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Writ of Mandamus Filed in Minnesota


Ed Felien, Writ of Mandamus
State of Minnesota District Court
Fourth Judicial District
Hennepin County
Ed Felien, Writ of Mandamus
Petitioner
Vs
Michael Freeman, Hennepin County Attorney

Persuant to Minnesota Statute 586.01 we petition the Court to order Hennepin County Attorney
Michael Freeman to arrest George W. Bush when he arrives here at the end of August, 2008 to
attend the National Republican Convention. Minnesota Statute 586.01 clearly states that this
court may issue a writ of mandamus to any person to compel the performance of an act that the
law specially enjoins as a duty resulting from their office.
The Minnesota Appeals Court has held in Demolition Landfill Servs., L. L. C. v. City of Duluth,
609 N. W. 2nd 278, 280 (Minn. App. 2000), review denied (Minn. July 25, 2000), “To be entitled
to mandamus relief the petitioner must show three elements: (1) the failure of an official to
perform a duty clearly imposed by law; (2) a public wrong specifically injurious to petitioners;
and (3) no other adequate remedy.”
It is the argument of this brief that George W. Bush has committed crimes against the people of
Hennepin County and as our chief law enforcement officer it is Michael Freeman’s
responsibility to charge him for these crimes. Ed Felien, petitioner, has written to County
Attorney Michael Freeman three times asking him to charge George W. Bush. Mr. Freeman
has refused saying he lacks jurisdiction to charge the President of the United States. This
complaint is not against the President of the United States acting in his official capacity. This
complaint is against George W. Bush acting as a private citizen for private gain.
This brief is not concerned with George W. Bush’s international crimes against humanity.
Those are matters for an international court. This brief is not concerned with George W. Bush’s
crimes against the Constitution. Those are matters for Congress. What concerns citizens of
Hennepin County is whether George W. Bush has violated Minnesota State law. Have his
actions caused serious harm to the citizens of Hennepin County? Was this harm incidental to
the legitimate performance of his official duties as President, or were his actions and the
consequent harm done in pursuit of personal gain? If, as I believe, there is probable cause that
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George W. Bush has committed crimes against the people of Hennepin County, then it is the
responsibility and duty of the County Attorney to charge him for these crimes and hold him
accountable. There is no other office that has this authority.
Does the Hennepin County Attorney have jurisdiction to bring charges against George W.
Bush? Are we a nation of men where the one with the biggest club is king? Or, are we a
society governed by common laws and customs with avenues of civil redress of grievances for
all citizens? Is it possible that George W. Bush, as President of the United States, has
immunity from prosecution? Thomas Paine wrote in Common Sense 57 (Philadelphia, 1776),
“In America THE LAW IS KING. For as in absolute governments the King is the law, so in free
countries the law ought to be king; and there ought to be no other.”
The Supreme Court said in an 1882 decision, United States v. Lee, 106 U.S. 196, 220, 1 S.Ct.
240, 261, 27 L.Ed. 171, that:
No man in this country is so high that he is above the law. No
officer of the law may set that law at defiance with impunity. All the
officers of the government, from the highest to the lowest, are creatures of
the law, and are bound to obey.
It is the only supreme power in our system of government, and every
man who by accepting office participates in its functions is only the more
strongly bound to submit to that supremacy, and to observe the limitations
which it imposes upon the exercise of the authority which it gives.

If a crime occurs in Hennepin County, it is the duty of the County Attorney to investigate that
crime and bring the criminal to justice. There is no rank or privilege or elective office that is
higher than the law.
There are three areas in where the criminal acts of George W. Bush have violated Minnesota
law.

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THE CRIME OF MURDER
First, his pursuit of a war against the government of Iraq was not done in legitimate defense of
national interest but rather in pursuit of personal wealth. His administration lied about the threat
of weapons of mass destruction, and they lied about a connection between Iraq and
international terrorists. They knew Iraq did not pose a threat to the United States. The only
reasonable explanation for George W. Bush’s invasion of Iraq was that he stood to personally
benefit from the war.
