COMPLAINT FOR EQUITABLE DAMAGES, PUNITIVE DAMAGES, AND REQUEST FOR INJUNCTIVE RELIEF

Kamran Edward Estelle E. E. Nightingale

201 York St., Apt. 6
Enola, Pennsylvania 17025

Attorney for Plaintiff:

(To Be Determined)

U.S. DISTRICT COURT

MIDDLE DISTRICT of PENNSYLVANIA

Kamran Edward Estelle E. E. Nightingale, Case No.: 1:18-CV-2132

(aka E. E. Nightingale, as author pseudonym),
(née Kamran Owzar)
Com plaint
Plaintiff,

v. Judge:

Federal Bureau of Investigations is the United The Honorable Christopher C. Conner

States’ federal law enforcement agency;
Pennsylvania State Police is Pennsylvania
State’s state (as in provincial) level law REQUESTING A TRAIL BY JURY
enforcement service;
Date Action filed:
York County District Courts is the judicial court
Date set for trial:
system for York County, Pennsylvania;
Swatara Township Police Department is the
local law enforcement service for Swatara
Township Pa., a suburb of its state’s capital of,
Harrisburg, Pa.;

Defendants.
 PARTIES

A. Plaintiff Kamran Edward Estelle Esiriluxe Elronde Nightingale (hereinafter referred

to as “Plaintiff” or “Nightingale”) is male adult residing in Enola, Pennsylvania
(hereinafter called “Enola”), a suburb located just five miles outside the state capital
of Harrisburg, PA (hereinafter referred to as “Harrisburg”), at the time of this
Complaint.
B. Plaintiff’s potential team, “Party Nightingale”, as they will be hereinafter called, will
consist of Plaintiff Nightingale (as pro-se, co-counsellor, albeit chief counsellor,
with the charge of Power of Attorney) as well as his experienced legal counsellor(s),
which have yet to determined.
C. Defendant Federal Bureau of Investigations (hereinafter referred to as “FBI”) is the
United States’ (hereinafter referred to as “U.S.”) primary federal law enforcement
service.
1. Headquartered in Washington, District of Columbia, the FBI’s official
headquarters, sometimes referred to as “J. Edgar Hoover”, is located
at 935 Pennsylvania Avenue NW, Washington, District of Columbia
(hereinafter referred to as “D.C.”).
2. The FBI furthermore has many field offices throughout the U.S., of
which one is located in Harrisburg, at the Federal Building therein
(that local field office in Harrisburg hereinafter referred to as “FBI-
Hbg”).

D. Defendant Pennsylvania State Police (hereinafter referred to as “PSP”) is

Pennsylvania State’s state-level (as in akin to provincial) law enforcement service.
1. Headquartered in Harrisburg, their main office is located at 1800
Elmerton Ave. Harrisburg, PA 17110.
2. PSP furthermore has many fields offices (called Troops) located
throughout Pennsylvania.
E. Defendant YORK COUNTY DISTRICT COURTS (hereinafter referred to as “YORK
COUNTY COURTS”) is the county-level court system for York County, PA - located
at 45 N. George St. in York, PA.

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 F. Defendant Swatara Township Police Department (hereinafter referred to as
“SWATARA POLICE“) serves as the local law enforcement service for Swatara
Township, PA (hereinafter called “Swatara”), which is located about six miles
outside Harrisburg.
G. The four defendants, FBI, PSP, YORK COUNTY COURTS and SWATARA POLICE can
hereinafter be collectively referred to as the “Defendants”.

JURISDICTION

J. Nightingale, the FBI, PSP, and SWATARA POLICE all reside, or had at least one
established address, within a ten-mile radius of Harrisburg, during
1. Two primary incidents involving SWATARA POLICE.
2. One primary incident (followed by a few subsequent torts Nightingale alleges)
by the PSP.
3. One primary incident involving YORK COUNTY COURTS.
K. YORK COUNTY COURTS is located in the city of York, being the seat of the County
of York, located about 26 miles south of Harrisburg.
L. As such, given the facts stated in this section titled “JURISDICTION”, it stands to
reason and rules that, given the information about all five primary parties in this
case, the jurisdiction of this court is proper for this case.

NATURE OF CASE

M. Nightingale brings this case against the four Defendants he is accusing of the
hereinafter listed torts.
N. Nightingale states that, what could be labeled as, torts by commission (referring to
actual committed acts by a party) committed by the three non-federal defendants,
were in large part a direct result of those very torts' enabling brought about by
torts by omission (referring to indisposition to act/ or repeated dereliction of duty)
by the FBI in Nightingale’s relevant environments over at least the 13-year period
leading up to the time of this Complaint.
O. The FBI is the U.S.’ federal law enforcement service, tasked with enforcing federal
laws, which include laws commonly referred to as Civil Liberties and Civil Rights

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 (hereinafter referred to as ”Civil Liberties”), appended as part of the Bill of Rights to
the United States’ Constitution, circa 1791.
1. If a government agency, such as a police service (be it at any level - federal,
state, county, and/ or local) commits a violation of a citizen’s rights it is
considered a violation of that citizen’(s) Civil Liberties, for which the FBI has the
jurisdiction and charge to see to it that the situation is remedied, along with
perhaps taking further actions.
2. The FBI, as a law enforcement service, furthermore has the responsibility of not
only prosecuting violations, but, and just as importantly, they are also
understandably responsible for maintaining order by handling their general
affairs in such a manner that,
a. To the extent that it can be shown to be practical, their remedial actions
should be of a nature that, along with other pertinent objectives, they
foreseeably produce enough of the influence necessary to prevent
repeated infractions of Civil Liberties (as well as all pertinent laws, for that
matter) from reoccurring – and all-the-while minding the longevity of
that influence.
P. The PSP is the state-level (as in akin to provincial) policing service for Pennsylvania
State.
1. On or about January 19th, 2018, PSP arrested Nightingale under what
Nightingale perceives as illegitimate circumstances.
Q. The YORK COUNTY COURT OF COMMON PLEAS (hereinafter referred to as “YORK
COUNTY COURTS”, is the county-level courts of common pleas for York County, PA.
1. On or about June 3rd, the YORK COUNTY COURTS incarcerated Nightingale in
YORK COUNTY JAIL on a Bench Warrant for a court hearing Nightingale was
never informed of. As Nightingale was never informed of his court hearing, he
could not have been expected to be there on that day.
R. SWATARA POLICE is the local police service for Swatara, PA.
1. On or about March 22nd, 2018, SWATARA POLICE filed a set of charges against
Nightingale under unverified and false accusations, all without even
questioning him once, and, hence, thereby tainting his character.
S. This entire scenario as a whole (meaning the case) is further aggravatingly
distressing considering a series of unchecked violations of Nightingale’s rights and

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safety that he has had to endure over the past 13 years, leading up to the time of
this Complaint.
1. That Nightingale was already burdened with those series of mistreatment and

their lingering and steady consequences and distresses, when these “nth “
ordeals of:
a. very worrisome acts on the part of PSP (tort by commission),
b. false imprisonment by YORK COUNTY COURTS (tort by commission),
c. false and confusing charges from SWATARA POLICE (tort by
commission),
d. …all under the auspices of gross neglect on the part of federal law
enforcement (torts by omission).
2. It is further distressing that this ordeal comes before Nightingale at a time
when, due to the direct result of uncommonly intense and protracted
distresses, Nightingale has already been afflicted with medical ailments that
came about from the mistreatments of others he has had to endure for at
least these prior 13 years leading up to the time of this Complaint. These
ailments include (though may not be limited to):
a. Hyper-Acidity.
i. Brought on to Nightingale by intense and protracted distresses
due to unchecked mistreatments by other people over at least
the prior 13-year period, leading up the time of this Complaint.
ii. This condition causes the body to go into a state where it
produces unusually large amounts of acid, which in turn cause
acid erosion when it touches body tissues.
As a result, Nightingale has severe damage on his innards by
sheer acid erosion.
b. Adrenal Cortical Insufficiency.
i. Brought by intense and protracted distresses due to the
unchecked mistreatments by other people over at least the prior
13-year period, leading up the time of this Complaint.
ii. This is a condition where the body has reached the point where
it’s sub-routine for being able to handle stress (largely consisting
of the Adrenal Glands located above each Kidney), is so worn
out that it can’t produce sufficient amounts of Cortisol anymore

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 i. Cortisol being the everyday hormone the human body
uses to allow it to be able to handle stress.
iii. Nightingale’s Adrenal Glands have been so worn out and
fatigued that they can no longer produce the amounts of
Cortisol that they’re meant to.
c. An odd form of Irritable Bowel Syndrome
i. This condition also brought on by protracted stress, it causes
Nightingale to have unusual and persistent bloating in his
abdomen.
d. In the last 10 months alone Nightingale has been tested twice for
Cardiomyopathy (Broken Heart Syndrome).
i. More commonly known as Broken Heart Syndrome, this
condition could readily be brought on by intense and/ or
protracted emotional distress.
e. It has reached the point where on most days Nightingale cannot
each much of anything.
f. Furthermore, Nightingale, an enthusiastic hobby body-builder, has
had to stop that activity for almost a year now at the time of this
Complaint.
g. As he cannot eat much most days, he has also lost, within about one
year’s time, almost all the lean muscle tissue he had worked hard to
develop over several years – and that deterioration continues at the
time of this Complaint, along with daily pain and distress.
T. As his Complaint against the Defendants, Nightingale has deduced for some time
now that the Defendants’ general means practically have a deducible collation to
the above (as well as below) stated violations and the consequences Nightingale
has had to endure for at least 13 years leading up to the time of this Complaint.
U. Those being among the torts and offending actions of all the Defendants
collectively, Nightingale brings more charge, a more foundational charge, against
the FBI.
V. Nightingale argues that the FBI’s indisposition to matters of Federal Question
(particularly those of Civil Liberties) over the course of at least these last 13 years
leading up to this Complaint is the foundational reason (the enabler and fosterer,

