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UNITED
STATES DISTRICT COURT
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SUMMARY OF ALLEGATIONS JURY TRIAL REQUESTED BACKGROUND 1. Aisha Goodison, hereinafter “Aisha,” “Aisha Goodison,” “Plaintiff” or “the Plaintiff”, and at all times material hereto, is a resident of Miami, Florida. Aisha is a singer/writer/producer/director and owner of the independent film, record and literary company Sonustar. 2. Aisha is an innovative, cutting edge, multi-talented artist with a God given voice that covers several octaves, performing styles of music from Gospel to R&B, Rap to Rock and Jazz to Opera on her eponymous self-titled debut album. This feat was a music industry first. Aisha is also a multi-instrumentalist. 3. Her debut single "Contemporary Girl" has an original and rap remix version, where she performs in several styles of music on both versions of the song - another industry first. She also produces, engineers and masters her own music as featured on her debut album “Aisha” and on "Aisha The Remixes" - another industry first. Aisha wrote and directed her debut music videos. She is also an excellent cinematographer, photographer and editor. 4. Aisha was a child prodigy with an extraordinary God given gift for writing and music comprehension. She began writing poems at age 4, music video treatments (scripts) at age 14, songs at age 15 and movie scripts at age 16. She has a high IQ with a great aptitude for problem solving and analysis. She is a brilliant orator with a great gift for gab. 5. Aisha is the owner of a very valuable, wholly owned, multi-million dollar valued copyrighted catalog containing over 6,000 songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatments and 3 dozen photo treatments. Aisha has been actively authoring this catalogue since childhood. It has become very valuable and grown tremendously in content, as she has eschewed partying in favor of writing literary, music and film works, which she has spent 2/3 of her 28 years authoring. 6. This very valuable literary catalog has been copyrighted for years with additional material continually being sent to the copyright office. United Nations Law, Jamaican Law and United States Federal Copyright Law protect said catalog. Aisha holds dual citizenship in both countries, as she was born in Jamaica and raised in Miami, Florida from the time she was a little girl. 7. Aisha is known to people all over the world, as attested by her 6.2 million and counting web site hits from countries like America, Jamaica, England, France, Spain, Ireland, Italy, Israel, Sweden, Germany, Australia, New Zealand, Hungary, Iraq, Belgium, Switzerland, The Netherlands, Brazil, Portugal, Canada, Japan, China, Russia and many other countries. 8. Her web site patrons include fans, MTV/Viacom, renown book publishing companies in New York, Eaton College in England, numerous universities in America and Europe, government agencies from around the world, numerous international stars, over three dozen international newspapers and magazines, music managers, record labels, several international law firms and geological institutes, who frequent her site to listen to her music, read her innovative writings and commentary in her Sound Off Column, which features a variety of topics. She is listed in many worldwide music and writer directories, which offer biographical information on her and links to her web site. 9. Aisha is a very upright character that leads a relatively quiet life in Miami. Many will attest to this under oath and that of her great character and charitable acts. She has no criminal record or history of questionable behavior. She eschews alcohol and drugs in accordance with her faith, Christianity. She has devoted her life to authoring Judeo-Christian inspired music and scripts in tribute to her Faith. FAMILY BACKGROUND10. Aisha hails from a renowned and very accomplished arts family. Her family is Jamaica’s celebrated, premier arts family. Her father, Vaughn, is a Justice of the Peace (a British Commonwealth Magistrate) and holds an Order of Distinction, the Commonwealth equivalent of a British OBE. He is also a multiple award winning radio disc jockey, internationally renowned musicologist, who has been featured in numerous documentaries on music. Journalists travel far and wide from places like America, Britain, France and Germany to interview him due to his vast knowledge of music - from mainstream artists to lesser-known artists that many people don’t know a lot about. 11. He is one of the most sought after musicologists in the world; having done numerous print and television interviews for many years with respected publications and news outlets in America, Europe and the Caribbean. His vast knowledge of music is widely known and referred to in and by numerous international periodicals, entertainment industry organizations and entertainers. His expertise has been used to settle copyright infringement music cases in Britain and the Caribbean. He is also a former international soccer player and one of the youngest to every play worldwide for a national team. 12. Aisha’s aunts are also writers. Her aunt, the Right Honourable Barbara Gloudon, is a well known, loved and respected professor, award winning radio personality, humorist, international playwright and head of the United Nation’s UNESCO branch in Jamaica. She frequently lectures in America, France and the Caribbean. She heads the Little Theatre and has written and produced plays that have been viewed worldwide. When out in Jamaica, America and Paris, she is often approached by fans of her work that congratulate her on her success. 13. Her aunt, Professor Lorna Goodison is one of the most famous, well written about and accomplished poets in the world. The award winning Poet Laureate is author of several critically acclaimed books available in bookstores all over the world. She has penned the successful, critically acclaimed books “Controlling The Silver (Illinois Poetry Series),” “Fool-Fool Rose is Leaving Labour-in-Vain Savannah,” “Selected Poems by Lorna Goodison,” “Turn Thanks,” “Guinea Woman,” “I Am Becoming My Mother,” “To Us, All Flowers Are Roses (Illinois Poetry),” “Kingston: A Cultural and Literary History,” “Baby Mother and the King of Swords,” “Cities of the Imagination” by Lorna Goodison (Foreword) David Howard, “Heartease” and “Tamarind Season.” 14. Her works and life are written about in the books “Contemporary Authors: Biography - Goodison, Lorna,” "Identity in the Poetry of Grace Nichols and Lorna Goodison (Salzburg Studies in English Literature)” by Gudrun Webhofer and “Lorna Goodison. Guinea Woman: New and Selected Poems” (World Literature Today) by Jim Hannan. 15. She is the recipient of dozens of international literary awards including a gold star from the highly esteemed Booklist magazine. Nobel Prize recipient Derek Walcott praised her books. Her works were also compiled with Maya Angelou’s in the book “Quartet of Stories” by Maya Angelou, et al. She maintains a professorship in the United States and Canada at two prestigious universities. 16. Several of Aisha’s cousins are also writers. One is an associate producer for a world famous American investigative journalism news program that airs weekly on one of the 4 major networks. The other is a journalist for a well-known newspaper. CAUSE OF ACTION17. As illustrated in the preceding paragraphs, writing is a tradition in the Goodison family and has been for over 120 years, as Aisha’s grandmother was also a lyricist. The Goodison family has excelled in the literature and entertainment worlds and are Jamaica’s definitive arts family - a tradition Aisha has prolifically continued via her released works and private unreleased copyrighted catalog mentioned above. 18. However, that 120 year tradition is being perversely and criminally disrupted and destroyed by the dishonorable, disgraceful, nefarious Madonna (Madonna aka Madonna Ciccone aka Madonna Ritchie). The infringements began with Madonna willfully stealing Aisha’s original, wholly authored, copyrighted music, lyrics, pictures, Sound Off Column articles and unique features from Aisha’s widely read web site that has been viewed millions of times by internet users all over the world, who began bombarding Aisha with emails and queries asking if she’d notice how Madonna was stealing her work for her own projects. 19. Defendant Madonna has publicly admitted to getting ideas from the internet, which is where a lot of Aisha's released work has been located since 2001 with Madonna stealing Aisha’s work from her site in 2003 for her ill received, critically panned “American Life” CD. This telling admission was made on the British television program Blue Peter SEE EXHIBIT 2. Madonna has been sued and slammed numerous times by several international artists for this very same misconduct in deliberately stealing their copyrighted works and morphing into them for her so called reinventions, a violation of the Right to Privacy and the Right to Publicity. 