OBrien_v

CASE NO. _

_

IN THE CIRCUIT COURT FOR DAVIDSON COUNTY
STATE OF TENNESSEE

CATHLEEN ANN O’BRIEN,

Plaintiff,

v.

ROBERT C. BYRD (a/k/a Cornelius Calvin Sale Jr.),
MICHAEL A. AQUINO,
JACK H. GREENE,
WAYNE COX (a/k/a Edward Wayne Cox),
and JOHN DOES 1–10 (political officials, co-conspirators, and masked participants whose identities are known to Defendants and who participated in the acts described herein),

Defendants.

COMPLAINT

Plaintiff Cathleen Ann O’Brien, by and through her undersigned counsel, complains of Defendants and respectfully shows the Court as follows:

I. JURISDICTION AND VENUE

1. This Court has subject-matter jurisdiction over this action pursuant to Tennessee Code Annotated §§ 16-10-101 et seq. and the general civil jurisdiction of the Circuit Court, as the claims arise from tortious acts occurring within the State of Tennessee.

2. Venue is proper in Davidson County pursuant to Tennessee Code Annotated § 20-4-101 because a substantial part of the events or omissions giving rise to the claims occurred in Nashville, Davidson County, Tennessee, specifically at the abandoned Union Station train depot and related locations within the county.

3. Defendants are subject to the long-arm jurisdiction of this Court because they purposefully availed themselves of the privilege of conducting activities within Tennessee by attending and participating in official political and entertainment events in Nashville, where they engaged in the unlawful conduct described below.

II. PARTIES

4. Plaintiff Cathleen Ann O’Brien is an individual who resides in the United States and was, at all times relevant herein, a minor (approximately fourteen years of age) subjected to repeated, systematic abuse while under the control of Defendants and their co-conspirators.

5. Defendant Robert C. Byrd was a U.S. Senator from West Virginia and participated in events at the Grand Ole Opry in Nashville, where he directly abused Plaintiff and orchestrated subsequent ritual abuse.

6. Defendant Michael Aquino (masked and unidentified to Plaintiff at the time) attended and participated in the ceremonial ritual abuse at Union Station while disguised, without Plaintiff having direct personal acquaintance with him.

7. Defendant Jack Greene was a country music performer who facilitated Plaintiff’s presence at the Grand Ole Opry and coordinated her transfer to the site of ritual abuse.

8. Defendant Wayne Cox was Plaintiff’s assigned handler and primary perpetrator of the underage rape and ceremonial ritual abuse at Union Station; he also committed murder and amputation in Plaintiff’s presence as part of the occult trauma.

9. John Does 1–10 are additional political officials, aides, masked ritual participants, and co-conspirators who facilitated or participated in the abuses in Nashville and whose identities will be ascertained through discovery.

III. FACTUAL ALLEGATIONS

10. When Plaintiff was approximately fourteen years old, in 1975, she was taken to Nashville, Tennessee, as part of a programmed “mission” involving high-level political and entertainment figures. The evening began with visits to multiple sleazy country music nightclubs in the Printer’s Alley district of downtown Nashville, followed by attendance at the Grand Ole Opry.

11. At the Grand Ole Opry, Defendant Jack Greene introduced Defendant Robert C. Byrd as a “special guest.” Plaintiff was drugged and, under pre-conditioned trance, was directed backstage to a dressing room shared by Greene and Byrd, where Byrd subjected her to sexual abuse.

12. Instead of being returned to her hotel as arranged, Plaintiff and her companion were further drugged and taken by Defendant Wayne Cox on a “flashlight tour” through the rubble of the then-abandoned Union Station train depot in Nashville (a facility that ceased passenger operations and was closed to the public by 1979). There, in the darkened, derelict structure, Cox and masked co-participants—including Defendant Michael Aquino, who remained unidentified to Plaintiff—conducted a satanic ceremonial ritual involving extreme sexual battery, physical torture, and occult trauma.

13. During this ritual, Plaintiff was subjected to underage rape by Cox and others. No protection was used, resulting in Plaintiff’s impregnation on one or more occasions and subsequent forced abortions as part of the ongoing pattern of exploitation.

14. Plaintiff witnessed Defendant Cox commit murder and amputation of a victim during the same evening’s events at Union Station, an act intended to further traumatize Plaintiff and enforce compliance through terror.

15. These acts were part of a larger pattern of trauma-based coercion, including physical and psychological manipulation, designed to control Plaintiff’s mind and body for the sexual gratification, political objectives, and occult rituals of Defendants. All conduct occurred in Davidson County, Tennessee, and caused Plaintiff severe, permanent physical and emotional harm, including dissociative identity disorder, chronic pain, and profound psychological trauma.

16. Defendants acted in concert with one another and with Plaintiff’s father (and other handlers) to conceal these crimes through threats, ritualistic programming, drugging, and exploitation of Plaintiff’s compartmentalized memory.

IV. CAUSES OF ACTION

COUNT I – SEXUAL BATTERY AND ASSAULT
(Against All Defendants)
17. Defendants intentionally and unlawfully touched Plaintiff in a harmful and offensive manner, including sexual penetration and other sexual acts, without consent.
18. As a direct and proximate result, Plaintiff suffered severe physical injury, emotional distress, and long-term psychological harm.

COUNT II – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against All Defendants)
19. Defendants’ conduct was extreme and outrageous, exceeding all bounds of decency, and was undertaken with the intent to cause, or with reckless disregard of the probability of causing, severe emotional distress.
20. Plaintiff has in fact suffered severe emotional distress, including but not limited to dissociative disorders, suicidal ideation, and permanent psychological damage.

COUNT III – FALSE IMPRISONMENT AND COERCIVE CONTROL
(Against All Defendants)
21. Defendants unlawfully restrained Plaintiff’s liberty through physical force, threats, drugging, and psychological coercion, holding her in a state of involuntary servitude in Nashville for purposes of sexual exploitation and ritual abuse.
22. Plaintiff was deprived of her freedom of movement and autonomy as a direct result of Defendants’ actions.

COUNT IV – BATTERY AND ASSAULT (WITNESSED MURDER AND AMPUTATION)
(Against Defendant Cox and Co-Conspirators)
23. Defendant Cox, in the presence of Plaintiff and with the knowledge and facilitation of the other Defendants, committed murder and amputation as part of the ceremonial ritual, directly causing Plaintiff additional severe emotional and psychological trauma.

V. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully prays for judgment against Defendants, jointly and severally, as follows:

A. Compensatory damages in an amount to be proven at trial, but not less than $50,000,000.00;
B. Punitive and exemplary damages in an amount sufficient to punish Defendants and deter future misconduct;
C. Pre- and post-judgment interest at the maximum legal rate;
D. Costs, attorneys’ fees, and expenses as allowed by law;
E. Such other and further relief as this Court deems just and proper.

Plaintiff demands a trial by jury on all issues so triable.