
WYOMING DOCKET INTEL
Head Minister, ROS / MLITR Principal
Official Civil Complaint establishing forum presence and legal standing in the United States District Court for the District of Wyoming.
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF WYOMING
IAIN CLIFFORD, an individual,
MLITR RESEARCH LLC, a Wyoming limited liability company,
OSN FOUNDATION, a Panama Private Interest Foundation,
Plaintiffs,
DANIEL MARC NEIDLE, an individual, and
TAX POLICY ASSOCIATES LTD, a UK company,
Defendants.
Case No. [To be assigned by Clerk]
COMPLAINT FOR DEFAMATION, FALSE LIGHT, TORTIOUS INTERFERENCE, INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS, AND NEGLIGENT MISREPRESENTATION JURY TRIAL DEMANDED
This Court has subject matter jurisdiction under 28 U.S.C. § 1332(a)(2). Plaintiffs and Defendants are citizens of different states (or, in the case of foreign defendants, of a foreign state). Plaintiff MLITR Research LLC is a Wyoming limited liability company. Defendant Daniel Marc Neidle is a citizen of the United Kingdom. Defendant Tax Policy Associates Ltd is a company registered in England and Wales. The amount in controversy exceeds $75,000, exclusive of interest and costs.
This Court has personal jurisdiction over the Defendants under the “effects test” of Calder v. Jones, 465 U.S. 783 (1984). The Defendants’ intentional tortious acts were expressly aimed at Wyoming: on March 10, 2026, Defendant Neidle filed a formal complaint with the Wyoming State Bar targeting MLITR Research LLC (Wyoming Filing ID 2025-001789709). The Defendants knew the brunt of the injury would be felt by Wyoming-registered entities.
In the alternative, this Court has personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2), because the Defendants have sufficient contacts with the United States as a whole (targeting Wyoming-registered entities and U.S.-based Foreign Grantor Trusts) but insufficient contacts with any single state to establish jurisdiction in that state’s courts.
Venue is proper in this District under 28 U.S.C. § 1391(b) and (c) because a substantial part of the events giving rise to the claims occurred in this District (the Wyoming State Bar complaint, the registration of MLITR Research LLC, and the operation of the trust infrastructure).
Plaintiff Iain Clifford is an individual residing in the United Kingdom. He is the Head Minister of the Republic of Old Souls (ROS) ministry, the Principal of MLITR Research LLC TA Ecclesia Law, and the architect of the Clifford Protocol. He has over 40 years of professional experience as a financial architect and CEO of regulated financial services companies.
Plaintiff MLITR Research LLC is a Wyoming limited liability company (Filing ID 2025- 001789709) with its principal address at 30 N Gould St Ste R, Sheridan, WY 82801. It operates under the trading names Ecclesia Law, Ecclesia Trustees, and Ecclesia Finance.
Plaintiff OSN Foundation is a Panama Private Interest Foundation (Folio 25058280) established under Law 25 of 1995. It serves as the national fiduciary for the ROS membership and is entitled to a 20% national membership tithe.
Defendant Daniel Marc Neidle is an individual residing in the United Kingdom. He is the founder and operator of Tax Policy Associates and publishes articles on taxpolicy.org.uk. 16. Defendant Tax Policy Associates Ltd is a company registered in England and Wales. It operates the taxpolicy.org.uk website.
Plaintiff Clifford is subject to a UK Crown Court order (Order 34/2023) imposing a 12-month sentence for contempt of court. This order is under active appeal in the UK Court of Appeal (Criminal Division) (Case Refs: 202504306 B3 / 202504307 B3). The Perfected Skeleton Argument (7 July 2026) advances five grounds of appeal.
Plaintiff Clifford is not a fugitive under U.S. law. Under United States v. Bescond, 4 F.4th 63 (2d Cir. 2021), a foreign national who remains in their home country and declines to enter the United States is not a fugitive.
The UK order is a non-self-executing foreign penal judgment that holds no legal force in the United States absent formal domestication under 28 U.S.C. § 2467. See United States v. Tammy Fu, 752 F.3d 188 (2d Cir. 2014).
The Fugitive Disentitlement Doctrine is inapplicable to this private civil action. See Degen v. United States, 517 U.S. 820 (1996).
The Clifford Protocol is a fiduciary commercial reconciliation methodology that operates strictly within the IRS’s own administrative framework. It does not fabricate tax claims, manufacture withholding balances, or extract funds from the Treasury. It corrects a specific, documented nominee reporting failure that occurs when systemic investment banks pool signature-originated credit instruments into CUSIP-assigned securitisation tranches but fail to file the corrective Form 1099-OID required by IRS Publication 1212 to identify the true beneficial owner.