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 if you will) of most of the serious violations of Nightingale’s rights and safety
during these 13 years.
1. Starting Spring of 2005, Nightingale has been pleading with the FBI to
handle certain matters for him.
2. The FBI’s invariable refusal to hold people that have violated Nightingale’s
rights accountable is what has enabled, indeed, fostered, a certain grade of
disorder in Nightingale’s environments – a condition that has essentially
enabled, condoned, and encouraged wrong acts against Nightingale, in
large part because
a. those violators were responding to the environment the FBI created
around Nightingale – an environment where, at least in effect, the
violators were likely expecting to, in effect, have practical immunity.
b. Those violators were also less cognizant of their natural inhibitions to
violate other peoples’ rights, as
i. having matters of considerable violations consistently remedied
would have better helped maintained an “atmosphere” of zero-
tolerance towards intentional violations of others’ considerable
rights (which would include Civil Liberties), and
ii. that orderly atmosphere would have kept the police officers and
other personnel (and also common citizens, for that matter) in a
state where they were much more consciously cognizant (aware)
of their inhibitions to violate other people’s rights.
c. As repeated violations of Civil Liberties and other rights were
consistently ignored, that conscious/ cognizant awareness that
should have been present was instead singed off.
W. Much of the mistreatments Nightingale has received over these past 13 years have been
explained off as people having a tendency to mistreat him because he has Asperger’s
Syndrome
1. Whether that is true to some degree or another, it’s almost beside the point
because if the proper authorities had held these people, as well as themselves,
accountable, then there would have been hardly any mistreatment towards
Nightingale at all – no more or less than anybody else, anyway.
2. Some of the matters that Nightingale has tried to convince the FBI to handle
are those of Theft of Intellectual Property Rights, Grand Larceny, Civil Liberties

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 violations, persistent considerable mistreatments at work-places that led to
Nightingale not being able to thus far have and keep a career, and what
obviously came off as the indisposition of some of their colleagues to
adequately assist Nightingale in holding accountable those that violated his
rights.
3. It is the FBI’s unwavering refusal to hold those people accountable that led
(“allowed”/ “enabled”) more and more violations of Nightingale’s rights.
4. Each subsequent violation that was committed against Nightingale was often
progressively more severe than the violation before it – the one that had not
been adequately prosecuted.
5. The FBI has over the past 13 years leading up to the time of this Complaint
been a party to the defamation of character against Nightingale by not
vindicating him in regard to the question of whether he was neutral, the
victim, or the culprit in some of the uncommonly undesirable scenarios that
Nightingale has been exposed to during these past 13 years, leading up to the
time of this Complaint.
6. This caused, in all practicality, a state of “open season” on Nightingale, as well
as sometimes his family, in which people (even people they never knew)
would verbally harass him, deny Nightingale opportunities, ruin aspects of
Nightingale’s personal life – all obviously with at least some undue
expectation of the likelihood of immunity, largely due to indisposition on the
part of local and state law enforcement, who in turn likely expected relative
immunity from the FBI.
7. If at any point in time the FBI would have properly held accountable those
who violated Nightingale’s Civil Liberties, or even common law rights, the
likelihood of Nightingale being subsequently, similarly, and repeatedly
wronged time and again would have been greatly diminished because in an
orderly run environment
a. The perpetrators, whether government agencies or just common
individuals, would be more likely to stay cognizant of their inhibition
against violating another person’s rights.
b. If having a conscience about violating other’s rights isn’t really a
substantial matter for them, then fear of being held accountable for
their actions might do, in lieu.

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 8. And, by extension, in such an orderly environment where the FBI holds law
enforcement accountable, and they in turn hold common citizens accountable
(to a degree that is practical) then:
a. Nightingale would not have had the protracted emotional distresses
he has had to endure these 13 some years.
b. Nightingale would not have been afflicted with the medical ailments
that came as a direct result of protracted distresses.
c. Nightingale would not have had his career life hitherto ruined.
d. Nightingale would not have had his personal life hitherto ruined.
9. It has, around the very time of time complaint, come to the point where
Nightingale now alleges a possible conspiracy against him, a disabled adult
male, on the part of the Pennsylvania State Police (PSP), as explained in detail
in the FACTUAL ALLEGATIONS further below.
X. As such, and given the extensive allegations detailed in the remainder of this
Complaint, Nightingale asks to bring his claims to a U.S. Federal Court, whereby he
may present his case before a trial by jury and have answered his petitions for relief.

FACTUAL ALLEGATIONS

2005, May | | Initial Meeting With FBI-Hbg

On or About April or May of the year 2005,
Y. Nightingale visited FBI-Hbg to
report a series of concerns.
1. Nightingale explained to the FBI:
a. How his (Nightingale’s) computer network had some strange activity
indicative of direct hacking and perhaps surveillance (as in the surveillance
of computer information, not video/ audio surveillance).
b. Nightingale was also concerned that there might have been theft of
intellectual property occurring during that surveillance.
i. It should interest you to know that since Nightingale reported
the suspected computer hacking and network surveillance, it
turns out that a group was hacking into the Nightingale’s

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 residence, though Nightingale doesn’t know what the authorities
did to resolve the matter; and it seems as if nothing was done
and no one held accountable for it – thus, it continued.
c. Furthermore, Nightingale explained how that he felt the local authorities
where he had gone to University were deliberately not looking into his
concerns at out sheer indisposition (something later explained off as due
to Nightingale’s Asperger’s Syndrome).
2. At the conclusion of that meeting before Nightingale left the Federal Building:
a. The FBI recommended that Nightingale file for a patent for the intellectual
property he thought others might have stolen.
i. Nightingale’s take on that was that, even with a patent, if the federal
authorities don’t adequately handle such an offense, Nightingale
could very well be powerless to make intended use of his patent, as
the offenders may just continue to offend anyway.
ii. Furthermore, the filing of a patent for an individual person,
particularly a recent University graduate, can be impractical due the
costs of filing a patent.
b. The FBI-Hbg at that time told Nightingale how the issue with the local
police service where Nightingale went to University at the time might not
be a not a federal matter, because the federal government can’t tell a local
government agency or department what do to just at federal behest.
i. As true of a point as that may or may not have been, it was beside
the point Nightingale was trying to make, and that was that if
Nightingale was being wrongly treated by a government agency at
any level, it would be a violation of his Civil Liberties, which is a
matter of federal law (Federal Question).

2005 – 2010 | | Repeated Follow-Up Requests With FBI

Between the timespan of Spring, 2005 till around the year 2010,
Z.
Nightingale continually tried to get an update from the FBI regarding what he had
reported to them, but there was no substantial response from them.

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Nightingale would also keep reporting more violations of his rights as they kept
happening to him after he first met with FBI-Hbg in the Spring of 2005.
1. From 2005 – 2008, Nightingale would have the careers that he tried starting
repeatedly ruined for him just from discrimination alone.
a. The mistreatment Nightingale received at several work places (across
different states) had been explained off as at least considerably due to
Asperger’s Syndrome.
b. Nightingale argues that even if it is the result of his Asperger’s Syndrome,
to whatsoever degree, it still does not give others the right to mistreat him.
Harassment is harassment, whether it’s done because the person has
Asperger’s Syndrome or for whatever reason – so something should have
still been done about it.
i. Nor does the Asperger’s Syndrome give the accountable authority(s)
the go-ahead to not do anything about it and let everything get
ruined for Nightingale, whether in his legal, career, or personal
affairs, without holding people accountable for discrimination and
possibly harassment.
c. And, as such, those mistreating Nightingale (those that were doing it in an
area, manner, or frequency that could be considered harassment) should
have been held accountable, or at least made to stop, as their violating
Nightingale’s rights
i. And, if federal question is a matter needing proved first, those
perpetrators should have been stopped from repeatedly violating
Nightingale’s PURSUIT OF HAPPINESS (so how is that for a Federal
Question qualifier?), as Nightingale kept losing his career (his
livelihood), couldn’t keep a significant-other relationship (as income is
generally a requisite for that) - which when thought about are
unacceptable; as well as the severe and presently persisting physical
ailments and emotional distresses he had been afflicted with.
d. If the authorities had done just that, Nightingale’s work environment may
have very well been agreeable for him, which in turn would have allowed
for him to keep working in that environment.
i. Who knows the contributions he might have made if he had been
allowed to succeed.

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 e. Nightingale continually faced discrimination that was unchecked by the
firms he worked for as well as the relevant authorities.

2006, May | | Untimely Death of Keyvan James Owzar

On May, 11, 2006, Nightingale’s younger brother, Keyvan James Owzar
AA.
(hereinafter referred to as “Keyvan”), died under suspicious circumstances at his
residence in Hampton Township, PA, another suburb of Harrisburg, located above five
miles from his parents’ house in Camp Hill.
On May 11, 2006
1. , on the morning thereof, Nightingale was abruptly awoken and
gripped by what he perceived to be his mother, A.J. Owzar (hereinafter referred to
as “A.J.”), exclaiming over the telephone frantically, saying, “Where is Keyvan?!
Where is Keyvan?!”
Seconds later Nightingale heard his mother telling his father, Albert Owzar
(hereinafter referred to as “Mr. Owzar”), that Keyvan’s then new Mother-in-Law
(name not known to Plaintiff) had just told her, over the telephone, the Keyvan had
somehow died.
a. Keyvan had just gotten married a couple weeks or so prior to Timily Stover,
making her Timily Stover Owzar (hereinafter referred to as “Timily”), and the
lady on the telephone with A.J. was Timily’s mother.
b. Meaning to inquire of Timily regarding this matter, Nightingale walked over
to where Timily and her mother were sitting at the scene. In questioning,
Nightingale simply asked Timily what happened.
c. Not having asked accusatively, Timily’s resting wit let her reveal a major
contradiction about the order of events the night before/ morning of the
death.
d. Nightingale having pointed that out discrepancy to her right then and there,
he got two or so sentences in before Timily supposedly went spontaneously
and temporarily deaf right there and then (as I understand it, she does have
some sort of ear issue), but her countenance that day came across as feigned.

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 2. The Inspector assigned to Keyvan’s incident was Detective Adams of the
Hampton Township Police Department (hereinafter referred to as “HAMPTON
POLICE”), located about 10 miles outside Harrisburg.
3. Nightingale acquainted Detective Adams there that day and was hoping to find
out what happened rather soon.
4. After not having heard from Detective Adams for some days, Nightingale went to
the HAMPTON POLICE to talk to Detective Adams.
5. Nightingale informed Detective Adams of the discrepancies in Timily’s story.
a. Nightingale further wanted to inform the detective about the legal
concerns (those Nightingale was asking the FBI to investigate) he was
having, per adventure the information therein was good for HAMPTON
POLICE and local authorities to have.
b. Keyvan Owzar was a healthy, 24 years of age boy at the time of his death.
i. He had just gotten married weeks before.
ii. He had also around that time passed the physical examination
required to go it the Army.
c. His family, friends, along with a considerable number of the town’s people,
knew about the discrepancies in the statement by Timily (Keyvan’s then
wife), as well as other bits of pertinent factors.
d. Yet his case was never investigated properly.
i. Some people may say “Well, that happens a lot”.
i. That’s one of Nightingale’s points (part of his grievance) in all this.

