I just heard about this. Pulled this off of SF, by Stan Hess. Anybody know him? Take a gander:

________________________________________________________

Ms. Graham is a law adiding citizen . She has long been a supporter of
less legal immigration , stoppping illegal aliens from entering our country ,
and deporting all illegals residing in the country . She also opposes any
amnesty for illegal aliens or any disguised bills for defacto amnesty like
the present so-called AG Bill promoted by many Republicans and Democrats .

Ms. Graham is a supporter of Michael Peroutka for President ..........

DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO
City & County Building
1437 Bannock Street
Denver, Colorado 80202
______________________________________

TERRY GRAHAM,
Plaintiff,

v.

JULISSA MOLINA, [et alia] ....;
FIRST DATA CORPORATION, a Delaware Corporation;
WESTERN UNION FINANCIAL SERVICES, a Delaware Corporation;
FIRST DATA WESTERN UNION FOUNDATION, a Colorado Non-Profit Corporation; and
THE HEP C CONNECTION, a Colorado Non-Profit Corporation;

Defendants.
______________________________________

Attorneys for Plaintiffs:
Robert J. Corry, Jr.
...Denver, Colorado 80202
...

VERIFIED COMPLAINT

.... This action arises out of a violent physical robbery, assault, and battery against Plaintiff Terry Graham, who justifiably feared for her life during this brutal and totally unjustified attack. Defendant Julissa Molina attacked, repeatedly hit, and knocked down Ms. Graham, in the absence of any provocation, all in retaliation for Ms. Graham’s peaceful exercise of her First Amendment right to participate in a community forum. The other Defendants either negligently set up the forum without taking reasonable steps to protect the safety of participants, and/or negligently hired or placed Defendant Molina in a position of contact with the public, with reckless disregard for her violent and dangerous propensities. As a result of the attack and Defendants’ intentional and negligent acts, Ms. Graham now fears for her life, safety, and well-being, and seeks actual and other damages from Defendants’ intentional and negligent misconduct.
Parties
2. Defendant Julissa Molina, AKA Julissa Soto, AKA Julissa Molina-Soto, AKA Julissa Molino Soto, AKA Julissa Davis-Soto (“Molina”), during the attack, was an agent or employee of Defendants First Data Corporation, Western Union Financial Services, First Data Western Union Foundation, and The Hep C Connection, and a resident of Adams County, with address 1621 S. Idalia Circle, Aurora, Colorado 80017.
3. Defendant First Data Corporation (“First Data”) is incorporated in the State of Delaware, with its principal business address at 6200 South Quebec Street, Greenwood Village, Colorado 80111. Its registered agent is the Corporation Service Company, 1560 Broadway, Denver, CO 80202.
4. Defendant Western Union Financial Services (“Western Union”) is incorporated in the State of Delaware, with its principal business address at 6200 South Quebec Street, Greenwood Village, Colorado 80111. Its registered agent is the Corporation Service Company, 1560 Broadway, Denver, CO 80202.
5. Defendant First Data Western Union Foundation (“FDWU Foundation”) is a non-profit Colorado corporation and an arm of Defendants First Data and Western Union, with its principal business address at 6200 South Quebec Street, Greenwood Village, Colorado 80111. Its registered agent is the Corporation Service Company, 1560 Broadway, Denver, CO 80202.
6. Defendant The Hep C Connection is a non-profit Colorado corporation with its principal business address at 1177 Grant Street, Suite 200, Denver, Colorado 80203. Its registered agent is Ann L. Jesse, 1177 Grant Street, Suite 200, Denver, Colorado 80203.
7. Plaintiff Terry Graham is a resident of Boulder County.
Jurisdiction and Venue
8. Pursuant to the Colorado Constitution, Art. VI, § 9, this Court has jurisdiction of this case.
9. Pursuant to C.R.C.P. 98(c)(5), venue is proper in this Court because the actions complained about were committed in the City and County of Denver, and certain Defendants may be found and service made in the City and County of Denver.
10. The amount in controversy exceeds $15,000.
General Allegations
11. Terry Graham is a peaceful, stable, upstanding, law-abiding citizen, employed in a good job with no prior criminal record of any sort.
12. Defendants First Data and Western Union invited Ms. Graham and other community members to participate in a July 22, 2004 community forum sponsored by Defendants First Data and Western Union at North High School in Denver.
13. Ms. Graham accepted Defendants First Data and Western Union’s invitation to participate, and began openly audiotaping the forum upon arrival, using a small hand-held tape recorder.
