Saturday, December 3, 2011

Zeng Xiamin Filed Lawsuit against Yu Zhengsheng and the CCP security agents in USA

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff Pro Se:
Xiamin Zeng    
--------------
Flushing, NY
 
-Against-                      

Defendant No. 1
Zhengsheng Yu
200 Renmin Avenue
Shanghai, China
Post Code 200003
Tel: 01186-21-2311-1111

Defendant No. 2 
Jianzhong Jin
111 South Bole Road
Jiading District
Shanghai, China
Post Code 201800
Tel: 01186-21-6998-9888 
  
Defendant No. 3
Yifeng Fu 
555 West Jinshajiang Road
Shanghai, China
Post Code 201803
Tel: 01186-21- 6911-8800

Defendant No. 4 
Yiming Yao
3035 Caoan Highway
Shanghai, China
Post Code 201812
Tel: 01186-21-3955-6141
Cell: 01186-135-0160-0775
  
Defendant No. 5
Jiwei Sun

111 South Bole Road
Jiading District 
Shanghai, China
Post Code 201800
Tel: 01186-21-6998-9500
Defendant No. 6
Jianfeng Guo
555 West Jinshajiang Road
Shanghai, China 
Post Code 201803
Tel: 01186-21-6911-2669
Cell: 01186-136-0160-6347 
     
Defendant No. 7 
Guoqiang Li 
555 West Jinshajiang Road
Shanghai, China
Post Code 201803
Tel: 01186-21-     6911-2662
Cell: 01186-135-0169-7095

Defendant No. 8
Weirong Shen         

3035 Caoan Highway
Shanghai, China 
Post Code 201812
Tel: 01186-21-     5913-6452
Cell: 01186-136-5184-1245 

Defendant No. 9 
Yuhua Tang 

308 East 38th Street, Apt. 7E
New York, NY 10016-9821                                     
                                         
Defendant No. 10                     
Yan Zhao                                 

xxx Street
Flushing, NY 11355                         
Cell: xxx-xxx-6988                        

_______________________________________________________________________
Complaint

Plaintiff Xiamin Zeng, pro se, alleges upon personal knowledge and belief as to her own circumstances, and upon information and belief as to all other matters, that substantial evidential support exists or will exist after a reasonable opportunity for further investigation and discovery as a result of trial proceedings, in support of the following:

The Parties:

Plaintiff Xiamin Zeng is the resident of the State of New York. Her current residential address is xxxxxxxx, Flushing, NY 11354. Plaintiff Xiamin Zeng owns a house of 7000 square feet and a land of 3 acres in Shanghai of the People’s Republic of China (hereinafter “PRC”). The Plaintiff’s house and the land were robbed and demolished by some of the defendants and/or their subsidiaries illegally.
                                       
Defendant Zhengsheng Yu is the head of the Chinese Communist Party (hereinafter “CCP”) in Shanghai.
Defendant Jianzhong Jin is the head of the CCP in Jiading District of Shanghai.
Defendant Yifeng Fu is the head of the CCP in Jiangqiao town of Shanghai.
Defendant Yiming Yao is the head of the CCP in Xinghuo village of Shanghai.
Defendant Jiwei Sun is the member of CCP reporting to defendant Jianzhong Jin. .  
Defendant Jianfeng Guo is the member of CCP reporting to defendant Yifeng Fu.
Defendant Guoqiang Li is the member of CCP reporting to defendant Yifeng Fu.
Defendant Weirong Sun is the member of CCP reporting to defendant Yiming Yao.
Defendant Yuhua Tang is the bureau chief for the UN headquarters of the Wenhui Daily, which is a news paper owned by the CCP of Shanghai, and thus Yuhua Tang reports to Defendant Zhengsheng Yu. Yuhua Tang is well known to be the chief of the Chinese security agency in the United States.
Defendant Yan Zhao, a former Chinese police officer, and now lives in New York..

The first 8 defendants listed in this complaint, including Zhengsheng Yu, Jianzhong Jian, Yifeng Fu, Yiming Yao, Jiwei Sun, Jianfeng Guo, Guoqiang Li, Weirong Sun (Hereinafter “8-Shanghai-Defendants”), are all residents in Shanghai of China, and are all key members of the CCP. These 8-Shanghai-Defendants had organized gang groups to rob private lands and residential houses for their own interests. The plaintiff’s house and lands were robbed by the gang groups led by the 8-Shanghai-Defendants. The plaintiff and her family members were also tortured, detained, deprived of freedom illegally by the 8-Shanghai-Defendants, and/or their agents, servants, subsidiaries. See attached files in A1.

Defendant Yuhua Tang and Defendant Yan Zhao are residents in the State of New York and have worked together to threaten and harass the Plaintiff, in order to silence the Plaintiff to petition/protest against the CCP in the United States. See attached files in A8.

Defendant Yan Zhao also committed sexual harassment and slander against the Plaintiff. See attached files in A9.

JURISDICTION AND VENUE
The substantive matter involves civil rights violations and several other federal question issues. Therefore, jurisdiction by this Honorable Court is found pursuant to 28 USC 1331, Federal Question Jurisdiction.  Plaintiff is a resident of the State of New York while all defendants are residents of either New York or the PRC, while the claimed damages are well exceeding the value of $75,000. Therefore, jurisdiction is found in the theory of Diversity of Citizenship Jurisdiction under 28 USC 1332.
This Court also has supplemental and personal jurisdiction over the defendants under subsections related clauses of New York civil procedures CPLR because upon information and belief, defendants, and/or their agents, servants, subsidiaries either transacted business in this State and within this District.
This Court also has supplemental jurisdiction over claims arising from violations of state law because, pursuant to 28 U.S.C. § 1367, the facts in the claims arising from state law are so related to the Plaintiffs’ claims under federal laws that they form part of the same case or controversy under Article III of the United States Constitution.
Venue is proper in this judicial district pursuant to 28 USC 1391(d), in connection to 28 U.S.C. § 1331 and 1332 and Federal Civil Rights Act, due to the Diversity of Citizenship and the amount of damages.
Cause of Actions
All Civil Rights violations pursuant to 42 USC 1983, 42 USC 1985 (2) and (3), 42 USC 1986 * in connection to all civil offenses and tortuous wrongs targeting Plaintiff under, or implicated by, 18 USC 241 (conspiracy against Rights), 242, 245, 3631, and 14141, et seq.

