****************************************
BARBARA CURLEY AND
ROBERT CURLEY
Administrators of the
Estate of JEFFREY J. CURLEY
plaintiffs
Docket No. 00CV10956 GAO
v.
NORTH AMERICAN MAN
BOY
LOVE ASSOCIATION, JOHN
DOE INC., ROY RADOW, JOE
POWERS, DAVID THORSTAD,
DAVID
MILLER, PETER HERMAN,
MAX
HUNTER and ARNOLD SCHOEN
defendants
****************************************
1. This is
a civil action brought by Barbara Curley and Robert Curley in
their capacity as administrators of the estate of their deceased
son, Jeffrey Curley, to recover for the conscious suffering and
wrongful death of Jeffrey Curley caused by the defendants. The
claims are brought under Massachusetts General Law Chapter 229
Section 2 and 6, and seek compensatory and punitive damages. In
addition plaintiffs allege a violation of 42 USC 1985 against
defendants North American Man Boy Love Association, Roy Radow,
Joe Powers, David Thorstad, David Miller, Peter Herman, Max Hunter
and Arnold Schoen.
2.
Jurisdiction is conveyed upon this Court by 28 USC Section 1332(a)(2)
and 42 USC Section 1985(3).
3.
The plaintiffs Barbara Curley and Robert Curley are residents
of Cambridge and Somerville, Middlesex County, Massachusetts and
are the duly appointed administrators of the estate of Jeffrey
J. Curley. Plaintiffs bring this action on behalf of the next
of kin and Estate of Jeffrey J. Curley.
4. The defendant North American Man Boy Love Association is a group of individuals organized and operating in the United States and allegedly North America under the name of "NAMBLA" and hereinafter referred to as "NAMBLA" with a principal place of business at P.O. Box 174 Midtown Station, New York, New York 10018.
5. The defendant John Doe Inc. is a duly organized corporation with a principal place of business unknown to the plaintiffs at this time hereinafter referred to as "John Doe".
6. The defendant Roy Radow is a resident of 175 20 Wexford Terrace, Jamaica, New York 11432. Hereinafter referred to as "Radow".
7. The defendant Joe Powers is a resident of parts unknown with a principal place of business at NAMBLA P.O. Box 174 Midtown Station, New York, New York 10018. Hereinafter referred to as "Powers".
8. The defendant Daniel Thorstad is a resident of parts unknown with a principal place of business at NAMBLA P.O. Box 174 Midtown Station, New York, New York 10018. Hereinafter referred to as "Thorstad".
9. The defendant David Miller is a resident of parts unknown with a principal place of business at NAMBLA P.O. Box 174 Midtown Station, New York, New York 10018. Hereinafter referred to as "Miller".
10. The defendant Peter Herman is a resident of parts unknown with a principal place of business at NAMBLA P.O. Box 174 Midtown Station, New York, New York 10018. Hereinafter referred to as "Herman".
11. The defendant Max Hunter is a resident of parts unknown with a principal place of business at NAMBLA P.O. Box 174 Midtown Station, New York, New York 10018. Hereinafter referred to as "Hunter".
12. The defendant Arnold Schoen
is a resident of parts unknown with a principal place of business
at NAMBLA P.O. Box 174 Midtown Station, New York, New York 10018.
Hereinafter referred to as "Schoen".
13. Defendants Radow, Powers,
Thorstad, Miller, Herman, Hunter and Schoen collectively organize,
manage and control the daily organization of NAMBLA at all times
material hereto.
14. NAMBLA is an organization which falsely alleges it is non-profit in nature as defined by the Internal Revenue Code of the United States of America and exists for the purpose of changing society's attitudes about man/boy love through publications, educational and political activities and membership conferences.
15. Although NAMBLA represents that it is a lawful non profit organization working to change society's attitudes on pedophile activity in reality it is not a recognized non-profit organization by the United States of America or any state in the United States.
16. NAMBLA publishes a quarterly bulletin which it distributes throughout the United States and Europe and maintains a website on the Internet at www.nambla.org.
17. NAMBLA attempts to associate itself with the Gays Rights Organizations in the United States to justify its advocacy of men having sex with male children. NAMBLA attempts to equate lust and sex with love in order to justify men illegally raping male children.
