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By Seven West Productions, LLC

Filed May 09, 2022 - Petition to unseal FOIA FBI

WRIT OF MANDAMUS; PETITION TO UNSEAL RECORDS
FOR FOIA FBI FILE REQUEST NUMBER 1334338-000 


Petitioner Tiwanda Lovelace brings this action against the U.S. Department of Justice and FBI to compel compliance with the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), Privacy Act, 5 U.S.C. § 552a (“Privacy Act”) and (Conspiracy Against Rights) 18, U.S.C., Section 241 and (Deprivation of Rights Under Color of Law) 18, U.S.C., Section 242. As grounds therefore, Petitioners allege as follows:


JURISDICTION AND VENUE


1. The Court has jurisdiction over this action pursuant to 5 U.S.C. § 552(a)(4)(B) and
28 U.S.C. § 1331.


2. Venue is proper in this district pursuant to 28 U.S.C. § 1391(e).


PARTIES

3. Petitioner Tiwanda Lovelace is a law-abiding private citizen residing in Las
Vegas, NV. who is also the daughter of Robert Heard (MDOC 112084), a man who was
convicted of killing a MI police officer, Stanley Rapaski and Bar owner, Cass Czerwinski.

4. Petitioner Lovelace is an online publisher who seeks to promote transparency,
integrity, and accountability in government and fidelity to the rule of law. As part of its mission, Petitioner requests records from federal agencies pursuant to FOIA. Petitioner analyzes the responses and disseminates its findings and the requested records to herself and the American public to inform them about “what their government is up to.” Petitioner Lovelace sought access to confirm and address concerns of unwarranted violation of privacy, unprovoked investigations, or any reason why l would be experiencing unexplained mail tampering, delays in telephone
connections, electronic and computer disturbances. Petitioner Lovelace is also trying to access reasons why the laws are never upheld when both, state and federal crimes are committed against the Petitioner and/or why my complaints or allegations combined with supporting legal documents, are dismissed, and ignored.


5. Respondent U.S. Department of Justice and FBI is an agency of the United States
government and is headquartered at 950 Pennsylvania Avenue, N.W., Washington, DC 20530. Respondent has possession, custody, and control of records to which Petitioner seeks access.


STATEMENT OF FACTS

6. On August 22, 2016, Petitioners jointly submitted a request to the Federal Bureau of Investigation (“FBI”), a component of Respondent (DOJ). Petitioner Tiwanda
Lovelace submitted the request under FOIA, and Petitioner Lovelace submitted the request under both FOIA and the Privacy Act on May 20, 2015.


7. Petitioner Lovelace sought access to any and all records concerning, regarding, or relating to herself. Such records include, but are not limited to, records of background checks of Tiwanda Lovelace, records of communications, contacts, or correspondence between Tiwanda Lovelace and employees, officials, or agents of the Federal Bureau of Investigation, and records of investigations concerning or regarding Tiwanda Lovelace as a victim.


8. On August 22, 2016, the letter from the US DOJ – FBI advised that under FOIPA, Title 5 U.S. Code. Section 552/552a there were (redactions) deletions made pursuant to
5 U.S.C. § 552(b)(6), 5 U.S.C. § (b)(7)(C), 5 U.S.C. § (b)(7)(D), 5 U.S.C. § (b)(7)(E) and 5
U.S.C. § 552a (j)(2). Upon receiving this request, the FBI sought to have the requested file request (FBI: 1334338-000), Sealed by Court Order on the basis of exemptions: 5 U.S.C. §552(b)(6) - Personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy; 5 U.S.C. § 552 (b)(7)(c) - could reasonably be expected to constitute an unwarranted invasion of personal privacy, and 5 U.S.C. § 552 (b)(7)(D) – could reasonably be expected to disclose the identity of confidential source, including a State, local or foreign agency or authority or any private institution which furnished information om a confidential basis, and, in the case of record or information compiled by a criminal law enforcement authority in the course of a criminal investigation or by an agency
conducting a lawful national security intelligence investigation, information furnished by a confidential source; and 5 U.S.C. § 552 (b)(7)(E) - would disclose techniques and procedures for law enforcement investigations or prosecutions or would disclose guidelines for law; and 5 U.S.C. § 552a (j)(2) – material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime or apprehend criminals. These exemptions indicate either an active investigation or undercover officer and/or informant, which means that this FBI file would span 35+ years ago for an individual without any federal arrest or
cases.


9. Petitioner has attached documents which clearly reflect federal crimes being
committed against her continually for a consistent thirty years; yet, there was no effort made to prevent, control, or reduce crime or apprehend criminals. Petitioner has attached documents which clearly demonstrate deprivation of privacy rights when mail tampering and delays are intercepted spanning thirty years, across multiple carriers. See Exhibits.


10. Petitioner Lovelace was subjected to abuse of power, intimidation, sexual
assault, mail tampering, illegal modifications and entries to her criminal background and other federal crimes that went unaddressed during the dates covered under the FBI file. With regards to exemption and 5 U.S.C. § 552 (b)(7)(D) – could reasonably be expected to disclose the identity of confidential source…Petitioner was never an informant. Petitioner contacted respondents and many governmental agencies for assistance with bullying from major entities but was denied at every turn. Petitioner asserts that her correspondences were most likely used in the respondent’s
alleged investigation. Petition is convinced that the respondents were able to achieve their intended goal or target because Petitioner was met with extreme bullying and referred to as a ‘Snitch’ or ‘Informant.’ Petitioner was exposed to violence, intimidation, threats and worse. Petitioner was never directly contacted by any officials regarding multiple state and federal crimes. Petitioner was left uninformed and unprotected. This FBI file indicates the timeframe for these events were covered in the FOIA FBI File that the respondents has had Sealed by Court Order. See Exhibits for intimidations and threats. The Respondents ‘alleged’ investigation results were made public because the petitioner was subjected to bullying by those associated with their intended target. Basically, Petitioner alleges that the Respondents use petitioner’s pleas for assistance in their own investigation, while refusing to acknowledge any and all criminal activity targeted towards petitioner. In fact, it is likely that petitioner was used as bait due to absolutely no direct communication. If Respondent claim ‘purposes for protection…,’ petitioner would have had direct communication with any law enforcement agencies that addressed unlawful,
criminal acts that petitioner was subjected to.