________________________________________________________      
*Title 42 U.S.C. § 1983. Every person who, under color or any statute, ordinance, regulation, custom or usage, of any State of Territory, subjects ... any citizen of the United States ... to the deprivation of any rights, privileges or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress. (emphasis added)
Title 42 U.S.C. § 1985 pertains to a conspiracy to interfere with civil rights, (1) to prevent an officer from performing a duty; (2) obstructing justice; intimidating party, witness, or juror; (3) or depriving persons of rights or privileges.
Title 42 U.S.C. § 1986. Action for neglect to prevent conspiracy
Every person who, having knowledge that any of the wrongs conspired to be done, and mentioned in the preceding section [42 USCS § 1985], are about to be committed, and having power to prevent or aid in preventing the commission of the same, neglects or refuses to do so, if such wrongful act be committed, shall be liable to the party injured, or his legal representatives, for all damages caused by such wrongful act, which such person by reasonable diligence could have prevented;
And such damages may be recovered in an action on the case; and any number of persons guilty of such wrongful neglect or refusal may be joined as defendants in the action, and if the death of any party be caused by any such wrongful act and neglect, the legal representatives of the deceased shall have such action therefore, and may recover not exceeding five thousand dollars damages therein, for the benefit of the widow of the deceased, if there be one, and if there be no widow, then for the benefit of the next of kin of the deceased. But no action under the provisions of this section shall be sustained which is not commenced within one year after the cause of action has accrued.  


