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