Paul deParrie
539 SE 39th, PMB 711
Portland, OR 97214
(503) 236-0883
Plaintiff pro se


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IN THE DISTRICT COURT OF THE UNITED STATES


DISTRICT OF OREGON


PAUL dePARRIE,

Plaintiff,

v.

JUDE HANZO, individually and in her

capacity as Director of Portland Feminist

Women's Health Center; KATHERINE

McDOWELL; PORTLAND FEMINIST

WOMEN'S HEALTH CENTER, Inc.; and

STOEL RIVES LLP,

Defendants.

___________________________ ____


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Civil No. CV 99-987 JE

COMPLAINT



Conspiracy to Deprive

Rights; Deprivation of Civil

Wrongful Civil Proceedings

Defamation of Character;

Negligence



Jury Trial Demanded

Plaintiff alleges as follows:

JURISDICTION AND VENUE
  1. Plaintiff brings this action to redress a conspiracy to deprive and actual deprivation of rights secured by the First and Fourteenth Amendments to the U.S. Constitution and Article I, sections 8, 20, and 26 of the Oregon Constitution as well as 42 USC sections 1983, 1985(3), 1986 and 1988; wrongful civil proceedings (malicious prosecution); defamation of character (slander per se); and negligence.

  2. The acts described occurred in the Judicial District of Oregon.

  3. The parties named reside in or acted within the Judicial District of Oregon.

  4. The matter of controversy exceeds the sum of $100,000, exclusive of interest and costs.

  5. This Court has jurisdiction pursuant to 28 USC § 1331.

  6. Plaintiff also invokes supplemental jurisdiction over state and common law claims pursuant to 28 USC § 1391.

  7. Claims are filed within state and federal statutes of limitations. Because the claims were being adjudicated in the Oregon Court of Appeals, time did not begin to run on statutes of limitations until the appellate court judgment in Hanzo v. deParrie, 152 OrApp 525, rev. den. ____ Or ____ (April 6, 1999). On April 6, 1999, the Oregon Supreme Court denied Hanzo's petition for review. Exhibit A to this complaint is a true and correct copy of that opinion.

  8. 8. Venue is proper in this District pursuant to 28 USC § 1391.

    PARTIES

  9. Plaintiff Paul deParrie is an individual person, a citizen of the United States, and a resident of the Judicial District of Oregon.

  10. Plaintiff is a nationally-known and effective anti-abortion activist.

  11. Plaintiff is the editor-in-chief of an international, anti-abortion

    magazine.

  12. Plaintiff is a reporter and photographer for an international, anti-abortion magazine.

  13. Plaintiff is a nationally-known book and commentary writer and social critic.

  14. Plaintiff is a nationally-known and effective critic of abortion.

  15. Defendant Jude Hanzo ("Hanzo") is an individual person and, at all times material, was Director of Feminist Women's Health Center, Inc. ("PFWHC"), and, at all times material, was a resident of the Judicial District of Oregon.

  16. Defendant Katherine McDowell ("McDowell") is an individual person, an active member of the Oregon State Bar, an officer of the court, and at all times material, acted within the Judicial District of Oregon. Defendant McDowell represented Defendant Hanzo against Plaintiff in Hanzo v. deParrie, supra, both at trial and on appeal (see Exhibit A).

  17. Defendant McDowell was at all times material a partner in the firm, Stoel Rives LLP ("Stoel Rives").

  18. 18. Defendant McDowell was, at all times material, a board member of the American Civil Liberties Union of Oregon ("ACLU/O").

  19. 19. Defendant Portland Feminist Women's Health Center, Inc., at all times material, was a corporation not-for-profit in the State of Oregon.

  20. 20. Defendant Stoel Rives LLP was, at all times material, a law firm in the District of Oregon, with offices in Oregon, Washington, Idaho, Utah, and Vancouver, Washington, D.C.

  21. 21. Defendant Stoel Rives, at all times material, supervised and ratified the work of Defendant McDowell.

    GENERAL ALLEGATIONS

  22. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell are part of a nation-wide conspiracy to silence active and effective opposition abortion.

  23. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell are part of a nation-wide conspiracy to silence active and effective opposition to abortion through the use of frivolous civil and criminal accusations against anti-abortion activists.

