Bill Windsor has filed a lawsuit against Claudine Dombrowski, the American Mothers Political Party, and its members

2013-07-17-Kansas-Topeka-Shawnee-County-Courthouse (1)-640w

Bill Windsor has filed a lawsuit against the American Mothers Political Party and its members, including Claudine Dombrowski, Lorraine Tipton, Jennifer Dotson, Shannon E. Miller, Kimberly Wigglesworth, Connie Bedwell, and Loryn Ryder.  The lawsuit was filed in the District Court of Shawnee County in Topeka, Kansas.  Tipton (Wisconsin), Dotson (Florida), Miller (Mississippi), Wigglesworth (Connecticut), Bedwell (California), and Ryder (Ohio) will all have to come to Kansas to participate.  I expect to  name many others since I sued these people and 1,000 Jane Does and John Does.

13C-1045-Windsor-v-AMPP-Verified-Petition-2013-09-12

COUNT I – DEFAMATION

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. In Kansas, the elements of defamation, both libel and slander, are: (1) false and defamatory words (2) communicated to a third person (3) which result in harm to the reputation of the person defamed.  An organization may be liable for the defamatory utterances of its agent which are made while acting within the scope of her authority.
  3. Defendants have published false and defamatory words about the Plaintiff. [Element 1.]  Published statements were false.  Many statements are mentioned above and may be seen in exhibits.  The Plaintiff believes much more will surface in discovery.
  4. Statements that Defendants have published were communicated to third persons. [Element 2.]  Many statements have been published online for the world to see.
  5. Statements made by Defendants have harmed the reputation of Plaintiff and have lowered him in the estimation of the community or to defer third persons from associating or dealing with him.  [Element 3.]  Many people have ceased dealing with the Plaintiff because of the statements.
  6. Defendants know the difference between what’s true and what’s a lie.  They know about laws to protect people from libel, slander, defamation, harassment, and stalking, but they acted anyway.  They had a duty to abide by the law, and they didn’t ignore it once; the laws were ignored again and again and again.
  7. The Plaintiff suffered damage as a result of statements by Defendants. The Plaintiff has lost his wife, his relationship with his children, and any contact whatsoever with his grandchildren.  He has lost his home.  His movie project has been severely hurt by what the Defendants have done.  His reputation has been tarnished almost beyond belief.  The Plaintiff has incurred costs and lost money as a result of the actions of the Defendants.

COUNT II – DEFAMATION PER SE

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. Statements made by Defendants impute the commission of crimes or acts that constitute an indictable offense.  Many statements made have accused the Plaintiff of criminal acts.
  3. Many statements made by Defendants impute fraud, misconduct, or incompetence in the Plaintiff’s business or occupation.
  4. Statements made by Defendants tend to harm the reputation of Plaintiff and to lower him in the estimation of the community or to defer third persons from associating or dealing with him.  Many people have ceased dealing with the Plaintiff because of the statements.
  5. Statements made by the Defendants were defamatory as a matter of law.

COUNT III – OUTRAGE AND INFLICTION OF EMOTIONAL DISTRESS

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. The tort of outrage or intentional infliction of emotional distress has four elements: (1) The conduct of defendant must be intentional or in reckless disregard of plaintiff; (2) the conduct must be extreme and outrageous; (3) there must be a causal connection between defendant’s conduct and plaintiff’s mental distress; and (4) plaintiff’s mental distress must be extreme and severe.
  3. Defendants intentionally or negligently inflicted emotional distress on the Plaintiff.  Defendants acted intentionally or recklessly. [Element 1.]  Defendants know the difference between what’s true and what’s a lie.  They know about laws to protect people from libel, slander, defamation, harassment, and stalking, but they acted anyway.  They had a duty to abide by the law, the they didn’t ignore it once, the laws were ignored again and again and again.
  4. Conduct of Defendants was extreme and outrageous. [Element 2.]  These outrageously false, criminal claims would prompt an average member of the community to exclaim “outrageous!”
  5. The conduct of Defendants caused the distress. [Element 3.]
  6. The distress caused was severe emotional distress to the Plaintiff.  [Element 4.]  The outrageous lies, libel, slander, and defamation are bad alone, but the effect on the Plaintiff’s life with the loss of his wife, his family, his home, and life as he knew it has caused severe emotional distress.

