Connie and Carl Scott supported their fifteen-year-old daughter's decision to have an abortion. But the girl's boyfriend and his family tried to stop her. After a confrontation at the Scott's home, the boyfriend was arrested.

Several hours later, police took the girl into protective custody. A judge allowed her to return to her parents "on the condition that no abortion shall be performed on the subject's unborn child without further order of the Court."

This is the Scott family's complaint against the county, various law officials and the boyfriend's family.

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA


CONNIE SCOTT and CARL (BUD)
SCOTT, individually, and on behalf of and as guardians and 
next friends of [redacted] Scott, a minor, 

Plaintiffs,

vs.

JOHN E. SAMSON, County Attorney for
Washington County, in his individual and official capacities; 
WASHINGTON COUNTY; DARRELL HOWARD, KEVIN 
WILLIS, and OFFICERS JOHN DOE I-IV, as members of the 
Washington County Sheriff's Department, in their individual 
and official capacities; JOSEPH LAGER, NICHOLAS 
THALLIS, BENJAMIN SHEAR, and OFFICERS JOHN 
DOE V-VIII, as members of the Blair, Nebraska Police 
Department, in their individual and official capacities; 
[redacted] , a minor, by and through his guardian and next 
friend; KATHY TULL, individually and as guardian and next 
friend of [redacted], JOHN TULL, DR. K.C. BAGBY and 
JAMES JORDAN, in their individual capacities, 

Defendants.


CIVIL ACTION NO._____


COMPLAINT AND DEMAND FOR JURY TRIAL


INTRODUCTORY STATEMENT

1.  This is an action under 42 U.S.C. Sections 1983, 1988 and 
Nebraska law seeking damages and other appropriate relief 
from public officials, and others acting in concert with them, 
for the unconstitutional and tortious interference with plaintiff 
[redacted] Scott's right to reproductive choice and the 
plaintiffs' right to family integrity effected when the 
defendants assaulted the plaintiffs in their home, illegally 
seized plaintiff [redacted] Scott, and removed her from her 
family in order to prevent her from making a free choice about 
whether to carry her pregnancy to term.   

JURISDICTION AND PARTIES

2.  Jurisdiction of this action is based on 28 U.S.C. Sections 
1331 and 1343.  The plaintiffs further invoke the supplemental 
jurisdiction of this Court with respect to claims arising under 
state law pursuant to 28 U.S.C. Section 1367. 

3.  Plaintiff [redacted] Scott is a woman under the age of 18. 
[redacted] Scott resided in Blair, Nebraska during the times 
relevant to this complaint.  In July 1995, [redacted] Scott 
moved from Blair with her parents, Connie and Carl Scott. 
[redacted] Scott appears in this action by and through her 
general guardians and next friends Connie and Carl Scott.  

4.  Plaintiff Connie Scott is [redacted] Scott's mother.  Connie 
Scott resided in Blair, Nebraska during the times relevant to 
this complaint.  In July, 1995, she moved from Blair with Carl 
and [redacted] Scott.  Connie Scott files on her own behalf and 
as a general guardian and next friend of [redacted] Scott.  

5.  Plaintiff Carl (Bud) Scott is [redacted] Scott's father.  
During the times relevant to this complaint, Carl Scott lived in 
Blair, Nebraska in the same house as Connie and [redacted] 
Scott.  In July 1995, he moved from Blair with Connie and 
[redacted] Scott.  Carl and Connie Scott have not yet sold the 
family home in Blair.  Carl Scott files on his own behalf and 
as a general guardian and next friend of [redacted] Scott. 

6.  Defendant John E. Samson is the County Attorney for 
Washington County, Nebraska and, as such, is responsible for 
making county policies and determining county practices and 
customs for the enforcement of the Nebraska child protection 
laws, and for investigating, initiating, and litigating actions 
under those laws.  At all times relevant to this complaint, 
Samson was acting under color of state law.  He is sued in 
both his individual and official capacities. 

7.  Officers Darrell Howard, Kevin Willis and John Doe I-IV 
are members of the Washington County Sheriff's Department 
and, as such, are responsible for enforcement of the laws, 
including the Nebraska child protection laws.  At all times 
relevant to this complaint, the defendant officers were acting 
under color of state law.  They are sued in both their 
individual and official capacities. 

