OCTOBER 2004 AMENDMENT TO CIVIL CASE 02-1052
Plaintiff Bell is unable to interface with co-plaintiff and paralegal Charles Bruce, Stewart, in the brief time allotted to do this amendment.  Bell would, if he could, re-edit the original Complaint to include this new material, but the court's Order to act within 30 days (actually, 18 days if a 7-day delay to actually mail the document, as well as a 5-day delivery delay, are factored in.)
Bell re-alleges all portions of the July 14, 2003-filed complaint, including those previously purported to have been
dismissed without prejudice.  Then, the following amendment material is ADDED, cumulatively, to that re-alleged original filing.
LIST OF DEFENDANTS ADDED
Anna Brown, Judge, is added in her individual, official, color-of-law, administrative, ministerial, co-conspirator, and agent of the conspiracy roles.
Garr M. King, Judge, is added in his individual, official, administrative, ministerial, color-of-law, co-conspirator, and Jonathan Solovy, attorney, is added in his individual, official, color-of-law, co-conspirator, and agent of the conspiracy roles.
Attorney Catherine Floit, is added in her individual, official, color-of-law, co-conspirator, and agent of the conspiracy roles.
A male attorney, possibly named "David Bukey", who was apparently temporarily assigned to Bell on or about July 2000, is added in his individual, official, color-of-law, co-conspirator, and agent of the conspiracy roles.
Law firm Bell, Flegenheimer, and Solovy (currently Bell, Flegenheimer, and Vance), as well as its partnership list, is added in its corporate, partnership, individual, official, color-of-law, co-conspirator, and agent of the conspiracy roles.
Attorney John Ransom is added in his individual, official, color-of-law, co-conspirator, and agent of the conspiracy roles.
At least nine (9) unknown-named persons, acting in part as Circuit Judqes of the Ninth Circuit Court of Appeals, but also acting in other non-judicial and non-jurisdictional capacities, are added in their individual, official, color-of-law, administrative, ministerial, co-conspirator, and agent of the conspiracy roles.
The unknown-named Attorney-General of the state of Washington, in his capacity as legal representative of that state, and his individual, official, color-of-law, co-conspirator, and agent of the conspiracy roles, pursuant to the practice of Ex Parte Young (Supreme Court 1908).
COUNTIES, COUNTY AGENCIES, AND MUNICIPALITIES: Clackamas County, Washington, Clackamas County Sheriff,
Clark County Sheriff, Clark County Washington, Vancouver
Washington
Pierce County, Washington, Pierce County Sheriff
(some of which have already been named in the July 14, 2003-filed
As well as unknown-named and previously-named agents of each of of the above cities, counties, and county agencies.
PRIVATE CITIZENS AND NEWS MEDIA
complaint) .

-Columbia Broadcasting System (CBS), an electronic broadcaster in
e. New York City, transmitting to Portland Oregon and other Oregon
locations, and producers of the program 60 Minutes; employees Adam Ciralsky and Tricia Sorrells.
Vancouver Columbian Newspaper, published in Vancouver Washington and distributed in Multnomah County, Oregon; its employee John Branton in his individual and employee capacities.
Portland Oregonian Newspaper, published in Multnomah County, Oregon; its employee Mark Larrabee in his individual and employee capacities.