18. By its publications, meetings and website NAMBLA encourages its members to rape male children. Public libraries have been identified as places for its members to meet or visit. Upon information and belief NAMBLA members travel to Thailand to have sex with young male slaves.
19. NAMBLA serves as a conduit for an underground network of pedophiles in the United States who use their NAMBLA association and contacts therein and the internet to obtain child pornography and promote pedophile activity.
20. NAMBLA maintains two mailing addresses in the United States. One location is a mail box location at 537 Jones Street, P.O. Box 8418, San Francisco, California 94102 (a photograph of this location is attached hereto, marked Exhibit A and incorporated by reference). This mailing address is maintained by Defendant Schoen. NAMBLA's second mailing address is P.O. Box 174, Midtown Station, New York, New York 10018. A photograph of this location is attached hereto marked Exhibit B and incorporated by reference. This mailing address is maintained by Defendant Radow from his residence at 17520 Wexford Terrace, Jamaica, New York 11432. A photograph of this location is attached hereto marked Exhibit C and incorporated by reference.
21. NAMBLA maintains two voice mail telephone numbers. One telephone number is 415-281-0767 and is located in San Francisco, California. The second telephone number is 212-631-1194 and is located in New York, New York. NAMBLA's voice mail system is established for the purpose of providing communication to and between it's members and to impede law enforcement investigation of it's members' activities.
22. NAMBLA regularly publishes a publication called the NAMBLA Bulletin. The Bulletin contains various articles and letters encouraging men to have sex with young male children. The articles and letter allegedly report of the sexual experiences between men and male children and contain statements such as "call it love, call it lust, call it whatever you want. We desire sex with boys and boys whether society is willing to admit it, desire sex with us". Lust - NAMBLA Bulletin No. 18.4.
23. NAMBLA members describe the Bulletin as "a nice collection of photos of cute boys (practically on every page)" NAMBLA Bulletin No. 18.4. A sample of some NAMBLA Bulletin photographs and drawings is attached hereto marked Exhibit D and incorporated by reference.
24. For a profit on or about October 11, 1996 Defendant John Doe was the internet service provider to NAMBLA and intentionally, negligently, recklessly and carelessly provided technical support to NAMBLA to create and maintain the NAMBLA website.
25. John Doe Inc. at all times material hereto provides the international website communication systems for pedophiles in North America under the name of NAMBLA which intentionally promotes child pornography and pedophile activity. John Doe Inc. allows NAMBLA to "reach more people and provide a more scattered target for" law enforcement officials. NAMBLA Bulletin No. 18.4.
26. At all times material hereto Defendants NAMBLA, John Doe, Radow, Powers, Thorstad, Miller, Herman, Hunter and Schoen intentionally, negligently, carelessly and recklessly promoted, advocated, conspired and urged the general public to illegally rape young male children and provided information to assist the general public in obtaining child pornography and pedophile related material.
27. In the Fall of 1996 Charles Jaynes also known as Elizah Woods, Anthony Scaccia and Scott Eastman of 42 Peterson Avenue, Brockton, Massachusetts joined NAMBLA.
28. Prior to joining NAMBLA Charles Jaynes was heterosexual.
29. After joining NAMBLA Charles Jaynes received and read the NAMBLA Bulletin, accessed and read the NAMBLA website which is provided by John Doe Inc. and by said means of communication began to collect child pornography and various pedophile material.
30. As a direct and proximate result of the urging, advocacy conspiring and promoting of pedophile activity by John Doe Inc., NAMBLA Radow, Powers, Thorstad, Miller, Herman, Hunter and Schoen, Charles Jaynes became obsessed with having sex with and raping young male children.
31. As a direct and proximate
result of the urging, advocacy and promoting of pedophile activity
by John Doe Inc., NAMBLA, Radow, Powers, Thorstad, Miller, Herman,
Hunter and Schoen, Charles Jaynes stalked Jeffrey Curley of Cambridge,
Massachusetts who was ten years old and tortured, murdered and
mutilated Jeffrey Curley's body on or about October 1, 1997. Upon
information and belief immediately prior to said acts Charles
Jaynes accessed NAMBLA's website at the Boston Public Library.
32) Plaintiffs incorporates the
allegations made in paragraphs 1 through 31 above, as if stated
herein.
