MOTION TO DISMISS/REPLACE ATTORNEY DANIEL DILZER

MOTION TO SUBPOENA DCF TRANSCRIPTS

It must first be established that the Defendant is a Lyme disease activist, an analytical chemist (disabled, Pfizer, Inc), and the mother of three children who have Lyme disease.

The “Special Public Defender” Daniel Dilzer did not defend the Defendant Kathleen M. Dickson adequately on the following grounds: Mr. Dilzer on two occasions did not want any evidence given to him which demonstrated that this was a false arrest. Mr. Dilzer stated that the criminal case had nothing to do with the DCF when it had everything to do with the DCF case because Jessica Gauvin falsely criminally charged the Defendant with her own insanity, invented for the Defendant during her DCF “trial.”

CHARGES

Assistant Attorney General Jessica Gauvin made a 100% fraudulent complaint to the Berlin Police, orchestrated DCF “trial” perjury, had Defendant committed with more false testimony, and Defendant now has a gag order not to criticize the government. This is a pattern, since Gauvin tried 16-17 times altogether (previous to the false statements to the Berlin Police) to have the Defendant either arrested or committed, in order to prevent the Defendant from seeking the criminal and/civil prosecution of Gauvin and her witnesses. In short, Gauvin wanted the Defendant refrain from exposing the criminally insane and incompetent behavior of the DCF staff. CT Statute 17a-28 states that the “person”, in this case, the Defendant, may give any information about her DCF case that she wants to the persons of her choice.

Defendant exposed the DCF’s incompetent and criminal behavior as far and wide as possible, in order to protect the public from DCF relentless lying and incompetence, but she never contacted Gauvin privately. Defendant is morally obligated and within her rights to spare the public the DCF’s criminal behavior by alerting the public to the DCF’s “tactics.”

MEDICAL BACKGROUND

Defendant has Chronic Lyme disease and High Functioning Autism. Lyme disease is a brain disease. Autism is a condition of very superior visual spatial abilities with a relative deficit in verbal and auditory processing. In the Defendant’s case, there is a 2 –4 standard deviation difference, which is considerable. Defendant is a visual thinker and scientist. “Judge” John C. Driscoll ordered that the Defendant’s two psychological evaluations that show these relative discrepancies and her brain SPECT scans be entered to this criminal case as evidence. Dilzer refused. This was not done. Defendant’s father and nephew have autism and Defendant’s sister and niece have Neurofibromatosis. These two “nerve overgrowth syndromes” co-confer at 150 times the rate of independent genetic events (they are known to frequently co-occur). The short version is that the Defendant is more mechanically inclined than most women are, and autistic people never lie. Chronic Lyme disease is a severe disability: encephalopathy (delirium/dementia), severe fatigue, neuritis, neuralgia, vision loss, and is multiple sclerosis, typically. Defendant remembers well the “Ted Kaszynski” and the “dangerous intelligence,” and “command hallucinations to kill” Jessica Gauvin Show, however, since these were quite bizarre and memorable courtroom stunts. Even Donald Dickson said, “That was WEIRD.”

PSYCHOLOGICAL EVALUATIONS

The State requested another psychiatric evaluation of the Defendant. That evaluation was performed by Dr. Debra Solomon, who is aware of the frustration and abuse and neglect of the Lyme disease victims. It is not certain that this evaluation was entered by State’s Attorney Brett Salafia, so the Defendant will enter that, too. All that the Defendant asked for was a baby sitter every now and then for when she was more sic, from Lyme, than usual. (Corrupticut’s motto should be ”Ask for help? Go to jail.”) The DCF refused this request in 1996 and in 1998 and then perjured themselves about that to the court (DCF’s Lorraine Thomas). The Dr. Solomon evaluation states that “In a thorough review of Kathleen Dickson’s Lyme-related research and writings, I cannot find any holes in her logic. I do hope that she will be able to continue in her pursuit of truth without having to pay with her children’s lives or her own.” Defendant asserts that she should not be having to do Lyme activism in Connecticut. Connecticut should demonstrate leadership on this issue. The problem is Yale and their various frauds. LymeRIX did none of the things Yale claimed, and Yale is the source of the research that LYMErix did nothing that Yale later claimed. It did not prevent Lyme, did not prevent asymptomatic infection, and did not disinfect ticks.

It’s simple: “Lyme disease,” the blood test definition, is scientific fraud, as is the statement that “Lyme is easily treated and cured.” Lyme is a permanent brain infection. Those who are asymptomatic are described as probably experiencing “normal brain flora” (Andrew Pachner, formerly of Yale.) “Lyme disease,” the blood test definition is scientific fraud, in that the test was developed around falsely qualifying the vaccines. “Lyme disease” is a relapsing fever borreliosis and is a permanent brain infection. Because of this “controversy,” which is fraud in the same way tobacco companies said it was a “conflict of opinion” whether or not nicotine was addictive is FRAUD, if a person does not have the fraudulent blood test definition of Lyme, they can’t get treatment. In the vaccine trials, if a person did not have the fraudulent definition of Lyme disease, vaccine failure in those cases were called “unconfirmed Lyme,” and were tossed out of the safety and efficacy calculations. This the Defendant explained to the FDA at the LYMErix (patent belonging to Yale) vaccine committee meeting in Bethesda, MD in 2001. The Defendant filed a scientific fraud and racketeering complaint with the US Attorney’s office.

