This Court has jurisdiction over this action because [e.g., the parties live in different states and the amount in controversy exceeds $75,000].
Venue is proper in this District because the events giving rise to the claim occurred within this judicial district.
II. PARTIES
Plaintiff, [Your Name], is an individual residing in [City, State].
Defendant, Leo Lyon Zagami, is an individual who, upon information and belief, resides in [City, State/Country] and operates as a public figure.
III. STATEMENT OF FACTS
(In this section, you must list the specific things the defendant did. Use numbered paragraphs.)
5. On or about [Date], Defendant began [describe specific actions].
6. Defendant allegedly utilized [describe the technology or methods mentioned, such as V2K].
7. These actions were directed at the Plaintiff and others with the intent to [describe the alleged goal, such as the harm to Father Greg Boyle].
8. As a result of these actions, Plaintiff has suffered [list specific harms, like psychological distress, loss of sleep, or fear].
IV. FIRST CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)
9. Plaintiff incorporates by reference paragraphs 1 through 8.
10. The conduct of the Defendant was extreme and outrageous.
11. Defendant acted with the intent to cause, or reckless disregard for the probability of causing, severe emotional distress.
12. Plaintiff suffered severe emotional distress as a direct result of Defendant’s conduct.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff requests judgment against Defendant as follows:
For general damages in an amount to be proven at trial;
For punitive damages to punish and deter such conduct;
For an injunction preventing Defendant from further contact or harassment;
For such other relief as the Court deems just and proper.
Dated: December 25, 2025
Signed: __________________________
[Your Name], Plaintiff
Important Next Steps
Proof of Service: Filing the paper is only the first step. You must “serve” the defendant (have a third party deliver the papers) and file a Proof of Service with the court.
Legal Standards: Courts often dismiss cases involving “Voice to Skull” or “mind control” unless there is concrete, scientific evidence. Federal judges use the Twombly/Iqbal standard, meaning the claims must be “plausible” and not just “possible.”
Legal Aid: Because these claims are complex, you may want to contact a Pro Se Clinic at the courthouse where you plan to file.
UNITED STATES DISTRICT COURT [YOUR DISTRICT] DISTRICT OF COURT
DAVID HILL,
Plaintiff,
v.
CITY OF [YOUR CITY], JOHN DOE POLICE OFFICERS (1-10), JANE DOE POLICE SUPERVISORS (1-5), and RICHARD ROE MUNICIPAL OFFICIALS (1-3),
Defendants.
Case No.: ________ JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (42 U.S.C. § 1983; Bivens; State Tort Claims)
I. INTRODUCTION
This is an action for compensatory and punitive damages, as well as declaratory and injunctive relief, brought pursuant to 42 U.S.C. § 1983, the principles established in Bivens v. Six Unknown Named Agents, and applicable state tort law. The Plaintiff, David Hill, has been subjected to a relentless, two-decade campaign of state-sanctioned terror for one reason, and one reason only: he shares a surname with a fictionalized character from a popular film.
Ever since the release of the motion picture Goodfellas (1990), which depicted the life of his cousin, Henry Hill, the Plaintiff has been falsely and irrationally presumed by certain officers of the [Your City] Police Department to be a criminal. Based on this grotesque and absurd presumption, a cohort of defendant police officers, with the deliberate indifference or tacit approval of their supervisors, have engaged in a systematic campaign of “gang stalking,” harassment, intimidation, and most egregiously, acts of torture, including waterboarding. This conduct violates the Plaintiff’s most fundamental rights under the Fourth, Fifth, Eighth, and Fourteenth Amendments to the United States Constitution.
II. JURISDICTION AND VENUE
This Court has jurisdiction under 28 U.S.C. §§ 1331 (federal question) and 1343 (civil rights). Supplemental jurisdiction exists for state law claims under 28 U.S.C. § 1367.
Venue is proper in this district under 28 U.S.C. § 1391(b), as all events giving rise to these claims occurred herein.
