PART 2

UNITED STATES FEDERAL COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

CIVIL LAWSUIT NUMBER 99-1675-CIU-T-25A
FILED July 18, 1999

RUGGERO MARIA SANTILLI
35246 US 19 No PMB 115
Palm Harbor, FL 34684

Plaintiff

vs.

ELIO CONTE
Libero Istituto Universitario Internazionale
Centro Studi Radioattivita'
Via Dante Alighieri 256
I-70122 Bari, Italy

MARIA PIERALICE
Libero Istituto Universitario Internazionale
Centro Studi Radioattivita'
Via Dante Alighieri 256
I-70122 Bari, Italy

The President
LIBERO ISTITUTO UNIVERSITARIO INTERNAZIONALE
Centro Studi Radioattivita'
Via Dante Alighieri 256
I-70122 Bari, Italy

EUGENE E. MALLOVE
Bow Technical Center
3 Robinson Rs, Building A, Suite 6
Bow, NH 03304

BARBARA A. F. DELLO RUSSO
Bow Technical Center
3 Robinson Rs, Building A, Suite 6
Bow, NH 03304

THOMAS E. PHIPPS, jr.
908 South Busey Ave
Urbana, IL 61801

COLD FUSION TECHNOLOGY, INC.
P. O. Box 2816
Concord, NH 03302-2816

ENRICO PANARELLA
ALFT, Inc.
189 Devensult St. No. 7
Hull, PQ J8Z 1S7 Canada

K. CHARBONNEAU
ALFT, Inc.
189 Devensult St. No. 7
Hull, PQ J8Z 1S7 Canada

B. R. ROBINSON
ALFT, Inc.
189 Devensult St. No. 7
Hull, PQ J8Z 1S7 Canada

ALFT, Inc.
189 Devensult St. No. 7
Hull, PQ J8Z 1S7 Canada

Defendants,

     In this Complaint, by acting pro se as an individual U. S. Citizen under the protection of the First Amendment of the Constitution of the United States of America, and without any connection, whether explicit or implied, with the institutions or corporations to which he may be affiliated, Plaintiff SANTILLI hereby sues Defendants, CONTE, PIERALICE, LIBERO ISTITUTO UNIVERSITARIO INTERNAZIONALE, an Italian administrative conduit, MALLOVE, DELLO RUSSO, PHIPPS, COLD FUSION TECHNOLOGY, a New Hampshire Corporation, PANARELLA, CHARBONNEAU, ROBINSON, ALFT, INC., a Canadian corporation, because of severe injuries, damages, and losses suffered due to:
     1) "Plagiarism", hereinafter defined as copying physics equations, texts and definitions whose copyright is owned by Plaintiff without the quotation of such origination;
     2) "Frauds", hereinafter defined as stealing theories originated and developed by the Plaintiff without the quotation of such a paternity;
     3) "Deception", hereinafter defined as the premeditated intent to cause the deceptive belief of the paternity of physical theories originated and developed by the Plaintiff.

     This lawsuit is filed under: the U. S. Copyright Act, U.S. Code, Title 17, Section 101 et seq.; the adherence in 1989 by the United States of America to the Berne Convention, for which all scientific publications in the U.S.A. after 1989 are protected even if no copyright notice has appeared in them; and any other Statutes at Law that may result to be applicable during the legal proceedings pertaining to this Complaint. The term "publication" is specifically and solely referred to scientific articles that have been printed and distributed to the public. It should be recalled that, according to the U. S. Copyright Act, U.S. Code, Title 17, Section 101 et seq., an infringement of copyrights occurs even when a small part of a given copyrighted work has been copied, e.g., a few words out of a book containing 100,000 words, particularly when the partial copying refers to the "heart of the work". It should be moreover recalled that the duration of the copyrights pertinent to this Complaint as set up by the current Law is the life of the Plaintiff plus fifty years.

     Plaintiff begs for leniency this Honorable Court for preparing and filing this complaint pro se without technical assistance by attorneys.

     Such preparation and filing was rendered mandatory by the fact that, following an extensive search, Plaintiff was unable to locate an attorney with an advanced, post-Ph. D. knowledge of mathematics and physics, which is necessary to understand, appraise, and describe the mean facts of this lawsuit.

     In view and consideration of the above, Plaintiff has made a true effort in rendering the technical topic of this Complaint understandable by all readers without any need of a Ph. D. in mathematics and physics.

     Plaintiff additionally begs this Honorable Court for leniency in regard to insufficiencies of this Complaint which are expected under the above circumstances.

     Plaintiff also begs this Honorable Court for leniency in the format, such as the inclusion in Section II of a brief scientific summary understandable to all, which would be considered atypical for a conventional Complaint, but whose absence, in this particular instance, would render this Complaint basically un-understandable to the general audience.

     Finally, Plaintiff would like to reassure this Honorable Court that he intends to hire an attorney for the proper conduction of all legal proceedings at the time of their initiation following the filing of this Complaint.

     This complaint comprises:

     I. THE PARTIES

     II. SCIENTIFIC BACKGROUND AND SUMMARY OF CLAIMS

     III. FACTUAL ALLEGATIONS
     III.A: THE COPYRIGHTED SCIENTIFIC PUBLICATIONS SUPPLIED BY PLAINTIFF SANTILLI TO DEFENDANT CONTE.
     III.B: DEFENDANT CONTE AND PIERALICE SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN A FIRST PAPER PUBLISHED IN THE MAGAZINE "INFINITE ENERGY"
     III-C: PLAINTIFF DENUNCIATION OF DEFENDANTS CONTE AND PIERALICE MISBEHAVIOR AND DEFENDANTS RESPONSE.
     III.D: DEFENDANT CONTE SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN A SECOND PAPER AT "INFINITE ENERGY"
     III-E: DEFENDANTS MALLOVE, DELLO RUSSO AND PHIPPS CONSPIRATORIAL COMPLICITY IN DEFENDANT CONTE'S SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN THE ARTICLES AT "INFINITE ENERGY"
     III.F: DEFENDANT CONTE SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN ADDITIONAL PAPERS PUBLISHED IN THE MAGAZINE "PHYSICS ESSAYS"
     III-G: DEFENDANTS PANARELLA, CHARBONNEAU, AND ROBINSON, CONSPIRATORIAL COMPLICITY IN DEFENDANT CONTE'S SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN THE ARTICLES AT "PHYSICS ESSAYS"

     IV. JURISDICTION

     V. CLAIMS

     I. THE PARTIES

     1. Plaintiff RUGGERO MARIA SANTILLI is a U. S. physicist who held academic positions at the University of Miami in Coral Gables, Boston University, The Massachusetts Institute of Technology, Harvard University (both Departments of Physics and Mathematics), and is currently the President of The Institute for Basic Research, formerly located within Harvard Grounds, Cambridge, MA, and currently located in Palm Harbor, Florida. Plaintiff SANTILLI has conducted research under financial support from NATO, U.S. AIR FORCE OFFICE OF SCIENTIFIC RESEARCH, and the U.S. DEPARTMENT OF ENERGY. Plaintiff SANTILLI is the Editor in Chief of three international journals of mathematics and physics, and Editor of two additional Journals; he has published over 200 papers in numerous, prestigious, refereed, international, physics and mathematics journals; has written 15 monograph in mathematics, physics and chemistry all at a post Ph. F. level; and has been the editor of about 50 volumes of proceedings of international conference in post Ph. D. topics in mathematics, physics and chemistry. Plaintiff SANTILLI has been the recipient of several honors, including: two Gold Medals for Scientific Merits; a formal Nomination by the Estonia Academy of Sciences among the most illustrious applied mathematicians of all times jointly with Gauss, Weyerstrass, Lie, Hamilton, and other historical names; has been honored with the naming of a Teaching Hall in his name in an Australian Research Institute; and has been Nominated for the Nobel Prize in Physics by numerous scientists since 1985, in particular, because of his construction of hadronic mechanics and the all important application to the structure of the neutron which are at the foundations of this Complaint.

     2. Defendants E. CONTE and A. PIERALICE are Italian physicists.

     3. Defendant LIBERO ISTITUTO UNIVERSITARIO INTERNAZIONALE is the Italian administrative conduit of Defendants CONTE and PIERALICE.

     Defendants E. MALLOVE and B. DELLO RUSSO are editors of a magazine called "Infinite Energy".

     4. Defendant T. E. PHIPPS, jr, is a close associate of Defendant MALLOVE who conducts reviews for "Infinite Energy".

     5. Defendant OLD FUSION TECHNOLOGY, INC. is a New Hampshire corporation publishing and distributing "Infinite Energy"

     Defendants E. PANARELLA, K. CHARBONNEAU, and B. R. ROBINSON are editors of a magazine called "Physics Essays".

     6. Defendant ALFT, INC. is a Canadian corporation printing and distributing "Physics Essay" in the U.S.A. and in the rest of the world.

     II. SCIENTIFIC BACKGROUND AND SUMMARY OF CLAIMS

     7. The main scientific background and claims of this Complaint can be briefly summarized as follows.

     8. Stars at their formation are solely composed of hydrogen, i.e., bound states at large mutual distances of one electron and one proton. Subsequently, stars first synthesize in their interior the neutron, then the deuteron (which is the nucleus of hydrogen isotope composed by one proton and one neutron), and then all other nuclei as available on Earth.

     9. In 1920 E. Rutherford conceived the neutron as a "compressed hydrogen atom" in the interior of stars at their formation, i.e., as an electron totally compressed inside a proton by the extreme pressures existing in the core of stars.

     11. subsequently, the existence of the neutron was established experimentally by J. Chadwick in 1932. However, Rutherford conception of the neutron as a bound state of one proton and one electron compressed in its interior was rejected by the scientific community of the time, because incompatible with quantum mechanics on numerous counts, including the impossibility of representing the mass, radius, spin, meanlife, magnetic moments and other characteristics of the neutron.

     12. This occurrence forced a historical change in the direction of physical research, which consists of the transition from the consideration of the constituents of bound states solely given by actual, physical particles which can be isolated in our laboratory (as it had occurred for the atoms), to a new trend in which the constituents of the neutron are hypothetical particles (the quarks) which cannot be isolated in our laboratories and can only be formulated in an abstract mathematical space (technically called unitary space). In particular, quarks can have no connection whatever with our physical spacetime.

     13. Unfortunately, despite the efforts of many distinguished physicists, a number of fundamental inconsistencies of quark conjectures have remained unsolved to this day, such as: the inability to confine quarks inside the neutron (as mandated by the fact that they cannot be observed in an isolated form),; the impossibility for any consistent definition of gravity, thus predicting hypothetical matter that should experience no gravity at all; and other, more technical, huge inconsistencies.

     14. Despite the impossibility of a quantum mechanical representation, with the passing of the decades Rutherford's conception of the neutron as a bound state of a proton and an electron compressed in its interior, preserved in its clear plausibility. This is due to the fact that the proton and the electron are the most stable elementary particles existing in the universe. The belief imposed by quantum mechanics and quark conjectures that such permanently stable particles disappear at the formation of the unstable neutron, is a pure figment of academic imagination which cannot resist the test of time.

     15. Back in 1978, when at the Lyman Laboratory of Physics of Harvard University under support from the U. S. Department of Energy, in publications identified below as Refs. [1,2], Plaintiff SANTILLI argued that the insufficiencies of Rutherford's conception of the neutron rest with quantum mechanics and not with Rutherford's conception itself. Plaintiff SANTILLI therefore suggested in the same Refs. [1,2] the construction of a generalization/covering of quantum mechanics under the name of hadronic mechanics. In the same original publications of 1978, Plaintiff SANTILLI proposed the conceptual foundations of the new mechanics, its basic equations, as well as the new mathematical methods needed for its consistent treatment (introduced under the name of isotopies).

     16. The main argument presented in Refs. [1,2] is essentially the following. The validity of quantum mechanics for the structure of the hydrogen atom is beyond doubt. In particular, quantum mechanics has a majestic physical and mathematical consistency, technically due to the fact that the time evolution constitutes a unitary transform (let an nxn matrix A is said to be unitarily transformed via another matrix U of the same dimension, A -> A' UAU+, when UU+ = 1, where "+" stands for the operations of complex conjugations and transposed); . As a consequence, quantum mechanics enjoys the basic property of being invariant, that is:
     1) The units of measurements for time, length, energy, etc,. are invariant in time, thus permitting the consistent confrontation of the theory to experiments (in fact, all units 1 are preserved by unitary transforms because, for UU+ = 1, 1 -> 1' = U1U+ = 1);
     2) The theory preserves the original observability of physical quantities at all subsequent times (technically expressed by the invariance of the condition of Hermiticity under unitary transforms);
     3) Quantum mechanics admits unique and invariant numerical predictions (because of the uniqueness and invariance under unitary transforms of conventional and special functions and transforms used in the data elaboration);
     4) Quantum mechanics verifies causality, probability and other basic laws in an un-equivocal way;
     5) Quantum mechanics verifies the fundamental Galilei's and Einstein's relativities.

     As a result of these majestic features, quantum mechanics has been successfully applied throughout this century.

     17. Nevertheless, there is no credibility or supportive evidence in the belief that the mechanics exactly valid for the proton and the electron at the large distances of the hydrogen structure, must necessarily valid in an exact way also for the dramatically different physical conditions of an electron totally immersed inside a proton.

     18. It should be stressed that the use of the term "violation" of quantum mechanics for Rutherford's conditions would be nonscientific-political, the only acceptable term being "inapplicable" due to conditions different than those of the original conception.

     19. On technical grounds, Refs. [1,2] recalled that quantum mechanics has a mathematical structure which is linear (i.e., solely depending on the first power of the wavefunction), local (i.e., solely holding for a finite set of isolated points), and potential (i.e., solely admitting action-at-a-distance forces derivable from a potential energy). These conditions are indeed met for the structure of the hydrogen atom, because the large mutual distances permit a point-like approximation of the constituents, thus confirming the exact validity of quantum mechanics for the structure of the hydrogen atom.

     20. However, the fundamental point-like approximation of the constituents is simply impossible for Rutherford's conception of the neutron. In fact, the electron has a wavepacket which is of the same order of magnitude as that of the proton and of the neutron. In Rutherford's conception of the neutron we have, therefore, a total mutual overlapping of the wavepackets of the two constituents, one totally inside the other. These dramatically new physical conditions imply additional interactions which are nonlinear (because depending on powers of the wavefunctions bigger than one), nonlocal (because acting on the finite volume of the proton which cannot be reduced to a finite set of isolated points), and nonpotential (because of contact, zero-range type for which no action-at-a-distance potential is conceivable).

     21. n the same original proposal of Refs. [1,2], Plaintiff SANTILLI established that, since the mathematics of quantum mechanics was constructed for linear, local and potential theories, it is evident that the same mathematics is inapplicable to the more general nonlinear, nonlocal and nonpotential conditions of Rutherford's conception of the neutron. For this reason, Plaintiff SANTILLI proposed the construction of the new isotopic mathematics indicated earlier, which subsequently proved to provide indeed the only known consistent treatment of Rutherford's historical legacy, and is today known as Santilli's isomathematics.

     22. Hadronic mechanics was also conceived to be a covering of quantum mechanics, i.e., admitting the latter as a particular case, as well as merely consisting of broader realizations of conventional, quantum, abstract laws and axioms. This established the scientific credibility of hadronic mechanics ab initio, because the new mechanics verifies by construction all established physical laws, such as Pauli's exclusion principle, Heisenberg's uncertainty relations, etc.

     23. Hadronic mechanics was subsequently developed by numerous mathematicians, theoreticians and experimentalists in: an estimated number of 1,000 papers published in scientific journals all over the world; 15 post Ph. D. monographs; and some 40 volumes of proceedings of international conferences held on hadronic mechanics, including five international conferences held at Harvard University, one at the Massachusetts State University in Boston, three at the Institute for Basic Research in Cambridge, MA, one at the University of Orleans, France, one at the University of Patras, Greece, one at the University of Skopjei, then Yugoslavia, one at the International Scientific Center A. Volta, on the Lake of Como, Italy, and seven at the Italian location of the Institute for Basic Research, the Castle Prince Pignatelli, Monteroduni, Isernia, Italy. This vast scientific effort resulted in over 10,000 pages of published research. Nowadays, hadronic mechanics has numerous experimental verifications in particle physics, nuclear physics, superconductivity, chemistry, biology, astrophysics, cosmology and other quantitative sciences.

