former Bruderhof members/residents KIT Newsletter December 1997 Volume IX #12

Untitled1

NOTE: Addresses of plaintiffs, attorneys and co-defendants have been
deleted as a courtesy to those involved.

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

BRUDERHOF COMMUNITIES IN NEW YORK, INC.,
and CHRISTIAN DOMER, Individually,
Plaintiffs,

- against -

THE PEREGRINE FOUNDATION and RAMON SENDER,
JULIUS H. RUBIN and
S. BLAIR PURCELL, Individually,
Defendants.

Plaintiffs BRUDERHOF COMMUNITIES IN NEW YORK, INC.
(hereinafter
"THE BRUDERHOF") and CHRISTIAN DOMER (hereinafter "DOMER"),
by their attorneys, Biedermann, Hoenig, Massamillo & Ruff, P.C.,
as and for their Complaint, upon information and belief,
aver as follows:

GENERAL ALLEGATIONS

1. Plaintiff THE BRUDERHOF is a corporation organized and existing under the laws of the State of New York and has its principal location at the Woodcrest Bruderhof, [DELETED].

2. Plaintiff CHRISTIAN DOMER is an individual residing at theWoodcrest Bruderhof, [DELETED].

3. Defendant THE PEREGRINE FOUNDATION (hereinafter "PEREGRINE") is a non-profit corporation duly organized and existing under the laws of the State of California.

4. Upon information and belief, defendant PEREGRINE at all times relevant hereto, regularly transacts, solicits and does business in New York.

5. Upon information and belief, defendant RAMON SENDER (hereinafter "SENDER"), is a citizen of the State of [DELETED] and, as both an officer of defendant PEREGRINE and in his personal capacity, regularly transacts, solicits and does business in New York and has engaged in a persistent course of conduct in the State of New York.

6. Upon information and belief, defendant S. BLAIR PURCELL(hereinafter "PURCELL"), is a citizen of the State [DELETED] and, as both an officer and member of defendant PEREGRINE and in his personal capacity, regularly transacts, solicits and does business in New York and has engaged in a persistent course of conduct in the State of New York.

7. Upon information and belief, defendant JULIUS H. RUBIN (hereinafter "RUBIN"), is a citizen of the State of [DELETED], and, as both a member of defendant PEREGRINE and in his personal capacity, regularly transacts, solicits and does business in New York, and in his personal capacity has engaged in a persistent course of conduct in the State of New York.

8. Plaintiff THE BRUDERHOF was formed in 1954 and is a collective membership organization. THE BRUDERHOF's purpose is for its members to live together in the spirit of, and obedience to, the teachings of Christ as was done by Christians throughout the centuries. Central tenets of THE BRUDERHOF are the spirit of love as professed by Jesus and a respect for family, children, purity in relationships and lifelong faithfulness in marriage. Members of THE BRUDERHOF also work together and share the income they generate in common, as instructed in Bible teachings.

9. The purposes of THE BRUDERHOF are achieved only by, and through, communal living. Members of THE BRUDERHOF earn their livelihood, interalia, by manufacturing educational furniture and toys for children as well as manufacturing specialized equipment for the physically disabled. In the operation of their businesses and in the earning of their livelihood, THE BRUDERHOF is dependent upon their reputation in the community and the goodwill of their customers.

10. Defendant, PEREGRINE, via its founder and president, SENDER, was established for the sole purpose of undermining the goals and membership of THE BRUDERHOF. Toward this end, it conducts, organizes and participates in a regular course of activities in New York (e.g., protests, meetings and mailings) solely designed to further its purpose; to wit, the ultimate dissolution of THE BRUDERHOF communities.

11. Defendant SENDER is the editor of PEREGRINE's Publication, the so-called "KIT" newsletter, the President of PEREGRINE and, PEREGRINE/KIT's chief proponent of the dissolution of THE BRUDERHOF communities.

12. At all times material herein, defendant PURCELL has furthered the goals of defendants PEREGRINE and SENDER as an officer and member of PEREGRINE by regularly contributing to the publications, mailings, meetings and protests of PEREGRINE and the KIT newsletter. PURCELL has further stated that his intent, along with that of defendants PEREGRINE and SENDER, is for the dissolution of THE BRUDERHOF communities; and he has stated as much in a October 11, 1995 television broadcast on WCVB-TV in Boston, Massachusetts: "We're out to destroy the BRUDERHOF."

