Congress Needs to Look West: An Investigation into Judicial Conflicts, Grant Fraud, Visa Fraud, and Whistleblower Suppression in America's Forgotten Pacific Territory
- CNMIGA .ORG
- 5 days ago
- 20 min read
Updated: 3 hours ago
AN OPEN LETTER
TO: U.S. ATTORNEY GENERAL TODD BLANCHE
THE DOJ ANTI-FRAUD TASK FORCE
AAG BRETT SHUMATE & AAG COLIN McDONALD
AND THE UNITED STATES SENATE JUDICIARY COMMITTEE
(CHAIRMAN TED CRUZ; CHAIRWOMAN MARSHA BLACKBURN,
SUBCOMMITTEE ON FEDERAL COURTS, OVERSIGHT, AGENCY ACTION & FEDERAL RIGHTS)
***RE: Judicial Corruption, Constitutional Deprivations, Federal Fund Fraud, Wire Fraud,
Whistleblower Retaliation, and a Concentration of Power in the Pacific That Would
Make a Mafia Blush — With Documentation, Citations, and Appropriate Disbelief
I. GREETINGS FROM THE MIDDLE OF THE PACIFIC — WE NEED TO TALK
Dear Attorney General Blanche, AAGs Shumate and McDonald, Chairman Cruz, Chairwoman Blackburn, and any congressional staffer who drew the short straw of reading Pacific territorial correspondence this week:
My name is Zaji Obatala Zajradhara.
I am a United States citizen.
I hold FEMA emergency management certifications, Red Cross Disaster Cycle Services credentials, NWCG firefighting qualifications, and the kind of stubborn faith in the U.S. Constitution that comes from years of watching it ignored at close range. I am the Program Director of the CNMI Growers Association, a SAM-registered nonprofit (UEI #PAV6D5R5MEH3) on the island of Saipan in the Commonwealth of the Northern Mariana Islands — an American territory in the Western Pacific that most people in Washington cannot locate on a map, and whose federal judicial system, this letter will demonstrate, they have not been paying nearly enough attention to.
I have filed complaints with the FBI. With the SBA Inspector General. With the Department of Education Inspector General. With the EEOC. With the Office of the Director of National Intelligence. With the U.S. Attorney. I have transmitted a 32-gigabyte USB evidence archive to fourteen senior federal officials. I have appeared pro se in multiple federal courts, drafted motions citing Ninth Circuit precedent, survived a government-obtained preliminary injunction, continued growing vegetables through all of it, and am now writing this letter — because every door I have knocked on in the CNMI has been answered by someone related to the person I am complaining about.
That is not a colorful metaphor. It is the central fact of this letter. Let me explain.
II. A BRIEF AND ONLY SLIGHTLY ALARMING INTRODUCTION TO THE CNMI
The Commonwealth of the Northern Mariana Islands is a United States territory. Its residents are U.S. citizens. The Constitution applies here. These facts are not controversial — they are merely, in the undersigned's experience, routinely forgotten by everyone in a position to enforce them. The CNMI became a U.S. Commonwealth in 1978 under the Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America, 48 U.S.C. §§ 1801 et seq. The territory has roughly 50,000 residents, a territorial legislature, a governor, a territorial supreme court, and exactly one federal district court judge.
That last detail is important. In the continental United States, if the presiding judge in your federal civil rights case appears to have a conflict of interest, you file a recusal motion and eventually a different judge considers the matter. In the CNMI, there is one federal district court judge. Her name is Chief Judge Ramona Villagomez Manglona. If she has a conflict of interest — which, as this letter will document at considerable length, she structurally does — the Ninth Circuit designates a replacement judge from Guam. That replacement judge is Chief Judge Frances M. Tydingco-Gatewood, who administered Chief Judge Manglona's oath of office.
The reader will notice that the phrase 'conflict of interest' is doing a great deal of work in this paragraph.
The CNMI receives federal funding across dozens of programs.
HUD has allocated $254,324,000 in Disaster Recovery Community Development Block Grant funds (CDBG-DR) to the Northern Marianas Housing Corporation. The CNMI's 2021 single audit — completed years behind schedule — resulted in a disclaimer of opinion for governmental activities and an adverse opinion on component units, including NMHC. To be precise about what this means: the auditors looked at the books covering a quarter-billion dollars in federal funds and formally stated they could not form an opinion about what happened. In the private sector, this is called a crisis.
