Plaintiffs, Don Adams ("Don") and Theresa Adams ("Teri"), by and through the undersigned counsel, hereby sue Defendants Teamsters Local 115, John P. Morris, Kevin McNulty, Marc A. Nardone, Mark Hopkins, Charlie Davis, Heather L. Diocson, Norma Bottomer, Sharon Hopkins, Norton Brainard, III, Esq., Edward G. Rendell, Lynne M. Abraham and John and Jane Doe Nos. 1-99, certain unknown officials, employees, and/or members of the City of Philadelphia Mayor�s Office, the District Attorney�s Office and/or Teamsters Local 115, and other entities, and allege as follows:

1. This is an action for violation of civil rights under 42 U.S.C. �� 1983, 1985(2), 1985(3) and 1986, defamation, invasion of privacy/false light, malicious prosecution, assault and battery, intentional infliction of emotional distress and civil conspiracy.

2. Don Adams is a citizen of the Commonwealth of Pennsylvania and resides at 626 Woodland Road, Cheltenham, PA 19012. He is the brother of Teri Adams.

3. Teri Adams is a citizen of the Commonwealth of Pennsylvania and resides at 7124 Shelborne Street, Philadelphia, PA 19111. She is the sister of Don Adams. Don and Teri Adams are orphans and have cared for each other for most of their lives.

4. Teamsters Local 115 is a local labor organization that is associated with and part of the International Brotherhood of Teamsters. Teamsters Local 115 is an unincorporated association or an incorporated entity under the laws of the Commonwealth of Pennsylvania. Teamsters Local 115 has its address at 2033 Cottman Avenue, Philadelphia, PA 19152, and exists for the purpose of collective bargaining on behalf of its members.

5. John P. Morris is a citizen of the Commonwealth of Pennsylvania and resides at 3421 Oakmont Street, Philadelphia, PA 19136. Morris is the founder and Secretary-Treasurer of Teamsters Local 115. He is also the President of the Pennsylvania Conference of Teamsters. He was twice elected Vice President of the International Brotherhood of Teamsters for the East Coast, and is the most influential labor leader in the Delaware Valley.

6. Kevin McNulty is a citizen of the Commonwealth of Pennsylvania and, on information and belief, resides at 200 S. Broad Street, Philadelphia, PA 19102. McNulty is approximately 21 years old, and a member of Teamsters Local 115.

7. Marc A. Nardone is a citizen of the Commonwealth of Pennsylvania and resides at 826 Avon Road, Philadelphia, PA 19116. Nardone is approximately 21 years old, and a member of Teamsters Local 115.

8. Mark Hopkins is a citizen of the Commonwealth of Pennsylvania and resides at 2107 E. Clementine Street, Philadelphia, PA 19143. Mark Hopkins is a member of the Teamsters Local 115. On information and belief, Mark Hopkins is the husband of Sharon Hopkins.

9. Charlie Davis is a citizen of the Commonwealth of Pennsylvania. Davis is a member of the Teamsters Local 115, 2033 Cottman Avenue, Philadelphia, PA 19152.

10. Heather L. Diocson is a citizen of the Commonwealth of Pennsylvania and resides at 2744 Elbridge Street, Philadelphia, PA 19149. Diocson is a member of Teamsters Local 115.

11. Norma Bottomer is a citizen of the Commonwealth of Pennsylvania. Bottomer is a member of the Teamsters Local 115, 2033 Cottman Avenue, Philadelphia, PA 19152.

12. Sharon Hopkins is a citizen of the Commonwealth of Pennsylvania and resides at 2107 E. Clementine Street, Philadelphia, PA 19143. Sharon Hopkins is a member of the Teamsters Local 115. On information and belief, Sharon Hopkins is the wife of Mark Hopkins.

13. Norton Brainard, III, Esq. a citizen of the Commonwealth of Pennsylvania and resides at 349 Barnsbury Road, Langhorne, PA 19047. On information and belief, Brainard is an attorney associated with the Teamsters Local 115.

14. Edward G. Rendell is a citizen of the Commonwealth of Pennsylvania and resides at 3425 Warden Drive, Philadelphia, PA 19129. Rendell is the Mayor of the City of Philadelphia.