14. The forum was entitled “Immigration: What Reform Will Bring to Our Nation.” Defendants First Data and Western Union’s corporate logos appear on the invitation as sponsors of the event. See Plaintiffs’ Exhibit A, Invitation to the Community, attached hereto and incorporated herein by reference.
15. Defendant First Data had formally applied for, and had been granted, permission from the Denver Public Schools to hold the forum at North High School. See Plaintiffs’ Exhibit B, Application for Use of School Facilities and Permit for Use, collectively attached hereto and incorporated herein by reference.
16. A commercial general liability policy specifically covered the July 22, 2004 event. See Plaintiffs’ Exhibit C, Certificate of Insurance, attached hereto and incorporated herein by reference.
17. Defendant First Data paid the Denver Public Schools for the auditorium, custodial overtime, and insurance. See Plaintiffs’ Exhibit D, Invoice and Check, collectively attached hereto and incorporated herein by reference. On information and belief, this payment did not provide for any security.
18. All of the initial six panelists on stage at the forum approached the issue of immigration from one side of the issue. There was no true diversity of opinion on the panel on stage.
19. The political issue of immigration is highly controversial, with passion on all sides of the issue. It is reasonable to expect that a forum dealing with a controversial issue with a stacked panel could potentially erupt into a violent and dangerous situation.
20. As the panel began, Ms. Graham chose to exercise her First Amendment rights to participate in the forum by commenting on the statements of the panelists. The panelists and some forum participants disagreed with Ms. Graham’s position and made their disagreement known.
21. One audience member, name unknown, rudely told Ms. Graham that this event was for “Mexicans only,” and that Ms. Graham did not belong there.
22. Two other forum participants, large middle-aged Latino men neatly dressed, whose names are unknown, approached Ms. Graham from her left in a threatening and intimidating manner, and told her to be silent and cease participating or she would be forced to leave. It appeared by their conduct that these two men were agents or employees of Defendants First Data, Western Union, or FDWU Foundation. Ms. Graham politely replied that she was properly exercising her First Amendment rights on public property.
23. Three other forum participants, also middle-aged Latino men neatly dressed, then approached Ms. Graham from her right in a threatening and intimidating manner, and told her to be silent and cease participating or she would be forced to leave. It appeared by their conduct that these three men were agents or employees of Defendants First Data, Western Union, or FDWU Foundation. Ms. Graham again politely replied that she was properly exercising her First Amendment rights on public property.
24. On information and belief, one of the five middle-aged Latino men who threatened Ms. Graham was Mario Hernandez, Director of Public Affairs for Defendant First Data, and was acting pursuant to the interests of First Data at that time.
25. Defendant Julissa Molina then entered Ms. Graham’s row of seats, sat down beside her, and repeatedly told her in a threatening manner to shut up.
26. At this point, Ms. Graham asked Defendant Molina to stop threatening her, but Defendant Molina persisted in her threats, harassment, and intimidation. Ms. Graham then informed Defendant Molina that Ms. Graham was taping the threats, and showed Defendant Molina the tape recorder in hopes that this would dissuade her from making further threats.
27. Then, Ms. Graham returned her attention to the panel on stage. Coming from outside of Ms. Graham’s peripheral vision, Defendant Molina lunged at Ms. Graham, grabbed the tape recorder away, ripped the audiotape out, beat Ms. Graham on the top of the head, tore Ms. Graham’s clothing, pushed Ms. Graham to the floor, and with Defendant Molina’s clenched fists pounded on Ms. Graham’s head repeatedly.
28. Ms. Graham attempted repeatedly to retreat from the attack, and called for help, but Defendant Molina grabbed Ms. Graham’s hair and clothing, ripping her shirt to continue the attack. Ms. Graham’s initial pleas for help were ignored by other forum participants, some of whom shouted encouragement to Defendant Molina.
29. On information and belief, Ms. Graham hit her head on a chair back while Defendant Molina pushed her to the floor. Ms. Graham temporarily lost some of hearing from this or other blows to her head.
30. On information and belief, Defendant Molina continued to beat Ms. Graham even after she was on the floor. Ms Graham temporarily lost her consciousness or awareness as a result of the ferocity of the attack.
31. Ms. Graham feared she would be killed at that point, because of the extreme brutality of the attack, and the fact that Ms. Graham’s pleas for help were being ignored by other forum participants.