8.  Defendant Washington County is a county of the State of 
Nebraska.  At all times relevant to this complaint, defendant 
Washington County acted under color of state law.  Through 
defendant John E. Samson and others, defendant Washington 
County makes county policies and determines county 
practices and customs for the enforcement of the Nebraska 
child protection laws, including the investigation, initiation, 
and litigation of actions under those laws. Through defendants 
Darrell Howard, Kevin Willis, and John Doe I-IV, defendant 
Washington County implements its policies, practices and 
customs relating to the enforcement of the Nebraska child 
protection laws. 

9.  Officers Joseph Lager, Nicholas Thallis, Benjamin Shear 
and John Doe V-VIII are members of the Blair, Nebraska 
Police Department and, as such, are responsible for the 
enforcement of the laws, including the Nebraska child 
protection laws.  At all times relevant to this complaint, the 
defendant officers were acting under color of state law. They 
are sued in both their individual and official capacities. 

10.  Defendant [redacted] is a man under the age of 18 who 
resides in Blair, Nebraska. 

11.  Defendant Kathy Tull resides in Blair, Nebraska and is 
the mother of [redacted]. 

12.  Defendant John Tull resides in Blair, Nebraska and is the 
stepfather of [redacted]. 

13.  Defendant K.C. Bagby is a physician and defendant 
James Jordan is a physician's assistant who, at all times 
relevant to this complaint, were practicing at the Blair Medical 
Group in Blair, Nebraska. 

14.  At all times relevant to this complaint, defendants 
[redacted], Kathy Tull, John Tull, K.C. Bagby and James 
Jordan were acting in concert with defendant public officials 
and thereby acting under color of state law. 

FACTS

15.  In September 1994, plaintiff [redacted] Scott, who at the 
time was 15 years old, became aware that she was pregnant. 
[redacted] had not questioned the absence of her menstrual 
period immediately, because her periods were consistently 
irregular.  On Monday, September 26, she informed her 
parents, plaintiffs Connie and Carl Scott, that she was 
pregnant as a result of sexual relations with her boyfriend 
[redacted].  Together the plaintiffs decided to have [redacted] 
consult a physician and to consider her options. 

16.  Defendants [redacted] and his mother and stepfather 
Kathy and John Tull had become aware of the pregnancy on 
the afternoon of September 26 because Kathy had [redacted] 
take two home pregnancy tests at the Tulls' house.  Later that 
evening, Kathy and John Tull made an unsolicited visit to the 
Scotts' home.  The Tulls informed the Scotts of their desire to 
help raise [redacted] child, even though [redacted] had not yet 
decided whether or not she would carry her pregnancy to term.  

17.  On Tuesday, September 27, plaintiff [redacted] Scott was 
examined by Dr. Carol Weckmuller at the Blair Medical 
Group.  The family's regular doctor was on vacation at the 
time. [redacted] was accompanied by her mother Connie 
Scott.  Based on a physical examination, Dr. Weckmuller 
informed [redacted] and Connie Scott that she estimated that 
[redacted] was twenty-three weeks pregnant.  Dr. Weckmuller 
advised [redacted] where she could get an abortion, should 
that be her choice. [redacted] Scott informed defendant Kathy 
Tull, by telephone, of the developments that day. 

18.  On Wednesday, September 28, [redacted] spoke at length 
with her family about her options.  After extensive 
deliberation, [redacted] decided to seek an abortion. 

19.  On Wednesday, September 28, [redacted] made an 
appointment by telephone for an abortion.  During the phone 
call, [redacted] spoke to a clinic employee, who asked her a 
series of questions and then explained the abortion procedure 
to her.  Connie Scott also talked to the employee and gave her 
additional information. [redacted] then spoke again with the 
clinic employee, who asked again whether [redacted] really 
wanted an abortion. [redacted] replied yes, and scheduled an 
appointment. 

20.  Early that evening, [the boyfriend] came over to [the 
Scott's] house. [redacted] told him that she planned to have an 
abortion.  He was upset, saying she was killing a baby.  Mid- 
evening Kathy Tull called the Scotts, screaming and saying 
such upsetting things that Connie Scott hung up the telephone. 