     24. The first feature of hadronic mechanics with a direct implication for this complaint is that the new mechanics has been proved to be universal, i.e., admitting as particular cases all infinitely possible generalizations of quantum mechanics, as established in numerous publications in prestigious refereed journals. In essence, a necessary condition for any theory to qualify as a bona-fide generalization of quantum mechanics is that its time evolution must be unitary (i.e., characterized by an nxn matrix with related transforms A -> A' = UAU+ such that UU+ is no longer 1). In fact, hadronic mechanics is characterized by the most general possible, nonlinear, nonlocal and nonpotential, nonunitary transformation UU+ of conventional quantum mechanics, which nonunitary transforms are defined for all possible numbers, including real numbers, complex numbers and quaternions.

     25. The first motivation for the filing of this Complaint is that, in articles published in the magazines called "Infinite Energy" and "Physics Essays", Defendant CONTE has copied identically virtually all the basic equations of hadronic mechanics without the identification of their true paternity and origination, thus constituting clear, documented plagiarisms.

     26. The second motivation for filing this complaint is that Defendant CONTE alleges the discovery of a new generalization of quantum mechanics which is claims to be different than quantum mechanics. In reality, it has been proved beyond any conceivable or otherwise credible doubt that the time evolution of Defendant CONTE studies is nonunitary, thus being a very small particular case of hadronic mechanics, thus constituting a fraud and deception, not only against the Plaintiff, but also against all other scientists who built hadronic mechanics.

     27. The technical origin of the additional motivation of this complaint is the following. It has been proved in refereed prestigious journals that, when treated with the mathematics of quantum mechanics, nonunitary theories are afflicted by inconsistencies so serious that they have been called catastrophic, such as:
     1') Nonunitary theories do not leave invariant the basic units of time, length, energy, etc., thus preventing the confrontation of the theory with experiments (in fact, any nonexpert reader can see that the unit is no longer preserved under the transform 1 -> 1' = U1U+ whenever UU+ is different than 1)
     2') Nonunitary theories do not contain observable quantities (technically because Hermiticity can be proved to be noninvariant under nonunitary transforms), thus having no physical value of any known type;
     3') Nonunitary theories have non-unique and non-invariant numerical predictions (because the conventional and special functions and transforms used in the data elaboration are both nonunique and noninvariant under nonunitary transforms);
     4') Nonunitary theories violate causality, because they can be easily proved to admit effects preceding the cause, and consequently violate all other known laws;
     5') Nonunitary theories grossly violate Galilei's and Einstein's relativities (because of their known strictly unitary character).

     28. One of the most important scientific achievements by Plaintiff SANTILLI published in prestigious refereed journals all over the world has been that of resolving the above inconsistencies 1')-5') without which no physical application of any type is conceivably or ethically possible for nonunitary theories. In particular, the resolution was permitted by the use of the new Santilli isomathematics, whose most fundamental axiom is the assumption of the nonunitary value 1' = U1U+ (different than 1) as a new generalized unit, and then the reconstruction of the entire mathematics in such a way to admit 1', rather than 1, as the correct unit. This study permitted the discovery of new numbers, called Santilli's isoreal, isocomplex and isoquaternions numbers, which are the conventional number with the new unit 1', a new multiplication, and other new operations; new spaces; new algebras; new geometries; etc.

     29. The third motivation for filing this complaint is that, in said articles published in the magazines "Infinite Energy" and "Physics Essays", Defendant CONTE alleges that his theory is fully consistent on physical grounds. However, the nonunitary character of such a theory has been proved beyond any conceivable or otherwise credible doubt, while the same theory is elaborated with the conventional mathematics of quantum mechanics. The catastrophic inconsistencies 1')-5' outlined above are then absolutely incontrovertible, because physics is an exact theory, and not an opinion. Said catastrophic inconsistencies have been communicated to Defendant CONTE numerous times in a documented and eyewitnessed way, as a result of which the allegation of physical consistency by Defendant CONTE constituents an intentional, premeditated, fraudulent deception which has damaged not only Plaintiff SANTILLI and all other scientists who have constructed hadronic mechanics, but also researchers in new energies which need generalized mechanics. This scenario demands the termination of this fraudulent deception by Defendant CONTE in any and all means permitted by Law.

     30. The additional technical motivations of this Complaint can be summarized as follows in a language accessible to a general audience.

     31. The first resolution of the historical open legacy of Rutherford, the neutron as a bound state of a proton and an electron, was achieved by Plaintiff SANTILLI in 1990 at the nonrelativistic level (i.e., for speed small as compared to that of light) in a copyrighted publication identified below, Ref. [3]. In particular, hadronic mechanics permitted in Ref. [3] the exact, numerical, invariant, and consistent representation of the totality of the characteristics of the neutron, with no exclusion, including: mass, radius, spin, meanlife, magnetic moment, spontaneous decay, etc. The resolution at the relativistic level (i.e., for speed close to that of light) was first achieved in 1993 also by Plaintiff SANTILLI in copyrighted publications Refs. [4,5] identified below.

     32. The fourth motivation for this Complaint is the fact that, in articles published in the magazines "Infinite Energy" and "Physics Essays" dedicated to Rutherford's conception of the neutron, Defendant CONTE plagiarized identically all the main copyrighted discoveries by Plaintiff SANTILLI in Refs. [3,4,5] without any quotation whatever of, specifically, the same publications. Since the latter publications had been brought to the attention of the defendant several years before under documented and eyewitnessed conditions, and since the Defendant himself has admitted the reception and the knowledge of the same publication in writing, Defendant CONTE has perpetrated a clear fraudulent plagiarism of Copyrighted discoveries by the Plaintiff.

     33. The additional motivations for this complaint originate from the fact that the case herewith considered has large scientific, industrial, and societal implications beyond those of a lawsuit. The above indicated historical shift in the conduction of physical research, from Rutherford's sound conception of the neutron with physical constituents, to the current conjecture that the hypothetical quarks are the neutron constituents, caused serious damages to society, because it eventually implied the contemporary nuclear power plants and related nightmare caused by their emission of extremely harmful radiations, and the additional still unsolved nightmare of where to dump tens of thousands of extremely harmful nuclear waste.

     34. In a copyrighted publication of 1994, later on identified as Ref. [10], additionally protected by Patent Pending, Plaintiff SANTILLI introduced a new form of clean energy under the name of hadronic energy, which originates precisely in the structure of the neutron. In essence, Ref. [10] showed that the problem of the constituents of the neutron is far from being a sole academic issue, because it carries large societal relevance. This is due to the fact that the neutron is the biggest reservoirs of clean energy available to mankind.

     35. An isolated neutron at rest decays spontaneously after a meanlife of about 15 minutes into a proton at rest, an electron emitted at high speed, and a neutrino (which is harmless to humans and the environment).

     36. The energy released in the decay of the neutron is very large (technically given by 0.8 millions of electron volts). It can be visualized by saying that the electrons emitted in the decay of the neutron carry 100,000 times more energy than the electrons hitting a computer screen. Therefore, a screen invested by the preceding electrons instantly heats-up, thus constituting a large source of energy which can be utilized via heat exchanges or other means. Moreover, this energy is clean in the dual sense that: it does not release harmful radiations (because a simple metal shield can easily trap all electrons emitted in the neutron decay). Moreover, the decay is clean because it does not release harmful waste, as it is the case for the current nuclear power plants for technical reasons presented in details in Ref. [10].

     37. By recalling that neutrons are everywhere in our environment, the study and utilization of the large clean energy contained in the neutron has been prohibited by the above indicated historical change of research in favor of the hypothetical quarks, resulting in nuclear power plants and related nightmare of nuclear waste disposal.

     38. As shown by Plaintiff SANTILLI in Ref. [10], this is due to the fact that the energy contained inside the neutron can be utilized if and only if its constituents are a proton and an electron, precisely as conceived by Rutherford. More specifically, said energy can be realized via the excitation of the electron inside the neutron using a photon with a special resonating frequency (technically identified as having 1.294 millions of electron volts). If the constituents of the neutron are quarks, no such excitation is possible, and the neutron cannot be stimulated to decay.

     39. Hadronic mechanics was constructed for the primary purpose of permitting quantitative, numerical, and scientific studies of new clean energies, beginning with that in the structure of the neutron, and then passing to additional new clean energies in the structure of nuclei and molecules. These industrial applications of hadronic mechanics are well under ways at various U.S. and European industries.

     40. The additional fifth motivation of this Complaint is to prosecute all Defendants in the most vigorous means permitted by Law for any fraudulent development of new energies via hadronic mechanics as protected by copyrighted publications and patent pending.

     41. In summary, according to available documentations and eyewitnesses, in the early 1990's Plaintiff SANTILLI mailed to Defendant CONTE a variety of Copyrighted scientific publications on the above outlined hadronic mechanics, on its most important application to Rutherford's conception of the neutron, and on its implication for new clean energies.

     42. Subsequently, Defendants CONTE and PIERALICE grossly plagiarized said new mechanics and said new structure model of the neutron, without the proper quotation and outline of the original publications as requested by Law as well as by ethics, resulting in plagiarized papers and scientific frauds published by Defendants MALLOVE and DELLO RUSSO in their magazine "Infinite Energy", and other papers published by Defendant PANARELLA, CHARBONNEAU, ROBINSON in their magazine "Physics Essays". Said plagiarisms and frauds were moreover made in a deceitful way so as to masquerade as much as possible the incontrovertible physical reality that the basic theory is entirely that of hadronic mechanics.

     43. According to documentation fully available to this Honorable Court, immediately upon discovering said scientific plagiarisms and frauds, the Plaintiff repetitiously requested to all Defendants of this Complaint the immediate publication in "Infinite Energy" and, separately, in "Physics Essays", of a denunciation of the plagiarisms, frauds and deceptions, as well as the publication of routine corrective measures, including, most importantly, the quotation in said magazines of the original specific publications which were plagiarized, yet not quoted.

     44. The same available documentation and eyewitnesses establish that the Plaintiff was ready to issue signed releases of any acquired liability following the immediate publication of the indicated corrective measures.

     45. None of the Defendants accepted the Plaintiff's repeated appeals for legal, ethical, and moral behavior via immediate corrective measures, thus leaving no other possibility than that of filing this Complaint for due compensations of the severe damages, injuries and torts suffered.

     46. The case is rendered particularly serious by the fact that, also according to incontrovertible documentation and eyewitnesses, all Defendants published the indicated papers in full awareness of their plagiarizing, fraudulent and deceptive nature, as confirmed by their opposition against any immediate corrective measure. This established beyond any possible or otherwise credible doubt the existence of a conspiracy among all Defendant to illegally and fraudulently steal hadronic mechanics via its identical reformulation under a different name, and then use the resulting advantages in industrial and other applications fort personal benefits.

     47. The above scientific plagiarisms, frauds, and deceptions cannot be easily dismissed as an egotistic desire by the Plaintiff to have his work acknowledged, because they have caused to the Plaintiff severe injuries, damages and losses, including infringements of scientific properties protected by copyrights and patent applications, loss of work opportunities, lack of peer recognition, and the defrauding of scientific priorities, from which financial rewards derive. As such, scientific plagiarisms, frauds, and deceptions are ordinary violation of the Civil Code like all others.

     48. According to multiple documentary evidence and eyewitnesses, all Defendants were fully informed of the catastrophic inconsistencies in the mathematical elaboration by Defendant CONTE of his plagiarism of Plaintiff's discoveries. Nevertheless, they elected to publish Defendant CONTE's papers without any mention whatever of said catastrophic inconsistencies, by therefore causing serious damage to all readers of the magazines "Infinite Energy" and "Physics Essays", as well as serious damages to society, because said theories are studied for their primary application to new clean energies so much needed by society.

     49. Such a misbehavior constitutes a clear case of deception perpetrated against ethics, science, and society for personal gains, thus requesting a consideration for the filing of a possible, separate criminal actions in the appropriate body at Law against all Defendants CONTE, PIERALICE, MALLOVE, DELLO RUSSO, PHIPPS, PANARELLA, CHARBONNEAU, and ROBINSON.

     50. In view of all the above, and as more specifically described below, Plaintiff respectfully requests this Honorable Court to grant five million dollars for compensatory damage, plus the appropriate Judicial Mandates for the publication of corrective statements in "Infinite Energy" and "Physics Essays", as well as the necessary Restraining Order against any additional plagiarism, fraud, and deception by the Defendants.

     III: FACTUAL ALLEGATIONS

     III.A: THE COPYRIGHTED SCIENTIFIC PUBLICATIONS SUPPLIED BY PLAINTIFF SANTILLI TO DEFENDANT CONTE.

     51. As documented in available sworn affidavits and eyewitnesses, and as confirmed by Defendant's CONTE in writing, in the early 1990's Plaintiff SANTILLI mailed to Defendant CONTE a large number of Copyrighted scientific publications on the new mechanics called hadronic mechanics, its mathematical structure, its most important application to the structure of the neutron according to Rutherford, and its implication of a new form of subnuclear energy, with particular reference to the following eleven scientific publications (hereinafter quoted to as "Ref. [1]" to "Ref. [12]" which are collegially referred hereinafter in the unified form "Refs. [1-12]"):

     52. "Ref. [1]": R. M. Santilli, then at the Lyman Laboratory of Physics, Harvard University, Cambridge, Massachusetts, article entitled "On a possible Lie-admissible covering of Galilei relativity in Newtonian mechanics for nonconserved and Galilei form-noninvariant systems", published in the "Hadronic Journal" Vol. 1, pages 223-423, 1978. In this article the Plaintiff introduced the new Lie-admissible mathematics which admits as a particular case the simpler Lie-isotopic mathematics, today known as Santilli's isomathematics, which permits the consistent elaboration of the basic equations and physical laws of hadronic mechanics. The Copyright of this article was originally filed in 1978 by the publisher, Hadronic Press, Inc., Nonantum, Massachusetts, and then assigned to the Plaintiff in the same year. Therefore, Plaintiff SANTILLI is the sole owner of said Copyright as well as of the scientific priority for the content. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     53. "Ref. [2]": R. M. Santilli, then at the Lyman Laboratory of Physics, Harvard University, Cambridge, Massachusetts, article entitled "Need of subjecting to an experimental verification the validity within a hadron of Einstein's special relativity and Pauli's exclusion principle", article published in "Hadronic Journal" Volume 1, pages 574-901, 1978. This is the article in which the Plaintiff originally proposed the construction of hadronic mechanics, following the prior identification of the needed new mathematics in Ref. [1]. The Copyright of this article was originally filed in 1978 by the publisher, Hadronic Press, Inc., Nonantum, Massachusetts, and then signed to the Plaintiff in the same year. Therefore, Plaintiff SANTILLI is the sole owner of said Copyright as well as of the scientific priority for the content. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     54. "Ref. [3]": R. M. Santilli, then at The Institute for Basic Research, Palm Harbor, Florida, article entitled "Apparent consistency of Rutherford's hypothesis on the neutron as a compressed hydrogen atom", published in "Hadronic Journal" Volume 13, pages 513-531, 1990. In this article the Plaintiff achieves for the first time in scientific history the representation of all characteristics of the neutron as a bound state of one proton and one electron via the use of nonrelativistic hadronic mechanics holding. the study was nonrelativistic, that is, restricted to speeds which are small when compared to that of light. The Copyright for this article was filed by the Plaintiff SANTILLI, who is the sole owner of said Copyright as well as of the scientific priority for the content. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE in its entirely, jointly with a letter outlining the main aspects and their implications.