32. On information and belief, other forum participants eventually restrained Defendant Molina after the approximately forty-five-to-sixty-second beating. The Denver Police eventually arrested Defendant Molina, and she currently faces criminal charges.
33. On information and belief, police set Defendant Molina free the night of the attack due in part to intervention by Defendants First Data and Western Union, the Mexican Consul, LARASA (Latin American Research and Service Agency), and Servicios de la Raza, Inc. The latter two entities are funded by Defendant FDWU Foundation.
34. On information and belief, the panel forum discussion resumed while Ms. Graham was sitting on the floor, in shock from the attack and her injuries.
35. Ms. Graham ended up approximately seven chairs away from where she had been sitting.
36. Ms. Graham remained on the floor for approximately five minutes, then police escorted her out of the auditorium to a separate room at the school.

37. Some of the forum participants had been shouting their support of Defendant Molina. As Ms. Graham was being helped out of the room by a Denver police officer, one audience member angrily shouted at Ms. Graham, “You deserved that!” which prompted claps and cheers from other forum participants. Ms. Graham feared for her life and safety at that point as well.
38. After Ms. Graham arrived at the other room, paramedics were called. Ms. Graham was attended by paramedics in the other room. A school administrator of North High School, possibly the Principal or Vice Principal, was present in the room with Ms. Graham, as were Denver police officers. The North High School administrator gave Ms. Graham an ice pack which she held alternately on the top of her head and neck.
39. While Ms. Graham waited in the other room, Polly Baca, along with attorney Adrienne Benavidez, took the podium and assured the forum participants that Defendants First Data, Western Union, and FDWU Foundation would provide Defendant Molina with legal representation in the criminal case.


40. Polly Baca is on the Board of Directors of Defendant First Data/Western Union Foundation, and also Executive Director of LARASA. Adrienne Benavidez is on the Board of Directors of Servicios de la Raza, Inc., and on the Board of Directors of the Denver Chapter of the American Civil Liberties Union (“ACLU”). On information and belief, both LARASA and Servicios de la Raza receive funding from, and act pursuant to the interests of, Defendants First Data, Western Union, or FDWU Foundation.
41. Ms. Graham did not want to be around any people after this brutal attack, so after crying and resting in the safe room she went home alone with numerous bruises on her arms, hip, and legs, a laceration on her neck, and two large bruises on the back of her head. She was still in fear for her safety and felt threatened by the people around her.
42. Ms. Graham suffers from memory loss and headaches since the attack, which has harmed her career and her quality of life. She also fears other people in general, and in particular, fears physical retaliation from Defendants and/or their agents and employees.
43. As a direct result of Defendants’ intentional and negligent actions, Ms. Graham suffers from lost wages, medical bills, physical pain and discomfort, emotional distress, nightmares, fear, loss of sleep, ruined clothing, and other damages in an amount to be determined at trial.
44. At the time of the attack, Defendant Molina served as Director of the Multicultural Outreach Program of the Hep C Connection in Denver. Her job duties included attending and participating in events involving the Latino community.
45. The Hep C Connection is funded by, and acts pursuant to the interests of, Defendants First Data, Western Union, and FDWU Foundation, so in this capacity Defendant Molina was an agent or employee of Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection.
46. On information and belief, Defendant Molina was criminally prosecuted for child abuse, and Defendant Hep C Connection knew, or should have known, about Defendant Molina’s criminal past and violent tendencies.


