915(g) — three or more bars IFP absent imminent danger (and the ongoing overflights are the imminent-danger argument if it comes to that). If the fee route is chosen, verify the current E.D. Cal. civil filing fee on the court's fee schedule.]

3. [FILL/DECIDE: the Fourth Amendment Count and the § 1986 Count] — keep or drop on strategy. The working draft keeps both with honest flags (Ciraolo/Riley for the Fourth; the one-year clock for § 1986). Recommendation of record: keep them; the Fourth is pleaded in the alternative and costs nothing; § 1986 rides on the 2026 neglect core.

4. Government-claims dependency: the supplemental state-law Counts (Twelfth–Fourteenth) against the City of Sacramento and the Counties must not be filed before their claims are presented and rejected (or deemed rejected). The claims calendar runs separately (November 22, December 3, December 4, 2026 cliffs). Options: (a) file the federal complaint without the state supplemental counts and amend them in after rejection; or (b) present the claims immediately (they can be presented now) and rely on the 30/45-day deemed-rejection windows landing before the federal case is at issue. [DECIDE: which route — (a) is the safer one.]

5. Exhibits assembled and hashed: Exhibits A–G per the master index; SHA-256 hashes computed; the flash-drive/appendix practice per the settled discipline. Exhibit E (records requests + claim proofs) will be incomplete at filing — that is acceptable if the complaint pleads the requests as ongoing.

6. Doe discipline confirmed: no pilot names anywhere; vehicles and callsigns only, per the attribution rule (the vehicle is the provable unit; individuals substitute after discovery).

7. POST track: runs in parallel (no exhaustion requirement, no tolling interaction). The settled sequencing instruction (POST first, federal second) is satisfied by transmitting the POST complaint before or with this filing; nothing in this package depends on POST.

8. E-filing check: E.D. Cal. pro se parties may not e-file without the assigned judge's permission (Local Rule 133) — the paper route at the Sacramento courthouse is the default; permission-first if e-filing is wanted.

9. Counsel review — standing recommendation.

10. The qui tam separation rule: the underlying qui tam action (the register's conspiracy-claim damages) must NEVER be a count in this public complaint — if pursued, it is a separate sealed filing under 31 U.S.C. § 3730(b), with its own procedural rules (the seal, the first-to-file bar, and the public-disclosure bar); counsel review is strongly recommended before any qui tam filing. The $10 billion-plus figure in this Complaint's prayer is the damages demand for the counts pleaded in this Complaint.

11. The 2014 body-worn video — the national-origin knowledge evidence for the Sixteenth Cause of Action — must be preserved and requested (CPRA/discovery) before that Count is finalized; expect an authenticity and completeness fight.

PART TWO — THE COMPLAINT (FILING TEXT)

Copy from here down for the complaint document. Fill every [FILL]; resolve every [DECIDE].

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

Editor UPR News,

Plaintiff,

v.

CALIFORNIA HIGHWAY PATROL, an agency of the State of California; [FILL: name], Commissioner of the California Highway Patrol, in his official capacity; DOES 1–10 (California Highway Patrol pilots and flight officers), in their individual capacities; CITY OF SACRAMENTO, a municipal corporation; DOES 11–20 (Sacramento Police Department officers and flight personnel), in their individual capacities; COUNTY OF SACRAMENTO, a political subdivision of the State of California; DOES 21–30 (Sacramento County Sheriff's Department deputies and flight personnel), in their individual capacities; COUNTY OF PLACER, a political subdivision of the State of California; DOES 31–40 (Placer County Sheriff's Department deputies and flight personnel), in their individual capacities; and DOES 41–50 (supervisors and commanders of the aerial units of each named agency),

Defendants.

