INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

STATE

RECEIVED NYSCEF: 03/06/2018

OF

SUPREME

NEW YORK
COUNTY

COURT

JOHAN

G.

Monroe

County,

BLICKMAN,
New

OF MONROE

M.D.,
York

Index

No.:

Plaintiff

Plaintiff,

designates
as the

County
-vs-

The

for

basis

location

KATIA

KAPLAN-LIST,

Broward

County,

is the

tort

and

the

of Plaintiff.

SUMMONS

M.D.,

WITH
COMPLAINT

VERIFIED

Florida

of trial.

venue

of the

residence

Monroe

place

Defendant.

To

the

above-named

YOU
a copy

of

ARE

your

HEREBY

Answer,

on the

Appearance,

exclusive

of

Summons

is not

failure

Defendant:

the

to appear

or,

SUMMONED
if the

Plaintiff's

day

of

Complaint

attorneys

service

(or

delivered

personally

or answer,

to

judgment

is not

within

within

to

will

within

be taken

the

served

twenty

thirty

you

answer

with

State

against

in this

after

the

by

service

service

New

of

you

the

of this

is

and

York);

default

action

to serve

Summons,

after

days

the

this

days

(20)

(30)

Complaint

for

the

and

to serve

a Notice

Summons,

complete

in

relief

of

case

if

of

this

your

demanded

herein.

Dated:

March
Rochestdr,

5

FOX

EVANS

, 2018

New

LLP

York
By:
Jar

P.

Attorneys
100

for

Meridian

Rochester,
(585)

1 of 15

irt,

Esq.
Plaintiff
Centre

New

787-7000

York

Boulevard,
14618

Suite

300

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

STATE

RECEIVED NYSCEF: 03/06/2018

OF

SUPREME

NEW YORK
COUNTY

COURT

JOHAN

G.

BLICKMAN,

OF MONROE

M.D.,

VERIFIED

COMPLAINT

Plaintiff,
-vs-

Index

KATIA

KAPLAN-LIST,

No.:

M.D.,

Defendant.

The

Plaintiff,

Evans

attorneys,

Fox

Johan

G.

LLP,

as

for

and

his

"Plaintiff"

(hereinafter

M.D.

Blickman,

Complaint

in

the

or

"Blickman"),

above-captioned

by

his

alleges

matter,

as

follows:

At

1.

of

County

Monroe

2.
"Defendant"

of

all

and

Upon

or

times

hereinafter

State

New

of

information

is an individual

who

resides

in the

York.

and

"Kaplan-List"
"Kaplan-List"),

Blickman

mentioned,

the

belief,

is an individual

Katia

Defendant,

who

resides

in

the

Kaplan-List

of

County

(hereinafter

Broward

and

State

Florida.

FACTS

3.

Blickman

is a medical

doctor,

4.

Blickman

is

employed,

duly

licensed

by

the

of

State

New

York

to

practice

medicine.

of Rochester

University

and

as

an

Attending

(hereinafter

Physician

"URMC").

Blickman

also

of

Sciences,

Director

Imaging

currently

serves

of

the

as the

the

has

as a Professor

"UR")

at

and

of

University

Associate

Pediatric

Chairman

Radiology

2 of 15

been

in the

employed

School

Rochester

of Clinical

Division.

since

of Medicine

Medical

Services

with

2009,

and

Center

in the

Dentistry

(hereinafter

Department

the

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 03/06/2018

Upon

5.

General

in the

Hospital

month

each

at Golisano

September

a written

Upon

three

last

a Resident

Physician

rotations

(3)

of which

of

from

was

at Rochester

one

approximately

August

24,

(1)

through

2014,

UR

16,

was

within

fifteen

the

romantic

relationship

Blickman

UR

the

of

having

and

(hereinafter

that

days

of the

issuance

and/or

had

Upon

information

and

belief,

Kaplan-List

knew,

Upon

information

and

belief,

Kaplan-List

failed

Blickman

that

did

not

106").