2006, July | | Move to NYC

On or About July of 2006, Nightingale started exploring career opportunities in
BB.
or around New York, NY and shortly thereafter moved to New York in hopes of
increasing his chances of getting a job
.
1. While living in New York, Nightingale was homeless most of the time, staying at
homeless shelters, as he was still trying to “make it on his own”, so to speak.

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 2. Nightingale was treated rather horribly in New York (which again, that was
considerably seen as just discrimination he was getting due to Asperger’s
Syndrome).
a. Not having been treated well in New York City, Nightingale was pushed
into moving back in with his parents in Harrisburg.
3. Nightingale soon thereafter moved to Northern California, wherein the Silicon
Valley is located, in hopes of increasing his chances of finding a career.
a. He was homeless for a while in Sacramento and San Jose, CA (hereinafter
referred to as “Sacramento” and “San Jose”, respectively), again forbearing
that in hopes that it will give him a better shot at finding a job, as he was
having a hard time finding one over the Internet, and firms tend to like
hiring locals, rather than relocating people, it seemed.
b. Sometime thereafter, Nightingale got a job at Yahoo!, Inc.
i. Yet Nightingale was treated poorly at Yahoo!, as well.

2008, June | | Letter to Department of Justice

On or About the last week of June, 2008 (about one week prior to finding
CC.
a job at Yahoo, Inc.), Nightingale decided that enough was enough. He would write a
letter to a proper authority, it being the Department of Justice, explaining the unusual
inequity has been confronted with for what was, at that time, about two or three years.
Nightingale never received a reply to that correspondence.
1.
2. Days thereafter, Nightingale got a position at Yahoo!, Inc.
3. About two weeks into his position at Yahoo!, Nightingale started being
mistreated by some of his co-workers.
4. This mistreatment was, again, seen, as per a psychologist, in considerable part
due to him having Asperger’s Syndrome.
DD. As the inequities against Nightingale continued, he was soon forced into flying back to
PA and move in with his parents, near Harrisburg.
1. There he stayed with his parents from August of 2008 to May of 2016.

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2018, Jan | | PSP Allegations of A Conspiracy
On or about January the 19th, 2018,
EE. PSP pulled over Nightingale, who
was driving northerly on I-83 in York County. Nightingale and a lady passenger were
driving to Nightingale’s residence after they had just left a night club called “Fat
Daddy’s” in York, PA.
1. PSP performed a series of sobriety tests that, to good defensive deduction,
Nightingale deemed he in fact passed, save only one test that he was not given
the instructions for properly.
a. The particular test Nightingale failed was one where he was asked to stand
on one foot for 30 seconds.
Not until Nightingale had begun the test and was standing on only one leg
did the PSP officer then tell him that he can actually throughout the test put
his foot back down, and then just lift it again and continue counting from
where he left off.
i. As Nightingale was already into performing the test on one leg, he
obviously would not have been able to give that last bit of instruction his
undivided attention.
b. As such, after several seconds Nightingale was wavering (as most people
might after standing on one leg for 10-15 seconds), trying his best to stand
on one leg.
When Nightingale began wavering the officer told him to stop and arrested
Nightingale, who was politely, yet steadfastly, protesting that he had
deduced that he had passed the sobriety test as a whole.
c. Nightingale recalls another test where the PSP officer asked him to hold out
his arms fully extended on both sides, look up to the sky, keep his eyes
closed, and count to 30 (seconds) silently in his mind – then tell the officer
when Nightingale thinks that 30 seconds is up.
i. Nightingale saw the officer’s stop watch timer right at the time he told
the officer he believed 30 seconds were up – the time read 29 seconds
and some milliseconds to it.
ii. As such, he knows he passed that test.

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 d. Nightingale recalls another test where he was asked to follow an object with
his eyes as the officer moved the object in divers directions before
Nightingale’s eyes.
i. Nightingale perceived that he passed that exam just fine.
2. During the sobriety test, and a number of times after the test was over and
Nightingale was in handcuffs, Nightingale insisted and pleaded with the two PSP
officers to let him do a simple breathalyzer test (which is done using a device the
officers keep on hand) to prove that he was not intoxicated.
a. The second officer, the one who was not administering the test, seemed to
have feign an “accidental” dropping of the breathalyzer device they had,
whereby the breathalyzer device broke into at least two separate pieces
when it hit the pavement.
b. Nightingale asked if that the two PSP officers could just radio to ask any
nearby PSP cruisers to stop by so that they could use their breathalyzer
device (as the previous one had broken and was said to be unusable by the
officers).
i. The PSP officers refused to do so.
3. What’s just as pertinent is the nature of the acquaintanceship that happened
between Nightingale and the lady in question (his passenger) that night.
a. Nightingale was walking around in a club called Fat Daddy’s in York, PA
earlier that night.
b. The lady in question, whom Nightingale had not met until that night, had
walked up to Nightingale earlier that night, greeted him (by looking at him
and saying, “Stunning!”, as Nightingale was still in his suit he wore to a
long-time-coming job interview), and then she walked away.
c. Later that night, as Nightingale was sitting down in the club, the same lady
in question sat next to him, and, without Nightingale’s prompting, the lady
touched his genital areas with her hand (having touched that area on the
outside of his pants, that is).
d. She then proceeded to keep giving Nightingale kisses on his head, neck
and shoulder a fair few times.
e. That interaction ended when Nightingale simply got up and said goodbye
and left, as he was a bit anxious that night about his exciting job interview

16
 he had had just earlier that day, and kept wondering if he would secure the
position.
f. Later that night, Nightingale noticed a mild commotion of sorts very close
to where he was in the club.
g. He approached the area and saw that he lady in question from earlier that
night was talking to a handful of bouncers at the club.
h. Nightingale asked what was going on, at which point the bouncers and the
lady explained that she was a bit too much under the influence to drive.
i. Nightingale then decided to offer the lady a ride home (given the affinity
the lady seemed to have with him earlier that night), to which the lady and
bouncers agreed was a good idea.
j. Nightingale, along with the bouncers, then physically helped the lady
walked down the stairs from the second floor they were on.
k. When the bouncers, the lady, and Nightingale got to the front door of the
club, the bouncers transferred complete fellowship of the lady to
Nightingale, at which point Nightingale provided some mild assistive aid to
the lady as they walked to his car, as she seemed to do fine walking by
herself on flat pavement (as oppose to walking down the stairs).
i. Of course, an immediate matter in deduction needed mentioned here
is that, if Nightingale was so intoxicated that he was swerving across
multiple lanes uncontrollably (and no less than three or four times at
that, according to the PSP’s own criminal indictment), it certainly does
not make any sense given Nightingale’s autonomous motor skills,
along with the assistive aid he and the bouncers offered the lady as
they were all walking down the stairs from the club’s second floor,
just 30 minutes or so earlier.
ii. Furthermore, the bouncers approved Nightingale to be the lady’s
designated driver, just 30 minutes or so earlier. They would not have
done that if they saw that he was not fit or even mildly intoxicated.
4. Given the above stated factors, it stands to reason then that Nightingale’s
swerving on the road was not due to him being intoxicated.
a. Indeed, the toxicology report that night showed Nightingale’s Blood Alcohol
Level (hereinafter referred to as “BAC”) was less than half the legal limit (at
about 0.0313).

17
5. In fact, the reason Nightingale was swerving that night (which he tried explaining
to the two PSP officers) goes as follows:
a. Nightingale that night was driving his car with the lady in the front
passenger seat.
b. After about 10 minutes or so into ride, the lady passenger started to all of a
sudden, and unexplainably, jolt in mild, yet unexpected ways, while uttering
what sounded to Nightingale as nothing but unintelligible gibberish.
c. Nightingale did not receive a response from the passenger as to if she was
okay (as in why she was acting that way and saying unintelligible things).
d. The lady passenger then proceeded to reach over and grab Nightingale’s
right hand (as in one of the two hands Nightingale was using to drive) a
series of times. As such, during these moments Nightingale would have to
try to control her grasping intentions, while at the same time trying to steer
with his left hand (which would be easy if Nightingale didn’t have to keep
trying to liberate his right hand from the lady’s grasp).
e. The grabbing got a bit more controlling rather quickly, and Nightingale had
to somehow free his right hand from the lady’s persistent grasp – all this
while trying to steer the car with his left hand.
f. In fact, for what was likely about a 30-minute drive until the PSP pulled
Nightingale over, the lady tried taking control of Nightingale’s right hand
about three or four times, each time causing Nightingale to swerve as he
assayed to liberate his right hand from the lady, while also trying to steer the
car with just his left hand.
g. What’s more intriguing, the moment Nightingale was pulled over by the
police, the lady passenger seemed to all of a sudden abruptly desist in her
bizarre behavior of jolting and uttering unintelligible words, - something she
was doing for most of the ride up until exactly that point.
i. Nightingale tried explaining that to the PSP officers that night, but they
were already intent on him taking a sobriety test, which Nightingale
was willing to do and did.
6. What’s more intriguing, the lady in question was entirely calm, and almost
entirely quiet, the entire time of the sobriety test, as well as the subsequent
arrest and ride-in-the-police-car.

18
 a. This lady appeared to be just fine, albeit mostly quiet, when the PSP police
officers sat both Nightingale and the lady passenger in the back of the
police car (both in handcuffs).
b. The lady was almost entirely quiet in the police car and had no
loquaciousness (whether intelligible or not) about her at all it seemed.
7. The only readily noticeable response she did seem to give during the ride in
the police car was an annoyed or otherwise disfavoring posture, sudden
jolting, and look (as in she rolled her eyes as if annoyed) when Nightingale
was explaining to the officer that he was interviewing at a school called the
Baldwin School. The moment Nightingale mentioned the name of that school
she gave that abrupt, unexpected, and disfavoring jolt and rolling of the eyes,
along with some short grunt.
8. She seemed to give another similar but even more intense countenance of
disfavor towards Nightingale once more when Nightingale also mentioned that
there was another school nearby the Baldwin School, called the Agnes Irwin
School, that he also was looking into.
9. It is in context, and, as such, pertinent here to mention that Nightingale, a male
adult, enjoys working with girls in the context of schooling and the recreational
activities.
a. As such, he has always been forthcoming that he has desired to work at a
school for girls, and has the references, and, indeed, an entire teaching
candidate portfolio, to show that he would very well be a good candidate at
such a school.
b. The two schools, Baldwin and Agnes Irwin, are both private, all-girls schools,
teaching students in the Pre-K through 12 levels (both are located just
outside Philadelphia in a suburb called Bryn Mawr).
10. Nightingale had not mentioned to neither the police officers nor the lady in
question that night that those were actually all-girls schools, only mentioning the
schools’ names.
a. Those two schools are located just outside Philadelphia, which would be
about 100 miles away from the York County (where the pull-over and
sobriety test were done).
b. It is highly unlikely that either the two officers or the lady would have heard
of either of these schools, as they are very far away (for a school) and