13. At all times material herein, defendant RUBIN has furthered the goals of defendants PEREGRINE, SENDER and PURCELL, by regularly contributing to the publications, mailings, meetings and protests of PEREGRINE and the KIT newsletter and by participating in a campaign of disinformation about THE BRUDERHOF to the public at large. Upon information and belief, although RUBIN has published many articles and essays concerning THE BRUDERHOF, he has never visited any of THE BRUDERHOF communities in the United States or abroad.

14. At all times relevant hereto, and as above-mentioned, PEREGRINE conducted a project known as the "KIT newsletter", which itself was an activity of the KIT Information Service (a Service also run by PEREGRINE).

15. At all times relevant hereto, PEREGRINE also maintained a web site on the Internet for, inter alia, the publication of KIT newsletters.

16. Upon information and belief, the KIT newsletter is mailed to subscribers throughout the United States, including New York. Attached hereto as Exhibit "A" is a copy of the February 1997 edition of the KIT newsletter which was mailed by KIT/SENDER and which bears a New York zip code, i.e., 12061-3721.

SPECIFIC ALLEGATIONS

17. In or about November, 1994, THE BRUDERHOF petitioned Fayette County, Pennsylvania for the rezoning of certain property in Wharton Township in order to replace an old plant used in the making of educational furniture and toys for children as well as manufacturing specialized equipment for the physically disabled.

18. On November 22, 1994, the Fayette County Planning Commission staff endorsed the proposed rezoning. On December 7, 1994, the Wharton Township Planning Board unanimously approved the rezoning.

19. On or about January, 1995, SENDER/KIT contacted officials of Wharton Township to influence them against the BRUDERHOF in a decision involving zoning permission to build a new factory at the New Meadow Run BRUDERHOF.

20. In furtherance of this plan, SENDER/KIT distributed "media packets" to Township officials wherein, inter alia, they characterized THE BRUDERHOF as a "destructive cult" and "coercive Christian sect", alleged that THE BRUDERHOF engaged in child abuse, and was a "parasite on society at large." In addition, SENDER/KIT circulated copies of THE BRUDERHOF's property tax exemption request to Township officials to further influence the Township against THE BRUDERHOF.

21. Upon information and belief, neither defendants PEREGRINE, SENDER, RUBIN nor PURCELL live in or near Fayette County, Pennsylvania, and have no business or other interest in that community except insofar as they envision an opportunity to destroy THE BRUDERHOF.

22. On or about February 6, 1995, as a direct result of SENDER'S/KIT'S activities, the Wharton Township Supervisors denied THE BRUDERHOF's request for rezoning. On August 7, 1995, only after an enormous expenditure of time, effort and money, did THE BRUDERHOF convince Wharton Township to issue to THE BRUDERHOF an extension of non-conforming use for the area of proposed rezoning.

23. On or about February, 1996, SENDER/KIT, maliciously contriving and intending solely to injure plaintiff THE BRUDERHOF and deprive it of the respect, confidence and esteem peculiarly essential to plaintiff's professions and businesses and contriving and intending to deprive plaintiff of its good name, reputation and the esteem of its clients and business associates and customers and to bring it into disastrous scandal, ridicule and professional disrepute before its clients, professional associates, friends, neighbors and acquaintances and the public in general and to hold plaintiff up to public scorn, ridicule and disgrace, did with actual malice, falsely and wrongfully publish and circulate of and concerning plaintiff THE BRUDERHOF in the February 1996 (vol. VIII #2) edition of the KIT newsletter and/or by regular or electronic mail over the Internet, claims of sexual abuses, criminal failure to report such abuses and cover-ups thereof, by way of the following malicious, false, scandalous and defamatory libel:

There have been several reports in the KIT newsletter recently
concerning physical and sexual abuse of minor children
within the BRUDERHOF.... And the abuse is NEVER reported.
How can these victims be protected? The fact is that physical
or sexual abuse is a crime . . . [and] representatives of any
institution (such as a church or medical care facility) who
become aware of alleged physical or sexual abuse have [sic]
specific responsibility under criminal law to report each occurrence
to the appropriate civil authority for investigation. Failure to do
so is a crime.
In addition, it would be a particularly egregious offense if the
church leadership moved an abuser out of the jurisdiction in
which a criminal act occurred in an effort to avoid embarrassment
to the Bruderhof.