Jessica Stern, employee of and associated with the "John F. Kennedy School of Government, Harvard University (Cambridge, Massachusetts) in her individual capacity.
The New York Times newspaper, distributed in Oregon; its editorial-page columnist, Nicholas Kristoff.
Wired News, Internet news media organization, distributed in Oregon, and former employer of Declan McCullagh.
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CNET electronic news organization, current employer of Declan
McCullagh, transmitting news and information on the Internet to
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Oregon locations.  And, Declan McCullagh in his individual and employee capacities.
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(end of list of added defendants)
ABSOLUTE IMMUNITIES
The Supreme Court has repeatedly held that "absolute immunities" to civil monetary damage awards are justified by the availability of "alternative" and "collateral" remedies. Examples are: "appeals", bar-association ethics complaints, and judicial ethics complaints.
The Supreme Court holds that absolute immunities are WAIVABLE and the burden is on the official claiming them to provide proof to support that claim in his specific case and circumstances.  Almost always, the existence of these alternative remedies is not challenged by plaintiffs, and thus the issue is not raised to the court, or decided.  However, in this specific case, that is not true.
This Amendment contains a new assertion:  That in the specific circumstances and events associated with this Complaint, NONE of the usual "alternative" or "collateral" remedies function.  Further, some and perhaps all of them have been corruptly thwarted and wrongfully obstructed by the instant civil defendants and others.  Therefore, this amendment claims a highly unusual fact pattern contrary to those on which absolute immunity depends, facts which must now be found by a jury, and cannot be found by a judge.
Plaintiffs need not argue that these remedies do not work for ANYONE, ever.  Rather, Bell asserts that in the extraordinary specific factual and legal situation of his "criminal cases" and
civil cases 01-1085 and 02-1052, Bell's exercise of alternative remedies is futile for reasons of pervasive corruption.
In order for absolute immunities to be granted absent a jury finding of availability of alternative remedies, it would be necessary for a court to rule that REGARDLESS of the lack of alternative remedies, absolute immunities apply.  That would be contrary to over 130 years of Supreme Court law, since before Bradley v. Fisher (Supreme Court, 1872) .
Also, absolute immunities do not apply to an official sued in its official capacity.  Example: a court, sued as a court, not a judge.  The only immunities that would apply to that situation are those of the parent body, and the Federal government has waived sovereign immunity by failing to raise the issue in a timely (or even an UNtimely) Rule 12 motion.  Bell has sued numerous federal government employees in their official capacities, which in reality is a suit against the Federal government.  Nor do absolute immunities apply to declaratory and injunctive relief as are sought here.
PERSONNEL SELECTION DOESN'T MERIT ABSOLUTE IMMUNITY
Forrester v. White (Supreme Court, 1988) held that even when a judge was the only person who could select or fire court personnel, those decisions did not merit absolute immunity.  The July 14, 2003-filed Complaint, amended by this amendment, contains allegations of wrongful assignment of corrupt appointed
attorneys, of failure to assign, and refusal to de-assign or replace, and of their wrongful de-assignment, by Judges Burgess, Tanner, and Brown, as well as at least one panel of the Ninth Circuit Court of Appeals. Therefore, they do not have absolute immunity for those decisions.
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ELEVENTH AMENDMENT IMMUNITY WAIVABLE
The State of Washington has acted to waive its Eleventh
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Amendment immunity by various actions with respect to the events related to the negotiations for, planning of, construction of, and operation of Seatac FDC jail.  Washington state has accepted Federal funds and other federal benefits, accepted federal-court adjudication of disputes relating to that installation, including on construction or operation, including liability.
The State of Washington is apparently the de-jure landlord of that property, and has accepted and allowed activities on that land by its tenant that are illegal and in violation of the
Washington Constitution, as well as the US Constitution.  The
State of Washington has or will accept the valuable preservation
and maintenance of that property virtually indefinitely, as well as the employment benefits which accrue to Washington State citizens, and the resulting tax benefits due to Washington as a consequence of its receipt of employment and income taxes, as well as sales taxes paid by Washington residents who work at Seatac FDC.  Further, the State of Washington demands from Seatac FDC and accepts and receives sales taxes, including cigarette taxes, on items sold to the captive audience of inmates involuntarily held in that facility.
The State of Washington has ceded day-to-day control of the property on which Seatac FDC was built, but cannot evade all of its responsibility for those events.
Further, the State of Washington has no Eleventh Amendment immunity for violations of the Thirteenth Amendment, or the Fourteenth Amendment, or of 42 USC 2000e, et seq, Equal Employment Opportunity Act, and this amendment includes such violations as described below.
Bell was subjected to slavery during his stay at Seatac FDC and subsequently at other locations  (Phoenix FCI, Lompoc USP, and Atwater USP) as an ostensible product of events occurring while Bell was wrongfully confined at Seatac FDC.
Further, in compliance with the principles of Ex Parte Young (Supreme Court 1908), to obtain declaratory and future injunctive relief, this amendment names the unknown-named Washington State Attorney General as a defendant.  One of these forms of prospective relief demanded is that both the Federal Government and Washington State relinquish all control over Seatac FDC, at least until the expiration date of the lease in question, and that it be put into the hands of the plaintiffs or their heirs, designees, and lessors for as long as they desire to exclude
CLAIMS CLAIM 500
