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Case 5:16-cv-04954-JFL Document 1 Filed 09/15/16 Page 1 of 18

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ELLEN HADDAD,

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Plaintiff,

v.
ANTHONY MIKLUS AND
JENNIFER MIKLUS
and
RELIC AGENCY INC. D/B/A
“SHESAHOMEWRECKER.COM”,
Defendants.

No.

JURY TRIAL DEMANDED

COMPLAINT
NOW COMES the Plaintiff Ellen Haddad (“Plaintiff”), a citizen and resident of the
Commonwealth of Pennsylvania, by and through her attorneys, David L. Deratzian, and
with him, Hahalis & Kounoupis, P.C., and complains of the Defendants Jennifer Miklus
and Anthony Miklus, citizens and residents of the Commonwealth of Pennsylvania
(“Miklus Defendants”), and Relic Agency Inc. d/b/a “shesahomewrecker.com,” a citizen
and resident of the State of California (“SAHW”) upon personal information as to her own
activities, and upon information and belief as to the activities of others and all other
matters, and states as follows:
NATURE OF ACTION
1.

This is an action for violation of the Computer Fraud and Abuse Act

(“CFAA”), and the Stored Communications Act (“SCA”); and defamation per se; false
light; intrusion upon seclusion; public disclosure of private facts; and, intentional
infliction of emotional distress, all arising from the Miklus Defendants obtaining

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Case 5:16-cv-04954-JFL Document 1 Filed 09/15/16 Page 2 of 18

unauthorized access to private information and photographs belonging to the Plaintiff,
publishing false statements about the Plaintiff online, and other related conduct.
2.

By this action, the Plaintiff seeks compensatory damages, punitive

damages, statutory damages, attorney’s fees and costs, and injunctive relief.
PARTIES
3.

Ellen Haddad is an adult citizen of the Commonwealth of Pennsylvania

and a resident of Northampton County, Pennsylvania.
4.

Defendant Jennifer Miklus is an adult citizen of the Commonwealth of

Pennsylvania and a resident of Carbon County, Pennsylvania.
5.

Defendant Anthony Miklus is an adult citizen of the Commonwealth of

Pennsylvania and a resident of Lehigh County, Pennsylvania.
6.

Defendant Relic Agency Inc. d/b/a “shesahomewrecker.com,” is upon

information and belief, a corporation organized under the laws of the State of California.
7.

Relic

Agency

Inc.

is

engaged

in

the

business

of

“Entertainment services, namely, providing a web site featuring photographic, audio,
video and prose presentations featuring opinions and evaluations of people,” and is the
owner and/or operator of a web-site known as “shesahomewrecker.com,” and has applied
for and/or holds “SHE'S A HOMEWRECKER” and “SHE IS A HOMEWRECKER” as
trademarks.1
JURISDICTION AND VENUE
8.

This Court has jurisdiction over the subject matter of the Plaintiff’s federal

statutory claims pursuant to 28 U.S.C. § 1331. This Court has supplemental jurisdiction

1

https://trademarks.justia.com/870/78/she-s-a-87078844.html (accessed 9/9/2016).

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over the subject matter of the Plaintiff’s state law claims pursuant to 28 U.S.C. § 1367.
9.

Venue in this district is proper pursuant to 28 U.S.C. § 1391 because a

substantial part of the events or omissions giving rise to the claims occurred in this
district. Furthermore, the Defendant Anthony Miklus is a resident of within this District and
Jennifer Miklus was a resident of this District when she engaged in the conduct directed toward
the Plaintiff in this district.
10.

This Court has personal jurisdiction over Defendant SAHW because

Defendant is a commercial and/or interactive website where a user can exchange
information with the host computer, the publications occurred within the
Commonwealth of Pennsylvania, and the Defendant reserves the right to exercise
editorial control over content.
STATEMENT OF THE CASE
11.

This action involves the Miklus Defendant’s violation of the Plaintiff’s

privacy and efforts to discredit, disparage, and damage the Plaintiff’s reputation.
Defendant’s
Unauthorized
Communications.
12.

Access

to

Electronic

On or before September 17, 2015, Defendant Jennifer Miklus obtained

unauthorized access to her husband’s, Anthony Miklus’, Facebook accounts.
13.

