Plaintiff resides at #### zzzzzzzz zz, zzzzzzzzzzz, [Morldeth] #####.

     Defendant [Acid Rain] Community College is located at ### zzzzzzz zzzz, [Bombarounyurclok] County, [Morldeth] #####.
     Defendant [Bombarounyurclok] County Police Department has main offices at ## zzzz zzz, zzzzzzzz, [Morldeth] #####.

     Defendant [CFC] Medical Center is located at ## zzzzzzzz zzzz, [Bombarounyurclok], [Morldeth] #####.

     Defendant [Defoliation] Mental Hospital's address is #### zzzzz zz, zzzzz, [Morldeth] #####.

[1.1]     I, Disraely Hapend, Plaintiff, hereby bring action against Defendants [Acid Rain] Community College ([AR]CC), the [Bombarounyurclok] County Police Department, [CFC] Medical Center ([CFC]MC) and [Defoliation] Mental Hospital ([D]MH) concerning violations of my rights protected by the First, Fourth and Fifth Amendments to the Constitution of the United States, and other laws. These violations involve invasion of privacy, false arrest, false imprisonment, physical deprivation, medical negligence, psychological torture, defamation of character and reputation, and discrimination.

[1.2]     In September 1991 at the age of 4# I became a student at [Acid Rain] Community College ([AR]CC) through a relative's financial aid. That Fall I was disturbed by the on-campus theft of my textbook and written comments by my Computer Literacy teacher on employment experiences as revealed in a resume composition assignment. However I achieved a 4.0 grade-point-average for this course and maintained this grade through the completion of four courses for a total of 11 credits, until my involuntary withdrawal from student status in February 1993.

[1.3]     In Spring and Summer 1992 I experienced harassment and other problems while employed as a temporary worker and complained in writing to work supervisors, including [Bombarounyurclok] Gas & Electric Company management. I also consulted my [AR]CC Oceanography teacher about family and coworker attitudes and career, employment and social contacts.

[1.4]     In late August-early September 1992 I discovered that an [AR]CC Job Bank lead was for a pornographic maid service. I reported this to zzzzz zzzzzzzzzzz of the [AR]CC Equal Opportunity Office and to zzz zzzzzzzzzzzz of the Job Bank. Their response was satisfactory but some of Mr. [Job Bank]'s comments disturbed me.

[2.2]     On September 21 or 22, 1992 at approximately 11:15 P.M. I phoned the Channel ### WZZZZZZ-TV News Line from my home, asked a derogatory but non-threatening question concerning a police officer mentioned in the news broadcast, and hung up. The young woman who had answered immediately return-called me, told me "That's sick", that she would tell the police, and that I should apologize, although I insisted I had not meant my comments for broadcast, and had suffered much unfair treatment from police.

[2.3]     At this time I began consulting [Counselor X] and [Counselor Y] of the [above-mentioned] Program for academic and employment advice. When I was terminated from employment by [Bullfight] Temporaries on October 8 I began communicating verbally and in writing to Ms. [Counselor Y] and Ms. [Counselor X] about my emotional distress, abuse experiences, family problems and career and relationship interests. Ms. [Counselor Y] arranged a "crisis" interview on November ### at the [sexual assault] Center at ### zzzzzzz zz; however it was not worked out how I would pay for regular therapy. I was also leery of some therapists' attitudes I had encountered in my own search. At Ms. [Counselor Y]'s suggestion I submitted a written complaint against my former employers and clients to the [Morldeth] Commission on Human Relations on November ###. I also applied for and received Federal Student Aid for Spring 1993 tuition at [AR]CC. In early December I was disturbed by responses to my MCHR complaint, and a challenge to obtaining Unemployment benefits. When I called BG&E Customer Service about bill payments, I added angry comments about my former employment experiences.

[2.4]     On two occasions between September 1992 and February 1993, while driving home from [AR]CC, I was followed in an unusual manner by a [Bombarounyurclok] County Police car.

[2.5]     At year's end I was assured of getting Unemployment and other benefits, eligibility for the [AR]CC Honors Program, and registration and tuition for Spring classes. However my vigorous search for employment and emotional therapy was still unsuccessful and some family members' attitudes remained hurtful. I developed a bad cold and the recurrence of sinus infection symptoms. I began a chronology of abuses I had suffered, using computers in the [AR]CC MacLab.

