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World of Discovery Defamation Complaint

World of Discovery Defamation Complaint

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Published by asamahavv
World of Discovery Defamation Complaint
World of Discovery Defamation Complaint

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Published by: asamahavv on Mar 04, 2014
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04/15/2014

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NYSCEF DOC. NO.
.1
RECEIVED NYSCEF:
02/14/2014
SUPREME COURT OF THE STATE OF
NEW
YORK COUNTY OF QUEENS WORLD OF DISCOVERY
DAY
CAMP OF QUEENS INC., Plaintiff, -against-LOREDANA JOHANSMEYER, EDWIN JOHANSMEYER, DONNA JOHANSMEYER, AND MICHELE BETTI,
SUMMONS
Index
No. Plaintiff designates New York County as the place
of
trial. Defendants.
C
t
e~0
CO
(J
33D
6rd
fJ K:
Ny
1
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IOOOd-
To the above-named defendants: Venue is based on the residence
of
Defendants.
YOU RE HEREBY SUMMONED
to answer the complaint in this action and to serve a copy
of
your answer, or
if
the complaint is not served with this summons, to serve a notice
of
appearance, on the plaintiff s attorney within twenty
20)
days after the service
of
this summons, exclusive
of
the day
of
service,
or
within thirty 30) days after service is complete
if
this summons is not personally delivered to you within the State
of
New York.
n
case
of
your failure to appear
or
answer, judgment will be taken against you
by
default for the relief demanded in the complaint. This is an action to obtain relief for defamation, tortious interference with actual and prospective business relations, aiding and abetting, and injunctive relief. Dated: February
13 2014
1017849\·4 013390.0101
MOSES SINGER LLP By:
~~ Z~~
Jaso anales C istina
M.
Gaudio
ttorn
s
or
the Plaintiff
405
exington Avenue,
12 h
Floor Ne York,
New
York
10174
Tel:
212) 554-7800
 
 
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.
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.
NYSCEF DOC,.
NO
SUPREME COURT OF THE STATE OF
NEW
YORK COUNTY OF QUEENS WORLD
OF
DISCOVERY DAY CAMP
OF
QUEENS INC., -against-Plaintiff, LOREDANA JOHANSMEYER, EDWIN JOHANSMEYER, DONNA JOHANSMEYER, AND MICHELE BETTI, Defendants.
RECEIVED NYSCEF:
02 14 2014
VERIFIED COMPLAINT
Index No. Plaintiff WORLD OF DISCOVERY DAY CAMP OF QUEENS ( Plaintiff' or the Camp ), for its complaint against Defendants EDWIN JOHANSMEYER, LOREDANA JOHANSMEYER, DONNA JOHANSMEYER (collectively referred to herein as the Johansmeyer Defendants ) and MICHELE BETTI ( Betti ) (collectively, the Defendants ), alleges as follows:
NATURE OF ACTION
1
This is an action for defamation, tortious interference with actual and prospective business relations, aiding and abetting the same, and injunctive relief. On December 1,2010, Defendants Edwin Johansmeyer and Loredana Johnasmeyer, on behalf
of
themselves and their son Anthony Johansmeyer, filed a lawsuit against the New York City Department
of
Education, the City
of
New York, the Child Center
of
New York, Inc., and Plaintiff (hereinafter referred to
as
the Negligence Suit ), alleging, in part, that Anthony Johansmeyer was sexually assaulted and abused on the premises
of
his public school, an after-school program and the Camp by an individual named Joseph Denice. 2. During depositions in the Negligence Suit, Loredana Johansmeyer and Anthony Johansmeyer each testified unequivocally that Anthony Johansmeyer
w s not
sexually assaulted
1017849v4 013390.0101
 
or
abused at the Camp,
but
instead, was sexually assaulted and abused
by
Joseph Denice
t his
home
months prior to his attendance at the Camp. 3. Realizing that these admissions would prove fatal to their case, Anthony's parents Edwin and Loredana Johansmeyer, through Michele Betti, Esq. ( Betti ), their attorney, attempted to extort a settlement from the Camp.
On
January 2,
20I4,
Betti sent an email to counsel for the Camp stating that
if
the parties could not reach a settlement, the [Johansmeyers] are not going to live
in
silence anymore regarding this matter and will this spring and summer under their First Amendment right warn other campers about the dangers
of
World
of
Discovery Day Camp
of
Queens
....
A settlement was not reached and nine days later Defendants went well beyond their threat: Rather than merely exercising their First Amendment rights, Defendants began to actively deter parents from enrolling and re-enrolling their children in the Camp through disseminating statements about the Camp that were false and defamatory by their
own
prior sworn admissions.
None
of
that is protected
by
the First Amendment or otherwise.
4
Specifically, on January
12,2014,
Edwin and Loredana Johansmeyer and their daughter Donna J ohansmeyer appeared at an open house hosted
by
the Camp for prospective and returning campers and their parents.
At
that open house they distributed to parents a flyer (attached hereto as Exhibit A), drafted upon information and belief
by
their lawyer Betti, containing false and defamatory statements about the Camp. For instance, the very first sentence
of
the flyer distributed
by
these Defendants falsely stated
We
are parents
of
a child who was molested at World
of
Discovery Day Camp
of
Queens
by
a counselor, Joseph Denice (who worked here roughly from 2003 through 2009). On February 9, 2014, the Johansmeyer Defendants appeared again at an open house hosted
by
the Camp and distributed the same flyer.
1017849v4 013390.0101
2

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