Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

Searchable full text

8,216 characters extracted

—

RIDGEWAY SUPERIOR COURT BATTALIONGAVIN, Plaintiff, v. GLENMCDEER, Defendant. Case No. RSC-CV-743 CIVIL COMPLAINT PLAINTIFF, BattalionGavin, by and through their undersigned counsel of record, for their complaint against GlenMcDeer alleges: INTRODUCTION 1. Plaintiff BattalionGavin (“Plaintiff”), who is a Candidate in the upcoming Senatorial Elections, was subject to the release of billboards (via. RidgeAds) across the State plastering false statements pertaining to his intentions as a Candidate in the Senate Race. 2. When a statement is made against one's intentions, or goals that are not true, then that statement is false. These false statements, however, carry detrimental repercussions as to the official business, reputation, and true meaning of the statements. 3. Such false statements arising around an incredibly divisive topic among voters, the State’s highly polarizing issue of sugarcane. The only underlying remedy to these statements is an expeditious filing to this court. 4. As a result of Defendant’s reckless leasing of a billboard containing false and defamatory statements, Plaintiff BattalionGavin is now falsely labeled as a “sugarcane-regulating official” despite no prior capacities as a law-regulating official within the State of Ridgeway. Defendants’ actions have exposed countless people to lies that have caused anomalous damage to his reputation, and career. 5. Plaintiff seeks compensatory and punitive damages for the extreme harm that the Defendants have jointly and severally caused. Plaintiff also seeks to enjoin Defendant from continuing to publish these defamatory statements. PARTIES 6. Plaintiff BattalionGavin Citizen of the State of Ridgeway. 7. Plaintiff GlenMcDeer Citizen of the State of Ridgeway. JURISDICTION AND VENUE 8. This Court has jurisdiction pursuant to Article IV, Section 7 of the Charter of Ridgeway County. 9. Venue is proper in this Court because the incident took place within Ridgeway County. FACTS 10. The Senatorial Race commences every few months, providing the opportunity for Citizens of the State of Ridgeway to cast their vote for the person in which they entrust with the powers delegated to a State Senator. 11. Plaintiff BattalionGavin, who is an established member of the State of Ridgeway in his prior capacities as a Law Enforcement Officer, took it upon himself to register as a Candidate in the State Senate election in hopes to win the trust of the voters. 12. The voters' trust of Plaintiff BattalionGavin, however, was challenged by the false statements produced by Defendant. 13. Plaintiff BattalionGavin has never withheld an official capacity or power to regulate anything within the sphere of the State of Ridgeway. Plaintiff, thus can not be adequately held to career-harming accusations in which he has never been in the capacity to pursue. I. Defendant Acted with Actual Malice by Leasing Billboards with False Statements at a Time that Profit by Damaging Plaintiff's Reputation. 14. The timing of the publishings of the billboards in the midst of the confirmation of the Candidates in the Senate Elections, with Plaintiff BattalionGavin being confirmed as a Candidate. The timing also ensured that the damage to Plaintiff would be considerable. 15. Upon information and belief, the billboard was viewed by over 1,200 individuals, given its publication to both in-game billboards and the State of Ridgeway community Discord via. #community-content, consequently spreading misinformation to countless potential voters in the Senate election. 16. Defendant included alongside Plaintiff BattalionGavin, two other Candidates in the Senate Race, in clear attempt to use the billboard to influence the decision of voters’ with knowingly, and provenly false statements. 17. Defendant, to date, has yet to rescind the statements nor make a good faith effort to prevent the misinformation from further spreading to potential voters in the ongoing Senate election. This further clearly demonstrates Defendants’ goal to ensure that the false statements are continuously brought forth during the elections season to misrepresent the intentions, and prior actions of Plaintiff BattalionGavin. I. Extensive Harm to Plaintiff, His Reputation, and His Candidacy 18. As a direct result of Defendant’s false and defamatory statements of Plaintiff allegedly being a “sugarcane-regulating official” and Defendants’ leasing of billboards reciprocating such statements, Plaintiff has suffered severe professional and personal harm. 19. As a direct result of Defendant’s false and defamatory statements of Plaintiff allegedly being a “sugarcane-regulating official” and Defendants’ leasing of billboards reciprocating such statements, the State of Ridgeway community server with over 9,000 members, posted the false statements published therein. 20. As soon as the billboard made its course to the State of Ridgeway community server, Plaintiff began to receive backlash as a result of the false statements thereof. 21. Most importantly, Plaintiff has been falsely branded a “sugarcane-regulating official.” This circumstance all but foreclosed his ability to pursue his candidacy, and his motive to make an honest living. His once promising career and political prospects have been severely harmed by the reckless publishing of these false allegations. FIRST CAUSE OF ACTION (Tortious Interference) 22. The allegations thus far are included in this complaint and are incorporated as reference as if fully set forth in this cause of action. 23. BattalionGavin is a Candidate in the State Senate elections. 24. Defendant leased the billboard in a highly populated area, at the Palmer Car Dealership. Without any prior voting, introduction of regulations or objective basis in fact, the statements within the billboard were FALSE — demonstrating severe backlash against Plaintiff. The billboard was published and republished, with knowledge of their falsity or with reckless disregard for the truth, to each and every Resident of the State of Ridgeway who took notice of the billboard. 25. Defendant was the only individual to lease the billboards depicting the false statements against Plaintiff. 26. Defendant GlenMcDeer, through Mothers for Big Kids, acted with actual malice by knowingly or intentionally disregarding the truth in publishing false and defamatory accusations against Plaintiff BattalionGavin. 27. Defendants’ publishing of the accusations have falsely portrayed Plaintiff as a “sugarcane-regulating official.” 28. Defendants’ publishing of the accusations are defamatory per se as to Plaintiff. They impute that Plaintiff regulated, or has previously regulated sugarcane – a divisive topic within the State of Ridgeway given its recent introduction. They also were intended to injure Plaintiff in his Candidacy to fulfill a seat in the State Senate. 29. As a direct and proximate result of Defendants’ actions, Plaintiff’s reputation has been damaged, and his professional prospects have been significantly diminished due to the false statements misleading potential voters. 30. Defendants’ actions were malicious and willful, and evidence of a conscious disregard for the rights of Plaintiff. Accordingly, in this case punitive damages are appropriate 31. These statements prove harmful to the reputation, career, and reliability of Plaintiff, and must be rectified immediately. RELIEF WHEREFORE, Plaintiff requests that the court grant relief as follows: A. For declaratory judgment that the Defendant’s publishing of the statements as alleged herein caused damage to the Plaintiff’s career; B. An injunction barring Defendant from continuing to publish the defamatory statements as complained of herein; C. An award of punitive damages to Plaintiff, against Defendant, in the amount of $5,000 in-game currency to compensate for the misrepresentation of facts; D. Awarding all expenses and costs, including attorneys’ fees; E. Such other and further relief as the Court deems appropriate Respectfully Submitted. STICKZA Managing Partner COHN, CICERO, & GOODRICH, LLC Suite 3B, Palmer Apartments Palmer, RW 33328 D: stick#0677 E: [email protected] Counsel for Plaintiff APPENDICES APPENDIX A - GlenMcDeer’s Leased Billboard

Civil_Complaint_BattalionGavin_v._McDeer.pdf

Original document

Searchable full text

Document record