19
 usually far too expensive for the vast-majority of people to afford (five
times more expensive than a Harvard education, actually).
c. Nightingale himself, an enthusiast for working at those types of schools,
had only heard about them for the first time about one year or so prior (as
he was working rather hard for an entire or so to secure an interview at a
such a school).
d. Given the officers curiosity as to the names of the schools Nightingale
was interviewing, or was trying to interview, at and given the lady’s put-off
countenances and seeming disfavoring attitude towards Nightingale the
moment he mentioned either of those two schools’ names, it stands to
good defensive deduction that the officers, along with the lady, has some
sort of interest the schools’ Nightingale wanted to work at, because, for
one, they probably wouldn’t have known about those schools otherwise.
i. Again, as those are not well-known schools in the area of York, PA
(which, again, is about 100 miles, a long way away, in Philadelphia and
cost far more than a Harvard Education), it stands to reason that the
police and the lady in question in all likelihood would not have known
about these two schools – not until Nightingale somehow became
pertinent to them.
11. As Nightingale is an adult, a male adult at that, it stands to reason that, given
the deductions revealed just above, they might have had preconceived
misgivings about males’ wanting to work at an all-girls school.
a. Unlike a co-ed school, because there are no girls at co-ed schools, so it’s
okay for guys to teach there all the time.
No, that’s being facetious, there are of course girls at both co-ed and
private schools.
i. So, the point is that it’s not logical to want to give guy teachers
working at co-ed schools “Huzzahs”, whilst that those working at
private schools for girls are labeled as potential anti-christs.
ii. For Nightingale personally, it can really cheer him up to be in their
presence, especially in the context of teaching and recreational (like
recess or art) activities at a school of that sort. That’s all there is to it –
that and an undercurrent of desiring to be there so Nightingale can
help look after them.

20
 b. It sounds like the PSP and that lady in question (who would not give
Nightingale her name, as it happens) might have just let fear get the
better of them.
12. Furthermore, as it stands to judicious impartial judgement that, as:
a. Nightingale did in fact get designated by the club bouncers to drive the
lady in question as her designated driver that night that (and that just
maybe 30 minutes before the police pulled Nightingale over), and
b. Nightingale did overall pass the sobriety test the PSP officers
administered that night, and
c. The PSP officers would not allow Nightingale to take a breathalyzer test,
which they knew would prove Nightingale was not even half-intoxicated –
they knew that because they seem to feign an “accidental” dropping of
the breathalyzer device, which broke the device into two separate pieces,
and
d. The curiosity of the officers as to the names of the individual schools
Nightingale wanted to work at, and
e. The annoyed or disfavoring jolting reaction of the lady in question that
night (including her rolling her eyes) in two back-to-back instances the
moment Nightingale would mention the names of either of the two
schools he wanted to work at.
f. It stands to judicious reason that, if not intoxicated (as per the bouncers’
judgement just about 30 minutes prior, as well as the seeming passing of
the sobriety test) that there is a reasonable possibility that Nightingale
was not illegally intoxicated that night and,
g. by extension, the reason the PSP arrested Nightingale that not was not for
intoxication, but perhaps some other reason, and
h. It stands to reason that it had to do with Nightingale wanting to work at a
private school for girls.
i. Furthermore, that night, while in York County Jail, the same PSP officer
that conducted the test was asking Nightingale questions about where he
was from and the culture thereof.
i. Nightingale told the officer that he was born in Persia and had lived
in the U.S. since he was seven years of age.

21
 ii. It seemed to Nightingale that the officer’s curiosity seemed a bit
more intense than the typical person he has had asked him those
questions in the past.
13. As such, the incident of the PSP bonding Nightingale on the night of January
the 19th, 2018 was in all honest deduction a matter of Conspiracy, and by
extension of them being a government agency, a major Civil Liberties violation;
a. – one that they were willing to cover-up and let Nightingale live a ruined
in the aftermath of.
14. Furthermore, and this is very important, it stands to reason that the PSP had
been watching Nightingale for a much longer time than that night.
a. As such, they would have known about Nightingale’s hapless state in so
many respects, including his love-life being inexistent, due to all the
discrimination and mistreatment that have ruined Nightingale’s affairs for
the past 13+ years leading up to the time of the arrest.
i. Meaning they used this lady to lure Nightingale, using his hapless
state at that time as the weakness with which to entrap him.
15. All this as Nightingale has already suffered a lot of physical and acute
emotional distress, by the time of the arrest having been diagnosed as:
i. an adult with Asperger’s who was already going through a lot of emotional
stress over other matters that had ruined his life, when he had to come to
reflect and deduce all this sometime later (mind you, Nightingale has been
being tested for signs of Cardiomyopathy (Broken Heart Syndrome) twice
this year, in addition to the Adrenal Cortical Insufficiency and IBS he has
already been diagnosed with).

2018, Mar | | Regarding Sex-Trafficking of Former Acquaintances

On or about March the 5th, 2018,
FF. Nightingale contacted emergency
service number 911, as he was concerned that his apartment might have been the
victim of breaking and entering.
1. When three East Pennsboro Township Police (hereinafter referred to as “East
Penn Police”) officers arrived at Nightingale’s residence, located at 201 York

22
 St. Apt. 6 in Enola, PA 17025, they searched the apartment and found no one
in it.
2. Nightingale thanked the officers but felt compelled to mention one of the
factors that concerned him with regards to the suspected break in.
a. Nightingale told the officers that he thought he might have seen
Kimberly Lopert (Kimberly) at Fat Daddy’s night club in York, PA just two
nights prior (which was a Saturday, as Nightingale was talking to the
officers on a Monday night).
b. Nightingale further stated that the girl who looked like Kimberly seemed
distressed, a bit scared, and, worse, seemed like she was being told what
to do and where not to go in the club by some three or four guys and
girls that were with her (the other members of her party unknown to
Nightingale).
c. Nightingale then further informed to the three police officers that he
met Kimberly a little over four year prior at a club in Harrisburg called
Savannah’s on Hanna (hereinafter referred to as “Savannah’s”), where
Kimberly at that time worked as a dancer.
d. When Nightingale told the three officers that
i. Kimberly use to work at Savannah’s, and
ii. that someone matching her description seemed like she was being
told what to do and where not to go (as in being controlled to a
peculiar extent, however, subtle) at a night club,
iii. When Nightingale said that one of the officers interjected,

“Well, if it’s Savannah’s, then it’s sex-trafficking!!!!”.

e. Nightingale became very alarmed at that. While he had prior heard

rumors that indicated that the girls working at Savannah’s sometimes
get involved in prostitution, it had never crossed Nightingale’s mind that
sex-trafficking (as in being told or intimidated to do sex-working against
one’s own will) might be going on in Savannah’s.
f. Nightingale had heard and witnessed some bad things at Savannah’s
when he used to attend Savannah’s about three years prior to the night
in question.

23
 But none of what he had witnessed it made him consider that sex-
trafficking was going at Savannah’s.
g. The East Penn Police officers then went on to explain that they do
suspect Savannah’s of sex-trafficking, but that it can be difficult to prove
in Savannah’s case.
3. A little over a week after this conversation with East Penn Police, Nightingale
called emergency services 911 and asked to speak with the East Penn Police.
a. Nightingale was a bit frantic, telling the 911 operator that he had
contacted Kimberly by cellphone text message (cellular SMS texting)
and told her what the East Penn Police had told him about her possibly
being sex-trafficked and that he (Nightingale wanted to help her).
b. Nightingale had gotten a response to that text message by someone
claiming to be a middle-aged male that did not know who Kimberly
was.
c. Furthermore, that “middle-aged male” seemed to be taking the
mentioning of sex-trafficking regarding Kimberly rather flippantly.
d. This got Nightingale very concerned that the person replying may very
well be Kimberly’s sex-work handler (as in sex-trafficker, aka “pimp”, if
you will) and that this person replying may now see Kimberly as a
liability and may want to harm her.
4. The 911 operator had the East Penn Police call Nightingale.
a. Nightingale explained the situation to the East Penn Police officer over
the telephone.
b. That East Penn Police officer reiterated that they suspect Savannah’s of
sex-trafficking, but that it can be very difficult to prove in Savannah’s
case.
c. The police officer then asked Nightingale for Kimberly’s phone number
so that he (the police) officer may call her to check on her.
d. It is alleged that Kimberly received about two phone calls from an
“unknown/ number not revealed” caller ID shortly thereafter that night.
Those calls, understandably, in all likelihood were made by the East
Penn Police officer after he got off the phone with Nightingale that
night.

24
GG. The history Nightingale and Kimberly, along with some of their other
acquaintances, shared at Savannah’s is a rather dark, sad, and disturbing one, given
what happened to them and some of their acquaintances at that club.
1. After attending Savannah’s for about six months in May of 2014, Nightingale
came to find out from one of the dancers at Savannah’s, a dancer with the
stage-name “Minx” (Minx was a Caucasian girl in her twenties, at about 5’ 10”
in height, shoulder-length blonde hair, she may have originally been from
Fairfield County, CT, and there is a chance her real name is something
homophonic to “Anjali”) suggested to Kamran that two of his closest buddies
at Savannah’s may have been sexually-assaulted there about five or so
months prior.
a. The first girl in question was a dancer with the stage-name “Nicole” (she
was about 5’ 8”, slender, of a tan complexion, with long, curly, dark hair).
i. Minx suggested to Nightingale that Nicole had indeed been
drugged one night while working inside the Savannah’s, and that she
had then subsequently been sexually-assaulted later that night
(though the sexual-assault itself might not have occurred at the club,
albeit the alleged drugging is said to have occurred at the club).
Minx further went on to tell Nightingale that it was done by two
guests who are regulars, and are known for prostituting (as a client,
not pimp, as I understood it) some of the girls working at
Savannah’s. She did not give the identities of those guests to
Nightingale, however.
Minx then concluded by saying that, after the alleged drugging and
sexual-assault, the two guests themselves (who were said to be male)
were still allowed to keep coming to the club, while that Nicole got
fired over the drugging/ sexual-assault.
ii. Nicole was one of the girls Nightingale got acquainted with early on
at the club. She stands out in Nightingale’s recollection because, the
very first night he and her sat down and talked to each other was
also the last night Nightingale ever saw her. She, for reasons not
determined by Nightingale up until the time of Minx’s allegations,
never returned to the club after that night – certainly not for the time
being Nightingale attended it.

