THE LAWSUIT

The Fayetteville officers, defendants, and members found out about the lawsuit
when it was carried in the local newspapers.  The suit was not served to the
FYV6 until Valentine's Day, February 14, 1999.  They were given 20 days to
respond to the lawsuit.
The following is the text of the papers served on the 6 union officers and the 4
national unions.

IN THE WESTERN DISTRICT OF ARKANSAS
STATE OF ARKANSAS
Case Assigned to Hendren, Judge
Filed January 12, 1999
(Papers Served February 14, 1999)
Chris R. Johnson, Clerk
LINDA J. PATRICK
an individual
vs.
1.  Loren Adams, an individual
2.  Tom Trailer, an individual
3.  Jeff Barnes, an individual
4.  Jim Warford, an individual
5.  Dale Buchanan, an individual
6.  Mark Lucas, an individual
7.  National Association of Letter Carriers, a Union
8.  American Postal Workers Union, a Union
9.  National Rural Letter Carriers Association, a Union
10.  National Mail Handlers Union, a Union
Case No. 99-5009
Jury Trial Requested
COMPLAINT
__________
Comes Now the Plaintiff Linda Patrick, an individual, residing in the State of
Arkansas, who at the time of all relevant incidents cited herein was the
Postmaster for the Post Office facility located in Fayetteville, Arkansas.
This court has jurisdiction pursuant to 28 U.S.C. 1332, Diversity of
Jurisdiction.  The conduct complained of occurred within this district and the
defendant national unions have their principal places of business and their
places of incorporation in states other than Arkansas.
The Plaintiff was damaged by the actions of certain individual Defendants and
by the actions, ratification, knowledge and/or acquiescence of the Defendant
Unions cited herein.
The Defendant Unions, through the authority granted to the local officials of
the respective Unions and by actions of the Unions themselves, including but
not limited to the receipt of union dues from Arkansas members, the claims
that "the union" represents its local members' interests, the granting of
rights to "locals" to utilize the national name, logo and authority, their
presence within the state and specific actions in this case, have submitted to
the jurisdiction of this Court.
The individual defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford,
Dale Buchanan and Mark Lucas are residents of the State of Arkansas; in
addition their wrongful actions occurred within the State of Arkansas.
The National Association of Letter Carriers is a nationally organized Union
having its primary headquarters located in Washington, D.C.  This Union herein
referred to as NALC, has a local chapter/organization located in Fayetteville,
Arkansas and is known as National Association of Letter Carriers, Fayetteville
Local.
The American Postal Workers Union is a nationally organized Union having its
primary headquarters located in Washington, D.C.  This Union herein referred
to as APWU has a local chapter/organization located in Fayetteville, Arkansas
and is known as American Postal Workers Union, Fayetteville Local #667.
The National Rural Letter Carriers Association is a nationally organized Union
having its primary headquarters located in Alexandria, VA.  This Union herein
referred to as NRLCA has a local chapter/organization in Fayetteville,
Arkansas and is known as National Rural Letter Carriers Association,
Fayetteville Local.
The National Mail Handlers Union is a nationally organized Union having its
primary headquarters located in Washington, D.C.  This Union herein referred
to as NMHU has a local chapter/organization located in Fayetteville, Arkansas
and is known as National Mail Handlers Union, Fayetteville Local.
Loren Adams was the Editor/Publisher of the Local and representative of the
American Postal Workers Union.  The individual defendant was acting as an
individual in his own behalf or alternatively was acting in his position or
representative of APWU when he was committing the wrongful actions complained
of herein, including writing certain documents which resulted in damages to
the Plaintiff Linda Patrick.
Tom Trailer was the President of the Local and representative of the National
Association of Letter Carriers.  The individual defendant was acting as an
individual in his own behalf or alternatively was acting in his position of
representative of NALC when he was committing the wrongful actions complained
of herein resulting in damages to the Plaintiff Linda Patrick.
Jeff Barnes was President of Local #667 and representative of the American
Postal Workers Union.  The individual defendant was acting as an individual in
his own behalf or alternatively was acting in his position of representative
of APWU when he was committing the wrongful actions complained of herein
resulting in damages to the Plaintiff Linda Patrick.
Jim Warford was Acting President of Local #667 and representative of the
American Postal Workers Union.  The individual defendant was acting as an
individual in his own behalf or alternatively was acting in his position of
representative of APWU when he was committing the wrongful actions complained
of herein resulting in damages to the Plaintiff Linda Patrick.
Dale Buchanan was Steward of the Local and representative of the National
Rural Letter Carriers Association.  The individual defendant was acting as an
individual in his own behalf or alternatively was acting in his position of
representative of NRLCA when he was committing the wrongful actions complained
of herein resulting in damages to the Plaintiff Linda Patrick.
