Complaint

ABORTION INDUSTRY IN MELBOURNE, FLORIDA
LAWSUITS
AWARE WOMAN V RANEY
DOCKET / CHRONOLOGICAL FILE
COMPLAINT

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION
NO. 99-5-CV-ORL-19C

AWARE WOMAN CENTER FOR CHOICE, INC,
a Florida corporation,
on its own behalf and for the class of patients, patient companions, staff, physicians, invitees, owners, and independent contractors,

PATRICIA BAIRD WINDLE,
EDWARD W WINDLE, JR,
TIFFANY POE, DON POE, GRANDFATHER POE,
and the classes of
JANE POE I-M {1-1000}, and JOHN POE I-M,
Plaintiffs,

-versus-

MEREDITH T RANEY, JR, individually and holding himself out as WOMEN'S LEGAL ACTION COALITION, and CHRISTIANS FOR LIFE, unincorporated associations, participating in concert with one another,

WILLIAM LESTOURGEON,
ALLEN LESTOOURGEON,
JOHN C 'JAY' ROGERS,
MARK STEVEN HALL,
PATRICIA McEWEN,
CHERYL PALMER,
CHRISTINE JAGOS,
DOLLY EDWARDS,
ALLEN MUNROE,
NORMA MUNROE,
RICHARD DEAN,
CECELIA STANBACK,
PAT PINKSTON,
NANCY LALLY,
LUTHER LAITE,
ANNE BLACKBURN,

NIGHTSTALKER DOE,
JANE DOEs and JOHN DOEs I-XX,

COMPUSERVE, INCORPORATED,
a corporation doing business in Florida,

AMERICA ONLINE, INC,
a corporation doing business in Florida, and parent successor to COMPUSERVE, INC,

TML INFORMATION SERVICES, INC,
a corporation doing business in Florida,

DOE CORPORATIONS I-XX,
their agents, assigns, successors in interest, those acting in concert or participating with them, all those having actual or constructive notice of any injunctive orders issued herein, and the class of individuals and entities similarly situated as to the named defendants,

Defendants.

COMPLAINT OF AWCC et al: CIVIL CLASS ACTION FOR DAMAGES, DECLARATORY & INJUNCTIVE RELIEF UNDER F.A.C.E., 18 USC §248, FDPPA, 18 USC §2721, AND SUPPLEMENTAL FEDERAL & STATE LAW GROUNDS, INJUNCTIVE RELIEF SOUGHT, JURY TRIAL REQUESTED ON DAMAGES, CLASS ACTION RELIEF SOUGHT

Plaintiffs AWARE WOMAN CENTER FOR CHOICE, INC, et al [hereafter, "AWCC" may designate all plaintiffs] are a reproductive health care facility, the staff of health care professionals, physicians, staff, and patients. AWCC brings these claims for declaratory and injunctive relief, actual & exemplary personal and business damages, statutory damages, physical and emotional damage and suffering, business and personal losses, costs & fees, and other necessary relief & compensation, and respectfully states the claims and allegations as follows:

I. JURISDICTION & VENUE

1. This federal district court has exclusive jurisdiction under FACE, 18 USC §248 et seq, and FDPPA, 18 USC §2721 et seq. There is further jurisdiction under the Federal Question Statute, 28 USC §1331, and the Civil Rights Acts, 28 USC §1343, implementing 42 USC §§1983-1986.

2. The Federal Supplemental Jurisdiction Statute, 28 USC §1367, and the U.S. and Florida Constitutions and Laws are additional jurisdictional bases.

3. All named Plaintiffs reside in the Middle District of Florida, Orlando Division, and have the capacity to sue on these claims. AWCC has standing to assert the jus tertii liberty, security, and privacy rights of third parties involved in seeking and providing legitimate reproductive health care services.

4. All named individual defendants reside in the Middle District of Florida for jurisdictional and venue purposes. All corporate named defendants transact substantial business in the Middle District of Florida.

II. FACTS

5. Defendant MEREDITH RANEY [hereafter "Mr Raney" or for brevity "Raney"] is an adult resident and citizen of Florida, operating primarily from the Middle District, Orlando Division, the City of Melbourne. He is a career professional anti-abortion harasser who for over a decade has devoted the bulk of his time to multiple forms of harassing plaintiffs, physicians, staff, patients, and others involved in seeking and providing reproductive health care services.

6. Raney is a retired electrical engineer on mental health disability, with a bi-polar manic depressive condition and symptoms of obsessive compulsive disorder. He is heavily medicated and considered dangerous by plaintiffs. Raney has been repeatedly arrested and convicted for violating the 36 foot protective "buffer zone" around AWCC, upheld by the Supreme Court in Madsen v WHC, 512 US 753 {1994). Said convictions were affirmed, and the Supreme Court denied certiorari October 2, 1995, as Raney has known and understood. Those citations are Alf v Florida, 116 SCt 65, 133 L Ed2d 27 {1995){mem), denying cert to 651 So2d 691, 692, 1211 (Fla 5th DCA)(mem)(upholding 108 similar buffer zone convictions). Raney has continued to violate the law of Madsen by his confession "thousands" of times.

7. Raney claims he is a "counselor" for total strangers going to AWCC, but he is altogether unschooled, untrained, uncredentialed, unlicensed, and unlicensable for any professional reproductive health counseling. He is a faux counselor without recognizable training, without willing patients, waiting in the rain even without umbrella.

8. None of Raney's routine activities harassing at AWCC bespeak the role of legitimate "counselor," particularly not his screaming "butcher" and "murderer" and "baby killer" to women who want nothing to do with him. Raney is more a hazard to the reproductive health and safety of patients and staff than any healer.

9. No reasonable fact-finder or jury could find that Raney is a legitimate counselor. He fails the evidentiary gatekeeper test.

10. Raney also holds himself out as the "WLAC" "CHIEF INVESTIGATOR." "WLAC" is not an organization or legitimate entity, but a deceptive Meredith Raney-created letterhead he sometimes uses. It says "Women's Legal Action Coalition." However, no women are involved in "WLAC," nor lawyers, nor is there any coalition. WLAC is only a paper letterhead, carelessly and recklessly deceptive and misleading in purpose and effect.

11. Raney also is admittedly not trained, licensed, or employed as an investigator of any kind. Characterization of himself as a "Chief Investigator" is carelessly and recklessly deceptive and misleading in purpose and effect.

12. The "action" part of Raney's self-created WLAC consists of unwanted and unsolicited letters sent on the faux letterhead negligently and recklessly attempting to damage and foment trouble for AWCC and the families of those victims and patients receiving the letters.

13. Groundless and undocumented Raney letters also have been sent through the federal mails to make numerous frivolous allegations and complaints to local, state and federal agencies, and to solicit patients to sue AWCC for malpractice, and to offer money for medical records identifying doctors, who then have been harassed and stalked by Raney et al. As 1999 unfolds, Raney is busybodily groundlessly harassing state transportation officials over partial acquisition by the State of AWCC property needed to widen US Highway One in north Melbourne. Raney obsessively attempts to infiltrate and insinuate himself in every aspect of AWCC activities, to cause damages and injuries to AWCC in every way possible, accidentally, recklessly, and otherwise.

14. By use of the WLAC letterhead, Raney has carelessly and recklessly misled hundreds of individuals through the federal mails, and caused untold damage. Raney has purveyed and spread false, inaccurate, misleading, and defamatory misinformation about AWCC, and invaded the safety, security, and privacy of those hundreds of individuals contacted by him through wire, telephone, or mail, on private, intimate matters without any consent or sane justification whatsoever. This is classic mail fraud, and includes numerous predicate acts for RICO purposes.

15. Raney further holds himself out as spokesman for a loosely unincorporated unregistered association he calls "Christians for Life." This CFL group of defendants primarily meets regularly, chants and prays, and participates together in various negligent, reckless, and otherwise tortious activities of harassment and intimidation at AWCC.