Pursuant to Monell (Supreme Court 1963?), plaintiffs allege that co-conspirator and defendant Portland Police Bureau and the City of Portland engage in a pattern and practice of corruptly and wrongfully cooperating with and assisting the Federal Government and federal agents knowing that those agents are engaging in, and asking state and local agents to engage in, illegal actions.  And, they cooperated and continue to cooperate with those federal agents without adequate verification that those activities and tasks are legal, proper, and not motivated by improper or illegal motives.  The agents of this defendant acted pursuant to this improper and wrongful pattern and practice, and they caused and allowed constitutional violations and other harms to occur to plaintiffs, as well as wrongfully concealing and continuing to conceal from plaintiffs the fact of the illegal and improper activities.  Plaintiffs were harmed by this wrongful practice.
CLAIM 501
Pursuant to Monell (Supreme Court 1963?), plaintiffs allege that co-conspirator and defendant Clackamas County Sheriff and Clackamas County, Oregon, agents engage in a pattern and practice of corruptly and wrongfully cooperating with and assisting the
are engaging in, and asking state and local agents to engage in, illegal actions.  And they cooperated and continue to cooperate with those federal agents without adequate verification that those activities and tasks are legal, proper, and not motivated by improper or illegal motives.  The agents of this defendant acted pursuant to this improper and wrongful pattern and practice, and they caused and allowed constitutional violations and other harms to occur to plaintiffs, as well as wrongfully concealing and continuing to conceal from plaintiffs the fact of the illegal and improper activities.  Plaintiffs were harmed by this wrongful practice.
CLAIM 502
Pursuant to Monell (Supreme Court 1963?), plaintiffs allege that co-conspirator and defendant Clark County Sheriff, Clark County Washington, and City of Vancouver engage in a pattern and practice of corruptly and wrongfully cooperating with and assisting the Federal Government and federal agents knowing that those agents are engaging in, and asking state and local agents to engage in, illegal actions.  And, they cooperated and continue to cooperate with those federal agents without adequate verification that those activities and tasks are legal, proper, and not motivated by improper or illegal motives.  The agents of this defendant acted pursuant to this improper and wrongful
violations and other harms to occur to plaintiffs, as well as wrongfully concealing and continuing to conceal from plaintiffs the fact of the illegal and improper activities.  Plaintiffs were harmed by this wrongful practice.
CLAIM 503
Pursuant to Monell (Supreme Court 1963?), plaintiffs allege that co-conspirator and defendant Pierce County Sheriff and the Pierce County, Washington, engage in a pattern and practice of corruptly and wrongfully cooperating with and assisting the Federal Government and federal agents knowing that those agents are engaging in, and asking state and local agents to engage in, illegal actions.  And they cooperated and continue to cooperate with those federal agents without adequate verification that those activities and tasks are legal, proper, and not motivated by improper or illegal motives.  The agents of this defendant acted pursuant to this improper and wrongful pattern and practice, and they caused and allowed constitutional violations and other harms to occur to plaintiffs, as well as wrongfully concealing and continuing to conceal from plaintiffs the fact of the illegal and improper activities.  Plaintiffs were harmed by this wrongful practice.
CLAIM 504
At an unknown time, but about June 1999, Franklin Burgess,
prosecutor Rob London, attorney Judith Handel, three unknown-named Circuit Judges of the Ninth Circuit Court of Appeal, Peter L. Shaw (appellate commissioner), and the clerical personnel of the Ninth Circuit Court of Appeals, as well as other unknown-named personnel, wrongfully colluded and agreed to illegally deny Plaintiff Bell's right to an appeal (as well as all other alternative or collateral remedies) and all his other constitutional rights on a probation revocation case began in June 1998 and ostensibly culminated in a two-day hearing in May/June of 1999.
At an unknown time but about June 1999, these personnel agreed to act, and acted, to wrongfully and illegally deny Bell an appointed attorney, and to forge and concoct false and misleading court records (including at Tacoma Washington and in the Ninth Circuit Court of Appeals) which falsely asserted that Bell was about to be, would be, was, and had been given the benefit of an "appeal" in the Ninth Circuit Court of Appeals.
CLAIM 505
Acting on secret orders from the conspiracy, co-conspirator Mandel filed a "Notice of Appeal" in case 00-5270, on or about June 20(?) 1999, but she and these conspirators agreed to, and did, wrongfully keep that fact from Bell for an extended and indefinite period that they then intended would last forever.
appeals court records to be assigned the secret code number 99-30210, resembling that of a typical Ninth Circuit Court Appeal case, and intending and agreeing to later misrepresent these records as if they had been a genuine appeals-court case.
CLAIM 506
In violation of Ninth Circuit precedent (US v. Dangdee, 1979?), these conspirators, and especially Judge Burgess, agreed to act, and acted, to "allow" attorney Mandel to resign from Bell's representation, wrongfully without replacement, in order to obstruct Bell's right to counsel and his right to assistance that would have allowed him to discover the ongoing fraud.
The conspirators then recruited unknown-named personnel, including those of the Federal Bureau of Prisons, who agreed to and did steal and fail to deliver to Bell all mail that would be sent to Bell from the Tacoma Federal Court, as well as the Ninth Circuit Court of Appeals.
CLAIM 507
The conspirators corruptly fabricated at least two "certified mail receipts", written on forms printed and distributed by the US Postal Service, with the intent and agreement that they would be attached to at least two pieces of "legal mail" sent from the Ninth Circuit Court of Appeals, to the facility then holding Bell:  Phoenix FCI, a federal prison.  They did so.
CLAIM 508
Then, unknown-named conspiring personnel, apparently personnel of the Federal Bureau of Prisons, acted and agreed to act to conceal those received mail packages from Bell, contrary to their obligations to deliver them, and then to forge and falsify writings on those attached "certified mail receipts" to falsely assert and represent that Bell had received those pieces of "Certified Mail", when they knew he had not.  The conspirators had agreed, and then they acted, to return those false and forged receipts to the hands of the post-office employee, with the knowledge and intent of all co-conspirators that those false records would be returned to the Ninth Circuit Court of Appeals, and that those records would be placed within and amongst those of "case 99-30210", thereby falsely reflecting that Bell had obtained those records.
CLAIM 509
