Any one of you can start the exposure process to bring these arrogant people to justice.
PO Box 10587
Reno, NV 89510
plaintiff in pro se
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF NEVADA
RODNEY F. STICH,
WESTERN DIABLO ENTERPRISES, Inc.
Estelle C. Mannis; Kent L. Mannis;
Friedman, Sloan & Ross, P.C.;
Joshua Landish; Vernon Bradley;
Stanley J. Friedman; Paul G. Sloan;
Lawrence A. Gibbs; Jeffrey S. Ross; Charles Duck; Carolyn
Goldberg, Stinnet & Macdonald;
Lawrence Goldberg; Terrance C. Stinnnett; Iam Macdonald;
Christopher A. Goelz; Merle C.
Meyers; Jerome Robertson;
John W. Murray; Susan E. Weber;
Murray & Murray, P.C.;
David Levi; Edward Jellen;
Michael McInnis; Harold F. Wolters;
William Jensen; J. Clinton Peterson;
Donald King; Harry Low;
Zerne Haning; Robile, Inc;
Concord Properties; Emma Stich;
Milton Schwartz; Raul Ramirez;
John Moulds; Marilyn Patel;
Vaughn Walker; Robert Jones;
) No. CV-N-00-0152-ECR-PHA
) AMENDED COMPLAINT
) FOR DAMAGES UNDER CIVIL RIGHTS
) ACT (42 U.S.C. Sections 1983-1986);
) RICO (18 U.S.C. Sections 1961-1965);
) BIVENS DOCTRINE; FRAUD;
) DECLARATORY JUDGMENT
) (28 U.S.C. Sections 2201, 2202);
) CONSTITUTIONAL VIOLATIONS;
) REPORTING FEDERAL CRIMES
) (18 U.S.C. Section 4);
) 28 U.S.C. Section 1361 REQUIRING
) FEDERAL OFFICER TO PERFORM A DUTY
) DEMAND FOR JURY TRIAL ON ALL
) JURY ISSUES
1. This action arises under:
a. The Constitution of the United States, and specifically the First Amendment (right to
petition government); Fifth Amendment (right to due process and equal protection of the
law); Article IV, § 1 (privileges and immunity clause); Article IV § 2 (constitutional right
to unabridged interstate travel); and under:
b. Title 28 United States Code § 1331, which provides that anyone stating facts raising a
federal cause of action has the right to file in the district courts a civil action stating claims
arising under the Constitution, laws, or treaties of the United States.
c. Title 28 United States Code § 1343, which provides a federal court forum in which
citizens may seek redress from the deprivation of rights, privileges and immunities under
color of state law.
d. Civil Rights Act, Title 42 United States Code §§ 1983-1986, that provides a federal
remedy to anyone suffering from violations of his civil rights perpetrated under color of
e. Title 42 U.S.C. § 1985 Conspiracy to interfere with civil rights, based upon the
conspiracy by the defendants that repeatedly violated plaintiff's civil rights.
f. Title 42 United States Code § 1986, which provides for damages from those defendants
who had knowledge of the violations of plaintiff's civil rights, who had the duty and the
ability to prevent or aid in the prevention of them, and who failed to perform that duty.
g. Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388
(1971). The Bivens claim is based upon the violations of plaintiff's civil rights under color of
federal law, which occurred continuously and inter-related from 1983 to the present date.
h. Title 18 United States Code §§ 1961-1964. The Racketeer Influenced and
Corrupt Organizations act (hereafter "RICO") claim arises from the pattern of
multiple predicate acts perpetrated by defendants over a 17 year span. The
predicate acts of racketeering by multiple defendants affected interstate
i. Declaratory Judgment Act, Title 28 United States Code §§ 2201 and 2202,
which provides for district courts to declare rights and legal relations that are
in controversy, and provide whatever remedies are appropriate. (Also FRCivP
j. Title 18 United States Code § 4. This federal crime reporting statute
requires any person who knows of a federal crime to promptly "report it to a
federal judge" or other officer.
k. The matters in controversy exceed ten million dollars.