11. Plaintiff Lovelace has repeatedly contacted the DOJ, FBI AND AG Offices
regarding privacy violation concerns, mail-tampering and intimidation dating back to onset and up to 2022. If Respondent is claiming exemption 5 U.S.C. § 552a (j)(2) – material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime or apprehend criminals… Yet, Petitioner has had no arrest, nor any state or federal criminal in over thirty years to justify a 357-page FBI file. Meanwhile, multiple federal and state crimes have been committed against the petitioner.


12. On March 11, 2003, Petitioner Lovelace filed civil action (1: 03-MI-0053 and 1:
03-CV-0925) in the U.S. District Court, against Def. Dekalb Central Probation and the Dekalb County Police Dept. under 28 USC, 42 U.S.C. §1983, 28 U.S.C. § 2201 and 42 U.S.C. 1983 and 1988, 28 U.S.C. § 2680 (a) and (h), alleging violations of the Due Process and Equal Protection Clauses of the 14th Amendment; asserting a general “deprivation of rights.” (Docket Item #2 Section I - page(s) 1, 2 and Section II - page 2). I video recorded submitting original filings, but courts clerks modified plaintiff’s filing to remove reference to supporting documents. Plaintiff had to submit repeated requests to court for clerks to correct filings that clerks edited to remove
police as defendants, etc... The Petition for Judicial review was dismissed referencing no supporting documentation. It is a federal crime for clerks to modify filings for the benefit of police as defendants. The FBI were made aware, but Petitioner was never addressed with regards to any documents in support of allegations. Petitioner’s pleas for assistance with federal crimes being committed against her was deliberately dismissed and ignored, depriving petitioner of rights.


13. Petitioner Lovelace repeatedly contacted officials regarding the maintenance of
inaccurate and illegal entries were being maintained on the CJIS/GCIC criminal background records. As of the date of this petition, these inaccurate and misleading transmittals remain and have not been completely corrected. Petitioner Lovelace alleged that Dekalb County Police, acting under color of state law, caused various constitutional harms, and engaged in “willful misconduct… conscious indifference” by permitted misleading entries to remain and by failing to train and supervise its employees in the entry and maintenance of criminal history information in CJIS and GCIC. According to O.C.G.A. 17-10—(f), ‘Any order modifying a sentence which
is entered without notice and an opportunity for a hearing as provided shall be void.’ In Morrisey b. Brewer, 408 U.S. 471, 484 (1972) – ‘to the probationer, who is integrating himself (or herself) into a community, it is fundamentally unfair to be promised freedom for turning square corners with the State but to have the State retract that promise when nothing he or she has done legitimately warrants such an about face.’ Similarly, it is irrational for the State to conclude, in the absence of valid cause tracing to the probationer’s conduct, that warrants changing First Offender’s Act to Conviction. Thus, while the state can define the rules of punishment initially, choosing probation or imprisonment, the State cannot change the rules in the middle of the game. See Wood v. Georgia, 450 U.S. 261, 286-287 (1981) – A probation violation must therefore be such as to make it logical for the State to conclude that its initial decision to choose probation under the First Offender’s Act should now be abandoned. Refer to Attachment, ‘Plaintiff had no prior criminal record; that is, other than a dismissed domestic. In Wisconsin v. Constantineau, 400 U.S. 433 (1971), it invalidates a statutory scheme by which a person, without any opportunity for a hearing and rebuttal, could be labeled and barred from justice; the court noted
that governmental action was stigmatizing the individual’s reputation, honor and integrity; as in this case.


14. Petitioner has endured abuse of power under color of law by the deliberate
neglect of officials (up to and including the respondents). Prior to receiving the First Offender Act, Petitioner booked a flight from MI to turn herself into Dekalb County authorities on June 27, 1992. Instead of listing my voluntary surrender as a ‘Surrender,’ officials illegally added (2) two more charges. Petitioner has provided a copy of the court transcript which confirms that Lovelace flew to Georgia to address the charges from 1988. Petitioner has attached copies of instances where ‘blatant egregious abuses of power, under color of law’ is easily identified. See attached Exhibits. Respondents ignored repeated pleas for assistance in upholding federal laws regarding the deliberate illegal modifications to criminal record, modifications of request and documents. Respondents allowed and facilitated a conspiracy by officers to intimidate and retaliate for lawsuit against police and for other apparent reasons. Respondents facilitated and enabled those in association with their intended target to bully and intimidate.

15. As recent as 2020, Lovelace was subject to a criminal background for housing
which returned an alert of felony charges, without referencing the date of 30+ years ago and that it should have been listed under the First Offender Act. Alerting the apartment complex of felonious charges without specifying actual dates would generate a negative reaction and/or denial. Petitioner is consistently denied assistance with abuses of power under color of law; therefore, she feels corralled into homelessness with very little options when anyone can violate rights without fear of consequences or reprisal. Most companies do not offer opportunity to dispute criminal background checks. Petitioner was and continues to be harmed by willful
neglect and continues to be deprived of her right to FOA First Offender Act.
16. Respondent was notified that officials, without case or notice of hearing,
illegally modified petitioner Lovelace’s criminal background to change her First Offender Act to an actual felony conviction. Then on December 7, 2005, Dekalb County officials notified the US Dept. of Housing and Urban Development that there was an active warrant. See Exhibit. Although I was living in Dekalb after this illegally obtained warrant and they could have arrested me; yet, they opted to only take my housing…forcing me and my children into homelessness, repeatedly over the course of thirty years. This action combined with the modification of criminal background entry of a Felony Sentence for Shopping Cart Offense for Petitioner demonstrate ‘a combined effort’ deliberate and willful intent with full knowledge petitioner was
under supervision in MI. Petitioner has NEVER had any arrest for any Shopping Cart cases and this entry into the criminal record data base reflected this inaccurate and false charges demonstrate true intent to harm.

17. Petitioner admonishes that the warrant was used by officials in defense to allow
officials to change FOA Sentence (without adjudication of guilt) to a Felony Sentence. It stayed active on petitioner’s criminal background as a felony conviction for over 20 years, preventing housing and hindering employment opportunities.


