Case: 45CH1:13-cv-01017

Document #: 8

Filed: 01/23/2014

Page 1 of 4

IN T H E C H A N C E R Y C O U R T O F MADISON COUNTY, MISSISSIPPI

HART K O L L E R , E T A L L V. MIRANDA JORDAN, E T A L L JOHN DOE DEFENDANTS 1-10

PLAINTIFF CA 45 Chl:13-cv-1017

DEFENDANT

C O U N T E R C L A I M F O R T E M P O R A R Y RESTRAINING O R D E R , P R E L I M I N A R Y AND PERMANENT INJUNCTION

COMES NOW, Miranda Jordan, and files this, her Counter Claim for a Temporary Restraining Order and Preliminary and Permanent Injunction against the Plaintiffs herein, and would show unto the Court the following facts, to-wit: 1) Counter-Plaintiff, Miranda Jordan, is an adult resident citizen of Madison County

and currently resides at 209 Ponderosa Place, Ridgeland, Mississippi 39157. 2) above cause. 3) Counter-Defendant's, Hart Koller and Sharla Bachelder, have engaged in a course Counter-Defendant's have a pending Petition filed against Miranda Jordan in the

of conduct to stalk, harass and intimidate your Counter-Plaintiff. 4) Counter-Defendant, Hart Koller, made false and untrue defamatory statements to

undermine the business of Miranda Jordan, Wolf Valley Creative, Random Art and Mississippi Craft Show. 5) Counter-Defendant, Hart Koller, continues to make slanderous and false

statements regarding Ms. Jordan. 6) Upon information and belief, Counter-Defendant, Hart Koller, has stalked

Miranda Jordan by driving by her residence repeatedly and intentionally going to places where Miranda is present. Defendant Koller has driven by Miranda Jordan's house as late as September, 2013, causing her to obtain extra security.

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Case: 45CH1:13-cv-01017

Document #: 8

Filed: 01/23/2014

Page 2 of 4

S T A T E OF MISSISSIPPI COUNTY OF HINDS This day personally appeared before me, the undersigned authority at law in and for the jurisdiction aforesaid, the within named MIRANDA JORDAN, who having been by me first duly sworn, states on oath that the matters and facts set forth in the above Counter Claim for Temporary Restraining Order, Preliminary and Permanent Injunction are true and correct as therein stated.

^/^/MIRANDA JORDAN

SWORN TO AND SUBSCRIBED BEFORE ME, this the,

day of January^2014.

NOTARY PUBLIC

MY COMMISSION E X P I R E S :
:</i: ' ID # 100933

: CHRISTINE L.CROTHERS '. ••.Commission Expires/ . May 30.2017 '

F. Andrew Howell, MSB #2734 318 South State Street Jackson, Mississippi 39201 (601) 949-3900 howelllaw@bellsouth.net

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Case: 45CH1:13-cv-01017
7)

Document #: 8

Filed: 01/23/2014

Page 3 of 4

Counter-Plaintiff is in continued fear of her safety and the safety of her family,

friends and pets. 8) Although Defendant's Koller and Bachelder claim similar allegations against

Miranda Jordan, both Defendant's appeared at a restaurant on January 18, 2014, where Jordan was present, to stalk and intimidate her. 9) Defendant's Koller and Balchelder are currently being investigated by the

authorities for conduct related to the "Madison Ark" and Jordan believes they will continue to stalk, harass and defame her for reporting said activities. WHEREFORE PREMISES CONSIDERED, the Counter-Plaintiff, Miranda Jordan, prays that a Temporary Restraining Order be issued by this Court restraining Defendant's Koller and Balchelder from coming within 250 feet of Miranda Jordan and her family, their property, contacting their families, spreading or forwarding defaming materials, further that Defendant's pay all attorney fees and costs in this matter. R E S P E C T F U L L Y SUBMITTED, COUNTER-PLAINTIFF MIRANDA J O R D A N

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Case: 45CH1:13-cv-01017

Document #: 8

Filed: 01/23/2014

Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that on this day I electronically filed the foregoing pleading or other paper with the Clerk of the Court using the MEC system which sent notification of such filing to the following: Anders Ferrington, Esq. MSB # 102444 Anders Ferrington, PLLC 419 S. State Street Jackson, Mississippi 39201 (601) 316-8428

Further, I hereby certify that I have mailed by United States Postal Service the document to the following non-MEC participants: None.

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