Sterling E

Sterling E. Norris, Esq. (SBN 040993)

James F. Marshall, Esq. (SBN 126030)

JUDICIAL WATCH, INC.

2540 Huntington Drive, Suite 201

San Marino, CA 91108-2601

(626) 287-4540

Larry Klayman, Esq.

(Not a member of California Bar)

JUDICIAL WATCH, INC.

501 S. School Street, S.W., Suite 725

Washington, D.C. 20024

(202) 646-5172

Attorneys for Plaintiffs

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES, CENTRAL DISTRICT

JESSE LEE PETERSON, an individual, and THE BROTHERHOOD ORGANIZATION OF A NEW DESTINY, a nonprofit California corporation,

Plaintiffs,

JESSE JACKSON, an individual; JONATHAN JACKSON, an individual; GREGORY MATHIS, an individual; RAINBOW/PUSH COALITION, an entity of unknown form; and DOES 1-50, inclusive,

Defendants.

______________________________________

)

Case No.

Unlimited Civil Case

VERIFIED COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF, AND DECLARATORY RELIEF:

1. ASSAULT;

2. BATTERY;

3. FALSE IMPRISONMENT;

4. INTENTIONAL INFLICTION OF

EMOTIONAL DISTRESS;

5. VIOLATIONS OF CIVIL RIGHTS;

6. INTENTIONAL INTERFERENCE WITH

PROSPECTIVE ECONOMIC

ADVANTAGE; AND

7. UNFAIR BUSINESS PRACTICES

2. PETERSON is an ordained Christian minister and the founder and president of Plaintiff THE BROTHERHOOD ORGANIZATION OF A NEW DESTINY (“BOND”), a California nonprofit corporation and national religious organization headquartered in the City and County of Los Angeles, California. The BOND Mission Statement is “Rebuilding the Family by Rebuilding the Man.” The BOND Vision Statement is “To Help Men and Their Families, Particularly in Major Urban Areas, Find Spiritual and Personal Freedom through Our Personal Development Programs and Community Outreach and Renewal Efforts.” Stressing the importance of character, self-reliance, honesty, integrity, and helping others through patience, BOND helps men and their families regain control of their lives and overcome life’s challenges. BOND’s membership is open to all people of good will.

3. On information and belief, Defendant JESSE JACKSON (“JACKSON”) is an individual who resides in Chicago, Illinois, and does business and is found inter alia in the County of Los Angeles, California. JACKSON is a self-described civil rights leader, a powerful member of the Democrat Party, and a former Democrat candidate for President of the United States. On information and belief, JACKSON despises minority conservatives and Republicans. JACKSON is and was at all relevant times the founder and head of RAINBOW/PUSH COALITION.

4. On information and belief, Defendant RAINBOW/PUSH COALITION (“PUSH”) is an entity, organization, and/or association of unknown form which has offices, operations, and members and is found in the County of Los Angeles, California. JACKSON is and at all relevant times has been a director, officer, managing agent, and/or employee of PUSH and, in all matters alleged below, was acting within the course and scope of that relationship. On information and belief, PUSH describes itself as nonpartisan but functions as a proxy for the Democrat Party, seeks to keep minorities within the Democrat Party, and/or despises minority conservatives and Republicans.

5. On information and belief, PUSH is an alter ego of JACKSON, and JACKSON is an alter ego of PUSH, in that JACKSON now and at all relevant times has completely dominated and controlled the assets, operations, activities, policies, programs, procedures, strategies, and tactics of PUSH, failed to observe important corporate formalities, and used the assets, facilities, and employees of PUSH for personal affairs and purposes, as if those assets, facilities, and employees belonged to and/or worked for JACKSON personally, to such an extent that any adherence to the fiction of the separate existence of PUSH as a person or entity distinct from JACKSON would permit the abuse of a corporate or similar privilege of limited liability, if any, and would promote injustice by allowing Defendants to evade liability or veil assets that should in equity be used to satisfy the judgment sought by PETERSON and BOND.

6. On information and belief, Defendant JONATHAN JACKSON (“JONATHAN”) is an individual who resides, does business, and is found in the County of Los Angeles, California, and is also a son of JACKSON. On information and belief, JONATHAN is a member of the Democrat Party and a leftist who despises minority conservatives and Republicans. On information and belief, JONATHAN is and at all relevant times has been a director, officer, managing agent, and/or employee of PUSH and, in all matters alleged below, was acting within the course and scope of that relationship.

