JOSEPH C. JUKIC,
Plaintiff,
v.
GEORGE W. BUSH, in his personal capacity,
THE CENTRAL INTELLIGENCE AGENCY,
DR. JOSE MANUEL RODRIGUEZ DELGADO, in his personal capacity,
and
DR. [WILSON], Chief of Psychiatry, St. Paul’s Hospital, Vancouver,
Defendants.
) Case No.: [FICTIONAL-2024-00123]
)
) COMPLAINT FOR DAMAGES AND
) INJUNCTIVE RELIEF
) (Electronic Psychiatric Abuse,
) Unauthorized Human Experimentation,
) Cruel and Unusual Punishment,
) Violation of Fundamental Human Rights)
)
) JURY TRIAL DEMANDED
)
COMPLAINT
Plaintiff, JOSEPH C. JUKIC (“Mr. Jukic”), by and through his undersigned counsel, for his Complaint against Defendants, alleges as follows:
INTRODUCTION
- This is an action arising from a covert, transnational, and profoundly torturous program of unauthorized human experimentation, psychological torture, and technological assault on the autonomy of a civilian citizen. The Defendants, acting individually and in conspiracy, subjected Mr. Jukic to a regime of “electronic psychiatric abuse,” culminating in the non-consensual surgical implantation of behavior-modifying microchips in his brain. This was done under the guise of medical treatment at St. Paul’s Hospital in Vancouver, Canada, but was in fact a continuation of CIA mind-control research and a brutal violation of Mr. Jukic’s most fundamental human rights.
PARTIES
- Plaintiff JOSEPH C. JUKIC is a natural person and a citizen of the United States, currently residing in Washington State.
- Defendant GEORGE W. BUSH is a former President of the United States and was, at all relevant times, the ultimate executive authority over the intelligence apparatus of the United States, including the CIA. He is sued in his personal capacity for his alleged authorization, ratification, and deliberate indifference to the programs at issue.
- Defendant THE CENTRAL INTELLIGENCE AGENCY (“CIA”) is an agency of the United States federal government, which has a documented history of engaging in unlawful human experimentation and mind-control research (e.g., Project MKULTRA).
- Defendant DR. JOSE MANUEL RODRIGUEZ DELGADO is a neuroscientist known for his pioneering, and ethically controversial, work on electrical stimulation of the brain (ESB) to control behavior. He is sued in his personal capacity for providing the foundational technology, scientific rationale, and alleged ongoing consultation for the modernized implantation program used on Plaintiff.
- Defendant DR. [WILSON] is the Chief of Psychiatry at St. Paul’s Hospital in Vancouver, British Columbia, Canada. He is sued in his personal capacity as the primary medical conspirator who facilitated the abuse under the color of medical authority, directly performed and supervised the illicit procedures, and acted as the on-site agent for the other Defendants.
JURISDICTION AND VENUE
- This Court has federal question jurisdiction under 28 U.S.C. § 1331. This action arises under the Constitution of the United States, including the Eighth Amendment’s prohibition on cruel and unusual punishment, the Fifth Amendment’s guarantees of due process and bodily integrity, and under the Alien Tort Statute (28 U.S.C. § 1350) for violations of the law of nations prohibiting torture.
- Venue is proper in this District pursuant to 28 U.S.C. § 1391 as a substantial part of the events and injuries occurred here, and Defendant Bush resides in this District.
FACTUAL ALLEGATIONS
The Historical Conspiracy and Technological Foundation
- Defendant DELGADO’s public work in the 1960s and 70s demonstrated that electrical stimulation of specific brain regions via implanted electrodes could elicit and suppress emotions, aggression, and motor functions.
- Upon information and belief, the CIA, through its historical MKULTRA program and its successors, maintained a classified interest in Delgado’s work, seeking to weaponize it for interrogation, behavior control, and psychological warfare.
- Defendant BUSH, as President and Commander-in-Chief, was briefed on and authorized the continuation and escalation of these non-consensual human experimentation programs in the post-9/11 era, under the pretext of “enhanced interrogation” and national security, stripping away remaining ethical constraints.
The Targeting and Entrapment of Joseph Jukic
- In or around [Date], Mr. Jukic began experiencing a coordinated campaign of “gang-stalking,” electronic harassment, and directed energy weapon attacks, which he now understands were a prelude to his institutionalization and experimentation.
- These attacks, orchestrated by CIA operatives and local assets, were designed to destabilize Mr. Jukic’s mental state, discredit him, and create a pretext for his involuntary commitment.