2. Venue is based upon the following:
a. A number of the wrongful acts and federal causes of action occurred while plaintiff was a
resident of the Northern District of Nevada.
b. Plaintiff resides in Nevada and California and considers Nevada his domicile.
c. Plaintiff's solely owned corporation was and is incorporated in Nevada and has its
principal place of business in the Northern District of Nevada.
d. A divorce judgment entered as a local judgment in Nevada, establishing plaintiff's
personal and property rights, is heavily involved with this action.
e. Property in the Northern District of Nevada and in other states was acquired by plaintiff
while he was a resident and domicile of Nevada and is involved with this lawsuit.
f. Property that was wrongfully taken from Plaintiff included property located in the
Northern District of Nevada.
g. All defendants participated in wrongful conduct that affected Northern Nevada interests, including
property and plaintiffs residences and domicile.
h. Venue exists in any location for reporting criminal activities to a federal judge, as required by federal
crime reporting statute, Title 18 U.S.C. § 4.
i. Venue lies in this district pursuant to 28 U.S.C. §§ 1391(a), (b), (e); 1392(b); 1402(b).
j. Further, plaintiff cannot exercise the rights and responsibilities in district courts of
California because of the following conditions:
i. Federal judges in the district and appellate courts have blocked the
reporting of criminal activities by Plaintiff and his group of government
whistleblowers which plaintiff sought to report to a federal judges under the
mandatory requirements of the federal crime reporting statute, Title 18 U.S.C.
Section 4. The internal security of the United States continues to be adversely
affected by these criminal acts and the obstruction with the reporting of them
to a federal judge.
ii. Federal judges in Northern and Eastern California have feloniously
retaliated against plaintiff for seeking to report these crimes. These retaliatory
acts were felonies under Title 18 U.S.C. §§ 1505, 1510, 1512, 1513(b). They
are also felonies by obstructing justice under Title 18 U.S.C. §§ 2, 3, and 4.
Statute Of Limitations
3. The violations of federally protected rights, for the purpose of this lawsuit, continued
without interruption from 1982 to the present date, consisting of continuing violations. One
of the latest acts in the continuing series of wrongful acts occurred on March 25, 1999,
when Chapter 11 judge Edward Jellen issued an order in plaintiff's Chapter 11 cases at
Oakland, California disposing of the last of plaintiff's $10 million in assets that were
corruptly, unlawfully, and unconstitutional seized.. Certain federal causes of actions
constituting major violations of federally protected rights, a part of a convoluted pattern of
unlawful conduct, occurred when plaintiff sought refuge in Chapter 11 courts from the civil
rights violations occurring during the past 20 years. The bankruptcy case was closed on
September 3, 1999.
4. Rodney F. Stich is a former Navy pilot in World War II, a former international airline
captain, a former inspector-investigator for the Federal Aviation Administration (FAA),
and for many years a private investigator. His discovery of serious criminal activities
relating to a series of fatal airline crashes occurring in his area of federal air safety
responsibilities led him to embark on a crusade to bring these matters to justice. Over a
period of many years, his activities were joined by a group of other government
whistleblowers who sought to report criminal activities in high government offices and
covert government operations. He published eight books and appeared as guest and
expert on over 3,000 radio and television shows since 1978. These books include the third
editions of Defrauding America and Unfriendly Skies and the first editions of Drugging
America and Disavow.
5. Western Diablo Enterprises, incorporated in Nevada in 1984, contained the bulk of
plaintiff's real estate properties that funded his exposure activities, and was plaintiff's de
facto properties. Both of these plaintiffs are hereinafter referred to as "plaintiff."
6. The defendants in this lawsuit are California judges, federal judges, and attorneys and law firms. The
California judges who perpetrated the wrongful acts stated in this complaint include Dwight Ely,
Michael McInnis, William Jensen, Harold F. Wolters; John A. Deronde; Dennis Bunting, J. Clinton
Peterson, Donald King, Harry Low, and Zerne Haning. The California judicial defendants were directly
involved in the wrongful acts constituting federal causes of actions from 1982 to 1986 and as part of a
conspiracy were implicated throughout the 1982 to 2000 time period covered by this lawsuit. They
violated and conspired to violate plaintiff's civil rights and knowingly inflicted great and irreparable
harm upon plaintiff. They became part of a RICO Enterprise and RICO conspiracy. California judges
are sued in their official and non-official capacities. Some have left their former judicial positions.
