JS 44 (Rev.

04/21) CIVIL COVER SHEET

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
MARK HOUCK, RYAN-MARIE HOUCK, and RYAN- UNITED STATES OF AMERICA; MICHAEL ROGERS,
MARIE HOUCK ON BEHALF OF M.H., A.M.H., K.H., JUAN BARRIOS, JOHN DOE #1, STEPHEN CAPUTO,
T.H., J.H.,
(b) County A.H.,ofand
of Residence First I.H.,
Listed Plaintiff Bucks BRIAN
County of CALABRESE, STEVE
Residence of First Listed JOHNSON, JOHN DOE #2,
Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

George Bochetto, Bochetto & Lentz, P.C., 1524 Locust

Street, Philadelphia, PA 19102, (215) 735-3900
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ INTELLECTUAL 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
Federal Tort Claims Act (FTCA)
VI. CAUSE OF ACTION Brief description of cause:
Malicious/retaliatory prosecution, abuse of process, false arrest and related claims.
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. in excess of 150,000 JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
May 20, 2024 /s/ George Bochetto
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

JS 44 Reverse (Rev. 04/21)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then
the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statute.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service.

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.
 Case 2:24-cv-02151 Document 1 Filed 05/20/24 Page 1 of 77

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

MARK HOUCK, RYAN-MARIE

HOUCK, and RYAN-MARIE HOUCK
ON BEHALF OF M.H., A.M.H., K.H.,
T.H., J.H., A.H., and I.H.,

Plaintiffs;

v. No. _____________

UNITED STATES OF AMERICA;

MICHAEL ROGERS, JUAN
BARRIOS, JOHN DOE #1, STEPHEN
CAPUTO, BRIAN CALABRESE,
STEVE JOHNSON, JOHN DOE #2,
JOHN DOE #3, ZACH BROSIUS, and
JOHN DOE #4,

Defendants.

COMPLAINT

I. PRELIMINARY STATEMENT

1. In September 2022, Mark Houck, a peaceful volunteer for a crisis

pregnancy center in Center City Philadelphia and a 40 Days for Life prayer vigil

participant, was indicted for two violations of the Freedom of Access to Clinic

Entrances Act (“FACE Act”), 18 U.S.C. § 248.

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2. The charges were a result of a faulty and malicious investigation of

Mr. Houck. Mr. Houck had been targeted for indictment without probable cause

because of his beliefs, his public prayer and speech, and his position as a counselor

associated with a crisis-pregnancy center.

3. The Federal Bureau of Investigation’s (“FBI”) investigators portrayed

Mr. Houck as a pro-life “protestor” who violently shoved an elderly Planned

Parenthood escort because the escort was attempting to escort two patients and

who intended to intimidate and interfere with the escort’s objective of providing

reproductive health services. This was false—knowingly false—in every respect.

4. The FBI’s investigators purposefully conducted a biased and corrupt

investigation despite actual knowledge from all available evidence that their

statements were false. The actions of the FBI’s investigators were contrary to the

Department of Justice’s (“DOJ”) public policy that the FACE Act “is not about

abortions.” Yet below the surface, the investigators’ actions were fully in accord

with extrajudicial statements of DOJ leadership that pro-life services are “fake”

and “predatory” upon abortion rights.

5. Federal officials’ attack on Mr. Houck was not limited to the

investigation, or even to Mr. Houck himself. Instead, they targeted the people in

this world he loved the most. Before sunrise on September 23, 2022, an

unsuspecting Mr. Houck had arisen early to begin making breakfast for his family.

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Suddenly, the Houck home was swarmed by federal, state, and local agents in an

act of overwhelming paramilitary force. In a shocking display of the political

animus against the pro-life movement harbored at the highest levels of the

Department of Justice, Mr. Houck was treated like a dangerous criminal. He was

arrested at gunpoint in front of his wife and children.

6. Mrs. Houck and her children were directly downrange from the

agents’ guns as Mrs. Houck frantically tried to find out what was happening to her

husband, all while her children sat on the stairs, directly downrange, crying in fear.

7. This egregious and excessive show of force was both unnecessary and

unlawful. Mr. Houck is a peaceful man. He has never been convicted of any crime

of violence or even owned a firearm, and was innocent of the non-violent federal

charges against him, as a jury would unanimously conclude after Mr. Houck’s trial

a few months later.

8. Mr. Houck, Mrs. Houck, and their children have deeply suffered

because of the actions of state and municipal agents on September 23, 2022, in

their unnecessary and unlawful show of force in storming the Houcks’ homestead.

9. State and municipal agents deprived Mr. Houck of his Fourth

Amendment rights by using excessive force to arrest him on non-violent charges

when he had not threatened law enforcement, did not own a gun, and had offered

to turn himself into authorities if indicted.

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10. This action is also brought under the Federal Tort Claims Act for the

torts of malicious prosecution, retaliatory prosecution, abuse of process, false

arrest, assault, and intentional infliction of emotional distress committed by federal

employees and agents against Mr. Houck, Mrs. Houck, and their children.

11. This action seeks just compensation for the deprivation of Mr.

Houck’s, Mrs. Houck’s, and their children’s rights under the law.

II. JURISDICTION AND VENUE

12. This Court has jurisdiction over the subject matter of this Complaint

under 28 U.S.C. § 1343.

13. On November 6, 2023, Administrative Tort Claims were submitted by

all Plaintiffs to the United States Department of Justice. Six (6) months have

passed since the filing of the administrative claims without action by the agencies.

Plaintiffs have, therefore, exhausted all administrative remedies under 28 U.S.C. §

2675(a).

14. Venue is properly within this District under 28 U.S.C. § 1391(b).

III. PARTIES

15. Plaintiff Mark Houck is and was at all times relevant to this

Complaint a resident of Bucks County, Pennsylvania.

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16. Plaintiff Ryan-Marie Houck is and was at all times relevant to this

Complaint a resident of Bucks County, Pennsylvania.

17. M.H. is the minor son of Mark and Ryan-Marie Houck.

18. A.M.H. is the minor daughter of Mark and Ryan-Marie Houck.

19. K.H. is the minor daughter of Mark and Ryan-Marie Houck.

20. T.H. is the minor daughter of Mark and Ryan-Marie Houck.

21. J.H is the minor son of Mark and Ryan-Marie Houck.

22. A.H. is the minor son of Mark and Ryan-Marie Houck.

23. I.H. is the minor daughter of Mark and Ryan-Marie Houck.

24. Defendant United States of America is the appropriate defendant

under the Federal Tort Claims Act.

25. Defendant Michael Rogers is a trooper in the Pennsylvania State

Police who was acting under color of state law at all times relevant to this

Complaint. Upon information and belief, Defendant Rogers participated in the

Houck arrest. Defendant Rogers is sued in his individual capacity.

26. Defendant Juan Barrios is a trooper in the Pennsylvania State Police

who was acting under color of state law at all times relevant to this Complaint.

Upon information and belief, Defendant Barrios participated in the Houck arrest.

Defendant Barrios is sued in his individual capacity.

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27. Defendant John Doe #1 is a trooper in the Pennsylvania State Police

who was acting under color of state law at all times relevant to this Complaint and

whose actual name is unknown to Plaintiffs after having conducted a reasonable

search with due diligence. Upon information and belief, Defendant John Doe #1

participated in the Houck arrest. Defendant John Doe #1 is sued in his individual

capacity. Plaintiffs do not presently know the name of this Defendant but will seek

leave to amend the Complaint so as to name each appropriate Defendant after the

completion of additional discovery.

28. Defendant Stephen Caputo is an officer in the Philadelphia Police

Department who was acting under color of state law at all times relevant to this

Complaint. Upon information and belief, Defendant Caputo participated in the

Houck arrest. Defendant Caputo is sued in his individual capacity.

29. Defendant Brian Calabrese is an officer in the Philadelphia Police

Department who was acting under color of state law at all times relevant to this

Complaint. Upon information and belief, Defendant Calabrese participated in the

Houck arrest. Defendant Calabrese is sued in his individual capacity.

30. Defendant Steve Johnson is an officer in the Philadelphia Police

Department who was acting under color of state law at all times relevant to this

Complaint. Upon information and belief, Defendant Johnson participated in the

Houck arrest. Defendant Johnson is sued in his individual capacity.

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31. Defendant John Doe #2 is an officer in the Philadelphia Police

Department who was acting under color of state law at all times relevant to this

Complaint and whose actual name is unknown to Plaintiffs after having conducted

a reasonable search with due diligence. Upon information and belief, Defendant

John Doe #2 participated in the Houck arrest. Defendant John Doe #2 is sued in

his individual capacity. Plaintiffs do not presently know the name of this

Defendant but will seek leave to amend the Complaint so as to name each

appropriate Defendant after the completion of additional discovery.

32. Defendant John Doe #3 is a Deputy Sheriff in the Bucks County

Sheriff’s Office who was acting under color of state law at all times relevant to this

Complaint and whose actual name is unknown to Plaintiffs after having conducted

a reasonable search with due diligence. Upon information and belief, Defendant

John Doe #3 participated in the Houck arrest. Defendant John Doe #3 is sued in

his individual capacity. Plaintiffs do not presently know the name of this

Defendant but will seek leave to amend the Complaint so as to name each

appropriate Defendant after the completion of additional discovery.

33. Defendant Zach Brosius is an officer in the Middletown Police

Department who was acting under color of state law at all times relevant to this

Complaint. Upon information and belief, Defendant Brosius participated in the

Houck arrest. Defendant Brosius is sued in his individual capacity.

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34. Defendant John Doe #4 is an officer in the Middletown Police

Department who was acting under color of state law at all times relevant to this

Complaint and whose actual name is unknown to Plaintiffs after having conducted

a reasonable search with due diligence. Upon information and belief, Defendant

John Doe #4 participated in the Houck arrest. Defendant John Doe #4 is sued in

his individual capacity. Plaintiffs do not presently know the name of this

Defendant but will seek leave to amend the Complaint so as to name each

appropriate Defendant after the completion of additional discovery.

IV. FACTUAL ALLEGATIONS

A. Mark Houck maintains a history of peaceful pro-life activity.

35. Mark Houck is a devout Catholic, author, lecturer, and pro-life activist

who has deeply held convictions regarding the sanctity of unborn human life.

36. For years, Mr. Houck has volunteered as a counselor referring and

physically escorting women to the crisis pregnancy center, the Community

Women’s Center of America (“CWCA”), slightly down the street from the

Elizabeth Blackwell Health Center at 1144 Locust Street in Philadelphia,

Pennsylvania (“Planned Parenthood”), as well as participating with the local 40

Days for Life prayer vigil at that location and others for over 20 years.

37. While volunteering Mr. Houck also adheres to his deeply held

religious beliefs by praying for each pregnant woman and the children in her

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womb. Among other things, Mr. Houck asks God to provide wisdom, comfort, and

health to the women and health and safety to their children.

38. Mr. Houck routinely conducts sidewalk counseling with 40 Days for

Life, in which he compassionately engages with pregnant women and their male

partners to invite them to consider alternatives to abortion.

39. 40 Days for Life conducts peaceful, prayerful, lawful vigils as

indicated by its Statement of Peace, to which Mr. Houck adheres.

40. Mr. Houck is often joined in the vigil by members of his family, most

frequently by his oldest son.