24. On or about December 14, 1994, PURCELL, maliciously contriving and intending solely to injure plaintiff THE BRUDERHOF and deprive it of the respect, confidence and esteem peculiarly essential to plaintiff's professions and businesses and contriving and intending to deprive plaintiff of its good name, reputation and the esteem of its clients and business associates and customers and to bring it into disastrous scandal, ridicule and professional disrepute before its clients, professional associates, friends, neighbors and acquaintances and the public in general and to hold plaintiff up to public scorn, ridicule and disgrace, did with actual malice, falsely and wrongfully publish and circulate of and concerning plaintiff THE BRUDERHOF in the KIT newsletter and/or by regular or electronic mail over the Internet, claims of sexual abuses and cover-ups thereof, by way of the following malicious, false, scandalous and defamatory libel:

our understanding is that he [BRUDERHOF member/doctor
Milton Zimmerman] has been moved out of pennsylvania to a new york
or connecticut [BRUDER] 'hof so that he is not available to answer
inquiries about this case from the sheriff's investigators near new
meadow run. The young woman's parents have been moved to canada
to avoid the same inquiries.

25. On or about June 29, 1995, PURCELL, contriving and intending solely to maliciously and wantonly injure plaintiffs, harass plaintiffs, subject plaintiffs to a criminal investigation, and deprive them of their good name, reputation and the esteem of their clients and business associates and customers did maliciously and wrongfully contact Howard County, Maryland, Police and accuse DOMER of making death threats against PURCELL, causing the Howard county, Maryland, Police to initiate a criminal investigation against plaintiff DOMER.

26. On or about April 10 through 12, 1996, SENDER/KIT and PURCELL maliciously contriving and intending solely to injure plaintiffs THE BRUDERHOF and deprive them of the respect, confidence and esteem peculiarly essential to plaintiffs' professions and businesses and contriving and intending to deprive plaintiffs of their good name, reputation and the esteem of their client sand business associates and customers and to bring them into disastrous scandal, ridicule and professional disrepute before their clients, professional associates, friends, neighbors and acquaintances and the public in general and to hold plaintiffs up to public scorn, ridicule and disgrace, did with actual malice, falsely and wrongfully publish and circulate of and concerning plaintiffs THE BRUDERHOF in letters and an April 1996 edition of the KIT newsletter by regular and/or electronic mail over the Internet, claims of death threats against PURCELL by DOMER and THE BRUDERHOF, by way of the following malicious, false, scandalous and defamatory libel:

They [THE BRUDERHOF] harassed COB's 800 help line
with nearly 2000 phone calls during the first thirty days
it was in service. Three of the calls that Blair Purcell personally
answered were death threats. Two of those came from National
Airport in Washington, D.C., and independent information has
been developed placing a ranking Bruderhof person at the
airport at precisely the time the calls were made.

27. In or about September, 1995, THE BRUDERHOF, along with The James E. Chaney Foundation, formed The National Commission on Capital Punishment ("NCCP") for a public review, in five regional hearings throughout the United States, of the human cost of the practice of Capital Punishment in the United States. THE BRUDERHOF is opposed to the use of Capital Punishment.

28. In an effort to derail the hearings and maliciously harm and discredit THE BRUDERHOF, SENDER/KIT and PURCELL distributed "media packets" including video tapes to the Philadelphia Fraternal Order of Police and other officials, individuals and organizations in the Philadelphia area wherein they characterized THE BRUDERHOF as a "totalitarian religious sect", alleged that THE BRUDERHOF engaged in harassment and "death threats", child abuse, and are "committed to 'spiritual' bullying and brutality."

29. Upon information and belief, SENDER, RUBIN and PURCELL are opposed to the death penalty, and engaged in their persistent course of conduct solely to vilify and maliciously harm THE BRUDERHOF.

30. On or about March 27, 1996, RUBIN and SENDER participated in a late-night radio talk-show broadcast on WWDB-FM, in Philadelphia, Pennsylvania.

31. During the course of RUBIN's comments on the program, RUBIN maliciously contriving and intending solely to injure plaintiffs THE BRUDERHOF and deprive them of the respect, confidence and esteem peculiarly essential to plaintiffs' professions and businesses and contriving and intending to deprive plaintiffs of their good name, reputation and the esteem of their clients and business associates and customers and to bring them into disastrous scandal, ridicule and professional disrepute before their clients, professional associates, friends, neighbors and acquaintances and the public in general and to hold plaintiffs up to public scorn, ridicule and disgrace, maliciously spoke of and concerning plaintiffs THE BRUDERHOF with the following words: that THE BRUDERHOF played "fast and loose with Social Security".

