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