41. Mr. Houck does not protest at the Planned Parenthood facility and has

never taken any action to block access to the facility. His activities are limited to

counseling pregnant women in crisis, referring them to CWCA, and praying.

42. In 2012, the Pro-Life Union established the CWCA, which is a pro-

life center that offers pregnancy-related services, in Center City Philadelphia. The

entrance to CWCA is across and slightly down the street from the Planned

Parenthood abortion clinic.

43. As a crisis pregnancy center that offers pregnancy-related services, the

CWCA presents pregnant women with alternatives to abortion, giving them the

opportunity to make fully informed decisions about their pregnancies.

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44. The CWCA is a certified reproductive health services facility and

long-time member of the Pro-Life Union of Greater Philadelphia.

45. The CWCA is staffed by trained professionals who provide pregnancy

testing, ultra-sounds, and counseling for pregnant women and their partners.

46. Over the years as part of his volunteer work, Mr. Houck has worked

with the CWCA and routinely conducted sidewalk counseling, in which he

compassionately engages with pregnant women and their partners and, if they

desire, escorts them to the CWCA to receive reproductive health services.

47. Mr. Houck has escorted many women into the CWCA facility and

assisted them in receiving reproductive health care services from the trained and

professionally credentialed staff within the facility.

48. Mr. Houck and his family have saved an estimated 100 lives due to

their peaceful activity outside the Planned Parenthood abortion facility on Locust

Street and Mr. Houck’s work with the professional staff at the CWCA to counsel

and escort patients to the CWCA, all of whom have received reproductive health

care services from the facility.

49. Mr. Houck’s work as a counselor and escort frequently involves him

physically escorting women into the CWCA facility and waiting with them until a

CWCA staffer begins the intake process. On at least one occasion Mr. Houck has

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escorted a woman to CWCA where she received counseling and then further

escorted her to a local hospital to receive treatment for an acute medical condition.

B. The first October 13, 2021, incident occurs.

50. On October 13, 2021, Mr. Houck had multiple encounters with Bruce

Love (“Mr. Love”), a Planned Parenthood “escort,” outside of the Planned

Parenthood abortion facility on Locust Street.

51. Mr. Houck was working as a counselor and escort for CWCA. He was

also praying and holding a vigil with his son.

52. At the same time, Mr. Love was at the entrance to Planned Parenthood

where he was supposed to be acting as a volunteer escort in accordance with

Planned Parenthood’s policies and procedures.

53. Mr. Love was a long-time Planned Parenthood “escort” who had

many previous interactions with Mr. Houck and other pro-life counselors and

escorts.

54. At all times relevant hereto, Mr. Love was aware that Planned

Parenthood had a policy which prohibited pro-choice escorts from “engaging” or

“antagonizing” pro-life counselors like Mr. Houck.

55. Mr. Love had wrongfully harassed pro-life counselors in the past in

violation of that policy, and Mr. Love had previously been instructed by Planned

Parenthood management on numerous occasions to stop doing so.

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56. Mr. Love’s long history of antagonizing pro-life counselors prior to

his interaction with Mr. Houck on October 13, 2021, was information readily

available to the FBI.

57. October 13, 2021, was no different. That day, like many before it, Mr.

Love decided to ignore the Planned Parenthood policy and accost pro-life

counselors. His chosen targets of the day were Mr. Houck and his 12-year-old son.

58. At the time, Mr. Houck and Mr. Love both knew of the other’s

volunteer activities. They were both repeat volunteers for their respective

reproductive healthcare facilities during the same time frames in the same city

block for several years.

59. Mr. Love was well aware that Mr. Houck was serving as a volunteer

in connection with the CWCA on October 13, 2021.

60. As counselors and escorts associated with reproductive healthcare

facilities, both Mr. Houck and Mr. Love were entitled to the protections of the

FACE Act, 18 U.S.C. § 248, because they were providing or attempting to provide

access to reproductive healthcare services.

61. In part, the FACE Act prohibits injuring or intimidating an individual

“in order to” interfere with one’s ability to obtain or provide reproductive health

services. 18 U.S.C. § 248(a)(1).

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62. The first encounter, on October 13, 2021 (the “First Incident”) began

when Mr. Houck—alongside his 12-year-old son, M.H.—approached two women

standing on the same street corner as themselves and began to explain the

reproductive health services available at the CWCA. This conversation began like

the many other conversations Mr. Houck had previously had with women during

his years as a volunteer, where he provided information and referrals to the

CWCA. Mr. Houck’s interaction with the women was similar to previous

occasions during which he had shared a CWCA brochure describing the available

reproductive healthcare services, answered questions, escorted women to the

facility to connect them with a healthcare professional, and assisted them in

receiving pregnancy-related services.

63. Only this time, when Mr. Love saw Mr. Houck talking to the two

women and showing them a CWCA brochure, Mr. Love ran nearly 100 feet to

where Mr. Houck and the two women were talking. Mr. Houck and the women

were located approximately 20 feet from the CWCA entrance.

64. Mr. Love forced himself into the group, physically positioning

himself between Mr. Houck and the women as they walked. Mr. Love tried to set a

moving pick, separate Mr. Houck from them, and interrupt Mr. Houck’s

counseling and referral to the CWCA.

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65. Mr. Houck, in an effort to continue counseling the two women as they

slid by Mr. Love’s pick, made brief and inadvertent contact with Mr. Love’s arm.

Mr. Love’s quick interjection and proximity prevented Mr. Houck from avoiding

contact with Mr. Love.

66. During cross examination at Mr. Houck’s criminal trial, Mr. Love

admitted that his “intent” when he approached Mr. Houck and the two women was

in order to prevent him from referring the women to the CWCA crisis pregnancy

center:

Q. “Well, didn’t you tell the FBI that the reason that you went up there

was because you didn’t want Mark to direct them to the woman’s center

across the street? That’s what you told the FBI.”

A. “That’s part of it, yes.”

(United States v. Houck, Trial Transcript Day 3, Page 108 Line 10-14).

67. Mr. Love’s effort on October 13, 2021, to interfere with and disturb

Mr. Houck’s work as a counselor and escort were successful because he physically

blocked Mr. Houck from speaking to the women. The women departed the area

without receiving information or access to the CWCA crisis pregnancy center.

68. The First Incident was a violation of the FACE Act by Mr. Love, not

Mr. Houck. Yet Mr. Love was not charged, and Mr. Houck was.

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69. Despite the presence of multiple cameras, including police cameras

and cameras on adjacent buildings in the vicinity of Mr. Love’s interference with

Mr. Houck, Planned Parenthood failed to preserve—and the FBI failed to collect—

any video of Mr. Love interfering with Mr. Houck’s work as a counselor and

escort to the CWCA.

70. This failure was especially egregious because Planned Parenthood’s

video system was on a “30-day loop.” Planned Parenthood only saved and turned

over a minute and a half of video surveillance depicting the second incident

(discussed below) in which Mr. Houck pushed Mr. Love to keep Mr. Love away

from his son, M.H. (United States v. Houck, Trial Transcript Day 2, Page 169 Line

15-22).

71. When the FBI requested additional video, Planned Parenthood

reported that the remainder of the video had been deleted. (United States v. Houck,

Trial Transcript Day 2, Page 170 Line 19-23). The FBI was notified of the second

incident on October 15, 2021, which was well within Planned Parenthood’s 30-day

video surveillance retention policy. The FBI had ample time to either collect

additional footage or require Planned Parenthood to retain additional footage. The

FBI failed to take these critical measures despite the FBI being specifically notified

that the surveillance video was being provided to the FBI for a potential FACE Act

violation. (United States v. Houck, Trial Transcript Day 2, Page 136 Line 14-16).

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72. Mr. Love’s conduct in physically interfering with Mr. Houck’s work

on behalf of a crisis pregnancy center (the CWCA) was a clear violation of the

FACE Act, 18 U.S.C. § 248, because he was intentionally using a physical

obstruction (his body) to interfere with an individual attempting to provide access

to pregnancy-related services.

73. In short, with respect to the First Incident, federal law enforcement

and the DOJ, acting in their official capacity and under color of law, knowingly

and intentionally chose not to charge Mr. Love for his clear FACE Act violations,

despite his history of antagonism toward pro-life volunteers and Mr. Houck and his

son on October 13, 2021, but rather unjustly chose to charge Mr. Houck with a

FACE Act crime that he clearly did not commit. This selective prosecution had a

substantial effect on Mr. Houck’s second charge, enhancing the potential

maximum penalty from three years to eleven years, as a predicate or prior offense.

C. The second October 13, 2021, incident occurs.

74. Mr. Houck told Mr. Love that he disapproved of Mr. Love’s

interference with his attempt to counsel the two women. Mr. Love responded not

by apologizing, but by berating Mr. Houck for offering such services in the first

place. He then retreated into the Planned Parenthood abortion facility.

75. Mr. Houck and his oldest son, M.H., then moved to a position

approximately 50 feet away from the Planned Parenthood abortion facility’s

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entrance at the corner of 12th Street and Locust Street. They began to pray and talk

to each other while waiting to speak to or counsel any individuals who might

approach from that direction. Meanwhile, Mr. Love reemerged from the Planned

Parenthood abortion clinic to man the entrance, his usual post.

76. Mr. Love did not stay at his post for long. Perhaps encouraged by his

success in blocking access to the CWCA in the First Incident and motivated by the

presence of Mr. Houck’s son, M.H., he once again left his post and instigated the

“Second Incident” of the day. Mr. Love walked up Locust Street toward Mr.

Houck and M.H. on the corner while loudly harassing them. Mr. Love refused to

stop despite multiple requests by Mr. Houck.

77. On multiple prior occasions, Mr. Love had harassed Mr. Houck while

Mr. Houck had attempted to counsel young women and stand vigil. On previous

occasions, Mr. Love had called Mr. Houck a “f----tt,” a derogatory name for

homosexuals, and grotesquely told Mr. Houck to “go home and masturbate” or to

go back to his friends “the pedophile priests.”

78. Planned Parenthood was aware of Mr. Love’s history of harassment,

and this information was readily available to the FBI.

79. On the date of this incident, Mr. Love made similarly abusive

comments directed at Mr. Houck, but then intentionally escalated the harassment

by directing his comments to Mr. Houck’s 12-year-old son, M.H.

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80. Mr. Love—while standing only feet away from Mr. Houck and

M.H.—began speaking directly to M.H. telling him his father was a “bad man that

does not like women” and other harassing and abusive comments.

81. At least one other person who witnessed the interaction urged Mr.

Love to move back to his position at Planned Parenthood and leave Mr. Houck and

M.H. alone.

82. Mr. Love ignored these pleas and instead continued to bait and harass

Mr. Houck.

83. Mr. Love’s intent was obvious: to drive Mr. Houck and M.H. away

from the corner and to prevent them from continuing Mr. Houck’s work as a

counselor on behalf of the CWCA.

84. At the time Mr. Love began to escalate his harassment of Mr. Houck

and M.H., no facility patients or individuals were being counseled by Mr. Houck,

M.H, or Mr. Love. No facility patients were nearby or in need of an escort. The

encounter (the “Second Incident”) did not in any way involve any person’s access

to a reproductive clinic.