To fully understand the Bush family financial interests in war profiteering it is necessary to
understand their family history.
Great-grandfather Samuel Prescott Bush was president of Buckeye Steel Castings. He
manufactured railroad couplings for railroads owned by the Morgans, Rockefellers and
Harrimans. During World War I he was on the War Industries Board and chaired the section on
forgings, guns, small arms and ammunition. He met and formed permanent trade relationships
with people from Dupont, Remington, Winchester and Colt. Sam Bush founded and became
the first president of the National Association of Manufacturers, an organization whose principal
objective was defending industrial capitalism from the threat of unions. He became an
indispensable part of the military-industrial complex, and he sent his son Prescott to Yale where
he could associate with the sons of his associates in the Skull and Bones fraternity.
Along with many of his college friends, Prescott joined Brown Brothers Harriman after college.
The biggest profits to be made in the 1920’s were in re-arming Germany. Harriman & Co. set
up Union Banking Corp with Prescott as Manager to trade with Nazi financier Fritz Thyssen.
They bought a steamship line to ship Remington arms to Germany through a dummy
corporation in Holland. Harriman & Co. bought Dresser Industries (manufacturers of oil
pipeline equipment) in 1929 and Prescott became a Director, and he continued to run Dresser
from the Board for the rest of his life. They, along with John Foster Dulles and others,
bankrolled Hitler as a shrewd business strategy. Prescott became Managing Director of Union
Bank in 1934 at the height of trade with Germany. In 1939 he took direct management of some
of the slave labor camps in Poland to aid Nazi armament, according to Dutch intelligence
sources.
In October of 1942, the U. S. government seized the assets of Union Bank and three other of
Prescott’s industries: the steamship line, the Seamless Steel Equipment Corporation (suppliers
of steel, wire and explosives to the Nazis) and the Silesian-American Company (the coal mining
company he managed along with John Foster Dulles on behalf of the Nazi Economic Minister).
This didn’t end Prescott Bush’s war profiteering career. Once the war started he simply
changed sides and started supplying war material to the Allies.
During the War friends of Prescott Bush from Skull and Bones were active in forming the OSS
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and its later incarnation, the CIA. Prescott’s relationship with the Dulles brothers would
become very useful during the Eisenhower years, with John Foster as Secretary of State and
his brother Allen Dulles as Director of the CIA. Prescott and Dresser Industries were kept well
inside the loop. Hans Gisevius, the German intelligence agent who acted as the go-between
with Allen Dulles in Switzerland and Admiral Canaris in the German High Command after the
war, acted as go-between with Dulles, Dresser Industries and Prescott Bush.
George Herbert Walker Bush, Prescott’s son, improved on the CIA connection to the point of
becoming its Director in 1976.
After graduating from Yale, George H. W. Bush went to work at his father’s firm, Dresser
Industries. Eventually, with money from Brown Brothers and Harriman (his dad’s parent
company) he set up his own company, Zapata. It was really a CIA front. The Bay of Pigs
invasion of Cuba in 1961 was probably George H. W. Bush’s operation as much as it was Allen
Dulles’s. The CIA code name for it was Zapata. The boats left for the Bay of Pigs from an
island that was leased to Bush, and the boats were named Houston and Barbara.
He ran for Congress in Houston in 1964 by campaigning against the Civil Rights Act. He didn’t
get elected that year, but he did get elected the next time he tried. When he was Chair of the
Republican Party in 1972 he set up ethnic heritage groups within the Party. These groups were
havens for ex-Nazis.
While Vice President under Reagan, Bush was Chair of the Special Situations Group
responsible for defeating the Sandanistas in Nicaragua. He and Ollie North set up, financed
and armed the Contras through an elaborate and highly secretive scheme that saw private
planes flying cash to Iran, buying Soviet-made guns, flying guns to the Contras at a private CIA
airstrip in Costa Rica, trading guns for marijuana and cocaine, then flying the drugs to a private
U. S. airbase in Homestead, Florida, where the drugs were traded for cash.
George Bush was Vice President under Reagan from 1980 to 1988. He was elected President
in 1988 and served one term until 1992. Dick Cheney was his Secretary of Defense. When
Bush lost the 1992 election, Cheney went from being Secretary of Defense to being CEO of
Halliburton, probably the largest supplier of goods and services to the Defense Department.
