ARGUMENT OF CASE

      Crouse’s first argument in the charge asserts that staff at the Bridge Over Troubled Waters, the Neuropsychiatric Center and West Oaks Hospital repeatedly refused to adhere to appropriate documentation procedures so as to prevent Crouse from accessing documentation that could be used as evidence in her investigation of racketeering activity. Crouse’s attorney Arlene Guzick refused to contact Crouse after her release from the West Oaks Hospital to provide her with a copy of the document she signed attesting to her desire to appear at her April 3, 2017 hearing to challenge the Order of Protective Custody. These acts violate Texas Rules of Appellate Procedures (TRAP) Rule 21.7 in that they intentionally impact the potential to submit evidence at a hearing that could then later be used as the basis of other potential legal proceedings in order to move forward with a formal investigation of the activities which Crouse had been investigating and attempting to report.

      Crouse was intentionally prevented from attending the April 3, 2017  hearing to challenge the Order of Protective Custody by staff at West Oaks Hospital and Guzick refused to contact Crouse to assist her in attending the hearing and thus appropriate application of TRAP Rule 21.7 was intentionally obstructed. Crouse specifically told Guzick she wanted to attend the hearing so as to submit evidence regarding her retaliatory detention for reporting on numerous crimes. Crouse spoke to Guzick about how she saw the hearing as an opportunity to potentially submit substantial primary and secondary evidence. Crouse had already had evidence stolen once; Crouse’s evidence that she had hoped to begin submitting at that hearing was later stolen while Crouse was forced to sleep outside due to her refusal to cooperate with criminal activities in a shelter to which she had been sent to seek indoor sleeping arrangements.

      Despite being given a copy of the Grievance Procedure upon entering the Bridge Over Troubled Waters, the procedure was not followed and Crouse was given no written notices regarding the various grievances allegedly filed against her OR any written responses to the two grievances Crouse wrote on her first few days there. In the course of being called out for various purported issues concerning her behavior and penalized or denied access to resources as a result of alleged infractions, Crouse requested written statements from staff but was refused. Crouse also was told by the Shelter Director Janelle Eaton that if she obtained a psychological evaluation then Eaton would either a) permit Crouse come back to the shelter or b) arrange for Crouse to be transferred to another shelter. Eaton, however, refused to put this in writing.

      Additionally, Crouse was denied copies of documents upon which she notated during admission to the Neuropsychiatric Center that the procedure the hospital was saying they had engaged had actually not been engaged at the time Crouse was told she needed to sign the documents. This document was legally required to be given to Crouse per Health Information Protection and Portability Act and the Texas Patient’s Bill of Rights and Crouse specifically requested a copy on March 24, 2017. Crouse was told by the nurse that she would receive a copy upon leaving the Neuropsychiatric Center but upon her discharge on March 27, 2017 Crouse requested a copy of this document and was denied copies of this or any other documents compiled on her while at the Neuropsychiatric Center.

      The shelter and the hospital’s failure to follow procedure, which includes providing documentation that shows they disclosed information about funding Crouse’s treatment and services per Health Information Protection and Portability Act and the Texas Patient’s Bill of Rights, means they cannot confirm that they have been compliant with the very policies with which Crouse was trying to comply. It is in the means by which resources are shared with the organizations in these networks that large-scale fraud and human trafficking takes place by intentionally denying individuals the means by which to provide for their-self-sufficiency so as to keep them dependent upon the programs funded by and through their networks. Documentation of consent and following appropriate grievance processes are one of the means by which both a provider and a recipient of services can prove that they are acting within the bounds of the law. Failure to adhere to appropriate documentation processes is thus potential proof the other illegal activities are occurring.