15. Lynne M. Abraham is a citizen of the Commonwealth of Pennsylvania and resides at 296 St. James Place, Philadelphia PA 19106. Abraham is the District Attorney for the City and County of Philadelphia.

16. Defendants John and Jane Doe Nos. 1-99 are currently unknown officials, employees and/or members of the City of Philadelphia Mayor�s Office, the District Attorney�s Office and/or Teamsters Local 115, and other entities.

17. Jurisdiction over this matter is proper under 28 U.S.C. � 1331, as Plaintiffs assert claims arising under the Constitution and laws of the United States.

18. Supplemental jurisdiction is also proper under 28 U.S.C. � 1367, because Plaintiffs assert various claims arising under state law that form the same "case or controversy" as Plaintiffs� claims arising under federal law.

19. Venue is proper in this district pursuant to the provisions 28 U.S.C. � 1391(b)(1) and (2) because more than one defendant resides in this district, all defendants reside in Pennsylvania, and a substantial part of the events giving rise to the claims occurred in this district.

20. Don Adams is 38 years old and has resided in Philadelphia all of his life.

21. Teri Adams is 40 years old and has resided in Philadelphia all of her life.

22. On or about October 1, 1998, Don learned from a radio broadcast on WWDB News Radio that William Jefferson Clinton, President of the United States, was planning to speak at a fundraiser the following evening at Philadelphia�s City Hall. Don decided to peacefully protest on October 2, 1998 and invited Teri to attend with him.

23. October 1998 was an intense political season -- the height of the impeachment fervor across the country. President Clinton had admitted two (2) months prior, on August 17, 1998, that he had an inappropriate relationship with Monica Lewinsky, and Independent Counsel Kenneth Starr just weeks before had made his referral to the United States House of Representatives. Articles of impeachment against President Clinton were being prepared by the House Judiciary Committee, and general elections were one (1) month away. President Clinton was peacefully being protested nearly everywhere he spoke.

24. The Clinton fundraiser, arranged and hosted by Mayor Edward G. Rendell, was to begin at approximately 6:00 p.m. on October 2, 1998 at City Hall. Don agreed to meet Teri at approximately 5:00 p.m. at a local parish, Saint John�s Catholic Church, located approximately two (2) blocks from City Hall. Because President Clinton was scheduled to visit several locations in the same general area, both supporters and protestors were spread throughout a several-block radius around City Hall. A phalanx of police also were on duty due to the presidential visit. Several television news crews also were in attendance.

25. After meeting at the church, Don and Teri walked toward City Hall, arriving there approximately an hour before President Clinton�s fundraising event was to begin. Don and Teri noticed three (3) buses with "Teamsters" painted on the sides, parked across from Center Square in an area where it was normally illegal to park at that hour. They also noticed approximately 150 individuals carrying "Teamsters for Clinton" signs and wearing white t-shirts that had the words "Teamsters for Clinton" emblazoned on the front. The Teamsters greatly outnumbered the peaceful Clinton protesters, of which there were approximately 20 at the time, and were acting in an obviously organized and coordinated fashion.

26. In fact, earlier in the day, Teamsters Local 115 had arranged for bus-loads of its members to be transported to City Hall. In addition to being allowed to park their buses in an area where parking was normally prohibited at that hour, a Teamsters tractor-trailer blaring music was allowed to park on the pavement just outside City Hall. On information and belief, the permission of the City was required to station the tractor-trailer there.

27. On information and belief, the Teamsters had been specifically invited by Mayor Rendell to contain, harass and intimidate peaceful Clinton protestors in order to curry favor with the administration of President Clinton and Vice-President Al Gore, as well as the Democratic Party. Mayor Rendell has since been named National Chairman of the Democratic Party.

28. Teamsters Local 115 has a long history of engaging in violence. In July 1995, Teamsters Local 115 was held in contempt by a unanimous, three-judge panel of the U.S. Court of Appeals for the Third Circuit for engaging in violent, strike-related conduct in violation of a nine-year old court injunction. The attack on Don, Teri and other peaceful Clinton protestors at the hands of the Teamsters was thus reasonably foreseeable given the Teamsters� long and sordid history of violence and organized crime connections.