At an unknown time, unknown-named conspirators and defendants agreed to forge, and subsequently did forge, a 1/3-page handwritten note, purportedly signed by Bell, but not in Bell's handwriting style, purporting to be a letter to the Ninth Circuit Court of Appeals, dated on or about August 5, 1999.  This document was forged with the intent that it would falsely "prove" that Bell was then aware of the existence of case 99-30210, and was participating in that case, when Bell was not.  The unknown-named forger(s), as well as the other conspirators, agreed and acted to transmit that forged note to the Ninth Circuit Court of Appeals, intending and ensuring that it would be placed among the other false and misleading documents of "case 99-30210" already present.
CLAIM 510
Further, at unknown times, unknown-named personnel of the Ninth Circuit Court of Appeals, acting on the corrupt and illegal orders of the conspiracy, agreed to act and acted to forge, falsify the record of events in "case 99-30210", a document known as a "docket".  These Ninth Circuit personnel agreed to and did continually add false records to that docket, and at various times they deleted some of those false records and substituted new false records, for the purposes of concealing the true events and for continuing to obstruct Bell's access to justice and his constitutional rights.
CLAIM 511
In April 2000, Bell was released from Phoenix FCI.  Unaware of the existence of "case 99-30210", in or about May 2000, Bell contacted the Ninth Circuit Court of Appeals, by letter, to demand an "appeal" on that probation-revocation case.  In
response, unknown-named Ninth Circuit Court personnel acted to recruit the assistance of a corrupt attorney to be collusively assigned to Bell, intending and agreeing that this attorney would assist the conspiracy by helping to concoct a false "appeal" of that case, the illusion of proper adjudication, which unknown-named Ninth Circuit Court Judges had already agreed to wrongfully deny.
CLAIM 512
The first assigned corrupt attorney, who had agreed to assist in the violation of all Bell's constitutional rights and to assist the conspiracy in every illegal manner and means, was Catherine Floit.  Acting on orders of the conspiracy, she communicated with Bell in a single telephone call June/July 2000, intending and having agreed to mislead and gull Bell into thinking that Floit would properly handle the appeal. Discovering during that telephone call that Bell was unalterably intent on discovering the corruption and illegal and fraudulent acts by people, people who had become her newly-adopted co-conspirators, and now knowing that Bell intended to research the law and facts and sue them, Floit failed to disclose to Bell the conspiratorial activity then occurring against him, nor her participation in it.  This violated Floit's ethical and legal obligations to Bell.
Floit abruptly terminated the conversation.  Floit then
called her co-conspirators, unethically repeated to them everything Bell had said in violation of Bell's attorney/client confidentiality rights, alerting and informing them that Bell would have to be stopped or disabled in some way.
Separately, in order to "explain" and "justify" her failure to continue with that case, Floit then made intentionally false public assertions, including to those that had overtly assigned her to the case, that Bell had somehow threatened her, as that was the "only" practical way at that time to "explain" her withdrawal from the case.  Floit knew that the only "danger" she faced, and in fact a very real danger, was that her wrongful actions would be discovered and she would be sued, as she has
now.
CLAIM 513
During 2000, the co-conspirators, alerted by Floit's warning, engaged in an effort to discover what Bell was learning and doing, and they agreed to impede and stop Bell's access to any court or other legal remedy he attempted to use.  They also agreed and acted to illegally misuse the governmental tools available to them to seize and obstruct Bell from his efforts, and to rob from Bell valuable evidence that Bell had collected with the intent of bringing legal cases against them.
CLAIM 514
A second attorney, possibly named David Bukey, was then assigned to Bell's "appeal case" 99-30210, having agreed to violate each and all of Bell's rights and to assist the conspiracy in every wrongful and illegal way.  However, Bukey got "cold feet" and he did not contact Bell.  Bukey sought to withdraw from the case, and he did so.  Bukey did not fulfill his ethical obligation and disclose to Bell the ongoing conspiratorial activity that he had agreed to further, with the intent to cover up his involvement and to impede Bell's efforts to protect all his constitutional rights.
CLAIM 515
Attorney Jonathan Solovy was then assigned in July/August 2000.  Solovy agreed to act, and did act, on orders of the conspiracy, to conceal from Bell the prior (June 99 through May 2000) existence of case 99-30210, and to help provide the illusion of adjudication of an "appeal" case.  To do this, he agreed to fraudulently prepare a fraudulent, deficient, and ineffective "appeal brief" that unknown-named Ninth Circuit Court Judges had already agreed to deny.
CLAIM 516
During the period of 2000-2001, Solovy prepared and filed that document, and he continued to gull and mislead Bell, and did not disclose to Bell the ongoing corrupt conspiracy of which Bell was a continuing victim.  On denial of the appeal, Bell told Solovy that the resulting "Opinion" contained many false statements purporting to be "facts", when they were not factual.
Solovy then failed and refused Bell's request to ask the personnel of the Ninth Circuit to correct those false assertions, and to reconsider the opinion in the light of the corrected information.  Later, Solovy filed a knowingly-inadequate "Petition for a Writ of Certiorari" which omitted facts and argument which would have revealed the conspiracy and its effects, which impeded Bell's access to the courts.
CLAIM 517
On or before November 19, 2000, the co-conspirators agreed to act, and did on that day act, to retaliate against Bell for his efforts to research the various violations of Constitutional rights, including the violations of anti-slavery laws and rules (Such as the Thirteenth Amendment, and 42 USC 2000e et seq). They agreed to act and acted harass Bell, and to retaliate against and impede Bell by making Bell into an involuntary employee, ostensibly of the Federal government (BOP), and provide the illusion of propriety by paying him negligible wages and confine him 24 hours per day.  They also agreed to obstruct and impede Bell's access to the courts, guaranteed under the First Amendment, by means of enslaving him in violation of the Thirteenth Amendment to the US Constitution.
Such a violation is privately actionable, but it was also a violation of 42 USC 2000e-3 (?).  The co-conspirators agreed and acted to kidnap Bell and to eventually take him to Seatac FDC, where they did so enslave and oppress him.  This slavery and oppression occurred and have continued up to through the filing date of this amendment.

