COMPLAINT

IN THE SUPERIOR COURT OF NEW JERSEY

JAHMEAN JACKSON

Plaintiff,

V.

BRIDGET SEMBER

LAURA SEMBER

DONALD SEMBER

MARCEL ROGERS

Defendant.

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DOCKET NO.:

Civil Action

COMPLAINT

Plaintiff JAHMEAN JACKSON KEENAN JACKSON (“Plaintiff”), pro se, brings and hereby submits this complaint against Defendant BRIDGET SEMBER, Defendant LAURA SEMBER, Defendant DONALD SEMBER and Defendant MARCEL ROGERS (collectively referred to as “Defendants”), and in support thereof, aver as follows:

FACTS COMMON TO ALL COUNTS

1. Plaintiff Jahmean Jackson, is an adult African-American male residing within Easton, Pennsylvania.
2. Defendant Bridget Sember, is an adult Caucasian female residing within the State of New Jersey.
3. Defendant Marcel Rogers, is an adult African-American male residing within the State of New Jersey.
4. Defendant Laura Sember, is an adult Caucasian female residing within the State of New Jersey.
5. Defendant Donald Sember, is an adult Caucasian female residing within the State of New Jersey.
6. At all relevant times hereinafter mentioned, Plaintiff and Defendant Bridget Sember are biological parents of one Keenan Jackson, a minor.
7. At all relevant times hereinafter mentioned, Defendant Laura Sember and Donald Sember are parents to Defendant Bridget Sember.
8. At all relevant times hereinafter mentioned, Defendant Marcel Rogers is employed by the State as a Social Worker at MA Department of Children and Families.
9. The Plaintiff is informed and believes, and upon such information and belief alleges the Defendant Defendant Bridget Sember only has one child, aforementioned Keenan Jackson.
10. Sometimes beginning the year 2019, the Defendants have resorted to underhanded tactics to deprive the Plaintiff of his rightfully awarded visitation rights including publishing libelous statements against the Plaintiff.
11. The Defendants have taken to damaging the Plaintiff’s character in the eyes of the general public by willfully and knowingly publishing falsehoods against the Plaintiff on Facebook, a worldwide social media platform.
12. The Defendant has on various occasions published statements on Facebook, alleging the Plaintiff to be mentally disabled and unstable. On one publication, the Defendant is quoted stating that “…Retardation & mental health are one hell of a thing pray for my son’s father. He done lost his mind”.
13. The act of publishing the statement invited other Facebook users to chime in and equally allege that the Plaintiff is mentally disabled and unstable without justification.
14. Facebook user Carmen Fucci comments on Defendant Bridget Sember’s Facebook post and states that “let his dumb a** go ahead”.
15. Facebook user Brenna Rose comments on Defendant Bridget Sember’s Facebook post and states that “ew he’s gross. Sounds like he’s the bitter baby mama cus he’s actin like a real b***h”.
16. Facebook user Hailey Gerrity comments on Defendant Bridget Sember’s Facebook post and states that “that’s embarrassing he got mental issues”. Defendant Bridget Sember responds in affirmation and states “sure tf does”. Hailey Gerrity responds with “yasss hes wild not healthy…”.
17.  Facebook user Kristen Wasson comments on Defendant Bridget Sember’s Facebook post and states that “Yo he is ridiculous…”
18. The above statement is false and no evaluation, now or ever, has been conducted and determined that the Plaintiff suffers from any form of mental instability or disability.
19. Defendant Bridget Sember has acted and displayed malice toward and against the Plaintiff and has, in addition to the above, publicly referred to the Plaintiff by the derogatory term of “nigga”. The Defendant has also involved and referred to family members of the Plaintiff and is quoted stating “…tell your ugly ass whore nigger sister to come see me”.
20. Defendant Bridget Sember together with Defendant Marcel Rogers have alleged, beyond their persons, that the Plaintiff is mentally disabled and incapacitated.
21. Defendants Laura Sember and Donald Sember, have equally contributed to tarnishing the name and character of the Plaintiff herein as they stood by and allowed the defamatory publication. Defendant Laura Sember, through her Facebook user account commented on Defendant Bridget Sember’s post and stated “and five days later I’m still being harassed!! Only now from yet another number pretending to be some dumb b***h!!!”.
22. The said Publications contained disparaging and defamatory statements designed to libel, slander, defame and place plaintiff in a false light, and were intended to do so.
23. All Publications were authored, overseen or otherwise compiled by defendant, who published the same to the general public with the intention of defaming and harming the reputation of plaintiff.
24. The Publications were authored by the Defendant with intention to subject the Plaintiff to great personal embarrassment and has exposed Plaintiff to hatred, contempt, ridicule and condemnation.
25. The publications complained of and that are known to the plaintiff at the time contain libelous, slanderous and defamatory statements and are annexed hereto as Exhibits “1” through “6”.
26. Without limitation, the false and defamatory statements contained in the publication accused Plaintiff of mental disability and instability.
27. The statements made by the defendant were false and known to be false at the time they were made. The defendant made the statements with the intention of injuring the plaintiff, placing the plaintiff in a false light and otherwise were designed to defame the plaintiff in connection with the minor.
28. The statements made were libelous, and defamatory per se.

COUNT ONE

• Plaintiff repeats and realleges all of the foregoing paragraphs as if set forth herein at length.
• The statements set forth above were false and defamatory.
• As a direct and proximate result of the statements set forth in the publications described above, Plaintiff has been damaged and will continue to suffer damage. The plaintiff has suffered irreparable harm to their reputation for which the defendant should be held liable.
• WHEREFORE, Plaintiffs demand judgment against’ the defendant(s) for special damages, consequential, incidental and punitive damages, together with lawful interest, costs of suit and fees.

COUNT TWO

• Plaintiff repeats and realleges all of the foregoing paragraphs as if set forth herein at length.
• The defendant intended to deprive the plaintiff of the opportunity to enjoy visitation rights of the minor, and therefore deprived him of the prospective advantage of pursuing a relationship with the minor. As a result of the actions of the defendant, the plaintiff has been injured.
• As a direct and proximate result of the actions of the defendant, the plaintiff has been and will continue to be damaged.
• WHEREFORE, Plaintiffs demand judgment against’ the defendant(s) for special damages, consequential, incidental and punitive damages, together with lawful interest and costs of suit.

COUNT THREE

• Plaintiff repeats and realleges all of the foregoing paragraphs as if set forth herein at length.
• The defendant has conspired with to injure the Plaintiff.
• The defendants are guilty of civil conspiracy designed and implemented to injure the plaintiff and to cause irreparable harm to the plaintiff and reputation.
• As a direct and proximate cause of the civil conspiracy committed by the defendant, the plaintiff has been damaged.
• WHEREFORE, Plaintiff demand judgment against the defendant for special damages, consequential, incidental and punitive damages, together with lawful interest and costs of suit.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for relief as follows:

1. For an award of damages in the amount of $1,000,000 based on injury and damage to reputation, and mental and emotional injury and distress.
2. For an award of compensatory damages for costs associated with libel and damage to the Plaintiff’s reputation as shall be established by proof at time of trial;
3. For an award of consequential damages for costs associated with libel and damage to the Plaintiff’s reputation as shall be established by proof at time of trial;
4. For mental and emotional distress damages as shall be established by proof at time of trial;
5. For exemplary and/or punitive damages;
6. For interest, expenses and costs of suit to the extent permitted by law; and
7. Any other relief the Court may deem just and proper

DEMAND FOR JURY TRIAL

Plaintiff demand a jury trial on all causes of action and claims to which they have a right to a jury trial.