Motion for Temporary Restraining Order In Matter of Elizabeth Coady v. President Donald J. Trump et. al
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ELIZABETH COADY
Plaintiff
v.
Donald J. TRUMP, President of the United States in his individual and official capacity;
Barack Obama, former President of the United States in his individual and official capacity;
Michael Kratsios, Director of White House Office of Science and Technology Policy, in his individual and official capacity;
Pete Hegseth, Secretary of Defense, in his individual and official capacity;
The Department of Defense;
Jim Jordan, Chairman of the US House Judiciary Committee and Weaponization subcommittee, in his individual and official capacity;
Robert F. Kennedy, Secretary of U.S. Health and Human Services, in his individual and official capacity;
Dr. Jay Bhattacharya, Director of National Institutes of Health in his individual and official capacity;
The National Institutes of Health;
Dr. John Ngai, Director of NIH Brain Initiative in his individual and official capacity;
Dr. Walter Koroshetz, his individual and official capacity as Director of the National Institute of Neurological Disorders and Stroke;
The National Institute of Neurological Disorders and Stroke;
Dr. Christine Grady, Chief of the Department of Bioethics at the National Institutes of Health, in her individual and official capacity;
Janet Petro, Acting Director of National and Space Administration (NASA) in her individual and official capacity;
Pam Bondi, Attorney General of the U.S. Department of Justice, in her individual and official capacity;
William Barr, former Attorney General of U.S. Department of Justice, in his individual and official capacity;
Eric Holder, former Attorney General of U.S. Department of Justice, in her individual and official capacity;
Kash Patel, Director of Federal Bureau of Investigation, in his individual and official capacity;
Christopher Wray, former Director of Federal Bureau of Investigation, in his individual and official capacity;
Federal Bureau of Investigations;
John Ratcliffe, Director of Central Intelligence Agency, in his individual and official capacity;
William Burns, former Director of Central Intelligence Agency, in his individual and official capacity;
Central Inteligence Agency
Sunday Pichai, Chief Operating Officer of Alphabet in his individual and official capacity;
Alphabet, Inc.;
Google, Inc.;
Elon Musk, Chief Operating Officer of Tesla, SpaceX, Starlink, xAI, Neuralink and The Boring Company, Chief Technology Officer of X.com, in his individual and official capacity;
Tesla, Inc.;
Neuralink, Inc.;
XAI, Inc.,
Peter Thiel, Chairman of Palantir, Inc. In his individual
and official capacity;
Blackrock Neurotech, Inc.;
Bill Gates, Chairman of The Bill & Melinda Gates Foundation, in his individual and official capacity;
The Bill & Melinda Gates Foundation;
IBM;
Satya Nadella, Chief Operating Officer of Microsoft, Inc. in his individual and official capacity;
Microsoft, Inc.;
Jeff Bezos, CEO of Amazon in his individual and official capacity;
Amazon, Inc.;
Northrup Grumman;
Harvard University;
Stanford University;
Massachusetts Institute of Technology;
Princeton University;
University of Pennsylvania;
University of California at Davis;
Mayor Bradley Johnson, Mayor of City of Chicago, in his individual and official capacity;
Dean Harrison, Chief Executive Office of Northwestern Memorial Healthcare, in his individual and official capacity;
Howard Chrisman, Chief Executive Office of Northwestern Memorial Healthcare, in his individual and official capacity;
Dr. Steven Flamm;
Dr. Kiran Nimmaggadda;
Dr. Kenneth Arbetter;
Jane Doe;
Dr. John Doe;
DEFENDANTS
Case No.
Ex Parte Motion FOR TEMPORARY RESTRAINING ORDER
Plaintiff, Elizabeth Coady, proceeding pro se, respectfully but urgently pleads with this Court pursuant to Federal Rule of Civil Procedure 65 for an Ex Parte TRO to prohibit Defendants from activating and maintaining the numerous nonconsensual implants in Plaintiff’s body and face, specifically, the Neuralink 'beta' prototype.
