AMICUS CURIAE AFFIDAVIT filed on behalf of Elsie Figueroa by Kathleen M. Dickson, et al




State of Connecticut vs Elsie Figueroa


DOCKET _______________________________



New Britain Superior Court

20 Franklin Square

New Britain, CT 06051


February 13, 2006




I, Kathleen M. Dickson, do HEARBY SWEAR that the following statements are truthful, sworn testimony, written as any reasonable person would understand, before God, as stated, and regarding the known incompetence, perjury, acts of defrauding the both the courts and The United States of America, the criminal behavior of the Connecticut Department of Criminal Justice and the CT Department of Children and Families (DCF) and related staff, and are in support of significant mitigation of charges against Elsie Figueroa. 


I further claim that no Connecticut resident stands a chance of intact and sane survival once “handled” by the incompetent, criminally insane frauds -Department of Children and Families- and the promoters and supporters of other abuses by staff of the Department of Health, the Department of Mental Health and Addiction Services, and the Department of “Corrections.”



I.  ABUSE OF PRISONERS in the PRISONS by the GUARDS (page 2)


Neuroleptic-induced akathisia and violence: a review


                        DCF WIRETAPPING


Joseph More, Elizabeth Byron, Vladimir Coric, Alice Smith, Christopher Gottschalk, Kenneth Marcus

V.  INCOMPETENCE, CRIMINAL SCIENTIFIC FRAUD and RACKETEERING by YALE   UNIVERSITY             LYMErix and the testing for Lyme disease   (page 15)


Vladimir Coric, James Phillips;  The fact that Yale knows how to perform a valid mental evaluation


Ethics questions raised by the neuropsychiatric, neuropsychological, educational, developmental, and family characteristics of 18 juveniles awaiting execution in Texas. NIH Clinical Trials, Bipolar (page 16)




X. CONCLUSION (page 31)



I personally have witnessed numerous examples of direct abuse and provocation of prisoners in the York prison.  I have witnessed a guard taking a swing at a prisoner’s head with his fist (she ducked).  I have witnessed every kind of verbal abuse to prisoners, randomly and without provocation.  I am aware of two specific circumstances (case names) where the guards, rather than defend a prisoner attacked by another, either blamed the attackee, or demanded that the attackee hit back, and then the guards pounced, throwing both in “segregation,” so that the guards would not have to file a police report of an assault.  I can provide the names of those involved and the witnesses.

I was involved in a situation where the head nurse of the mental health section of the women’s prison, Jan, tried to provoke another prisoner to violence against myself and two other prisoners, by lying to that other prisoner (who had a reputation for violence) about what we did and said.  I can provide the names of the individuals involved who will be witnesses should the occasion arise where I am called to demonstrate that these events occurred as I report they did to this court in this Amicus.

The condition of the women’s prison promotes and supports violence, since, in this way, the guards get plenty of overtime.   I have seen instances where a prisoner was agitated, and where a DMHAS staff person single-handedly was able to get the prisoner to calm down (CVH).  The reverse happens in the prison.  In the case of Elsie Figueroa, she would have learned from “Corrections” that violence is necessary to survival because the guards absolutely will not protect the prisoners.  The guards promote fights and enjoy them.   There is no other entertainment going on in the prison, and so the guards enjoy the fights very much. 

I have seen a prison guard have an angry, fiercely gesticulating conversation with no one.  The guard was walking along, completely alone, on a “lock down,” and thought no one was looking.  I can provide the name of this guard.  Being a prison guard is clearly attractive to racist/KKK/member psychopaths.  Working as prison guards, is where most of the Connecticut white supremacists can be found.  This is 100% undeniable.

Given the prison guards’ obvious lack of restraint and obvious lack of effort to hide their abundant and pervasive racism, one can imagine the guards talk about what heroes they are to their children at home,  “Yes, Junior, today I body-slammed another POS-moron for sticking her tongue out at me.  It was great.  Perhaps when you grow up you can also participate in the fun.  You don’t even need a college degree, you only work 20 years, and look at all my nice gold jewelry that I wear to the prison every day.  Look at that gorgeous car out there in the driveway.  And all I have to do is go to work and be a vicious psychopath all day, and I get paid for it!!!”

This is precisely the sentiment I encountered in the prison.  How can these guards turn it off at the end of a work shift at the prison?  Hatred, abuse and violence is precisely what is taught by example to young women in the prison, who have a reputation in the prison for being violent and dangerous, true or not.  They are called “Y-Os” which is prison jargon for Youthful Offenders.  The word among the other prisoners is that the YOs are to be avoided because they are violent, true or not.

 A young female incarcerated in this environment will undoubtedly very quickly learn that violence is the only means of survival.  The women’s prison is probably now much like the men’s prisons, and this is due to the fact that the guards foster violence and will not protect anyone who is a victim of violence by another prisoner.  One wonders if the prisoners themselves are actually more violent nowadays, or is this due to exposure to the vicious and insane psychopathic male guards?  

The guards simply do not want to fill out the paperwork.  Any kind of violence brings “a code.”  Then, 15 guards run around hysterically, with all their jingly tough-guy metal equipment, and with their trousers tucked into their boots as if they are on some SWAT Team Wannabe “Terminator” Safari out to save the whole world from the bad guys.  They have no idea how foolish they appear.  They get the camera AFTER the incident, and capturing only what they want to capture on video. 

These are UNARMED WOMEN, are we are talking about.  Why the SWAT Team Wannabe response?  Because the vast majority of prison guards in Connecticut are psychopaths.  Where else would we expect to find a psychopath regularly employed? 

The guards make no attempt to hide the fact that they are gang members.  In this sworn affidavit, I am stating under penalty of perjury, that I have heard prison guards discuss being members of a gang.  The prison guards are not allowed to be gang members.

The point is, how can DCF send these girls into this environment and expect to not have churned out future violent criminals?    How is this child, Figueroa, responsible for having acquired hatred and violence “skills” at the hands of the DCF and “Corrections?”


When the HARTFORD COURANT does a story about DCF or “Corrections” or how children are “handled,” they rarely give the children’s or the DCF-abused family’s side of the story.  In my “case,” I have even offered to sign over all of DCF’s “records,” with the stipulation that I get to demonstrate where the DCF are lying in their “records.”   I am happy to do that to anyone who comes forward and would like to learn more about this, under CT Statute 17a-28.   This is the one way the public and the legislators can know the real reason for DCF’s failures.  I never get a response or a call back from either the Governor or any of the legislators, despite my record of Lyme activism and accomplishments, and despite the fact that I was an analytical chemist for Pfizer for nearly 10 years.  One would think a chemist would have something logical to say, since how can one get a degree in chemistry if one is as insane as DCF says I am?  ‘Especially when they themselves (DCF) invented what I did and said, meaning they’re the ones who are psychotic. 

If I told the FDA vaccine committee in Bethesda, MD, in 2001, in simple terms, that none of the contributors to the national blood testing standard discussions for Lyme disease in Dearborn, Michigan (1994) agreed with the current testing for Lyme disease, and that none of these labs found the current CDC method for the detection of Lyme disease to exceed 25% accuracy, and challenge all to prove me wrong - despite these contributions and opinions being published and published science – how is it no one has done so? 

If I say, “Yale University committed scientific fraud, and know how to test for Lyme disease with 94.4% accuracy and 100% specificity, and they have a patent for this method (US Pat No 5, 618, 533), but this accurate method is not in use because they wanted to pass off their bogus Lyme vaccine (LYMErix, Yale patent US Pat No. 6, 747, 294),” why am I not challenged about these facts by anyone in the State of Connecticut?  Isn’t DCF mandated to discover if children are not receiving proper medical care?  The current CDC testing for Lyme disease is at best, 25% accurate.  That mean 75% of the cases are being missed.

Why do these facts never make it into the newspaper?

If I say “Yale University committed an enormous crime, and that they never had a Lyme vaccine and they are denying us the use of this early and accurate test for Lyme,” why does not one person in the State investigate whether or not that is true?

No one can sue me for slander or libel.   That would be because I never slander or libel. 