  24. Other non-party conspirators in the nation-wide conspiracy include but are not limited to Planned Parenthood Federation of Americas and its affilliates, American Civil Liberties Union and its affilliates, National Organization for Women and its affilliates, National Abortion and Reproductive Rights League and its affiliates, Feminist Majority Foundation, and National Abortion Federation.

  25. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell did egregiously conspire together and act in furtherance of a conspiracy to deprive Plaintiff of his civil rights in violation of 42 USC § 1985(3) of the Ku Klux Klan Act. Exhibit B to this complaint is a true and correct copy of 42 USC § 1985(3)

  26. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell, by their egregious actions, did abuse the statutes and civil process of law to deprive Plaintiff of his civil rights under color of ORS 30.866 and ORS 163.730, Stalking, in violation of 42 USC § 1983 of the Ku Klux Klan Act. Exhibit C is a true and correct copy of ORS 30.866. Exhibit D to this complaint is a true and correct copy of ORS 163.730. Exhibit E to this complaint is a true and correct copy of 42 USC § 1983.

  27. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell obtained significant assistance from the State of Oregon and its organs in depriving Plaintiff of his rights.

  28. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell by their inaction and negligence, failed to or refused to prevent or aid in preventing the conspiracy and acts in furtherance of the conspiracy against the civil right of Plaintiff in violation of 42 USC § 1986 of the Ku Klux Klan Act. Exhibit F to this complaint is a true and correct copy of 42 USC § 1986.

  29. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell, by their egregious actions, did bring public scorn and defamation upon Plaintiff.

  30. Defendants McDowell, as an officer of the court, did perpetrate a crime or fraud against Plaintiff in her representation(s) in Hanzo v. deParrie.

  31. Defendant Stoel Rives supervised and/or ratified the activities of Defendant McDowell related to Hanzo v. deParrie and knew or should have known that the stalking complaint lacked merit.

  32. Defendant Stoel Rives provided attorneys, clerks, secretaries, assistants, support staff, office space, telephone lines, printing, postage, and other materials related to Hanzo v. deParrie.

  33. Defendants were aided in their conspiracyto deprive Plaintiff of his civil rights by the ACLU/O.

  34. The ACLU/O is a pro-abortion organization.

    FIRST CLAIM FOR RELIEF

    (42 USC § 1985: Conspiracy to deprive Plaintiff of the right to free expression)

    Plaintiff realleges paragraphs 1 through 34.

  35. Defendants Stoel Rives, PFWHC, McDowell, and Hanzo knew or should have known that none of the Plaintiff's acts listed in their "stalking" complaint satisfied the requisites for issuance of a stalking order under ORS 30.866 or qualify as "contact" under ORS 163.730. Exhibit G to this complaint is a true and correct copy of the "stalking" complaint filed by Defendants.

  36. Defendants Stoel Rives and PFWHC provided funding, assistance, and personnel in furtherance of the conspiracy to deprive Plaintiff of his right to free expression.

  37. Defendant Stoel Rives provided funding, assistance, and personnel in furtherance of the conspiracy to deprive Plaintiff of his right to free expression.

  38. On or about the following dates, Defendant Hanzo met with Defendant McDowell, and conspired to stop Plaintiff's lawful, peaceful demonstrations through the use of the state stalking statute, ORS 30.866:

    1. January 24, 1996
    2. January 25, 1996
    3. January 29, 1996
    4. February 14, 1996
    5. February 15, 1996
    6. February 21, 1996
    7. February 26, 1996
    8. February 27, 1996
    9. February 29, 1996
    10. March 25, 1996

  39. On or about the following dates, Defendant McDowell met or spoke with Hanzo or others and conspired to use the color of statute, namely ORS 30.866, to stop Plaintiff's lawful, peaceful demonstrations:

    1. February 12, 1996
    2. February 13, 1996
    3. February 15, 1996
    4. February 16, 1996
    5. February 21, 1996
    6. February 27, 1996
    7. February 29, 1996
    8. March 5, 1996
    9. March 22, 1996
    10. March 25, 1996

  40. Defendants did conspire and act in furtherance of said conspiracy to directly and indirectly deprive Plaintiff of his right to freedom of expression on the public streets and sidewalks on issues of public concern.

