Runyon vs Thomas A Mix COUNTERCLAIM FOR DEFAMATION .pdf
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IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY FLORIDA
Case No 31-2015-CA-000961
COUNTER-CLAIM FOR DEFAMATION
AND INTENTIONAL INFLICTION OF DISTRESSADMENDED
JEANETTE TYE RUNYON,
1. The Complaint filed in this action by Plaintiff is a complete work of fiction. It is just
one more example of Plaintiffs’ malicious multi-year harassment and defamation
campaign that Plaintiff in concert with others has conducted against the Defendant.
Plaintiffs’ Complaint contains the outrageously false allegations that Defendant
stated or implied that he is a pedophile; stalked his family members, published his
home address and falsely implied that he committed criminal acts. Further Plaintiff
has falsely claimed that Defendant embarked upon an “electronic campaign to
destroy Plaintiff physically, emotionally, and to personally interfere with Plaintiffs’
life, reputation, and personal safety.” Not only is this not true it is an outrageous lie.
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In fact it has been the Plaintiff who has embarked on a multi-year campaign to
destroy Defendant, physically, emotionally, and to personally interfere with
Defendants’ life, reputation, and personal safety. Making such extreme false
accusations with the sole intention of causing undue harm is simply inhumane.
Behavior, such as Plaintiffs’ not only destroy the lives of the people who are
wrongfully accused, but they also place unnecessary burden, emotional and physical
distress on the victim, and also on the victim’s family and friends. Plaintiff even
bizarrely tweeted “#Runyon liked my cities page on FB. Starting to stalk again”. Is
the Plaintiff so obsessed with harassing the Defendant that he will use the excuse
that she liked his cities public Facebook page to further defame and accuse the
Defendant of committing a crime?
2. Defendant submits this Counter-complaint for defamation and intentional infliction
of emotional distress (“Counter-complaint”) to redress the harm caused by Plaintiffs’
attempt to ruin and destroy Defendants’ life.
3. Defendant is an individual, over the age of eighteen and, at all times relevant hereto,
a resident of Davidson County, North Carolina.
4. Plaintiff is an individual, over the age of eighteen and, at all times relevant hereto, a
resident of Vero Beach, Florida.
STATEMENT OF FACTS
5. Defendant first encountered Plaintiff sometime in April 2013 when he burst on her
Twitter timeline using vile ad hominems and falsely accusing her of being a criminal,
a human trafficker, mentally ill and a stalker. Since then the Plaintiff has been
obsessed with destroying the Defendant reputation and has openly declared that he
is going to “bring her down” and that he would like to see the Defendant removed
from the internet altogether and committed to a mental institution. Plaintiff has
boasted about shutting down Defendants’ Twitter account and Defendants’
Facebook account and has reported Defendant to Defendants’ local District
Attorney, local Sheriff’s department, and the FBI in a failed attempt to have
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Defendant arrested. Plaintiff has a blog devoted to “exposing” the Defendant,
further defaming Defendant by insisting that the Defendant is a convicted felon with
sealed criminal records who is stalking the Plaintiff, when in fact it is the Plaintiff
that is cyber-harassing the Defendant. Plaintiff uses various aliases and has
accomplices to help him secure his goal of completely disenfranchising the
6. In reality, it is Plaintiff who has set out to destroy the Defendants’ reputation:
repeatedly seeking to interfere with her good name and reputation, personally and
professionally, jeopardizing Defendants’ personal safety and prohibits Defendant
from exercising her first amendment rights to free speech. Plaintiff has boasted of
doing so on his personal, yet very public, Twitter, Facebook and Tumblr social
media accounts. Furthermore, it is the height of hypocritical overreach by the
Plaintiff that he feels he is entitled to lie about and defame Defendant for years but
objects when Defendant takes notice of his ongoing, targeted abuse of her.
7. Plaintiff has falsely claimed that Defendant called him a pedophile or a pedophile
supporter; nothing can be further from the truth. Defendant has a degree in
psychology and is a Licensed Psychiatric Technician in the State of California.
Defendant has been trained to deal with Mentally Disordered Sex Offenders unit.
Defendant would never say anything so contrary to Defendants’ training. In fact it is
the Plaintiff who has implied repeatedly on Plaintiffs’ public Twitter feed that the
Defendant is a danger to children, and Plaintiff claims that all Defendant’s friends
are pedophile enthusiasts and has no problems tweeting that others are pedophiles.