18. Petitioner has provided a copy of this referenced warrant, wherein, Dekalb
officials state that Lovelace had absconded from supervision. However, petitioner has provided documentation from reporting agency that contradicts their alleged findings. Every time petitioner attempts to exercise her rights, she is faced with more abuse of power and absolutely no communication from those contacted to address deprivations.


19. Petitioner met with her Rep. Catherine Cortez- Masto office rep. Manuel Davilla
and provided documents in support of abuse of power under color of law and advised her staff member of intimidation and forced homelessness. I was advised that they would forward the materials and that they would see about securing my housing again. I never heard from them again, forcing me into more homelessness and deprivations.


20. Petitioner has recently (2022) filed an official complaint with the Ethics
committee. She has now lost her employment upon return of medical leave.


21. Petitioner has travelled the United States, seeking to exercise her rights to Life,
Liberty and Justice, only to be corralled into homelessness as punishment for fighting for her rights. Petitioner Lovelace has never had any drug addictions or criminal cases after her FOA (1988-1993) but she was forced to seek shelter accommodations in multiple cities across the U.S. Petitioner had employment rescinded due to the maintenance and illegally modified criminal background. For example, Lovelace has never been arrested for a shopping cart case but it is on my arrest record. Petitioner has attached copies of instances where ‘blatant egregious abuses of power, under color of law’ is easily identified. See attached Exhibits.


22. Petitioner walked into the Las Vegas FBI Field office with her documentation in
support of allegations of abuse of power, privacy violation and intimidation. In addition, petitioner Lovelace received a letter that was allegedly from the DOJ (see attached). This letter was sent first class mail from DOJ stating no interest in investigating the matter was unsigned, with incorrect zip code and was sent allegedly from D.C. was received in less than two days. It is impossible for a letter with the incorrect zip code to go from DC to NV in two days. Petitioner has attached copies of instances where ‘blatant egregious abuses of power, under color of law’ is
easily identified. See attached Exhibits.


23. Petitioner had a major music co-publishing contract, secured copyrights with
names of musical works that were on the top of music charts; yet Lovelace was refused any and all legal representation across multiple states. The only entities that can address crimes across multiple states is the DOJ/FBI; yet, when contacted…their response was to obtain a court ordered seal.


24. Petitioner began her online publishing to shed light on the atrocities that she has
faced but has been met with unfair trade practices and unfair competition for over a decade. Respondents referred to exemption 5 U.S.C. § 552a (j)(2) – material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime or apprehend criminals…however, supporting document show blatant unfair competition, unfair practice and intimidation. Petitioner was told by random individuals that her sharing her experience through her publications would not make a profit. Through the combined efforts of third-party seller on multiple platforms, petitioner was forced to compete with her own
publications ranking last. See exhibits where sellers had her publication for sale for $33,418.88 and another seller listed eBook for $0.78. Petitioner alleges these instances were retaliation and intimidation tactics used to induce hopelessness and ‘harm.’ Respondents were made aware of continued violations of law; yet, petitioner consistent received correspondences which denied any assistance. These exhibits confirm public knowledge of an allowed conspiracy to harm because clearly shows multiple sellers entertaining prices meant to induce harm. Petitioner has
no public social media following and has no celebrity status; yet, public records show constant mockery of business ventures that are related to exposing abuses of power and corruption.


25. While trying to establish her publishing business, Petitioner received a delivery
or receipt confirmation as if someone had placed an order on her eBook website but the actual items: ‘a sledgehammer and a wire cutter’ were listed as a bookstore purchase. Petitioner alleges this was intimidation and a threat. Petitioner has continued receiving threats and bullying that is meant to stop my attempts to seek assistance.


26. Petitioner Lovelace is not from the ‘streets’ and has no other options but to
continue to seek resolution through the courts. Petitioner Lovelace believe that her privacy has been violated to deter others from assisting with abuses of power, under color of law. The courts would have to agree that in order for anything to be blocked, there would have to be access and knowledge prior to events in order to intercept. Prior knowledge would explain mail tampering and email service delivery issues when seeking assistance. Petitioner has submitted a substantial number of convenient coincidences that when given access to the FBI file…this would provide clarification as to their knowledge and/or involvement. Likewise, by violating petitioners’ privacy these same officials behind abuses would be alerted when Petitioner would contact
others in position to assist. This would explain why Petitioner has never been able to obtain resolution. Petitioner can present evidence that her privacy is being violated for unlawful purposes. Petitioner alleges that Respondents would be in a position to counter any attempts to expose official abuses of power. bPetitioner is the daughter of a man convicted of killing a police office and yet, no officials find it odd that a US citizen would have a 357- page FBI file and consistent complaints filed with multiple governmental agencies that have gone unaddressed for decades?


27. There are too many federal crimes being committed across multiple state lines
blatantly for me not to have any communication with officials. Petitioner Lovelace has never a drug abuse history has no federal, felony or misdemeanor convictions that would merit a 357-page file; therefore, respondents should be ordered to release an unredacted FOIA FBI file AND be investigated for federal crimes that went unaddressed for decades.


28. Petitioner is an average citizen who was able to compile using public records the
list of documents below. If petitioner was able to compile this information without resources or assistance surely the FBI is fully aware and have opted to not uphold the laws and communicate directly with petitioner at some point in these 30 years of all of these federal crimes being committed. Respondents claim exemption 5 U.S.C. § 552a (j)(2) – material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime or apprehend criminals; yet, they refuse to review and address documents in support of allegations against violations of a conspiracy against rights for decades.


29. Petitioner has clearly shown that respondents has shown a deliberate, willful
indifference and willful neglect to uphold the laws for three decades. Petitioner has been humiliated degraded and deprived of all her human and civil rights in these matters.’ Petitioner begs the court to consider this information and assist an upholding the laws by providing her access to the information which they choose to not disclose. The public has a right to know that those in positions of power are not using that power for selfish or personal gains.


30. Throughout these three decades anybody that even attempts to assist is
discouraged illegally and through intimidation or bribery. 5 U.S.C. § 552a (j)(2) – material reporting investigative efforts pertaining to the enforcement of criminal law including efforts to prevent, control, or reduce crime or apprehend criminals.