7. On information and belief, Defendant GREGORY MATHIS (“MATHIS”) is an individual who resides, does business, and/or is found in the County of Los Angeles, California. MATHIS is a former Michigan state court judge who hosts and at all relevant times hosted a “reality-based” nationally televised court show known as “Judge Mathis.” MATHIS describes himself and is publicized as a committed civil rights activist who claims to have triumphed over a personal history of lawlessness and criminality involving street gangs, guns, drugs, and jail. On information and belief, MATHIS is a close personal friend of JACKSON and has worked on JACKSON’s political campaigns as a Democrat candidate. On information and belief, MATHIS is a member of the Democrat Party and a leftist who despises minority conservatives and Republicans.

8. The true names and capacities of Defendants DOES 1 through 50 are unknown to PETERSON at this time and are accordingly being sued by such fictitious names under California Code of Civil Procedure Section 474. On information and belief, given the large number of persons involved in the mob attack set forth below, these DOES include inter alia individuals and/or other persons that are residents of California. On information and belief, given the mob attack set forth below, some or all of the DOES are Democrats and leftists who despise minority conservatives and Republicans. PETERSON and BOND will amend this pleading to show the true names and capacities of DOE Defendants when these facts have been ascertained.

9. On information and belief, each DOE Defendant is in some manner responsible for the events, happenings, threats, injury, and damages to PETERSON and BOND alleged herein.

10. On information and belief, each Defendant is and at all relevant times has been an authorized agent, employee, joint venturer, partner, or co-conspirator of other Defendants, and at all relevant times (a) acted in the course and scope of such relationship; (b) was aware of and/or ratified acts of other Defendants; (c) committed tortious acts in concert with other Defendants; (d) knew that the other Defendants’ conduct constituted a breach of duty and gave substantial assistance or encouragement to the other Defendants so to conduct themselves; and/or (e) gave substantial assistance to the other Defendants in accomplishing a tortious result when such Defendant’s conduct, separately considered, was a breach of duty to PETERSON and/or BOND.

COMMON ALLEGATIONS

11. On information and belief, Toyota Motor Sales U.S.A., Inc. (“Toyota”) is and at all relevant times has been an automotive company that has offices and does business in the County of Los Angeles, California, and is and for decades has been an equal opportunity employer with affirmative action and diversity programs benefitting minorities and minority-owned businesses without regard to ideological and political affiliation.

12. On information and belief, Toyota undertook to develop and institute what is now known as “Toyota’s 21^st Century Diversity Strategy: A Comprehensive Program for Minority Participation in Toyota Today and Tomorrow” (the “Toyota Strategy”). On information and belief, a true and correct copy of a Toyota document entitled “TOYOTA’S 21^ST CENTURY DIVERSITY STRATEGY: A Comprehensive Program for Minority Participation in Toyota Today and Tomorrow” is attached hereto and marked as Exhibit “A.” On information and belief, it was at all relevant times Toyota’s intention that the Toyota Strategy would be nonpartisan and would be implemented and administered without regard to political and ideological affiliation.

13. On information and belief, JACKSON and PUSH sought to interject themselves into the Toyota Strategy, and to take control of its implementation and administration, by means of an express or implied threat of adverse publicity and/or a possible boycott of Toyota automobiles by supporters and/or members of JACKSON and PUSH, for the purpose of (a) obtaining monetary payments to JACKSON and/or PUSH as a precondition for minorities to benefit from the Toyota Strategy, (b) increasing the membership of and/or contributions to PUSH and JACKSON, and (c) holding minorities within the Democrat Party.

14. On information and belief, based on the documentation attached hereto and marked as Exhibit “A” and information published on Toyota’s website, it is and at all relevant times has been Toyota’s intention to implement and administer the Toyota Strategy directly from within Toyota, as opposed to indirectly through the auspices of JACKSON and PUSH, and without regard to political and ideological affiliation.

15. On or about December 10, 2001, a meeting of the Los Angeles Trade Bureau Forum was held at the Los Angeles Chamber of Commerce (the “Meeting”). The Meeting was open to the public and took place at 350 South Bixel Street, Los Angeles, CA 90017. On information and belief, JACKSON and PUSH organized, controlled, dominated, and ran the Meeting. PUSH publicized and promoted the event as a meeting with JACKSON and unnamed Toyota officials.