I have Lyme borreliosis, which is a permanent brain infection.  I was falsely arrested by the thoroughly psychotic ASSISTANT ATTORNEY GENERAL JESSICA GAUVIN, and falsely criminally charged with GAUVIN’s own insanity.  I was reporting Gauvin’s and the DCF’s insanity and criminal behavior to the US ATTTORNEY KEVIN J. O’CONNOR, in New Haven, repeatedly.  Gauvin invented for me that I have “command hallucinations to kill,” etc., and then she falsely criminally charged me with saying that myself, when she knew that was false.  I was not allowed a trial.  My children, who also have Lyme, were fraudulently removed and placed with a known child-abuser, wife-beater, and psychiatrist-diagnosed “sociopath,” DONALD G. DICKSON, and are not being treated for Lyme disease and Ehrlichiosis.

 This is: risk of injury to minors, medical neglect, false allegations, are numerous frauds upon the court, perjury, and then a false arrest.  If GAUVIN invented for me that I have “command hallucinations to kill,” then that is, by definition, an example of AAG JESSICA GAUVIN’S PSYCHOSIS.

While in the prison, the prison health staff were insane, vicious, lied to other prisoners to provoke fights among the prisoners.  They refused to treat me for Lyme disease, although they had a court order to do so from Judge Kevin P. McMahon.  The prison staff had an order to give my ibuprofen, but they declined to tell me this and never gave it to me. 

I had a discussion about my aberrant bloodwork with HUMBERTO TEMPORINI, MD, in the prison and when I explained to him that I have Lyme disease and High Functioning Autism (which comes with it a known immune incompetence, since HFA is a condition of reversed duplication and over-expression of a B cell lymphoma molecule, resulting in incompetent lymphocytes), Temporini and the other staff were furious.  They do not like to hear medical facts from a pharmaceutical chemist.  One wonders what are the criteria for hiring such staff, if they would not even consider verifying these claims on MEDLINE, rather than be furious-acting “mental health staff,” and refuse to follow a judge’s order for medical treatment?

I had a discussion with Dr. CRABBE in the mental health section of the prison.  He offered me whatever psychotropic I wanted.  I said, “No thanks, they are all brain damaging.”  The prisoners are allowed to get whatever psychotropic they like and most try to get Seroquel in order to sleep their sentences away, unaware that this will contribute to a dementia in the same exact way street drugs do.  Chronic specific neurotransmitter receptor antagonism results in the down-regulation of that receptor.  Chronic specific neurotransmitter transporter antagonism (SSRIs) results in the down-regulation of that transporter.  People with depression end up more depressed; people with severe anxiety end up more anxious to the point of mania.  The latter is known as “rebound psychosis.”  No one in Connecticut wants to hear these facts, although I am quoting the published science.  The effect of psychotropics on young people is unknown, but neither the DCF, DMHAS, or “Corrections,” care about these bad outcomes of their “treatments” because there is no incentive for a reduction in the bodies in this meatgrinder called Connecticut, or a reduction in the overtime created by creating the deranged and the “criminals,” through this organized abuse.

I do not know if Ms. Figueroa took advantage of the available “brain candy” (psychotropics) at the prison, but if she did, and if she took any kind of psychotropic whatsoever, her case is automatically mitigated because the published science says it is.


1: J Forensic Sci. 2003 Jan;48(1):187-9.

Related Articles, Links

Neuroleptic-induced akathisia and violence: a review.

Leong GB, Silva JA.

Center for Forensic Services, Western State Hospital, Tacoma, WA 98498-7213, USA.

Surprisingly, the association of neuroleptic-induced akathisia and aggressive behavior was not formally recognized until nearly two and one-half decades of antipsychotic prescribing had passed. Using a search of the anglophonic literature, this phenomenon is reviewed. Advances in psychopharmacology have reduced neuroleptic-induced akathisia and hold promise to eliminate it altogether. Nonetheless, important clinical and forensic aspects of neuroleptic-induced akathisia and aggression remain and are explored.
Publication Types:    Review   
PMID: 12570226 [PubMed - indexed for MEDLINE]



This means that it is well-understood that liability is to be shared if there is a known correlation between psychotropics and violence- that association being the psychomotor agitation caused by the psychotropics.

We have all heard of criminal violence being associated with illegal drug trade and use.  How is it not common knowledge that the same occurs with prescription “medications?”  The State is in possession of the full text of this above abstract.  I am an analytical chemist and used to work for Pfizer.


Here is Pfizer discussing how to treat the SSRI’s induced agitation (akathisia), while simultaneously denying it exists:


1: J Psychopharmacol. 1998;12(2):192-214.

Related Articles, Links

SSRI-induced extrapyramidal side-effects and akathisia: implications for treatment.

Lane RM.

Pfizer Inc., New York, NY 10017, USA.

The selective serotonin reuptake inhibitors (SSRIs) may occasionally induce extrapyramidal side-effects (EPS) and/or akathisia.This may be a consequence of serotonergically-mediated inhibition of the dopaminergic system. Manifestations of these effects in patients may depend on predisposing factors such as the presence of psychomotor disturbance, a previous history of drug-induced akathisia and/or EPS, concurrent antidopaminergic and/or serotonergic therapy, recent monoamine oxidase inhibitor discontinuation, comorbid Parkinson's disease and possibly deficient cytochrome P450 (CYP) isoenzyme status. There is increasing awareness that there may be a distinct form of melancholic or endogenous depression with neurobiological underpinnings similar to those of disorders of the basal ganglia such as Parkinson's disease. Thus, it is not surprising that some individuals with depressive disorders appear to be susceptible to developing drug-induced EPS and/or akathisia. In addition, the propensity for the SSRIs to induce these effects in individual patients may vary within the drug class depending, for example, on their selectivity for serotonin relative to other monoamines, affinity for the 5-HT2C receptor, pharmacokinetic drug interaction potential with concomitantly administered neuroleptics and potential for accumulation due to a long half-life. The relative risk of EPS and akathisia associated with SSRIs have yet to be clearly established. The potential risks may be reduced by avoiding rapid and unnecessary dose titration. Furthermore, early recognition and appropriate management of EPS and/or akathisia is required to prevent the impact of these effects on patient compliance and subjective well-being. It is important that the rare occurrence of EPS in patients receiving SSRIs does not preclude their use in Parkinson's disease where their potentially significant role requires more systematic evaluation.
Publication Types:  Review   
PMID: 9694033 [PubMed - indexed for MEDLINE]



“The relative risk of EPS and akathisia associated with SSRIs have yet to be clearly established.”    It is  legally safer for pharmaceutical companies to pretend they don’t know what they are talking about.

After long term use and the removal of SSRIs, a person ends up more depressed than when they started because the specific antagonism is of a serotonin transporter.  The body senses that, “Oh, I don’t need this much serotonin,” since the normal amount is not being reabsorbed.  Fewer serotonin transporters are needed.  Remove the drug?  The person is left with an overall serotonin deficit.  Some people claim they now can’t live without antidepressants.  This would be why.

Rather than it being true that “mental illnesses” are usually the result of a chemical imbalance, in truth and in fact, psychotropics result in a chemical imbalance.  Whoever has seen someone detox from heroin – up close and personal - knows what I mean when I say “chemical imbalance.”  These poor victims of the Department of Corrections’ incompetence are “chemical imbalancing” all over the floors, walls, and ceilings of the prison for 5 days straight and the guards stand in the doorways and laugh at this.  I do not exaggerate.   These heroin detox-ors claim they feel like they are “crawling out of their skin.”  That’s exactly what it looks like to the casual observer. 

The prisons are required by CT law to treat “clinically relevant heroin addiction.”   They never do, and then they lie about it.  This is factual.  A prison psychologist lied about this to my face, and then immediately interrupted his own interview and left the room.  I frightened the prison psychologist away with a fact. 

The prison psychiatrists prescribe any drug anyone wants, and the more sedated the prisoners the better, is the probable thinking, but this actually results in increased violence, and when these prisoners are released they are triple basket-cases, and of course, return to prison.