  41. As a direct and proximate cause of Defendants' actions, Plaintiff was barred from lawful, peaceful free expression on certain public streets and sidewalks from May 16, 1996 through June 24, 1999.

  42. As a direct and proximate cause of Defendants' actions, Plaintiff was chilled in his exercise of lawful, peaceful free expression on all public streets and sidewalks from May 16, 1996 through June 24, 1999.

  43. As a direct and proximate cause of Defendants' actions, Plaintiff's right to freedom of expression on public streets and sidewalks was chilled, abridged, and otherwise diminished out of fear that similar actions would be brought against him by Defendants or others.

  44. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his First Claim for Relief.

    SECOND CLAIM FOR RELIEF

    (42 USC § 1985: Conspiracy to deprive Plaintiff of the right to peaceably assemble)

    Plaintiff realleges paragraphs 1 through 44.

  45. Defendants did conspire and act in furtherance of said conspiracy to directly and indirectly deprive Plaintiff of his right to freedom to peaceably assemble on the public streets and sidewalks.

  46. Defendants Stoel Rives and PFWHC provided funding, assistance, and personnel in furtherance of the conspiracy to deprive Plaintiff of his right to peaceable assembly.

  47. As a direct and proximate cause of Defendants' actions, Plaintiff was barred from the freedom to peaceably assemble on certain public streets and sidewalks from May 16, 1996 through June 24, 1999.

  48. As a direct and proximate cause of Defendants' actions, Plaintiff was chilled in his freedom to peaceably assemble on all public streets and sidewalks from May 16, 1996 through June 24, 1999.

  49. As a direct and proximate cause of Defendants' actions, Plaintiff's right to freedom to peaceably assemble on public streets and sidewalks was chilled, abridged, and otherwise diminished out of fear that similar actions would be brought against him by Defendants or others.

  50. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Second Claim for Relief.

    THIRD CLAIM FOR RELIEF

    (42 USC § 1983: Deprivation of Plaintiff's right to freedom of expression under color of state statute)

    Plaintiff realleges paragraphs 1 through 50.

  51. On or about March 26, 1996, Defendants filed a civil complaint for "stalking" under color of ORS 30.866 (Hanzo v. deParrie, Civil No. 9603-02315). (Exhibit G)

  52. On or about March 26, 1996, Defendants caused the State of Oregon by and through the Clerk of its Circuit Court for the State of Oregon, Multnomah County, to issue a Temporary Stalking Protective Order ("TSPO"). Exhibit H to this complaint is a true and correct copy of that TSPO.

  53. On or about March 27, 1996, Defendants caused a sworn officer of the State of Oregon, to wit, a Deputy Sheriff of Multnomah County Oregon, to deliver said TSPO to the home and person of Plaintiff.

  54. On or about March 27, 1996, Defendants caused a sworn officer of the State of Oregon, to wit, a Deputy Sheriff of Multnomah County Oregon, to demand that Plaintiff surrender his State-issued Concealed Handgun Permit, lawfully obtained under ORS 163.291 et seq.

  55. On or about May 16, 1996, Plaintiff was declared a "stalker" after a non-jury, show-cause hearing in the Circuit Court for the State of Oregon, County of Multnomah and the court issued a Permanent Stalking Protective Order ("PSPO"). Exhibit I to this complaint is a true and correct copy of that PSPO.

  56. On or about May 16, 1996, Defendants did cause the State of Oregon to list Plaintiff on the Law Enforcement Data System ("LEDS") computer as a "stalker."

  57. On or about February 18, 1998, the Court of Appeals of the State of Oregon overturned the PSPO in de novo review and Plaintiff prevailed (See Exhibit A).

  58. On or about February 18, 1998, the Court of Appeals of the State of Oregon stated, "We conclude that none of the six alleged contacts satisfied the requisites for issuance of an SPO [PSPO] Under ORS 30.866." (at 547)

  59. On April 6, 1999, the Oregon Supreme Court denied review of the Oregon Court of Appeals decision in Hanzo v. deParrie.

  60. Defendants Stoel Rives and PFWHC provided funding, assistance, and personnel in actions which did deprive Plaintiff of his right to free expression.

