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1] JEFFREY A. MARKS, P.C. ATTORNEY AT LAW 2 || 4773 EAST CAMP LOWELL ORIVE TUCSON, ARIZONA 85712-1258 jeffreyamarkspc@q com ‘TELEPHONE (620) 327-5000, 4 TOLL-FREE (866) 927-5300 _ TELEFAX (520) 327-6611 5 ‘State Bar No 05670 PCCN: 36116 6|| Attorney for Plaintifts 7 IN THE SUPERIOR COURT OF THE STATE OF ARIZONA 8 IN AND FOR THE COUNTY OF PIMA ° | TIFFANY BREDFELDT AND NO. C2013 1650 19 | PHILIP BREDFELDT, HUSBAND | AND WIFE i AMENDED COMPLAINT FOR Plaintiffs, INJUNCTIVE RELIEF (NON- 12 | and CLASSIFIED CIVIL) 13 | TODD GREENE, Assigned to: Hon, Carmine ia Defendant. Cornelio 1 Defendant is a resident of Pima County, Arizona. The Pima County Superior Court has 16 | full jurisdiction over this matter 2. Plaintiff Tiffany (“Plaintiff Tiffany”) and Philip (“Plaintiff Philip") Bredfeldt previously resided in Pima County, Arizona while Plaintiff Tiffany obtained het doctorate in Pharmacology and Toxicology. They both now reside in Texas where Plaintiff Tiffany is S a toxicologist employed by the State of Texas 3 In 2006, Plaintiff Tiffany applied for and received an Order from the Pima County Justice Court restraining Defendant fiom harassing and contacting her Defendant thenafter requested a hearing in which Plaintiffs prevailed. Thenafter, Defendantappealed the matter to the Pima County Superior Court where Plaintiffs again prevailed. }4 Following the appeal which upheld the Order, Defendant has set on a intentional couse 26 of conduct since 2006 to constantly defame Plaintiff Tiffany and cause het emotional distress, Defendant also seeks to have Plaintiff terminated from her employment, lose her credentials, be black listed in her profession, and have her marriage to Plaintiff Philip fail 15. Defendant’s stated behaviors are not those protected by either the United States (Constitution or the Arizona Constitution 3/6. Defendant’s stated behaviors ate those which may be lawfully enjoined by this Court. 4)7 Defendant's statements and publications regarding Plaintiff Tiffany are false, 5 /defamatory, and intentional, They serve absolutely no legitimate purpose. In fact, 6 [Defendant once offered to remove his websites disparaging Plaintiff Tiffany for the 7 | payment of $20,000.00. 8 8 Plaintiffs have elected to seek their remedy at equity rather than at law since their belief 9 jis that Defendant would not be able to satisfy any type of money judgment. Also, no money 10 judgment could remedy the damage Defendant is causing Plaintiffs 1/9. Asan example of continuing improper behavior, On: February 12,2013, Defendant wrote {2 |to the Inspector General of the United States Department of Health and Human Services, on, LL.M , JD to “report” Plaintiff Tiffany’s perceived sexual promiscuity 13 |Daniel Levi 14 Jin Texas, (See exhibit “One”) The communication also refers to Plaintiff Tiffany as a “a shame to her profession ” 15 |ftaud”, having “criminal depravity,” and that she i 16 Defendant also recently posted a concocted article entitled “Tiffany Bredfeldt’s Vagina: 17 |On Marital Discontent and Restraining Order Abuse.” (See exhibit “Two”) The exact date 18 |lof its posting is unknown 19 10. Similar harassments and defamations occur on almost a weekly basis. Communications 20 | g0 out to the world at large as well as Plaintiff Tiffany's colleagues, fhiends, employers, 21 | former professors, and the scientific community. 22 }11 Further, Defendant has already directly communicated the same defamatory statements 23 [regarding Plaintiff Tiffany to the Presbyterian Church of America, National Association 24 jot Evangelicals, Plaintiff Tiffany Bredfeldt’s own clergy person, the clergy person for 25 |/Plaintiff Tiffany’s family, and Plaintiff Tiffany's own family 26 12 Defendant publishes his communications regarding Plaintiff Tiffany via personal 27 fcommunications, letters, e-mails, and an ever updated web sites regarding Plaintiff 28 | Tiffany 1/13 In addition to his above-described harassment, Defendant also, pro se, filed a lawsuit in the Pima County Superior Court against Plaintiff Tiffany. Said lawsuit was unable to 3 | withstand a Motion for Summary Judgment and was dismissed 14. This Court has the jurisdiction to Order Defendant to stop all communications of all 5 } sorts, directly or indirectly, in which Plaintiff Tiffany ’s identity could be ascertained and/or *eminated, or fiom mentioning anything regarding or involving her, and to restrain him nducing anyone else from the same 6 7 [from directing o: 8 115 In addition to what is stated above, Defendant's defamatory statements regarding 9 0 Plaintiff Tiffany Bredfeldt include her being a whore, a criminal, a disgrace to her profession, unethical, and diseased All are false or hold Plaintiff Tiffany Bredfeldt in a 1 [fase light 12116 Further, Plaintiffs’ rights to privacy are constantly invaded by Defendant as he 13 Jroutinely contacts church author ities, employers, family members, supervisors, friends, and 14 [government authorities to falsely eport on Plaintiff Tiffany Bredfeldt's fraud, criminality, 19 threat to her profession, sexual perversions, and mental health diagnoses 16 WHEREFORE Plaintifis request that following from this Court: 17 A) Find Defendant’s actions to be defamatory and actionable as slander and libel. 18 }B) Find the Defendant’s stated endeavors ate not constitutionally protected and serve no 19 flegitimate purposes 20 |) Find that Defendant’s stated behaviors constitute harassment to both Plaintif 21 JD) Find that Defendant's stated behaviors may be lawfully enjoined 22 JE) Order Defendant not to communicate any statements which could even remotely be 23 |connected to Plaintiffs or identified as being Plaintiffs, and permanently cease from 24 | disclosing Plaintifis’ signatures, addresses, photographs, images, and the like | 25 |F) Order and enjoin Defendant from communications toor with anyone regarding anything 26 | involving Plaintiffs, including his opinions regarding Plaintiff Tiffany’s job performance, 27 | morals, ethics, mental and physical health, credibility, and ethics, 28 }G) Order Defendant to permanently remove his website and never statt another one, nor | [start nor otherwise link or affiliate Plaintiffs to another website in which Plaintifs* names 2 fot identities are tated ot could be deciphered, including using Plaintiff Tiffany’s likeness 3]19 Enjoin Defendant ftom enticing, aiding, abetting, hiring, counseling, or motivating anyone else to do what Defendant is testiained from doing, > |P Order Defendant to have no contact at all with Plaintiffs or their families, fhiends, § Jollesgues, co-workers, employers, supervisors, organizations, and the world at large 7 [regarding Plaintiffs, 8 |1) Employ a Master to over-sec Defendant’s full compliance with the Orders and 9 Jinjunctions of the Court. inary injunction should not be issued, and 10 |) Order Defendant to show cause why a pr 11 |[that it be made permanent. 12 IL) Grant alt further necessary and just relief’ 14 DATED this_7)_ day of May, 2013