The State of Connecticut, DCF, is fully aware of numerous mechanisms of psychotropics-induced agitation and violence because I gave the DCF several full text articles in the early winter (January 2003) and fall of 2003, regarding these specific drug-rebound effects, and informed them that they were now partially liable for any cases where their forced-drugged victims became violent. 

The family of the Burgos boy who committed suicide in Manson prison last summer now has a wrongful death case against the State of Connecticut.  No children should be force-drugged since the published scientific data already identifies the brain damage caused by psychotropics, which I now present to the court.  It is common knowledge that “10 different psychiatrists will give 10 different diagnoses of the same patient.” (The New York Times)  Therefore, would it not be convenient for the DCF just to assign any child any diagnosis, depending on the treatment protocol being developed at Yale?  If all psychotropics are simply anesthetics (technically, this is what they are as neurotransmitter blockers), won’t any “treatment” result in a diminution of “symptoms?”

People don’t realize that this is exactly what most psychotropics are:  Anesthesia, where they aren’t stimulants.  DCF kidnaps kids and then numbs them into oblivion.   DCF is not responsible for these brain-damaged-children-come-adults, and have no interest in them unless these victims later become parents.  For some families, they are never out of the State’s crosshairs their entire lives and recycle through various incarceration-like “interventions,” rendering them hopeless, uneducated, and having no real-life skills.  One would expect to find these young women to be out of their minds and they are.

I hand-delivered these full-text scientific articles that show that all psychotropics are brain damaging to LAURA LUSTIG of the New Learning Center Westport, 1200 Boston Post Road, on November 20, 2003.  Laura Lustig’s second in command at that time was MARK MARCUS, who advertised on Lustig’s website that he was a former DCF Commissioner.  Lustig also had a contract at that time to train the cognitively- and morally-impaired DCF “social workers” to be even more truth and fact- impaired.

DCF’s PATRICIA LEEBENS defrauded the court with her Order of Temporary Custody of my children 6 days later (November 26, 2003), and did not mention this databinder full of scientific journal articles, nor did she state what was the true content of the other databinder left with Laura Lustig - the 3 inch databinder dated 11-16-03 - which contained my responses to complaints I filed against the DCF staff to the Commission on Human Rights (PEKAH WALLACE, Waterbury CHRO) and Statewide Bar Counsel (ATTORNEY GERALD DWYER, New Haven).  Leebens defrauded the court, and then “left the country” and could not be cross-examined in the 10 days allowed after the issue of the OTC for my children.  I completely proved my “case” was fraudulent by Nov 20, 2003, and that these were all false allegations and nonsense reported by the criminally insane NANCY MARTIN, DCF staff, DONALD DICKSON, and JAMES PHILLIPS.   DCF would have none of it.  They did not want these scientific facts or these facts of false allegations and perjury, nor the scientific evidence regarding the specific brain damage caused by psychotropics to become a record of the court.   They are now, and DCF is liable.  Leebens wanted me to be committed on the day of the OTC.  There were two State Troopers standing by.  I fooled them.  I had always been telling the truth, whereas Gauvin and everyone else were not. 




The formula for DCF is to tell everyone you, their victim, knows, stories that are 180 degrees from the truth.  They call up everyone their victim knows and lies about them, so that all are happy to come and perjure themselves in the State’s behalf.  They also bug all of their victims’ phones. 

This DCF phone-bugging will become common knowledge.  Gauvin repeated what I said the night before on the phone to my children, verbatim, the very next day, in the courtroom.  Elements of my phone conversations are being repeatedly rebroadcast onto the internet.  Since the Stonington Police will do nothing about my complaints of my phone being bugged, they must either approve of it, or this remains the case with the DCF still having bugged my phone and allowing others to be privileged to my conversations.

The issue is, how can anyone mount a defense of their fraudulent DCF persecution, if one is not allowed to have privileged phone conversations with their lawyer? 


This will become common knowledge in the interest of public safety.


All psychotropics are brain damaging, cause brain cell lose, and cause agitation and/or dementia.  Stimulants (Ritalin) cause the down-regulation of dopaminergic tone and, in effect, decrease intelligence.  The addition to prescription psychotropics occurs through the exact same mechanisms as addiction to street drugs.  My own sibling complained of spending the whole day crying in the bathtub when he/she ran out of Zoloft.  I told my own incompetent psychiatrist about this (JAMES PHILLIPS), and he would not do anything for him/her.  My sibling was never this bad before he/she started taking Zoloft.  The effect over the long term is, again, greater depression, due to the down-regulation of serotonin transporters.  What if she/he had decided to take his/her own life?  How would I have felt, if he/she did and I did not do enough for him/her?

            James Phillips was my psychiatrist for “child abuse.”  This child abuser was CAROLYN MARTIN, the mother of another of my siblings who was having this rebound reaction to Zoloft.  Nancy Martin invented the false allegations against me, with her mother, Carolyn Martin.  Carolyn Martin invented for me that I “showed up at her house and threatened to slit my own throat.”  I removed my children from the presence of Carolyn Martin because she was physically violent and verbally abusive to my children in early December 2002.

This is a clear pattern.  Carolyn Martin was violent and abusive to her own children, and she started in with her hatred and violence on my children.  She told my daughter Diane that Diane was not sick with Lyme disease- that Diane was, “just stupid and clumsy, like your mother.”   This may seem like no big deal unless one has seen Carolyn Martin in action.   She nearly broke her foot kicking my now-deceased brother, JAMES MARTIN, and she beat us with a cat of nine tails but she now blames all of these beatings on my now-deceased father.   Carolyn Martin beat us with a whip, too.  My father never kicked anyone, nor did he ever say anything vicious and mean about anyone.  He also hated liars, much like myself.

DCF approves of all of this abuse and reported in their “records” that Carolyn Martin asked me to leave.  No such thing happened.  I took my children away from Carolyn Martin because she was abusing my children and saying horrible, untrue things about my children, to others.  Carolyn Martin apparently was also saying horrible and untrue things about me, to others.  Carolyn Martin is insane, Nancy Martin is insane, and yet Carolyn Martin is still in the care of other children- a child who the schools wanted to diagnose as having Childhood Schizophrenia.

 In any other world, people would observe that there is something very wrong with Carolyn Martin to have caused this much disorder in the lives of so many children: 5 of her own, and 4 grandchildren.  Not so Connecticut DCF-land.  DCF loves this kind of viciousness, lying, and abuse, since they do it themselves.



Joseph More, James Phillips Elizabeth Byron, Vladimir Coric, Alice Smith, Christopher Gottschalk, Kenneth Marcus, “Medical Director” for DMHAS



It should be stated from the outset that DMHAS is now being investigated for their well-known incompetence by the federal government.  DMHAS has also been sued by the Office of Protection and Advocacy for Persons with Disabilities, for their incompetence.

In my “cases,” the above individuals committed perjury.  Lyme is a brain disease, I have this brain disease, DMHAS’ CVH staff spoke with my infectious diseases specialist, yet perjured themselves about that conversation (DMHAS’ Elizabeth Byron).  All of the above in one way or another denied that Lyme is a brain disease, that it causes an organic delirium, and that the American Psychiatric Association’s guidelines on the treatment of a delirium specifically state that even in the condition of a comorbid “psychiatric disorder,” the delirium is to be treated medically first, because psychotropics can exacerbate the delirium.  This is a long-understood phenomenon, the newest research supports this, and advises against treating Alzheimer’s patients with central nervous system depressing psychotropics (antipsychotics).  This “treatment” can kill older people for the obvious reason that CNS depressing agents act wherever there is the right neurotransmitter receptor, which could also be the heart or other organs. 