29. Throughout the evening and in plain view of the substantial police force on duty around City Hall for the presidential visit, Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts had harassed, heckled and shouted obscenities at peaceful Clinton protesters. Peaceful Clinton protesters were forced to move to other locations to avoid the Teamsters. At least one peaceful Clinton protester, Dr. Kevin L. Sterner of the Physics Department at the University of Pennsylvania, had been physically attacked by Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts, at approximately 4:30 p.m.

30. Don and Teri continued walking towards a street corner where a group of peaceful Clinton protestors had congregated and joined in a peaceful protest. Don carried a sign, approximately 2-feet-by-3-feet in size, advocating the President�s resignation or impeachment. Teri carried a sign approximately the same size, also advocating the President�s resignation or impeachment. As the President�s motorcade passed by, Don, Teri and other protestors yelled "resign and impeach him." They remained at this location for approximately another ten (10) minutes, after which the police asked them to move to another corner. Don, Teri and the other Clinton protestors did so peacefully.

31. About 30 minutes later, Don and Teri watched as a dark sedan carrying three or four passengers drove up to the street corner where they and the other peaceful Clinton protestors were protesting. Although it was rush hour, the car stopped in the middle of the intersection in heavy traffic, and a short, bald man got out and began to shout at and verbally abuse the peaceful Clinton protestors. The police did nothing despite a substantial interference to the flow of traffic.

32. Don and Teri watched as Morris verbally attacked an elderly male peaceful Clinton protester who was holding a sign, telling him "Go home. Go the f--- home." The police still failed to intervene. An official from another union who was known to Teri and who happened to pass by informed Teri that the man was John Morris, President of the Pennsylvania Conference of Teamsters and founder and Secretary-Treasurer of Teamster Local 115.

33. Morris then came closer to where Don and Teri were standing. Don told Morris to leave them alone, and Morris then began shouting and verbally abusing Don, telling him to "Go to hell." The police again failed to intervene. Two (2) other occupants of the sedan had gotten out and joined Morris in verbally abusing Don, Teri and the other peaceful Clinton protestors. Morris and the two (2) other occupants eventually got back into the car and drove down the block.

34. About fifteen (15) minutes later, another group of Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts approached the street corner where Don, Teri and other peaceful Clinton protestors were protesting. They again began verbally abusing and harassing Don, Teri and the other peaceful Clinton protestors. Don and Teri and others peaceful Clinton protestors decided to walk to another location. Some peaceful Clinton protestors decided to give up in the face of the Teamsters� intimidation and harassment.

35. After protesting at another location, Don, Teri and a small group of other peaceful Clinton protestors decided to walk over to City Hall, nearer to television cameras and where other peaceful Clinton protesters had congregated. Along the way, Don stopped to be interviewed by National Public Radio.

36. Upon nearing City Hall, Don and Teri joined a group of peaceful Clinton protesters marching past television cameras with other Clinton protesters. President Clinton had already arrived and entered City Hall. Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts began to chant "Impeach Ken Starr." Don, Teri and other peaceful Clinton protesters chanted back "Impeach Bill Clinton." Don and Teri repeated this chant about eight (8) times when Don�s signs were suddenly ripped out of his hands from behind by Teamsters wearing white "Teamsters for Clinton" t-shirts. Don turned around and requested his signs back, and a crowd of Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts began to circle him and Teri pushing into and screaming obscenities at them. Again, the police failed to intervene.

37. Don told the Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts to give him back his sign and to stop pushing. Don identified Morris among them. The crowd of Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts parted to allow Morris to approach Don and Teri. Morris then reached out and rammed his hat, a fedora, on Don�s head, pushing the brim down so low that Don was blinded. This tactic, known as "marking," "hatting" and/or "capping," is typically used to single out an individual for attack. Morris then hit Don on the head and punched him.

38. The crowd of Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts, including McNulty, Nardone, Mark Hopkins and Davis, led by Norma Bottomer, then charged at Don, viciously kicking and punching him, and knocking over both Don and Teri. Morris also punched Don. McNulty, Nardone, Mark Hopkins and Davis are also known as Morris� personal detail or "flying squad." Again, the police failed to intervene.

39. Before he knew what was happening, Don was on the ground, with throngs of Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts, including McNulty, Nardone, Mark Hopkins and Davis, surrounding him and beating him.

