IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA

_____________________________________

NOTRA TRULOCK, III

AND

LINDA CONRAD

   Plaintiffs,

   vs.

LOUIS FREEH, in his personal capacity,
NEIL GALLAGHER, in his personal capacity,
STEVE DILLARD, in his personal capacity,
BRIAN HALPIN, in his personal capacity,
STEVE CARR, in his personal capacity,
JANE DOE NO. 1, in her personal capacity,

   Defendants.
_____________________________________
)
)
)
)
)
)
)
)
)
)
)
)   Case No.
)
)
)
)
)
)
)
)
)



COMPLAINT

This is an action to redress violations of the First and Fourth Amendments to the U.S. Constitution.

PARTIES

JURISDICTION AND VENUE

STATEMENT OF FACTS

As you may know, Judicial Watch has been retained to represent Notra Trulock and Linda Conrad, Mr. Trulock's landlord. Based upon our investigation, we have determined that you and your agents have violated the civil rights of Mr. Trulock and Ms. Conrad in undertaking an unconstitutional search and seizure of their home and computer and other illegal acts. Our investigation shows that you, personally, are involved, particularly given the importance of this matter and the media and Congressional attention which it has generated. It was Mr. Trulock who, not coincidentally, blew the whistle on the Clinton-Gore Administration's, the Energy Department's, the Justice Department's, the CIA's, and the FBI's coverup of the unprecedented breach of national security nuclear secrets at Los Alamos, which now threatens the lives of all Americans.



Before filing suit against you and your agents, we are willing to discuss a resolution of this matter. If you are interested, a meeting or conference call must be set up today, since Mr. Trulock and Ms. Conrad continue to be harassed and/or smeared by you and your agents. Just recently for instance, their home was broken into and Mr. Trulock's dog attacked and harmed. It is likely that FBI officials have been responsible for, or complicit in, this as well. If we do not hear from you today, Judicial Watch is authorized to immediately file suit on various grounds.



Thank you for the courtesy of an immediate response.



COUNT I

(Fourth Amendment Violations)



WHEREFORE, Plaintiffs demand judgment be entered against Defendants, jointly and severally, including an award of compensatory damages, punitive damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.

COUNT II

(First Amendment Violations)

WHEREFORE, Plaintiff Trulock demands judgment be entered against Defendants, jointly and severally, including an award of compensatory damages, punitive damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.

Plaintiff demands trial by jury on all issues so triable.



By: ____________________________

Brett M. Wood, Esq.

VA Bar No. 14224



Larry Klayman, Esq.

General Counsel

D.C. Bar No. 334581

Paul J. Orfanedes, Esq.

D.C. Bar No. 429716

JUDICIAL WATCH, INC.

Suite 725

501 School Street, S.W.

Washington, DC 20024

(202) 646-5172

Attorneys for Plaintiffs