The factual basis — Ex nihilo credit creation. The protocol is grounded in empirical economics confirmed by the Bank of England Quarterly Bulletin (Q1 2014) and the peer-reviewed research of Professor Richard Werner (2014). These authoritative sources confirm that commercial banks do not lend pre-existing deposits. Instead, they create credit ex nihilo (out of nothing) at the exact moment a borrower signs a promissory note, mortgage agreement, or loan contract. The biological signature of the borrower is the originating force of the credit. The bank records the signed instrument as a bank asset and credits the borrower’s account with a newly created deposit liability — the Werner equation for credit creation: $\Delta \text{Bank Assets} = \Delta \text{Bank
Liabilities}$. This is not a theory; it is the Bank of England’s own published description of how the modern monetary system operates.
The factual basis — The nominee reporting failure. Under Section 3 of the UK Bills of Exchange Act 1882 and UCC § 3-104, the signed promissory note is a negotiable instrument. Under Section 20 of the 1882 Act (and UCC § 3-115), the signature was delivered in an inchoate state, granting the bank prima facie authority to “fill it up” — assigning CUSIP numbers, pooling it into tranches, and securitizing it on the secondary market. However, under IRS Publication 1212, when a financial institution holds an OID debt instrument as a nominee for the true beneficial owner (as occurs when instruments are held in omnibus accounts under street names such as Cede & Co.), it is statutorily required to file a corrective Form 1099-OID to report the OID income and withheld tax to the true owner. Systemic investment banks routinely fail to file these corrective forms, instead reporting the OID income under their own corporate tax ledgers and treating the credit as “abandoned property.” The Clifford Protocol corrects this nominee misreporting — it does not fabricate claims.
The factual basis — The OID calculation. Under IRC § 1273, Original Issue Discount is defined as the excess of a debt instrument’s stated redemption price at maturity over its initial issue price. Because credit is created ex nihilo at the moment of signing — meaning no cash consideration was advanced by the bank — the initial issue price is mathematically established as zero ($0.00). The OID formula is: $\text{OID} = \text{Stated Redemption Price at Maturity} – \text{Initial Issue Price} = \text{FV} – \$0 = \text{FV}$ (where $\text{FV}$ is the entire face value of the instrument). This is a straightforward mathematical application of the statute as written.
The factual basis — The 98-series Foreign Grantor Trust architecture. The protocol operates exclusively through 98-series Foreign Grantor Trusts assigned EINs by the IRS Cincinnati International Unit under IRC § 6048. These trusts must intentionally fail both the “court test” and the “control test” under 26 CFR § 301.7701-7 to qualify as non-domestic fiduciary entities. The trust establishes Holder in Due Course (HDC) standing under UCC § 3-203(b) and § 3-302(a) — taking the instrument for value (the credit energy originated by the living person), in good faith, and without notice of defect. This standing is formalized via IRS Form 56 under IRC § 6903. The corrective 1099-OID is filed by the HDC correcting a nominee reporting error — not by a debtor attempting to discharge their own debt. The IRS’s own systems accepted over $600 million in these filings, generating official Wages and Tax Transcripts and 26-digit IRMF Document Locator Numbers.
The factual basis — The Form 945 module linkage. The 1099-OID identifies the nominee bank (under its corporate EIN and CUSIP) as the payer, creating a direct link to the bank’s Form 945 nonpayroll withholding module (MFT 16). Form 945 is the IRS-designated repository for backup withholding on OID income. The banks have already physically remitted these taxes to the U.S. Treasury — verified examples include JPMorgan Chase ($13,510,000), HSBC Bank USA ($72,143,158), NatWest Markets ($55,667,083), Barclays Capital ($18,596,522), and Deutsche Bank Trust Company Americas ($1,210,000). The protocol redirects these pre-existing, already remitted credits to the true owner. It does not invent tax liabilities; it corrects nominee reporting defaults under the IRS’s own Publication 1212 framework.
The factual basis — The cross-modular transfer under Revenue Procedure 2002-26. Because banks systematically underfund their Form 945 withholding modules while paying multi-billion dollar surpluses into their Form 1120 corporate income tax modules, the fiduciary invokes the
taxpayer’s absolute right of designation under Revenue Procedure 2002-26 (2002-1 C.B. 746). Section 3.01 of this procedure states that if a taxpayer provides specific written directions, the IRS must apply voluntary payments accordingly. The fiduciary directs the IRS to reallocate overpayment credits from the bank’s Form 1120 module to its Form 945 module — a zero-sum administrative reallocation of credits already held by the Treasury that imposes no additional cost on the payer banks.