      That the attorney appointed for Crouse to assist with the hearing to challenge the Order of Protection did not even respond to Crouse’s signed statement that she wanted to attend the hearing, much less intervene when the hospital denied Crouse release or travel assistance to get to court, shows that there are conscious efforts by representatives of the legal community cognizant of the Texas Rules of Appellate Procedure to obstruct potential justice in pursuing legal recourse against these efforts to traffic humans and commit large-scale fraud. Had Crouse been able to attend the April 3, 2017 hearing to challenge the validity of the Order of Protective Custody, Crouse could have submitted documentation regarding her challenge to the hold, which would have included copies of documents Crouse attempted to show to those who were performing her intake at both the Neuropsychiatric Center and West Oaks Hospital concerning her fraud investigation, infractions committed by staff at the Bridge Over Troubled Waters and other evidence of potential child abuse. Crouse missed that hearing because the hospital refused to discharge her until after the hearing had occurred, however, and Crouse was compelled to file grievances against staff at both hospitals with the Texas Medical Board as well as her attorney via the State Bar of Texas aka “Texas Bar Association” on April 6, 2017.

      While awaiting a response from the State Bar of Texas aka “Texas Bar Association” Crouse missed the 15-day appeal deadline regarding her initial hearing. Crouse encountered additional criminal activity at another shelter, the Salvation Army, to which she was referred during this timeframe. Had her attorney assisted her in attending the hearing a proper evidentiary procedure could have been engaged so that evidence from those crimes could have been compiled and submitted in the correct manner. However, Crouse ended up sleeping on the streets for refusal to cooperate with criminal activity at the shelter and on April 21, 2017 all of her evidence, as well as personal identification documents, were stolen.

      As a result of Crouse missing the 15-day appeal deadline while waiting for the 30-day review period by the State Bar of Texas aka “Texas Bar Association” and the 45-day review period by the Texas Medical Board, Crouse pursued a pro se effort to file a petition with the Texas Supreme Court for an En Banc Review based on the Plenary Power of Courts to review the original Order of Protective Custody on June 2, 2017. As Crouse had no legal counsel to assist and was not able to obtain confirmation on appropriate Notice of Service, Crouse sent a copy of the full petition to all of the named parties in the suit. While none of the named parties confirmed receipt of suit, Crouse did send them information regarding her legal challenge to their activities, including legal strategy, giving them an opportunity to obtain even more information from Crouse without themselves following legal requirements to confirm receipt.

      This includes the State Bar of Texas aka “Texas Bar Association”, who several times attempted to divert Crouse’s effort to serve notice and ended up engaging in an act around her attempt at Notice of Service that later revealed itself to be a potential crime in the pattern of racketeering activity Crouse was attempting to report. Crouse was informed on June 8, 2017 that the Texas Supreme Court did not have jurisdiction to hear her case.

      The State Bar of Texas aka “Texas Bar Association” and the Texas Medical Board refused to respond to Crouse’s queries during a time when the Sunset Review Commission of the Texas State Legislature wass considering re-funding of their services. The State Bar of Texas also has members representing organizations that strategically denied Crouse access to resources to sustain her self-sufficiency. They also engaged in fraudulent practices that prevented Crouse from availing herself of an education grant at the time she was supposed to and instead enrolled Crouse in publicly-funded health insurance to pay for costly treatment while federal legislation was being considered for the continued funding of public healthcare marketplaces. These coordinated actions show that there is substantial organized criminal activity that includes members of various state and federal agencies.

      The interstate implications becomes clear when one sees how this pattern followed a similar pattern that Crouse has been reporting on prior to arriving in Texas and with which she sought support from via individuals and organizations affiliated with the aforementioned entities. The previous pattern included several social service agencies that were funding a shelter Crouse was attempting to report for similar non-compliance, fraud and rights violations. Crouse’s reporting efforts were intentionally obstructed while a $100 million settlement from the State of Illinois was pending unbeknownst to Crouse at the time. That all of the above organizations are connected through the Health Management Information System (HMIS) and the Public Assistance Reporting Information System (PARIS) means that the administrators in Texas had access to information about Crouse in Illinois, including that Crouse had attempted to access resources funded by the same networks that fund programs in Texas and that Crouse had attempted to report fraud. These operations are able to access pertinent information about Crouse through their centralized reporting systems, however, Crouse has been prevented from being able to obtain, maintain or provide evidence of her attempts to address their lack of compliance with various legal protections that should be guaranteed and for which compliance is mandated.