Case No. [FILL]

PLAINTIFF'S COMPLAINT FOR VIOLATIONS OF 42 U.S.C. §§ 1983, 1985, AND 1986; CIVIL RACKETEERING UNDER 18 U.S.C. §§ 1962(c) AND (d); FALSE CLAIMS ACT RETALIATION UNDER 31 U.S.C. § 3730(h); AND SUPPLEMENTAL STATE-LAW CLAIMS

Plaintiff Editor UPR News, by and through himself, alleges as follows:

I. NATURE OF THE ACTION

1. This is a civil rights action arising from a years-long course of conduct in which aircraft operated by the defendant law-enforcement agencies have repeatedly and deliberately converged on Plaintiff's single-family residence in Rocklin, California, in low, loud, and at times nighttime passes serving no lawful operational purpose — a campaign of aerial stalking, harassment, and witness intimidation that continued after, and intensified following, Plaintiff's 2024 whistleblower submissions to the United States Department of Justice, which named these agencies.

2. All four defendant agencies — the California Highway Patrol ("CHP"), the Sacramento Police Department (through the City of Sacramento), the Sacramento County Sheriff's Department (through the County of Sacramento), and the Placer County Sheriff's Department (through the County of Placer) — were named in Plaintiff's August 29, 2024 whistleblower-retaliation submission to federal authorities. The conduct described here continued after that submission.

3. The geometry excludes innocent explanation. The direct route between the two airports anchoring the relevant corridor — Auburn Municipal Airport (KAUN) and McClellan Airfield (KMCC), both documented CHP operating locations — passes approximately 1.5 statute miles from Plaintiff's residence. On October 11, 2026, a same-day control flight on that corridor flew nearly straight — 28 actual miles against a 26-mile direct line — demonstrating that the corridor itself does not force any deviation toward Plaintiff's property. Each incident flight instead departed the corridor by approximately the full 1.5 miles to cross one fixed residential address.

4. Plaintiff has preserved flight-data captures documenting the recurrence by specific aircraft: CHP tails N911CA, N974HP, N708HP, N947HP, and N978HP in 2023–2024 (published contemporaneously and included in Plaintiff's August 29, 2024 submission to the Department of Justice); N978HP again on April 4, 2026; CHP21 fixed-wing flights on May 22, June 3 (2:12 a.m. and 10:12 p.m.), and June 4, 2026; and CHP24 on September 23 and October 11, 2026. Plaintiff's published record further documents aircraft of the Sacramento Police Department and the Sacramento County Sheriff's Department flying out of their jurisdictions — across multiple cities and two counties — to converge on Plaintiff's Rocklin community, and the Placer County Sheriff's Department's AS-350 "Falcon 30" (N911WL, Auburn-based, publicly registered to Placer County) participating in the same pattern.

5. The statistical character of the pattern — repeated same-address convergences by the same vehicles, callsigns, and agencies, measured against independent null baselines — shows deviations that are non-random and highly improbable, as corroborated in the totality of the circumstances and to be supported by expert testimony.

6. Roadmap: Counts 1–3 plead constitutional deprivations under 42 U.S.C. § 1983 against the individual defendants; Count 4 pleads municipal/county liability; Count 5 pleads supervisory liability; Counts 6–7 plead the civil-rights conspiracy statutes; Counts 8–9 plead civil racketeering; Count 10 pleads False Claims Act retaliation; Count 11 seeks prospective injunctive relief; Counts 12–14 plead supplemental state-law claims; and Counts 15–17 plead concerted-action and joint-tortfeasor liability, national-origin discrimination, and interference with prospective economic advantage.

II. PARTIES

7. Plaintiff Editor UPR News is an individual residing in Rocklin, Placer County, California. He is the publisher and editor of an independent news publication, Uprights News, and a whistleblower who has submitted evidence of criminal conduct to the United States Department of Justice and Department of State, including a submission accepted in writing on August 29, 2024.

8. Defendant CALIFORNIA HIGHWAY PATROL is a state agency whose Office of Air Operations is headquartered at McClellan Park and operates an air unit at Auburn Municipal Airport. CHP is named solely for prospective declaratory and injunctive relief; Plaintiff seeks no damages from CHP or from any state officer in official capacity.

9. Defendant [FILL] is the Commissioner of the California Highway Patrol and is sued in his official capacity solely for prospective injunctive relief.

10. DOES 1–10 are CHP pilots and flight officers who participated in the conduct described below, whose identities are unknown to Plaintiff and will be ascertained through discovery.

11. Defendant CITY OF SACRAMENTO is a municipal corporation that operates the Sacramento Police Department, including its air operations.