85. During this lull in activity, Mr. Houck decided to defuse the situation

and protect M.H. from Mr. Love’s abusive and threatening conduct. Mr. Houck

again asked Mr. Love to leave, and Mr. Houck first attempted to walk Mr. Love

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from M.H. on the corner and back to Mr. Love’s post at the entrance of the

Planned Parenthood abortion facility on Locust Street.

86. This de-escalation seemed to initially work, and Mr. Love appeared to

comply with Mr. Houck’s request to leave them alone. Mr. Houck therefore turned

back toward his son on the corner. At that very moment, however, Mr. Love

reversed course and headed back toward M.H., resuming his verbal harassment.

87. At this, Mr. Houck turned around and, finding Mr. Love advancing

toward him, pushed Mr. Love to protect M.H.

88. When Mr. Houck finally pushed Mr. Love, he was pushing him away

from the corner where he and M.H. were standing in order to stop Mr. Love’s

harassment of his child.

89. The Planned Parenthood video reviewed by the FBI has no audio, but

it shows that Mr. Love and Mr. Houck were arguing at the time of the shove and

that M.H. was about three (3) feet behind Mr. Houck on the corner.

90. The FBI interviewed Mr. Love and two (2) eyewitnesses who all

verified that Mr. Houck mentioned his “son” at the time of the shove.

91. Mr. Love himself told the FBI that at the time of the shove Mr. Houck

told Mr. Love to “stay away from me, and away from my son.” (United States v.

Mark Houck, Trial Transcript, Day 3, Page 120 Line 19-25 and Page 121 Line 1-

8).

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92. Eyewitness Ellen Weiss also testified while reviewing the video

during her trial testimony that she recalled Mr. Houck “yelling something about his

son.” (United States v. Houck, Trial Transcript, Day 3, Page 177, Line 20-25, Page

178 Line 1 and Page 194 Line 11-17).

93. Eyewitness Steven Jeronimo testified that at the time he heard Mr.

Houck yelling that he heard “mention of a kid.” (United States v. Houck, Trial

Transcript, Day 3, Page 232 Line 3-6).

94. A third eyewitness, Tristan Dahn, testified at trial and told the FBI

that he heard “angry” shouting from Mr. Houck and that there may have been a

child with Mr. Houck as he walked away. (United States v. Houck, Trial

Transcript, Page 201 Line 19-20 and Page 210 Line 11-22).

95. Prior to the filing of the indictment, there was sufficient evidence

which showed that Mr. Houck acted to defend M.H., not to interfere with Mr.

Love’s work as a volunteer.

96. There were no “patients” or prospective “patients” of the abortion

facility present or nearby. The parties’ brief encounter did not involve any person’s

access to the facility. Mr. Love was not escorting anyone or assisting anyone in

obtaining reproductive health services. None of the parties, the Houcks included,

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were so much as talking with a patient, or even preparing to talk with an

approaching patient.

97. Instead, Mr. Love unilaterally initiated an argument in an attempt to

threaten and antagonize Mr. Houck and M.H. after having scored what he viewed

as an initial victory in blocking women’s access to the CWCA in the First Incident.

98. Mr. Love’s conduct was therefore motivated by, and for the express

purpose of interfering with, Mr. Houck’s work for the CWCA.

99. Mr. Love’s conduct was also in direct violation of Planned

Parenthood policies governing volunteers. Those policies were promulgated at

least in part to keep Planned Parenthood volunteers from violating the FACE Act.

Specifically, the Planned Parenthood escort training manual dictates that it is

“unacceptable behavior” for an escort to “engage with or antagonize” pro-life

advocates including “sidewalk counselors.”

100. Mr. Love had received this training and had previously been

reprimanded for violating this edict.

101. At the criminal trial of Mr. Houck, Dayle Steinberg (“Ms. Steinberg”),

the President and Chief Executive Officer of Planned Parenthood of Southeastern

Pennsylvania, acknowledged that Mr. Love had “been spoken to on numerous

occasions” about the “non-engagement policy and he continues to disregard it.”

(United States v. Houck, Trial Transcript Day 2, Page 104, Line 13-20).

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102. Ms. Steinberg further acknowledged that she had directed that Mr.

Love be removed from the volunteer scheduled rotation. (Id.).

103. Ms. Steinberg had memorialized these statements in an email to the

Planned Parenthood Chief of Security shortly after the incident. This email, which

discussed Mr. Love’s history and repeated violations of Planned Parenthood’s

policies that specifically required him to avoid antagonizing pro-life counselors in

light of the FACE Act, was available to the FBI prior to the Grand Jury Indictment

of Mr. Houck.

D. State authorities decline to prosecute Mr. Houck.

104. After the Second Incident, Mr. Houck and M.H. left the area but later

returned and provided officers of the Philadelphia Police Department Civil Affairs

Unit (“PPCAU”) a full statement describing both encounters including Mr. Love’s

violation of the FACE Act.

105. After interviewing Mr. Houck and Mr. Love, the Philadelphia Police

Department declined to pursue the incident further.

106. A week later on October 20, 2021, Mr. Love filed a private criminal

complaint against Mr. Houck in Pennsylvania state court relating to the October

13, 2021, incident in which he identified himself as a “volunteer” for Planned

Parenthood and Mr. Houck as a “member of the Kingsman organization.”

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107. In the complaint, Mr. Love made two false statements: first that he

was positioned on the corner near Mr. Houck “waiting for clients” and second that

he had been pushed in the back while he was “walking away.”

108. Upon information and belief, Mr. Love was assisted in filing the

complaint, and it was drafted by a Planned Parenthood attorney notwithstanding

Planned Parenthood’s own concerns about Mr. Love’s violation of Planned

Parenthood policy.

109. Mr. Love and Planned Parenthood had seven (7) days prior to filing

the private criminal complaint to review the video footage and were at all times

aware that Mr. Houck had not pushed Mr. Love in the back, despite Mr. Love’s

testimony claiming such.

110. The FBI’s investigative officer, including Special Agent Christopher

Jackson, had access to this false complaint as early as October 21, 2021.

111. Presumably at the direction of the FBI and federal authorities, the

Philadelphia District Attorney did not bring charges against Mr. Houck relating to

the incidents that occurred October 13, 2021 (the “Incidents”) and did not pursue

the private criminal complaint.

112. The Philadelphia District Attorney spokesman publicly stated at the

time of Mr. Houck’s arrest that “[t]he case was disposed of locally so the DOJ

could assume and lead the investigation.” Jo Ciavaglia, FBI Denies Anti-Abortion

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Activists Claims that SWAT Force Was Used in Arrest at Upper Bucks Home, The

Morning Call (Sept. 27, 2022), https://www.mcall.com/2022/09/27/fbi-denies-anti-

abortion-activists-claims-that-swat-force-was-used-in-arrest-at-upper-bucks-home/.

113. The District Attorney’s statement confirms that federal investigative

and/or law enforcement officers were aware that Mr. Love’s complaint contained

false allegations and that the federal officers, nonetheless, communicated directly

with the state authorities about not pursuing the private criminal complaint so the

DOJ could pursue a Federal Indictment.

114. Mr. Love did his part and purposely failed to appear for trial. The

state court dismissed Mr. Love’s complaint on April 25, 2022, for his failure to

appear and prosecute his case.

E. The FBI arbitrarily enforces the FACE Act.

115. The FBI’s investigative officers, including Special Agent Christopher

Jackson and other unnamed individuals, understood at the time of their

investigation of Mr. Houck they were serving a malicious and illegitimate purpose

in facilitating the prosecution of Mr. Houck, while ignoring Mr. Love’s violations

of the FACE Act.

116. The FBI knew that the FACE Act was rarely used to protect

counselors associated with crisis pregnancy centers—pro-life centers that offer

pregnancy-related services—but instead was used almost exclusively to prosecute

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alleged victims associated with Planned Parenthood and other pro-choice

organizations.

117. FACE Act prosecutions are overseen by the DOJ Civil Rights

Division.

118. The target letter issued to Mr. Houck was signed by a local Assistant

U.S. Attorney (“AUSA”) in the Eastern District of Pennsylvania.

119. There is no record of any prosecution of an individual violating the

FACE Act by intimidating or interfering with a volunteer or employee of a crisis

pregnancy center.

120. In fact, the DOJ publicizes on its website the number of FACE Act

prosecutions it has conducted.

121. The most recent data shows that almost all of the publicized

prosecutions were of pro-life advocates, not pro-choice ones.

Prosecution of Pro-Life Defendant Prosecution of Pro-Choice Defendant

United States v. Zastrow, et al. (2023) United States v. Freestone, et al. (2023)
United States v. Gallagher, et al. (2022)
United States v. Handy, et al. (2022)
United States v. Barron (2022)
United States v. Moscinski (2022)
United States v. Houck (2022)
United States v. Kruse (2022)
United States v. Chamberlin (2022)
United States v. Brime (2021)
United States v. Little (2021)
United States v. Gulick (2021)
United States v. Allen (2020)

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United States v. Dear (2019)

United States v. Kaster (2019)
United States v. Wiersma (2019)
United States v. Reynolds (2016)
United States v. Harris (2017)
United States v. Curell (2014)
United States v. Grady (2012)
United States v. Mower (2011)

Dept. of Justice, Recent Cases on Violence Against Reproductive Health Care

Providers (updated May 30, 2023), https://www.justice.gov/crt/recent-cases-

violence-against-reproductive-health-care-providers. The DOJ list still includes

Mark Houck despite his acquittal on all charges.

122. The single publicized prosecution of a pro-choice advocate involved

vandalism of a pregnancy resource center.

123. There are no cases involving the prosecution of an individual like Mr.

Love who interfered with the work of a counselor working with a crisis pregnancy

center—a pro-life center that offers pregnancy-related services.

124. These disparities and the reasons behind them were well known to the

FBI.

125. The head of the DOJ Civil Rights Division, Kristen Clarke, has

publicly declared that counselors and crisis pregnancy centers are not entitled to

the protections of the FACE Act.

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126. In 2018, the United States Supreme Court issued an opinion in

National Institute of Family Life Advocates v. Becerra, which upheld the First

Amendment rights of crisis pregnancy centers. 138 S. Ct. 2361 (2018).

127. At the time this decision was issued Ms. Clarke was the President and

Executive Director of the Lawyer’s Committee on Civil Rights.

128. The Lawyer’s Committee and Ms. Clarke condemned the court’s

ruling referring to crisis pregnancy centers as “fake clinics”:

“Make no mistake, today’s decision at the #SCOTUS striking down a CA

disclosure requirement for crisis pregnancy centers is part of a coordinated

strategy to tear down #RoevWade. The anti-choice movement will stop at

nothing. #EndTheLied #ExposeFakeClincs.”

@KristenClarkJD, X (Jun. 26, 2018, 12:14 PM),

https://twitter.com/kristenclarkejd/status/1011658850498273280.

129. Ms. Clarke further expressed her personal opinion on social media

where she described crisis pregnancy centers like the CWCA as “predatory”:

“Today’s #SCOTUS ruling striking down CA law that required crisis

pregnancy centers to provide factual information about state-offered

services, including abortions, will have harmful consequences for

women, especially women of color who are often targeted by predatory

CPCs [Crisis Pregnancy Centers].”

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@KristenClarkJD, X (Jun. 26, 2018, 10:29 AM),

https://twitter.com/KristenClarkeJD/status/1011632487129407488.