40. Several Teamsters wearing white "Teamsters for Clinton" t-shirts, including McNulty, Nardone, Mark Hopkins and Davis, viciously hit and kicked Don and Teri numerous times. Bottomer, held Don down and battered him as well. At least one Teamster, either McNulty, Nardone, Mark Hopkins or Davis, made several repetitive full force punches to Don�s head. Don was kicked in the head also.

41. Thinking that the Teamsters would not hit a woman, Teri crawled partially on top of Don. Just as she tried to put her forearm over Don�s face to protect him, a Teamster carrying "Teamsters for Clinton" signs and wearing a white "Teamster for Clinton" t-shirt kicked Don full force in the face. Teri also received several direct punches and/or kicks from Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts, including McNulty, Nardone, Mark Hopkins and Davis.

42. Uniformed police officers were not available to break up the attack. Plain clothed police officers were the first on the scene and had to push their way through the mob of Teamsters to break up the assault. The teamsters resisted. The police then helped Don and Teri over a police barrier, hedges and a fence. When the media attempted to interview them, the police forcibly removed Don to an area where he could not speak to the media.

43. President Clinton and Mayor Rendell were inside City Hall conducting Democratic Party fundraising activities at the time of the attack on Don and Teri.

44. Morris was obviously directing and coordinating the Teamsters� activities. According to a Philadelphia Police Department Investigation Report, Police Officer Charles Taylor witnessed that "on several occasions Morris would remove his hat and point the hat in a certain direction and the crowd of teamsters would move to that area."

45. Don was belatedly taken to Hahnemann Hospital and treated for head, face, abdomen, and neck injuries.

46. Several minutes after the attack on Don, Morris pointed his hat in the direction of an elderly man, Charles Radich. Radich was then knocked down by Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts, beaten and had his sign taken away.

47. According to a Philadelphia Police Department Investigative Report and testimony given by Officer Charles Taylor, Morris himself had verbal confrontations with at least two (2) police officers, and even pushed and shoved one of them. However, the police did not arrest or detain Morris, or otherwise prevent him from engaging in further unlawful conduct.

48. Morris then led Teamsters carrying "Teamsters for Clinton" signs and wearing white "Teamsters for Clinton" t-shirts in at least one triumphant march around City Hall. During the march, Morris, Diocson and Brainard gave interviews to television stations that were broadcast that evening, and subsequently, in which they falsely accused Don and Teri of insulting Hillary Rodham Clinton and Chelsea Clinton, and falsely accused Don of hitting Teamster women and inciting a riot:

Mr. Morris: "We resent anybody putting Hillary and Chelsea down. We had it. We don�t want it no more. . . .

Does he have any blood on him? Where�s he have blood on him? Somebody grabbed his face from his side. They grabbed him and brought him back. He�s a nut. Don�t you know a nut when you see a nut? We didn�t do nothing to him."

Ms. Diocson: "They came -- they were pushing him and they punched me in the nose. . . .When we came down here they attacked our car."

Mr. Brainard: "They came down here looking for a fight. They came looking for a fight and they got one."

49. The entire attack was captured on videotape and by television cameras, and was broadcast on television news programs. The Philadelphia Daily News reported that "a group of beefy Teamsters kicked and punched" Don and Teri and others, after they saw Don�s sign criticizing President Clinton.

50. During an interview on October 3, 1999, broadcast by WTFX-TV, Morris again accused Don of inciting a riot: "We didn�t provoke it. He provoked it."

51. Two (2) days later, on October 4, 1998, WPVI-TV Action News broadcast an interview of Morris and Diocson, in which they falsely accused Don of attacking Teamster women:

Mr. Morris: "He hit the two girls. First there�s the one � she�s on the side of me � he hit another girl, and her husband�s there, and he hit her twice. Cut her (motions with his hand to the back of his head) � she�s all marked up in the back."

Ms. Diocson: "The next thing I know he punched me right in the face."

