The County of Santa Barbara had demonstrated so completely a conspiracy with the courts as well as other law enforcement agencies and the local newspapers, that there was only one place to go. Federal court.

damages for injury to his person or property, or because of the deprivation of any right or privilege of a citizen of the United States, by any act done in furtherance of any conspiracy mentioned in section 1985 of Title 42;

This complaint of violations of statute, UNITED STATES CODE, Title 42, Sec. 1985. "Conspiracy to interfere with civil rights" (2), (3) and Sec. 1983 "deprivation of rights" and Sec. 1981. "Equal rights under the law", is in the proper venue.

The County of Santa Barbara did collude with other official entities and with the Santa Barbara News Press, with the intent to remove Plaintiffs civil rights for the purpose of preventing plaintiff from utilizing effectively his right to free speech and to meaningfully share information concerning the County of Santa Barbara's neglect of duties as defined by state statute and the danger thereby created for the public; FIRST CAUSE OF ACTION. The County conspired with the city of Santa Barbara with reckless disregard for plaintiff, plaintiffs family and the public with knowledge of its tortuitous effects upon plaintiff, with the intent of violating public confidence, and failing to uphold state laws.

In a letter (EXHIBIT ONE) dated January 22nd 1997, plaintiff informed the County Board of Supervisors of the Nature of an old conflict between the local Native tribe of Chumash people and the County that began with the survey of the City of Santa Barbara then later became based in missing court case files of 1876 to 1884.

On Monday July 21, 1997, the Santa Barbara News Press published an articleon page, B1, (EXHIBIT TWO) called "Crusade to save street names". Part of the article concerns the street name Anapamu and gives erroneous, conflicting information to plaintiffs "common knowledge and verifiable facts" information provided to the supervisors that is supported by Chumash people as shown on the last page of EXHIBIT TWO, a plaque on Anapamu street in downtown Santa Barbara that has been in place since 1993 stating that the street refers to a remote hilltop and a winter solstice shrine. Neil Graffy is related to Jean Graffy, a member of the board of supervisors at the time of the article.

Plaintiff in the fall of 1997 received a call from Rhonda Parks (Manville) of the News Press concerning his civil action against the County of Santa Barbara , case 220298, and met with the reporter. The News Press refused to publish an article concerning the missing court case files that Christopher A. Brown had adequately documented.

On December 26, 1997 the News Press published an article (EXHIBIT THREE) "Point of Contention" 6 days after Plaintiffs letters to county agencies and schools (EXHIBIT FOUR) as well as other county departments informing them of hypnotic activities being conducted, on the public and children, unconsciously, by Natives or others in the County, in violation of state laws and causing extreme behaviors or dangerous conditions for the public. The defendant Santa Barbara News Press, acting in collusion with the County of Santa Barbara, used its influence to confuse and diminish the plaintiffs right to free speech, obviously in that it was the County that had been informed by the plaintiffs letter of dangerous conditions for children created by the missing court case files of Santa Barbara County, not the newspaper. The story "Point of Contention" erroneously casts doubt on the ancestry of the very Chumash family (article, Family A) that the plaintiff sued a member of in S.B. Sup. Crt. 220298. This was done with conscious disregard of the safety of others and escalated the oppressive effort to maliciously devalue plaintiffs efforts to use his rights of free speech by confusing his message to protect himself, his family and the public by bringing information to the community.

On January 20, 1998 plaintiff informed the Santa Barbara County Supervisors, at a supervisors board meeting during public comment, of arrest and booking records from 1876 to 1878 containing approximately 650 arrests for crimes of insanity and later provided them with a Declaration (EXHIBIT FIVE) from George Michael Skuse documenting the presence of the records in the Counties possession. Comparing the also provided statement of the Santa Barbara Superiour Court Clerk, also EXHIBIT FIVE, with the arrest and booking records shows that at least 300 insanity actions are missing. On February 16, 1998 the News Press ran an article (EXHIBIT SIX) titled, "Heavy Metal Hotel." In the story Sheriff's Deputy Tony Baker is pictured holding the arrest and booking records. The news story "Heavy Metal Hotel" is an event of collusion creating, by confusion, malicious oppression of the Plaintiffs civil right to free speech and exemplifies conscious disregard for the safety of others by confusing the plaintiffs efforts to provide information to the public concerning a dangerous condition.