[2.6]     In January 1993 I again attended Ms. [Counselor X's] Job Support Club but her advice to me was puzzling and discouraging, particularly about the [outside ARCC] Counseling Clinic. I confided further to Ms. [Counselor Y] about ongoing verbal abuse and other past problems with family members, including my mother's mysterious death in 196#. She returned some of my written submissions, saying "I'm not a psychological counselor" and other almost blameful comments, and was skeptical about my own search for therapy. She asked about showing my letters to others and I told her she could show them only to therapists or psychological persons. She arranged another "crisis" interview on January ###, 1993 with zzzzz zzzzzzzzz at the [another sexual assault etc.] Center at #### zzzzzz zzz; however this agency was also unable to schedule regular therapy and Ms. [therapist] displayed what I considered to be irresponsible attitudes about drugs.

[2.7]     On February 1 I had a disappointing interview with zzzzzz zzzzzzzzzz, administrator of [AR]CC's Co-op Education Program. I phoned zzzzz zzzz of the [outside ARCC] Counseling Clinic, related many of the abuses I had suffered and was promised a consultation with a psychiatrist. When my purchase of textbooks was clerically

[3.2]     In January and February I continued my employment applications but was totally frustrated. Sometime during the cold weather (although I was not informed of this incident until July), [Bombarounyurclok] County Police were allowed by an apartment manager to look into my apartment in my absence on the suspicion that I had committed suicide.

[3.3]     On February 4 I left a phone message about the current edition of the required textbook for zzz zzzzzzz, campus instructor for the TV course Introductory Psychology/[Un]covering Psychology. On February 9 I used the [AR]CC MacLab to compose a letter to Mr. [Co-op Ed] expressing some enthusiastic environmental career wishes, some creative ideas, some cynical attitudes about society acquired from my experiences and qualified hints at a possibly violent suicide. A copy of this letter is included with this complaint. I slid the letter, along with much relevant background information, under Mr. zzzzzzzzzz's office door on the evening of February 9. On the 10th I used the MacLab for a job application. That evening I attended a Chemistry lab session, where I saw a [Bombarounyurclok] County policeman standing by in the hall and adjoining room. I was involved with other students in the lab work and was not sure whether I was followed from the lab. On the 11th I applied in person to two zzzzzzz businesses, visited zzzzzzzzzzzz Nature Center and shopped in a zzzzzzz store where I observed a person who seemed to be following and/or observing me and who may have been Mr. [Psych. instructor]. In the evening of the 11th and/or possibly late afternoon of the 10th I received at my home phone calls from Ms. [Counselor Y] and possibly Ms. [Counselor X], concerned about "that line" in the letter to Mr. [Co-op Ed]. They told me what to do and I told them what not to do, among other things.

[3.4]     On the morning of February 12 I phoned Mr. [Co-op Ed] from my home and apologized for the drastic expressions in the letter. He promised to assist me as much as he could and said "I've put you into the system." I left my apartment but did not visit the campus. After I returned I was visited by Sgt. zzzzzzzzzz zzzz of the zzzzzzzzz Precinct of the [Bombarounyurclok] County Police and another [Bombarounyurclok] County Police officer. Sgt. zzzz had my letter to Mr. [Co-op Ed] in hand and we discussed certain lines in the letter and their circumstances. He suggested I allow them to drive me "over to the hospital to speak to a counselor". I asked "Are you saying I have to?" and he replied "Well let's put it this way-- if you don't, the people that called us will probably show this letter to a judge and he could give us a court order and then we can pick you up at any time." The other officer left. I decided to comply with [the cop]'s request and was assured that I was not being arrested; however certain other aspects of his information and behavior towards me were coercive. I asked him several times but he would not reveal who had called the police, other than "somebody from the school."

[3.5]     At the [CFC] Medical Center ([CFC]MC) Emergency Room, I was leery about treatment request forms. [The cop] remained alone with me in a booth for about an hour, during which I became very depressed and felt betrayed and trapped, although I remained still and quiet. [The cop] left and a hospital worker insisted I move to an ER cubicle, where it was also insisted I remove my clothes, which with some relevant papers and my purse, were put into a paper bag and set in the hallway. I sympathized with two other ER patients and conversed with technicians. I became apprehensive after several hours without food or a "counselor's" attention. Verbal protests and pleas to technicians and a passing doctor were answered brusquely or ignored. I was allowed to phone my aunt zzzzzzz zzzzzzzzzzzz.