These nonconsensual 'injectible electronic' devices, which include fluid-filled rubber wifi chips, have been activated to the highest levels Plaintiff has ever experienced since President Donald J. Trump was sworn in as 47th President of the United States.
Plaintiff reports the nonconsensual tech was placed in her covertly at Northwestern Memorial Hospital at least four times at Northwestern Memorial Hospital in Chicago between January 2013 and July 2024. Plaintiff's accompanying Affidavit recounts the circumstances
surrounding the nonconsensual implants and includes radiologic images and diagnostics to confirm her claims.
These 'brain-to-computer' devices are causing grave and permanent harm to the Plaintiff's brain and face and must be removed immediately to stave off more harm and forced suicide.
Plaintiff asserts the implanted technology, now commonly referred to as 'biosurveillance,' was designed and developed to be plausibly deniable and difficult to identify in radiologic scans, as described in the video lecture, 'The Brain Is The Battlefield of the 21st Century,' by Dr. James Giordano, a Johns Hopkins University professor and Darpa Brain Initiative scientist.
This deliberate deceptive aspect of the technology is designed to hide Defendants' criminal and unconstitutional actions against Plaintiff under cover of false charges of mental illness.
Plaintiff asserts and believes that she and other unwitting experimental subjects in the Darpa Brain Initiative were and are political targets placed in the 'secret research program' alluded to during discovery of the Obama Administration's well-documented FISA IRS scandal and abuses that occurred the early 2010s through to today. https://theconservativetreehouse.com/blog/2019/05/28/the-secret-research-project-an-irs-list-an-nsa-database-and-resulting-
files-on-americans/
Plaintiff asserts she was politically targeted for inclusion in the Darpa Brain Initiative in which researchers across multiple fields carry out cognitive studies and 'brain emulations'
on subjects who are then subjected to covert assassination or forced suicide --- unconstitutional acts against an American citizen.
Neuroscientist Anders Sandberg, in a publicly-available video lecture entitled, 'Making Minds Morally,' openly describes whole brain emulations as 'a one-way ticket,' a euphemistic reference to a death sentence. The 20-minute video is a shocking if short treatise on how deadly brain emulations are protected legally by mental illness diagnoses because 'legal nonpersons' legally are considered unable to give consent.
Defendants' deceptive acts have and are intended to deliberately cause Plaintiff and other nonconsenting subjects to be labeled psychotic or delusional, and to suffer lost of credibility to legally cover criminally malicious and grotesque 'experimentation' while also denying legitimate medical care, as Plaintiff illustrates in her Affidavit.
Defendants' deceptive acts have and are intended to deliberately steal Plaintiff's brain waves and other biological data for whole brain emulation, cognitive study, comparative studies, archiving, reselling, marketing, predictive
programming, neural networks, avatars, artificial intelligence, software, robotics, 'radical gaming' and other exploitative intent for which Plaintiff gave zero consent.
Defendants' deceptive acts have and are intended to deliberately cause Plaintiff extreme pain and suffering, and to force her to suicide with the use of secret 'plausibly deniable' military technology and weapons.
Plaintiff urgently requests this Court grant an ex parte TRO to immediately temporarily halt the activation of these nonconsensual implants and to order Defendants to allow and enable Plaintiff to surgically remove these devices without interference by Defendants who through semiotics
have repeatedly threatened harm to Plaintiff's family should she proceed with litigation.
Plaintiff also requests this Court to order Defendants to cease collecting, distributing, storing, processing, archiving and profiting from her brain waves harvested and delivered to government, corporate and academic data servers via wifi and Bluetooth, and to order the immediate deactivation and removal of said nonconsensual devices placed in Plaintiff in deliberate political targeting carried out under 'wraparound' falsified fisas, thus ending her 21st Century 'Logan's Run' existence.
In support, Plaintiff states:
INTRODUCTION
1. Plaintiff alleges between January 2013 and July 2014, she was nonconsensually and with malice and deliberate forethought implanted with experimental biomedical devices dubbed 'injectable electronics' at Northwestern Memorial Hospital in Chicago throughout Plaintiff’s body as 'Beta one' in Darpa Brain Initiative, causing grave and irreparable harm.