25
 b. The second girl in question was a dancer whom, next to Kimberly, was
Nightingale’s closest acquaintance there. Her real name Angelique Diaz
(stage-name at the time was Lola), she was in her early twenties, was
about 5’ 5”, slender, with a slight Latino complexion, and was from
Lancaster.
i. Minx proceeded to tell Nightingale that Angelique and a former
bouncer named Roger were NOT, in fact, fired for having relations
with each other at the club, but that Angelique was, in fact, sexually-
assaulted by Roger, who was then fired while Angelique took a
temporary leave (a leave that might have lasted one or two months
as Nightingale recalls).
c. The very week Minx told Nightingale this was the week Nightingale was
due to fly out of state for a surgery, and he did not return to Savannah’s
for about another six months, in late-October 2014.
2. After Nightingale started attending Savannah’s for a second time in that
late-October of 2014, he attended the club for another four months, into
late-February of 2015, before deciding to permanently leave the club and
never attend it again.
During that second stint at Savannah’s:
a. Nightingale himself was physically-assaulted in the genital area by one
of the bouncers working at the club. He had been the victim of male
genital damage by means of aggravated-assault by one of the
bouncers at Savannah’s, all that while a lady manager was standing but
five feet away from him (her name likely Jillian, she might have become
their General Manager later on).
b. Furthermore, he had suspicions that his closest and dear acquaintance
at Savannah, Kimberly, may have also been sexually-assaulted, given
the aforementioned allegations by Minx six months prior – allegations
regarding the other girls being drugging and sexually-assaulted at
Savannah’s.
i. Kimberly seemed different than Nightingale remembered her to be
just six months prior, and as such, the suspicion did cross his mind,
though at the time he was never able to get any sort of convincing

26
 proof of it – which included Kimberly’s denial, in November of
2014, that anything had happened to her.
c. Furthermore, Nightingale was also concerned about another of his
girl-acquaintances at Savannah’s, a girl whose name is Audrianna
Duvall, who seemed to have also unexplainably stopped working at
Savannah’s.
3. In late-February of 2015, Nightingale decided that Savannah’s had become
an undesirable, indeed, dangerous, place and that it was time to leave for
good.
a. Kimberly with a very emotional Nightingale had their last conversation
at the club in late-February 2015.
i. During that conversation Nightingale told Kimberly that he
would likely not be coming back.
ii. To which Kimberly’s response was “Not even in like maybe a
year or two? (Paraphrased)”, to which Nightingale pretty much
made it obvious that his continued attendance was highly-
unlikely to happen.
iii. Furthermore, a suggestion in all this was that Kimberly should
leave Savannah’s, as well, as it was not a good, nor even a safe,
place to be anymore.
iv. Nightingale and Kimberly exchanged several hugs during that
conversation.
v. Nightingale also told Kimberly that if she ever stops working at
Savannah’s he would like for them to get back in contact and
become acquaintances again – outside Savannah’s.
vi. Nightingale left Savannah’s after that last discussion with
Kimberly – and he never returned to Savannah’s since.
4. On or About the Winter of 2017 (about two years after Nightingale stopped
visiting Savannah’s club) Nightingale was informed by an acquaintance,
whom he had met at Savannah’s about three years prior, that Kimberly, and
possibly Audrianna, had in fact been sexually-assaulted while working at
Savannah’s.
a. The acquaintance in question was Paige Ransome, aka “Ran”,
(hereinafter referred to as “Paige”). Paige’s stage-name while working

27
 at Savannah’s was “Vivian”, and it was possibly later changed to
“Seven”.
b. Paige indicated that Kimberly had been drugged at Savannah’s by
means of a substance sometimes referred to as “rufee”.
i. The account goes that Kimberly had been drugged with the
substance and was unconscious and about to be sexually
assaulted, when by happen stance, somebody else happened
across the scene and was able to prevent the physical part of the
assault from going any further.
c. When Nightingale also inquired of Paige about Audrianna Duvall, I
got the suggestion that she had been sexually-assaulted, as well.
d. In total, it is alleged that four of Nightingale’s closest acquaintances at
Savannah’s were all sexually-assaulted in the same six-month period,
from about January – June of 2014.

2013, Jan | | Corrupt Doctor with Morbid Mal-Practice

On or About January of 2013, and all the way to about April of 2015,
HH.
Nightingale had serious physical damage inflicted to his pelvic region at least twice
by a doctor who it later turned out was running a very dangerous medical scam – a
scam that was repeatedly reported, but repeatedly unchecked, for many years.
Dr. James Elist (hereinafter referred to as “Dr. Elist”) is a surgeon based in
1.
Beverly Hills, CA (hereinafter referred to as “Beverly Hills”).
2. Dr. Elist has, for at least several years at the time of this complaint,
repeatedly implanted in patients a pelvic device that almost always fails,
then has to be removed, and leaves serious damage to the male’s pelvic
region.
3. This is a matter well-known to other surgeon’s in Elist’s field, as Nightingale
has had at least two leading surgeons in the country tell him that Dr. Elist
has been implanting a dangerous device into males’ pelvic regions for years
– a device that has been shown to fail almost all the time, leaving serious
damage to the male pelvic region.

28
 i. This damage is so severe it often times ruins a male’s life.
4. The two doctors that informed Nightingale of this (after his injuries) were Dr.
Gary Alter of Beverly Hills, and Dr. Mark P. Solomon of Philadelphia.
5. The doctors that told Nightingale this also said that there have been
numerous complaints against Dr. Elist by patients who have had their pelvic
region sustain serious injuries as a result of Dr. Elist’s device, but that
nothing is usually done about it.
6. As of Summer of 2018, a formal complaint has been filed against Dr. Elist by
the Medical Board of California after Nightingale filed a formal grievance
with them; however, that is after several years of persistent failed implant
insertions surgeries (which, again, leave damages that pretty much ruins a
male’s life to a considerable extent) and numerous complaints that seemed
to have been ignored for several years.

2013, Mar | | Swatara Township Police

On or About March the 22nd, 2018,
II. SWATARA POLICE filed a set of
charges against Nightingale under uneducated, and certainly unverified
circumstances – all without even questioning Nightingale once prior to charging
him.
1. SWATARA POLICE should have known that there was a considerable
probability that the accusations were at least grossly misconstrued, given a
prior experience they have had with Nightingale about eight months prior in
July of 2017, where Nightingale was pleading with them to check on Kimberly
Marie Lopert (Kimberly), who lived in SWATARA POLICES’ jurisdiction at the
time:
2. On or about July the 15th, 2017 (about eight months prior to the filing of the
charges by SWATARA POLICE), Nightingale had contacted emergency phone
number 911 and asked to speak with the police service that had jurisdiction
over a particular neighborhood in Bressler, PA (which is about five miles
outside of Harrisburg), as he had reason to believe Kimberly, who at that time
lived in Bressler, could be in danger.

29
a. Nightingale was put in contact with SWATARA POLICE, as the jurisdiction
of that neighborhood in Bressler was theirs. SWATARA POLICE instructed
Nightingale to drive to their police station so he can speak to them.
b. Soon thereafter, at around 1:00AM on July the 15, Nightingale arrived at
their police station parking lot and waited for the police to arrive.
c. When they arrived (in a police SUV marked with SWATARA POLICE logo),
two police officers, the driver (a male, African-American, about 6’ in
height, with a rather athletic build) and his partner that night (a female,
Caucasian, about 5’ 6” in height, with long, blonde-toned hair that
seemed black at the roots), got out and started talking with Nightingale.
d. Nightingale proceeded to explain to the two officers that he had received
information from a former law enforcement acquaintance of his that
Kimberly may be in dire straits and in danger.
i. The name of the informing acquaintance was Ginnie Seaborn Heaton
(Ginnie), who, according to her own admission, use to work white-collar
crime law enforcement with FBI personnel, as well as a lot of police
chiefs, all over the country.
e. When Nightingale received this information from Ginnie, he got very
concerned, given the history he and Kimberly both experienced together
at Savannah’s
f. The moment Ginnie informed Nightingale that Kimberly may be in
danger, Nightingale pleaded with her repeatedly to send one of her FBI
contacts (or another personnel) into the situation to check on Kimberly,
and if necessary, pull her out of a dangerous environment.
i. These pleading took place a fair few times over the course of about
half-a-day.
ii. Nightingale further added that Kimberly could always come stay at
his apartment, should she need a place.
g. Though Nightingale pleaded over the course of about 12 hours with his
then acquaintance Ginnie to send someone to look into Kimberly’s
welfare, Ginnie refused to do so.
h. Nightingale told the officers that night that he would reveal to them the
name of his contact (Ginnie, that is)

30
 i. He asked that they only use discretion with her name, given the
nature of her prior (and possibly even then-current) law enforcement
work.
i. The male officer that night was shown, by Nightingale, the communique
between Nightingale and Ginnie, and
i. That it indicated that Kimberly was on such a bad path in life that
Ginnie warned Nightingale that if he does manage to win back
Kimberly’s friendship, that he would have to be very careful that
Kimberly would not pull him into whatever Kimberly was said to be
into at that time, and being rather vague as to what it was Kimberly
was into until finally she revealed that she thought Kimberly was
hooked on a narcotic called Meth (known more formally as Crystal
Meth).
ii. The male officer that night also saw that Ginnie had, in fact, given
Nightingale Kimberly’s address during that very same communique
(Ginnie herself in turn having obtained that address via a
Google.com Internet search).
iii. The officer saw how Nightingale was pleading with Ginnie, and that
Ginnie would not agree to look into Kimberly’s welfare.
j. About 21 hours later, Nightingale had had enough torment at the
thought of what might be going on with Kimberly and he decided he
would have to look into it himself.
i. He did so and was able to find someone in Kimberly’s then Bressler,
PA neighborhood that was able to identify Kim by a photograph
Nightingale had of Kimberly on his mobile phone.
ii. The neighbor seemed to indicate that he was not aware of any
considerable danger nor life-style choices Kimberly was into.
i. He also said that Kimberly had gotten married about two
months prior (which seems to have turned out to be not
true).
ii. He furthermore claimed that Kimberly’s then
boyfriend/new-husband, Brian Anthony Orlando
(hereinafter referred to as “Orlando”), was one of his (this
neighbor’s) employees or a co-worker of sorts.

