IN THE SUPERIOR COURT OF NEW JERSEY
PERSONA
Plaintiff,
V.
PERSONA
Defendant.
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DOCKET NO.:
COMPLAINT
Plaintiff PERSONA (“Plaintiff”), pro se, brings and hereby submits this complaint against Defendant PERSONAr (“Defendant”), and in support thereof, aver as follows:
FACTS COMMON TO ALL COUNTS
- Plaintiff , is an adult African-American male residing within the State of New Jersey.
- Defendant is an adult Caucasian female residing within the State of New Jersey.
- At all times hereinafter mentioned, Plaintiff and Defendant are biological parents of one Keenan Jackson, a minor.
- The Plaintiff is informed and believes, and upon such information and belief alleges the Defendant only has one child, aforementioned Keenan Jackson.
- The Defendant has resorted to underhanded tactics to deprive the Plaintiff of his rightfully awarded visitation rights.
- The Defendant has 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.
- The Defendant has submitted to the public that the Plaintiff is mentally disabled and unstable. 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”.
- 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.
- On a separate post, the Defendant authored publication alleging the Plaintiff “threatened to harm me [Defendant] and kill people in front of our son”. The Defendant further refers to the Plaintiff as a “stalker”.
- The Plaintiff is informed and believes, and upon such information and belief alleges threats to commit a felony must be taken seriously, and the Defendant never reported the alleged threat to the police or other relevant authority for appropriate action.
- The Defendant has acted maliciously toward the Plaintiff and has publicly referred to the Plaintiff by the derogatory term of “nigga”.
- 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.
- 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.
- 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.
- 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”.
- Without limitation, the false and defamatory statements contained in the publication accused Plaintiff of mental disability and instability.
- 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.
- 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:
- 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.
- 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;
- 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;
- For mental and emotional distress damages as shall be established by proof at time of trial;
- For exemplary and/or punitive damages;
- For interest, expenses and costs of suit to the extent permitted by law; and
- Any other relief the Court may deem just and proper
| Dated: ____________________ | Respectfully submitted, |
| By: | |
| PERSONA, Pro Se |
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.
| Dated: ____________________ | Respectfully submitted, |
| By: | |
| PERSONA, Pro Se |