INFORMATION FOR DEMAND FOR GRAND JURY INVESTIGATION AND INDICTMENTS AND PROSECUTION FOR CRIMES THE UNITED STATES OF AMERICA v. BILLY C. SANDERS JOSEPH DARBY PATRICIA THOMPSON DWIGHT JAMES LYNN MARTIN BILL ALLAN SCNAACP EEOC FCC LM COMMUNICATIONS INC. LM COMMUNICATIONS SOUTH CAROLINA INC. LM COMMUNICATIONS SOUTH CAROLINA II INC. GESS MATTINGLY AND ATCHISON John or Jane Doe E.E.O.C. John or Jane Doe F.C.C. VIOLATIONS: U.S. TITLE 18 PART I CHAPTER 63 Sec. 1343 (Fraud by wire, radio, or television) U.S. TITLE 18 PART I CHAPTER 1 Sec. 1. Sec. 2. (Aiding and Abetting) U.S. TITLE 18 PART I CHAPTER 19 Sec. 371 (Conspiracy to commit offense or to defraud United States) U.S. TITLE 18 PART I CHAPTER 13 Sec. 241 (Conspiracy against rights) U.S. TITLE 18 PART I CHAPTER 13 Sec. 242 (Deprivation of rights under color of law} U.S. TITLE 18 PART I CHAPTER 13 Sec. 245 (Federally protected activities} U.S. TITLE 18 PART I CHAPTER 47 Sec. 1017 (Government seals wrongfully used and instruments wrongfully sealed) U.S. TITLE 18 PART I CHAPTER 47 Sec. 1001. (False Statements - Statements or entries generally) U.S. TITLE 18 PART I CHAPTER 73 Sec. 1512. (Tampering with a witness, victim, or an informant) U.S. TITLE 18 PART I CHAPTER 73 Sec. 1505. (Obstruction of proceedings before departments, agencies, and committees) U.S. TITLE 18 PART I CHAPTER 95 Sec. 1957. (Engaging in monetary transactions in property derived from specified unlawful activity) U.S. TITLE 18 PART I CHAPTER 101 Sec. 2071. (Concealment, removal, or mutilation generally of RECORDS AND REPORTS) U.S. Title VII of the Civil Rights Act of 1964 (Title VII), ENFORCEMENT PROVISIONS SEC. 2000e-5. [Section 706] (b),((e) (1)) S.C.: Title 16 CHAPTER 5. Sec. 16-5-10 (Conspiracy against civil rights.) S.C.: Title 16 CHAPTER 5. Sec, 16-5-20 (Punishment for commission of additional crimes.) U.S. TITLE 18 PART I CHAPTER 41 Sec. 872 (Extortion by officers or employees of the United States) U.S. TITLE 18 PART I CHAPTER 41 Sec. 875 (Interstate communications) U.S. TITLE 18 PART I CHAPTER 1 Section 3 (Accessory after the fact) DEMAND FOR JUSTICE IN INDICTMENTS: The Plaintiff-Victim charges that: Introductory Allegation 1. At all times material to this Demand For Indictment, defendant BILLY C. SANDERS was a resident of or near Charlotte North Carolina; defendant JOSEPH DARBY was a resident of or near Charleston South Carolina; defendant PATRICIA THOMPSON was a resident of or near North Charleston South Carolina; defendant DWIGHT JAMES was a resident of or near Columbia South Carolina; defendant LYNN MARTIN was a resident of or near Lexington Kentucky; defendant BILL ALLAN was a resident of or near Lexington Kentucky. 2. At all times material to this Demand For Indictment, defendant BILLY C. SANDERS held the position of Program Manager of the Equal Employment Opportunities Commission in the Charlotte, North Carolina District Office; defendant JOSEPH DARBY held an executive position (Vice President) of the South Carolina Chapter of the National Association for the Advancement of Colored People (SCNAACP); defendant DWIGHT JAMES held an executive position (Vice President) of the South Carolina Chapter of the National Association for the Advancement of Colored People (SCNAACP); defendant PATRICIA THOMPSON's employment and affiliation was unknown; defendant LYNN MARTIN owned L.M. Communications Inc of Lexington Kentucky, L.M. Communications Inc., of South Carolina and L.M. Communications II Inc., of South Carolina; defendant BILL ALLAN was an attorney with the firm of Gess Mattingly & Atchison in Lexington Kentucky. 3. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 63 Sec. 1343, specifically prohibited "having devised or intending to devise any scheme or artifice to defraud" by "means of wire, radio, or television communication in interstate or foreign commerce", the transmission of email correspondence having sufficed for electronic transmission of communication over wire. 4. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 1 Sec. 1. & Sec. 2. part (a) defined "Whoever commits an offense against the United States or aids, abets, counsels, commands, induces or procures its commission, is punishable as a principal." and (b) "Whoever willfully causes an act to be done which if directly performed by him or another would be an offense against the United States, is punishable as a principal" were in force. 5. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 19 Sec. 371 prohibited "two or more persons [to] conspire either to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose, and one or more of such persons do any act to effect the object of the conspiracy". 6. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 13 Sec. 241 prohibited "two or more persons [to] conspire to injure, oppress, threaten, or intimidate any person in any State, Territory, Commonwealth, Possession, or District in the free exercise or enjoyment of any right or privilege secured to him by the Constitution or laws of the United States, or because of his having so exercised the same". 7. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 13 Sec. 242 prohibited anyone who "under color of any law, statute, ordinance, regulation, or custom, [to] willfully subject(s) any person in any State, Territory, Commonwealth, Possession, or District to the deprivation of any rights, privileges, or immunities secured or protected by the Constitution or laws of the United States, or to different punishments, pains, or penalties, on account of such person being an alien, or by reason of his color, or race." 8. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 13 Sec. 245 prohibited any person "(b) whether or not acting under color of law, by force or threat of force willfully injures, intimidates or interferes with, or attempts to injure, intimidate or interfere with", "(1) any person because he is or has been, or in order to intimidate such person or any other person or any class of persons from", "(B) participating in or enjoying any benefit, service, privilege, program, facility, or activity provided or administered by the United States;". 9. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 47 Sec. 1017 prohibited "fraudulently or wrongfully affix(es)(ing) or impresses the seal of any department or agency of the United States, to or upon any certificate, instrument, commission, document, or paper or with knowledge of its fraudulent character." 10. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 47 Sec. 1001 prohibited "whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly and willfully," "(1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;", "(2) makes any materially false, fictitious, or fraudulent statement or representation;", "(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;". 11. At all times material to this Demand For Indictment TITLE 18 > PART I > CHAPTER 73 > Sec. 1512 prohibited the "(A) prevent(ion) [of] the attendance or testimony of any person in an official proceeding;", or the "(B) prevent(ion) [of] the production of a record, document, or other object, in an official proceeding;", likewise: "(b) Whoever knowingly uses intimidation or physical force, threatens, or corruptly persuades another person, or attempts to do so, or engages in misleading conduct toward another person, with intent to;", "(1) influence, delay, or prevent the testimony of any person in an official proceeding;", "(2) cause or induce any person to -;", "(A) withhold testimony, or withhold a record, document, or other object, from an official proceeding;", "(B) alter, destroy, mutilate, or conceal an object with intent to impair the object's integrity or availability for use in an official proceeding;", "(C) evade legal process summoning that person to appear as a witness, or to produce a record, document, or other object, in an official proceeding; or,", "(D) be absent from an official proceeding to which such person has been summoned by legal process;". 12. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 73 Sec. 1505 prohibited "Whoever corruptly, or by threats or force, or by any threatening letter or communication influences, obstructs, or impedes or endeavors to influence, obstruct, or impede the due and proper administration of the law under which any pending proceeding is being had before any department or agency of the United States,". 13. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 95 Sec. 1957 prohibited anyone "knowingly engag(es)(ing) or attempt(s)(ing) to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and is derived from specified unlawful activity,". 14. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 101 Sec. 2071 prohibited "willfully and unlawfully conceal(s)(ing), remove(s)(ing), mutilate(s)(ing), obliterate(s)(ing), or destroy(s)(ing), or attempt(s)(ing) to do so, or, with intent to do so take(s)(ing) and carrie(s)(ing) away any record, proceeding, map, book, paper, document, or other thing, filed or deposited with any clerk or officer of any court of the United States, or in any public office, or with any judicial or public officer of the United States." 15. At all times material to this Demand For Indictment Title VII of the Civil Rights Act of 1964 (Title VII), SEC. 2000e-5. [Section 706] required "The Commission shall make its determination on reasonable cause as promptly as possible and, so far as practicable, not later than one hundred and twenty days from the filing of the charge." 16. At all times material to this Demand For Indictment South Carolina: Title 16 CHAPTER 5. Sec. 16-5-10 prohibited "two or more persons to band or conspire together", "to hinder, prevent, or obstruct a citizen in the free exercise and enjoyment of any right or privilege secured to him by the Constitution and laws of the United States or by the Constitution and laws of this State". Sec. 16-5-20 inclusive. 17. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 41 Sec. 872 prohibited "an officer, or employee of the United States or any department or agency thereof, or representing himself to be or assuming to act as such, under color or pretense of office or employment commits or attempts an act of extortion." 18. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 41 Sec. 875 prohibited "intent to extort from any person, firm, association, or corporation, any money or other thing of value, transmits in interstate or foreign commerce any communication containing any threat to injure the property or reputation of the addressee or of another." 19. At all times material to this Demand For Indictment TITLE 18 PART I CHAPTER 1 Sec. 3 required "Whoever, knowing that an offense against the United States has been committed, receives, relieves, comforts or assists the offender in order to hinder or prevent his apprehension, trial or punishment, is an accessory after the fact." The Conspiracy 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. Manner and Means of the Conspiracy 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. OVERT ACTS In furtherance of the conspiracy and to effect the objects thereof, the following overt acts, among others, were committed in the State of South Carolina, State of North Carolina and elsewhere: COUNT ONE EMAILS SENT FROM SANDERS TO DEFER DUE PROCESS, DENY DUE PROCESS AND THREATEN AND IMPEED DUE PROCESS. in violation of (Fraud by wire, radio, or television) U.S. TITLE 18 PART I CHAPTER 63 Sec. 1343 COUNT TWO EEOC RESPONDENT AFTER RECEIVING INFORMATION FROM GRAHAM'S OFFICE ABOUT ALLEGATIONS OF CRIMES WITHOUT REFERENCE TO THE CRIMES ALLEDGED AND IN ATTEMPT TO WITHHOLD DUE PROCESS AND COVER UP CRIMES COMMITTED AGAINST LAWS OF THE UNITED STATES AND REGULATIONS OF THE EEOC. in violation of (Aiding and Abetting) U.S. TITLE 18 PART I CHAPTER 1 Sec. 1. Sec. 2. COUNT THREE NAACP, SANDERS AND OTHERS IN EEOC AND FCC COMMIT OFFENSE AGAINST THE UNITED STATES BY INFLUENCE OF AN AGENCY OR AGENCIES TO PROHIBIT DUE PROCESS FOR ILLEGAL PURPOSES. in violation of (Conspiracy to commit offense or to defraud United States) U.S. TITLE 18 PART I CHAPTER 19 Sec. 371 COUNT FOUR EEOC, SANDERS, NAACP, FCC AND EEOC RESPONDENT CONSPIRE TO OPPRESS RIGHTS OF PLAINTIFF. in violation of (Conspiracy against rights) U.S. TITLE 18 PART I CHAPTER 13 Sec. 241 COUNT FIVE SANDERS WORKING UNDER COLOR OF LAW DEPRIVES RIGHTS AND PRIVILIDGES OF PLAINTIFF. in violation of (Deprivation of rights under color of law} U.S. TITLE 18 PART I CHAPTER 13 Sec. 242 COUNT SIX SANDERS GRABBING PLAINTIFF IN BEAR HUG OFF GUARD IN A PUBLIC PLACE TO INTIMIDATE PLAINTIFF. in violation of (Federally protected activities} U.S. TITLE 18 PART I CHAPTER 13 Sec. 245 COUNT SEVEN SANDERS HAS FALSIFIED RECORDS AT EEOC TO PROHIBIT DUE PROCESS. in violation of (Government seals wrongfully used and instruments wrongfully sealed) U.S. TITLE 18 PART I CHAPTER 47 Sec. 1017 COUNT EIGHT RESPONDENT FROM EEOC AND SANDERS AND