These two previous psychological evaluations (Coleman and Domitrovic), which Judge Driscoll said should be entered in this “criminal” case have more validity than any of the State’s fraudulent evaluations of the Defendant which were meant to enforce the notion that the Defendant was insane to be filing complaints, and insane to be saying “Lyme disease” is scientific fraud and racketeering, were not, notably, performed by anyone who works for Yale University. All of the Psychiatric expert perjurers in Defendants’ DCF and criminal cases were from Yale: Kenneth Marcus (DMHAS) is a Yale Psychiatry graduate, Vladimir Coric is associated with Yale’s Forensic Psychiatry, DCF’s Patricia Leebens claims to “work” at the Yale Child Study Center, and James Phillips is an associate clinical professor of psychiatry at Yale. Yale performed the autopsy on the congenitally infected (with Lyme) newborn and reported that the cause of death was probably due to the congenital brain damage. What Yale left out of their declarations of the Defendant’s “insanity” and “dangerous intelligence” was the mention of the several scientific journal articles which show that all psychotropics are brain damaging. For Yale Psychiatry to not know a thing about Lyme as a neuropsychiatric illness is incompetence and for Gauvin/Leebens to mention the 11-16-03 databinders and not the 11-20-03 databinders while both were left with Laura Lustig is extremely important to note. The only services DCF provides is kidnapping, jail, and forced psychotropic drugging. It is not hard to see in retrospect that this enterprise went too far and Rowland himself is now in jail for these excesses in a lack of leadership and care for the constituency. Executive Order Number Two signed by John Rowland (1995) associates welfare and drugs and is therefore Racial Profiling as policy. If The Bell Curve’s “g factor” is a valid marker of the mental incompetence of black people, why is there a discrepancy between people at CVH and the color of the jails’ populations?

Connecticut’s human and civil rights record is an abomination, and does not reflect intellectual sophistication. Defendant is not arguing drugs are a problem, nor that young black children are often participants in the gangs which perform serious drug-related crimes. Defendant is arguing that not enough investment is made in this community, historically, and “treats” the chronic abuse of black women by all - including by black men - with more abuse. This is a difficult population to reach but the logic there should be zero tolerance of abuse of women of color and that that should be Morano’s campaign. Morano never responds to complaints from the Defendant and needs to be replaced. Defendant is a human rights activist and has been, officially, since the summer of 1999, as ActionLyme was founded upon the UN Declaration and records prove this.

Any evaluations of the Defendant after the false, bizarre, and unsubstantiated DCF allegations filed by the Defendant’s “sister” Nancy E. Martin, 21 Redstone Way, Farmington, CT, and Defendant’s ex-husband, Donald G. Dickson will simply yield the obvious: Defendant is furious. Nancy Martin, Donald Dickson, Jessica Gauvin, and Carolyn Martin need psychiatric evaluations, obviously. It is psychosis to invent out of thin air what someone said or did. Psychosis is defined by not living in a reality shared by a majority in a society.

DONALD DICKSON

AAG Jessica Gauvin, who prosecuted Defendant, threw out the DCF’s first petition because it was all false allegations and nonsense, and the second petition attempted to assert that the Defendant was insane to be filing complaints - yet the first petition was thrown out because these were false and unsubstantiated allegations, making it logical to be filing complaints. Donald Dickson has a very long history of physical violence towards the defendant and her children and DCF has these records and testimony of violence and some of the incidents of his exposure of his genitals to the children is documented in DCF’s their records. There was a restraining order against him (1996), he was arrested for domestic violence (1993), and the Defendant had to stay at the Battered Women’s Shelter (1994), although there were numerous occasions that the Defendant left the domicile of Donald Dickson (with her children, of course), due to his abuse and stayed with relatives. Defendant’s supervisor at Pfizer referred Defendant to Pfizer Employee Assistance Program, due to the missed work as a result of chronically looking for places to live with the children. That Pfizer EAP associate coincidentally is now the supervisor of Nancy Martin in Stafford Springs, JoEllen Sayjek who showed up at Defendant’s father’s wake. (Defendant used to have a photographic memory before Lyme disease.) Relatives were 45 to 60 miles away from Pfizer. Defendant finally left the psychiatrist-diagnosed “sociopath” (diagnosed in 1995 by J. David Ruffner, MD), Donald G. Dickson, in 1995 after her third child was born, because she could not longer tolerate Donald Dickson’s abuse, which increased with each child. The children were 3 years-, 25 months- and nearly 4 months- old when the Defendant moved out, closer to Pfizer, permanently.