The factual basis — Categorical distinction from criminal schemes. The protocol is categorically distinct from the schemes of convicted promoters such as Franzie Colaco (9-year sentence) and Ronald Brekke (12-year sentence), who operated via SSN-based retail filings that triggered automated TC 810/RC-4 frivolous-filer freezes. Every criminal conviction Neidle can cite — Colaco, Brekke, Cyster, Sookdeo — involved individuals filing under their personal SSN or ITIN, placing themselves in a “retail debtor” capacity. The Clifford Protocol operates exclusively through 98-series Foreign Grantor Trust EINs filed by a licensed Electronic Return Originator (ERO) using IRS-approved professional software (TaxAct Professional) that has completed IRS Assurance Testing System (ATS) parsing requirements. No federal court has ever adjudicated — let alone rejected — a 98-series FGT operating as HDC and filing corrective 1099-OID forms under Publication 1212.
The factual basis — Corroboration by independent deep research verification. The technical framework underlying the Clifford Protocol has been subjected to exhaustive verification through independent agentic deep research, including: (i) “Ex Nihilo Credit Monetization, Nominee Withholding Mechanics, and Cross-Modular Fiduciary Reconciliation,” which verified the nominee reporting failure under IRS Publication 1212 and the cross-modular transfer mechanics under Revenue Procedure 2002-26; (ii) “Foreign Grantor Trust 1099-OID vs Retail Filings,” which established the categorical distinction between the 98-series FGT fiduciary creditor architecture and the SSN-based retail debtor filings that led to the criminal convictions of Colaco, Brekke, Cyster, and Sookdeo; (iii) “Deep Research Verification of the Form 945 Tax Module,” which confirmed the verified 2025 Form 945 actual payments of JPMorgan Chase ($13,510,000), HSBC ($72,143,158), NatWest ($55,667,083), Barclays ($18,596,522), and Deutsche Bank ($1,210,000), proving that these banks have already physically remitted backup withholding taxes to the U.S. Treasury for OID income generated by signature-originated credit; (iv) “Investment Bank Form 945 Tax Modules, Holder in Due Course Claims, and the Mechanics of Signature Credit Tax Redirection,” which mapped the CUSIP-to-module linkage that connects the nominee bank’s securitization pools to its Form 945 withholding ledger; and (v) “Investment Bank Hypothecation of Ex Nihilo Signature Credit Securitization,” which documented the DTCC/Cede & Co. street name architecture, Rule 15c3-3 rehypothecation limits, and the systematic underfunding of Form 945 modules relative to the “Full Forensic 945 Liability” calculated under the 24% backup withholding heuristic. These research documents demonstrate that the protocol does not fabricate tax claims — it corrects a documented, systemic nominee reporting failure using the IRS’s own administrative framework.
The Defendants were served with the full technical Treatise and challenged to debunk it. On or about January to May 2025, the Defendants were served with the comprehensive Treatise (“Signature Credit Tax Redirection”) and over 50 additional technical research papers detailing the precise statutory framework, the economic basis, the nominee reporting mechanics, and the mathematical calculations underlying the protocol. The Defendants were formally challenged to
debunk the Treatise and to attend a public debate on its technical merits. The Defendants did neither. Instead, they published the defamatory article “Iain Clifford Stamp’s $600m US tax fraud and its 3,000 victims” on 17 May 2026 — after receiving the Treatise, after being invited to debate, and after being warned of Wyoming litigation. This conduct — receiving a comprehensive technical document, refusing to engage with it, refusing to debate it, and publishing a “fraud” characterisation anyway — satisfies the New York Times v. Sullivan actual malice standard beyond any reasonable dispute.
In 2024, the IRS issued four (4) treasury cheques based on the Clifford Protocol in a pilot scheme. The cheques were cashed by the recipients. The IRS has never initiated proceedings under IRC § 7405 or any other provision to recover these funds.
In 2025, the IRS accepted and processed over $600 million in 1099-OID filings submitted under the Clifford Protocol, generating official Wages and Tax Transcripts via the Transcript Delivery System.
On or about August 2025, Lisa Griffin received $98,000 from the IRS based on the Clifford Protocol — a Pirate Faction member who personally benefited from the protocol before turning against it.
In January 2026, the authorised ERO (WK) provided full disclosure of 3,000 Foreign Grantor Trust filings to the IRS Treasury Inspector General for Tax Administration (TIGTA). TIGTA responded constructively, asking WK to identify any filings not processed by him. WK provided a report identifying the unauthorised filings.