PERSON OR PERSON AT FCC CONCEAL AND COVER UP TRICK AND SCHEME TO DEPRIVE CIVIL RIGHTS. in violation of (False Statements - Statements or entries generally) U.S. TITLE 18 PART I CHAPTER 47 Sec. 1001. COUNT NINE SAMDERS SCHEDULES FACT FINDING MEETING THEN CANCELS AT LAST MINUTE. IT IS BELIEVED THAT FACT FINDING MEETING TOOK PLACE AND RESULTED IN THE DEAL THAT SACRIFICED PLAINTIFF'S DUE PROCESS AND CIVIL RIGHTS IN ORDER TO SECURE SETTLEMENT FOR THOMPSON. in violation of (Tampering with a witness, victim, or an informant) U.S. TITLE 18 PART I CHAPTER 73 Sec. 1512. COUNT TEN SANDERS AT DESCRETION OF NAACP AND FCC AT DESCRETION OF NAACP WITHHELD DUE PROCESS. in violation of (Obstruction of proceedings before departments, agencies, and committees) U.S. TITLE 18 PART I CHAPTER 73 Sec. 1505. COUNT ELEVEN PROPERTY IS CASH SETTLEMENT ACQUIRED BY PATRICIA THOMPSON WHICH WAS ACQUIRED FROM CRIMINALLY DERIVED DEPREVATION OF PLAINTIFF'S CIVIL RIGHTS. in violation of (Engaging in monetary transactions in property derived from specified unlawful activity) U.S. TITLE 18 PART I CHAPTER 95 Sec. 1957. COUNT TWELVE CLAIMS BY SANDERS IN EMAIL TO THE CONTRARY OF RECORDS SUBMITTED TO EEOC INDICATES EITHER TAMPERING WITH EVIDENCE (ESPECIALLY THE FORM 5 OF THOMPSON) OR LIEING ABOUT IT AND WITHHOLDING ACCESS. FCC RECEIVES THEN DESTROYS COMPLAINT THREE TIMES AFTER DOCUMENT IS GIVEN TO DARBY BY THOMPSON TO SEND TO WASHINGTON. in violation of (Concealment, removal, or mutilation generally of RECORDS AND REPORTS) U.S. TITLE 18 PART I CHAPTER 101 Sec. 2071. COUNT THIRTEEN IT HAS NOW REACHED DAYS WITHOUT A DETERMINATION, WITHOUT A FACT FINDING MEETING, WITHOUT JUSTICE OR DUE PROCESS. in violation of U.S. Title VII of the Civil Rights Act of 1964 (Title VII), ENFORCEMENT PROVISIONS SEC. 2000e-5. [Section 706] (b),((e) (1)) COUNT FOURTEEN ALL DEFENDANTS. in violation of S.C.: (Conspiracy against civil rights.) Title 16 CHAPTER 5. Sec. 16-5-10 COUNT FIFTEEN ALL DEFENDANTS. in violation of S.C.: (Punishment for commission of additional crimes.) Title 16 CHAPTER 5. Sec, 16-5-20 COUNT SIXTEEN SANDERS EXTORTS (Illegal use of one's official position or powers to obtain property, funds, or patronage.) in violation of (Extortion by officers or employees of the United States) U.S. TITLE 18 PART I CHAPTER 41 Sec. 872 COUNT SEVENTEEN SANDERS EXTORTS LM COMMUNICATIONS FOR MONEY IN LEW OF PLAINTIFF'S CASE AND KILLS PLAINTIFF'S CASE AFTER AGREEMENT. MONEY PAID FROM KENTUCKY TO SOUTH CAROLINA. in violation of (Interstate communications) U.S. TITLE 18 PART I CHAPTER 41 Sec. 875 COUNT EIGHTEEN RESPONDENT FROM EEOC AFTER INCIDENTS. LM COMMUNICATIONS, MARTIN ET.AL. AFTER CONSPIRACY HATCHED. in violation of U.S. (Accessory after the fact) TITLE 18 PART I CHAPTER 1 Section 3 PARTICULARS 1. This document is in accordance with South Carolina SECTION 17-19-20. "Every indictment shall be deemed and judged sufficient and good in law which, in addition to allegations as to time and place, as required by law, charges the crime substantially in the language of the common law or of the statute prohibiting the crime or so plainly that the nature of the offense charged may be easily understood and, if the offense be a statutory offense, that the offense be alleged to be contrary to the statute in such case made and provided." 2. Title 29, Volume 4, Sec. 1600.101 Cross-reference to employee ethical conduct standards and financial disclosure regulations. "Employees of the Equal Employment Opportunity Commission (EEOC) are subject to the executive branch-wide Standards of Ethical Conduct at 5 CFR part 2635, the EEOC regulation at 5 CFR part 7201, which supplements the executive branch-wide standards, and the executive branch-wide financial disclosure regulations at 5 CFR part 2634. A GRAND JURY IS DEMANDED TO INVESTIGATE THESE CHARGES AND RETURN INDICTMENTS AND THE ATTORNEY GENERAL OF THE UNITED STATES OF AMERICA IS DEMANDED TO PROSECUTE THESE AND OTHER CHARGES THAT MAY BE FORTHCOMING FROM JUST INVESTIGATION. A GRAND JURY IS REQUESTED TO INVESTIGATE THE EQUAL EMPLOYMENT OPPORTUNITIES COMMISSION, THE FEDERAL COMMUNICATIONS COMMISSION AND THEIR INDIVIDUAL AND JOINT INFLUENCE BY THE NAACP AND OTHER OUTSIDE ILLEGAL INTERFERENCE. PLAINTIFF EXPECTS IMMEDIATE ACTION ON THESE CHARGES FROM ALL JURISDICTIONAL VENUES.