AMENDED COMPLAINT

This is an action by Mrs. Gennifer Flowers for defamation and false light against Mr. James Carville, Mr. George Stephanopoulos, Little, Brown & Company, and Hillary Rodham Clinton. Damages exceed the sum of $75,000, exclusive of interest, costs and attorney's fees.

JURISDICTION

1. This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1332, as the parties are of diverse citizenship and the amount in controversy, exclusive of interest and costs, exceeds seventy-five thousand dollars ($75,000.00).

PARTIES

2. Plaintiff Gennifer Flowers ("Plaintiff") is a citizen of the State of Nevada.

3. Defendant James Carville ("Carville") is, on information and belief, a citizen of the State of Virginia, residing at 424 South Washington St., Alexandria, VA 22314 and/or 325 Fishers Rd., Maurertown, VA 22644-2760. Defendant Carville is author of statements concerning Plaintiff.

4. Defendant George Stephanopoulos ("Stephanopoulos") is, on information and belief, a citizen of the State of New York, residing at 200 West 86th Street, New York, NY 10024. Defendant Stephanopoulos is author of statements concerning Plaintiff.

5. Defendant Little, Brown and Company is incorporated under the laws of the State of Massachusetts and is owned by Time Warner, Inc., 75 Rockefeller Plaza, New York, New York

10014-6990. Little, Brown and Company is the publisher of a book written by Defendant George Stephanopoulos entitled All Too Human: A Political Education.

6. Defendant Hillary Rodham Clinton is First Lady of the United States. Defendant Clinton currently resides at 105 Old House Lane, Chappaqua, New York 10514.

FACTS

7. During the 1992 presidential campaign, a "War Room" was created by the Clinton campaign to plot strategy for the campaign, and to attack and smear persons, including Plaintiff, who were perceived to be adverse to the candidacy of Bill Clinton and the interests of Defendant Clinton.

8. This "War Room" was organized and directed by Defendant Clinton, with the other two other principals of the War Room, Defendants Carville and Stephanopoulos, among others, carrying out the orders and desires of Defendant Clinton. For example, by virtue of her authority, Defendant Carville represented that "Hillary named the War Room." M. Matalin & J. Carville, All's Fair: Love, War and Running for President 243 (1994). Defendant Carville also represented that:

"When I was in the Marine Corps there was a way of finding out what was actually the story that didn't appear in any training manual. You're new to the regiment and you know who the colonel is: He's the regimental commander. You know who the executive officer is: He's the old guy who's getting ready to retire. But when you're having a beer at the off-base hangout every troop will tell you, 'Old Major Jones over there, you might not see him right on up the chain of command, but if you want something done he's the guy.' Well, you walk into Clintonland and you pick up this mythology pretty quick. The campaign scuttlebutt was that Hillary Rodham Clinton was somebody to deal with, a tough woman. A factor."

...

"You didn't have to be a genius in room dynamics to figure out the drift of her place in the campaign. You got it from her body language, from the deference with which people spoke to her, from the way she was referred to in the conversations that were breaking out around her. She has a way about her."

...

"There were about ten conversations going on at once [in the War Room], but when Hillary spoke they all sort of toned down a little bit."

Id., at 87-88.

Mrs. Clinton thus conceived of, ran, and used the War Room to smear, defame, and harm perceived adversaries, such as Plaintiff, in order that her husband, Bill Clinton, and she, could attain the benefits and trappings of the Office of the President of the United States and First Lady, respectively.

9. From the 1992 presidential campaign to the present, Defendants Carville and Stephanopoulos, and those acting in concert with them, have, at the direction of Defendant Clinton, continuously libeled and slandered Plaintiff, Gennifer Flowers, as well as held her in a false light, in order to smear, defame and harm her. Plaintiff had been implicated by the media in a personal relationship with Bill Clinton, and the conduct of Defendants was a means to destroy her credibility, reputation, livelihood, emotional well-being and deflect attention away from the truth.

10. As part of this campaign, which continues to the present, to smear defame and harm Plaintiff, Defendant Carville, in concert with, and at the direction of Defendant Clinton, caused false, misleading and defamatory statements about Plaintiff to be published. Among other things, Defendant Carville falsely accused Plaintiff of fabricating, for monetary gain, Plaintiff's claim that she had had a relationship with Bill Clinton:

"But the Star was paying her over $100,000 for her story, and things will change when dollars get involved."