Defendant submits the DCF’s Respondent’s (the Defendant Kathleen Dickson’s) DCF trial summary, and the Attorney for the Children’s trial summary (Scott Sawyer, of Eminent Domain fame) as evidence that there was no abuse or neglect of Defendant’s children by the Defendant. These attorneys found the testimony of DCF/Yale psychiatrists Patricia Leebens (who never met the Defendant or her children), and DMHAS/Yale’s Kenneth Marcus (who also never met the Defendant or her children) to be unacceptable.

Both attorneys, Bartinik and Sawyer, argued that the Defendant’s children should be returned to the Defendant, as there was no history or evidence of abuse or neglect of the children by the Defendant.

Defendant’s son was born prematurely, and almost died because Donald Dickson refused to drive the Defendant to the hospital during a period of extreme illness late in the pregnancy. After much insisting and putting up with Donald Dickson’s temper tantrums, within one hour of arriving at the hospital December 9, 1994, David Dickson was born by emergency C section, since he was in fetal distress. Therefore Donald Dickson’s chronic abuse nearly killed Defendant and her son. David (DOB 12-10-94) was enrolled in the Lyme Disease Foundation’s in Pregnancy Study, because Defendant had congenitally infected her first two children with Lyme disease. Two days after David was born, the Defendant had to “bum a ride home,” from the hospital, clothes for the Defendant and her infant, and a car seat, because Donald Dickson refused to bring Defendant and her son home from the hospital. Three and a half months later, Defendant left Donald Dickson. Gauvin placed the children with this maniac, Donald Dickson who filed false allegations against the Defendant and told the DCF that the Defendant intended to kill the children and other bizarre false allegations. Donald Dickson’s brother did the same thing to his former wife (claim false child abuse and neglect allegations- the formula is to declare the wife crazy, by inventing what she did), in order to not pay child support. The brother’s two older children will have nothing to do with their father, now, for ruining their family, and sending their mother away. Donald Dickson wrote to the Defendant in 1996, “IF YOU WANT ME TO BE WITY MY CHILDREN, PLEASE DROP A LETTER WITH YOUR PROPOSITION (IN AMPLE TIME) AND I WILL ACCOMMODATE IF POSSIBLE.” Donald Dickson never wanted to have anything to do with the care of his children except as a reason for harassing the Defendant since this is the nature of a sociopath.

THE MOTION FOR ADMINISTRATIVE REVIEW, MARCH 25, 2004

After DCF’s Jessica Gauvin invented for Defendant Dickson, that she is a “dangerously intelligent” chemist, “like Ted Kaszynski,” the Unibomber, who has “command hallucinations to kill” with her perjuring witnesses (Marcus and Phillips), in the DCF “trial.” AAG Jessica Gauvin then criminally charged the Defendant with Gauvin’s same, own, nonsense and the perjury Gauvin orchestrated, as “harassing communications and threatening.” These were not threatening and harassing, but were Defendant’s complaints - within her rights - of Gauvin’s psychotic behavior, to State legislators, Christopher Morano, the Chief State’s Attorney, to the Statewide Bar Counsel, the US Attorney Kevin O’Connor, to CIGNA, AG Richard Blumenthal, and to other State and Federal agencies, which Dickson is allowed to do under state and federal law.

Note that the gag order states that the Defendant “may not post or fax anything critical of govt w/out prior approval of OAP.” That is more correctly translated as Defendant “may not report the criminal behavior of Jessica Gauvin to the proper law enforcement authorities because Gauvin could get 30 years for perjury, orchestrating perjury, color of law abuses, defrauding the courts, risk of injury to 3 minors, and the false arrest of the Defendant, which Ms. Gauvin might not find enjoyable.”

After Judge Kevin P. McMahon ordered Dickson to be treated for Lyme as a condition of her release for the false arrest, and stated that “Lyme is known to cause all sorts of psychiatric disorders” (but in this case, it is Jessica Gauvin who is insane and dangerous), the State prosecution switched courts and public defenders and assigned Dilzer.

Dilzer did not refute the perjury of Elizabeth Byron of the Department of Mental Health and Addiction Services, who said for the court, that DMHAS was “not aware of the Defendant Dickson’s diagnosis of Lyme Disease” and that “Lyme is not a brain disease.” Defendant’s infectious diseases specialist, Sam Donta, spoke with Joseph More at CVH and Defendant offers this evidence. Dilzer did not refute the perjury of Yale’s Vladimir Coric. Defendant was committed for saying she was innocent, and that the children’s Ad Litem had said to the Defendant that, “The State is watching this case very closely,” after the depositions where we found out Nancy Martin should have been arrested for filing false allegations.

Coric invented, himself, the Defendant’s psychiatric and psychotropics use history and does not know what “pervasive development disorder” means. Autism is a pervasive development disorder, e.g., Defendant had numerous surgeries and mild congenital deformities including left thumb, which was straightened out surgically in 1972 and pelvic deformities such that the Defendant had to deliver her children surgically. Coric seemed utterly clueless as to what “pervasive development disorder” might look like, yet Yale has an autism clinic, at which Leebens claims to work (The Yale Child Study Center). Anyone can pick up a dictionary and look up the terms “pervasive” and “development” and “disorder” and then put them all together. One does not have to have an MD to understand PDD, and apparently even when they do have an MD from Yale they are incompetent to the obvious use of references.

