COUNT I
(Unjust Enrichment -- Defendant William Jefferson Clinton)
97. Plaintiff realleges paragraphs 1 through 96 as if fully set forth herein.
98. Defendant William Jefferson Clinton personally and directly benefitted from the contributions Plaintiff made to Mrs. Clinton’s U.S. Senate campaign.
99. Defendant William Jefferson Clinton was unjustly enriched at Plaintiff’s expense. Specifically, Defendant William Jefferson Clinton was unjustly enriched by contributions made by Plaintiff in good faith to Mrs. Clinton’s U.S. Senate campaign, upon the direction of Defendant William Jefferson Clinton’s agent, Defendant Levin, in order to induce Defendant William Jefferson Clinton to enter into a business relationship with Plaintiff after he left The White House.
100. The circumstances of Defendant’s unjust enrichment are such that Defendant William Jefferson Clinton should, in good conscience, make restitution to Plaintiff.
101. As a proximate result of Defendant’s failure to make restitution, Plaintiff suffered substantial damages.
WHEREFORE, Plaintiff demands judgment be entered against Defendant William Jefferson Clinton including an award of compensatory damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.
COUNT II
(Unjust Enrichment -- Defendants Hillary Rodham Clinton, Hillary
Rodham Clinton for Senate Committee, Inc., and
New York Senate 2000)
102. Plaintiff realleges paragraphs 1 through 101 as if fully set forth herein.
103. Defendants Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc., and New York Senate 2000 benefitted directly from Plaintiff’s contributions to Mrs. Clinton’s U.S. Senate campaign.
104. Defendants Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc., and New York Senate 2000 were unjustly enriched at Plaintiff’s expense. Specifically, Defendants Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc., and New York Senate 2000 were unjustly enriched by contributions made by Plaintiff in good faith to influence the outcome of Mrs. Clinton’s U.S. Senate Campaign, but which Defendants Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc. and/or New York Senate 2000 failed to report to the Federal Election Commission or return to Plaintiff, as required by federal campaign finance laws.
105. The circumstances of Defendants’ unjust enrichment are such that Defendants Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc., and New York Senate 2000 should, in good conscience, make restitution to Plaintiff.
106. As a proximate result of Defendants’ failure to make restitution, Plaintiff suffered substantial damages.
WHEREFORE, Plaintiff demands judgment be entered against Defendants Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc., and New York Senate 2000, jointly and severally, including an award of compensatory damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.
COUNT III
(Fraud -- Defendants David Rosen, Hillary Rodham Clinton for
U.S. Senate Committee, Inc., New York Senate 2000
and Hillary Rodham Clinton)
107. Plaintiff realleges paragraphs 1 through 106 as if fully set forth herein.
108. Defendant Rosen, acting in his personal capacity and as the agent of Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton, repeatedly represented to Plaintiff in meetings and telephone conversations throughout June and July, 2000 that he and Mrs. Clinton’s U.S. Senate campaign would make appropriate arrangements to ensure that Plaintiff’s contributions to Mrs. Clinton’s U.S. Senate campaign were allocated and reported in such a manner as to comply with all applicable federal campaign fundraising requirements.
109. Defendant Rosen, acting in his personal capacity and as the agent of Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton, made these representations to Plaintiff in order to induce him to make substantial contributions to Mrs. Clinton’s U.S. Senate campaign, even though neither he, Mrs. Clinton’s U.S. Senate Campaign, New York Senate 2000, nor Mrs. Clinton had any intention of making sure that Plaintiff’s contributions were allocated and reported in a matter that complied with all applicable federal campaign fundraising requirements.
110. Defendant Rosen, acting in his personal capacity and as the agent of Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton, intentionally made these false representations to Plaintiff and/or made them with reckless disregard for Plaintiff’s rights.
111. Plaintiff reasonably relied on Defendant Rosen’s false representations by making substantial campaign contributions to Mrs. Clinton’s U.S. Senate campaign.
112. As a proximate result, Plaintiff suffered substantial damages, including but not limited to the substantial campaign contributions made by Plaintiff and the substantial risk that he will be prosecuted for violating campaign finance laws.