Distortion
Defendant Zhengsheng Yu, being aided and abetted with the co-defendants, committed corruptive distortion against the Plaintiff by repeatedly torturing, illegal detention the Plaintiff in order to silence the Plaintiff from disclosing explosive scandalous and criminal activities committed by the defendants, for the purpose of obstructing justice.
Claims and Statement of Facts:
1.      The defendant, Zhengsheng Yu, the head of the CCP in Shanghai, created gang groups and illegal armed forces in Shanghai to do illegal businesses, including but not limited to robbing private lands, demolishing residential homes. The defendant Zhengsheng Yu created the projects Shanghai-Beijing High Speed Railway and the Shanghai Expo 2010.  To implement these two and some other similar projects, the Defendant Zhengshang Yu sent his gang members, agents subsidiaries, to rob private lands and to destroy residential houses, without legal documents or court orders. Many victims were seriously beaten or injured by the demolishers sent by the Defendant Zhengsheng Yu during the forced demolish. Most of the victims haven’t got fair compensation.
2.      The Plaintiff Xiamin Zeng and her family own a house of 7000 square feet and 3 acres of land located at 115 Xinghuo Cun, Jiangqiao Town, Jiading District, Shanghai, China. The land was robbed and the house was demolished by a group of gangs with 300 gang members sent by the Defendant Zhengsheng Yu and led by the other 8-Shanghai-defendants on November 17, 2009 and February 25, 2010. See attached files in A2.
3.      The Plaintiff’s 3 Acres of land had a market value around 1.5 Billion RMB (about 0.25 Billion USD) and the demolished house had a market value around 2 million USD. The 8-Shanghai-Defendants and/or their subsidiaries have never provided any compensation to the Plaintiff for the demolished houses and robbed lands. See attached files in A13 and A14.
4.      The Plaintiff and her family have exhausted most of the appeal and/or petition procedures to search for damage compensation. In order to silence and to retaliate the Plaintiff, to stop the Plaintiff from appeal or petition, the 8-Shanghai-Defendants and/or their subsidiaries had persecuted the Plaintiff repeatedly, through torture, harassment, illegal imprisonment, and house arrest. See attached files in A10, A11, and A12.
5.      Plaintiff Xiamin Zeng had been harassed, tortured, assaulted by the 8-Shanghai-Defendants, and/or their agents, subsidiaries. The Plaintiff’s nose was broken and 3 teeth were knocked out by the Gang members led by the Defendant Yiming Yao and Weirong Shen right in the office of Defendant Yiming Yao’s. See attached files in A3.
6.      The Plaintiff’s grand mother, Xiaomei Yan, had been harassed, tortured, assaulted by the 8-Shanghai-Defendants or their subsidiaries, See attached files in A4.
7.      The Plaintiff’s mother, Guojuan Zeng, had been harassed, tortured, assaulted by the 8-Shanghai-Defendants or their subsidiaries, See attached files in A5.
8.      The Plaintiff’s two dogs and one cat were buried to death by the demolishers sent/led by the 8-Shanghai-Defendants. See attached files in A6.
9.      As a retaliation and threatening to the Plaintiff, the 8-Shanghai-Defendents sent their gang members, and/or agents, to beat Mr. Hongqi Hang, the Plaintiff’s neighbor and friend, to death on October 12, 2011. After the death of Mr. Hongqi Hang, the 8-Shanghai-Defendants threatened the Plaintiff, her family members, and her friends, that the death of Mr. Hongqi Hang would be an example for the Plaintiff, if she wouldn’t stop protesting the CCP in the United States. See attached files in A7.
10.  Plaintiff Xiamin Zeng, had been falsely accused and arrested over 20 times by the 8-Shanghai-Defendants and/or their subsidiaries, See attached files in A11.
11.  Plaintiff Xiamin Zeng, had been illegally put under house arrest over 200 days by the 8-Shanghai-Defendants and/or their subsidiaries, having deeply traumatized her physically and mentally, and having caused the Plaintiff substantial property and money damages. See attached files in A12.
12.  Plaintiff Xiamin Zeng arrived in the United States on June 29th, 2011. Since then, Plaintiff Xiamin Zeng has joined the protests against the CCP at various locations in the United States, to appeal for fair compensation for her demolished house and robbed land. See attached files in A15.
13.  Plaintiff Xiamin Zeng’s appeal/petition activities in the United States have made the 8-Shanghai-Defendants very anxious and angry. The Plaintiff believes that the 8-Shanghai-Defendents have applied their resources/subsidiaries/agents in the United States to harass Plaintiff Xiamin Zeng to silence the Plaintiff or to stop the Plaintiff’s protests.
14. On August 3rd, 2011, Defendant Yan Zhao introduced Defendant Yuhua Tang to meet Plaintiff Xiamin Zeng at Mulan Restaurant, a Chinese restaurant in Flushing. Defendant Yan Zhao clearly told Plaintiff Xiamin Zeng that the actual identity of Yuhua Tang was the chief of the Chinese Security agency in North America, although his title is the Chief of the Wenhui Daily in UN branch. During the meeting, both Defendants inspired Plaintiff Xiamin Zeng to assault Ban Ki-moon, the Secretary General of the UN. Defendant Yuhua Tang repeatedly told Plaintiff Xiamin Zeng that it would be very helpful to have the Chinese government pay attention to her and to have her petitions resolved quickly, if she could create big news by assaulting Ban Ki-moon or Hu Jintao. Defendant Yuhua Tang’s office is located in the UN building. Defendant Yuhua Tang even drew a detailed map to show the offices and conference rooms that Ban Ki-moon frequently showed up. Defendant Yuhua Tang told Plaintiff Xiamin Zeng that it would be very easy to meet and assault Ban Ki-moon in the UN building. Defendant Yan Zhao and Defendant Yuhua Tang even provided detailed plans for the Plaintiff to assault Ban Ki-moon in the UN building. Plaintiff Xiamin Zeng refused to follow the Defendant’s advice/plan, and clearly told them that she would not be part of any terrorism attacks against Ban Ki-moon or any other leaders.
15.  Defendant Yuhua Tang works for the Wenhui Daily, which is a subsidiary of the CCP in Shanghai, and thus reports to Defendant Zhengsheng Yu. Defendant Yan Zhao used to be Chinese police officer. Both Yuhua Tang and Yan Zhao have harassed Plaintiff Xiamin Zeng to silence Xiamin Zeng’s protests, and thus to protect the 8-Shanghai-Defendants.
16.  Defendant Yuhua Tang has frequently sent Chinese security Agents to harass the Plaintiff while the Plaintiff exercised her civil right to protest against the CCP and asking for fair compensation for her demolished houses and robbed lands. See attached files in A8.
17.  Defendant Yuhua Tang called the Plaintiff several times to threaten the plaintiff, usually at about 2AM in the early morning while the plaintiff was in deep sleeping, to make the Plaintiff very nervous and insomnia.
18.  Defendant Yan Zhao frequently asked Plaintiff Xiamin Zeng to enter the UN building to do the so called “Action Arts Exhibition”. Whenever they went into the UN building together, Defendant Yan Zhao always asked/inspired the Plaintiff to assault UN officers to draw attention and/or to create big news. The Plaintiff refused to do any such kind terrorism attacks.
19.  Defendant Yan Zhao asked Ms. Yan Hu, another Chinese petitioner protesting against the CCP at the UN building, to clime on the top 40th floor of the UN building to commit/threaten suicides. Ms. Yan Hu refused to follow Defendant Yan Zhao’s advice. It is clearly another trap designed by Defendant Yan Zhao to put Chinese dissidents/petitioners into trouble situation.
20.  As the Plaintiff refused to follow the “advices” given by the defendants, Defendant Yan Zhao has started to harass the Plaintiff by posting slander/threatening postings against the Plaintiff on public websites or discussion groups, spread rumors about the Plaintiff, and sexual harassment against the Plaintiff. Defendant Yan Zhao also intimated his former Chinese Police colleagues to assault and sexual harass the Plaintiff. See attached files in A9.
21.  In July 2011, Defendant Yan Zhao continuously asked the Plaintiff to live in his house with him and to be his “Female Secretary” (Xiao Mi), which means a lover in Chinese. The Plaintiff immediately warned Defendant Yan Zhao to stop such kind sexual harassment.
22.   At the end of July, 1011, Defendant Yan Zhao invited the Plaintiff to visit his home. Defendant Yan Zhao intentinally torn off his pants at the crotch, the light grey color pants he was wearing in the picture in A9.1, then asked the Plaintiff to sew the pants for him. The Plaintiff immediately warned Defendant Yan Zhao to stop such kind sexual harassment.
23.  Defendant Yan Zhao repeatedly cheated/promised the plaintiff that he could help the plaintiff to be reported by the New York Times, as he himself was a reporter of the New York Times. In the picture in A9.1, Defendant Yan Zhao showed a banner which claimed he was a reporter of the New York Times. Actually, Yan Zhao has never been a reporter of the New York Times, instead, he used to be a Chinese Police officer.
24.  In July 2011, Defendant Yan Zhao frequently asked the Plaintiff to wash his dirty shirts. The plaintiff believed it was a kind of sexual harassment against the Plaintiff and refused to wash the shirts for Defendant Yan Zhao. See attached files in A9.2.
25.  In early August, 2011, Defendant Yan Zhao summoned some of his Chinese Police colleagues to meet and harass the Plaintiff. Yan Zhao told the Plaintiff that it would be better to date with his men, because his men were Chinese police officers, and were powerful and handsome. The plaintiff immediately told Yan Zhao that she already had her own boy friend and wouldn’t date with any Chinese police officers.
26.  Around August 3rd, 2011, Yan Zhao summoned one of his Chinese Police colleagues from Michigan,  the man wearing glasses (hereinafter “the glass-policeman”) and standing at the right in the attached file A9.3, to come to New York and meet the Plaintiff, while the Plaintiff did her daily protest at the UN building. The glass-policeman immediately harassed the Plaintiff once he arrived at the UN building. The glass-policeman grabbed the Plaintiff’s hands and requested the Plaintiff to go with him to a quite place to talk about sexual relationship. The glass-policeman also asked the Plaintiff to give him phone numbers. The Plaintiff refused the glass-policeman’s requests. The glass-policeman immediately threatened the Plaintiff by telling the Plaintiff that he was a Chinese Police officer and no one can reject him.
27.  Defendant Yan Zhao frequently contacted with high rank CCP officials, including the secretary/assistant of President Hu Jintao, and “Lao Qi”, who was claimed as an active general in the People’s Liberation Army and the head of body guards of Hu Jintao. Defendant Yan Zhao frequently reported to Hu Jintao and his assistants about the Plaintiff's articles and protesting activities. “Lao Qi” is the head of the Chinese military security agency, while Defendant reports to “Lao Qi”. Several other people, including Ms. Xin Zhao (Yan Zhao’s cousin), Mr. Likun Zhang (Yan Zhao’s friend and a retired Chinese military officer), etc., are all working for “Lao Qi” and are witnesses to prove that Defendant Yan Zhao also works for “Lao Qi” as a Chinese secret security agent. Defendant Yan Zhao has invited some Chinese police officers and military officers, including Likun Zhang and the glass-policeman shown in the attached picture in A9.3, into the United States. Defendant Yan Zhao has also shown a photo that shows himself to meet with Wang Qishan, the Chinese Vice Premier and the Standing Committee Member of the CCP. All these are strong evidences to indicated that Defendant Yan Zhao works for the Chinese security agency as a secret security agent reporting to “Lao Qi”.
28.  Defendant Yan Zhao and Defendant Yuhua Tang have worked together to lure Chinese dissidents into their well designed traps: the defendants Yan Zhao and Yuhua Tang first inspired the Plaintiff and other Chinese dissidents to assault the Chinese leaders by throwing eggs/tomatoes on their faces, and then let the the Chinese security agents report to FBI to false acuse the plaintiff was a terrorism suspect. See attached files in A16.1.  
29.  Defendant Yan Zhao and Defendant Yuhua Tang tried their best to convince the Plaintiff and other Chinese dissidents that the best strategy to have their petition requests resolved was, to assault/attack Hu Jintao, the President of China, or Ban Ki-moon, the Secretary General of UN, by throwing eggs/tomatoes/shoes on their faces, and to have them lose face.
30.  The Plaintiff was strictly restricted to enter the UN building since September, 2011. Several UN security agents explained to the Plaintiff that some Chinese security agents already reported to the UN that the Plaintiff was terrorism suspects and planned to attack Ban Ki-moon. The Plaintiff believed that Defendant Yan Zhao and Defendant Yuhua Tang, and/or their Chinese security agents, intentionally reported to UN security agents to make the false acusation, because only these two Defendants knew that kind assaulting plans.
31.  Since August, 2011, Defendant Yan Zhao has continuously posted many articles using different author names to describe/disclose the terrorism plans and participants who would execute such terrorism groups. All of those articles are talking about who/how to assault Hu Jintao at the APEC conference held in Hawaii around November 12, 2011. All articles were written and posted by Defendant Yan Zhao, although he used different author names. All the author names highlighted in circle are Yan Zhao’s. To avoid the conspiracy traps being exposed, all the articles with the Defendant Yan Zhao’s true name have been removed from the web after the APEC conference. See attached file in A16.2.
32.  Defendant Yan Zhao also asked some of the Chinese petitioners/dissidents to post similar articles to describe/disclose their assaulting/terrorism plans. Some Chinese petitioners/dissidents, including Furong Ai, Lifang Ge, Dongyan Wang, Yongli Wang were convinced by Defendant Yan Zhao and were anxious to participant in such assaulting plans. The attached file in A16.3 lists some articles posted and authored by the above mentioned Chinese petitioners/dissidents.
33.  Using the articles written/posted by Defendant Yan Zhao as shown in A16.2, Chinese security agents reported to FBI that there were terrorism assaulting plans/conspiracies against the Chinese President Hu Jintao, and asked the FBI to investigate the terrorism suspects, including the Plaintiff Xiamin Zeng, Furong Ai, Lifang Ge, Dongyan Wang, Yongli Wang, and other Chinese petitioners/dissidents. This resulted that the Plaintiff along with some Chinese petitioners/dissidents were listed as terrorism suspects, Mr. Furong Ai was even interrogated by FBI while Furong Ai was protesting against Hu Jintao at the APEC meeting on November 12th, 2011. This proves that Defendant Yan Zhao and Defendant Yuhua Tang had trapped the Plaintiff and other Chinese dissidents/petitioners into trouble situation. See attached files in A16.1.
34.  On November 12, 2011, Defendant Yan Zhao shot a video and posted it on the web. The video shows that Defendant Yan Zhao encountered Ms. Liu Yongqing, the First Lady of China, in the Sheraton Hotel in Hawaii. By posting this video, Defendant Yan Zhao convinced FBI and the Chinese dissidents that the terrorism attacks/plans against Hu Jintao were really a mission possible. Therefore, the Chinese security agents pushed the FBI to investigate the terrorism attacks. At the same time, Defendant Yan Zhao inspired the Chinese dissidents/petitioners to execute the assaulting plans. The video was shot within a distance of 3 meters, and have 70 seconds. But it only shows the back of Ms. Liu Yongqing and never shows her face. See attached files in A16.4.
It is unbelievable that the First Lady of China went out the Hotel for a few minutes and happened encountered and shot by Defendant Yan Zhao, who had openly declared to assault Hu Jintao and any of his accompanies.
It is possibly that the lady in the video is NOT the true First Lady of China! It could be a Chinese security agent acting as the First Lady of China!
It is obvious that Defendant Yan Zhao and the Chinese Security agents worked together to create this video!
Posting this video on the web is just another conspiracy to trap the FBI to fight against the Chinese dissidents/petitioners!