12. Defendant COUNTY OF SACRAMENTO is a county that operates the Sacramento County Sheriff's Department, including its air operations.

13. Defendant COUNTY OF PLACER is a county that operates the Placer County Sheriff's Department, including its air unit and AS-350 "Falcon 30" aircraft publicly registered to Placer County.

14. DOES 11–40 are officers, deputies, and flight personnel of the Sacramento Police Department, the Sacramento County Sheriff's Department, and the Placer County Sheriff's Department, respectively, who participated in the conduct described below, sued in their individual capacities. DOES 41–50 are the supervisors and commanders of the aerial units of each named agency.

III. JURISDICTION AND VENUE

15. This Court has jurisdiction under 28 U.S.C. §§ 1331 and 1343, and under 18 U.S.C. § 1964 as to the racketeering counts. Supplemental jurisdiction over the state-law counts lies under 28 U.S.C. § 1367.

16. Venue lies in this District under 28 U.S.C. § 1391(b) because a substantial part of the events or omissions occurred in Rocklin, Placer County, within the Eastern District of California, and because the defendants operate from Auburn, McClellan Park, and Sacramento, all within this District.

17. No administrative exhaustion is required for the claims under 42 U.S.C. § 1983, and California's claim-presentation requirements do not apply to the § 1983 counts.

IV. FACTUAL ALLEGATIONS

A. Plaintiff's protected activity

18. From at least 2013 through 2016, Plaintiff conducted an investigation into public corruption and organized criminal conduct. His findings and evidence of retaliation against him were submitted to federal authorities on August 24 and August 29, 2024. The August 29, 2024 submission was accepted in writing by the United States Attorney's Office.

19. The August 29, 2024 submission included a 374-page evidentiary record of Plaintiff's contemporaneously published documentation of the aerial campaign, including CHP aircraft tail numbers, altitudes, and speeds. The defendant agencies' aerial conduct was thus documented and disclosed to the federal government before the 2026 flights described below occurred.

20. Plaintiff publishes his findings through Uprights News. As early as November 2023, Plaintiff's published record identified a pattern of uniformed pilots based at McClellan Park conducting low, off-course passes over communities in Placer and Sacramento counties, and announced the purpose of identifying the specific aircraft and pilots involved. The published record naming the Sacramento Police Department, the Sacramento County Sheriff's Department, and the Placer County Sheriff's Department appeared no later than September 5 and 11, 2026.

21. The conduct described below continued and recurred after each of these notice events.

B. Plaintiff's residence and the corridor geometry

22. Plaintiff's residence is in the Stanford Ranch neighborhood of Rocklin. It does not lie between, on, or near any airport pair's direct route. The direct great-circle route between Auburn Municipal Airport (KAUN) and McClellan Airfield (KMCC) — approximately 26.2 statute miles — passes approximately 1.5 statute miles from Plaintiff's residence.

23. On October 11, 2026 at approximately 3:17 p.m., an aircraft flew the same corridor nearly straight, tracking 28 actual miles against a 26-mile direct line, at approximately 1,500–2,500 feet and 100–160 miles per hour. This control observation demonstrates that the corridor is routinely flown straight and that no operational constraint forces aircraft toward Plaintiff's property.

C. The 2023–2024 flight record

24. The evidentiary article included in Plaintiff's August 29, 2024 submission documents, among other incidents: on August 29, 2023, a CHP aircraft (registration N974HP) flying off course, converging on Plaintiff's community, and passing at approximately 1,500 feet while accelerating; on September 6, 2023, a CHP aircraft circling Plaintiff's community off course; on November 2, 2023, a CHP aircraft (registration N911CA, based at Auburn) departing on a vector away from its destination, converging on the community, descending, and passing at approximately 800 feet with sufficient force to shake the walls and windows of residences; and on February 22, 2024, a similar 800-foot pass. The same article identifies CHP aircraft N708HP and N947HP as additional recurrent participants and N978HP among the CHP fleet operating the pattern.

D. The 2026 flight record

25. On April 4, 2026, at approximately 8:07–8:09 a.m., CHP helicopter N978HP passed over Plaintiff's residential block at approximately 800 feet and 152 miles per hour, and approximately two minutes later passed the same block at approximately 500 feet and 59 miles per hour — a descent to a low loiter over the same block.