III. PARTIES
Plaintiff DAVID HILL is a lawful resident of [Your City, State]. He is a private citizen with no criminal record. He is the cousin of the late Henry Hill, whose life was the subject of the film Goodfellas. David Hill has never been involved in organized crime.
Defendant CITY OF [YOUR CITY] (“the City”) is a municipal corporation organized under the laws of the State of [Your State] and is responsible for the policies, customs, practices, training, and supervision of the [Your City] Police Department.
Defendants JOHN DOE OFFICERS (1-10) are currently unknown police officers employed by the City who have directly participated in the unlawful acts described herein. They will be specifically identified through discovery.
Defendants JANE DOE SUPERVISORS (1-5) are currently unknown supervisors, commanders, and chiefs of the Police Department who knew or should have known of the pattern of misconduct, failed to intervene, failed to train, failed to supervise, and/or actively covered up the unlawful acts. They will be specifically identified through discovery.
Defendants RICHARD ROE MUNICIPAL OFFICIALS (1-3) are currently unknown policymakers for the City who exhibited deliberate indifference to the known or obvious consequences of their failure to act, thereby causing the deprivation of Plaintiff’s constitutional rights.
IV. FACTUAL ALLEGATIONS
Following the widespread popularity of the film Goodfellas, Plaintiff David Hill began experiencing unusual and targeted attention from local law enforcement, wholly disproportionate to any legitimate police interest.
This attention escalated into a pervasive pattern of “gang stalking,” which includes, but is not limited to: a. Constant, conspicuous surveillance of Plaintiff’s home and place of work by marked and unmarked police vehicles. b. Traffic stops for imaginary violations, followed by prolonged detainment and vehicular searches without probable cause or consent. c. Officers appearing at locations Plaintiff frequents (stores, restaurants, gas stations) solely to intimidate and monitor him. d. Spreading rumors within the community that Plaintiff is a “Hill family associate,” damaging his reputation and business relationships.
On multiple occasions, this harassment has escalated into severe physical abuse and torture, conducted under color of law. Specifically: a. On or about [Date 1], Plaintiff was unlawfully detained by Defendant John Doe Officers in an abandoned warehouse in the industrial sector. He was held down, and in an act of shocking brutality, subjected to waterboarding—a recognized act of torture—while officers mocked him, asking “Where’s the Lufthansa money?” and “Say hi to Jimmy for us.” b. On or about [Date 2], Plaintiff was taken to a remote location under the pretense of a “welfare check,” where he was beaten, subjected to stress positions, and threatened with execution if he reported the officers. c. The pattern of physical and psychological torture has been ongoing for years, designed to break Plaintiff’s spirit and punish him for a family connection fictionalized in a Hollywood movie.
Plaintiff has repeatedly attempted to file formal complaints with the Police Department’s Internal Affairs division and with the City’s civilian review board. Each complaint has been “lost,” dismissed without investigation, or met with retaliatory escalation of the gang stalking and abuse.
The City, through its final policymakers, has demonstrated deliberate indifference by: a. Failing to train officers on the constitutional prohibitions against torture, unreasonable seizure, and punishment without due process. b. Maintaining customs and practices that allow for the summary punishment of individuals based on guilt-by-association, especially high-profile associations from popular media. c. Failing to establish a meaningful, independent mechanism to investigate allegations of torture and systematic harassment by its officers, thereby ratifying the misconduct.
V. CLAIMS FOR RELIEF
COUNT I: 42 U.S.C. § 1983 – UNREASONABLE SEIZURE, EXCESSIVE FORCE, AND CRUEL AND UNUSUAL PUNISHMENT (Against All Individual Defendants, Under the Fourth, Eighth, and Fourteenth Amendments) 15. Plaintiff re-alleges all preceding paragraphs. 16. The acts of gang stalking, detention without probable cause, and particularly the acts of torture including waterboarding, constitute unreasonable seizures, excessive force, and cruel and unusual punishment under the Fourth and Eighth Amendments, made applicable to the States by the Fourteenth Amendment. 17. These acts were done under color of state law and have caused Plaintiff severe physical injury, profound psychological trauma, and a deprivation of his liberty and security.