     55. "Ref. [4]": R. M. Santilli, then at Joint Institute for Nuclear Research (JINR), Dubna, Russia, article entitled "Recent theoretical and experimental evidence on the cold fusion of elementary particles", Publication of the JINR, Dubna, Russia, number E4-93-352, of 1993, subsequently reprinted in the "Chinese Journal of Systems Designs and Electronics", Vol. 6, pages 177-199, 1995. In this article the Plaintiff achieves for the first time in scientific history the representation of all characteristics of the neutron as a bound state of one proton and one electron, although this time via the use of relativistic hadronic mechanics holding at speeds close to that of light. We recall for this Honorable Court that the JINR is the most important nuclear physics laboratory of the former USSR, where all Russian nuclear weapons were built, and which was declassified only after the collapse of the communism. Plaintiff had a visiting position at the JINR for a number of years following the collapse of communism. The Copyright of this article was filed by the Plaintiff , who is the same owner of the same as well as of the scientific priority of the theory therein presented. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, first in a Copyrighted draft form preceding the official publication of the JINR in Russia, and subsequently in its published form, jointly with a letter outlining the main aspects and their implications.

     56. "Ref. [5]": R. M. Santilli, then at the Institute for Basic Research, article entitled "Recent theoretical and experimental evidence on the apparent synthesis of the neutron from protons and electrons", published in the "Chinese Journal of System Engineering and Electronics" Vol.6, pages 177-199, 1995. The Copyright of this article was filed by the Plaintiff, who is the sole owner of the same. The article presents a revised and updated version of the relativistic treatment of Rutherford's conception of the neutron as in Ref. [4]. As per available sworn affidavits and eyewitnesses, first a draft of this article, and then a copy of the published articles were mailed in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     57. "Ref. [6]": R. M. Santilli, then at Joint Institute for Nuclear Research (JINR), Dubna, Russia, article entitled "Isonmumbers and genonumbers of dimension 1, 2, 4, 8, their isoduals And pseudoduals, and of dimension 3,5,6,7", published in Algebras, Groups and Geometries Vol. 10, pages 273-322, 1993. This articles presents the first generalization in scientific records of real numbers, complex numbers, and quaternions into a form with an arbitrary generalized unit. The Copyright for this article was filed by the Plaintiff SANTILLI, who is the sole owner of the same as well as of the scientific priority for the content. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     58. "Ref. [7]". R. M. Santilli, then at The Institute for Basic Research, Harvard Grounds, Cambridge, MA, article entitled "Lie-isotopic lifting of the special relativity for extended deformable particles", published in the journal of the Italian Physical Society called "Il Nuovo Cimento" Vol. 37, pages 545-555, 1983. In this article the Plaintiff introduces for the first time in scientific records a structural generalization of Einstein special relativity to represent extended, nonspherical. and deformable particles under forces both derivable and non-derivable from a potential. The generalization is based on the "lifting" (broadening), for the first time in scientific records, of the basic Minkowskian spacetime called "isotopic" for technical reasons, it includes the lifting of spacetime symmetries, and only thereafter presents the lifting of Einstein's axioms. The Copyright of this article was filed by the Plaintiff, who is the sole owner of the same as well as of the scientific paternity and priority of the theory there presented. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     59. "Ref. [8]": R. M. Santilli, then at the JINR, Dubna, Russia, "Isotopic lifting of SU(2) symmetry with application to nuclear physics", published in the "JINR Rapid Communications", Vol. 6, pages 24-38, 1993. The copyright of this article was filed by the Plaintiff, who is the sole owner off the same as well as of the scientific paternity of the theories presented therein. The article presents the first structural generalization of the fundamental Pauli's matrices for spin. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     60. "Ref. [9]", R. M. Santilli, article entitled "Nonlinear, nonlocal and noncanonical isotopies of the Poincare« symmetry", published in the Russian "Journal Moscow Physical Society", Vol. 3, 255Đ280, 1993. The copyright of this article was filed by the Plaintiff, who is the sole owner of the same as well as of the scientific paternity of the theories contained therein. The article contains the first a comprehensive presentation of the isotopic generalization of the special relativity worked out by the Plaintiff. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications.

     61. "Ref. [10]": R. M. Santilli, then at the Institute for Basic Research, Palm Harbor, Florida, article entitled "Hadronic Energy" and published in the "Hadronic Journal", Vol. 17, pages 311-348, 1994. In this article the Plaintiff presents for the first time in scientific history the large, new, clean energy which can be produced via the stimulated decay of the neutron, once assumed as a bound state of one proton and one electron under total mutual penetration verifying the laws of hadronic mechanics. The Copyright for this article was filed by the Plaintiff, who is the sole owner of the same as well as of the paternity of the scientific priority of its content. The Plaintiff has additionally filed a Patent Application for the new hadronic energy which is currently pending. As per available sworn affidavits and eyewitnesses, this article was mailed in its entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, first in its Copyrighted draft form and then in its published form, jointly with independent reviews and letters outlining the main aspects and their implications.

     62. "Ref. [11]". R. M. Santilli, then at the Institute for Basic Research, Palm Harbor, Florida, two monographs entitled "Isotopic Generalization of Galilei's and Einstein's Relativities", published by Hadronic Press, Inc., in 1991. In this two monographs the Plaintiff presents his generalization of the Galilean and Einsteinian relativities in classical mechanics, whose foundations were first published in the preceding Refs. [1-6]. As per the Berne Convention and other laws, the Plaintiff is the sole owner of the scientific priority for the content. As per available sworn affidavits and eyewitnesses, copies of the most important pages of these monographs were mailed by Plaintiff SANTILLI to Defendant CONTE. The same monographs were repeatedly quoted by Plaintiff SANTILLI in his long explanatory letters to Defendant CONTE, and they are available in university libraries, including that at the university of the city where Defendant CONTE resides.

     63. "Ref. [12]": R. M. Santilli, then at the Institute of Basic Research, Palm Harbor, Florida, two monographs entitled "Elements of Hadronic Mechanics", Volumes I and II, 1st edition 1993, Ukraine Academy of Sciences, Kiev. In these monographs the Plaintiff presents in all details the new hadronic mechanics as outlined in preceding works, plus numerous additional advances, including Plaintiff's generalization of the Galilean and Einsteinian relativities at the operator level. The Copyright was filed by The Institute for Basic Research in 1993 and then, and then assigned to the Plaintiff in the same year. Therefore, the Plaintiff is the sole owner of the Copyright as well as of the scientific priority for the content. As per available sworn affidavits and eyewitnesses, the first, fully Copyrighted drafts of these two monographs were mailed in their entirety in the early 1990's by Plaintiff SANTILLI to Defendant CONTE, jointly with a letter outlining the main aspects and their implications. The first printing of these monographs by the Ukraine Academy of Sciences in 1993 was brought to the attention of Defendant CONTE by Plaintiff's numerous letters, as well as by all subsequent works on hadronic mechanics which evidently quote the monographs herein considered. The printed version of the monographs is available in various university libraries.

     64. "Ref. [13]": Don Borghi et al., then at Center for Nuclear Energy, Recife, Brasil, article entitled "Experimental evidence on the emission of neutrons from cold hydrogen plasma", published in the Russian "Journal of Nuclear Physics" (Yadernaya Fizika) Vol. 56, pages 147-154, 1993. This paper presents the first experimental evidence on the validity of Rutherford's historical conception of the neutron as a bound state of a proton and an electron, thus confirming also the validity of hadronic mechanics. In essence, as expressed by the title of this publication, the experimenters filled up a metal chamber with protons and electrons and then measured a flow of neutrons emanating from such a chamber, thus confirming that protons and electrons can indeed bond to each other to form neutrons. The late Don Borghi was an Italian priest-physicist of the University of Milano, who spent his scientific life in proving experimentally Rutherford's conception of the neutron. Don Borghi's experimental studies were horrendously opposed by the organized scientific crime in the Italian Physical Society of the time, to such extreme misbehavior of: preventing the conduction of the test in Italy, thus forcing its conduction on Brasil; and prohibiting the publication in Italy of his "experimental" results on grounds that "a theory for the explanation of the measurements does not exist". These misbehavior establish beyond any possible doubt the existence of organized scientific crime at the Italian Physical Society of the time, primarily intent in protecting financial, academic and other interests on the old quantum mechanics, whose universal validity is disproved by don Borghi's tests. In any case, these clear misbehavior constitute clear violation of fundamental ethical rules in science, according to which no experiment should be opposed and experimental results should only be dismissed via counter-experiments, and certainly not via mumbo-jambo pseudo-physical deceptions perpetrated by an organized scientific crime for personal gains. To minimize intentional misrepresentations, Plaintiff should stress that, by no means, don Borghi's experiment is perfect and resolutory, because it is afflicted by a number of insufficiencies known to experts in the field, and essentially due to insufficiencies of the laboratory in which it was conducted. Also, by no means, this is atypical for first tests, because all of them routinely suffer of shortcoming which are unavoidable in first attempts, which shortcomings are then resolved in subsequent tests. After having clarified these limitations, Plaintiff wants to stress emphatically that don Borghi's experiment has the absolutely incontrovertible first paternity in the experimental measurements of the synthesis of neutrons from protons and electrons, exactly as predicted by Rutherford.

     65. As established by available affidavits and eyewitnesses, jointly with the above identified, Copyrighted scientific publications, Refs. [1-11], Plaintiff SANTILLI also mailed to Defendant CONTE numerous explanatory letters indicating the importance of the studies for the resolution of the problem of the structure of the neutron.

     66. Moreover, according to incontrovertible documentary evidence and eyewitnesses, Defendant CONTE submitted various papers to Plaintiff SANTILLI in the latter's capacity as Editor in Chief of a scientific Journal. Plaintiff SANTILLI did accept for publication one paper by Defendant CONTE following corrections of major errors. However, Plaintiff SANTILLI rejected all additional papers by Defendant CONTE with a detailed technical; explanation of the main reason, namely, that Defendant's papers were treating new physical conditions via the old mathematics of quantum mechanics, by therefore resulting in the catastrophic inconsistencies indicated earlier.

     67. Plaintiff SANTILLI then suggested Defendant CONTE to submit revised papers according to specified editorial requirements, but Defendant CONTE elected to abstain from doing so. In fact, one of said editorial requirements was the absolutely mandatory condition of quoting specified prior papers in the field. Defendant CONTE did not sent the revised version to Plaintiff SANTILLI precisely to avoid the quotation of said prior publication, and submitted instead the paper to Defendant PANARELLA at "Physics Essays", resulting in scientific fraud, plagiarism, and deception identified later on.

     68. In particular, in the indicated documented correspondence Plaintiff SANTILLI made Defendant CONTE fully aware of the resolution of the catastrophic inconsistencies of his work which is permitted by Santilli's isomathematics (including the Hamilton-Santilli isoquaternions), as well as the fact that the latter is the only known resolution of said inconsistencies.

     69. In summary, multiple, diversified, and incontrovertible documentary evidence and eyewitnesses, confirmed in writing any how by Defendant CONTE, establish beyond any possible, conceivable or otherwise credible doubt that Defendant CONTE was completely aware in the mid 1990's of the following Copyrighted publications and scientific discoveries by Plaintiff SANTILLI :
     I) The basic concepts, dynamical equations and physical laws of hadronic mechanics, Refs. [1,2,10,12];
    
II) The new isomathematics which is necessary for their consistent elaboration, including the Hamilton-Santilli isooctonions, Refs. [1,6];
     III) The first nonrelativistic representation in 1990 d of all characteristics of the neutron according to Rutherford's conception, Ref. [3];
     IV) The first relativistic representation in 1993 of all characteristics of the neutron according to Rutherford, Refs. [4,5]; and
     V) The application of the above studies for a new subnuclear, hadronic energy based on the stimulated decay of the neutron according to Rutherford, Ref. [10];
     VI) The experimental verification of the above structure model of the neutron by don Borghi et al., Ref. [13];
     VII) Drafts of additional papers submitted for publication identified later on.

     III.B: DEFENDANT CONTE AND PIERALICE SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN A FIRST PAPER PUBLISHED IN THE MAGAZINE "INFINITE ENERGY"

     70. In February 1999 Defendants CONTE and PIERALICE published the following paper:

     71. "Ref. [14]": E. Conte and M. Pieralice, "An experiment indicating the nuclear fusion of the proton and electron into the neutron", published in "Infinite Energy" issue 23, pages 67-68, 1999, in which Defendant CONTE and PIERALICE allege that they conducted a new experiment proving the validity of Rutherford's hypothesis on the neutron.

     72. Apart from major technical errors in both the execution and the presentation of the alleged experiment which are irrelevant for this Complaint, Defendants CONTE and PIERALICE perpetrated an extremely questionable fraud against a dead priest-physicist, don Borghi.

     73. In fact, Defendants CONTE and PIERALICE completely abstained from quoting, mentioning or alluding in Ref. [14] at the historical Ref. [13] by don Borghi and his colleagues, while being in full awareness of its existence as per multiple documentary evidence and eyewitnesses accounts.

     74. The scientifically, ethically and legally correct presentation by Defendants CONTE and PIERALICE should have been that of quoting the first priority by don Borghi beginning with the title itself, e.g., "Confirmation of don Borghi's experiments on Rutherford's synthesis of the neutron", and then quoting Ref. [13] beginning from the first words of the first line of the text. On the contrary, in a dishonest, plagiaristic, fraudulent and deceitful way, they intentionally suppressed any mention of the existing scientific priority for the evident purpose of attempting its acquisition via fraud.

     75. Ref. [14] initiates with another scientific fraud consisting in the statement "As we shall see, the primary tasks of the experiments was to have the proton essentially at rest and the electron having a minimum threshold energy of 0.80 MeV". Such a statement was copied ad litteram from Plaintiff SANTILLI's letters to Defendant CONTE when proposing to the latter alternatives in which don Borghi's test can be conducted. Yet, Defendant CONTE and PIERALICE did not quote Plaintiff SANTILLI nowhere, thus perpetrating the second of several scientific frauds in one single paper.

     76. A third scientific fraud was perpetrated by Defendants CONTE and PIERALICE at the end of p. 67, Ref. [14]. via the statement "... we developed a theory [quoting Ref. 2 of [14]] in which the proton can be made to interact with the electron via a nonlocal and nonpotential interaction due to the mutual overlap of the wavepackets." These are the most fundamental assumptions of hadronic mechanics established under internationally known Copyrights since 1978, Refs. [1-3]. These are also the fundamental assumptions of Plaintiff's internationally known and Copyrighted representation of Rutherford's hypothesis published in 1990, Ref. [3], as repetitiously stated by Plaintiff to Defendants in numerous correspondence, in addition to the documented mailing of copies of said copyrighted publications.

     77. Yet, Defendants CONTE and PIERALICE uses the word "we", and Ref. 2 of Ref. [14] solely contains references to their papers, with no mention whatever nowhere of Plaintiff's prior work. This constitutes a third most vulgar scientific plagiarism, fraud and deception, because the Defendants have copies ad litteram Plaintiff's theory and then stated that they are their sole authors.

     78. COUNT 1: In view and consideration of the above, Plaintiff SANTILLI hereby prays this Honorable Court to accept as Claim 1 the fraudulent and deceptive plagiaristic statement by Defendants CONTE and PIERALICE as the originators of the theory on Rutherford's conception of the neutron implied by the use in that context of the term "we" in Ref. [14] without any referral whatever to the actual, true, origination of exactly the same theory by the Plaintiff in Refs. [3,4,5]. Because of this fraudulent and deceptive plagiarism, Plaintiff prays this Honorable Court to grant hymn the biggest possible compensation and reliefs permitted by Law.

     III-C: PLAINTIFF DENUNCIATION OF DEFENDANTS CONTE AND PIERALICE MISBEHAVIOR AND DEFENDANTS RESPONSE.

     79. Immediately upon reading Ref. [14], Plaintiff denounced Defendants plagiarism, fraud, deception and other misbehavior in

     80. "Ref. [15]": R. M. Santilli, letter to the editor published in "Infinite Energy, issue 24, pages 56-57, 1999, which contains the denunciation of the following three main misbehavior:
     1) The lack of any quotation in Ref. [14] of the incontrovertible paternity by don Borghi and his group, Ref. [13], for the first synthesis of neutrons from protons and electrons, as requested by ethics and the Law;
     2) The lack of any quotation in Ref. [14] of hadronic mechanics and its first exact representation of all characteristics of the neutrons according to Rutherford's conception, Refs. [3,4,5,6], as requested by ethics and the Law;
     3) The catastrophic inconsistencies of the papers quoted in Ref. 2 of Ref. [14], as outlined in above.