2. These nonconsensually implants devices were implanted for the development of transhumanist technologies the US government characterizes as 'biosurveillance' devices and that include the first prototype of Elon Musk's brain-to-computer-inferface currently marketed under the name Neuralink.
3. These devices are activated remotely via satellite, wifi, Bluetooth, and other radiation sources, and are intended to 'merge man with machines' ostensibly to make them more intelligent while actually being part of 'control systems' developed by the United States Air Force and the Defense Advance Research Projects Agency (DARPA), the research arm of the US Pentagon.
3. Beginning in August 2013 and trolling through May 23, 2025, Plaintiff has endured the activation of these multiple foreign implants and other targeting which cause Plainfiff to experience:
• Persistent nonstop radiation burns;
• Shocks;
• Persistent sonic blasting in the interior of Plaintiff's left skull and face;
• Poisoning via constant aerosol and 'nanoswarm' attacks;
• Psychological trauma;
• Psychological distress;
• Facial disfigurement;
• Sexual arousal;
• Familial treachery and abandonment;
• Mental cognitive decline;
• Radiological and chemical assaults;
• Electrification of her skull and body;
• AROUND-the-clock invasion of privacy for 12 years with Plaintiff's voice broadcast on radio frequencies maintained for military, intelligence and first respondents' use;
• Plaintiff has endure extraordinary and voluminous abuses for 12 years only some of which she outlines in her Affidavit.
Plaintiff brings this request for relief through an Ex Parte TRO to halt the abuses to her body, face and brain now because since January 20, 2025, when President Trump returned to the presidency, the Neuralink or 'brain-to-computer' device has been activated at its highest levels ever.
Plaintiff asserts these grossly elevated attacks are being perpetrated because Defendant Trump received financial support from Defendant Musk in amounts reported to
total at least $288 million dollars. https://www.washingtonpost.com/politics/2025/01/31/elon-musk-trump-donor-2024-election/
Plaintiff's implants fall under the rubric of 'biosurveillance' and in addition to collecting and translating brain waves in real time for artificial intelligence, predictive programking, neural networks, these 'touchless torture" technologies are being used covertly in the Darpa Brain Initiative to harm Plaintiff and other nonconsenting subjects.
Plaintiff pleads for immediate injunctive relief which is necessary to prevent further ongoing harm, cancer, disfigurement and certain imminent death, as detailed in the Complaint and attached Affidavit and Exhibits.
• Plaintiff requests an ex parte TRO under FRCP 65(b)(1)
due to the risk of retaliation if Defendants are notified, or a preliminary injunction following a hearing.
LEGAL STANDARD
• Under Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008), a plaintiff seeking injunctive relief must show: (1) likelihood of success on the merits; (2) irreparable harm absent relief; (3) the balance of equities favors the plaintiff; and (4) the public interest supports relief.
ARGUMENT
Likelihood of Success on the Merits
Plaintiff asserts that the totality of established federal case law, excluding that pertaining to enlisted military personnel, weighs in her interests in having the offending nonconsensual tech removed.
Plaintiff is likely to succeed on her claims under 42 U.S.C. § 1983, as Defendants, acting under color of state law, violated Plaintiff’s Fourth and Fourteenth Amendment rights by implanting multiple devices without consent, an intrusion into bodily integrity that constitutes unlawful search and seizure. See Rochin v. California, 342 U.S. 165 (1952).
Mohr v. Williams (1905, Minnesota Supreme Court) established that performing a medical procedure without specific consent constitutes battery, setting a foundational precedent for bodily autonomy, and emphasized that any unauthorized invasive procedure, including implantation, violates a patient's rights. This principle arguably remains robust in modern medical law.
Pratt v. Davis (1905, Illinois Apellate Court) reinforced the norm that performing an invasive procedure without specific consent is battery. This case applies to nonconsensual implantation of devices if done explicitly without patient approval.