The DCF depositions took place November 21, 2003. Five days later, DCF/Yale’s Patricia Leebens defrauded the court over the content and nature of the 3-inch November 16, 2003 databinders left in the office of Laura Lustig (New Learning Center, Westport). These 3 inch data binders were substantiated complaints to both the Statewide Bar Counsel and the Commission on Human Rights regarding DCF attorney Sarah Gibson. Leebens referred to these databinders in the first page of her Temporary Order of Custody, yet the actual content of them was nothing like what Leebens described to the court in her TOC, which is a fraud on the court. This is the reason Leebens “left the country” and could not be cross-examined after she ordered the removal of the Defendant’s children. Gauvin proceeded to orchestrate all sorts of perjury, which Bartinik for some reason did not have the Defendant refute, nor did he bring the witnesses that he should have. For example, one day the principal of the children’s grammar school, Terry Jordan, slammed the door to her office and would not let the Defendant leave until Jordam was finished yelling at the Defendant. Gauvin knew this. Gauvin had the secretary outside the principal’s office say in court that the Defendant was the cause of the fuss and that it frightened the children outside -which was totally false. There were many other such examples of Gauvin twisting all the events to make the Defendant look like the crazy person. Such is not the case. The Defendant has “autism” and “lack’s spontaneity” according to James Phillips, MD. Therefore all of Gauvin’s attempts to perjure and paint a different picture of the Defendant were 180 degrees from the truth. (This is the DCF’s “formula.”)

Carolyn A. Martin, 55 Easy Street, Milford, CT, (Defendant’s “mother”) and Donald G. Dickson (Defendant’s ex-husband) were abusing Defendant’s children. Carolyn Martin invented that the Defendant “threatened to slit her own throat.” Carolyn Martin’s daughter Nancy E. Martin made numerous false statements to the DCF in writing regarding the Defendant including that the Defendant was “physically violent to Carolyn Martin,” yet was not arrested at the depositions by Gauvin. They both said the Defendant was never physically violent to anyone ion her life, under oath, at the depositions, for which Gauvin was present and a participant. Therefore the two most serious charges against the Defendant by Nancy Martin were false.

Since December 2004, upon release after 8 months incarceration for crimes not committed, the Defendant has tried any and all means to have Gauvin arrested and prosecuted for walking into the Berlin Police Department office and recording numerous false statements and signing an affidavit to such, on March 25, 2004, clearly without providing the proof of her false allegations. Earlier in the day, on March 25, 2004, the Defendant Kathleen Dickson had faxed a motion to the DCF court for an Administrative Review, in which it would have been demonstrated that Gauvin orchestrated perjury and defrauded the DCF court in numerous motions and statements sworn in affidavits. Plaintiff Dickson specifically requested in this motion that law enforcement officers and someone from the Chief State’s Attorney’s Office be present, in order to arrest and place Gauvin in jail for her criminal behavior. Upon this, knowing she was guilty and not wanting the judge to hear the evidence of what did, Gauvin ordered the Plaintiff’s false arrest the very same day, apparently on her way home from work. This was a false arrest, orchestrated perjury, numerous attempts to have the Defendant committed or arrested, and now a gag order not to continue to report the crimes of Jessica Gauvin, Yale Psychiatry, the DCF, and others, to law enforcement. Defendant has Lyme disease, her children have Lyme disease, and for several years starting in 1996, Defendant attempted to obtain assistance from the State of CT- all State agencies - including the DCF in 1996 and 1998, and was denied. Therefore she had to become and activist.

When we got Yale’s “bogus” LYMErix vaccine off the market and Karen Forschner of the Lyme Disease Foundation (www.lyme.org) and I were ecstatic at the success of our hard work, Defendant’s sister and mother could not longer contain their chronic jealousy issues, because the Defendant’s father said, “Keep doing what you’re doing.” The main issue with the two of them, Nancy and Carolyn Martin, is that the Defendant’s father was a design engineer (autism) and the Defendant is a scientist, and no one else in the family was any kind of an academic performer, with the exception of Defendant’s autistic nephew whose IQ is so high, his school says, they can’t assess it.

DCF’s COMPETENCY

Gauvin tried to prevent a lawsuit against the DCF. Gauvin does not care how much perjury she conducts and clearly believes she is above the law. Perhaps DCF is above the law, except in cases where DCF then falsely criminally charges a parent with the same perjury they orchestrate in DCF “trials” as is the case in this case. DCF’s New Haven former principal attorney Sarah Gibson (who was fired) lied to the Bar Counsel and the Commission on Human Rights. Norwich DCF lied to the Norwich Police. A DCF supervisor recently lied about the Hartford Police. The DCF have gone too far, and are putting children at risk for the purpose of showing Connecticut residents who exactly owns their children, and that no one should ever dare question their authority.