32. In or about April, 1996, SENDER/KIT, maliciously contriving and intending solely to injure plaintiffs THE BRUDERHOF and deprive them of the respect, confidence and esteem peculiarly essential to plaintiffs' professions and businesses and contriving and intending to deprive plaintiffs of their good name, reputation and the esteem of their clients and business associates and customers and to bring them into disastrous scandal, ridicule and professional disrepute before their clients, professional associates, friends, neighbors and acquaintances and the public in general and to hold plaintiffs up to public scorn, ridicule and disgrace, did with actual malice, falsely and wrongfully publish and circulate of and concerning plaintiffs THE BRUDERHOF in the April, 1996 KIT newsletter (Vol. 4, #8) and/or by regular or electronic mail over the Internet, the transcript of the aforesaid WWDB-FM radio program which contained the following malicious, false, scandalous and defamatory words: that THE BRUDERHOF played "fast and loose with Social Security".

33. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

34. By reason of SENDER'S/KIT'S malicious and intentional publication and dissemination of false statements and misleading information to Wharton Township officials, defendant SENDER has inflicted intentional harm upon plaintiffs THE BRUDERHOF.

35. Upon information and belief, defendant SENDER can offer no legally justifiable reason or excuse for these actions.

36. As a result of these actions, defendants have suffered and will continue to suffer special damages including, but not limited to, cost incurred due to delaying of the building schedule in the amount of two hundred seventy eight thousand, nine hundred and ninety nine dollars ($278,999.00), and damage to their personal and professional reputations.

AS AND FOR A SECOND CAUSE OF ACTION AGAINST PEREGRINE AND RAMON SENDER FOR INJURIOUS FALSEHOOD

37. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

38. By reason of SENDER'S/KIT'S malicious and intentional publication and dissemination of the false and misleading information to Wharton Township officials, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens, have suffered a tremendous amount of embarrassment, humiliation and mental agony, have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A THIRD CAUSE OF ACTION AGAINST PEREGRINE AND RAMON SENDER FOR DEFAMATION

39. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

40. By reason of SENDER'S/KIT'S intentional and malicious publication and dissemination of the information contained in the above February, 1996, KIT Newsletter by publication through regular and/or electronic mail on the Internet regarding the claims of sexual abuse and cover- up thereof, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens; have suffered a tremendous amount of embarrassment, humiliation and mental agony; have been held in contempt, distrust and ridicule; and have been disparaged in their office, profession and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A FOURTH CAUSE OF ACTION AGAINST PEREGRINE AND RAMON SENDER FOR INJURIOUS FALSEHOOD

41. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

42. By reason of SENDER'S/KIT'S malicious and intentional publication and dissemination of the false and misleading information contained in the above February, 1996 KIT Newsletter by publication through regular and/or electronic mail on the Internet regarding the claims of sexual abuse and cover-up thereof, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens, have suffered a tremendous amount of embarrassment, humiliation and mental agony, have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A FIFTH CAUSE OF ACTION AGAINST S. BLAIR PURCELL FOR DEFAMATION

43. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

44. By reason of PURCELL'S intentional and malicious publication and dissemination of the information contained in the above December, 1994 correspondence by publication through regular and/or electronic mail on the Internet regarding the claims of sexual abuse and cover-up thereof, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens; have suffered a tremendous amount of embarrassment, humiliation and mental agony; have been held in contempt, distrust and ridicule; and have been disparaged in their office, profession and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A SIXTH CAUSE OF ACTION AGAINST S. BLAIR PURCELL FOR INJURIOUS FALSEHOOD

45. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein. 46.

By reason of PURCELL'S intentional and malicious publication and dissemination of the false and misleading information contained in the above December 1994, correspondence by publication through regular and/or electronic mail on the Internet regarding the claims of sexual abuse and cover-up thereof, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens, have suffered a tremendous amount of embarrassment, humiliation and mental agony, have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A SEVENTH CAUSE OF ACTION AGAINST S. BLAIR PURCELL FOR PRIMA FACIE TORT

47. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

48. By reason of PURCELL'S harmful acts and malicious and intentional furnishing of false statements and misleading information to Howard County, Maryland, Police officials, defendant PURCELL has inflicted intentional harm upon plaintiffs THE BRUDERHOF and DOMER.