33) The Defendant North American Man Boy Love Association's aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
34) The Defendant North American Man Boy Love Association's malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
35) Pursuant to Massachusetts law, Jeffrey J. Curley's next to kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
36) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
37) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against NAMBLA as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
38) Plaintiffs incorporates the
allegations made in paragraph 1 through 37 above, as if stated
herein.
39) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, North American Man Boy Love Association, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
40) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE Plaintiffs in their representative capacity, requests judgment in his favor against NAMBLA as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
41) Plaintiffs incorporates the
allegations made in paragraphs 1 through 40 above, as if stated
herein.
42) The Defendant Roy Radow's aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
43) The Defendant Roy Radow malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
44) Pursuant to Massachusetts law, Jeffrey J. Curley's next of kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
45) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
46) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against Roy Radow as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
47) Plaintiffs incorporates the
allegations made in paragraph 1 through 46 above, as if stated
herein.
48) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, Roy Radow, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
49) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE Plaintiffs in their representative capacity, requests judgment in his favor against Roy Radow as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
50) Plaintiffs incorporates the allegations made in paragraphs 1 through 49 above, as if stated herein.
51) The Defendant Joe Powers' aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
52) The Defendant Joe Powers' malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
53) Pursuant to Massachusetts law, Jeffrey J. Curley's next of kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
54) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
55) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against Joe Powers as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
56) Plaintiffs incorporates the
allegations made in paragraph 1 through 55 above, as if stated
herein.
57) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, Joe Powers, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
58) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against Joe Powers as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
59) Plaintiffs incorporates the
allegations made in paragraphs 1 through 58 above, as if stated
herein.
60) The Defendant David Thorstad's aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
61) The Defendant David Thorstad's malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
62) Pursuant to Massachusetts law, Jeffrey J. Curley's next to kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
63) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
64) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against David Thorstad as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
65) Plaintiffs incorporates the
allegations made in paragraph 1 through 64 above, as if stated
herein.
66) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, David Thorstad, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
67) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against David Thorstad as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
68) Plaintiffs incorporates the
allegations made in paragraphs 1 through 67 above, as if stated
herein.
69) The Defendant David Miller aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
70) The Defendant David Miller malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
71) Pursuant to Massachusetts law, Jeffrey J. Curley's next of kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
72) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
73) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against David Miller as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
74) Plaintiffs incorporates the allegations made in paragraph 1 through 73 above, as if stated herein.
75) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, David Miller, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
76) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against David Miller as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
77) Plaintiffs incorporates the
allegations made in paragraphs 1 through 76 above, as if stated
herein.
78) The Defendant Peter Herman's aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
79) The Defendant Peter Herman malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
80) Pursuant to Massachusetts law, Jeffrey J. Curley's next to kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
81) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
82) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against Peter Herman as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
83) Plaintiffs incorporates the
allegations made in paragraph 1 through 82 above, as if stated
herein.
84) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, Peter Herman, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
85) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against Peter Herman as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
86) Plaintiffs incorporates the
allegations made in paragraphs 1 through 85 above, as if stated
herein.
87) The Defendant Max Hunter's aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
88) The Defendant Max Hunter's malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
89) Pursuant to Massachusetts law, Jeffrey J. Curley's next of kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
90) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
91) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against Max Hunter as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
92) Plaintiffs
incorporates the allegations made in paragraph 1 through 91 above,
as if stated herein.
93) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, Max Hunter, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
94) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against Max Hunter as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
95) Plaintiffs incorporates the
allegations made in paragraphs 1 through 97 above, as if stated
herein.
96) The Defendant Arnold Schoen's aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
97) The Defendant Arnold Schoen malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
98) Pursuant to Massachusetts law, Jeffrey J. Curley's next of kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
99) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
100) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against Arnold Schoen as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
101) Plaintiffs incorporates the
allegations made in paragraph 1 through 100 above, as if stated
herein.
102) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, Arnold Schoen, Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
103) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against Arnold Schoen as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
104) Plaintiffs incorporates the
allegations made in paragraphs 1 through 103 above, as if stated
herein.
105) The Defendant John Doe Inc.'s aforementioned conduct constituted malicious, willful, wanton or reckless conduct.
106) The Defendant John Doe Inc.'s malicious, willful, wanton or reckless conduct directly and proximately caused the death of Jeffrey J. Curley under such circumstances that Jeffrey J. Curley could have recovered damages for personal injuries if his death had not resulted.