One social worker (Lisa McArthur) was asking her fellow social workers how serious Lyme disease was so they could take the Defendant’s children on the basis of medical neglect (of all things), after this same social worker had earlier told the Defendant that her dog and grandfather died of Lyme disease, and after the Defendant gave this very social worker a great deal of evidence regarding how very serious Lyme disease is. The Defendant later suggested that if this worker wanted to know how serious Lyme disease was, she could go visit the cemetery and see if her grandfather was better now? Such off-the-charts stupid people have no innate authority over other people’s rights to their own children. The United Nations Human Rights Commission Rights of the Child Declaration states that such kidnappers should be “competent.” They therefore should at the very least be able to read. There is no evidence that the DCF is competent to health and brain matters and this is not helped, but hindered, by Yale Department of Psychiatry’s clear incompetence to brain matters. Lyme is a brain disease. Autism is a pervasive development disorder. All psychotropics are brain damaging. This is likely the “dangerous intelligence” of which Marcus accuses the Defendant. Defendant was an analytical chemist for a pharmaceutical company and had researched the relationship between psychotropics induced agitation, which the Defendant suffered as a result of James Phillips malpractice. These journal articles are in the November 20, 2003 databinders, left with Laura Lustig, but were not mentioned in Leebens’ TOC. These references clearly made the DCF furious, since they are now liable for the brain damage and the suicides of the children they force-drug.

The phenomenon and expression of this psychotropics-induced brain damage is known as “akathisia” or psychomotor agitation. Defendant shared these references with Attorney Andy Vickery (defending Christopher Pittman- the “Zoloft” murders), and Attorney George Parnum (Andrea Yates’s attorney), both of whose clients will get new trials. Since the DCF’s false arrest and during the Defendant’s incarceration, FDA has put black box warnings on antidepressants. This clearly puts Patricia Leebens’ job at risk, since she is the chief drug-pusher of the DCF. In the UK there is a ban on antidepressant use in children. All the DCF does is 1) kidnap and 2) drug. That is the limit of their “services.” DCF offered but then denied the Defendant their Respite Care (babysitting), and then perjured themselves about that in the DCF “trial” (DCF’s Lorrain Thomas). Therefore for Daniel Dilzer to say the false arrest had nothing to do with the DCF trial is 100% incorrect.

CAROLYN MARTIN

It is Donald Dickson and Carolyn Martin who are abusive to the Defendant’s children. Carolyn Martin was abusive to the Defendant. Defendant went to a psychiatrist for the flashbacks of this abuse. James Phillips stated for the record of the DCF court, that Defendant was his patient for “CHILD ABUSE.” Carolyn Martin invented that the Defendant “showed up at her house and threatened to slit her own throat,” and then spread this extremely disgusting and bizarre rumor through the entire extended family. Carolyn Martin is insane and abusive. Therefore it is no stretch of the imagination to assume that Defendant is not exaggerating when she says Carolyn Martin was also abusive to the Defendant’s children. Carolyn Martin throttled Defendant’s child Diane Dickson (violent shaking and screaming in her face), and said Diane was “stupid and clumsy like your mother!” Defendant was an endurance athlete and competed on 3 varsity sports teams in high school: basketball, volleyball, and softball. Diane has Lyme disease and has 504 special education due to her medical disability, Lyme disease. Therefore not only is Carolyn Martin physically violent to her children and grandchildren, she is relentlessly verbally abusive and says extremely bizarre things.

EVIDENCE THAT CRIMINAL CHARGES WERE FALSE

Plaintiff/Defendant now submits the evidence that was supposed to be admitted at the beginning of the criminal cases CT CR04-021010 and CT CR04-276816, and the other evidence which supports the claim that this was a false arrest, that DMHAS committed perjury, and that Dilzer did not defend the Plaintiff/Defendant:

1) These are the psychological evaluations; evidence that Plaintiff has Lyme disease and

2) That it affects her brain: 3 Brain SPECT scans;

3) That the Plaintiff and her children have Lyme disease,

4) That Elizabeth Byron perjured herself and said DMHAS was not aware that the Plaintiff had Lyme disease and that Lyme was not a brain disease

5) Yale’s autopsy on the congenitally infected with Lyme newborn –died of brain damage- report;

6) That Byron further perjured herself and stated that the Plaintiff refused to meet with a Neurologist- Plaintiff met with Christopher Gottschalk, MD Cross County Neurology who gave Plaintiff this document;

7) The Plaintiff is a former analytical chemist from Pfizer and testified the FDA in January about how LymeRIX was not qualified with a valid standard and had not been proven to be a vaccine.