31. Their investigative practices would appear to involve using citizens without
consideration, consent or knowledge to pursue their intended target(s). Their investigative practices would appear to involve using citizens request for assistance, complaints and allegations for their own purposes, without communication for decades. Petitioner has provided substantial documentation to establish petitioner has been targeted.


32. When petitioner seeks assistance, she is met with more bullying and pressure to
stop. when petitioner trying to maintain shelter and employment, she is met with external pressure to fight for rights or referred to as a pet or slave, and complacently accepting deprivations. Due to privacy violations and public knowledge, Petitioner has been pulled between the Respondents (who represents the system) and the part of the public that has been subjected to similar abuses…forcing petitioner to be subjected, repeatedly. The exhibits that involve the public’s participation in intimidation stems from their believing a ‘narrative’ provided to them by the system, while Respondents conceal the file from petitioner. It is public knowledge that the public is trained to frown on ‘informants’ or ‘Snitches’. What better way to
evade accountability and be entertained by abuses of power? Fighting for rights does not make an individual an informant!


33. As an African American female US citizen who can legally say that she has no
misdemeanors or felony convictions (state or federal), Petitioner is supposed to be able to exercise her civil and human rights to life, liberty, etc... I shouldn't have a 357-page FBI file.


COUNT 1
(Violation of FOIA, 5 U.S.C. § 552)

34. Petitioner reallege paragraphs 1 through 33 as if fully stated herein.

35. Respondent is unlawfully withholding records requested by Petitioners and this
FBI file was not sealed by court order until after Petitioner Lovelace requested a copy.

36. Respondent is unlawfully withholding and have redacted records requested by 
Petitioners pursuant FOIA and has had them Sealed by Court Order to hide.

37. Petitioners are being irreparably harmed by reason of Respondent’s
unlawful withholding of requested records by redacting, and Petitioners will continue to be irreparably harmed unless Respondent is compelled to conform its conduct to the requirements of the law.


38. Petitioner Lovelace is well aware that all officials are not untrustworthy;
however, in 30+ years of contacting representatives and our governmental agencies…I have been unable to locate anyone who would at a minimum review the documents in support of the many allegations. Petitioner is convinced that everywhere she seeks
assistance, there is intimidation and more abuse of power under color of law. Hopefully, this court will allow for the review of the file in question because petitioner has provided sufficient documentation to demonstrate that respondent is not being forthright in it’s decision to withhold the file that covers decades of abuse, through redaction.


COUNT 2
(Violation of Privacy Act, 5 U.S.C. § 552a)

39. Petitioner Lovelace paragraphs 1 through 38 as if fully stated herein.

40. Respondent is unreasonably refusing to comply with Petitioner Lovelace’s
request under the Privacy Act.

41. Petitioner Lovelace is being irreparably harmed by reason of Respondent’s 
unlawful withholding of requested records, and Petitioner Lovelace will continue to be irreparably harmed unless Respondent is compelled to conform its conduct to the
requirements of the law.

42. Respondent placed Petitioner Lovelace in extreme danger without her
knowledge or consent and now has petitioned the court to Seal their illegal actions.
Respondents engaged in willful deliberate neglect to uphold the laws on behalf of Petitioner.

43. Petitioner Lovelace has never worked with law enforcement on any level other
than to seek assistance with addressing the 30+ years of bullying wherein she has been forced into homelessness and denied employment due to illegal modification and maintenance of inaccurate and misleading transmittals designed to degrade and deprive rights to the daughter of a man convicted of killing a police officer.


44. Petitioner is not completely convinced if the initial cause for deliberate
deprivation of rights is immediately connected to her brief stint within the music industry or her father’s conviction history or all of the above; however, Lovelace can produce a multitude of documents in support of allegations (at a minimum) which demonstrate questionable behavior…surely, the DOJ/FBI has the resources and all can assume that the Respondents are aware of each of these allegations. Lovelace has never been directly addressed regarding copyright infringements, publishing and music royalties, blatant civil and human rights allegations or anything. I submitted a complaint of civil rights to the Dept of Civil rights against the FBI; yet, they referred me back to the FBI.


45. During this copyright infringements, Lovelace was working with her copublishing company, and they sent her a letter addressing her allegations of copyright
infringements with the mail stamped or postmarked with the words, “comics” on a serious matter involving millions of dollars in music royalties on a top can recording. The USPS or post office is under Federal jurisdiction, Respondents were made aware, yet, Petitioner never received no direct communication at any point while suffering from these violations of federal crimes of intimidation.


46. Petitioner has never experienced any alcohol or drug abuse or mental health
concerns or issues. Petitioner stayed out of trouble with the law after being given the FOA First Offender Act but was essentially deprived of all rights, publicly and under color of law.


47. Petitioner Lovelace has a right to life, liberty and justice but has been denied
any and all recourse covering three industries over 30+ years of deprivation of rights, under color of law. By requesting that the FOIA FBI file, Lovelace would definitely be able to clear her name and to denounce any claims that she worked with the FBI as an Informant. Lovelace has been subject to persecution from whoever it was that they were investigating at the start. Lovelace contends that she (through her work) may have been involuntarily used by officials, without her knowledge than she was discarded. Lovelace has been bullied for decades, while all officials disregard her request for assistance in all matters (under color of law) and ignore bullying from officials across multiple states. 


Count 3
(Violation of Conspiracy Against Rights 18, U.S.C., Section 241)

48. Petitioner Lovelace paragraphs 1 through 47 as if fully stated herein.


49. Respondent place Petitioner Lovelace in extreme danger without her
knowledge or consent and now has petitioned the court to seal their illegal actions.
Respondents engaged in willful deliberate neglect to uphold the laws on behalf of Petitioner.


50. This statute makes it unlawful for two or more persons to conspire to injure,
oppress, threaten, or intimidate any person of any state, territory or district in the free exercise or enjoyment of any right or privilege secured to him/her by the Constitution or the laws of the United States, (or because of his/her having exercised the same).


51. The statute further makes it unlawful for two or more persons to go in
disguise…’ with the intent to prevent or hinder his/her free exercise or enjoyment of any rights so secured.