130. Ms. Clarke took over the Civil Rights Division in May 2021, five (5)

months before the incident that led to Mr. Houck’s arrest.

131. Upon information and belief, her opinions on the biased enforcement

of the FACE Act are well known as a result of her confirmation testimony and

previous public statements.

132. Upon information and belief, Ms. Clarke directly reported at all

relevant times to Associate Attorney General Vanita Gupta, the third-highest

ranking official in the DOJ. Like Ms. Clarke, Ms. Gupta has attacked crisis

pregnancy centers.

133. In 2020, Ms. Gupta criticized a judicial nominee for serving as

president and legal counsel of a “so-called crisis pregnancy center.” Letter from

Vanita Gupta to Oppose the Confirmation of David Dugan to the U.S. District

Court for the Southern District of Illinois, July 29, 2020, at 1, at

http://civilrightsdocs.info/pdf/policy/letters/2020/David-Dugan-Opposition-Letter-

SDIL-7.29.20-FINAL.pdf. Ms. Gupta then quoted the National Association for the

Repeal of Abortion Laws, also known as NARAL Pro-Choice America, to

disparage crisis pregnancy centers as “fake health-care clinics that lie to, shame

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and intentionally mislead women about their reproductive-health-care options to

block them from accessing abortion care.” Id. at 2.

134. Ms. Gupta took office as Associate Attorney General in April 2021,

six months before the Incidents that led to Mr. Houck’s arrest and served until

February 2024. During her time in office, Ms. Gupta’s public comments on the

FACE Act reflected her belief that the ACT only applies to prosecute pro-life

individuals.

135. After the Supreme Court’s decision in Dobbs v. Jackson Women’s

Health Organization, 597 U.S. 215 (2022), the DOJ established a “Reproductive

Rights Task Force” led by Ms. Gupta. In July 2022—just two months before Mr.

Houck’s arrest—Ms. Gupta announced that the Task Force was “supporting the

Department’s ongoing work to enforce the FACE Act, which establishes criminal

and civil penalties for injuring, intimidating or interfering with a person seeking to

obtain or provide reproductive health services.” Department of Justice, Associate

Attorney General Vanita Gupta Delivers Remarks at White House Convening of

Lawyers in Defense of Reproductive Rights (July 29, 2022),

https://www.justice.gov/opa/speech/associate-attorney-general-vanita-gupta-

delivers-remarks-white-house-convening-lawyers.

136. In December 2022, Ms. Gupta reported that the Supreme Court’s

decision in Dobbs “increase[ed] the urgency” of enforcing the FACE Act: “Earlier

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this year, in Dobbs v. Jackson Women’s Health Organization, the Supreme Court

dealt a devastating blow to women throughout the country, taking away the

constitutional right to abortion and increasing the urgency of our work, including

enforcement of the FACE Act, to ensure continued lawful access to reproductive

services.” Department of Justice, Associate Attorney General Vanita Gupta

Delivers Remarks at the Civil Rights Division’s 65th Anniversary (Dec. 6, 2022),

https://www.justice.gov/opa/speech/associate-attorney-general-vanita-gupta-

delivers-remarks-civil-rights-divisions-65th.

137. Ms. Gupta’s remarks made clear her view that the FACE Act protects

abortion clinics and proponents of abortion rights but not crisis pregnancy centers

and pro-life individuals.

138. Upon information and belief, the FBI’s investigative officers were

aware that Ms. Clarke and Ms. Gupta believed the FACE Act did not apply to

“fake clinics” and should instead be used to prosecute pro-life individuals on

behalf of alleged victims associated with pro-choice organizations. As such, the

FBI’s investigative officers have failed to prosecute FACE Act violations on behalf

of alleged victims associated with crisis pregnancy centers—pro-life centers that

offer pregnancy-related services.

139. The FBI’s officers acted contrary to the DOJ’s stated policy of the

FACE Act not being “about abortion” and instead acted in accordance with Ms.

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Clarke’s and Ms. Gupta’s improper views when they intentionally investigated and

indicted Mr. Houck because he was pro-life and declined to investigate and

prosecute Mr. Love because he was pro-choice.

F. Federal authorities fail to communicate with Mr. Houck’s

attorney.

140. On April 27, 2022, just two days after dismissal of Mr. Love’s

complaint, Mr. Houck received a letter notifying him that he was the target of a

federal grand jury investigation concerning a violation of the FACE ACT, 18

U.S.C. § 248. It was served personally on Mr. Houck while he was counseling in

front of a clinic.

141. The letter invited Mr. Houck’s counsel to communicate with federal

officials.

142. In response, Mr. Houck’s counsel repeatedly attempted to reach the

AUSA who signed the target letter, in writing and by telephone.

143. Neither the AUSA nor any other federal official responded to Mr.

Houck’s counsel so much as to acknowledge his communication.

144. On June 9, 2022, Mr. Houck’s counsel emailed the AUSA to explain

why the Government should not charge Mr. Houck with a FACE Act violation.

This explanation highlighted legal precedent demonstrating that in cases like Mr.

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Houck’s, where a physical altercation occurred that was wholly unmotivated by the

volunteer’s work, no FACE Act violation had occurred.

145. In the event that the Government decided to move forward with

charges, Mr. Houck’s counsel additionally stated that he would “accept a summons

on [his] client’s behalf, rather [than] put Mr. Houck and his family through

needless disruption.”

146. Months passed with no response to Mr. Houck’s counsel’s email or

subsequent phone calls.

147. Mr. Houck and his counsel had reason to believe that the Government

had reconsidered its position after reviewing the law and facts. The FACE Act,

after all, prohibits injuring or intimidating an individual “because that person is or

has been” or “in order to intimidate” such person from obtaining or providing

reproductive health services. 18 U.S.C. § 248(a)(1).

148. Shortly after Mr. Houck’s counsel’s letter, on June 24, 2022, the

United States Supreme Court handed down Dobbs, which reversed Roe v. Wade.

Mr. Houck’s counsel did not receive a response from the AUSA until after Mr.

Houck had been arrested on September 23, 2022.

149. Under Ms. Gupta’s and Ms. Clarke’s leadership, and at the instigation

of FBI agents who by this point had the true facts, a federal grand jury was

convened.

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150. On September 20, 2022, a federal grand jury charged Mr. Houck with

two violations of the FACE Act, with one count against Mr. Houck for each of the

two incidents that occurred on October 13, 2021 (the “Indictment”).

151. Upon information and belief, no investigation was ever conducted

regarding Mr. Love for violating the FACE Act with respect to either Incident.

152. With respect to the First Incident, this failure to investigate Mr. Love

was despite his admission that he had intentionally interfered with Mr. Houck

while Mr. Houck was acting as a counselor for the crisis pregnancy center.

153. The first paragraph of the Indictment introduces and identifies

“Planned Parenthood – Elizabeth Blackwell Health Center” as a “provider of

women’s reproductive health services. . .” The Indictment makes no mention of the

CWCA directly across the street from Planned Parenthood or Mr. Houck’s work as

a counselor and escort.

154. Instead, the Indictment describes Mr. Houck as a “[p]rotestor.” The

alleged victim in the case was identified as Mr. Love, a Planned Parenthood

volunteer escort who is described as an individual assisting patients in “safely

entering and exiting the [Planned Parenthood] facility.”

155. This treatment is consistent with Ms. Gupta’s and Ms. Clarke’s widely

known views that pro-life crisis pregnancy centers are “fake” and “predatory.” On

that view, anyone like Mr. Houck who prays, counsels, and assists in bringing

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women to such pro-life centers can only be viewed as a “protestor” against Planned

Parenthood, and not as someone engaged in conduct protected by the FACE Act.

156. The FBI targeted Mr. Houck for indictment without probable cause

because of his beliefs, his public prayer and speech, and the fact that he is a

counselor associated with a crisis pregnancy center.

157. The FBI personnel, including Special Agent Jackson, were all aware

of the discriminatory policies and practices surrounding the enforcement of the

FACE Act, and that the DOJ was targeting Mr. Houck and protecting Mr. Love in

an effort to intimidate and disrupt the activities of pro-life counselors and

pregnancy crisis centers.

158. Count I of Mr. Houck’s Indictment, which charged the First Incident,

also contained egregious factual errors.

159. For example, it completely reversed the facts and falsely alleged that

Mr. Houck “shoved” a Planned Parenthood volunteer (Mr. Love) to the ground as

the volunteer “attempted to escort two patients” into a reproductive health services

facility. It further alleged that Mr. Houck did so in an effort to “intimidate and

interfere with” the volunteer “because” the volunteer “was or had been providing

reproductive health services.” (emphasis added).

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160. The FBI intentionally ignored Mr. Love’s admitted violation of the

FACE Act presumably because Mr. Love is a counselor associated with Planned

Parenthood, an organization that provides, and advocates for, abortions.

161. Count I was patently false. It was also easily disproven by Mr. Love’s

own admissions.

162. Count II, which charged the Second Incident, was also false. Mr.

Houck did not push Mr. Love away “in order to” interfere with the reproductive

health services of Planned Parenthood. When Mr. Love was pushed to the ground,

he was not in the process of escorting anyone to receive any reproductive health

services, nor was anyone speaking with potential patients or preparing to speak

with potential patients.

163. Rather, the push happened because Mr. Love had repeatedly left his

station at the clinic entrance to accost Mr. Houck and his 12-year-old son with

outrageous comments.

164. All of the witnesses agreed that the physical altercation happened

because Mr. Houck got “angry” and yelled for Mr. Love to “leave [him and] his

son alone.”

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165. Count II is also easily disproven by video surveillance, as Mr. Love

was not escorting any patients into Planned Parenthood when the physical contact

took place.

166. The only way the false statements in the Indictment could have been

adopted by the grand jury is by the malicious presentation of false or misleading

facts and instructions or the concealment of critical and material information.

167. Upon information and belief, FBI Special Agent Jackson and other

agents participated and assisted in the presentation of evidence to the grand jury.

168. This false and misleading information was presented to the grand jury

for the sole purpose of obtaining an indictment to charge Mr. Houck. This effort

was malicious and based on Mr. Houck’s speech, prayer, and work as a counselor

for a pro-life center that offers pregnancy-related services.

169. This malice was also consistent with Ms. Gupta’s and Ms. Clarke’s

view that not only are pro-life centers “fake” clinics unworthy of protection under

the FACE Act, but also Ms. Clarke’s view that anyone working on their behalf

shares in their “predatory” mission and is therefore a prime subject for FACE Act

prosecution.

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170. Mr. Love, on the other hand, was spared investigation, arrest, and

prosecution because he was associated with Planned Parenthood, a pro-choice

abortion clinic that offers pregnancy-related services.

171. At all times relevant hereto, the FBI’s investigative officers acted

deliberately to fabricate probable cause in order to indict, arrest and charge Mr.

Houck with a crime they knew he did not commit.

G. Mr. Houck is arrested at gunpoint in front of his family.

172. The Government moved quickly after the Indictment, but it ignored

Mr. Houck’s counsel’s offer to surrender their client.

173. Instead, government agents opted for excessive and overwhelming

force that resulted in unnecessary danger and fear.

174. Early on the morning of September 23, 2022, Mr. Houck started

breakfast on the main floor of his home while his wife dressed, and his seven

children slept in their upstairs bedrooms.