31
iii. He went on to try to tell me where Kimberly’s new house
was (as the address Ginnie had given was no longer
where Kimberly lived it turned out) – the new house her
and her new husband had purchased. Nightingale told
him that he would rather not get Kimberly’s address, lest
it should get her in trouble with her new husband.
iv. The neighbor, without Nightingale inquiring about it, also
went on to tell Nightingale that Kimberly was then
working at a nearby hotel.
1. Nightingale’s response to that was
“She works in the bakery!”, and the fellow seemed
to acquiesce.
2. Nightingale didn’t know she worked at a bakery in
a hotel. He only deduced that she likely worked in
the Hotel’s bakery because Kimberly had gone to
school and studied Culinary Arts (a subject
Nightingale and her would periodically talk to each
other about when they had dinner together at
Savannah’s).
v. Nightingale had misgivings about the accuracy of what
this neighbor was telling him, and he didn’t want to not
do something only to have something bad happen to
Kimberly (naturally, that would be a mistake he would
have regretted rather intensely for the rest of his life,
given the degree to which he esteems Kimberly).
vi. As such, as a fail-safe, if you will, for Kimberly’s well-
being, Nightingale gave a note to the neighbor to give to
Kimberly if he saw her.
1. In that note Nightingale indicated to Kimberly that
he had received information that indicated she
could be strung out on narcotics.
2. Nightingale also put his contact information,
including his address, in the note, telling Kimberly
that if she ever needed a place to stay, she could
always come stay with him.
32
iii. Nightingale then left the neighbor in question and began driving
back home.
iv. Fifteen minutes into Nightingale’s drive back home, he got a
Messenger chat request from Kimberly.
v. Kimberly could not understand why Nightingale was out looking
for.
vi. Kimberly was also very angry, and Nightingale tried assuring
Kimberly by informing her that someone he knew that works in
law enforcement circles suggested to him that Kimberly was in
bad shape in life and strung out on narcotics, such as meth.
i. Apparently, Kimberly didn’t believe Nightingale.
vii. Kimberly’s then boyfriend/husband, the aforementioned
Orlando, got involved in the Messenger chatting and asked what
Nightingale was doing.
i. Nightingale explained the information he received.
ii. Orlando told Nightingale to stay away from them, which
Nightingale agreed to.
iii. Shortly later, during that chat, Kimberly sent a message to
Nightingale stating that Orlando was considering whether
or not Kimberly and I might be having an affair of sorts.
iv. Nightingale sent back message assuring them that that
was not going on and that he was only there because he
pleaded with law enforcement (at that time Ginnie) to
look into her. When Ginnie refused, Nightingale felt
compelled to have to look into it himself, concerned that
if he didn’t do it then no one would and something really
bad could happen to Kimberly.
v. Orlando appeared to remain agitated, and, as such,
Nightingale got concerned regarding how Orlando would
react towards Kimberly, whether he would hurt her or not.
1. In addition to matters about Kimberly alone, Ginnie
had also suggested to Nightingale that Orlando
was a bad character who mistreated Kimberly
pretty badly.

33
 viii. As such, Nightingale called 911 that night and was told to drive
to the SWATARA POLICE station (at around 1:00AM) to implore
them to look into Kimberly, as Nightingale was concerned that,
in addition to his first concern about narcotics, he was also now
concerned that Orlando may want to hurt her, thinking her and
Nightingale were romantically involved.
ix. Nightingale was very worried and rather visibly emotional that
night when he was speaking to the SWATARA POLICE in their
police station parking lot, exclaiming:
i. “Look, she (Kimberly) had some really bad things happen
to her at Savannah’s..” (Paraphrased), and
ii. “I just don’t want him (Orlando) doing anything to hurt
her! (so, please, could you check on her. (Paraphrased)”,
and
iii. “Please just go to their (Kimberly/ Orlando’s) house and
tell Orlando that I did in fact show you (the police) the
evidence that I had received information that Kimberly
was in danger and that’s the reason I came, not because
her and I were having an affair!” (Paraphrased)
x. The male officer refused to go to Kimberly’s house and explain
that at most he will call Kimberly by telephone.
i. To which Nightingale insisted that it would be best to call
Orlando and let him know, not just Kimberly.
xi. As such, Nightingale had proven himself in trial by ordeal eight
months earlier on the night/ dark morning hours of July the 14/
15th, by showing the SWATARA POLICE his actual evidence of the
communique Ginnie had sent Nightingale about 24 hours
earlier.
k. The male police officer told Kamran to stay away from Kimberly.
3. About six months later, in late-January of 2018, Nightingale met a
girl by the name of Sarah Snyder (hereinafter referred to as Sarah) of
Steelton, PA.
i. Nightingale came to find out that Sarah at least knew who
Kimberly Lopert (Kimberly) was.
ii. Nightingale simply inquired about Kimberly asking
34
 i. “Is she doing okay?”, and
ii. “Is she happy in life”, and
iii. “Is her new husband (Brian Orlando) a decent guy?”,
along with other similar questions.
iii. Sarah’s response was speechless, because quite literally she
would say nothing and instead had a unsettlingly sad look on
her.

4. About six weeks later, On or About March the 3rd, 2018,

Nightingale was at Fat Daddy’s club in York, PA, when he saw what
appeared to be a girl who looked very much like Kimberly.
i. This girl in question seemed to be rather afraid and annoyed at
the same time.
ii. She seemed to be with a group of four or five people, of whom
one was a very tall and slender male. It seemed as if she was
being told what to do and where to go.
iii. There was a bouncer by the name of Patrick O’Mara (last name
may not be spelled correctly, though it would be homophonic)
at the club who might have also perceived this incident, as well.

5. Two nights later, on March the 5th, 2018, Nightingale called

the East Penn Police, in the aforementioned incident (dated March 5th,
2018) to report a potential breaking and entering into his apartment
at 201 York St. Apt. 6 Enola, PA 17025.
i. After a search of the apartment did not reveal an intruder, the
police said that it was good Nightingale called, just be on the
safe side of things.
ii. When Nightingale then told the police officers that his concerns
for a break-in were heightened because he thought he saw
Kimberly Lopert in distress at Fat Daddy’s club just two nights
prior, seemingly being told what to do and not do by her
company, one of the police officers interrupted and said
“Well, if it’s Savannah’s then it’s sex-trafficking”
iii. That officer further went on to say that they suspect Savannah’s
of sex-trafficking, but that it can be really hard to prove in
Savannah’s case.

35
 iv. Nightingale then pleaded with them to look into Kimberly to
ensure her safety,
i. To which the police that night said they couldn’t because
she did not live in their jurisdiction.
v. Nightingale then asked them if they can at least call the state
police.
i. They told Nightingale that he shouldn’t do that either.
vi. Instead, they told Nightingale to go to the Department of
Homeland Security’s Immigration and Custom’s (hereinafter
referred to as “ICE”) office to report this entire matter, as they
are the agency that handle counter-sex-trafficking.

b. The following day, On March the 6th, 2018, Nightingale drove

to the ICE offices and related the entire tale, including the history of
him, Kimberly, and the other girls at Savannah’s.
c. The ICE officer Nightingale spoke with said they would look into this
some as it was police officers (the East Penn Police) that told him that
sex-trafficking may be involved.
d. However, the ICE officer also told Nightingale that in many of these
cases they never hear from these girls again and the they will likely let
it go and that Nightingale should just forget about it, as well
i. The way the ICE officer said that almost made it appear as if it
would be inconvenient to look into Kimberly thoroughly and try
to find her and that it’s just convenient in cases like this to forget
about the girl and perhaps sweep it under the carpet, so to
speak. This is sometimes perported to be the attitude law
enforcement has at times with girls that work at gentlemen’s
clubs, and that’s what Nightingale thought was, at least in
considerable part, going on.
e. Nightingale made it rather plain that,
“Yea, that’s not going to happen!”
f. To which the ICE officer’s response was an annoyed.
“Okay, well you go ahead and do what you gotta do.”
6. Eight Days Later, On March the 14th, 2018, Nightingale sent a text
message (via mobile phone SMS texting) to Kimberly telling her that

36
 he had had three police officers suggest to him that she was possibly
being sex-trafficked.
i. Nightingale called after eight days of being emotionally
tormented by thoughts of what could be going on with Kimberly
in the context of sex-trafficking.
ii. He was persistently tormented with imaginations of Kimberly
being held down against her own will in the context of sex-
trafficking.
iii. Furthermore, with uniformed police officers suggesting the sex-
trafficking, it then became apparent that perhaps Ginnie wasn’t
mistaken about Kimberly’s situation when she (Ginnie) sent
Nightingale the information about her eight months prior in July
2017.
iv. Furthermore, given what had happened to Kimberly and
Nightingale and their acquaintances at Savannah’s was
tormenting him, having thoughts that he failed Kimberly before
in that context.
v. After eight days of that kind of torment, and what appeared to
be law enforcement’s indisposition (akin to what had been going
for the past 13 years discussed in this complaint), and the
thought that hesitating might have irreparable consequences,
Nightingale couldn’t take the torment anymore. The law
enforcement did not provide Nightingale with any updates
during that time.
vi. As such, and being that this was the girl Nightingale had taken a
liking to and cared for very much, he was compelled to send
Kimberly a text message explaining the situation.
7. Weeks later, Nightingale received a criminal complaint in the mail
that showed that SWATARA POLICE had filed charges against him.
8. SWATARA POLICE should have known, given the prior incident in July
2017, that Nightingale had sincere reason to be concerned for
Kimberly then, and that he may very well have good reason for trying
to help her again.
9. SWATARA POLICE, had seen the evidence that night that showed
Nightingale was telling the truth about that.
37
 10. Nightingale tried his hardest to get the authorities, including the sex-
trafficking federal police, to help Kimberly. When they indicated
through word and action that they wouldn’t, Nightingale felt as if he
had to.
11. SWATARA POLICE, withheld evidence that would have shown
Nightingale’s sincere motives, reasons, and regards for feeling
compelled to do something himself, lest waiting for the police to do it
causes something bad to happen to Kimberly.
12. Furthermore, the SWATARA POLICE never came even once to
question Nightingale about the second incident, which they should
have given the evidence he showed them during the first incident in
July of 2017.
13. Furthermore, SWATARA POLICE never came to question Nightingale
about the incident before pressing charges against him, though they
knew exactly where Nightingale resides, and Nightingale would have
been available for them to ask questions to.
i. And, again, to imperatively reiterate, they should have done so
given Nightingale having proven himself in a prior trial by
ordeal, that was processed through their very police department
just eight months prior, on the very grounds of their own police
station.
14. A government police service, those deliberate false accusations by
SWATARA POLICE are a violation of Nightingale’s Civil Liberties.
15. Furthermore, even if SWATARA POLICE were to claim negligence,
even gross negligence (as oppose to deliberate intent), on their part,
it would still be a violation of Nightingale’s Civil Liberties.