In the CNMI, the government formed a committee.
III. THE MANGLONA SITUATION, OR: WHEN 'SMALL WORLD' BECOMES A LEGAL DOCTRINE
Here is a fact that the undersigned will now state as plainly as the English language permits, because it deserves to be read without editorial softening:
The sole United States federal district court judge serving the Commonwealth of the Northern Mariana Islands is married to the Associate Justice of the CNMI Supreme Court.
Chief Judge Ramona Villagomez Manglona is the federal judge. Associate Justice John A. Manglona is her husband. He has sat on the CNMI Supreme Court since 2000. Before that, he was a CNMI Superior Court judge. Before that, he operated the Law Office of John A. Manglona, a private practice focused on probate, corporations, tax, and — the undersigned pauses here for emphasis — real property transactions in the CNMI.
Chief Judge Manglona, for her part, worked in her family's real estate management business before law school, served as CNMI Attorney General (the first woman to do so, 2002-2003), and was appointed to the federal bench by President Obama in 2011 and confirmed for a second term in April 2024 by a vote of 96-2.
The undersigned wishes to be clear: this letter does not question Chief Judge Manglona's credentials, her intelligence, or her general commitment to the law.
It questions the architecture.
The architecture is this: every federal civil rights claim, False Claims Act matter, constitutional challenge, and employment discrimination case in the CNMI is adjudicated in a federal court presided over by a judge who goes home every evening to the highest territorial appellate court justice — the same court that issues binding precedent on territorial matters that practitioners in her federal courtroom must cite, and whose members spent their careers representing the same businesses, property owners, and government officials who are now the institutional respondents in the undersigned's federal litigation.
28 U.S.C. § 455(a) requires a federal judge to 'disqualify himself in any proceeding in which his impartiality might reasonably be questioned.'
The standard is objective. It does not require proof of actual bias. It requires only that a reasonable person, knowing all the facts, would question the judge's impartiality.
The undersigned submits that a reasonable person — upon learning that the sole federal judge and the territorial supreme court justice share a home, a history, and a professional network that encompasses virtually every significant CNMI institution — would have questions.
Many questions.
The kind of questions that typically produce a recusal motion, which the undersigned has in fact filed, with the predictable result that the judge reviewed the motion and determined that she was not biased. A system in which the only available arbiter of a judge's impartiality is the judge herself is, in communities this small, a structural problem rather than a judicial solution.
This conflict has historical recognition.
In Commonwealth v. Caja, App. No. 99-011 (N.M.I. 2001), a defendant moved to disqualify then-Superior Court Judge John A. Manglona on the grounds that he was married to then-prosecutor Ramona V. Manglona, who worked in the same Attorney General's office as the prosecuting attorney. The CNMI Supreme Court — the same court on which John Manglona now sits — reviewed and affirmed the denial.
The circle has been closed for twenty-five years.
The question before this Committee and the Department of Justice is whether it will remain closed for another twenty-five.
The undersigned also notes that Justice Manglona serves as a justice pro tempore of the Guam Supreme Court, extending the network's reach to the jurisdiction that supplies the CNMI federal court's 'replacement' judge when Chief Judge Manglona recuses herself.
That replacement is Chief Judge Frances M. Tydingco-Gatewood of the U.S. District Court for Guam — who administered Chief Judge Manglona's oath of office in April 2024 and is, by any reasonable social cartography, an intimate member of the same professional and judicial community.
When the undersigned raised conflict-of-interest concerns before Judge Tydingco-Gatewood in Case No. 1:25-cv-00004, she reviewed the motion and determined that she also was not biased.
The undersigned notes this outcome without surprise and with a weariness that approximately 32 gigabytes of documentation has done nothing to diminish.
The undersigned respectfully requests that the Committee direct a review of the real property holdings, trust interests, and financial relationships of Chief Judge Manglona and Justice Manglona by investigators with no CNMI/Guam jurisdictional ties, pursuant to 28 U.S.C. §§ 351-364 and the Code of Conduct for United States Judges, Canons 2 and 3(C). Given that Justice Manglona's prior private practice specialized in CNMI real property transactions, and that Chief Judge Manglona worked in a family real estate business before law school, and that CNMI Article XII constitutional provisions restricting land ownership to persons of Northern Mariana Islander descent are currently implicated in federal litigation before Chief Judge Manglona's court, these are not idle questions.
They are precisely the disclosures that 28 U.S.C. § 455(b)(4) was written to require.