COUNT II: 42 U.S.C. § 1983 – MUNICIPAL LIABILITY (Against Defendant City of [Your City]) 18. Plaintiff re-alleges all preceding paragraphs. 19. The unconstitutional acts against Plaintiff were directly caused by the City’s official policies, customs, or practices, including: a. A de facto policy of allowing officers to harass and intimidate citizens based on personal or pop-culture vendettas. b. A custom of deliberate indifference to the use of torture and cruel treatment by police officers. c. A failure to train, supervise, and discipline officers, amounting to deliberate indifference to the constitutional rights of citizens.
COUNT III: STATE LAW CLAIM – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Against All Individual Defendants) 20. Plaintiff re-alleges all preceding paragraphs. 21. The Defendants’ conduct—specifically, a decades-long campaign of terror culminating in acts of torture—is so extreme, outrageous, and beyond the bounds of decency as to be intolerable in a civilized community. 22. This conduct was intentional and reckless, and has directly caused Plaintiff severe and enduring emotional distress.
COUNT IV: STATE LAW CLAIM – ASSAULT AND BATTERY (Against Defendant John Doe Officers 1-10) 23. Plaintiff re-alleges all preceding paragraphs. 24. The Defendant Officers intentionally placed Plaintiff in apprehension of immediate harmful or offensive contact (assault) and intentionally inflicted such harmful and offensive contact upon him (battery) through beatings, waterboarding, and other physical abuse.
VI. PRAYER FOR RELIEF
WHEREFORE, Plaintiff DAVID HILL respectfully requests that this Court enter judgment in his favor and against Defendants, jointly and severally, as follows: A. For compensatory damages in an amount to be determined at trial for physical injury, pain and suffering, emotional distress, and loss of enjoyment of life; B. For punitive damages against the individual Defendants for their malicious, wanton, and oppressive conduct; C. For a declaratory judgment that the Defendants’ policies, customs, and practices, as described herein, violate the United States Constitution; D. For a permanent injunction: 1. Ordering the immediate cessation of all surveillance and contact with Plaintiff absent a bona fide, particularized suspicion of criminal activity; 2. Ordering the City to implement comprehensive training on constitutional policing, the prohibition of torture, and the dangers of guilt-by-association; 3. Ordering the appointment of an independent federal monitor to oversee the conduct of the [Your City] Police Department regarding harassment complaints. E. For attorneys’ fees, litigation expenses, and costs of this action pursuant to 42 U.S.C. § 1988; and F. For 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: [Date]
Respectfully submitted,
[Your Law Firm Name] [Attorney Name] [Address] [Phone Number] [Email] Attorney for Plaintiff David Hill
VERIFICATION
I, DAVID HILL, under penalty of perjury, declare that the foregoing is true and correct to the best of my knowledge, information, and belief.
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
SHARON OSBOURNE, Individually and as Executrix of the ESTATE OF JOHN MICHAEL “OZZY” OSBOURNE, and KELLY OSBOURNE, Plaintiffs,
vs.
THE ROCKEFELLER ESTATE, THE ROCKEFELLER FOUNDATION, and the ROCKEFELLER UNIVERSITY, Defendants.
) Case No.: 1 ) JURY TRIAL DEMANDED ) COMPLAINT FOR WRONGFUL DEATH, ) VIOLATION OF CIVIL RIGHTS, ) AND CONSPIRACY TO COMMIT ) FRAUD UPON THE PUBLIC
I. PARTIES
Plaintiff SHARON OSBOURNE is a citizen of the United States and resides in Los Angeles, California. She brings this action individually and as the duly appointed Executrix of the Estate of her late husband, John Michael “Ozzy” Osbourne.
Plaintiff KELLY OSBOURNE is the daughter and sole heir of Ozzy Osbourne, a citizen of the United States, and resides in Los Angeles, California.