Kaplan-List

106,

issued

concluding

"Policy

Policy

and

Complaint,

Decision"
Decision"),

"UR

to

(15)

another.

accusing

consensual

Policy

pursuant

belief,

Kaplan-

and

Complaint"
Complaint").

(hereinafter

Blickman

one

after

a letter

investigated

duly

2016

with

2016,

"UR

Discrimination

and

Decision

received

UR

belief,

and

information

June

Blickman

2016,

January

relationship

(hereinafter

September

and

sexual

UR

ended,

and

through

in or around

belief,

Kaplan-List

the

2014

and

Kaplan-List

Harassment

to appeal

of

reason

said

had

the

Decision.

to know,

of the

Decision.

11.

inter

about

on/or

Upon

10.

and

information

Sexual

9.

UR

with

between

relationship

opportunity

the

romantic

Kaplan-List

interactions

UR's

was

performed

September

a consensual

and

decision

violate

and

Hospital,

information

Blickman

8.

the

in

Upon

inappropriate

Kaplan-List

belief,

2014

approximately

involved

7.

between

Summer

Children's

From

were

and

2014.

19,

6.

List

information

alia,

found

that

the

between

relationship

Kaplan-List

to appeal

and

the

Blickman

UR

was

Decision,

consensual

which,

and

not

inappropriate.

12.

claims

against

13.

Thereafter,

and

for

nearly

the

next

16

months,

Kaplan-List

did

not

pursue

any

Blickman.

Joel

Seligman,

the

prior

of UR,

President

2

3 of 15

announced

his

resignation

as President

of

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

UR

on

RECEIVED NYSCEF: 03/06/2018

11,

January

information

and

of

a report

Verified

Complaint

through

the

Complaint

by

the

16.

No

17.

15,

February

commenced

15,

by

Defendant

of

negligent

State

as

by

Seligman's

Kaplan-List

that

resignation

attempted

Complaint"
Complaint")

with

the

to file

Monroe

A

System.

Filing

the

belief,

upon

was,

and

the

a lawsuit

by

of

the

a

filing

Clerk's

County

copy

public

Office

Kaplan-List

initial

filing

of

2018,

the

the

Kaplan-List

Complaint

was

Office.

about

with

Filing

the

required

the

15,

February

Electronic

filed

specifically

Blickman

UR

at

A.

Court

was

misconduct

of

filing

CPLR

the

was

re-

2018,

or

Complaint

System.

Kaplan-List

by

Kaplan-List

Complaint

§

Kaplan-List

304.

on

12,

January

no

Accordingly,

Complaint

on

action

12,

January

was

or

2018,

2018.

the

a "Notice

Frank

Complaint

of

Claim"

for:

(a)

was

the

sexual

Complaint

by

even

foregoing,

assault,

(b)

attaches

the

is

dated

(hereinafter

Esq.

Housh,

also

signed

Complaint

Notwithstanding

Blickman

Kaplan-List

counsel,

Kaplan-List

Kaplan-List

19.

against

York

Kaplan-List's

the

the

on/or

Additionally,

however,

before

Clerk's

2018,

18.

verified

County

Summons

against

February

and

sexual

after

day

Electronic

as Exhibit

and

on

Kaplan-List.

(1)

at UR,

Clerk's

information

New

the

and

"Kaplan-List

hereto

Monroe

a report

one

being

misconduct

County

Thereafter,

through

2018,

(hereinafter

Upon

of

release

to Blickman

12,

sexual

is annexed

rejected

filed

on

Monroe

15.

the

unrelated

belief,

On January

14.

release

after

2018,

what

Defendant

to

December

2018,

on January

"Housh"),

purports

on

12,

January

be

and

12,

a verification

21,

2017,

being

was

2018;

by

22

the

days

finalized.

the

sexual

Kaplan-List

harassment,

hiring/supervision/retention.

3

4 of 15

Complaint

(c)

alleges

respondeat

causes

superior

of

action

and

(d)

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 03/06/2018

20.