IV. THE FBI SAIPAN FIELD OFFICE AND THE REMARKABLE PHENOMENON OF SELECTIVE SILENCE
The Federal Bureau of Investigation maintains a field presence on Saipan. The undersigned has availed himself of this resource. He has presented the Saipan Field Office with evidence of visa fraud, federal grant mismanagement, civil rights violations, wire fraud, and whistleblower retaliation. He has done this more than once. He has done it with documentation organized in the manner one would expect from a FEMA-certified grants management professional who has been building an evidentiary record for years.
The response from the FBI Saipan Field Office has been, in the technical language of law enforcement, nothing.
Not a formal declination. Not an acknowledgment of receipt. Not a referral. Nothing. The undersigned sought similarly meaningful investigatory assistance from U.S. Attorney Shawn Anderson, whose office covers both Guam and the CNMI, with an equally impressive result: nothing.
The undersigned does not attribute this inaction to laziness or corruption at the individual level. He attributes it to the same structural reality that pervades every institutional interaction he has described in this letter: on an island of 50,000 people, federal agents go to the same grocery stores, the same churches, and the same community events as the CNMI government officials, attorneys, judges, and business executives whose conduct has been reported.
Investigating one's neighbors is, as a matter of human psychology and institutional culture, more difficult than investigating strangers.
This is not a flaw unique to the CNMI — it is a flaw inherent to placing oversight authority in communities too small to accommodate it. The remedy is not to criticize the local agents. It is to send investigators from somewhere else.
The undersigned respectfully requests that any investigation arising from this submission be conducted by federal agents and prosecutors assigned from continental U.S. field offices, with no prior personal, professional, or familial ties to the CNMI. This is not a preference. It is the only structural arrangement under which a meaningful investigation is possible.
CNMI CORRUPTION DOCS:
V. NORTHERN MARIANAS COLLEGE, THE SBDC, AND THE MOST CREATIVE USE OF A RESTRAINING ORDER IN AMERICAN CONSTITUTIONAL HISTORY
Northern Marianas College is the territory's only public institution of higher education. It hosts the NMC-SBA Small Business Development Center (SBDC), a federally funded program administered under an SBA cooperative agreement and designed to provide technical assistance to small business owners and entrepreneurs. The undersigned is a small business owner and entrepreneur. He sought access to this program, funded in part by his federal tax dollars, beginning in 2019.
NMC denied him access.
He reported the denial to SBA.
He received no meaningful response.
He documented additional incidents of differential treatment, public harassment, and threats of false arrest by program administrators. He reported those as well. He persisted, because persistence in the face of institutional obstruction is not vexatiousness — it is the exercise of constitutional rights. NMC responded by filing a complaint in the CNMI Superior Court alleging harassment and obtaining a preliminary injunction that (a) barred the undersigned from communicating with SBDC employees, and (b) prohibited him from coming within 500 yards of the SBDC or any SBDC event.
Let us pause here to appreciate the constitutional architecture of what just happened.
A public institution receiving federal funds obtained a court order barring a named American citizen from accessing those federal funds — based on allegations that were never fully adjudicated on the merits — in a court whose appellate oversight flows through the territorial supreme court on which the husband of the federal judge sits.
The circle, the undersigned notes, is elegant in a way that should trouble everyone in this distribution list.
Article I, Section 9, Clause 3 of the U.S. Constitution prohibits bills of attainder — legislative or judicial acts that single out a named individual for punishment without a trial on the merits.
The Supreme Court, in United States v. Lovett, 328 U.S. 303 (1946), defined a bill of attainder as an act that 'legislatively determines guilt and inflicts punishment upon an identifiable individual without provision of the protections of a judicial trial.'
The NMC injunction punishes the undersigned — by name — by severing his access to federally funded programs, without a full merits adjudication, on the motion of the institution whose discriminatory conduct the undersigned was reporting. Nixon v. Administrator of General Services, 433 U.S. 425 (1977), and Selective Service System v. Minnesota Public Interest Research Group, 468 U.S. 841 (1984), confirm that targeted punitive exclusion of named individuals from federal program benefits, without trial, is constitutionally void.
The undersigned also flags that NMC-SBDC Network Director Nadine Guerrero shares a surname with NMC President Dr. Galvin Sablan Deleon Guerrero. He raises this not as genealogical curiosity but as a federal compliance matter — anti-nepotism statutes and SBA program rules prohibit the appointment of relatives to positions in federally funded programs. A formal complaint has been filed with the SBA Inspector General (Complaint ID: 20251229nlsf).