175. Suddenly, around 6:45 am, before daylight, Mr. Houck’s quiet

morning was abruptly interrupted with loud pounding on the front door, repeated

ringing of the doorbell, and voices shouting to “Open up!” and “Hurry!”

176. Before opening the door, Mr. Houck advised whoever was outside

that he was going to open the door and to stay calm because he had seven babies

inside.

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177. Mr. Houck opened the door to find a large cohort of heavily armed

federal, state, and local law enforcement surrounding his home and pointing rifles

and pistols directly at him.

178. Upon information and belief, at least 20 law enforcement agents

participated in Mr. Houck’s arrest. A senior FBI source has admitted that “there

may have been 15-20 agents at the scene.” Bradford Betz et al., Pennsylvania pro-

life activist arrested by FBI, charged with assaulting clinic escort, FOX NEWS

(Sept. 25, 2022), https://www.foxnews.com/us/pennsylvania-pro-life-activist-

arrested-fbi-charged-assaulting-clinic-escort. In addition to the federal agents, state

and local law enforcement agents also participated in the arrest.

179. Mr. Houck observed that the agents were wielding firearms, battering

rams, a crowbar, and were equipped with heavily armored vests, ballistic helmets,

and shields. Marked and unmarked government vehicles surrounded his home and

lined his driveway.

180. Mr. Houck also observed rifles, including AR-styled rifles and

handguns aimed at him from his porch, his yard, and his driveway. Agents

crouched behind their vehicles and aimed their guns at him as if they were

arresting a dangerous criminal.

181. Two agents were in the rear of Mr. Houck’s home and scared Mr.

Houck’s daughter, T.H., when she discovered agents dressed in black behind the

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home. T.H. observed that the agents were holding rifles and were looking into the

Houcks’ home through the back door windows.

182. Mr. Houck asked why the agents were there, to which an agent

replied, “you know why we are here.”

183. No warrant was visible or provided.

184. The show of force and attempts to intimidate and terrify Mr. Houck

were unnecessary, however, as he was at all times peaceful and complied with

agents’ instructions without delay or question.

185. Meanwhile, Mrs. Houck, confused to see flashing lights on her

bedroom walls, approached the upstairs window to observe the scene below.

186. Mrs. Houck, with her bird’s eye view, observed marked and

unmarked government vehicles surrounding her home. Mrs. Houck saw that every

officer present had a gun that was aimed directly at her house.

187. Mrs. Houck rushed down the stairs, which are less than five feet from

the front door, to join her husband in front of the agents’ pointed guns. The

officers’ guns were pointed at her and followed her movements.

188. Mrs. Houck immediately asked who the agents were looking for. An

agent initially refused to provide the name of the individual the cohort was

attempting to arrest, but after Mrs. Houck insisted, an agent eventually replied they

were there for Mark Houck.

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189. The Houck children had begun to scream, gathering on the stairs just

behind the front door and downrange of the firearms pointed at their parents.

190. In the several minutes that elapsed since Mr. Houck had stepped onto

the front porch, the officers’ guns remained pointed at him and followed his

movements.

191. Mr. Houck cooperated throughout the arrest. He did not resist or

attempt to evade arrest. Mr. Houck placed his hands in the air and slowly walked

out his front door onto his porch. Nonetheless, the officers’ guns remained pointed

at him.

192. Mr. Houck asked if he could get dressed. The officers refused his

basic request.

193. When Mrs. Houck demanded to know if the agents had a warrant for

her husband’s arrest, an agent responded that “we are taking him with or without a

warrant.” Only later, after Mr. Houck had been handcuffed and loaded into the

transport vehicle, did any agent produce a warrant to Mrs. Houck.

194. Mr. Houck’s oldest son, M.H. unsuccessfully attempted to shield his

younger siblings from seeing their father arrested by armed agents.

195. Mr. Houck’s children stood on the stairs screaming, crying, and

watching in terror as heavily armed agents hauled their father away.

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196. It was not until after the children had made their way down the stairs

that the guns were put down and put away, but by then, the children had already

been subjected to the raised guns and the forcible detention of their father.

197. Mrs. Houck found it difficult to breathe as FBI agents surrounded her

home with ballistic shields and loaded weapons.

198. As Mr. Houck was arrested, Mrs. Houck was shaking in fear for the

safety of herself, her husband, and her children who were all screaming and crying

on the stairs.

199. During transport, Mr. Houck asked the transporting officers, including

Agent Jackson, the lead officer on the case, why so many agents were necessary in

his arrest. The agent responded by claiming that they did not know anything about

Mr. Houck and arguing that they always came “prepared for anything.”

200. But in fact, as noted above, the team would have learned from its

preparation that Mr. Houck had no criminal history, that he had no history of

violence, that his attorney had offered his voluntary surrender in the event of an

indictment, and that Mr. Houck had no registered guns at all, let alone any guns in

his home.

201. Agent Jackson’s comment was gaslighting, an effort at plausible

deniability for his team’s unnecessary and excessive force in detaining Mr. Houck.

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202. On September 23, 2022, nearly ten hours after the raid on his home,

Mr. Houck was released on his own recognizance and reunited with his family.

The FBI’s chosen means of arrest allowed it to last a period of several hours during

which Mr. Houck was chained to a desk and left alone in a room with no

communication or information.

203. Even after the federal law enforcement agents knew that Mr. Houck

was to be released on his own recognizance, he was kept chained hand and foot

until released. Again, this was precisely the treatment one would expect for those

whom the DOJ’s senior leadership viewed as aiding “fake” and “predatory” pro-

life centers.

204. Mr. Houck stood trial beginning on January 24, 2023.

205. After a trial and deliberations that spanned five days, the jury

acquitted Mr. Houck on all charges on January 30, 2023.

H. Defendants engaged in unlawful actions against Mr. Houck.

206. Upon information and belief, FBI’s investigative officers participated

in the investigation leading to Mr. Houck’s subsequent indictment.

207. Upon information and belief, the FBI’s investigative officers

intentionally, knowingly, and/or recklessly made or caused to be made false

statements and representation and material omissions of facts in reports, affidavits,

or other communications with federal prosecutors, thereby initiating a malicious

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prosecution of Mr. Houck, as evidenced by false allegations made in the

indictment.

208. Upon information and belief, Defendants participated in Mr. Houck’s

arrest and were present at his home on September 23, 2022.

209. Upon information and belief, Defendants had guns drawn and pointed

at Mr. Houck during his arrest.

210. Upon information and belief, the Defendants conspired and agreed

before Mr. Houck’s arrest to draw up their weapons and aim them at Mr. Houck.

Based on what the Defendants knew or should have known about Mr. Houck, they

knew or should have known that it would constitute excessive force to draw up

their weapons and aim them at Mr. Houck.

211. Each Defendant knew or should have known that Mr. Houck had

been charged with non-violent crimes.

212. Each Defendant knew or should have known that Mr. Houck did not

pose an immediate threat to their safety or the safety of others during his arrest.

213. Each Defendant knew or should have known that Mr. Houck had no

criminal history or history of violence.

214. Each Defendant knew or should have known that Mr. Houck had

never threatened law enforcement officers.

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215. Each Defendant knew or should have known that Mr. Houck, his

wife, and his children did not own a firearm.

216. Each Defendant knew or should have known that Mr. Houck’s wife

and seven children lived with Mr. Houck and would be present during an arrest at

the family home.

217. At least one Defendant admitted awareness that Mr. Houck’s children

would be present. As Mr. Houck was being arrested, the vehicle dashcam video

captured one agent confiding to another: “My only concern, really, was the schools

in the morning. You saw the kids starting to come out.” The two agents discussed

how Mr. Houck’s kids could have been standing at the end of the driveway. The

second agent then exclaimed the obvious: “Yeah, I don’t want any kid to see this s-

--.”

218. Each Defendant knew or should have known that the ratio of law

enforcement agents to Mr. Houck clearly compelled a low level of force.

219. Each Defendant knew or should have known that Mr. Houck was

willing to and had offered to, through counsel, turn himself in if he was indicted.

220. Each Defendant knew or should have known that Mr. Houck was

represented by counsel all at relevant times during the arrest.

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221. At all times relevant to this Complaint, the conduct of Defendants

was extreme and outrageous and was in willful, reckless, and callous disregard of

the Plaintiffs’ rights under federal and state law.

I. Defendants’ unlawful actions resulted in significant damages to

Plaintiffs.

Injuries to Mr. Houck

222. As a direct and proximate result of the FBI’s raid of Mr. and Mrs.

Houck’s home, as well as the FBI’s investigation and false arrest of Mr. Houck and

the resulting imprisonment and malicious prosecution of him, Mr. Houck suffered,

and continues to suffer, substantial damages.

223. Those damages include loss of liberty, invasion of privacy,

substantial emotional distress and harm with physical manifestations, irreparable

loss of reputation, infringement on his free exercise of religion and free speech

rights, and post-traumatic stress.

224. Mr. Houck incurred economic damages from cancelled speaking

engagements and lost business opportunities due to these events, and from the need

to install a security system in the family home after the arrests.

225. Mr. Houck will also suffer future economic damages, as his

professional reputation has been severely tarnished by the FBI’s humiliating arrest

and the DOJ’s frivolous, malicious prosecution.

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226. Most tragically, Mr. Houck and his wife have lost three babies from

miscarriages due to the stress of the FBI’s conduct and resulting prosecution. The

stress of these events was so severe that the Houcks have been diagnosed with

infertility.

227. Mr. Houck has suffered severe emotional distress since the day

federal, state, and local agents raided his home without notice in the early hours of

September 23, 2022. The raid violated his personal liberty in his home, a place

where he felt responsible for his wife and his children as their family protector.

228. Officers purposely surprised and shocked him with guns drawn and

then humiliated him in front of his family. He was made to appear as a criminal to

his wife and children. More importantly, the core of his identity as a father and

family protector was violated in the most vivid way possible, seared into the

memory of Mr. Houck and his loved ones.

229. The FBI further degraded Mr. Houck during the booking period.

Despite his total cooperation, the officers forced him to walk in chains and

handcuffs to the U.S. Marshals Service. They used intimidation tactics throughout

the booking process. As Mr. Houck was forced to shuffle along in his chains, the

foot shackles dug into his ankles, leaving scrapes and cuts in his flesh.

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230. Officers placed Mr. Houck in a sterile, white room, still chained and

shackled. There was little to no communication with attorneys or his terrified

family for almost six hours.

231. Those hours waiting to speak to and comfort his family over the

phone were the most agonizing hours of Mr. Houck’s life. He still carries deep-

seated trauma from that memory.

232. To this day, the mere recollection of that time emotionally triggers

him.

233. He is especially tormented by the thought of the mental anguish his

family suffered while he was detained without any word from him.

234. As he sat in the cell, all he could hear was the cry of his six-year-old

son J.H. to the FBI agents, “Please don’t take him, he is my best friend,” and all he

could see were the terrified eyes of his nine-year-old daughter T.H. as she looked

into the face of an officer dressed in SWAT gear through the back window.

235. Mr. Houck also suffered extreme stress from the time of the arrest

until his acquittal four and half months later. He woke up every day in fear—fear

that his family was not safe inside their own home, fear that his children were not

safe even sleeping in their own beds, and fear that he may have to go to prison and

leave his wife and seven children to fend for themselves.

