Nature of Action
This is a civil action pursuant to Title 42 USC secs 1983 (violation of civil rights), 1985 (conspiracy), and 1986 (neglect to prevent).
The facts and circumstances described herein below arise out of circumstances surrounding the implementation and operation of Catfish Services BlackBook (hereinafter, CFS). CFS was a wireless method designed and intended to locate sex offender fugitives and disrupt the business of street level prostitution.
In July 2016, CFS began conducting real world tests to construct the aforementioned wireless method into an automated system, in the Dothan/Taylor Alabama area. The real world test were accomplished by posting “women looking for men” ads on those websites that were utilized by street level prostitutes to communicate with men who were looking for sexual favors with drug addicted prostitutes'. On July 24, 2016, CFS posted an ad in the then personals section of Craigslist. The post ended with the name "Ms. Peggy"".
In response, CFS received emails from men who wanted a woman to perform anal sex on them with a dildo. One of the men turned out to be a captain who was stationed at a nearby Army base (Ft. Rucker). At the time, plaintiff was unaware that "peggy" was a play on "pegging" - a sexual fetish where men desire women to anally penetrate them with a dildo. Plaintiff did not know the name would be construed as an "invitation" or implication that the intent of the post was amenability to a particular sexual fetish. Plaintiff did not know CFS would receive compromising photographs of men in women's lingerie, heels, lipstick, etc.
The captain (5'-7" - 5'-8", 170, white hair parted on the left, blue eyes, clean shaven, sounds like “Charlie” from “Charlie’s Angels”) sent pictures of himself dressed in women's lingerie, heels, lipstick and had his own ten inch black dildo that he wanted a woman to use on him. On July 24, 2016, between 1p - 3p, the captain arrived 3028 Nottingham Way, Dothan, Alabama for the purpose of meeting up with who he thought was going to be woman for his fetish time. He met the plaintiff instead.
The captain was visibly embarrassed, upset and angry. That same night, the Dothan Alabama police department visited plaintiff in Taylor Alabama inquiring about the photographs. Plaintiff assured the police that he did not have the compromising.
On July 25, 2016, an enlisted man visited plaintiff in Taylor Alabama for the purpose of finding out if plaintiff had the pictures. Plaintiff allowed the enlisted man to search his computer. The pictures were not found.