16. PETERSON and BOND attended the Meeting, among other reasons, to learn whether and to what extent BOND, its members, and those assisted by BOND might participate in and benefit from the Toyota Strategy, e.g. through training and job programs for inner city youth or direct funding and/or contributions by Toyota to BOND. PETERSON and BOND also sought to meet with appropriate Toyota officials to provide them with information about BOND.

17. During the Meeting, JACKSON, PUSH, and Toyota announced inter alia that it would award $700 million worth of contracts to minority-owned businesses in 2002 as part of the Toyota Strategy. JACKSON and PUSH also announced that J.L. Armstrong -- a close personal friend of JACKSON and/or a member and strong supporter of PUSH -- had been promoted to a key management position in Toyota and would be the key liaison between Toyota and minority businesses for the $700 million worth of contracts. JACKSON and PUSH orchestrated and ran the Meeting and distributed documents in such a way as strongly to imply that, for all practical purposes, it would be necessary for businesses to pay from $250 to $2,500 annually to an organization called “The International Trade Bureau” in order to have a reasonable chance of participating in the $700 million worth of contracts to be awarded through JACKSON’s and PUSH’s key man within Toyota (i.e. J.L. Armstrong). On information and belief, The International Trade Bureau is part of PUSH and, for the reasons set forth in Paragraph 5 supra, is the alter ego of JACKSON.

18. During a question-and-answer session with a Toyota representative at the Meeting, PETERSON expressed concern, individually and as the president of BOND, that young people assisted by BOND might be excluded from training programs and other diversity efforts offered by Toyota because (a) PETERSON is a conservative and a Republican; (b) many of BOND’s members are perceived to have conservative and Republican affiliations; (c) JACKSON and PUSH are intensely hostile toward minorities who have conservative and Republican affiliations; and/or (d) JACKSON and PUSH appeared to be positioned as the de facto gatekeepers of Toyota contracts because inter alia JACKSON’s and PUSH’s key man, J.L. Armstrong, was on the inside of Toyota in a key management position.

19. During the Meeting, PETERSON tried to use the question-and-answer session to ask a Toyota official how Toyota would ensure that JACKSON, PUSH, and their agents do not discriminate against minorities who have or are perceived as having Republican and conservative affiliations.

20. PETERSON’s remarks and questions during the question-and-answer session were orderly but were met with loud, angry, and unruly outbursts by JACKSON, PUSH, and their agents. In an attempt to silence and marginalize PETERSON and any others having or perceived as having Republican and conservative affiliations, to incite a hostile reaction from the agents of JACKSON and PUSH, and to manipulate Toyota, JACKSON and PUSH denigrated PETERSON and his stated concerns as involving “some parasites, who want to pick up apples from trees they didn’t shake.” As a result, PETERSON was repeatedly interrupted, called offensive names (including inter alia “stupid” and “nigger”), and shouted down by JACKSON, PUSH, and their agents, and could not obtain satisfactory answers to his questions of Toyota.

21. After the foregoing disturbances caused by JACKSON, PUSH, and their agents, JONATHAN and two other agents of JACKSON and PUSH positioned themselves immediately in front of and behind PETERSON and glared at him menacingly for the rest of the Meeting. These acts of JONATHAN and other agents of JACKSON and PUSH were visible to JACKSON and/or other officers, directors, or managing agents of PUSH, all of whom made no effort to stop this threatening behavior but instead approved and ratified it by permitting it to continue.

22. At the end of the Meeting, when PETERSON rose to leave his seat, JONATHAN moved closer to PETERSON and stood in his way to obstruct his only pathway for leaving the area where he had been seated. After a short but appreciable period of confinement, PETERSON was able to escape from JONATHAN. On information and belief, JONATHAN engaged in these acts with the intent of intimidating PETERSON, preventing his further interaction with Toyota officials, and silencing further criticism of the ongoing JACKSON/PUSH shakedown of Toyota and minority businesses seeking contracts with Toyota. These acts of JONATHAN were visible to JACKSON and/or other officers, directors, or managing agents of PUSH, all of whom made no effort to stop JONATHAN’s threatening behavior but instead approved and ratified it.

