Pippen v. Comcast Corporation et al

Filing 1

COMPLAINT filed by Scottie Pippen; Filing fee $ 350, receipt number 0752-6653080. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit)(Gold, Arthur)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
SCOTTIE PIPPEN,

)
)
Plaintiff,
)
v.
)
)
COMCAST CORPORATION AND
)
GENERAL ELECTRIC COMPANY, OWNERS,
)
OF NBC UNIVERSAL, OWNER OF CNBC,
)
d/b/a CNBC.Com, CBS CORPORATION
)
d/b/a CBSSPORTSLINE.COM, ARIZONA STATE
)
UNIVERSITY FOUNDATION FOR A NEW
)
AMERICAN UNIVERSITY A NON FOR PROFIT
)
CORPORATION, YAKEZIE NETWORK d/b/a
)
ONE MONEY DESIGN, MINT SOFTWARE INC.
)
d/b/a CREDIT NET, INVESTING ANSWERS.COM, )
SPORTSREPORT360, EVOLVE
)
MEDIA CORP, d/b/a HOOPSVIBE.COM, and THE )
UNIVERSITY OF TAMPA, INC. d/b/a MINARET
)
ONLINE,
)
)
Defendants,
)

Case No.

COMPLAINT

Plaintiff, SCOTTIE PIPPEN (“Scottie”), by and through his attorneys, Arthur S. Gold of
Gold & Coulson and the Spellmire Law Firm LLC, files this Complaint against the above named
defendants, and alleges as follows:
INTRODUCTION
1.

It is a most foul libel indeed to be falsely accused of being bankrupt.

2.

That is what happened to Scottie, and the malicious libel was disseminated across the

nation by the media.

1

THE PARTIES
3.

Scottie was born in Hamburg, Arkansas, and attended college at the University of Central

Arkansas in Conway. At the start of his college career, Scottie was a walk-on for the now-former
NAIA school and depended on his stipend for being the team manager and his summer job as a
welder to fund his education. Scottie then became a player and his 23.6 points per game average
and near 60% field goal shooting earned the Central Arkansas senior Consensus NAIA allAmerican honors in 1987. He was then selected fifth overall in the 1987 NBA Draft by the
Seattle SuperSonics and traded eventually to the Chicago Bulls for Olden Polynice.
Scottie became part of Chicago's young forward tandem with 6’ 10” power forward
Horace Grant, both coming off the bench to back up Brad Sellers and Charles Oakley during
their respective rookie seasons. With Michael Jordan, a fellow Chicago Bull, as a motivational
and instructional mentor, Scottie refined his skills while slowly developing many new ones over
the course of his career. Michael and Scottie were known to frequently play one-on-one outside
of team practices simply to hone each other's offensive and defensive skills. Scottie claimed the
starting small forward position during the 1988 Playoffs, helping the Jordan-led Bulls to reach
the conference semifinals for the first time in over a decade. Scottie emerged as one of the
league's premier young forwards at the turn of the decade, recording then-career highs in points
(16.5 points per game), rebounds (6.7 rebounds per game), and field goal shooting (48.9%) as
well as being the NBA's number three leader in steals (211). These feats earned Scottie his debut
NBA All-Star selection in 1990. Scottie continued to improve, helping the Bulls to the
Conference Finals in 1989 as well as in 1990. However, the Bulls lost both Conference Finals to
the Detroit Pistons.