M. Matalin & J. Carville, All's Fair: Love, War and Running for President 101 (1994).

Defendant Carville made this statement despite the fact that he and Defendant Clinton knew Plaintiff was telling the truth about Plaintiff's relationship with Bill Clinton, and in furtherance of their efforts to smear, defame and harm Plaintiff.

11. As part of Defendants' continuing campaign to smear, defame and harm Plaintiff, Defendant Carville, in concert with, and at the direction of Defendant Clinton, also characterized Plaintiff to the national media as a dishonest, loathsome and unsavory person. In response to a January 1992 press conference held by Plaintiff in which Plaintiff played audio tapes of conversations with Mr. Clinton -- tapes which confirm Mr. Clinton's personal relationship with Mrs. Flowers -- Defendant Carville stated:

" . . . you all are more interested in putting some bimbo on the air than in getting at the truth. And the truth is that this is just sleazy tabloid trash and you all should be ashamed of yourselves."

M. Matalin & J. Carville, All's Fair: Love, War and Running for President 114 (1994).

12. Defendant Carville's campaign, in concert with, and at the direction of Defendant Clinton, to smear, defame and harm Plaintiff included numerous personal attacks on Plaintiff intended to damage and/or destroy her credibility, reputation, livelihood, and emotional well-being, subject her to public hatred, contempt, and/or ridicule, and to further the interests of Bill Clinton and Defendant Clinton:

"We decided right away to launch the attack on Gennifer Flowers because we saw an opening: People thought she was a liar or worse. We did a focus group and found that women reacted much more negatively to her than men. One woman took a look at her and said, "She looks like a liar. And she ought to learn to dye her roots."

M. Matalin & J. Carville, All's Fair: Love, War and Running for President 112-13 (1994).

"I was the first surrogate to go after her. By going with the Star, taking the money, playing the aggrieved lover, she put herself in the line of fire, she was fair game. I thought, "Just don't call her a whore - but short of that, let'er rip."

Id. at 113.

"The only person I'm absolutely certain died their hair in this campaign was

Gennifer Flowers."

Id. at 390.

13. Over the years, and throughout the years of the Clinton Administration to the present, Defendant Carville's campaign, in concert with and at the direction of Defendant Clinton, to smear, defame, and harm Plaintiff, continued. For instance, on the television program Larry King Live, Defendant Carville continued to publish false and misleading statements about Plaintiff:

"One of the things is to remember, we'll go back to the Gennifer Flowers statement; I think the found that tape was doctored and CNN even found our, like 19 or 12 different places..."

Larry King Live: Larry King Interview of James Carville (CNN television broadcast Jan. 21, 1998).

14. On the television program Larry King Live, Defendant Stephanopoulos, in concert with and at the direction of Defendants Carville and Clinton, continued the campaign to smear, defame and harm Plaintiff, by causing the following false, misleading and defamatory statements about Plaintiff to be published:

CALLER: George [Stephanopoulos], I heard you speak earlier this year in the fall, and you had claimed when you spoke that you believed Clinton in the case of Gennifer Flowers...

***

STEPHANOPOULOS: ...know for a fact that the story she gave the tabloid, the "Star" wasn't true.

LARRY KING: So it wasn't 12 months -- 12 years, could it have been eight?

STEPHANOPOULOS: I have no idea. You know the truth was, I did not ask him.

***

BILL KRISTOL: ...Gennifer Flowers seems to me to have turned out to have had a pretty good track record. I don't know that there was so much concoction there.

STEPHANOPOULOS: That's not true at all. I mean, I don't have the "Star" story in front of me right now, but she was making up trips when he was in other states. There was an awful lot there that was probably untrue.

KING: The tape was damaging?

STEPHANOPOULOS: The tape was damaging, but it was also doctored.

[emphasis added]

KRISTOL: ...There is no evidence of doctoring of what had been said.

STEPHANOPOULOS: Absolutely untrue. Both Brooks Jackson of CNN and KCBS, unfortunately that is something I did live with...KCBS, in 1992 showed that the tapes were doctored and that's what we said in 1992.

Larry King Live: Larry King Interview of George Stephanopoulos (CNN television broadcast, Feb. 2, 1998).

15. Defendant Stephanopoulos, acting in concert with, and at the direction of Defendants Carville and Clinton, continued to smear, defame, and harm Plaintiff by causing the following false and misleading statements about Plaintiff to be published:

Since Clinton had admitted to "problems" in his marriage, we knew there had to be at least one woman out there whose charges we couldn't deny. More likely, many more. So we tried to avoid the trap by attacking the tabloid messenger. Paul [Begala] cooked up some lines about other Star scoops like the discovery of "alien babies," and I came up with a no-comment denial: "I'm not going to comment on that tabloid trash."