23. After escaping JONATHAN’s initial confinement, PETERSON went over to a refreshments table to get a cup of coffee. While PETERSON was standing at the refreshments table, JONATHAN approached and wilfully, intentionally, and maliciously shoved PETERSON. These acts of JONATHAN were visible to JACKSON and/or other officers, directors, or managing agents of PUSH, none of whom did anything to stop JONATHAN’s misconduct but instead approved and ratified it.

24. PETERSON objected to being shoved by JONATHAN and told JONATHAN that he was not allowed to touch PETERSON, whereupon JONATHAN started yelling and a loud, unruly, and threatening crowd formed around PETERSON. Over the next several minutes, the crowd grew and escalated into a very loud, unruly, and threatening mob, several people deep all around, comprised of JACKSON, JONATHAN, MATHIS, and other agents of JACKSON and PUSH. Confined in the middle of this menacing mob, PETERSON feared for his life.

25. JACKSON, JONATHAN, and MATHIS incited, participated in, and egged on the escalating mob. JACKSON, JONATHAN, MATHIS, and/or other agents of JACKSON and PUSH shouted the word “nigger” and other offensive names inter alia at PETERSON. JONATHAN shouted “suck my dick!” and other obscenities at PETERSON. Abandoning all restraint and semblance of judicial decorum, MATHIS taunted PETERSON inter alia about having no one to rescue him from the mob, saying inter alia “where’s your buddy [Bill] O’Reilly [of Fox News] now?” Incited and egged on by JACKSON, JONATHAN, and MATHIS, other members of the mob screamed at PETERSON, called him offensive names (including inter alia the word “nigger”), and made many threatening gestures. JONATHAN lunged at PETERSON. JACKSON and others yelled inter alia, “Get his ass out of here” and similar threats of physical seizure and expulsion. These and similar acts continued for several minutes with PETERSON confined by the mob. JACKSON and PUSH did nothing to quiet or restrain the mob in any way. Instead, JACKSON and PUSH actively incited, participated in, egged on, approved, and ratified the mob attack.

26. PETERSON was unable to escape the mob. After the mob had accosted, encircled, and confined PETERSON for several minutes, another employee of BOND tried to rescue him by physically snatching him from the mob and moving him toward an exit. The mob pursued PETERSON toward the exit, continuing to accost, encircle, confine, shout at, and threaten him the entire time he was being pushed toward the exit. JACKSON and PUSH did nothing to restrain, but actively incited, participated in, egged on, approved, and ratified the mob pursuit.

27. On information and belief, JACKSON, JONATHAN, MATHIS, PUSH, and their agents despise, hate, and/or bear ill will, anger, and/or rage toward PETERSON and BOND because of (a) their open disagreement with and challenges to the strategies, tactics, and actions of JACKSON and PUSH, (b) the conservative and Republican affiliation of PETERSON, and (c) the perceived conservative and Republican affiliations of certain members of BOND (which itself is nonpartisan).

28. On information and belief, the foregoing actions of JACKSON, JONATHAN, MATHIS, PUSH, and their agents were motivated by (a) their contempt, hatred, ill will, anger, and/or rage toward PETERSON and BOND; (b) the desire of JACKSON and PUSH to obtain substantial sums of money annually from those who wanted to benefit from the Toyota Strategy and the $700 million worth of contracts; and (c) concern on the part of JACKSON, JONATHAN, MATHIS, PUSH, and their agents that PETERSON, unless immediately silenced, would clarify for those present at the Meeting that minorities and minority businesses need not pay any tribute to JACKSON, PUSH, or their affiliates as a prerequisite of dealing with Toyota.

29. On information and belief, JACKSON, PUSH, and their agents have dealt with other major corporations in substantially the same manner that they dealt with Toyota, as set forth in detail above. JACKSON and PUSH announced at the Meeting that those in attendance need not worry if they do not enter into contracts with Toyota, because JACKSON and PUSH would soon attempt to establish and control similar diversity programs with other corporations, specifically mentioning BMW. PETERSON and BOND are legally entitled to seek to participate in corporate diversity programs benefitting minorities and minority enterprises. PETERSON and BOND are legally entitled to criticize any future efforts by JACKSON, PUSH, and their affiliates to highjack and convert such programs into a patronage system benefitting only the cronies of JACKSON and PUSH and those who pay them tribute. On information and belief, the foregoing outrageous and unlawful acts of Defendants at the Meeting are substantially likely to recur at similar diversity meetings with other corporations unless appropriate injunctive relief is granted beforehand.

