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Judicial Watch filed the lawsuit against Jackson, his son Jonathan, and others on behalf of Rev. Jesse Lee Peterson, who was the victim of a physical and verbal assault at an event hosted by Jackson?s Rainbow/PUSH Coalition and Toyota Motor Sales, U.S.A., Inc. in December 2001.
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Judicial Watch?s lawsuit stems from a public meeting held in Los Angeles, California on December 10, 2001 to discuss participation in Toyota?s ?21st Century Diversity Strategy,? which had been announced after Jackson and Rainbow/PUSH threatened to boycott Toyota. After remarks from Jackson and Toyota representative Irving Miller, the meeting was opened up to questions from the audience. Rev. Peterson asked Miller if black Republicans and conservative groups like his organization, Brotherhood Organization of a New Destiny (BOND), would have to go through Rev. Jackson?s Rainbow/PUSH in order to participate in the Toyota program.

Jackson told the crowd, ?And the issue, for the record?is not conservative or liberal. The issue is certain parasites trying to pick up fruit from trees they didn?t shake.? Rev. Peterson testified that after the ?parasite? comment, the crowd became ?more hostile?.Some of the words I can?t even mention here.?

Within minutes following adjournment of the meeting, Jonathan Jackson struck Rev. Peterson and Rev. Peterson was physically threatened and verbally assaulted by both Jesse Jackson and Jonathan Jackson. Incited by Jackson?s earlier remarks, an angry crowd gathered, cursing, shoving and encircling Rev. Peterson and one of his associates. ?I feared for my life,? said Peterson.
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12. On information and belief, Toyota undertook to develop and institute what is now known as ?Toyota?s 21st Century Diversity Strategy: A Comprehensive Program for Minority Participation in Toyota Today and Tomorrow? (the ?Toyota Strategy?). On information and belief, a true and correct copy of a Toyota document entitled ?TOYOTA?S 21ST CENTURY DIVERSITY STRATEGY: A Comprehensive Program for Minority Participation in Toyota Today and Tomorrow? is attached hereto and marked as Exhibit ?A.? On information and belief, it was at all relevant times Toyota?s intention that the Toyota Strategy would be nonpartisan and would be implemented and administered without regard to political and ideological affiliation.

13. On information and belief, JACKSON and PUSH sought to interject themselves into the Toyota Strategy, and to take control of its implementation and administration, by means of an express or implied threat of adverse publicity and/or a possible boycott of Toyota automobiles by supporters and/or members of JACKSON and PUSH, for the purpose of (a) obtaining monetary payments to JACKSON and/or PUSH as a precondition for minorities to benefit from the Toyota Strategy, (b) increasing the membership of and/or contributions to PUSH and JACKSON, and (c) holding minorities within the Democrat Party.

14. On information and belief, based on the documentation attached hereto and marked as Exhibit ?A? and information published on Toyota?s website, it is and at all relevant times has been Toyota?s intention to implement and administer the Toyota Strategy directly from within Toyota, as opposed to indirectly through the auspices of JACKSON and PUSH, and without regard to political and ideological affiliation.

15. On or about December 10, 2001, a meeting of the Los Angeles Trade Bureau Forum was held at the Los Angeles Chamber of Commerce (the ?Meeting?). The Meeting was open to the public and took place at 350 South Bixel Street, Los Angeles, CA 90017. On information and belief, JACKSON and PUSH organized, controlled, dominated, and ran the Meeting. PUSH publicized and promoted the event as a meeting with JACKSON and unnamed Toyota officials.

16. PETERSON and BOND attended the Meeting, among other reasons, to learn whether and to what extent BOND, its members, and those assisted by BOND might participate in and benefit from the Toyota Strategy, e.g. through training and job programs for inner city youth or direct funding and/or contributions by Toyota to BOND. PETERSON and BOND also sought to meet with appropriate Toyota officials to provide them with information about BOND.

17. During the Meeting, JACKSON, PUSH, and Toyota announced inter alia that it would award $700 million worth of contracts to minority-owned businesses in 2002 as part of the Toyota Strategy. JACKSON and PUSH also announced that J.L. Armstrong — a close personal friend of JACKSON and/or a member and strong supporter of PUSH — had been promoted to a key management position in Toyota and would be the key liaison between Toyota and minority businesses for the $700 million worth of contracts. JACKSON and PUSH orchestrated and ran the Meeting and distributed documents in such a way as strongly to imply that, for all practical purposes, it would be necessary for businesses to pay from $250 to $2,500 annually to an organization called ?The International Trade Bureau? in order to have a reasonable chance of participating in the $700 million worth of contracts to be awarded through JACKSON?s and PUSH?s key man within Toyota (i.e. J.L. Armstrong). On information and belief, The International Trade Bureau is part of PUSH and, for the reasons set forth in Paragraph 5 supra, is the alter ego of JACKSON.