By obtaining unauthorized access to her husband’s Facebook accounts, the

Defendant obtained unauthorized access to the postings on his “wall,” one of which
contained a photograph of Plaintiff.
14.

“Friends” on Facebook are other users who have been approved by

another user to view material posted by the approving user.
15.

The amount of information that a “Friend” can access can be limited by

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the approving user.
16.

Similarly, a user can restrict the ability of non-friends (the “Public”).

17.

Plaintiff had not published the photograph for public viewing, but had

restricted its availability to “Friends.”
Defendant Jennifer Miklus’ Text Communications with Plaintiff
18.

Between August 3 and 4, 2015, the Plaintiff exchanged text messages from

the Defendant which accused her of having a sexual relationship with Defendant Anthony
Miklus.
19.

Over the course of the ensuing exchanges, Plaintiff consistently denied

such a relationship.
Defendant’s Publication
of Defamatory Statements
Photographs by Jennifer Miklus
20.

and

Private

On or around September 17, 2015, the Defendant posted statements about

the Plaintiff on the website at the domain name shesahomewrecker.com (“SAHW.com”),
which is owned and/or operated by Defendant SAHW, a copy of which is attached hereto
as Exhibit A.
21.

In the statements she posted on SAHW.com, the Defendant disclosed

private information about the Plaintiff and published false and defamatory statements
about her, including but not limited to:
a. Calling Plaintiff a “Twat waffle”;
b. Disclosing that Plaintiff “worked at a strip club” while
failing to disclose that Plaintiff was a bartender and not a
dancer;
c.

Claiming that Plaintiff “went after” Anthony Miklus despite
knowing that he was married with 4 kids and him;

d. Stating that Plaintiff is “lower than low;”

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e. Falsely stating that Plaintiff “had an affair” with Anthony
Miklus;
f. Falsely stating that Plaintiff used drugs with Anthony
Miklus;
g. Falsely stating that Plaintiff was “screwing around” with
Anthony Miklus for a couple months;
h. Stating that Plaintiff was a gold-digger;
i. Falsely stating that Plaintiff is “a drug addicted alcoholic
little slut with no morals and likes to screw older married
men, tries to pin her sins on other people and has no
remorse for any of it!”
22.

In the statements she posted on SAHW.com, the Defendant identified the

Plaintiff by name.
23.

The Defendant also posted one of the Plaintiff’s Private Photographs on

SAHW.com.
24.

The statements the Defendant posted on SAHW.com remain accessible on

SAHW.com to this date.
25.

The Private Photographs of the Plaintiff the Defendant posted on

SAHW.com remained accessible on SAHW.com until on or about July 14, 2016.
26.

Additionally, the uniform resource locator (“URL”) for SAHW.com

identifies the Plaintiff by name http://shesahomewrecker.com/ellen-haddad-allentownpennsylvania/#page-2.
27.

Through the foregoing false and defamatory statements (“False and

Defamatory Statements”), the Defendant falsely characterizes the Plaintiff as a woman
who seduced a married man in order obtain drugs, alcohol and money..
28.

Plaintiff believes and therefore avers that some or all of the statements

made by Defendant Jennifer Miklus were based upon false statements by Defendant

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Anthony Miklus.
Public Perception
29.

The publication of the false and defamatory Statements, the public

disclosure of private facts, and the publication of the Private Photographs (“Offending
Content”) convey the meaning that the Plaintiff is immoral, devious, is a drug addict, and has
engaged in serious sexual misconduct.
30.

Since the publication of the Offending Content, any individual reading the

Offending Content might believe that the Plaintiff is immoral, devious, is a drug addict, and
has engaged in serious sexual misconduct.
31.

The Plaintiff is not immoral.

32.

The Plaintiff is not devious.

33.

The Plaintiff is not a drug addict.

34.

The Plaintiff did not engage in any sexual misconduct, and specifically did

not engage in any sexual conduct whatsoever with Anthony Miklus.
Intent and Actual Malice
35.