First Claim for Relief
(Assault and Battery)
(Against Defendant Molina)
47. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
48. Defendants acted either with the intent of making a harmful or offensive contact with the person of the Plaintiff, or with the intent of putting the Plaintiff in apprehension of such a contact.
49. Plaintiff was placed in apprehension of an imminent harmful or offensive contact with her person by the conduct of the Defendants.
50. Such contact was or appeared to be harmful or offensive, and the contact directly or indirectly resulted from Defendants and their actions.
51. As a proximate result of Defendants’ actions, Plaintiff suffered damage in an amount to be shown at trial.


Second Claim for Relief

(Intentional Infliction of Emotional Distress)

(Against All Defendants)

52. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
53. Defendants engaged in extreme, outrageous, intimidating, and threatening conduct, recklessly or with the intent of causing the Plaintiff severe emotional distress.
54. Plaintiff incurred severe emotional distress as a result of Defendants’ conduct.
55. As a proximate result of Defendants’ actions, Plaintiff suffered damage in an amount to be shown at trial.
Third Claim for Relief
(Negligence)

(Against Defendants First Data, Western Union, and FDWU Foundation)
56. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
57. Defendants First Data, Western Union, and FDWU Foundation had a duty to provide a safe environment and adequate security to Ms. Graham and others who attended the July 22, 2004 event Defendants First Data, Western Union, and FDWU Foundation sponsored.
58. Defendants First Data, Western Union, and FDWU Foundation breached their duty to provide a safe environment and adequate security at the event. A reasonable person would have known that “stacking” the panel on an already-contentious public policy and cultural issue such as immigration would increase the already-high chance of danger and violence to the community members invited to participate in the event.
59. Defendants First Data, Western Union, and FDWU Foundation’s breach of their duty to provide adequate security and a safe environment caused damages to Ms. Graham in an amount that will be shown at trial.
Fourth Claim for Relief
(Robbery)

(Against Defendant Molina)

60. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
61. Defendant Molina knowingly took a thing of value, an audiotape, from the person of another, Ms. Graham, by the use of force, threats, or intimidation.
62. Plaintiff suffered damage in an amount to be shown at trial.
Fifth Claim for Relief
(Damaging or Destroying Property)
(Against All Defendants)
63. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
64. Defendants intentionally and maliciously damaged and/or destroyed the real or personal property of one or more persons, as detailed above, in the course of a single episode.
65. Defendant Molina damaged or destroyed Ms. Graham’s property, her clothing and the audiotape, and the other defendants failed to use reasonable measures to retrieve the property from their agent Defendant Molina.
66. As a proximate result of Defendants’ actions, Plaintiffs suffered damage in an amount to be shown at trial.
Sixth Claim for Relief
(Theft)
(Against Defendant Molina)
67. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
68. Defendant Molina intentionally and permanently deprived Plaintiff of the use or benefit of a thing of value, an audiotape, as detailed above.
69. As a proximate result of Defendant’s actions, Plaintiff suffered damage in an amount to be shown at trial.
Seventh Claim for Relief
(Respondeat Superior)

(Against Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection)

70. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
71. Defendant Molina is an employee and/or agent of Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection, and acts pursuant to their interests.
72. The acts of Defendant Molina were performed within the scope of her employment or agency relationship with Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection.
73. As a proximate result of Defendants’ actions, Plaintiff suffered damage in an amount to be shown at trial.
Eighth Claim for Relief
(Negligent Hiring/Training/Supervision)

(Against Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection)

74. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
75. Defendant Molina is an employee and/or agent of Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection, and was hired, trained, and supervised by them.
76. Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection conduct an activity through employee Defendant Molina.
77. Defendants First Data, Western Union, FDWU Foundation, and Hep C Connection caused harm resulting from negligent conduct in the employment of improper persons or instrumentalities in work involving risk of harm to others.
78. As a proximate result of Defendants’ actions, Plaintiff suffered damage in an amount to be shown at trial.

79. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
80. In Defendants’ and/or their agents’ interactions with Plaintiff, there was an object to be accomplished, namely to assault and intimidate Plaintiff; an agreement by two or more persons on a course of action to accomplish that object; and in furtherance of that course of action, one or more unlawful acts which were performed to accomplish a lawful or unlawful goal, or one or more lawful acts which were performed to accomplish an unlawful goal.
81. Plaintiff suffered damage as a proximate result of Defendants’ conspiracy, in an amount to be shown at trial.
Tenth Claim for Relief
(Ethnic Intimidation in Violation of C.R.S. § 18-9-121)

(Against All Defendants)

82. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
83. With the intent to intimidate or harass Ms. Graham, because of her race, color, religion, ancestry, or national origin, Defendants knowingly caused bodily injury to Ms. Graham and by words or conduct, knowingly placed Ms. Graham in fear of imminent lawless action directed at Ms. Graham, and such words or conduct were likely to produce bodily injury to Ms. Graham or damage to her property, and knowingly caused damage to or destruction of the property of Ms. Graham.
84. Plaintiff suffered damage in an amount to be shown at trial.
Eleventh Claim for Relief
(Extreme and Outrageous Conduct)

(Against All Defendants)
85. Plaintiff incorporates and alleges the foregoing paragraphs of this complaint as if fully stated herein.
86. Defendants engaged in extreme and outrageous conduct, recklessly or with the intent of causing Plaintiff severe emotional distress.
87. Plaintiff has had severe emotional distress caused by the Defendants’ conduct, and was damaged in an amount that be will shown at trial.
Prayer for Relief
WHEREFORE, Plaintiff Terry Graham prays for the following relief:
a) Enter judgment in her favor against Defendants;
b) Award Plaintiff compensation and damages, actual, compensatory, punitive, and otherwise, in an amount that will be shown at trial;
c) Award her attorneys’ fees and costs of litigation; and
d) Grant her any and all other relief the Court deems proper.
Jury Demand
Plaintiff requests trial by jury on all issues so triable.
Date: October 20, 2004 Respectfully submitted,

CORRY & FELLOWS, LLP
_________________________
Robert J. Corry, Jr.

VERIFICATION

I, Terry Graham, declare under penalty of perjury that the foregoing Verified Complaint is true and correct. Executed on October __, 2004.

_________________________
Terry Graham

Here's an account in non-legalese
http://www.amren.com/mtnews/archives/2004/10/first_dataweste.php
ree Speech Forum, Oct. 20

Denver: A woman assaulted by a Mexican national at a Denver pro-immigration forum sponsored by First Data/Western Union filed a civil lawsuit today in Denver District Court. The lawsuit suit includes claims for ethnic intimidation, civil conspiracy, assault and battery, robbery, personal injury, and property damage against Colorado-based First Data Corporation, its subsidiary Western Union, the First Data/Western Union Foundation, the attacker and her former employer, Hep C Connection.

The plaintiff, Terry Graham, was challenging the forum’s panelists from the audience when she was attacked and brutally assaulted by Julissa Molina-Soto, 32, an immigrants’ rights activist.

Denver attorney Robert Corry, who is representing Graham, said, “No person in the United States of America should fear violent retaliation for exercising her First Amendment rights to speak out and participate in an open community forum. The sponsors of this forum, First Data Corporation and Western Union, had a duty and obligation to provide adequate security at the event, a responsibility they utterly failed to satisfy.”