COUNT IV – NEGLIGENCE

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. Defendants were negligent.  Negligence is the failure to exercise the degree of care which a reasonably prudent and careful person would use under the same or similar circumstances.
  3. The elements of a negligence claim are (1) The existence of a duty on the part of the defendant to protect the plaintiff from the injury of which he complains; (2) an act or omission in breach of that duty, (3) An injury to the plaintiff from such failure of the defendant, and (4) an injury.
  4. The Defendants had a duty to abide by the laws regarding defamation, cyberstalking, harassment, libel, slander, and they ignored that duty.  Harm was clearly forseeable.  Duty, the obligation of one person to another, flows from millennia of social customs, philosophy, and religion. Serving as the glue of society, duty is the thread that binds humans to one another in community. Duty constrains and channels behavior in a socially responsible way.  The Defendants did not behave in a socially responsible way.  Their actions were totally irresponsible.
  5. There is a standard of proper behavior necessary to avoid imposing undue risks of harm to other persons and their property, and the Defendants breached their duty.  They ignored the behavior necessary to avoid harming the Plaintiff.  They thumbed their noses at the law and the Plaintiff with one blatant slanderous statement after another.  The Defendants had a duty to act with reasonable care for the safety the Plaintiff.  The Defendants acted carelessly, unreasonably, without due care.  The Defendants breached the duty of care, and their conduct was negligent.
  6. The damages the Plaintiff suffers are a proximate result of the Defendants’ breach of duty.  The Defendants must be required to compensate the Plaintiff for harm improperly inflicted.  How do you compensate the Plaintiff for the loss of his wife, his children, and his grandchildren?  As much as money damages can do so, the law requires the Defendants to restore what the Plaintiff lost as a proximate result of the Defendants’ wrongs.
  7. The Plaintiff has been caused pain and suffering, emotional distress, lost enjoyment of life, loss of his marriage, loss of his relationship with his family, loss of his home, severe damage to his reputation, damage to his career, and more.

COUNT V – TORTIOUS INTERFERENCE WITH CONTRACT

OR BUSINESS RELATIONS

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. Tortious interference with a contract or business expectancy requires proof of: (1) a contract or valid business relationship; (2) defendant’s knowledge of the contract or relationship; (3) a breach induced or caused by defendant’s intentional interference; (4) absence of justification; and (5) damages resulting therefrom.
  3. The Plaintiff was involved in a valid business relationship. [Element 1.]  The Defendants knew that the Plaintiff had a valid business relationship with people all over America in filming videos, conducting interviews, and producing a movie.  Several of the Defendants signed a contract with the Plaintiff, and they were aware that everyone filmed by the Plaintiff signed the same contract.
  4. Defendants were aware of the relationship. [Element 2.]  The Defendants were totally aware of the business relationship that the Plaintiff has had with thousands of people.
  5. Defendants intentionally interfered with the relationship. [Element 3.]  Defendants know the difference between what’s true and what’s a lie.  They know about laws to protect people from libel, slander, defamation, harassment, and stalking, but they acted anyway.  They had a duty to abide by the law, the they didn’t ignore it once, the laws were ignored again and again and again.  They took actions to damage the Plaintiff’s business relationships.
  6. Defendants acted without justification. [Element 4.]  There can never be a justification for lies, libel, slander, harassment, defamation, and false criminal charges.
  7. The Plaintiff suffered damages as a direct result of conduct of Defendants. [Element 5.]  Many people have dropped out of the Plaintiff’s projects.  Very few people contact the Plaintiff now while many thousands did before this.  The Plaintiff had over 50,000 followers on Facebook before this, and now he has less than 100.  The Defendants caused this.

COUNT VI – FALSE LIGHT INVASION OF PRIVACY

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. The right to privacy is invaded when there is (1) publication of some kind is made to a third party; (2) the publication  falsely represents the person; and (3) that representation is highly offensive to a reasonable person.  This is a cause of action based upon injury to plaintiff’s emotions and his mental suffering.
  3. Defendants have given publicity to matters concerning the Plaintiff.
  4. Defendants have invaded the Plaintiff’s privacy.  The Plaintiff’s name has been misappropriated as has the name of his deceased parents.  The Plaintiff’s photos and intellectual property have been misappropriated many times.
  5. Private facts about the Plaintiff have been publicly disclosed, and totally false personal information has been publicly disclosed.  Facts disclosed include alleged sex life, alleged criminal activity, alleged failure to pay taxes, alleged pedophilia, and much more.  There is an absolutely false article on Business Week’s website posted by Dombrowski that claims the Plaintiff is a sexual deviant.  The Plaintiff’s personal photos, photos of family members, as well as photos and alleged photos of his family have been published to damage the Plaintiff and in violation of his privacy and intellectual property rights. The matters publicized would be offensive to a reasonable person.  The disclosures have humiliated the Plaintiff.
  6. The Plaintiff has been portrayed in an absolutely false light to the public.