The Offending Content constitutes libel per se, and was published by

Defendants as set forth above in reckless disregard of the truth.
36. The Defendant acted with intent and actual malice because she intended to
harm the Plaintiff.
37. The foregoing conduct engaged in by the Defendant shall hereinafter be called
the Wrongful Conduct.
Harm
38. The content on the website ShesAHomewrecker.com (“Offending
Website”) has caused the Plaintiff to suffer harm.
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39. Indeed the entire reason for the existence of the Offending Website is to
provide a forum for persons to make public disclosures of private facts with the
intent of cause harm to the victims.
40. The false and defamatory statements on the Offending Websites (“False and
Defamatory Statements”) have caused the Plaintiff to suffer harm.
41.

The public disclosure of private facts on the Offending Websites has caused

the Plaintiff to suffer harm.
42. The Plaintiff has suffered, and continues to suffer, harm arising from the
Wrongful Conduct by the Defendant.
43. The publication of the Offending Content has affected the Plaintiff’s private and
professional life and the manner in which she is viewed among family, friends, and
colleagues.
44.

Defendant’s Wrongful Conduct has caused the Plaintiff to suffer and

continue to suffer from embarrassment and emotional distress.
CLAIMS FOR RELIEF
COUNT ONE
VIOLATION OF THE COMPUTER FRAUD AND ABUSE ACT
18 U.S.C. § 1030
PLAINTIFF VS. MIKLUS DEFENDANTS
45.

Plaintiff hereby incorporates by reference Paragraphs 1 through 44

above in this First Count as though fully set forth herein.
46. Defendant Jennifer Miklus knowingly and with an intent to commit fraud
obtained unauthorized access and/or exceeded her authorized access to the computers
hosting her husband’s private Facebook account.
47. Defendant Jennifer Miklus did not possess authorization to access information
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that Plaintiff had permitted “Friends” to access.
48. Defendant Anthony Miklus did not possess authorization to provide others
with access to information that Plaintiff had permitted “Friends” to access.
49. The Private Facebook Accounts contained private photographs of the Plaintiff.
50. Defendants obtained unauthorized access or exceeded the authorized access.
51.

Defendant Jennifer Miklus obtained value by and through acquiring,

reading, and possessing the private photograph of Plaintiff.
52.

The computers hosting the Private Facebook Accounts are used in or affect

interstate and/or foreign commerce or communication.
53. The computers hosting the Private Facebook Account are protected computers.
54.

The Defendant intended to harm the Plaintiff personally.

55.

By engaging in the foregoing conduct, the Defendant violated the

Computer Fraud and Abuse Act, 18 U.S.C. § 1030(a)(4).
56.

The Plaintiff has suffered losses attributable to the Defendant’s violation

of the Computer Fraud and Abuse Act totaling more than $5,000 including, but not
limited to, costs of responding to the violations, reputation management, and legal fees.

COUNT TWO
VIOLATION OF THE STORED COMMUNICATIONS ACT
18 U.S.C. §§ 2701, et seq.
PLAINTIFF VS. MIKLUS DEFENDANTS

57.

The Plaintiff hereby incorporates by reference Paragraphs 1 through 56

above in this Second Count as though fully set forth herein.
58.

By obtaining unauthorized access to the Private Facebook Account, the

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Defendants knowingly and/or intentionally accessed without authorization facilities
through which electronic communication services are provided.
59.

By obtaining unauthorized access to the Private Facebook Account, the

Defendants also knowingly and/or intentionally obtained access to private electronic
communications stored in such facilities and system.
60. If the Defendants did not obtain access without authorization, they exceeded
any authorization she possessed.
61. The Defendants acted willfully and/or intentionally.
62.

By obtaining access to the stored communications in the foregoing

facilities and system, the Defendants violated the Stored Communications Act,
specifically 18 U.S.C. § 2701(a).
63.

As a result of the Defendants’ conduct, the Plaintiff suffered injuries and

damages resulting therefrom that include, but are not limited to, violation of her
statutory rights, invasion of her privacy, and harm to her reputation.
64.

The Plaintiff has suffered and continues to suffer irreparable injury for

which she has no adequate remedy at law.
COUNT THREE
DEFAMATION PER SE
PLAINTIFF VS. MIKLUS DEFENDANTS

65. The Plaintiff hereby incorporates by reference Paragraphs 1 through 64 above
in this Third Count as though fully set forth herein.
66.