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In 1991, Scottie emerged as the Bulls' primary defensive stopper and a versatile scoring
threat in Phil Jackson's Triangle offense. He helped lead the Bulls to their first three NBA
championships (1991, 1992 and 1993).
Scottie earned 10 NBA All-Defensive Team nods, including eight on the first team. In
1992, he was named to the original Dream Team, which competed in the Olympics in Barcelona,
Spain. With the U.S. winning the gold medal, both Scottie and Michael would become the first
players to win both NBA championship and Olympic gold medal in the same year.
Michael retired before the 1993–94 season, and in his absence Scottie emerged from his
shadow. That year, he earned All-Star Game MVP honors and led the Bulls in scoring, assists,
and blocks, and leading the entire league in steals, averaging 22.0 points, 8.7 rebounds, 5.6
assists, 2.9 steals, 1.9 three-pointers, and 0.8 blocks per game, while shooting 49.1% from the
field and a career-best 32% from the three-point line. For his efforts, Scottie earned the first of
three straight All-NBA First Team nods and finished third in the MVP voting. The Bulls finished
the season with 55 wins, only two fewer than the year before.
With the return of Michael and the addition of two-time champion Dennis Rodman, the
Bulls posted the best regular-season record in NBA history (72—10) in 1995–96 en route to
winning their fourth title against the Seattle SuperSonics. Later that year, Scottie became the first
(and to this date, the only) person to win an NBA championship and an Olympic gold medal in
the same year, twice, playing for Team USA at the Atlanta Olympics.
In the following season, Chicago finished a league-best 69–13 and again won the title,
this time defeating the Utah Jazz. Amid speculation that the 1997–98 season would be the last in
Chicago for Scottie, Michael, and Jackson, the Bulls followed by topping the Jazz again in the

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1998 NBA Finals to cap their second three-peat. Scottie was selected as one of the NBA's Fifty
Greatest Players when the league was celebrating its 50th season in 1997.
Scottie was a near-constant presence in the NBA post-season during his career, reaching
the playoffs 16 straight years (11 with Chicago, one with Houston, four with Portland). He
played in more playoff games than any NBA player except Robert Horry and Kareem AbdulJabbar. After retiring, he spent some time working as a basketball analyst for the Chicago Bulls.
He was a special assistant coach for the Los Angeles Lakers. On December 25, 2005, Scottie
debuted as studio analyst for the NBA on ABC. Before that, he was a part-time analyst for ESPN.
The Chicago Bulls retired Scottie's jersey number in a ceremony on December 9, 2005.
The team played against the Los Angeles Lakers that night, and Scottie was reunited with Phil
Jackson, Michael Jordan, Dennis Rodman, and Horace Grant during the ceremony. Scottie's
jersey number 33 joined Michael's 23, Jerry Sloan's 4, and Bob Love's 10 as the only numbers
retired by the Bulls. Scottie returned to the Bulls on July 15, 2010 as a team ambassador.
Scottie is remembered as one of the most versatile and agile players, and perhaps most
notably as one of the greatest defenders, to ever play the game of basketball. Much like fellow
Bull Michael Jordan, Scottie could provide tenacious on-the-ball perimeter defense, or tough
interior defense, and he was particularly effective as a help defender. He was gifted with
extraordinary athleticism, even compared with other professional athletes, and skills in areas that
bode well for basketball.
Throughout his life, Scottie worked zealously to create and maintain a reputation in the
community as a person of impeccable character, who has worked tirelessly to succeed as a

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student, teammate, businessperson, community member, husband, father, and mentor to children
and youth.
4

Defendants COMCAST CORPORATION, A CITIZEN OF THE STATE OF

PENNSYLVANIA AND GENERAL ELECTRIC CORPORATION, A CITIZEN OF THE
STATE OF NEW YORK own NBC Universal, which owns CNBC. Hereinafter these defendants
are collectively referred to as “CNBC,” which has its headquarters in Englewood Cliffs, N.J and
is a recognized world leader in business news, providing real-time financial market coverage and
business information to more than 340 million homes worldwide, including more than 95 million
households in the United States and Canada. CNBC’s Business Day programming is produced at
CNBC's headquarters in Englewood Cliffs, N.J. CNBC also includes reports from its news
bureaus worldwide in Midtown Manhattan, the NASDAQ MarketSite, Washington D.C.,
Chicago, Los Angeles, Palo Alto, London, Singapore and CNBC's headquarters in Englewood
Cliffs, N.J
5.

Defendant CBS Corporation d/b/a CBSSportsline.com is a citizen of the State of

Delaware, is a registered trademark of CBS Broadcasting Inc. (hereinafter ‘CBSSportsline”), a
year-round leader in television sports, broadcasts a portfolio of events on the CBS Television
Network, including the NFL’s American Football Conference; THE NFL TODAY, college
basketball, including the NCAA Division I Men’s Basketball Championship; golf, including The
Masters and PGA Championship; college football, including the SEC ON CBS; the U.S. Open
Tennis Championships; CBS SPORTS SPECTACULAR, including track & field, auto racing
and gymnastics. In addition, the division directs the CBS Sports Network, a 24-hour national

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cable network, which produces “Inside the NFL” for Showtime and partners with CBS
Sports.com in creating a recognized leader among sports Internet destinations.
6.