52. Petitioner Lovelace is being irreparably harmed by reason of Respondent’s
unlawful withholding of requested records, and Petitioner Lovelace will continue to be irreparably harmed unless Respondent is compelled to conform its conduct to the
requirements of the law.

53. Petitioner has documentation that confirms mail, emails and other 
correspondences regarding numerous complaints against official’s misconduct have beenblocked, hindered and tampered with. See Exhibits.


54. Petitioner Lovelace has provided copies of printouts which clearly demonstrate
the officials have deliberately sought to harm by illegally maintaining false arrest entries and modifying my criminal background. In one instance, officials placed an image of an unknown African American Male with her name underneath. Clearly, Lovelace is not a male. Petitioner has been presented as aggressive in pursuing resolution which has lead to harmful accusations that she is masculine or as an insult. These events were used to belittle, demean and to induce duress and harass petitioner. See attachment.


Count 4
(Violation of Deprivation of Rights Under Color of Law 18, U.S.C., Section 242)

55. Petitioner Lovelace paragraphs 1 through 54 as if fully stated herein.

56. By depriving Petitioner the ability to benefit from First Offender Act that the
Court had Ruled, Petitioner was deprived of hat right to “…honestly state that Petitioner was adjudicated without guilt and has no felony convictions for well over (30) years. Instead, Petitioner suffered continued loss of employment and housing opportunities. Petitioner Lovelace has a right to life, liberty and justice but has been denied any and all recourse covering three industries over 30+ years of deprivation of rights, under color of law.


57. Petitioner Lovelace is being irreparably harmed by reason of Respondent’s
unlawful withholding of requested records, and Petitioner Lovelace will continue to be irreparably harmed unless Respondent is compelled to conform its conduct to the
requirements of the law.


WHEREFORE, Petitioners respectfully request that the Court: (1) unseal FOIPA
Request: 1334338-000 and order Respondent to conduct a search for any and all records responsive to Petitioners’ request and demonstrate that it employed search methods reasonably likely to lead to the discovery of records responsive to Petitioners’ request; (2) order Respondent to produce unredacted and unsealed, by a date certain, any and all non-exempt records responsive to Petitioners’ request and a Vaughn index of any responsive records withheld under claim of exemption; (3) enjoin Respondent from continuing to withhold any and all non-exempt records responsive to Petitioners’ request; (4) grant Petitioners an award of attorneys’ fees and other litigation costs reasonably incurred in this action pursuant to 5 U.S.C. § 552(a)(4)(E) and 5 U.S.C. § 552a(g)(3)(B); and (5) grant Petitioner a hearing to ensure the Courts has received complete filings and (6) grant Petitioners such other relief as the Court deems just and proper.


Dated: May 5, 2022 Respectfully submitted,
Tiwanda Lovelace
2750 W. Wigwam Ave., Apt. 2214
Las Vegas, NV 89123
(253) 457-1647
Petitioner

Exhibits 1-97

This is a copy of Exhibits for 2022 Writ of Mandamus / Petition to Unseal FOIPA FBI 357-page file for a U.S. Citizen who is without any misdemeanors or felony sentences and absolutely no federal arrest.  Petitioner Lovelace was subjected to abuse of power, intimidation, sexual assault, mail tampering, illegal modifications and entries to her criminal background and other federal crimes that went unaddressed during the dates covered under the FBI file. Basically, Petitioner alleges that the Respondents use petitioner’s pleas for assistance in their own investigation, while refusing to acknowledge any and all criminal activity targeted towards petitioner. In fact, it is likely that petitioner was used as bait due to absolutely no direct communication.

SUMMARY of events

Proof of Corruption and Misconduct

BIO | Email Website | Twitter YouTube | Licensing Rights Available | Donate

BACKGROUND

My name is Tiwanda Lovelace and I am the daughter of a man convicted of allegedly killing a police officer. I have been subjected to years of unaddressed deprivations. I declare and attest to the information provided within and at the following links are true and correct! The supporting documentation can be found https://mega.nz/#F!HjolFYiD!6g220woQqxtU1B6lYQMkFw.

I have had no peace and in 2021, the use of technology to harass and induce harm has not changed, nor subsided. I have been harassed, subjected to illegal privacy violations and deprivation of all rights and suffered wrongful vilification, for decades without any shield! Let me be clear, we do not need more laws. We need the laws to be enforced for ALL, equally. 

Per the FBI file, their Involvement should have ended upon my return to GA but it continued for years, without justification. If the FBI's presence was lawful, why not communicate or assist with the enforcement of laws to uphold human and civil rights? These dates that have been sealed by court order were consistent with events  and allegations of violations.

Instead of preventing the numerous allegations of rape, deprivation, degradation and rights violation, they did nothing but watch! When these allegations and concerns of unlawful privacy violations led to my request for a copy of my FBI file under F.O.I.A. (Freedom of Information Act).

The FBI responded by getting a Court Order to Seal...WHY? In decades of blatant disregard for human and civil rights, the only actions were to 'Under color of Law' cover up and hide their knowledge of atrocities...

I have traveled domestic and abroad, seeking assistance in stopping the abuse of power. However, as an unaligned and sacrificed African American female, (facing all of the 'Isms' of this world), I have received absolutely NO SUPPORT from any groups, organizations or entities.

Maybe your organizations will have better luck utilizing the supporting documentation that exposes decades of willful, corruption, deliberate deprivation of rights and blatant abuse of power! 

What was allowed to be implemented on me was not only allowed but encouraged through false narratives presented to the public and due to abuse of power, across multiple industries! I have been harassed, nonstop for thirty years by random strangers, co-workers and the general public to the point that I have no choice. 

I am judged by what others have used their power to illegally execute upon me. Clearly, I cannot fight the streets, gangs, officials, police and FBI...especially, without any support. They control the narratives and that is how an individual is kept publicly, enslaved.

Without support, all I can do is share my experiences, WORLDWIDE! A joint effort is the only way to address these atrocities!

I have been harassed, nonstop for thirty years by random strangers, co-workers and the general public to the point that I have no choice. Without support, all I can do is share my experiences, WORLDWIDE! A joint effort is the only way to address these atrocities!  

All rights reserved, REVOKED for worldwide usage. The information on this website that exposes and provides uncontested proof of corruption may be reproduced for non-commercial use in any form or by electronic or mechanical means, including information storage or retrieval system, without permission from the publisher, by a reviewer who may quote passages.