8) That LymeRIX was Yale’s non-vaccine, US Patent No 5, 747, 294

9) That Plaintiff later filed a scientific fraud and racketeering complaint with the US Attorney Kevin O’Connor in the summer of 2003 in New Haven, upon referral from AG Richard Blumenthal’s staff lawyers in Hartford;

10) That Plaintiff’s former Yale Psychiatrist for child abuse of the Defendant by Carolyn Martin, was James Phillips,

11) That James Phillips prescribed all types of medication, which made the Plaintiff/Defendant worse, committing malpractice and perjury as regards the treatment of this Lyme delirium, and injured the Plaintiff with the extra brain damage caused by these drugs. The clonazepam was for the movement disorder and agitation caused by the wrong drugs and malpractice. One is not supposed to treat an organic delirium with central nervous system depressing drugs, because that exacerbates the delirium according to the American Psychiatric Associations own guidelines. Lyme is to be treated medically, since it is a permanent brain infection; The guidelines clearly state: “Medications for psychiatric disorders can be both the cause of delirium and exacerbate or contribute to delirium from other causes.” Lyme is an organic delirium. The Defendant’s brain SPECT scans show reduced perfusion or blood flow to the brain, and that the Defendant recovered with ceftriaxone and then relapsed. DMHAS’s Medical Director Kenneth Marcus perjured himself and said that one treats Lyme delirium the same as any “psychosis” which is clearly perjury, and dangerous for all persons who have Lyme disease;

12) That the Plaintiff has a gag order as terms of release for Gauvin’s psychosis and crimes;

13) That the DCF unsubstantiated the false throat-slitting allegations;

14) That Jessica Gauvin was present at the depositions in which she learned that the Plaintiff/Defendant was never physically violent to anyone in her life;

15) That the trial summaries of the DCF/Respondent/Defendant Kathleen Dickson entered by both the children’s attorney and the Defendant’s attorney state that the Defendant was never physically violent to the children.

16) These trial summaries also state that James Phillips said that the Respondent/Defendant would probably never harm her children.

17) Gauvin clearly was present when Carolyn Martin, Nancy Martin and James Phillips all stated on record at the depositions and/or the trial, that the Defendant Kathleen Dickson was never physically violent to anyone in her life.

18) Gauvin filed a false police report, and made it appear that she was frightened of the Defendant and that the Defendant was violent and psychotic when she knew otherwise;

19) The subsequent and perjurous diagnosis of psychosis diagnosis of James Phillips was a means to prevent a malpractice lawsuit, as was the perjury of Kenneth Marcus, Patricia Leebens, and Vladimir Coric, since all work for Yale University, and do not want to be liable for not performing medical rule-outs for all persons in CT since Lyme is a brain disease and this is beyond dispute. All of the perjury and false criminal charges have a single underlying meaning, and that is to defend the non-medical practice of Psychiatry and malpractice of James Phillips;

20) Defendant enters the November 20 2003 databinders which show that all psychotropics are brain damaging. These are scientific journal articles that the Defendant obtained from the Yale Medical Library. These databinders were left in the office of Laura Lustig on November 20, 2003 along with the November 16, databinders, but these were not mentioned in Leebens’s TOC. The State is in possession of these records.

21) The 3- inch thick November 16, 2003 databinders contain evidence of Defendant’s attempts to get care for her children and that the very people who filed false allegations and perjured themselves were the same people who denied assisting the Defendant including the DCF; Compare to the first page of the TOC. The records are also records of activism. Defendant suggests that Gauvin wrote the TOC and had Leebens sign it. The TOC inferred that the Defendant is insane and dangerous to be saying “Rowland should be impeached” in the Fall of 2003, “for using the DCF as a federal money farm for the Tomassos,” which is true and is reflected in Kristine Ragaglia’s bills. A DMHAS worker stated that “DCF brought him down,” and most State employees seem to agree. Defendant sent Assistant US Attorney Nora Dannehy copies of these Ragaglia Rowlandgate enabling bills;

22) Lustig has a contract to train the DCF “workers” and Lustig’s second in command at that time was a former DCF commissioner, Mark Marcus. All that DCF does in terms of “services” is defraud the courts, remove and traumatize children and then order the brain damaging psychotropics. Most of their victims end up in the prisons, the Defendant discovered. This DCF abuse and excessive removals instead of helping people when they ask, is too much trauma; The children are chronically abused and neglected in DCF incarceration, and the records of this are on the Defendant’s website- they are public records.

23) That the Plaintiff never sent Gauvin SOLELY any communications, that in fact these were open communications and to the proper authorities and were not disguised, and not threatening, but merely statements of law (Death Penalty is a condition of Color of Law abuses- USC. Title 18 Secs 241, 242, and 245 - which Gauvin would be liable for, if anything happens to Plaintiff’s children), that Gauvin said UCONN’s Paul Chill was “brilliant, but on the other side”;

24) That Gauvin herself mentioned her son “Nicholas!!” in the courtroom, where she was discussing walking in on her own son in the bathroom and then yelling “NICHOLAS!” in her own words to Attorney Scott Sawyer. Gauvin made it appear to the Berlin Police as if the Defendant Dickson was stalking Gauvin; Gauvin talked about her son-in-the-bathroom incident in open court while the Defendant was sitting in the witness chair, waiting for the judge to return. Defendant thought this conversation was crazy.

25) The alleged “harassing communications and threatening,” dated April, 14, 2004, which were exactly the opposite of what Gauvin said they were, and were in fact evidence that Gauvin placed Plaintiff/Defendant Dickson’s children with a known child-abuser and wife beater, Donald Dickson. They also contain the letters written by Plaintiff’s children, about how much they hate the DCF and do not like Donald Dickson for the reasons they explained. Plaintiff was corresponding with CIGNA and told them where to find CRAZY people to drop the long term disability insurance for: DCF. This evidence shows the Defendant was not a fugitive from justice as Gauvin falsely claimed.