  61. As a direct and proximate cause of their actions, Defendants did directly and indirectly deprive Plaintiff of his right to freedom of expression on the public streets and sidewalks on issues of public concern under color of Oregon Revised Statute 30.866.

  62. As a direct and proximate cause of Defendants' actions under color of statute, Plaintiff was barred from lawful, peaceful free expression on certain public streets and sidewalks from May 16, 1996 through June 24, 1999.

  63. As a direct and proximate cause of Defendants' actions under color of statute, Plaintiff was chilled in his exercise of lawful, peaceful free expression on all public streets and sidewalks from May 16, 1996 through June 24, 1999.

  64. As a direct and proximate cause of Defendants' actions under color of statute, Plaintiff's right to freedom of expression on public streets and sidewalks was chilled, abridged, and otherwise diminished out of fear that similar actions would be brought against him by Defendants or others.

  65. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Third Claim for Relief.

    FOURTH CLAIM FOR RELIEF

    (42 USC § 1983: Deprivation of Plaintiff's right to peaceably assemble under color of state statute)

    Plaintiff realleges paragraphs 1 through 65.

  66. Defendants did directly and indirectly deprive Plaintiff of his freedom to peaceably assemble on the public streets and sidewalks under color of Oregon Revised Statute 30.866.

  67. Defendants Stoel Rives and PFWHC provided funding, assistance, and personnel in actions which did deprive Plaintiff of his right to peaceable assembly.

  68. As a direct and proximate cause of Defendants' actions under color of statute, Plaintiff was barred from his freedom to peaceably assemble on certain public streets and sidewalks from May 16, 1996 through June 24, 1999.

  69. As a direct and proximate cause of Defendants' actions under color of statute, Plaintiff was chilled in his freedom to peaceably assemble on all public streets and sidewalks from May 16, 1996 through June 24, 1999.

  70. As a direct and proximate cause of Defendants' actions under color of statute, Plaintiff's freedom to peaceably assemble on public streets and sidewalks was chilled, abridged, and otherwise diminished out of fear that similar actions would be brought against him by Defendants or others.

  71. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Fourth Claim for Relief.

    FIFTH CLAIM FOR RELIEF

    (42 USC § 1986: Failure to prevent or aid in preventing conspiracy and acts of deprivation of Plaintiff's civil rights)

    Plaintiff realleges paragraphs 1 through 71.

  72. Defendants Stoel Rives, PFWHC, McDowell, and Hanzo had an affirmative duty under 42 USC § 1986 to: a. prevent or aid in preventing conspiracies to deprive Plaintiff of his rights under the U.S. Constitution if she had prior knowledge of the conspiracy; and b. prevent or aid in preventing acts that deprive Plaintiff of his rights under the U.S. Constitution if she had prior knowledge of the acts.

  73. Defendants failed to expose, prevent, or otherwise aid in preventing the conspiracy to deprive Plaintiff of his civil rights of which they were a part.

  74. Defendants failed to expose, prevent, or otherwise aid in preventing the acts of deprivation of Plaintiff's civil rights in furtherance of the conspiracy of which they were a part.

  75. As a direct and proximate result of Defendants' failure to expose, prevent, or aid in preventing the conspiracy to deprive Plaintiff of his civil rights, Plaintiff was deprived of his rights to full, lawful freedom of expression and freedom to peaceably assemble from May 16, 1996 through June 24, 1999.

  76. As a direct and proximate result of Defendants' failure to expose, prevent, or aid in preventing the conspiracy to deprive Plaintiff of his civil rights, Plaintiff's rights to freedom of expression and freedom to peaceably assemble were chilled, abridged, and otherwise diminished out of fear that similar actions might be taken by Defendants or others.

  77. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Fifth Claim for Relief.

    SIXTH CLAIM FOR RELIEF

    (Wrongful Civil Proceeding, Malicious Prosecution)

    Plaintiff realleges paragraphs 1 through 77.

  78. Defendants Stoel Rives, PFWHC, McDowell, and Hanzo had an affirmative duty to:

    1. reasonably inquire whether court pleadings they sign or authorize are true;

    2. determine whether court pleadings they authorize or sign are not being presented for an improper purpose;

    3. determine whether court pleadings they authorize or sign are not frivolous;

    4. determine whether court pleadings they authorize or sign are not being presented for harassment; and

    5. determine whether court pleadings they authorize or sign are warranted by existing law.

