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Follow on Google News | Lawsuit Filed Against Serial Convicted Stalker Deneale K. WilliamsDeneale K. Williams sued for stalking, harassment and defamation
By: Torchmark Media The complaint in the lawsuit against Deneale K. Williams: IN THE DISTRICT COURT OF DENVER COURT, COLORADO CIVIL DIVISION Theatrix USA, a limited liability company, Torchmark Media, a limited liability company, 2 Corners Enterprises, a limited liability holding company, and Mike Broemmel, an individual, Plaintiffs, vs. Case No. ______________________________ Deneale K. Williams, Defendant. COMPLAINT COMES NOW Theatrix USA, a limited liability company, Torchmark Media, a limited liability company, 2 Corners Enterprises, a limited liability holding company and Mike Broemmel, an individual, (hereinafter collectively known as “Plaintiffs”) Theatrix USA is a theatrical production company that produces original stage plays in cities across the United States and is partially owned by Broemmel. Torchmark Media is a media syndication service providing columnists and feature articles to publications in the United States and is partially owned by Broemmel 2 Corners Enterprises is a holding company partially owned by Broemmel. In addition to his ownership interest in the aforementioned enterprises, Broemmel is an author and lecturer with books published internationally and who speaks at conferences and conventions across the United States. Deneale K. Williams (hereinafter Defendant) is an individual who can be served with Summons and Complaint at Manager’s Unit, King Street Mobile Home Park, Brevard County, Florida. Statement of Facts Defendant has been prosecuted and incarcerated for stalking and harassment. Defendant has engaged in an ongoing pattern and practice of harassing, defaming and placing in false light the Plaintiffs herein. In October 2014, Defendant posted at multiple locations on the Internet false statements that accused Plaintiff Broemmel of misappropriating money from her, of accessing her personal bank account, of accessing her PayPal account multiple times and of accessing her email account(s) multiple times. Defendant contended that Plaintiff Broemmel undertook these activities as part of his association with Theatrix USA. One October 6, 2014, Defendant posted false statements multiple times on the Internet that accused Plaintiff Broemmel of telephoning her and stating that he was coming over to her house to rape and murder her. Over the course of the past 45 days, Defendant has posted other false, defamatory and statements made in false light on the Internet with the express purpose of hampering the operations of the business entities named as Plaintiffs herein and to impair Plaintiff Broemmel’s ability to earn a living. Count One – Defamation Plaintiffs incorporate paragraphs 1 through 11 into this section as if the same were set forth in their entirety. Plaintiffs contend that the false statements referenced herein and above constitute defamation and were knowingly made by Defendant with the express purpose of harming the reputation of Plaintiffs and causing Plaintiffs financial loss. WHEREFORE, Plaintiffs request judgment in their favor and against Defendant in an amount in excess of $50,000 for defamation. Count Two – False Light Plaintiffs incorporate paragraphs 1 through 11 into this section as if the same were set forth in their entirety. Plaintiffs contend that the false statements referenced herein and above constitute false light and were knowingly made by Defendant with the express purpose of harming the reputation of Plaintiffs and causing Plaintiffs financial loss. WHEREFORE, Plaintiffs request judgment in their favor and against Defendant in an amount in excess of $50,000 for false light. Count Three – Tortious Interference with Business Operations Plaintiffs incorporate paragraphs 1 through 11 into this section as if the same were set forth in their entirety. Plaintiffs contend that the false statements referenced here1in and above constitute tortious interference with business operations and were knowingly made by Defendant with the express purpose of harming the reputation of Plaintiffs and causing Plaintiffs financial loss. WHEREFORE, Plaintiffs request judgment in their favor and against Defendant in an amount in excess of $50,000 for tortious interference. Count Four – Harassment 18. Plaintiffs incorporate paragraphs 1 through 11 into this section as if the same were set forth in their entirety. 19. Defendant has engaged in an ongoing pattern and practice of harassment that is designed to cause Plaintiffs financial loss. WHEREFORE, Plaintiffs request judgment in their favor and against Defendant in an amount in excess of $50,000 for harassment. Plaintiffs pray for such other and further relief the Court deems just and equitable in the premises, including expenses and attorney fees. Plaintiffs further reserve the right to submit to the Court an appropriate pleading seeking punitive damages because of the egregious conduct of Defendant in falsely accusing Plaintiff Broemmel of telephoning her to advise that he was coming to her residence to rape and murder her. Plaintiffs request that this matter be scheduled for a trial by jury. Finally, Because Defendant’s inappropriate and illegal conduct is ongoing, Plaintiffs respectfully reserve the right at amend this Complaint to reflect additional damages caused by Defendant’s willful and wrongful conduct. Respectfully submitted, End
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