CLAIM 518
Later, in 2004, co-conspirator Anna Brown violated Bell's right to an appointed attorney under 42 USC 2000e-5(f)(1)(B) to prepare a claim of employment harassment, retaliation and wrongful imposition of slavery.

CLAIM 519
Due to Bell's filing on March 27, 2001 of an interlocutory appeal notice which became case 01-30143, the resulting April 3-10 purported "trial" was then and now known by all government-employed observers and participants, to be without jurisdiction, and a fraudulent and corrupt "stage play" intended to mislead and gull the public and Bell into the belief that Bell had received a fair trial.
CLAIM 520
Bell filed civil action 01-1085KI in Portland Federal Court
date, the conspiracy recruited another co-conspirator, Garr M. King, acting in all his capacities, for the purpose of obstructing that civil action, and they did so.  King agreed to act, and did act, to wrongfully, illegally and secretly dismiss case 01-1085KI on September 12, 2001, for numerous intentionally erroneous reasons.

CLAIM 521
Acting according to his prior conspiratorial agreement, King agreed and acted with his co-conspirators (including clerks) to conceal the fact of that dismissal from Bell, which they accomplished by either intentionally failing to mail to Bell a copy of that dismissal, or they mailed that dismissal and co-conspirator personnel of Seatac FDC agreed to and did steal or fraudulently non-deliver that dismissal Order to Bell.
Unaware of the dismissal, Bell filed a motion for a default judgment, and two requests for a docket, to Portland Federal Court, to only one of the latter did Bell receive any return mail.  This was accomplished either by not mailing a return, or by the intentional failure of the conspiring BOP personnel to forward and/or deliver that mail to Bell.
CLAIM 522
In mid-Jan 2002, Bell received a docket for case 01-1085KI, and days afterwards a copy of the Sept 12, 2001 dismissal Order. Bell responded with what should have been construed as a Motion for reconsideration.  King further acted to conceal the impropriety of the dismissal, its errors, and his role in it, by wrongfully ignoring that Motion and suppressing it for almost
three months.

CLAIM 523
Having discovered on or about January 31, 2002, that attorney Juergens was ignoring jurisdictional appeal case 01-30296, and was hijacking and sabotaging non-jurisdictional case 01-30303, Bell began to write complaint filings to the Ninth Circuit Court of Appeals, informing them that case 01-30303 was non-jurisdictional and moot, and informing them of Juergens' sabotage. Bell also asked for a replacement for Juergens. Unknown-named co-conspirators, including at least three appeal panel judges and three Motions panel judges, as well as Peter L. Shaw (appellate commissioner"), despite their lack of jurisdiction over case 01-30303 (and, thus, lack of civil judicial immunity under Rankin v. Howard (9th Cir 1980)), proceeded to follow their conspiratorial agreement and to ignore Bell's valid complaints.  They wrongfully allowed Juergens to ignore case 01-30296, and to sabotage case 01-30303.

CLAIM 524
As a consequence of their failure to disclose it to Bell and others, the conspirators had been illegally recording Bell's phone calls and sharing their contents with persons outside the Atwater prison.  On an unknown date, but no later than the first two weeks of May, 2002, the co-conspirators discovered that Bell had delivered to David Harris, then acting as Bell's paralegal, an extensive draft constituting the beginnings of a successor action to case 01-1085KI.  The conspirators also learned that
Harris was beginning work on editing that document for Bell, and that Bell intended to later file it as a successor lawsuit.  The co-conspirators, in order to "cover their tracks" concerning Bell's unanswered motion for reconsideration, recruited a new co-conspirator, Anna Brown, to corruptly forge a document, belatedly purporting to be an Order responding to the Feb 13 2002 motion, but in fact ignoring and suppressing the large majority of that document including the challenges to the merits of the dismissal. Brown dealt only with Bell's request that case 01-1085 be transferred to a different judge, and she obstructed that request.
CLAIM 525
The conspirators agreed to file that forged document in case 01-1085 as if it were genuine, and did so on or about May 14, 2002, but they also acted to prevent that document from being mailed (as it would normally have been) to Bell.  Or in the alternative, it was mailed, and other co-conspirators at USP Atwater or elsewhere agreed to act and acted to fail to forward it, or steal or non-deliver that document to Bell. This was done to prevent Bell from knowing about it and to prevent Bell from appealing that purported "Order".  This obstructed, and was intended by all co-conspirators to obstruct, Bell's access to the courts, and to the "alternative remedies" which might otherwise support civil judicial and other immunities.

CLAIM 526
At an unknown date, but in early May 2002, the conspirators including Anna Brown agreed that Bell would be obstructed and impeded from editing, filing, maintaining, amending, prosecuting, or trying that case in the usual way to which Bell and his co-plaintiffs had a right.  Anna Brown agreed to seize control of Bell's and plaintiffs' upcoming civil case whenever it appeared in Portland Federal Court.  Brown agreed to then repeatedly wrongly and illegally rule against it to obstruct and defeat that case.  Brown agreed to this before she had a judicial role in that case.
Acting according to her prior conspiratorial agreement, Anna Brown agreed to engage in a SIMULATION of a legal process, the illusion of an adjudication which was not actually occurring. The conspirators and Brown agreed that it was necessary, as a part of this simulation process, to prevent and defeat the critical "adversarial" nature of the American justice system, and they acted to do so.  They agreed that the co-plaintiffs would be denied any and all professional representation, without regard to plaintiffs' rights under all laws and rules, and the co-conspirators have since acted at all times to achieve this, and have done so.
CLAIM 527
On unknown time and dates, but in or before 2002, agents of
the conspiracy corruptly approached David Harris, then acting as Bell's paralegal, and interfered with Bell's business relationship with him, and wrongfully induced Harris to secretly delay and obstruct the editing process.  They also wrongfully dissuaded Harris from using his ordinary and expected paralegal expertise from identifying and reporting document errors, omissions, and deficiencies in the ongoing editing process, and inducing Harris to fail to act in his capacity as paralegal to ensure that the Complaint was properly ready to file.  The co-conspirators also induced Harris to unnecessarily delay the editing process, intending to delay the filing, as they had learned that Bell had intended to sue and serve co-conspirator Peggy Sue Juergens.   Bell had informed Harris that he wanted Harris to file the lawsuit naming Juergens, and to serve it on Juergen in plenty of time to stop her from participating in oral arguments in that appeal case.  Harris intentionally delayed the filing and service on Juergens of the case, which became case 02-1052BR.  Harris delayed filing and service to "the last minute", intending and agreeing with the conspirators that this delay would be used allow Juergens to further inflict herself on Bell,
and also to allow her to falsely claim that she hadn't known of the suit or the service.  This delay was also intended to help
the conspirators "steer" the complaint to Anna Brown, and it helped them do so.  Harris served the suit in a manner calculated to allow Juergens to claim it was served inadequately or late.