     81. Defendant CONTE replied with:

     82. "Ref. [16]": E. Conte, letter to the editor, "Infinite Energy", issue 24, p. 57, 1999, which was published immediately following Plaintiff Ref. [15].

     83. Defendant's answer, Ref. [16], begins by claiming that he quoted don Borghi et al, Ref. [13], although in another subsequent paper by the Defendant. To begin, this behavior is fraudulent, because the scientific priority must be identified, quoted and reviewed in the very first scientific publication of alleged new results, and not in secondary subsequent notes nobody will consider seriously and which nobody will be obliged to quoted.

     84. Moreover, according to information secured by the Plaintiff, the reference to don Borghi et al., Ref. [13], was added in this secondary paper subsequent to Ref. [14] only following the strong denunciation by the Plaintiff of scientific corruption in Ref. [16].

     85. Defendant CONTE, evidently answering also on behalf of Defendant PIERALICE, stated in Ref. [16] that "In particular, these authors [don Borghi et al., Ref. [13]] did not aim to show the synthesis of the neutron". This is an additional, most despicable fraud, because of the simply incontrovertible physical reality, acknowledged by scientists all over the world, that Ref. [13] constitutes the first experimental detection of neutron synthesized from protons and electrons, as evident from the title and its content.

     86. In other words, to proper appraise their dishonest behavior, this Honorable Court should note that, after attempting to steal in Ref. [14] the scientific paternity of a dead priest who cannot defend himself, in the subsequent Ref. [16] Defendants CONTE and PIERALICE insisted in their extremely dishonest and fraudulent posture by attempting to convince non-expert readers that don Borghi et al did not seek the synthesis of the neutron, all this perpetrated with the full support and backing of the editors of that magazine, Defendants MALLOVE and DELLO RUSSO ! This is an incredible collegial misbehavior, by far the most despicable scientific-editorial misbehavior eyewitnesses by the Plaintiff in all his academic life! Yet, it is true and documented in black and white.

     87. When one considers on the top of all this that don Borghi was Italian as Defendants CONTE and PIERALICE are, and that don Borghi's lifelong efforts on the synthesis of the neutron are well known in Italy, any individual who believes that Defendants CONTE and PIERALICE are honest persons, should be removed from any membership in any society.

     88. Moreover, in Ref. [16] Defendant CONTE claims that "I reject Santilli's comments expressed in so evident conditions........ of envy." Plaintiff's scientific achievements are a large multiple of the minute, lilliputian achievements by the Defendant. Plaintiff has published some 200 technical papers in some of the best journals all over the world, has written some 15 post Ph.D. monographs in mathematics, physics and chemistry, and the editors of five technical journals as well as over 40 Conference Proceedings. By comparison, Defendant CONTE sole paper published in a technical, severely refereed journal, is that published by the Plaintiff. The claim that, under such oceanical differences, the Plaintiff could be envious of the Defendant is an unconditionally vulgar lie, yet it received full support by Defendants MALLOVE and DELLO RUSSO.

     89. Defendant CONTE continues in Ref. [16] in his intentional scientific plagiarism, fraud, deception, lies and other misconducts by claiming that he has invented a new theory for the representation of Rutherford's hypothesis, which he dubs "biquaternion quantum mechanics", and, for this reason he does not need to quote Plaintiff's work any more!

     90. Yet, Defendant CONTE himself states in Ref. [16] "Apart from some linguistic and also conceptual aspects [whose Copyright is owned by Plaintiff], ..."; "...my [sic!] theoretical work .... also evidencing some contact points with hadronic mechanics [this is the first and only time hadronic mechanics is mentioned in Refs. [14,16]] in some formal (and only formal) development,......"; and other vulgar misrepresentations.

     91. Thus, Defendant CONTE himself acknowledges that his studies are based on the same linguistic, conceptual and formal (meaning equation in physics) foundations of hadronic mechanics [the identity of all technical aspects will be established below]. Yet, Defendant CONTE abstains from quoting the Copyrighted paternity beginning from 1978, Refs. [1,2,3,4,5,6,7,8,9], and explicitly claims that "... there is no need to quote Santilli anymore...". This is the most profoundly dishonest, immoral, and illegal statement Plaintiff had the disgrace of reading in all his scientific life, which has mandated the filing of this Complaint.

     92. As recalled in the introductory part of this Complaint, the above evidence constitutes formal admission by the Defendant CONTE himself of his violation of the Copyright laws, because such a violation occurs only when copying a few words our of a copyrighted work with hundred of thousands of words.

     93. The Plaintiff hereby respectfully requests this honorable Court to grant this additional deception by Defendant CONTE as an additional claim for due financial compensation and other remedies at Law.

     94. Despite all the above misrepresentations, lies, frauds and other misconducts, the biggest deception perpetrated by Defendant CONTE in Ref. [16] is the denial without proof of Point 3) of Plaintiff's denunciation, Ref. [15], the lack of invariance of Defendant's theoretical work, with consequential catastrophic inconsistencies.

     95. While the Plaintiff motivated in Ref. [15] his claim of lack of invariance with very precise statements and technical references published in prestigious refereed journals, Defendant CONTE answered in Ref. [14] with the statement "Concerning the lack of invariance of biquaternion quantum mechanics, I find it superfluous to explain here this argument. Santilli needs to understand seriously the results of biquaternion quantum mechanics."

     96. As anybody can see, Defendant CONTE answers very precisely technical arguments proving catastrophic physical inconsistencies of his studies by merely avoiding any counter-argument or technical proof of his claim, thus perpetrating an additional fraud, lie, and deception.

     97. Inconsistencies 1'), 2'), 3'), 4') and 5') indicated in Section Ii of this Complaint of Defendant CONTE's mathematical elaboration of the plagiarized basic equations of hadronic mechanics can be easily proved by a first year undergraduate student of quantum mechanics. The time evolution of Defendant's work incontrovertibly violates the unitary condition of quantum mechanics, yet it is treated via the old math of quantum mechanics. The validity of all indicated catastrophic inconsistencies is then beyond any credible doubt. Physics is a quantitative science and not the deceptive discipline Defendant CONTE hopes to manipulated for personal gains. In fact, the "results" themselves quoted by Defendant CONTE in Ref. [16] have no physical meaning, e.g., because not invariant in time.

     98. Plaintiff's preceding Ref. [15] establishes beyond credible doubt that this deception was perpetrated by Defendant CONTE in Ref. [16] in his full awareness. As such, it is so serious and has implications so grave for new energies and for society, that it may imply a violation of the Criminal Code. As such, it should perhaps be treated in a separate Criminal Complaint.

     99. Defendant CONTE ends Ref. [16] with the statement "Santilli spontaneously sent me his books on hadronic mechanics... In sending the books and other preprints, his explicit aim was to involve me in a crusade in favor of hadronic mechanics."

     100. As this Honorable Court can see, Defendant CONTE clearly and plainly admits and confirms that Plaintiff SANTILLI sent to him several copyrighted scientific publications on hadronic mechanics, therefore confirming in his own writing the intentional character of the scientific frauds that motivated this Complaint.

     101. In regard to the alleged "crusade", the various correspondence that was joined to the books and preprints by Plaintiff SANTILLI was specifically intended to explain: 1) The necessity for a generalized theory to represent Rutherford's hypothesis, technically expressed by the need for a nonunitary theory outside the class of equivalence of quantum mechanics; 2) The universality of hadronic mechanics for all infinitely possible generalized theories; and 3) The need for the appropriate mathematics for the correct elaboration of the basic equations and laws to avoid catastrophic inconsistencies. Defendant CONTE ignored all this, and engaged himself in incredible scientific frauds and deceptions, evidently because of receptive editors and supportive accomplices, such as Defendant MALLOVE and PANARELLA.

     102. COUNT 2: In view of its blatantly plagiaristic nature moved by a pre-meditated intent to re-affirm the fraudulent deception of paternity of hadronic mechanics and its primary application to the structure of the neutron as per original copyrighted Refs. [3,4,5], Plaintiff prays this Honorable Court to accept the entire content of Ref. [16] as the Count 2 for financial compensate, injunctive reliefs and other remedies permitted by Law.

     III.D: DEFENDANT CONTE SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN A SECOND PAPER AT "INFINITE ENERGY"

     103. The filing of this complaint has been rendered necessary by the appearance of the following additional plagiarisms by Defendant CONTE, as well as by the refusal of all corrective measures by all Defendants. This case refers to:

     104. "Refs [17]": E, Conte, article entitled "Theoretical indications of the possibility of nuclear reactions at low energy", published in "Infinite Energy", issue no. 24, pages 49-54, 1999, in which Defendant CONTE presents a nonrelativistic and relativistic study, specifically, on the structure of the neutron as a bound state of one proton and one electron as predicted by Rutherford.

     105. The above paper by Defendant Conte constitutes a truly incredible, systematic plagiarisms of the Copyrighted scientific work on hadronic mechanics and on the structure of the neutron without any quotation of any of prior publications, Refs. [1-12].

     106. The case can be summarized as follows. Physics is not an undefined discipline, such as philosophy, where topics can be debated ad infinitum without any resolution. Physics is an exact science, based on rigorously proved theorems, equations and derivations which simply cannot be debated without instantly leaving the boundary of science for scientific corruption.

     107.The main properties of hadronic mechanics in general, and the correct treatment of Rutherford's historical hypothesis on the structure of the neutron have been established in Refs. [1-13], as well as numerous subsequent articles published in prestigious, refereed mathematical and physical journals, such as "Rendiconti Circolo Matematico Palermo", a famous Italian mathematics journal, "Foundations of Physics", a famous U.S. physics journal, "Mathematical Methods in Applied Sciences", a very prestigious applied mathematics journal in Germany, and several others. In particular, Refs. [3,4,5] which were in documented possession of Defendant CONTE years prior to releasing Ref. [17] for print, have established that:
     1) Quantum mechanics cannot permit any consistent representation of Rutherford's hypothesis on the structure of the neutron for numerous independent reasons;
     2) The same applied for all possible theories which are equivalent to quantum mechanics, technically characterized by unitary transforms of the quantum formalism, UU+ = 1;
     3) A necessary condition for the representation of Rutherford's historical hypothesis is that one must exit from the class of equivalence of quantum mechanics, which can only be done via the use of nonunitary transforms, UU+ not equal to 1.
     4) Hadronic mechanics is precisely constructed via the most general possible nonlinear, nonlocal and nonunitary transforms and, as such, it has been proved via theorems published in prestigious refereed journals that it is universal, that is, it contains as particular cases all other infinitely possible nonunitary theories defined over real numbers, complex numbers and quaternions;
     5) The consistent elaboration of the new basic nonunitary equations cannot be done with the old mathematics of quantum mechanics evidently to avoid a minestrone rather than science, and requires instead a new mathematics specifically built for the scope, today called Santilli's isomathematics in numerous publications and books.

     108. In summary, the basic equations of hadronic mechanics can be obtained via a nonunitary transform of the corresponding equations of quantum mechanics, as clearly established in copyrighted articles and books [1-12]. For instance, the basic quantum mechanical commutator [p, q] = pq - qp = 1 between linear momenta p and coordinates q is mapped into the expression U[p, q]U+ = UpU+(1/(UU+))UqU+ - UqU+(1/(UU+))UpU+ = p'Tq' - q'Tp' = UU+, q' = UqU+, p' = UpU+, T = 1/UU+, I = UU+. One has consequentially the generalization of Heisenberg's equations proposed by Plaintiff SANTILLI in 1978, Ref. [2], ihdA/dt = AHT - HTA; the generalization of Schroedinger equation proposed by Plaintiff SANTILLI and other scientists HT(psi) = E(psi), where (psi) represent the Greek letter "psi", which is easily obtained via the nonunitary transform of the conventional equation UH(psi) = UHU+(1/(UU+)U(psi) = H'T(psi)' = E(psi)', H' = UHU+, T = 1/UU+, (psi)' = U(psi), Refs. [3-12]; similarly all needed equations can be obtained with the same elementary method which is today internationally known.

     109. Once achieved, the above equations must be treated properly to avoid the catastrophic inconsistencies indicated earlier. The main point in that respect is that nonunitary maps do not preserve the unit 1 by their very definition, 1 -> 1' = U1U+ is no longer equal to 1. Instead, the new unit is given by I = U1U+ and does not coincide with the old unit 1. But the unit is the fundamental quantities of all of mathematics, including the entire mathematics of quantum mechanics, where the unit is given by Planck's constant h assumed to be 1. Therefore, one does mot need a Ph. D. in theoretical physics to see that the elaboration of the hadronic equations via the mathematics of quantum mechanics is totally inconsistent and has no known physical value of any type, because the former is based on the new generalized unit I = UU+, while the latter is based on the different trivial value 1.

     110. The Plaintiff achieved a consistent elaboration of the generalized equations and laws of hadronic mechanics via the construction of a new mathematics in which the new quantity I = UU+ is the correct (left and right) unit at all levels. This required the construction of new real, complex and quaternionic numbers with generalized unit I = UU+, new generalized metric spaces with metric m' = Tm, new associative algebras with product ATB, new Lie algebras with product ATB - BTA today known as Lie-Santilli isoproduct, new geometries, new topology, etc.

     111. The plagiarism by Defendant CONTE in Ref. [17] can be summarized via the following Claims identified in detail below:

     112. COUNT 3: As per evidence provided below, Defendant CONTE has plagiarized in Ref. [17] the discovery by Plaintiff SANTILLI of the quaternion numbers with complex elements defined for a generalized unit, by copying the heart of the matter of Ref. [6] whose copyright is owned by Plaintiff, without any quotation of the same, despite documentary evidence that such a Ref. [6] was fully known to Defendant CONTE many years prior to Ref. [17];

     113. COUNT 4: As per evidence provided below, Defendant CONTE has copied ad litteram in Ref. [17] the very heart of the matter of hadronic mechanics, including all the main words, definitions and laws, as originally appeared in copyrighted Refs. [1-12], thus injuring the Plaintiff and all other scientists who built the new mechanics, despite documentary evidence that such Ref. [1-12] were fully known to Defendant CONTE many years prior to Ref. [17];

     114. COUNT 5: As per evidence provided below, In Ref. [17] Defendant CONTE plagiarized ad litteram all the basic concepts, notions and equations of Plaintiff's copyrighted Refs. [3,4,5] on the first consistent and invariant representation in scientific records of all characteristics of the neutron according to Rutherford's historical hypothesis, without any quotation whatever of the latter paternity, by therefore perpetrating a documented violation the Law on Copyright, despite the documentary evidence that such Refs. [3,4,5] were fully known to Defendant CONTE years prior to Ref. [17], a prior knowledge which is admitted in writing by the Defendant himself anyhow.

     115. COUNT 6: As per evidence provided below, the plagiarisms of Counts 3, 4, 5 were done in a pre-meditated and intentional form, because of the multiple documentary evidence and eyewitnesses according to which Defendant CONTE fully knew Plaintiff's copyrighted Refs. [3,4,5] years before Ref. [17], as admitted so in writing by the Defendant himself in his answer [16] published prior to Ref. [17], and he released the publication of Ref. [17] just after Plaintiff's denunciation of plagiarism in Ref. [15] published just before Ref. [17]. This constitutes a documented scientific fraud which violated the Statute on Tort and other Laws.