2018, May | | York County Courts, False Imprisonment

JJ. On or about May the 4th, 2018, Nightingale showed up to Magisterial court of the
Honorable Judge Robert A. Eckenrode, in York County, PA, for his Preliminary
Hearing for the aforementioned DUI charges pressed by PSP.

38
 1. Nightingale had arrived about 10 minutes late for that hearing and
met with the judge outside the courtroom, as the judge had cancelled
that hearing after Nightingale was five minutes late.
2. Judge Eckenrode told Nightingale to expect a letter in the mail from
York County Courts, indicating the date of a rescheduled hearing.
i. Judge Eckenrode indicated that Nightingale would get the letter
the following week.
3. After seven days Nightingale had still not received a letter, so he took
the initiative to contact the York County Courts to find out when he
should be getting that letter.
4. When Nightingale called York County Courts, he spoke with some
whose name was rather homophonic to “Markita” or “Markita”.
i. This lady informed Nightingale that the hearing was actually
earlier that day.
ii. Furthermore, Nightingale was told that, a Bench Warrant had
been issued for his arrest.
5. Nightingale tried explaining to the lady that he was told by Judge
Eckenrode that he would receive a letter in the mail from the York
County Courts telling him the date of the hearing.
i. To which the lady’s reply was that that is not their responsibility,
but that it was Judge Eckenrode who was suppose to tell me the
date of the rescheduled hearing.
6. Nightingale contacted Judge Eckenrodes office and asked if they
could speak to the York County Courts and tell them that it was a
misunderstanding between them and the county court.
i. The lady Nightingale spoke with at Judge Eckenrode’s office
refused to do so, saying that is something I have to sort out with
the county courts.
7. On June the 3rd, 2018, Nightingale was imprisoned at York County Jail
and was kept there for eight days, until a painstaking effort on his
parents’ part, which included his parents calling many lawyers and
bail bonds men, and also paying a $5,000 bail.
KK. In late-October of 2018, Nightingale contacted the Department of Justice’s Civil
Liberties division.
1. Nightingale spoke with Kevin (whose last name may be Callahan).
39
 2. Nightingale explained everything that had happened to him.
3. Kevin then said that I should file for a Motion-To-Dismiss.
4. He also urged that I get another attorney relative to the one that I
had had since early-June 2018 while still in York County Jail, as that
lawyer for some reason failed to bring up the rights that Kevin
claimed Nightingale has.

CAUSE FOR ACTION

2018, Nov | | FBI: Count 1, Gross Neglect

LL. First CAUSE OF ACTION
COUNT 1, Against FBI
Gross Neglect
November the 1st, 2018

1. The FBI has, for however long, quite long, indeed, very long, not been
dutiful and diligent in maintaining order inside their own service.
i. Their own personnel have been getting away with at least gross
negligence, and for some time now.
ii. Nightingale sees them as having lost control over some of their
responsibilities.
iii. As such, and as a side note, the FBI may very well need
Nightingale to do this, that, in part, it will be a monumental
boost in helping sort out this internal issue they haven’t been
able to seem to sort out.
2. As a result of the FBI’s Gross Negligence, it eventually led to loss of
control over too many of their responsibilities, those uncontrollable
assets then allowing people to get away with violating others’ rights
(whether as a matter of general indisposition or, in some cases,
possibly an actual sense of affinity with the perpetrators).

40
3. Furthermore, as a result of their Gross Negligence, the FBI caused a
trickle-down effect that then influenced state and local agencies to
see that type of gross negligence as the way of doing things, and, in
turn, begin their own sub-culture of gross negligence.
4. As a result of the FBI’s persistent indisposition towards the concerns
of Nightingale, the lack of control over their own assets and internal
sub-operations, Nightingale has been afflicted with acute, horrible,
daily gross-stress inducing, conditions, such as Adrenal Cortical
Insufficiency, hyper-acidity, IBS, and possibly even Cardiomyopathy
(more commonly referred to as Broken Heart Syndrome).
5. As can readily be deduced by all this, Nightingale has suffered
unbelievable emotional distress these past 13 years or so, and has
reached a point where it seems his life has been so ruined and that he
may very well not have a future.
6. As the result of Gross Negligence, Nightingale, the pertinent girls at
Savannah’s, and other peoples’ lives have been horribly affected –
where if it wasn’t for that Gross Negligence and the trickle-down
affect it had on state and local law enforcement agencies that in turn
also caused an influence of gross negligence on the part of state and
local agencies, the damages and torts inflicted on Nightingale,
Kimberly, the other relevant girls at Savannah’s, as well as their family
and friends, would likely not have happened – certainly not close to
the degree to which those torts took place.
7. Furthermore, Nightingale has had his career opportunities ruined for
him time and again.
8. It has gotten to the point where Nightingale now alleges a conspiracy
on the part of the Pennsylvania State Police (PSP), in large part due to
their expecting to get away with those types of infractions.

41
2018, Nov | | FBI: Count 2, Conspiracy and Fraud
MM. Second CAUSE OF ACTION
COUNT 2, Against FBI
Conspiracy and Fraud
November the 1st, 2018

1. The FBI, an intricate agency of their size and their resources, should
be able to detect such repeated, indeed, persistent, indisposition and
mal-treatment by the personnel they train.
2. As such, it stands to sufficient reason that there was enough internal
conspiring (as in the internal conspiring done to not hold their own
personnel accountable for Gross Negligence/ Dereliction of Duties)
going on internally, however understood, to allow this sort of thing to
happen to Nightingale, and quite probably others, for so long.
3. The conspiracy going on for so long, it can be deduced that there is a
chance there was some personal incentive for their personnel who
were neglecting their duties to do so, which can readily suggest the
motives in turn were, at least in considerable part, fraud on the part of
some of their individual perpetrators.

2018, Nov | | PSP: Count 1, Conspiracy

NN. Third CAUSE FOR ACTION
COUNT 1, Against PSP
CONSPIRACY
November the 1st, 2018

1. On January 19th 2018, PSP pulled Nightingale over, as he was

swerving because a lady passenger in his vehicle was repeatedly
assaying to keep reaching for and taking hold of Nightingale’s hands,
the hands he was driving with.
2. Through solid defensive deduction, Nightingale had seemingly
passed his sobriety test, with the exception of one stand-on-one-foot
test he was NOT properly given the instructions for.

42
 Nightingale repeatedly asked the officers that night to allow him to
perform a breathalyzer test to prove he passed the sobriety test. PSP
refused to allow Nightingale to prove he was not under the influence
with the use of a breathalyzer device, seemingly going so far as to
feign the “accidental” dropping of the device issued to them, the
device thereby breaking into two parts.
It is necessary to mind that the subsequent toxicology report showed
Nightingale’s blood alcohol level at less than half the legal limit.
3. Nightingale was wrongfully imprisoned.
4. It is always necessary, given the strong circumstantial evidence, to
analyze whether this entire scenario did involve a form of “honey-
trap” scenario, given the coincidences between the lady in question’s
seeming intentions, and that of the PSP, who apparently weren’t
entirely accurate in their analysis that Nightingale failed a sobriety
test that, to good defensive deductions, he had in fact passed. Please
keep in mind that Nightingale is an adult male with Asperger’s
Syndrome, which would really exacerbate the emotional distresses he
would experience from the thought of such an onslaught against him,
and by the authorities he was always taught to trust growing up.

2018, Nov | | PSP: Count 2, Wrongful Imprisonment

OO. Fourth CAUSE OF ACTION
COUNT 2, Against PSP
Wrongful Imprisonment
November the 1st, 2018

1. Through solid defensive deduction, Nightingale had seemingly

passed his sobriety test, with the exception of one stand-on-one-foot
test he was NOT properly given the instructions for.
Nightingale repeatedly asked the officers that night to allow him to
perform a breathalyzer test to prove he passed the sobriety test. PSP
refused to allow Nightingale to prove he was not under the influence
with the use of a breathalyzer device, seemingly going so far as to
43
 feign the “accidental” dropping of the device issued to them, the
device thereby breaking into two parts.
It is necessary to mind that the subsequent toxicology report showed
Nightingale’s blood alcohol level at less than half the legal limit.
2. Nightingale was, as such, wrongfully imprisoned.

2018, Nov | | PSP: Count 4, Defamation of Character

PP. Fifth CAUSE OF ACTION
COUNT 3, Against PSP
Obstruction of Justice
November the 1st, 2018

1. On January 19th 2018, PSP pulled Nightingale over, and later

subsequently charged him with DUI.
2. Through solid defensive deduction, Nightingale had seemingly
passed his sobriety test, with the exception of one stand-on-one-foot
test he was NOT properly given the instructions for.
Nightingale repeatedly asked the officers that night to allow him to
perform a breathalyzer test to prove he passed the sobriety test. PSP
refused to allow Nightingale to prove he was not under the influence
with the use of a breathalyzer device, seemingly going so far as to
feign the “accidental” dropping of the device issued to them, the
device thereby breaking into two parts.
3. As such, they withheld information that would have shown that
Nightingale was not intoxicated at that time.
4. As such, they thus Obstructed Justice, by withholding very pertinent
information.

44
2018, Nov | | PSP: Count 4, Defamation of Character
QQ. Sixth CAUSE OF ACTION
COUNT 4, Against PSP
Defamation of Character
November the 1st, 2018

1. On January 19th 2018, PSP pulled Nightingale over, and later

subsequently charged him with DUI.
2. Through solid defensive deduction, Nightingale had seemingly
passed his sobriety test, with the exception of one stand-on-one-foot
test he was NOT properly given the instructions for.
Nightingale repeatedly asked the officers that night to allow him to
perform a breathalyzer test to prove he passed the sobriety test. PSP
refused to allow Nightingale to prove he was not under the influence
with the use of a breathalyzer device, seemingly going so far as to
feign the “accidental” dropping of the device issued to them, the
device thereby breaking into two parts.
3. The description of the charges is very misconstrued and could really
damage a person’s reputation and also ruin their life, just based on
the allegations alone.
4. The above charges against Nightingale are public and can readily
accessed through public docket search web sites for anyone to see,
including the schools that would have looked into Nightingale’s
records when considering him for a position.
5. As a direct and proximate result of these stated acts and omissions,
PSP has defamed Nightingale’s character illegitimately.
6. Nightingale really aspires to become a teacher. This sort of matter
may very well have ruined a good opportunity for him that he was
seeking at the Baldwin School in Pennsylvania at that time. If his
employment opportunity is thus ruined at one school, that in turn can
ruin his chances to get a position at other similar schools.
a. This issue has caused a lot of continuous distress for Nightingale, as
Nightingale really desires to be a teacher, working with preK-12

45
 students at a private school for girls, and has been left considerably
distressed as a result of this.