COUNT VII – CONSPIRACY TO COMMIT DEFAMATION

  1. The facts in paragraphs 21-65 are incorporated herein.
  2. The elements for civil conspiracy under Kansas law are: (1) Two or more persons; (2) an object to be accomplished; (3) a meeting of minds on the object or course of action; (4) one or more unlawful overt acts; and (5) damages as the proximate result thereof.
  3. Defendants conspired to defame the Plaintiff.
  4. Defendants formed and operated the conspiracy.  The object to be accomplished was to defame, libel, slander, harass, cyberstalk, falsely charge the Plaintiff with felonies, cause emotional distress, and damage the Plaintiff.  Evidence shows that Defendants had a meeting of the minds and actively worked together toward this objective.
  5. Multiple overt acts were committed.  A substantial act or substantial effect from the conspiracy occurred in Kansas.  Defendants knew of the acts to be committed in Kansas and the impact in Kansas of acts done elsewhere in furtherance of the conspiracy.  The act in, and effect on, Kansas was a direct and foreseeable result of the conduct in furtherance of the conspiracy.
  6. Damage resulted to the Plaintiff from acts done in furtherance of the common design.  The Plaintiff has been caused pain and suffering, emotional distress, lost enjoyment of life, loss of his marriage, loss of his relationship with his family, loss of his home, severe damage to his reputation, damage to his career, and more.  The Plaintiff’s business relationships have been severely damaged.  The Plaintiff’s reputation is now sullied by a massive amount of absolutely false, defamatory information online.  This defamation likely can never be erased because it is breeding in cyberspace.

PUNITIVE DAMAGES

45.          The facts in paragraphs 21-65 are incorporated herein.

46.          The Defendants acted intentionally to damage the Plaintiff.  This isn’t the case of someone slipping up and making one false statement.  The actions of the Defendants were deliberate.  Defendants’ conduct as described above is willful, wanton, wicked, intentional, and malicious resulting from fraud, insult, and malice, and it is associated with aggravating circumstances, including willfulness, wantonness, malice, oppression, outrageous conduct, insult, and fraud, thus warranting the Plaintiff’s recovery of punitive damages from the Defendants, to be determined by the trier of fact.  The Plaintiff should receive an award of punitive damages.  Exemplary damages serve to provide the claimant with recovery above and beyond compensatory damages in order to punish the wrongdoer for egregious conduct and to deter the wrongdoer and others from similar conduct in the future. Since the Plaintiff’s damages can never be erased in this case; there is no amount of money that could compensate the Plaintiff for the loss of the loves of his life, his wife, children, and grandchildren; there is no amount of money to compensate a decent, honest, law-abiding citizen for the destruction of his reputation.

JURY TRIAL

Plaintiff demands a jury trial.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests that the Defendants be cited to appear and answer, and that on final trial, Plaintiff has the following:

  1. Judgment against Defendants for economic, pecuniary, lost profits, consequential, and incidental damages;
  2. By reason of Defendants’ knowing and intentional conduct, mental anguish damages in an amount within the jurisdictional limits of the Court;
  3. Prejudgment interest as provided by law;
  4. Exemplary and punitive damages appropriate to deter any future willful conduct;
  5. Attorney’s fees;
  6. Costs of suit;
  7. Post-judgment interest as provided by law;
  8. An Order that Defendants remove all false information regarding Plaintiff from the Internet;
  9. An Order that Defendants retract all false statements made by Defendants regarding Plaintiff;
  10. An Order that Defendants cease all false statements regarding Plaintiff; and
  11. Such other and further relief to which Plaintiff may be justly entitled.

Submitted this 12th day of September, 2013,

_________________________

William M. Windsor

For more information, see:

Ellis County Texas — Ellis County Texas Corruption — Ellis County Texas District Attorney Patrick Wilson — Ellis County Texas Jail — Ellis County Texas Judge Bob Carroll — Ellis County Mafia — Ellis County Texas Sheriff Johnny Brown — Joeyisalittlekid.blogspot.com — Lawless AmericaMissoula County Judge John W. LarsonMontana MafiaTexas Extradition Law — University of Montana EmployeeJoeyisalittlekid — Albert FioriniAllie OverstreetAmerican Mothers Political Party — Betsi BixbyBrandy OwenBrannon BridgeBrenda WilliamsonCarrie WaltersCasey P. HargroveCheryl SosbyClaudine DombrowskiClyde HargroveConnie BedwellCurtis W. ButlerDale TrowbridgeDavid HargroveDeanna KloostraDeborah ParksDiane GochinGail LakritzHargrove Real EstateJay HoskinsJennifer DotsonKathy A. CarrollKC HargroveKellie McDougaldKimberly WigglesworthKinley HardinL WilsonLorraine TiptonLoryn RyderMadeline HargroveMark SupanichMary BagnaschiMegan Van ZelfdenMelanie WhiteMichelle StilipecMorgan HargroveNancy RolfeRenee HarringtonSam RoundSean D. FlemingShannon MillerShonda HargroveSid Wallingford GrayStacy EmersonTrinity Baker

Contact Bill Windsor at Bill@BillWindsor.com — www.LawlessAmerica.com — www.facebook.com/billwindsor1www.youtube.com/lawlessamerica — www.imdb.com/title/tt2337260/ — www.LawlessAmerica.org — www.twitter.com/lawlessamerica

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