**********************************************************************
Note: This is a scan of an actual court document filed in the Hinds County
Mississippi court.  The names of the plaintiffs have been blanked.  The 
numbers of the BBS in question are listed in the document.  I should note
that the charges in this document are accusations, not fact, and that a
trial has not been held yet, but is scheduled for sometime later this month.

BBS name: Irrelevant BBS
1-601-956-8215 and/or 957-0843
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	    IN THE COUNTY COURT OF THE FIRST JUDICIAL DISTRICT  
		  OF HINDS COUNTY, MISSISSIPPI



   and






 






, as NATURAL PARENTS
AND ADULT NEXT FRIENDS OF: 
  , A MINOR                        PLAINTIFFS

VERSUS                                  CIVIL ACTION NO. __________

MIKE FORESTER AND  FORESTER                      DEFENDANTS

				 COMPLAINT

	Come the Plaintiffs,   , and 














, as Natural Parents and Adult Next Friends of 

, A MINOR, hereinafter referred to as 

, and file this their Complaint on behalf of ,

a minor, against the Defendants, MIKE FORESTER AND  FORESTER,

and in support hereof would show unto the Court, the following

facts, to-wit:

			       JURISDICTION

				    1.

	Plaintiffs,   , AND 





 






, are

each adult resident citizens of the First Judicial District of

Hinds County, Mississippi.   is a minor, who is the

natural son of the Plaintiffs, and who resides with his parents at

   , Clinton, Mississippi, 39056.

				    2.

	The defendants, Mike Forester and  Forester, are each

adult resident citizens of the First Judicial District of Hinds

County, Mississippi, on whom the process of this Court may be had

at 5369 Briarfield Road, Jackson, First Judicial District of Hinds

County, Mississippi, 39213.

				     3.

	That this Court has Jurisdiction over the parties and subject

matter of this Cause of Action by virtue of the terms and

provisions of Section 9-9-21 of the Mississippi Code of 1972

(Anno.).

 

			       COUNT ONE

			   FACTUAL BACKGROUND

				    4.

	, is a sixteen year old minor, who resides, as

aforesaid, with his parents in Clinton, Mississippi.  Situated at

their residence in Clinton, Mississippi is a telephone which is

utilized by the residents of the household for communication

purposes.  For a period of time covering approximately 12 to 18

months, the plaintiffs and said minor,  , have been

receiving unsolicited telephone calls to their residence telephone

from the Defendant, Mike Forester, which are originated by Mike

Forester at and from the residence of  Forester, whom the

Plaintiffs believe to be the father of the Defendant, Mike

Forester.  During said telephone calls the Defendant, Mike

Forester, used profane and indecent language to, toward and about

the minor,  , which language was and is sexually

explicit, profane and indecent and which are and continue to be

emotionally upsetting and damaging to  , a minor.

				    5.

	Plaintiffs allow their minor son to utilize a computer in his

educational and recreational pursuits, and he has become

sufficiently proficient in the use of a computer as to be able to

communicate with other computers over telephone lines which offer

"Bulletin Board Service" (BBS). The Defendant, Mike Forester, is

the SysOP or operator of a certain bulletin board which may be

reached by telephone at 956-8215 and/or 957-0843 in the City of

Jackson, Mississippi.  That Mike Forester, as SysOP of the BBS

known as "IRRELEVANT", allows and permits persons to login on said

BBS and to view and download data and graphic depictions from the

BBS to the caller's computer.  The BBS also is used to allow users

to leave messages and to communicate with each other by means of

such messages left on the section of the Bulletin Board which is

being utilized. Plaintiffs charge that Mike Forester allowed

minors to utilize the BBS, required them to register via means of

communicating with the computer, their names, addresses, telephone

numbers, dates of birth and other information which allowed Mike




Forester to identify the caller and to log the calls, times and the

information accessed on the computer which he utilized to operate

the IRRELEVANT BBS at his residence, which Plaintiffs allege was

owned by the Defendant,  Forester.  Plaintiffs have

verified recently the origin of the obscene and harassing phone

calls to   as having originated at the telephones

situated in the residence of the defendants.

				  CLAIMS

				    6.