The

allegations

Blickman

32

of

22.

are

the

Kaplan-List

The

allegations

in

plead

Defendant

the

to

the

criminal

hire

with

replete

actions

sexual

into

to

that

include,

encounters,

and

Complaint

but

are not

requested

also

Kaplan-List's

malicious

false,

sets

boyfriend

limited

of

acts

forth

and

to,

kill

and

drugging

bestiality.

impertinent

to

defamatory

allegations

Blickman's

that

ex-wife.

See

Complaint.

impertinent

Kaplan-List

the

in

contained

and

infuriate

is

Kaplan-List

attempted

immaterial

obviously

action

her

Additionally,

that

and

of

coercing

21.

imply

Complaint

Blickman

accusing

Kaplan-List,

raping

¶¶31

Kaplan-List

to

the

and

and

32

of

the

remainder

further

and

Complaint,

community

31

Paragraphs

defame

the

of

Kaplan-List

allegations

evidence

Plaintiff

the

the

and

the

malicious

and

by

Complaint

causes

of

of

the

intent

through

the

Kaplan-List

Complaint.

23.

been

aware

at the

State

is not

commenced

2018,

statement

to

does

Blickman

not

public

lives

25.

that

the

and

Kaplan-List

the

of

filing

and

an

when

thus

was

aware

that

filed,

a legal

and/or

should

have

New

action

in

2018,

and

York

a Summons.

as filed

Complaint,

commence

was

attorney,

practicing

Complaint

Kaplan-List

which,

record

As

the

legally

and

admitted

without

Kaplan-List,

by

become

time

Although

24.

15,

as a duly

Housh,

action

it was

published

under

with

filed

to

a third

on

CPLR

the

the

§ 304,

Monroe

to

party,

12,

January

same

County

wit,

the

does

constitute

was

Clerk,

February

community

intended

in

which

works.

a result

of

the

foregoing,

no

privilege

attaches

to the

statements

set

forth

in the

Complaint.

Kaplan-List

DEFENDANT'S

BY THE
26.

Upon

information

and

CLAIMS

BARRED

OF LIMITATIONS

STATUTES

belief,

ARE

a Summons

4

5 of 15

was

issued

by

Housh,

on

March

2, 2018,

a

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

and

the

RECEIVED NYSCEF: 03/06/2018

thereafter

New

Exhibit

filed

York

a duplicate

State

Court

Each

and

of

copy

Electronic

the

Kaplan-List

A

System.

Filing

Complaint

of the

copy

on

that

same

through

date

Summons

is annexed

Kaplan-List

Complaint

hereto

as

B.

27.

Blickman

are

barred

28.

August

3, 2014.

to have

was

in

in

in/or

around

State

of

alleged

the

the

on/or

alleged

set

forth

within

in

Blickman

that

Kaplan-List

the

2 of the

Article

drugged

and

against

CPLR.

raped

Kaplan-List

on/or

about

the

action

Complaint.

is an allegation

foregoing

before

August

of

CPLR

assault,

3, 2015,

within

being

requires

§ 215(3)

one

of

year

(1)

the

date

said

occurred.

no

other

Kaplan-List

specific

at which

2016;

date

the

Complaint,

of

other

any

alleged

between

relationship

upon

point,

year

have

Kaplan-List

Accordingly,

for

information

assault

or intentional

Kaplan-List

and

and

Blickman

Kaplan-List

belief,

tort

is set

ended

moved

to the

assault,

from

battery,

the

last

or

point

any

in time

was

other

required

to

tort

to

legally

intentional

the

accusations

action

for

prior

contained

commence

end

of

an

action

of

January

within

the

Kaplan-List

tort

alleged

in

against

2017,

being

Complaint

accrued.

32.

Complaint

Thus,

any

is untimely

33.

Resident

limitations

the

to have

January

action

Connecticut.

Blickman

could

of

Although

31.