16. CFL is a direct descendant of "Operation Rescue Brevard," and is one vehicle for surveilling and invading the security, safety, and privacy of AWCC and hundreds of former patients and individuals.

17. Raney, CFL, and other defendants accomplish this by videotaping, surreptitiously copying license plates, obtaining personal information from COMPUSERVE or TML SERVICES, monitoring, and contacting women without their consent, and for no sane reason related to motor vehicle or traffic safety.

18. Raney has continuously and regularly in 1989-1998 engaged with numerous others of defendants in multiple forms of negligent, reckless, and tortious harassment, intimidation, threats, obstruction, trespass, following physicians, staff, and patients, copying license plates, videotaping of individuals and their vehicles, surveillance of individuals, obtaining personal information on individuals without their consent, and other insidious activities against AWCC not presently fully known, but which have caused overwhelming and substantial damage to AWCC in loss of patients, good will, reputation, physical and mental suffering.

19. Because of the surveillance by Raney and his confederates, prospective AWCC patients are intimidated and threatened. Many come to AWCC only in disguise or in rental cars, to protect their security from stalking, and their lives from unwanted, unpredictable intrusions.

20. Many other patients feel compelled to travel long distances to other cities for medical care, to avoid harassment, intimidation, surveillance, and unwanted contact with Raney's group of loud, unpredictable fundamentalist extremists. This causes several health hazards to patients.

21. Raney has numerous arrests and convictions for his equally tortious activities impacting and damaging AWCC. Raney has appealed, seen said convictions affirmed, and had certiorari denied, as to the 36 foot "buffer zone." Raney continues and will continue, however, to violate and obstruct the buffer zone repeatedly until federally restrained, and perhaps not then. Raney has admitted violating the buffer zone "thousands" of times. This shows his utter disregard for American law.

22. Raney's and other named defendants' affirmed buffer zone convictions culminated in Alf v Florida, 116 SCt 65, 133 L Ed2d 27 {US No 94-1951}, denying cert to 651 So2d 691, 692, 1211 (Fla DCA 5th 1995){mem). Some 108 similar buffer zone defendants were tried and convicted together in three trials. All also affirmed the buffer zone convictions of the following additional defendants: RICHARD DEAN, NIGHTSTALKER DOE, MARK HALL, PATRICIA McEWEN, NORMA MUNROE, WILLIAM LeSTOURGEON, CHERYL PALMER, JOHN C ROGERS, DOLLY EDWARDS, ALLAN MUNROE, PAT PINKSTON, LUTHER LAITE, and CHRISTINE JAGOS, all post, as well as dozens of others.

23. Defendants WILLIAM and ALLEN LeSTOURGEON [hereafter "LeStourgeon"] are adult residents and citizens of the Middle District of Florida. The LeStourgeons have actively and regularly participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

24. These have included the copying of license plates, invasions of security & privacy, violating the "buffer zone," and following patients and staff, as well as other equally and more serious activity not yet fully known.

25. William LeStourgeon has been arrested and convicted for his tortious activity impacting and damaging AWCC. Said convictions for "buffer zone" invasions have been affirmed and certiorari denied in Alf. The LeStourgeons have been major principal "thieves of privacy" in their almost daily surveillance of AWCC. Both have been regular "scribes" on the front lawn of Jay Rogers' "Spy House," across from AWCC, copying the plates of strangers to aid and abet unnwanted contact.

26. There the LeStourgeons have utilized binoculars and clipboards to facilitate, aid, and abet compilation of the massive "blackmail database" known to be maintained by Raney.

27. This database amasses personal information and details on hundreds and hundreds of women who have come to AWCC for private medical care from 1989 to date.

28. The "scribes," COMPUSERVE, TML, and others cooperate to make the "blackmail database" all come together in the computer of Meredith Raney and other computers used by defendants.

29. Raney compiles this information in part for an imagined day of reckoning when all abortion doctors, patients, and accessories will face their war crimes holocaust trials under a new fundamentalist theocracy, as proclaimed by the Swiss hermit Francis Schaeffer.

30. Raney contributes to Internet Websites which compile and disseminate biographical profiles of individuals designated to be brought before such a war crimes tribunal. He even has a few federal judges on the site. Neither Raney nor the Website has consent or authorization to trade in the names of those on the "Hit List."

31. The individuals whose personal information is surreptitiously collected by Raney did not consent to, or have reasonable means to avoid the security and privacy-invading surveillance maintained by Raney, the LeStourgeons, and others across the street from AWCC at 1575 Dixie Way [hereafter the "Spy House," owned by defendant John "Jay" Rogers.

32. The defendant LeStourgeons have been actively aided and abetted in their activities damaging AWCC by participating spouses. William has made asset transfers since the passage of FACE, 18 USC §248, and the decision in Madsen v WHC, 512 US 753 (1994}, to avoid judgments such as sought in this case, and thereby to mislead and defraud likely creditors and victims such as AWCC.

33. Defendant JOHN C 'JAY' ROGERS [hereafter "Rogers"] is an adult resident and citizen of the Middle District of Florida. Rogers owns, has primarily resided in, and has encouraged and permitted the use of the "Spy House" at 1575 Dixie Way, Melbourne, from the outset, for negligent, reckless, and tortious activities damaging the AWCC class since Rogers acquired said house in his name.

34. On information and belief, Rogers became the named owner of said "Spy House" to promote and facilitate the use of said property for his own and the activities of numerous other defendants, negligently and recklessly causing damages of many kinds to AWCC and others.

35. Recently in 1998 Rogers moved many of his assets and much of his property out of the "Spy House", on information and belief, after learning of his potential liability, and the liability exposure to the "Spy House" itself as a "harassment and vandalism staging area."

36. On further information and belief, the "Spy House" was financed and acquired by Rogers and other persons presently unknown, to encourage and provide a "staging area" for negligent, reckless, and tortious activities of harassment and intimidation toward AWCC and associated persons.

37. The result has been substantial damage to AWCC in numerous ways, including physical damage and suffering, and property damage.

38. Said "Spy House" has in fact been used by defendants inside and out extensively to promote and facilitate multifaceted negligent and reckless tortious activities. It has been a metaphorical "tort volcano."

39. These activities have included the maintenance and storage of the aforesaid "blackmail database," ongoing intrusive surveillance, stalking, videotaping, binocular observations, use of long distance directional microphones, staged contemptuous violations of the 36 foot "buffer zone," harassment, intimidation, attempted blinding by flashlights at night, lurking & looming about at night, and obstruction of driveways and persons coming in and out of AWCC.

40. Persons utilizing the "Spy House" property have shined flashlights in the eyes of AWCC staff and other individuals driving out of the AWCC parking lot in semidarkness. Raney has been identified as one such "illuminator" person. Another is the unknown defendant NIGHTSTALKER DOE who regularly stalks at AWCC until as late as 1 AM, and refuses to identify himself. Defendants, including Mark Hall and Meredith Raney have aided and abetted DOE.

41. Persons utilizing the "Spy House" property and front lawn have also "spotted" with binoculars business telephone numbers on the sides of vehicles at AWCC. Then said persons have telephoned the business numbers and stated that someone from the business was having an abortion at AWCC.

42. LeStourgeon and Raney have both been identified as likely such perpetrators, in that they have opportunity, means, and motive. Also, they have no visible gainful employment or other life, and spend innumerable hours and days in the front yard of the "Spy House" with binoculars, writing materials, clip boards, cell phones, and Raney's special "surveillance log sheets," which have been maintained and stored at the "Spy House" for years, and backed up & combined with additional personal information on Raney's and others' computers.