In the False and Defamatory Statements, the Defendant falsely stated

that the Plaintiff engaged in serious sexual misconduct, deceptive conduct and is a

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drug addict.
67.

Through the False and Defamatory Statements, the Defendant falsely

characterizes the Plaintiff as being sexually and otherwise immoral.
68.

The False and Defamatory Statements convey a meaning that the Plaintiff

lacks morals and integrity.
69.

Plaintiff is not immoral and does not lack integrity.

70.

The False and Defamatory Statements prejudice the Plaintiff.

71.

Defendant Anthony Miklus published some or all of the False and

Defamatory Statements concerning the Plaintiff to Jennifer Miklus and/or to third parties.
72.

Defendant Jennifer Miklus published and/or republished all of the False

and Defamatory Statements concerning the Plaintiff to third parties.
73.

The Defendants caused the False and Defamatory Statements to be

published on and through the Internet.
74.

The False and Defamatory Statements identified the Plaintiff by name.

75.

Persons other than the Plaintiff and the Defendant would and actually have

reasonably understood that the False and Defamatory Statements related to and were
about the Plaintiff.
76.

Because postings on SAHW.com are automatically posted to Facebook,

Plaintiff has been further defamed by the republication and public comments of persons
on Facebook.
77.

The Defendant presented the False and Defamatory Statements as fact.

78.

The False and Defamatory Statements constituted unprivileged

publications of defamatory statements by the Defendant to third parties.
79.

The Defendant made the False and Defamatory Statements with actual
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malice knowing the falsity of the statements.
80.

The False and Defamatory Statements constitute defamation per se

because they impute a serious sexual misconduct and prejudice the Plaintiff.
81.

As a result of the Defendant’s conduct and the publication of the False and

Defamatory Statements, the Plaintiff has suffered and continues to suffer damages
including, but not limited to, harmed reputation.
COUNT FOUR
FALSE LIGHT
PLAINTIFF VS. MIKLUS DEFENDANTS
82.

The Plaintiff hereby incorporates by reference Paragraphs 1 through 81

above in this Fourth Count as though fully set forth herein.
83.

The Defendant published the False and Defamatory Statements on the

Internet.
84.

The URL associated with the Offending Content identify the Plaintiff by

85.

The False and Defamatory Statements cast the Plaintiff in a false light by

name.

falsely portraying her as being immoral, deceitful and having engaged in serious sexual
misconduct.
86.

The False and Defamatory Statements prejudice the Plaintiff.

87.

The Defendant made the False and Defamatory Statements with actual

malice, knowing or being recklessly indifferent to the falsity of the statements.
88.

As a result of the Defendant’s conduct and publication of the Private

Photographs and the False and Defamatory Statements casting her in a false light, the
Plaintiff has suffered and continues to suffer damages including, but not limited to,
harmed reputation, embarrassment, invasion of privacy, mental anguish, trauma, and
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emotional distress.
COUNT FIVE
INTRUSION UPON SECLUSION
PLAINTIFF VS. MIKLUS DEFENDANTS
89.

The Plaintiff hereby incorporates by reference Paragraphs 1 through 88

above in this Seventh Count as though fully set forth herein.
90.

The Defendants violated federal statutes prohibiting unauthorized

interception, reading, and use of electronic communications.
91.

The electronic communications were private.

92.

The Plaintiff considered her Facebook postings to be private and took

reasonable and available steps to protect that privacy.
93.

The Defendants made an unauthorized intrusion into the Plaintiff’s

privacy and seclusion when they accessed the Plaintiff’s stored private electronic
communications.
94.

The Defendants made an unauthorized intrusion into the Plaintiff’s

privacy and seclusion when they used and disclosed the Plaintiff’s private
communications.
95.

The Defendants did not have authority to engage in her Wrongful Conduct.

96.

The Defendant’s intrusions were unauthorized and unreasonable.

97.

The Defendant’s intrusions are offensive to a reasonable person.

98.

The Defendant’s intrusions are objectionable to a reasonable person.

99.