(1)

¶21

See

commenced

30.

forth

time

of

it is alleged

Because

been

assault

the

by

cause

every

Specifically,

29.

one

with

34.

pursuant

at

Therefore,

URMC
the

CPLR

to

and

Additionally,

Physician

of

cause

as

on/or

statutes

of

intentional

the

Kaplan-List

§ 215(3).

set

previously

ended

an

about

forth

herein,

September

limitations

for

5

6 of 15

the

19,

Kaplan-List's

last

rotation

as

2014.

commencement

of

any

cause

of

action

a

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

for

RECEIVED NYSCEF: 03/06/2018

harassment

sexual

three

from

years

(3)

with

the

Monroe

a Summons

the

on

Office

rotation

September

as a Resident

was

and

12, 2018,

19,

Physician

Complaint

Kaplan-List

on January

and

information

familiar

fully

the

about

on/or

URMC

at

filed

without

being

ended.

a Summons

then

and

15, 2018;

February

2017,

with

2, 2018.

Upon

be,

last

foregoing,

Clerk's

March

terminated

Kaplan-List's

date

County

36.

should

the

Despite

35.

discrimination

and/or

with

belief,

all

applicable

and

upon

as a licensed

Housh,

statute

of limitation

and

attorney,

practicing

periods

set forth

or

is,

2 of the

in Article

CPLR.

37.

Additionally,

Kaplan-List

Law

296

§

is

discrimination

years

of

the

of

cause

2 of the

Article

requirements

medical

of

the

intent

profession,

against

plead

such

a cause

to CPLR

of

an

of

action

the

that

employer

time

New

for

must

be

of

York

sexual

the

of

filing

Executive

State

harassment

commenced

within

and

three

Blickman

were

salacious

and

true

factually

within

the

contained

allegations

(3)

and

Kaplan-List

correct

in

(which

Complaint

the

are

they

is prohibited

(a)

2 of

and

the

maliciously

and

(b)

CPLR

and

defame

monetarily

Kaplan-List

belief,

proceeded

Blickman

capitalize

by

and

willfully

with

and

his

the

false

filing

the

reputation

and

ignored

intentionally

Kaplan-List

within

salacious

Complaint

the

community

accusations

Additionally,

upon

information

and

belief,

6

7 of 15

in

fulfilling

her

intent

to

the

with

and

contained

therein.

40.

the

§ 214(2).

false,

Blickman

aware

been,

malicious,

against

information

Article

to:

the

have

at

belief,

CPLR.

Upon

of

if

and

liability

pursuant

even

action

for

claim

plead

should

creates

action

any

Complaint

any

clear

that

or

was,

which

Therefore,

39.

the

statute

accrual

Kaplan-List

by

a

and

38.

not),

Housh

Complaint,

information

maliciously

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

defame

RECEIVED NYSCEF: 03/06/2018

it

Blickman,

with

Complaint

Monroe

would

and

County,

41.

media

Complaint

was

the

then

Blickman

AS AND

in

forth

the

of

filing

discovered

the

Kaplan-List

media

by

the

or

about

in

Monroe

this

in

endeavor,

York

that

published

publicized

and

false

the

on

and

reported

March

that

salacious

the

1, 2018,

Kaplan-List

allegations

contained

Complaint.

AGAINST

plead

and

be

would

New

County,

that

media.

in

successful

in Monroe

against

that

by

hopeful

was

Office

Clerk's

was

Kaplan-List

42.

Kaplan-List

be published

outlets

filed

that

County

Kaplan-List

numerous

within

clear

is

Blickman

Paragraphs

FOR

THE

FIRST

repeats

1-41

and

above

as if

CAUSE

FOR

KAPLAN-LIST

realleges

each

each

and

OF

ACTION

AND

DEFAMATION
and

allegation

every

every

allegation

through

the

LIBEL

set

heretofore

forth

therein

previously

is more

set

fully

herein.

Upon

43.

made

false

and

Clerk's

and

belief,

statements

defamatory

Upon

44.