      This pattern of evidence tampering which impacts a potential proper application of TRAP Rule 21.7 is connected to earlier and later efforts to prevent Crouse from being able to obtain reports or submit evidence by numerous agencies as detailed in the “Statement of Facts.” The obstruction began with Crouse’s attempts to seek assistance from Attorney Bob Bennett in November of 2016 to report numerous crimes and ask for a referral for an appropriate attorney. Rather than engage Crouse in a procedure for obtaining counsel and documenting evidence, Bennett attempted to divert Crouse’s attempts at reporting by either trying to engage Crouse in sexual activity or compelling her to focus on a specific legal assignment related to his re-acquisition of a client. That client, Anthony Graves, had been exonerated from Death Row after Prosecutorial Misconduct in his trial had been proven. Bennett was disbarred right as he was attempting to work with Graves on his appeal. Bennett was able to re-establish accreditation with the State Bar of Texas aka “Texas Bar Association” to practice law and had commissioned Crouse to write a piece about the disbarment proceedings. Bennett was later able to re-engage Graves as a client in a civil suit. Crouse was not aware at the time that Bennett was specifically seeking to re-engage Graves as a client for a civil suit or that his daughter was being used to attempt to set Crouse up for an appearance of Conflict of Interest. This civil suit would have involved awards for monetary damages from the State of Texas, which would potentially be provided by financing from partners who might be implicated in a comprehensive investigation of the securities fraud that Crouse was trying to report. Crouse did not realize until later that Bennett was intentionally refusing to assist her with proper reporting and instead compelling her to compose a piece specifically linked to Graves’ case as a way to establish a potential conflict of interest scenario should Crouse later be able to move forward with her investigation. Crouse sent Bennett an email on Jan. 23, 2017 discussing her awareness of this scheme and exposing what she understood at the time to be the implications of the situation, including Bennett’s attempt to get his daughter to connect Crouse to pursuit of monetary damages in the case.

      When Crouse later attempted to contact the Houston Police Department to file a report, she was first diverted because she did not have a “file number” or know the appropriate department. When Crouse later encountered McClelland and sought his assistance, she was diverted to a church whose atmosphere and indirect method of engaging Crouse made her suspect that she was being targeted for engagement in a prostitution ring being set up using homeless women for the upcoming SuperBowl. Crouse attempted to report this to a Houston IAD agent in January of 2017, who ridiculed Crouse and refused to assist her, instead diverting her to the FBI. 

      Crouse later learned that transactions engaged during the SuperBowl were directly related to the Houston Police Pension Fund fraud scheme that she attempted to report to several offices beginning on June 26, 2017. Crouse attempted to file reports with the Constable Precinct 1 Office, the Harris County Attorney and the Harris County District Attorney prior to her detention. The Constable referred her to the HPD; the Harris County Attorney engaged in multiple acts that served to divert Crouse including one staff member referring her to the Harris County District Attorney; and the Harris County District Attorney told her she need to file a police report but refused to give her any information on what charges to file or with what department to file.

      After Crouse’s detention, Crouse again attempted to contact law enforcement bodies and several state and federal legislators to report on the organized criminal activity and seek assistance with how to submit evidence. Crouse contacted the Houston Office of the Department of Justice twice and the Houston Office of the Federal Bureau of Investigation twice. All four times, Crouse’s contact information was taken but no one ever contacted Crouse back and Crouse was not permitted to submit any evidence or file any of her reports. Hence there was no chain of evidence with any official law enforcement body establishing a timeline around commission and reporting of crimes and no appropriate method for Crouse to engage in an appropriate application of TRAP Rule 21.7 should Crouse ever be able to take her case to trial and need to appeal.