Schloehndorff v. Society of New York Hospital (1914, New York Court of Appeals) solidified the doctrine of informed consent, stating that 'every human being of adult years and sound mind has a right to determine what shall be done with his body.' Nonconsensual implants of brain chips and other materials and devices intended to enable torture and 'under the skin' surveillance, steal cognition and other biological data, violate this principle as implantation involves an invasive act without permission.
Mink v. University of Chicago (1979, U.S. District Court, Northern District of Illinois) found that medical treatment without consent constitutes battery. In Plaintiff's case, her life is literally in danger as devices and materials implanted interiorly and activated remotely -- just as mobile phones, GPS devices, garage door openers and other wireless
devices -- are being activated at the highest levels ever since Defendant Trump returned to office.
Canterbury v. Spence and Cobbs v. Grant further defined informed consent, requiring physicians to disclose material risks and obtain explicit permission. Plaintiff's provable and numerous nonconsensual devices are an extreme and criminal violation of this standard.
In Winston v. Lee (471 U.S. 1, 1985), the Supreme Court held that a compelled surgical procedure to remove a bullet violated the Fourth Amendment due to its intrusiveness, balancing individual privacy against government interests. This case bolsters Plaintiff's argument that nonconsensual implantation of a brain-to-computer interface is unqualified unreasonable search and seizure.
In Skinner v. Railway Labor Executives’ Assn. (489 U.S. 602, 1989), the Court recognized that bodily intrusions (e.g., drug testing) can constitute searches under the Fourth Amendment, requiring a balancing of privacy and governmental interests.
The deliberately deceptive and criminal manner in which Plaintiff was nonconsensually implanted with devices is prima facie evidence of Defendants' willfully depriving Plaintiff of her Constitutional rights to privacy, due process and freedom from cruel and unusual punishment as set forth in Screws v. United States, 325 U.S. 91 (1945)
In Smith v. Wade, 461 U.S. 30 (1983), the Supreme Court
held that punitive damages may be awarded when the conduct of government actors is shown to be 'motivated by evil motive or intent,' as will be horrifically and evidently displayed in Plaintiff's case.
Harlow v. Fitzgerald, 457 U.S. 800 (1982) applies as Defendants' actions egregiously and shockingly violated and continue to violate her Constitutional rights, as well the Nuremberg code, as well as the standards of sane human beings worldwide.
Thompson v. Connick, 563 F. 3d 111 (5th Cir. 2009) holds that public officials' reckless disregard for the truth stripes them of immunity as Plaintiff's rights have been shockingly suppressed since 2013. She has also repeatedly called, written and visited public officials who are charged with representing citizens' interests and defending their rights. Plaintiff has literally written hundreds of letters to Congressmembers, Executive branch executives and even Supreme Court jurists seeking relief and has continually been denied.
Al Shimari v. CACI (Abu Graib Case, 2008-2024) established that private corporations can be held civilly liable for torture and set a precedent for accountability under the Torture Victim Protection Act (TVPA) for human rights abuses by private entities.
In Abdullahi v. PFIZER, INC. (2009), the Second Circuit ruled
that nonconsensual experimentation by private corporation violated customary international law and thus can be actionable under the Alien Tort Statute, the U.S. Constitution and international law.
In Doe v. Sullivan (1976), an Oregon District Court ruled that nonconsensual experimentation on prisoners could constitute a constitutional violation.
Rochin v. California (1952) found that nonconsensual experimentation by government actors may violate substantive due process if it 'shocks the conscience,' a threshold certainly met in Plaintiff's complaint.
Beyond the borders of the United States, the establishment of the Nuremberg Code (1947) mandated
voluntary consent for medical experiments. That the United States government is flouting this international standard covertly while oasting worldwide of being a protector and defender of human rights and U.S. Constitutional liberties is both a betrayal of American citizens and values and tantamount to canard. https://www.google.com/url?sa=t&source=web&rct=j&opi=89978449&url=https://thefederalist.com/2025/05/13/gabbard-reaffirms-americas-commitment-to-protecting-individual-liberty-on-the-world-stage/&ved=2ahUKEwirlfPoxbeNAxXZGFkFHQP6HosQFnoECB0QAQ&sqi=2&usg=AOvVaw2P5zqjyi4JLblvaNzDre5X
The UN Convention Against Torture asserts nonconsensual
experimentation causing severe pain or suffering can constitute torture or cruel, Inhuman, or Degrading Treatment. CAT applies to state actors but can extend to private entities acting under state authority.