On March 4, 2026, the IRS issued a new ERO licence (EFIN xxxxx) to WK via Letter 5880C — total administrative vindication.
On April 1, 2026, the IRS restored WK’s Centralized Authorization File (CAF xxxxxxxxxx) via Notice CP547 — total administrative vindication.
In July 2026, new Wages and Tax Transcripts were generated following Clifford Protocol 1099- OID filings under WK’s new ERO licence.
Over 1,000 Foreign Grantor Trust EINs have been received with MLITR Research LLC as the trustee. The protocol continues to operate without interruption.
No conviction or charge has ever been brought against WK for filing 4,000 1099-OIDs for Foreign Grantor Trusts.
Between June 2024 and the present, the Defendants published the following defamatory statements:
| Date | Publication | Key Defamatory Statement |
|---|---|---|
| 8 June 2024 | “Matrix Freedom — the scam conspiracy theory” | Labelled Plaintiff as a “fraudster” operating a “scam” |
| 24 June 2024 | TPA Website Update | Called for FCA and police criminal fraud inquiry |
| 15 January 2025 | TPA Website Comments | Labelled OID recoupment operators “legally illiterate” and “anti-tax cults” |
| 30 July 2025 | TPA Website Update | Characterised Plaintiff’s jurisdictional defences as “nonsense” |
| 21 January 2026 | TPA Blog Comment Response | Declared: “The ‘recouping’ is fraud… These people are scammers” |
| 25 February 2026 | “Simon Goldberg and Empower the People” | Identified Plaintiff as “one of the most financially successful sovereign citizens” |
| 17 May 2026 | “Iain Clifford Stamp’s $600m US tax fraud and its 3,000 victims” | Headlined a “$600 million US tax fraud” with “3,000 victims” |
| August 2026 | LinkedIn post on GoldSilver case | Repeated “fugitive” and “sovereign citizen” labels |
| August 2026 | Threads post on GoldSilver case | Called the SDNY case a “scrap” and repeated defamatory characterisations |
The Defendants’ publications remain live on taxpolicy.org.uk, LinkedIn, and Threads as of the date of this Complaint.
The Defendants’ defamatory publications have been ingested by artificial intelligence platforms, including Google Gemini, ChatGPT, Perplexity, and Copilot. These platforms now republish the defamatory characterisations as factual answers to user queries about Plaintiff Clifford, the Clifford Protocol, Ecclesia Law, and MLITR Research.
The AI amplification compounds the reputational damage exponentially because: (a) every search query generates a new defamatory “answer”; (b) AI outputs carry an implicit aura of objectivity; (c) the defamatory content is “baked into” the AI model weights, making it extremely difficult to correct; and (d) AI-generated content is scraped by other platforms, creating a multiplier effect.
On March 10, 2026, Defendant Neidle filed a formal complaint with the Wyoming State Bar targeting MLITR Research LLC. This was a direct, intentional invocation of Wyoming’s regulatory jurisdiction — the clearest possible form of “express aiming” under Calder v. Jones.
Plaintiffs incorporate by reference all preceding paragraphs.
The Defendants published false statements of fact about Plaintiff Clifford, including that he is a “fraudster,” a “scammer,” a “sovereign citizen,” a “fugitive from justice,” and the operator of a “$600 million US tax fraud” with “3,000 victims.”
These statements are demonstrably false, as established by the IRS’s acceptance of $600 million in filings, the issuance of four cheques, the restoration of the ERO credentials, and the absence of any criminal charge.
The statements were published with actual malice — the Defendants knew they were false or acted with reckless disregard for the truth, as established by their receipt of the 50+ research papers, the IRS transcripts, and the debate invitation before publishing.
The statements have caused and continue to cause severe and permanent reputational harm to Plaintiff Clifford, including global humiliation, loss of professional credibility, stigmatisation of the ROS ministry, and the creation of a permanent “digital scarlet letter.”
Plaintiffs seek compensatory damages of $90,000,000 to $225,000,000 for reputational harm (including the AI amplification component).
Plaintiffs incorporate by reference all preceding paragraphs.
The Defendants’ publications placed Plaintiff Clifford in a false light that would be highly offensive to a reasonable person — characterising him as a criminal, a fraudster, and a fugitive when he is none of these things.
The Defendants acted with actual malice or reckless disregard for the truth.
Plaintiffs seek compensatory damages of $5,000,000 to $10,000,000.
Plaintiffs incorporate by reference all preceding paragraphs.