Full Files proving corruption and misconduct

http://musicbizadirtygame.blogspot.com/

https://mega.nz/#F!HjolFYiD!6g220woQqxtU1B6lYQMkFw 

https://mega.nz/#F!HjolFYiD!6g220woQqxtU1B6lYQMkFw

https://drive.google.com/…/1Eiy-Y-4u9HeMNaRgUC17c-FMv8…/view

At the very least, we owe it to the future to equip them for the world that they will inherit! Maybe the future can do what those in positions for the last three decades failed to do...Acknowledge ALL and assist when Citizens ask for help AND provide concrete proof!

Abuse of Power, Corruption and Misconduct, Facilitates Modern-day Slavery!

No one has ever discussed the abuses under color of law, privacy violations or addressed the many atrocities that I have been forced to endure. They just gave the public reasons, justifications, allowed violence, slander and misinformation to sway public opinion in support of continued deprivations.

The FBI Involvement should have ended upon my return to GA but it continued for years, without justification. If the FBI's presence was lawful, why not communicate or assist with the enforcement of laws to uphold human and civil rights?

Instead of preventing the numerous allegations of rape, deprivation, degradation and rights violation, they did nothing but watch! When these allegations and concerns of unlawful privacy violations led to my request for a copy of my FBI file under FOIA (Freedom of Information Act).

The FBI responded by getting a Court Order to Seal...WHY? In decades of blatant disregard for human and civil rights, the only actions were to 'Under color of Law' cover up and hide their knowledge of atrocities...

Was I used (without knowledge, as bait? Were all of the forced atrocities, deprivation and dehumanization some kind of revenge for the alleged murder of an officer and popular well--connected individual?

There is proof of mail tampering, blatant obstruction and judicial misconduct across multiple states.

There has been decades of deprivations across multiple states, covering multiple industries - Music Industry, Book Publishing and Legal System! Deliberately deprived of all opportunities and rights!

___________

My father, Robert Heard currently serving a life sentence in Michigan for allegedly murdering a police officer – Stanley Rapaski and bar owner – Cass Czerwinski (also referred to as Casimir A. Czerwinski, Cass Czerwinski.

I wonder if Cass Czerwinski, the bar owner and his family were influential, powerful people that could keep their names out of the press. I am still researching both parties; however, I can’t help but wonder if Czerwinski is related to Democratic Representative Joseph C. Czerwinski.

As the daughter of man convicted of allegedly killing a police officer, I have been subjected to years of unaddressed deprivations.

I have been deprived of all rights to seek justice and denied basic needs. Blatant proof of  abuse of power and deprivation has never even been addressed; instead, they are dismissed. Due to the entities involved, when I seek assistance these entities use their positions, influence and power ‘under color of law’ to hinder.

I have never had any issues or history with mental illness or drug abuse. I have never been some hardened criminal, but my background is managed by those who I have accused of acting ‘under color of law.’ Due to inaction and willful deliberate indifference, this has made me easy prey for those who have been negatively impacted by this corrupt ‘network’ or ‘system’ operating with impunity. No one should be forced to live without any shield against corruption. I was told that I should kill myself but I refuse. The documentation speaks for itself.

I am seeking to exercise my rights as a citizen, so, that my dignity can be restored. I am requesting help to unseal my FBI File because it was not sealed until I asked for a copy.

All proof and documents are in support of allegations listed below:

  • While ‘under color of law’ Officials modified CJIS/GCIC criminal background without a hearing or cause on a (FOA) First Offender sentencing (although subject was reporting as directed by court under the First Offender Act.

  •  Officials used illegally obtained warrant to seize housing and repeated hindered employment. 

  • Plaintiff filed a second lawsuit against a police agency but was met with blatant obstruction and intimidation.

  •  There is proof of mail tampering, blatant obstruction and judicial misconduct across multiple states. 

  • Plaintiff’s court filings were illegally modified, judges were switched without cause prior to summary judgment ruling which confirms blatant obstruction and deprivation of rights.

  • Under the FOIA and due to privacy violations, plaintiff requested a copy of F.B.I. files on herself and others. There were 221 pages of 357 pages of the F.B.I. file that were questionably SEALED BY COURT ORDER, just prior to request for file.

There has been no direct communication; wherein, the facts and proof of blatant, deliberate deprivation and willful indifference and neglect has been addressed.

These are just a few of the many allegations provided that can be substantiated with an multitude of supporting documentation. Read online the Full unedited and modified Publishers Release! Maybe I can get the right person to read it so that this deprivation, degradation, dehumanization and madness can stop! #Invisible Judicial Misconduct Exposed Pages: 83 .pdf 

Full Files proving corruption and misconduct

https://mega.nz/#F!HjolFYiD!6g220woQqxtU1B6lYQMkFw


https://drive.google.com/…/1Eiy-Y-4u9HeMNaRgUC17c-FMv8…/view 

BOOK LINKS- Download Books on  Amazon or Google Play

INVISIBLE: JUDICIAL MISCONDUCT EXPOSED! Pages: 83

MUSIC BUSINESS: IT'S A DIRTY GAME! Pages: 417

BIO | Email Website | Twitter | YouTube | Licensing Rights Available

Copyright © 2013 Created and Written by Tiwanda ‘Ne Ne’ Lovelace All rights reserved.

No part of this blog or books may be reproduced in any form or by electronic or mechanical means, including information storage or retrieval system, without permission in writing from the publisher, except by a reviewer who may quote brief passages.

Video Proof found at - https://vimeo.com/286729911

These videos are intended to provoke thought and inspire change in how bullying 'under color of law' by officials and those in power truly affects its victims. These videos also address its impact on future generations. These videos are intended to provoke thought and inspire change in how bullying 'under color of law' by officials and those in power truly affects its victims. This video also addresses its impact on future generations. 

Show your support: Donate using Zelle to tiwandalovelace@gmail.com

 

BIO

 

Proof can be found in videos available at my websites or by contacting me. (Videos are difficult for others to modify). Email: tiwanda@7westpublishing.com or +1 (702) 860-0116 or +1 (702) 900-4087.