  79. Defendants did knowingly and wrongfully file and continue to prosecute a civil action against Plaintiff under ORS 30.866 without probable cause to believe that any of the alleged "contacts" would satisfy the requisites of the statute.

  80. Defendants did file a civil action against Plaintiff under ORS 30.866 for an improper purpose, to wit, to deprive Plaintiff of his civil rights.

  81. After seeing that the TSPO designated "lawful pickets" as not a "contact," Defendant McDowell, did not withdraw the allegation that Plaintiff's lawful pickets were "contacts" under ORS 163.730.

  82. As a direct and proximate cause of Defendants' actions, Plaintiff was deprived of his rights to full, lawful freedom of expression and freedom to peaceably assemble from May 16, 1996 through February 18, 1998.

  83. As a direct and proximate result of Defendants' actions, Plaintiff's rights to freedom of expression and freedom to peaceably assemble were chilled, abridged, and otherwise diminished out of fear that similar actions might be taken by Defendants or others.

  84. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Sixth Claim for Relief.

    SEVENTH CLAIM FOR RELIEF

    (Negligence)

    Plaintiff realleges paragraphs 1 through 84.

  85. Defendants Stoel Rives, PFWHC, Hanzo, and McDowell knew or should have known that they lacked any reasonable basis for pursuing the proceeding against Plaintiff.

  86. On or about March 27, 1996, Defendants Hanzo and McDowell did act in furtherance of their conspiracy by obtaining an ex parte TSPO.

  87. The TSPO obtained by Defendants Hanzo and McDowell states, "'Contact' does not include constitutionally protected activity or lawful picketing." (Exhibit H)

  88. Upon seeing the above statement in the TSPO, Defendants McDowell and Hanzo did not withdraw or amend the stalking complaint.

  89. Defendants did neglect to perform their duty under 42 USC § 1986 to prevent or aid in preventing a conspiracy against Plaintiff's civil rights.

  90. Defendant McDowell, an officer of the court, did neglect her duty not to file or prosecute civil actions for improper purposes against Plaintiff.

  91. Defendant Hanzo did neglect her duty not to authorize, sign, or file or civil actions for improper purposes against Plaintiff.

  92. As a direct and proximate result of Defendants' actions, Plaintiff was harmed in his exercise of his civil rights.

  93. As a direct and proximate result of Defendants' actions, Plaintiff was harmed in his ability to effectively pursue his profession.

  94. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Seventh Claim for Relief.

    EIGHTH CLAIM FOR RELIEF

    (Defamation of Character: Slander per se)

    Plaintiff realleges paragraphs 1 through 94.


  95. On or about May 16, 1996, Defendants Hanzo and McDowell obtained a PSPO against Plaintiff.

  96. The PSPO was granted solely on the grounds of two peaceful, nonviolent demonstrations on public streets and sidewalks.

  97. The trial court declared Plaintiff to be a "stalker" under ORS 30.866.

  98. An Oregon court "stalker" designation subjects a person to criminal liability for violation of the "stalking" order.

  99. An Oregon court "stalker" designation is added to the person's listing under the Law Enforcement Data System ("LEDS") computer.

  100. The "stalker" designation appears on the computer of every law enforcement officer's computer when that person's name is entered into the computer during any traffic or other "stop."

  101. The public perception of a "stalker" is a morally degenerate, violent, craven, and criminal individual.

  102. On or about May 15, 1996, in a front-page article of The Oregonian newspaper, Plaintiff was publicly accused of being a "stalker" by Defendant Hanzo.

  103. On or about May 17, 1996, as a result of the actions of Defendants Plaintiff was publicly defamed as a "stalker" in a front-page article with a photograph of Plaintiff in The Oregonian newspaper.
  104. On or about May 18, 1996, Plaintiff was again publicly defamed as a "stalker" on the front page of the Metro section of The Oregonian newspaper.

  105. On or about May 21, 1996, Plaintiff was publicly defamed in a story with Plaintiff's photograph in the national edition as a "stalker" by the New York Times newspaper.

  106. The May 21, 1996 New York Times story is still available on at least two websites on the Internet.

  107. On or about June 10, 1996, Plaintiff was again publicly defamed as a "stalker" on the front page of the Metro section of The Oregonian newspaper.