26. On May 22, 2026 at approximately 9:39 p.m., a CHP aircraft using callsign CHP21 (Cessna 208) passed over Plaintiff's residential block at night at approximately 3,200 feet, after a steep recorded descent.

27. On June 3, 2026, CHP21 operated over Plaintiff's area at approximately 2:12 a.m. and again at approximately 10:12 p.m. On June 4, 2026 at approximately 4:47 p.m., CHP21 passed directly over the West Stanford Ranch Road area of Plaintiff's neighborhood at approximately 3,600 feet.

28. On September 23, 2026 at approximately 5:36–5:39 p.m., a CHP aircraft using callsign CHP24 (Airbus AS-350) passed directly over Plaintiff's residential block at approximately 2,800 feet and 120 miles per hour, with recorded flight data showing a descent coupled to an acceleration at the pass, continuing to approximately 1,500 feet within approximately three minutes.

29. On October 11, 2026, CHP24 passed directly over Plaintiff's residential block at approximately 2:48 p.m. at 1,600 feet and 100 miles per hour, and at approximately 3:08 p.m. conducted a positioning run toward the same block at approximately 1,000 feet and 90 miles per hour, maneuvering to align with the residence. The near-straight control flight on the same corridor followed at approximately 3:17 p.m. (¶ 23). Plaintiff separately documented a morning overflight of his residence that day.

30. The nighttime passes at 9:39 p.m., 2:12 a.m., and 10:12 p.m. evidence a design to deprive Plaintiff of sleep as part of the course of conduct.

31. Plaintiff has preserved the original flight-data captures documenting each of the foregoing. Plaintiff has verified each aircraft's registration against public Federal Aviation Administration records and has excluded from this complaint one flight initially attributed to a defendant agency but confirmed by registry to be a hospital air ambulance; the correction is logged in Plaintiff's exhibit set.

E. The multi-agency course of conduct

32. Plaintiff's published record, incorporated here as allegations of notice and pattern, documents: Sacramento Police Department and Sacramento County Sheriff's Department aircraft flying outside their jurisdictions — across multiple cities and two counties — to converge on Plaintiff's Rocklin community, passing at approximately 700–900 feet, including circling and repeat passes over Plaintiff's residence; and the Placer County Sheriff's Department's AS-350 "Falcon 30" (N911WL, publicly registered to Placer County and based at Auburn Municipal Airport, the same facility used by CHP's air unit) passing at approximately 800–900 feet.

33. Convergence on a single fixed residential address by aircraft of four separate agencies defeats the suggestion of isolated operational coincidence: under any random model it would require independent operators coincidentally selecting the same address, and by its structure it implies coordination.

34. Plaintiff's 2014 history with the Sacramento Police Department — including an arrest on September 21, 2014, alleged entrapment, alleged threats of lethal force discussed by officers on body-worn camera, alleged physical abuse, alleged suppression of exculpatory evidence, and an alleged defamation campaign — is pleaded as background, pattern, and retaliatory-animus context. That operation included the seizure of Plaintiff's draft qui tam complaint. Plaintiff's home country is Canada, and the officers' own body-worn video recorded their knowledge of it. Plaintiff attributes the operation and the continuing conduct described in this Complaint to a single conspiracy whose object is the destruction of Plaintiff's investigation and the concealment of its subject matter, in which conspiracy the defendant agencies participate.

35. In August 2024 Plaintiff presented to federal authorities his whistleblower-retaliation complaint naming CHP, the Sacramento Police Department, the Sacramento County Sheriff's Department, and the Placer County Sheriff's Department, among others. The flights described in ¶¶ 25–32 post-date that submission and were conducted by the same agencies' aircraft.

F. The statistical showing

36. Plaintiff developed a scoring instrument for evaluating pilot intent from flight data, constructed to be usable by plaintiffs and defendants alike, employing a deliberately conservative per-event null probability of one chance in 360 that an off-course flight would cross any given residence, and a rule of thumb that three visits at least one mile off the normal path, with any pass below 1,000 feet, is inconsistent with innocent explanation.

