STATE OF RHODE ISLAND SUPERIOR COURT PROVIDENCE, SC. JOHN J. TASSONI, JR. Plaintiff v C.A. No: PC-2019- MEDICAL TRANSPORTATION MANAGEMENT, INC. Defendant VERIFIED COMPLAINT PARTIES John J. Tassoni, Jr., “Mr. Tassoni”) is a domiciled resident of the State of Rhode Island. . Medical Transportation Management, Inc. (“Defendant”) is a foreign corporation organized under the laws of Missouri and has a principal place of business at 635, Maryville Centre Drive, Suite 300, St. Louis, MO 63141. SURISDICTION |. This Court has jurisdiction of this matter pursuant to RI. Gen. Laws 1956 §§ 8-2-13 and/or 8214, Venue is appropriate pursuant to RL Gen. Laws 1956 § 9-4-3. . Defendants have sufficient minimum contacts with the State of Rhode Island for this Honorable Court to exercise personal jurisdiction over them pursuant to RI. Gen. Laws 1956 § 9-5-33. STATEMENT OF FACTS . On May 23, 2019, Mr. Tassoni testified before the Rhode Island House Committee on Oversight of the RI House of Representatives (“House Oversight”).10. i 12, 13. 14, On July 8, 2019, Defendant sent a letter to Mr. Tassoni (the “Letter”) alleging that Mr. Tassoni made statements (“Statements”) before House Oversight on May 23, 2019 that were “false” and “defamatory” See Exhibit A Mr. Tassoni’s statements were grounded in truth and fact, and were relative to matters of public concem, which is protected speech pursuant to the RI Anti-SLAPP statute, RL. Gen. Laws § 9-33-1 of seg. In retaliation, the Defendant sent said Letter with a copy to each of Mr. Tassoni’s Twenty- six (26) relationship, with the intent to personally harm Mr. Tassoni, and his business. Defendant threatened litigation in the event Mr. Tassoni failed to retract said Statements within 7-days of receiving said Letter. See Exhibit A On July 18, 2019, Mr. Tassoni responded to Defendant, through his attomeys, requesting a retraction of Defendant's July 8, 2019 Letter, and then again on September 25, 2019; both were ignored. See Exhibit B Defendant's Letter caused damages to Mr. Tassoni, and his business and Defendant's Letter is the direct and proximate cause of said damages. Mr. Tassoni had contractual relations with these agencies/entities as well as prospective business relations. Defendant's, by carbon-copying these agencies/entities on the July 8, 2019 Letter, directly and proximately caused intentional and/or tortious interference with Mr. Tassoni’s contractual relations and prospective contractual relations.COUNTI To 3 Interferen Jationshi 15. Mr. Tassoni hereby incorporates and re-alleges each preceding paragraph of this complaint as if the same were set forth in fall herein. 16, Defendant's Letter was intended to harm Mr. Tassoni and interfere with Mr. Tassonis business. 17, Following Defendant’s Letter, some of the agencies/entities carbon-copied on the letter have threatened termination of their business relationships with Mr. Tassoni. 18. Defendant’s interference directly and proximately caused injury to Mr. Tassoni, WHEREFORE, Plaintiff demands that this Honorable Court: (@ enter judgment in favor of Plaintiff and against Defendant for compensatory damages plus costs and reasonable attorney fees and expenses; (b) enter judgment in favor of Plaintiff and against Defendant for punitive damages; and (©) award to Plaintiff any other and further relief as this Court deems just and proper. COUNT IL ‘Tortious Interference with Prospective Business Advantage 19. Mr. Tassoni hereby incorporates and re-alleges each preceding paragraph of this complaint as if the same were set forth in full herein. 20. Defendant's Letter has interfered with Mr. Tassoni’s prospective business. 21. Rollowing Defendant's Letter, certain lobbying prospects have failed to materialize due to the intentional acts of Defendant.22, Defendant's interference directly and proximately caused injury to Mr. Tassoni WHEREFORE, Plaintiff demands that this Honorable Court: (a) enter judgment in favor of Plaintiff and against Defendant for compensatory damages plus costs and reasonable attomey fees and expenses; (b) enter judgment in favor of Plaintiff and against Defendant in punitive damages; and (c) award to Plaintiff any other and further relief as this Court deems just and proper. Dated: November 6, 2019 Mr. Tassoni, By his Attorneys 4/Richard W. Nicholson, Esa Richard W. Nicholson #6245 Nicholson & Associates, LLC 9 Thurber Boulevard, Suite D Smithfield, Rhode Island 02917 Tel: (401) 453-5055 (401) 453-5056 rich@rilawepa.com (s/ August E, Bigos, Esq ‘August E. Bigos #9869 Nicholson & Associates, LLC 9 Thurber Boulevard, Suite D Smithfield, Rhode Island 02917 Tel: (401) 453-5055 (401) 453-5056 Zrilawepa.comNow comes John J. Tassoni, Jr., and first being duly sworn makes affidavit and states as follows: 1. _ That I'am John J. Tassoni, Jr., who states under oath that I have reviewed the facts contained within the Verified Complaint and confirm that the facts are true and accurate to the best of my knowledge. 2. ‘That Ihave read the Verified Complaint and it is tre to the best of my knowledge and belief, except as to the matter stated to be alleged on information and belief, which I believe to be true. iat John J} Tassoni, Jr., STATE OF RHODE ISLAND COUNTY OF PROVIDENCE Subscribed and swom to before me, this 6" day of November, 2019. NOTARY P| Commission Expires: Hal .4,.693, on ly Cmedasion Expres rch 4, 2023CERTIFICATE OF SERVICE Thereby certify that a copy of the within Verified Complaint was electronically filed on the State’s EFS, 4/ Anthony Bettencourt