Read without ads and support Scribd by becoming a Scribd Premium Reader.
 
1234567891011121314151617181920212223242526
Michael Roberts#1493 PO Box 1198Sacramento CA 95812408-916-5977michael.roberts@BadForPeople.org 
Superior Court of the State of CaliforniaCounty of Orange – Central Justice CenterMICHAEL ROBERTS
, an Individual,PLAINTIFF,vs.
GOOGLE, INC.
and
DARREN MITCHELL MEADE
and
FOXNEWS NETWORK, LLC.
and
PERRY CHIARAMONTE
and
XCENTRIC VENTURES, LLC.
DBA RIPOFFREPORT.COMand
EDWARD MAGEDSON
and
JOHN B. RICHTER 
DEFENDANTS.
)))))))))))))))))))
Case No.:
Complaint for:1.Defamation2.Civil Conspiracy3.Tortious Interference4.False Light5.Business Disparagement6.Emotional Distress7.Injunctive Relief 8.Punitive Damages
 ________________________________________ I declare under penalty of perjury under the laws of the State of California that the foregoing istrue and correct.March 22, 2012Michael Roberts
ELECTRONICALLYFILED
SUPERIOR COURT OF CALIFORNIACOUNTY OF ORANGECIVIL COMPLEX CENTER
Mar 27 2012
ALAN CARLSON, Clerk of the Courtby M. NORDMAN
JUDGE NANCY WIEBEN STOCKDEPT. CX105
xxxxxxxxxxxxxxxxCivil Complex Center30-2012-00557149
 
12345678910111213141516171819202122232425262
JURISDICTION/THE PARTIES
1)PLAINTIFF is a Californian resident and operates his businesseswww.Rexxfield.comandwww.BadForPeople.orgin California as a Social Forensic, Digital Forensic and Internet Defamation Analyst.2)GOOGLE, INC. ("GOOGLE") is an Internet Service Provider ("ISP"), and is aCalifornia corporation that does business internationally and in all fifty states of the United States.3)Defendant DARREN MEADE (“MEADE”) is a California resident and anemployee, agent or contractor for Defendant XCENTRIC VENTURES, LLC.4)FOXNEWS NETWORK, LLC. ("FoxNews") is a California corporation that does business internationally and in all fifty states of the United States.5)PERRY CHIARAMONTE (hereinafter “CHIARAMONTE “) is a New York resident and journalist employed or contracted by PLAINTIFF FoxNews and publishes a regular column on the website WWW.FOXNEWS.COM.6)Defendant XCENTRIC VENTURES, LLC (hereinafter "XCENTRIC"), is a limitedliability company duly organized under the laws of the State of Arizona, with its principal place of  business in the State of Arizona.7)Upon information and belief, Defendant EDWARD MAGEDSON, also known asED MAGEDSON (hereinafter "MAGEDSON"), is a resident of the State of Arizona.8)Defendant JOHN B. RICHTER (hereinafter "RICHTER"), is an Illinois Residentand an officer with the Chicago Police Dept. he is the brother of convicted murderer TRACEY.
FACTS RELEVANT TO ALL COUNTS
1)TRACEY ANNE RICHTER (aka Sophie Corrina Terese Boronin VonRichterhausen Edwards) (Hereinafter called “TRACEY”) is a non-party, three-times convicted
 
12345678910111213141516171819202122232425263felon serving a life prison sentence without the possibility of parole in Iowa for the 2001 executionstyle murder of 20-year-old Dustin Wehde; TRACEY is PLAINTIFF’s ex-wife.2)XCENTRIC & MAGEDSON's presumed immunity to liability for defamation pursuant to part (c) of §230 of the Communications Decency Act("§230") does not apply in thisaction with respect to MEADE’s Submissions to the RIPOFFREPORT.COM website, becauseMEADE has been acting as an agent for XCENTRIC & MAGEDSON, and because XCENTRIC& MAGEDSON have adopted MEADE’s words as their own, and MAGEDSON has personallyslandered and libeled PLAINTIFF.3)GOOGLE's presumed immunity to liability for defamation pursuant to part (c) of §230 of the Communications Decency Act("§230") does not apply in this action because§230(c)(1)'s contextual reference to the word "
information
" as defined by the Miriam Webster dictionary is:
"Something (as a message, experimental data, or a picture), which justifies change in aconstruct (as a plan or theory) that represents physical or mental experience or another construct." 
4)GOOGLE, as the self-appointed curator of all the World’s knowledge, has usurpedthe 5th Estate; and through its pattern of actions, has demonstrated that it cannot be trusted tocontrol public access to said information through such a narrow door.5)Moreover, GOOGLE consistently violates the trust between itself and its user-base, by using a law that is clearly intended to protect individuals, against its users and others for  prospective financial gain. Specifically, by invoking section 230(c) of the CommunicationsDecency Act, GOOGLE thereby exploits all the privileges and federal immunity conveyed thereinvia §230(c)1; all the while methodically avoiding the social responsibility, respect, or self-regulation expressly implied through §230(c)2 within the context and confines of the law asdefined by Congress.
Search History:
Searching...
Result 00 of 00
00 results for result for
  • p.
  • More From This User

    Notes
    Load more