Defendant Arizona State University is a citizen of the State of Arizona and was founded

by a group of Valley cattlemen and farmers, establishing the Agricultural Advisory Council in
1947. The Arizona State College Foundation was incorporated in 1955 to broaden the mission of
the Agricultural Advisory Council. Now called the ASU Foundation Board of Directors, the
board was instrumental in raising support for all educational areas.
7.

Defendant Yakezie Network d/b/a One Money Design, is one of world's largest and most

sophisticated networks of personal finance and lifestyle bloggers. On information and belief it is
an assumed name owned by Sam Dogen in San Francisco, California. It started in December of
2009, and has since grown to be a mainstay force in the personal finance world.
8.

Mint Software Inc., is a subsidiary of Intuit, Inc., which is a citizen of the State of

Delaware. Founded in 2006, it provides a Web-based solution for online financial management.
It offers money management, debt management, expense tracking, investment management,
budget management, mutual fund, IRA management, and financial planning services. The
company also provides suggestions based on user’s spending patterns and automatic
categorization of purchases. Mint Software, Inc. was founded in 2006. As of November 2, 2009,
Mint Software, Inc. operates as a subsidiary of Intuit Inc.
9.

INVESTING ANSWERS is a citizen in the State of Texas and at one time was a

Maryland LLC but was dissolved yet still operatews under the name “INVESTING
ANSWERS”. Industry veterans Lou Betancourt and Paul Tracy founded Investing Answers in
2001. Investing Answers is a financial research and publishing company with offices in Austin,

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Texas and Gaithersburg, Maryland. It is the nation's premier source for investment research,
guidance, and related information.
10.

Sportsreport360.com was launched in June 2011 as a sports network for talented writers

dedicated to examining and profiling sports teams around the world. At one time it was a
Delaware LLC but has been dissolved and is presently a citizen of the State of Arizona still
operating under the name Sportsreport360.com.
11.

EVOLVE MEDIA CORP. is a Delaware corporation, owns HoopsVibe.com, and is a

citizen of the State of Delaware. It is an online forum site that disseminates all basketball-related
news to basketball fans.
12.

THE UNIVERSITY OF TAMPA, INC. is a citizen of the State of Florida and a private,

co-educational university in downtown Tampa, Florida. It owns and operates a student-run
newspaper by the name of Minaret Online, which claims to be the University of Tampa’s News
Source since 1933.
JURISDICTION AND VENUE
13.

Each of the above non-Illinois citizen defendants committed tortious acts within Cook

County, Illinois by publishing and disseminating and causing to be published and disseminated
the defamations described in this Complaint, in Cook County, Illinois, and elsewhere across the
country.
14.

Jurisdiction in this Court is proper under 28 USC § 1332 as complete diversity between

Plaintiff and Defendants exists in that Plaintiff is a citizen of the State of Illinois and all
Defendants are citizens of the States outlined in paragraphs 5-13 above: all of which are different
than the state of Plaintiff.

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15.

The amount in controversy exceeds $75,000 exclusive of interest and costs.

16.

Venue is properly laid in this District as a majority of the acts or omissions complained of

have occurred in this District.
THE LIBELS
17.

On April 26, 2011, the CNBC.com website published an article “15 Athletes Gone

Bankrupt” listing Scottie Pippen in which the following statement was made:
“Scottie Pippen is best remembered for his tenure with the Chicago Bulls. The
2010 Basketball Hall of Fame inductee was there when they won six NBA
Championships, and he was there during the 1995-1996 season in which they won
72 games. He is also the only person to win both an NBA championship and an
Olympic gold medal in the same year, and he is one of only four players from the
Chicago Bulls to have his jersey retired. Unfortunately, Pippen’s successes on the
court couldn’t stop him from losing career earnings worth $120 million, including
over $4 million for a corporate jet that was grounded just months after he bought
it. . .”
(A copy of that story is attached as Exhibit 1.)
18.