WHEREFORE, Plaintiff demands judgment be entered against Defendants Rosen, Hillary Rodham Clinton for U.S. Senate Committee, Inc., New York Senate 2000, and Hillary Rodham Clinton, jointly and severally, including an award of compensatory damages, punitive damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.
COUNT IV
(Breach of Special Duty -- Defendants David Rosen, Hillary Rodham Clinton
for U.S. Senate Committee, Inc., New York Senate 2000
and Hillary Rodham Clinton)
113. Plaintiff realleges paragraphs 1 through 111 as if fully set forth herein.
114. Because Defendant Rosen, acting in his personal capacity and as the agent of Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton, repeatedly represented to Plaintiff in meetings and telephone conversations throughout June and July, 2000 that he and Mrs. Clinton’s U.S. Senate campaign would make appropriate arrangements to ensure that any contributions Plaintiff made to Mrs. Clinton’s U.S. Senate campaign were allocated and reported in such a manner as to comply with all applicable federal campaign fundraising requirements, Defendants Rosen, Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Hillary Rodham Clinton owed Plaintiff a special duty to make sure that Plaintiff’s contributions to Mrs. Clinton’s campaign were allocated and reported in an appropriate, lawful manner.
115. At a minimum, Defendants Hillary Rodham Clinton for U.S. Senate Committee, Inc. and/or New York Senate 2000 owed Plaintiff this same duty because federal campaign fundraising laws require campaign officials to report and allocate all contributions in a manner that does not exceed federal campaign fundraising limits, and/or otherwise confirm the legality of a contribution or refund the contribution within thirty days.
116. Defendant Rosen, Hillary Rodham Clinton for U.S. Senate Committee, Inc., New York Senate 2000, and Hillary Rodham Clinton breached this duty to Plaintiff by failing to report Plaintiff’s contributions to Mrs. Clinton’s U.S. Senate campaign, by failing to allocate Plaintiff’s contributions in a manner that did not exceed federal campaign limits, and by failing to otherwise confirm the legality of Plaintiff’s contributions or refund the contributions to Plaintiff within thirty days.
117. Defendant Rosen, Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton breached this special duty intentionally and/or with reckless disregard for Plaintiff’s rights.
118. As a proximate result, Plaintiff suffered substantial damages, including but not limited to the substantial risk that he will be prosecuted for violating campaign finance laws.
WHEREFORE, Plaintiff demands judgment be entered against Defendants Rosen, Hillary Rodham Clinton for U.S. Senate Committee, Inc., New York Senate 2000, and Hillary Rodham Clinton, jointly and severally, including an award of compensatory damages, punitive damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.
COUNT V
(Conspiracy -- Defendants Aaron Tonken, Hillary Rodham Clinton
for U.S. Senate Committee, Inc., New York Senate 2000
and Hillary Rodham Clinton)
119. Plaintiff realleges paragraphs 1 through 118 as if fully set forth herein.
120. On information and belief, Defendant Tonken tacitly and/or expressly agreed with Defendant Rosen, acting in his personal capacity and as the agent of Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton, not to allocate, report, or otherwise make appropriate arrangements to ensure that Plaintiff’s contributions to Mrs. Clinton’s U.S. Senate campaign, including the approximately $500,000 Plaintiff had provided to Tonken to pay for expenses associated with the Hollywood Tribute fundraiser, were allocated and reported in such a manner as to comply with all applicable federal campaign fundraising requirements.
121. Defendants Tonken, Rosen, Hillary Rodham Clinton for Senate Committee, Inc., New York Senate 2000, and Mrs. Clinton acted intentionally and/or with reckless disregard for Plaintiff’s rights.
122. As a proximate result, Plaintiff suffered substantial damages, including but not limited to the substantial campaign contributions made by Plaintiff and the substantial risk that he will be prosecuted for violating campaign finance laws.
WHEREFORE, Plaintiff demands judgment be entered against Defendants Tonken, Rosen, Hillary Rodham Clinton for U.S. Senate Committee, Inc., New York Senate 2000, and Hillary Rodham Clinton, jointly and severally, including an award of compensatory damages, punitive damages, reasonable attorneys fees, pre-judgment interest, post-judgment interest, costs and such other relief as the Court deems just and proper.
Plaintiff demands a jury trial on all issues so triable.
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