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236. Since his acquittal, the emotional stress of these events has not

ceased. Mr. Houck has suffered and continues to suffer from severe anxiety about

the future. He is occupied with persistent worries about his ability to protect his

family.

237. After the arrest, he was so worried about the safety of his family

members that he could not leave the home for even 15 to 30 minutes. His wife and

children were equally concerned about Mr. Houck leaving the house.

238. The family lived in a constant state of fear. Eventually they became

prisoners in their home. Even today whenever either Mr. or Mrs. Houck leave the

house, the children cling to them and express fears that their parents will not

return. After all, when Mr. Houck left after his arrest, Mrs. Houck and the children

had no idea when or if he would return.

239. The simple act of leaving the home, even for a short amount of time,

triggers that traumatic memory for the entire family.

240. Mr. Houck also must cope with and comfort a family that lives in

constant fear that someone will invade their home. To this day, panic ensues

whenever visitors or guests arrive unannounced on the property. Mr. Houck feels a

strong need to protect his family even from false threats, which has ultimately led

them to install a gate at the entrance of their property and security cameras to feel

more secure in their own home.

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241. The family’s involvement in the community and in religious activities

has also suffered, and they have withdrawn socially as a result of the arrest. The

family no longer attends as many prayer vigils as they used to because these events

are triggering for the children.

242. The family worries whenever they see police officers or police

vehicles and the Houcks no longer take the children on field trips to visit state

trooper barracks due to the trauma from the invasion of their home.

243. Mr. Houck has also suffered immensely in observing the effects that

trauma and stress stemming from the arrest and subsequent trial have had on his

children. Mr. Houck has spent many days consoling and crying with his wife and

children.

244. In the immediate aftermath of the arrest, all of the children suffered

from severe sleeping problems and had to sleep with Mr. Houck and his wife for at

least a month.

245. The children continue to suffer from sleeping problems and all of

them have some degree of sleep deprivation or nightmares.

246. Mr. Houck regularly wakes up to his children crying from nightmares

of the events, and his youngest son, A.H., now suffers from sleepwalking as a

result.

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247. All of the children also suffer from anxiety, loss of joy, and deep

sadness from this trauma, and they spend hours crying.

248. Mr. Houck finds it important to be strong for them; however, carrying

his own emotional burden alongside the grief and fear his wife and seven children

experience has taken an enormous toll on Mr. Houck. He has been forced to deal

not only with his own trauma but also with the trauma of everyone in his

household.

249. The publicity from these events has compounded the emotional

distress Mr. Houck and his family have experienced.

250. Mr. Houck and his wife have seen their dreams of having more

children dashed and have lost three children due to these events. The raid of their

home, the arrest, and the prosecution took such a toll on the mental and emotional

health of the entire family that the couple had three miscarriages. Doctors attribute

the loss of these babies to the stress of these events and have told the Houcks that

they are now infertile as a result.

251. Mr. and Mrs. Houck suffer immense grief and pain from these losses

of life and this diagnosis.

252. Mr. Houck also suffers from continual anxiety about his ability to

provide a living for his family with this scarlet letter on his chest. Even though he

did not go to prison, the damage of this prosecution on his professional prospects

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and reputation are irreversible. Many of his professional and personal relationships

have been forever ruined because individuals still believe the falsehoods spread by

the Government in its charging documents and press releases.

253. Mr. Houck also lost a significant amount of time doing his life’s work

that can never be regained due to the FBI’s actions. From the time he was arrested

until he was acquitted four and a half months later, he was prohibited from

standing vigil at any abortion clinic.

254. He previously devoted several hours a week to praying and

counseling patients outside the clinic. This activity was more than volunteer

work—he considered it his religious calling.

255. The FBI’s tortious actions stripped away his religious freedom to

stand vigil outside any clinic and carry out his vocation. This infringement on his

religious exercise, for any length of time, is irreparable.

256. Mr. Houck also suffered significant economic damage from these

events. This includes lost income from the time he was arrested on September 23,

2022, until he was acquitted on January 30, 2023, due to his time in jail, time spent

preparing for trial, and reputational damage from the publicly humiliating arrest

and malicious prosecution.

257. Mr. Houck has lost multiple business opportunities even after he was

acquitted on January 30, 2023. He was uninvited from speaking at various

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conferences and other events due to the arrest and prosecution. He has suffered lost

income from these speaking cancellations since the acquittal on January 30, 2023.

258. Mr. Houck expects to continue to suffer economic damages from lost

future speaking engagements that he would have obtained absent the arrest.

259. Mr. Houck has also lost other volunteer ministry opportunities that

would have led to compensable speaking engagements.

260. Likewise, the travel limitations he faced from the time of the arrest

until the end of trial significantly restricted his ability to obtain new donors and

form partnerships with potential sponsors. Thus, Mr. Houck has lost sources of

funding for his ministry that he would have otherwise obtained.

261. These negative impacts on Mr. Houck’s reputation were caused by

the malicious indictment, arrest, and prosecution, all of which the FBI publicized

in a press release that characterized Mr. Houck as perpetrating “violence” against a

72-year-old man “because” he was a volunteer.

262. The press release falsely described Mr. Houck as targeting an

individual based on his volunteer associations and committing a “federal crime”

punishable by up to “11 years in prison.”1

1
Ironically, the DOJ press release accused Mr. Houck of the exact conduct DOJ was engaging in
when the DOJ targeted him for arrest and prosecution, i.e., targeting Mr. Houck based on his
beliefs and his volunteer association with a crisis pregnancy center.

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263. These false characterizations were repeated in multiple media outlets

and were read by potentially millions of Mr. Houck’s fellow citizens.

264. Mr. Houck also incurred significant costs from this malicious arrest

and prosecution.

a. Injuries to Mrs. Houck and the Houck children

265. As a direct and proximate result of the FBI’s investigation and

invasion of Mr. and Mrs. Houck’s home, as well as the FBI’s false arrest of Mr.

Houck and the resulting imprisonment and malicious prosecution of him, Mrs.

Houck suffered, and continues to suffer, substantial damages.

266. Those damages include invasion of privacy, substantial emotional

distress and harm with physical manifestations, and post-traumatic stress.

267. Mrs. Houck carried her children’s immense emotional trauma and

physical manifestations of stress while her husband was away during his

imprisonment and prosecution.

268. Mrs. Houck has suffered severe emotional distress and physical

manifestations of stress and post-traumatic stress since the day FBI agents raided

her home without notice in the early hours of September 23, 2022.

269. At the time of the raid, she was dressing and preparing to wake her

children for breakfast. When the FBI surrounded and stormed her house with their

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guns drawn in the early hours of the morning, they accosted her personal liberty in

her home, a place where she thought she and her children were safe.

270. Mrs. Houck saw officers swarm her husband with their guns pointed

at him, and she rushed down the stairs to stand by his side at the end of several gun

barrels. She heard her children crying and knew there was nothing she could do to

protect them. Then officers led her husband away at gun point and in handcuffs to

the car.

271. Mrs. Houck had no idea when or if he would return. The rest of the

day was agony as she waited to hear from Mr. Houck. And while she shouldered

her own fears and questions, she had to stay strong for her seven children and care

for them.

272. Even after Mr. Houck returned home, the emotional trauma of that

day continued to haunt Mrs. Houck; and the stress of the prosecution and the

following months only made matters worse.

273. Mrs. Houck has suffered from depression since the arrest. She

struggles to sleep, and she has continual nightmares. She takes sleep medication

just to get a few hours of sleep.

274. Mrs. Houck spends hours crying and is often teary-eyed.

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275. She has continual, racing thoughts that someone is going to come to

her house while she is sleeping. She has paranoia that people are following and

watching her family and that the house is bugged.

276. The public media attention has only made her condition worse. She

now fears that since people know where she lives, they could bring additional harm

to her and her family. With her mind always racing and occupied by these fears,

she struggles to focus on daily tasks. This leads to more stress and a sense of

feeling overwhelmed.

277. The stress of these events has taken an immense toll on her body–

such a significant toll that she had three miscarriages from stress. Doctors have

now diagnosed her with infertility. Alongside the trauma, paranoia, and anxiety she

has suffered, she now carries the grief of losing three children and the pain of

infertility.

278. Many things can trigger the emotional trauma of these events for her.

When Mr. Houck first returned after his arrest, Mrs. Houck struggled to cope every

time he left the house. Even trips of 15 to 30 minutes took an immense toll on her.

After all, when he was arrested, she did not know when or if he would return. She

still struggles with these fears.

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279. Unannounced guests or visitors also trigger an emotional response.

She had a panic attack when a surprise visitor showed up at the home even though

the person did not pose an actual threat.

280. Mrs. Houck lives in a constant state of fear that someone will invade

their home. This anxiety led the family to install a gate at the entrance of their

property and security cameras to feel more secure.

281. Mrs. Houck’s involvement in the community and in religious

activities has also suffered, and she has withdrawn socially as a result of the FBI

and DOJ’s actions.

282. The family no longer attends as many prayer vigils as they used to

because these events are triggering for the children.

283. The family worries whenever they see police officers or vehicles.

And the parents no longer take the children on field trips to visit state trooper

barracks due to the trauma from the invasion of their home.

284. Mrs. Houck has also shouldered the emotional distress of caring for

her seven children and their individual needs as they each process their own trauma

from these events.

285. The children continually come to her crying and suffering from

nightmares. The children slept in bed with her and her husband for the first month

after the arrest, and they continue to ask to sleep in their parents’ bed. The children

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are easily triggered whenever the situation is brought up or unannounced guests

arrive at the property and Mrs. Houck spends a significant amount of time

counseling and comforting them.

286. Based upon the foregoing allegations, Mrs. Houck now seeks to

recover monetary damages due to the intentional infliction of emotional distress

and assault committed by the DOJ and FBI.

287. Mrs. Houck also brings intentional infliction of emotional distress

claims on behalf of her children, who have suffered individual physical and

emotional damage as a result of these events.

i. Injuries to M.H.

288. The oldest child, M.H, took on significant responsibilities in the

household after his father’s arrest and during the prosecution.

289. He shouldered the emotional burdens of his mother and his younger

siblings while trying to carry his own distress.

290. M.H. suffers immense anxiety, which is only compounded by his

continual sleep deprivation and nightmares from the stress. He has to take sleep

medication to get a few hours of sleep.

291. M.H. is triggered any time one of his parents tries to leave the house

for fear that they will not return.

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292. He is also emotionally triggered any time unannounced guests show

up at the house. Encounters with police officers and vehicles also spawn worry.

His parents no longer take him to prayer vigils or certain field trips involving state

troopers due to his trauma.

293. For the emotional distress, medication, and physical impact of these

events on M.H.’s sleep, health, and well-being, the Houcks seek to recover

monetary damages.

ii. Injuries to A.M.H.

294. The eldest daughter, A.M.H., is only eleven years old but has taken

on an immense amount of stress in caring for her younger siblings in the aftermath

of these events.

295. She suffers from severe sleep deprivation and nightmares. She has to

take sleep medication to get a few hours of sleep.

296. For the first month after the arrest, she could only fall asleep in her

parents’ room.

297. She is terrified any time one of her parents tries to leave the house for

fear that they will not return.