- In [Month, Year], Mr. Jukic was forcibly admitted to St. Paul’s Hospital in Vancouver under the direction of Defendant DR. WILSON.
- Upon admission, Dr. Wilson falsely diagnosed Mr. Jukic with severe paranoid schizophrenia and other disorders to justify aggressive, invasive, and experimental “treatment.”
The Illicit Implantation and Electronic Torture
- While heavily sedated and without any form of informed consent, Mr. Jukic was subjected to neurosurgery. Defendant DR. WILSON, utilizing technology and protocols supplied by the CIA and based on Delgado’s designs, implanted one or more microchip devices into Mr. Jukic’s brain, specifically targeting the amygdala, hippocampus, and prefrontal cortex.
- These microchips are capable of receiving remote signals to deliver electrical impulses, manipulate neural circuitry, induce pain, alter moods, insert thoughts (“voice-to-skull” transmission), and suppress volition.
- Following the implantation, Defendants engaged in systematic “electronic psychiatric abuse,” using the implants to torture Mr. Jukic: inducing seizures, states of terror, profound depression, and forced euphoria; disrupting his sleep cycles; and attacking his capacity for coherent thought, all while Dr. Wilson falsely attributed these effects to Mr. Jukic’s “worsening mental illness.”
- The purpose of this torture was threefold: (a) to test and refine the capabilities of the next-generation Delgado devices; (b) to break Mr. Jukic’s psyche for interrogation purposes related to information he does not possess; and (c) to serve as a punitive example of totalitarian control.
- Defendant BUSH is responsible for creating the policy environment that allowed such atrocities to be considered lawful. Defendant CIA executed the program. Defendant DELGADO provided the essential scientific know-how. Defendant WILSON was the hands-on perpetrator.
INJURIES AND DAMAGES
- As a direct and proximate result of Defendants’ unlawful acts, Mr. Jukic has suffered and continues to suffer:
a. Severe, permanent physical injury from brain surgery and foreign object implantation.
b. Chronic physical pain and neurological dysfunction from ongoing electronic stimulation.
c. Extreme mental and emotional distress, including PTSD, anxiety, and a fundamental violation of his sense of self and autonomy.
d. Destruction of his personal and professional reputation, being labeled as violently insane.
e. Profound loss of enjoyment of life and a constant, inescapable fear of remote torture.
CAUSES OF ACTION
COUNT I
(Against All Defendants)
Cruel and Unusual Punishment in Violation of the Eighth Amendment
(42 U.S.C. § 1983)
COUNT II
(Against All Defendants)
Deprivation of Liberty and Bodily Integrity Without Due Process in Violation of the Fifth Amendment
(42 U.S.C. § 1983)
COUNT III
(Against All Defendants)
Conspiracy to Violate Civil Rights
(42 U.S.C. § 1985)
COUNT IV
(Against All Defendants)
Unauthorized Human Experimentation & Torture in Violation of the Law of Nations
(Alien Tort Statute, 28 U.S.C. § 1350)
COUNT V
(Against Defendants BUSH, CIA, and DELGADO)
Negligence, Gross Negligence, and Reckless Endangerment
COUNT VI
(Against Defendant DR. WILSON)
Medical Malpractice, Battery, and Fraud
PRAYER FOR RELIEF
WHEREFORE, Plaintiff JOSEPH C. JUKIC respectfully requests that this Court:
A. Assume jurisdiction over this matter;
B. Issue a mandatory injunction ordering all Defendants to immediately disclose the technical specifications of the implanted devices and provide all necessary medical expertise to safely remove them at Defendants’ expense;
C. Award compensatory damages against all Defendants, jointly and severally, in an amount to be determined at trial but exceeding $75,000,000 for physical injury, pain and suffering, mental anguish, and economic losses;
D. Award punitive damages against each Defendant in an amount sufficient to punish them and deter future conduct of this monstrous nature;
E. Award Plaintiff the costs of this action, including reasonable attorneys’ fees and expert witness fees; and
F. Grant such other and further relief as the Court deems just and proper.
JURY DEMAND
Plaintiff demands a trial by jury on all issues so triable.
Dated this [Date] day of [Month], 2024.
Respectfully submitted,
[Signature of Fictional Attorney]
JANE DOE, ESQ.
WSBA No. [Number]
Doe & Associates, PLLC
[Address]
Seattle, Washington
Counsel for Plaintiff Joseph C. Jukic