A well-known phenomenon of CNS depressing psychotropics are heart irregularities.  Anyone with a brain in their head- which clearly excludes anyone who works for the State of Connecticut – would understand that a brain anesthetic might have the effect of anesthetizing certain other autonomically regulated CNS function, such as the heart and breathing.   DMHAS and DCF now want all of their lying, ridiculous “records” to be kept 100% confidential, such that they are not held accountable for the accidental deaths due to misdiagnosis and malpractice treatment of their victims.  One such victim is LESLIE ANDINO who has Multiple Sclerosis.  Multiple Sclerosis is a brain disease.  Ms. Andino was treated with CNS depressants by the incompetent staff at DMHAS.  She was – not surprisingly- never “restored to competency,” and with this continued malpractice treatment of her as a result of her being mismanaged and uncared for at nursing home, resulted in an accidental fire, which killed 16 elderly people who never should have been housed with persons with simple medical illnesses that affect the brain, Ms. Andino will continue to deteriorate.  Her life is effectively OVER because of the incompetence of others.  Ms Andino could have been in a group home for disabled people- something I requested funding for from JOHN G. ROWLAND in 1997 and was met with the typical Connecticut-Incompetence Response.  I asked for money for a group home for disabled people who have Lyme/Multiple Sclerosis.  The State sent me legal references about group homes and ignored my specific request for funding for this group home.  I imagine that had anyone in the State of Connecticut been competent to care, perhaps all 17 of them involved in the destruction of the nursing home might still have a life/be alive.   The bodies hidden from view by DMHAS continue to add up, despite their efforts to be unaccountable.

I have no idea how GOTTSCHALK can call himself a neurologist and dare to say to me that Lyme disease is not a permanent brain infection, when this fact was “well-established” in 1944, and “well-known” in 1975.  One wonders if there is not a pervasive collective Jungian psychosis occurring at Yale University.  They were formerly sons of Belial?  The only reason I say this is because James Phillips is still a Freudian, and physical and verbal assaults against children (CAROLYN MARTIN) and Lyme neuroborreliosis have absolute ZERO to do with sex, but to a Freudian everything has everything to do with sex.  For all of Yale and DMHAS to perjure themselves to defend this man’s malpractice reminds one of the Prince of Licentious (Belial-  a mythical demon):  

Unrestrained by law or morality; lawless; immoral; dissolute; lewd; lascivious, Unrestrained; uncurbed; uncontrolled; unruly; riotous; ungovernable; wanton; profligate; dissolute; lax; loose; sensual; impure; unchaste; lascivious; immoral, dissolute indulgence in sensual pleasure.


It is important to recognize how far hypothetical psychiatric nonsense has perverted the human experience.  Jung and Freud were “giants” in the non-science of Psychiatry.  Can anyone get into this “making it up as we go along” game, or is it only the purvue of Yale Psychiatric lunatics?  I prefer to stick with the facts.  A factual and scientific approach to life has served me well working for Pfizer and studying the scientific fraud in “Lyme disease.”

DMHAS/CVH’s ALICE SMITH has no right and no place telling me anything about Lyme borreliosis at all.  I would request of the court to find out more about her and whether or not she is appropriately placed at DMHAS.   It’s bad enough that the medical doctors at CVH are 100% incompetent to brain matters.  I wonder under what delusion Alice Smith believes she has any authority to tell me anything about Lyme disease.  Where are ALICE SMITH’s Lyme websites with all the scientific articles links and scanned in?  Where is her testimony on the FDA’s website about how Yale’s LYMErix vaccine was a complete fraud?

The testimony of anyone from DMHAS or Yale in any criminal or DCF “case” in  Connecticut may now be thrown out, due to a complete loss of integrity/credibility of their “forensic testimony.” 




Yale University owns the patent for an early and accurate (94.4%) and close to 100% specific test for Lyme borreliosis.  That patent number is US Pat No. 5,618,533 and was applied for in Dec 1993.  Yale also owns the patent for LYMErix (US Pat No. 5,747,294).  Yale did not use their early and accurate 5,618,533 test for Lyme borreliosis to assess the outcome of LYMErix because 4 days after they applied for a patent for LYMErix, Yale sent for publication a scientific article in which they explained how LYMErix would not work.

In the body of the patent for Yale’s early and accurate test for Lyme disease, they claim:


“The neurologic manifestations of Lyme disease are protean and include weakness, peripheral nerve palsy, radiculitis, meningitis and encephalitis. …”


“Antibodies to the B. burgdorferi flagellin antigen remain prominent in patient serum during infection, and local CSF antibody production to spirochetal antigens, including flagellin, occurs. Further, the sera from patients with neurologic manifestations of Lyme disease have IgM antibodies that bind human axons; binding is weak or absent in patients without neurologic disease. The presence of high antibody titers in the CSF correlates with clinical signs of neuroborreliosis. ..”



This means that this antibody, the 41 kilodalton flagellin antibody, is not only accurate, early, and made nearly 100% specific by Yale’s further refinement (the actual claim of the patent is for the specificity of their flagellin fragment), Yale suspects it might be involved in the neurological disease process.

Therefore, for anyone at Yale or DMHAS to claim that Lyme is not a brain and nerve disease, under oath and in court, as part of forensic testimony, one would expect that expert witness to also demonstrate where a brain cell is not a nerve cell.  This did not occur in any of my famously perjuring prosecutions- in the false criminal charges “case,” and in the DCF “case.”

The State of Connecticut is 100% incompetent to brain matters.  No staff member of DCF, DMHAS, or the Department of Health explained to the FDA how Yale’s LYMErix vaccine was not proven to be a vaccine.  I did.




Vladimir Coric, James Phillips

The fact that Yale knows how to perform a valid mental evaluation




James Phillips gave me every kind of psychotropic that there is, except for the ProVigil that I asked for initially, in Sep 2000, to increase daytime alertness (June 2000 to Dec 2002).  Lyme neuroborreliosis is a CNS infection and causes delirium, demonstrated by brain imaging.  Instead, Phillips gave me more brain damage which was evident to all, in a large public forum, in January 2001, since I was intensely pacing (the brain damage known as akathisia) and body- rocking at the FDA meeting in Bethesda (Jan 2001).  After causing significant extra brain damage to the point where I could not even sit in the summer of 2002, and after 10 different medications, Phillips said, “I think you need to be on medication, I just don’t know what kind.”  Two and a half years after asking for ProVigil, and putting up with all of his nonsense, he finally decided to look into what Lyme disease is, after I had been talking about Lyme for 2.5 years, and discussing specific markers of neurotoxicity.  Then when he knew I was going to sue him for malpractice, he perjured himself and told people I was “unstable.”  Unstable is exactly how a person with psychotropics looks.  Body rocking and intense pacing is subjectively felt agitation and feels like you have butterflies in your stomach, 24/7.

Therefore the point of all of this abuse of myself and my children was to blame me for Phillips’ malpractice, rather than Phillips is sued for malpractice.  I lost my children and went to jail on totally false criminal charges to prevent a malpractice lawsuit against a Yale clinical professor of Psychiatry and forensic Psychiatrist for the State.   There is no question I was talking about Lyme as a brain disease the entire time, and I put up two websites while his patient one in Nov 2000 and one in 2001.  Both websites mention markers of disease in this brain infection, Lyme borreliosis.  I was falsely blamed for Phillips’ malpractice by Jessica Gauvin and all of her perjuring witnesses.

All of this abuse of myself and my children was the result of seeing “the most incompetent psychiatrist who ever lived,” who I stated I was seeing because of abuse by Carolyn Martin and not because of Lyme disease.  Thus, because of the abuse of Carolyn Martin, my children are now with the well-known and extensively documented child-abuser, wife-beater, and sociopath, Donald G. Dickson. 


Extrapolated as perjury were my discussions to Phillips about how the Lyme delirium manifests.  This is not psychosis- these are reduced consciousness signs (known to Lyme patients as “sleep-driving,” or “Lymenesia,” and know to Lyme experts as Lyme delirium).  Gauvin presented it as psychosis because she knew I was going to sue Phillips for malpractice.  I was not allowed to refute this perjury.  My lawyer Peter Bartinik did not have me refute any of the perjury in my DCF “case.”  I found out after I was released from CVH - after allegedly being “restored to competency” - that one is supposed to refute the perjury in one’s trial.  Bartinik never told me this, nor did I learn it from CVH in “competency restoration.”  This was never discussed once.  I read about it after I got out of prison.  So much for hiring a lawyer and “competency restoration.”  Competency restoration at CVH is, in fact, where they threaten you to take the plea bargain, or you will be committed permanently and the State will take all of your assets and income to pay for your treatment for a State prosecutor’s psychosis.  This is what I learned in DMHAS’ competency restoration.  DMHAS has been found incompetent by the feds and is being sued by the OPAPD for being incompetent.

