Case 1:19-cv-00329 Document 1-1 Filed 06/18/19 Page 1 of 5 PageID #: 4 STATE OF R‘HODE ISLAND AND PROVIDENCE PLANTATIONS WASHINGTON COUNTY, SC SUPERIOR COURT KATHRYN NARCISI FLA INTIF’F, CA VS. NO. WC-2019- VVVUVVVVV TURTLEBOY DIGITAL MARKETING, LLC D/B/A TU RTLEBOYSPORTS.COM DEFENDANT VERIFIED COMPLAINT NATURE 0F THE ACTION THIS Is A CIVIL ACTION SEEKING To PERMANENTLY ENJOIN THE DEFENDANT, TURTLEBOY DIGITAL MARKETING, LLC (HEREINAFTER “TURTLEBOY”) FROM CONTACTING, ASSAULTING, CYBERBULLYING, SLANDERING, MOLESTING, BULLYING, LIBELING, STALKING, HARASSING, MALIGNING 0R CYBERSTALKING, THREATENING, OTHERWISE ANNOYING, INTERFERING WITH PLAINTIFF AT HOME, AT WORK, THROUGH THIRD PARTIES, 0N THE STREET, OVER THE INTERNET, 0R ELSEWHERE. PLAINTIFF SEEKS INJUNCTIVE RELIEF PURSUANT To RULE 65 0F THE RHODE ISLAND SUPERIOR COURT RULES 0F CIVIL PROCEDURE. PLAINTIFF’S SEEK DAMAGES 'ro IN ADDITION, THE EXTENT THEY ARE AVAILABLE FOR VIOLATIONS 0F ANY INJUNCTIVE. RELIEF GRANTED IN CONNECTION HEREWITH AND APPROPRIATE ATTORNEY’S FEES. ll. PARTIES PLAINTIFF, KATHRYN NARCISI, Is A RESIDENT 0F THE COUNTY OF WASHINGTON AND STATE OF RHODE ISLAND. EXHIBIT A TOWN 0F HOPKINTON, Case 1:19-cv-00329 Document 1-1 Filed 06/18/19 Page 2 of 5 PageID #: 5 4. DEFENDANT, TURTLEBOY, BUSINESS LOCATED IN Is A CORPORATION WITH A PRINCIPLE PLACE 0F THE CITY 0F WORCESTER, COMMONWEALTH 0F MASSACHUSETTS. STATEMENT 0F THE FACTS Ill. 5. PLAINTIFF Is A BUSINESS OWNER IN THE STATE 0F RHODE ISLAND OPERATING Two BUSINESSES OVER THE INTERNET CALLED “Hls AND HER SECRETS” AND “AN AMERICAN TREASURE”. 6. PLAINTIFF HAS MULTIPLE PLACEMENTS 0N THE INTERNET BOTH PERSONAL AND BUSINESS RELATED 0N PLATFORMS WHICH INCLUDE, BUT ARE NOT LIMITED To, FACEBOOK, TWITTER, AND INSTAGRAM, WHICH HAVE THOUSANDS 0F FOLLOWERS. 7. IN FEBRUARY 201 9, PLAINTIFF BECAME AWARE 0F A BLOG THAT WAs POSTED To THE INTERNET 0N THE BLOG www.TURTLEBOYSPORTs.COM, THE DEFENDANT’S WEBSITE (“HEREINAFTER “TURTLEBOYSPORTs.c0M”) WHICH DEFAMED AND DISCREDITED THE PLAINTIFF AND HER BUSINESS ENTITIEs; 8. THAT PLAINTIFF HAs NEVER COMMUNICATED WITH DEFENDANT IN REGARDs To THIS DEFAMATORY POST; 9. PLAINTIEF BEGAN To RECEIVE REPEATED EMAIL MESSAGES, COMMENTS, PRIVATE MESSAGES, SOLICITED, 1o. TEXTS, AND OTHER COMMUNICATIONS, NEITHER WANTED NOR FROM FOLLOWERS 0F THE DEFENDANT’S WEBSITE; PLAINTIFF HAs RECEIVED HUNDREDS 0F MESSAGES FROM THE DEFENDANT’s FOLLOWERS, BETWEEN THE DATES 0F FEBRUARY 2019 UNTIL PRESENT. 11. THAT THE COMMUNICATIONS ARE UNWANTED As PLAINTIFF HAS NEVER RESPONDED To THESE MESSAGES. 12. THAT THESE MESSAGES HAVE ALL BEEN SENT To PLAINTIFF’s EMAIL ADDRESS, SOCIAL MEDIA ACCOUNTS, AND EVEN CELL PHONE; Case 1:19-cv-00329 Document 1-1 Filed 06/18/19 Page 3 of 5 PageID #: 6 13. THAT THESE ELECTRONIC COMMUNICATIONS FROM THE DEFENDANT’s FOLLOWERS ARE INTENDED To ANNov, HARAss, LIBEL AND DEFAME THE PLAINTIFF; 14. THESE HARASSING COMMUNICATIONS AND POSTS ARE KNOWINGLY BEING SENT To PLAINTIFF’s ACCOUNTS; 15. THAT THls SITUATION CREATING A DIFFICULT AND UNCOMFORTABLE Is SITUATION FOR PLAINTIFF AT WORK, HOME, AND ALL PUBLIC PLACES, AND THE PLAINTIFF Is IN CONSTANT FEAR FOR HER SAFETY