CLAIM 528
The document Harris eventually did file was defective and deficient, and acting on orders of the conspiracy, Harris then ceased to cooperate with Bell to correct it in any way.  Bell concluded it should not be served on any other defendant in its then-current form, so it was not.
CLAIM 529
Co-conspirator Anna Brown acted, pursuant to her prior and ongoing conspiratorial agreement, to seize control of this case, by means of wrongfully causing it to be assigned to her caseload, by Harris' timing of the filing.
CLAIM 530
On or about August 5, 2002, that document was filed and served on Juergens at her usual place of work, and she was made aware of that filing and the resulting conflict of interest. Nevertheless, on or about August 6, 2002, acting on orders of the conspiracy, she, co-defendant McKay, and three unknown-named conspirators including three unknown-named appeals judges acting purportedly in an "appeals panel" participated in a fraudulent simulation of an "oral argument" despite their knowledge of the non-jurisdictional nature of case 01-30303.
They acted, secretly knowing that attorney Juergens could not act for Bell due to a conflict of interest engendered by the
lawsuit served on her the previous day, and they concealed their overt knowledge of that fact in order to make it appear in the record that it was proper to proceed.
CLAIM 531
On July 14, 2003, a new Complaint, heavily edited from the August 2002 filing, was filed in Portland Federal Court, which was also given the case number 02-1052.  This is that case.  The co-conspirators agreed and acted to suppress and obstruct this case, and they continued to do so.
CLAIM 532
During and after July 14, 2003, Anna Brown, acting on orders of the conspiracy, agreed to act and acted to ignore the portion of the instant complaint claiming "Great Writ" habeas corpus jurisdiction, 28 USC 2241.  She did this for the wrongful purpose of forcing Bell to remain in prison, and to allow her co-conspirators (including the Federal BOP) to continue to accomplish that illegally.
CLAIM 533
On an unrecollected date, perhaps in October or November 2003, pursuant to her prior conspiratorial agreement, Anna Brown obstructed the progress in case 02-1052 by means of wrongfully failing to approve, and in fact denying, class-action status for
this case, for the specious reason that the class was not represented.  Less than 10 days after that Order was issued, new amendments to the Federal Rule of Civil Procedure 23 came into force, requiring a judge to appoint class counsel for a class. Bell, having received the Order days after those amendments came into force, immediately filed a Motion for Reconsideration citing this change in law.  Anna Brown wrongfully failed and refused to correct her ruling and grant class status; nor did she appoint class counsel.
CLAIM 534
Brown wrongfully made false assertions that plaintiffs had not alleged common fact and law applying to the class members, when in fact Bell had done so.
CLAIM 535
On an unrecollected date but in 2004, Anna Brown, acting pursuant to her conspiratorial agreement, obstructed Bell's right to an appointed attorney under statutes 18 USC 3006A and 42 USC 2000e-5(f)(1)(B).  Brown made false statements purporting to justify her position, including intentionally and wrongfully misrepresenting the nature of Bell's Equal Employment claim and wrongfully summarily rejecting it, and ignoring Bell's allegation of slavery within the meaning of the 13th Amendment.  Brown also misrepresented and wrongfully denied Bell's correct argument that he had a right to an attorney due to the fact that he had not yet been tried.
CLAIM 536
In addition, Brown wrongfully denied Bell and the other co-Plaintiffs an attorney under statute 28 USC 1915, purported based solely on the specious and false claim that the law in this case was not difficult, thus ignoring the numerous other reasons (other than the mere complexity of the law itself) that made the appointment of an attorney necessary in this case.
CLAIM 537
During 2003, and despite Bell's numerous letters to him, Solovy acted according to his prior conspiratorial agreement and failed and refused to cognize and deal with Bell's then recently-discovered evidence that "appeal case" 99-30210 had been a sham and had been concealed from Bell for at least 11 months between June 1999 and May 2000.  During the late 2003-early 2004 time frame, employees of the law firm "Bell, Flegenheimer and Vance" began to actively mislead and trick Bell into believing that Solovy would arrange to have his responsibilities transferred to another attorney, and that someone would handle necessary legal tasks, assertions which assisted Solovy in delaying Bell's relief.