     116. COUNT 7: As per evidence provided below, to masquerade his scientific fraud, Defendant CONTE does not admit that his basic transform is nonunitary exactly as requested by hadronic mechanics, evidently to avoid excessive visibility of his scheme, and completely abstain from indicating the existence in his mathematical elaborations of catastrophic inconsistencies, thus perpetrating a clear deception that violate additional laws to such an extent that this Count 7 may be the subject of a separate Criminal Complaint;

     117. COUNT 8: As established by the evidence provided below, the plagiarisms, frauds and deceptions as per Counts 1, 2, 3, 4, 5, 6, 7, were perpetrated with the documented, complete awareness, thus full complicity by the editor of "Infinite Energy", Defendants MALLOVE and "DELLO RUSSO", by therefore establishing the clear existence of a conspiracy against Plaintiff SANTILLI. Plaintiff therefore prays this Honorable Court for due compensatory payments and other reliefs by all said Defendants originating from the publication of Ref. [17];

     118. COUNT 9: As per documentary evidence provided below, the central objective of Defendants CONTE, PIERALICE, MALLOVE, DELLO RUSSO, PANARELLA, CHARBONNEAU, ROBINSON and their associates is that of stealing hadronic mechanics, by copying all its basic words, notions, concepts, equations and laws, and presenting it under a different name, by therefore injuring in this way all the numerous mathematicians, theoreticians and experimentalists that contributed to its construction in two decades of serious work, with the consequential violation of additional separate Laws and the possibility of filing a separate Class Action against all Defendants.

     119. To begin the detailed presentation of the above infringements, Defendant CONTE perpetrates Ref. [17] with a flagrant violation of scientific ethics and accountability. In fact, said article treats nonrelativistically and relativistically the structure of the neutron as a bound state of a proton and an electron. Nevertheless, in a fully intended, pre-meditated scientific fraud, Defendant CONTE completely abstains from the moral, let alone legal obligation of quoting and reviewing Plaintiff's prior publications in exactly the same topic, Refs. [3,4,5].

     120. The intentional premeditated nature of the scientific fraud is proved beyond any possible or otherwise credible doubt by various evidence, such as: the documented and eyewitnessed knowledge of Plaintiff's Copyrighted papers by Defendant CONTE; the admission of said knowledge by the same Defendant CONTE in Ref. [16]; and the fact that Refs. [17] was authorized for publication by Defendant CONTE following Plaintiff's denunciation of plagiarism, Ref. [15], and Defendant CONTE replay, Ref. [16].

     121. The scientific fraud by Defendant CONTE is truly extensive and can only be summarized in this Complaint to avoid a prohibitive length.

     122. Count 3 is established by the following evidence. Ref. [17] begins with the extreme plagiarism and scientific fraud of robbing the paternity of the famous quaternions to their original discoverer, Hamilton, one of the most illustrious Founders of contemporary science. In fact,. Defendant CONTE invents the new name of "biquaternions", precisely and exactly for the very same numbers discovered by Hamilton, the quaternions defined over complex numbers, which were historically introduced by Hamilton for his first representation of electromagnetic equations.

     123. At the same time, Defendant CONTE plagiarizes Plaintiff's generalized unit, as done below Eq. (2.10, I = UU+ (not equal to 1) and in Eq. Eq. [2.10] of Ref. 17]. This implies the definition of quaternions over a generalized unit which is an incredible plagiarism of Plaintiff SANTILLI discovery of the isoquaternions, as treated in detail in the copyrighted Ref. 6].

     124. Count 4 is establish by the copying of many different structural lines of hadronic mechanics, such as the statement following Eq. (2.9), Ref. [17], in which Defendant CONTE states "In addition to the conventional, local, action-at-a-distance, potential interactions indicated by V(r) in Eq. (2.6), we have to add, as existing in Nature, other interactions that are nonlinear, nonlocal and non-potential interactions, and they are due to the wave-overlapping .... The biquaternion quantum mechanics considers physical processes that are marked by an actual overlap of the wavefunctions." This is flagrant, verbatim plagiarisms of the very foundations of hadronic mechanics, Refs. [1-13], renamed for fraudulent purposes "biquaternion quantum mechanics" to confuse the uninformed, yet Defendant CONTE does not states the true origination in hadronic mechanics or quote any of the Copyrighted paternity, Refs. [1-13].

     125. Count 4 is also established beyond any possible doubt in the concluding remarks of Defendant CONTE Ref. [17], because they consist of the absolutely identical, verbatim, words by work, plagiarism of the physical laws, notions and definitions of hadronic mechanics without any mention whatever of the latter and while renaming it "biquaternion quantum mechanics" for an evident fraudulent deception.

     126. Count 4 is moreover established by the following evidence. The transformation in Eq. (2.1), Ref. [17], is the fundamental transformation of hadronic mechanics recalled earlier, Ref. [1-13], i.e.., A -> A' = UAU+, where UU+ is different than 1, which maps operators from quantum mechanics to hadronic mechanics. Despite that, the Defendant does not quote its Copyrighted paternity.

     127. The scientific plagiarism of hadronic mechanics continues when, below Eq. (2.1), Defendant CONTE writes I = UU+, namely, he assumes the very generalization of the unit, which is internationally known to be the ultimate and most fundamental Copyrighted assumption of hadronic mechanics (see, e.g., Eq. (2.1) of Ref. [3]), yet the Defendant does not quote its Copyrighted paternity, thus grossly violating ethics and the Law.

     128. The scientific fraud by Defendant CONTE is here much deeper than what may appear in the surface. In fact, Defendant CONTE intentionally omits the very technical nature of the transform, that of being nonunitary (i.e., UU+ is not equal to 1). This is done, first of all because that characterization would have identified the main structure of hadronic mechanics to all expert readers, and also because, when treated with the quantum mathematics as done in Ref. [17], nonunitary transforms are internationally known to imply the catastrophic physical inconsistencies indicated earlier. Therefore, Defendant CONTE perpetrates in Ref. [17] a fraudulent deception as defined in the introductory lines of this Complaint.

     129. Defendant CONTE ignores that the primary legal protection of the Statute on Copyright for scientific publications is in that on equations. Eq. (2.1) is an incontrovertible plagiarism of Plaintiff's Copyrighted equations in Refs. [1-13].

     130. Count 5 is established by the following evidence at the nonrelativistic level. Eqs. (2.3) and (2.4) of Ref. [17] are a fraudulent copy of Eqs. (2.6) and (2.7) of Ref. [3], yet the Defendant does not quote its Copyrighted paternity. To confuse the uninformed for the intent of securing the paternity, Defendant CONTE changes some of the symbols. For instance the symbol T of Ref. [3] is masqueraded with the new symbol 1/S, and "hat I" in Ref. [3] is changed into S. However, the Copyright Act covers the content for scientific material. The change of symbols while keeping exactly the same equation unchanged in its numerical-structural characteristics is a gross violation of the Law.

     131. More specifically, Defendant CONTE plagiarizes in Eq. (2.4) of Ref. [17] the fundamental, internationally known and Copyrighted equation of hadronic mechanics, the isoschroedinger equation of Refs. [3-13], which can be written in nontechnical symbols suitable for this Complaint ihd(psi)/dt = HT(psi). To masquerade his scientific fraud, Defendant CONTE writes exactly the same equation of hadronic mechanics in the form ihd(psi)/dt = H(psi)', (psi)' = (1/S)(psi), thus merely changing the symbol T used by hadronic mechanics with the symbol 1/S. The important point is that T = 1/S. Thus, changing the symbols while the equation remains structurally identical does not constitute new physics, but merely a fraudulent plagiarism an deception.

     132. At any rate, following the substitution of T with 1/S, Defendant CONTE plagiarized equation recovers the fundamental isoschroedinger equation identically, because H(psi)' is identical to HT(psi), T = 1/S, thus confirming the scientific fraud beyond any conceivable or otherwise credible doubt.

     133. The intentional, pre-meditated character of the fraud is established by the dubbing (psi)' = (1/S)(psi), rather than the originally used symbol T(psi). Moreover, the resulting equation ihd(psi)/dt = H(psi)' is pure mumbo-jambo nonscientific nonsense, because a wave equation defined on two different wavefunctions, (psi) and (psi)', is total, pure, mumbo-jambo nonscientific nonsense. The only correct way of writing the equation is the Copyrighted form in Ref. [1,2,3], i.e., ihd(psi)/dt = HT(psi). The case also proves the insufficient technical knowledge by Defendant CONTE as well as by the editors that published Ref. [17], Defendants MALLOVE and DELLO RUSSO,and establish their sole capability to steal and defraud Plaintiff's copyrighted work.

     134. Subsequently, throughout Ref. [17] Defendant CONTE claims the above equation to be his discovery, therefore rendering mandatory the filing of this Complaint and the prosecution of the case in the most vigorous possible form permitted by Law.

     135. Count 5 is also established by the following evidence. Eq. (2.8) of Ref. [17] is an additional truly incredible scientific fraud without any quotation of the true paternity, this time consisting in the plagiarism of the Hulten potential caused by the wave overlapping which was first derived in Sect. 5 of the copyrighted Ref. [2], and then copied ad litteram in a truly incredible way from Eqs. (2.11) and (2.12) of Ref. [3], without quoting the latter and without even bothering to change the symbols ! What a fantastic authorship-editorship !

     136. In summary, the nonrelativistic treatment of Rutherford's hypothesis on the structure of the neutron published by Defendant CONTE in "Infinite Energy", Ref. [17], under the full complicity of its editors, Defendant MALLOVE and DELLO RUSSO, is absolutely incredible, absolutely identical, verbatim copy of the nonrelativistic treatment by Plaintiff SANTILLI in Ref. [3], without a shadow of novelty whatever, not even minute, yet without quotation of Ref. [3].

     137. This establishes the nonrelativistic part of Count 5 beyond any possible or otherwise credible doubt.

     138. The relativistic part of Count 5 is established by the following evidence. Defendant CONTE passes in Ref. [17] to the an additional, verbatim plagiarism, this time of Plaintiff's Ref. [7]. In fact, the main equation of the generalized spacetime, Eq. (3.10), is an identical copy, even in the symbols x and b used of Eq. (2) of Plaintiff's Ref. [7] without any quotation of the latter. Defendant CONTE goes to the extreme of fraud and deception by even calling the b-quantities with exactly the same name as that originally introduced and Copyrighted in Ref. [7] as "characteristic functions" of the generalized spacetime, without any quotation of the original paternity, Ref. [7].

     139. The conceptual elaboration following plagiarized Eq. (3.10), Ref. [17], is an additional incredible scientific fraud of Ref. [7] without its quotation. In fact, said conceptual elaboration dwells on the foundation of paper [6], the conventional spacetime representing particles moving within the homogeneous and isotropic vacuum, while the generalized spacetime deals with extended particles moving within inhomogeneous and anisotropic physical media.

     140. Within such a fraudulent context, Defendant CONTE even goes to the extreme of copying the dedication made by Plaintiff SANTILLI to Enrico Fermi of Vol. II of the monographs on hadronic mechanics, Refs. [12] !

     141. Defendant CONTE then passes to the incredible plagiarism of the Fifth Axiom of Santilli's isospecial relativity, the principle of isoequivalence, which is internationally well known and copyrighted in Refs. [7,9,11,12]. In fact, at the end of page 51 of Ref. [17] Defendant CONTE identically copied, even with exactly the same symbols (!) the generalization of Einstein's equivalence law E = mc2 valid in empty space to the new law valid within p[physical media E = mc2b42 where the speed of light is not c but c' = cb4. This is the fundamental Fifth Axiom of the isospecial relativity, which is at the foundation of all relativistic studies by Plaintiff SANTILLI, as first introduced in Ref. [7] of 1983, and then presented in details in all subsequent relativistic studies received by Defendant CONTE under eyewitnesses, such as Refs. [9,11,12], yet Defendant CONTE fraudulently, maliciously, intentionally avoid the quotation of the proper paternity of this fundamental law.

     142. The subsequent Eq. (4.1) of Ref. [17] is an identical copy even in the symbol of the fundamental equation of structure of Rutherford's neutron, Eq. (2.10) of Ref. [3], yet the Defendant does not quote its Copyrighted paternity in a pre-meditated, intentional way.

     143. The following Eqs. (4.4) and (4.5) of Ref. [17] are an additional fraudulent copy of the corresponding equations in Ref. [3], yet without the quotation of their Copyrighted paternity.

     144. The concluding, fundamental, Hulten spectrum of the energy, Eq. (4.7) of Ref. [17], is an additional incredible, fraudulent plagiarism of the very fundamental result obtained by Plaintiff's SANTILLI beginning with in Sect. 5 of Ref. [2], then reviewed in Ref. [3], and communicated to Defendant CONTE via numerous letters and comments. Yet, Defendant CONTE vulgarly abstain from any quotation of the paternity, in a documented, pre-meditated intent to perpetrate a fraud.

     145. Following Eq. (4.7) of Ref. [17] Defendant CONTE perpetrates yet another, additional, extremely fraudulent plagiarism of Plaintiff's original discoveries, the exact numerical representation of the neutron rest energy via the use of the isoequivalence principle, yet abstaining the identification of the true paternity, Ref. [3].

     146. In the unmarked equation below Eq. (4.7) of Ref. [17] Defendant CONTE reached the climax of fraudulent deception in presenting a numerical result identically copied from Plaintiff's Ref. [4], but without even explaining how it is derived ! This climax of misbehavior in science is perpetrated in the presentation of the negative binding energy -0.072 MeV of Rutherford's neutron, which is totally copied from Ref. [4], but without at least the decency of explaining in the necessary details its origination, and without any reference to its actual first discovery and detailed derivation in Ref. [4], as the Plaintiff had brought to the attention of the Defendant CONTE so many times to be dubbed as a "crusade" in Ref. [16].

     147. Defendant CONTE then passes to an additional equally incredible misconduct by reproducing ad litteram another fundamental discovery by Plaintiff SANTILLI in Ref. [3], the first representation in scientific history of the spin of the neutron according to Rutherford, again, with the pernicious, fraudulent, intentional, pre-mediated avoidance of quoting its first derivation. In fact, Eqs. (5.5) of Ref. [17] are absolutely identical to the fundamental Eqs. (2.34)-(2.37) of Ref. [3], without any quotation of the latter paternity whatever.

     148. This establishes the Count 5 at both nonrelativistic and relativistic levels beyond any remotely conceivable or otherwise credible doubt.

     149. Count 6 on the intentional character of the fraud has been proved before by the documented awareness by Defendant CONTE of all copyrighted scientific papers he plagiarized.

     150. Count 7 is established by the following evidence:
     1) Defendant CONTE intentionally avoids in Ref. [17] the identification of the main characteristic of the fundamental transform UU+ used for the construction of the theory, that of being nonunitary (UU+ is different than 1), and instead invents the new pompous name for the same transform of "Linear, Homogeneous, Biquaternion Transformations, see page 50 of Ref. [17]. This is an intentional, premeditated deception, because Defendant CONTE himself soon states in the same page that UU+ is not equal to 1. This deception is pre-meditated as part of the general objective of robbing the paternity of hadronic mechanics. In fact, had Defendant CONTE stated the true technical character of his basic transform, that of being nonunitary, readers of "Infinite Energy" would have immediately discovered that he was plagiarizing hadronic mechanics.
     2) The second more serious deception perpetrated by Defendant CONTE in Ref. [17] is via his complete silence on the catastrophic inconsistencies that are inherent in the way he handled the plagiarized equations of hadronic mechanics, which catastrophic inconsistencies are typical of all conventionally treated nonunitary theories, and consists of: A) Loss of invariant units of space, time, energy, etc. with consequential inability to verify the theory with experiments; 2) Lack of any observable quantities, thus having no known physical content of any type, because of the lack of preservation of Hermiticity under nonunitary transform; 3) lack of invariant numerical results which change in time and, thus, have no physical meaning whatever; 4) Violation of the fundamental law of causality, because of the existence of nonunitary transforms under which the effect can precede the cause, violation of probability, and other basic laws; V) Violation of Galilei and Einstein relativities. As recalled earlier, hadronic mechanics has long resolved the above catastrophic inconsistencies because it treats exactly the same equations plagiarized by Defendant CONTE with Santilli's isomathematics. As this Honorable Court recalls from the preceding parts of this Complaint, Defendant CONTE answered in Ref. [16] with mumbo-jambo nonsense the precise, specific, and technical denunciation of catastrophic inconsistencies expressed by Plaintiff in Ref. [15]. Despite that, Defendant CONTE released the publication of Ref. [17] immediately before denunciation [15], which confirms the pre-meditated intent of the deception beyond any conceivable or otherwise credible doubt. In fact, any real scientist, that is, a person with integrity and dignity, would have at least alluded in Ref. [17] to the existence of unsolved problematic aspects. But not Defendant CONTE, who has violated all possible values in science.
     3) Yet another deception perpetrated by Defendant CONTE in a documentedly intentional, premeditated way is that in the very name "biquaternions quantum mechanics" and its alleged use to represent the structure of the neutron. In fact, as defined in Ref. [17, "biquaternions" are exactly the historical Hamilton' numbers with complex elements. As such, they are well known since the early part of this century to provide a mere reformulation of conventional relativistic quantum mechanics, without any generalization at all. Therefore, the name "biquaternion quantum mechanics" is synonym of conventional relativistic quantum mechanics, only formulated according to Hamilton's teaching (and certainly not that by the Defendant CONTE!). The intentional deception is then clear: it is known that conventional relativistic quantum mechanics absolutely-positively cannot represent the structure of the neutron, due to the incontrovertible need to generalize the very structure of the theory. In short, the very name "biquaternion quantum mechanics": are the climax of the plagiarisms, fraud, and deception perpetrated by Defendant CONTE with the full backing of the editors, Defendant MALLOVE and DELLO RUSSO.