Assault and false imprisonment
Defendants jointly or severally caused Plaintiff to be harassed, intimidated, assaulted and illegal imprisoned in color of law enforcement, through means intentional conspiracy. See attached files in A10, A11, and A12.
Unjust Enrichment
The 8-Shanghai-Defendants listed in this complaint have apparently obtained improper benefits and get unjustly enriched by robbing Plaintiff’s private lands and houses, and selling the lands to the third party - the Beijing-Shanghai High Speed Railway Inc.
Civil Conspiracy:
In implementing all these jointly or severally committed serious wrongs, all Defendants have been allegedly conspiring together to persecute and harass the Plaintiff.
Injuries:
Due to Defendants offenses, tortures, and frequent harassments, the Plaintiff has suffered great and immeasurable and crippling losses and damages, including:
1.      Plaintiff Xiamin Zeng had been harassed, tortured, assaulted by the 8-Shanghai-Defendants or their subsidiaries, the Plaintiff’s nose was broken and 3 teeth were knocked out. See attached files in A3.
2.      The Plaintiff’s grand mother, Xiaomei Yan, had been harassed, tortured, assaulted by the 8-Shanghai-Defendants or their subsidiaries, See attached files in A4.
3.      The Plaintiff’s mother, Guojuan Zeng, had been harassed, tortured, assaulted by the 8-Shanghai-Defendants or their subsidiaries, See attached files in A5.
4.      Two dogs and one cat of the Plaintiff’s were buried to death by the demolishers sent by the 8-Shanghai-Defendants. See attached files in A6.
5.      Plaintiff Xiamin Zeng, had been falsely accused and arrested over 20 times by the 8-Shanghai-Defendants and/or their subsidiaries, See attached files in A8.
6.      The Plaintiff Xiamin Zeng, had been illegally put under house arrested over 200 days by the 8-Shanghai-Defendants and/or their subsidiaries, having deeply traumatized her physically and mentally, and having caused the Plaintiff also substantial money damages. See attached files in A10.
7.      The Plaintiff’s 3 Acres of land had a market value around 1.5 Billion RMB (about 0.25 Billion USD) and the demolished house had a market value around 2 million USD. The land was robbed and the house was demolished by the 8-Shanghai-Defendants and/or their subsidiaries. See attached files in A2, A13, and A14.
8.      Plaintiff Xiamin Zheng has been frequently harassed, slandered, and false accused by Defendant Yan Zhao, Defendant Yuhua Tang, and/or their agents, subsidiaries.
Relief Sought:
Plaintiff seeks for injunctive relief in a restraining order that strictly restrain Defendant Yan Zhao and Defendant Yuahua Tang, and any of their Chinese police officers, agents, subsidiaries, from any harassment against the Plaintiff and the Plaintiff’s family members. The order may further restrain Defendant Yan Zhao and Defendant Yuhua Tang, and any of their Chinese police officers, agents, subsidiaries from posting any slander articles against the Plaintiff and the Plaintiff’s family members.
Plaintiff also seeks compensation/relief for damages brought by the defendants as following:
Damages against defendant Zhengsheng Yu for the amount of $10,000,000.00.
Damages against defendant Jianzhong Jin for the amount of $10,000,000.00.
Damages against defendant Yifeng Fu for the amount of $10,000,000.00.
Damages against defendant Yiming Yao for the amount of $10,000,000.00.
Damages against defendant Jiwei Sun for the amount of $2,000,000.00.
Damages against defendant Jianfeng Guo for the amount of $2,000,000.00.
Damages against defendant Guoqiang Li for the amount of $2,000,000.00.
Damages against defendant Weirong Shen for the amount of $2,000,000.00.
Damages against defendant Yuhua Tang for the amount of $200,000.00.
Damages against defendant Yan Zhao for the amount of $200,000.00.
Plaintiff also seeks for such incidental damages, and such other relief that the Jury and the Court finds it appropriate.