While Cheney was CEO of Halliburton he built up the company by buying other companies.
One of the companies he bought was Dresser Industries for $8 billion. When he bought it,
Halliburton’s stock dropped by a third. Wall Street thought it was a bad investment. Why did
Cheney pay so much? The only reasonable conclusion could be that it was a sweetheart deal
because the owners of Dresser were his former and future employers. His loyalty was
rewarded when George W. Bush selected him as his Vice President for the 2000 campaign.
There is no evidence that large amounts of cash changed hands, so it must be assumed there
was a transfer of stock. Since the total value of Halliburton was $8 billion at the time and
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Cheney paid $8 billion for Dresser, it has to be assumed that the Bush family now owns at least
half of Halliburton.
As the faithful family retainer, Cheney could be counted on to understand and value the
principal Bush family objective: to make money from war profiteering and oil. During the 2000
presidential election Cheney admitted Halliburton did business with Libya and Iran, but he
denied they had done business with Iraq, “I had a firm policy that we wouldn’t do anything in
Iraq, even arrangements that were supposedly legal. We’ve not done any business in Iraq
since U. N. sanctions were imposed on Iraq in 1990, and I had a standing policy that I wouldn’t
do that,” he said on ABC-TV’s This Week on July 30, 2000. But Dresser was selling equipment
through French subsidiaries to Iraq from early in 1997 through 2000. Halliburton didn’t buy
Dresser until 1998, so from 1997 to 1998 it was the Bush family business that was trading with
the enemy in violation of American law and U. N. sanctions. From 1998 through 2000, after
Halliburton purchased Dresser, Halliburton continued the practice. Purchasing the company
also covered up the trail and dusted off any Bush fingerprints.
Already in June of 1998 Cheney made the case, in a speech before the Cato Institute, that
sanctions don’t work and unilateral sanctions are bad for U. S. companies involved in
international business. The very sanctions against trade with Iraq that he wanted lifted were the
ones he was responsible for putting in place after the first Gulf war. Although he never said it
directly, he clearly wanted sanctions against Iraq lifted: “The good Lord didn’t see fit to put oil
and gas only where there are democratically elected regimes friendly to the United States.
Occasionally we have to operate in places where, all things considered, one would not normally
choose to go. But, we go where the business is.” Even before he took over Bush’s problem,
he was defending it.
George W. Bush, in the best traditions of his family, waged war against the people of Iraq so
that Halliburton could assign oil leases and thereby control the supply and price of oil and so
that Halliburton would get multi-billion dollar no-bid contracts to supply the military. More than
4000 Americans have lost their lives in Iraq. Of that number 60, as of March 29, 2008, were
from Minnesota. Of that 60, three were from Hennepin County.
David Day of St. Louis Park was killed on February 21, 2005 when a roadside bomb went off.
He joined the National Guard so he could pay for his training to become a police officer. Day
had been a member of the St. Louis Park Police Department for about eight months before his
deployment to Iraq.
Army Spc. Robert Dixon, 27, of Minneapolis, died Sunday May 6, 2007 in Baghdad. He was the
gunner on top of a Humvee when it was hit. He and his wife were married for less than two
years.
Lance Cpl. Scott Modeen, 24, of New Hope, was killed by a roadside bomb in Fallujah on
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December 1, 2005.
These men were victims of a deliberate fraud perpetrated by George W. Bush in an improper
use of his office as President of the United States. There were no stockpiles of uranium or
poison gases. There was no international conspiracy of terrorists of which Saddam Hussein
was a part. Bush cynically exploited the patriotism of these young men for the sole purpose of
enriching himself as a war profiteer and oilman.