43. Rogers and Hall have negligently, recklessly, and otherwise tortiously allowed the "Spy House" mailbox (which sits across the street in the buffer zone entryway in front of AWCC) to be adorned with the label "THE KILLING PLACE." This is a threatening, intimidating nuisance, and a serial defamation of AWCC with utterly no civilized justification, certainly not since the "Scarlet Letter" designations of 15th century Salem, Mass. The DBA for "KILLING PLACE" was obtained under false pretenses for tortious usages and serial defamation, in violation of federal and state laws.

44. Rogers has negligently, recklessly, and tortiously conspired with and aided & abetted numerous other defendants, and has himself been arrested and convicted for contemptuous violation of the 36 foot buffer zone. Said conviction(s) of Rogers were affirmed, and certiorari denied, in Alf.

45. Rogers has carelessly and recklessly promoted and allowed the use of his house, yard, storage facilities, telephone, and computers as the instruments for causing ongoing and irreparable injury and damage of many kinds to AWCC, from purchase of the "Spy House" to date.

46. Defendant MARK STEVEN HALL [hereafter "Hall"] is an adult resident and citizen of the Middle District of Florida. Hall has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC, including and certainly not limited to the climbing of nearby tall trees and ladders near the North side of AWCC property, in order to intimidate and spy on physicians and patients, with no consent, authorization or legitimate lawful purpose.

47. Hall has violated the 36 foot AWCC buffer zone to harass, threaten, and intimidate AWCC. He has been arrested and convicted, appealed, and had certiorari denied, for his tortious activities impacting and damaging AWCC.

48. Hall has most recently in 1998 been involved in the acquisition and leasing of additional property on Dixie Way across the street from AWCC, beside the "Spy House." There he has announced plans to continue and expand the activities heretofore conducted primarily from the "Spy House."

49. Use of property such as the "Spy House" for surveillance activities by hostiles is an ongoing threat, intimidation, nuisance, and danger to the peace and safety of the neighborhood, and to the physical safety of AWCC, patients, staff, and physicians. This is evidenced by multiple rifle shootings in the U.S. and Canada from properties adjacent to reproductive health facilities and physicians' homes. The most recent such shooting resulted in the murder and death of a Buffalo, N.Y. obstetrician-gynecologist. Extremist anti-abortion zealots, particularly when manic, delusional, and/or obsessive compulsive, are always but .a short step from violence.

50. Raney and others of the defendants and their associates have been involved in harassing and picketing at many of the clinic shooting and bomb sites in the United States: E.g., Buffalo, Birmingham, Atlanta, Dayton, Wichita.

51. The numerous threatening, intimidating, obstructive, privacy-invading activities, and notorious "UNWANTED POSTERS" produced by Raney and his confederates -- detailing private and personal address information about physicians, staff, and even their children and elderly mothers' whereabouts -- have the careless and reckless purpose and effect of intimidating and threatening these "targets" who reasonably fear for their own and others' safety.

52. Said activities of Raney and confederates have necessitated and caused extraordinary security expenses by AWCC, and stressful alteration of living patterns by all plaintiffs and their associates, including the need for guards, security fences, security cameras, prevention of chemical attacks, bullet proof glass & apparel, extra protection of children, and ongoing constantly stressful vigilance against stalkers, lurkers, strangers, and persons behaving oddly. Many ordinary business papers now have to be shredded, or be at considerable risk in the garbage which Raney confessed to ransacking on occasion. Rental cars are often necessary for security.

53. Defendant PATRICIA McEWEN [hereafter "McEwen"] is an adult resident and citizen of the Middle District of Florida. McEwen has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

54. These have included the copying of license plates, invasions of privacy and security, violating the "buffer zone," rallying to a criminal FACE violation scene in West Palm Beach at 5 AM in the morning, and other activity not yet fully known and investigated.

55. McEwen has been arrested and convicted for her tortious activity impacting and damaging AWCC. Said conviction(s) have been affirmed, and certiorari denied.

56. McEwen has also been a regular "scribe" involved in compiling the massive "blackmail database" maintained by Raney and his confederates, of personal information and details on women and their companions who have come to AWCC for private medical care.

57. Defendant CHERYL PALMER [hereafter "Palmer"] is an adult resident and citizen of the Middle District of Florida. Palmer has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

58. These tortious activities have included the copying of license plates, other invasions of privacy and security, and violating the court ordered buffer zone. Palmer has also been a regular "scribe" involved in compiling the massive "blackmail database" maintained by Raney of personal information and details on women who have come to AWCC. Palmer has caused and contributed to personal damage and injury thereby.

59. PALMER has been identified as one of two Raney confederates who trespassed into a hospital room in early 1998 to harass and interfere with an AWCC patient who had been admitted for observation.

60. Defendant CHRISTINE JAGOS [hereafter "Jagos"] is an adult resident and citizen of the Middle District of Florida. Jagos has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC. She has been aided and abetted by spouse ROD JAGOS.

61. These activities have included the copying of license plates, other invasions of privacy and security, and violating the court ordered buffer zone.

62. Jagos has been a "scribe" involved in compiling the massive "blackmail database" maintained by Raney of personal information and details on women who have come to AWCC, and she has caused damage and injury thereby.

63. Defendant DOLLY EDWARDS [hereafter "Edwards"] is an adult resident and citizen of the Middle District of Florida. Edwards has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

64. These have included the copying of license plates, other invasions of privacy, and violations of the court-ordered buffer zone.

65. Edwards has also been a "scribe" involved in compiling the massive "blackmail database" maintained by Raney of personal information and details on women who have come to AWCC, and she has caused damage and injury thereby.

66. Defendants ALLEN MUNROE and NORMA MUNROE [hereafter the "MUNROEs"] are adult residents and citizens of the Middle District of Florida, and have worked closely together in their similar activities material to this lawsuit. The Munroes have participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

67. These have included the copying of license plates, other invasions of security and privacy, and violations of the court-ordered buffer zone.

68. The Munroes have been principal "scribes" involved in aiding and abetting the compiling of the massive "blackmail database" maintained by Raney of personal information and details on women who have come to AWCC, and they have caused substantial damage and injury to numerous plaintiffs thereby.

69. Defendant CECELIA STANBACK [hereafter "Stanback"] is an adult resident and citizen of the Middle District of Florida. Stanback has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

70. In particular Stanback has surveilled and shadowed patients and loudly shouted "fighting words" to people entering and leaving AWCC, including threats to staff that they were risking "death" by working at AWCC.

71. Defendants PAT PINKSTON [hereafter "Pinkston"] and RICHARD DEAN [hereafter "DEAN"] are adult residents and citizens of the Middle District of Florida. Pinkston and Dean have participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC, including the copying of license plates and maintaining stalking-like surveillance.

72. Pinkston and/or Dean in particular are believed to have surveilled patients and shone lights in the eyes of persons driving away from AWCC some evenings as darkness fell. PINKSTON is fixated on describing some AWCC invitees as "satan worshippers."

73. Defendant NANCY LALLY [hereafter "Lally"] is an adult resident and citizen of the Middle District of Florida. Lally has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

74. Defendant LUTHER LAITE [hereafter "Laite"] is an adult resident and citizen of the Middle District of Florida. Laite has participated with Raney and others for a number of years in various negligent, reckless, and tortious activities of harassment and intimidation damaging AWCC.

75. Laite also holds himself out as a fundamentalist minister, operating out of a storefront in an industrial park in Palm Bay.

76. Defendant ANNE BLACKBURN [hereafter "Blackburn"] is an adult resident and citizen of the Middle District of Florida. Blackburn has participated with Raney and others in various negligent, reckless, threatening, and tortious activities of harassment and intimidation damaging AWCC.

77. Blackburn's most recent role has been to violate the court-ordered buffer zone, obstruct the entrance to the AWCC parking lot to slow and impede vehicles entering and leaving, and to scream "fighting and insulting words" at drivers and passengers.