37. Applying official population, area, and fleet figures, Plaintiff computed six independent null baselines for a chance overflight of his specific residence, ranging from one chance in 360 (the most defense-favorable) to one chance in approximately 25 million. The fair local average across the six baselines is approximately one chance in 362,000. At that average, a single chance overflight of Plaintiff's residence would be expected once in approximately 248 years even if every relevant aircraft flew daily and always off course; for a single pilot, once in approximately 990 years. The 2026 record alone documents approximately nine vehicle-named convergence events.

38. Plaintiff alleges these deviations are non-random and highly improbable in the totality of the circumstances, and will support this allegation through expert testimony and the exhibits, including the control observation described at ¶ 23.

V. CAUSES OF ACTION

FIRST CAUSE OF ACTION
42 U.S.C. § 1983 — Substantive Due Process, Fourteenth Amendment
(Individual Defendants)

39. Plaintiff realleges ¶¶ 1–38. Acting under color of state law, the individual Defendants engaged in a course of conduct — the repeated deliberate convergence of government aircraft on Plaintiff's residence in low, loud, and nighttime passes, including descent-and-accelerate passes and a loiter at approximately 500 feet — intended to intimidate and harass Plaintiff and to deprive him of sleep and of bodily and psychological integrity. The conduct was repeated over years with full opportunity for deliberation, and shocks the conscience in the constitutional sense. It serves no legitimate government purpose and lies outside any officer's lawful duties. As a direct and proximate result, Plaintiff suffered deprivation of sleep, physical and emotional injury, and interference with his home life, family, and work.

SECOND CAUSE OF ACTION
42 U.S.C. § 1983 — Unreasonable Search and Intrusion, Fourth Amendment
(Individual Defendants)

40. Plaintiff realleges ¶¶ 1–39. The individual Defendants' repeated targeting overflights, loitering at approximately 500 feet, and nighttime passes intruded upon Plaintiff's reasonable expectation of privacy in his residence and its curtilage, and the physical and sensory invasions of the curtilage — noise, vibration, and structural shaking — constitute an unreasonable intrusion. As a direct and proximate result, Plaintiff suffered the injuries described above. [DECIDE: keep or drop this Count before filing — see Gate 3.]

THIRD CAUSE OF ACTION
42 U.S.C. § 1983 — First Amendment Retaliation
(Individual Defendants)

41. Plaintiff realleges ¶¶ 1–40. Plaintiff engaged in constitutionally protected activity: whistleblower submissions to federal authorities (¶¶ 18–19) and continuous publication of his findings and of the aerial campaign (¶¶ 20–21). The individual Defendants, all employed by agencies named in those submissions, retaliated against Plaintiff for that protected activity through the course of conduct described above, which intensified after the August 2024 submissions and would chill a person of ordinary firmness from continuing such speech and petitioning activity, and did chill Plaintiff. As a direct and proximate result, Plaintiff suffered the injuries described above and a burden on his publication and reporting.

FOURTH CAUSE OF ACTION
42 U.S.C. § 1983 — Municipal and County Liability
(City of Sacramento, County of Sacramento, County of Placer)

42. Plaintiff realleges ¶¶ 1–41. Each municipal and county Defendant maintained and tolerated a custom or practice under which its flight personnel conduct the aerial course of conduct described above without investigation, discipline, or correction. Each Defendant was on notice of the conduct, including through Plaintiff's years of published documentation and specifically the September 5 and September 11, 2026 publications naming these entities, and after that notice the conduct continued. Each Defendant failed to train and supervise its flight personnel regarding the constitutional limits of aerial operations, and its deliberate indifference was a moving force behind the constitutional deprivations. As a direct and proximate result, Plaintiff suffered the injuries described above.

FIFTH CAUSE OF ACTION
42 U.S.C. § 1983 — Supervisory Liability
(Defendant Does 41–50)

43. Plaintiff realleges ¶¶ 1–42. The Doe supervisors and commanders of each named agency's aerial unit knew of, participated in, approved, and were deliberately indifferent to the constitutional deprivations described above; they assigned and scheduled the flights, and failed and refused to prevent, investigate, or correct the conduct after years of notice. As a direct and proximate result, Plaintiff suffered the injuries described above.