21.  Shortly thereafter someone pounded on the Scotts' door.  
Carl Scott went to answer the door, but before he could open 
it, defendant [the boyfriend] kicked the door, causing it to hit 
Carl in the eye and [redacted] across the face.  Present with 
[the boyfriend] at the Scott home were, among others, Kathy  
and John Tull, another Tull family member, and several of 
[the boyfriend]'s friends. They were screaming, calling the 
Scotts "baby killers" and other derogatory names, pulling 
[redacted], and hitting Carl. Connie Scott called the police to 
the house because of the violence against her family.  When 
the police arrived, including defendants Willis, Lager, Thallis, 
Shear and John Does I-VIII, [the boyfriend] struck Officer 
Lager and was arrested.  Kathy Tull assaulted Connie Scott by 
kicking her in the stomach.  Kathy Tull was not arrested.  Two 
officers asked [redacted] if she had made an appointment for 
an abortion, to which she responded, yes. 

22.  At least one deputy from the Sheriff's Department, 
defendant Officer Darrell Howard, arrived at the scene 
separately.  He tried to give [redacted] a manila envelope 
containing anti-abortion literature.  Earlier that day, Officer 
Howard, who is active in the anti-choice movement in Blair, 
had met with the Tulls at their home apparently for the 
purpose of preventing [redacted] from obtaining an abortion.  

23.  After the altercation, the plaintiffs and [redacted]'s 
younger brother went to their cousins' house for the night.  
The plaintiffs had earlier told the police that they would be 
staying at their cousins' home in Blair that night and had given 
the officers their cousins' address.  

24.  That same day, September 28, without [redacted] Scotts' 
consent, defendant Kathy Tull discussed [redacted]'s 
pregnancy and abortion plans with defendants Bagby and 
Jordan apparently for the purpose of preventing [redacted] 
from obtaining an abortion.  Defendants Bagby and Jordan 
cooperated, by writing a letter stating that "any elective 
abortion could potentially cause medical and emotional 
damage to the mother at any stage of pregnancy" and that an 
abortion at twenty-three weeks "could be harmful" to 
[redacted].  (Emphasis added.)  Neither Bagby nor Jordan had 
ever examined or spoken with [redacted].  The letter does not 
state that an abortion at twenty-three weeks is legal and is 
accepted medical practice, nor does it note that carrying to 
term and delivering a child could also be harmful to 
[redacted].  Kathy Tull then took the letter to the Blair police 
station.  Attached as Exhibit A is a copy of that letter. 

25.  At around 12:30 a.m. on Thursday, September 29, the 
plaintiffs were awakened by police at their cousins' house.  
More than ten law enforcement vehicles surrounded the house.  
Present were members of the Blair Police Department, 
including defendants Lager, Thallis and Shear, as well as 
county officers.  The police took [redacted] into custody.  
They did so for the purpose of preventing [redacted] from 
obtaining an abortion.  

26.  The Scotts were told that [redacted] was being taken into 
protective custody.  The police offered the Scotts little 
explanation as to why [redacted] was being taken into custody 
except to show them the letter from defendants Bagby and 
Jordan, and to say that defendant John E. Samson, the County 
Attorney, had directed them to take [redacted] into custody.  
The police told the Scotts there would be a hearing at 9 a.m. 
that morning, and advised them to get an attorney.  They did 
not inform the plaintiffs where they were taking [redacted] or 
what they would do with her.  The plaintiffs were extremely 
frightened and confused by the police removing [redacted] in 
the middle of the night to an undisclosed place for an 
undefined purpose. 

27. [redacted] was taken by the police to the Blair police 
station. [redacted] was at the police station for several hours.  
During this time, the police did not give her written notice of 
the reasons she was taken into custody.  During this time, 
[redacted] also noticed anti-choice materials on one of the 
lockers in the station. 


28.  After several hours at the police station, [redacted] was 
transported to the home of a foster family who were strangers 
to her.  At approximately 3:30 a.m., plaintiffs Connie and Carl 
Scott received a call from Deborah Bales, whom they did not 
know, but who identified herself as being with the Nebraska 
Department of Social Services.  Ms. Bales informed the Scotts 
that [redacted] was safe and urged them to get an attorney. 

29.  Early Thursday morning, September 29, plaintiffs Connie 
and Carl Scott sought and obtained counsel.  Their attorney 
was informed by defendant County Attorney Samson that no 
hearing would be held that day because there were no judges 
in town.  Plaintiffs Connie and Carl Scott were not told when 
a hearing would be held, nor were they given the option of 
going to another town to appear before a judge in order to 
avoid further delay. 