78. Blackburn also has a trained loud voice audible at great distances and inside the clinic. She shouts fighting words and ominously threatening harassment and intimidation at others, threatening that they will "burn in hell," and calling them "murderers" and "baby killers." She, like Mr Raney, refers to this as "counseling."

79. Blackburn regularly ignores and violates the "36 foot buffer zone."

80. Also, she maintains vigilance over a gigantic bloody fetus poster, a reference item she, Raney, and others use for "counseling," but which has the effect of threatening, harassing, and intimidating individuals, and no educational effect.

81. Defendants NIGHTSTALKER DOE, JANE DOEs and JOHN DOEs I-XX are similarly situated as yet unidentified natural persons, who will be named and described after further discovery. NIGHTSTALKER in particular lurks around AWCC near and after dark. He pops out beside cars as they leave. He regularly invades the buffer zone. He appears to talk to himself and chant or speak verse in some unrecognizable tongue, perhaps "tongues" itself. No one will reveal his name.

82. Defendant COMPUSERVE, INCORPORATED [hereafter "COMPUSERVE"], is or has been a non-Florida corporation doing business in Florida. COMPUSERVE has negligently, recklessly, and tortiously facilitated the foregoing security and privacy-invading activities of Mr Raney, and others not yet fully known.

83. COMPUSERVE has thereby caused much reasonably foreseeable damage and suffering to AWCC, the plaintiffs, and the entire class seeking relief.

84. In particular COMPUSERVE has provided, for a fee, the link between license plates and personal information and addresses on vehicle owners, and all of the harassment, intimidation, and damage that follow.

85. COMPUSERVE's practice was to buy personal information data from the State DMV, then sell names, addresses, and other personal information, with only careless preliminaries, to Raney and any other person whatsoever.

86. COMPUSERVE'S sales allowed personal information to come into the hands of many kinds of recipients, including prisoners, mental institution inmates outpatients, stalkers, and estranged spouses, all negligently and recklessly without limitation or consideration of foreseeable risks to the unsuspecting class of victims.

87. Defendant AMERICA ONLINE, INC [hereafter "AOL"] is a non-Florida corporation doing business in Florida. At all times material hereto, AOL has been the parent corporation and owner of COMPUSERVE, with management and ultimate control, and responsible for the liabilities set forth in this lawsuit, jointly and severally liable with COMPUSERVE and others, during the time in which COMPUSERVE provided its personal information service to Raney.

88. AOL and COMPUSERVE are believed to have discontinued the foregoing information gathering and dissemination because of carelessly and recklessly belated security and privacy concerns.

89. Defendant TML INFORMATION SERVICES, INC [hereafter "TML"] is a corporation doing business in Florida.

90. TML has also negligently, recklessly, and tortiously facilitated the unconsented, careless and reckless security and privacy-invading activities of Mr Raney and others not yet fully known.

91. TML has thereby caused much damage and suffering to AWCC and the plaintiff classes.

92. DOE CORPORATIONS I-XX are similarly situated with respect to other natural and corporate defendants, have not yet been identified by name, but will be named and added after further discovery.

93. As historical fact and background, in 1972 the State of Florida through its legislature sanctioned medically supervised pregnancy terminations in clinics and hospitals.

94. That was twenty-six years ago, prior to and independent of Roe v Wade, 410 US 113 (1973), and Doe v Bolton, 410 US 179 (1973).

95. The Florida abortion law was further relieved of some of its restrictions in cases leading up to and including Poe v Getsrein, 517 F2d 787 (5th Cir 1975), afffd mem, 428 US 901 (1976).

96. Independent of Roe/Doe, the Florida Constitution and Supreme Court have also developed an impressive body of jurisprudence on a state constitutional right of privacy, including medically safe abortions for adult women and minors, as in In re T.W., 551 So2d 1186 {Fla 1989}.

97. Safe and legal medically supervised abortion has been the policy of the State of Florida for a quarter of a century, as opposed to dangerous back-alley, non-medical abortions, which are the alternative when clinics and doctors are harassed, intimidated, and threatened out of business by extreme fundamentalists and zealots.

98. Florida law, the Florida Constitution, and state statutes/regulations were fortified under both the Due Process and Equal Protection clauses of the U.S. Constitution in Roe and Doe, as reaffirmed repeatedly after exhaustive and exhausting debate through Planned Parenthood v Casey, 505 US 833 (1992). During these years the Supreme Court has been deluged with fetus pictures and videos, and has accorded them due deliberation.

99. In Florida, and Melbourne is a part of Central Florida, an outpatient medical facility providing abortions is a lawful entity as much as or moreso than any other clinic, hospital, or physician's office.

100. As a lawful and policy-favored entity AWCC is entitled fully to the protection of federal and state laws, including law enforcement and judicial injunctive relief from trespass, vandalism, harassment, threats, obstruction, intimidation, stalking, and invasions of personal security, safety, liberty, and privacy.

101. When state laws and courts fail, as has been the case here, the federal authorities may and should step in, as is authorized by the jurisdictional statutes cited at the outset of this document.

102. The state courts, and Melbourne police, have ceased to enforce and protect AWCC with the buffer zone, and the Raney group has accordingly stepped up the proximity and intensity of its tortious activities, leaving AWCC with only FACE, FDPPA, and common law remedies.

103. Medical facility neighborhoods, also, are generally understood by reasonable people to be "quiet zones," not the same as public forums or political caucuses of boisterous harassment and verbal abuse.

104. A person nearing or entering a medical facility entrance is a "captive audience" for those few moments. S/he has reasonable expectations of privacy and peace. She should not have to run an obstacle course through unpredictable, unwanted fundamentalist extremists yelling loudly, photographing, videotaping without consent, then taunting, following, telephoning, visiting in the night, lurking, contacting, or stalking afterwards. She should not be confronted with poster signs that display her own name in public, an unconsented practice that must be condemned.

105. AWCC was a peaceful, relatively unharried haven of physicians and staff helping grateful patients, until one October morning in 1989 when a stranger arrived, probably sent by OPERATION RESCUE to haunt the area, sporting a video camera, binoculars, and an apparent obsessive and manic dislike for independent women, fueled by bad personal experiences.

106. The AWCC neighborhood off Highway U.S. 1 in fact was quiet and very residential until Meredith Trotter Raney, Jr, showed up with his repertoire of confederates, harassment, intimidation, and dirty tricks.

107. Raney videos from those early days show his continuing pattern of videotaping license plates and capturing video images of people he did not know, and who did not know or want to know him, outside a medical facility where he had no legitimate business whatsoever. His siege began in 1989 and has continued without interruption, an unending stream of unwanted, unconsented multi-faceted tortious interference with the lives and personal security of plaintiffs and their classes.

108. Raney at that time had been recruited and trained directly or indirectly by OPERATION RESCUE associated persons he has declined to disclose. Raney was also already a few years into a serious mental illness then, clinically known as bi-polar, manic depression, with accompanying obsessive compulsive disorder (OCD). This is a common mental illness among the worst of extremist fundamentalists.

109. Raney had actually been trained in the real world as an electrical engineer (BS 1968). He had and still has utterly no medical or professional health care background, certification, knowledge, or eligibility, not even to be the lowliest health care provider imaginable. His attempts to practice medicine are dangerous to the public health and hazardous to the health of women going to the AWCC facility.

110. As a consequence of his mental illness, and the need to control the known symptoms of aggressive, obsessive, poor judgment, and delusional symptoms, Raney's daily dosage of Lithium Carbonate at that time was and still is a staggering 1500 milligrams. He ignores his need for regular monitoring.

