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Runyon Reply to Thomas A Mix Affirmative Defenses .pdf



Original filename: Runyon Reply to Thomas A Mix Affirmative Defenses.pdf
Title: IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY FLORIDA
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IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL
CIRCUIT IN AND FOR INDIAN RIVER COUNTY FLORIDA

THOMAS MIX,
Counter-defendant/Plaintiff

Case No 31-2015-CA-00961
REPLY TO COUNTER-DEFENDANT'S
AFFIRMATIVE DEFENSES

vs.
JEANETTE TYE RUNYON,
Counter-claimant/Defendant
__________________________/

REPLY TO COUNTER- DEFENDANT’S RESPONSE TO COUNTERCLAIM
Comes now counter-claimant/defendant JEANETTE RUNYON hereby files
this reply to Counter-defendant/Plaintiff’s THOMAS MIX Affirmative Defenses
set forth Counter-defendant/Plaintiff’s THOMAS MIX answer to counterclaimant/defendant JEANETTE RUNYON counter-claim.

-1REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

1. In paragraph 1. Counter-defendant/Plaintiff’s THOMAS MIX through
counsel now denies that counter-claimant/defendant JEANETTE
RUNYON, embarked on and “electronic campaign to destroy Plaintiff
physically, emotionally, and to personally interfere with Plaintiffs’ life,
reputation, and personal safety.” This directly contradicts Counterdefendant/Plaintiff’s THOMAS MIX original lawsuit Further counterdefendant/Plaintiff’s THOMAS MIX denies that he tweeted #Runyon
liked my cities page on FB. Starting to stalk again” That is false statement;
in fact on 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted those exact words.
2. In paragraph 5. Counter-defendant/Plaintiff’s THOMAS MIX through
counsel falsely denies that he accused counter-claimant/defendant
JEANETTE RUNYON of being a criminal, a human trafficker, mentally
ill and a stalker. That is simply not true see following examples:
a. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted “She's a criminal and professional stalker.”
b. On 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted: “#Conservative Convicted Criminal #JeanetteRunyon
having others harass me.”
c. On 13 Oct 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted You've know Runyon is a criminal.”
d. On 4 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted: “Jeanette is a professional conservative stalker … She's a
fake Christian. Only a criminal.”
e. On 4 Feb 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
-2REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

RUNYON “That’s right cunt. I use just as much tolerance as you
depict in your actions, filthy disgusting criminal."
f. On 2 Feb 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "You’re a fucking nut Jeanette. You’re a criminal who
pleaded guilty."
g. On 17 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted “Jeanette is a criminal stalker.”
h. On 2 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted "She is entering my conversations as well. Little baby
buying stalker."
i. On 16 Apr 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "this lady tried to trafficking an infant and got caught
thank god."
j. On 16 Apr 2014 Counter-defendant/Plaintiff’s THOMAS MIX also
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Beware #JeanetteVictoriaRunyon #NC. She is a
crimal and tried to human traffick a BABY back the US."
k. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted; “Its funny that Jeanette Runyon thinks she’s decent after
trying to smuggle a baby you into the US....”
l. On 15 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted “When the stupid stalking human trafficking criminal
should know if she properly searched Google, she'd know what...”
m. On 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
-3REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

RUNYON "Gotta love all these fake Christians that break laws,
smuggle babies, and all other sorts of vile crimes."
n. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted "omfg look at this baby buying freak. Jeanette Runyon
release your court documents...."
o. On 21 Jan 2014 Counter-defendant/Plaintiff’s THOMAS MIX
tweeted on 21 Jan 2014, “She's been admitted to a mental
hospital involuntarily…She may be bi-polar or may hear
voices.”
p. On 1 Feb 2014 Plaintiff THOMAS MIX tweeted “Jeanette T
Runyon. You’re a #stalker with severe mental issues.”
q. Plaintiff THOMAS MIX tweeted on 11 Oct 2014 posted about
“She has been institutionalized.”
r. On 6 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "The human trafficker is currently suspended."
s. On 8 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Not all Virgo's buy babies and try to smuggle
them."
t. On 18 Oct 2014 Plaintiff THOMAS MIX Tweeted “Runyon has
been diagnosed w/w Borderline Personality Disorder...was
institutionalized in a mental health facility... prescribed
Risperdal.”
u. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "She's a criminal and professional stalker."
-4REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

v. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted "This is my stalker Jeanette Runyon."
w. On 26 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Psycho conservative stalker is still mentioning me in
comments. Still obsessed."
x. On 15 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted "As #JeanetteRunyon can see its not about her. Fucking
stalker."
y. On 1 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "She's evil stalker incarnate"
z. On 1 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted "Trying to get me suspended? You’re the stalker. And it is
on going, by you Jeanette Runyon."
aa. On 18 Jun 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted

"#No1Important00

is

stalker

and

Criminal

#JeanetteRunyon use caution when tweeting to her."
bb. On 16 Mar 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to JEANETTE RUNYON "She clearly is a
stalker."
3. Further in Paragraph 5. Unbelievably Counter-defendant/Plaintiff’s
THOMAS MIX had the audacity to deny that he has a blog devoted to
“exposing” the Counter-claimant/defendant JEANETTE RUNYON.
Counter-defendant/Plaintiff’s THOMAS MIX has two blogs where he
posts

about

Counter-claimant/defendant

JEANETTE

RUNYON

-5REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

“staking” him (according Counter-defendant/Plaintiff’s THOMAS MIX
the mere mention of his name is stalking) http://periabo.tumblr.com and
http://thomasamix.tumblr.com/ both blogs have dozens of screen shots
of Counter-claimant/defendant JEANETTE RUNYON Facebook posts
old tweets, and Disqus comments which he claims is harassment. Further
Counter-defendant/Plaintiff’s THOMAS MIX falsely denies he 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 Defendant arrested.
a. On 10 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "A person may be missing a Facebook."
b. On 11 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Yeah she needs to use Disqus cause her Facebook is
suspended. Her other two will be down soon hopefully."
c. On 11 12 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "You think she misses her Facebook?"
d. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Calling her district attorney now to see what can be
done about hack attempts."
e. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Contacted (336) 242-2100 her local Sheriff."
-6REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

f. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Transferring to FBI near Lexington. Calling them now.
Referred by Sheriff."
4. In paragraph 7 Counter-defendant/Plaintiff’s THOMAS MIX contradicts
his original lawsuit where he alleges Counter-claimant/defendant
JEANETTE RUNYON called him a pedophile or a pedophile supporter.
He now claims that he no knowledge of the allegations and therefore,
denies any and all claims.
5. In paragraph 8 Counter-defendant/Plaintiff’s THOMAS MIX now claims
that he has no knowledge that Counter-claimant/defendant JEANETTE
RUNYON printed or caused to be or printed false allegations regarding
Plaintiff‘s conduct, character, sexual orientation, beliefs, and criminal
activity. That directly contradicts what Counter-defendant/Plaintiff’s
THOMAS

MIX

states

in

his

lawsuit.

Further

Counter-

defendant/Plaintiff’s THOMAS MIX now claims that he has no
knowledge of his outrageous claim that blogger Robert Stacy McCain
posted “sealed juvenile records” on his blog. That is another fabrication
as Counter-defendant/Plaintiff’s THOMAS MIX tweeted on 17 Apr 2014
“Robert Stacy McCain loves hosting sealed documents on his website of
minors.”
6. In paragraph 8 Counter-defendant/Plaintiff’s THOMAS MIX has the
audacity to deny what he originally claimed in his defamation lawsuit, that
Counter-claimant/defendant JEANETTE RUNYON insinuated or cause
-7REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

to be insinuated that the Counter-defendant/Plaintiff’s THOMAS MIX is
a criminal, which directly contradicts his suit.
7. In paragraph 9. Counter-defendant/Plaintiff’s THOMAS MIX

now

denies that Counter-claimant/defendant JEANETTE RUNYON called,
insinuated or cause to be insinuated that the Plaintiff is a criminal in
contradiction to Counter-defendant/Plaintiff’s THOMAS MIX original
defamation lawsuit.

Further Counter-defendant/Plaintiff’s THOMAS

MIX denied that he has posted that Counter-claimant/defendant
JEANETTE RUNYON 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.
a. See paragraph 2 a-bb for Counter-defendant/Plaintiff’s THOMAS
MIX

quotes

where

he

calls

Counter-claimant/defendant

JEANETTE RUNYON a human trafficker, a baby buying freak,
convicted criminal, a professional cyber-stalker, a danger to
children, and she is severely mentally ill, hears voices may be bipolar and has been institutionalized, and needs to be committed
again.
b. On 28 Jun 2016 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Thanks for that link with the sealed record. Let's see
what it's hiding, shall we?!"
-8REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

c. On 14 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "has sealed court documents she knows she had them
sealed."
d. On 17 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "I keep asking her to release her sealed court docs."
e. On 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "I can't believe many #conservatives have criminal
records in their adult lives. Stalking, trying to smuggle in babies,
defamation."
f. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted "omfg look at this baby buying freak. Jeanette Runyon
release your court documents...."
g. On 7 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "And she won't release her sealed court docs involving
the Ukraine incident."
h. On 7 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "I keep asking her to release her sealed court docs, cause
she says I'm lying. I tell her prove."
i. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX
Tweeted referring to Counter-claimant/defendant JEANETTE
RUNYON "Then release your court documents from the case. You
have them sealed Jeanette Runyon."
-9REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


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