On August 22, 1999 the Santa Barbara News Press published an article about Christopher Todd Brown, a graduate of UCSB, concerning disparaging vulgarities written in his graduate thesis on page B1 (see EXHIBIT FIFTEEN). The article was written by reporter Rhonda Parks Manville,

On September 19, 1999 page A5 the Santa Barbara News Press published an article about a Christopher Brown from UCLA who was involved in illegal exchanges of cadaver parts. (see EXHIBIT FIFTEEN)

Defendant Santa Barbara News Press did use its power as a publisher of a daily paper in the City of Santa Barbara, plaintiffs home of 46 years, colluding with the County of Santa Barbara, to diminish plaintiffs civil right to unimpaired free speech, by confusion, of plaintiffs message and the plaintiffs identity, over time. The County of Santa Barbara and the Santa Barbara Newspress, with its publication, conspired to violate the plaintiffs civil rights by confusing his message and identity over time.

The County hired a consultant, The Buske group to conduct workshops and phone surveys of cable television subscribers. On September 23, 1998 plaintiff attended a meeting held during the evening in the board room of the Santa Barbara County Supervisors. At the meeting the plaintiff observed the Buske group controlling the publics involvement with the determinations concerning the renewal of the cable franchise contract. The plaintiff has at least two years experience as a member of the Santa Barbara public access studio and attempted to inform the attending public of aspects critical to public access of television and freedom of expression. On September 24, 1998 at another meeting the plaintiff was verbally intimidated, insulted and humiliated by the Buske group in a coordinated, premeditated way when he attempted to assist the public of the workshop to form concepts improving public access television. After obtaining the names and addresses of the public attending the meetings (see EXHIBIT SIXTEEN), the plaintiff discovered that many of those listed were taking mail at County Department addresses.

Plaintiff mailed 120 letters and received no replies and alleges here that a large portion of the listed, attending public was intentionally derived from the County employment roster for the purpose of deceptively fulfilling the required public attendance of the meetings to further diminish of the plaintiffs civil right to free speech through his constitutionally protected uses of public access television thereby violating his civil rights.

The judge in civil case 220298 (EXHIBIT NINE) failed to disqualify himself when presented with proof of his prejudice through a MOTION TO DISQUALIFY (EXHIBIT SEVEN). Later at trial on September 8, 1998

the judge allowed the County of Santa Barbara to be in contempt when it denied 2 subpoena duces tecum (EXHIBIT EIGHT) for records made available to the public by state law.

U. S. C. TITLE 42 Sec. 1981. Equal rights under the law

(a) Statement of equal rights

All persons within the jurisdiction of the United States shall have the same right in every State and Territory to make and enforce contracts, to sue, be parties, give evidence, and to the full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens, and shall be subject to like punishment, pains, penalties, taxes, licenses, and exaction's of every kind, and to no other.

(c) Protection against impairment The rights protected by this section are protected against impairment by non governmental discrimination and impairment under color of State law.

The County of Santa Barbara violating plaintiffs right to give evidence by colluding with the court for the purposes of depriving the plaintiff of equal protection under the law and continuing its negligence or non feasance.

The actual fraud of depriving the Plaintiff a fair trial in case 220298 (EXHIBIT NINE) subjected him to the ongoing conspiracy while tormenting plaintiff with the constructive fraud of omission when violating public confidence. Discriminating against plaintiff, leaving plaintiff impoverished, without means to effectively use his civil rights meaningfully. Leaving plaintiff vulnerable with no protection of the law from the unimpeded, illegal conspiracy.

U. S.C. TITLE 28 Sec. 35.130 General prohibitions against discrimination.

(a) No qualified individual with a disability shall, on the basis of

disability, be excluded from participation in or be denied the benefits

of the services, programs, or activities of a public entity, or be

subjected to discrimination by any public entity.

(ii) That have the purpose or effect of defeating or substantially

impairing the accomplishment of the objectives of the service, program,

or activity with respect to individuals with disabilities.

(g) A public entity shall not exclude or otherwise deny equal

services, programs, or activities to an individual or entity because of

the known disability of an individual with whom the individual or entity is known to have a relationship or association.

The plaintiff had informed the Superior Court through his complaint, case No. 220298 of the damages, his injury and disability. The plaintiff depended upon the dutiful performance or benefits of the Santa Barbara Superior court administering a service of fair, unbiased, impartial hearings and trial, an activity of the County of Santa Barbara, a public entity.