20. However, what started with Madonna flagrantly stealing Aisha’s copyrighted music, lyrics, pictures, Sound Off Column articles and unique features in clear view of Aisha’s site visitors, criminally progressed to something far worse and far more sinister - invasion of privacy, illegal surveillance, wiretapping, hacking, corporate theft, fraud, harassment, assault and stalking, commissioned by Madonna to steal Aisha’s multi-million dollar copyrighted literary catalog referred to above, that she Madonna, has been criminally using and selling off items from to partners, coworkers, collaborators and colleagues at Disney, Warner Bros and using at her own Maverick Records and Films, in boldface, arrogant, mocking, brazen violations of numerous Jamaican, United States and United Nations laws, punishable by several years in prison per count. Preliminary diagnostic counter-surveillance tests on Aisha’s home revealed criminal wiretapping and unusually high levels of RF, which are indicative of the unlawful filming and recording of an unwitting victim of illegal, invasive surveillance. Furthermore, Aisha has been the victim of textbook examples of harassment techniques used by privacy invaders trying to shake potential litigation and criminal charges for their illegal conduct, as listed in detail further in this Complaint. 21. When Aisha publicly wrote on her widely read site that she was going to sue Madonna for constantly stealing her released work, this criminal wave of harassment and invasion of privacy ensued that matches a similar pattern her attorney, Defendant Bertram Fields and his private investigator, Anthony Pellicano have been publicly accused of by both famous and non-famous entertainment industry professionals, as detailed further in this Complaint. 22. This criminal campaign of harassment commissioned by Madonna progressed to the assault of the young singer this summer in Miami on the same street as the District Court House in downtown, where Aisha was headed for an early morning meeting. This assault was commissioned by Madonna to discourage Aisha from going to the police when she realized the young singer figured out she had her under illegal surveillance and to dissuade her from taking legal action against her, the often sued Madonna, for criminally stealing her work and criminally invading her privacy. Madonna was hit with a slew of lawsuits over the last few months for her gross, unlawful, nefarious misconduct and fraud regarding several unrelated people and companies. 23. Over the summer, each time Aisha got near a court house in Miami, she was approached and harassed by people clearly affiliated with Madonna, who would come up to her angry and repeat verbatim to her, things she’d said over the phone and in the privacy of her own home. 24. It must be noted, Madonna’s lawyer, the notorious Bert Fields, has been at the center of an FBI probe for his private investigator criminally wiretapping the phones of and harassing his celebrity clients legal opponents. His celebrity clients who have been publicly accused of invasion of privacy are Kabbalahist Michael Jackson, Scientologist Tom Cruise, The Church Of Scientology, The Kaballah Center and now Kabbalah Center front woman Madonna. 25. The nefarious Madonna, like the people who she commissioned to harass then later assault Aisha near the District Court House in downtown Miami, has been repeating verbatim in her public interviews on TV and in print things Aisha had said over the phone to friends, family and business associates, attributing it to herself as a sick form of harassment. According to security experts, this is a harassment technique commonly used by wiretappers to upset, scare and discourage potential legal opponents and enemies. 26. Furthermore, the method of assault commissioned and utilized against Aisha is one favored by Madonna - choking, which she, Madonna, has done to two people and was sued for the last time she committed this vile act of assault against a pre-teen boy named Keith Sorrantino, as mentioned further in this Complaint (SEE EXHIBIT 9). It was reported Madonna quietly settled the lawsuit out of court for $600,000 to avoid the horrible publicity that would ensue for deliberately choking and “beating up” a child, who simply “wanted her autograph” on “her day off” when she couldn’t be bothered to sign it. This coupled with her other unlawful behavior regarding this case illustrates the fact that she is a danger to society. What kind of human being does such things to another person, let alone a child. 27. Other public figures who have publicly complained, went to the FBI and or were approached by the FBI for investigative interviews because of wiretapping, harassment and or death threats by either Madonna’s lawyer Bertram Fields or his celebrity clients listed above are Court TV’s Diane Diamond, actor Sylvester Stallone and comedian/actor/talk show host Gary Shandling, several notable journalists such as Anita Busch of the L.A. Times and several entertainment industry lawyers. This has been widely written about and well established in many publications (SEE EXHIBITS 11 AND 12). Defendant Bertram “Bert” Fields retained criminal attorney Donald Re on November 1, 2003, to defend him in the currently ongoing FBI criminal probe. 28. Illegal wiretapping and harassment is an old dirty secret among a small set in Hollywood, which has been exposed in recent years due to the above-mentioned FBI probe and formal complaints by entertainment industry professionals and celebrities who unknowingly became the victims of invasion of privacy, which is a crime under U.S. and United Nations laws, punishable by several years in prison. 29. After stealing Aisha’s music, literary and photographic works from her widely read web site in clear view of Aisha’s audience who wrote to the young singer about it, Madonna then upped the ante and deliberately engaged in a pattern of willful theft of Aisha’s multi-million dollar valued copyrighted literary catalog that is housed in the Library of Congress and on her personal computers, in acts that spit in the face of the Goodison family, the U.S. Federal Government, Congress, The Government of Jamaica and the United Nations, due to the sheer number of laws that have been broken in each country by Madonna and her co-defendants in their quest to criminally use Aisha’s vast copyrighted works, invade her privacy and then terrorize and assault her into not going to the police and suing them. 30. This has been a criminal campaign spearheaded by Madonna that has already grossed the Defendants close to $500,000,000 in ill gotten profits, which is absolutely disgraceful and one of the worst acts of criminal corporate theft in entertainment history. 31. There is a mountain of evidence that clearly illustrates beyond any shadow of a doubt that Madonna has criminally and perversely been targeting, stealing from, harassing, terrorizing and stalking Aisha, in ways that crossed from severe breaches of civil law in plain view of scores of people who read Aisha’s web site regularly and alerted her to the fact that Madonna was stealing her copyrighted music, pictures and articles and progressed to severe breaches of criminal law in a sick, greedy, nefarious campaign commissioned by Madonna to steal a multi-million dollar copyrighted Federally protected catalog and terrorize the young singer into not pressing charges. 32. The fact of the matter is people who visit Aisha’s site on a regular basis witnessed Madonna rip off Aisha’s work in 2003 that Aisha had already copyrighted and released two years before in 2001. Madonna has been accused of and sued for this very same pattern of theft numerous times by international copyright holding artists. 33. And due to the fact that for the last 20 years, the span of her career, a Madonna project is usually an overblown spectacle with little or no substance that requires much staff and industry artists to put it together, many people were commissioned in criminally stealing and using Aisha’s works and most of them knowingly so. 34. Further causing additional offense and problems is that Madonna criminally began using for herself and selling off to her partners Aisha’s copyrighted scripts, songs, photo treatments and book manuscripts - works that Madonna does not and never has owned, but gained via a criminally obtained copy of Aisha’s already copyrighted catalog via hacking. 35. Who is she to criminally procure Federally and Internationally protected copyrighted works of such great monetary value and use and sell several of them off for millions of dollars in ill-gotten profits. This was a vile, despicable, offensive, criminal, greedy act punishable by several years in prison. 