...

Now my initial doubts, which I had partially pushed aside earlier on the plane, were swept away by righteous anger. I seethed as Clinton answered the Fox reporter and blew up when CeCe Connelly of the Associated Press asked Clinton if the Star story were true."You can't do that," I barked at CeCe. "You're trying to create a story with our response." Fox TV we could handle, but the prospect of a credible news organization like the AP broadcasting this garbage around the globe was trouble -- and it drove me crazy. I went straight to the phone to call John King, the AP's chief political reporter in Washington. "You can't put this crap on the wire," I said.

...

But any fun I was having faded fast a week later, when Gennifer Flowers flipped. Another Thursday, another Star story, another garbage day. But this one was

more serious. A key witness for the defense was now part of the prosecution -- and she said she had tapes. Early that morning, from a pay phone at National Airport's private terminal, I made my daily pre-dawn call to Carville.

"You gotta get to the airport," I said. "We need you to come to New Hampshire with us."

"What's goin' on?"

"Some woman in Arkansas is claiming she slept with..."

"Ah shit George. Is that all?"

"No, it's bad. You gotta come."

James resisted, but he wasn't going to miss this. There hadn't been much for him to do when everything was going so well in December; now we needed his gut. I felt better just having him around. The Cajun in him spoke to the Greek in me. As with Klein, we fed on each other's dark side, and I loved just listening to him talk.

G. Stephanopoulos, All Too Human: A Political Education 56-59 (1999)

Stephanopoulos further represented:

Clinton insisted that the Flowers story was untrue, so any admission of a sexual affair with Gennifer was off the table. But we discussed whether he should make a general admission of adultery -- explicitly, unequivocally, using that word instead of a euphemism like "problems in our marriage." . . . Once the two threshold questions were set aside with our empty plates, Mandy and James took control of the meeting and focused on our goals: to appear candid about past marriage troubles, to define character as a constant struggle for personal improvement, and to confront the country with the question of whether the presidential campaign should be about one candidate's past or the whole country's future. I synthesized the strategy in hand-lettered notes that I gave to Clinton when Hillary adjourned the meeting around one a.m.: . . .You're sad about Gennifer, not angry. You don't know why she changed her story, but you're not going to be diverted.

Id. at 65.

The conversation sounded stilted; her questions were leading -- maybe the tapes were doctored? It's a setup. Later investigations by CNN and KCBS would show that the tapes were "selectively edited," but there was no getting around the fact that by talking to her on the phone, Clinton had put everything we had worked for at risk.

Id. at 68.

The ultimate rationale for getting my hands dirty and doing what it took to win -- from attacking Gennifer Flowers to working with Dick Morris to accepting welfare reform -- was not just the thrill of the fight or my need to be on top, but also my belief that progressive ideals would be better protected as long as Clinton was president.

Id. at 439-440.

16. From 1992 to the present, Defendants Carville and Stephanopoulos, in concert with, and at the direction of Defendant Clinton, have acted in a consistent, deliberate pattern of behavior, calculated to smear, defame and harm Plaintiff and her reputation. Since the filing of the initial complaint, further evidence has surfaced that the campaign to smear, defame, and harm Plaintiff was instigated and directed by Defendant Clinton. During an interview of Mrs. Clinton's close friend and confidante, Gail Sheehy, she attributed the following statements Defendant Clinton:

STONE PHILLIPS: 1992, you watched Mrs. Clinton as she watched Gennifer Flowers on television describing her relationship with Bill Clinton?

GAIL SHEEHY: I was flying with her knee to knee on that campaign.

PHILLIPS: You write, "Hillary's eyes took this in with the glittering

blink of a lizard. Not a tremor of emotion crossed her face, nothing personal."

SHEEHY: She did not flinch. I mean, I found it the most astonishing thing I have ever seen.

PHILLIPS: (Voiceover) And what she heard later that same night, Gail Sheehy says, would be even more revealing.

SHEEHY: She immediately went into battle mode.

PHILLIPS: Ordering up dirt on Gennifer Flowers?