The plaintiffs request to the court to call the defendant to the stand at trial to testify, September 8, 1998, on page 25, beginning at line 23, of the official transcripts was falsified and an utterance of the judge, discriminatory to the plaintiff was omitted by Sharon Reinhold depriving the plaintiff of his equal rights and furthering the conspiracy against him violating U. S. C. TITLE 42 Sec. 1981 and 1985, the FOURTH CAUSE OF ACTION.

The plaintiff requests the court use inference to define a manipulation of legal process made by defendants attorney in Santa Barbara Superior Court case #220298. The opening statement of the defendants attorney, MOTION, (EXHIBIT NINETEEN) became a vehicle, with the courts recognition of the inference covertly introduced, with language having a "defensive tone", asserting on page 2, lines 3 and 4, with statements serving the interests of the defendants conspiracy as described in (S.B.co.SUP.CRT) case #220298 (EXHIBIT NINE) & 209449 (EXHIBIT TEN), by utilizing the unwilling but injured plaintiff to gain official recognition of hypnotic abuses and subconscious programming with the introduction of the opening statement into legal proceedings of courts of record.

Attorney for defendants request for responses to interrogatories from Christopher A. Brown were later used as a basis to infer the activity of telepathy that the defendant in case 220298 intended to introduce into legal pleading, then stating by process of inference, what could, as if in trial, be used to intentionally define the activity of telepathy is instead presented in the defendants opening statement (Page 2-,2,3) as a "claim by the plaintiff.......that the defendant.....inflicted harmful hypnotic telepathy on him" constituting a manipulation of the legal process.

The plaintiff immediately following the hearing of 209449 on May 16, 1997 was followed by investigators of the district attorneys office, cited for driving without a license then his car was towed and impounded (EXHIBIT TWELVE). Plaintiff alleges this was done to threaten and intimidate, to impoverish him and to discourage his legal actions of redress and recourse and that it was done under the color of authority and law.

On April 20, 1999, while the shooting at Columbine high school in Colorado was occurring, plaintiffs vehicle was being towed (EXHIBIT TWELVE) due to expired registration by Officer Jill Johnson of the Santa Barbara City police department although plaintiff had documentation from that day substantiating his claim that he was on his way to the DMV to register the vehicle. This was done, plaintiff alleges, to impoverish him, threaten and intimidate him and to discourage his legal actions.

The County of Santa Barbara canceled, without notice, a hearing scheduled for December 18, 1998 in plaintiffs complaint 226736 (NOTICE OF CONTINUANCE, EXHIBIT ELEVEN) for the purpose of replacing the County Council with a council prepared to deceive the court and provide opportunity to intimidate plaintiff. The conspiracy alleged in 220298, unimpeded, exploited this by causing a traffic accident with the plaintiff documented in the erroneous "Traffic Collision Report" (EXHIBIT THIRTEEN), an act of collusion with the City of Santa Barbara consummated by Santa Barbara City police Officer Jill Johnson, THIRD CAUSE OF ACTION.

Officer Johnson states in the report, at "CONCLUSIONS", in her collision report, that plaintiff was "driving too fast for conditions of the roadway". In Santa Barbara Municipal Court, small claims court, (SC-988098) (EXHIBIT FOURTEEN) the plaintiff prevailed when he was able to communicate to the court the obvious cause of the accident and was awarded $635.00. The obvious cause of the accident was V-2 crossing from the extreme left side of the road, across three lanes of traffic, to the far right lane at a 45 degree angle. Photos provided to the small claims court explained the intentional collision by demonstrating plaintiffs front bumper pushed sideways from the rush of V-2's "intent" to collide with V-1.

Parking Officer Fishback (EXHIBIT THIRTEEN) states she saw "V-2 move in front of the parked truck." She does not state that V-2 was still in the parking lane nor that the truck was double parked illegally. When plaintiff locked his brakes after V-2 accelerated and turned in front of him, plaintiff observed Officer Fishback look back to the scene after the impact.

Officer Johnson created the erroneous report for the purpose of causing the plaintiff anxiety and tortuitous feelings, designed, by collusive covert manipulation and intimidation to induce plaintiff to cease his legal actions. Officer Johnson erroneously, with an intent to cause plaintiff anxiety and mental torment, states in her collision report that "V-1 was obviously" the cause of the accident. Officer Johnson also states in the report that there was a semi truck legally parked. The double parked truck, in fact, did not have caution cones as required by law.

U.S.C. TITLE 42 Sec. 1985.