49. Upon information and belief, defendant PURCELL can offer no justifiable reason or excuse for these actions.

50. As a result of these actions, plaintiffs THE BRUDERHOF and DOMER have suffered and will continue to suffer special damages including, but not limited to, attorneys' costs and fees arising out of the Howard County, Maryland, Police investigation in the amount of two- thousand dollars ($2,000.00), and damage to their personal and professional reputations.

AS AND FOR AN EIGHTH CAUSE OF ACTION AGAINST S. BLAIR PURCELL FOR INJURIOUS FALSEHOOD

51. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

52. By reason of PURCELL'S harmful acts and malicious and intentional furnishing of false and misleading information to Howard County, Maryland, Police officials, plaintiffs THE BRUDERHOF and DOMER have been deprived in the State of New York of the public confidence which they held as private citizens, have suffered a tremendous amount of embarrassment, humiliation and mental agony, have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A NINTH CAUSE OF ACTION AGAINST PEREGRINE, RAMON SENDER AND S. BLAIR PURCELL FOR DEFAMATION

53. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

54. By reason of SENDER'S/KIT'S and PURCELL'S intentional and malicious publication and dissemination of the information contained in the above April 10 through 12, 1996, publications by publication through regular and/or electronic mail on the Internet regarding the claims of alleged death threats upon PURCELL by DOMER, plaintiffs THE BRUDERHOF and DOMER have been deprived in the State of New York of the public confidence which they held as private citizens; have suffered a tremendous amount of embarrassment, humiliation and mental agony; have been held in contempt, distrust and ridicule; and have been disparaged in their office, profession and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A TENTH CAUSE OF ACTION AGAINST PEREGRINE, RAMON SENDER AND S. BLAIR PURCELL FOR INJURIOUS FALSEHOOD

55. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

56. By reason of SENDER'S/KIT'S and PURCELL'S malicious and intentional publication and dissemination of the false and misleading information contained in the above April 10 through 12, 1996, publications by publication through regular and/or electronic mail on the Internet regarding the claims of alleged death threats upon PURCELL by DOMER, plaintiffs THE BRUDERHOF and DOMER have been deprived in the State of New York of the public confidence which they held as private citizens, have suffered a tremendous amount of embarrassment, humiliation and mental agony, have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR AN ELEVENTH CAUSE OF ACTION AGAINST PEREGRINE, RAMON SENDER AND S. BLAIR PURCELL FOR PRIMA FACIE TORT

57. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

58. By reason of SENDER'S/KIT'S and PURCELL'S March, 1996, activities in connection with THE BRUDERHOF'S participation in the National Commission on Capital Punishment, their harmful acts and malicious and intentional furnishing of false statements and misleading information to The Philadelphia Fraternal Order of Police and other officials, individuals and organizations in the Philadelphia, Pennsylvania, area, defendants SENDER and PURCELL have inflicted intentional harm upon plaintiffs THE BRUDERHOF.

59. Upon information and belief, defendants SENDER and PURCELL can offer no justifiable reason or excuse for these actions.

60. As a result of these actions, plaintiffs THE BRUDERHOF have suffered and will continue to suffer special damages including, but not limited to, expenses, attorneys' costs and fees arising out of the cancellation of the further planned hearings in four other cities, in the amount of twenty-one thousand, one hundred and eighty five dollars ($21,185.00), and damage to their personal and professional reputations.

AS AND FOR A TWELFTH CAUSE OF ACTION AGAINST PEREGRINE, RAMON SENDER AND S. BLAIR PURCELL FOR INJURIOUS FALSEHOOD

61. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

62. By reason of SENDER'S/KIT'S and PURCELL'S March, 1996, activities in connection with THE BRUDERHOF'S participation in the National Commission on Capital Punishment, their harmful acts and malicious and intentional furnishing of false statements and misleading information to The Philadelphia Fraternal Order of Police and other officials, individuals and organizations in the Philadelphia, Pennsylvania, area, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens, have suffered a tremendous amount of embarrassment, humiliation and mental agony, have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A THIRTEENTH CAUSE OF ACTION AGAINST JULIUS RUBIN FOR CONSPIRACY TO COMMIT PRIMA FACIE TORT AND INJURIOUS FALSEHOOD

63. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

64. Defendant RUBIN has participated and is participating in a long standing conspiracy to abuse, discredit, vilify, slander and injure by malicious falsehoods plaintiffs THE BRUDERHOF and DOMER because of their devotion and adherence to their communal living and Christian way of life. Defendants RUBIN, SENDER and PURCELL belong to a small coterie of individuals, some of whom had been members of THE BRUDERHOF community and from which they are now estranged, whose sole aim is the destruction and dissolution of THE BRUDERHOF communities.