SIXTH CAUSE OF ACTION
42 U.S.C. § 1985(3) — Conspiracy to Interfere with Civil Rights
(All Defendants)

44. Plaintiff realleges ¶¶ 1–43. The Defendants conspired for the purpose of hindering and preventing Plaintiff, in the free exercise and enjoyment of rights secured by the Constitution and laws of the United States — including freedom of speech and of the press, the right to petition for redress of grievances, and his participation as a witness and informant in federal proceedings — through the intimidation course of conduct described above. One or more overt acts in furtherance of the conspiracy include the October 11, 2026 flights described at ¶ 29. Plaintiff was injured in his person and property, and Defendants intended to obstruct the exercise of the rights described. The class of persons targeted includes witnesses, victims, and government informants, and, in the alternative, persons discriminated against on the basis of national origin, Plaintiff's home country being Canada.

SEVENTH CAUSE OF ACTION
42 U.S.C. § 1986 — Neglect to Prevent
(All Defendants)

45. Plaintiff realleges ¶¶ 1–44. The Defendants, having knowledge of the conspiracy described above and the power to prevent or aid in its prevention, neglected and refused to prevent it, including during the one year preceding the filing of this action. As a direct and proximate result, Plaintiff suffered the injuries described above.

EIGHTH CAUSE OF ACTION
Civil RICO — 18 U.S.C. § 1962(c)
(Individual Defendants)

46. Plaintiff realleges ¶¶ 1–45. Beginning no later than November 2023, the individual Defendants and their co-conspirators — uniformed pilots and their supervisors based at Auburn Municipal Airport and McClellan Park and associated with the four named agencies — formed and participated in the conduct of the affairs of an association-in-fact enterprise through a pattern of racketeering activity, including acts indictable under 18 U.S.C. §§ 1512 and 1513 (tampering with, and retaliating against, a witness, victim, or informant) and related obstruction provisions. The pattern of racketeering activity included repeated acts of intimidation of Plaintiff by aircraft in furtherance of the enterprise's purpose: obstructing Plaintiff's whistleblowing and publication. The pattern's obstruction dimension is the interference with Plaintiff's economic activity — the operation of his publication and his business and professional relationships — which is the injury to his business and property for purposes of 18 U.S.C. § 1964(c). Plaintiff's business and property — his news publication and his home-based work upon which the conduct inflicted continuous disruption — were injured by reason of the pattern. Plaintiff seeks treble damages and costs under 18 U.S.C. § 1964(c).

NINTH CAUSE OF ACTION
Civil RICO — 18 U.S.C. § 1962(d) — Conspiracy
(All Defendants)

47. Plaintiff realleges ¶¶ 1–46. The Defendants agreed to the objectives of the enterprise described above. The multi-agency, multi-vehicle, multi-year convergence on a single residential address — persisting after years of published notice and after the 2024 federal submissions — demonstrates coordination that isolated operational coincidence cannot produce. As a direct and proximate result, Plaintiff suffered the injuries described above.

TENTH CAUSE OF ACTION
False Claims Act Retaliation — 31 U.S.C. § 3730(h)
(All Defendants)

48. Plaintiff realleges ¶¶ 1–47. Plaintiff engaged in activity protected by 31 U.S.C. § 3730(h): his 2024 submissions to federal authorities constituted efforts to disclose and stop fraud on the United States and retaliation against whistleblowers. Because of that protected activity, the Defendants — agencies named in the submissions — retaliated against Plaintiff through the course of conduct described above, including acts post-dating the submissions and continuing into October 2026. As a direct and proximate result, Plaintiff suffered the injuries described above.

ELEVENTH CAUSE OF ACTION
Prospective Injunctive Relief — Ex Parte Young
(Commissioner of the California Highway Patrol, in official capacity)

49. Plaintiff realleges ¶¶ 1–48. Plaintiff seeks prospective relief against the Commissioner in his official capacity to end continuing violations of federal law: an order enjoining CHP aircraft from operating within a defined exclusion band around Plaintiff's residence absent a documented emergency or mission exigency, together with periodic disclosure of mission and dispatch records sufficient to verify compliance. Plaintiff seeks no damages under this Count.

