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[Bradley Tyler Burns / Central Intelligence Agency Legal Department VSOP] [401 Courthouse Square] [Alexandria, Virginia, USA] [ciabradleyburns@gmail.com] [702.773.4529] [03/10/2025] Clerk of the Court [Eastern District Of Alexandria Virginia] [401 Courthouse Square] [Alexandria, Virginia, USA] RE: Notice of Malpractice Lawsuit Against the University of Kentucky Psychiatric Department Plaintiffs: [Bradley Tyler Burns] [Gary Smith III, if any] Defendant: University of Kentucky, Department of Psychiatry [245 Fountain Ct, Lexington, KY 40509] Case No.: [121-po-588] COMPLAINT FOR MALPRACTICE AND MEDICARE FRAUD INTRODUCTION This is a civil action for medical malpractice and fraud against the University of Kentucky's Psychiatric Department. Plaintiffs allege that the University engaged in grossly negligent practices resulting in severe harm, including the wrongful diagnosis of patients and dual-booking that defrauded Medicare, leading to the loss of lives and countless emotional and financial damages. PARTIES Plaintiff [Bradley Tyler Burns/ Chief Prosecutor CIA] is a resident of [Clark, Las Vegas, Nevada] and has standing to sue in this jurisdiction. [Gary Smith III, Austin, Texas] Defendant, the University of Kentucky, Department of Psychiatry, is located at [245 Fountain Ct, Lexington, KY 40509] and is responsible for psychiatric treatment and care provided to its patients. JURISDICTION AND VENUE Jurisdiction is proper in this Court as the conduct giving rise to this action occurred within this jurisdiction, and the parties reside or are deemed residents within this jurisdiction. Venue is appropriate as all relevant transactions, actions, and occurrences giving rise to this Complaint took place within the jurisdiction of this Court. FACTUAL ALLEGATIONS Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein. Plaintiffs allege that the University of Kentucky Psychiatric Department misdiagnosed patients with severe psychiatric disorders without appropriate clinical evaluations. Numerous complaints from both patients and families noted inconsistencies in diagnoses, leading to improper treatments, therapeutic mismanagement, and exacerbation of existing conditions. Furthermore, the Department was found engaging in dual-booking practices—scheduling multiple patients for appointments at the same time—resulting in a failure to provide adequate care and attention to vulnerable individuals. Evidence indicates that a number of patients died as a direct result of the misdiagnoses and subsequent lack of appropriate treatment. Investigations into the Psychiatric Department also revealed fraudulent billing practices, filing claims to Medicare for services not rendered and artificially inflating treatment costs. As a result, this fraud has resulted in millions of dollars in wrongful payments to the University. The actions of the Defendant created additional emotional turmoil for the families and contributed to the loss of lives that could have otherwise been prevented. COUNT I: MEDICAL MALPRACTICE Plaintiffs restate and incorporate all preceding paragraphs. The Defendant had a duty to provide care that meets accepted standards in psychiatric treatment. Breaching this duty, the Defendant misdiagnosed patients and failed to conduct adequate evaluations, which constitutes gross negligence. As a direct result of this negligence, Plaintiffs have suffered severe emotional, psychological, and financial harm, including the loss of loved ones. COUNT II: FRAUD Plaintiffs restate and incorporate all preceding paragraphs. The Defendant knowingly engaged in fraudulent billing practices, submitting false claims to Medicare for services not rendered, resulting in financial loss to the government and directly impacting the quality of care patients received. As a direct and proximate result of these fraudulent activities, Plaintiffs and the deceased victims’ families have suffered economic and non-economic damages. PRAYER FOR RELIEF WHEREFORE, Plaintiffs pray that this Court: A. Award damages in excess of [specify an amount], including but not limited to compensation for medical expenses, lost wages, wrongful death, emotional distress, and punitive damages; B. Order a full accounting of all fraudulent claims made against Medicare and impose sanctions for unlawful actions; C. Grant any other relief the Court deems just and proper. JURY DEMAND Plaintiffs demand a trial by jury on all issues so triable. Respectfully submitted, [Bradley Tyler Burns & Gary Smith III - Central Intelligence Agency Legal Department VSOP]
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IN THE [Eastern District Of Alexandria] OF [Central Intelligence Agency Jurisdiction] [121-po-588] [Bradley Tyler Burns / Chief Prosecutor CIA], Plaintiff, v. KENTUCKY DEPARTMENT OF MOTOR VEHICLES, Defendant. REQUEST FOR INJUNCTION TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW the Plaintiff, [Bradley Tyler Burns / Gary Smith Representing Central Intelligence Agency], and respectfully represents unto the Court as follows: 1. PARTIES AND JURISDICTION a. Plaintiff, [Bradley Tyler Burns / Gary Smith Representing Central Intelligence Agency], is a resident of [Lexington, Fayette, Kentucky & Las Vegas, Nevada]. b. Defendant, Kentucky Department of Motor Vehicles ("KDMT"), is an agency of the Commonwealth of Kentucky responsible for vehicle registration and regulation. 