7. Federal judges aided and abetted, and expanded on the wrongful acts. For the purpose of this
lawsuit, they included Milton Schwartz, Raul Ramirez and Magistrate John Moulds; San Francisco
Judges Marilyn Patel and Vaughn Walker; Las Vegas Chapter 11 judge Robert Jones, and Oakland
Chapter 11 judge Edward Jellen. Federal judges are sued in their official and non-official capacities.
Some of these federal judges have left the federal judiciary.
8. Attorneys and law firms named as defendants include Stanley J. Friedman, Paul G. Sloan; Lawrence
C. Gibbs; Jeffrey S. Ross; John W. Murray; Christopher A. Goelz; Carolyn E. Moore; Merle C.
Meyers; Rene Feinstein; Joshua Landish; Estelle Mannis; Susan E. Weber; Friedman, Sloan and
Ross, P.C.; Goldberg, Stinnet and Meyers, P.C.; Murray and Murray, P.C.
9. Defendants who were Chapter 11 trustees include Charles Duck and Jerome
10. Other defendants include Robile, Inc and Concord Properties in the Concord,
California area and Texas resident Emma Stich.
11. The United States of America is listed as a defendant for its role in allowing federal
personnel to engage in the wrongful acts described in this amended complaint.
12. Matters of grave national issues are intertwined with this lawsuit and are adversely
affecting the internal security of the United States. Serious allegations are stated in this
lawsuit, most of which are proven by judicial records.
13. This action raises multiple federal causes of actions for which federal judges have a
mandatory responsibility to provide a federal court forum and relief. Plaintiffs, both
individually and as a class, a whistleblower against corrupt government personnel, have
been deprived of personal and property rights without, and in direct and repeated
violations of due process of law. Although all allegations must be accepted as true at this
stage of the pleading, most of the allegations are proven in judicial records, and plaintiff
requests that judicial notice be taken of these records. Further, during discovery, this
evidence will be entered into these proceedings.
Thumbnail Highlights Of the Convoluted Scheme To Obstruct Justice
14. Basically, the evidence strongly indicates that the reasons for the record setting
numbers of violations judicially inflicted upon plaintiff by California and federal judges
arose from a convoluted scheme concocted somewhere high in the federal government to
strip plaintiff of the considerable assets he possessed that funded his exposure of
high-level corruption in government.
15. The overt part of the scheme was initiated by the San Francisco law firm of Friedman,
Sloan and Ross, which had been identified to plaintiff by two reliable sources as a CIA-front
law firm. The apparent thought was that plaintiff's assets would be promptly taken from him
by cooperating California judges. But when plaintiff unexpectedly exercised federal
remedies for the multitude of violations of federally protected rights, it then became
necessary to obtain the cooperation of federal judges. The escalation of the violations of
law by federal judges increased the number of remedies under the laws and Constitution of
the United States. A judicial crisis was eventually reached, which federal judges rendering
unlawful and unconstitutional orders converting plaintiff into a citizen of the United States
stripped of the protections in law while the judicial offices and the courts openly and
corruptly inflicted great and irreparable harm upon him. Further details can be found in the
attached Addendum "A," which is the third edition of the book, Defrauding America.
Bizarre as this sounds, for those who have an inside knowledge of covert government
operations, it is easy to understand and proven by judicial records.
16. Plaintiff seeks:
a. A return to him of the assets that were unlawfully and unconstitutionally
seized by judicial defendants named herein, who acted without jurisdiction
while concurrently violating large numbers of federal laws and constitutional
safeguards, and compounding these acts by felonious retaliation when plaintiff
exercised federal due process remedies.
b. Damages from the defendants as stated herein.
c. Declaratory judgment to declare certain rights and legal obligations as
stated in this action.
d. A demand for this court to receive reports and evidence of criminal
activities that Plaintiff and his group of present and former government agents
have discovered, as can provide. Federal judges must receive these reports
and evidence under the clear wording of the federal crime reporting statute,
Title 18 U.S.C. § 4.