CLAIM 538
On an unknown time in 2003, attorneys Peter Avenia, Judith Mandel, Robert Leen, and Peggy Sue Jurgens began to conspire for the purpose of violating their attorney-client confidentiality obligations to Bell.  They desired and agreed to unethically and wrongfully share privileged work-product information they had obtained as a product of their representation of Bell, employ it for purposes of harming Bell, and for manufacturing a false defense for themselves, and to protect themselves from being incriminated by the other attorneys, and for purposes of avoiding claiming inconsistent and contradictory defenses.  They wished and intended that material that one attorney had obtained, in confidence, would be secretly and unethically and illegally used to benefit all these attorneys.  They proceeded to engage in an unethical and illegal plan to obtain and share the legal services of an attorney, John Ransom, an Oregon attorney, agreeing with him and intending that they would deliver to Ransom such confidential materials and that Ransom would intermix and intermingle those materials, and so Ransom would secretly and improperly use those materials to craft the defenses and filings of all these attorneys.  They, and he, proceeded to do so, violating Bell's confidentiality rights.
CLAIM 539
Later, Bell complained, requesting Rule 11 sanctions and a
prohibition on this joint representation.  Anna Brown, acting pursuant to her conspiratorial agreement, failed and refused to grant Bell this relief to which he had a right.
CLAIM 540
On an unrecollected day in early 2004, attorney Solovy interfered with and violated Bell's right to an attorney by filing a motion to be relieved as attorney in case 99-30210. Solovy did this filing in Garr King's court, purportedly in case 00-5270, although King had not appointed him and King had no authority to relieve Solovy of his appeals-case obligations. Also, Solovy knew that Bell had sued King, and thus knew conflicted King could not ethically or legally rule on that issue.  See US v. Dangdee (9th Cir. 1979).
Garr M. King wrongfully interfered with Bell's right to an appointed appeal attorney to prepare a Rule 60(b) motion in case 99-30210, by means of issuing a purported Order allowing Solovy to withdraw.
CLAIM 541
Anna Brown, acting pursuant to her prior conspiratorial agreement, failed and refused Bell's request for an injunction against both Solovy and King, prohibiting them from interfering with Bell's right to counsel.

CLAIM 542
Anna Brown, acting pursuant to her conspiratorial agreement, also wrongfully dismissed the State of Washington, despite Bell's numerous and correct arguments requiring a decision to the contrary.
CLAIM 543
Before and during the period of April 1 and September 24, 2004, and according to her conspiratorial agreement, Brown wrongfully suppressed, and failed and refused to act on Bell's filed motions including his "Clerk's action" default judgment and his "Motion" for default judgment.  This was done to impede plaintiffs' access to those default judgments and to delay and impede collection of the defaulted defendants' assets, to obstruct plaintiffs' access to funds sufficient to successfully
prosecute this case.
CLAIM 544
Anna Brown failed and apparently refused to respond to Bell's Motion requesting that she intervene to establish that he is entitled to vote in the upcoming November 2004 elections, for the reason that he is not convicted of a crime and is not serving a "sentence".  This is a voting-rights violation, as well as being extraordinarily petty.

CLAIM 545
Subsequent to April I, 2004, Anna Brown, acting pursuant to her conspiratorial agreement, acted to further suppress progress on this case, by means of wasting nearly six (6) months of time: April 1 through September 24, 2004.  Brown, acting according to her conspiratorial agreement, Ordered plaintiffs to amend the Complaint within an already-highly-unreasonable thirty (30) days, and then she and unknown-named court personnel further acted to obstruct the plaintiffs' ability to amend by means of delaying the mailing to Bell of the September 24 Order, postmarking it
October 1, delaying its delivery to Bell on October 5, 2004.

CLAIM 546
Anna Brown proceeded to wrongfully purport to dismiss numerous classes of defendants from this case, based on false and specious reasons.  Brown ignored law and procedural requirements to do so.  Brown intentionally wrongfully applied 28 USC 1915A, inapplicable to non-prisoners, and she intentionally and wrongfully ignored Bell's factual pleadings which she was required to accept that he was not a prisoner within the meaning of that statute, and others which established that no defendant possessed "absolute immunity", and that the court had personal jurisdiction over each defendant.

CLAIM 547
Acting pursuant to her conspiratorial agreement, Brown ignored precedent which required "absolute-immunity"-seeking claimants to first, claim that immunity and second, to support their entitlement to that immunity.  Brown employed an illegal and highly-non-standard variation on the proper F.R.Civ.P. 12 adjudication, in which she first claimed to not be considering the large number of pending Rule 12 Motions, but she in fact not merely considered them, she also wrongfully and automatically accepted all their allegations as true.  Brown also ignored Bell's Responses to those Rule 12 Motions, a procedure wrongfully intended and calculated to ignore any of plaintiffs' successful support of the burdens of proof placed on them by certain Rule 12 Motion assertions.  Brown wrongfully failed and refused to apply the required standards to the Rule 12 matter, failing to "accept all allegations of material fact" of the non-moving party (plaintiffs).  Also, she did not "construe the pleadings liberally and afford[] the plaintiff the benefit of any doubt", despite her claim and cite to the contrary.
CLAIM 548
Brown has also wrongfully failed to deal with Bell's filing, being part a filing under "Great Writ" habeas corpus (28 USC 2241).
CLAIM 549
Acting pursuant to her conspiratorial agreement, Brown intentionally wrongly claimed that plaintiffs had not supported a civil-rights conspiracy under 42 USC 1985, when they had done so. Brown also wrongfully entirely ignored plaintiffs' claims under the Sherman Anti-Trust Act, 15 USC 1 et seq.
CLAIM 550
At an unknown time, but during or before January 2001, Adam Ciralsky and Tricia Sorrells, along with other unknown-named employees of CBS/60 Minutes, began to conspire with the government co-conspirators, especially Jeff Gordon.  These personnel agreed that Ciralsky would wrongfully and maliciously approach Bell, for the hidden purpose of later engaging in libel against Bell using their television newsmagazine as a conduit, and they did so.  Ciralsky approached Bell under false pretenses, amounting to Mail Fraud, and wrongfully induced Bell to make telephone calls to him, which is Wire Fraud, for purposes of assisting the government co-conspirators, whom Ciralsky knew or should have known were illegally recording these conversations.
Ciralsky and the Federal Bureau of Prisons then attempted to lure Bell into signing a "Media Waiver" form, intending to open up a further channel to libel Bell. These personnel were exposed to actual knowledge of the fact that Bell and other plaintiffs were victims of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop,
expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.
CLAIM 551
On an unrecollected-date day in August or September 2000, Vancouver Columbian newspaper reporter John Branton fraudulently offered to Bell that the Columbian would respond to, and cover, Bell's accusations against the government if he, Bell, would prepare and file a lawsuit against the government.  Bell immediately accepted this offer, and in Consideration  of this agreement and oral contract Bell continued his research.  Acting to fulfill his part of the agreement, Bell filed the first revision of his lawsuit in July 2001, sending a copy to The Columbian newspaper and John Branton, but the Columbian did not begin to publish such promised articles, acting in breach of their contract.
These personnel were exposed to actual knowledge of the fact that Bell and other plaintiffs were victims of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop,
expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.  The Columbian also published libellous articles containing false and misleading assertions about Bell.