[3.6]     At around 11 PM. to midnight, I estimate, I was interrogated for about 20 minutes by a clinical psychologist who professed ignorance of my letter to Mr. [Co-op Ed], about which I informed him. I also told him about my 4.0 GPA and career

[4.2]     During the next several hours I was treated roughly and sarcastically by ER technicians. They speculated cruelly on where I would be sent and how much of a societal menace I was. Instead of being examined or treated for slight hemorrhoidal bleeding, I was accused of intentionally stuffing toilets with paper. I cried quietly and was unable to sleep due to surveillance procedures.

[4.3]     About 5 or 6 A.M. on the 13th I was strapped onto a guerney although completely docile and transported to [Defoliation] Mental Hospital ([D]MH) in a zzzz Ambulance Service ambulance. I gave personal information to 2 [D]MH admitting clerks. I am not sure whether [First Name] or one of them filled out most of the Involuntary Admission form, but the handwriting seems to indicate one person did all the writing, however omitting or misstating certain information. I was questioned and given a superficial physical examination by a somatic doctor, Dr. zzz, I believe. I was then installed on Ward zzzzz-z.

[4.4]     I phoned Aunt zzzzzzz who had been frantically inquiring about me at [CFC]MC. She and my brother zzzzzzzzz visited with supplies. Exactly 12 hours after admission I was interviewed by Dr. zzzz zzzz who informed me about the hearing procedure and discussed my drug treatment and family concerns and my letter to Mr. [Co-op Ed], of which he seemed quite familiar with the entire contents. I pleaded unsuccessfully with a Public Defender investigator. Using the patient pay phone, I left messages at the [AR]CC offices of Mr. [Co-op Ed] and several of my teachers and department heads. Several calls were returned. I also phoned friends, associates and other interested parties, and legal aid and utility bill payment offices. Aunt zzzzzzz and her brother zz visited with textbooks and personal items. I began a log and notes on patients and conditions. Assigned to Dr. zzzzzzzzzzzzz, I requested a woman doctor and got Dr. [female], who first interviewed me on the 15th and showed me a FAX of instructions from [AR]CC. She never gave me the copy I requested.

[4.5]     zzzzzz zzzzzzz of the Public Defender Office appeared as my lawyer at the February 16 hearing. The only mention of a voluntary admission agreement on this date was my unanswered question to [him]. The most disgruntled parts of some of my letters to [AR]CC personnel were read. Aunt zzzzzzz was present and testified. Administrators and [the lawyer] agreed on a postponement, later attributing the request for such to me.

[4.6]     As the week progressed I trusted the patient mail service and Aunt zzzzzzz to send letters. By phone I tried to arrange outpatient therapy with several agencies but none would make a committment. Two friends visited me. Nurses and aides commented both encouragingly and sarcastically to me and about me. I was not given the vitamins I requested and developed cracked lips and fingertips. Dr. zzzzz zzzzzz, Ph.D. administered psychological tests but was pettily despotic

[5.1] about the results. There was no EEG or chemical testing. Aunt zzzzzzz took care of my apartment and pets and retained the lawyer zzzzzzzzz zzzzz for me. Begged interviews with Dr. [female] and the social worker zzzzzzz zzzzzzzz were delayed.

[5.2]     Dr. [female] seemed to regard me as a criminal about to explode. I related details of abuses of myself by family, employers and associates. She would not listen to an abusive recording. I pointed out to her that my "symptoms" matched neither bipolar disorder nor unipolar depression. She abandoned her initial suggestion of treatment with neuraleptics but recommended Lithium. She blamed mistreatment by others on my own projection of low self-esteem, which I protested. I showed her my resume and other self-promotional material. Drs. [female] and [Ph.D.] were both skeptical of my accounts of rape and other abuses and my attempts at family communication. They questioned me repeatedly as to whom I would kill. They seemed dissatisfied with my methods of relaxation and recreation. Dr. [Ph.D.] was very suspicious of my interest and ability in science. There was absolutely no appreciation or encouragement of my career interests, grades, environmental activities or my own assistance to others.

[5.3]     I observed several patients being mistreated by staff, one severely. My sympathetic attention to him and other patients was interfered with.

[5.4]     Just before the hearing on February 23 there was a private meeting between myself, Mr. [my lawyer], Dr. [female] and Dr. zzzzzzzzzzzzzz zzzzzzzz, who said he was Dr. [female]'s supervisor. Dr. [supervisor] explained that it would be "useless" to offer me a voluntary admission agreement. He had never spoken to or with me until this meeting.