TWELFTH CAUSE OF ACTION
California Civil Code § 52.1 (Bane Act)
(Individual Defendants)

50. Plaintiff realleges ¶¶ 1–49. By threats, intimidation, and coercion — including the menace inherent in repeated low passes and descent-and-accelerate passes over his residence — the individual Defendants interfered, and continue to interfere, with Plaintiff's federal and state constitutional rights, including freedom of speech and press and the right to be secure in his home.

THIRTEENTH CAUSE OF ACTION
California Civil Code § 1708.7 (Civil Stalking)
(Individual Defendants)

51. Plaintiff realleges ¶¶ 1–50. Each individual Defendant is liable for stalking Plaintiff: a knowing and repeated course of conduct directed at Plaintiff, by aircraft, in a manner that would cause a reasonable person substantial emotional distress, serving no legitimate purpose, and causing Plaintiff substantial emotional distress, including acts making a credible threat. Plaintiff seeks the damages, civil penalties, and equitable relief provided by the statute.

FOURTEENTH CAUSE OF ACTION
Intentional Infliction of Emotional Distress
(Individual Defendants)

52. Plaintiff realleges ¶¶ 1–51. The course of conduct described above — years of multi-agency aerial harassment of a single residence, including passes at 2:12 a.m., descent-and-accelerate passes, and a loiter at approximately 500 feet — constitutes extreme and outrageous conduct exceeding all bounds tolerated in a civilized community, intended to and causing Plaintiff severe emotional distress, sleep deprivation, and harm to his health, family, and work.

FIFTEENTH CAUSE OF ACTION
Concerted Action; Joint Tortfeasor Liability
(All Defendants)

53. Plaintiff realleges ¶¶ 1–52. Each Defendant joined and furthered a common design — the course of conduct described above — and each is liable for the acts of every other participant done in furtherance of the common design and for their foreseeable consequences, whether or not each performed each act, pursuant to the principles of concerted action, Restatement (Second) of Torts §§ 875–876, civil-conspiracy liability under California law, and California Code of Civil Procedure §§ 875–880, and as co-conspirators under 18 U.S.C. § 1962(d). The defendant agencies jointly caused the whole of Plaintiff's harm, and each is liable for the entirety of it, including the harm caused by the officers of any other participating agency.

SIXTEENTH CAUSE OF ACTION
National-Origin Discrimination — 42 U.S.C. § 1983 (Equal Protection); Cal. Civ. Code §§ 51.7 and 52
(Individual Defendants)

54. Plaintiff realleges ¶¶ 1–53. Plaintiff's home country is Canada, and the Sacramento Police officers knew it from their own recorded video. The individual Defendants, acting under color of law, discriminated against Plaintiff on the basis of national origin with discriminatory purpose, and violated Plaintiff's right to be free from violence and intimidation by threat of violence because of national origin, in violation of California Civil Code § 51.7. As a direct and proximate result, Plaintiff suffered the injuries described above.

SEVENTEENTH CAUSE OF ACTION
Intentional Interference with Prospective Economic Advantage
(All Defendants)

55. Plaintiff realleges ¶¶ 1–54. The Defendants, through the conduct described above — including the September 21, 2014 operation and the continuing aerial course of conduct — intentionally interfered with Plaintiff's economic relations, including the operation of his publication and his business and professional relationships, through unlawful means, causing economic loss. As a direct and proximate result, Plaintiff suffered the injuries described above.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment as follows:

1. Against the individual Defendants, compensatory damages according to proof;

2. Against the individual Defendants, punitive damages;

3. Against the City of Sacramento, County of Sacramento, and County of Placer, compensatory damages on the Fourth Cause of Action;
   3-A. Against all Defendants, jointly and severally, damages in the aggregate in excess of ten billion dollars ($10,000,000,000), the multipliers pleaded above to be applied as authorized;

4. Treble damages, costs, and attorneys' fees under 18 U.S.C. § 1964(c);

5. Damages, penalties, fees, and costs under 31 U.S.C. § 3730(h);

6. Statutory damages, penalties, and fees under California Civil Code §§ 52.1 and 1708.7, and damages and civil penalties under California Civil Code §§ 51.7 and 52;

7. Compensatory and punitive damages on the Fourteenth Cause of Action;

8. Prospective injunctive and declaratory relief as pleaded in the Eleventh Cause of Action;

9. Attorneys' fees under 42 U.S.C. § 1988 and applicable state fee statutes;

10. Costs of suit; and

11. Such other and further relief as the Court deems just.

DATED: [FILL]

Editor UPR News, Plaintiff pro se
[FILL: address, telephone, email]

JURY TRIAL DEMANDED as to all Counts triable to a jury.