298. She is also emotionally triggered any time unannounced guests show

up at the house.

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299. Encounters with police officers and vehicles also spawn worry. Her

parents no longer take her to prayer vigils or certain field trips involving state

troopers due to her trauma.

300. A once happy eleven-year-old girl, she now carries a great deal of

sadness from the trauma of these events.

301. For the emotional distress, medication, and physical impact of these

events on A.M.H.’s sleep, health, and well-being, the Houcks seek to recover

monetary damages.

iii. Injuries to K.H.

302. K.H. is only ten years old and yet has experienced a severe loss of joy

and deep sadness at her young age due to these events.

303. She suffers from severe anxiety and worry, and she still carries deep-

seated fears that she will lose her father.

304. She continues to suffer from severe sleep deprivation and nightmares

due to these events. She has to take sleep medication to get a few hours of sleep.

305. For the first month after the arrest, she could only fall asleep in her

parents’ room.

306. She is terrified any time one of her parents tries to leave the house for

fear that they will not return.

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307. She is also emotionally triggered any time unannounced guests show

up at the house.

308. Encounters with police officers and vehicles also spawn worry.

309. Her parents no longer take her to prayer vigils or certain field trips

involving state troopers due to her trauma.

310. For the emotional distress and physical impact of these events on

K.H.’s sleep, health, and well-being, the Houcks seek to recover monetary

damages.

iv. Injuries to T.H.

311. T.H. is the most deeply traumatized of the children. Her preexisting

struggles with anxiety and worry have immensely intensified in the aftermath of

these events.

312. At the time of the raid, when she was only nine years old, she

witnessed SWAT personnel staring her down at the back door. This memory

continues to haunt her to this day.

313. She suffers from tremendous nightmares, never-ending poor sleep,

and sleep deprivation due to the overwhelming stress of this situation.

314. The trauma of the raid as well as the stress of the trial have taken an

immense emotional toll on her.

315. She has to take sleep medication to get a few hours of sleep.

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316. For the first month after the arrest, she could only fall asleep in her

parents’ room.

317. She is terrified any time one of her parents tries to leave the house for

fear that they will not return.

318. She is also emotionally triggered any time unannounced guests show

up at the house.

319. Encounters with police officers and vehicles also spawn worry.

320. Her parents no longer take her to prayer vigils or certain field trips

involving state troopers due to her trauma.

321. For the emotional distress and physical impact of these events on

T.H.’s sleep, health, and well-being, the Houcks seek to recover monetary

damages.

v. Injuries to J.H.

322. J.H. was six years old at the time he saw his father taken away at

gunpoint.

323. He cried the entire time and yelled to the FBI, “Please don’t take him

he is my best friend.”

324. To this day, any time someone brings up the raid or tells the story, he

starts to cry as if he is reliving the day all over again.

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325. J.H. consistently worries that he will lose his father or mother. And

his sleep quality is just as bad as his siblings’. He has to take sleep medication, and

for the first month after the arrest, he could only fall asleep in his parents’ room.

326. He is also emotionally triggered any time unannounced guests show

up at the house.

327. Encounters with police officers and vehicles also spawn worry.

328. His parents no longer take him to prayer vigils or certain field trips

involving state troopers due to this trauma.

329. For the emotional distress and physical impact of these events on

J.H.’s sleep, health, and well-being, the Houcks seek to recover monetary damages.

vi. Injuries to A.H.

330. A.H. is a four-year-old who was deeply impacted and traumatized by

the raid and subsequent prosecution.

331. While he cannot express in words the amount of worry and trauma he

has suffered, he often shouts and cries for his parents.

332. He has also started sleepwalking as a result of the stress.

333. For the emotional distress and physical impact of these events on

A.H.’s sleep, health, and well-being, the Houcks seek to recover monetary

damages.

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vii. Injuries to I.H.

334. I.H. is a two-year-old who also carries deep-seated trauma from these

events. Like her older siblings, she suffers from poor sleep and continual worry.

For the emotional distress and physical impact of these events on I.H.’s sleep,

health, and well-being, the Houcks seek to recover monetary damages.

COUNT I
Plaintiff Mark Houck v. Defendant United States of America
Federal Tort Claims Act – Malicious Prosecution

335. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

336. Through their actions, the FBI’s investigative or law enforcement

officers, including but not limited to Agent Christopher Jackson, initiated the

prosecution of Mr. Houck without probable cause and with malice.

337. Upon information and belief, from October 15, 2021, when the FBI’s

investigative or law enforcement officers received the video showing the

interaction between Mr. Love and Mr. Houck, to January 30, 2023, when Mr.

Houck was acquitted of all charges, the FBI’s investigative and law enforcement

officers committed tortious conduct in their investigation and communications with

prosecuting authorities.

338. FBI officers initiated a criminal proceeding when Agent Jackson

intentionally, knowingly, and/or recklessly made or caused false statements and

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representations and material omissions of facts in his reports, affidavits, and other

communications with federal prosecutors.

339. The criminal proceeding was initiated without probable cause. An

indictment procured by fraud, perjury or other corrupt means, or when the agent

knowingly and deliberately, or with a reckless disregard for the truth, makes

materially false statements or omissions in the warrant application cannot serve as

a basis for probable cause.

340. The FBI’s actions via its agents spanning from October 15, 2021, to

January 30, 2023, resulted in the tort of malicious prosecution under the laws of

the Commonwealth of Pennsylvania and violated Mr. Houck’s rights guaranteed

under the Fourth Amendment of the United States Constitution to be free from

malicious prosecution.

341. Under the Federal Tort Claim Act, Defendant United States of

America is liable for these actions.

COUNT II
Plaintiff Mark Houck v. Defendant United States of America
Federal Tort Claims Act – Retaliatory Prosecution

342. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

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343. Through their actions, the FBI’s investigative or law enforcement

officers committed tortious conduct in their investigation and communications with

prosecuting attorneys.

344. Upon information and belief, the FBI’s officers initiated a criminal

proceeding without probable cause when Agent Jackson intentionally, knowingly,

and/or recklessly made or caused false statements and representations and material

omission of facts in his reports, affidavits, and other communications with federal

prosecutors based on impermissible motives including retaliation based on Mr.

Houck’s First Amendment-protected activities of standing vigil outside of the

Planned Parenthood.

345. Upon information and belief, the purpose of the prosecution was to

punish and chill speech and religious exercise by Mr. Houck and other pro-life

advocates and volunteers for pro-life clinics, which senior leadership at the

Department of Justice viewed as “predatory,” unworthy of FACE Act and

constitutional protection, and indeed, necessary to punish.

346. The FBI’s actions via its agents spanning from October 15, 2021, to

January 30, 2023, resulted in the tort of retaliatory prosecution under Pennsylvania

law and further violated Mr. Houck’s rights to be free from retaliation based on his

rights under the First Amendment of the U.S. Constitution.

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347. Under the Federal Tort Claims Act, Defendant United States of

America is liable for these actions.

COUNT III
Plaintiff Mark Houck v. Defendant United States of America
Federal Tort Claims Act – Abuse of Process

348. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

349. Upon information and belief, from October 15, 2021, to January 30,

2023, the FBI’s investigative and law enforcement officers committed tortious

conduct in their investigation and communications with prosecuting authorities

when they used legal process against Mark Houck for an impermissible purpose.

350. Upon information and belief, the FBI’s officers improperly used a

federal indictment under the FACE Act for the impermissible purpose of harassing

and causing injury to Mr. Houck.

351. Upon information and belief, the FBI’s agents were aware of previous

statements from the DOJ’s Kristen Clarke calling pro-life pregnancy crisis centers

“fake clinics” and “predatory.” Ms. Clarke and Ms. Gupta’s public statements

directly contradicted the statements on the Civil Rights Division website and sent a

clear message to all DOJ personnel about what the DOJ’s real policy was: use the

FACE Act against pro-life organizations.

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352. Upon information and belief, FBI personnel, including Special Agent

Jackson, were all aware of the discriminatory policies and practices surrounding

the enforcement of the FACE Act, and that the DOJ was targeting Mr. Houck to

intimidate and disrupt the activities of pro-life counselors and pregnancy crisis

centers.

353. The FBI’s decision to improperly investigate and seek a federal

indictment under the FACE Act against Mr. Houck was to discourage Mr. Houck

from continuing the exercise his First Amendment right to engage in speech and

free exercise of his religion through prayer and work as a pro-life counselor and

escort for a crisis pregnancy center.

354. The actions of the FBI’s officers resulted in the tort of abuse of

process under Pennsylvania law and violated Mr. Houck’s rights guaranteed under

the First Amendment of the U.S. Constitution.

355. Under the Federal Tort Claims Act, Defendant United States of

America is liable for these actions.

Count IV
Plaintiff Mark Houck v. Defendant United States of America
Federal Tort Claims Act – False Arrest

356. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

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357. On September 23, 2023, the FBI officers, including Agent Jackson

and other unnamed agents, falsely arrested Mr. Houck without probable cause.

358. Upon information and belief, FBI investigative agents committed

tortious conduct in their investigation and communication with prosecuting

attorneys.

359. Upon information and belief, the FBI’s officers intentionally,

knowingly, and/or recklessly made or caused false statements and representations

and material omissions of facts in its reports, affidavits, and other communications

with federal prosecutors.

360. These actions led to the false arrest of Mr. Houck because no probable

cause existed to support the indictment or subsequent warrant.

361. The actions of the FBI’s officers resulted in the tort of false arrest

under Pennsylvania law and violated Mr. Houck’s right to be free from

unreasonable and unlawful seizure under the Fourth Amendment of the U.S.

Constitution.

362. Under the Federal Tort Claims Act, Defendant United States of

America is liable for these actions.

Count V
All Plaintiffs v. Defendant United States of America
Federal Tort Claims Act – Assault

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363. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

364. The FBI, through its agents’ actions on September 23, 2022, in the

arrest of Mr. Houck, committed the common law tort of assault when officers used

unreasonable force under the circumstances to effectuate the arrest of Mr. Houck.

365. Moreover, under the Fourth Amendment, Plaintiffs have

constitutional rights to be “secure in [their] person[s], houses, papers, and effects,

against unreasonable searches and seizures.”

366. Defendant deprived Plaintiffs of rights, privileges or immunities

secured by the Constitution and laws of the United States, by using excessive force

to arrest Mr. Houck on September 23, 2022.

367. FBI agents intentionally attempted to harm Plaintiffs in their show of

excessive and unreasonable force in Mr. Houck’s arrest. FBI agents participated in

Mr. Houck’s arrest and were present at his home on September 23, 2022. FBI

agents had guns drawn and pointed at Plaintiffs during Mr. Houck’s arrest.

368. Upon information and belief, FBI agents conspired and agreed before

Mr. Houck’s arrest to draw their weapons and aim them at Plaintiffs.

369. Upon information and belief, based on what the FBI likely knew

about Plaintiffs, the FBI knew or should have known that it would constitute

excessive force to draw their weapons and aim them at Plaintiffs.

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370. The FBI knew or should have known that Mr. Houck had been

charged with a non-violent crime.

371. The FBI knew or should have known that Mr. Houck, Mrs. Houck,

and their children did not pose an immediate threat to their safety or the safety of

others during Mr. Houck’s arrest.