Mark Lucas was Steward of the Local and representative of the National Mail
Handlers Union.  The individual defendant was acting as an individual in his
own behalf or alternatively was acting in his position of representative of
NMHU when he was committing the wrongful actions complained of herein
resulting in damages to the Plaintiff Linda Patrick.
Each national Union listed herein as a defendant has authorized its local
representatives, particularly local officers and Stewards within each
respective union, to represent its local interests, to ensure that certain
policies are followed, and to carry out its particular agenda.
Each national Union listed herein as a Defendant has acquiesced to and/or
authorized its local representatives, particularly local officers within each
respective union, to commit acts and conduct activities, as well as to make
statements and publications for which the national union should be held liable
and responsible for - absent affirmative actions to prevent suspected wrongful
conduct by its respective local representative.
The individual Defendants and the Defendant Unions should each separately be
punished by an award for punitive and/or exemplary damages against each in the
amount in excess of $100,000.00 because their individual and common actions
demonstrate a reckless disregard for the rights of Linda Patrick and/or
evidence ill will, wanton, intentional and malicious conduct designed to harm
the Plaintiff Linda Patrick.  This type of activity if allowed to occur in the
future to others could cause immediate and irreparable harm without any
recourse.
The Defendants should be held jointly and severally liable for all damages
incurred by the Plaintiff due to the fact that many of the wrongful acts were
committed by all or more than one defendant in concert and contemporaneously.
Hereinafter when the Plaintiff is referring to all of the individual
defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford, Dale Buchanan
and Mark Lucas as a group acting to some degree in concert of action or
intention the Plaintiff will refer to this group as "the individual
defendants."
Hereinafter when the Plaintiff is referring to a specific individual Defendant
the Plaintiff will refer to the Defendant by using his specific name such as
"Defendant Adams."
First Cause of Action
SLANDER
The individual defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford,
Dale Buchanan and Mark Lucas knowingly and intentionally published false,
misleading and defamatory statements against and referring to Linda Patrick.
The Defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford, Dale
Buchanan and Mark Lucas each have verbally slandered the Plaintiff on various
occasions (specific times and dates to be revealed in discovery) causing Linda
Patrick damages.  These defendants also slandered the Plaintiff by verbally
endorsing a letter containing false information: this letter was then
published to numerous recipients, including but not limited to:  newspapers,
United States postal employees, union membership in the Fayetteville area,
union membership outside of the local Fayetteville postal area, United States
Postal Service, "USPS," management and to other persons not associated with
the United States Postal Service.
Defendant Unions became aware of these publications or alternately each Union
became aware of this publication through its representative.  Each Defendant
Union thereafter by its actions/inactions supported and ratified the conduct
of each of their respective local officials thereby joining in concert with
the individual defendants in any further publication of the false, slanderous
and misleading information.
The Plaintiff was an effective, efficient, caring and successful Postmaster
for the Fayetteville postal facilities until wrongful actions by the
Defendants interfered with her duties and caused her to be transferred.  One
or more of the individuals named as defendants had personal animosity against
Linda Patrick.  These individuals then utilized their positions within their
respective unions to act upon this motivation.  The Defendants' wrongful
actions were designed to slander and create distrust in the Postmaster Linda
Patrick within Union members, USPS management, USPS employees, the
Fayetteville community and others receiving the false, slanderous, misleading
and incorrect information.
The Defendants verbally slandered Linda Patrick in meetings, telephone
conversations, interviews and personal conversations during the period of
November 1996 through October 1998 causing Linda Patrick to suffer emotional
stress, physical/medical problems, financial loss, embarrassment and other
damages as further described in the "damages" paragraph at the end of this
complaint.  Plaintiff requests the Court incorporate in this cause, and other
causes, of action all damages set out herein and in the "damages" paragraph.

 Second Cause of Action
LIBEL
The Plaintiff herein incorporates each and every preceding paragraph of this
complaint and further alleges the following:
The Defendants, Tom Trailer, Jeff Barnes, Jim Warford, Dale Buchanan and Mark
Lucas signed and published at least one written defamatory statement
concerning the Plaintiff which caused the Plaintiff damage to her career,
emotional stress, physical/medical problems, financial loss, embarrassment and
other damages as further described in the "damages" paragraph at the end of
this complaint.  Plaintiff requests the Court incorporate in this cause of
action all damages set out herein and the "damages" paragraph.
The Defendants Tom Trailer, Jeff Barnes, Dale Buchanan and Mark Lucas each
signed as individuals, and as representatives of their respective
unions/associations a defamatory, false, inaccurate and misleading letter
dated Friday, July 17, 1998 which was addressed to Mr. Charles K. Kernan,
Vice-President, Southwest Area USPS, P.O. Box 224748, Dallas, TX 75222-4748.
