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Gaston v Facebook Complaint

Gaston v Facebook Complaint

Ratings: (0)|Views: 402 |Likes:
Published by Eric Goldman
I've lost track of similar complaints by the same pro se Gaston, but I believe this is at least his fourth
I've lost track of similar complaints by the same pro se Gaston, but I believe this is at least his fourth

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Published by: Eric Goldman on Jan 19, 2012
Copyright:Attribution Non-commercial

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08/09/2012

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original

 
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222324
25
2627Name: KANAL
V.
GASTONAddress: P.O.
BOX
4682PORTLAND.
OR
97208Phone Number:
.....
N..!!../"-"A'---
___
_
E-mail
Pro SeUNITED STATES DISTRICT COURT
FORTHE
DISTRICT
OF
OREGON, EUGENE DIVISION
Kanal
V.
Gaston 
~
)
Plaintiffl: s), )
)
vs. )
)
(1)
Facebook, Inc. )(2) Maria Raquel Rivas )
(3) 
Lexis-Nexis Group and/or Reed )Elsevier, Inc. )(4) Capitol Information Group. Inc.
and/or)
Business Management Daily )
(5)
Google. Inc. )(6) Texas Office
of
the Attorney General )
and/orSmteofTexas
)(7) The PNC Financial Services Group, )Inc. )
)
DefendanUsl.Case Number: /
~
-c
t.J
-
/...(J3
S-r
COMPLAINT
JURy
DEMAND
ON
ALL COUNTSCOMPLAINTPlaintiff, Kana!
V.
Gaston, brings this complaint against the Defendants and states the following:
1
Case 3:12-cv-00063-ST Document 2 Filed 01/12/12 Page 1 of 17 Page ID#: 5
 
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252627JURISDICTION
&
VENUE 
1.
This Court enJoys subject matter jurisdiction over this action under 28
US.c.
§1332(a)(I) because the Plaintiff and Defendants are citizens
of
different states and
th
amount
in
controversy exceeds $75,000.
2. 
This Court enjoys venue under 28
US.C.
§
1331
because this case involves a federaquestion and/or federal laws
or
treaties under the fourth
(4th)
and the fourteenth
(14
th
amendments
of
the United States Constitution.PARTIES3. Plaintiff, Kanal
V.
Gaston, is a private individual and not a public figure, current!residing in Phoenix, Arizona. From October 29, 2007
to
January
12,
2011, Plaintiworked in the White-Collar Crimes UnitlDivision
of
the Harris County DistricAttorney's Office in Houston, Texas as Fraud Examiner with the highest level
0
responsibilities
of
conducting white-collar (financial) criminal investigations froinception
to
final adjudication, and testifying
as
expert in such matters in judicial (cou
&
grand jury) proceedings. In that capacity, because
of
Plaintiff oral and written fluencin English, Spanish, and French, he also served as the sole foreign language translator ithese criminal investigations whenever necessary, with an annual salary
of
about $72000. After spending more than
18
years in college/university, Plaintiff has managed tobtain four (4) college degrees, which includes a master's degree in business and othedegrees
or
studies in criminal justice, accounting/finance, and computer engineerintechnology. In an effort
to
enhance his professional reputation and standing in
hi
profession, plaintiff further sacrificed his own time and money
to
pursue and study
fo
additional professional certifications and/or recognitions.
In
2006, plaintiff was grant
2
Case 3:12-cv-00063-ST Document 2 Filed 01/12/12 Page 2 of 17 Page ID#: 6
 
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2627the Certified Fraud Examiner (CFE) status by the Association
of
Certified FrauExaminers (ACFE). In 2010, Plaintiff was granted the Certified Internal Auditor (CIAstatus by the Institute
of
Internal Auditor, and that same year also passed the exam tbecome Certified Information Systems Auditor (CISA) to be granted by ISACA.
4. 
Defendant
1,
Facebook, Inc. is located at One Hacker Way, Menlo Park, CA 94025
0
1050 Pagemill Road Palo Alto, CA 94301
or
1601
California Ave, Palo Alto, CA 9430or
1601
Willow Road, Menlo Park, CA 94025 (Agent). Its listed phone number is 650543-1300
or
650-543-4800
or
650-543-4801. This Defendant has allowed and/or giveDefendant # 2 access to its server
or
internet web communication system or device
0
social network to spread false
or
defamatory statements against Plaintiff.
5. 
Defendant
2,
Maria Raquel Rivas,
is
an individual and the mother
of
Plaintiff's chilagainst whom Plaintiff was forced to call the police and the Texas Child ProtectivServices (CPS) in Houston several times because she had engaged in an abusive anunlawful pattern
of
stalking and harassing Plaintiff at his home and his place
0
employment (job), for calling and emailing Plaintiff's friends, girlfriend, familmembers, colleagues and bosses and others to lie and make false
or
defamatostatements against Plaintiff as retaliation or grudge or revenge. This Defendant's addres
is:
1977 Western Village Ln., Houston,
TX
77043 and place
of
business is 955 CambelRd., Houston, TX 77024-2803. Her last known phone number
is
713-251-3665.6. Defendant 3, Lexis-Nexis Group, a division
of
Reed Elsevier, Inc. and/or Reed ElseviePLC and/or Reed Elsevier
NY
and/or Corporation Services Company (CSC) hamaintained its headquarters at
125
Park Avenue, Suite 2200, New York,
NY
10017.
It
listed phone number is 212-309-8100 and 800-455-3947. Defendant claims to engage iproviding computer assisted legal research to the public at large and holds the largeselectronic database for legal and public records in the world. This Defendant conspirwith the other Defendants to retaliate against Plaintiff, and has published
or
republishefalse
&
defamatory statements against
him.
3
Case 3:12-cv-00063-ST Document 2 Filed 01/12/12 Page 3 of 17 Page ID#: 7

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