County

information

information

on

Office

and

Kaplan-List

and

2018,

Kaplan-List

Complaint,

Blickman.

regarding

the

belief,

12,

January

fact

of

Kaplan-List

Complaint

15,

February

was

and

2018,

filed

thus

with

was

the

Monroe

published

to

third-party.

As

45.

and

and

46.

Ten

at the

his

within

the

and

of trial;

attorneys'
fees,

that,

Monroe

of

publication

inter

alia,

County

Dollars

Blickman

costs

and

the

his

Kaplan-List

for

damages

or

($10,000,000.00),

is further

expenses

entitled

with

employer,

with

such

7

8 of 15

his

and

suffered

to an award

associated

his

is permanently

community

Blickman

Complaint,

reputation

is liable

Kaplan-List

00/100

and

the

in

Accordingly,

Million

time

of

to be injured,

continues

profession,

of

a result

other

by

amount

of punitive

defense

of

the

within

irreparably

Blickman

as may

damages,

Kaplan-List

was

injured,

the

medical

harmed.

in the

amount

be determined

together

with

Complaint

a

 INDEX NO. E2018001329

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NYSCEF DOC. NO. 1

as well

RECEIVED NYSCEF: 03/06/2018

prosecution

as the

of

AS AND

this

FOR

matter.

A SECOND
FOR

KAPLAN-LIST

47.

in

plead

forth

Blickman

Paragraphs

knowledge

Upon

of

the

49.

each

within

AND

each

and

and

AGAINST

LIBEL

PER

allegation

every

allegation

every

set

forth

SE

heretofore

therein

previously

is more

fully

set

suffered

As

punitive

Kaplan-List

53.

in

of

false

and

Kaplan-List

Kaplan-List

by

contempt,

claims

means

of

Blickman

Complaint

by

and

ridicule,

filed

with

the

and/or

aversion,

Kaplan-List

by

with

the

dealt

Monroe

disgrace.

and

specifically

a living.

earning

in

medical

the

with

profession,

criminal

fraud,

imputing

together

at the

with

Blickman

his

1-52

above

libelous

and

of

00/100

and

trial;

fees,

Blickman

prosecution

as the

FACIE

and

each

realleges

each

of

his

action,

employer,

dishonesty,

and

every

8

9 of 15

Blickman

Kaplan-List,

or such

($10,000,000.00),

is further

expenses

this

OF ACTION

CAUSE

FOR PRIMA

as if

and

costs,

of

conduct

Dollars

attorneys'

THIRD

repeats

Million

time

as well

THE

and

defamatory

of Ten

determined

FOR

Paragraphs

the

community

the

amount

Complaint

AND

made

to public

affected

County

a result

be

damages,

AS

business

allegations

in the

as may

of

the

unfitness.

damages

amount

Blickman

filed

therein.

allegations

matter

Monroe

and/or

52.

exposed

Defendant

belief,

contained

written

subject

Said

the

misconduct,

and

Blickman's

51.

plead

ACTION

DEFAMATION

realleges

as if

accusations

false

The

with

exclusively

false

Office

50.

the

above

information

The

Clerk's

County

of

1-46

and

OF

herein.

48.

and

repeats

CAUSE

entitled

associated

to

with

an

his

other

award

of

defense

matter.

AGAINST

KAPLAN-LIST

TORT
and

every

allegation

allegation

set

forth

heretofore

therein

is more

previously

fully

set

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 03/06/2018

herein.

forth

54.

against

List

information

Upon

were

Blickman

Complaint

false

the

with

and

and

belief,

barred

Monroe

the

by

relevant

Clerk's

County

with

Kaplan-List,

of

statutes

on

Office

that

knowledge

12,

allegations

filed

limitations,

January

her

and

2018,

Kaplan-

the

15,

February

2018.

55.

an act

that

The

is otherwise

56.

Complaint

List

reputation

and

him

cause

determined

together

information

was

to maliciously

his

of

Ten

at the

with

his

Kaplan-List

and

and

job,

of

time

medical

the

of

List's

Kaplan

and

forth

in

fees,

as the

Blickman

costs,

to

be

Office

is

of this

repeats

1-57

above

as if

each

each

and

an

economic

with

has

suffered

such

amount

of

his

defense

his

damaging

in the

award

Kaplan-

the

loss,

future.

in

damages

as

punitive

of

may

be

damages,

the

Kaplan-

matter.