111. The symptoms, behavior patterns, and acting out of this kind of bi-polar and obsessive illness are antithetical to what is desired in a medical school applicant, or counseling therapist. More commonly, the bi-polar condition is found in persons apprehended and confined for stalking, or worse, as noted in professional literature.

1112. There is a substantial body of professional and medical literature on obsessive compulsive disorder (OCD), bipolar disorder, manic depression, and the mental illness aspects of stalking, as well as various delusional disorders, for which there is much evidence in this case.

113. The origin of Raney's harassing behavior and his obsessive-compulsive f'~xation upon fetuses {which he always calls "babies," "children," or some other post-delivery name), is not yet fully known.

114. The consequences, however, of Raney's harassment and that of his confederates, has been massive and irreparable damage and suffering for many hundreds of women they have outrageously violated by unwanted surveillance and intimidation systematically and continuously throughout 1989-1999.

115. Raney and his group have been insidious thieves of privacy, security, and autonomy for almost a decade. It is known that in the mid-1980s Raney suffered through a painful and difficult divorce, lost his wife, lost substantial assets, and became obsessive-compulsive, delusional and bipolar. As is often described in professional literature he needed an anchor and a cause, however illusory, and became involved in Operation Rescue and other extremist fundamentalist activity.

116. Raney was persuaded to accept early retirement from engineering because of his mental illness, and his inner hostility grew, as he had lost both wife and job, a common symptomology. He transferred and projected his anger upon AWCC and reproductive health facilities, unfortunately for the thousands of women he has harassed and damaged.

117. None of the above was remotely the fault of AWCC and the plaintiffs who became Raney's subsequent victims, the objects of his anger, hostility, obsessions, and acting out.

118. Much of the above, however, closely fits the psychological profiles of potentially dangerous stalkers, as described in the professional and F.B.I literature.

119. The painful circumstances leading up to the Raney divorce coincided with Raney's manifestation of mental illness and his less than enthusiastic attempts at having treatment.

120. At that time Raney also became a free lance fundamentalist extremist, pretending to find answers to everything in his and others' interpretations of the Judaeo-Christian Bible, as opposed to some other guide for living.

121. Raney also began irrationally acting out an obsessive-compulsive need for imposing upon others his own personal version of imagined Biblical wisdom on reproductive health matters. By this reasoning, for example, Raney most recently was a principal organizer for the May-June 1998 protests of "Operation Rescue National" at Disney and Barnes & Nobles, accusing them respectively of promoting "sodomy" and "pornography." No fact finder could see this as based in reason, as opposed to delusional.

122. Whatever the dark reason, Raney laid siege to AWCC around October 1989. Untoward events and damage have continuously followed one upon the other since that time, not just a few, but literally the hundreds one would expect from a small, secretive cell of obsessively motivated extremists with nothing else to do, and funding from "above."

123. Each named defendant, and others, singularly, and/or in participation with Raney, have negligently, recklessly, and otherwise tortiously caused untold damage and suffering- physical, mental, emotional, and financial - to AWCC and other plaintiffs, continuously since 1989.

124. The variety of harassing and intimidating activities has been enormous and multiplicitous, a veritable encyclopedia of harassment techniques, evidence of systematic extremist training.

125. Books and training by convicted extortionists Joseph Scheidler and Randall Terry have included "CLOSED: 99 WAYS TO STOP ABORTION," first published in 1986. Terry and his successors supported harassment training at "I.M.P.A.C.T. boot camp" held in Melbourne, FL, for extremist fundamentalists (including many of these defendants) to learn multiple harassing techniques, and to try them out on central Florida clinics, particularly AWCC.

126. "IMPACT" gang activities directly caused the closure of the AWCC satellite clinic in Port St Lucie, FL.

127. The history of "IMPACT" is the background for passage of FACE. Raney attended said boot camp and has been a follower of Randall Terry. Terry is a charismatic exused-car (and used-tire) salesperson, and high school dropout, who is said to speak in tongues, a mark of divine inspiration in fundamentalist circles.

128. Terry founded so-called "OPERATION RESCUE," a lucrative DBA for him in Upstate New York. Raney's "Christians for Life" is the successor to Operation Rescue South Brevard.

129. A WestLaw search on Joseph Scheidler, Randall Terry, Flip Benham, and Operation Rescue reveals a textbook of federal case law on tortious interference schemes, RICO, FACE, injunctions, contempt convictions, unpaid and evaded fines, asset concealment, bankruptcy abuse, and unsatisfied judgments involving Raney's mentors and associates.

130. An example of classic harassment and intimidation directed toward AWCC has been insidious telephone and communications interference and diversion activity.

131. Phone jams have occurred often at AWCC, meaning multiple and repeated harassing calls from pay phones and other sources difficult to trace, more than 5,000 in the ultimate peak month. This originates with a local extremist request to other extremists nationwide that they deluge AWCC telephone and pager numbers with untraceable pay phone calls, and leave the handsets swinging. 800-Number billings show the national pattern of calls.

132. An order authorizing a phone trap by the relevant telephone companies is necessary to identify the perpetrators of this harassment. The AWCC 800-WATS number had to be canceled because of jamming. Harassers routinely make phony appointments in order to know surgery days.

133. Diversion of telephone and FAX lines is another harassment problem of which there is evidence. This would be done to intercept or reroute appointment calls. FAX diversion would delay transmissions long enough for harassers to copy letters, medical, and legal documents being sent back and forth. This is very difficult to document or trace without sophisticated electronics and communications training, which Raney has.

134. Raney's thinly veiled orchestration of doctor threats, following, stalking, and pressure on them to quit seeing reproductive health patients, has been and remains a continuous form of ongoing, decade-long harassment at AWCC.

135. The doctor harassment has included surveillance, running license plates through COMPUSERVE or TML SERVICES, unwanted contact, chasing on the highway {a tactic dating back to the Klan), and the production by Raney of "UNWANTED POSTERS" which provide any unbalanced shooter with target information.

136. A further example of insidious harassment and intimidation would be the cases in early 1998 of the damage inflicted upon three specific plaintiff POEs (a pseudonym).

137. Raney, LeStourgeon, or a confederate first binoculared the Poe's license plates going into or out of AWCC.

138. COMPUSERVE or TML SERVICES then provided personal identification, address, characteristics, and name information on the vehicle owners and licensees. These were of the patient's father and then of the grandparents' vehicles.

139. Raney personally followed Tiffany Poe to a local hospital where she was to be admitted for observation. Raney confederates breached hospital security, Raney with a video camera.

140. Two spooky women found Tiffany's room, entered without invitation {i.e., trespass, invasion of security and privacy), and began chanting around her hospital bed without anyone's consent, an outrageous invasion of security, safety, and privacy. Defendant CHERYL PALMER has been identified as one of those people.

141. Subsequently there were unwanted letters and telephone calls from Raney or confederates to the POEs. COMPUSERVE or TML gave Raney enough information that he could knock on the door in the middle of the night, like a Night Stalker.

142. On at least one occasion, Raney confederate and codefendant WILLIAM LESTOURGEON followed Tiffany Poe and another person in his car, surveilling them in a Melbourne department store parking lot, and following them further.

143. This surveillance by LeStourgeon caused reasonable fear for their physical safety and security, as he is unpredictable, unemployed, and ever-lurking about the "Spy House," seeking to cause trouble and disrupt lives of strangers.

144. In any case where an AWCC patient is admitted to an ER for observation, Raney makes an unsubstantiated claim or complaint to state medical authorities. Raney also attempts to solicit a malpractice case in such instances for certain coastal personal injury lawyers. This causes much wasted time and damage to AWCC. That is a foreseeable objective of the harassment, since Raney is not professionally competent to evaluate the medical circumstances nor privy to confidential private records, unless he steals them. Raney is driven, however, to scream "butcher," and to wallpaper state agency walls with such unfounded complaints, thereby causing great unwarranted damage.