DECLARATION UNDER PENALTY OF PERJURY (28 U.S.C. § 1746)

I declare under penalty of perjury under the laws of the United States that the facts stated in this Complaint are true and correct to the best of my knowledge, information, and belief. Executed on [FILL] at Rocklin, California.

Editor UPR News

EXHIBITS

• Exhibit A — Evidentiary article (374 pp.) included in Plaintiff's August 29, 2024 submission to the U.S. Department of Justice (the 2023–2024 flight record).

• Exhibit B — Vehicle-named flight-data register, 2023–2026, including the registry-verification and correction log.

• Exhibit C — Plaintiff's Aerial Intent scoring instrument (with figures).

• Exhibit D — Original flight-data captures keyed to the register.

• Exhibit E — Public-records requests and responses (ongoing).

• Exhibit F — Exhibit master index and file hashes.

• Exhibit G — Published-notice record (including the September 5 and September 11, 2026 articles).

PART THREE — THE FILING SET (forms to obtain and complete)

1. The Complaint — Part Two, printed; signature and § 1746 declaration completed.

2. Summons (AO 440 / 440A) — issued by the clerk after filing; one per defendant group (state defendants; each county; the city; the Does via later service).

3. Civil Cover Sheet (JS-44) — required in most districts; complete using the nature-of-suit codes for civil rights (flag: verify the E.D. Cal. requirement and codes at filing).

4. IFP application (if Gate 2 chooses IFP) — Application to Proceed Without Prepaying Fees (28 U.S.C. § 1915), with financial declaration; § 1915(e)(2) screening applies, and § 1915(g) must be answered first (Gate 2).

5. Exhibits — assembled, hashed, indexed per Exhibit F discipline.

6. Copies — the E.D. Cal. pro se paper route requires an original plus judge's copy set [verify the court's current copy requirements].

PART FOUR — SERVICE MAP (Rule 4, once summons issues; the 90-day clock under Rule 4(m) starts at filing)

• CHP and the Commissioner (state defendants): Rule 4(j)(2) — deliver the summons and complaint to the agency and the officer, and send a copy to the California Attorney General. [Verify the AG service address at filing.]

• County of Placer and County of Sacramento: Rule 4(j)(3) — serve each county in the manner California law prescribes for counties (the clerk of the board of supervisors) [verify the current CCP citation].

• City of Sacramento: Rule 4(j)(3) — serve the city in the manner California law prescribes for municipal corporations (the city clerk) [verify the current CCP citation].

• Individual Does: not served until identified and substituted; the naming discipline (vehicles/callsigns, discovery-driven substitution) governs.

PART FIVE — POST-FILING SEQUENCE

1. File at the Sacramento courthouse window (paper default; e-filing only with the assigned judge's permission); obtain the case number and issued summons.

2. Serve within Rule 4(m)'s 90 days; track each defendant's proof of service.

3. Answer deadlines: 21 days after service for federal defendants absent waiver; defaults where applicable.

4. Initial disclosures, Rule 26(f) conference, scheduling order; the discovery targets are already settled in the record — mission/dispatch/crew records for CHP21, CHP24, N911CA, N947HP, N974HP, N708HP, N978HP (2023–2024 and 2026 dates) and N911WL (Placer County).

5. The Doe-substitution amendments as crew records arrive.

6. The § 1367(d) discipline if the state counts are amended out/in: the California complaint (the fallback draft) is filed within 30 days of any supplemental-jurisdiction decline, with state limitations tolled during federal pendency — but the Government Claims Act presentations (Part Zero of the state draft) must already be in motion regardless.