OF ACTION

every

AGAINST

OF PROCESS

ABUSE

realleges

and

or

associated

and

medicine

Blickman

to

by

financial

($10,000,000.00),

CAUSE

FOR

Blickman

practicing

entitled

of

filing

and

allegation

every

allegation

set

forth

heretofore

therein

previously

is more

fully

her

allegations

set

herein.

59.

against

Clerk's

County

upon

him

behavior,

expenses

FOURTH

THE

from

is further

and

prosecution

FOR

Blickman

Paragraphs

Monroe

Defendant's

cause

him

Dollars

the

harm

profession,

malicious

00/100

and

trial;

inflict

prevent

KAPLAN-LIST

plead

the

of

purpose

intentionally

attorneys'

as well

the

to otherwise

Million

AS AND

58.

with

Complaint

belief,

and

within

a result

As

Complaint

List

Upon

to lose

amount

the

legal.

relationship

57.

the

of

filing

Blickman

issued,

Upon

were

process

information

false

by

the

and

and

barred

filing

the

belief,

by

with

Kaplan-List,

the

relevant

Kaplan-List

statutes

Complaint

9

10 of 15

knowledge

of limitations,

with

the

that

issued,

Monroe

and/or

caused
Clerk'

County

s

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

Office

on

RECEIVED NYSCEF: 03/06/2018

12,

January

Upon

60.

Kaplan-List

Upon

Complaint

in

a perverted

Blickman

to harm

and

belief,

Kaplan-List

to

obtain

the

manner

of

Defendant

the

belief,

an intent

information

reputation

the

harming

with

and

2018.

15,

February

information

Complaint

61.

and

2018,

Blickman

and

to

without

used

collateral

excuse

the

caused

to

be

the

filed,

or justification.

of filing

process

objective

a financial

receive

and/or

filed,

of

the

defaming,

windfall

that

Kaplan-List

and

slandering

she

is not

otherwise

entitled.

62.

Million

As

and

00/100

Dollars

Blickman

trial;

and

fees,

costs,

and

prosecution

of

expenses

this

in

forth

entitled

has

or such

($10,000,000.00),

to an award

with

associated

FOR

THE

FIFTH

his

suffered

amount

of

the

amount

be determined

together

damages,

the

in

damages

as may

of punitive

defense

Kaplan-List

of

at the

with

Ten

of

time

attorneys'

his

Complaint

and

above

realleges

as if

each

each

and

AGAINST

as well

as the

KAPLAN-LIST

OF EMOTIONAL

INFLICTION

repeats

1-62

Paragraphs

OF ACTION

CAUSE

INTENTIONAL

Blickman

and

allegation

every

allegation

every

DISTRESS

set

forth

as

it

heretofore

therein

previously

is more

set

fully

herein.

64.

Kaplan-List's

Kaplan-List

Kaplan-List

of

disregard

66.

emotional

malicious

constitutes

Complaint

65.

physical

Blickman

foregoing,

matter.

FOR
63.

the

is further

AS AND

plead

of

a result

injury

and

said

harm

of

extreme

severe

that

and

but

conduct

outrageous

extreme

causing,

emotional

includes,

salacious

and

said

likelihood

Kaplan-List's

and

extreme

undertook

a substantial

distress

and

and

Blickman

distress

is not

has

limited

10

11 of 15

to

the

filing

of

with

the

intent,

the

conduct.

outrageous

severe

conduct

outrageous

relates

conduct

emotional

has

manifested

to,

loss

of

distress.

caused

itself

or the

into

appetite,

Blickman

Blickman

loss

of

severe

suffering

weight

and

 INDEX NO. E2018001329

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NYSCEF DOC. NO. 1

loss

RECEIVED NYSCEF: 03/06/2018

sleep.

of

As

67.