145. Garbage theft of papers from AWCC, staff, owners, children, and others has often and regularly occurred as part of defendants' program. This was the probable predicate for rerouting of mail and cancellation of credit accounts, as well as other malicious mischief perpetrated against AWCC.

146. Huge phony poster signs that are in violation of city codes, and contain defamatory, false & misleading allegations, are a routine form of continuous harassment from the lawn of the "Spy House." The city poorly enforces sign code violations, if at all. The city comes out; the signs go down; the city departs; the signs go back up. Since the LeStourgeons have sign-making experience, this form of harassment is ubiquitous and a daily phenomenon. Defendants often carry the bloody giant fetus signs into the buffer zone and AWCC driveway to harass and intimidate AWCC clients.

147. Defendants have, of course, attempted to disguise their harassment and intimidation in manipulative and delusional language of counseling, religion, and love. As to the latter, particularly, history shows that "love" was the stated reason for the Scarlet Letter punishment, for hanging witches, burning heretics, Papal overruling of the Magna Carta, and more recently for the mass murders by the Charles Manson group. The murderers of American doctors who perform abortions have similarly based their acts on the same rhetoric espoused by Meredith Raney himself, and his codefendant confederates.

III. CLASS ACTION ALLEGATIONS

148. The classes of plaintiffs damaged by one or more defendants is so numerous that joinder of all members individually would not be pragmatic, but rather unduly cumbersome and intrusive upon security, safety, and privacy.

149. As many as a few thousand license plates may have been copied by defendants, and personal addresses and information accessed without consent.

150. Numerous questions of law and fact are common to these claims, and predominant over individual questions, and are likely to be opposed by common defenses of the classes of individual and corporate defendants.

151. The claims of the plaintiffs are typical of the class, and will be fairly presented by the named and pseudonymnamed class members, who will fully and adequately protect the interests of the class.

1512. The prosecution of separate actions in different courts by individual members of the class would be impossibly burdensome and would create a risk of varying determinations on multiple interrelated issues that would establish incompatible rules of conduct for the classes of defendants, who have acted on grounds generally applicable to the class in any event.

153. A class action is superior to any other methods for the fair and efficient adjudication of the overall controversy and its many parts.

IV. IRREPARABLE INJURIES & DAMAGES

154. The federal statutory and constitutional violations involved in these claims render their related injuries to patients, physicians, and staff irreparable per se. The statutes include FACE, 18 USC §248, FDPPA, 18 USC §2721, and the Civil Rights Acts, 42 USC §§1983-1986.

155. Undue burdens on access to reproductive health care are irreparable injury per se to the plaintiffs, who are specifically and seriously harmed.

156. Invasions of personal safety, security, and privacy, such as involved here, have dangerous and irreparable consequences that can only be prevented and avoided by serious enforced injunctive relief.

157. Numerous forms of damage have been suffered by the plaintiffs as a proximate consequence of the negligent, reckless, wanton, intended, and tortious misconduct of the defendants, and each one of them.

158. These include but are not limited to intrusions on physical security & safety, intrusions upon personal liberty & privacy, physical and mental suffering, emotional distress, and many forms of financial loss.

V. BURDEN ON STATUTORY & CONSTITUTIONAL RIGHTS

159. The negligent, reckless, wanton, intended, and tortious acts and omissions of defendants have unreasonably burdened access to and delivery of reproductive health care services to and by the plaintiffs.

160. The multi-faceted siege of AWCC by defendants since 1989 continuously to date has negligently, recklessly, and tortiously interfered with peaceful, lawful reproductive health care services, and has threatened, intimidated, and obstructed the delivery of such services at AWCC, as well as the safety, security, and privacy of the plaintiffs.

161. The obtaining, release, videotaping, and dissemination of personal information on persons entering and leaving AWCC from 1989 to date has negligently, recklessly, wantonly, and tortiously resulted in a dangerous "blackmail database" of vehicle and licensee personal addresses and details, augmented and expanded by Raney's further obsessive research and "chumming" dissemination.

162. This burdens and damages the plaintiffs severely as an ongoing serial threat to personal security, bodily safety, and privacy.

VI. PUBLIC INTEREST AND POLICY

163. The constitutional & statutory law of Florida favors unimpeded access by citizens to reproductive health care services. "[T]he State has a strong interest in protecting a woman's freedom to seek lawful medical or counseling services in connection with her pregnancy." Rehnquist, C.J., in Madsen v WHC, 512 US 753 (1994)(p 12 of opinion).

164. The federal constitutional & statutory law of the United States favors the unimpeded access of citizens to reproductive health care services. Id; Roe v Wade, 410 US 113 (1973}; Doe v Bolton, 410 US 179 (1973}.

165. Federal and state law disfavor and often criminalize the harassment, obstruction, and unreasonable intimidation of persons entering and leaving health care facilities. "[T]argeted picketing of a hospital or clinic threatens not only the psychological, but the physical well-being of the patient held 'captive' by medical circumstance." Rehnquist, CJ, in Madsen v IVHC, 512 US 753 (1994)(p 12 of opinion}.

166. Federal and state law further disfavor unreasonable and intimidating invasions of both public and personal safety, security, and privacy.

VII. CLAIMS FOR RELIEF

167. Plaintiffs AWCC et al the foregoing allegations and state the following as their counts and claims for relief.

COUNT I: MULTIPLE FACE VIOLATIONS

168. The negligent, reckless, wanton, intended, and tortious acts and omissions of defendants, have attempted to injure, intimidate, and interfere with the class of plaintiffs, because the latter were seeking to, or obtaining, or providing, reproductive health services at the AWCC facility. Said acts and omissions of defendants are multiple violations of FACE.

169. The negligent, reckless, wanton, intended, and otherwise tortious acts and omissions of the defendants have damaged and attempted to damage the property of plaintiffs, because the latter were seeking to, or obtaining, or providing, reproductive health services at the AWCC facility. Said acts of defendants are multiple violations of FACE.

170. The plaintiffs have been seriously damaged, injured, and aggrieved by the acts and omissions of defendants. Said acts were directed at plaintiffs, because they were involved in seeking to obtain or provide services in the AWCC reproductive health facility.

171. The defendants have attempted to and in fact restricted freedom of movement in and out of AWCC, delayed and rendered impassable ingress and egress, and repeatedly placed plaintiffs in reasonable apprehension of bodily harm to themselves and others.

172. The individual Defendants and each one of them are jointly and severally responsible and liable for each and every one of the multiple FACE violations set out, for actual or statutory damages of a minimum $5,000 each per count, multiplied by each individual, and a corporate plaintiff, and for punitive damages, to the extent that one or more contributing incidents, occurrences, acts or omissions was reckless, wanton, malicious, or willful, and for forfeiture of property and assets used in the violations, and other relief.

COUNT II: MULTIPLE INVASIONS OF SECURITY & PRIVACY RIGHTS UNDER FEDERAL & STATE LAW

173. The negligent, reckless, wanton, intended, and otherwise tortious acts and omissions of defendants have caused and contributed to multiple irreparable and severely damaging invasions of the federal and state security, safety, liberty, and privacy rights of the plaintiffs and each member of each class.

COUNT III: INFLICTION OF EMOTIONAL DISTRESS

174. The negligent, reckless, wanton, intended, outrageous, and otherwise tortious acts and omissions of defendants have caused and contributed to substantial and severe emotional distress with physical manifestations and substantial foreseeable damages to each plaintiff and each member of each class.

COUNT IV: NUISANCE

175. The individual Defendants and each one of them are jointly and severally responsible and liable as nuisances in law and fact, for the conduct and omissions heretofore alleged.

COUNT V: INTERFERENCE WITH BUSINESS & PROFESSIONAL RELATIONSHIPS

176. The negligent, reckless, wanton, intended, and otherwise tortious acts and omissions of defendants have unreasonably interfered with numerous business and professional relationships among AWCC, physicians, staff, patients, invitees, and others.