Title 18 U.S.C. § 4 (misprision of felony).
e. "Whoever, having knowledge of the actual commission of a felony
cognizable by a court of the United States, conceals and does not as soon as
possible make known the same to some judge or other person in civil or
military authority under the United States, shall be fined not more than $500 or
imprisoned not more than three years, or both."
e. These present and former government agents include plaintiff, who is a former federal
investigator, from former heads of secret Central Intelligence Agency airlines and CIA
financial operations, and agents of the FBI, CIA, DEA, Customs, INS, Secret Service, and
other government and non-government insiders.
f. Included in these criminal activities are drug smuggling by the Central Intelligence
Agency, judicial corruption in the bankruptcy courts, the cover-ups of these matters by
other government personnel, as detailed in this action and in plaintiff's books, including
the third editions of Defrauding America and Unfriendly Skies, and the first edition of
Drugging America. The book Defrauding America is made a part of this lawsuit and
included as Addendum "A."
17. More details are presented in this amended complaint because of the requirement of Federal Rule
of Civil Procedure 9(b), which requires that allegations of fraud, condition of mind, and conspiracy be
stated with specificity rather than general allegations. Further, the great number of repeated violations
of federally protected rights over a 20-year period requires more detail than a single violation of
federally protected rights. Prior to that 20-year period, plaintiff documented, as a federal inspector,
criminal activities related to a series of fatal airline crashes occurring in plaintiff's area of federal air
18. This lawsuit addresses a convoluted pattern of unlawful and unconstitutional acts that focused on
blocking plaintiff's reporting of serious criminal activities that plaintiff and his group of government
whistleblowers sought to report. Each defendant listed in this amended complaint covered up for, and
enlarged upon, the criminal and civil rights violations of those who preceded them.
A Brief History Of Earlier Events
19. To help understand the events that preceded the attacks upon plaintiff which, for the purpose of
this lawsuit, commenced in 1982 and continues to this day, plaintiff presents a brief outline. As an
inspector-investigator for the Federal Aviation Administration (FAA), Plaintiff discovered and reported
federal air safety and criminal violations relating to a series of airline crashes in his area of federal air
safety responsibilities while he held air safety responsibilities for the most senior program at United
Airlines. Implicated in the corrupt activities were management personnel at United Airlines and the
Federal Aviation Administration. Federal inspectors were blocked from carrying out federal air safety
responsibilities. Harassment and threats by key management personnel at United Airlines and within
the FAA blocked inspectors from carrying out the federal government's air safety responsibilities in
such a manner that a series of fatal airline crashes occurred. Evidence of this misconduct is in plaintiff's
possession, and detailed in plaintiff's book, the third edition of Unfriendly Skies and in a condensed
section in the third edition of Defrauding America. These were criminal acts associated with the deaths
of many people in a series of specific airline crashes.
20. Possibly because of the enormous implications between the pattern of corrupt and criminal acts and
the great numbers of fatal crashes, and the liabilities incurred by the federal government if this
information became known, a pattern of cover-up and obstruction of justice followed. These included
key personnel in the Federal Aviation Administration (FAA), the National Transportation Safety Board
(NTSB--called CAB Bureau of Safety at that time), and the Department of Justice.
21. The cover-ups and criminal obstruction of justice by NTSB officials required falsification of
government accident reports, which expanded the criminal activities. In turn, the cover-ups and the
falsified accident reports covered up for the air safety and criminal violations involved in prior crashes,
which then became involved in subsequent crashes. As expected, the cover-ups and falsified accident
22. Plaintiff documented many of the crash-related misconduct as he forced an unprecedented
four-month-long hearing upon the FAA during which he acted as a self-appointed independent counsel.
Three other fatal crashes in plaintiff's area of direct air safety responsibilities occurred during that
hearing which were due to the air safety and criminal violations plaintiff and other inspectors had
discovered. Perjury and subornation of perjury by FAA management and FAA legal counsel was
rampant and proven during that hearing.