SHEEHY: That's right. And on the plane with me she was fulminating over, 'Bill just doesn't take it seriously, I don't know what I can do. He says that nobody will believe her. I said, 'What do you mean nobody will believe her? They'll say why were you even talking to this woman?' And finally I said, 'What would you do if you had Gennifer Flowers in front of you?' And she says, 'If I had her on the stand I would crucify her.' She never said a word about Bill.

Dateline: Stone Phillips Interview of Gail Sheehy (NBC television broadcast, Monday, November 29, 1999).

17. During the period leading up to and during the Clinton Administration, Plaintiff's residence has been broken into at least three (3) times. Plaintiff has also been threatened. For example, Plaintiff's mother has received a threat from a caller stating: "Your daughter is better off dead."

18. In his book, Bill and Hillary: The Marriage, Christopher Anderson reveals that in 1982 Defendant Clinton hired a private investigator named Ivan Duda to investigate her husband, Bill Clinton. On information and belief, Defendant Clinton hired and worked with other private investigators, such as Jack Palladino, to employ against Plaintiff. (Conversely, it has recently been revealed that Bill Clinton also hired a private investigator to investigate Defendant Clinton.) Duda informed Defendant Clinton that Bill Clinton was in fact having an affair with Gennifer Flowers:

"Duda's dossier on Bill focused on those women the governor was seeing with some degree of frequency. 'I came up with eight women,' the investigator said. Gennifer Flowers was at the top of the list, but that was not the name that Hillary found most upsetting. 'What really ticked her off,' Duda said, 'was that one of them was an employee at the Rose Law Firm..."

...

Duda claimed his report 'enabled Hillary to go to Bill and work out arrangements for keeping those women quiet -- by offering them jobs, promotions, contracts to better positions, or whatever it took to keep everything hush-hush.'

...

'Hillary's main job as a wife,' Duda added, 'is to protect Bill from himself-- to pretend, playact, deny, lie, and cover his rear end.'"

C. Anderson, Bill and Hillary: The Marriage 185 (1999).

Therefore, in directing Defendants Carville and Stephanopoulos to smear, defame and harm Plaintiff and her reputation, Defendant Clinton knew the statements made by Defendants Carville and Stephanopoulos were in fact false, misleading, defamatory, and would hold Plaintiff in a false light.

19. Therefore, when Defendant Clinton appeared in 1992 on the television program "60 Minutes" with her husband, Bill Clinton, and made the following false and/or misleading statements, Defendant Clinton knew that Plaintiff was telling the truth when Plaintiff stated that Plaintiff had had an affair with Bill Clinton:

STEVE KROFT: How do you know her [Gennifer Flowers]: How would you describe your relationship?

BILL CLINTON: Very limited, but until this, you know, friendly, but limited. I have--I met her in the late '70's when I was attorney general. She was one of a number of young people who were working for the television stations around Little Rock...So that's how-- that's who she is.

KROFT: Was she a friend, an acquaintance? Did your wife know her?

BILL CLINTON: Yes.

HILLARY CLINTON: Oh, sure.

BILL CLINTON: She was an acquaintance. I would say a friendly acquaintance.

HILLARY CLINTON: Mm-hmm.

...

KROFT: She's alleging and has described in some detail in the supermarket tabloid what she calls a 12-year affair with you.

BILL CLINTON: It--that allegation is false.

HILLARY CLINTON:When this woman first got caught up in these charges, I felt as I felt about all these women, that, you know, they've just been minding their own business, and they got hit by a meteor. I mean it was no fault of their own. We reached out to them. I met with two of them to reassure them. They were friends of ours. I felt terrible about what was happening to them. You know, Bill talked to this woman every time she called distraught, saying her life was going to be ruined. And, you know, he'd get off the phone and tell me that she said the sort of wacky things which we thought were attributable to the fact that she was terrified.

60 Minutes: Governor and Mrs. Bill Clinton Discuss Adultery Allegations (CBS television broadcast, Jan. 26, 1992)

20. In directing Defendants Carville and Stephanopoulos to smear, defame and harm Plaintiff and her reputation, Defendant Clinton therefore acted maliciously and/or in reckless disregard of what she knew to be the truth, and with the intent to smear, defame and harm Plaintiff, as well as hold Plaintiff in a false light. On information and belief, Defendants Carville and Stephanopoulos also knew, or had reason to know, that Plaintiff was telling the truth and therefore acted maliciously and/or recklessly in smearing, defaming, and harming Gennifer Flowers.

