UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
Chris Walters, Counseling Director Manuel Flores
Plaintiff Pro Se San Antonio College
910 W Commerce Street 1300 San Pedro Avenue
San Antonio, TX 78206 San Antonio, Texas 78212-4299
(message 210-224-5838) (210-733-2300)
email: chrisw911@hotmail.com
Chris Walters )
Plaintiff )
)
vs. ) Civil Case: SA97CA1327
) Recieved By Clerk: Oct 28,1997
Manuel Flores )
et all.... )
Defendants )
COMPLAINT
Now Comes The Plaintiff Chris Walters before the Honorable United States District
Court, Western District of Texas in this Action At Law and Complaint to Wit:
1. Jurisdiction: This action is mandated by law as required by Title 28 USC 4 Misprision
the felony and permitted under Title 28 USC 1343 (a)(3) as cited by Magistrate John Primo
on 12-30-93 in Walters v. Raiford SA93CA1115.
2. Cause of Action: Manuel Flores Counselor at San Antonio College states he has violated
disabled student Chris Walters rights to 4th amendment as violation of Title 18 USC 241 Civil
rights and Federal Privacy Act and is aiding and abetting violations of TITLE 18 CRIMES by
joining assisting third parties named as actors Walters v. Miller, USCD SACV1313; Walters v.
McColl USDC.NDF 4 97 CV297MP an amicus curia before the US Senate Committee on Jurisidicary;
Walters v. Freeh USDC NV 96CV896HRM....
3. Relief Sought: Pursuant to Title 28 USC 4 Misprision the felony Chris Walters seeks
the permission of the Court to proceed on Manuel Flores generous offer to identify his fellow
"coconspirators", evidence he explained he is in possession of which he states implicates SAC
legal counsel, evidence he and his coconspirators have tampered with a Social Security Claim
in Florida; and various federal court actions to which they are not named and authorized parties
of interest.
Respectfully Submitted ByChris Walters,
Plaintiff Pro Se
Registered Voter At: 910 W Commerce
San Antonio, Texas 78206
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
Chris Walters, Counseling Director Manuel Flores
Plaintiff Pro Se San Antonio College
910 W Commerce Street 1300 San Pedro Avenue
San Antonio, TX 78206 San Antonio, Texas 78212-4299
(message 210-224-5838) (210-733-23
email: chrisw911@hotmail.com
Chris Walters )
Plaintiff )
)
vs. ) Civil Case SA97CA1327
)
Manuel Flores )
et all.... )
Defendants )
MEMORANDUM OF LAW IN SUPPORT OF COMPLAINT
Now Comes The Plaintiff Chris Walters before the Honorable United States District Court, Western District of
Texas in this Action At Law and Memorandum of Law in Support of Complaint to establish:
1. Jurisdiction: United States District Court jurisdiction for violations of Title 18 CRIMES is established
in Title 42 and Chris Walters clear obligation to report violations as a person granted permission to pratice in
US District Court is required under Title 28 USC 4 Misprision the felony and maybe further supported by
Title 42 USC 1983 or Title 28 USC 1343 (a)(3) as Cited by US Magistrate John Primo.
2. Cause of Action: Chris Walters was directed by Legal Counsel Robert Schulman and ADA Coordinator
Robin Martin (210-220-1674) of Alamo Community College District to file a "grievance" to with officials of
San Antonio College to determine why disabled student Chris Walters is being denied access to the Disabled
Student Services.
3. On Monday, October 27th, 1997 at about 8:30 Am Chris Walters was following the instructions of Alamo
Community College District instructions to contact members of SAC and provide copies of the "grievance" and
met with Defendand Manuel Flores.
4. In the course of a brief conservation in Mr. Flores office, Mr. Flores volunteered that the circumstances
of Chris Walters being denied access to SAC had no basis in Americans With Disabilities Act but stated that
Mr. Flores and other members of SAC had initiated what Mr. Flores describes as a," private federal criminal
investigation" of Chris Walters because Chris Walters has exercised his right to question policies of the
4. San Antonio College if they were approved by ACCD.
5. Mr. Flores and his "coconspirators" according to statements of Mr. Flores to legal counsel of record
Chris Walters used Chris Walters name, social security number, date or birth, and other information provided
to San Antonio College to initial an extensive investigation by "police" and involve the San Antonio College,
and Alamo Community College District in legal issues where they have no legal right.
6. Mr. Flores claim is that he and his coconspirators violated Chris Walters rights under the Federal
Privacy Act and probally Chris Walters rights to privacy guaranteed under Title 18 USC 241 Civil rights.
7. Mr. Flores volunteers that "we are very aware of your background in Florida, "police reports", social
security claim, and a whole lot of other things probally more than you are aware"?
8. Referring to himself and his "coconspirators", Mr. Flores states he is working with parties to bring about
an end to what he believes to be Chris Walters criminal activities as he states: "We are going to have definite
closure very soon".
9. In the course of Mr. Flores private federal criminal investigation of disabled student Chris Walters what
Mr. Flores and his coconspirators have accomplished is to identify persons Chris Walters is seeking to have
criminally prosecuted in various United States District Courts in San Antonio and elsewhere and Mr. Flores
offer to provide evidence he states he is in possession of is actionable in USDC, not within the framework of
a student grievance at SAC.