30.  On Thursday morning, defendant County Attorney John 
Samson interrogated [redacted] Scott. [redacted] was alone 
throughout the questioning, even though defendant Samson 
knew that she was under eighteen years of age and that her 
parents were available.  Defendant Samson further knew that 
the Scotts had retained counsel.  Defendant Samson also 
refused Deborah Bales' requests that he release [redacted].  
Instead, he filed a baseless petition with the Washington 
County Juvenile Court under the child protection law, alleging  
that [redacted] was in a situation dangerous to life or limb or 
injurious to her health.  The only stated reasons for the 
petition were that plaintiffs Connie and Carl Scott "had made 
arrangements" for [redacted] Scott to obtain an abortion and 
that defendant Bagby had provided a letter to law enforcement 
officials stating that an elective abortion could be harmful to 
[redacted].  A copy of the petition is attached as Exhibit B. 

31.  On Thursday, September 29, the Scotts discovered that 
fliers had been posted all over Blair stating that plaintiffs Carl 
and Connie Scott were "murderers."  Members of [the 
boyfriend's] family and his friends were responsible for 
posting the fliers. 

32.  On Friday afternoon, September 30, the Honorable F.A. 
Gossett, III, of Juvenile Court of Washington County held a 
hearing regarding [redacted].  No guardian ad litem or 
attorney was ever appointed to represent [redacted]'s interests. 

33.  At the hearing, County Attorney Samson filed an 
Amended Petition alleging that [redacted] was in a situation 
dangerous or injurious to her health or morals and that she was 
being neglected by her parents.  These allegations were based 
solely on the assertion that [redacted] was twenty-three weeks 
pregnant and considering an abortion. The only evidence put 
forth by Samson was the letter from defendants Bagby and 
Jordan (Ex. A), who had never examined or spoken to 
[redacted], stating that they believed an abortion at twenty-
three weeks could be harmful to [redacted].  A copy of the 
Amended Petition is attached as Exhibit C. 

34.  The petition filed by defendant County Attorney Samson 
stated that the allegations against plaintiffs Connie and Carl 
Scott were based on reports to "Law Enforcement." The Scotts 
did not, however, receive written notification of the 
investigation from the state Department of Social Services.  
Nor were any of the other procedures typically associated with 
a child abuse or neglect investigation followed, such as the 
appointment of a guardian ad litem for [redacted]. 

35.  Upon consideration of the Amended Petition, Judge 
Gossett stated that [redacted] should not have been removed 
from the Scotts' custody.  Judge Gossett ordered that the 
temporary placement of [redacted] with the Department of 
Social Services be terminated, and further ordered that 
[redacted] be released to the custody of her parents "on the 
condition that no abortion shall be performed on the subject's 
unborn child without further order of the Court." The order 
provides that any violation of its terms is punishable as 
contempt.   A copy of the Order is attached as Exhibit D. 

36.  Subsequent to the hearing, [redacted] obtained protective 
orders from the District Court of Washington County against 
Kathy Tull and [redacted] prohibiting them from harassing 
[redacted] and entering the Scott home. These orders became 
permanent on October 14, 1994, and are still in effect. 

37.  After the incident, [the boyfriend] tried repeatedly to 
contact [redacted].  His friends followed [redacted] when she 
left the house in Blair. [redacted] was threatened with assault. 
[redacted] became afraid to leave the house alone.  School in 
Blair became so threatening that [redacted] was tutored at 
home. [redacted] was so upset by the events that she had to 
seek the advice and support of a counselor.  Connie and Carl 
Scott were also harassed. Because of the trauma to their 
family caused by these events and the ongoing harassment, 
Connie and Carl Scott decided to move from Blair.  They 
wanted [redacted] to be able to return to school and again be 
with peers.  Despite the move and passage of time, [redacted] 
continues to have nightmares. 

38.  Subsequent to the events, [the boyfriend] pleaded guilty 
to assaulting a police officer at the Scotts' house and was 
placed on probation for one year. 

39.  In December 1994, [redacted] gave birth to a baby, whom 
she is raising in [redacted]'s parents' home. 

40.  On September 22, 1995, the plaintiffs served upon 
defendants Washington County, John E. Samson, Darrell 
Howard, Kevin Willis, City of Blair, Joseph Lager, Nicholas 
Thallis, Benjamin Shear, and John Doe I-VII tort claim 
notices in the form required and provided in such cases by the 
laws of the State of Nebraska concerning claims of trespass, 
intentional infliction of emotional distress, invasion of privacy 
and interference with the rights to reproductive choice, family 
integrity, due process, and freedom from illegal search and 
seizure as guaranteed by the Nebraska Constitution.   