The intrusion upon the Plaintiff’s private communications caused the

Plaintiff damages and injuries including, but not limited to, invasion of her privacy,
anguish and suffering, harmed reputation, embarrassment, and loss of trust.

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COUNT SIX
PUBLIC DISCLOSURE OF PRIVATE FACTS
PLAINTIFF VS. MIKLUS DEFENDANTS
100.

The Plaintiff hereby incorporates by reference Paragraphs 1 through 99

above in this Sixth Count as though fully set forth herein.
101.

The Defendants disclosed private facts about the Plaintiff without her

authorization.
102.

By publishing the Plaintiff’s Private Photographs and the False and

Defamatory Statements, the Defendants disclosed private facts about Plaintiff without her
authorization.
103.

The Defendants facilitated the disclosure of the Plaintiff’s private facts

and the Private Photographs to the Offending Websites.
104.

These private facts (albeit false) concerned the private, intimate life of the

Plaintiff and her private, intimate activities.
105.

The public disclosure of these private facts represents an intrusion upon the

Plaintiff’s privacy that is objectionable and highly offensive to a reasonable person.
106.

The Plaintiff’s private facts were not of legitimate public concern.

107.

The Plaintiff’s private facts contained within the Private Photographs

were not of any legitimate public concern.
108.

The public disclosure of the Plaintiff’s private facts has caused and

continues to cause the Plaintiff to suffer harm including, but not limited to, invasion of
her privacy, anguish and suffering, harmed reputation, and embarrassment.

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COUNT SEVEN
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
PLAINTIFF VS. MIKLUS DEFENDANTS
109.

The Plaintiff hereby incorporates by reference Paragraphs 1 through 108

above in this Seventh Count as though fully set forth herein.
110.

The Defendants published the False and Defamatory Statements and Private

Photograph.
111.

The

Defendants intentionally published

the

False

and

Defamatory Statements and Private Photograph.
112.

The Defendants published the False and Defamatory Statements and

Private Photograph without the Plaintiff’s authorization.
113.

The Defendants displayed the False and Defamatory Statements and

Private Photograph in such a manner that they would be disseminated throughout the
Plaintiff’s local community and the world.
114.

The Defendants intended to harass, annoy, humiliate and alarm the

Plaintiff by publishing the Private Photographs and the False and Defamatory
Statements.
115.

The Defendants intentionally caused the Plaintiff to suffer severe

emotional distress.
116.

If the Defendants did not act intentionally, the Defendants acted

recklessly by disregarding the high probability that publishing the False and
Defamatory Statements and Private Photograph would cause the Plaintiff to suffer
severe emotional distress.
117.

The Plaintiff has suffered severe emotional distress as a direct result of the

publication of the False and Defamatory Statements and Private Photograph.
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118.

The Defendant’s Wrongful Conduct was extreme and outrageous.

119.

The Defendant’s Wrongful Conduct was so outrageous that it cannot

be tolerated by civilized society.
120.

The Defendant’s Wrongful Conduct rises to a level of behavior beyond

all possible bounds of decency.
121.

The Defendant’s Wrongful Conduct proximately caused the Plaintiff to

suffer severe emotional distress.

COUNT EIGHT
INJUNCTIVE RELIEF
PLAINTIFF vs. ALL DEFENDANTS
122.

Plaintiff hereby incorporates by reference Paragraphs 1 through 121 in this

Eighth Count as though fully set forth herein.
123.

The nature and extent of the conduct of Defendant Jennifer Miklus toward

Plaintiff demonstrates an intent to place Plaintiff in reasonable fear of bodily injury or to
has caused substantial emotional distress to Plaintiff, and therefore constitutes stalking.
124.

The Plaintiff has suffered and will continue to suffer irreparable harm if

this Court does not issue an injunction requiring Defendants to take all reasonable actions
to remove the False and Defamatory Statements, and the entire post contained in Exhibit
A, and all references thereto from the Offending web-site and any pages on any social
media controlled by any Defendant, and from continuing to engage in harmful conduct.
125.

The Plaintiff will suffer irreparable harm in the absence of injunctive relief.

126.