[5.5]     The hearing was audio-taped by Judge zzzz zzzzzzzzz. A number of excerpts from my letters to [AR]CC persons were read by zzzzzzz zz, [D]MH's Hearings Coordinator. These contained accounts of abuses by employers and family and my analysis of their attitudes and those of prospective employers and associates. There was speculation about the wisdom of suicide, but in none of my writings were there any threats or plans for violence to myself or others, nor was there hate speech by myself, nor was there admission of past violence by myself, nor was there indication of self-perversion or substance abuse past or present. I had phrased "certain lines" so that they would be disturbing and call attention to my own existential predicament, with hope of assistance to myself. Omitted from reading at the hearing were friendly, confident, enthusiastic and appreciative excerpts, a greeting card, career testing, my highly praised composition on ecology, Honors Program placement test results, a reference letter from a teacher, my own evaluation of a teacher as requested by [AR]CC and my Spouse Requirements. All written doctors' reports from both hospitals were read, revealing differing serious diagnoses, misquotations of some of my attitudes and recommendations for a hospital stay. Dr. [female] was present and reported that I was "evasive", "grandiose" and "circumstantial". She diagnosed me as having "mixed" bipolar disorder which would erupt into a major problem without drugs to "stop it before it starts". She even found pathology in an abortion rights discussion between me and my aunt. To my amazement some incidents from my high school years were mentioned. Dr. [supervisor] remarked about "that psychotic undercurrent she hides so well" in an off-the-record (tape-changing) moment; Mr. [my lawyer] later commented that this remark was unfair. A witness I had contacted spoke for a few minutes on my behalf. Mr. [Co-op Ed] displayed the enclosures I had included with my February 9 letter, grudgingly acknowledged that there topic was environmental, and related my phone apology and the circumstances of the police summons on February 12, which he said had been a decision by Dean zzzzzz zzzzz and ["displaced homemakers" program]. Dr. zzzzzz zzzzzzz, [AR]CC Head of Counseling, whom I had never met before, said 3 people wished

[6.2]     On the morning of February 24 I attempted to contact the [outside] Counseling Clinic but was informed by [the social worker] of [D]MH that this agency had reneged on its promise of therapy. In the late afternoon I was phoned by Dr. [ARCC Head of Counseling] who arranged a conference date of March 1 and advised me not to come onto the campus until then. On the 25th I phoned many therapy sources and composed a conciliatory letter to Dean zzzzz. I mailed it to her along with some self-promotional material such as had been included with my letter to Mr. [Co-op Ed]. I did not phone or visit the campus until the conference between Dean zzzzz, Dr. [Head of Counseling] and myself in Dean zzzzz's office in the Z Building on March 1.

[6.3]     At this conference Dean zzzzz said she had not gotten my letter of February 25 or the other material; however I brought along more copies. Dean zzzzz explained that I would be administratively withdrawn from student status for six months, during which time I would be expected to obtain mental health therapy, and there would be an attempt to have my Pell grant funds transferred for use in the Fall 1993 semester at [AR]CC. I was forbidden to come onto the campus or phone campus offices during these six months. Dean zzzzz said that I had "created an atmosphere of fear" on the campus and that "police were called". She said that she herself had been criticized for not calling a "crisis conference" among my teachers and administrative personnel; I expressed enthusiasm for participation in such a conference, but it was not planned. Dean zzzzz phoned other administrative personnel from her office. I informed her that I would be starting emotional therapy on March 2. At the end of our conference I was given no written notification of my withdrawal or the campus ban.

[6.4]     On March 2 I mailed letters in envelopes without return addresses to Dr. [Chem teacher] and Dr. zzz zzzzzzzzzz, Chair of the [AR]CC Psychology Department, at their campus offices. I informed Dr. [Psych chair] of my incarceration at [D]MH, the withdrawal by Dean zzzzz and other circumstances, and requested her assistance in enabling me to continue with the Spring courses I had been enrolled in. Also on March 2 I began regular emotional therapy with a Licensed Clinical Social Worker. On March 3 Dean zzzzz phoned me at home to tell me I was jeopardizing my future at [AR]CC by sending letters onto the campus. I told her I had not visited or phoned the campus since the ban, but I did not understand how I could be prevented from communicating through the U.S. Mail. I also told her that if I were banned for six months, I would perhaps choose not to attend [AR]CC in the Fall, and I would assist the Federal Government in the return of its Pell money, or its transfer to another school. Dean zzzzz said she would send me written notification of the withdrawal and Pell grant transfer. She gave me permission to contact her superiors or other [AR]CC Deans. On March 5 I mailed identical copies of a 3-page letter to [AR]CC President zzzz zzzzzzzzzzzzzzz and zzz zzzzzzzzzzzzzzzz, Dean of Administrative Services. This letter related my personal