     151. In summary, Defendant CONTE's paper, Ref. [17], published in "Infinite Energy" under the full complicity, support and cooperation of its editors, Defendant MALLOVE and DELLO RUSSO, constitutes the most dishonest and illegal publication the Plaintiff has had the disgrace of being exposed to in his three decades of scientific activities in three continents.

     152. To appraise the insidious nature of the fraud, this Honorable Court should note that Defendant CONTE did indeed quote Plaintiff SANTILLI in ref. 6 of Ref. [17]. However, the quotation was made after that by Caldirola, a famous late Italian physicist of the 1950's, in full knowledge that: 1) the quotation of a paper after a famous one is a well known scheme to minimize paternities; 2) The joining of the Plaintiff quotation and that of Caldirola had no scientific basis every expert can easily identify, because the two quoted papers treat dramatically different topics; and, above all, 3) the Plaintiff paper quoted by Defendant CONTE had no direct relevance for the structure of the neutron.

     153. Therefore, Defendant CONTE quoted Plaintiff SANTILLI in the intentionally wrong way, that for papers which had no connection to the structure of the neutron, for the specific premeditated deception of projecting the image of proper conduct, while in reality perpetrating a widespread fraud.

     III-E: DEFENDANTS MALLOVE, DELLO RUSSO AND PHIPPS CONSPIRATORIAL COMPLICITY IN DEFENDANT CONTE'S SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN THE ARTICLES AT "INFINITE ENERGY"

     154. Immediately following the discovery of scientific frauds by Defendant CONTE in Ref. [17], by following due procedure in similar case, on May 31, 1999, Plaintiff SANTILLI and his associates requested to Defendants MALLOVE and DELLO RUSSO:
     1) The publication in the immediately next issue of their magazine "Infinite Energy", and solely in the immediately next issue, of a denunciation submitted either authored by the Plaintiff or by one of his several associates, as preferred by Defendant MALLOVE and DELLO RUSSO.
     2) Jointly with the publication of the above denunciation, Defendant MALLOVE and DELLO RUSSO were left free to publish whatever lies and frauds by Defendant CONTE they desired, because evidently damaging to them, rather than to Plaintiff.
     3) Jointly with the publication of the denunciation of scientific frauds, and the answer by Defendant CONTE, Defendants MALLOVE and DELLO RUSSO were requested to abstain from siding for the scientific frauds perpetrated by Defendant CONTE for various reasons, such as: the reputation they have acquired of siding with equivocal conduct for personal financial and other gains related to the evident increased sales of their magazine; the evident need to prevent that such a siding would void all the corrective benefits derived form the publication of the denunciation; and the need for justice and scientific value which, in the final analysis, should not be entirely forgotten.

     155. As established by ample documentation and multiple eyewitnesses, Plaintiff SANTILLI repeatedly reassured defendants MALLOVE and DELLO RUSSO that the above corrective measures 1), 2) and 3) would completely remove them from any liability acquired in their publication of fraudulent paper Ref. [17]. Moreover, Plaintiff Santilli repeatedly expressed in writing his full availability to issue a written release for any said liability upon formal confirmation of implementing requests 1), 2), and 3).

     156. As also established by incontrovertible documentation and multiple eyewitnesses, Defendants MALLOVE and DELLO RUSSO, perniciously, insistently, repetitiously refused to implement any immediate corrective measure, by dubbing all requests as "pressures in their editorial conduction of the journal", in flagrant ignorance that they had perpetrated a violation of the Law, let alone of scientific values, and an evident d injury to the Plaintiff.

     157. It has been internationally established throughout the history of science that the denunciation of plagiarisms is a simply unalienable right of the victims of scientific frauds, as well as a simply unalienable duty to implement by all honest editors and publishers, in which editors must relinquish their editorial authority and independence, and correct their errors, rather than keep dreaming of their independence.

     158. The repetitious denials by Defendants MALLOVE and DELLO RUSSO of this unalienable right by the injured Plaintiff to implement immediate corrective measures is a profoundly unethical behavior, which Plaintiff SANTILLI feel the moral obligation to denounce, oppose and prosecute via all means permitted by Law.

     159. In response to mounting requests by various scientists that they should implement immediate corrective measures, Defendants MALLOVE and DELLO RUSSO answered with the indication that they may eventually publish a presentation on the case with unspecified authors, at an unspecified future time, and with unspecified content.

     160. Such a response was absolutely unacceptable by the Plaintiff, primarily on ethical as compared top legal grounds, because the longer the scientific frauds of Ref. [17] remain un-denounced, the bigger are the injury, damage and loss of scientific paternity suffered by the Plaintiff, as evident to all persons in goof faith.

     161. When forced into the evidence that the plagiarism perpetrated by Defendant CONTE in Ref. [17] is so widespread to be visible by all;, Defendant MALLOVE and DELLO RUSSO answered by stating that they needed inspections of the case by "experts". This established beyond any possible or credible doubt the lack of technical expertise by Defendant MALLOVE and DELLO RUSSO for the conduction of their editorial functions, as confirmed in writing by Defendant MALLOVE with the statement that he is not a physicist, which evidence and confirmatory statement, therefore, completely disqualifies them from running what is supposed to be a highly technical physics magazine on new energies. However, this posture confirmed beyond any possible or otherwise credible doubt the lack that Defendant MALLOVE and DELLO RUSSO where not acting in good faith, because the ethical need of quoting Plaintiff's copyrighted Refs. [3,4,5] by any subsequent publication in exactly the same topic is absolutely incontrovertible and understandable to all without any need for a Ph. D. in physics.

     162. Moreover, the impossibility to accept an undefined presentation at an undefined future time, and with undefined content, was mandated by the use indicated by Defendant MALLOVE as reviewer of the case one of their friends, Defendant PHIPPS, whose scientific honesty is questionable as per evidence provided below.

     163. The rejection of an itemized denunciation of very specific and technically documented plagiarisms, frauds, and deceptions in Ref. [17]; the formally acknowledged fraudulent posture of lack of personal expertise by Defendants MALLOVE and DELLO RUSSO to understand evident ethical, scientific and legal rules in the papers they publish; and the selection by Defendants MALLOVE and DELLO RUSSO of a reviewer such as Defendant PHIPPS, rendered the filing of this Complaint absolutely mandatory, because of the lack of any recourse other than that at L      164. Due to the pernicious, intentional, premeditated decision by Defendants MALLOVE and DELLO RUSSO to prohibit the implementation of immediate corrective measures, in conformity with the Law on Plagiarism Tort and other Statutes, on June 22, 1999, Plaintiff sent under multiple eyewitnesses via certified mail return receipt requested with copy via regular mail and via fax, a formal notification of plagiarism perpetrated by Defendants MALLOVE and DELLO RUSSO with the publication of Ref. [17] in their magazine, with request of immediate corrective measures as in items 1), 2) and 3) above.

     165. Since no acknowledgment or corrective action of any type was issued by Defendants MALLOVE and DELLO RUSSO, Plaintiff SANTILLI sent to said Defendants, under multiple eyewitnesses, on June 27, 1999, a second and final, formal notification of plagiarism with request for corrective measures under which a written release of all acquired liabilities would have been issued, with the ultimate deadline of July 7, 1999, for any action.

     166. In this final notification of June 27, 199, Plaintiff SANTILLI clarified with clarity that, in the absence of appropriate corrective actions on or before July 7, 1999, he would initiate legal proceedings against them without any need to wait for the publication of the next issue of "Infinite Energy", and that, once filed, the lawsuit would stand even in the event of the publication of a denunciation.

     167. July 7, 1999, came and went by without any corrective action, and this Complaint was therefore filed.

     168. COUNT 10: In view and consideration of the evidence provided below, Plaintiff SANTILLI hereby respectfully prays this Honorable Court to accept as Count 10 the fact that the editors of the magazine "Infinite Energy", Defendants MALLOVE and DELLO RUSSO, and their friend reviewer Defendant PHIPPS, conspired with Defendant CONTE to steal in Refs. [14,16,17] the scientific discoveries by Plaintiff SANTILLI copyrighted in Refs. [1-12] regarding hadronic mechanics and its primary application to the resolution of the historical problem of the structure of the neutron according to Rutherford, in multiple documentary evidence and eyewitness accounts that Defendants MALLOVE, DELLO RUSSO, and PHIPPS were fully aware of said Refs. [1-12] much prior to the publication of said Refs. [14,16,17], yet they abstained from publishing them in the correct referral form, thus perpetrating in Refs. [14,16,17] a clear act of fraudulent and deceptive plagiaristic editorship, for which Plaintiff prays this Honorable Court to grant the maximal possible reliefs permitted by Law.

     169. CONSPIRATORIAL EVIDENCE # 1: Back in 1998, Plaintiff SANTILLI had secured a large financial compensation to Defendants MALLOVE and DELLO RUSSO for the publication in their magazine "Infinite Energy" of a series of five articles outlining hadronic mechanics and its application to new energies. In fact, the following articles were indeed published:

     170. "Ref. [18]", R. M. Santilli, article entitled "Physical Laws of the Emerging New Energies as Predicted by Hadronic Mechanics, I: Insufficiencies of Quantum Mechanics", published in "Infinite Energy" issue no. 22, pages 33-49, 1998.

     171. "Ref. [19]", R. M. Santilli, article entitled "Physical Laws of the Emerging New Energies as Predicted by Hadronic Mechanics, II: The New Mechanics", published in "Infinite Energy" issue no. 23, pages 69-71, 1999, and issue 25, pages 60-74, 1999.

     172. "Ref. [20]", R. M. Santilli, article entitled "Physical Laws of the Emerging New Energies as Predicted by Hadronic Mechanics, Part IIIA: The structure of the Neutron and New Energies of Class I", published in "Infinite Energy" issue no. 25, pages 75-85, 1999.

     173. As amply documented beyond credible doubt, the completion of the latter article III, hereinafter referred as "Part IIIB", that specifically dealing with a review of Refs. [3,4,5] on Rutherford's structure of the neutron as permitted by hadronic mechanics, was submitted by Plaintiff SANTILLI to Defendants MALLOVE and DELLO RUSSO in early February, 1999, in a preliminary version, followed by improved versions later on. Then same paper was accepted for publication by Defendants MALLOVE and DELLO RUSSO, except for minor linguistic corrections of no consequence for this Complaints which Plaintiff immediately accepted to implement in their entirety. It should be noted that, by comparison, the fraudulent article by Defendant CONTE, Ref. [17], was published by Defendants MALLOVE and DELLO RUSSO in late April, 1999.

     174. This incontrovertible documentary evidence which cannot be denied by any person with a minimum of dignity, establishes that, at the time of electing to publish fraudulent article Ref. [17] in late April, 1999, Defendants MALLOVE and DELLO RUSSO were fully aware of hadronic mechanics, having accepted months before papers [18,19,20] in exactly that field under their editorial review, and were specifically aware of the plaintiff representation of the structure of the neutron, since they had received, inspected, and approved Plaintiff's Paper IIIB exactly in that field months before the publication of fraudulent Ref. [17]. Moreover, Plaintiff SANTILLI had mailed under eyewitnesses to Defendants MALLOVE and DELLO RUSSO in early February 1999 copies of all original copyrighted Refs. [3,4,5] and several others.

     175. Despite all that, Defendant MALLOVE and DELLO RUSSO in a pre-meditated and intentional, conspiratorial way, decided to publish the fraudulent paper by Defendant CONTE, Ref. [17] in the structure of the neutron, rather than Plaintiff's paper IIIB, in their full, documented awareness that Ref. [17] had no quotation whatever to the Plaintiff's work, Refs. [3,4,5]. \

     176. Moreover, the preference of fraudulent Ref. [17] over Plaintiff's scientifically and legally proper Paper IIIB was perpetrated in full awareness that the plagiarizing fraud by Defendant CONTE had no financial support, while the presentation of then original derivation by the Plaintiff SANTILLI had a large financial support already cashed by Defendant MALLOVE and DELLO RUSSO.

     177. This constitutes clear evidence of a conspiracy between Defendants MALLOVE, DELLO RUSSO and CONTE to plagiarize hadronic mechanics and its most important application for evident personal gains. The above evidence is reaffirmed by their incredible denial of publishing immediate corrective measures, whose first and foremost task was the indication of Refs. [3,4,5] they had intentionally avoided in the fraudulent Ref. [17].

     178. This Honorable Court should note that the intentional, pre-meditated violation by Defendants MALLOVE and DELLO RUSSO of the above sacrosanct duty at the foundations of all real scientific publications, the quotation and review of prior references directly in the field, is completely independent from the issue of plagiarism. Therefore, by suppressing the quotation of Refs. [3,4,5] in Ref. [17], Defendants MALLOVE and DELLO RUSSO have caused to Plaintiff serious injuries and damages for which due financial compensations and other remedies at Law are requested under Count 10.

     179. The above evidence of conspiracy by Defendants MALLOVE and DELLO RUSSO was reaffirmed by the fact that, in their mind-obliterating feverish intent to control, and abuse the lives and rights of their authors, they issued an incredible written prohibition to Plaintiff SANTILLI for any change whatever in Paper IIIB reviewing Refs. [1-5], i.e., no change whatever were allowed over the version that had been submitted and approved prior to the discovery of the fraud in Ref. [17] . This evidently implied the prohibition to denounce in said accepted Paper IIIB the scientific fraud by Defendant CONTE in Ref. [17], thus confirming, re-establishing, and re-asserting the premeditated intent by Defendant MALLOVE and DELLO RUSSO to prohibit any denunciation of plagiarism whatever by the Plaintiff, whether in the separate denunciation submitted on May 31, 1999, or in Paper IIIB already approved for print.

     180. Since Plaintiff's Paper IIIB reviewing Refs. [1-5] was absolutely identical in technical content to the plagiarized Ref. [17] already appeared in print at "Infinite Energy", Plaintiff could not possibly release for print Paper IIIB as demanded by Defendants MALLOVE and DELLO RUSSO, i.e., without any joint denunciation of the plagiarisms perpetrated in Ref. [17]. Very regrettably for the community of researchers in new energies, Plaintiff had, under said impositions, no other alternative than that of withdrawing Paper IIIB and the rest of the series from publication in "Infinite Energy", and publish the completion of the series in a more qualified journal under a more ethical and professional editorship.

     181. CONSPIRATORIAL EVIDENCE # 2. As established by the above evidence, Defendants MALLOVE and DELLO RUSSO had incontrovertible, documented and eyewitnessed knowledge since at least since February 1999 of the representation of Rutherford's hypothesis via hadronic mechanics, at the same time when they were inspecting the fraudulent representation of the same problem by Defendant CONTE.

     182. As a result of this evidence, Defendants MALLOVE and DELLO RUSSO had full, complete, documented, and eyewitnessed, advance notice that Refs. [3,4,5] and Ref. [17] were identical in all words, all basic concepts, all basic formulae and all basic laws. But Refs. [3,4,5] were published some ten years before [17]. Therefore, the incontrovertible fraudulent nature of Ref. [17] was fully known to Defendants MALLOVE and DELLO RUSSO prior to the publication of Ref. [17].