Trial by Jury is Prayed
Trial of this case for its factual merits by Jury is respectfully prayed.
Respectfully submitted by,


Xiamin Zeng
The Plaintiff, pro se            
------------------------------------------------------
Attachements:
A1. The Defendants
A1.1 The Defendant Zhengsheng Yu, the third from the right in the picture, led a group of gangs to rob private lands and residential houses in Shanghai.
A1.2. The Defendants Jianzhong Jin, Jiwei Sun, Yifeng Fu were on site to direct the forced demolish.

A1.3. The Defendants Yiming Yao (on the right) and Weirong Shen (on the left) beat the Plaintiff Zeng in this room, to have Zeng’s nose broken and 3 teeth knocked out.

A2. The Plaintiff’s house was demolished and 3 acre land was robbed.
A2.1. The Plaintiff’s house before demolish.


A2.2. The Plaintiff’s house was being demolished by a group of gangs with 300 people sent by the Defendant Zhengsheng Yu and led by some of the 8-Shanghai-Defendants on Feb. 25th, 2010.

A2.3. The ruins of the Plaintiff’s house after demolish.


A2.4. The Beijing-Shanghai High Speed Railway has been built and run through the Plaintiff’s robbed land and demolished house.
A3. The Plaintiff Xiamin Zeng had been beaten by the 8-Shanghai-Defendants or their subsidiaries several times and made the Plaintiff’s nose broken and teeth knocked out.


A4. The Plaintiff’s grand mother was beaten to heart broken.
A4.1. The Plaintiff’s grand mother was beaten and pushed down on the ground during the demolish,

A4.2. The Plaintiff’s grand mother was sent to hospital due to heart broken.

A4.3. The hospital that the plaintiff and her family members were sent after they were tortured by the defendants or their subsidiaries.
A4.4. The emergency room that the grand mother was sent during the demolish process.

On Nov. 17th, 2009 and at the early morning 2AM, the 8-Shanghai-Defendants sent demolishers to demolish the plaintiff’s house. The Plaintiff’s mother was almost buried in the ruins of the house and was seriously injured.

A5. The Plaintiff’s mother was beaten and was seriously injured.
A.5.1.
A5.2. The Plaintiff/s mother was beaten by the demolishers during the 2nd demolish on Feb. 25th, 2010.

A5.3. On November 1st, 2010, the Defendant Yiming Yao, Yifeng Fu, and Weirong Shen led a group of gangs to beat the Plaintiff and her mother. The following pictures showed several injuries of the plaintiff’s mother.


A5.4. The following medical records showed that the Plaintiff’s mother was injured, including all the injuries showed in the pictures in A5.3.
A5.5. The following police report given by Shanghai Police Bureau also showed that the Plaintiff’s mother was injured, including all the injuries showed in the pictures in A5.3.

A6. The following lovely dogs and cat of the Plaintiff’s were buried to death under the ruins of demolished house by the demolishers on Nov. 17th, 2009.
A7. As a retaliation and threatening to the Plaintiff, the 8-Shanghai-Defendents sent their gang members to beat Mr. Hongqi Hang, my neighbor and friend, to death on October 12, 2011.