The SBA OIG, like the FBI, has not yet taken visible action. The undersigned is beginning to detect a pattern.
VI. THE QUARTER-BILLION-DOLLAR AUDIT DISCLAIMER, OR: WHAT DOES 'ADVERSE OPINION' MEAN AND WHY SHOULD YOU CARE
The Northern Marianas Housing Corporation is the HUD-designated grantee for the CNMI, responsible for administering $254,324,000 in CDBG-Disaster Recovery funds allocated by HUD following Super Typhoon Yutu.
To provide scale: the CNMI's entire annual government budget runs in the range of $300-350 million. NMHC is therefore managing, in its disaster recovery portfolio alone, an amount roughly equivalent to the territory's annual governmental expenditure.
The CNMI's fiscal year 2021 single audit — completed years behind the required deadline — resulted in a disclaimer of opinion for governmental activities and an adverse opinion on the component units, which include NMHC.
For readers unfamiliar with audit terminology: a disclaimer of opinion means the auditors could not gather sufficient appropriate evidence to form any conclusion about the financial statements. An adverse opinion means the financial statements do not fairly present the entity's financial position. NMHC did not provide audited financial statements to be included in the consolidated CNMI audit at all.
To translate: the organization responsible for a quarter-billion dollars in federal disaster recovery funds could not produce financial statements that any auditor was willing to certify. The CNMI government's response was Governor Apatang's Executive Order 2025-003, creating a Single Audit Committee to address the delays.
The undersigned congratulates the Commonwealth on this development and observes that an executive order to ensure that required audits are completed on time is itself evidence that required audits have not been completed on time — which is itself the audit finding.
The logic is circular in a way that the undersigned finds thematically consistent with the rest of this letter.
The undersigned is the plaintiff in federal Case No. 1:25-cv-00004, challenging NMHC's conduct with respect to his civil rights and access to federally funded housing programs.
The case has been presided over by Judge Tydingco-Gatewood following designation, with results consistent with the structural concerns described in Section III.
The undersigned requests that the DOJ Anti-Fraud Task Force open a comprehensive investigation into NMHC's management of HUD CDBG-DR funds, including review of all compliance certifications, subgrant selection processes, and individual disbursement records, pursuant to potential violations of 31 U.S.C. § 3729 (False Claims Act), 18 U.S.C. § 666 (theft from federal programs), 18 U.S.C. §§ 1341 and 1343 (mail and wire fraud), and 18 U.S.C. § 1001 (false statements to federal agencies).
VII. THE ETA-9142C FRAUD SCHEME, OR: AMERICA FIRST (UNLESS YOU ARE ACTUALLY AN AMERICAN AND ACTUALLY APPLYING)
The CW-1 transitional worker visa program requires CNMI employers to file an ETA-9142C attestation with the Department of Labor, certifying — under penalty of law — that they have made good-faith efforts to recruit U.S. workers and that no qualified U.S. workers applied or were available before foreign workers were hired.
The undersigned is a U.S. citizen. He is educated, experienced, certified in emergency management and grants administration, and has lived and worked productively in the CNMI for years. He is, by any reasonable metric, a qualified U.S. worker.
He applied for positions with multiple CNMI employers.
He was rejected.
Those same employers then filed ETA-9142C attestations certifying that no qualified U.S. workers were available.
This pattern — documented application, rejection, attestation of unavailability — recurred across Fortune Pacific Corporation (three consecutive JVA cycles, 2022-2026), Coca-Cola Beverage Co. Micronesia, Tan Holdings, Hong Ye Trading, and MANY OTHER FOREIGN OPERATED COMPANIES IN THE CNMI.
The legal framework is not ambiguous.
8 U.S.C. § 1324b prohibits citizenship status discrimination in hiring. INA § 274B protects U.S. citizens in CW-1/H-2 hiring contexts. Title VII prohibits employment discrimination on the basis of race, color, and national origin. 18 U.S.C. § 1546 criminalizes false immigration documents — including ETA-9142C attestations that falsely certify U.S. worker unavailability when qualified U.S. workers applied and were turned away. 18 U.S.C. § 1343 covers electronic transmission of those false attestations to the DOL's online processing system.