This letters has a "receipt stamp" dated JUL 16 1998. "Vice-President Area
Operations Southwest Area".
This defamatory letter dated July 17, 1998 also has an "action stamp" on it
for "action" checked for the MGR, Human Resources for the Southwest Area.  The
Plaintiff worked within this Southwest Area and suffered direct harm to her
career as a result of the contents of this letter and the acts committed by
the Defendants including the outrageous mailing of this letter to a myriad of
recipients including federal government employees.
The same defamatory letter dated July 17, 1998 was published with the intent
to harm the Plaintiff to at least the following persons:
Thomas Ranft, Arkansas District Manager, USPS
William Henderson, Postmaster General of the United States
John Potter, Vice-President, Labor Relations, USPS
Senator Tim Hutchinson of Arkansas
Senator David Pryor of Arkansas, retired
Representative Asa Hutchinson of Arkansas
Representative John M. McHugh, Chairman, House Subcommittee on Postal Service
Representative Marshall Mark Sanford, Co-Chairman, House Subcommittee on
Postal Service
Steve Spencer, Post Office Operations Manager, Arkansas USPS
Cassandra Goodwin, EAP Counselor, Arkansas District
David King, Arkansas State Steward, National Rural Letter Carriers Association
Dennis Taff, Arkansas Postal Workers Union President
William Burrus, Executive Vice-President, APWU
Carl Casillas, National Business Agent, APWU
Bob Kessler, National Business Agent, APWU
This same defamatory letter misleads and deceives the readers in numerous ways
including, but not limited to, its outrageous attempt to equate the
Fayetteville Post Office facilities under the supervision of Postmaster Linda
Patrick with the "murderous atmosphere" at the Edmond, Oklahoma Post Office in
1986 and Royal Oak, Michigan in 1991.  The allegations within the letter dated
July 17, 1998 were false, inflammatory, defamatory and designed to harm Linda
Patrick.
The Defendants intentionally used incorrect and false information with the
malicious intent to immediately damage the career of Linda Patrick in this
same letter.
Additionally, the Defendants Tom Trailer, Jim Warford, Dale Buchanan and Mark
Lucas signed and published another libelous letter dated August 31, 1998, and
made other verbal and written communications including publications in
newspapers of defamatory information provided by the individual Defendants and
ratified by the Defendant Unions.
Third Cause of Action
INTENTIONAL INTERFERENCE with BUSINESS RELATIONSHIP
The Plaintiff herein incorporates each and every preceding paragraph of this
complaint and further alleges the following:
The Defendants Tom Trailer, Jeff Barnes, Dale Buchanan, Loren Adams, Jim
Warford and Mark Lucas were each knowledgeable of USPS procedures, USPS career
patterns and opportunities, as well as the procedures for filing grievances
against USPS management.
The individual Defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford,
Dale Buchanan and Mark Lucas knowingly and intentionally chose a course of
conduct designed to interfere with and/or destroy the business relationship
and/or employment contract and employment relationship and career path that
Linda Patrick had with USPS.
The individual Defendants with knowledge, ratification, apparent authority and
acquiesces of each of the Defendant Unions continued on a course of action
which caused the business relationship between the Plaintiff and USPS to be
irreparably interfered with and damaged.
The Defendants through their wrongful conduct caused emotional stress,
physical medical problems, financial loss, embarrassment and other damages as
further described in the "damages" paragraph at the end of this complaint.
Plaintiff requests the Court incorporate in this cause of action all damages
set out herein and in the "damages" paragraph.
Fourth Cause of Action
INVASION OF PRIVACY
The Plaintiff herein incorporates each and every preceding paragraph of this
complaint and further alleges the following:
The defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford, Dale
Buchanan and Mark Lucas, as well as the Defendant Unions, intentionally
committed acts which placed Linda Patrick in a false light, one which was
highly offensive to Linda Patrick and to any reasonable person.
The Plaintiff, contrary to wild allegations put forth by the defendants, was
effective, caring, efficient and successful as Postmaster of the Fayetteville
facilities until actions by the Defendants placed Linda Patrick in a false
light to USPS officials, Union members, USPS management, the Fayetteville
community and others who received misleading, false and incorrect information
relating to the Plaintiff and the work environment at the Fayetteville Post
Office.  False and incorrect information was not rescinded when an
investigation proved the allegations in the defamatory publications were false
and incorrect further damaging the plaintiff.
Linda Patrick has suffered emotional stress, physical medical problems,
financial loss, embarrassment and other damages as further described in the
"damages" paragraph at the end of this complaint.  The Plaintiff requests the
Court incorporate in this cause of action all damages set out herein and in
the "damages" paragraph.

