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we civiL suit NuMBER “1-0 Qa GREGORY R. AYMOND PINEVILLE CITY COURT VERSUS PARISH OF RAPIDES ED HOOPER STATE OF LOUISIANA PETITION The Petition of GREGORY R. AYMOND, a citizen and resident of Alexandria, Rapides Parish, Louisiana, and of the age of majority, with respect represents: as ED HOOPER, a resident and domiciliary of Ward 11 of Rapides Parish, Louisiana, is made defendant herein. 2 The defendant is indebted unto your petitioner for sums as are reasonable and proper in premises, for reasonable attorney fees, and for all costs of court, together with legal interest on all sums from date of judicial demand until paid. 3. That the defendant is a “blogger” who has a blog entitled “we saw that...” wherein he posts things with regard to news and current events and other things which interest him and which he operates from his home in Ward 11, Rapides Parish, Louisiana. 4. That on or about March 27, 2009, on the “we saw that...” blog, ED HOOPER published the following defamatory comments about your plaintiff: ‘a “however, can anyone really believe mr. aymond when he is a = known liar?” “ b. “lately, mr. aymond has been using his blog to promote and = defend members of his criminal network.” c “he uses or did use marijuana ...” d. “our experience with greg aymond has taught us that he is nothing but a liar and a user. mr. greg aymond has no sense of loyalty, honor or integrity. he is not a man of his word and cannot be trusted. mr. aymond’s scam is to use people; then when he has gotten what he wants casts them aside and criticizes them. greg aymond is one big phony.” e. “greg aymond is one of the 99% of lawyers who give the other 4% of lawvere a had renistation ” i “see also the unethical attorney greg aymond label in the footer of this post” and published it to the general public where it is available for reading to anyone who goes to his blog and where approximately 300 to 500 people read this blog on a daily basis. 5. That on or about April 2, 2009, on the “we saw that...” blog, ED HOOPER published the following defamatory comments about your plaintiff: a. “mr. aymond's attacks are evidence of the growing desperation and pressure that he and the criminals that he’s working with are under to shut wst... down.” “he is unethical” “in reality mr. aymond and his criminal friends simply want to be in control of the information so that they can trick you into thinking that the criminals that he supports are honest and the criminals in the rival crime gangs that he dogs out are not.” “mr. aymond and his criminal friends have with wst... is that we arent owned or controlled by anyone” “mr. aymond on the other hand went to law school and learned how to become a professional liar, user and con-artist.” “we have greg aymond sitting on a shitter in alexandria, louisiana; thinking up ways of how to gyp someone, whilst jacking his dick.” and published it to the general public where it is available for reading to anyone who goes to his blog and whereby approximately 300 to 500 people read this on a daily basis. 6. That on or about May 20, 2009, on the “we saw that...” blog, ED HOOPER made the following defamatory comments about your plaintiff on his blog: “for instance self-admitted unethical and mentally defective local attorney and alleged “former member” of the ku klux Klan, greg aymond (when he’s not busy stealing gannett/town talk content and posting it to his blog to mock some black kids who have never done anything to him other than to be born black which in mr. aymond’s world is the same as driving while black — or monitoring wst...)” Te That the untrue statements published on the we saw that... blog by ED HOOPER about petitioner constitute an unwarranted false. malicious and liable attack upon his character and reputation or, in the alternative, represent a careless, reckless and negligent blatant disregard for the truth and of plaintiff and his welfare, causing him resulting injuries and damages. 8. Publication of said falsities has and continues to expose your petitioner to disrepute, ridicule, contempt and deprived him of the benefit of public confidence and social intercourse and further, has exposed or continues to expose him to the humiliation and embarrassment of having his family, friends, acquaintances and fellow church members read said untruths about him, causing him great mental pain and anguish and embarrassment and discrediting his character and reputation before his friends, family and the entire Central Louisiana community; further, these published comments constitute defamation “per se” since they accuse him of crimes. 9. That around the same approximate time when these purulent allegations were made against your petitioner, he had a stroke, which rendered him unable to practice his profession and physically disabled. 10. That the defendant published on his blog on or about May 19, 2009, that your petitioner was a self-admitted, unethical and mentally defective local attorney. 11, That all of the statements which were published were made with malice aforethought as can be seen by the cruel nature there used, and the statements.were also made with the knowledge that they were false or with reckless disregard as to whether the allegations were false or not. 12. That the stress, humiliation and embarrassment caused your petitioner by the defendant caused him a serious personal injury in that the defendant's defamation of his character was a contributing, significant and aggravating factor leading to the stroke he suffered and also in preventing his full recovery from same. 13. That the sums sought by petitioner are less than that required for a trial by jury