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Poet)RETURN DATE: NOVEMBER 15" 2009: SUPERIOR COURT.
DANIEL RGAITA __ JUDICIAL DISTRICT OF DANHURY
vs - ATDANBURY
anv cuesusy - ocrowts, 209
MATTHEW KNICKERBOCKER a,
TAWRANCE CREYBAS
ILL MILAAN
Plaintitf complains and for causes of action alleges as follows:
4. Plaintif is an individual and is now, and at all times
mentioned in this complaint, a resident of the Town of Bethel, Fairfield County,
Connecticut.
Plaintiff created on Jan 2009, a voluntary public service information research website for
his community located at hito:JAww.bethelat info and has worked as a self employed
personal trainer for over 10 years and owns a local private fitness center. He Nas
Fesided in Bethel Connecticut for over 15 years, Plaintiff has during all this time enjoyed
‘an excellent reputation, both generally and professionally.
2, Defendant Dr. Gary Chesley, is an individual and is
‘now, and at al mes mentioned in this complaint a resident
Of Fairfield County Connecticut and employed by the Bethel Connecticut Public Schoo!
System as its Superintendent of Schoo!s.
3, Defendant(s) Matthew Knickerbocker and Lawrence Craybas are now, and
at all times mentioned in this complaint, residents of the Town of Bethel, Fairfield
County, Connecticut. Both are serving as elected board member on the Bethe!
Connecticut Board of Education
4. Defendant Bill Hillman at all times mentioned in this complaint. is an individual and is.
how, and at all times mentioned in this complaint, a resident
of the Town of Bethel, Fairfield County Connecticut
5, On or about August 17" 2009, defendant published
an email stating the Plaintiff used “hate Speech” labeled others un-American Liars”
‘and acted “against the military code of conduct”
6. The email referred to the plaintif by name throughout, was made of
and concerning plaintiff, and was so understood by those who
read the email7. The entire statement(s) “His efforts were determined to be against the law and
‘against the miltary code of conduc’, “Using Hate Speech’ “Labeled others un-
‘American liars" Is false as it pertains to plaintif.
& The emailis libelous on its face. It clearly exposes plaintiff
to hatred, contempt, ridicule and obloquy because the plaintiff is being accused of
‘actions which are both illegal and socially reprehensible. It charges plaintif with having
Committed the crime of copyright infringement and a violation of the Miltary Code of
Conduct Furthermore it alleges the plaintiff used hate speech.
6. The emai publication was seen and read on or about August 12" 2000 by Town of
Bethe! Board of Education Members: Bill Kingston, Lawence Craybas, Mike Duff,
pert Edarison, lit Derosa, Matthew Knickerbocker, Cythia McCorkndale, Robin
Rener, Stuart Carlsen ané Gary Chesley,
10. As a proximate result of the above-described publication, piaintiff has suffered loss
of hig reputation, shame, mortification, and injury to his feelings, all to his damage in a
total amount to be established by proof at trial
11. The above-described publication was not privileged
because it was published by defendants with malice, hatred and il wil toward paint
and the desite to injure him, in that defendants had expressed
2 desire to “challenge and stop” the plaintiff. Because of defendants’ malice in
publishing, plaintif seeks punitive damages in a total amount to be established by proof
atrial
WHEREFORE, plaintiff demands judgment against defendants,
and each of them, for:
1. Compensatory damages according to proof
2. Punitive damages:
3. Interest as allowed by law.
4, Costs of suit; and
5, Such other and further relief as this court may deem
just and proper.
ayy
relafens
(Signature)pn
tte OF CONNECTICUT
ss: BETHEL, DANBURY ccTORER 22, 2009
COUNTY OF PAIRFTELD
‘Then and there, by virtue hereof, of the original Writ, Summons,
Instructions, Complaint, Verification and Cash Bond, I made service
upon the within, named defendant(s):
DR. GARY CHESLEY
MATTHEW KNICKERBOCKER
LAWRENCE S. CRAYBAS
WILLIAM HTLLMAN
by leaving a true and attested copy of the original Writ, Summons,
Instructions, Complaint, Verification and Cash Bond, with my doings
thereon endorsed,
at the usual place of abode of:
DR. GARY CHESLEY, at, 14 CONTEMPORARY DRIVE, DANBURY, CT 06811
MATTHEW KNICKERBOCKER, at, 14 COLONIAL DRIVE, BETHEL, CT 06801
WILLIAM HILLMAN, at, 86 WALNUT HILL ROAD, BETHEL, cr 06801
LAWRENCE S. CRAYBAS, at, 15 KELLOGG STRET, BETHEL, Cr 06901
One such copy to each of the within named defendant (s)
‘The within and foregoing is the original Writ, Summons, Instructions,
Complaint, Verification and Cash Bond, with my doings hereon
endorsed.
Fees Attest:
Travel $22.60
Pages 24.00
Service 120.00
Endorsement __&.40 Richard 7. Debucia
Total $ 175.00 State Marshal, Fairfield County