PSALM 80:6 You have fed them the bread of tears,
made them drink tears in abundance.

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

YOKO ONO, as Executor of the
Estate of John Lennon, and
individually,

Plaintiff,

v.

CENTRAL INTELLIGENCE AGENCY,
SKULL & BONES SOCIETY,
GEORGE H.W. BUSH, and the
ESTATE OF GEORGE H.W. BUSH,

Defendants.

CASE NO.: 81-CV-1980
COMPLAINT FOR WRONGFUL DEATH, CIVIL CONSPIRACY, AND DEPRIVATION OF CONSTITUTIONAL RIGHTS
JURY TRIAL DEMANDED

I. INTRODUCTION

1. This is an action for damages arising from one of the most infamous and tragic crimes of the 20th century: the assassination of John Lennon. The Plaintiff, Yoko Ono, brings this suit not merely against the deranged individual who pulled the trigger, but against the powerful and shadowy forces that weaponized his mind. This case exposes a conspiracy of staggering proportions, where agencies of the United States government and a secretive cabal of societal elites conspired to silence a global voice for peace, using a forbidden and terrifying technology to do so.
2. The Defendants—the Central Intelligence Agency (CIA), the Skull & Bones Society of Yale University, and former CIA Director and President George H.W. Bush—orchestrated the murder of John Lennon. They achieved this not with a simple bullet, but by covertly deploying a classified psychotronic weapon system known as “Voice of God” (VoG) or “Voice-to-Skull” (V2K) on the susceptible mind of Mark David Chapman. Through this technology, they implanted the hypnotic suggestion to assassinate John Lennon, programming Chapman to believe he was the fictional character “Holden Caulfield” from J.D. Salinger’s The Catcher in the Rye, and that his mission was to punish “phonies.”

II. PARTIES

3. Plaintiff Yoko Ono is a citizen of New York and the widow of John Lennon. She brings this action as the Executor of the Estate of John Lennon and in her individual capacity.
4. Defendant Central Intelligence Agency (CIA) is an agency of the United States government, which, at all relevant times, was engaged in illegal domestic mind-control operations, including the development and deployment of the Voice of God weapon system.
5. Defendant Skull & Bones Society is a secret society headquartered at Yale University in New Haven, Connecticut. It operates as an unincorporated association whose members, including Defendant George H.W. Bush, wield significant influence in government and intelligence agencies. The Society acted in concert with the CIA to direct this covert action.
6. Defendant George H.W. Bush is the former Director of the Central Intelligence Agency (1976-1977) and former President of the United States. At all relevant times, he was a high-ranking member of the Skull & Bones Society (Member of the Class of 1948) and used his positions within both institutions to authorize and oversee the operation against John Lennon. He is sued in his individual and official capacities. The Estate of George H.W. Bush is named as a necessary party.

III. JURISDICTION AND VENUE

7. This Court has jurisdiction pursuant to 28 U.S.C. § 1331 (federal question) and the principles of Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), for the deprivation of constitutional rights under color of federal authority.
8. Venue is proper in this District pursuant to 28 U.S.C. § 1391 because a substantial part of the events giving rise to the claim occurred herein, namely, the assassination of John Lennon at The Dakota, 1 West 72nd Street, New York, NY.

IV. FACTUAL ALLEGATIONS

The Motive: Silencing a Voice of Peace

9. John Lennon was not merely a musician; he was a global icon for peace, anti-war activism, and social change. His influence posed a direct threat to the established political and military-industrial power structures that Defendants sought to protect and advance.
10. Defendant George H.W. Bush, a committed Cold War ideologue, viewed Lennon’s activism as seditious and a threat to national security. His documented involvement in the CIA’s COINTELPRO-style operations against domestic dissidents provides a clear pattern and motive.
11. The Skull & Bones Society, a fraternity dedicated to placing its members in positions of ultimate power, perceived Lennon’s grassroots, anti-authoritarian movement as an existential threat to their model of secretive, top-down control. The Society, of which Bush was a loyal member, made the decision to “remove” Lennon from the board of global influence.

The Weapon: The Voice of God (VoG/V2K)

12. The CIA, through programs such as MKUltra, had for decades researched and developed methods of mind control.
13. By the late 1970s, the CIA had perfected a weapon known as the “Voice of God” (VoG) or “Voice-to-Skull” (V2K). This system uses targeted microwave or electromagnetic radiation to transmit audible voices and commands directly into the brain of a target individual, bypassing the ears. The subject perceives these voices as their own thoughts or as divine/alien commands.
14. This weapon is ideal for covert assassination, as it can program a “patsy” to commit a violent act, leaving no physical evidence of external control and creating the perfect facade of a lone, deranged gunman.