All residents of Connecticut should hereby be advised to give a potential competency evaluation and intelligence test to any psychiatrist before paying them a cent.  I have found not one psychiatrist yet, who is fully competent to brain matters in the State of Connecticut.


The perjury of Yale’s VLADIMIR CORIC and “The Case of the Missing Kathleen Martin (Dickson) Records from the 1980s,” was about helping JAMES PHILLIPS not being liable for his chronic malpractice treatment of me.  Phillips gave me exactly 3 bottles of tranquilizers to use as needed from 1980 to 1985, when I saw him on and off for my child abuse by CAROLYN MARTIN - which James Phillips and I never discussed.  Later this child-abusing CAROLYN MARTIN (55 Easy Street Milford, CT) physically and verbally abused my own children and invented for me that I, “threatened to slit my own throat.”  Carolyn Martin and NANCY MARTIN (21 Redstone Way, Farmington, CT) were not arrested by the psychotic JESSICA GAUVIN because obviously Gauvin likes that kind of psychosis, being a participant in it herself.   

Coric stated for the perjury-record-of-the-court that I was treated with antipsychotics for 5 years.  Had that been the case, I would surely never have become a chemist due to the brain shrinkage associated with chronic antipsychotic use:


   1: Arch Gen Psychiatry. 2002 Nov;59(11):1002-10.

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Brain volume changes in first-episode schizophrenia: a 1-year follow-up study.

Cahn W, Hulshoff Pol HE, Lems EB, van Haren NE, Schnack HG, van der Linden JA, Schothorst PF, van Engeland H, Kahn RS.

Department of Psychiatry, University Medical Center Utrecht, Heidelberglaan 100, 3584 CX Utrecht, the Netherlands.

BACKGROUND: Imaging studies of patients with schizophrenia have demonstrated that brain abnormalities are largely confined to decreases in gray matter volume and enlargement of the lateral and third ventricles. Global gray matter volume has been reported to progressively decrease in childhood-onset and chronic schizophrenia. Global gray matter volumes have not been examined longitudinally in patients with first-episode schizophrenia. One would expect global gray matter to decrease progressively, particularly in first-episode patients, because clinical deterioration is greatest in the early stages of the disease. METHODS: Patients with first-episode schizophrenia who had taken antipsychotic medication for 0 to 16 weeks (n = 34) and matched healthy comparison subjects (n = 36) were included in the study. For all subjects, magnetic resonance imaging scans of the whole brain were obtained at inclusion and after 1 year (mean [SD], 12.7 [1.1] months). Outcome was measured 2 years after inclusion. To compare morphological changes over time between patients and healthy comparison subjects, multiple repeated-measures analyses of variance were conducted with intracranial volume as a covariate. Outcome and cumulative antipsychotic medication were related to changes in patients' brain volumes. RESULTS: Total brain volume (-1.2%) and gray matter volume of the cerebrum (-2.9%) significantly decreased and lateral ventricle volume significantly increased (7.7%) in patients. The decrease in global gray matter volume significantly correlated with outcome and, independently of that, with higher cumulative dosage of antipsychotic medication. CONCLUSIONS: The loss of global gray matter in schizophrenia is progressive, occurs at an early stage of the illness, and is related to the disease process and antipsychotic medication.
PMID: 12418933 [PubMed - indexed for MEDLINE]



The malpractice treatment of an organic delirium compounds this neurotoxicity. 


No one can anyone expect to acquire any kind of medical or mental health assistance in this state with this astronomical incompetence.  A nearly 8% brain total brain cell lose as a “treatment,” is not a treatment in the full medical sense of “treatment” being about recovery.

The following report shows that Yale University is aware of the valid parameters of mental assessment, but with their logic-disconnect where one cannot give a DSM diagnosis when one has made these other valid genetic and trauma rule outs:


1: J Am Acad Psychiatry Law. 2004;32(4):408-29.

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Ethics questions raised by the neuropsychiatric, neuropsychological, educational, developmental, and family characteristics of 18 juveniles awaiting execution in Texas.

Lewis DO, Yeager CA, Blake P, Bard B, Strenziok M.

Yale University Child Study Center, New Haven, CT, USA.

Eighteen males condemned to death in Texas for homicides committed prior to the defendants' 18th birthdays received systematic psychiatric, neurologic, neuropsychological, and educational assessments, and all available medical, psychological, educational, social, and family data were reviewed. Six subjects began life with potentially compromised central nervous system (CNS) function (e.g., prematurity, respiratory distress syndrome). All but one experienced serious head traumas in childhood and adolescence.      All subjects evaluated neurologically and neuropsychologically had signs of prefrontal cortical dysfunction.   Neuropsychological testing was more sensitive to executive dysfunction than neurologic examination. Fifteen (83%) had signs, symptoms, and histories consistent with bipolar spectrum, schizoaffective spectrum, or hypomanic disorders.   Two subjects were intellectually limited, and one suffered from parasomnias and dissociation.    All but one came from extremely violent and/or abusive families in which mental illness was prevalent in multiple generations. Implications regarding the ethics involved in matters of culpability and mitigation are considered.
PMID: 15704627 [PubMed - indexed for MEDLINE]


To repeat:

1) All but one experienced serious head traumas in childhood and adolescence.     

2) All subjects evaluated neurologically and neuropsychologically had signs of prefrontal cortical dysfunction

3) All but one came from extremely violent and/or abusive families


Almost all of them had genetic and traumatic brain compromise.  None had an actual current medical rule-out such as a spinal fluid analysis or any kind of brain imaging.  These actions would have completed the picture and would have been something these analysts could have presented to the court and said,


“Here’s how we don’t need to kill these children who have already been severely injured and are validly intellectually compromised.  We can’t account for intent under these valid axes of compromise.  To claim intent on the part of these alleged murdering children would be similar to us saying that ‘all persons who drive under the influence of alcohol do so to deliberately hit people with their cars. ‘ The perception and cognition of these children is validly off-base.  Based on our findings, we make the following recommendations for their treatment and recovery:  Validate their traumas, assess for organic illness, adapt a special education protocol because they are children and deserve an education rather than the sensory deprivation they get in prison, and especially, children are inherently incompetent.  We know this because we are physicians.  Youth is just that.  We don’t give children under the age of 16 drivers’ licenses and we don’t ask 5 year olds to authorize their own medical treatment…”



Most of the children in that study had a history of genetic and traumatic compromise, and in which, even according to the DSM-IV, one cannot make a diagnosis of a mental illness such as Bipolar when these and other valid parameters of a medical history are present.   Similarly, one cannot diagnose Bipolar in a person who has Lyme or Multiple Sclerosis.  It says so right in the DSM, and according to an NIH study of rapid-cycling bipolar in children:

Ruling out Lyme disease in Bipolar disorder in children and Adolescents:

Study ID Numbers  000198;  00-M-0198












What's New




Symptoms and Causes of Bipolar Disorder in Children and Adolescents

This study is currently recruiting patients.

Sponsored by

National Institute of Mental Health (NIMH)


The purpose of this study is to learn more about and describe the moods and behaviors of children with bipolar disorder. This study will also examine what happens in the brain to produce these moods and behaviors. This is not a treatment study; children will not receive any new or experimental therapies


Children and adolescents ages 6 through 17 with bipolar disorder and normal healthy volunteers (controls) of the same age group may participate in this study. Candidates will have a telephone interview and review of medical records to determine eligibility. Additional screening will include a medical and psychiatric history of the patient and extended family members, and a physical and neurological evaluation. The medical history interviews will be videotaped and kept confidential.


Study participants will have a 3-day baseline evaluation, including the following physiologic tests and procedures:


1. Questionnaires and interviews about the subject's mood and behavior, stressful family events, and so forth, and observation and documentation of the subject's behavior twice daily by clinical staff.


2. Computer and written tests to assess intelligence, memory, learning, motor skills, reaction time, and planning skills.