Article 7 of The International Covenant on Civil and Political Rights (ICCPR) prohibits medical or scientific experimentation without consent, binding signatories including the United States.
The Torture Victim Protection Act allows civil suits against individuals for torture or extrajudicial killings.
Plaintiff Coady contends this civil action affords this Court the opportunity to establish boundaries for the 21st Century's brave new world of 'biosurveillance,' and to establish that neither state actors nor corporate entities have a legal or commercial right to run roughshod over individual American citizens in depraved experiments to obtain brain and other biological data for sadistic appetites and bottom lines, and to levy penalties against actors doing exactly that.
While state actors are often granted qualified immunity, the brazen and demented criminality of the experimentation and torture of Elizabeth Coady must compel this Court to deny such legal cover to these state actor perpetrators.
While the issue of cognitive privacy and rights has not yet been addressed by U.S. Courts or the U.S. Congress, largely because of the deliberate hurdles created by U.S. FEDERAL Defendants, in Girardi v. Zemotiv Inc. (Chilean Supreme Court, August 9, 2023), the Chilean Supreme Court recognized that protection of 'neural activity,' as part of mental privacy under existing constitutional and data, requires due diligence in handling. The landmark ruling suggests neurodata collected by private corporations constitutes a form of surveillance and highlights the need for specific legislation protecting cognitive privacy.
To date, there has been no effort among U.S. federal lawmakers to protect Americans' cognitive privacy and property, and Plaintiff asserts that is wholly because they have already given Americans' brain data to corporations by nonconsensually brainchipping at least 200,000 Americans as disclosed by former NASA Director Dennish Bushnell -- and likely millions more, since Congress legalized nonconsensual experimentation in Section 3024 of the Cares Act.
Congress in 2024 also expanded
FISA's reach into allowing the collection of data from public wifi networks, the intent no doubt the harvesting of brain waves from these nonconsensually brainchipped. The public is largely unaware of this activity.
While some court rulings have promulgated the idea that neural surveillance is 'fanciful, fantastic and delusional,' as
they did in Maxey v. United States (E.D. Cal., 2015), Plaintiff's provable nonconsensual neural and other bodily implants obviate that discussion and must compel this Court to grant her a TRO to remove these harmful foreign objects from her body. Plaintiff avers that these implants must be found to establish proof of battery, an invasion of privacy and cruel and unusual punishment.
Further, courts no longer skirt the reality of our brave new world of futuristic science when this current White House Administration in April called a press conference and giddily hailed American technology that can 'manipulate time and space' and 'leave distance annihilated.' Https://interestingengineering.com/trump-advisor-says-american-can-bend-time. They are in fact speaking of the neural surveillance and remote touch that has been developed on Plaintiff in the Darpa Brain Initiative and, specifically, Neuralink.
These 'translational' science breakthroughs have been made at the expense of the lives of innocent Americans discredited with false diagnoses and tortured to suicide and death by the repugnant unconstitutional experimentation in the Darpa Brain Initiative launched officially in 2013 but planned years earlier.
Defendants' have deliberately, repeatedly and systematically promulgated the fallacy that Plaintiff Coady suffers from delusions and psychosis to hide their horrific human rights abuses and criminal behavior by government officials. And it
was done maliciously and wantonly under deliberately falsified FISAs.
Under 18 U.S.C.§ 242 Defendants' are clearly, willfully and maliciously violating Plaintiff's Constitutional rights.
Medical imaging and the removal of some pieces of 'foreign' materials in Plaintiff's skull, arm, and Plaintiff’s affidavit detail nonconsensual implantation, theft of cognition and torture directly linked to Defendants’ actions.