Conspiracy to interfere with civil rights

(2) "Obstructing justice; intimidating party, witness, or juror

If two or more persons in any State or Territory conspire to deter, by

force, intimidation, or threat, any party or witness in any court of

the United States from attending such court................."

Unknown employees of defendant Santa Barbara County caused the delayed hearing of December 18, 1998, without notice, to interfere with the party/plaintiff in S.B. Sup. Crt. case 226736 by collusion and conspiracy to intimidate Christopher A. Brown and deprive him of equal protection of the laws.

"..............or if two or more persons conspire for the purpose of impeding, hindering, obstructing, or defeating, in any manner, the due course of justice in any State or Territory, with intent to deny to any citizen the equal protection of the laws, or to injure him or his property for lawfully enforcing, or attempting to enforce, the right of any person, or class of persons, to the equal protection of the laws;"

(3) "Depriving persons of rights or privileges.

If two or more persons in any State or Territory conspire or go in

disguise on the highway or on the premises of another, for the purpose

of depriving, either directly or indirectly, any person or class of

persons of the equal protection of the laws, or of equal privileges and

immunities under the laws; or for the purpose of preventing or

hindering the constituted authorities of any State or Territory from

giving or securing to all persons within such State or Territory the

equal protection of the laws;...................... one or more persons engaged

therein do, or cause to be done, any act in furtherance of the object

of such conspiracy, whereby another is injured in his person or

property, or deprived of having and exercising any right or privilege

of a citizen of the United States, the party so injured or deprived may

have an action for the recovery of damages occasioned by such injury or deprivation, against any one or more of the conspirators.

The officers involved, in uniform or disguise on the highway, and unknown employees of the County, conspired to alter the courts calendar for the hearing of the demurrer of December 18, 1998 without proper notice (NOTICE OF CONTINUANCE, EXHIBIT ELEVEN dated December 22, 1998) within the protracted, unimpeded conspiracy, plaintiff describes in S.B. Sup. Crt. Case No.s 220298 and 209449, conspired to threaten and deprive plaintiff of equal protection of the law.

The City of Santa Barbara has discriminately enforced parking laws to intimidate and impoverish plaintiff. The semi truck illegally parked was instrumental in causing the traffic accident and was allowed to park illegally. EXHIBIT TWELVE shows another truck parked in the red, two different times, at an area frequented by the Santa Barbara Police Department. EXHIBIT TWELVE also shows a demand for payment of a parking ticket plaintiff received while at the Santa Barbara County court house law library doing legal research.

For over ten years the parking time limit surrounding the Court house has been ninety minutes. In September of 1999 the Court house and other parts of town had new signage making the maximum time seventy five minutes inhibiting plaintiffs time to conduct legal research. Plaintiff parked a block away in an old ninety minute zone around the corner form the Police Station on September 12, the next day plaintiff parked in the same place and emerged from his vehicle to find one half inch roofing nails scattered in the area. Plaintiff concluded prematurely his legal research into case law and files this compliant citing the following cases that by summary, seem to support a decision in his favor. Plaintiff is injured with Attention Deficit Disorder disabling him from efficient legal research and is not an attorney and accompanying this complaint is a request for the appointment of an attorney.

Jennings v Nester (CA7 Ill) 217 F2d 153, cert den 349 US 958, 99 L Ed 1281, 75 S Ct 888.

Lewis v Brautigam (CA5 Fla) 227 F2d 124, 55 ALR2d 505.

Adickes v S.H. Kress& Co., 398 US 144, 26 L Ed 2d 142, 90 S Ct 1598.

United States v Anderson (1973, CA4 W Va) 481 F2d 685, affd 417 US 211, 41 L Ed 2d 20, 94 S Ct 2253

Since Monday July 21, 1997, the County of Santa Barbara and the Santa Barbara News Press have colluded to violate the plaintiffs rights, his constitutionally protected tools, as a citizen to contribute to rightful civility by confusing what is being said and who is saying it. In the case of the Newspress, the power of the publication first confuses the message spoken, then it is later used to confuse the identity of the speaker, the plaintiff violating his civil rights as described in;

UNITED STATES CODE, TITLE. 28, SEC. 1343

(a) The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any person: (1) To recover damages for injury to his person or property, or because of the deprivation of any right or privilege of a citizen of the United States, by any act done in furtherance of any conspiracy mentioned in section 1985 of Title 42; (2) To recover damages from any person who fails to prevent or to aid in preventing any wrongs mentioned in section 1985 of Title 42 which he had knowledge were about to occur and power to prevent; (3) To redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of any right, privilege or immunity secured by the Constitution of the United States or by any Act of Congress providing for equal rights of citizens or of all persons within the jurisdiction of the United States; (4) To recover damages or to secure equitable or other relief under any Act of Congress providing for the protection of civil rights.