CLAIMS FOR RELIEF

41.  The allegations set forth in paragraphs 1 through 40, 
inclusive, are repeated as if again set forth at length. 

42.  By, among other things, violently trespassing into the 
plaintiffs' home, assaulting [redacted] , Connie, and Carl 
Scott, obtaining and providing a letter to law enforcement 
officials misrepresenting the danger of abortion to [redacted], 
awakening and taking [redacted] into custody in the middle of 
the night, removing her from her parents, holding her in a 
police station and placing her with total strangers for over 36 
hours, interrogating [redacted], then fifteen years of age, 
without counsel or her parents present, delaying the 
appearance before a judge for over 29 hours while refusing to 
release [redacted], filing and pursuing a petition and amended 
petition alleging that [redacted]'s consideration of her 
constitutional right to have an abortion was injurious to her 
and reflective of parental neglect and lacking any evidence of 
abuse or neglect under Nebraska law, prohibiting [redacted] 
from attending her pre-scheduled and urgent appointment for 
an abortion, and through ongoing harassment, the defendants, 
willfully participating in joint activity, have interfered with 
and infringed and continue to interfere with and infringe 
plaintiff [redacted] Scott's right to reproductive choice in 
violation of the Fourteenth Amendment to the United States 
Constitution and Art. 1, Sections 1, 3 of the Nebraska 
Constitution. 

43.  By, among other things, violently trespassing into the 
plaintiffs' home, assaulting [redacted] and Carl Scott, 
obtaining and providing a letter to law enforcement officials 
misrepresenting the danger of abortion to [redacted], 
awakening and taking [redacted] into custody in the middle of 
the night, removing her from her parents, holding her in a 
police station and placing her with total strangers for over 36 
hours, interrogating [redacted], then fifteen years of age, 
without counsel or her parents present, delaying the 
appearance before a judge for over 29 hours, while refusing to 
release [redacted], filing and pursuing a petition and amended 
petition alleging that [redacted]'s consideration of her 
constitutional right to have an abortion was injurious to her 
and reflective of parental neglect and lacking any evidence of 
abuse or neglect under Nebraska law, prohibiting [redacted] 
from attending her pre-scheduled and urgent appointment for 
an abortion, and through ongoing harassment, the defendants, 
willfully participating in joint activity, have interfered with 
and infringed and continue to interfere with and infringe the 
plaintiffs' right of family integrity in violation of the 
Fourteenth Amendment to the United States Constitution and 
Art. 1, Sections 1, 3 of the Nebraska Constitution. 

44.  By, among other things, taking [redacted] into custody in 
the middle of the night, removing her from her parents, 
holding her in a police station and placing her with total 
strangers for over 36 hours, interrogating [redacted], then 
fifteen years of age, without counsel or her parents present, 
filing and pursuing a petition and amended petition alleging 
that [redacted]'s consideration of her constitutional right to 
have an abortion was injurious to her and reflective of parental 
neglect and lacking any evidence of abuse or neglect under 
Nebraska law, delaying the appearance before a judge for over 
29 hours, while refusing to release [redacted], the defendants, 
willfully participating in joint activity, deprived the plaintiffs 
of their liberty without due process of law in violation of the 
Fourteenth Amendment to the United States Constitution and 
Art. 1, Section 3 of the Nebraska Constitution. 

45.  By, among other things, forcibly and without consent, 
entering the Scotts' residence, entering the residence where the 
plaintiffs were staying, taking [redacted] into custody, forcibly 
removing her from home and her parents without a judicial 
warrant or order, probable cause, or any exigent circumstances 
excusing the absence of a warrant, the defendants, willfully 
participating in joint activity, violated the plaintiffs' rights in 
violation of the Fourth and Fourteenth Amendments to the 
United States Constitution and Art. 1, Section 7 of the 
Nebraska Constitution. 

46.  By, among other things, intentionally kicking in the door 
of the Scotts' home, causing it to hit Carl Scott in the eye and 
[redacted] Scott across the face, and pulling, hitting, kicking 
and injuring [redacted] Scott, Carl Scott and Connie Scott, 
defendants [redacted] and Kathy Tull assaulted and battered 
the plaintiffs. 

47.  By, among other things, willfully, forcibly, and without 
consent, entering upon the Scotts' property and kicking in their 
door on the night of September 28, 1994, Defendants 
[redacted], Kathy Tull and John Tull trespassed upon the 
Plaintiffs' property. 