A SCADA Frequency Allocation test performed by Melinda Kidder of Columbia Investigations in Missouri confirmed frequencies emanating from Elizabeth Coady's body at least 11 different bodily points.
Due to Defendants' shocking flouting of Constitutional law Plaintiff is likely to succeed under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), establishing individuals could sue federal officers for damages for constitutional abuses. or the Administrative Procedure Act, 5 U.S.C. § 706, as multiple federal actors are involved.
B. Irreparable Harm
The 'injectable electronic' implants expose Plaintiff to nonstop radiation, biochemicals, nanoparticulates and 'nanoswarms' throughout skull and body, and in particular to left side of face and skull while also activating hair-thin wires, nanomaterials, graphene and rubber wifi capsules
containing magnetic fluid and nano implanted inside Plaintiff's skull.
Through semiotics, communication through signage and symbols, Plaintiff has been informed that 23 chemists were involved in designing what she calls the architecture of her interior; she has also been told four 'Pams' or contracts have been issued on her by the Dept. Of Energy
for experimentation on her body.
The nonconsensual materials in Plaintiff's face are deliberately and maliciously intended to cause Alzheimers, dementia, physical disfigurement and mental disability, mental retardation, disfigurement of face, jaw cancer, and to force plaintiff to suicide. These intentions have been communicated to Plaintiff repeatedly by intelligence sources and contractors using semiotics such as memes, emails, tweets, license plates and clothing on a host of platforms including X, email, embedded advertising, car license plates
and even confidential human sources' clothing. Plaintiff has dozens of examples of these but is under such severe attack she is not able to collate them but will submit in an amended filing.
Monetary damages cannot remedy these permanent injuries. See City of Los Angeles v. Lyons, 461 U.S. 95 (1983).
Without immediate relief, Plaintiff faces certain and imminent disfigurement, disability and death.
C. Basis for Jurisdiction
Plaintiff is filing this federal action in Delaware because it is routinely the seat of incorporation for United States corporations.
In addition, the two states where Plaintiff, now forced into homelessness, has largely resided since her targeting began --- Illinois and Pennsylvania --- Plaintiff has suffered direct abuses by state and local officials, including the deliberate manipulating of municipal properties and laws in order to access Plaintiff physically.
Plaintiff's targeting is a case of personal revenge by President Barack Obama who was and is still widely considered head of the Democratic Party. Plaintiff has evidence that both city of Chicago officials, Chicago Police and the State's Attorney General were directly involved in her targeting. Also, the state's current Governor JB Pritzker has donated $2 million dollars to two candidates in llinois court elections.
Governor Pritzker and his family profit directly from Plaintiff's and others' stolen brain waves or cognition as the Pritzker family underwrites the University of Chicago's Pritzker School of Medicine which, through its infrastructure, collaborates with the Neuroscience Institute at UC on translational and clinical research. Plaintiff has personally had her brain waves collected by earbud-wearing brainwave harvesters or
'pirates' while visiting the Chicago campus and can provide photos in an amended complaint if necessary.
In Pennsylvania, Plaintiff also has evidence that officials in Philadelphia have targeted her personally, going so far as to suspend an Airbnb space she stayed in occasionally until host consented to install an oscillator to activate Plaintiff's nonconsensual implants.
City employees in Erie, Pa. also were directly involved in the vandalism of Plaintiff's car, and the Erie Police conspired with federal authorities to steal and destroy all of Plaintiff and her child's belongings accumulated over their lifetimes.
Plaintiff has video and audio evidence of her assertions, in particular the utter destruction of every bit of personal property, memento, art collection, and historic, personal and familial artifact accumulated in her and her child's lifetimes and will submit these to the Court in an amended complaint upon approval of electronic filing.
D. Balance of Equities
The harm to Plaintiff from the implant outweighs any burden on Defendants, who face no legitimate hardship save loss of profits and stolen brain data in ceasing unlawful conduct. See Winter, 555 U.S. at 24.
Ordering removal of an illegal implant imposes minimal cost compared to Plaintiff’s ongoing suffering and imminent
guaranteed death.