177. Said interferences have caused serious, substantial, painful, and irreparable injury and damages to plaintiffs.

COUNT VI: INTERFERENCE WITH BUSINESS & PROFESSIONAL REPUTATION & GOOD WILL

178. The negligent, reckless, wanton, intended, and otherwise tortious acts and omissions of defendants have unreasonably interfered in numerous ways with, and caused immeasurable damage to, the business and professional activities and reputation of AWCC.

COUNT VII: CIVIL CONSPIRACY

179. Defendants and each one of them are jointly and severally responsible and liable for civil conspiracy to obstruct, intimidate, threaten, and interfere with the seeking, obtaining, and provision of reproductive health care services by plaintiffs.

180. Said civil conspiracy has caused and contributed to immeasurable, irreparable, and substantial personal and property damages to the plaintiffs and their classes.

COUNT VIII: MULTIPLE FDPPA VIOLATIONS BY CERTAIN DEFENDANTS

181. The negligent, reckless, wantons intended, and otherwise tortious acts and omissions of the defendants threaten unreasonably, unnecessarily, and recklessly to disclose, and have disclosed, personal information that can and has been derived from motor vehicle and/or drivers license records based on surreptitious copying of plates by the individual defendants, and unconsented, invasive use by their confederates.

182. Said disclosures are not necessary for, nor related to, motor vehicle or public safety, nor can they be based on knowing and informed written consent of drivers, passengers, or invitees associated with AWCC, who strongly object to and are seriously damaged by such unconsented and unwanted invasions of security and privacy.

183. Nor are such disclosures and disseminations allowable under any excepting provision of FDPPA, 18 USC §2721(b)(1}-(14}, nor for any other lawful purpose.

184. The disclosures and disseminations complained of and anticipated occur in part because of careless and reckless state agency practices in making unconsented open sales of private informational details on vehicle driver lists, without providing clear and conspicuous notice or reasonable opt out mechanisms for vehicle owners, and with no protection whatever for non-owner drivers and passengers.

185. Individuals in Florida are required to register their vehicles and become licensed to drive. But, no individuals consent thereby to have their names, addresses, and other personal information splashed in effect across a public billboard that can be viewed and copied by any voyeur, stalker, rapist, burglar, potential killer, shooter, prison inmate, or other dangerous person. Defendants have emblazoned patient names on posters and shouted to them from across the street at the "Spy House."

186. AWCC associates and threatened individuals who drive in and out of the AWCC parking areas are irreparably injured and damaged by the foregoing acts and omissions. None of these individuals has an adequate opportunity, means, or notice to prevent release and unlawful use of this information against them, nor to stop the compilation and reckless development and use of a "blackmail database" by Raney, LeStourgeon, and their confederates against them, aided and abetted by the corporate defendants.

187. The public interest favors protection of private personal information from potential stalkers and abusers, over the practice by State DMVs and computer database entities of profiting from the unrestrained sale of such information to individuals such as Raney and his confederates.

188. On good information and belief, certain defendants made false material misrepresentations and/or omissions to obtain said personal information from State DMV records and elsewhere, in violation of FDPPA and numerous other laws involving fraud, misrepresentation, mail & wire fraud, obtaining records by deceit, and the like.

189. Each said incident of license plate copying and unwanted subsequent contact further constitutes sufficient harassment, threatening conduct, and intimidating activity, to create reasonable fear in the minds of each plaintiff of serious and unpredictable physical harm, and to further violate FACE in each such instance, as well as FDPPA.

COUNT IX: CIVIL RICO VIOLATIONS

190. Defendants and each one of them with sufficient predicate acts of mail fraud, Hobbs Act violations, FACE violations, and other criminal misconduct not yet fully documented, are jointly and severally responsible and liable under RICO for engaging in an unlawful conspiracy, and consorting with unlawful enterprises against plaintiffs, and are thereby subject to penalties of treble damages and asset forfeiture.

COUNT X: EXEMPLARY DAMAGES, FORFEITURE, WORK

191. Certain reckless misconduct and omissions by defendants have been sufficiently reckless, wanton, outrageous, inhumane, and malicious to warrant substantial exemplary damage awards against each and every such defendant on behalf of each and every plaintiff and class member.

192. Said exemplary damage awards should be made sufficient to deter each defendant forever, and punish and prevent each said defendant from continuing the misconduct at issue, directly or indirectly, in any form, long into the future.

193. Defendants such as Raney, LeStourgeons, Hall, Rogers, and others, who have worked primarily at harassing women and terrorizing health care facilities for these many years, should have their harassment-related assets, property and buildings forfeited, and be ordered to work using any real world skills they may have to satisfy the foregoing requested judgments, and to break loose from their cult-like patterns of unlawful, tortious, obsessive, delusional, and irrational lawbreaking behavior.

VIII. TRIAL BY JURY REQUESTED

194. Plaintiffs request trial by jury on each issue of fact and damages as would be required under the common law and the usual practice of this Court.

IX. RELIEF AND JUDGMENTS REQUESTED

195. WHEREFORE, AWCC and each plaintiff respectfully urge this Court to grant and order the following, as well as other necessary and appropriate relief:

FACE and FDPPA INJUNCTIONS

(1) Preliminary and permanent injunctions barring each and every defendant from copying, writing down, logging, recording, inputting, transcribing, memorizing, and/or memorializing in any form whatsoever any vehicle identifying license plate number, telephone number, FAX number, E-mail address, and/or any other potentially identifying characteristic in, on, or of a vehicle and/or any of its occupants, within 1500 feet of any property line of AWCC.

(2) Preliminary and permanent injunctions barring each and every defendant from possessing and/or allowing in his or her proximity any camera of any kind or size, video or audio recording device or instrument of any kind or size, binoculars, telescope, visual magnifying device, microphone that is capable of recording audio transmissions and/or conversations, computer large or small, word processor, typewriter, gun, rifle, knife, machete, noxious chemical, bacteria, virus, and/or other dangerous weapon or substance within 1500 feet of any property line of AWCC.

{3} Accessing, or attempting to access in any way, distributing or attempting to distribute or disseminate in any way, directly or indirectly, personal information about any person associated with AWCC, its staff, patients, physicians, owners, service people, employees, independent contractors, and/or vendors, from any record of any kind, public or private, maintained, or provided to another person or entity, by any agency of the State of Florida, or of the United States, or any information gathering source whatsoever, including accessing by any defendant of personal information from CompuServe, AOL, unsolicited mail, FAX, E-mail, written or printed matter, package, and/or other material, device, or substance to AWCC, any physician, staff, patient, suspected patient, patient companion, and/or associate of same, and/or any member of the classes of plaintiffs, without prior approval of the Court.

(4) Preliminary and permanent injunctions prohibiting any and all defendants from destroying, defacing, concealing, and/or disseminating in any way, any information whatsoever in their actual or constructive possession, pertaining to any past or present AWCC patient, patient companion, visitor, physician, staff person, owner, service person, vendor, independent contractor, and/or employee, said injunction requiring each person served therewith to surrender, provide, and turn over all originals and copies in any form of any such information to an individual designated by the Court, with full hard copies of all such information being also provided to counsel for AWCC.

UNWANTED CONTACT INJUNCTIONS

(5) Preliminary and permanent injunctions prohibiting Meredith Raney, and any and all defendants, from sending or dispatching, directly or indirectly, any unsolicited mail, FAX, E-Mail, written or printed matter, package, box, parcel, and/or other matter, material, device, or substance to AWCC, any physician, staff or volunteer person, patient or companion, independent contractor, vendor, AWCC visitor, and/or associate of same, and/or any member of the plaintiff class, without informed written consent or prior approval of the Court.

