Court of Common Pleas New York County New York, New York Jean M. Temple, MBA (Ms.) and all others similarly situated, Plaintiff v Case No: Marsh McLennan and Mulligan Security and their “security” personnel, Defendant(s) COMPLAINT 1. On or about Tuesday, October 18, 2005 at or about 1:03pm while seated in the public space area adjacent to Marsh McClennon office building, commonly addressed as 114 W 47TH STREET, NEW YORK, NY 10036 Phone: (212) 345-2000, I was accosted by a Puerto Rican male wearing a fluorescent green vest with the single word “security” on it. He stood right in front of me, within my personal space, and wagged his index finger and shook his head as though silently “scolding” me. I responded by pointing MY index finger at HIM and saying “don’t START with me.” 2. He had enough brainpower to know to walk on – but only for three steps [which is consistent with my past experience with cerebrally-deficient P.R. males.] He then turned and started verbalizing to me; I shouted him down with “this is a PUBLIC park.” 3. He then threatened me verbally with “I’m going to get SOMEONE ELSE.” 4. I followed him into the Marsh McClennon lobby where he addressed himself to a black male in a suit. I also addressed myself to that individual and said I was lodging an harassment complaint against the “security” person. 5. This resulted in a verbal melee. 6. The “suit” bellowed at me to leave the building; I did. 7. The entire incident was unnecessary, intrusive, and demeaning with the "suit" saying words to the effect "would you use that mouth with your mother" -- an inherently harassing comment used to juvenilize. Plaintiff contends that she has the right to peaceable enjoyment of public spaces without having her right of access or her constitutional right to “life, liberty, and the pursuit of happiness" curtailed by blatant attempts to harass/dominate and control. Respectfully submitted, Jean M. Temple, MBA (Ms.) jeantemple@lycos.com Attorney for Plaintiff: Daniel Girard, Esq. dcg@girardgibbs.com