3. Tests to measure heart rate, sweating, brain wave activity and eyeblinking while watching film clips that elicit various emotions and while playing computer games. Recordings include electromyogram, electrooculogram, heart rate, skin conductance, and electroencephalogram.


4. Needlestick to collect 3 tablespoons of blood to measure blood count and thyroid levels, liver and kidney function, to test the immune system and check for certain diseases, such as Lyme disease.


5. Magnetic resonance imaging (MRI) of the brain….




This clinical trial excludes people who have Lyme disease because one cannot be given a diagnosis of a psychiatric disorder in the presence of a central nervous system disease.    Therefore, if it is for me to be making these claims and valid arguments demonstrating the incompetence, fraud, and perjury of all of the State of CT employees and Yale employees, one cannot expect a good outcome of State of Connecticut interference in the lives of the unassuming victims of this relentless crime and incompetence being performed in the name of the State of Connecticut.

The child in question, Ms. Figueroa, should have the option of being transferred out of State to a competent facility where they understand brain matters, psychotropics-induced brain damage, and understand that one has to validate a child’s traumas.

Ms. Figueroa was removed from her parents unwillingly as a child by DCF and learned how to fight to survive.  Having been there (in prison) and seen the things that go on in the prison, and being a pharmaceutical scientist, I can validly claim that no child has a chance in hell to survive the abuse of the DCF and that most of DCF’s victims end up in the prisons anyway.  Connecticut is hell.

Where is the population of DCF “success stories” claiming they were indeed rescued by the DCF and their lives improved?

It doesn’t exist.




There is not one thing that is the truth in the DCF “records” of myself, and my family.  It is as though these DCF people are from another universe.  I have never seen anything so bizarre as DCF’s “records.”  Lie after lie after lie after lie after lie.   My ex-husband, DONALD G. DICKSON, who is a certified “sociopath” and who had been physically violent to me (arrest, restraining order, Battered Women’s shelter), and the children, had been filing false allegations for years.  Donald Dickson told the DCF I intended to drive my children into a lake in June of 2002.  Nearly a year and a half later, DCF decided to kidnap my children because I continued to file complaints about the idiots of the DCF and scanned in their ridiculous lying nonsense into my website for the whole world to see, to expose the crimes they commit, for the benefit of public safety.  Such lying, retarded, lunatics should never be in charge of other people’s children.   Donald Dickson left my children with me for 3 weeks this summer because he knew I would never kill the children - because he made up that allegation himself.  No one in Connecticut has ever be criminally charged with filing false allegations, and neither the Middletown court, nor the State’s Attorney’s Office in Milford knew whose job it was to prosecute false allegations because, they told me, it had never been done before.

My sister, Nancy E. Martin, who is a marriage and family therapist and is on an e-list with me regarding “Microbes and Mental Health,” filed such bizarre and false allegations against me, and continuously, and again as perjury in my DCF “trial,” and at the depositions, that I am certain this woman, Nancy E. Martin (21 Redstone Way, Farmington, CT) is severely mentally ill.

Nancy Martin attended 2 Lyme conferences with me, one in New York City in 1998 and another in Farmington in 2001, yet in all her bizarre and false allegations she never mentioned I was sick with Lyme disease.  I had no idea, after reading and listening to this series of lies, that she actually had hated me that much, for that long. 

Nancy Martin told the DCF I had “Bipolar,” when she knew the first rule out for Bipolar was Lyme disease from the elist, MMI.  The proof of this was all entered in my DCF “trial,” but the incompetent “judge” (John C. Driscoll) never looked at any of the evidence.  Nancy Martin told the DCF I was having conversations about my grandparents as if they were alive in 1977.  They all had been dead for 12 years by 1977, so that conversation only took place in Nancy Martin’s bizarre imagination.  Nancy Martin told the DCF that I, “left my children on a street corner and was nowhere to be found for several days.”  The street corner was my mother’s house where I had permission to leave the children any time I needed to, when I was too sick from Lyme disease to care for them.  The DCF refused to help me TWICE, in 1996 and in 1998, with this babysitting care, yet they perjured themselves (DCF’s Lorraine Thomas) about that in my DCF “trial.” 

I had been corresponding with Nancy Martin that entire weekend I was “nowhere to be found for several days” over an article in the newspaper.  I had the Norwalk virus on top of Lyme disease in 2002, from around January 25 to the 30th. The Norwalk virus comes with an extreme headache.  That would be: an extreme headache added to the chronic encephalitic migraine headache of Lyme neuroborreliosis.  My kids were fighting.  The whole house was shaking.  The kids would not stop fighting.  The whole house was shaking.  I told the kids to pack a few overnight things, because I was taking them to Grandma, because they would not stop trying to kill each other while I tried to lie down with the headache.  The evidence and the facts that prove this is true were entered as evidence in my DCF “trial.”  The judge (John C. Driscoll) never looked at any of the evidence submitted.   My case would have been a case where, from the 88 million dollars that the DCF defrauded the federal government in TANF funds, the DCF could have paid a babysitter for me for a few hours.  Instead we had to have this catastrophe of incompetence, false arrest, a traumatizing kidnapping and my kids doing worse, and not seeing an infectious diseases specialist. 

I would like to know how much the DCF spent on abusing my family altogether as a reward for my helping to get a dangerous vaccine off the market, being a Lyme activist and helping to get legislation passed to protect the rights of patients’ and Lyme treating physicians’ access to care, and protection from harassment from Yale and insurance companies who have committed this fraud as regards the testing for Lyme and the bogus Lyme vaccine, in three states (New York, Rhode Island, & Connecticut) - because I had no choice, because no one would ever help me when I asked.

Nancy Martin was conspiring with an eleven year old relative to say awful things about my children, as if this woman, Nancy Martin, had no other focus in her life except to conspire to lie about me and my children, even with an eleven year old Special Ed kid.  This is not a guess, I saw an email from Nancy Martin to the child.

Nancy Martin falsely told the DCF that I was the cause of this eleven year old’s bad grades, when the child had always had bad grades, had always had Special Ed.  The school wanted to diagnose the child with Childhood Schizophrenia because of the obvious paranoia and thought disorder, which the guidance counselors had long been tracking.  The child was in the 6th grade, reading at the mid-3rd grade level and with no use of phonics and with only a limited sight vocabulary.  Nancy Martin never helped that child, but I did, in fact, help the child in a 504 meeting, and to obtain more Special Ed hours for her.  Therefore, I was actually helping this child, while Nancy Martin, the Marriage and Family Therapist, was not only not helping, but making matters worse for the child.  Nancy Martin was teaching this child to lie and be paranoid.  Nancy Martin was actually teaching this child more lying and paranoia skills to get by in life.   The lying and paranoia as survival skills, were taught to Nancy Martin by her mother Carolyn Martin (55 Easy Street, Milford, CT).  Carolyn Martin invented for me that I showed up at her house and “threatened to slit my own throat.”  No such thing happened.  Not even close.

The child needed special care, and Nancy Martin is a Marriage and Family Therapist, has had three husbands, and has no children.   One wonders 1) is this nonsense what goes on in the “minds” of all “social workers?” and “therapists?” and 2) how does one get a diploma and a degree in Marriage and Family Therapy when they themselves are clearly evil, thought-disordered, and psychotic?

Nancy Martin continued to perjure and delude herself, and said I, “nearly flew out the window,” after my father’s funeral.  No such thing happened.  I merely asked who wrote the eulogy because it stunk.  I needn’t have asked, since if the eulogy was impossibly stupid, only one person could have written it- someone who is a narcissist and has no idea that eulogies are supposed to be about the deceased:  Nancy Martin.

Nancy Martin further made false statements to the DCF and said I yelled at Carolyn Martin in the hospital while my father was dying (May 2002).  I yelled at Nancy Martin for never letting anyone else express an opinion, stating that my brother and other sister were not happy with this rude and obnoxious behavior of hers.  Nancy Martin at that point started to cry, so there is no mistaking that Nancy Martin deliberately lied to the DCF.   We have Carolyn Martin stating in the depositions that it was Nancy Martin who I confronted about her rude behavior towards myself and my other siblings.  Nancy Martin indeed has a thought disorder, she could never keep any of the information straight regarding my father’s health, and it was obvious.  Every morning I had to come in to the hospital and unscramble the status of my father for my mother, because Nancy had everything mixed up and confused.  One wonders how in the world could Nancy Martin be any kind of a counselor with such an obvious thought disorder?