8. Plaintiff states the Defendant printed or caused to be or printed false allegations
regarding Plaintiff‘s conduct, character, sexual orientation, beliefs, and criminal
activity. That is untrue. Defendant has never printed any false printed materials
against the Plaintiff. Defendant has no control what others write about the Plaintiff’s
abusive public posts and aggressive online behavior. Plaintiff outrageously claimed
that blogger Robert Stacy McCain posted “sealed juvenile records” on his blog
TheOtherMcCain.com and further the Plaintiff blamed the Defendant. That is a
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complete and total fabrication. And begs the question how a private citizen could get
access to such documents? There are no sealed juvenile records about Plaintiff on
anyone’s blog. If Plaintiff objected to what was written Plaintiff should have sued the
authors of said “printed materials” rather than misusing the court to further harass
9. The Plaintiff claims that the Defendant called, insinuated or cause to be insinuated
that the Plaintiff is a criminal is also untrue and the claim is especially egregious
coming from the person who has for years publicly posted several hundred times
that the Defendant is a human trafficker, a baby buying freak, convicted criminal, a
professional cyber-stalker, a danger to children, who has her criminal records sealed,
a welfare queen and she is severely mentally ill, hears voices may be bi-polar and has
been institutionalized, and needs to be committed again. All of Plaintiff claims are
10. The Plaintiff himself has several fake Facebook pages, (John Doeman, Michael Jon
Ortiz, and James/Jim Davis) which he has used to propagate his defamation about
the Defendant. Plaintiffs’ “Jim Davis” persona was especially odious as he posted a
number of Pinterest (https://www.pinterest.com/davis8500/race-relations-of-christthe-king-anglican-church) and Facebook pages aimed at Defendant as well as her
church and calling them a “hate group!” After two years of this abuse Plaintiff was
successful at manipulating the new Vicar to expel the Defendant from her
11. Further, Plaintiff using several Twitter handles, (@Tamix2011 @Periabo
@__Lazarus__ @_Lazarus___ ) to engage in a multi-year cyber-harassment
campaign toward the Defendant. Plaintiff posted that Defendant is a confessed
human trafficker, a convicted criminal, has sealed criminal records, is mentally ill
hears voices and has been involuntary committed. Defendant has no such
conviction; in fact the Defendant has no felony convictions whatsoever, nor does the
Defendant have sealed criminal records, the Defendant is not mentally ill, nor does
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the Defendant hear voices and the Defendant never been involuntary committed and
12. Plaintiff spread these vile lies too as many anti-trafficking persons and groups as
possible and as a result the Defendant is has become the target of hateful and
disturbing messages calling her a felon and criminal.
13. Plaintiff even inserted himself into a comments section of a blog
(http://www.crimeandfederalism.com/2015/05/ever-had-the-police-called-on-youfor-blogging.html) and called the Defendant a criminal, falsely claimed that
Defendant stalked family members and post addresses of people who disagree with
the Defendant. Plaintiff also falsely claimed that the Defendant was using that blog
to stalk him. Defendant never mentioned Plaintiffs’ name, yet the Plaintiff inserted
himself into the conversation, then he outrageously claimed he was the victim of
14. Plaintiff has falsely claimed that Defendant created a meme using a head shot of
Plaintiff with his support of statutory rapist Kaitlyn Hunt having sex with a minor as
expressed on Plaintiffs’ blog https://pariabos.wordpress.com. That is another lie.
In fact the meme is still visible on Brandon Morales @ConvictKate account on
Twitter and has remained visible for over two years without single protest from
Plaintiff. Plaintiff even reposted the meme on his on his own Twitter and Twicsy
account and I quote“@rachiez3 look she made me into a meme! LMAO.” And the
meme remains visible to the public to this day. Since this photo has remained on
Brandon Morales @ConvictKate Twitter feed and the Plaintiff’ Twicsy account for
over two years with no objections from the Plaintiff, his outrage to having this photo
posted is obviously manufactured for one reason only to further harass and annoy
15. In addition Plaintiff Mix has stolen Defendant’s voice teacher’s copyrighted photos
and her churches copyrighted photos and altered them for the purpose of ridicule.
The Plaintiff also added his own personal message on the false report about the
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Defendants Newborn photography on RipOffReport.com repeating his favorite lie
that the Defendant is a criminal and a human trafficker. As a result Defendant had
to shut down her Photography Facebook page and her newborn photography
webpage which has cost Defendant tens of thousands of dollars in lost business
16. As a result of Plaintiff the multi-year harassment and defamation campaign toward
Defendant, Defendant has been forced to shut down her photography webpage and
Facebook page. Defendant has lost the fellowship of the church that she belonged
too for eight years. Because the Plaintiff has posted that the Defendant is a human
trafficker 100's of time Defendant gets unsolicited messages in her Facebook private
messaging system that she is a felon and a criminal.
17. Defendant no longer answers the phone due the amount of crank calls. Defendant
is fearful to leave Defendants’ home because of Plaintiffs’ actions. The Defendant
refuses to leave her residence unless the Defendant takes her dogs with her as the
Defendant no longer feels safe because the Plaintiffs’ smears have been extremely
vast and extensive. Defendant lost a position she was offered as the US coordinator
in a start up conservative group The American Traditionalist Society, as a result of
the Plaintiff propagation of the horrific lie that she was a convicted human trafficker.
18. Defendant is a Christian vocalist who sings primarily in churches but she has been
hesitant to take her musical career further because Defendant doesn’t want to have
to explain to the churches she sings at that she is not a human trafficker and had no
felony conviction and has never stalked anyone. Defendant is also convinced if her
singing got any publicity that the Plaintiff and his cohorts would in fact contact the
church she was performing at and defame her further; just like he did with her last
FIRST CAUSE OF ACTION
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19. Defendant realleges and incorporates herein by reference Paragraph 1 through 18,
inclusive, of this Counter-Complaint.