18. During a question-and-answer session with a Toyota representative at the Meeting, PETERSON expressed concern, individually and as the president of BOND, that young people assisted by BOND might be excluded from training programs and other diversity efforts offered by Toyota because (a) PETERSON is a conservative and a Republican; (b) many of BOND?s members are perceived to have conservative and Republican affiliations; (c) JACKSON and PUSH are intensely hostile toward minorities who have conservative and Republican affiliations; and/or (d) JACKSON and PUSH appeared to be positioned as the de facto gatekeepers of Toyota contracts because inter alia JACKSON?s and PUSH?s key man, J.L. Armstrong, was on the inside of Toyota in a key management position.

19. During the Meeting, PETERSON tried to use the question-and-answer session to ask a Toyota official how Toyota would ensure that JACKSON, PUSH, and their agents do not discriminate against minorities who have or are perceived as having Republican and conservative affiliations.

20. PETERSON?s remarks and questions during the question-and-answer session were orderly but were met with loud, angry, and unruly outbursts by JACKSON, PUSH, and their agents. In an attempt to silence and marginalize PETERSON and any others having or perceived as having Republican and conservative affiliations, to incite a hostile reaction from the agents of JACKSON and PUSH, and to manipulate Toyota, JACKSON and PUSH denigrated PETERSON and his stated concerns as involving ?some parasites, who want to pick up apples from trees they didn?t shake.? As a result, PETERSON was repeatedly interrupted, called offensive names (including inter alia ?stupid? and ?nigger?), and shouted down by JACKSON, PUSH, and their agents, and could not obtain satisfactory answers to his questions of Toyota.

21. After the foregoing disturbances caused by JACKSON, PUSH, and their agents, JONATHAN and two other agents of JACKSON and PUSH positioned themselves immediately in front of and behind PETERSON and glared at him menacingly for the rest of the Meeting. These acts of JONATHAN and other agents of JACKSON and PUSH were visible to JACKSON and/or other officers, directors, or managing agents of PUSH, all of whom made no effort to stop this threatening behavior but instead approved and ratified it by permitting it to continue.

22. At the end of the Meeting, when PETERSON rose to leave his seat, JONATHAN moved closer to PETERSON and stood in his way to obstruct his only pathway for leaving the area where he had been seated. After a short but appreciable period of confinement, PETERSON was able to escape from JONATHAN. On information and belief, JONATHAN engaged in these acts with the intent of intimidating PETERSON, preventing his further interaction with Toyota officials, and silencing further criticism of the ongoing JACKSON/PUSH shakedown of Toyota and minority businesses seeking contracts with Toyota. These acts of JONATHAN were visible to JACKSON and/or other officers, directors, or managing agents of PUSH, all of whom made no effort to stop JONATHAN?s threatening behavior but instead approved and ratified it.

23. After escaping JONATHAN?s initial confinement, PETERSON went over to a refreshments table to get a cup of coffee. While PETERSON was standing at the refreshments table, JONATHAN approached and wilfully, intentionally, and maliciously shoved PETERSON. These acts of JONATHAN were visible to JACKSON and/or other officers, directors, or managing agents of PUSH, none of whom did anything to stop JONATHAN?s misconduct but instead approved and ratified it.

24. PETERSON objected to being shoved by JONATHAN and told JONATHAN that he was not allowed to touch PETERSON, whereupon JONATHAN started yelling and a loud, unruly, and threatening crowd formed around PETERSON. Over the next several minutes, the crowd grew and escalated into a very loud, unruly, and threatening mob, several people deep all around, comprised of JACKSON, JONATHAN, MATHIS, and other agents of JACKSON and PUSH. Confined in the middle of this menacing mob, PETERSON feared for his life.

25. JACKSON, JONATHAN, and MATHIS incited, participated in, and egged on the escalating mob. JACKSON, JONATHAN, MATHIS, and/or other agents of JACKSON and PUSH shouted the word ?nigger? and other offensive names inter alia at PETERSON. JONATHAN shouted ?suck my dick!? and other obscenities at PETERSON. Abandoning all restraint and semblance of judicial decorum, MATHIS taunted PETERSON inter alia about having no one to rescue him from the mob, saying inter alia ?where?s your buddy [Bill] O?Reilly [of Fox News] now?? Incited and egged on by JACKSON, JONATHAN, and MATHIS, other members of the mob screamed at PETERSON, called him offensive names (including inter alia the word ?nigger?), and made many threatening gestures. JONATHAN lunged at PETERSON. JACKSON and others yelled inter alia, ?Get his ass out of here? and similar threats of physical seizure and expulsion. These and similar acts continued for several minutes with PETERSON confined by the mob. JACKSON and PUSH did nothing to quiet or restrain the mob in any way. Instead, JACKSON and PUSH actively incited, participated in, egged on, approved, and ratified the mob attack.

26. PETERSON was unable to escape the mob. After the mob had accosted, encircled, and confined PETERSON for several minutes, another employee of BOND tried to rescue him by physically snatching him from the mob and moving him toward an exit. The mob pursued PETERSON toward the exit, continuing to accost, encircle, confine, shout at, and threaten him the entire time he was being pushed toward the exit. JACKSON and PUSH did nothing to restrain, but actively incited, participated in, egged on, approved, and ratified the mob pursuit.
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