The same is true with the DCF staff.  These are off-the-charts stupid people.  They do nothing but lie.  Lie after lie after lie after lie.  I would have to spend the rest of my life straightening out all these DCF “records.”  There is no truth or reality in any of it.

Since that is the case, the same must be true of all DCF’s “records.”  In fact, my children and I overheard another family of DCF victims say, “How’d THAT get in there, that’s ANOTHER lie!” in the New Haven DCF office.

All the DCF does is lie.  The State has to know this because otherwise they can’t try to manage all the children who the DCF are clearly incompetent to managing.

DCF’s “records” are utterly useless and far beyond reality.  One DCF moron worker wanted to know how serious Lyme disease was after I had already given her the scientific information, and AFTER, she had told me her dog and grandfather died of Lyme disease.  I suggested if she wanted to find out if Lyme was easily diagnosed and cured, then she could go to the cemetery and see of her grandfather had improved.

OUTRAGEOUS LIARS AND INCREDIBLY STUPID people are managing other people’s kidnapped children.  Rowland bragged about a 445% increase in children taken from their parents under his administration.  The bills for this abuse-as-federal-income were written by Kristine Ragaglia and Marc S. Ryan.  I have sued the State of Connecticut twice, and one suit is a class action (CA-5-328-Torres, in the District of Rhode Island).

I am a Lyme disease activist and a scientist, and the very people who I asked for help from, and who refused, were later the perjurers and filers of false allegations in my DCF “case:”  I asked DCF-twice (1996 and 1998),  I asked Governor John G. Rowland, the Stonington Schools, my “family” (Nancy Martin- who has no kids), and the Department of Social Services in Norwich, and the State of Connecticut in a public hearing on Lyme disease.   My kids have congenital Lyme.  One of them also tests positive for Ehrlichiosis.  None of my children are being treated for Lyme, and my sickest kid has not been going to school because she is afraid of being kidnapped by the DCF again from the school, as she was on Nov 26, 2003.  November 26, 2003 was 5 days after depositions, where we learned Nancy Martin should have been arrested for filing false allegations.  AAG Jessica Gauvin should have arrested her.   Nancy Martin further under-whelmed the lawyers with her intellect at the depositions by stating that I was an “irresponsible parent” because I “go to the library.”  I later learned that no one had ever been charged with filing false allegations to DCF, and that no one (either the Middletown court, or the State’s Attorney’s Office), knew whose job it was to criminally charge persons who file false allegations.

This would have been a case of clearly and deliberately filing false allegations.  Nancy Martin continued to lie and perjure to avoid being prosecuted for filing false allegations.  Nancy Martin is licensed by the State of CT and knows I have Lyme disease.   Nancy Martin knows what Lyme disease is, since she herself had Chronic Fatigue and Immune Dysfunction Syndrome (Lyme and CFIDS are identical), her illness is what got her interested in counseling people with chronic illnesses in the first place, and she advertises is her expertise in “therapy.”  I have never run across a better example of a “total nutcase”in my entire life and she is my sister.

Nancy Martin is fully aware that “Lyme disease” is scientific fraud and racketeering.  In January 2001, I explained to the FDA vaccine committee on LYMErix how Yale’s LYMErix was not a vaccine, according to FDA rules and LYMErix came off the market a year later.  It was never a vaccine.  It never was shown to prevent Lyme disease.  I filed a scientific fraud and racketeering complaint to the US Attorney in 2003, naming Yale as central to the fraud.  The cover pages of the RICO complaint are scanned into my website.  There are 5 boxes of data now in the US Attorney’s office regarding this FRAUD, Lyme disease and LYMErix.   All Yale staff were the ones who determined I am insane.

There is no excuse for this behavior of Nancy Martin’s because she was on a daily email list called MMI sine the Fall of 1999, and which is about the problems people with Lyme disease have.  This email list (MMI) is hosted and managed by Robert C. Bransfield, MD, who is a psychiatrist and whose website is, and which is listed at the top of James Phillips’ records on page 4, from the summer of 2000.  I invited Phillips to the MMI conference at the annual Psychiatric Services conference in the Fall of 2000 to hear Bransfield and others involved in discovering how brain infections such as Lyme borreliosis might be misdiagnosed as “mental illnesses.”  Phillips wasn’t interested in learning anything.   After two and a half years of not listening to me, and after denying me ProVigil for alertness initially in Sep 2000, Phillips in the interim gave me every kind of psychotropic that there is, gave me a movement disorder right away (akathisia) and then two years later said, “I think you need to be on medication, I just don’t know what kind,” in December 2002.  At that point I was fully aware that I was dealing with a complete idiot and our conversations had taken place in a reality vacuum- Phillips’ reality vacuum.

Phillips is a forensic psychiatrist for the State, perjurer and “the most incompetent psychiatrist who ever lived.”  His world is sex, and always was.  In the Fall of 2004 Phillips gave a presentation in Germany- still talking about Freud and “psychosexual development,” as if nothing else happens in the world.  Pity his poor wife.   Phillips is also an allegedly religious person and philosopher.  One can conclude that even at the highest levels of alleged intelligence, is perversion and logical disconnect.  How can one be a religious person, lifelong student of philosophy, and perjure himself to avoid a malpractice lawsuit?  Reality is science.  The science says Lyme is a permanent brain infection.  Science and reality leave the courtroom whenever a “psychiatric expert” enters it.  No one even knows how to challenge the validity of a psychiatric diagnosis in a courtroom.  There are no witnesses to these court ordered psychiatric evaluations, and no one can challenge whether or not the dialogue occurred as reported by the “analyst.”  Such was the case with Vladimir Coric and Patricia Leebens, as previously mentioned.  All three are psychiatric perjuring nutcases who make things up and call their made up nonsense a “record.”   Such situations never arise in analytical chemistry labs.   For someone so obsessed with sex, one would expect that person to demonstrate he actually has male gonads - act like a man - and admit he lied and “screwed up.”  Now we all know what to expect from Freudians; they can’t connect penis with testicles despite having to look at this connection every single day of their lives.  Truth is something they hide from because sex and one’s own imagination is so much more rewarding than actually helping someone with their valid, everyday-life, reality-complaints, such as the abuse of Lyme victims by Yale.




Patricia Leebens of Yale and DCF wrote the Order of Custody of my children and then “left the country” and could not be cross-examined.  I have never met Patricia Leebens, nor have I ever seen her.  She defrauded the court with her OTC.  Her OTC looks the opposite of my complaint to the Statewide Bar Counsel and Commission on Human Rights- a 3 inch thick databinder dated 11-160-03 and left in the office of Laura Lustig Nov 20, 2003.  Lustig is a DCF lying-moron trainer.  Leebens mentions this 11-16-2003 databinder in page one of her custody order of my children, but she defrauded the court over its contents.  Leebens and the DCF were hoping I would never have a trial.  When we went to enter this Nov 16, 2003 databinder in my DCF “trial,” AAG Jessica Gauvin dropped her objection, and said “I didn’t see that!!” after I threatened to subpoena RICHARD BLUMENTHAL or the US ATTORNEY KEVIN O’CONNOR to come and tell us what was the content of that databinder.

Gauvin most certainly did “see that.”  It was on page one of the Order of Custody, which was probably written by Gauvin and not Leebens.  Gauvin is a classic nutcase, perjurer, liar, and fraud, and ordered my false arrest to prevent going to jail herself on March 25, 2004.  I was not allowed a “criminal” trial, because I was threatened that if I did not plead guilty, I would be committed permanently and the State of CT would take my house and all of my assets to pay for Jessica Gauvin’s psychosis.  I did not have any legal representation.  The records of this bizarre excuse for justice are in this New Britain court house. 