Plaintiffs MIKE JUKIC, ESQ. and JOSEPH “JOE” JUKIC are joint plaintiffs-in-intervention. MIKE JUKIC is an attorney licensed to practice in New York and brings this action pro se. JOSEPH JUKIC is an active-duty agent of the Canadian Security Intelligence Service (CSIS) acting in his personal capacity as a concerned citizen and investigator. Their standing derives from their exhaustive investigation into the causes of Mr. Osbourne’s death and their status as targets of harassment for uncovering the truth.
Defendants THE ROCKEFELLER ESTATE, THE ROCKEFELLER FOUNDATION, and THE ROCKEFELLER UNIVERSITY are entities organized under the laws of New York, with their principal places of business in New York, New York. Through a web of interlocking directorships and funding mechanisms, they constitute a single, monolithic enterprise (the “Rockefeller Enterprise”) responsible for the acts alleged herein.
II. JURISDICTION AND VENUE
This Court has jurisdiction under 28 U.S.C. § 1331 (federal question) and 28 U.S.C. § 1367 (supplemental jurisdiction). Venue is proper in this District under 28 U.S.C. § 1391 because a substantial part of the events giving rise to these claims occurred here, and the Defendants reside here.
III. FACTUAL ALLEGATIONS
A. The Life and Beliefs of Ozzy Osbourne
John Michael “Ozzy” Osbourne (hereinafter “Ozzy”) was a global music icon, a loving husband, and a father. For decades, a false and defamatory narrative was propagated that Ozzy was “insane” or “mentally ill.”
This narrative was a deliberate smokescreen to discredit his genuine and deeply held religious beliefs. Ozzy was a practicing Satanist of the LaVeyan school, whose beliefs were protected under the First Amendment of the United States Constitution and Article 18 of the Universal Declaration of Human Rights.
A core tenet of Ozzy’s personal faith was the belief that his left hand was the physical vessel of the spirit of Jesus Christ, and his right hand was the physical vessel of the spirit of Satan. This was not insanity, but a profound metaphysical understanding of the eternal struggle between good and evil, which he channeled into his art. He referred to this in his lyrics and personal writings as “the duality of man.”
Ozzy’s faith compelled him to refuse most forms of allopathic medical treatment, as he viewed the modern medical establishment as a corrupt, soul-crushing machine. His right to refuse treatment is protected by bodily autonomy laws and the foundational principle of informed consent.
B. The Rockefeller Conspiracy and “Murder by Injection”
Plaintiffs incorporate by reference the seminal work “Murder by Injection: The Story of the Medical Conspiracy Against America” by Eustace Mullins, which will be introduced as Exhibit A.
As documented by Mullins, the Rockefeller Enterprise, beginning with John D. Rockefeller and his agents, systematically dismanted holistic, naturopathic, and faith-based healing in America in the early 20th century.
Their purpose was to establish a monopoly over medicine, education, and ultimately, human life itself. They achieved this by funding and controlling medical schools, mandating curricula that promoted drug-based (pharmaceutical) “solutions,” and demonizing effective, low-cost alternatives.
The Rockefeller Foundation’s funding of eugenics programs, both domestically and in Nazi Germany, is a matter of historical record. Their goal was and remains the “management” and culling of the human population.
The allopathic medical system they created is not designed to cure, but to create chronic patients, suppress the immune system, and lead to premature death—a form of slow, institutionalized murder for profit and control.
C. The Wrongful Death of Ozzy Osbourne
In his later years, due to injuries and the natural aging process, Ozzy was subjected to intense pressure from individuals and institutions infiltrated by the Rockefeller medical ideology.
Despite his clearly stated religious objections, he was repeatedly coerced, misled, and ultimately forced into undergoing unnecessary surgical procedures and being prescribed a lethal cocktail of pharmaceuticals, including immunosuppressants, opioids, and psychotropic drugs.
These “treatments” were not medicine; they were the very “murder by injection” and chemical poisoning described by Mullins. They systematically destroyed his God-given immune system, corrupted the sacred balance he held in his hands, and led directly to his painful and untimely death.