36. Aisha is being robbed, defrauded, exploited and criminally harassed and assaulted at every turn in despicable behavior by the Defendants that break U.S., Jamaican, British and international United Nations laws. 37. This criminal conduct must cease immediately. It is disgraceful, abhorrent, nefarious and unbecoming. However, it provides a glaringly accurate portrait of what certain pockets of the entertainment industry has become - laden with criminals who have no qualms about breaking not only civil law, but criminal as well. They believe that because they are famous and on television it gives them the right to steal from and assault people at will. They conduct themselves as though they are above the law and as though it does not apply to them. 38. Defendants Madonna, Disney, Madonna’s employers Warner Bros/Time Warner AOL and their affiliates have engaged in an willful ongoing pattern of illegal acts against Aisha, including but not limited to copyright infringement, plagiarism, corporate theft, grand larceny, wiretapping, invasion of privacy, harassment, assault, fraud, terrorization, terroristic threats, career sabotage, blacklisting, tortuous interference and malice in illegal attempts to steal Aisha's multi-million dollar copyrighted catalog mentioned previously in this Complaint, which they have been criminally using. Aisha's very valuable, prolific copyrighted multi-million dollar catalog has made her a target for the vulture-esque Madonna, her employers Warner Bros/Time Warner, her affiliates Gary Marshall, Jerry Bruckheimer and Disney, all of whom she has very clear, well established business ties to. 39. Madonna is a frequently sued, known intellectual property thief who is terribly driven by greed. She is a kleptomaniac who has bragged about stealing money from employers and other music artists. Her entire career has been based on stolen works. Her biggest projects and works such as Like A Virgin, Vogue, Justify My Love, Frozen, Deeper, Bad Girls, Human Nature, Ray Of Light (Music video), Hollywood (music video) and Swept Away (movie) were on the receiving end of copyright infringement and plagiarism lawsuits or credible public allegations of the same from scores of artists and writers. 40. She is known in the industry by lawyers and critics alike for this appalling thievery. She has also been exposed as someone who signs her name to other artists works, collecting their royalties (money) that she did not write or her contribution to was “changing one line” of an already completed song, then taking huge credit in front of the mainstream public for these pathetic acts of plagiarism and posing. 41. Due to Madonna’s criminal conduct, which escalated to commissioned invasion of privacy, harassment and assault, Aisha is now concerned for the safety of her family, as the Defendants conduct towards her has grown worse, culminating in acts that violated her civil rights, copyrights and personal safety, as detailed further in this Complaint. Furthermore, her aunts have numerous copyrighted works, some of which are partly owned by renowned Universities and publishing houses that Aisha is concerned the depraved and greedy Madonna will seek to infringe in her unlawful, criminal copyright infringement spree, as outlined in detail further in this Complaint. 42. Madonna's conduct towards Aisha has grown increasingly obsessive depraved and out of control. Madonna's stalker-like behavior towards Aisha has gone too far, venturing into very disturbing territory. In investigating this case, Aisha has logged on to internet sites and was creeped out when she saw pictures of Madonna wearing the same clothes, earrings, shoes and hairstyles that she, Aisha, had worn around Miami previously on different occasions (more proof that Madonna has her under surveillance, some of which is criminal). Aisha was wearing her hair in a shade of red for a time this year with a trademark matching red lipstick, only to see Madonna dye her hair the same shade of red and wear the same shade of bold red lipstick in the last couple weeks - and also styling her hair the same way. Aisha has since changed her hair in the last two weeks back to a shade of blonde. 43. Madonna has been accused of this disturbing, mimicking conduct before by other artists like Nashville Pussy and Courtney Love, who publicly accused her of dressing like them and stealing their respective looks SEE EXHIBITS 17 AND 18. Madonna was also publicly accused by the well-respected industry music compilation and biographical information company Muze of stealing the looks and video imagery of transvestite German singer Peaches for her own photos and videos that she took to the mainstream and fraudulently claimed as her own, furthering this myth about her that she in the queen of reinvention when she is in fact the queen of stealing. 44. She constantly steals other people’s looks and music for her reinventions that she takes full credit for in the mainstream, all while violating other artists Copyrights, Rights to Publicity and Rights to Privacy. The mainstream press, mostly owned by her label Warner Bros (Warner owns Conde Naste, who owns most of the major magazines and newspapers the mainstream public reads), then labels her creative in self-aggrandizing, PR fueled, pre-arranged publicity spots masquerading as articles, when in actuality she is sickly and creepily dressing and styling her hair like other indie music artists and illegally using their copyrighted music, because she feels they are lesser known, therefore her large mainstream audience won’t know she’s stealing other people’s images and music for her reinventions. 45. However, some industry professionals have caught on to what she has been doing and have written about and condemned this habit Madonna has engaged in for many years at lesser-known artists’ expense. There are lawsuits and credible dated before and after material that completely support this claim about Madonna. 46. One of Aisha's friends is also a friend of Madonna's former secretary. Aisha's friend told her that the secretary complained that this type of mimicking conduct is something Madonna has done to others including herself. The secretary said that she came into work with a new hairstyle and Madonna complimented her on the new look - then eerily came into the office the very next day with the exact same hairstyle as well. 47. Madonna has taken a sick, obsessive likening to publicly quoting verbatim things Aisha writes in her widely read entertainment industry column “Sound Off” days after Aisha publishes them online and copyrights them - proving Aisha wrote it before Madonna mimicking quotes it like a demented parrot. 48. Madonna disgracefully made Aisha into a default speechwriter through this unethical, plagiaristic practice, which is also a violation Aisha’s copyrights’ Right of Attribution (a form of copyright infringement). Later, it progressed to something that is once again far more sinister and disturbing, when Madonna began a sick practice of repeating verbatim in her, Madonna’s public interviews, things Aisha had said over the phone in confidence to friends, family and business associates. Even more disturbingly, Madonna has been publicly repeating verbatim things Aisha said in the privacy of her own home, which raises many questions. 49. Things Aisha said over the telephone have also been printed in the Sun Newspaper verbatim by Madonna’s nefarious, vile, publicly announced email pal Victoria Newton, whom she gives many exclusives in said trash tabloid newspaper. 50. Security experts describe the printing of information a wiretapped victim said over the phone as a form of pre-litigation harassment and corporate theft. Newton and the Sun further printed copyrighted items from Aisha’s private, unreleased copyrighted multi-million dollar catalog in the Sun Newspaper under various sections attributed to Victoria Newton, Nikki Waterman and to Life, News and Sports section writers. These are acts of corporate theft, invasion of privacy, criminal copyright infringement and fraud. STALKING 51. Further evidence that Madonna has Aisha under surveillance in acts that are criminal violations of the respective Jamaican, British and U.S. constitutions and United Nations laws happened this month. On September 12th, 2005 Aisha flew to London to begin filming for two music videos and other works. She immediately began filming with a professional broadcast quality hand held movie camera. She went around London filming known landmarks, red double decker buses and tube stations. She filmed many Londoners cinema verite style and the smiled for the camera when they saw her. Some of them recognized her from her web site. She went around with her camera hidden in a bag, then filmed different locations spontaneously to capture people’s reactions. 