20. Plaintiff has harmed Defendant by making numerous false statements regarding
Defendant (the “False Statements”) for the purpose of intimidation, damaging
Defendants’ reputation, interfering with Defendants’ personal off line life and
turning other people against Defendant; and shutting Defendant up by driving
Defendant off the internet altogether. These False Statements posted/published on
the internet by the Plaintiff are:
• Defendant is a professional stalker
• Defendant called or insinuated that Plaintiff is a pedophile
• Defendant is a criminal and repeat offender
• Defendant is a human trafficker
• Defendant’s criminal records are sealed
• Defendant is severely mentally ill hears voices may be bi-polar and was
• Defendant caused false printed materials to be distributed that would cause
people to conclude that plaintiff committed criminal acts
• Defendant stalks family members of people who disagree with her
• Defendant stalked Plaintiff’s family and posted their home address
• Defendant posts addresses of people who disagree with her
• Defendant intentionally threatened Plaintiffs personal safety
• Defendant stalked and threatened a young mother
• Defendant’s husband, Larry Woolslayer has left her
• Defendant may be a lesbian
• Defendant is a welfare queen
21. These False Statements are all lies and are defamatory, Defendant has never been
indicted tried or convicted of the crime of human trafficking. She has no sealed criminal
records. She is not a “professional” stalker. Defendant has never stalked anyone let
alone the Plaintiff or his family members. Defendant does not hear voices, she is not bipolar and has never been involuntary committed to a mental hospital and has never been
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institutionalized. Defendant has never called the Plaintiff a pedophile or pedophile
22. There were no false printed materials. The Plaintiff’s own mother filed an
application for a protection order against domestic violence because of battery upon
his father, which is a matter of public record easily found on the Indian River clerk’s
page http://ori.indian-river.org/home/index and therefore NOT privileged. It is
clearly stated on the application that the Plaintiff committed battery upon his father.
23. Defendant has never threatened Plaintiffs personal safety.
24. Defendant has never stalked anyone, responding to public posts on Twitter is not
stalking. Asking someone to stop posting the lie that the Defendant is a convicted
human trafficker is not a threat.
25. Defendant is not a lesbian.
26. Defendant is still married, her husband has not left her and she is not collecting
welfare nor has she ever collected welfare.
27. All of the False Statements are defamatory on their face an there is no legitimate
purpose for making such statements other than to injure and harm the Defendant.
Many of the statements made by the Plaintiff falsely accuse the Defendant of
committing criminal acts and felonies. Plaintiff posted these false allegations with
malice and even publically boasted that he did not care if they were true or not.
Plaintiff was informed numerous times that the document he claimed was evidence of
Defendant felonious crimes was simply a criminal complaint to obtain a search
warrant and that is clearly stated on said document; he was further informed that the
Defendant that no such indictment or conviction and is not a felon. The Plaintiff
then posted that the Defendant probably got some Christian group to seal her
criminal records and began demanding that she unseal them. Defendant has no
sealed criminal records. This is just another outrageous lie by the Plaintiff.
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28. The False Statements made by the Plaintiff would cause a reasonable person to
believe that the Defendant is a dangerous criminal who is especially dangerous
29. The False Statements published by Plaintiff on Twitter, Facebook, Tumblr, and
Pinterest and propagated to as wide an audience as possible. Defendant is still
finding reposts that she is a human trafficker on various religious and anti-human
30. Plaintiff acted with actual malice to cause harm and with the intent to cause injury to
Defendant, which entitles Defendant to punitive damages. Plaintiff made the False
Statements with actual knowledge of their falsity. Plaintiff was made well aware
many times that Plaintiffs’ statements were false but Plaintiff persisted in repeating
and spreading the defamation specifically to cause damage to the Defendant.
31. The False Statements from the Plaintiff are libelous on their face and is defamation
per se, because he claims that the Defendant has engaged in criminal conduct. As
such, the False Statements clearly exposes Defendant to hatred, contempt, ridicule
and obloquy, and/or causes Defendant to be shunned or avoided, and has a
tendency to injure Defendant in her professional and personal life.
32. Defendant has falsely stated the Plaintiff has been involved in several kinds of
serious criminal activity. Florida has singled out defamation per se cases for special
treatment. There’s no need for the plaintiff to prove malice on the part of the
defendant. “[T]he law presumes malice in their utterance,” Abraham v. Baldwin, 52
Fla. 151, 42 So. 591, 592 (1906), where the words are “… of such common notoriety
established by the general consent of men, that the courts must of necessity take
judicial notice of its harmful effect.” Layne v. Tribune Co., 108 Fla. 177, 146 So. 234,
236 (1933). In Lawnwood Medical Center Inc. v. Sadow, 43 So. 3d 710, 729 (Fla.
4th DCA 2010) It is stated “The personal interest in one’s own good name and
reputation surpasses economics, business practices or money. It is a fundamental
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