      The issue of documentation is also at the core of Crouse’s second issue, concerning her request for the Court to consider the applicability of the Texas Organized Crimes Act §71.01 TPC in investigating the pattern of racketeering activity prompting this appeal and to declare it as in violation of 21 USC §963.

U.S. v. Williams, 809 F.2d 1072 (5th Cir. 1987) states:

“…because of federal government’s treatment of marijuana, the RICO statute gives a person of ordinary intelligence fair notice that marijuana is included as a dangerous drug and would serve as predicate of RICO.”

      While at this time controlled substances that are scheduled as prescription medications for medical treatment may not qualify as “narcotics,” this case shows how and why they are “dangerous drugs” as defined through the above-referenced case and should therefore also be accountable to laws that define “narcotics” and distribution of narcotics per 21 USC §963. These controlled substances do impact brain chemistry and also contribute to behavior modification. Without adherence to certain standards, habituation to the processes of acquiring, consuming, storing and distributing such controlled substances can contribute to the proliferation of criminal activity in much the same manner as do those controlled substances classified as “narcotics.”

      These controlled substances are distributed through hospitals wherein they are originally prescribed and shelters that refer or demand that persons residing within acquire a mental health assessment with attendant treatment involving controlled substances. The prescription itself creates a number of economic variables that can and are assigned to others to whom the hospitals and shelters refer persons in an effort to acquire additional resources. Programs requiring the acquisition, consumption, onsite storage and/or distribution of controlled substances and that are engaged in experimental behavioral economics testing must therefore be held accountable for the means by which persons acquire, consume, store and distribute controlled substances. This accountability requires caution in assuring that controlled substances are acquired, consumed, stored and distributed correctly, especially considering that the intent of habituating persons to patterns of resource acquisition, consumption, storage and distribution are inherent in the process of participating in behavioral economics testing modalities. At the least, this obligates providers to adhere to appropriate procedures so as to assure that the distribution of these controlled substances through referrals is not a criminal act. At most, it compels administrators to exercise vigilance to assure that they or no one from whom they receive economic or other benefit through the assignment to others of economic variables associated with the prescription of controlled substances are engaged in a conspiracy to commit a crime or are actively participating in organized criminal activity. 

      That persons are then discharged from a hospital or shelter with a prescription to acquire, consume, store and distribute controlled substances upon exit requires physicians and providers to exercise caution in assuring that persons understand the dosage and side effects of the controlled substances as well as how to acquire, consume, store and distribute or not distribute the controlled substances responsibly. There are several policies and procedures for assuring that persons are prepared to assume this responsibility, such as adherence to the Health Information Protection and Portability Act and the Texas Patient’s Bill of Rights. Willful refusal to apply the precepts of these policies and procedures demonstrates a reckless disregard for the implications behind prescribing controlled substances expressly aimed at altering brain chemistry and effecting behavior modification. This is at best a form of criminal negligence under §6.03(d) TPC. Penalizing persons who attempt to inform physicians or providers of the appropriate procedure for prescribing controlled substances is a form of theft under §31.03(f)(4) TPC.

      Forcing persons to remain in a facility while in deliberate violation of the appropriate legal procedure for doing so is a form of kidnapping per §20.03 TPC. Physicians and providers who refuse to release persons from a facility, permit persons to return to a facility, or refuse to permit them to acquire services from a facility for lack of acquisition, consumption, storage and distribution of controlled substances — or any economic variables associated with being referred to another service provider after being prescribed controlled substances — commit an additional act of extortion through “fear of economic harm” [U.S. v. Crockett, 979 F.2d 1204 (7th Cir. 1992) in reference to United States v. Nedza, 880 F.2d 896, 902 (7th Cir. 1989)]. Sending persons from one provider in the network to another provider in the same network using the economic variables associated with the prescription of controlled substances as well as threatening to withhold resources or subject persons to harm through abuse of the legal process is a form of trafficking per §20A.01(d) and (g) TPC.