Because he has committed troops of the Minnesota National Guard to tragic danger and
fatalities in Iraq for the sole purpose of enriching his family’s business, Halliburton, and,
thereby, causing the death of Minnesota citizens, he is guilty of committing murder in the third
degree: Section 609.195: MURDER IN THE THIRD DEGREE: whoever, without intent to effect
the death of any person, causes the death of another by perpetrating an act eminently
dangerous to others and evincing a depraved mind, without regard for human life, is guilty of
murder in the third degree and may be sentenced to imprisonment for not more than 25 years
on each count.
THE CRIME OF CONSPIRACY TO FIX PRICES
The price of a barrel of crude oil has almost doubled since the beginning of the Iraq War. That
has implications for the price of gasoline at every service station in Hennepin County.
Through the sale of oil drilling equipment, Dresser Company and the Bush family have had a
relationship with the Saudi royal family stretching back three generations. The bin Laden family
have been the principal contracting firm for the Saudi royal family, so it was natural for the bin
Laden family to give George W. Bush $50,000 to get started in the oil exploration business in
Texas. Bush returned the favor by grounding all aircraft after 9/11 except the plane that
evacuated those members of the bin Laden family staying in the U. S. There was a video of
Crown Prince Faisal visiting George W. Bush at his ranch in Crawford, Texas. They were seen
holding hands as they walked, evidence of a stronger relationship than the one Bush had with
Tony Blair or Berlusconi.
As head of the Bush family, George W. Bush directs their investment in Halliburton.
Halliburton directs the movement of oil out of Iraq, 25% of the world’s supply. The Saudi family
directs the movement of oil out of Saudi Arabia, 40% of the world’s supply. It is reasonable to
assume that when George W. Bush and Prince Faisal get together they talk about the supply
and price of oil. After their last meeting in Saudi Arabia, supplies dropped and the price of oil
rose dramatically. According to Minnesota State law that meeting looks suspiciously like a
conspiracy to fix prices.
Because, through Halliburton’s control of Iraqi oil, he has acted in collusion with Saudi Arabia
and OPEC to fix the price and supply of oil to distributors in Hennepin County, he is guilty of
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price fixing: Section 325.53: PROHIBITED CONTRACTS, COMBINATIONS, AND
CONSPIRACIES: Subdivision 1. Price fixing, production control, allocation of markets, collusive
bidding, and concerted refusals to deal. Without limiting section 325D.51, the following shall be
deemed to restrain trade or commerce unreasonably and are unlawful: (1) A contract,
combination or conspiracy between two or more persons in competition: (a) for the purpose or
with the effect of affecting, fixing, controlling or maintaining the market price, rate or fee of any
commodity or service; (b) affecting, fixing, controlling, maintaining, limiting, or discontinuing the
production, manufacture, mining, sale or supply of any commodity, or the sale or supply of any
service, for the purpose or with the effect of affecting, fixing, controlling, or maintaining the
market price, rate, or fee of the commodity or service.

THE CRIME OF CONSPIRACY TO DISTRIBUTE HEROIN
Finally, George W. Bush should be arrested and prosecuted for his collusion with the opium
warlords in Afghanistan to distribute heroin in Hennepin County.
The National Drug Intelligence Center in its Minnesota Drug Threat Assessment report of
August, 2001, said “Historically, heroin abuse has been low in Minnesota, but there are signs of
increased use. There were 36 opiate-related deaths in Hennepin County through September
2000, compared with 27 in all of 1999.”
The United Nations and all objective reports verify that during the last year of the Taliban reign
in Afghanistan, their government had reduced the Afghanistan contribution to the world supply
of opium and heroin to zero, and everyone agrees that since the opium warlords have taken
back control of the rural areas of Afghanistan opium production in Afghanistan now contributes
90% of the world supply. The U. S. Army and the CIA worked to support the opium warlords
and granted them effective control over most of the opium growing areas of Afghanistan. They
continue to support the opium warlords by protecting their estates from the peasants and small
farmers from whom the land was taken. The CIA got opium warlords a respected place in the
central government. The CIA even insured that an opium warlord would be in charge of the
Department of the Interior—the government agency responsible for drug enforcement.