10. Walters v. Miller and Crownover filed USDC, SACV1313 certainly wants to know exactly who Mr.
Flores has contacted to tamper with Social Security Claim 261-90-6357 in Florida and if evidence is found to
support a cause of tampering with a federal agency this court will be asked to issue Federal Bench Warrants for
a crime committed in the Western District of Texas.
11. Walters v. Freeh filed USDC,NV CV892HDM and Walters v. Freeh and Hatch in USDC, EDC certainly
already concern questions of "police reports" and misuse of the NCIC criminal history to slander and liabel Chris
Walters good name and reputation which Mr. Flores states are actors in the Western District of Texas and
probally prosecutable under Title 18 USC 241 Civil rights and Title 18 USC 372 Conspiracy to defraud the US
for violation of Chris Walters rights under due process and equal protection of both 5th and 14th Amendments.
12. Mr. Flores has implicated both himself and SAC Legal Counsel Robert Schulman in various federal
crimes ranging from "Contempt of Court" by obstructing, intimidating, and harassing Chris Walters an
established person qualified to pratice in certain USDC; tampering with a social security claim; and offering
to implicate quite a number of other parties who are Actors both in Florida and Texas.
DISCUSSION OF MR. FLORES OFFER
Counselor Manuel Flores of San Antonio College began his vendetts against disabled student Chris Walters as
he stated because Chris Walters questioned a SAC policy which is not approved by Alamo Community College
District. Mr. Flores states he used information from Chris Walters school files to initiate his own private federal
criminal investigation as he stated which involves unknown "police reports" or police personnel. Mr. Flores
apparently has heavily involved San Antonio College acting with his "coconspirators" to involve himself as a
party seeking the satisfaction of and legal relief of "closure" in actions to which he as a nonparty has no legal
rights to participate. The act of participating in a USDC action to which a third party is not recognized is
generally known as "contempt of court". The act of using a publically funded institution such as SAC to acquire
such information as Chris Walters vital stastics for some other purpose beyond what is stated as policy is
generally known as the Federal Privacy Act and in some instances violates Title 18 USC 241 Civil rights.
In course of these selfprofessed crimes and private federal criminal investigation, Mr. Flores has stated he has
come into contact with third parties who are the subject of existing investigations filed in various United States
District Courts and who have violated Chris Walters civil rights. The identieis of these third parties is of direct
and obvious concern to Social Security Inspector General Miller, USDA Civil Rights Office, US Health and
Human Services Office of Civil Rights, Government Accounting Office, and the area of interest is possible
violations of TITLE 18 CRIMES which have been perpetrated in Western District of Texas. Mr. Flores is at least
a very material witness and his testimony, if it can be gotten should implicate the third parties.
Once the identies of these third party "Principals" is discovered Chris Walters intends to use Mr. Flores
testimony and evidence to secure Federal Bench Warrants for the arrest of the offending parties for their part
in crimes in Western District of Texas; no matter which venue they reside in. The legal actions which Mr. Flores
and current third parties are acting in are primarily "amicus curia" or "courtsey suits" which are joined to the
United States Senate Judiciary Committee whose actions are not subject to direct review by US District Courts,
states, nor the Federal Executive Branch.
During the course of the docketing various legal briefs, and reviewing evidence Chris Walters may question if
the operation of San Antonio College is within the bounds set by Alamo Community College District and
operating in a manner consistent with the public interest, and welfare of the students. If it is established that the
operation of the San Antonio College is so far removed from what is authorized by law as to be a real and possible
threat to Chris Walters and other students, then Chri sWalters will move the Court to appoint a special master
to administer San Antonio College until such time as it operates in the public interest.
Request for Special Writs and Warrants by Chris Walters will be tendered as briefs as testimony and evidence
should warrant.
Respectfully Submitted By
Chris Walters, Plaintiff Pro Se
910 West Commerce
San Antonio, Texas 78206
(210-224-5838)
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
Chris Walters )
Plaintiff ) Filed October 31, 1997
)
vs. ) Civil Case: SA-97-CA-1327
) US Magistrate Robert OConnor
Manuel Flores )
Defendants )
ORDER
On thi date came on to be considered plaintiff's request for
leave to proceed in forma pauperis, together with the affidavit in
support thereof. (Docket no.1). The Court is of the opinion
that the plaintiff's request should be granted.
It is, therefore, ORDERED that plaintiff's complaint be filed
with the Clerk without prepayment of fees, costs, or the giving of
security therefor, and the Clerk shall, until further Order of this
Court, waive the collection of any other fees or costs from
plaintiff. The clerk shall serve the defendants without cost to
plaintiff.
Local Court Rule CV-7(f) provides an 11 day period within
which an opposing party must file a response to a motion.
Plaintiff is advised that if he desires to respond to any motion
which defendants may file, his response should be filed within 11
working days after he recieves a copy of the motion. Failure to
respone will be interpreted as lack of opposition, and could result
in dismissal for failure to prosecute.
Plaintiff is reminded that it is his responsibility to advise
the United State District Clerk's Office and defendants of his
current address and to promprly furnish change of addresses when
such occurs. Failure to do so may be interpretered as failure to
prosecute and result in dismissal of the case.
Plaintiff is further advised to his responsiblity under Rule
5 of the Federal Rules of Civil Procedure and Local Court Rule CV-5
to serve a copy of any pleading filed, upon counsel for defendants.
Failure to do so could result in the imposition of sanctions.
Signed this 31th day of October 1997.
Robert B. O'Connor
United States Magistrate Judge