Million

and

00/100

Dollars

and

fees,

costs,

and

prosecution

of

this

FOR

Blickman

foregoing,

entitled

has

or such

($10,000,000.00),

with

his

amount

defense

of

damages

suffered

of punitive

to an award

associated

expenses

AND

AS

the

is further

Blickman

trial;

of

a result

as may

the

together

Kaplan-List

of

amount

be determined

damages,

the

in

at the

with

time

of

attorneys'

his

as well

Complaint

Ten

as the

matter.

FOR

THE

SIXTH

TORTIOUS

OF ACTION

CAUSE

WITH

INTERFERENCE

AGAINST

KAPLAN-LIST

PROSPECTIVE

BUSINESS

RELATIONSHIPS

Blickman

68.

plead

forth

in

Paragraphs

1-67

and

above

realleges

as if

each

and

belief,

each

and

and

allegation

every

allegation

every

set

heretofore

forth

therein

previously

is more

set

fully

herein.

Upon

69.

Kaplan-List

for

repeats

was

information

third-parties

those

that

Blickman

based

upon

aware

was

at the

time

routinely

Blickman's

that

hired

the

Kaplan-List

stature

experience,

to perform

third-parties

by

and

was

Complaint

reputation

filed,

certain

in

the

tasks

medical

profession.

70.

These

and

lecturing

moderating

Complaint

are

Complaint

73.

opportunities

objectively

Kaplan-List's

to

provide

third-parties

and

malicious

was

undertaken

Kaplan-List's

72.

from

but

include,

are

in

no

limited

way

to,

at seminars.

Kaplan-List's

71.

Kaplan-List

opportunities

for

allegations

false

and

services

the

has

to

sole

purpose

as

third-parties

and

continues

including,

11

12 of 15

it

relates

to

the

filing

of

the

Blickman.

forth

set

in

the

Kaplan-List

wrongful.

independently

caused

as

of harming

Blickman

against

otherwise

conduct

conduct

salacious

but

to

cause

not

limited

Blickman

to,

lecturing

to

lose

and

 INDEX NO. E2018001329

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NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 03/06/2018

at seminars.

moderating

74.

Million

and

As

a result

00/100

Dollars

Blickman

trial;

and

fees,

costs,

prosecution

and

of

of

the

is further

expenses

the

As

for

and

against

the

Dollars

time

of

fees,

costs

As

First

of

damages

as may

of punitive

G.

the

in

the

amount

be determined

together

damages,

Kaplan-List

Blickman,

of

at the

with

Ten

of

time

attorneys'

his

as well

Complaint

judgment

demands

M.D.,

and

as well

the

Second

as the

to

awarding

and

at the
attorneys'

and

for
the

00/100

the

fees,

costs

and

for
the

00/100

the

of

fees,

costs

and

a Money

Cause

the

of

Katina

as an

Fifth

Judgment

as the

prosecution

Cause

of Action

against

the

with

prosecution

of

Prima

Facie
for

the
this

sum

damages,

with

Plaintiff's

defense

the
this

matter;

for

Abuse

of

M.D.,

for

other

sum

amount

as

sum

of

of

the

of

and

Kaplan-List

Judgment

Ten

damages,

with

Plaintiff's

defense

of

13 of 15

Million

be determined
at the
attorneys'
with
all

with

12

defense

Judgment

Ten

together

Defendant,

be

matter;

as may

for

Ten

may

Plaintiff's

amount

this

of

together

a Money

Process,
the

a Money

Se,

the

punitive

of

Kaplan-List

a Money

Tort,
the

together

the

and

at the
attorneys'

damages,

as may

or such

associated

punitive

associated

other

Kaplan-List,

of

of

award

other

amount

Action

all
the

Per

for

punitive

of

award

such

M.D.,

or such
of

award

prosecution

expenses

as well

for

Kaplan-List,

($10,000,000.00),

and

for

Libel

M.D.,

or

as an

Action

of

and

Kaplan-List,

as the

Million

be determined

matter;