65. As further part of this continuing plan and conspiracy and with willful and malicious motives, defendant RUBIN did intentionally furnish false statements and misleading information to The Philadelphia Fraternal Order of Police and other officials, individuals and organizations in the Philadelphia, Pennsylvania, area, and has inflicted intentional harm upon plaintiffs THE BRUDERHOF, as set forth in paragraphs 25 through 32 and 57 through 62, above.

66. As a direct result of this continuing plan and conspiracy and with willful and malicious motives, defendant RUBIN has caused plaintiffs THE BRUDERHOF to have suffered and to continue to suffer special damages including, but not limited to, expenses, attorneys' costs and fees arising out of the cancellation of the further planned hearings in four other cities, in the amount of twenty-one thousand, one hundred and eighty five dollars ($21,185.00), and damage to their personal and professional reputations.

67. As a direct result of this continuing plan and conspiracy and with willful and malicious motives, defendant RUBIN caused THE BRUDERHOF to suffer a tremendous amount of embarrassment, humiliation and mental agony, and caused THE BRUDERHOF to have been held in contempt, distrust and ridicule and have been disparaged in their office, professions and trades, as set forth in paragraphs 25 through 32 and 56 through 60, above, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A FOURTEENTH CAUSE OF ACTION AGAINST JULIUS RUBIN FOR DEFAMATION

68. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

69. By reason of RUBIN'S March 27, 1996, intentional and malicious publication of false statements and misleading information in a late-night radio talk-show broadcast on WWDB-FM, in Philadelphia, Pennsylvania, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens; have suffered a tremendous amount of embarrassment, humiliation and mental agony; have been held in contempt, distrust and ridicule; and have been disparaged in their office, profession and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

AS AND FOR A FIFTEENTH CAUSE OF ACTION AGAINST JULIUS RUBIN FOR INJURIOUS FALSEHOOD

70. Plaintiffs reallege and incorporate by reference each and every allegation set forth in paragraphs 1 through 32, inclusive, as though fully set forth herein.

71. By reason of RUBIN'S March 27, 1996, intentional and malicious publication of false statements and misleading information in a late-night radio talk-show broadcast on WWDB-FM, in Philadelphia, Pennsylvania, plaintiffs THE BRUDERHOF have been deprived in the State of New York of the public confidence which they held as private citizens; have suffered a tremendous amount of embarrassment, humiliation and mental agony; have been held in contempt, distrust and ridicule; and have been disparaged in their office, profession and trades, all to their damage in the sum of one million dollars ($1,000,000.00).

WHEREFORE, plaintiffs pray for judgment as against the defendants THE PEREGRINE FOUNDATION and RAMON SENDER, for a sum to exceed two million, three hundred thousand, one hundred and eighty four dollars ($2,300,184.00) in compensatory damages, and for a sum to exceed one million dollars ($1,000,000.00) in punitive damages, and for such other, further and different relief as the Court deems proper under the circumstances; plaintiffs pray for judgment as against the defendant S. BLAIR PURCELL, for a sum to exceed two million, twenty-three thousand, one hundred and eighty five dollars ($2,023,185.00) in compensatory damages, and for a sum to exceed one million dollars ($1,000,000.00) in punitive damages, and for such other, further and different relief as the Court deems proper under the circumstances; plaintiffs pray for judgment as against the defendant JULIUS RUBIN, for a sum to exceed two million, twenty one thousand, one hundred and eighty five dollars ($2,021,185.00) in compensatory damages, and for a sum to exceed one million dollars ($1,000,000.00) in punitive damages, and for such other, further and different relief as the Court deems proper under the circumstances.

Dated: July 21, 1997 New York, New York

BIEDERMANN, HOENIG, MASSAMILLO & RUFF
Attorneys for Plaintiffs
BRUDERHOF COMMUNITIES IN NEW YORK, INC.
and CHRISTIAN DOMER, Individually
[DELETED]

TO:

THE PEREGRINE FOUNDATION
c/o RAMON SENDER, PRESIDENT
[DELETED]

RAMON SENDER
[DELETED]BR>

S. BLAIR PURCELL
[DELETED]

JULIUS H. RUBIN
[DELETED]