I feel obligated to utilize social media due to decisions that are being made without direct communication based on false information provided by those who gain from deprivation of civil and human rights violations.

My website and blogs provide more information, I have been asking for help for over 30 years but due to entities involved, I have received no assistance and no direct communication.

I am commonly referred to as a pet, slave and worse for decades. Visit: http://musicbizadirtygame.blogspot.com/ and https://exercisingmyright.wordpress.com

The statutes do not apply in criminal civil rights violations involving the use of intimidation or threat of force and obstruction... Law enforcement misconduct (especially, acts committed under 'color of law,' blatant obstruction of justice, deliberate willful neglect, etc...). 

I declare that the information provided is true and correct. 

Supporting docs - 26 pages: 

https://drive.google.com/file/d/0BzFntWihlRZIdlc2dmRzNG1PQWc/view

Legal Misconduct:

https://drive.google.com/file/d/0Bxyj65ly7-H9WVB3Vkc3TFh3aU0/view and https://drive.google.com/file/d/0B_GhVOC4dlH0VVFMWVJWd0szbG8/view

Full General Request Letter:

https://docs.google.com/document/d/1d1OBMP4FPgP3DsCXiPlYYTICyrawuJ3p3dBfm4P9Rks/view

Tiwanda Lovelace

Proof can be found in videos available at my websites or by contacting me. (Videos are difficult for others to modify).

Email: tiwanda@7westpublishing.com or +1 (702) 860-0116 or +1 (702) 900-4087.

Thank you for any assistance provided,

Tiwanda Lovelace

BACKGROUND

Although the unethical practices are not limited to any single industry, even after providing solid evidence of unethical business practices, secured copyrights in response to copyright infringements and contracts, the standard response was to attempt to discredit, induce suicide and to intimidate. When you attempt to exercise your rights to seek justice through the courts, you face deliberate deprivation of rights, judicial misconduct and obstruction.

The entire process facilitates betrayal, initiates competition among its writers/producers and battles for royalties. If you manage to survive, the aforementioned is followed by some subhuman offer consisting of less than slave wages, meant to minimize the damage and avoid true accountability.

These titles are presented through this artist/writer’s eyes while experiencing multiple tragedies and events. Emotionally charged, this title clearly expresses the pain and anger of being betrayed, sacrificed and scorned. Inside, are the actual documentation and files used to demonstrate some of the tactics used to steal artist lives, deny rights and enslave the artist. This title is compiled using personal journals, public records, contracts, copyrights and other documentation which demonstrates how it is allowed to continue.

It is through these titles that Lovelace has an opportunity to shed light on the tactics that are used to deprive rights, manipulate events which are used to facilitate public support. These publications provide detailed proof of corruption and collusion.

Learn how every resource and outlet is used in an effort to initiate hardship on those who insist on exercising their rights while discouraging their desire to seek resolution as if to say, 'Let it go!' 'We do this to everyone so there is no hope...'

Learn the entire process which demonstrates egregious intent to influence a sense of hopelessness.

When the smell of violence was fresh and 'street justice' was being used inflict further damage, the initial response from professionals (both, legal and official) was, "(We) can't help you..." These events cover thirty years of willful, deliberate civil and criminal violations used to cover up atrocities.

These events cover thirty years of willful, deliberate civil and criminal violations (which were used to cover up atrocities). These titles were initiated from actual legal battles involving an Artist/Songwriter’s personal experiences with major music publisher’s. Proof is derived from actual court cases involving copyright infringements, breach of contracts and ‘obstruction of justice’ events.

It is through these titles that Lovelace has an opportunity to shed light on the tactics that are used to deprive rights, manipulate events which are used to facilitate public support. These publications provide detailed proof of corruption and collusion.

Usually, when a business idea conflicts with the goals of a major competitor, those ideas rarely see the light of day. Even when an idea can be extremely beneficial to many, they face great opposition and are widely rejected without consideration to the good that it can bring.

Unfortunately, it has also become customary in business to vilify, discredit and deter support for any individual who threatens or interferes with ‘big business’ and its profits. In competition, sometimes there is the use malicious means to gain an unfair advantage; such as, making a direct attack against a competitor or misleading the public to the detriment of a competitor.

Whether it is by blocking a website with unnecessary warnings, redirecting links or giving away unedited copies of publications...these tactics can only be successful when implemented against unprotected individuals and small businesses. In these cases, it is imperative to think outside of the box or in this case, everywhere. Especially when you have a universal product.

Samples of publications - https://drive.google.com/open?id=1FZgo0D1fgb2RH2hckICMmK1AiXYMRZVV

By offering our program in your region, we are able ensure that future generations across the globe will have a chance to utilize our program to make well-informed decisions regarding their career path. I'd like to work with multiple organizations and groups to offer this program for your aspiring youth. For the Love of Music! 

Please take a moment to review information on our products and watch our videos on YouTube.

I am excited to launch this program in your region so please do not hesitate to contact me.

Thank you for your consideration,

Tiwanda Lovelace,

Seven West Productions, LLC

Regional Licensing Rights Available from SWP, LLC - https://youtu.be/Won28YEZ8KM

Don’t miss your opportunity to share in our global project!

SHOP OUR ONLINE PRODUCTS - 

Downloads are available at AMAZON or Google Play! Also, available in French and Spanish AMAZON or Google Play!

Donations are accepted using Zelle to - tiwandalovelace@gmail.com

Your donations support our efforts in seeking justice and assist with shining the light on many atrocities.

BIO | Email Website | Twitter | YouTube | Licensing Rights Available | Donate

Request for Legal Assistance

Although I have a letter from DOC Central Probation confirming adjudication without guilt, upholding FOA First Offender Act completion. My CJIS/GCIC criminal background has not been corrected and updated. 

The Dekalb public defender’s offices provided assistance in receiving the First Offender Act in 1992. The Dekalb public defender’s offices helped quash the illegally obtained warrant and helped close the case without adjudication of guilt under the FOA-First Offender Act.

I have a letter showing that this Case was closed without adjudication of guilt under First Offender Act O.C.G.A. a42-8-60 but officers have not corrected and updated GCIC and CJIS.  This letter should have generated a GCIC/ CJIS update at least 3 of the 5 Arrest or Received and removal of conviction from original case no. Case: 136470 / 89CR2414.