 
A8. The Defendant Yuhua Tang harassed and threaten the Plaintiff
A8.1. While the Plaintiff was protesting against the CCP at the UN building, the Defendant Yuhua Tang send his security agents to follow/harass/threaten the Plaintiff.
A8.2. This Chinese camera-man approached and harassed the plaintiff frequently.

A8.3. While taking pictures at the Plaintiff and her banners, this camera-man told the plaintiff that his pictures would be used by the CCP to sue the Plaintiff. It made the Plaintiff very nervous.


A9. Defendant Yan Zhao and his Chinese Police colleagues committed sexual harassment to the Plaintiff.
A9.1. Defendant Yan Zhao torn off his pants, the pants he was wearing in the picture, then asked the Plaintiff to sew the pants for him.
A9.2. Defendant Yan Zhao frequently asked the Plaintiff to wear/wash his dirty shirts.. Here are some of the dirty shits Yan Zhao brought to the plaintiff to wash.
A9.3. Defendant Yan Zhao summoned one of his Chinese Police colleagues, the man standing on the right, to commit sexual harassment to the Plaintiff.
A9.4. To avoid further sexual harassment from the Chinese Police officer who was summoned by Defendant Yan Zhao, the Plaintiff had to come to the UN Security Agents for helps.


A9.5. The Defendant continuously harassed the Plaintiff by posting slander messages on public website or chatting room.
A9.6. The English translation of the postings in A9.5.
Yan Zhao posted at 11:13AM:
I have never talked to you. It was Mr. Liu who asked me to forgive you. Considering you are a little baby, you know nothing. I show you my face, but you don’t want to take my face.
amy (The Plaintiff’s nickname) responded at 2:08PM:
Yan Zhao, Please stop threatening to meWhy did you say I don’t want to take your face? What else part you want to show to me? I tried my best to protect your face, but you forced me to disclose all the facts about how you harassed me. You have been angry at me just because I refused to sew your pants, isn’t it? I have tried not to mention all such harassments you have done to me. Please don’t push me! You have threatened to sue me. I will wait to meet you at the court!
A9.7. Defendant Yan Zhao frequently spread rumors and slander on the Plaintiff. He told the Plaintiff’s friends and family members that the Plaintiff had been kidnapped, disappeared, and would not fight for justice, etc. In the following postings shown on the next page, Yan Zhao invited some of me old friends who misled by Yan Zhao’s rumors to curse me on a public internet chatting room.



Here is the English translation of the postings:
On Friday, November 18, 2011.
The Plaintiff posted at 9:47PM: Good luck to all of you! Good bye!
Yan Zhao Posted at 10:06PM: Shame on you! To establish your own banks, you asked 10% of compensation from other petitioners. I myself wouldn’t ask for that. You shouldn’t be so disgusting, even you are crazy for money. I forgive you again and again. Don’t think I can be insulted. I thought my previous conclusion was wrong. Now the USA court had made decision – your back driver was mad. So, I and your aunt Shen would accept that we have bad luck. Your aunt Shen is right for what she just said: you are a little baby, you need to be careful.
Yuehua Jin posted at 11:00PM: Teacher Zhao, you need to treat her as a patient, treat her as a crazy animal. Leave her alone.
Yan Zhao posted at 12:31: Your black hand had asked all people to join your bank. You and your black hand promised to help the petitioners to file lawsuits against the CCP, so that to ask for compensations. Once successful, you will get 10%. How can you forget it so quickly? Your black hand would ask for evidences or contracts about that. Dare you have guts to admit that? You should let your black hand to show up, instead of being a ghost. You are mad. You should go to hospital. Don’t drive the whole world to be crazy like you.


A10. The 8-Shanghai-Defendants created their illegal armed forces to persecuted citizens in Shanghai. The gang members in the pictures of A10 are not police officers. They are gangs and illegal armed forces led by the 8-Shanghai-Defendants, although they are in uniforms.

A10.1. The Plaintiff Xiamin Zeng had been beaten in this room, the office of the defendant Yiming Yao. The the defendant Yiming Yao and his gang members in this room beat the Plaintiff Xiamin Zeng to broke her nose and knocked out her teeth.

Here is the English translation of the postings:
On Friday, November 18, 2011.
The Plaintiff posted at 9:47PM: Good luck to all of you! Good bye!
Yan Zhao Posted at 10:06PM: Shame on you! To establish your own banks, you asked 10% of compensation from other petitioners. I myself wouldn’t ask for that. You shouldn’t be so disgusting, even you are crazy for money. I forgive you again and again. Don’t think I can be insulted. I thought my previous conclusion was wrong. Now the USA court had made decision – your back driver was mad. So, I and your aunt Shen would accept that we have bad luck. Your aunt Shen is right for what she just said: you are a little baby, you need to be careful.
Yuehua Jin posted at 11:00PM: Teacher Zhao, you need to treat her as a patient, treat her as a crazy animal. Leave her alone.
Yan Zhao posted at 12:31: Your black hand had asked all people to join your bank. You and your black hand promised to help the petitioners to file lawsuits against the CCP, so that to ask for compensations. Once successful, you will get 10%. How can you forget it so quickly? Your black hand would ask for evidences or contracts about that. Dare you have guts to admit that? You should let your black hand to show up, instead of being a ghost. You are mad. You should go to hospital. Don’t drive the whole world to be crazy like you.

A10. The 8-Shanghai-Defendants created their illegal armed forces to persecuted citizens in Shanghai. The gang members in the pictures of A10 are not police officers. They are gangs and illegal armed forces led by the 8-Shanghai-Defendants, although they are in uniforms.
A10.1. The Plaintiff Xiamin Zeng had been beaten in this room, the office of the defendant Yiming Yao. The the defendant Yiming Yao and his gang members in this room beat the Plaintiff Xiamin Zeng to broke her nose and knocked out her teeth.


A10.3. The following two pictures show that the gangs that were sent by the 8-Shanghai-Defendants to the Plaintiff’s house to harass and beat the Plaintiff frequently.