26) That the Defendant grieved DCF Attorney’s Sarah Gibson and Jessica Gauvin to the Bar Counsel,

27) That DCF knew Plaintiff was not a “fugitive from Justice” as the State claimed, but rather was seeking political asylum in Canada, and later tried to contact the FBI labs in Quantico so that a chemist in the FBI could look at the scientific fraud committed by Yale, since the US Attorney’s Office appeared to not understand it (and Defendant was not “demanding to be trained with the cadets” as the retarded DCF asserts); Gauvin asserted in her petition 2, that the Defendant was insane to be saying Yale and their bogus LYMErix vaccine was RICO and scientific fraud. There absolutely is an organized effort to spin Lyme. The former chief State’s Attorney Jack Bailey died of Lou Gehrig’s disease. There is a 47% chance this was caused by Lyme disease. Since ALS and the congenital Lyme brain damage death results are not common knowledge, Lyme is clearly being spun LYMErix was removed from the market because of all the unreported adverse events which showed up after the FDA approved LYMErix because Yale did not report the adverse events during the vaccine trial.

Yale has an early, accurate and specific test for Lyme disease, but they did not use it to qualify LYMErix, because they knew LYMErix was not a vaccine. Defendant is an analytical methods development chemist. Defendant is not a Unibomber chemist nor a synthetic chemist as Yale’s Vladimir Coric said in his report. Synthetic chemistry is more along the lines of bomb-making. Analytical chemistry is more along the lines of detecting scientific fraud in analytical methods used to qualify vaccines.

28) Plaintiff did not know there was an arrest warrant out for her even as of March 31, 2004, in an email about having been informed Plaintiff would be committed April 2, 2004, by her former Attorney Peter J. Bartinik Jr.,

29) That the Plaintiff submitted a Motion on March 25, 2004 for an Administrative Review in the DCF court in Middletown,

30) That the Plaintiff/Defendant Dickson asked for the case to be returned to court in August 2005, so that she could have a trial, having failed to get adequate protection from law enforcement. The request from the OAP states, “PER YOUR REQUEST, YOUR ACCELERATE REHAB … IS BEING RETURNED TO COURT OCTOBER 4, 2005…”

31) The Defendant submits into evidence these false criminal charges. They are an attempt to make the Defendant look like 100% the opposite of the person she is. This is DCF’s formula. (Unimaginative lies.)

32) Letter to the Editor by Lewis Bull regarding Vijay Sikand’s unwillingness to report his adverse LymeRIX events (1999) to the FDA, and Mr. Bull’s advising that no one should get this vaccine.

33) The Debra Solomon, MD psychiatric expert evaluation, which isn’t interest-conflicted as are all of Yale’s evals.

34) Some of the reports and not emails in the DCF’s petition 2. Marcus only spoke of emails. Bartinik and Sawyer spoke of emails. Most were not emails, but hard copy complaints to the proper authorities, which many people were copied in. Gauvin defrauded the court, by not providing Marcus any of the non-emails. There was only one email listed in DCF’s petition 2.

II. MOTION TO SUBPOENA TRANSCRIPTS:

Defendant motions for the criminal court to subpoena the child protections court to produce the transcripts of the Defendant’s DCF “trial.” With these transcripts, the perjury and false criminal charges can be prosecuted under the law, and Defendant’ children can be returned to their mother where they clearly want to be (see Trial Summary of the children’s attorney). Defendant will demonstrate who committed perjury in the DCF trial. That would include all of the State’s witnesses, and even one of the Defendant’s witnesses.

CAUSE

The Defendant’s children are extremely unhappy and want to come home. The Defendant’s disabled child (age 12) is not attending school, and none of the children are being seen by an infectious diseases specialist. Defendant’s son has migraines. He is now being given acid-reflux medication for his headaches and apnea. Diane (age 12) is not attending school due to “anxiety.” The academic caliber of the Alabama schools they now attend, even the children criticize. These are high-academic-performing children, wasting their time and their lives down there. Defendant’s 10 year old son reads at nearly the 11^th grade level. Donald Dickson continues to be obsessive and abusive.

Every night, the children say, Donald Dickson rushes to the computer to see what the Defendant has posted to the Lyme newsgroup. Donald has always been obsessed with the Defendant, as is characteristic of a sociopath. The records, particularly the 1996 restraining order, show Donald Dickson even traveled to Defendant’s place of employment to harass the Defendant. The children now see why the Defendant divorced Donald Dickson and have said to so to relatives (not Carolyn and Nancy Martin). Every night on the way home from Pfizer, when still married to Donald Dickson, the Defendant dreaded what Donald Dickson had in store for her that evening, since all he seems to do is concentrate on how he can make the Defendant’s life miserable. Our Marriage Counselor Psychiatrist told the Defendant that Donald was a sociopath and that he would never improve, in 1995. This turned out to be 100% correct. Ruffner loaned Defendant a book entitled “SOCIOPATHY.” Evidence of this claim and his behavior is in the alleged “harassing communications and threatening” since Defendant was demonstrating how insane the DCF is, to give these children to such a well-documented maniac.