21. The publications of these false, misleading, disparaging and defamatory statements were intended to defame, and did defame Plaintiff, and were intended to, and did hold Plaintiff in a false light, by depicting her as a dishonest, loathsome and unsavory person, among other disparagements intended to damage and/or destroy her personal and professional reputations, and career, and subject her to public hatred, contempt, and/or ridicule.

22. The publication of these false, misleading, disparaging and defamatory statements

were intended to, and did cause substantial harm to Plaintiff's personal and professional reputations and career, such as lost business opportunities.

23. The publication of these false, misleading, disparaging and defamatory statements

also caused Plaintiff to suffer emotional distress, shame, mortification, hurt feelings, embarrassment and personal humiliation.

COUNT I

(Defamation -- All Defendants)

24. Plaintiff realleges paragraphs 1 through 23 as if fully set forth herein.

25. At all relevant times, Defendants Carville and Stephanopoulos acted individually and as the instrumentality of Defendant Clinton in Defendant Clinton's efforts to defame Plaintiff, to harm Plaintiff's personal and business reputation and business opportunities, and to cause Plaintiff to suffer emotional distress, embarrassment, and personal humiliation.

26. Defendant Carville composed and caused the statements set forth in paragraphs 8 and 10-13 of this complaint to be published in his book All's Fair: Love, War and Running for President, as well as on the CNN television program Larry King Live, on January 21, 1998.

27. The statements by Carville are false, misleading, disparaging and defamatory towards Plaintiff.

28. Defendant Stephanopoulos composed and caused the statements set forth in paragraphs 14 and 15 of this complaint to be published on the CNN program Larry King Live, on February 2, 1998, and in his 1999 book, All Too Human: A Political Education, published by Defendant Little, Brown & Company.

29. The statements by Stephanopoulos are false, misleading, disparaging and defamatory towards Plaintiff.

30. In composing and causing the statements to be published on the CNN television program Larry King Live, in the book All Too Human: A Political Education, as well as the book All's Fair: Love, War and Running for President, Defendants Carville, Stephanopoulos, and Little Brown & Company, and those acting in concert with them, including Defendant Clinton, acted with malice, had knowledge that the statements contained therein were false, and/or acted with a reckless disregard for the truth and without reasonable grounds to believe that the statements contained therein were true. In fact, Defendants and those acting in concert with them, conspired to have Plaintiff prosecuted wrongfully as a further means to harm her and her reputation.

31. As a proximate result, Plaintiff suffered substantial special, general and exemplary damages, including but not limited to loss of personal and business reputations and lost business opportunity, emotional distress, embarrassment and personal humiliation.

WHEREFORE, Plaintiffs demands judgment against Defendants Carville, Stephanopoulos and Little, Brown and Company, and Hillary Rodham Clinton, jointly and severally, for special, general and exemplary damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.

COUNT II

(False Light -- All Defendants)

32. Plaintiff realleges paragraphs 1 through 31 as if fully set forth herein.

33. At all relevant times, Defendants Carville and Stephanopoulos acted individually and as the instrumentality of Defendant Clinton in Defendant Clinton's efforts to portray and hold Plaintiff in a false light, to harm Plaintiff's personal and business reputation and business opportunities, and cause Plaintiff to suffer emotional distress, embarrassment, and personal humiliation. The statements place Plaintiff in a false light that is highly offensive to a reasonable person.

34. In composing the statements and causing them to be published, on the CNN television program Larry King Live, in the books All Too Human: A Political Education, and All's Fair: Love, War and Running for President Defendants Carville, Stephanopoulos, Little, Brown & Company, and those acting in concert with them, including Defendant Clinton, acted with malice, had knowledge that the statements were false, and/or acted with reckless disregard for the false light

in which Plaintiff was being placed.

35. As a proximate result, Plaintiff suffered substantial damages including but not limited to, loss of personal and business reputations and lost business opportunity, emotional distress, embarrassment and personal humiliation.

WHEREFORE, Plaintiffs demands judgment against Defendants Carville, Stephanopoulos and Little, Brown and Company, and Hillary Rodham Clinton, jointly and severally, for special, general and exemplary damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.

COUNT III

(Invasion of Privacy (Publicity Given to Private Life) --

Defendant Hillary Rodham Clinton)

36. Plaintiff realleges paragraphs 1 through 35 as if fully set forth herein.

37. The actions of Defendant Clinton in, for example, hiring private investigators, and willfully and intentionally obtaining and disclosing private facts about Plaintiff, such as involving her parental, family, marital and sexual relations and insurance claims, among other areas, were offensive and objectionable to a reasonable person of ordinary sensibilities. On information and belief, Defendant Clinton, and those acting in concert with her, was behind the unlawful entry into the residence of Plaintiff.