The employers' counsels', in OCAHO proceedings, have characterized the undersigned's litigation as harassment and invoked Molski v. Evergreen Dynasty Corp., 500 F.3d 1047 (9th Cir. 2007), arguing vexatious litigant status.
The undersigned finds this characterization both factually challenged and philosophically noteworthy: apparently, in the CNMI, a U.S. citizen who persistently argues that employers should not be permitted to lie to the federal government about the availability of American workers is the problem.
The undersigned accepts the label of 'persistent' and respectfully declines the label of 'vexatious,' on the grounds that his claims are grounded in public federal records — the applications, the rejections, the attestations — that do not become less true when cited repeatedly.
The undersigned requests that the DOJ Anti-Fraud Task Force obtain and review all ETA-9142C filings by the employers named herein for 2015 to present, cross-referenced against documented applications by U.S. workers, and that CNMI DOL contacts Manases Iguel and Leila Staffler be interviewed regarding their institutional knowledge of and involvement in the attestation processing pipeline. This investigation should be assigned to agents based in a continental U.S. field office.
VIII. THE UNDERSIGNED'S ACTIVE FEDERAL DOCKET — A BRIEF STATUS REPORT
The undersigned is simultaneously maintaining the following federal matters, not because he has an abundance of free time or a law firm covering his filing fees, but because the misconduct described in this letter spans multiple legal theories and multiple institutions, each requiring its own forum:
• Case No. 1:22-cv-00014 (Zajradhara v. David DLG Atalig et al., USDC NMI) — Employment discrimination and civil rights claims; Screening Order issued June 17, 2026; Notice of Appeal to the Ninth Circuit due July 17, 2026. This deadline is 25 days from the date of this letter.
The Committee is asked to note it.
• Case No. 1:25-cv-00010 (Zajradhara v. Global Resources Solutions, Inc., USDC NMI) — Motion for venue transfer to District of Hawaii or Central District of California on judicial conflict-of-interest grounds; Motion for Addendum prepared applying the Eng v. Cooley five-step framework, with verified citations to Bernard v. Coyne, SeaRiver Maritime, and a corrected Soranno's Gasco pin cite. The undersigned notes that preparing this motion without a Westlaw subscription, a law clerk, or a paralegal in a territory with limited legal library resources is its own form of civic service.
• Case No. 1:25-cv-00004 (Zajradhara v. NMHC, USDC NMI / Judge Tydingco-Gatewood) — Fair Housing Act violations, civil rights deprivations, and discriminatory administration of $254 million in federally funded housing programs. Active.
• OCAHO Proceedings — INA antidiscrimination claims against Pure Water Corp., Blossom Corporation, Ranni's Corporation, Jin Joo Corporation, and Manbin Corporation regarding CW-1 hiring practices.
• EEOC Pre-Charge Inquiry — Fortune Pacific Corporation, covering three JVA cycles (2022-2026); filing deadline approximately April 14, 2027.
IX. THE FULL LEGAL FRAMEWORK — A COMPENDIUM OF STATUTES THE CNMI HAS NOT MET
Judicial Conduct and Recusal
• 28 U.S.C. § 455(a) — Mandatory disqualification where impartiality might reasonably be questioned (objective standard; no actual bias required)
• 28 U.S.C. § 455(b)(2) — Disqualification where spouse has professional ties to the matter or parties
• 28 U.S.C. § 455(b)(4) — Disqualification where judge or spouse has financial interest in the subject matter
• 28 U.S.C. §§ 351-364 — Judicial Conduct and Disability Act
• Code of Conduct for United States Judges, Canons 2 and 3(C)
• Commonwealth v. Caja, App. No. 99-011 (N.M.I. 2001) — Historical precedent: Manglona conflict-of-interest issue raised and documented in CNMI courts since 2001
Constitutional Violations
• 42 U.S.C. § 1983 — Civil rights violations under color of law; Monroe v. Pape, 365 U.S. 167 (1961); Adickes v. S.H. Kress & Co., 398 U.S. 144 (1970)
• 42 U.S.C. § 1985 — Conspiracy to interfere with civil rights
• U.S. Const. Amend. I — First Amendment retaliation; Hartman v. Moore, 547 U.S. 250 (2006); Crawford-El v. Britton, 523 U.S. 574 (1998)