     183. Moreover, Defendants MALLOVE and DELLO RUSSO simply cannot deny without passing all levels of human and scientific decency, that they had indeed noted the complete absence of Refs. [3.4.5] in the fraudulent Ref. [17].

     184. Despite that, in an intentional and pre-meditated way, Defendants MALLOVE and DELLO RUSSO elected to publish the fraudulent paper Ref. [17] by Defendant CONTE rather than publish Plaintiff's Paper IIIB in exactly, absolutely the same topic.

     185. his establishes beyond any conceivable or otherwise credible doubt that the scientific plagiarism, fraud, deception, lies and other illegalities of Ref. [17] were published by Defendant MALLOVE and DEL.LO RUSSO in their full awareness and support, thus establishing the existence of a conspiracy by Defendants MALLOVE, DELLO RUSSO and CONTE also beyond any possible or credible doubt, as confirmed, reaffirmed and reinforced by the repetitious, stubborn, hostile refusal by Defendants MALLOVE and DELLO RUSSO against the publication of any immediate corrective measure.

     186. Moreover, this Honorable Court should note that Defendants MALLOVE and DELLO RUSSO preferred the publication of fraudulent paper Ref. [17] against the legitimate Paper III by the Plaintiff even though the former had no financial support whatever, while the latter had a large financial support. Therefore, the preference of the fraudulent paper by Defendant CONTE, Ref. [17], over Paper IIIB by the Plaintiff in exactly the same topic, also constitute a breach of precise financial obligations for which Defendants MALLOVE and DELLO RUSSO will indeed be made accountable via due process at Law.

     187. The motivation of this clear conspiracy is also clear: money. In fact, by intentionally creating a controversy, Defendant MALLOVE and DELLO RUSSO put the foundations of a large increase in sales of their magazine, with consequential large increase of their financial returns. In this way, they planned to make money by inflicting severe inures, damages and torts to Plaintiff, as well as in total disrespect of the interest of science and the Law.

     188. Plaintiff therefore request this Honorable Court the maximal possible punishment and relief against Defendants MALLOVE and DELLO RUSSO permitted by Law in regard to this Count 10.

     189. CONSPIRATORIAL EVIDENCE # 3. This Honorable Court should moreover note that, quite unbelievably, but true and documented in black and white for all to see, Defendants MALLOVE and DELLO RUSSO published in strict sequence next to each other in the same issue 24, 1999, of their magazine "Infinite Energy", from page 49 to page 57: 1) the fraudulent paper Ref, [17] by defendant CONTE; 2) the strong denunciation of plagiarism by Plaintiff SANTILLI, Ref. [15]; and 3) the answer by Defendant CONTE, Ref. [16]; all evidently published under editorial control, corrections, formatting, publishing, distributing, etc. by Defendants MALLOVE and DELLO RUSSO.

     190. Therefore, under no condition whatever, not even remote, can Defendants MALLOVE and CONTE credibly deny their complete awareness at the time of publication of Ref. [17] its fraudulent and plagiaristic character denounced in the subsequent publication [15].

     192. This provides clear, additional, incontrovertible evidence of the conspiracy by Defendants MALLOVE, DELLO RUSSO and CONTE to fraudulently copy the main structure and application of hadronic mechanics, as confirmed, re-asserted and re-established by their stubborn opposition against any immediate corrective measure..

     193. CONSPIRATORIAL EVIDENCE # 4. The most serious editorial misbehavior by Defendants MALLOVE and DELLO RUSSO has yet to be identified and denounced. It consists of the conspiratorial publication of the fraudulent Ref. [17] in full, documented and eyewitnessed awareness that said Ref. [17] is afflicted by catastrophic inconsistencies denounced in point 3) of Ref. [15] by the Plaintiff which was published by Defendants MALLOVE and DELLO RUSSO immediately following said Ref. [17], as well as denounced by Plaintiff to Defendants MALLOVE and DELLO RUSSO in numerous personal communications.

     194. Moreover, Defendants MALLOVE and DELLO RUSSO cannot credibly deny their complete awareness of said catastrophic inconsistencies , because the same are treated in detail in Sect. 4 of Plaintiff's Ref. [19] they had received months earlier, reviewed, edited, printed and distributed in their magazine.

     195. The publication by Defendants MALLOVE and DELLO RUSSO of Ref. [17] in their documented full awareness of the existence of catastrophic inconsistencies without any mention of the same, constitute a documented pre-meditated deception, not only against the Plaintiff, but also against society, because it has caused serious damage and injury to the credibility of research in new clean energies which are so needed by our society, while damaging an unspecified number of researchers who are spending their name, time and effort in the use of a catastrophically inconsistent theory.

     196. As a consequence of the gravity of such an editorial misbehavior, Plaintiff SANTILLI is considering the possibility to initiate separate Criminal Proceedings against the Defendants MALLOVEA and DELLO RUSSO.

     197. CONSPIRATORIAL EVIDENCE # 5. In their refusal to implement any immediate corrective measure, Defendant MALLOVE and DELLO RUSSO indicated that they had passed the case to their friend Defendant PHIPPS for review. Since, at that time, Defendant PHIPPS was a Honorary Professor at the Institute of which Plaintiff is the President, which honorary position had been received by Defendant PHIPPS because of the personal intervention by Plaintiff SANTILLI, on June 24, 1999, Plaintiff SANTILLI phoned Defendant PHIPPS for the purpose of indicating to him the impending legal actions rendered unavoidable by the stubborn opposition by Defendants MALLOVE and DELLO RUSSO against the publication of any immediate correction, as requested by Law and ethics.

     198. During the phone conversation, in which Defendant PHIPPS remained essentially silent, Plaintiff brought to Defendant PHIPPS attention: 1) The complete lack of quotation of the preceding Refs. [3,4,5] in Ref. [17] despite the former being some ten years earlier, and treating exactly the same topic, in clear violation of ethics and the Copyright Law; 2) The identical character of all structural equations in Refs. [3,4,5] and Ref. [17] that Defendant PHIPPS, being a physicist, was expected to see in a few seconds glance without any study; and 3) The most serious scientific crime, the publications of Ref. [17] with catastrophic inconsistencies without any mention or allusion at the same, in violation of other basic rules and Laws.

     199. To his extreme astonishment, on June 28, 1999, Plaintiff SANTILLI received from Defendant PHIPPS a letter in which he completely supported his close friends Defendants MALLOVE and DELLO RUSSO, denied all of Plaintiff's claims, and resigned from the honorary position the Plaintiff had so generously secured for him.

     200. Under the protection of the First Amendment of the U. S. Constitution, Plaintiff RUGGERO MARIA SANTILLI intends to denounce the above behavior of Defendant PHIPPS in the strongest possible terms permitted by Law.

     201. First, after a pompous laudation of his close friend Defendant MALLOVE, which is crushed into lilliputian dimensions by the evidence of his editorial misbehavior, in the letter of June 24, 1999, Defendant PHIPPS denied the sacrosanct right the Plaintiff has to have his prior work Refs. [3,4,5] on Rutherford's historical hypothesis quoted in all research directly related in the field. Defendant PHIPPS then supported in full the absence of such quotation in Ref. [17]. This is the most dishonest behavior any person with the self-qualification as a scientist could possibly perpetrate, which Plaintiff intent to denounce, oppose and prosecute in an y means permitted by Law. It should be noted again that the ethical rule of quotation of prior work on which real, non-sectarian science is based, is independent from the issue of plagiarism.

     202. Next, Defendant PHIPPS lies in stating that he did not have Plaintiff's Refs. [3,4,5], when they were mailed under eyewitnesses by Plaintiff to him months earlier jointly with correspondence exactly on Rutherford's neutron, while additional copies had been independently mailed to him by Defendant MALLOVE as part of the request of his review. This re-affirms the dishonest nature of defendant PHIPPS, and establishes that his action was intended for anti-scientific, conspiratorial-sectarian behaviour aiming at personal gains in disrespect of ethics and the Law.

     203. Next, in the same letter of June 24, 1999, Defendant PHIPPS emphatically supports Defendant CONTE and states that the latter has committed no plagiarism because, as per Plaintiff's own statement, Defendant CONTE had copied papers [3,4,5] only in their basic equations and not in the mathematics needed for their correct elaboration. However, Plaintiff SANTILLI had reminded Defendant PHIPPS during their phone conversation that it is illegal to copy a copyrighted work even in part, as recalled in the introductory part of this Complaint. Therefore, the mind-obliterating fervor by Defendant PHIPPS for his conspiratorial-sectarian conduct was pushed to such incredible extremes of blatantly supporting clear illegalities in scientific papers !

     204. Next, in the same letter of June 24, 1999, Defendant PHIPPS strongly supports the decision by Defendant MALLOVE to publish an unspecified presentation at an unspecified future time authored by unspecified individuals. Since Defendant MALLOVE had requested the review of the case by Defendant PHIPPS, it is evident that the latter was supporting the delated publication of alleged corrective measures to have his own scientific misbehavior appear in print. The net result of this posture was mandating the filing of this Complaint.

     205. Next, in the same letter of June 24, 1999, Defendant PHIPPS strongly supports the suppression of the quotation of catastrophic inconsistencies when they are known to the author and/or to the editors, which is the most dishonest and immoral scientific behavior Plaintiff has the disgrace of ever experiencing, and which Plaintiff has the right to denounce in the strongest possible terms, precisely on the same grounds abused by Defendant PHIPPS for his support of scientific deception, the freedom of expression permitted by the First Amendment of the U. S. Constitution.

     206. Next, in his mind obliterating fervor to support his close friend Defendant MALLOVE in disrespect of the interests of science, ethics, and society, in his letter of June 24, 1999, Defendant PHIPPS enters into a vociferous support of deception in science, on grounds that nowadays deception pervades all segments of society.

     207. This Honorable Court should be informed that all generalized theories published by Defendant PHIPPS can be very easily proved to suffer horrendously catastrophic inconsistencies because said generalized theories possess a nonunitary structure which, as such, activates said catastrophic inconsistencies in a way beyond any possible or credible doubt. Therefore, Defendant PHIPPS supported in writing the deception in physics for the very specific purpose of continuing his own deceptive publications without any mention of their catastrophic inconsistencies.

     208. Plaintiff's SANTILLI spares this Honorable Court additional details of the dishonest, asocial, anti-scientific, and conspiratorial-sectarian posture by Defendant PHIPPS in his mind obliterating fervor to support his friend, Defendant MALLOVE.

     209. The above evidence pertaining to Defendant PHIPPS has been included in this Complain because it confirms, re-establishes and re-affirms the existence of an organized conspiracy by Defendants MALLOVE, DELLO RUSSO, PHIPPS and CONTE to defraud Plaintiff SANTILLI of his scientific priorities and copyrighted paternities.

     210. In summary, the letter written by Defendant PHIPPS to Plaintiff SANTILLI dated  June 24, 1999, can only be qualified as the act of a member of a conspiratorial sect, and absolutely not as the act of a real Scientist. Plaintiff still carries in his body scars from Nazi shells when he was a little boy in Italy during WWII. Following that, Plaintiff never did and never will tolerate any abuse of his rights from any individual, any association, or any sect, whatever their ethnic, religious, or other connotation. This Complaint is a partial outcome of that iron-strong resolve.

     III.F: DEFENDANT CONTE SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN ADDITIONAL PAPERS PUBLISHED IN THE MAGAZINE "PHYSICS ESSAYS"

     211. This Honorable Court should be aware that the plagiarisms, frauds and deceptions perpetrated by Defendant CONTE against Plaintiff SANTILLI copyrighted scientific publications Ref. [1-12], as presented above, are only part of the systematic misbehavior by Defendant CONTE. Additional plagiarisms, frauds and deceptions were perpetrated by Defendant CONTE via further articles published in the magazine "Physics Essays", thus mandating the most vigorous possible action permitted by Law.

     212. "Ref. [21]", E. Conte, article entitled "Generalization of Schroedinger equation using biquaternions: The possibility of fusion of particles", published in "Physics Essays" Vol. 8, pages 52-59, 1995.

     213. COUNT 11. As per multiple evidence provided below, Plaintiff SANTILLI prays this Honorable Court to accept as Count 11 the truly incredible, systematic, and verbatim plagiarisms perpetrated by Defendant CONTE in Ref. [21] of all the Copyrighted basic equations of hadronic mechanics, Refs. [1-12], in the absence of any quotation of the original references, in full pre-meditated intent to defraud Plaintiff SANTILLI and his associates of said scientific and copyrighted paternity due to the multiple documented and eyewitnessed full awareness by Defendant CONTE of the existence of said original publications.

     214. Evidence of Count 11 can be summarized as follows: Eq. (17), page 54, Ref. [21] is an incredible identical copy of the internationally known, most fundamental assumption of hadronic mechanics, the generalization of the unit, as copyrighted in virtually all publications on hadronic mechanics, such as Refs. [1-12] fully known to Defendant CONTE, yet without any quotation of the same.

     215. Eq. (19) of Ref. [21] is a fraudulent particularization of the generalized unit of hadronic mechanics as needed to preserve conventional values of spin, repeatedly brought by Plaintiff SANTILLI to the attention of Defendant CONTE in numerous letters and related copyrighted papers, such as Refs. [4,5,6,7], yet in the absence of any quotation of the same.

     216. Eq. (21) Ref. [21] is also am identical copy of exactly the fundamental transformation mapping the commutator of quantum into hadronic mechanics, as available, for instance, in the copyrighted Eq. (2.5) of Ref. [8], which has been copied by even using the same symbols, yet without any quotation of Plaintiff's work, thus establishing the intentional, pre-meditated fraud by Defendant CONTE beyond any possible or otherwise credible doubt.

     217. The multiple fraud is perpetrated on the basis of the allegation that the transform (21) of Ref. [21] refers to the new number pompously dubbed by Defendant CONTE as "biquaternions".

     218. his posture implies a first fraud perpetrated in Ref. [21] again the famous scientist who invented the quaternions, Hamilton. In fact, in the way they are defined by Defendant CONTE in Ref. [21] (quaternions whose elements are ordinary complex numbers) the "biquaternions" are precisely the historical way Hamilton discovered them, as stated in all qualified technical books.

     219. The above posture also implies the second fraud perpetrated in Ref. [21] on the allegation that such "biquaternions" are new and, therefore, no mention of hadronic mechanics is needed. This is a blatant, patented, intentional lie because it is well known since its inception that hadronic mechanics is defined for all possible numbers, including quaternions over real or complex numbers. This establishes beyond any possible or otherwise credible doubt the complete lack of any novelty whatever by Defendant CONTE in his studies. Only a non-original reformulation of well known results first and originally obtained by others.

     220. The third fraud is perpetrated in Ref. [21] on the presentation of an alleged generalization of quantum mechanics via the conventional quaternions with elements given by complex numbers. It is well known since early this century that such a treatment only provides a reformulation of conventional quantum mechanics with no generalization of any type.

     221. The sole, clean, original, consistent, and invariant generalization of quantum mechanics via quaternions is that admitted as a particular case of hadronic mechanics, that via quaternions with a generalized unit, which constitute the central part of Ref. [6] on isonumbers and genonumbers, as mailed to Defendant CONTE under eyewitnesses, yet the latter vulgarly abstains from quoting said Ref. [6].

     222. Defendant CONTE does indeed introduces a generalized unit, as quoted earlier, but abstains from indicating that his "biquaternions" are the Hamilton-Santilli isoquaternions, because the fraud would then appeared too evident.

     223. In short, Defendant CONTE has only worked out an erroneous reformulation of hadronic mechanics which suffers of the catastrophic inconsistencies indicated earlier due to the absence of the needed isomathematics, without any shadow whatever of any novelty whatever, in the conceptual foundations (copied ad litteram), basic equations (copied ad litteram) and applications also copied ad litteram).

