UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

DONNA J. WARREN AND BERLINA M. CASE No. 99-02603

DOSS.

Plaintiffs.

v.

CENTRAL INTELLIGENCE AGENCY,

UNITED STATES DEPARTMENT OF

JUSTICE, ESTATE OF WILLIAM CASEY,

ROBERT GATES, JOHN DEUTCH,

GEORGE TENET, ESTATE OF WILLIAM

FRENCH SMITH, EDWIN MEESE,

RICHARD THORNBURGH, JANET RENO,

AND DOES I - XXX.

Defendants.

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COMPLAINT FOR DAMAGES

INJUNCTIVE RELIEF AND

DECLARATORY RELIEF

DEMAND FOR JURY TRIAL

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1 PLAINTIFFS DONNA J. WARREN and BERLINA M. DOSS are citizens of the United States, and reside in the State of California. Ms. Warren resides in the City of Los Angeles and Ms. Doss resides in the City of Hesperia.

2 DEFENDANTS CENTRAL INTELLIGENCE AGENCY and UNITED STATES

DEPARTMENT OF JUSTICE are federal agencies. In 1982, the heads of these agencies entered into a recently revealed agreement, giving rise to a policy under which the CIA had no duty to report drug crimes to the Department of Justice.

STATEMENT OF FACTS

10 On March 16, 1998, CIA Inspector General Fredrick Hitz appeared before the House Intelligence Committee to report on his investigation of the CIA, the Contras and crack cocaine. Hitz testified that beginning in 1982, the CIA entered into an undisclosed agreement with the Department of Justice, allowing CIA officers to refrain from reporting drug trafficking by its "agents, assets, and non-staff employees." Hitz admitted that "there are instances where the CIA did not in an expeditious or consistent fashion, cut off relationships with individuals supporting the Contra program who were alleged to have engaged in drug trafficking activity, or take action to resolve the allegation."

11 When asked by Congressman Norman Dicks of Washington, "Did any of these allegations involve trafficking in the United States?", Hitz's answer was "yes." Hitz acknowledged that the CIA knew of drug trafficking allegations "regarding dozens of individuals and a number of companies connected in some fashion to the Contra program or the Contra movement."

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