A copy of the Complaint as filed in court is attached, as is a page with excerpts from the Complaint.
The suit accuses the defendants of violating the Wilsons' constitutional and other legal rights as a result of "a conspiracy among current and former high-level officials in the White House" to "discredit, punish and seek revenge against" Mr. Wilson for publicly disputing statements made by President Bush in his 2003 State of the Union address justifying the war in Iraq.
The suit was filed nearly three years after Washington columnist Robert Novak disclosed Valerie Wilson's classified CIA employment in a column he wrote on July 14, 2003, based on leaks from senior administration officials. It subsequently was confirmed, during Special Counsel Patrick Fitzgerald's criminal investigation, that several top ranking officials in the White House leaked Wilson's name and status with the CIA to Novak and other reporters.
The Complaint was filed in the United States District Court for the District of Columbia by the international law firm of Proskauer Rose LLP, whose team is headed by Washington, D.C. litigation partner and privacy law practitioner Christopher Wolf. Noted Constitutional law scholar Erwin Chemerinsky, a professor of law at Duke University, is of counsel in the case.
As a result of Cheney, Libby and Rove's conduct, the suit claims that the Wilsons have suffered violations of their rights guaranteed under the United States Constitution and by laws of the District of Columbia.
The Complaint specifies that each of the Wilsons has been deprived of their First and Fifth Amendment rights; each has suffered a gross invasion of their privacy; each has been impaired in pursuing professional opportunities; and that they fear for their safety and the safety of their children as a result of the wrongful public disclosures. In addition, the Complaint alleges that Valerie Wilson was impaired in her ability to carry out her duties at the CIA, and to pursue her career at the agency in further service to her country, as she had planned. While no specific dollar amount is requested, the suit seeks compensatory damages, punitive damages and attorneys' fees and costs.
Coinciding with the filing of the Complaint, the Joseph and Valerie Wilson Legal Support Trust has been established. Funds from the trust will help the Wilsons pay the substantial legal costs forced upon them by the unlawful leaking of Mrs. Wilson's covert CIA status. The objectives of the trust include:
-- Counseling them in connection with their potential witness testimony during the upcoming trial of Scooter Libby; and
-- Helping them to prepare the civil suit that will uncover the truth surrounding the leak, ensure all relevant public officials are held accountable for actions depriving the Wilsons of their privacy and constitutional rights, and serve as a deterrent to similar wrongdoing being committed in the future.
The Trust was established with the Wilsons' approval and provides that should the suit result in a payment to the Wilsons in excess of their legal costs, they will reimburse the Trust for all legal costs paid by the Trust. That money will then be distributed by the trustees to a charitable organization(s) that works to protect the rights of government whistleblowers.
Contributions to the Joseph and Valerie Wilson Legal Support Trust can be given at www.wilsonsupport.org or sent to P.O. Box 40918, Washington, D.C. 20016-0918.
Neither the Wilsons nor their attorneys will comment on the civil suit today, but they will meet with the news media at 10:00 a.m. Friday at the National Press Club, 14th and F Sts.
Excerpts From the Complaint in Wilson v. Libby, et al.:
"The lawsuit concerns the intentional and malicious exposure by senior officials of the federal government of one such human source at the CIA, Valerie Plame Wilson, whose job it was to gather intelligence to make the nation safer, and who risked her life for her country."
"The Defendants reached an agreement to discredit, punish, and seek revenge against the Plaintiffs . . . . Said agreement was motivated by an invidiously discriminatory animus towards those who had publicly criticized the administration's stated justifications for going to war with Iraq."
"The Defendants chose not to address publicly, directly, and on the merits why they may have thought Mr. Wilson was wrong or unfair in his statements on the President's misstatements. Rather, they embarked on an anonymous 'whispering campaign' designed to discredit and injure the Plaintiffs and to deter other critics from publicly speaking out."
"But for Mr. Wilson coming forward, it is unlikely that the Administration ever would have acknowledged its error. The fact that the administration had to admit its mistake is one likely reason why the Defendants chose to attack the Wilsons"
"The Defendants fraudulently concealed the existence of the Plaintiffs' cause of action . . . by, among other things, giving false or misleading testimony to federal law enforcement personnel and/or the federal grand jury empanelled to investigate the unlawful publication of Plaintiff Valerie Plame Wilson's classified CIA employment . . . ."