52. Also on or about October 4, 1998, during an interview broadcast by WCAU-TV News 10, Mayor Rendell falsely accused Don and Teri of attacking Hillary Rodham Clinton and Chelsea Clinton, implying that Don and Teri provoked the attack: "Some things said about Hillary and Chelsea Clinton were disgusting, but that�s not the point. People have a right to say them." Mayor Rendell�s agent and spokesman, Kevin Feeley, stated: "The anti-Clinton groups chose to make their views known. They chose to make their views known in the faces of the Teamsters. That is generally not a good career move." The published false and/or misleading statements by Mayor Rendell about Don and Teri attacking Hillary Rodham Clinton and Chelsea, both of whom are women, were similar to, reinforced, and furthered the published false and misleading statements by Morris and others that Don and Teri had attacked women and disparaged Hillary Rodham and Chelsea Clinton. Rendell�s statements evidence concerted and/or coordinated action against Don and Teri Adams, and other peaceful Clinton protesters.

53. On October 5, 1998, WCAU-TV News 10 broadcast another interview of Morris during which Morris again falsely accused Don of attacking Teamster women and admitted that other Teamsters attacked Don:

Mr. Morris: "Never touched him except to put the hat on his face. And he acts like he�s crazy. Take a look at the guy�s crazy looking eyes coming at you."

Reporter: "You�re crazy?"

Mr. Morris: "No, he�s crazy."

* * *

Mr. Morris: "I did it (put the hat on Adams) when he hurt her."

Reporter: "Was that a signal to do something?"

Mr. Morris: "No, it was a signal to stop him. The only way I could stop him from fighting was put my hat in his face and he couldn�t see."

Reporter: "The bottom line is your guys beat him up."

Mr. Morris: "No, they punched his arms and legs and all that (expletive), but if they did a lot of damage to his face there would�ve been a problem, but they didn�t."

54. On October 6, 1998, The Philadelphia Daily News published another interview of Morris in which Morris admitted to placing his hat on Don and falsely accused Don of attacking Teamster women. Morris stated that he put his hat "in Adams� face to block him from coming forward," and that when he raised his hat, Adams had "already hit [Teamster Local 105 member] Heather [Diocson] and was hitting [Teamster Local 105 member] Sharon [Hopkins]."

55. Also on or about October 6, 1998, both Dioscon and Sharon Hopkins gave false interviews to the Philadelphia Police Department, falsely claiming that Don had attacked them. Nardone had also given a false interview to the Philadelphia Police Department.

56. In interviews with the Philadelphia Daily News, published on October 14, 1998, Morris, Sharon Hopkins, Bottomer and Diocson falsely accused Don of instigating the attack. Sharon Hopkins falsely accused Don of bruising her right hand and upper arm. Bottomer falsely accused Don of injuring the back of her hand and neck. Diocson falsely accused Don of punching her in the nose. Morris falsely accused Don of provoking the attack and falsely claimed that Don "had his hands in a claw," and that if he (Morris) hesitated, Don "could�ve cut her face," and "could�ve cut my face."

57. In October 1998, the Teamsters waged a letter writing campaign to The Philadelphia Inquirer and The Daily News falsely accusing Don of hitting three (3) Teamster women -- Sharon Hopkins, Bottomer and Diocson. Letters written by Teamsters were published in both newspapers in October 1998.

58. On or about November 3, 1998, arrest warrants were issued for McNulty and Nardone in connection with the attack on Don and Teri. In an interview with Associated Press published on November 3 and 4, 1998, Morris again falsely accused Don of being the aggressor in the attack.

59. Approximately five (5) weeks after the attack, Nardone and McNulty turned themselves into Philadelphia authorities.

60. During an interview by WCAU-TV News 10 broadcast on November 4, 1998, Morris falsely accused Don of having ties to the Mafia and conspiring with Teamster presidential candidate James Hoffa, Jr. to disgrace Morris shortly before the Teamsters� December 1998 elections. Morris himself was a candidate for Vice President of the Teamsters:

Reporter: "You mean to tell me this whole thing was engineered by Hoffa and the Mafia?"

Mr. Morris: "Yeah, sure. I mean this is what I�m fighting against, Hoffa and this mob thing."

Reporter: "You mean they engineered this somehow?"

Mr. Morris: Sure they engineered this."

Reporter: "They knew this guy, they put him up to it? Is that what you mean?

Mr. Morris: "Well take a look at the pictures in the paper yesterday. They were across the street."

61. On December 7, 1998, approximately two (2) months after the attack, Diocson filed a sworn, private criminal complaint against Don, falsely accusing him of jumping in front of her and punching her in the nose.