On January 26, 2011 CBSSports.com aired a story “Money a problem for a lot of former

players” with a huge picture of Scottie under the title: in which the following quote was made:
“A big, eye-catching number was tossed around a few years ago in regards to
former NBA players and bankruptcy. According to the Toronto Star, around 60
percent of NBA players are broke after five years of retirement.
There's been a little debate as to how accurate that number really is, but the truth
is this: A lot of former NBA players don't manage their millions well and end up
filing for bankruptcy. Not all do it just from spending on cars, houses, women and
other material things though. Most just lose it through poor money management.
Bad investments, bad business choices and bad people helping them.” (Emphasis
added.)
(A copy of that story is attached as Exhibit 2.)

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19.

On February 1, 2011, Sportsandentertainmentlawblog.com, created by Arizona State

University, tagged Scottie’s name with bankruptcy. (A copy of that story is attached as Exhibit
3.)
20.

On May 5, 2011 Onemoneydesign.com cited the CNBC.com story “15 Athletes Gone

Bankrupt” listing Scottie Pippen the following was quoted: (A copy of that story is attached as
Exhibit 4.)
“Scottie Pippen is best remembered for his tenure with the Chicago Bulls.
The 2010 Basketball Hall of Fame inductee was there when they won six
NBA Championships, and he was there during the 1995-1996 season in
which they won 72 games. He is also the only person to win both an NBA
championship and an Olympic gold medal in the same year, and he is one of
only four players from the Chicago Bulls to have his jersey retired.
Unfortunately, Pippen’s successes on the court couldn’t stop him
from losing career earnings worth $120 million, including over $4 million for
a corporate jet that was grounded just months after he bought it.”
21.

On May 31, 2011, Creditnet.com reported a story “Bankrupt Athletes: How They Got

There” Scottie Pippen is listed as one of the Athletes, in which the following quote was made:

“Scottie Pippen
Famous for his leading role with Michael Jordan and the Chicago Bulls, Pippen
earned nearly $120 million during his successful career. Rather, he suffered the
same fate of other athletes like Raghib “Rocket” Ismael, Rollie Fingers, Johnny
Unitas, and Sheryl Swoopes.”
(A copy of that story is attached as Exhibit 5.)
22.

On the website mint.com/blog/investing “From Stoke to Broke Why Are Sports Stars

Going Bankrupt?” was an article in which the following information was cited:
“Scottie Pippen, Basketball
Year bankruptcy filed: 2003
Risky investments, Buying a corporate jet”
(A copy of that story is attached as Exhibit 6.)

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23.

On April 27, 2011 Investinganswers.com posted a story “20 Star Athletes Who Went

From Millions to Bankruptcy Court”, “Scottie Pippen: Estimated Lost - $120 Million” in which
the following quote was made:
“Scottie Pippen was instrumental in six NBA Championships with the Chicago
Bulls throughout the 1990s. He was the "Robin" to Chicago's "Batman," Michael
Jordan. Pippen is considered one of the best NBA small forwards of all time, a
seven-time NBA All-Star and was inducted into the Basketball Hall of Fame on
August 13, 2010.
Unfortunately, Pippen not as successful with investing his money as he was on the
basketball court.”
(A copy of that story is attached as Exhibit 7.)
24.

On August 26, 2011, Sportsreport360.com posted a story “Top 5 NBA Players Who

Went Bankrupt” listing Scottie Pippen in which the following quote was made:
“Scottie Pippen won six NBA Championships with the Bulls, an Olympic gold
medal and is a Hall of Fame inductee. Pippen earned about $120 million during
his lustrous career, but ended up losing most of that amount.”
(A copy of that story is attached as Exhibit 8.)
25.

On October 26, 2011, HoopsVibe.com posted a story “If Dr. J is Broke, What Chance Do

ANY of Us Have??” listing Scottie Pippen in which the following quote was made:
“Scottie Pippen was another big name who lost big. After making $120 million dollars
during his playing career he famously filed bankruptcy due in large part to a failed
investment in a corporate jet. He also got screwed over by his former law firm, losing $27
million dollars in the process.”
(A copy of that story is attached as Exhibit 9.)
26.

On November 9, 2011, Minaret Online posted a story “How to Be an Athlete and Not Go

Broke – For Dummies” listing Scottie Pippen in which the following quote was made:
“Scottie Pippen has made approximately $250 million … These world championship
athletes have one analogous trait in common; they have all reached the point of broke
after their career has ended.”
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(A copy of that story is attached as Exhibit 10.)
27.

