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William C.

Pro Se Litigation
P.O. Box 4823
Baltimore, Maryland 21211

April 1, 2015
The Hon. David A. Faber via: Hand Delivery
United States District Judge
C/o Clerk
United States District Court
District of Maryland
101 West Lombard Street
Baltimore, Maryland 21201
RE: Civil Case No.: 15-00199-DAF
RE: Notice of Possible Attorney Conflict of Interest and Other Matters
Dear Judge Faber:
I write to you today regarding several concerns I have with the above case.
1. When I filed this case, the courts intake clerk supervisor, Kay Owens, told me that the
complaint and IFP motion would have to be approved by a judge before the summons would be
stamped and returned for service and/or served by the U.S. Marshal.
2. The complaint addresses two requests for relief: (1) injunctive and (2) qui tam and/or similarly
styled. Because of the order of the complaint, the civil cover sheet was filled out as it was and
the caption and filing were done with that in mind.
3. That said, count (2) two clearly is a 31 U.S.C. 3730 claim for relief. If the caption of the
complaint should have read United States ex rel. William C. Bond v. Johnny L. Hughes et al.,
then I ask the court to sua sponte make that change.
Likewise, while clearly filing and service was not done in the manner 3730 suggests, it appears
that the practical effect is the same: the court has held the complaint for the 60 days as required,
a time which has now passed, and there is no evidence it was ever live on the docket or
publicized outside of the limited notice to the defendants, which was given to both defendants
and the government on or about the date of filing.
4. It should also be clear that on page (2) of the complaint, in addition to the codes and statutes

stated, the complaint is also brought under 18 U.S.C. 641, that there should be a five (5) before 5
C.F.R. 2635.704, that this is a FCA case under 31 U.S.C. 3730; and that jurisdiction is also under
31 U.S.C. 3732.
5. I apologize for the above items as I always strive to make my filings the best they can be.
Nevertheless, I believe these issues and/or omissions are excusable under a pro se analysis and
do not merit the use of my one allotted amended complaint for correction.
6. That said, I am very concerned about the Maryland U.S. Attorneys Offices (USAO MD)
representation of the Maryland U.S. Marshal and his officers (USMS MD) because of the
obligations and rights the DOJ is granted by statute in 31 U.S.C. 3730. As the court knows, the
statute gives continuing rights to the government that can be acted upon by the government
throughout the litigation.
I am also concerned that the USMS and/or U.S. DOJ are processing a FOIA request that relates
to this litigation.
Simply put, I dont see how the government can both represent the Marshal and take care of their
responsibilities under 3730, while also processing a FOIA claim about the same subject.
7. I am also very concerned about how the USAO MD has found themselves in this case when
the defendants were never served. I do not believe that the USAO MD is incompetent or that
they do not know how to read a docket.
8. What I do believe is that the USAO MD, lacking any real defense in this matter and seeing
great exposure in many areas, has attempted to subvert the courts initial order as stated in item
no. 1 by, not through answer, but through action, taking a stance which throws plaintiffs whole
action upon its head and creates a conundrum of irreconcilable conflicts of interests for the
9. Clearly, the only time a plaintiff has total control of his case is at the initial stage from filing
leading up until the defendants answer. In this case, the government had to and/or still has to
answer as to their position under 31 U.S.C. 3730 in regard to plaintiffs action. It is hard to see
how deciding to represent the USMS MD constitutes that answer, and leaves open the question
of how in the world could U.S. DOJ then meet their responsibilities under 3730 in the future?
10. In my opinion, this case is no different from the hypothetical of the manager of a health club
giving his friends free use of the health clubs facilities without the health club owners
knowledge or consent. That, in this case, the manager is the U.S. Marshal and his officers and
the friends are Article III judges is really of no moment under the law.
I ask that this court make whatever rulings and/or orders are necessary to move this case
forward. In the alternative, I ask that the court schedule a chambers conference, either in-person
or telephonically, as soon as possible to discuss these and any other matters necessary.
I hope this letter finds you well.

Very truly yours, I am

William C. Bond
cc: Matthew P. Phelps, AUSA, USAO MD via: Email