The United States of America through the US Department of Social Services and the Agency for Children and Families have given tens of millions to the CT DCF to distribute to needy families, under TEMPORARY AID FOR NEEDY FAMILIES (TANF funds).  The CT DCF defrauded the United States to the tune of 88 million dollars of that TANF money in one year alone (2003).  This aid did not go to the families; it went into the pockets of the Organized Crime and Racketeering Influenced Enterprise known as the CT Department of Children and Families.   Meanwhile the CT Attorney General Richard Blumenthal has sued the federal government for asking for unfunded improvements in educations performance under our brilliant President Bush’s initiative, No Child Left Behind (NCLB).

I claim that DCF is a RICO entity because of the intimidation fraud and harm they cause, in order not to be liable for their own crimes- crimes I have already demonstrated and have proven to the DCF court.  That is, the proof is already in evidence in my DCF “case” – evidence that Judge John C. Driscoll never looked at.   The DCF is a RICO entity because all psychotropics are brain damaging, DCF knows they are, and the DCF falsely arrested me and threw me in jail, falsely claiming that, for all intents and purposes, I am a terrorist instead of a human rights activist.  Their behavior could be called The DCF-180-Degrees-from-Reality-Formula, since they are not even very imaginative liars.   They simply say what is the total opposite of the truth about their victims, under oath, under affidavit, and as their relentless perjury-record-of-the-“court.”  Their abusive and criminal treatment of me and my children and then the gag order not to “criticize the government” demonstrates intent to maintain this RICO enterprise, DCF, as it is.

This 180-Degrees-from-the-Truth-DCF-Formula is proven by the fact that on the FDA’s website at this very moment is a document in which I say to the FDA, “This vaccine should not be given to children, unless we know what is making adults so sick.”  Is this the behavior of a Unibomber terrorist?  According to the clearly criminally insane DCF, it is.

If the 88 million dollars went to the needy families, perhaps Connecticut would not have so many failing NCLB children.  Most people believe financial struggles for parents results in compromised child care and thus, education outcomes.  This week, a 54 year old intoxicated grandfather was arrested for the inadvertent death of his grandchild while under his care, while the mother worked.  What if some of that TANF money had gone to this working mother for a real babysitter instead of the drunken grandfather?


The TANF money was earmarked by the federal government for needy families.  All of Connecticut residents are aware of DCF’s abundant incompetence, but they are not aware of the fact that the DCF staff are criminals, defraud the courts, lie to the police, lie about the police, lie to everyone about their victims, tamper with witnesses routinely, chronically defraud the United States and the taxpayers from the other 49 states, their victims end up in the adult prisons - demented from the psychotropics, the children are treated violently in the children’s prisons, and 90% of them don’t belong in the clutches of the criminally insane DCF.  This is a racket.  DCF does nothing but kidnap and kid-drug, and have defrauded the federal government hundreds of millions of dollars in an effort to cause this much harm to children, to continue to do so, threw me in jail to shut me up, gave me a gag order not to criticize the government, and invented my insanity for me, because the DCF have no other skills except being criminally insane and expert- and chronic- liars. 

The CT DCF are simply about the processing of bodies.  ‘Small bodies and big bodies.  ‘For pay.  They throw parents in jail all the time with false criminal charges when they don’t have a legitimate reason to kidnap.  Then, once the parent has been jailed on false criminal charges, DCF takes the kids, because DCF has now invented that the parent is a criminal.  I have seen the DCF do this 6 times in the last year.  I know of 6 such specific cases where DCF filed false criminal charges against parents.

The very day I filed a motion for an Administrative Review (March 25, 2004), the raging lunatic AAG Jessica Gauvin ordered my false arrest in order to avoid going to jail herself, because I asked for Law Enforcement to be present for this Administrative Review.

This is trafficking in humans and organized crime.




The women and girls are abused by the psychopathic prison guards- after a significant portion of them have already been abused by the DCF.  Violence in the prison is survival because the guards will not protect them and in fact, promote these fights.

Abuse should not be treated with abuse.   The courts will not hear this from DCF, Yale, or DMHAS Psychiatry, because the full platform of Psychiatry is that the victim of abuse should get the diagnosis and the subsequent brain damaging psychotropics “treatment.’


Therefore, representing all cases of abuse and mistreatment by Psychiatry as a treatment for abuse, and as an incompetent and brain-damaging “medical” practice, I bring to the court this Amicus. I have an interest in the cessation of this abusive status quo.  I had the good luck of a genetic endowment that allowed me to survive this insanity conducted against the residents of the State of Connecticut, intact.  I have a “very superior” performance IQ (visual-spatial abilities), I am a scientist, and the visual cortex is the only area of my brain that remains uncompromised in brain SPECT scan imaging.  In other words, I have all along been telling the truth about everything.   Men hate it when women are smarter than they are; especially when women are smarter scientists.  I am stating these facts as a record for this court, because they is also a verifiable record in my DCF “case” and were entered at the beginning of the DCF “trial,” but the judge never looked at any of the evidence.   


I was not aware that judges do not have to look at the evidence submitted.  I have not seen that written anywhere. 


All persons in Connecticut should learn that CT judges do not have to look at evidence.

My children are not safe and they are not happy and this DCF abuse and interference had a significantly negative affect on their lives.  My children are the only children I know who get nothing under the Christmas tree by their “father.”  My son has still not gotten a single thing for Christmas 2005 from his father, Donald G. Dickson.  My daughter is afraid of going to school and she is sick with Lyme disease and Ehrlichiosis and none of my children are getting proper medical treatment under Donald G. Dickson’s “care.”  My children have congenital Lyme disease, and the State of CT and Yale University do not want it known to the public that this occurs, despite Yale having been a participant in the autopsy of a newborn who they, Yale, stated probably died as a result of the congenital Lyme brain damage.

Lyme is a borreliosis- a permanent brain infection.  Some persons have latent borreliosis and they are at risk for a dementia.  Yale committed scientific fraud as regards the testing for Lyme disease and as regards their Lyme vaccine.  The citizens of this state are not protected against this fraud because the US Attorney KEVIN O’CONNOR is an incompetent DCF-Rowlandgate appointee, whose wife worked in Rowland’s legal office during the DCF-Rowlandgate crimes.  Yale knows Lyme is a brain disease, but they would prefer to destroy people than help them with this illness, and most of all, help people to get an early diagnosis via the use of their patented valid test: 5,618,533, which is 94% accurate.  In addition to the false arrest and fraudulent removal of my children, the perjury to protect James Phillips from a malpractice lawsuit, Jessica Gauvin and the DCF are guilty of obstruction of justice as regards the RICO complaint against Yale University.  The psychiatric perjury committed against me must be prosecuted.

As Friend of the Court, I request that this child be transferred to a competent facility for a full evaluation:  cognitive-genetic, traumatic, and organic, and be placed in the care of competent people, wherever they may be found, and which clearly won’t be in Connecticut, and which will also clearly be far away from Yale University.



The above amicus and accompanying data given to Laura Lustig and JESSICA GAUVIN in the fall and winter of 2003-2004 has been given to the prosecution, the court, and the defense of Ms. Elsie Figueroa with the intent that it applies to any child who is a victim of DCF, DMHAS, Yale, or the Department of “Corrections.”  All such criminal cases and cases where the child suffered DCF-abuse, including psychotropics-abuse, as a “treatment” for an alleged abuse, are inherently at least doubly mitigated. 


There is no one in the State of CT qualified to be a forensic psychiatrist for the State, since so many of them have clearly perjured themselves in my “cases.”  Psychiatry is not a valid medical practice and all psychotropics are brain damaging.  I submit this evidence to:



1) State’s Attorney’s Office

New Britain, CT



2) To be Entered for the Record of the Court in the case



3) Defense Attorney for Elsie Figueroa



4) The Hartford Courant newspaper




                                                            This _____ Day of February, 2006






                                                            Kathleen M. Dickson

                                                            23 Garden Street

                                                            Pawcatuck, CT 06379







Cross Reference:  The Class Action Civil Rights Abuses lawsuit against the State of Connecticut, in the District of Rhode Island CA-05-328-Torres, Providence RI, and 3:05-CV-91 (CFDroney), District of Connecticut, Hartford, Dickson vs State of CT, et al.