A10.4. The 8-Shanghai-Defendants forced the Plaintiff to be house arrested for about 200 days without any trial, nor court orders. The following two pictures show that the gangs that were sent by the 8-Shanghai-Defendants to the Plaintiff’s house to harass and watch the Plaintiff frequently.

A11. The Plaintiff was falsely arrested and jailed over 20 times by the 8-Shanghai-Defendants or their subsidiaries.
A11.1. The Detention Notice to Detain the Plaintiff for 10 Days on 2010-08-20.
A11.2. The English translation of the detention notice listed in A11.1
The Detention Notice in English

Warrant of Detention Issued by Shanghai Police Bureau

Name: Zeng Xiamin. Gender: Female. Age: 28.
ID Number: 310114198109091421
Work units: Investment Office Jiaoqiao Town Government  .
Address: No. 115, Xinghuo Village, Jiangqiao Town, Jiading District, Shanghai

You were arrested for doing demonstration at the 8-1 entrance of the Shanghai Expo, located at Pudong New District of Shanghai, on August 14th, 2010. Your activities are illegal and disrupt order in public areas.(relevant evidences are listed below: testimony of the defendant, statement of the relevant law, testimony of other witnesses), based on "Republic of China on Administrative Penalties for Public Security law", Article 23, section 2, and item 1, you are given the following administrative penalties:
10 days in prison.
If you oppose this detention decision, you can go to Jiading District People's Government or to the Shanghai Police Bureau for appeal within sixty days from the date you received this notice. You can also go to the people's court for appeal within three months.

Jiading Police Bureau, Shanghai
August 20, 2010
.
A11.3. The Detention Notice to Detain the Plaintiff for 10 Days on 2011-03-08.
A11.4. The English translation of the detention notice listed in A11.3..

Warrant of Detention Issued by Shanghai Police Bureau

Name: Zeng Xiamin.
Gender: Female. Age: 29.
ID Number: 310114198109091421
Work units: None.
Address: No. 115, Xinghuo Village, Jiangqiao town, Jiading District, Shanghai

You were arrested for doing demonstration on Tiananmen Square in Beijing on March 5th, 2011. Your activities are illegal and disrupt order in public areas.(relevant evidences are listed below: testimony of the defendant, statement of the relevant law, testimony of other witnesses), based on "Republic of China on Administrative Penalties for Public Security law", Article 23, section 2, and item 1, you are given the following administrative penalties:
10 days in prison.

If you oppose this detention decision, you can go to Jiading District People's Government or to the Shanghai Police Bureau for appeal within sixty days from the date you received this notice. You can also go to the people's court for appeal within three months.

Jiading, Shanghai Police Bureau
March 8, 2011


A12. The 8-Shanghai-Defendants restricted the freedom of the Plaintiff illegally.
A12.1. The 8-Shanghai-Defendants gave orders to monitor the Plaintiff and restricted the freedom of the Plaintiff.
A12.2. The English translation of the document in A12.1.

Responsibilities of the members in the monitoring and controlling team.

Team name: Security Volunteers.

Basic responsibilities: 1. Watch all time; 2. Strictly forbidden; 3. Daily contact; 4. Report immediately.

Detailed responsibilities:
1.      Watch all time: watch and monitor Zeng Xiamin 24 hours a day, 7 days a week.
Strictly forbidden: Strictly keep Zeng Xiam from getting close to the EXPO area.
2.      Daily Contact: Contact and speak to Zeng Xiamin every day to find any of her potential movement and plans.
3.      Report immediately.: Report immediately whenever there are any suspicious activities or out of control. Immediately report to Wu Guigen, the leader of the Control group, call at 1333-195-0695. For any significant activities, call 110 and report to police immediately.
4.      Understand the target to be monitored:
Name: Zeng Xiamin
Target Class: The most important petitioner.

Priority Group: Highest level.
The Petition Office of the Jiangqiao town.

A12.3. Meeting minutes about monitoring Zeng



A12.4. The English translation of the meeting minutes in A12.3.

Expo security volunteer emergency meeting content

Date: April 23, 2010
Location: Jiangqiao Petition Office
City
supervisors to do in the near future check this end, made
​​the following requirements:
1, Clarify the target to be monitored and watched. Design specific plan for each target person. 
2, Requirement to the monitoring group and team members:
Training content:
(1) Monitoring team: 6 to 8 in one team.
(2) Monitoring requirements: 7 days and 24 hours to monitor the target.
(3) Working principle: Strictly block the 1st and 2nd dangerous level targets moving into the Expo site area.
(4) unexpected events: the village where the head of the real-time reports, reports by the head of the police station, town supervisors to do the Expo
(5) methods of work: flexible application of
Volunteer training arrangements over time, place, personnel coordinated by the Comprehensive Management, today and tomorrow to complete.
Jiangqiao Petition Office

The Petition Office of the Jiangqiao town.
Meeting date: April 23rd, 2010

A12.5. The monitoring reports written by the gang members sent by the 8-Shanghai-Defendants.



A12.6. The English translation for partial of the monitoring reports given in A12.5.
Detention and Monitoring report for significant petitioners during
the world exhibition in Shanghai in 2010

Detention and Monitoring report for significant petitioners during
the world exhibition in Shanghai in 2010




Count
Date
Team Leaders
Suspicious activities
1
2010-4-16
Zhu Wenzhong, Mao Fengying
Zeng Xiamin went out at 6:30am and came back home at 7pm. We followed her.
2
2010-4-17
Zhang Qilong, Li Ping
9:50am-10:45am, Zeng Xiamin went to Jingyuan public bath to have hair cut and have shower.
 
2010-4-17
 
12:40pm, Zeng called emergency 110 to inquire directions.
 
2010-4-17
 
1:00pm, Zeng took the bus to go to the Lotus supermarket.
 
2010-4-17
 
1:40pm-1:50pm, Zeng got out of the Lotus supermarket and walked to another cloth super market.
 
2010-4-17
 
1:55pm-2:00pm, Zeng Xiamin got out of the supermarket and took bus line 948 to go to Putuo Hospital.
 
2010-4-17
 
Shen Dashuang,Zeng Xiamin's father, got of the bus at Caoyang supermarket.
 