I have been attempting to have my illegally modified GCIC and CJIS updated and corrected. GCIC Entries 3-5 are from the same case number – 136470; however, they are entered as different charges and arrest. Although each of the entries were well before and included (same case number) under FOA and there has been no criminal history, my criminal background has not been corrected or updated.

I failed to mention that I am the daughter of man convicted of allegedly killing a police officer has been subjected to years of unaddressed deprivations. I am not asking for your offices to take on my plight to fight officials. I am only requesting assistance in clearing my illegally modified criminal background. Basically, although I have received adjudication without guilt under the FOA, for over 20 years I have been deprived of employment opportunities, housing and the ability to travel. I am unable to maintain employment, so I have no income to cover cost for Request to Restrict Arrest Records or pay a lawyer.

The officers presented a warrant stating that I had absconded when I was reporting as directed, without notice of hearing. They used this illegally obtained warrant to modify my FOA sentence to conviction, without cause or notice. After decades, The Dekalb public defender’s offices helped get the illegally obtained warrant quashed.

I have been deprived of all rights to seek justice and denied basic needs. Blatant proof of abuse of power and deprivation has never even been addressed; instead, they are dismissed. Due to the entities involved, when I seek assistance these entities use their positions, influence and power ‘under color of law’ to hinder. Files are available at: Dekalb Georgia or click the following link - https://drive.google.com/open?id=1vQ6apCx2d7gQjRRlG-_r_JZWv9LcI8JQ.

G.C.I.C AND C.J.I.S. shows that Lovelace’s First Offender Act was changed to Conviction, although no sentence should be modified without prior notification to all parties and hearings on the matter. Refer to Inter-State Case Report from Michigan Probation Office. No contact was made, and no notice served.

I filed a lawsuit against the police but was met with obstruction and intimidation. Lovelace v. Dekalb County Police 1:03-CV-00925  - JTC (judges switched without cause to WSD). See Lawsuit: https://drive.google.com/file/d/0Bxyj65ly7-H9X2R5Y2oxdXhMWTg/view?usp=sharing

Would you be willing to assist in the removal of dismissed arrest and update of GCIC / CJIS?

I have completed the application for assistance through Public Defenders office.

Thank you for any assistance,

Tiwanda Lovelace

P.S. This is additional information that summarizes situation and clarifies questionable inaction.

I am not a lawyer. I am trying to be heard by someone who can properly address.

Background (excerpt from Lawsuit that was met with obstruction)

According to O.C.G.A. 17-10—(f), ‘Any order modifying a sentence which is entered without notice and an opportunity for a hearing as provided shall be void.’ In Morrisey b. Brewer, 408 U.S. 471, 484 (1972) – ‘to the probationer, who is integrating himself (or herself) into a community, it is fundamentally unfair to be promised freedom for turning square corners with the State but to have the State retract that promise when nothing he or she has done legitimately warrants such an about face.’ Similarly, it is irrational for the State to conclude, in the absence of valid cause tracing to the probationer’s conduct, that warrants changing First Offender’s Act to Conviction. Thus, while the state can define the rules of punishment initially, choosing probation or imprisonment, the State cannot change the rules in the middle of the game. See Wood v. Georgia, 450 U.S. 261, 286-287 (1981) – A probation violation must therefore be such as to make it logical for the State to conclude that it’s initial decision to choose probation under the First Offender’s Act should now be abandoned. Refer to Attachment, ‘Plaintiff had no prior criminal record; that is, other than a dismissed domestic.

G.C.I.C AND C.J.I.S., both receives and share information submitted and provided by local authorities, such as police and sheriffs. Department employees are trained and instructed on the validation process to ensure that only accurate, valid information is maintained; however, for the last (10) ten years, obviously questionable information has been entered and allowed to remain on Lovelace’s G.C.I.C AND C.J.I.S. reports.

G.C.I.C AND C.J.I.S. records reflect multiple arrest and repeated offenses and in fact provides misleading transmittals when 4 of the 5 items listed are in reference to the same original First Offenders Act offense. The Agency Case: 136470, is the same for 3 of the offense but put under various names. Please note that No. 5 is dated the day that I turned myself into police from original incident for which I was given the First Offender Act. 

Date and charges are inaccurate and/or inaccurately presented. The CJIS in comparison with actual facts shows bias and/or strong implications of bias in my quest to exercise my rights to life and liberty. I am repeatedly impeded by Defendants actions and inaction, which clearly demonstrates malice, vindictiveness, intolerance and prejudice on the part of authorities.

In this case, a Georgia Probation Officer, (without attempt or service of notification of hearing, etc…) presented a violation report to the courts on a probationer whom he knew was reporting in all aspects according to sentencing order. Probation officer knew was reporting in all aspects according to sentencing order. Probation officer knew that Michigan Probation Office has accepted case for supervision and that Lovelace was reporting as directed by courts.

In Wisconsin v. Constantineau, 400 U.S. 433 (1971), it invalidates a statutory scheme by which a person, without any opportunity for a hearing and rebuttal, could be labeled and barred from justice; the court noted that governmental action was stigmatizing the individual’s reputation, honor and integrity; as in this case.

Lovelace was not avoiding service or evading supervision in that she was reporting as directed; hence, Lovelace could have been served with notice either by or through Michigan Probation office or directly since her address was on files. Each of the charges listed were for same incident. I left the state of Ga but returned 1992/06/27 to turn myself in. The police rearrested me as if I had been caught committing another crime; however, they dismissed the groundless charges, but arrest stayed. While awaiting court, police took me out of holding and re-arrested me again, but charges were dismissed.

I have attached documents in support of allegations. I have a letter showing that this Case was closed without adjudication of guilt under First Offender Act O.C.G.A. a42-8-60.  This letter should have generated an GCIC/ CJIS update and removal of at least 3 of the 5 Arrest or Received from original case no. Case: 136470 / 89CR2414.

Every time I attempt to leave the country, I am met with scrutiny based on this background. There were no other offenses committed after First Offender Act.

Would you be willing to assist in the removal of dismissed arrest and update of GCIC / CJIS?

 

Thank you for any assistance,