62. In approximately November 1998, before the District Attorney�s office had even approved criminal charges against Don, District Attorney Abraham appeared at a Jewish women�s association meeting to give a speech, during which Abraham falsely stated and published -- as a fact and not a mere factual allegation -- that "[w]hat you saw in the video isn�t what happened. Don was hitting women." Abraham�s published false statement show concerted and/or coordinated action among the Defendants, including but not limited to Morris and Mayor Rendell.

63. In approximately November 1998, the District Attorney�s office approved Diocson�s private criminal complaint against Don. On information and belief, the approval was authorized by Abraham, who had received campaign contributions from the Teamsters for her election. Teri was later told by someone close to the District Attorney�s office that Abraham approved Diocson�s criminal complaint as a political favor to Morris.

64. A summons served on Don in December 1998 commanded him to appear for arraignment on January 5, 1999 in Philadelphia Municipal Court. The charges against Don included simple assault, inciting a riot, and reckless endangerment.

65. On December 11, 1998, Associated Press reported that Morris claimed Don started the fight, and that, according to Ms. Diocson�s criminal complaint, which the District Attorney�s Office approved, Don punched her in the nose.

66. On or about January 3, 1999, Don filed a sworn, private criminal complaint against Morris. Despite the clear and compelling videotape evidence showing Morris ramming a hat onto Don�s head to signal the start of the attack, as well as the subsequent attack itself, Don�s complaint was "disapproved" by the Philadelphia District Attorney�s Office, allegedly because of "insufficient evidence" and "contradictory statements by both sides."

67. On January 5, 1999, Don appeared for arraignment at the Philadelphia Municipal Court and pled not guilty to the charges against him. Brainard offered to drop the charges against Don if Don would drop the charges against the Teamsters.

68. On February 10, 1999, a local judge dismissed aggravated assault charges against McNutly and Nardone. Simple assault and other charges were carried over for trial.

69. In pre-trial proceedings, Don, through his defense counsel and pursuant to the Pennsylvania Rules of Criminal Procedure, requested that all discoverable materials concerning the allegations against him, including all police reports and Brady evidence, be provided to him. The Philadelphia District Attorney�s Office denied the existence of any such materials.

70. On June 18, 1999, Don, Teri and Don�s defense counsel, Brian L. Buckley, Esq., met with Bruce Sagel, an Assistant District Attorney for the City and County of Philadelphia, to discuss Don�s private criminal complaint against the Teamsters. Sagel admitted to Buckley, in Don�s presence, "Look, Brian, you know, I know, everyone knows that Don did not strike anyone and that the women who say he did are lying." When Buckley responded that it was amoral for the District Attorney�s office to let the charges against Don proceed another minute, Sagel replied that the District Attorney�s office had a different strategy in mind -- obtain convictions against McNulty and Nardone first, then dismiss the charges against Don.

71. On the day before his trial in Philadelphia Municipal Court, Don learned that, contrary to the Philadelphia District Attorney�s offices� representations to his counsel and the Court, at least three (3) exculpatory statements had been given by police officers at the time of the attack.

72. On July 1, 1999, McNulty and Nardone pled guilty to charges of criminal conspiracy, riot and simple assault. They were later sentenced to five (5) years of probation.

73. Contrary to Sagel�s alleged strategy of obtaining convictions of McNulty and Nardone first, then dismissing the charges against Don, the charges against Don were not dismissed.

74. Don was tried in Philadelphia Municipal Court on July 8, 1999. He was found not guilty on all charges.

75. On or about September 28, 1999, Mayor Rendell admitted, in an interview with renowned journalist John Fund of The Wall Street Journal and others, that the Teamsters "own" the Philadelphia legal system "lock, stock and barrel." On information and belief, Mayor Rendell was, by implication, talking about the Mayor�s Office and the District Attorney�s Office, which are part of the legal system.

76. Spanning more than one administration, there has been a pattern and practice by the Philadelphia Mayor�s Office of using Teamsters for political purposes to contain, harass and intimidate civil protestors, among other illegal acts.

77. On information and belief, other false statements were made by Defendants and other persons named and/or implicated in this lawsuit, but the specifics of these false statements must await discovery, when Plaintiffs will be able to subpoena videotapes and audiotapes from various local and national television and radio stations.