• U.S. Const. Art. I, § 9, cl. 3 — Bill of Attainder Clause; United States v. Lovett, 328 U.S. 303 (1946); Nixon v. Administrator of General Services, 433 U.S. 425 (1977)
Federal Criminal Statutes
• 18 U.S.C. § 1343 — Wire fraud (electronic ETA-9142C false attestations to DOL)
• 18 U.S.C. § 1341 — Mail fraud (false federal grant certifications)
• 18 U.S.C. § 1001 — False statements to federal agencies (HUD, SBA, GSA, DOL)
• 18 U.S.C. § 1546 — Visa fraud (false ETA-9142C immigration documents)
• 18 U.S.C. § 666 — Theft from programs receiving federal funds (NMHC, NMC, CNMI DOL)
• 18 U.S.C. § 1512 — Witness/informant tampering (retaliatory injunctions against whistleblower)
• 18 U.S.C. § 1519 — Destruction of records in federal investigations
• 18 U.S.C. §§ 1961-1968 — RICO; H.J. Inc. v. Northwestern Bell, 492 U.S. 229 (1989); Sedima S.P.R.L. v. Imrex Co., 473 U.S. 479 (1985)
Civil Federal Statutes
• 31 U.S.C. § 3729 — False Claims Act (qui tam; NMC ARPA/CSLFRF and NMHC HUD certifications)
• 5 U.S.C. §§ 1201 et seq., 2302(b)(8) — Whistleblower Protection Act; denial of whistleblower recognition by CNMI courts and federal judges is itself a statutory violation
• 8 U.S.C. § 1324b — IRCA antidiscrimination in H-2 hiring
• 42 U.S.C. §§ 2000e et seq. — Title VII; 29 U.S.C. § 621 — ADEA
• 42 U.S.C. § 3604 — Fair Housing Act (NMHC)
• Title VI, Civil Rights Act of 1964 — Discriminatory denial of federally funded program access (NMC-SBDC, NMHC)
• 2 C.F.R. Part 200 — Uniform Guidance noncompliance (NMHC, NMC grant programs)
X. WHAT THE UNDERSIGNED IS ASKING FOR (SPECIFIC, FINITE, AND LEGALLY GROUNDED)
From the Senate Judiciary Committee:
• Convene oversight hearings — in Washington, D.C., not the CNMI — on the structural conflict of interest created by the simultaneous service of Chief Judge Ramona V. Manglona and Associate Justice John A. Manglona, and on whether 28 U.S.C. § 455 adequately addresses structural conflicts in Article IV territorial courts serving communities of 50,000 people.
• Direct the Subcommittee to review all federal court orders in CNMI matters involving NMC, NMHC, the CNMI DOL, and associated respondents, for patterns of systematic gatekeeping of civil rights claims.
• Request a comprehensive financial disclosure investigation of Chief Judge Manglona and Justice Manglona, including real property holdings, trust interests, and financial ties to CNMI governmental entities and federal grantees, conducted by investigators with no CNMI/Guam ties.
• Refer judicial conduct concerns to the Ninth Circuit Judicial Council and the U.S. Judicial Conference under 28 U.S.C. § 351, requesting a Special Committee of out-of-circuit judges for review.
• Direct formally that all investigations arising from this submission be conducted by personnel operating outside the CNMI/Guam jurisdiction.
From the Attorney General and Anti-Fraud Task Force:
• Open a federal criminal investigation into the ETA-9142C fraud scheme, assigned to continental U.S. DOJ attorneys and FBI agents, covering all named employers for the period 2019 to present.
• Open a False Claims Act investigation into NMHC's management of $254,324,000 in HUD CDBG-DR funds, including comprehensive review of all compliance certifications, subgrant selection, and disbursement records.
• Open a False Claims Act investigation into NMC's ARPA/CSLFRF fund handling under Dr. Galvin Sablan Deleon Guerrero, including nepotism compliance review regarding Nadine Guerrero's appointment as NMC-SBDC Network Director.
• Formally recognize the undersigned's federal whistleblower status in writing and transmit that recognition to the relevant CNMI institutions and the CNMI federal court.
• Assign a civil rights attorney and False Claims Act coordinator from a continental U.S. field office to assist the undersigned in developing viable qui tam claims.
• Evaluate the undersigned's full evidence record for potential RICO prosecution given the multi-actor, multi-year, multi-statute pattern documented herein.
XI. IN CLOSING: THE PACIFIC IS AMERICAN TERRITORY AND THE CONSTITUTION APPLIES HERE TOO
The undersigned has been called persistent.
He has been called a vexatious litigant.