AND FOR THE SAFETY 0F HER HUSBAND AND FAMILY; 16. THAT THE MESSAGES FROM RANGE NONSENSICAL To HOSTILE, DEMANDING, THREATENING, HARASSING, AND EVEN DEATH RELATED; 17. THAT THIS HARASSMENT BOTH HER WORK AND HOME Is CAUSING PLAINTIFF EXTREME DISTRESS IN LIFE; COUNT l LIBEL DEFENDANT HAS DEFAMED PLAINTIFF AND PUBLISHED FALSE STATEMENTS ON OR THROUGHOUT CALENDAR YEARS 2019 18. THROUGH PRESENT, DEFENDANT PUBLISHED BLOGS DESCRIBING A LITANY OF MATTERS FROM NONSENSE TO MATTERS THAT ARE LIBEL PER SE. THE BLOGS REFERRED TO PLAINTIFF BY NAME 19. THROUGHOUT, WAS MADE OF AND CONCERNING PLAINTIFF, AND WAS SO UNDERSTOOD BY THOSE WHO READ THE BLOG. . MANY OF THE STATEMENTS CONTAINED 20. EMAILS ARE FALSE AS IT PERTAINS TO PLAINTIFF. IN THE Case 1:19-cv-00329 Document 1-1 Filed 06/18/19 Page 4 of 5 PageID #: 7 THE BLOGS ARE LIBELOUS ON THEIR FACE. 21. IT CLEARLY EXPOSES PLAINTIFF TO HATRED, CONTEMPT, RIDICULE AND OBLOQUY BECAUSE IT DEALS WITH MATTERS THAT ALLOW LIBEL PER SE RECOVERY. THE BLOGS WERE SEEN AND READ ON OR ABOUT 22. THE DAY OF THEIR CREATION BY MEMBERS OF THE PUBLIC SUBSCRIBE TO OR SIMPLY BROWSE TURTLEBOY BOTH HERE lN WHO EITHER RHODE ISLAND AND ALL OVER THE WORLD. AS A PROXIMATE RESULT OF THE ABOVE-DESCRIBED 23. PUBLICATION, PLAINTIFF HAS SUFFERED LOSS OF HER REPUTATION, SHAME, MORTIFICATION, AND INJURY TO HER FEELINGS, ALL TO HER DAMAGES IN A TOTAL AMOUNT TO BE ESTABLISHED BY PROOF AT WHEREFORE, TRIAL. PLAINTIFF REQUEST THIS HONORABLE COURT ENTER A JUDGMENT REQUIRING THE DEFENDANT TO PAY DAMAGES, INCLUDING REASONABLE ATTORNEY’S FEES. COUNT Ill INJUNCTIVE RELIEF PERMANENT INJUNCTION PLAINTIFF 24. PARAGRAPHS 1-23 AS IF RE-ALLEGES AND RE-AVERS FULLY SET FORTH HEREIN. PLAINTIFF AND HER REPUTATION HAS SUFFERED 25. AND CONTINUES TO SUFFER DAMAGES IN CONNECTION WITH THE ALLEGATIONS CONTAINED HEREIN. 26. PLAINTIFF DEMANDS DEFENDANT BE RESTRAINED AND ENJOINED FROM CONTACTING, ASSAULTING, MOLESTING, STALKING, CYBER STALKING, CYBER BULLYING, BULLYING, HARAssmG, THREATENING, ANNOYING, SLANDERING 0R OTHERWISE INTERFERING WITH PLAINTIFF AT HOME, AT WORK, THROUGH THIRD PARTIES, 0N THE STREET, 0R ELSEWHERE. THE PLAINTIFF DEMANDS THAT ANY AND ALL POSTS, BLOGS, AND COMMENTS FOLLOWING THE SAME BE IMMEDIATELY Case 1:19-cv-00329 Document 1-1 Filed 06/18/19 Page 5 of 5 PageID #: 8 REMOVED FROM THE DEFENDANT’S WEBSITE AND ALL OTHER SITES ASSOCIATED WITH THE SAME. WHEREFORE, PLAINTIFFS REQUEST THIS HONORABLE COURT ENTER A PERMANENT INJUNCTION PURSUANT TO RULE 56 OF THE RI RULES OF CIVIL PROCEDURE. VERIFICATION I, KATHRYN NARCISI, AM A PLAINTIFF IN THE ABOVE-ENTITLED ACTION. THE FOREGOING AND KNOW THE CONTENTS THEREOF. THE SAME IS I HAVE READ TRUE OF MY OWN KNOWLEDGE, EXCEPT AS TO THOSE MATTERS WHICH ARE THEREIN ALLEGED ON INFORMATION AND BELIEF, AND AS TO THOSE MATTERS, I I BELIEVE DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IT IS TO BE TRUE. TRUE AND CORRECT AND THAT THIS DECLARATION WAS EXECUTED AT WAKEFIELD, RHODE ISLAND. 2301;. ?a RESPECTFULLY SUBMITTED, KATHRYN NARCISI BY HER ATTORNEY, CHRISTOPHER T. MILLEA, Eg; 37 SOCKANOSSET CROSSROAD CRANSTON, RI 02920 ls/ 401 .453.4ooo MILLEALAW®VERIZON.NET