Defamation

for

expenses

associated

as the

Fourth

as well

trial;

Complaint

as an

Defendant,

Dollars

time

and

Katina

expenses

as well

of

as well

($10,000,000.00),

and

with

defense

as well

Cause

as well

trial;

Complaint

Third

together

this

Judgment

Ten

damages,

the

($10,000,000.00),

costs

of

Plaintiff's

Action

trial;

sum

punitive

Katina

Complaint

Defendant,

Dollars
of

against

of

fees,

time

As

Dollars
time

Kaplan-List

against

As

00/100

the

with
of

Defendant,

for

M.D.,
other

a Money

Libel,

as may

prosecution

of

and

amount

of

award

Cause

the

Defamation

or such

associated

as the

against

determined

As

as an

expenses

for

Kaplan-List,

($10,000,000.00),

Million

all

Action

Katina

as well

trial;

of

Cause

Defendant,

for

and

of the

(e)

amount

defense

his

Johan

Plaintiff,

the

00/100

with

(d)

with

suffered

relief:

Judgment

(c)

or such

to an award

associated

Complaint

(b)

entitled

has

matter.

this

following

(a)

Blickman

foregoing,

($10,000,000.00),

WHEREFORE,
him

the

Million

be determined
all
the

and

at the
attorneys'

Kaplan-List

matter;

Intentional
Katina

Infliction
Kaplan-List,

of Emotional
M.D.,

Distress,
for

the

sum

 INDEX NO. E2018001329

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NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 03/06/2018

of

Ten

Million

and

Dollars

00/100

of trial;
be determined
at the time
as well
as an award
attorneys'
costs
and
with
all
expenses
associated
fees,
of

(f)

Kaplan-List

the

As

for

and

Business
M.D.,

for

such

other

amount

of

March
Rochester,

Sixth

List,

with

Dated:

the

For

5_,

the
this

Cause

sum
as may

damages,

together

Plaintiff's

defense

matter;

such

the

other

as well

of

of

as the

Action

a Money

Relationships,

punitive

(g)

Complaint

Ten

with

the

00/100

Dollars
of trial;

of the

and

Kaplan-List

costs

with

defense

Prospective
Kaplan-

Katina

or

($10,000,000.00),
as well
and

as an award

expenses

as well

Complaint

together

matter;

Defendant,

be determined
at the time
attorneys'
with
all
fees,

as may

Plaintiff's

Interference

against

amount

damages,

the

of this

Tortious

for

Million

of punitive

prosecution

Judgment

other

or such

($10,000,000.00),

as the

associated
prosecution

and

and

further

relief

that

this

Court

to be just

deems

and

proper.

2018

New

York

FOX

EVANS

LLP

By:
Jar

P.

Attorneys
100

Meridian

Rochester,
Telephone:

13

14 of 15

irt,
for

Esq.
Plaintiff
Centre

New
(585)

York

Boulevard,
14618

787-7000

Suite

300

of

 INDEX NO. E2018001329

FILED: MONROE COUNTY CLERK 03/06/2018 03:20 PM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 03/06/2018

VERIFICATION

STATE

NEW

OF

YORK)
OF MONROE)

COUNTY

JOHAN

I,
Plaintiff
contents
stated

in

the

G.

ss.:

BLICKMAN,

above-entitled
that

thereof;
to be alleged

being

duly

that

I have

read

action;

the

upon

M.D.,

same
information

is

true

to
and

my
belief,

own
and

to before

5 +

day

o ary

Pubhc

of

2018.

JARED P. HIRT
Notary Public, State of New York
Monroe County, REG #02Hl6125021
My Commission Expires April 4, 20~

15 of 15

depose

foregoing

aspthos

me this
March,

the

knowledge,

OHAN

Sworn
5'

sworn,

G.fLICKMAN,

except
matte

and

say

Complaint
as to

the

I believe

M.D.

that
and
matters
them

I

am

know

the
the

therein
to be true.