Plaintiff is certain by nature of his injuries that the extreme violence of young people in schools, in America today, since January 22, 1997, is caused by abuses similar to those alleged inflicted upon plaintiff as a child, described in S.B. co. SUP. CRT case 220298 and that the violence since that aforementioned date may NOT have happened had Santa Barbara County not conspired with its influence to violate and diminish plaintiffs civil right to free speech, followed State laws, and exercised reasonable discretion from that time to the present. Plaintiff, with each act of violence of children in schools, has experienced worsened anxiety, stress and emotional distress at increased levels since September 8, 1998.

The cause of action for conspiracy to deny equal protection under the law as well as conspiracy to deny due process with the indirect purpose of depriving plaintiff his civil rights, his fair exercise of free speech, in order for the County of Santa Barbara to remain unexposed in an old conspiracy of neglect or nonfeasance, is consummated by the conspiracy between the County, the Superior Court, the City of Santa Barbara and the Santa Barbara Newspress. A conspiracy and an overt act in furtherance thereof resulting in injury to the plaintiff and deprivation of equal privileges of law under color of authority.

The conspiracy was also consummated through the Court in 220298 when it denied plaintiff due process, when, by omission, the principles of the California State Civil Code of procedure, 170.6 were ignored as they applied to Christopher A. Browns contention of prejudice in his MOTION TO DISQUALIFY (EXHIBIT SEVEN).

The judge of the court would have immunity under USC TIT. 42 Sec. 1983 for his omission although the County of Santa Barbara would be libel due to civil provisions against conspiracies to interfere with civil rights allowing that an injured party can have an action for the recovery of damages for the consummation of the conspiracy illegally using the judge to determine the outcome of the plaintiffs legal actions.

U.S.C. Title 42 Sec. 1983. Civil action for deprivation of rights

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.

Had plaintiffs case 220298 been fairly tried it would have enabled plaintiff to rightly use the information of his past for the purposes of obtaining legal representation, medical treatment, publicity and artistic opportunity and prevented damage to plaintiffs reputation. Opportunity to realize the only possible benefits of plaintiffs life, to plaintiffs life would have been realized with verification of plaintiffs life experience. Had the plaintiff been fairly treated in civil case 220298 by the upholding of state laws, plaintiffs ability to provide for himself and family would have been robust. These abuses to the plaintiff has impoverished him, caused his eviction (unlawful detainers SB228201 1/26/99 & SB229276 3/8/99), caused him to be repeatedly, as alleged in the conspiracy described in 220298, victimized by the same parties from forty years earlier with other intentionally tortuitous, humiliating acts and injuries caused by post hypnotic instruction of others around him.

Plaintiffs past is unusual as a victim of illegal psychological abuses utilizing hypnosis and requires official verification to be valuable.

Plaintiff has suffered monetary damages due to the counties collusive actions with the court denying the Plaintiff testimony from the defendant willing to testify in case 220298 and provide the verification plaintiff requires for relief. Numerous publishing or music contracts or film offers would have been already made and accepted at this time.

The County of Santa Barbara, colluding with the court has kept the plaintiffs medical condition, or his injuries from being correctly identified in their fundamental nature preventing him from obtaining adequate medical treatment. Plaintiffs continued untreated condition has devalued his life experience due to severe emotional problems associated with the lack of treatment or increased anxiety, tormenting him by loss of reputation and publicity leading to poverty. The Court and County actions prevented Plaintiff from obtaining adequate protection for his children and has increased the injury to them by depriving plaintiff of vital medical information needed to procure appropriate treatment for the perpetrator and prevent the molestation (Santa Barbara County Superior Court M992970) of his daughter.

I Christopher A. Brown Declare on October 18, 1999 under the penalty of the laws of perjury of the United States of America that the foregoing is true and correct.

Date;_____________Pro per plaintiff, Christopher A. Brown

Plaintiff in this civil action hereby demands a jury trial pursuant to TITLE 28, FEDERAL RULES OF CIVIL PROCEDURE, Rule 38. Jury Trial of Right and files the demand as required by Rule 5(d).

Respectfully submitted;

Date;_________Pro per plaintiff, Christopher A. Brown