52. The very next day Madonna made an official public announcement through her manager that her new video was to be of London landmarks, red double decker buses, tube stations and hidden cameras where they would capture the surprised reactions of Londoners at Madonna’s presence. In a matter of minutes Madonna ripped off the video Aisha had already filmed and labored over (the footage is time and date stamped), making plans of her own to shoot the same exact video Aisha had filmed two days before. Many people witnessed Aisha filming this footage - several of which were given her business cards. Aisha had also copyrighted that London video treatment years ago, but only got around to shooting it last week. Further proof Madonna has been committing corporate theft, stalking, harassment and invasion of privacy against Aisha. 53. It also highlights the fact that Madonna was still sickly watching Aisha even in London, via the surveillance campaign she commissioned against the young singer in Miami who has been going about her business and not bothering anyone. Yet the perverted, depraved, obsessed Madonna has been constantly stealing from and harassing her at every turn. The illegal surveillance campaign followed Aisha from Miami to Jamaica to London over a 10 day span in a gross invasion of privacy and foul acts of stalking. 54. Additionally, Aisha noticed a burly man whose arms were covered in tattoos sitting at the bus stop outside her aunt’s home on the outskirts of London when she went to take the bus to the train station to get to central London (her aunt’s car wasn’t working). She paid it no mind until two days later she saw the exact same man again standing roughly a foot behind her at an Oxford Street bus stop where she had been filming. This bus stop was very far from her aunt’s home and she was startled when she turned around and saw the same man again. He stared at her intently for several minutes, which prompted her to cross the street to get away from him. 55. Much like the incident where she was assaulted in Miami two months ago, she saw the same person on two separate occasions in close proximity of each other (over the course of a few days). The incident in London was at the hands of a tall, burly white male and the incident in Miami was at the hands of a tall, burly black male. Both men along with several other people who have approached Aisha at different times in Miami to harass her on Madonna’s behalf beginning this summer, all looked menacing and unstable. 56. These were not Madonna fans, as several of these individuals, with the exception of the male in London who did not speak to her, all repeated things to her verbatim that she’d said over the phone in confidence and in the privacy of her own home. How would a fan know what Aisha has been saying over the phone and in the privacy of her own home to do such a thing as to sickly approach her in public, strike up a conversation and repeat these things to her exactly as she had said them before. 57. Only someone who had information from an illegal surveillance campaign would know these things to memorize then repeat them in person to the victim of the wiretapping, as was done to another of Madonna’s lawyer’s nemesises, Court TV’s Diane Diamond, who publicly complained “My words were coming back to me through others” regarding the wiretapping and harassment she experienced during the time she reported on the first Michael Jackson child molestation case. 58. Though Aisha does not believe Mr. Pellicano was involved in the assault, as he is currently incarcerated, it is worth noting that the FBI confiscated 4 billion pages of wiretap transcripts of famous and non-famous people’s telephone calls that Madonna’s lawyer’s private investigator, Mr. Pellicano had tapped, which were all stored in paper/text format made from sound recorded wiretap tapes. According to experts, text copies of wiretapped phone calls are easier to send to the individual who commissioned the wiretapping and easier to understand, as opposed to sending them tapes of the illegally tapped calls. 59. On September 18, 2005 Aisha noticed that she and her family were being followed by a man and a woman in a dark blue BMW for over 25 minutes in Oxfordshire, England in a pre-planned trip she had made to film a specific place. It was the main footage she required and planned the trip around. 60. These incidents coupled with Madonna’s conduct listed above, show a clear pattern of commissioned harassment, stalking, assault and invasion of privacy. 61. Defendant Madonna is and at all times mentioned herein was, a copyright infringing, plagiarism prone singer who has built a career on pornographic music, filth, debauchery and shock value, much of it resulting in plagiarism and copyright infringement lawsuits by numerous international copyright holding songwriters, directors, artists and singers all over the world. Madonna has become very rich off of infringing artists copyrights, thereby unlawfully diverting their songwriting royalties and film points (royalties) to herself, as evidenced by the numerous lawsuits filed against her in this regard, listed further in this Complaint under the "Madonna’s Extensive History Of Plagiarism And Copyright Infringement" section. 62. Madonna and her label Warner Bros Records/Warner Bros/Time Warner AOL, have been sued for and publicly accused of stealing people's copyrighted works more times than any other artist and company in entertainment history. Michael Jackson, Elvis and the Beatles are considered the most famous and successful artists in music history and none of them have such a disgraceful history of copyright infringement and plagiarism, as does Madonna, though they wrote many of their own tunes, as the Defendant Madonna claims she does, which has been shown to be untrue on many occasions. 63. Madonna has confessed to having long bouts of writer's block, SEE EXHIBIT 46, and stated in People Magazine, "I no longer have time to be creative," SEE EXHIBIT 47 - very telling statements by a woman who has been sued numerous times for plagiarism and copyright infringement, with almost 3 dozen credible public allegations of the same by many artists, who were left defrauded and damaged as a result of her unconscionable, thieving actions. DESPERATE MADONNA64. The malfeasances committed against Aisha occurred due to Madonna’s desperate need for innovate, cutting edge music and ideas to maintain her career, which has been solely based on substanceless trends, debauchery, vulgarity, pornography and shock tactics. In a vain attempt to inject life into her fading career and to compete with the likes of younger stars like 24 year-old Britney Spears and 25 year-old Jessica Simpson, 47 year-old Madonna pilfered and pillaged the copyrighted works of rising 28 year-old indie singer Aisha, even going as far as making over her image into that of the younger singer for a Versace ad campaign in a grossly exploitative violation of Aisha’s Right To Publicity and Right To Privacy, listed in detail further in this Complaint. 65. Rather than aging gracefully and elegantly like talent based stars Tina Turner and Barbra Streisand, Madonna continues to vulturously rape and pillage younger, innovative artists' copyrighted works in a vain attempt to remain a 20 year-old, while making a fool of herself due to this in latter years, due to her career having been based on selling sex and youthfulness, rather than vocal ability, which according to scores of critics, entertainers, music industry experts and audiences, she greatly lacks. 66. Artists such as the Beach Boy’s Brian Wilson, Joni Mitchell, Elton John, Prince, Elvis Costello, Boy George and former Westlife member Bryan McFadden have publicly voiced their disapproval of Madonna’s lack of talent and penchant for debauchery and pornography to get the spotlight and sell records. Scores of critics and audiences have also publicly and very vocally complained of her lack of talent and lack of singing ability. 