2. FACTUAL BACKGROUND a. Plaintiff is an owner/operator of a vehicle registered with KDMT,DOT, with over 30 registered work vehicles in the county of question. b. It has come to the attention of the Plaintiff that the KDMT has failed to report or accurately account for over 500,000+ miles associated with the operational use of vehicles within its jurisdiction. c. As a result of these unreported miles, there is a substantial discrepancy in the assessment and collection of gas taxes owed to the Commonwealth of Kentucky, which has caused economic harm to the Plaintiff and other registered vehicle owners. 3. GROUNDS FOR INJUNCTION a. Plaintiff asserts that this failure to report has resulted in a direct economic impact on registered vehicle owners, leading to financial losses and potential penalties. b. The actions of the Defendant are arbitrary, capricious, and contrary to the statutory obligations of KDMT under Kentucky law. c. Injury to the Plaintiff is imminent, and without intervention from the Court, Plaintiff and other affected parties will continue to face financial detriment. 4. REQUEST FOR INJUNCTIVE RELIEF WHEREFORE, Plaintiff respectfully requests that this Honorable Court issue a temporary and permanent injunction against the Kentucky Department of Motor Vehicles, ordering the following: a. Immediate cessation of all operations related to vehicle mile reporting until a satisfactory resolution is reached. b. A thorough review and accurate reporting of all miles associated with registered vehicles in Kentucky. c. A comprehensive audit of gas tax collections and assessments related to the unreported miles. d. Any other relief the Court deems just and proper. DATED this [09] day of [03], [2025]. [Bradley Tyler Burns] [401 Courthouse Square] [Alexandria, Virginia, USA] [702.773.4529] [ciabradleyburns@gmail.com] Attorney for Plaintiff (if applicable): [Gary Smith III] [Smith Solutions LLC] [gary@smithsolutions.us] CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served upon the Defendant by [method of service] on this [Date] day of [Month], [Year]. [Bradley Tyler Burns] [Chief Prosecutor CIA]
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IN THE [Eastern District Of Virginia] AGAINST THE STATE OF KENTUCKY [Bradley Tyler Burns / Central Intelligence Agency VSOP Legal Department] PLAINTIFF, v. KENTUCKY UNEMPLOYMENT DEPARTMENT, DEFENDANT. CASE NO. [121-po-588] MOTION FOR INJUNCTIVE RELIEF AGAINST KENTUCKY UNEMPLOYMENT DEPARTMENT TO THE HONORABLE [Mark Steven Davis], JUDGE OF EASTERN DISTRICT OF ALEXANDRIA: COMES NOW, [Bradley Tyler Burns - Chief Prosecutor Central Intelligence Agency], Plaintiff in the above-entitled action, and respectfully moves this honorable Court for an injunction against Defendant Kentucky Unemployment Department for the reasons set forth below: 1. INTRODUCTION This motion arises out of the urgent need to address significant issues regarding the operations of the Kentucky Unemployment Department, particularly pertaining to the rampant fraud estimated at $400 million and the outdated computer server networks which have contributed to this crisis. 2. FACTUAL BACKGROUND Two critical issues necessitate this motion: a. Fraudulent Payments: There have been extensive reports and investigations indicating widespread fraudulent claims within the Kentucky Unemployment Department, resulting in approximately $400 million in erroneous disbursements. b. Outdated Technology: The existing computer server networks are inadequate for the department's needs, failing to prevent fraud and hindering effective responses to the unemployment crisis. 3. RELIEF SOUGHT Plaintiff requests an injunction ordering the immediate termination of current personnel in the Kentucky Unemployment Department and the initiation of a comprehensive upgrade of the department’s computer server networks. This action is necessary to: a. Implement better security measures to prevent further fraudulent activities. b. Establish a more efficient and reliable unemployment benefit disbursement system. c. Restore public trust in the state's ability to manage unemployment resources effectively. 4. LIKELIHOOD OF SUCCESS ON THE MERITS Plaintiff asserts that the overwhelming evidence of fraud coupled with the department's failure to adapt its technology demonstrates that this course of action is both justified and necessary. 5. BALANCE OF HARMS The termination of current employees and upgrading of technological infrastructure, while disruptive, will ultimately serve the greater public good by preventing further misuse of taxpayer funds and improving the overall functionality of the Kentucky Unemployment Department. 6. PUBLIC INTEREST The public interest is best served by ensuring that taxpayer money is managed effectively and that any fraudulent activities are curtailed. This injunction serves the greater good by promoting accountability and efficiency in public service. WHEREFORE, PREMISES CONSIDERED, Plaintiff requests that this Court: a. Grant a temporary and permanent injunction to terminate the employees of the Kentucky Unemployment Department and upgrade the existing computer server networks; b. Award any additional relief the Court deems just and appropriate. Respectfully submitted, [BRADLEY TYLER BURNS] [401 COURTHOUSE SQUARE] [ALEXANDRIA, VIRGINIA USA] [702.773.4529] [ciabradleyburns@gmail.com] [Gary Smith III, if applicable] [CIA VSOP, if applicable] CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served upon all parties of record that must be served.