[7.1] history and my recent experiences with [AR]CC, the police, [CFC]MC and [D]MH, and beseeched the President and [Admin. Serv.] Dean to arrange the lifting of the campus ban and the prevention of my official withdrawal. However on March 11 I received by certified mail delivery to my home Dean zzzzz's official notification of my withdrawal from student status and 6-month campus ban and certain conditions which must be fulfilled before I could be reenrolled. This notification contained the same instructions I had seen in the FAX shown to me by Dr. [female] at [D]MH. A copy of it is included with this complaint. On March 18 I received in the mail an answer from President zzzzzzzzzzzzzzz confirming Dean zzzzz's decisions.

[7.2]     In mid-March I consulted a psychiatrist who disagreed with the diagnosis of bipolar disorder and suggested a much milder "disorder" which could be interpretted as a socio-political condition. On March 21 I mailed a request for the police report of February 12, indicating that it should include one or several letters. I received the report but it included no letters or other documents.

[7.3]     In March, April and June 1993 I received notices from [AR]CC offices warning of an outstanding balance, "missed" grades and danger of losing my financial aid due to failure to maintain good academic standing. I phoned these offices in March and April and was told the matter would be looked into. I have had no further communication from [AR]CC about financial matters except a form postcard inquiring about my Job Bank registration. I have also received [AR]CC course catalogs, Job Bank and other flyers and I may have gotten a notice of a personal registration date for Fall 1993 classes. However I have not phoned the campus since April 1993, I have not mailed anything to the campus since March 1993, nor have I visited the campus since that month.

[7.4]     I communicated with Sgt. [that same cop] in March 1993 concerning [AR]CC's bans; since that time I have had no communication with police about this affair.

[7.5]     I received several bills from [CFC]MC, physicians and the ambulance service. My phone calls and mailings resulted in these charges being written off or charged to the State. Since April 1993 I have not communicated with [CFC]MC concerning this affair except for a phone call to Dial-a-Nurse to check the spelling of "guerney".

[7.6]     I visited patients in [D]MH twice in the Spring of 1993 but have not visited or communicated with the hospital since then.

[7.7]     I continued the complaint process against my former employers with the MCHR/EEOC which I had begun in November 1992. I believe that investigators for these agencies were biased by rumors and suppositions arising from my incarceration in a mental hospital. However I did obtain a Right-to-Sue Letter and filed a Title VII suit by myself in December 1993.

[7.8]     I have continued to have trouble getting employment, probably likewise due to rumors and suppositions. After the hospital incident I did not actually start working until January of 1994 at part-time work from home. Later I obtained work from another temporary service but have been treated strangely on some assignments.

[7.9]     Although the hospital experience helped me learn that I indeed have several real true friends, the stigma attached to the possibility of mental illness has affected my social relationships and, I believe, prevented new ones. I have written to persons concerned with human rights, particularly where mental illness is involved, about my experiences.

[7.10]     The Defendants have scorned and punished my very legitimate, if rashly expressed, anguish and anger at abuses committed against me and their own negligence, and labeled my distress as a mental illness, one which is characterized by irresponsible and often disruptive behavior. They have tried to visit upon me a moral degradation and personal political repression which I had not thought possible in modern America.

[8.1] I pray the Court to bring the Defendants to trial and to grant me monetary relief in the amount of five million dollars, plus any legal costs I may incur in this case. It may be appropriate seek imprisonment of one or more persons involved. I shall begin complaint processes towards removal from employment or invalidation of professional licenses for several persons involved.

[8.2]     If relief is not granted, I will indeed be irreparably denied basic American rights secured by the Constitution, and will live, or rather exist for a while, in fear of further repression.

[8.3]     I am filing this suit today without benefit of formal legal advice. I was told that the statute of limitations allowance for such complaints is three years, and hope that I have not been misinformed. With the knowledge of time requirements I also hereby pray that the Court appoint me legal counsel; however I shall continue my own search for same. I also pray the Court grant such injunctive orders as may be appropriate.

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