48.  By, among other things, misusing information about 
[redacted] Scott, without ever examining her or speaking to 
her, to provide a misleading letter to law enforcement 
officials, which caused such law enforcement officials to take 
[redacted] into custody unlawfully in the middle of the night, 
remove her from her parents, hold her in a police station and 
place her with total strangers for over 36 hours, defendants 
K.C. Bagby and James Jordan are liable for the false arrest and 
imprisonment of plaintiff [redacted] Scott. 

49.  By, among other things, obtaining and providing the 
above letter and making other statements to law enforcement 
officials, which caused such law enforcement officials to take 
[redacted] into custody unlawfully in the middle of the night, 
remove her from her parents, hold her in a police station and 
place her with total strangers for over 36 hours, defendant 
Kathy Tull is liable for the false arrest and imprisonment of 
plaintiff [redacted] Scott. 

50.  By, among other things, willfully, forcibly, and without 
consent, entering upon the Scotts' property and kicking in their 
door on the night of September 28, 1994, providing 
confidential medical information to third parties, obtaining 
and providing a letter to law enforcement officials that 
misrepresented the danger of abortion to [redacted] and caused 
law enforcement to intrude upon the home where [redacted] 
Scott was staying and remove her from her family, and by 
interfering with [redacted] Scott's right to bodily integrity and 
autonomy with respect to her childbearing decisions and the 
Scott family's right to family privacy and integrity, defendants 
[redacted], Kathy Tull and John Tull intruded upon plaintiffs' 
solitude in violation of NRS Section 20-203. 

51.  By, among other things, violently trespassing onto 
plaintiffs' property, assaulting [redacted], Carl and Connie 
Scott, calling them "baby killers," obtaining and providing a 
letter to law enforcement officials that  misrepresented the 
danger of abortion to [redacted]and caused such law 
enforcement officials to take [redacted] into custody in the 
middle of the night, remove her from her parents, hold her in a 
police station and place her with total strangers for over 36 
hours, all of which, in addition to continuing harassment, has 
resulted in injury to all plaintiffs including interference with 
[redacted] Scott's bodily autonomy regarding her decision 
whether to continue her pregnancy, and all of which has led to 
humiliating, disabling and debilitating emotional injury for the 
Scott family including, but not limited to, [redacted]'s inability 
to leave her house alone and to continue her education at Blair 
High School, and the Scott family's decision to move out of 
town, defendants [redacted], Kathy Tull, John Tull, K.C. 
Bagby, and James Jordan have intentionally inflicted 
emotional distress upon plaintiffs. 

52.  As a direct and proximate result of the foregoing actions 
by the Defendants, the plaintiffs have suffered and continue to 
suffer damages. 

WHEREFORE, plaintiffs pray that this Honorable Court: 

I.  Declare that the seizure of plaintiff [redacted] Scott, 
removal from her family, placement in police and foster 
custody and interference with her right to reproductive choice 
and plaintiffs' right of family integrity were unconstitutional 
and tortious; 

II.  Award plaintiffs compensatory and punitive damages; 

III.  Enjoin defendants Washington County and Samson from 
intervening, investigating, authorizing state custody or filing 
further petitions, under the Nebraska child protection laws or 
otherwise, based on a woman's decision to consider an 
abortion and enjoin defendants Howard, Willis, Lager, Thallis, 
Shear and John Doe I-VIII from taking a minor into custody 
under the child protection laws of Nebraska or otherwise 
based on her decision to consider an abortion; 

IV.  Award plaintiffs reasonable attorneys' fees and the costs 
of this action, pursuant to 42 U.S.C. Section 1988 and any 
other applicable law; and 

V.  Award such further or other relief as the Court deems just 
and proper. 


DEMAND FOR JURY TRIAL

Plaintiffs demand trial by jury of all issues triable by jury in 
Lincoln, Nebraska.    DATED:____________________  BY:  
________________________ 


Jeanelle Kleveland, Esq.
333 South  9th Street
Lincoln, Nebraska  68508
(402) 477-7776
Bar No. 17565

Cooperating Counsel for the Nebraska
Civil Liberties Union   

________________________

Pat Knapp, Esq.
1614 N. 31st
Lincoln, Nebraska  68503
(402) 464-7272
Bar No. 17718

Cooperating Counsel for the Nebraska
Civil Liberties Union      

________________________

Louise Melling
Reproductive Freedom Project
American Civil Liberties Union Foundation 132 W. 43rd 
Street New York, New York  10036 (212) 944-9800  

Attorneys for Plaintiffs