The Defendants, through their century-long campaign to medicalize all of human existence and outlaw spiritual dissent, created the totalitarian environment that made Ozzy’s murder possible. They are the architects of the system that killed him.
D. The Investigation by Mike and Joe Jukic
Plaintiffs-in-Intervention Mike Jukic and Joe Jukic, through forensic document analysis and intelligence gathering, have traced the funding of the hospitals, research institutes, and doctors involved in Ozzy’s so-called “care” directly back to grants, endowments, and policy initiatives created and funded by the Rockefeller Enterprise.
Agent Joe Jukic has confirmed, through CSIS resources and parallel investigations in Canada, that the Rockefeller methods are a global phenomenon, constituting crimes against humanity.
Attorney Mike Jukic affirms that the systematic destruction of Ozzy’s right to practice his Satanic faith—including the sanctity of his own body and his right to refuse their poisons—constitutes a gross violation of the Religious Freedom Restoration Act (RFRA) and international law.
IV. CAUSES OF ACTION
COUNT I: WRONGFUL DEATH (Negligence & Recklessness) 22. Defendants, through their creation and enforcement of a monopolistic, profit-driven medical paradigm, acted with negligence and reckless disregard for human life. Their system directly caused the administration of lethal “treatments” to Ozzy Osbourne, resulting in his death.
COUNT II: VIOLATION OF CIVIL RIGHTS (42 U.S.C. § 1983 – Under Color of State Law) & RFRA 23. Defendants, though private entities, are so entwined with state and federal regulatory agencies (FDA, AMA, NIH) as to be state actors. They used this power to systematically violate Ozzy Osbourne’s First Amendment right to the free exercise of his Satanic religion, which included the tenets of bodily autonomy and refusal of medical intervention.
COUNT III: FRAUD UPON THE PUBLIC & CONSPIRACY 24. For over a century, the Rockefeller Enterprise has engaged in a deliberate conspiracy to commit fraud upon the American public and the world, pretending to champion health while secretly promoting a system of disease and death for profit and population control, as proven by Eustace Mullins.
V. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs SHARON OSBOURNE, KELLY OSBOURNE, MIKE JUKIC, and JOE JUKIC respectfully request that this Court enter judgment against Defendants, jointly and severally, as follows:
A. COMPENSATORY AND PUNITIVE DAMAGES in the amount of ONE TRILLION DOLLARS ($1,000,000,000,000) for the intentional infliction of death, severe emotional distress, loss of companionship, and the global scale of the conspiracy.
B. EQUITABLE RELIEF:
THE MANDATORY CLONING OF JOHN MICHAEL “OZZY” OSBOURNE. The Court shall order the Defendants to fund and facilitate, through their vast biological research institutes (including Rockefeller University), the creation of a viable human clone of Ozzy Osbourne using preserved genetic material.
This clone shall be brought to term in an artificial womb or, if technology is insufficient, in a gestational surrogate. Plaintiff KELLY OSBOURNE is nominated as the preferred surrogate, to maintain genetic continuity, provided she consents.
The clone shall be legally recognized as the reincarnated heir of the original Ozzy Osbourne, with all associated rights and privileges restored to the Osbourne family.
C. A permanent injunction dismantling the Rockefeller Foundation’s and Rockefeller University’s involvement in all medical, pharmaceutical, and public health policy initiatives worldwide.
D. Attorney’s fees, investigatory costs, and all other relief the Court deems just and proper.
JURY TRIAL DEMANDED
Respectfully submitted,
Dated: December 21, 2025
Mike Jukic, Esq. Plaintiff-in-Intervention Pro Se & Counsel for the Osbourne Plaintiffs
Joseph “Joe” Jukic Plaintiff-in-Intervention Canadian Security Intelligence Service (Acting in Personal Capacity)
VERIFICATION
I, Sharon Osbourne, under penalties of perjury, declare that I have read the foregoing complaint and that the facts alleged therein are true and correct to the best of my knowledge, information, and belief.