2018, Nov | | York County Courts: Count 1, Wrongful Imprisonment

RR. Seventh CAUSE FOR ACTION
COUNT 1, Against YORK COUNTY DISTRICT COURTS
WRONGFUL IMPRISONMENT
November the 1st, 2018

1. On May 11th, 2018, YORK COUNTY DISTRICT COURTS issued a Bench

Warrant as Nightingale did not show up for a court hearing he was
NEVER told about.
2. Notwithstanding Nightingale coming forward on his own (and
coincidentally the very day of the court hearing he was never made
aware of) and trying to sort out this matter between the York
Magisterial and District Courts on his own accord, the District Courts
had Nightingale imprisoned, whereby he was held in York County jail
for eight days until his parents could finally get him bail after a very
painstaking effort.
3. YORK COUNTY DISTRICT COURTS, both at the Magisterial and District
levels, were well aware that Nightingale had not been informed that a
hearing had been scheduled for him to appear in.

2018, Nov | | Swatara Police : Count 1, Obstruction of Justice

SS. Eight CAUSE OF ACTION
COUNT 1, Against SWATARA POLICE
OBSTRUCTION OF JUSTICE
November the 1st, 2018

46
 1. On March the 22nd, 2018, SWATARA POLICE pressed against
Nightingale unverified, premature, unexpected, and unjustified
charges of
i. Stalking-Communication or Conduct to Instill Fear/Distress.
ii. Harassment-Otherwise Repeatedly Communicate
2. They withheld information that would have revealed that Nightingale
had good humane intentions for going to look for Kimberly when he
had reason to believe she was in danger.
3. In neither the charges listed nor the Affidavit of Probable Cause, did
SWATARA POLICE so much as alluded to Nightingale having shown
their male officer, on the night of July’s Ides, 2018 at around the
1:30AM EST hours, the evidence that he had received from Ginnie
indicating that Kimberly was in danger.
4. SWATARA POLICE omitted the fact that Nightingale had showed
them proof that he had in fact received messages from Ginnie
indicating that Kimberly was on a hardcore narcotic, saying it was
meth or something just as destructive.
5. That evidence was shown on Nightingales mobile phone, using the
chatting app, Facebook Messenger.
6. The description of the charges is very misconstrued and could really
damage a person’s reputation and also ruin their life, just based on
the allegations alone.
7. The above charges against Nightingale are public and can readily
accessed through public docket search web sites for anyone to see,
including the schools that would have looked into Nightingale’s
records when considering him for a position.

2018, Nov | | PSP: Count 2, Defamation of Character

TT. Ninth CAUSE OF ACTION
COUNT 2, Against SWATARA POLICE
Defamation of Character
November the 1st, 2018

47
1. On March the 22nd, 2018, SWATARA POLICE pressed against
Nightingale unverified, premature, unexpected, and unjustified
charges of
i. Stalking-Communication or Conduct to Instill Fear/Distress.
ii. Harassment-Otherwise Repeatedly Communicate
2. They withheld information that would have revealed that Nightingale
had good humane intentions for going to look for Kimberly when he
had reason to believe she was in danger.
3. In neither the charges listed nor the Affidavit of Probable Cause, did
SWATARA POLICE so much as alluded to Nightingale having shown
their male officer, on the night of July’s Ides, 2018 at around the
1:30AM EST hours, the evidence that he had received from Ginnie
indicating that Kimberly was in danger.
4. SWATARA POLICE omitted the fact that Nightingale had showed
them proof that he had in fact received messages from Ginnie
indicating that Kimberly was on a hardcore narcotic, saying it was
meth or something just as destructive.
5. That evidence was shown on Nightingales mobile phone, using the
chatting app, Facebook Messenger.
6. The description of the charges is very misconstrued and could really
damage a person’s reputation and also ruin their life, just based on
the allegations alone.
7. The above charges against Nightingale are public and can readily
accessed through public docket search web sites for anyone to see,
including the schools that would have looked into Nightingale’s
records when considering him for a position.
8. As a direct and proximate result of these stated acts and omissions,
SWATARA POLICE has defamed Nightingale’s character illegitimately.
9. Nightingale really aspires to become a teacher. This sort of matter
may very well have ruined a good opportunity for him that he was
seeking at the Baldwin School in Pennsylvania at that time. If his
employment opportunity is thus ruined at one school, that in turn can
ruin his chances to get a position at other similar schools.

48
 10. This issue has caused a lot of continuous distress for Nightingale, as
Nightingale really desires to be a teacher, working with preK-12
students at a private school for girls, and has been left considerably
distressed as a result of this.

Plaintiff’s Petition for Judgement Against Defendants

UU. Plaintiff WHEREFORE, Plaintiff respectfully petitions for a judgment against
Defendants for:
1. Against defendant FBI for monetary amount of:
i. For damages due to Gross Negligence and Fraud:
1. For protracted Emotional Distresses from what Nightingale has been
enduring at least 13 years,
$12,000,000.00USD (Twelve Million Dollars).
2. For other damages including Nightingale’s life having been seemingly
now ruined,
$17,000,000.00USD (Seventeen Million Dollars).
2. Against defendant PSP for the monetary amount of:
i. For damages due to Conspiracy and that against a disabled
adult
i. For protracted Emotional Distresses from what
Nightingale has been enduring since that night.
$7,200,000USD (Seven Million, Two-Hundred Thousand
Dollars)
ii. For damages due to Defamation of Character:
i. For protracted Emotional Distresses from what
Nightingale has been enduring as a result of his career
dreams seemingly having now been ruined.
$2,500,000USD (Two Million, Five-Hundred Thousand
Dollars).
iii. For damages due to Wrongful Imprisonment:

49
 For protracted Emotional Distresses from what
Nightingale has been enduring as a result of being
wrongfully imprisoned.
$3,120,000USD (Three Million, One-Hundred
Twenty Thousand Dollars).
iv. For damages due to possibly having ruined Nightingales
prospective teaching career:
For protracted Emotional Distresses from what
Nightingale has been enduring as a result of the
line of work he dearly wants to work for possibly
now being ruined.
$9,340,000USD (Nine Million, Three-Hundred
Forty-Thousand Dollars).
3. Against defendant SWATARA POLICE for the monetary amount of:
i. For damages due to Obstruction of Justice
i. For protracted Emotional Distresses from what
Nightingale has been enduring since the unverified
charges were filed in 2018.
$2,500,000USD (Two Million, Five-Hundred Thousand
Dollars)
ii. For damages due to Defamation of Character:
i. For protracted Emotional Distresses from what
Nightingale has been enduring as a result of his career
dreams seemingly having now been ruined.
$2,000,000USD (Two Million Dollars).
4. Against defendant YORK COUNTY DISTRICT COURTS for the
monetary amount of:
i. For damages due to Wrongful Imprisonment:
i. For protracted Emotional Distresses from what
Nightingale has been enduring since he was wrongfully
imprisoned in June of 2018
$3,120,000USD (Two Million Dollars)
ii. For damages due to Defamation of Character:

50
 For protracted Emotional Distresses from what
Nightingale has been enduring as a result of his career
dreams seemingly having now been ruined.
$3,000,000USD (Three Million Dollars)
VV. Injunctive and equitable relief as the Court deems appropriate including:
1. Having the FBI take measures to ensure the safety of should
Nightingale, Kimberly, Ginnie, and other relevant parties in this
matter.
2. Require the FBI to take measures to prevent violations of
Nightingale’s rights hereafter, as well as that of other relevant parties.
3. Having the FBI ensure that Nightingale has every legal advantage he
should have in the current charges filed against him by Dauphin and
York counties of Pennsylvania, which would include making sure he is
not wrongly imprisoned or imprisoned as a means of retaliation/
threat/ intimidation by either of those counties (or anybody, for that
matter).
4. Take measures to ensure the safety of Kimberly, Audrianna, Nicole,
Angelique, and other girls that were or are still working at Savannah’s.
In particular, to ensure that they do not feel a sense of intimidation
during the course of this proceeding, nor thereafter.
Furthermore, to ensure that the personal, professional, and other
aspects of Kimberly’s and the other girls’ lives are not adversely
affected by this matter, not now, not hereafter,
i. And, if such effects have already taken place these last five years
(at the time of this complaint), that they need be remedied for
them.
i. As such, a monetary judgement for other relevant parties
in this matter, including the girls at Savannah’s that were
victimized by all this, may also be appropriate.
ii. Whereby, if the alleged sexual-assaults against Kimberly,
Angelique, Nicole, Audrianna, or any of Nightingale’s
acquaintances are proven to be true, that then a
judgment of $120,000USD (One-Hundred Twenty-

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 Thousand Dollars) be awarded to each girl in whose case
it was shown to be true.
1. Additionally, in the cases where the allegations are
proved to be true, an additional $30,000USD
(Thirty-Thousand Dollars) to be awarded for each
child the victim may have at the time of this
Complaint.
5. Nightingale also requests that the girl in question whom resembled
Kimberly at Fat Daddy’s club in early March, 2018 perhaps also be
looked into to ensure her well-being, as she had a most terrified look
on her face that night.
A bouncer at Fat Daddy’s by the name of Patrick O’Mara (last name
may not be spelled correctly) might have also seen the terrified girl in
question that night, as well.
6. Nightingale also requests that the girls mentioned above be treated
with some clemency for anything anyone may want to hold against
them. Kimberly and Nightingale, in particular, have had a lot of
horrible things come against them in the course of knowing each
other that has made life difficult for them. It only makes sense to treat
these girls as victims in the much bigger picture.
7. As the sense of violation by government entities, the private business
sector, and possibly plagiarists could very well re-emerge sometime
after this case, the FBI take strict measure to make sure no one is by
any means trying to benefit from Nightingale in those types of
regards.
8. Take measures to ensure that the sort of illegitimate affairs that might
have affected Nightingale’s probability of getting a job at a school are
straightened out;
i. and that, furthermore, those affairs not have any degree of
lasting effect on the overall stability of the schools themselves,
as they were also subjected to such an illegitimate affair, along
with Nightingale.
WW. Compensatory damages to be paid by all Defendants, according to proof at trial;
XX. Punitive damages as the court deems appropriate;

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 YY. Costs and attorneys’ fees of this lawsuit;
ZZ. Any other relief as the court deems appropriate.

Dated: November the 3rd, 2018, Party Nightingale

Kamran Edward Estelle Esiriluxe Elronde Nightingale, nee Kamran Owzar

Plaintiff and Pro se, Co-Counsellor for Party Nightingale.

Counsellor(s) for Plaintiff Nightingale

Experienced, Bar-Certified Attorney(s) as counsellors are intended, only have yet to be chosen, until then Nightingale is Pro Se.

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