23. Armed with additional evidence of criminal activities arising during the four-month-long hearing and
associated with identifiable airline crashes, plaintiff offered evidence to the Department of Justice and
to the U.S. attorneys at Denver, Oklahoma City, and eventually San Francisco. In the first of what
plaintiff discovered for the next 35 years, each office engaged in cover-ups and obstruction of justice.
Seeking to circumvent this high-level block, plaintiff appeared before a federal grand jury at Denver. It
was here that he discovered the ability of the U.S. attorney to block a grand jury investigation of
high-level corruption in government.
24. These attempts to meet responsibilities as a federal investigator resulted in retaliation, which
caused plaintiff to eventually leave the FAA and continue the exposure of these criminal activities as a
private citizen. As the covered up corruption continued to play a key role in other air disasters, plaintiff
used his considerable assets to publish books, appear as guest on hundreds of radio and television
shows, and filed federal actions in San Francisco and Los Angeles district courts under Title 18 U.S.C.
§ 4 and 28 U.S.C. § 1361. These included:
Stich v. United States, et al., 554 F.2d 1070 (9th Cir.) (table), cert. denied, 434 U.S. 920 (1977); Stich v.
National Transportation Safety Board, 685 F.2d 446 (9th Cir.)(table), cert. denied, 459 U.S. 861 (1982));
Flanagan v. McDonnell Douglas Corporation and United States of America, Civil Action 74-808-PH,
MDL 172, Central District California.).
25. In the actions filed in the U.S. district courts at San Francisco, the judges were sympathetic but
denied they had the responsibility under these statutes, claiming it was the responsibility of Congress
to take action. Every filing was authorized under Title 28 U.S.C. §§ 1361 and Title 18 U.S.C. § 4.
a. Title 28 U.S.C. § 1361. Action to compel an officer of the United States to perform his
duty. The district courts shall have original jurisdiction of any action in the nature of
mandamus to compel an officer or employee of the United States or any agency thereof to
perform a duty owed to the plaintiff.
b. Title 18 U.S.C. § 4 (misprision of felony). "Whoever, having knowledge of the actual
commission of a felony cognizable by a court of the United States, conceals and does not as
soon as possible make known the same to some judge or other person in civil or military
authority under the United States, shall be fined not more than $500 or imprisoned not
more than three years, or both."
26. These dismissals by federal judges made possible the continuation of the air safety and criminal
violations that plaintiff and other FAA inspectors discovered at United Airlines and within the FAA. As
expected, further crashes and further deaths followed the cover-up. These matters are detailed in
plaintiff's third edition of Unfriendly Skies.
27. In Plaintiff second edition of Unfriendly Skies, he named the federal judges who refused to act and
who made possible the continuation of the air safety and criminal violations that made possible other air
disasters. Plaintiff's continued appearances on radio and television shows and the continued sales of
the book threatened to expose federal judges, Justice Department offices, members of Congress, and
United Airlines personnel.
The Probable Motive For the Start Of Judicial Retaliation
28. The start of the judicial violations of federally protected rights commenced with the filing of a sham
lawsuit against plaintiff in California on December 12, 1982. (In re the Marriage of Stich, 83472, Solano
County Superior Court, Fairfield, California.).
29. The lawsuit was filed by the San Francisco law firm of Friedman, Sloan and Ross. The Friedman law
firm and their attorneys (hereinafter called "Friedman") who took part in the lawsuit fraudulently
claimed that plaintiff was married to their client, Texas resident Emma Stich (hereafter "Emma"), and
that she wanted a dissolution of the alleged marriage. That lawsuit also claimed that plaintiff's $10
million in personal and corporate assets were community properties and that the Texas resident
wanted half of these. These were the assets that funded plaintiff's investigative and exposure activities
that threatened federal judges in the Ninth Circuit and other implicated government personnel.
Legally Divorced For the Prior Two Decades
30. The divorce action was a sham...
For the rest of the lawsuit, please click here Rodney Stich Lawsuit