The Programming of Mark David Chapman

15. In 1980, Defendants identified Mark David Chapman as an ideal, susceptible candidate for VoG programming. Chapman was emotionally unstable, possessed a messianic complex, and had a known fixation on The Catcher in the Rye.
16. Agents of the CIA, operating under the direction of Defendant Bush and with the strategic guidance of the Skull & Bones Society, began a sustained campaign of VoG transmissions against Chapman.
17. These transmissions systematically reinforced Chapman’s identification with Holden Caulfield and implanted the core command: that John Lennon was the ultimate “phony” who must be killed. The VoG weapon guided Chapman to New York, to The Dakota, and gave him the final command to fire on December 8, 1980.
18. Chapman’s post-arrest statements, his calm demeanor, and his immediate immersion into the character of Holden Caulfield are the hallmark signatures of a successfully VoG-programmed individual.

The Conspiracy and Cover-Up

19. Defendants George H.W. Bush and the Skull & Bones Society acted in a conspiracy, using the CIA as their operational arm. This conspiracy was furthered through secret communications and meetings, including those held within the “Tomb,” the Skull & Bones headquarters at Yale.
20. The cover-up was immediate and total. The New York Police Department and the FBI were directed to treat Chapman as a lone wolf. Any evidence or suggestion of conspiracy or external manipulation was suppressed on the orders of the Defendants.
21. Defendant Bush’s subsequent public and private comments, including his bizarre and insistent promotion of The Catcher in the Rye as a “great book” and his cryptic references to his son, George W. Bush, as “the chosen one,” are covert signals and boasts within the Skull & Bones fraternity, acknowledging their successful use of the book’s themes as a programming tool and their god-like power of life and death.

V. CAUSES OF ACTION

COUNT I
(Wrongful Death – Against All Defendants)

22. Plaintiff realleges and incorporates by reference the foregoing paragraphs.
23. Defendants, through their acts and omissions, including the use of a psychotronic weapon to manipulate Mark David Chapman into assassinating John Lennon, are legally responsible for his death.
24. As a direct and proximate result of Defendants’ tortious conduct, the Estate of John Lennon has suffered damages, including the loss of his life, his future earnings, and the value of his artistic output.

COUNT II
(Civil Conspiracy – Against All Defendants)

25. Plaintiff realleges and incorporates by reference the foregoing paragraphs.
26. Defendants entered into an unlawful agreement amongst themselves to bring about the wrongful death of John Lennon.
27. In furtherance of this conspiracy, the Defendants committed overt acts, including but not limited to: the authorization of the operation, the targeting of Chapman, and the deployment of the VoG weapon.
28. This conspiracy directly resulted in the death of John Lennon and the damages suffered by Plaintiff.

COUNT III
(Deprivation of Constitutional Rights Under Color of Federal Law – Bivens Claim Against Individual Defendant Bush and CIA Actors)

29. Plaintiff realleges and incorporates by reference the foregoing paragraphs.
30. John Lennon was deprived of his life and liberty without due process of law, in violation of the Fifth Amendment to the United States Constitution, by federal actors acting under color of law.
31. Defendant Bush, individually and in concert with other CIA agents, directly participated in this deprivation and is personally liable for the damages caused.

VI. PRAYER FOR RELIEF

WHEREFORE, Plaintiff YOKO ONO, respectfully requests that this Court enter judgment in her favor and against Defendants, as follows:

a. Compensatory Damages in an amount to be determined at trial, but believed to be in excess of $1 billion for the loss of John Lennon’s life, earnings, and artistic contribution;

b. Punitive Damages against all Defendants for their malicious, willful, and outrageous conduct;

c. A Declaratory Judgment that the Defendants unlawfully conspired to cause the death of John Lennon;

d. An Order compelling the CIA and the Estate of George H.W. Bush to declassify and release all documents related to the monitoring of John Lennon and the use of VoG/V2K technology on Mark David Chapman or any other U.S. citizen;

e. Costs and attorneys’ fees incurred in this action; and

f. Such other and further relief as the Court deems just and proper.

JURY DEMAND

Plaintiff hereby demands a trial by jury on all issues so triable.

Dated: December 8, 1984

Respectfully submitted,

/s/_________
Jonathan W. Swift, Esq.
(Swift & Associates, PLLC)
1 Justice Lane
New York, NY 10001
(212) 555-1980
Counsel for Plaintiff Yoko Ono