The CIA was actually born out of a conspiracy to distribute heroin. One of the most important
Mafia figures at the beginning of World War II was Meyer Lansky. He convinced the OSS (the
Office of Special Services, the early precursor to the CIA) that Mafia contacts in Sicily could be
very useful in facilitating an Allied invasion. In exchange for Mafia cooperation the U. S.
government freed Lucky Luciano from prison and made it easier for the Mafia to import heroin.
Since then the Mafia in America has always been a ready and willing patriot in any CIA off the
shelf adventure. When Ollie North brought cocaine and marijuana in from Colombia, the Mafia
was ready to pay cash for it and distribute it. Ollie North knew these contacts when he was
working with the Hmong and Meo tribes in Laos during the Vietnam War. As part of the golden
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triangle these tribes produced large amounts of opium that CIA planes would then transport to
Marseille, continuing the colonial tradition begun by French forces in Vietnam. George H. W.
Bush was a part of all this because he was Director of the CIA when the golden triangle was
active, and he was Vice President during the Contra War, and he was probably in charge of the
operation to fund the Contras through the illegal importation of cocaine and marijuana.
Opium poppies have grown in Afghanistan since ancient times. The British began to control
the exporting of the drug early in the nineteenth century. The Opium War in China in the
middle of the nineteenth century was a result of the Chinese government trying to forbid the
British importation of opium. The British won the war and the Chinese were forced to allow the
British to sell opium. Early in the twentieth century Sicilians and Italians found the opium
through contacts in Beirut and had it manufactured into heroin in laboratories in Marseilles.
The heroin was then smuggled into Europe and the United States.
The traditional route for smugglers was over the mountains from Afghanistan, through Iran,
Iraq, Jordan and to Beirut, Lebanon. The lack of cooperation recently of the Iranian
government in this smuggling conspiracy has created problems for the smugglers and
international problems for Iran. But, thanks to the active cooperation of the CIA and the U S
government, opium does make its way through the Middle East, to Sicily and laboratories to be
refined into heroin and, finally, to the U S and Hennepin County.
Section 609.228 of the Minnesota penal code, GREAT BODILY HARM CAUSED BY
DISTRIBUTION OF DRUGS, says, “Whoever proximately causes great bodily harm by, directly
or indirectly, unlawfully selling, giving away, bartering, delivering, exchanging, distributing, or
administering a controlled substance classified in schedule I or II may be sentenced to
imprisonment for not more than ten years or to payment of a fine of not more than $20,000, or
both.

Whereas there is probable cause to believe George W. Bush is guilty of murder in the third
degree through his wanton disregard of human life in his pursuit of profits for his family’s
business, thereby ending the lives of Hennepin County residents David Day, Robert Dixon and
Scott Modeen, and
Whereas there is probable cause to believe that George W. Bush and the Saudi royal family
have entered into a conspiracy to withhold oil supplies and raise the price of crude oil causing
gasoline prices to dramatically increase in Hennepin County, and
Whereas there is probable cause to believe that George W. Bush has acted in collusion with
the opium warlords of Afghanistan and elements within the CIA to distribute heroin in Europe,
the United States and Hennepin County,
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Therefore, the petitioner asks this court to order Hennepin County Attorney Michael Freeman
to bring charges of Murder in the Third Degree, Section 609.195; Conspiracy to fix prices,
Section 325D.51; and Conspiracy to distribute drugs, Section 609.228 against George W. Bush
and present them to a Grand Jury so that a Grand Jury may return a Bill of Indictment and
George W. Bush may be arrested and made to stand trial when his plane lands in Hennepin
County at the end of August.

Respectfully submitted,
Ed Felien
3152 10th Avenue South
Minneapolis, MN 55407
612 827 3381
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