COMMONWEALTH OF MASSACHUSETTS
COMPLAINT AND JURY DEMAND ON ALL COUNTS
This arises out of a relationship between a woman and a man. The woman, the defendant here, wanted a "serious" relationship and the man, the plaintiff here, wanted a friendship. The plaintiff was in the middle of a divorce and a serious relationship was premature. Feeling scorned and rejected and wanting more attention, the woman began threatening the man and writing defamatory things about him to diverse people, including friends of his. Ultimately, the woman began talking defamatorily to the attorney for the man's wife and then with the guardian ad litem.
By her actions, defendant intentionally inflicted emotional distress on the plaintiff, John Smith.
1. Plaintiff John Smith ["Smith"] is a natural person residing at 00 XXXXX Road, TOWN, County, Massachusetts 00000-0000; was a resident of TOWN, Massachusetts. during all relevant times of this action; is married to Pocahontas Doe Smith; and is the biological father of Zach Doe Smith and John Doe Smith.
2. Defendant MEDUSA ['MEDUSA"] is a natural person residing at 00 YYYYYY Street, CITY, County, Massachusetts, 00000; was a resident of CITY, Massachusetts, during all relevant times of this action; and is unmarried.
COUNT 1: DEFAMATION
3. Smith repeats and realleges and incorporates by reference the allegations in paragraphs 1 and 2 above with the same force and effect as if herein set forth.
4. Defendant MEDUSA published one or more oral and written false statements which were intended to impeach Plaintiff Smith's honesty, integrity, virtue, or reputation.
5. The defamatory
including, but not limited to, the following:
b. "Johnny is mean, he doesn't have the heart of gold that everyone thinks he does," Thursday, 15 March 2001 at 07:57:46;
c. "I'm concerned about him parenting the boys," Thursday, 15 March 2001 at 07:57:46;
d. "I don't think Johnny is telling either of you the truth," Monday, 12 March 2001 at 03:36 PM and republished Thursday, 15 March 2001 at 07:57:55;
"Johnny did something TODAY that is going to hurt his kids GREATLY. If
you knew about it ahead of time, you should have stopped him. If you don't
should ask him what he's up to before telling ME where to go...He's
at this point. He's
f. "Johnny DID do something yesterday that was really bad for his kids, it has nothing to do with me and him. If you want to be a friend to HIM, you should ask him about it and suggest that he retract his actions, immediately, somehow. He's already made it so he's lost visitation effective immediately. And I think he's ALREADY dug his own grave on the whole case. And, I know all this for a FACT, it's not my opinion.
"Why aren't I telling Johnny all this? Because somehow he's gone off the deep end and won't listen to reason anymore." Published on Tuesday, Mar 13, 2001, 1:34 AM and republished on Thursday, 15 Mar 2001 07:58:06;
g. "Johnny has shown me directly that he can lie while looking me straight in the face, be controlling, vengeful, neglectful, manipulative, emotionally unstable, have a horrible temper, and most of all be very self-centered. . . .
"He has asked me to write lies when writing documents, and to write things that never happened, while angrily telling me that I just don't remember it correctly. I've had to show him documentation to the contrary, at which point he has told me to destroy it. I am not an attorney, and do not know what position this puts me in now. I hope that I will not need my own attorney, I cannot afford one. BUT, I refuse to lie for him anymore." Published Monday, 19 February 2001 at 14:54:00;
h. "Briefly, Johnny has just yesterday brought certain allegations to the court's attention that are going to be very traumatic to his boys, and it's going to deny him visitation altogether, and maybe any chance at custody. I've already made a few phone calls, and because I have shared my knowledge of Johnny's actions, I'm told I will probably be subpoenaed.
"Johnny has pushed me away and will not listen to why his actions were wrong. I think he's become desperate, and I am wondering if someone from the Fathers' Group can try to call him. I am afraid that he has resorted to other than honest or ethical t