30. A controversy has arisen and currently exists between Plaintiffs and Defendants over their respective legal rights and duties involving the foregoing matters, the following causes of action, and the appropriate relief to be awarded. Accordingly, Plaintiffs seek a declaration of the respective rights and duties of Plaintiffs and Defendants in connection with all such matters, as well as damages and such other relief as the Court may deem just and proper.

///

FIRST CAUSE OF ACTION

(By PETERSON only, for Assault, against All Defendants)

31. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 30 as if fully set forth at this point.

32. At no time did PETERSON consent to any of the acts of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, set forth in detail above.

33. In doing the acts set forth in detail above, JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, intended to cause and/or to place PETERSON in apprehension of harmful and offensive contacts with PETERSON’s person.

34. As a further proximate result of the foregoing acts of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, PETERSON was in fact repeatedly placed in great apprehension of harmful and offensive contacts with his person.

35. As a further proximate result of the foregoing acts of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, PETERSON has feared for his life and suffered severe emotional distress.

36. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, committed the foregoing acts intentionally, despicably, maliciously, and oppressively to injure PETERSON and BOND and to subject them to cruel and unjust hardship in connection with the Meeting and the Toyota Strategy, in wilful and conscious disregard of the safety of PETERSON and the rights of PETERSON and BOND. PETERSON is therefore entitled to an award of punitive damages against Defendants, jointly and severally, for the sake of example and by way of punishing JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them.

///

SECOND CAUSE OF ACTION

(By PETERSON only, for Battery, against All Defendants)

37. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 36 as if fully set forth at this point.

38. JONATHAN shoved PETERSON with intent to make contact with his person.

39. JONATHAN’s shoving of PETERSON was offensive in itself as well as under the circumstances of the mob attack set forth in detail above.

40. JONATHAN’s shoving of PETERSON was harmful in itself and proximately caused PETERSON to suffer severe emotional distress.

41. At no time did PETERSON consent to JONATHAN shoving him.

42. By engaging in the foregoing acts, JACKSON, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, incited, cooperated with, participated in, assisted, approved, and ratified JONATHAN’s shoving of PETERSON.

43. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts intentionally, despicably, maliciously, and oppressively to injure PETERSON and BOND and to subject them to cruel and unjust hardship in connection with the Meeting and the Toyota Strategy, in wilful and conscious disregard of the safety of PETERSON and the rights of PETERSON and BOND. PETERSON is therefore entitled to an award of punitive damages against Defendants, jointly and severally, for the sake of example and by way of punishing JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them.

THIRD CAUSE OF ACTION

(By PETERSON only, for False Imprisonment, against All Defendants)

44. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 43 as if fully set forth at this point.

45. PETERSON and BOND were legally entitled to be present at the Meeting, to communicate with Toyota at the Meeting, and to explore the possibility of participating in the Toyota Strategy and/or other Toyota diversity efforts. At all relevant times PETERSON conducted himself in an orderly and peaceful manner. At no time did PETERSON steal, nor was he ever in the process of stealing, any property belonging to Defendants or anyone else, nor did he commit any other unlawful act, and Defendants, and each of them, knew of PETERSON’s innocence at all relevant times.

46. By accosting PETERSON at the end of the Meeting and blocking his path so that he could not leave the area where he had been seated, JONATHAN falsely imprisoned PETERSON for an appreciable period of several seconds with the intention of intimidating and silencing him.

47. By further accosting PETERSON as a mob in the very loud, unruly, and threatening manner set forth above, JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, used force, threats, and their bodies to encircle, confine, and falsely imprison PETERSON within the angry mob at the fringe of the Meeting for an appreciable period of at least several minutes. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, all incited, cooperated with, participated in, assisted, approved, and ratified the false imprisonment of PETERSON within the mob and, earlier, by JONATHAN alone.

48. At no time did PETERSON consent to any false imprisonment.

49. The false imprisonment of PETERSON was harmful in itself and proximately caused PETERSON to fear for his life and suffer severe emotional distress.

50. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts intentionally, despicably, maliciously, and oppressively to injure PETERSON and BOND and to subject them to cruel and unjust hardship in connection with the Meeting and the Toyota Strategy, in wilful and conscious disregard of the safety of PETERSON and the rights of PETERSON and BOND. PETERSON is therefore entitled to an award of punitive damages against Defendants, jointly and severally, for the sake of example and by way of punishing JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them.