He has been told, implicitly and explicitly, that the appropriate response to judicial conflicts of interest, federal grant fraud, visa fraud, and whistleblower retaliation in a small Pacific territory is to let it go and find a different island. He has considered this advice and declined it, on the grounds that the U.S. Constitution does not contain a geographic carve-out for American territories located west of Hawaii.
The First Amendment applies in the CNMI. The False Claims Act applies in the CNMI. The wire fraud statute reaches every electronic transmission from this island. 28 U.S.C. § 455 requires recusal in the CNMI exactly as it does in the Southern District of New York. The Whistleblower Protection Act does not suspend its protections because the territory is inconveniently located in the Western Pacific.
These are not controversial propositions.
They are the law.
The undersigned is not asking for preferential treatment. He is asking for the ordinary operations of federal law — the kind that Americans in every other jurisdiction take for granted. Investigators who are not embedded in the community they are investigating.
A judicial forum that does not require one spouse to adjudicate matters in which the other spouse has institutional history.
Federal grant oversight that reaches territories.
Civil rights enforcement that responds to documented discrimination.
A government that hears its whistleblowers.
He submits 32 gigabytes of documentation in support of these modest requests, addresses this letter to the highest law enforcement officer in the United States and to the body charged with oversight of the federal judiciary, and reminds both that the Pacific Ocean, while vast, is within the jurisdiction of the United States Constitution.
The undersigned remains available for testimony, document production, and any follow-up questions.
He asks only that someone in Washington read this letter with the same seriousness with which it was written.
APPENDIX: SIMULTANEOUS DISTRIBUTION
This open letter is simultaneously transmitted to the following federal officials, because the undersigned's experience has taught him that transmitting a complaint to a single CNMI-adjacent federal agency is roughly equivalent to dropping a message in a bottle off the Saipan reef — scenic, but not productive:
• The Honorable Ted Cruz, Chairman, Senate Committee on the Judiciary
• The Honorable Marsha Blackburn, Chair, Subcommittee on Federal Courts, Oversight, Agency Action, and Federal Rights
• The Honorable Todd Blanche, Attorney General of the United States
• AAG Brett Shumate, Department of Justice
• AAG Colin McDonald, DOJ Anti-Fraud Task Force
• The Honorable Kash Patel, Director, Federal Bureau of Investigation — with the respectful request that continental U.S. personnel review the Saipan Field Office's handling of the undersigned's prior submissions
• Inspector General, U.S. Department of Housing and Urban Development — re: NMHC CDBG-DR fund oversight
• Inspector General, U.S. Small Business Administration — re: Complaint ID 20251229nlsf
• Inspector General, U.S. Department of Education — re: NMC ARPA/CSLFRF funds and WSCUC accreditation
• Inspector General, U.S. Department of Labor — re: ETA-9142C fraud scheme
• U.S. Senate Committee on Energy and Natural Resources — re: Prior submission rebutting Governor Apatang's June 17, 2026 testimony
• U.S. Judicial Conference, Committee on Judicial Conduct and Disability
• Ninth Circuit Judicial Council, Circuit Executive — re: Designation of out-of-circuit judges for CNMI matters
• Office of the Director of National Intelligence — consistent with prior whistleblower disclosures
• Treasury Inspector General — re: ARPA/CSLFRF oversight at NMC
• Office of Personnel Management — re: Anti-nepotism compliance in CNMI federal grant programs
END OF OPEN LETTER
About the Author
Zaji “Persona Non Grata” Zajradhara is a staunch advocate for American workers and indigenous rights in the CNMI. Labeled a “persona non grata” by the CNMI government for his relentless pursuit of justice and his outspoken criticism of corruption and foreign influence, Zajradhara has become a symbol of resistance against the forces seeking to undermine American sovereignty in the islands.
As An Unemployed Afro-American resident and father, Zajradhara's firsthand experience with the CNMI’s dysfunctional labor market, its rigged political system, and the exploitation of vulnerable communities has fueled his activism. He has filed numerous legal claims against companies, including Tan Holdings, for violating labor laws and discriminating against American workers.
His unwavering commitment to exposing the truth, challenging the status quo, and demanding accountability has made him a thorn in the side of the CNMI establishment and a target of their efforts to silence him. However, Zajradhara remains undeterred, determined to fight for the rights of American workers and to protect the CNMI from the grip of foreign influence.
NOTHING HAS CHANGED IN 33 YEARS~!!!
Comments