Fifth Cause of Action
INTENTIONAL INFLICTION of EMOTIONAL DISTRESS
The Plaintiff herein incorporates each and every preceding paragraph of this
complaint and further alleges the following:
The individual Defendants Loren Adams, Tom Trailer, Jeff Barnes, Jim Warford,
Dale Buchanan and Mark Lucas committed the outrageous conduct referred herein
with the intent to cause severe emotional distress to Linda Patrick.  One
example of this conduct occurred with the defendants allege in the letter of
July 17, 1998 that "however, we can inform you that those under Ms. Linda
Patrick's regime face suffering:  repression of contractual and legal rights
and suspensions and terminations based on whimsical petty grounds."  etc.,
etc.  The Defendants not only condoned their prior misconduct, but went on to
say in a letter dated August 31, 1998 to Thomas K. Ranft and mailed to
numerous persons and officials that "with this communication the postal unions
of Fayetteville re-affirmed the letter to Charles Kernan  ... The Defendants
in these same letters outrageously attempt to equate the "murderous episodes"
in Edmond, Oklahoma and Royal Oak, Michigan with the Fayetteville facilities
without justification.
The USPS system, management and employees, look with horror upon the murderous
episodes referred to in these letters; therefore, the Defendants knew or
should have known that their libelous letter of July 17, 1998 and subsequent
actions would cause irreparable harm and severe emotional distress to Linda
Patrick.  The individual Defendants committed other wrongful acts and made
other publications with the intent to cause severe emotional distress in Linda
Patrick.
The Plaintiff Linda Patrick did in fact suffer severe emotional stress,
physical/medical problems, financial loss, embarrassment and other damages as
further described in the "damages" paragraph at the end of this complaint.
Plaintiff requests the Court incorporate in this cause of action all damages
set out herein and in the "damages" paragraph.
Sixth Cause of Action
The Plaintiff herein incorporates each and every preceding paragraph of this
complaint and further alleges the following:
The Defendants Tom Trailer, Jeff Barnes, Dale Buchanan and Mark Lucas
knowingly gave false information to the United States Postal System by sending
the letter dated July 17, 1998 to a federal agency, to wit:  Mr. Charles K.
Kernan, Vice-President Southwest Area USPS as described above which is a
violation of Federal Statute: Title 18 U.S.C. Par. 1001.
This statute, even though a criminal statute, establishes a minimal standard
and duty by which persons making statements to the United States government
agencies must adhere.  This duty is designed in part to protect innocent
persons from being damaged, in this case Linda Patrick.
The Plaintiff has been damaged by the false statements contained in the
letters by the very fact of these false representations being made to a senior
management official who would reasonably be concerned about the alleged
potentially "murderous" atmosphere in one of his facilities.
The Plaintiff immediately suffered irreparable harm to her career as well as
sustaining emotional stress, physical/medical problems, financial loss,
embarrassment and other damages as further described in the "damages"
paragraph.  Plaintiff requests the Court incorporate in this cause of action
all damages set out herein in the "damages" paragraph.
DAMAGES
The Plaintiff has suffered irreparable harm to her career in the USPS,
emotional distress, physical and medical symptoms as a result of emotional
distress caused by the Defendants' actions, financial loss in the form of lost
potential income and salary from not being in the same career development path
that she was in prior to the Defendants' actions, as well as expenses,
embarrassment, humiliation, loss of reputation, bonuses and other compensation
as well as larger retirement income which she would reasonably have attained
absent the Defendants' actions, medical expenses and other compensable damages
in excess of $100,000.
The actions of the Defendants, individually, jointly and severally demonstrate
a reckless disregard for the rights of the Plaintiff and/or demonstrate
malicious wanton, willful and intentional conduct designed to injure the
Plaintiff which should be punished by an award against each Defendant
separately in excess of $100,000 for exemplary and punitive damages.
WHEREFORE the Plaintiff prays judgment against each defendant separately,
severally and jointly in an amount in excess of one hundred thousand dollars
($100,000.00), prays for a judgment of punitive and exemplary damages in
excess of one hundred thousand dollars ($100,000.00) against each defendant,
costs, pre-judgment and post-judgment interest, any Equitable relief the Court
deems appropriate, attorneys fees and permission by this Court to amend these
pleadings as discovery proceeds.
JURY TRIAL DEMANDED
Attorney lien claimed
Verification Attached
Respectfully submitted,
Roland V. Funk, OBA #3182
Attorney for the Plaintiff
3314 E. 51st Street, Suite 206
Tulsa, OK  74135
(918) 585-8522
Respectfully submitted