Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
10Activity
0 of .
Results for:
No results containing your search query
P. 1
Hill v. PAUS Complaint - Filed 092612

Hill v. PAUS Complaint - Filed 092612

Ratings: (0)|Views: 213,421 |Likes:
Published by joenyc

More info:

Published by: joenyc on Sep 26, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

11/29/2012

pdf

text

original

 
 
1
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADO
Civil Action No.:KRISTINA HILL,BRIAN EDWARDS, andTHOMAS PRIVITERE,Plaintiffs,v.PUBLIC ADVOCATE OF THE UNITED STATES,Defendant.
COMPLAINT
Plaintiffs KRISTINA HILL, BRIAN EDWARDS, and THOMAS PRIVITERE, throughtheir undersigned counsel, bring this action against Defendant PUBLIC ADVOCATE OF THEUNITED STATES (“PAUS”), a non-governmental organization. By this Complaint, Plaintiffsseek declaratory relief, compensatory damages, costs and attorneys’ fees, as well as any otherrelief to which they may be entitled.
PRELIMINARY STATEMENT
1.
 
This case is about the defilement of a beautiful moment. Brian Edwards(“Edwards”) and Thomas Privitere (“Privitere”) are a married couple living in Montclair, NewJersey. Edwards and Privitere, like many couples, hired a photographer to memorialize theirhappiness on the occasion of their engagement. They chose Kristina Hill (“Hill”), a well-regarded Brooklyn wedding photographer, and a college friend of Edwards.
Case 1:12-cv-02550 Document 1 Filed 09/26/12 USDC Colorado Page 1 of 13
 
 22.
 
Hill is a professional photographer. She began working as a freelance editorialphotographer eight years ago for newspapers and magazines, and for the past four years hasmade her living as a professional wedding photographer.3.
 
Hill made the following photograph, which became one of the couple’s favoritephotos (the “Photograph”):4.
 
Defendant Public Advocate of the United States is an organization whichencourages discrimination against lesbian, gay, bisexual and transgender (“LGBT”) people.5.
 
Earlier this spring, PAUS sent the following mailer to recipients in Colorado (the“White Mailer”):
Case 1:12-cv-02550 Document 1 Filed 09/26/12 USDC Colorado Page 2 of 13
 
 36.
 
The White Mailer refers to Republican then-State Senator Jean White, of Colorado’s 8th District, who had supported a bill that would have granted same-sex couples theright to enter into civil unions. At the time, Sen. White was engaged in a primary race againstanother Republican for her Senate seat.7.
 
The reverse side of the White Mailer identifies the sender as “Public Advocate of the United States, 5613 Leesburg Pike, Suite 17, Falls Church, VA 22041,PublicAdvocateUSA.org”.8.
 
Prior to Plaintiffs’ discovery of the unlawful acts described in this Complaint, theWhite Mailer was prominently featured and displayed in a
 Denver Post 
article entitled, “Ugly
Case 1:12-cv-02550 Document 1 Filed 09/26/12 USDC Colorado Page 3 of 13

Activity (10)

You've already reviewed this. Edit your review.
1 hundred reads
Colleen liked this
joenyc liked this

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->