///

FOURTH CAUSE OF ACTION

(By PETERSON only,

for Intentional Infliction of Emotional Distress,

against All Defendants)

51. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 50 as if fully set forth at this point.

52. The foregoing conduct of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, in glaring menacingly at PETERSON, falsely imprisoning him on at least two distinct occasions after the Meeting, assaulting and battering him, shouting obscenities at him, screaming at him, calling him offensive names (including inter alia the word “nigger”), making threatening gestures, taunting him for having no one to rescue him from the mob, and similar mob intimidation are beyond all bounds of decency in a civilized society.

53. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts with the intent of causing PETERSON to fear for his safety and suffer severe emotional distress.

54. As a proximate result of the foregoing acts of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, PETERSON has feared for his life and suffered severe emotional distress.

55. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts intentionally, despicably, maliciously, and oppressively to injure PETERSON and BOND, to subject them to cruel and unjust hardship in connection with the Meeting and the Toyota Strategy, and to cause PETERSON severe emotional distress, in wilful and conscious disregard of the safety of PETERSON and the rights of PETERSON and BOND. PETERSON is accordingly entitled to punitive damages against Defendants, jointly and severally, for the sake of example and by way of punishing JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them.

FIFTH CAUSE OF ACTION

(By PETERSON only, for Violation of Civil Rights, against All Defendants)

56. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 55 as if fully set forth at this point.

57. Pursuant to the Unruh Civil Rights Act, Civil Code Section 51, PETERSON is and at all relevant times was entitled to the full and equal accommodations, advantages, facilities, privileges, and services in all business establishments of every kind whatsoever, including inter alia those made available by, through, and/or in connection with the question-and-answer session at the Meeting, the Los Angeles Trade Bureau Forum, the Los Angeles Chamber of Commerce, and opportunities to benefit from the Toyota Strategy and/or other Toyota diversity programs.

58. Pursuant to Civil Code Section 51.7, PETERSON has and at all relevant times had the right inter alia to be free from any violence and intimidation by threat of violence against his person because of his political and ideological affiliation or another person’s perception of his political and ideological affiliation.

59. Pursuant to the Tom Banes Civil Rights Act, Civil Code Section 52.1, PETERSON has and at all relevant times had the right inter alia to be free from any interference or attempts to interfere by threats, intimidation, or coercion, with his exercise or enjoyment of any rights secured by the Constitution or laws of the United States or the State of California.

60. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts for the purpose of interfering with PETERSON’s right to the full and equal accommodations, advantages, facilities, privileges, and services made available by, through, and/or in connection with the question-and-answer session at the Meeting, the Los Angeles Trade Bureau Forum, the Los Angeles Chamber of Commerce, and opportunities to benefit from the Toyota Strategy and/or other Toyota diversity programs.

61. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing outrageous and unlawful acts because of PETERSON’s conservative and Republican political affiliation.

62. By engaging in the foregoing conduct, JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, interfered and/or attempted to interfere by threats, intimidation, and coercion, with PETERSON’s exercise and enjoyment of his statutory rights under Civil Code Sections 51, 51.7, and 52.1.

63. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts intentionally, wilfully, maliciously, oppressively, and with conscious disregard for the safety of PETERSON and the rights of PETERSON and BOND.

64. The foregoing conduct of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, violates the Tom Banes Civil Rights Act, Civil Code Section 52.1(a), and entitles PETERSON to all the relief and remedies afforded by Civil Code Sections 52 and 52.1, including inter alia general damages, exemplary and punitive damages, a civil penalty of $25,000, attorneys’ fees, and injunctive and other equitable relief against Defendants, jointly and severally.

SIXTH CAUSE OF ACTION

(By PETERSON and BOND,

for Intentional Interference with Prospective Economic Advantage,

against All Defendants)

65. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 64 as if fully set forth at this point.

66. On information and belief, BOND, its members, and those assisted by BOND are the type of organization and persons that Toyota, as a responsible corporate citizen and/or as part of the Toyota Strategy, wants to help and routinely helps with training, funding, contributions, and other assistance as part of its diversity efforts. In consequence, BOND at all relevant times had a reasonable expectation of prospective economic advantage in association with Toyota’s diversity efforts, and BOND attended the Meeting and sought to communicate with appropriate Toyota personnel to give Toyota more information about BOND and to develop that prospect.

67. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts with the intent of interfering with BOND’s efforts to develop its prospective economic advantage in association with various Toyota’s diversity efforts, and the foregoing acts did in fact interfere with BOND’s efforts to do so.

68. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts intentionally, despicably, maliciously, and oppressively to injure BOND and to subject BOND to cruel and unjust hardship in connection with the Meeting and the Toyota Strategy, in wilful and conscious disregard of the rights of BOND and its prospective economic advantage in association with Toyota’s various diversity efforts. BOND is accordingly entitled to punitive damages against Defendants, jointly and severally, for the sake of example and by way of punishing JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them.

SEVENTH CAUSE OF ACTION

(By PETERSON and BOND,

in Their Own Right and on Behalf of the General Public,

for Unfair Business Practices, against All Defendants)

69. PETERSON hereby fully incorporates by reference all allegations set forth in preceding Paragraphs 1 through 68 as if fully set forth at this point.

70. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts with the intent of causing those persons present at the Meeting to believe mistakenly that it was necessary to make annual monetary payments to JACKSON, PUSH, and their affiliates as a condition of benefitting from the Toyota Strategy and, specifically, participating in the $700 million worth of contracts to be awarded in 2002.

71. JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, committed the foregoing acts with the intent of violating PETERSON’s civil rights.

72. On information and belief, absent entry of appropriate injunctive relief, JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, will engage in similar misconduct in the future, in connection with other diversity programs through other corporations, toward PETERSON, BOND, and others who (a) criticize the strategies, tactics, and actions of JACKSON, PUSH, and their affiliates, or (b) who have or are perceived as having conservative and Republican political affiliations, and/or (c) who refuse to pay tribute to JACKSON, PUSH, and their affiliates as a prerequisite to participating in corporate diversity programs.

73. The foregoing acts of JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, were, are, and/or will be unlawful, unfair, and/or fraudulent business acts and practices in violation of Business & Professions Code Section 17200 et seq., as a result of which PETERSON, BOND, and aggrieved members of the general public are entitled to appropriate injunctive relief, orders of restitution and disgorgement, and other equitable relief.

74. In their capacity as a private attorney general bringing suit on behalf of the general public, PETERSON and BOND seek to ensure that JACKSON, JONATHAN, MATHIS, PUSH, DOES 1 through 50, and each of them, individually and in concert, never again commit against anyone the kind of assault and battery, false imprisonment, intentional infliction of emotional distress, violations of civil rights, intentional interference with prospective economic advantage, and related practices and acts set forth above. PETERSON and BOND will thereby confer a significant benefit on the general public and a large class of persons. The necessity and financial burden of this private enforcement action are such as to make an award of attorneys’ fees appropriate. On information and belief, such fees should not in the interest of justice be paid out of the monetary amounts to be disgorged by Defendants, jointly and severally. PETERSON and BOND are therefore entitled to an award of attorneys’ fees pursuant to Code of Civil Procedure Section 1021.5.

///

PRAYER FOR RELIEF

WHEREFORE, PETERSON and BOND pray for the following relief:

1. For judgment in favor of PETERSON against all Defendants, jointly and severally;

2. For declaratory relief under each of the foregoing causes of action;

3. For general damages, according to proof at trial;

4. For exemplary and punitive damages, according to proof at trial;

5. For the statutory penalty of $25,000 under Civil Code Section 52(b)(2);

6. For all other damages permitted by law, according to proof at trial;

7. For disgorgement and restitution of monies wrongfully obtained by Defendants;

8. For temporary, preliminary, and permanent injunctive relief to prevent any future assault, battery, false imprisonment, intentional infliction of emotional distress, violation of civil rights, intentional interference with prospective economic advantage, and/or unfair business practices or acts by Defendants;

9. For all other equitable relief permitted by law, according to proof at trial;

10. For attorneys’ fees pursuant to Civil Code Section 52.1(h);

11. For attorneys’ fees pursuant to Code of Civil Procedure Section 1021.5;

12. For costs of suit; and

13. For all other and further relief that the Court deems just and proper.

Dated: January 15, 2002 Respectfully Submitted,

JUDICIAL WATCH, INC.

By: ____________________

Sterling Norris, Esq.

James F. Marshall, Esq.

Attorneys for Plaintiff

JUDICIAL WATCH, INC.