E. Public Interest
Granting relief is essential to protect Plaintiff's, her daughter's and all Americans' Constitutional rights which have been quietly subverted by all three branches of the government to the point of making the foundational doctrine of America obsolete and quaint. It is heavily in public interest that Plaintiff be made whole as much as possible and that federal authorities recognize the rights of Elizabeth Coady and child under the Fourth, Fifth and Eighth and 14th Amendments.
Granting relief and a temporary restraining order against federal and state actors serves the public interest by protecting constitutional rights and bodily autonomy.
More than Plaintiff's rights are at stake: the United States Government has and is criminally and deceptively brainchipping and torturing at a minimum hundreds of thousands of citizens under falsified medical diagnoses and FISAS, labeling them 'terrorists' and mentally ill, and denying them any due process for the profits OF OLIGARCHS AND MULTINATIONAL CORPORATIONS. See Weinberger v. Romero-Barcelo, 456 U.S. 305 (1982).
Plaintiff avers that this Court's support of a TRO prevents and repairs government misconduct, including nonconsensual implantation of at least 200,000 Americans
with brain chips, and is of paramount need to protect the Constitution, American citizens, Plaintiff as well public trust. Despite the translation research and breakthroughs accomplished since the Darpa Brain Initiative was officially launched in 2013, Defendants have no legal, moral or commercial right to essentially frame citizens for the predation of brain data.
Plaintiff requests an ex parte TRO under FRCP 65(b)(1) because notifying Defendants risks retaliation, as devices are currently activated at the most extreme levels they've ever been which Plaintiff attributes to the lead Defendant's $288 million election funding from Defendant Musk who personally and materially profits from the stolen cognition.
Plaintiff's brain has been literally
open-sourced since 2013 and her brain waves have been likely distributed to the Darpa Brain Initiative's more than 500 corporate, academic, military and medical partners and potentially hundreds of thousands of scientists, physicists, technologists, neuroscientists, psychologists, computer engineers and more -- an eyepopping degree of personal privacy violation. Neuroscientists with whom she has no delation routinely visit her LinkedIn page.
Even her sexual orgasms are initiated, observed, collected, distributed and studied, and were in fact used by the NIH in its 10th anniversary literature celebrating a 'decade of discovery.' Plaintiff avers the first- place winning photograph entitled “Light Me Up!,” by Andrew Janson, then graduate
student research assistant, Scientific Computing and Imaging Institute, University of Utah, is based on Plaintiff's orgasm. While the original text that accompanied the photo revealed it to be of a woman who suffered a previous concussion in an earlier car accident, as did Plaintiff, accompanying text was changed to describe it merely as 'electrical excitation of neuronal fiber pathways' after Plaintiff tweeted that it was her orgasm.This is the type of semantical deceptions the NIH practices to disguise its mad science.
Plaintiff has been brazenly turned into a commodity much like a farm animal. In addition, Plaintiff has also repeatedly received threats that her family would be harmed should she proceed with this lawsuit. She is gobsmacked that the federal authorities have done this to her and her family. As Oprah likes to say, Plaintiff should be living her 'best life' at this stage in her life.
Plaintiff asserts TRO AND PERMANENT RESTRAINING ORDER SHOULD BE granted immediately and without delay as she is under nonstop assault and the disfigurement of her face increases daily.
A TRO is necessary to halt the status quo until a preliminary injunction hearing.
CONCLUSION
Plaintiff respectfully requests that the Court:
a. Issue a temporary restraining order prohibiting Defendants from activating, operating, and maintaining the implants and ordering their immediate removal or deactivation within 3 days.
b. Issue a preliminary injunction after a hearing, granting the same relief until the case is resolved.
c. Defendants shall arrange for the safe removal or deactivation of the implant within 3 days of this Order, under medical supervision.
d. Schedule a hearing at the Court’s earliest convenience.
e. Grant any further relief deemed just and proper.
RESPECTFULLY SUBMITTED,
Elizabeth COADY, “Pro Se Plaintiff”
773-412-5326
ELIZABETHC@PROTONMAIL.COM
May 23, 2025