     224. Eq. (49) of Ref. [21] is an additional truly incredible plagiarism of another very fundamental and internationally known law of hadronic mechanics, the generalization of Planck's constant into an operator, which has been treated numerous times in Refs.. [1-12] fully known to Defendant CONTE, yet the latter abstains from quoting its original Copyrighted discovery.

     225. Eqs. (55) and (56) of Ref. [21] are an additional, incredible, immoral, identical copy of the fundamental isoschroedinger equations of hadronic mechanics, which have been copied even using exactly the same symbols, yet Defendant CONTE intentionally abstains from quoting and reviewing the copyrighted origination fully known to him, such as Ref. [3].

     226. Plaintiff SANTILLI spares this Honorable Court the continuation of the litany of incredible, plagiarism, fraud and deception by Defendant CONTE in the remaining part of his paper [21], although reserves the rights of a more detailed documentation whenever needed.

     227. "Ref. [22]": E. Conte, article entitled "New Pauli matrices in biquaternion quantum mechanics: A case of an explicit and concrete realization of hidden variables", published in "Physics Essays" Vol. 8, pages 605-614, 1995.

     228. COUNT 12: Due to the multiple evidence presented below, Plaintiff SANTILLI prays this Honorable Court to accept as Count 12 the additional injuries, damages and losses Plaintiff has suffered because of Defendant CONTE additional, truly incredible plagiarisms perpetrated in Ref. [22] of the copyrighted scientific property by the Plaintiff ion Refs. [3,8,12], which has been of such degrees and implications to mandate the filing of this Complaint.

     229. The multiple damage, injury and loss suffered by Plaintiff SANTILLI because of Ref. [22] begins in the very title with the claims of "New Pauli's matrices" allegedly invented by Defendant CONTE. In the reality, such "new Pauli's matrices", given by Eq. (28), page 607, Ref. [22], are an identical copy of copyrighted equations personally brought by the Plaintiff to the attention of the Defendant CONTE, such as Eq. (2.32), Ref. [3], Eqs. (3.9) and (3.11) of Ref. [8], and entire chapters of Ref. [12] dedicated to the same topic. Yet, Defendant CONTE intentionally abstain from quoting the same original references in the first derivation of said matrices, for the evident intent of defrauding Plaintiff SANTILLI of the paternity of another one of his most important discoveries.

     230. It should be stressed for this Honorable Court that, as any clear scientist can verify, Defendant CONTE did not even introduce a new derivation of the Pauli-Santilli matrices of Refs. [3,4,5,6,7.8,9,10,11,12] because the derivation of said matrices via quaternions was fully and consistently constructed for the first time in the Copyrighted Ref. [6,12] documentedly known to Defendant CONTE, but which he elected not to quote.

     231. The second incredible fraud of the title of Ref. [22] is in the statement of "explicit and concrete realization of hidden variables". The is an identical plagiarism of the first explicit and concrete realization of hidden variables in scientific history achieved in Ref. [12] and preceding copyrighted publications not mentioned here for brevity, including an identical copy of the very words used in that Copyrighted publication ! What an immoral way of dishonoring science, perpetrated by Defendant CONTE in a documented premeditated way and in equally documented, full complicity by the editors of "Physics Essays", Defendant PANARELLA, CHARBONNEAU, and ROBINSON, as shown below in this Complaint.

     232. To confuse inepts and uninformed, Defendant CONTE did indeed quote "hadronic mechanics" in Ref. 5 of Ref. [22], and discussed the latter in pages 608 and 609 of Ref. [22]. However, any scientist with a minimum of ethics can see the intentional fraud by both the author and the editors because of the careful absence in addressing the real issues, e.g.:
     1) the lack of explicit statement in the comparison between hadronic mechanics and "biquaternion quantum mechanics" that the "new Pauli matrices" were first discovered by Plaintiff SANTILLI in Refs. [3,8,etc.], thus perpetrating a first intentional, pre-,meditated fraud and deception;
     2) The lack of any quotation in the comparison between hadronic mechanics and "biquaternion quantum mechanics" that the first derivation of the Pauli-Santilli matrices via quaternions was done in Ref. [6] known to the author of Ref. [22] and the editors alike, thus perpetrating a second, intentional, fraud by the author and editors alike of Ref. [22];
     3) The lack of any statement in the comparison between hadronic mechanics and "biquaternion quantum mechanics" that the first "explicit and concrete realization of hidden variables" is precisely that presented in Ref. [22] which copies ad litteram Santilli's monographs, Refs [12], fully known to author and editor alike, thus confirming the pre-meditated, intentional fraud and deception beyond any possible or credible doubt.

     233. Above all, the biggest fraud and deception by author and editors alike of Refs. [21,22] are perpetrated in the very title of the alleged new theory, "biquaternion quantum mechanics" for the reasons indicated earlier (that, by its very definition, cannot imply any generalizations of quantum mechanics at all since the quaternions used by the Defendant CONTE are conventional).

     234. spare this Honorable Court additional details of the plagiarisms, frauds, and deceptions perpetrated in Ref. [22], although Plaintiff reserves the right of more detailed presentations and documentations at some later time.

     235. "Ref. [23]": E. Conte, article entitled "On the generalization of the physical laws by biquaternions: Application to the generalization of Minkowski spacetime", published in the magazine "Physics Essay" Vol. 10, pages 437-441, 1997.

     236. COUNT 13: Plaintiff SANTILLI prays this Honorable Court to accept as Count 13 the fact that, in a truly incredible way documented below, Defendant CONTE continues in Ref. [23] the plagiarism of Copyrighted scientific works by Plaintiff SANTILLI in Ref. [8,11], yet the quotation of the latter is intentionally avoided in Ref. [23], thus constituting grounds for the highest possible reliefs permitted by Law.

     237. To begin, all the essential wordings and text of Ref. [23] constitutes an identical plagiarism, word by word, of the Copyrighted Refs. [6,11], which Plaintiff reserves the right to identify, and denounce in all the necessary details whenever needed during the interim of this Complaint.

     238. Moreover, the central equation of the paper, Eq. (23), page 439, Ref. [23], is a dishonest, identical copy of the first derivation by Plaintiff, Eq. (2) of Ref. [8], without any quotation of the same, yet in documented and eyewitnessed, full awareness by Defendant CONTE of its existence.

     239. This establishes the plagiarizing fraudulent, deceptive, immoral and illegal behavior by Defendant CONTE beyond any remotely conceivable or otherwise credible doubt.

     240. Ref. 2 of Ref. [23] does indeed quote the Plaintiff, but again in the now familiar deceitful style of intentionally quoting articles not directly related to the topic. The childish scheme evident to all is here that of being in a position to claim to have quoted Plaintiff SANTILLI, yet being able to allege a fraudulent paternity because of lack of quotation of the first derivation of the alleged "new results".

     241. Plaintiff SANTILLI intends to oppose this immoral, fraudulent, and illegal scheme in any and all means permitted by U. S., European and Italian Laws.

     III-G: DEFENDANTS PANARELLA, CHARBONNEAU, AND ROBINSON, CONSPIRATORIAL COMPLICITY IN DEFENDANT CONTE'S SCIENTIFIC PLAGIARISMS, FRAUDS, AND DECEPTIONS AGAINST PLAINTIFF IN THE ARTICLES AT "PHYSICS ESSAYS"

     242. As a final aspect of the main argument of this Complaint, this Honorable Court should be aware of the existence of simply incontrovertible, multiple documentation, and eyewitnessed evidence that the editors of the magazine "Physics Essays", Defendants PANARELLA, CHARBONNEAU, and ROBINSON, were fully aware of the original paternity by Plaintiff SANTILLI of the theories fraudulently depicted in Refs. [21,22,23] as "new", yet they intentionally abstaining from having them quoted.

     243. COUNT 14: Plaintiff SANTILLI finally prays this Honorable Court to accept as Count 14 the evident provided below according to which the editors of the magazine "Physics Essays", Defendants PANARELLA, CHARBONNEAU, and ROBINSON, conspired with Defendant CONTE to defraud in Refs. [21,22,23] Plaintiff SANTILLI of his scientific discoveries copyrighted in Refs. [1-12], without a proper quotation of the same, except for intentionally deceptive and manipulated referrals, despite the multiple evidence and eyewitness accounts that the editors Defendants PANARELLA, CHARBONNEAU, and ROBINSON were fully aware of Plaintiff's Refs. [1-12], thus perpetrating in Refs. [21,22,23] a clear act of fraudulent and deceptive plagiaristic editorship, for which Plaintiff prays this Honorable Court to grant the maximal possible reliefs permitted by Law.

     244. To begin, Defendant PANARELLA, editor in chief of the magazine "Physics Essay", was a personal guest at the Plaintiff's house in Florida in late December 1992, under the eye witnessing of other physicists. During that meeting, Defendant PANARELLA stated that he was fully aware of hadronic mechanics, its various applications and primary references. Subsequently, Plaintiff SANTILLI gave as a gift to Defendant PANARELLA complimentary copies of monographs [12]. Additional subsequent papers published in various prestigious international journals were subsequently mailed to Defendant PANARELLA always under eyewitnesses.

     245. Following the pledge of mutual scientific collaboration voiced at such a meeting of late December 1992, Plaintiff SANTILLI and his editorial staff reviewed numerous papers for the magazine "Physics Essays" on behalf of and following request by Defendant PANARELLA and his associates. Virtually all these reviews and related referee reports contained detailed quotations of the main aspects and references of hadronic mechanics and its applications.

     246. Plaintiff SANTILLI terminated his refereeing for the magazine "Physics Essays" in 1994 because, following his request to Defendant PANARELLA of the courtesy copy of a paper his staff had reviewed for "Physics Essays" at no charge, Defendant PANARELLA quite vulgarly requested the payment of $ 20 per page for the release of that copy, despite the fact that all the long work for reviews conducted by Plaintiff and his staff for "Physics Essays" had been done free of any charge, and no review of any type had been done by Defendant PANARELLA and his staff for the journals edited by Plaintiff SANTILLI due to the advanced nature of the latter, and consequential expertise that was lacking by Defendant PANARELLA.

     247. Moreover, this Honorable Court should be made aware of the paper:

     248. "Ref. [24]": R. Mignani, First University of Rome, Italy, article entitled "Quasar redshift in iso-minkowski space", published in the magazine "Physics Essays" Vol. 5, pages 531-535, 1992, which is considered an integral part of this Complaint as all other above quoted articles, Refs. [1] to [Ref. [23].

     249. As anybody can see, in his capacity as editor in chief of the magazine "Physics Essays", Defendant PANARELLA had received, inspected, reviewed, edited, published and distributed Ref. [24] which contains very specific paternities by the Plaintiff authored by an independent physicist, such as: "Santilli's Lie-isotopic lifting of the special relativity", which was subsequently plagiarized in Refs. [21,22,23] at the same magazine; the statement "Santilli's isominkowskian spacetime" with fundamental equation (4) of Ref. [24] properly quoted under the paternity of Ref. [8], which fundamental equation was subsequently plagiarized by Defendant CONTE in Eq. (23) of Ref. [23] without the quotation of the proper paternity, Ref. [8]; and other review of Plaintiff's discoveries; and other fraud, deceptions, plagiarisms, and lies.

     250. The publication of Ref. [24] by Defendant PANARELLA and his associates establishes beyond any conceivable or credible doubt their total, complete and full knowledge of Plaintiff SANTILLI's discoveries as well as of their original references

     251. hen joined with the preceding evidence presented in this Complaints, the latter evidence also establishes beyond any possible or otherwise credible doubt the existence of a conspiracy among all Defendants CONTE, PIERALICE, MALLOVE, DELLO RUSSO, PHIPPS, PANARELLA, CHARBONNEAU, and ROBINSON, to defraud Plaintiff SANTILLI as well as his associates of the paternity of hadronic mechanics and its main applications. C

     CONCLUDING REMARKS: The main contention by Plaintiff SANTILLI throughout this Complaint is that Defendant CONTE has achieved absolutely no new result whatever, not even minute, in the sense that the totality of the results presented in Refs. [14,16,17,21,22,23] with no exception whatever, were first achieved by the Plaintiff in his copyrighted publications Refs. [1-12] pertaining to hadronic mechanics and its various applications. To avoid turning a U. S. legal process into a farce, with consequential offense for this Honorable U. S. Court this Plaintiff will oppose with any means permitted by Law, all Defendants are hereby challenged to prove in their answer that Defendant CONTE has obtained at least ONE result that was not previously and identically obtained by the Plaintiff in the indicated references, with the clear understanding that a defense worth respect solely occurs, not via fraudulent, deceptive, and unsubstantiated beliefs ventured by Defendant CONTE based on mere changes of symbols and other plagiaristic lies, but via a REAL SCIENTIFIC PROOF OF AT LEAST ONE NOVELTY reached by Defendant CONTE, which is solely achieved via extremely rigorous comparative MATHEMATICAL elaborations and development worth their qualification as being scientific.

     IV JURISDICTION

     252. This Honorable Court has federal; jurisdiction of this Complaint pursuant to U.S. Code, Title 28, Section 1338(a), as well as pursuant to Middle District Rule 1.02(c), as the Tampa Division of the U. S. Federal Court encompassing Pinellas County in which the Plaintiff has been a resident since 1990.

     V. CLAIMS

     In the preceding parts of this Complaints, Plaintiff has provides:
     1) Multiple evidence of plagiarisms by all Defendants, whether acting individually or in a collegial conspiratorial way, of copyrighted scientific publications by the Plaintiff;
     2) Multiple evidence, corroborated by multiple eyewitnesses as well as written statements by the Defendants, of the full knowledge by all Defendants of each and all plagiarized copyrighted publications by the Plaintiff;
     3) Evidence on the organized conspiratorial character of the action by all Defendants;
     4) Human, scientific, and financial injuries, damages and losses suffered by the Plaintiff;
     4) Plaintiff right to protection under the copyright, tort and other applicable laws;
     5) Jurisdiction by this Honorable Court.

     Plaintiff remains available to provide copies of the necessary evidence and documentation, including copies of letters, e-mails, papers, copyright ownership, and whatever else requested for due proceedings of this Complaint. Plaintiff also pledges to remedy promptly any possible insufficiency of this Complaint.

     WHEREFORE, IN VIEW AND CONSIDERATION OF THE ABOVE, WITH PARTICULAR REFERENCES TO COUNTS 1, 2, 3, 4, 5, 6, 7, 8, 9,. 10, 11, 12, 13, AND 14, PRESENTED IN DETAILS IN PARAGRAPHS 78, 102, 112, 113, 114, 115, 116, 117, 118, 168, 213, 228, 236, and 243, RESPECTIVELY, BUT NOT LIMITING THE COUNTS SOLELY TO THE SAME, PLAINTIFF RESPECTFULLY PRAYS THIS HONORABLE COURT TO GRANT THE FOLLOWING RELIEFS:

     RELIEF I: The payment by Defendants of a cumulative compensatory sum of $ 5,000,000.00 (five million U. S. dollars);

     RELIEF II: An injunctive order to publish in "Infinite Energy" and, separately, in "Physics essays" the necessary denunciation of plagiarism with the quotation of the missing, original, copyrighted references;

     RELIEF III: Injunctive order against any continuation by the Defendants of the ongoing plagiarisms, frauds, and deceptions;

     RELIEF IV: An injunctive order against any additional publication of plagiarism of the Plaintiff work by other authors at "Infinite Energy" and "Physics Essays";

     RELIEF V: Reimbursement of all costs sustained by Plaintiff for this Complaint, including full reimbursement of the fee of an attorney the Plaintiff may hire for the proper interim of this Complaint following its filing.

     In faith

 

RUGGERO MARIA SANTILLI
Plaintiff acting pro se
as a U.S. Citizen in his own understanding of the Law, under the protection of the First Amendment of the U. S. Constitution, with no connection, whether explicit or implied, with the Institutions and Corporations the Plaintiff may be affiliated with/
Address or these legal proceedings:
35246 US 19, PMB No. # 115
Palm Harbor, FL 34684, U.S.A.

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Copyright © 1999-2002 Committee for Scientific Ethics.
Email: science2@gte.net
First updated July 18th, 1999. Revised July 30th, 2001