All of Defendants’ above statements are false. Scottie never filed bankruptcy and indeed

has a substantial net worth, which has not been less than approximately $40,000,000 in the last
ten years.
SCOTTIE’S PUBLIC SERVICE
28.

Scottie was honored in Miami, Florida at a ceremony by The Buoniconti Fund to Cure

Paralysis. That organization does work with Make A Wish and when asked why he was there,
the following interview took place:
Scottie: I’m being honored here tonight from a great foundation, the
Buoniconti Foundation for paralysis. It’s a great foundation, it’s great to be
honored among some of the greatest athletes in their various sports and it’s
just great for me to be here and be a part of something and knowing that it’s
for a great cause.
CGG: Has paralysis affected anyone you know?
SP: Yeah, it actually affected my brother when I was about four years old. I
had a brother who got paralyzed in a gym class and he’s still paralyzed to
this day; he’s 53 years old. It definitely has hit home to me and I think that
this is a great cause and hopefully in the future, no one will have to suffer the
way I have seen my brother suffer the last 40 years.
CGG: What do you hope will be the result of tonight?
SP: Well I hope they continue to raise money and continue to be able to fund
the research and what they need to find a cure.
CGG: What other causes are you passionate about?
SP: I’m passionate about diabetics for one. I have a mother who’s diabetic. I
have very deep feelings for anything revolving [sic] kids, or child abuse,
things of that nature. I definitely put this among the top because of the fact
that I lived through it at a younger age.
At Victor Herbert elementary School in Chicago the following occurred:
Chicago Bulls legend Scottie Pippen and other Bulls members teamed up with
Kia Motors to organize a rally to deliver much-needed school supplies to
students at Victor Herbert Elementary School in Chicago. Pippen was joined
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by Bulls personalities to include mascot Benny the Bull and team members
Randy Brown, Adrian Griffin, Bob Love, Sidney Green, and Chuck Swirsky.
The Bulls were on hand to personally deliver the donated supplies, including
spiral notebooks, pencils, pens, pocket folders, crayons, and backpacks – all in
Kia vehicles – to the kids at the school.

Fans were also encouraged to make donations to the drive online, which resulted
in raising $11,740 that went towards the purchase of 35 brand new laptops for
the students.
Moreover, Scottie has signed numerous materials for donations to charity events and has been
heavily involved in the CharitaBulls (charity arm of the Bulls). He appeared at the opening of the
Kroc Center on the southside of Chicago where the Bulls donated $1million. He also appeared at
the Champions for Children event in 2011 benefitting the Children's Memorial Hospital.
On November 9, 2010 he publicized the McPherson EnergizaBulls Fitness Learning
Center Opening. The student, parents, faculty and staff of McPherson Elementary (4728 N.
Wolcott) welcomed Bulls legend Scottie Pippen. The state-of-the-art fitness center is part of an
ongoing program by the Chicago Bulls to help teach students the importance of a healthy and
active lifestyle. The EnergizaBulls program is supported by a $1.475 million grant from the U.S.
Department of Education, awarded to the Chicago Bulls in an effort to help curb the rising
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obesity rates among young children. The McPherson fitness center is the tenth facility built by
the Chicago Bulls organization at Chicago area public schools, with plans for a total of 15 by the
end of the 2011-12 school year.
On October 21, 2010. Scottie joined the Bulls as they officially opened the 2010-11
basketball season with the team’s annual Tip-Off Luncheon at the Hilton Chicago. Long-time
guests enjoyed lunch and took advantage of the opportunity to purchase pieces of Bulls’ history
in a silent auction. All proceeds from the event and the silent auction benefitted CharitaBulls.
On October 7, 2010, Scottie attended the Ray and Joan Kroc Corps Community Center
Groundbreaking. CharitaBulls, donated $1 million to the Salvation Army Chicago Metropolitan
Division to help build the Ray and Joan Kroc Corps Community Center in the West Pullman
neighborhood. The Kroc Center is the largest single investment ever made by a social service
organization in the City of Chicago.
29.

Paragraph 29 demonstrates only a few examples of Scottie’s public commitment.

30.

