These are the worst counts IMO against the WT:
http://www.silentlambs.org/assistance/andersonscom6-2-03.htm
COUNT SIX
(Fraud)
122. The Plaintiffs reassert and reallege paragraphs 1-69 and further allege as follows:
123. That, on information and belief, the Defendants on or about April or May of 2002 formulated a fraudulent and malicious plan designed to use their otherwise legitimate right to disfellowship members to destroy the credibility of Plaintiff Barbara J. Anderson prior to her Dateline appearance, so as to frustrate her efforts to assist victims of child sexual abuse and to prevent the church from sheltering child abusers.
124. That, the Defendants, acting individually, as agents for the other Defendants, and as part of their conspiracy, intentionally represented to members of the Jehovah's Witnesses committees considering whether to disfellowship the Plaintiffs, to the members of the Manchester congregation, and to inquiring members of the media that the Plaintiffs had committed spiritual violations that justified their expulsion from the faith;
125. That the Defendants concealed from the members of the Jehovah's Witnesses committees considering whether to disfellowship the Plaintiffs, to the members of the Manchester congregation, and to inquiring members of the media that Plaintiff Barbara J. Anderson had not committed any spiritual violations;
126. That the Defendants knew that these representations were untrue, that the facts concealed were material, and that the Plaintiff had not committed any spiritual violation that would justify disfellowshipping;
127. That those members of the tribunals who were not a part of the fraudulent and malicious plan reasonably relied on these false representations and voted to disfellowship Plaintiffs;
128. That the Plaintiffs were disfellowshipped as a result of the Defendant?s fraudulent misrepresentations and concealment of material facts;
129. That Plaintiff Barbara J. Anderson suffered damage in the form of great emotional distress and out of pocket fees paid to her attorney to represent her in the disfellowshipping proceedings as a result of the Defendants? fraud; that Plaintiff Barbara J. Anderson suffered damage in the form of great emotional distress and loss of profits from his business as a result of the Defendants? fraud;
WHEREFORE, the Plaintiffs respectfully request the Court:
(a) To award Plaintiff Barbara J. Anderson compensatory damages in the amount of Three Million Five Hundred Thousand Dollars ($3,500,000.00);
(b) To award Plaintiff Barbara J. Anderson punitive damages in the amount of Six Million Five Hundred Thousand Dollars ($6,500,000.00);
(c) To award Plaintiff A. Joseph Anderson compensatory damages in the amount of Three Million Five Hundred Thousand Dollars ($3,500,000.00);
(d) To award Plaintiff A. Joseph Anderson punitive damages in the amount of Six Million Five Hundred Thousand Dollars ($6,500,000.00); and
(e) To award Plaintiffs any other relief to which they may be entitled.
COUNT SEVEN
(Intentional Infliction of Emotional Distress)
130. The Plaintiffs reassert and reallege paragraphs 1-69 and further allege as follows:
131. That, in using their otherwise legitimate right to disfellowship members to silence the Plaintiff Barbara J. Anderson?s efforts to assist victims of child sexual abuse and to prevent the church from sheltering child abusers, the Defendants, acting individually, as agents for the other Defendants, and as part of their conspiracy, the Defendants at all times acted intentionally or recklessly;
132. That their conduct was so outrageous that it should not be tolerated by a civilized society;
133. That the conduct caused serious emotional distress to both Plaintiffs;
WHEREFORE, the Plaintiffs respectfully request the Court:
(a) To award Plaintiff Barbara J. Anderson compensatory damages in the amount of Three Million Five Hundred Thousand Dollars ($3,500,000.00);
(b) To award Plaintiff Barbara J. Anderson punitive damages in the amount of Six Million Five Hundred Thousand Dollars ($6,500,000.00);
(c) To award Plaintiff A. Joseph Anderson compensatory damages in the amount of Three Million Five Hundred Thousand Dollars ($3,500,000.00);
(d) To award Plaintiff A. Joseph Anderson punitive damages in the amount of Six Million Five Hundred Thousand Dollars ($6,500,000.00);and
(e) To award Plaintiffs any other relief to which they may be entitled.
COUNT EIGHT
(Wrongful Disfellowshipping)
134. The Plaintiffs reassert and reallege paragraphs 1-69 and further allege as follows:
135. That, prior to the summer of 2002, Plaintiff Barbara J. Anderson and Plaintiff A. Joseph Anderson were both members and participants of the Jehovah's Witnesses and devout believers in the faith of this religion;
136. That the Defendants, acting individually, as agents for the other Defendants, and as part of their conspiracy, disfellowshipped both Plaintiffs
137. That the Defendants disfellowshipped both Plaintiffs for purely secular purposes and as part of their intentional, fraudulent and malicious effort to silence the Plaintiff Barbara J. Anderson?s efforts to assist victims of child sexual abuse and to prevent the church from sheltering child abusers;
138. That the Defendants? use of their otherwise legitimate right to disfellowship members to silence Ms. Anderson?s efforts to assist victims of child sexual abuse and to prevent the church from sheltering child abusers and to punish both Plaintiffs violates important public policies of the State of Tennessee designed to permit the free exercise of religion and those policies designed to prevent the sexual abuse of children and the reporting of said abuse;
139. That the wrongful disfellowshipping of both Plaintiffs caused each Plaintiff to suffer damages including emotional harm, damage to reputation, and out of pocket losses.
WHEREFORE, the Plaintiffs respectfully request the Court:
(a) To award Plaintiff Barbara J. Anderson compensatory damages in the amount of Three Million Five Hundred Thousand Dollars ($3,500,000.00);
(b) To award Plaintiff Barbara J. Anderson punitive damages in the amount of Six Million Five Hundred Thousand Dollars ($6,500,000.00);
(c) To award Plaintiff A. Joseph Anderson compensatory damages in the amount of Three Million Five Hundred Thousand Dollars ($3,500,000.00);
(d) To award Plaintiff A. Joseph Anderson punitive damages in the amount of Six Million Five Hundred Thousand Dollars ($6,500,000.00); and
(e) To award Plaintiffs any other relief to which they may be entitled.
Respectfully submitted,