2010-4-17
 
2:38pm, we lost them and we have to go back Zeng Xiamin's home.
 
2010-4-17
 
15:43pm, we arrived Room 102, Zeng Xiamin's home. 
 
2010-4-17
 
17:12pm, Shen Dashuang came back home.
3
2010-4-18
Zhu Gendi, Tang Xiaohua
During our duty time, Zeng Xiamin was not seen to go out for the whole day.
4
2010-4-19
Zhu Wenzhong, Mao Fengying
During our duty time, Zeng Xiamin was not seen to go out for the whole day.
5
2010-4-20
Ding Minwen, Chen Yongsheng
During our duty time, Zeng Xiamin was not seen to go out for the whole day.
6
2010-4-21
Zhu Gendi, Tang Xiaohua
Zeng Xiamin was forced to stay home all day.
7
2010-4-22
Zhu Wenzhong, Mao Fengying
Zeng Xiamin was forced to stay home all day.
8
2010-4-23
Zhang Qilong, Ding Minwen
11:00am, No one got out from Zeng Xiamin's house.
9
2010-4-24
Zhu Gendi, Tang Xiaohua
Zeng Xiamin has been at home all day. Everything is ok.
10
2010-4-25
Zhu Wenzhong, Mao Fengying
10:00am, Zeng Xiamin went out to give away trash. Around 3:00pm, she went out to purchase a phone card. She came back home at 7pm.
11
2010-4-26
Zhang Qilong, Ding Minwen
Zeng Xiamin went out at 6:30am and came back at 7:30pm.
up to
2011-5-1
ignored
similar records as above.
200
more lines
up to 2011-5-1
The rest of the lines are not translated.
A13. Evidences that can prove the demolish activities are illegal.
A13.1. The demolish permit should be given by court orders. The 8-Shanghai-Defendants created the demolish permit through the Department of Residential management of Jiading District. The demolish order is illegal.
A13.2. The enforcement notice for the forced demolishment was issued by the government of Jiading district. According to the Chinese law, only the court and the State Department are the legal authorities to issue orders to expropriate lands and residential houses.
A13.3. The English translation of the document in A13.2.

Enforcement notices
Document No.: (2009) 12

Yan Xiaomei, Zeng GuoJuan Families:
Your house located at 115 Xinghuo village, Jiangqiao town, Jiading District, Shanghai, is within the construction area of the Beijing-Shanghai high-speed railway and will be demolished. On September 8th, 2009, the Department of Residential Houses of Shanghai  has issued the “Housing Demolition Management Regulations" (document No. 2009-032), which gives the permit to demolish your house.  Because you failed to reach a resettlement agreement with the demolition contractor, the demolition contractor (Jiangqiao town, housing security and the Authority) will demolish your house. You are forced to move out the house within 15 days. The demolition contractor is authorized to demolish your house 15 days after you receive this notice.

We hope you to cooperate with the demolition contractor and vacant the house as soon as possible. 

Notice is hereby given.
People's Government of Jiading District
December 3, 2009

Cc:
District Housing Authority housing support
The District Police Bureau
Jiangqiao Government, the District Notary Office.

A14. The real estate license of the Plaintiff’s house and land.
The following real estate license indicates that Plaintiff and her family own the stated 3 acre land and the house on that land.


A15. Since June 30, 2011, Plaintiff Xiamin Zeng has started to protest at various locations in the United States against the CCP, to appeal for fair compensation for her demolished house and robbed land.

A15.1. Plaintiff Xiamin Zeng protested at the Chinese Consulate General in New York.

A15.2. Plaintiff Xiamin Zeng protested at the UN building in New York.


A16. Defendant Yan Zhao and Defendant Yuhua Tang worked together to lure Chinese dissidents into their well designed traps.

A16.1. Defendant Yan Zhao posted many articles on Boxun.net or canyu.org to describe/disclose the terrorism assaulting plans against the President Hu Jintao at the APEC conference held in Hawaii around November 12, 2011. The articles described details about the assaulting plan, including participant’s name list, time, location, etc. Using these articles as evidences, the Chinese Communist security agents reported the terrorism plan along with the terrorism suspects to FBI and resulted some of the Chinese dissidents/petitioners being interrogated by FBI. The following picture shows a web article/video about Mr. Furong Ai being interrogated by FBI.
A16.2. Defendant Yan Zhao posted many articles to describe/disclose the terrorism plans against Hu Jintao. Only the subject lines and related urls are listed here.


A16.3. Defendants Yan Zhao convinced Chinese dissidents/petitioners to post articles about their protest plans, which can be used as evidences for terrorism assaults.

A16.4. To convince FBI or Chinese dissidents that to assault Hu Jintao is a mission possible, Defendant Yan Zhao shoot/posted a video about the Chinese First Lady in Hawaii.

A16.5. English translation/description for the files in A16.1, A16.2, A16.3, and A16.4.
All the contents in A16.1, A16.2, A16.3, and A16.4 are simply searching results on the web.

Files in A16.1 give the web address for a video in which Mr. Furong Ai was interrogated by FBI, because the Chinese security agents reported that Mr. Furong Ai was a terrorist suspect.

Files in A16.2 give a list of web articles written/posted by Defendant Yan Zhao. All these articles are talking about the terrorism assaulting plans against President Hu Jintao, with details including who (Furong Ai, Lifang Ge, Dongyan Wang, Yongli Wang, etc.), when (November 12-13, 2011), where (Hawaii), and How (throwing eggs/tomatoes, stop the Vans of Hu Jintao’s). Defendant Yan Zhao used different author names to post these articles. All the author names highlighted in rectangles are Yan Zhao’s pen names. To avoid the conspiracy traps being exposed, all the articles with the Defendant’s true name were removed after the APEC conference.  

Files in A16.3 give a list of web articles posted by some of the Chinese dissidents/petitioners. Although these articles shows author name as Furong Ai or Lifang Ge, most of the original contents/ideas were provided by Defendant Yan Zhao.

Files in A16.4 show the web address of a video shot and posted by Defendant Yan Zhao. The video shows that Defendant Yan Zhao encountered Ms. Liu Yongqing, the First Lady of China, at the Sheraton Hotel in Hawaii.

2 comments: