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Letter From Plaintiffs' Counsel & Complaint

Letter From Plaintiffs' Counsel & Complaint

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Published by Ben Sheffner
Letter From Plaintiffs' Counsel to Ripoff Report and & Complaint in Blockowicz v. Williams
Letter From Plaintiffs' Counsel to Ripoff Report and & Complaint in Blockowicz v. Williams

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Published by: Ben Sheffner on Dec 24, 2009
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05/27/2012

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ALBANYAMSTERDAMATLANTAAUSTINBERLIN**BOSTONBRUSSELS**CHICAGODALLASDELAWAREDENVERFORT LAUDERDALEHOUSTONLAS VEGASLONDON*LOS ANGELESMIAMIMILAN**NEW JERSEYNEW YORKORANGE COUNTYORLANDOPALMBEACH COUNTYPHILADELPHIAPHOENIXROME**SACRAMENTOSHANGHAISILICON VALLEYTALLAHASSEETAMPATOKYO**TYSONS CORNERWASHINGTON, D.C.WHITE PLAINSZURICH**
OPERATES AS GREENBERGTRAURIG MAHER LLP
**
STRATEGICALLIANCE
GREENBERGTRAURIG,LLP
ATTORNEYSATLAW
WWW.GTLAW.COM77WestWackerDrive,Suite3100
Chicago,Illinois
Tel312.456.8400
Fax312.456.8435Cameron M. NelsonTel 312.456.6590Fax 312.456.8435NelsonC@gtlaw.com
October 13, 2009
VIAE-MAIL
Ed MagedsonRippoff ReportPO Box 310Tempe, Arizona, 85280EDitor@RipoffReport.comRe: Blockowicz et al. v. Williams et al., Case No. 09-cv-03955 (N.D. Ill.)Our File No. 119963.010100Mr. Magedson:We represent David, Mary and Lisa Blockowicz. They are being collectively harassedby David Williams and Michelle Ramey, who are posting disgusting, false anddefamatory statements about them on the Internet, including your own site. Having noother recourse, we filed suit in Federal Court and, after the Defendants defaulted,obtained an order that these false statements be taken down. The original Complaint andthe Permanent Injunction are enclosed.As you can see, the Court has authorized us to engage the assistance of third parties,such as yourself, to ensure compliance with the Court’s order that these false statementsbe removed. The Defendants have refused to obey the Court's order and have evendeclared (on other websites) that they do not intend to obey the order. Per the attachedCourt order, please immediately remove the offending posts and their comments. Thereport numbers are 445743, 70642, and 69190.Please contact me immediately if you have any questions or comments.Very truly yours,Cameron M. NelsonCMN:amk Enclosures
CHI 58,697,220v1 10-13-09 
 
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CHI 58,381,759v2 6-29-09 
IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF ILLINOISEASTERN DIVISIONCOMPLAINT
Plaintiffs David Blockowicz and Lisa Blockowicz allege against Defendants JosephDavid Williams and Michelle Ramey as follows:
NATURE OF ACTION
1. This is an action for defamation, including defamation
per se
, false light, andreckless infliction of emotional distress. Plaintiffs seek compensatory damages, punitivedamages, attorneys’ fees, costs, and preliminary and permanent injunctive relief.
JURISDICTION AND VENUE
2. This Court has diversity jurisdiction over this case pursuant to 28 U.S.C. §§ 1332.3. This Court has personal jurisdiction over Defendants Joseph David Williams andMichelle Ramey, currently residents of Oregon, because they have intentionally directed harmfuland egregious tortious acts at Plaintiffs, causing injury and having other harmful effects in thisstate, related to this specific cause of action. 735 ILCS 5/2 209; Fed.R.Civ.P. 4.4. Venue is proper in the United States District Court for the Northern District of Illinois pursuant to 28 U.S.C. § 1391(a)(2).David Blockowicz, Mary Blockowicz, and LisaBlockowicz, individuals,Plaintiffs,v.Joseph David Williams and Michelle Ramey,individuals,Defendants.))))))))))Civil Action No.:Judge:Magistrate:
 
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CHI 58,381,759v2 6-29-09 
PARTIES
5. David Blockowicz is 67 years old, and resides in Illinois with his wife of forty-two (42) years, Mary Blockowicz. He is a principal of his own accounting firm, Blockowicz andTognocchi LLP, which has a principal place of business at 1701 East Lake Avenue, Suite 480,Glenview, Illinois.6. Lisa Blockowicz is also an Illinois resident and the oldest of David and MaryBlockowicz’s four adopted children. She is 39 years old, and an elementary school teacher forChicago Public Schools. Though not parties to this case, Lisa’s other siblings are Brendan, age38, Megan, age 36, and Scott, age 34.7. In or around 1992, Megan Blockowicz married Defendant Joseph DavidWilliams. Megan Blockowicz and Joseph David Williams divorced in or around 1999 or 2000.Joseph David Williams was physically and emotional abusive to Megan Blockowicz and, as setforth below, he has begun directing his aggressive behavior towards Megan’s family, includingMegan’s parents David and Mary Blockowicz, and her sister Lisa Blockowicz. On informationand belief, Joseph David Williams resides in or around Hillsboro, Oregon.8. On information and belief, Michelle Ramey a/k/a Michelle Clayborn, is a long-time associate of Joseph David Williams who also resides with him in or around Hillsboro,Oregon.
ALLEGATIONS COMMON TO ALL COUNTS
9. On information and belief, Joseph David Williams has been posting and continuesto post false statements about David Blockowicz, Mary Blockowicz, and Lisa Blockowicz onnumerous websites.10. The website <ripoffreport.com> is a purported “consumer advocacywebsite

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