Points for Hearing on Order of Conditions:



The instant offense was preceded by a remarkable series of events, creating a situation of stress and instability in the respondent's environment and personal health. The defendant's confused and delusional state on 2/6/97 was the result of no single, simple cause, but was in large part the result of hypomania induced by Prozac and psychotherapeutic malpractice.  The circumstances surrounding the offense are extremely unlikely to recur.



These circumstances included:

1) Stress from arrest for a DWI ( 1:40AM, 12/22/96) which occurred as a result of being given a spiked drink and then pulled over for a speeding "violation" prompted solely by speeding and tailgating by the officer making the arrest (Exhibit 2, Sgt. Curtolo's testimony describing his driving).

2) Stress from arrest after a false complaint of sexual assault made by the defendent's girlfriend (3:00AM 12/29/96).  

3) Stress from these arrests, comprising the first instances in which the defendent had ever been arrested and jailed, caused the defendent great psychological distress and loss of sleep, and prompted him to go on Prozac on 12/30/96.  Prozac was proven in Eli Lilly's clinical trials to cause hypomania or mania in .7% of patients, and it caused the defendent to enter a hypomanic state which severely affected his judgment, which hypomanic state persisted until after his use of the drug was discontinued (6/15/97).

4) Physical distress, as the defendent began to experience the progressive loss of sensation in his arms, legs, and back and left side of his head, along with confusion and loss of memory (1/6/97-on).  The defendent made efforts to seek treatment for these problems, which were attributed incorrectly to hysteria accompanying depression (1/11/97).  The judgment of the emergency room physician was somewhat prejudiced by incorrect beliefs regarding the events which occurred 12/29/96, since Susan Hamann had visited the emergency room after the alleged assault; these prejudiced beliefs helped further prejudice subsequent clinical judgments when wholly false claims that violence had occurred on that occasion were inserted into the defendent's medical record.

Defendent evidently suffers from a case of Chronic Inflammatory Demyelinating Polyneuropathy, an autoimmune disease aggravated by stress, which was caused by a nearly-lethal case of mycoplasma pneumoniae in September 1972.  Defendent was diagnosed with another autoimmune disorder, psoriatic arthritis (1/20/97), which was likewise probably induced by this exposure to M. Pneumoniae, which is a persistent prokaryotic mammalian parasite resistant to antibiotic treatment (Exhibit 3, St. Vincent's Hospital record, Exhibit 4, MedLine abstracts re: m. pneumoniae, CIDP, and psychosis).

5) Psychotherapeutic malpractice and fraud (6/7/96-1/30/97):  Exhibit XXX, the Family and Children's Service diagnosis and treatment plan for the defendent, demonstrates fraud when the DSMdiagnostic numbers are compared with the plain English text and the verbal summary of the diagnosis--dysthymia--which was given to the defendent: suggestio falsi, suppressio veri.  Defendent's therapy was summarily terminated by the agency 1/30/97 because he returned to his customary use of cannabis sativa after realizing it was essential to controlling the distressing physical symptoms noted above (Exhibit XXX "Delta-9 THC as a novel treatment for chronic inflammatory demyelinating polyneuropathy"), claiming they were incompetent to handle his case, even though the agency had already treated him (without informing him) for "cannabis dependence" for eight months, as documented by FCS' client billing records (Exhibit XXX).  

Defendent states moreover for the record that his use of cannabis over the past 20 years has been greatly beneficial in controlling his anxiety disorder, and is safer and more effective in controlling this disorder than would be the use of the only legally available alternative drugs, benzodiazepine family of tranquilizers, which become ineffective due to the development of tolerance, are prone to cause profound physiological dependence (withdrawal may cause death by seizure if benzodiazepine treatment is abrubtly discontinued), and cause permanent cognitive deficits from long-term use even after treatment is discontinued (Exhibit XXX).  Claims by FCS and other therapists that he suffers from "cannabis dependence" or "cannabis abuse" do not employ the diagnostic criteria set forth in the DSM-IV.

6) Defendent had only partially recoved from the physical and mentally debilitated state (presumably caused by an acute episode of CIDP, which in an acute phase has the same symptoms as Guillain-Barre Syndrome) when he read Silence of the Lambs for the first time (2/4/97) and noted the amazing coincidental similarities between Clarice Starling and Susan Hamann.  This provided a framework for interpreting Susan Hamann's assault complaint and other strange circumstances, in which the pattern of unprecedented legal and medical difficulties experienced by the defendent could be fit into a grand scheme to paint him as a psychopathic deviate--one who would be bait for a trap set for Hannibal Lecter, whom the defendent presumed to be fictional rendition of a real terrorist who had threatened to unleash anthrax in a terrorist conspiracy, whose plot had been indirectly leaked to Thomas Harris and incorporated obliquely into The Silence of the Lambs, a plot too terrible to reveal to the American public because of the widespread panic which would ensue following any announcement that devices capable of delivering anthrax had been deployed by an unbreakable terrorist genius.  

The Order of Protection which forbade communication between defendent and Susan Hamann was yet another factor in undermining his sanity, insofar as it prevented him from contacting Susan Hamann and discussing his fears and beliefs until his rationality was so far undermined by sheer terror that he began experiencing auditory illusions (2/6/97) and wound up, propelled witlessly by circumstantial "clues" and musical "cues" from a radio station, feeling "like a rat in a maze" designed by Hannibal Lecter, a subject in a bizarre test arranged by a real personage who evidently stood behind the most frightening criminal genius ever portrayed in literature--"Remember, Lecter loves his little jokes."

The similarity between Susan Hamann and Clarice Starling is probably the most astonishing coincidence ever noted by the defendent.  



  Psychotherapeutic misconduct constituting both malpractice and criminal fraud on the part of his therapist, Amari Meader, Dr. Hamlisch, and the Family and Children's Service, which from 7/5/96 through 1/30/97 secretly diagnosed him as suffering from "Cannabis Dependence" and "Borderline Personality Disorder" while informing him that his $19/week fees were being applied to treatment for a diagnosis of "Dysthymia".


Exhibit 1 contains the diagnosis and treatment plan, which contains DSM IV codes for all three psychological disorders, despite the fact that the diagnosis of "Cannabis Dependence" is contradicted by the  plain English of the treatment plan, which  refers to "substance use" rather than "abuse" or "dependence", and the fact that the defendant, when asked at the time the diagnosis was signed whether he thought he might suffer from "Borderline Personality Disorder," ridiculed the idea, not from false bravado but rather from confidence based on familiarity with the disorder based not only on clinical literature discussing the symptoms and behaviors associated with it, but from intimate involvement with a person diagnosed as suffering from the disorder.


  Respondent was encouraged by FCS to substitute his therapeutic self-medication with cannabis, which respondent had used with great success for 18 years as self-medication for stress management, with Prozac.  Prozac is a remarkably effective anti-depressant, which is safe in a majority of cases; however, in the defendent's case, like that of the .7% (1/140) of patients in the clinical trials for Prozac, it had effects detrimental to his stability, inducing states of hypomania.


    The defendent stated clearly in initiating counseling at FCS that he was seeking "someone to talk to," and received instead escalating intervention and interference in managing his life, culminating in a non-sensical proposal that he enter a drug rehab program which would treat two disorders from which he does not suffer, at a time when defendant was acutely physically ill.

Respondent was encouraged by FCS to escalate conflicts with his girlfriend; reprehensible tactics, such as "dumping all of her stuff on the street," were suggested to get her to move out.  Near the end of this relationship, Amari Meader amazed the defendant by stating that "you came here to get help throwing her (Susan Hamann) out."