372. The FBI knew or should have known that Mr. Houck, Mrs. Houck,

and their children had no criminal history or history of violence and had never

threatened law enforcement officers.

373. The FBI knew or should have known that Mr. Houck, his wife, and

his children did not own a firearm.

374. The FBI knew or should have known that Mr. Houck was willing to

turn himself in if he was indicted and that Mr. Houck’s attorney had offered to

accept a summons on Mr. Houck’s behalf in the event of an indictment.

375. The force used in the seizure of Mr. Houck was unreasonable.

376. Mr. Houck did not pose an immediate threat to the safety of the

officers or others. Mr. Houck did not resist arrest or attempt to evade arrest by

flight.

377. Mr. Houck has no history of being violent or dangerous.

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378. Mr. Houck was not armed, nor was anyone living with him armed.

Mr. Houck posed no threat to the FBI’s exercise of authority or performance of the

FBI’s duty.

379. The FBI’s actions on September 23, 2022, resulted in the tort of

assault under Pennsylvania law and violated Mr. Houck’s rights to be free from

excessive force under the Fourth Amendment of the U.S. Constitution.

380. Under the Federal Tort Claims Act, Defendant United States of

America is liable for these actions.

Count VI
Plaintiffs Ryan-Marie Houck, M.H., A.M.H., K.H., T.H., J.H., A.H., and I.H.
v. Defendant United States of America
Federal Tort Claims Act – Intentional Infliction of Emotional Distress

381. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

382. The FBI, through its agent’s actions on September 23, 2022,

committed the common law tort of intentional infliction of emotional distress

against Mrs. Houck and the Houck children when officers participated in extreme

and outrageous conduct during the arrest of Mr. Houck.

383. The FBI agents aimed loaded weapons at Mrs. Houck and the Houck

children during the arrest of Mr. Houck.

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384. The FBI agents continued to aim their weapons at Mrs. Houck and the

children even after Mr. Houck voluntarily stepped outside of his home after

warning the officers to “stay calm” because he had “seven babies inside.”

385. The FBI agents intentionally intended to harm the entire Houck family

with their actions that were wholly unnecessary based on what the FBI likely

knew, or should have known, about the Houck family.

386. The Houck family had no history of owning any weapons, no criminal

history, and no history of violence, and they did not pose an immediate threat to

the safety of others during the arrest.

387. The FBI agents knew or should have known that Mrs. Houck and her

children did not pose an immediate threat to their safety or the safety of others

during Mr. Houck’s arrest.

388. The FBI agents knew or should have known that Mrs. Houck and her

children did not have a criminal history or history of violence and had never

threatened law enforcement officers.

389. The FBI’s actions through their agents were outrageous and utterly

intolerable in a civilized community.

390. These actions have caused severe emotional distress to Mrs. Houck

and each of the Houck children.

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391. The FBI’s actions on September 23, 2022, resulted in the tort of

intentional infliction of emotional distress under Pennsylvania law against Mrs.

Houck and each of the Houck children. These actions also violated Mrs. Houck

and each of the Houck children’s rights to be free from excessive force under the

Fourth Amendment of the U.S. Constitution.

392. Under the Federal Tort Claims Act, Defendant United States of

America is liable for these actions.

COUNT VII
Plaintiff Mark Houck v. Defendants Michael Rogers, Juan Barrios, Stephen
Caputo, Brian Calabrese, Steve Johnson, Zack Brosius, and John Doe
Defendants
42 U.S.C. § 1983 -- Excessive Force in Violation of the Fourth Amendment

393. All preceding paragraphs are repleaded, realleged, and incorporated

by reference herein.

394. Under the Fourth Amendment, Mr. Houck has the constitutional right

to be “secure in his person, houses, papers, and effects, against unreasonable

searches and seizures.”

395. Defendants, acting individually and in concert, deprived Mr. Houck of

rights, privileges or immunities secured by the Constitution and laws by using

excessive force to arrest him on September 23, 2022.

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396. The Fourth Amendment right to be free of excessive force in an arrest

was clearly established at the time of Mr. Houck’s arrest. See, e.g., Couden v.

Duffy, 446 F.3d 483, 497 (3d Cir. 2006).

397. The right to be free of excessive force is the right to be free of force

that is objectively unreasonable from the perspective of a reasonable officer.

398. The seizure of Mr. Houck occurred when he was arrested on

September 23, 2022.

399. The seizure of Mr. Houck was objectively unreasonable.

400. Mr. Houck had not been charged with a severe crime at the time of his

arrest. Mr. Houck has never been charged with a severe crime.

401. Mr. Houck’s attorney had offered to accept a summons on Mr.

Houck’s behalf in the event of an indictment.

402. No law enforcement or governmental agencies made any effort to

communicate with Mr. Houck or his counsel prior to his arrest and after the target

letter.

403. Mr. Houck did not pose an immediate threat to the safety of the

officers or others.

404. Mr. Houck did not resist arrest or attempt to evade arrest by flight.

405. Mr. Houck has no history of being violent or dangerous.

406. Mr. Houck was not armed.

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407. No one living with Mr. Houck was armed.

408. Mr. Houck posed no flight risk, danger to himself, or to the

community as evidenced by his release on his own recognizance.

409. Mr. Houck’s wife and seven children lived with Mr. Houck and were

present during his arrest.

410. Upon information and belief, Defendants pointed guns at Mr. Houck

during his arrest, as they had agreed to do before arriving to arrest him.

411. Mr. Houck’s wife and children were behind Mr. Houck at the time of

his arrest. Upon information and belief, Mrs. Houck and at least some of Mr.

Houck’s children were in the line of fire from Defendants’ guns.

412. Defendants acted in their official capacities and under color of state

law at all times during Mr. Houck’s arrest on September 23, 2022, including at all

times when they deprived Mr. Houck of rights, privileges, or immunities secured

by the Constitution and laws.

413. Defendants were motivated by evil motive or intent, or with reckless

or callous indifference to the federally protected rights of Mr. Houck. No

reasonable officer would have believed that this conduct was lawful.

414. As a direct and proximate result of Defendants’ excessive display and

exercise of force, Mr. Houck has suffered compensable injury in the form of fear

and distress, and pain and suffering.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs Mark Houck, Ryan-Marie Houck, M.H., A.M.H,

K.H., T.H., J.H., A.H., and I.H respectfully pray that this Court grant them the

following relief:

A. Order a jury trial on all issues so triable;

B. Award Plaintiffs compensatory damages in excess of $150,000 as to

Defendant United States;

C. Award Plaintiff Mark Houck compensatory damages in excess of

$150,000 pursuant to 42 U.S.C. § 1983 as to Defendants Michael

Rogers, Juan Barrios, Stephen Caputo, Brian Calabrese, Steve

Johnson, Zack Brosius, and unnamed John Doe Defendants.

D. Award Plaintiff Mark Houck punitive damages pursuant to 42 U.S.C.

§ 1983 as to Defendants Michael Rogers, Juan Barrios, Stephen

Caputo, Brian Calabrese, Steve Johnson, Zack Brosius, and unnamed

John Doe Defendants;

E. Award Plaintiffs reasonable costs, expenses, and reasonable attorneys’

fees pursuant to 42 U.S.C. § 1988 and other applicable laws; and

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F. Grant such other and further relief as the Court deems just and proper.

Dated: May 20, 2024 Respectfully submitted,

40 DAYS FOR LIFE GRAVES GARRETT GREIM LLC

/s/ Matthew Britton /s/ Todd P. Graves

Matthew Britton, Va. Bar No. 39160* Todd P. Graves, Mo. Bar No. 41319*
4112 East 29th Street Edward D. Greim, Mo. Bar No. 54034*
Bryan, Texas 77802 Katherine Graves, Mo. Bar No. 74671*
Tel: (888) 543-3316 1100 Main Street
matt.britton@40daysforlife.com Suite 2700
Kansas City, Missouri 64105
* pro hac vice forthcoming Tel: (816) 256-3181
Fax: (816) 256-5958
BOCHETTO & LENTZ, P.C. tgraves@gravesgarrett.com
edgreim@gravesgarrett.com
/s/ George Bochetto
George Bochetto, PA Bar No. 27783 * pro hac vice forthcoming
1524 Locust St,
Philadelphia, PA 19102 JAMES OTIS LAW GROUP, LLC
Tel: (215) 735-3900
gbochetto@bochettoandlentz.com /s/ Justin D. Smith
Justin D. Smith, Mo. Bar No. 63253*
13321 North Outer Forty Road, Ste. 300
St. Louis, Missouri 63017
(816) 678-2103
Justin.Smith@james-otis.com

* pro hac vice forthcoming

77
 UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

DESIGNATION FORM
(to be used by counsel or pro se plaintiff to indicate the category of the case for the purpose of assignment to the appropriate calendar)

Address of Plaintiff: ______________________________________________________________________________________________

Address of Defendant: ____________________________________________________________________________________________

Place of Accident, Incident or Transaction: ___________________________________________________________________________

RELATED CASE, IF ANY:

Case Number: ______________________________ Judge: _________________________________ Date Terminated: ______________________

Civil cases are deemed related when Yes is answered to any of the following questions:

1. Is this case related to property included in an earlier numbered suit pending or within one year Yes No
previously terminated action in this court?

2. Does this case involve the same issue of fact or grow out of the same transaction as a prior suit Yes No
pending or within one year previously terminated action in this court?

3. Does this case involve the validity or infringement of a patent already in suit or any earlier Yes No
numbered case pending or within one year previously terminated action of this court?

4. Is this case a second or successive habeas corpus, social security appeal, or pro se civil rights Yes No
case filed by the same individual?

I certify that, to my knowledge, the within case is / is not related to any case now pending or within one year previously terminated action in
this court except as noted above.

DATE: __________________________________ __________________________________________ ___________________________________

Attorney-at-Law / Pro Se Plaintiff Attorney I.D. # (if applicable)

CIVIL:

A. Federal Question Cases: B. Diversity Jurisdiction Cases:

1. Indemnity Contract, Marine Contract, and All Other Contracts 1. Insurance Contract and Other Contracts
2. FELA 2. Airplane Personal Injury
3. Jones Act-Personal Injury 3. Assault, Defamation
4. Antitrust 4. Marine Personal Injury
5. Patent 5. Motor Vehicle Personal Injury
6. Labor-Management Relations 6. Other Personal Injury (Please specify): _____________________
7. Civil Rights 7. Products Liability
8. Habeas Corpus 8. Products Liability – Asbestos
9. Securities Act(s) Cases 9. All other Diversity Cases
10. Social Security Review Cases (Please specify): ____________________________________________
11. All other Federal Question Cases
(Please specify): ____________________________________________

ARBITRATION CERTIFICATION
(

I, ____________________________________________, counsel of record or pro se plaintiff, do hereby certify:

Pursuant to Local Civil Rule 53.2, § 3(c) (2), that to the best of my knowledge and belief, the damages recoverable in this civil action case
exceed the sum of $150,000.00 exclusive of interest and costs:

Relief other than monetary damages is sought.

DATE: __________________________________ __________________________________________ ___________________________________

Attorney-at-Law / Pro Se Plaintiff Attorney I.D. # (if applicable)

NOTE: A trial de novo will be a trial by jury only if there has been compliance with F.R.C.P. 38.

Civ. 609 ( /2018)