  108. On or about August 2, 1996, in a story about an lawful, peaceful AFLM picket, Plaintiff was publicly defamed as a "stalker" on the front page of the Corvallis (OR) Gazette-Times newspaper.

  109. On or about August 4, 1996, in a story about an lawful, peaceful AFLM picket, Plaintiff was publicly defamed as a "stalker" and shown in a photograph on the front page of the Corvallis (OR) Gazette-Times newspaper.

  110. On or about August 5, 1996, in a story about an lawful, peaceful AFLM picket, Plaintiff was publicly defamed as a "stalker" and shown in a photograph in the Snohomish (WA) Herald newspaper.

  111. As a result of the actions of Defendants the public designation of "stalker" has been given to Plaintiff in many newspapers, magazines, and electronic media since May 16, 1996.

  112. Defendants by their actions, caused the dissemination of the false accusation in the national media.

  113. As a direct and proximate cause of Defendant's actions, Plaintiff was falsely listed as a "stalker" on the LEDS computer.

  114. As a direct and proximate result of Defendants' actions, Plaintiff, labeled a "stalker," was publicly regarded as morally degenerate, violent, and criminal.

  115. As a direct and proximate result of Defendants' actions, Plaintiff was subjected public to hatred, contempt, and ridicule.

  116. As a direct and proximate result of Defendants' actions, Plaintiff suffered the loss of esteem, respect, good will, and confidence of his peers.

  117. As a direct and proximate result of Defendants' actions, Plaintiff was harmed in his reputation.

  118. As a direct and proximate result of Defendants' actions, Plaintiff was prejudiced in his profession as an anti-abortion activist.

  119. As a direct and proximate result of Defendant's actions, activist who formerly joined Plaintiff in anti-abortion activities, refused to continue doing so.

  120. As a direct and proximate cause of Defendants' actions, the possibility of future book contracts for Plaintiff has been decreased.

  121. Plaintiff therefore is entitled to $5,000 in compensatory damages, $1 in nominal damages, and $1,000,000 in punitive damages on his Eighth Claim for Relief.

    NINTH CLAIM FOR RELIEF

    (42 USC § 1988: Claim for reasonable costs, disbursements, and attorney fees in bringing actions under 42 USC sections 1983, 1985, and 1986)

    Plaintiff realleges paragraphs 1 through 121.

  122. Defendants conspired, acted in furtherance of a conspiracy, and caused actual deprivation of Plaintiff's civil rights under color of statute in violation of 42 USC sections 1983, 1985(3), and 1966.

  123. As a direct and proximate result of said actions, Plaintiff, to restore himself to his prior condition, is forced to bring suit against Defendants under the above statutes.

  124. Plaintiff, therefore, is entitled under 42 USC § 1988, to recover reasonable costs, disbursements, and attorney fees on his Ninth Claim for Relief.

    PRAYER FOR RELIEF

    WHEREFORE, Plaintiff prays that this Court enter judgment against Defendants

    and award Plaintiff relief as follows:

    1. The amount of $1,005,001 on Plaintiff's First Claim for Relief;

    2. The amount of $1,005,001 on Plaintiff's Second Claim for Relief;

    3. The amount of $1,005,001 on Plaintiff's Third Claim for Relief;

    4. The amount of $1,005,001 on Plaintiff's Fourth Claim for Relief;

    5. The amount of $1,005,001 on Plaintiff's Fifth Claim for Relief;

    6. The amount of $1,005,001 on Plaintiff's Sixth Claim for Relief;

    7. The amount of $1,005,001 on Plaintiff's Seventh Claim for Relief;

    8. The amount of $1,005,001 on Plaintiff's Eighth Claim for Relief;

    9. Reasonable costs, disbursements, and attorney fees on Plaintiff's

      Ninth Claim for Relief;

    10. That all Defendants be jointly and severally liable for such awards;

    11. A permanent injunction against Defendants from improperly using

      the courts to silence opposition to abortion; and

    12. Whatever other relief this Court deems just and equitable.

    Jury trial is demanded pursuant to FRCivP 38.

    Dated: _________________________

    ______________________________
    Paul deParrie, pro se


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