Defendant’s14 year old complains of the extreme boredom of having an entire semester of CPR as one of her 3 classes. (“CPR, CPR, CPR for 96 minutes a day, day in and day out.” Defendant’s daughter finds this ridiculous.)

Peter J. Bartinik jr. did not have the Defendant refute any of the perjury of the State’s witnesses. For example, Nancy Martin, who filed the false DCF allegations informed the DCF that the Defendant yelled at Carolyn Martin in the hospital when Defendant’s father was dying (May 2002). Defendant Dickson was yelling at Nancy Martin for not ever allowing anyone else to have any input, yet the Defendant is a scientist in the health field. Carolyn Martin stated in the depositions that the Defendant was yelling at Nancy Martin. Nancy Martin stated in the “trial” that the Defendant “nearly flew out the window!” when the Defendant asked who wrote the Defendant’s father’s eulogy. No such thing happened. Defendant merely said, “Who wrote the eulogy? It sucked.” No one was in any mood to be flying out windows of limousines on the way to the cemetery after a funeral. Someone forgot to tell Nancy Martin that eulogies are supposed to be about the deceased and not Nancy Martin. Nancy Martin has a Masters in Marriage and Family Therapy, is on an e-list called “Microbes and Mental illness” and has been since 1999, yet she never told the DCF in all of her false allegations that the Defendant was sick with Lyme disease. She instead told the DCF that the Defendant had “bipolar disorder” when she knew bipolar disorder is the first rule out in Lyme disease and in fact, she knew of an NIMH study of bipolar which includes a rule-out for Lyme disease.

That is, no one who has Lyme disease can participate in the clinical trial, it is that well-known that the abuse and trauma sick people with Lyme suffer, results in frustration.

Nancy Martin also stated at the depositions that the Defendant was remarking about her grandparents at her brother’s funeral in 1977. The grandparents were all dead by 1964, so no such conversation took place. Nancy Martin has a thought disorder. Nancy Martin counsels people with Chronic Illnesses, and attended two Lyme disease conferences with the Defendant (1998 and 2001), yet she never told the DCF, in all of her false allegations, that the Defendant was sick with Lyme disease. She simply filed false allegations and perjured herself to avoid a lawsuit. Nobody nearly flew out any windows, the grandparents were not alive in 1977, and no one told Nancy Martin what eulogies were supposed to be about, and no one told the Defendant that Nancy Martin would be writing the eulogy or she would have asked input or at least editing. The Defendant’s father was not fond of Nancy Martin because of her self-centeredness, and there are some major issues as regards the Defendant’s father’s will. Nancy Martin “got squat,” in a word, and this hurt her very much. In retrospect, John J. Martin knew what he was doing, as regards distribution of his assets.

There has always been a major jealousy issue. The Defendant is quiet and thoughtful. The Defendant’s father always disliked loud, gossipy people and he especially hated liars. Defendant was always compared to her father (but in a negative sense), and this was one of the first complaints Defendant made to James Phillips, and is in record, in the DCF trial, dated June 2000. What does a child know about whether they are “JUST LIKE YOUR FATHER!!!” The Defendant heard this a million times from Carolyn Martin, since Day One. Defendant is a scientist and was an athlete. It is not the Defendant who is insane. These records are part of the DCF’s trial records and it states in two sets of James Phillips notes from 1980 to 2000, that the problem is Carolyn Martin. So much for psychotherapy. Now the Defendant’s children are gone because of Carolyn Martin’s relentless insanity and abuse. Carolyn Martin invented out of thin air that the Defendant “showed up at her house and threatened to slit her own throat,” which is a disgusting, repulsive thought. No one has ever heard of anyone “slitting their own throat.” Carolyn Martin was always going to strangle her children, but we never took her seriously.

Carolyn Martin has always had neck or throat theme, needs mental health treatment and should not be around children.

Defendant respectfully asks the court to examine all the evidence, subpoena the DCF transcripts, and assist with the prosecution of the guilty.
CERTIFICATION Mailed/hand delivered/faxed to

State’s Attorney’s Office

GA15 Courthouse

20 Franklin Square,

New Britain, CT 06051

Fax 515-5266

Juvenile Matters

978 Hartford Tnpke

Waterford, CT

Fax 440-5885

__________________________

Kathleen M. Dickson

23 Garden Street

Pawcatuck, CT 06379

CR CT CR04-021010 , CT CR04-276816 , New Britain, CT GA-15

MOTIONS REGARDING THE FALSE ARREST AND GAG ORDER OF KATHLEEN M. DICKSON

07 DECEMBER 2005

Defendants request that the DCF trial transcripts be turned over to the Defendant and the State’s Attorney Scott Murphy for comparison to the false criminal charges is GRANTED/ DENIED

_________________________ _________________________

JUDGE CLERK