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IN THE DISTRICT COURT OF [EASTERN DISTRICT OF], KENTUCKY [Bradley Tyler Burns], Plaintiff, v. KENTUCKY STATE POLICE, [KYNect, Bluegrass.org, New Vista and Lagrange Prison System], Defendants. Civil Action No. [121-po-588 Eastern District Of Alexandria] COMPLAINT FOR LABOR FRAUD AND COERCION Plaintiff’s Complaint COMES NOW, the Plaintiff, [Bradley Tyler Burns], by and through their undersigned counsel, and for their Complaint against the Defendants, state as follows: PARTIES Plaintiff, [Bradley Tyler Burns], is a resident of [Las Vegas, Nevada, 89117], and at all relevant times, has been a witness to events surrounding an international sovereign murder investigation of multiple federal law enforcement agencies employees and or connected co workers in international law enforcement. Defendant, Kentucky State Police, is a governmental agency operating within the Commonwealth of Kentucky, responsible for law enforcement and public safety. Additional Defendants may include individual officers or members of the Kentucky State Police their liaisons and or court appointed representatives, unnamed at this time, who participated in the acts described herein. JURISDICTION AND VENUE This Court has jurisdiction over the subject matter of this action pursuant to KRS [KRS. Choice of Evils Clause], as the events giving rise to this action occurred within this jurisdiction. Venue is proper in this Court pursuant to KRS [KRS Labor Fraud Statutes] because the Defendants reside or conduct business in this District. FACTUAL BACKGROUND On or about [03/15/2021], an international sovereign murder was committed, drawing public and media attention. The Plaintiff possesses critical information relating to the aforementioned murder and was prepared to offer testimony that would implicate certain individuals involved. Instead of facilitating the Plaintiff’s cooperation, members of the Kentucky State Police engaged in a pattern of intimidation and coercion. The actions of the Kentucky State Police included threats disguised as warnings to the Plaintiff and other witnesses, creating an environment of fear that dissuaded them from coming forward with information. Posing as potential customers of the business of the plaintiff and criminally coercing them to entrapment. Furthermore, the Kentucky State Police materially misrepresented the investigative process, suggesting that cooperation would jeopardize the safety of the witnesses involved. As a part of this unlawful scheme, the Defendant(s) engaged in labor fraud by manipulating the narrative of the investigation to exclude truthful testimony from witnesses and failing to properly document and investigate potential leads relevant to the case. CLAIMS FOR RELIEF Count I: Labor Fraud Plaintiff incorporates all previous paragraphs as if fully set forth herein. Defendants’ actions constitute labor fraud, as they intentionally misled witnesses and suppressed critical information necessary for the pursuit of justice. As a direct result of the Defendants’ fraudulent actions, the Plaintiff and other witnesses have suffered emotional distress, fear of retribution, and potential damage to their credibility. Count II: Criminal Coercion Plaintiff incorporates all previous paragraphs as if fully set forth herein. The conduct of the Defendants in threatening the Plaintiff and other witnesses constitutes criminal coercion, as they sought to unlawfully compel silence and discourage testimony through intimidation. These actions not only undermined the investigation into the sovereign murder but violated the civil rights of the Plaintiff and other witnesses. DEMAND FOR RELIEF WHEREFORE, the Plaintiff, [Bradley Tyler Burns], respectfully requests that this Court grant the following relief: a. A jury trial on all issues so triable; b. Compensatory damages in an amount to be determined at trial; c. Punitive damages to deter future conduct by Defendants; d. Attorneys’ fees, costs, and expenses incurred in prosecuting this action; and e. Any such further relief that this Court deems just and equitable. DATED this [03/08/2025]. Respectfully submitted, [Bradley Tyler Burns / Chief Prosecutor] [Gary Smith III / Prosecution Research] [401 Courthouse Square] [Alexandria, Virginia, United States] [702.773.4529] [ciabradleyburns@gmail.com] Attorneys for Plaintiff [Not Named At This Time]
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