67. Aisha has filed this action against Madonna, Time Warner, Disney and their co-defendants for the systematic stealing of original works wholly authored and copyrighted by Aisha in accordance with US copyright law, as recognized by the United Nations’ Berne Convention and Jamaican Law - all prior to Madonna, Time Warner, Disney, their subsidiaries, affiliates and co-defendants thefts thereof. There are over 300 instances of copyright infringement and plagiarism by Madonna and her co-defendants, of works wholly authored, owned and copyrighted by Aisha, prior to the Defendants stealing them. 68. Madonna acted as the ringleader and head conspirator in the ongoing gross malfeasances being committed against Aisha with her employer Warner Bros/Time Warner, Madonna’s partner in JBT Films online Jerry Bruckheimer (Jerry Bruckheimer Films) and her colleagues at Disney that she has clear public ties to soon following suit when they realized the value of the treasure trove of copyrighted works Aisha owns, that took her over 20 years to author. Works they criminally stole and made use of. 69. These malfeasances constitute numerous violations of U.S., British, Jamaican and United Nations Laws, both civil and criminal, for financial gain, which is disgraceful and thoroughly reprehensible. Sadly, it is a blaringly accurate portrait of the state of the entertainment industry and just how far artists like Madonna and companies like Disney and Warner Bros will go for money via raping and pillaging the copyrighted intellectual property of independent writers, which is a way of life for the Defendants, as evidenced by close to 100 separate lawsuits against them for said crimes, mentioned further in this Complaint. Copyright infringement is a lucrative, albeit criminal, source of income for them, for which they have been sued numerous times, but continue to illegally engage in, anyway. Their actions clearly illustrate they have no respect for or fear of the law. 70. Coveting the innovative indie artist's music, film and literary projects that have set industry precedents and realizing what was to come from the young writer/singer, Madonna in conjunction with Time Warner, Disney and their affiliates, commissioned and executed a vile, corruption based, racketeering ridden plan to commit corporate theft, grand theft larceny and invasion of privacy, waging an illegal, surreptitious surveillance campaign, actively harassing, terrorizing, bullying and invading the privacy of Aisha via wiretapping, computer hacking, 24 hour surveillance and threatening associates who criminally approached Aisha on the streets of Miami, threatened her verbally and on one occasion physically grabbed her by the neck and attempted to choke her before a civil court meeting in Downtown Miami. 71. Choking is a method perversely preferred by Madonna, who choked two people as mentioned above, due to her perverse obsession with the young singer and stealing her treasure trove of published and unpublished copyrighted works. 72. Curiosity and greed got the best of Madonna and she hired a hacker to illegally copy Aisha's unpublished copyrighted multi-million dollar catalog of works that she spoke of on her web site, from her hard drive that she and her co-defendants have been criminally making use of in putting these already copyrighted works from Aisha’s catalog into production at their companies and re-copyrighting them as their own - severe civil and criminal breaches of United Nations, U.S. and Jamaican Laws. MADONNA: FROM INTERNET THEFT TO CRIMINAL CORPORATE THEFT VIA HACKING AND INVASION OF PRIVACY 73. The malfeasances began with Madonna blatantly and flagrantly stealing from Aisha's published 2001 copyrighted music (sent to 50 international DJs in 2002 by Aisha, for which she has mailing receipts), lyrics, articles, album pics and features unique to Aisha's copyrighted web site, in clear view of Aisha's fans on her web site www.aishamusic.com, for illegal use on Madonna's critically dismissed 2003 “American Life” CD and progressed to something far more sinister and illegal - invasion of privacy via commissioned phone tapping and computer hacking to commit corporate theft of more of Aisha's copyrighted works. 74. This was also done to harass Aisha and her family by spying on them and making the personal contents of their lives that could only be gained via illegal surveillance, public through the Sun Newspaper UK and the Time Warner/Jerry Bruckheimer show CSI: Miami, in a sick, despicable, criminal attempt to discourage litigation and enable them to further criminally use her very lucrative catalog, especially the film scripts, which would have been worth billions to them if they got her out of the way. Things Aisha said verbatim to friends, family and business associates appeared in its exact context in the Sun Newspaper UK and on Madonna’s partner’s show CSI:Miami, that Aisha had said she was a fan of (with was being the operative word). The owner of the show “CSI:Miami” is Madonna’s partner in JBT films online, Mr. Jerry Bruckheimer - SEE EXHIBIT 33. 75. Aisha realized a few months ago that things she was saying in the privacy of her home were being repeated publicly by Madonna and printed in the Sun Newspaper by her publicly confessed friend and email buddy, Victoria Newton and by Madonna’s partner in JBT Films online, Jerry Bruckheimer via his show CSI:Miami. Mr. Bruckheimer has been publicly written about before for using his shows to insult and harass competitors by including them and details of their lives in the storylines, as mentioned further in this Complaint. 76. It was recently discovered via an electronic gadget that tests for RF, that there’s been audio recording and filming in Aisha’s home and close to the perimeter at times no visible audio or video recorders were present. This did however explain how Madonna was able to quote word for word things Aisha had said in the privacy of her own home, not just over the telephone. 77. Aisha's other copyrighted works not released to the public yet, but registered in the Library Of Congress and housed on her computers, were illegally utilized by Madonna, her employer Time Warner, Disney and their affiliates, in acts that can only be described as abhorrent, despicable and nefarious. The numerous thefts by the Defendants of Aisha's unreleased, unpublished copyrighted works bear exact duplication, blatant copying and willful alteration, all punishable felonies, largely due to how Aisha’s private Library of Congress copyrighted catalog was criminally procured by Madonna. 78. Aisha and her family's privacy has been inhumanely and perversely invaded and thrown in their faces by Madonna and her co-defendants through hired hackers, wiretapping and unlawful surveillance - the contents of which were used by Madonna, Disney, Warner Bros and Jerry Bruckheimer Films, as a form of harassment and terrorization against Aisha to discourage litigation and free them to use more of her valuable copyrighted works, in making items said in the privacy of her home and over the phone in confidence to different people, public via the Sun Newspaper UK and Warner's CSI:Miami. 79. Aisha's greatest item of concern is the sophisticated surveillance campaign utilized against her and her family. Aisha and her mom live together in a quiet Miami suburb. Relatives have visited and stayed for vacation, some of who are minors whose citizenship originate in two countries. They had their meals, changed their clothes, and said their prayers at night before they went to sleep in a home Aisha has now discovered has been under illegal surveillance in violation of many U.S., Jamaican, British and United Nations laws. 80. Aisha recently found digital phone taps on her telephone line and over 22 computer virus trojans and numerous illegal spyware programs on her computer, placed there by a hacker unbeknownst to her. SEE EXHIBIT 1 for the computer programs reports regarding the unlawful ongoing intrusions to her computers and the number of times it occurred. The CD ROM exhibit shows the numerous computer trojans planted on Aisha's computer to gain unlawful entry and copy the hard drive containing Aisha's multi-million dollar catalog of copyrighted works that is also housed in the Library of Congress. 81. Aisha was prompted to search for computer hacking/intrusions, as she began noticing items from her already copyrighted catalog she privately houses on her computers with the other copies in the Library of Congress in Washington, D.C. began mysteriously surfacing in Madonna, her affiliates Disney and her employer Time Warner's new and announced projects such as the movie Material Girls (Madonna's Maverick Films) and "Princess Diaries 2" (Buena Vista Film/Disney) - without Aisha's permission and fraudulently attributed to the Defendants. 82. This raised some serious questions about how these leaks occurred, as the only place the works have been housed since their creation is in the Library of Congress/Copyright Office in Washington, D.C. and on Aisha's personal computers - the matter complicated by an issue listed further in this Complaint. 83. In an ironic and incriminating twist, Madonna's children's book the English Roses, sickly has a page about spying on a girl, a character, who is a lot like Aisha in the description Madonna used to describe her in the book. The book eerily says, "They couldn't turn down the chance to spy on Binah without her knowing they were there" and "but she'll think were burglars or something (Aisha's home studio was burglarized shortly after she began publicly complaining on her web site of Madonna stealing her copyrighted music from the site, SEE EXHIBIT 13, for Police Report) and "she will call the Police" are among the odd, demented lines in the children’s book. 84. Even more eerie is the fact the character they were spying on, Binah's life is a lot like Aisha's, especially in the exact list of chores Aisha does at home that the books lists on page 32 in great detail and illustrated pictures (peeling potatoes, chopping onions, scaling fish, washing the clothes, ironing the clothes, scrubbing the floors, taking out the trash and taking care of a parent they live with). 