38. As a proximate result of the unlawful conduct of Defendant Clinton, Plaintiff suffered substantial damages, including but not limited to out-of-pocket expenses and loss of time necessarily incurred in investigating and responding to Defendant Clinton's unlawful conduct, emotional distress, mental anguish, and loss of reputation.

39. As the unlawful conduct of Defendant Clinton was, on information and belief, politically and/or improperly motivated (e.g., to obtain and publicly disseminate potentially embarrassing and/or damaging information concerning Plaintiff) and lacked any proper or legal purpose, such unlawful conduct was not only intentional, and/or willful, and/or malicious and/or outrageous, but demonstrated reckless and/or willful disregard for Plaintiff's privacy rights such that an award of punitive damages is warranted.

WHEREFORE, Plaintiffs demands judgment against Defendants Carville, Stephanopoulos and Little, Brown and Company, and Hillary Rodham Clinton, jointly and severally, for special, general and exemplary damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.COUNT IV

(Invasion of Privacy (IntrusionUpon Seclusion) --

Defendant Hillary Rodham Clinton)

40. Plaintiff realleges paragraphs 1 through 39 as if fully set forth herein.

41. The actions of Defendant Clinton in, for example, hiring private investigators, and willfully and intentionally intruding upon Plaintiff's reasonable expectation of solitude and seclusion, such as involving her parental, family, marital and sexual relations and insurance claims, among other areas, were highly offensive and objectionable to a reasonable person. On information and belief, Defendant Clinton, and those acting in concert with her, was behind the breaking and entering into the residence of Plaintiff.

42. As a proximate result of the unlawful conduct of Defendant Clinton, Plaintiff suffered substantial damages, including but not limited to out-of-pocket expenses and loss of time necessarily incurred in investigating and responding to Defendant Clinton's unlawful conduct, emotional distress, mental anguish, and loss of reputation.

43. As the unlawful conduct of Defendant Clinton was, on information and belief, politically and/or improperly motivated (e.g., to obtain and publicly disseminate potentially embarrassing and/or damaging information concerning Plaintiff) and lacked any proper or legal purpose, such unlawful conduct was not only intentional, and/or willful, and/or malicious and/or outrageous, but demonstrated reckless and/or willful disregard for Plaintiff's privacy rights such that an award of punitive damages is warranted.

WHEREFORE, Plaintiffs demands judgment against Defendants Carville, Stephanopoulos and Little, Brown and Company, and Hillary Rodham Clinton, jointly and severally, for special, general and exemplary damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.

COUNT V

(Conspiracy -- All Defendants)

44. Plaintiff realleges paragraphs 1 through 43 as if fully set forth herein.

45. Defendants Carville, Stephanopoulos, and Clinton, acting individually and/or in concert, tacitly or explicitly agreed to participate in the unlawful conduct described in paragraphs 7-43, and or tacitly or explicitly agreed to perform certain lawful acts in an unlawful manner.

46. The unlawful conduct, by one or more of these Defendants, alleged in paragraphs 7-43, and/or the performance, by one or more of the Defendants of certain lawful acts in an unlawful manner, caused injury to Plaintiff.

47. Upon information and belief, one or more these Defendants, who were parties to the agreement, performed the injury-producing unlawful conduct.

48. Upon information and belief, the injury-producing unlawful conduct was done pursuant to and in furtherance of a common scheme to smear, defame, violate the privacy rights, and harm Plaintiff, as well as hold her in a false light.

WHEREFORE, Plaintiff demands judgment against Defendants Carville, Stephanopoulos, and Hillary Rodham Clinton, jointly and severally, for special, general and exemplary damages, punitive damages, prejudgment interest, postjudgment interest, costs, attorney's fees and such other relief as the Court deems appropriate.

Plaintiff demands trial by jury on all issues so triable.

________________________________

Larry Klayman, Esq.

Paul J. Orfanedes, Esq.

JUDICIAL WATCH, Inc.

501 School Street, SW

Suite 725

Washington, DC 20024

(202) 646-5172

________________________________

Rex Bell, Esq.

John P. Lukens, Esq.

Bell, Lukens & Kent

550 East Charleston, Suite B

Las Vegas, Nevada 89104

(702) 387-6156

Counsel for Plaintiff