107) Pursuant to Massachusetts law, Jeffrey J. Curley's next of kin are entitled as damages to the fair monetary value of injury to Jeffrey J. Curley including, but not limited to, compensation for the loss of the reasonably expected net income, services, protection, care, assistance, society, companionship, comfort, guidance, counsel, and advice.
108) Pursuant to Massachusetts law, Jeffrey J. Curley's estate is entitled to the reasonable medical, funeral and burial expenses.
109) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to punitive damages
in an amount no less than five thousand dollars.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in their favor against John Doe Inc. as follows:
a. For compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages as allowed by law; and
c. For such other damages and relief as the Court may deem appropriate.
110) Plaintiffs incorporates the
allegations made in paragraph 1 through 109 above, as if stated
herein.
111) As the direct and proximate result of the serious bodily injuries to Jeffrey J. Curley caused by Defendant, Best Communication Inc., Jeffrey J. Curley was caused to suffer consciously from the time he was injured until his death.
112) Pursuant to Massachusetts
law, Jeffrey J. Curley's estate is entitled to damages for conscious
suffering resulting from such serious bodily injuries.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment in his favor against John Doe Inc. as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For such other relief as the Court may deem appropriate.
113. Plaintiffs incorporates the
allegations made in paragraph 1 through 112 above, as if stated
herein.
114. Jeffrey Curley was a member of a protected class of persons under the United States Constitution as a minor child pursuant to 42 USC 1985, and Massachusetts General Laws Chapter 265 Sections 22A, 23, 24B.
115. At all times material hereto Jeffrey Curley had the right to life and liberty and to be free of illegal sexual contact and intercourse pursuant to the laws of the Commonwealth of Massachusetts and United States Constitution.
116. At all times material hereto NAMBLA, Radow, Powers, Thorstad, Miller, Herman, Hunter and Schoen in the United States conspired directly and indirectly for the purpose of depriving young male children including Jeffrey Curley of their right to liberty and to be free from illegal sexual contact and intercourse.
117. Pursuant to said conspiracy defendants Radow, Powers, Thorstad, Miller, Herman, Hunter, Schoen and NAMBLA maintained a website and published material to the general public in a manner to impede law enforcement officials investigating child rape, urging, advocating and promoting members of the public to directly or indirectly deprive young male children of their liberty and right to be free of illegal sexual contact and intercourse.
118. As a direct and proximate result of the urging, advocacy conspiring and promoting of pedophile activity by NAMBLA, Radow, Powers, Thorstad, Miller, Herman, Hunter, Schoen, Charles Jaynes became obsessed with having sex with a raping young male children.
119. As a direct and proximate result of the urging, advocacy and promoting of pedophile activity by NAMBLA, Radow, Powers, Thorstad, Miller, Herman, Hunter, Schoen, Charles Jaynes stalked Jeffrey Curley of Cambridge, Massachusetts who was ten years old and tortured, murdered and mutilated Jeffrey Curley's body on or about October 1, 1997. Immediately prior to said act Charles Jaynes accessed NAMBLA's website at the Boston Public Library.
120. The aforementioned acts of defendants NAMBLA, Radow, Powers, Thorstad, Miller, Herman, Hunter and Schoen violated Jeffrey Curley's rights to life, liberty, equal protection under the laws of the United States and Commonwealth of Massachusetts and the equal privileges and immunities under the Constitution and laws of the United States and Commonwealth of Massachusetts and 42 USC 1985.
WHEREFORE, Plaintiffs in their representative capacity, requests judgment jointly and severally against defendants North American Man Boy Love Association, Roy Radow, Joe Powers, David Thorstad, David Miller, Peter Herman, Max Hunter and Arnold Schoen in their favor as follows:
a. For general and compensatory damages in an amount to be determined by the Court with interest and costs;
b. For punitive damages in an amount to be determined by the court with interest;
c. For reasonable attorneys fees;
d. For such other relief as the Court may deem appropriate.
Respectfully submitted,
For Plaintiffs
Lawrence W. Frisoli
Frisoli & Frisoli
797 Cambridge Street
Cambridge, MA 02141
(617) 354-2220
Dated: [May 16, 2000]
|
Next | Previous | Random | List Sites Next 5 | Previous 5 | Join Children's Safety & Sites United made possible by CrickRock Webrings. |