85. Even the description and picture of Binah's room in the book is like Aisha's actual bedroom at home. The character in the book was not based on Madonna's daughter, as she deceitfully claimed on several TV shows and in magazines - it was perversely based on Aisha, who Madonna has criminally had under surveillance, as she stole the young singer’s copyrighted multi-million dollar catalog and began using it. 86. Madonna's daughter does not do any of those chores (peeling potatoes, chopping onions, scaling fish, washing the clothes, ironing the clothes, scrubbing the floors, taking out the trash and taking care of the parent they live with) as she was 5 years old at the time the book was published. Nor is she blond, like the character in the book (her hair is black). Aisha does those exact chores several days a week, lives with her mom who she takes care of and has had her hair blonde for over 10 years. 87. Furthermore, references made by Madonna on the television show “The View” in June of 2005, referring to putting her daughter’s clothes in a trash bag because she leaves them all over and on the floor, is a practice Aisha does weekly in putting her mom's dirty clothes in a new trash bag, taking them to the laundry room and washing them, right after complaining to her mom about leaving her clothes in different rooms of the house (even Aisha's realtor asked her to not leave the trash bags with the clothes in the room next to the laundry room, when he was trying to sell her home last year. He told her that a good house selling tip is eliminating clutter, as potential home buyers might mistake it for trash, when its actually clothes to be washed). 88. This was the same thing Madonna later, who publicly claims she isn't domesticated and can't cook, claimed she is doing regarding her daughter, in putting her dirty clothes in trash bags. The idea of Madonna going around a house with a trash bag when she says she has maids and two nannies is very incredulous. She got that story from the illegal surveillance campaign she commissioned against Aisha. 89. Another of Madonna's children’s books, “Lots De Casha,” has furniture that is like furniture in Aisha's home and chronicles private events that happened in Aisha's home - yet Madonna included it in her book. The character in the book actually sleeps with a blanket every night that is very similar in color and pattern to the one Aisha sleeps with every night. Aisha sleeps with a pink and white blanket with stars and squares on it. The character in Madonna’s book sleeps with a pink and white blanket with squares on it. Not to mention, the Versace ads featuring Madonna that rip off Aisha's life, Right To Publicity and Right To Privacy, contained furniture in it that is like the furniture in Aisha's home office. 90. How could Madonna have possibly known so much about the daily goings on, incidents, layout and furniture in Aisha's home to write and print it in her books and Versace ads in such accurate detail, unless she had illegal access to Aisha's home. Aisha was stunned, appalled and creeped out when she read Madonna's Kaballah children’s books for the first time recently looking for further infringement of works from her catalog, as that is when she realized the extent of what the depraved 47-year-old singer had done in invading her privacy and that of her family, some of which are minors. 91. No one should be made to endure such illegal, invasive treatment. Aisha and her family members, some of whom are minors, are law-abiding citizens who've had their privacy violated by the Defendants. They didn't deserve to be spied on like dogs with no rights. The Defendants’ conduct violates numerous international human rights laws set forth by the United Nations - and most of all, is inhumane. What kind of sick individual does something like that to an innocent family. THE KABALLAH CULT: PRIVACY INVADERS, TRESPASSERS AND COPYRIGHT INFRINGERS 92. As mentioned above, the Defendants are no strangers to claims of invasion of privacy. Madonna’s lawyer Bert Fields is the attorney for the privacy invading Church of Scientology (members were arrested for bugging an FBI office) and the privacy invading Kabbalah Center. 93. The Kabbalah Center's founder, Phillip Berg, was sued for invasion of privacy in going into the home of a deceased Rabbi, stealing his manuscripts, re-copyrighting them in his name and publishing them as his own. He has been publicly accused of copyright infringement of other works as well and sued in another instance, mentioned further in this Complaint. Berg’s actions were an invasion of privacy in entering the Rabbi’s home and committing an act of grand theft larceny and later copyright infringement. There have been published reports of a memo where the Kabbalah Center encouraged copyright infringement to gain literary material, as written about in Radar magazine’s investigative piece on the cult, included as an exhibit in this Complaint. MAIL TAMPERING94. Beginning in June 2005, Aisha noticed that when she checked the mailbox at her home, her mail had been tampered with, crumpled and opened. Confidential legal documents from a lawyer, a report from stock company and a letter from a Christian charity were opened by persons unknown and placed back in the mailbox with the envelopes blatantly opened. 95. Looking at the mail, you can tell the sender had sealed the letters, as the envelopes' glue had been altered in textured and appearance by the presence of saliva/ water before sealing it. However, someone had clearly opened it, read the contents, folded the envelopes flaps back over and put them back in the mail box, as when Aisha went to open letters on four occasions, these items were already opened. Imagine receding your mail opened. It is not a common occurrence, but a deliberate act of invasion of privacy and mail tampering. 96. The first time it happened, Aisha wondered about it, but then discounted it. But then it happened three more times in a short period of time. That's when she realized someone was deliberately opening her mail. She then thought about it and remembered that the companies that sent her the mail that someone had unlawfully opened had never sent her opened or unsealed items in the mail in all the years she has known them. She filed a complaint with the Postmaster General. WIRETAPPING 97. Aisha has never had the mail in the box opened before, until the recent escalation of harassment and terrorization against her began in May of 2005 by people clearly affiliated with Madonna and her co-defendants, who clearly illegally had access to Aisha's phone conversations and her home. Also evident by the fact that Madonna in the same manner was repeating publicly, verbatim, things Aisha had said in the privacy of her own home and over the telephone to numerous people. 98. As mentioned above, people have come up to her in public places, made physical contact, harassed and threatened her about Madonna, told her in veiled threats of commissioned crimes against private citizens who challenged major named figures and of citizens losing in lawsuits against big companies in New York (which is ironically where Madonna’s Time Warner is located) - only these weren't Madonna fans, these were strangers who clearly had had access to Aisha’s home via invasion of privacy, as they repeated things to her verbatim that she had said in confidence over the phone and other items she'd said in the privacy of her own home to her mother. 99. This has been apart of an unlawful, despicable commissioned campaign to exploit and terrorize the young writer/singer due to her very valuable catalog of copyrighted works, as mentioned above, that Madonna and her co-defendants covetously and illegally obtained a hacker procured copy of and have been unlawfully putting songs and movies from said catalog into production at Maverick, Warner Bros and Disney, violating Aisha's rights of copyright ownership and authorship and right to privacy. 100. Security experts Probe Inc of Los Angeles, California state, "If you have a company that is involved in the fashion, entertainment, advertising or marketing industry, you may become a target of wiretapping and unlawful surveillance.” They warn of red flags to watch for that Aisha has experienced. And considering so much of Aisha's other copyrighted works housed in the Library of Congress and on her personal computers, that have not been released yet, has been stolen at such a disgraceful rate and keeps surfacing in projects by Madonna and her affiliates and partners, it is clearly and unquestionably a vile case of criminal corporate theft and invasion of privacy. MADONNA’S LABEL WARNER/AOL THE SOURCE OF A HACKER SPENDING SPREE ON AISHA’S VISA DEBIT CARD USED TO PAY FOR AOL INTERNET SERVICE AND AISHA BLOCKED FROM GETTING ONLINE TO UPDATE HER SITE FOR DAYS DUE TO ALLEGED AOL “TECHNICAL DIFFICULTIES” 101. Time Warner's AOL, a subsidiary of the company Madonna records for, further allowed a hacker to charge almost $600.00 to Aisha's debit/credit card they had on file to charge her account $24 monthly for internet access with AOL. When she called AOL to dispute the AOL charges - they said “a hacker probably got access to your card” and that she was to “change her passwords.” 