CLAIM 552
On an unrecollected-date day in August or September 2000, Portland Oregonian newspaper employee Mark Larrabee fraudulently offered to Bell that the Oregonian would respond to, and cover, Bell's accusations against the government if he, Bell, would prepare and file a lawsuit against the government.  Bell immediately accepted this offer, and in Consideration of this agreement continued his research.  Bell filed the first revision of his lawsuit in July 2001, sending a copy to The Oregonian and Larrabee, but the Oregonian did not begin to publish such promised articles, acting in breach of their contract.
These personnel were exposed to actual knowledge of the fact that Bell and other plaintiffs were victims of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop, expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.
The Oregonian also published libellous articles containing false and misleading statements about Bell.
CLAIM 553
On an unknown date but apparently in 1998, Jessica Stern began to conspire with the conspirators, but especially Jeff Gordon, and agreed that she would approach and contact Bell by mail, which is Mail Fraud, for purposes of defrauding and misleading Bell of his cooperation, and for the purpose of later libelling Bell.  Subsequently, Stern engaged in this libel by
means of publishing a false and misleading book falsely referring to Bell and intentionally and libelously misrepresenting Bell's activities and intent.
Stern was exposed to actual knowledge of the fact that Bell and other plaintiffs were victims of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop, expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.
CLAIM 554
On an unrecollected date, but apparently in 2002, the New York Times published a libel of Bell, written by their regular editorial columnist Nicholas Kristoff, which was intentionally false, defamatory and misleading, and which also held Bell in a false light.
The New York Times and Kristoff were exposed to actual knowledge of the fact that Bell and other plaintiffs were victims  of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop, expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.
CLAIM 555
During an unknown period of time, but apparently including at least 2000 through 2003, Wired News and its reporter/employee Declan McCullagh were exposed to actual knowledge of the fact
that Bell and other plaintiffs were victims of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop, expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.
CLAIM 556
During an unknown period of time, but apparently including at least 2002 through 2004, CNET News and its reporter/employee Declan McCullagh were exposed to actual knowledge of the fact that Bell and other plaintiffs were victims of a civil rights conspiracy under 42 USC 1985, and they did not act to help stop, expose, or ameliorate that conspiracy:  This is a violation under 42 USC 1986.
(END OF NEW CLAIMS)
DAMAGES
Plaintiffs including Bell demand the following, in addition to damages listed in the original complaint:
(Add punitive damages equal sum of requested RICO and general damages.)
Anna Brown, $30 million in RICO+general damages, plus value of all damages sought in case 02-1052.
Garr King: $30 million in RICO damages; plus all damages sought
in case 01-1085.
Jonathan Solovy and Bell, Flegenheimer, and Vance:  $5 million in
RICO+general damages.
Catherine Floit: $250,000 in RICO+general damages.
David Bukey: $250,000 in RICO+general damages. John Ransom:  $500,000 in RICO damages
Unknown-named Ninth Circuit Justices:  $10 million in RICO+general (each).
Attorney General of Washington: Permanent injunction abrogating the contract of Seatac FDC, evicting the Federal government from premises of Seatac FDC; Placing that facility into the hands of the plaintiffs, their heirs, successors, designees, and lessors, until the date stated of the expiration of the original lease. Also, an Order requiring the State of Washington of digorge all income, employment, sales, and property taxes generated by Seatac FDC, its sales, employees, etc, from its inception, construction and operation until the expiration of lease, to be paid to plaintiffs.
Clackamas County: $1 million RICO+general Clark County  $5 million RICO+general
Portland Minimum $40 million RICO+general.
CBS/60 Minutes/Ciralsky: $10 million RICO+general.
Vancouver Columbian/Branton $1 million general.
Portland Oregonian/Larrabee $1 million general.
Jessica Stern $10 million general
New York Times/Kristoff $10 million general
Wired News/McCullagh $1 million general.
Unknown name/McCullagh $1 million general.

Signed, 
James' Dalton Bell, pro-se,

Signed,

Charles   Bruce,   Stewart 
Signed, _ Dated, Michael Hunter, pro-se,