But, saliently, the Defendants’ sloppy conduct, in light of the previous description of

Scottie, was especially egregious in view of the fact that a mere click of the mouse for
bankruptcies in Scottie’s home State would have illustrated he never filed a bankruptcy.
31.

Scottie has had to vigorously deny and refute the above defamatory statements to

business associates, colleagues, family and friends despite his outstanding charitable
involvement and appearances.
32.

As a proximate result of the above-delineated false defamatory statements made by

Defendants, Scottie’s reputation has been permanently damaged and he has been forever

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deprived of the impeccable personal and professional reputation which he worked for years to
create and maintain, and which he deserves.
33.

As a proximate result of the above delineated false defamatory statements made by

Defendants, Plaintiff has suffered emotional distress and mental pain and suffering, and will
continue to do so in the future.
34.

As a proximate result of the above delineated false defamatory statements made by

Defendants, Plaintiff has suffered substantial monetary damages because since these false
defamatory statements have been circulated worldwide, Scottie’s offers for personal appearances
and endorsements have dwindled to a fraction of what they had been previously: all of which
will be established at the trial of this matter.
35.

Scottie is entitled to punitive damages in order to punish and deter Defendants from such

reckless conduct.
COUNT I - NEGLIGENCE
36.

Paragraphs 1 through 36 are realleged and incorporated herein.

37.

Each Defendant owed a duty of care to Scottie, who never filed bankruptcy, including a

duty to properly investigate the truth of the matter.
38.

Each Defendant failed to act as a reasonably careful person would act under the same or

similar circumstances.
39.

As a proximate cause, Scottie was injured as alleged.
WHEREFORE, Scottie prays this Court to enter judgment in his favor and against each

of the Defendants, as follows:
a.

Judgment in such amount as the Court may deem just and appropriate to

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compensate Scottie for all actual damages that Plaintiff’s reputation and privacy
suffered.
b.

Court costs.

c.

Such further relief as this Court may deem necessary and proper.
COUNT II - FALSE LIGHT

40.

Paragraphs 1 through 40 are realleged and incorporated herein.

41.

AS ALLEGED ABOVE, EACH Defendant’s actions placed Scottie in a false light before

the public.
42.

The false light, as alleged above, was of such a nature as to be highly offensive to a

reasonable person.
43.

As a result, Scottie has been damaged.
WHEREFORE, Scottie prays that this court enter judgment in his favor and against each

of the Defendants, as follows:
a.

Judgment in such amount as the Court may deem just and appropriate to
compensate Scottie for all actual damages that he may demonstrate to have
suffered.

b.

Judgment in an amount equivalent to that sum fixed by the Court to punish each
Defendant for its wrongful conduct, but in no event less than $1,000,000.

c.

Court costs.

d.

Such further relief as this Court may deem necessary and proper.
COUNT III - DEFAMATION PER SE

44.

Paragraphs 1 through 44 are realleged and incorporated herein.

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45.

Defendants’ unprivileged defamations, as alleged above, were published with actual

malice and/or utter disregard for Scottie’s rights and interest.
46.

Defendants’ false statements about Scottie constitute defamation per se.
WHEREFORE, Scottie prays this court enter judgment in favor of Scottie and against

each of the Defendants, as follows:
a.

Judgment in such amount as the Court may deem just and appropriate to
compensate Scottie for all presumed damages that Scottie has suffered as a result
of Defendants’ wrongful and unprivileged defamations.

b.

Judgment in such amount as the Court may deem just and appropriate to
compensate Scottie for all actual damages that he may be demonstrated to have
suffered as a result of the Defendants’ wrongful and unprivileged defamations.

c.

Judgment in an amount equivalent to that sum fixed by the Court to punish each
Defendant for its malicious and unprivileged defamation, but in no event less than
$1,000,000.

d.

Court costs.

e.

Such further relief as this Court may deem necessary and proper.
Respectfully submitted,
s/Arthur S. Gold
By one of Plaintiff’s attorneys
Arthur S. Gold
Gold & Coulson
11 S. LaSalle Street, Suite 2402
Chicago, IL 60603
[phone]
Jeffrey Katz
Spellmire Law Firm
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233 S. Wacker Drive, Suite 2100
Chicago, IL 60606
[phone]
C:\wp51\asg\PIPPEN\Complaint.doc

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