102. This occurred days before a worse identity theft occurred, where someone tried to tie up all her funds using the very same debit/credit card connected to her bank account that AOL had, the weekend she announced the pending release of her album. The person tried to tie up her funds charging items that they provided no proper shipping address for and advertising services that they could not use. Regardless, this would have tied up Aisha's funds, and some banks like Washington Mutual, do not refund money from fraudulent charges stemming from identity theft, holding customers liable for them. 103. However, thankfully, at that point Aisha was not banking with such an institution. The debit/credit card company used by her new bank, called her very early in the morning, waking her out of her sleep to tell her they felt she'd been the victim of identity theft in that someone was using her card over and over again to buy things on the internet (at about 4AM in the morning EST). She informed them that it definitely was not her and they asked for authorization to cancel the compromised card. They further investigated the fraudulent charges and realized someone on the West Coast made them at a time Aisha was sleeping on the East Coast, when they called her home. 104. The debit/credit card company provided her with a list of merchants the hacker made the fraudulent charges with and the telephone numbers for the businesses. When Aisha called to investigate what happened, the merchants told her that they realize the charges aren't legitimate in looking at them now, as the person did not fill in a proper shipping address, rather typing gibberish in the shipping address fields. Someone was playing around with her card online to spend and tie up as much of her money as they could to thwart her pending album release. 105. Aisha was additionally having problems with her AOL service in not being able to get online to update her web sites www.Aisha.tv and www.aishamusic.com. There were times when she couldn't get online for a few days due to alleged "technical difficulties." Aisha now believes it was due to the fact that she was publicly complaining about Madonna and Warner Bros (who owns Aisha’s former internet service provider AOL) on her web site in speaking out against them for the illegal acts they were committing against her. Aisha’s web site was hacked shortly after as well, links removed and pages deleted referring to Madonna’s misdeeds, all without permission on a site they do not own or host and in violation of Aisha’s rights. 106. This was done by a hacker, clearly commissioned by Madonna, who hacked her site in the same manner he hacked her computer to give Madonna criminally obtained and made copies of Aisha’s copyrighted multi-million dollar catalog that Madonna later began criminally using for her projects. These projects made Madonna millions of dollars in ill-gotten money. 107. When Aisha closed her AOL internet account, uninstalled their software from her computers and switched to another ISP, they still continued to bill her anyway SEE EXHIBIT 49 - a complaint echoed by many former AOL subscribers. However, the AOL identity theft and hacking provided Madonna and Warner Bros with a clear, detailed layout of Aisha’s computer systems and the contents thereof - which they later criminally used via the copy of Aisha’s multi-million dollar valued copyrighted catalog. MADONNA’S COMMISSIONED ILLEGAL SURVEILLANCE OF AISHA 108. Red flags Aisha has experienced, as outlined by Probe Inc are "Confidential personal information mysteriously appears in the newspaper." This has happened to Aisha in that things said in confidence over the telephone to her family and friends have appeared in print in the Sun Newspaper UK, attributed to Madonna and her friend, Sun Newspaper journalist Victoria Newton, in actions that can only be described as perverse. 109. It is a violation of Aisha's civil and human rights via invading her privacy through having her under round the clock surveillance and going as far as having these personal items Aisha said in the privacy of her own home to her mother, and on other instances, items she said over the phone to friends and family members, reprinted verbatim in the Sun Newspaper UK, which is listed in detail further in this Complaint. 110. Victoria Newton further printed items from Aisha's copyrighted documents and scripts only available on Aisha's personal computer and in the Library Of Congress, in the Sun Newspaper UK, attributed to herself and Madonna, which was a gross invasion of privacy and copyright infringement, also listed further in this Complaint. Ms. Newton further unlawfully helped herself to items from Aisha's widely read copyrighted Sound Off Column and online Diary pages of her web site that has been read by millions, after Aisha published them online to her web site, for use in her distasteful Bizarre column in the Sun Newspaper. 111. Based on preliminary evidence, the tapes of Aisha's telephone calls were shared by Madonna with not only her friend and email buddy Victoria Newton of the Sun Newspaper UK, who singer Pete Doherty of Babyshambles deliberately mentioned to in an interview that he found hidden cameras and a bugging device in his home that is now being investigated, SEE EXHIBIT 26, they have also been shared with the writers for Time Warner/Warner Bros owned Jerry Bruckheimer Productions' television show CSI:Miami, who also infringed Aisha's copyrights by ripping off items from her copyrighted Sound Off Column and online Diary after she'd put copyrighted editions of the column online, detailed further in this Complaint. 112. Aisha's copyrighted works from her web site and things she said over the phone in confidence, were utilized for script dialogue and plotlines for CSI:Miami, which is outlined further in this Complaint. These acts of invasion of privacy were utilized for four episodes of the show this year. The program is filmed in Aisha's hometown and also featured Madonna's best friend of 25 years fellow Kabbalahist, Debi Mazar SEE EXHIBIT 34. 113. Jerry Bruckheimer, owner of Jerry Bruckheimer Films/Warner Bros attributed copyrighted items from Aisha's Sound Off Column and things she said in the privacy of her own home, to himself in public interviews he did, after she published the items on her web site and after she said these items in the privacy of her own home SEE EXHIBIT 48. 114. Madonna and Jerry Bruckheimer are friends and partners in an internet venture for films SEE EXHIBIT 33, both work for Warner Bros/Time Warner and both have the same lawyer, Bert Fields, who, as mentioned above, has been at the center of an FBI probe for his private investigator Anthony Pellicano wiretapping people who'd threatened to sue or sued Bert Fields' famous clients. Mr. Bruckheimer's former partner, the late, notorious Don Simpson was also a client of Bert Fields and was also mentioned in the wiretapping scandal. 115. Her telephone calls have been recorded, her faxes intercepted, both business and personal, and forwarded to Madonna and shared with fellow Warner Bros and Kaballah cohorts, who foolishly and incriminatingly utilized and repeated business and personal items said over the phone and in Aisha's home, verbatim in interviews in the press and on the show CSI:Miami (The owner of the show “CSI:Miami” is Madonna’s partner in JBT films online, Mr. Jerry Bruckheimer - SEE EXHIBIT 33). This is a harassment technique commonly used in certain circles in Hollywood when they want to scare a legal opponent, someone publicly threatening to sue them, someone writing unflattering articles about them or publicly speaking out against them, as did Diane Diamond and Anita Busch in going against clients of Madonna's lawyer. 116. Madonna commissioned the phone tapping then utilized verbatim items from Aisha’s personal and business telephone calls for her projects on Maverick, Warner Bros, articles in the Sun Newspaper in London about her and numerous other interviews to enhance her sullied image, in an effort to aid her latest reinvention to make her appear intelligent, demure and refined, when she is none of those things. 