	Plaintiffs charge that the health, welfare and well being and

mental state of their minor son,  , has been adversely

affected, causing emotional distress and anguish as a result of the

sexually explicit and obscene and harassing phone calls placed by

the Defendant, Mike Forester to the Plaintiffs' residence and to

the minor Plaintiff,  .  That all of said worry,

anxiety, and emotional distress proximately resulted from and were

proximately caused by the obscene and harassing phone calls made

to the Plaintiffs' minor son by the Defendant, Mike Forester.

				    7.

	Plaintiffs charge that the Defendant, Mike Forester, violated

Section 97-29-45 of the Mississippi Code of 1972, in that said

phone calls were obscene, harassing and contained profane and

indecent language, and were made with the intent to annoy, abuse, or

harass the plaintiffs and their minor son at their residence

through their telephone there situated.  Plaintiffs charge that the

violation of said statute was and is the proximate cause of their

damages flowing from the actions of the Defendant, Mike Forester.

				    8.

	Plaintiffs charge that the Defendant,  Forester, as the

owner of the premises where the computer and the BBS was operated

by the Defendant, Mike Forester, and as the person to whom the

telephones were listed at said address, was negligent in allowing

the Defendant, Mike Forester to operate the BBS from which Mike

Forester obtained the telephone numbers and other personal





information which he apparently utilized in initiating the

telephone calls to the Plaintiffs residence which contained profane

and indecent language which were annoying and harassing to the

plaintiffs.  That in the exercise of reasonable and ordinary care,

the Defendant,  Forester, knew or should have known of Mike

Forester's use of the computer and telephone, as set forth herein,

and he failed to take action to cause such activities to cease.

That said negligence proximately caused and proximately contributed

to the cause of the Plaintiffs' son's damages.

				    9.

	Plaintiffs charge that the Defendant, Mike Forester's actions

constitute a reckless disregard of the rights of the plaintiff and

were calculated to lead to emotional distress and anxiety in a

child just past puberty, and that such actions are continuing.

That in addition to any actual damages the Plaintiff's minor son

has sustained, the defendant, Mike Forester, is liable for punitive

damages in an amount to be set by the Court, actual and punitive

damages not to exceed the jurisdictional limit of this Court.

	Wherefore, Plaintiffs demand judgment against the Defendants

in amount of actual and punitive damages not to exceed the

jurisdictional limits of this Court, together with court costs and

interest on any judgment according to law.

				COUNT TWO

		      MOTION FOR INJUNCTIVE RELIEF

				   10.

	Plaintiffs adopt by reference the allegations of

Paragraphs 1 through 9 above.

				   11.

	Plaintiffs further allege that the Defendant, Mike Forester,

in maintaining and operating the IRRELEVANT BBS utilizes his

contacts through the computer to access personal information of,

concerning and about the minors who communicate with said bulletin

board, after which he has utilized such information to make the

phone calls described above.  As the SysOp of the Irrelevant BBS,




Mike Forester, actively allows such minors to access, view and

download certain pornographic matter and graphics which are

maintained on said BBS in an "Adult Section". That such material

is detrimental to minors and which constitute a nuisance and which

causes irreparable harm to the Plaintiff's minor son and other

minors using said BBS. Plaintiffs allege that the Defendant, Mike

Forester, should be Ordered by this Court to refrain and desist

from such activity and to enjoin him from allowing Minors to access

such information contained on his BBS and to enjoin him from making

any further contact with   by telephone in any manner.

	Wherefore, Plaintiffs pray that this Court will set an

immediate hearing and issue process to the Defendants to show cause

why the Court should not enter a Restraining Order against the

Defendant, Mike Forester, enjoining him from making any further

phone calls to the residence of the Plaintiffs and to their minor

son,  , and upon a hearing of said matter to

temporarily enjoin him from utilizing the IRRELEVANT BBS so as to

allow minors to access any Adult Pornographic or Sexually Explicit

data, graphics or documents, and that upon a final hearing hereof

that said injunction be made permanent.

	And Plaintiffs pray for such other and further relief as to

which they may be entitled.

				 
				   ____________________________________                            
				       , Plaintiff

				      _________________________________                               
				      





 






, PLAINTIFF