The Defendants’ publications were a substantial factor in causing Amy Jo Sanger and associated trustees to file bogus Form 14039 identity theft reports with the IRS, which froze $600 million in verified tax recoupments and disrupted the contractual relations between MLITR Research LLC, the Foreign Grantor Trusts, and the trust beneficiaries.
The Defendants knew or should have known that their publications would be read by individuals associated with the protocol and would likely cause disruption.
Plaintiffs seek compensatory damages of $35,000,000 to $50,000,000 for delay, disruption, and lost pipeline.
Plaintiffs incorporate by reference all preceding paragraphs.
The Defendants’ conduct — publishing knowingly false statements after receiving irrefutable evidence, refusing to debate, and publishing despite litigation warnings — was extreme and outrageous, beyond all possible bounds of decency.
The Defendants acted intentionally or with reckless disregard for the probability of causing emotional distress.
Plaintiff Clifford has suffered severe emotional distress, including being forced into constructive exile, separation from his family, and global humiliation.
Plaintiffs seek compensatory damages of $5,000,000 to $10,000,000.
Plaintiffs incorporate by reference all preceding paragraphs.
The Defendants made false representations of fact about the Clifford Protocol and Plaintiff Clifford, without reasonable grounds for believing them to be true.
The Defendants owed a duty of care to Plaintiff Clifford and to the readers of their publications to verify the accuracy of their statements before publishing.
The Defendants breached this duty by publishing false statements without investigating the IRS validation evidence that had been served on them.
Plaintiffs suffered damages as a direct result of the Defendants’ negligent misrepresentations.
WHEREFORE, Plaintiffs respectfully request that this Court enter judgment in their favour and against the Defendants, and grant the following relief:
(a) Compensatory damages in the range of $132,000,000 to $288,000,000, including:
(b) Punitive damages in the range of $75,000,000 to $150,000,000 (2x-3x multiplier based on the actual malice evidence);
(c) Injunctive relief:
(e) Such other and further relief as this Court deems just and proper.
Plaintiffs demand a trial by jury on all issues so triable.
Dated: [Date of Filing]
Respectfully submitted,
/s/ Iain Clifford
Iain Clifford, Pro Se Plaintiff
MLITR Research LLC TA Ecclesia Law
30 N Gould St Ste R, Sheridan, WY 82801
Email: service@ecclesialaw.org
| Exhibit | Document |
|---|---|
| Exhibit 1 | Screenshots of Defendants’ defamatory publications (with URLs and dates) |
| Exhibit 2 | The $4,477,610 IRS Transcript (TIN 98-6138781) |
| Exhibit 3 | Summary of $600M in aggregate Wages and Tax Transcripts |
| Exhibit 4 | Sample of the 50+ Ecclesia Law research papers (the Treatise) |
| Exhibit 5 | The debate invitation (and evidence of Defendants’ non-response) |
| Exhibit 6 | Formal notices/warnings of Wyoming litigation (Letter Before Claim; Final Notice) |
| Exhibit 7 | Sanger’s Rule 36 Admissions (SDNY Case 1:25-cv-08704) |
| Exhibit 8 | The Wyoming State Bar complaint filed by Defendant Neidle (March 10, 2026) |
| Exhibit 9 | MLITR Research LLC Articles of Organization (Wyoming Filing ID 2025-001789709) |
| Exhibit 10 | The Master Fiduciary Control Agreement |
| Exhibit 11 | OSN Foundation Charter (Panama, Folio 25058280) |
| Exhibit 12 | UK Court of Appeal Skeleton Argument (7 July 2026) |
| Exhibit 13 | IRS Letter 5880C (EFIN restoration, March 4, 2026) |
| Exhibit 14 | IRS Notice CP547 (CAF restoration, April 1, 2026) |
| Exhibit 15 | Bank of England Q1 2014 Report |
| Exhibit 16 | Proof of the 2024 IRS cheques (4 cheques issued, never reclaimed) |
| Exhibit 17 | New IRS Wages and Tax Transcript (23 July 2026) |
| Exhibit 18 | Screenshots of defamatory Google Gemini AI outputs |
| Exhibit 19 | Screenshots of Defendants’ LinkedIn and Threads posts (August 2026) |
| Exhibit 20 | Proof of delivery for the Letter Before Claim and Final Notice |
Wyoming Filing Posture Notice
Following expiration of the pre-suit demand window in the Letter Before Claim (LBC), the Complaint for Defamation, Tortious Interference, and 10 Related Torts is finalized for docketing in the U.S. District Court for the District of Wyoming seeking $142M–$289M.