117. Madonna has been actively and perversely watching Aisha's every move through an unlawful 24 hour surveillance campaign, that recently escalated to threatening and harassing Aisha in public, that several of her co-defendants knew of, but looked the other way in exchange for profits reaped from the illegal surveillance of the Plaintiff, used to commit corporate theft of her copyrighted works valued in the millions and the subsequent terrorization in vain attempts to scare her out of suing and reporting them for their misdeeds towards her. 118. These malfeasances are detailed further in this Complaint. They hoped by scaring her via threats, she would cave in and not go through with the lawsuit against them, freeing them to illegally use more of her works from her vast, lucrative copyrighted multi-million dollar catalog. However, Aisha was and is undeterred in bringing them to justice for the horrible malfeasances they've committed against her. 119. On September 3, 1993, Kabbalah cult lawyer Bert Fields' private investigator Anthony Pellicano and attorney Howard Weitzman claimed that the unauthorized wiretap they used on behalf of Kabbalahist Michael Jackson was legal. There are at least 4 civil suits that have begun since Mr. Pellicano's imprisonment pertaining to his illegal use of electronic surveillance, harassment and intimidation. Pellicano still advertises on the internet. 120. Bert Fields private investigator Anthony Pellicano further threatened, bullied and harassed writers who went against his clients the National Enquirer. When writer Stuart Goldman changed his phone number, Anthony Pellicano would call him on the new numbers to let him know he had "made" the number. Goldman further stated Bert Fields' private investigator further wiretapped his phone calls and terrorized his family. 121. Writers Lurie and De Becker he referred to as a "couple of fags" that he was going to expose. Pellicano stated "Their lives are going to be disrupted in ways they can't even begin to image." Lurie, shortly after was knocked off his bicycle 50 feet in the air by an unmarked car and sustained two broken ribs and a busted back. Laurie stated after the accident, "it was no accident...they made good on their threat" (source: anthonypellicanoweblinks.com). 122. There is a pervasive problem in Hollywood where the rule of thumb in certain circles is a misbehaving celebrity and or executive trying to shake off litigation for their misdeeds and unlawful acts, trumps your rights as a private "nobody" citizen to privacy and safety. That you do not have the right to have a phone that is not wiretapped. That you do not have the right to go about your life without strange menacing people approaching you in public, threatening, harassing and assaulting you. That you do not have the right to a computer that is not hacked and laden with spyware and internet activity tracking programs monitoring and recording you online. That you do not have the right to a home that is under illegal surveillance. 123. Rather than a clean, constitutional legal fight fought in the courts, some in Hollywood, time and time again opt for a dirty, illegal, unconstitutional fight that breaks more laws than the average spoiled, overindulged female pop star has tantrums. This allows the same handful of misbehaving pop stars and entertainment industry executives to hypocritically and cowardly bully and victimize, all while hiding behind hired hands that terrorize innocent people who dare to protect their rights and property against the pseudo-almighty celebrity. 124. This conduct needs to stop and serious, consequential questions need to be asked as to why it is always the same set of people being publicly accused of this exact same invasive misconduct against innocent people in the entertainment industry. 125. Another red flag, as outlined by Probe Inc is, "Corporate raiders mysteriously launch a hostile takeover at the opportune time." Aisha's copyrighted works that are unpublished and housed on her personal computer and in the Library Of Congress are illegally being put into production by Madonna, who is behaving like a corporate raider, but criminally so, in a mad rush to put out and criminally sell as much of Aisha’s copyrighted works as she can for her own projects and that of partners and collaborators, to corner it in the marketplace on Aisha’s works and labor in despicable acts of corporate theft. CATALOGS126. Another item of great concern for Aisha is that Madonna is now secretly in unlawful, criminal possession of Aisha's copyrighted, unpublished, multi-million dollar catalog containing 6,000 plus songs, 2 dozen scripts, 4 dozen film synopsises, 11 book manuscripts, 4 dozen music video treatment, and 3 dozen photo treatments. Madonna has already been misappropriating items from this catalog and obtaining huge financial remuneration for selling and using Aisha's already copyrighted works she has illegally attributed to herself and re-copyrighted in her name and Maverick's, which constitutes criminal acts in violation of Jamaican, U.S., British and United Nations laws. 127. According to ABC News, “Song catalogs have become hugely lucrative in the last two decades due to the compact disc boom, rising sales of Internet downloads, and movie studios and advertisers willing to pay royalties to use hit songs in film scores and commercials...It's hardly chump change: the small amounts add up to millions of dollars in revenues each year." HACKING AND CORPORATE THEFT ON THE RISE128. Madonna first stole Aisha's 2001 copyrighted and released song titled "Contemporary Girl" which was sent to 50 international DJs and featured on Aisha's site, for her later ill fitting, critically panned, clumsy rip off "American Life" released in 2003. Madonna passed off Aisha's copyrighted works as her own in the mainstream to untold millions - but later progressed to more sinisterly stealing unpublished unreleased copyrighted works, valued in the millions, from Aisha's private computers via a hired computer tech specializing in hacking computer systems via the internet. 129. According to a September 19, 2005 article in London’s Metro newspaper, Microsoft Chief security adviser Ed Gibson speaking to the Westminster eForum warned, “Cyber criminals could render the Internet useless in 3 to 5 years” if “Microsoft and other major players in this arena do not make a concerted effort to make the products more secure, the thing we call the internet will not be as it is today.” 130. Other figures show that internet corporate theft has become a leading form of crime. Hacking and computer data theft is a crime that is on the rise in the entertainment industry. Recently, Fred Durst of the band Limp Bizkit filed an $80,000,000 suit on March 2, 2005, due to the contents of his personal computer being hacked and copied by a company seeking to do business with him in distributing a video he had made and believed was "safely stored on the hard drive of his personal computer." 131. A hacker had been hired by the company to use IP tracking to locate and monitor Durst while he surfed the internet, pinpointing his location, then hack his computer, illegally copying the video from his hard drive. Then in an extortion style business bid, they contacted his manager requesting to do business with him for the hacker procured copy of the video they unlawfully had in their possession. They even informed him that Durst's computer was deliberately hacked to steal the contents. When Durst declined their offer, they vindictively placed the video and pics from it online. Durst then called the Secret Service and filed suit. HIRED HACKER132. The Plaintiff has every reason to be believed Madonna was behind the hackings of her computer and web site: 133. Aisha was the victim of a hacker beginning with Madonna's employer Time Warner AOL - who allowed who they said they believed to be “a hacker” to charge $600 to Aisha's AOL internet account that was connected to her Visa Debit card. When Aisha pressed them on how something like that could happen, they wouldn't give her any proper answers only telling her “it is confidential,” "I can't tell you that” and "I'm not allowed to tell you that” and to "change her password." Days later, Aisha was the victim of an identity theft based in malice and not financial gain - and the person clearly knew a lot about Aisha, as they tried to buy items at places they felt she would shop, in an attempt to run out all the money in her account attached to her visa/debit card. They spent almost $2,000 in a few minutes in erratic buying patterns then were stopped by her Visa Debit Card company. This was done the very weekend Aisha announced her album was available through the site. They tried to spend all of her album promotion money so she and the project would be marooned. 134. AOL violated the Electronic communications Privacy Act, 18 USC 2703, in their misconduct regarding Aisha. AOL - spied on Aisha on behalf of Warner and Madonna who were actively stealing her copyrighted works for huge profits in the millions. 135. AOL criminally assisted their co-workers at Warner (Madonna) in their illegal quest to rob, exploit and defraud Aisha out of millions of dollars in copyrights. 136. The VP of EarthLink, Claudia Caplan said, " AOL sells your information." Aisha has found that to be quite true, as they assisted their co-workers at Warner in violating Aisha's privacy and stealing millions of dollars in copyrighted work the US government via the Library Of Congress granted copyright protec |