The forum was held on July 22 at Denver’s North High School. The school was recently the focus of a national controversy for displaying the Mexican flag in its classrooms.

Denver police at the event arrested Molina-Soto and charged her with assault. She was released within minutes after the intervention of Mexican General Consul Juan Marcos Gutierrez and other Latino leaders, according to reports published in La Voz Nueva, a bilingual newspaper.

As paramedics attended to Graham following the assault, Polly Baca—a Director of First Data/Western Union Foundation and head of Denver nonprofit LARASA (“The Race”)—and ACLU lawyer Adrienne Benavidez assured the largely Latino audience from the podium that Molina-Soto would have legal representation.

Molina-Soto is scheduled to appear on October 26 in Denver County Court on the assault charges.

Jeff Joseph, head of the Colorado Chapter of the American Immigration Lawyers Association (AILA), is representing Molina-Soto in the criminal case.

Molina-Soto and her two children entered the U.S. nine years ago. A Mexican citizen, she reportedly has permanent resident alien status. She has held various jobs involving healthcare rights for legal and illegal Latino immigrants.

Baca’s organization, LARASA, and Molina-Soto, who until recently was multicultural outreach coordinator for Denver’s Hep C Connection, jointly ran a Latino outreach campaign on Hepatitis C in 2003. Benavidez, head of Denver’s nonprofit Color of Justice, has long been a critic of the Denver Police Department’s treatment of minorities. Benavidez headed Denver’s Public Safety Review Commission, reviewing citizen complaints against police officers, for five years during which time the Police Protective Association accused her of bias. Former Police Chief Tom Sanchez protested the PSRC’s “witch-hunt atmosphere” under her leadership. A vocal opponent of Denver’s Columbus Day celebration, Benavidez also sits on the Board of Directors of Servicios de la Raza (“Services For The Race”).

According to the First Data/Western Union Foundation website (www.westernunionfirstdata.org) LARASA, Services de la Raza, and Hep C Connection have all received Foundation grants since 2001.

Molina-Soto’s attorney, Jeff Joseph, debated Colorado Congressman Tom Tancredo in February on the topic of immigration stating that “[The] enforcement policy of immigration is not in line with reality.” Joseph also criticized President Bush’s controversial immigrant amnesty proposal, saying it did not give incentives for illegal aliens to register and become legal US residents.

First Data Corporation has taken the lead in promoting massive immigration and immigrants’ rights—including illegal aliens—since settling lawsuits charging that its subsidiary, Western Union, failed to disclose unreasonably high commissions it charged when wiring customers’ money to Mexico.

In March, First Data/Western Union set up a $10 million “Empowerment Fund” to be used for Latino and pro-immigration causes. Raul Yzaguirre, president of the National Council of La Raza (“The Race”); Sal Gomez, Chairman the Denver Hispanic Chamber Gomez; and Robert de Posada, President of the Latino Coalition, were appointed by First Data to the Fund’s Advisory Board. The Empowerment Fund is separate and in addition to charitable donations totaling about $5.5 million that First Data made as part of settlements of the class-action lawsuits.

Since March, First Data/Western Union has sponsored immigration panels across the nation. FIrst Data ignored complaints made prior to the Denver forum that participants did not represent both sides of the issue. Panelists at the Denver forum included Thomas Saenz of the Mexican-American Legal Defense and Educational Fund (MALDEF); Lisa Duran of Derechos Por Todos (“Rights For Everyone”); Juan Salgado, President of the Illinois Coalition for Immigrant and Refugee Rights; Robert de Posada of The Latino Coalition; Raul Hinosa, UCLA’s North American Integration and Development Center; and Roberto Ramirez, Founder of the Jesus Guadalupe Foundation. Some individuals had complained to First Data prior to the Denver panel that it was skewed and did not represent both sides of the issue.

First Data CEO Charles Fote announced in April that $800,000 of the Empowerment Fund would be used to create a Denver pilot program to support and increase the number of Latino business owners.

(Posted on October 21, 2004)