Preliminary Data justifying filing of a Civil Suit, in an amount to be determined, against New Mexico State University and/or The City of Las Cruces for egregious violation of human rights, failure to investigate, false arrest , unjustified incarceration, and prolonged detention.

Dr. Anton Black: Background Material related to the Events
of January 27, 1999 and Subsequent Consequences

Dr. Anton Black, aged 53, Caucasian and a U.S. Citizen, had been a professor of linguistics in Berlin, Germany for many years, and an instructor of political science at El Paso Community College thereafter. His doctorate was awarded by the University of Berlin in the field of semantics and linguistics. He speaks several European and Asian languages, has mastered Sanskrit, and enjoys sophisticated cognitively-based games such as Go and Bridge. In the period prior to his divorce in 1990, he had both achieved academic recognition in his field, and had interfaced with unspecified U.S. Intelligence Agencies in Europe, rendering commendable service to his nation's vital interests.

Since 1990, Dr. Black, deeply saddened by the break-up of his marriage under trying circumstances, and not infrequently depressed by this major life adjustment, has been traveling widely. Fairly recently, trips have brought him to Mexico City and to his native New York State. Although for a number of years subsequent to his divorce he remained in El Paso, befriending professionals at UTEP and in legal circles in Ciudad Juarez, he moved to Las Cruces in the last year. Conditions here are suitable for pursuing his academic interests which include the latest technological developments in artificial intelligence and in computer-based translation systems. It was within the context of this specific interest that the incident of last January 27th occurred.

Dr. Black, although not employed by New Mexico State University, had been circulating freely on campus as an independent research specialist. For several months prior to the incident under discussion, he could be seen interacting with students, faculty and research colleagues on campus, notably in the New and Branson Libraries, in Corbett Center and in either the CANTO or Jacobs Computer Laboratories where he was compiling data related to the mathematical probabilities associated with the Asian game Go.

Those who knew Dr. Black would be forced to say that, although he was clearly eccentric, sometimes unkempt by conservative standards, and occasionally lapsed into recollections concerning his tragic divorce, he was neither on mood-elevating medication nor behaviorally unusual in any way, given the breadth of personalities found on contemporary American university campuses.

The Computer Research Lab (CRL), located on the second floor of Science Hall on the NMSU Main Campus, was the scene of the January 27, 1999 incident about to be described. During standard business hours, Dr. Black had accompanied "Ardid", an Hispanic Graduate Student employed at CRL to the latter's office, located within the CRL work area. Their discussion centered on progress that had recently been made in the field of artificial intelligence and may have included specific morphological or phonemic reference to languages of which Dr. Black had professional knowledge. Dr. Black's conversation with Ardid may have become animated, but was certainly well within the scope of their respective specialities. The CRL work area is apparently structured so that Ms. Nicole Burston, employed in some unidentified capacity by CRL, may have been able to overhear the content and nature of the arguably private and professional conversation between Ardid and Dr. Black. At this point, she may have been forming judgements concerning the socio-political stance of Dr. Black or whatever contentious matter he may have been discussing with Ardid who, for his part, had no complaints about the nature, tone or content of the conversation.

When, presumably having reached a lull in his conversation with Ardid, Dr. Black turned toward Nicole, not knowing in what capacity she was employed, and asked her whether a cup of coffee might be available in CRL, she turned viciously toward Dr. Black and irrationally and inexplicably retorted, "Who do you think I am? I'm not your secretary! You had better leave now! I'm calling Security!" Whether (1) she was reacting to material she had overheard in Dr. Black's prior conversation with Ardid, or whether (2) she was tremendously sensitive to her "professional" image within CRL and was expressing her refusal to "serve coffee" is open to speculation. Ardid was astonished, as was Dr. Black, and the latter left the CRL complex at that point.

The events which ensued are a matter of record. Dr. Black was intercepted in front of the Subway Restaurant Outlet, approximately 500 feet from Science Hall, by Campus Security who, when he expressed astonishment at what was transpiring, proceeded to arrest him, acting under color of law and under the authority vested in them by the University, on unfounded, fabricated, and falsified charges of assault, with no injuries having taken place against anyone. He was transferred to the Las Cruces City Police, and detained in solitary confinement for 30 days. Thereafter, he was transferred, apparently on the basis of amateur assessment of his condition, to a State Facility where he received injections by force and was medicated against his will.

The Civil Suit which Dr. Black wishes to file against New Mexico State University and/or the City of Las Cruces is based on obvious violation of fundamental human rights, unjustified detention, false arrest and prolonged incarceration. Additionally, compensatory damages are sought for psychological destabilization related to the effects of cruel and unusual punishment, to wit solitary isolation, and for physiological injury sustained as a result of forced injections and medications throughout Dr. Black's period of confinement.

Witnesses are, of course, willing to come forward to confirm the foregoing events.