FALSE COMPLAINT HARASSMENT

(6) Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from making any complaints without substantiating professional legal and medical reports, to any agency, subdivision, municipality, or other entity of the State of Florida, other State, or the United States, or any professional regulatory body, concerning AWCC, physicians, staff, patients, patient companions, owners, employees, independent contractors, property, and/or visitors, without leave of the Court.

HARASSMENT AND INTIMIDATION

(7) Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from unrequested telephoning, E-mailing, FAX-ing, harassing, intimidating, touching, assaulting, following, stalking, surveilling, contacting or attempting to contact, the AWCC facility, any AWCC patient, past-present-or future- patient companion, physician, staff member, employee, family member, vendor, or independent contractor, from or at .any place whatsoever, or at the AWCC vicinity, and/or at any place of residence or business or other activity of any such person, except as otherwise provided hereafter.

(8) Preliminary and permanent injunctions prohibiting Raney, and all defendants, their class(es), those acting in concert or participating with them, and any persons having actual or constructive notice of the injunction, from

(a) entering the property of AWCC,

(b) blocking, impeding, obstructing, or delaying access, ingress, or egress, to or from AWCC premises, and/or buffer zone areas where entry is sought by authorized person(s),

(c) gathering, congregating, picketing, purporting to counsel, demonstrating, patrolling, walking about, and/or entering that portion of public right-of-way or private property within 36 feet of the AWCC property line. This prohibition bars the defendants and all notified persons from crossing the Dixie Way street onto the AWCC property, driveways, and sidewalks uninvited by authorized persons at any time, period. It does not apply to owners or invitees of private property adjacent to AWCC using said property for purposes unrelated to surveilling AWCC, nor to inhibit legitimate mailbox access for residents of 1575 Dixie Way. It does prohibit defendants from spying, surveilling, video taping, tree & ladder & truck climbing from private property on the North side of AWCC, based upon the more comprehensive evidence of this abuse available now.

"FIGHTING WORDS"

{9) Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from yelling, shouting, screaming, the use of "fightintl words" such as "butcher," "baby killer," "murderer," "killer," "abortionist," "killing place," "abortuary," "abortion mill,~ "death," "killing," and similar expressions defamatory of AWCC, physicians, staff, or patients, and/or any form of noise-making, individually or artificially, above a reasonable conversational level, within 1500 feet of the AWCC property line, and further from displaying any signs, images, or symbols bearing any of said expressions or any substantial equivalent thereof.

HIGHWAY TRAFFIC HAZARD

(10} Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from being in the area within 150 feet of the traffic on U.S. Highway 1, and 1500 feet of the AWCC property line, except when traveling through the area to some other destination, or as otherwise authorized herein.

DEFAMATORY MAILBOX HAZARD

(Il) Preliminary and permanent injunctions directing defendant John "Jay" Rogers and Mark Hall to remove from the 1575 Dixie Way mailbox the defamatory expression "KILLING PLACE," and to replace same with nothing more than the street or thoroughfare number "1575" in black print or lettering, without more, in light of prior abuses.

TIME, PLACE, MASS, AND SIGN LIMITS

{12) Preliminary and permanent injunctions prohibiting any more than five (5) persons from assembling in any yard of the Spy House, 1575 Dixie Way, and/or any other property adjacent thereto, and/or under the direction or control of a defendant, except for legitimate social or business gatherings unrelated to AWCC and its activities, and limiting said five or fewer person gatherings to a maximum of two each week, with duration of each a maximum of one hour. Said five or fewer persons are limited to a maximum of two images or signs at any time, measuring no more than 2 x 3 feet, said signs to have no depiction of blood, gore, fetuses, embryos, or parts thereof, or any other visuals reasonably perceived as likely to shock or mislead viewers, and each sign is limited to black & white English or Spanish text, with readable and accurate translation. Each and every sign must bear a disclaimer on any side with any text and in the same Font size, type size & density, and color of print or lettering, which states:

"MEDICAL ABORTION IS AUTHORIZED BY FLORIDA LAW AND THE UNITED STATES CONSTITUTION AND HAS BEEN SANCTIONED AS SAFE BY THE AMERICAN MEDICAL ASSOCIATION"

MOVING VEHICLE & PERSON ZONE

(13) Preliminary and permanent injunctions establishing a five foot protective zone of separation for each and every individual, and vehicle, entering or leaving the AWCC area, and prohibiting intrusion upon that zone by Raney, and/or any defendant, and/or class member, as is reasonable and necessary in light of prior abuses, harassment, and accident potential. See U.S. v Scott, 975 F Supp 428, 431,432 (D Conn 1997}.

PREVENTION OF CHILD ABUSE RISKS

(14} Preliminary and permanent injunctions prohibiting defendants from bringing, directly or indirectly, any individuals with them to the AWCC vicinity who are under the age of fourteen years, that is, within 1500 feet of any AWCC property line.

MISREPRESENTATION LIMITATIONS

(15) Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from holding himself or themselves out as an "investigator," in the absence of any qualifying certification or licensure by the State of Florida, which must be clearly displayed on the person.

(16) Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from purporting to dispense medical advice, and/or any medical, laboratory, technical health care or nursing service, and/or from holding themselves out as qualified to provide such advice or service, in the absence of any qualifying certification or licensure by the State of Florida, which must be shown and displayed by the person dispensing said advice.

GARBAGE INVASIONS

(17) Preliminary and permanent injunctions prohibiting Raney, and any and all defendants, from approaching within 36 feet of the garbage, trash, refuse, or the like, of AWCC, any plaintiff, physician, patient, patient companion, staff person, employee, independent contractor, and/or vendor.

NECESSITY FOR PHONE TRAP

(18) An order authorizing and requiring any telephone service company to provide and install upon request one or more phone traps upon any and all phones of AWCC, physician{s), owners, staff, employees, and/or independent contractors, to detect, record, and monitor any and all incoming calls, transmissions, interceptions, or communications from whatever origin.

(19) Such other preliminary and permanent injunctive relief as shall appear necessary and appropriate.

NOTICE AND SERVICE

(20) An order providing that each and every provision of the injunction shall bind any and all persons having actual or constructive notice thereof, and that notice shall be provided by an appropriate sign in the vicinity, and proof of notice may be made by delivery of said injunction in writing or verbally to any person appearing in the vicinity to be at risk of a violation of any kind., said person to be notified and allowed to cease and desist prior to arrest.

DAMAGES, FORFEITURE, WORK

196. AWCC, each plaintiff, and each class member further respectfully urge the Court to award:

{1) appropriate actual, statutory, and exemplary damages as proven on each applicable count against each and every defendant, jointly and severally as well as reasonable costs, interest, expert witness fees, counsel fees and all other reasonable and necessary litigation expenses.

(2) forfeiture of sufficient and relevant assets of real and personal property of the defendants used in their unlawful and tortious activities.

(3) appropriate work orders requiring certain individual defendants to engage in lawful employment pursuits to pay off and satisfy these damages and judgment debts.

(4) orders setting aside real and personal property transfers made by defendants to avoid responsibility for the unlawful and tortious misconduct involved herein, and

(5) such other relief as shall be necessary and appropriate.

RESPECTFULLY SUBMITTED:
Roy Lucas <signed>
DC # 153957
c/o PO Box 1433
Melbourne, FL 32902-1433
TEL: 1-407-725-2413
FAX: 1-407-725-3847

Scott R Rost
FL # 779385
228 Park Ave North
Winter Park, FL 32789
TEL: 1-407-539-1140
FAX: 1-407-539-1126

Susan England, Esq
FL # 0186018
2805 Lakeview Drive
Fern Park, FL 32730
TEL: 1-407-339-4600
FAX: 1-407-331-3006

ATTORNEYS FOR AWCC ET AL PLAINTIFFS.