In contrast, the Defendants will suffer no harm because they have no legal

right to engage in the conduct about which the Plaintiff complains of herein, and no

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protected interest in maintaining false and defamatory statements on the Internet.
127.

The Plaintiff can clearly demonstrate some likelihood of success on the

merits of her claims.
128.

Mere compensation at law can only provide the Plaintiff with

compensation for injuries up to the present.
129.

It remains difficult if not impossible to calculate the damages arising from

the Defendant’s Wrongful Conduct.
130.

The Plaintiff therefore has an inadequate remedy at law.

131.

The public interest will not be harmed if an injunction is granted.

PRAYER FOR RELIEF
132.

Plaintiff seeks a preliminary and permanent injunction as to all

Defendants:
a. Compelling the Defendants to secure the immediate removal of and/or
to immediately disable access, content, and viewing capabilities to any
site on the Internet containing the Private Photographs, False and
Defamatory Statements about the Plaintiff, and/or any private facts
about the Plaintiff;
b. Compelling the Defendanst to make all reasonable efforts to remove all
cached information on any additional search engines and cooperate with
third party efforts to do so;
c. Compelling the Defendants to destroy all electronic copies of the Private
Photographs;
d. Enjoining Defendants from engaging in any further conduct enabling the
Private Photographs to be displayed, distributed, or accessed over the
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Internet; and
e. Compelling Defendants to engage in any such further conduct necessary
to effectuate the foregoing relief.
133. Plaintiff accordingly and respectfully prays for judgment against the Miklus
Defendants as follows:
a. That the Plaintiff be awarded statutory damages in an amount to
be determined at trial;
b. That the Plaintiff be awarded compensatory damages in an amount to
be determined at trial;
c. That the Plaintiff be awarded punitive damages as may be
available at law in an amount to be determined at trial;
d. That the Plaintiff be awarded injunctive relief sought; and,
e. That the Plaintiff be awarded any such other and further relief as this
Court may deem just and proper or to which she may be entitled as a
matter of law or equity.
f. Such attorney fees and costs as may be recoverable at law or in equity.
JURY DEMAND
Plaintiff hereby demands trial by jury as to all claims so triable.
HAHALIS & KOUNOUPIS, P.C.

Dated: September 15, 2016

By:

DAVID L. DERATZIAN, ESQUIRE
20 East Broad Street
Bethlehem, PA 18018
(610) 865-2608
Attorneys for Plaintiff

17

Sf o's a Hornewrecker

Haddad - 1Allenlown,
I Pennsylvania - Ellen
Pennsiyl'uania
Case 5:16-cv-04954-JFL
Document
Filed 09/15/16
Page 18 of 18 Page I

o,f 3

I

Search ANY Name For
- Arrest Records

- Hidden profiles
- Phone Number/Address

ll-']f--l@:={l

Ellen Haddad - Allentown, pennsiylvania
O

Septomber 17th, 2010

-

12:s9 pM

This little 23 year old Twat waffle Ellen worked at a strip club vyhich I had no idea
my husbarrd weis
even going to. ln september of 2013 she met my husband, sl^e Knewrny hu$band
of 14 years
was manied with 4 kids and went after him anyway. He is alsc, to blame for
b,eing the scum lie is,
but women who knowingly get involved with a maried man arr) lower than
low. They had an,affaii.
He was buying her drinks, booze, drugs, and screwing around with her for
a coupte rnonths. He
had several other affairs as well in the YEAR he wes doing thlt behind my
back. She thought he
was rich (in reality we were broke and at the time I couldn't figure out why)
so shrs wasi also after
the "lifestyle"' after I found out she tried to deny they were anything but friends
for months. She
tried to make it look like another woman named amber who ahio worked at
the strip club, was
screwing around with my husband and was pretending to be nry friend for monthrs,
all the time she
was just playing a fucking game. come to find out her and my husband
were BorH doing drugs
and fucking around for months as well. when finally I got the proof she
tried t' talk her way qut of
it' She is a drug addicted alcoholic little slut with no morals ancl tikes to screw
older married men,
tries to pin her sins on other peopre and has no remorse for any of it!

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Share This Homewrecker

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http://shesrhomewrecker.conjrh=:!6900

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Exhibit A
http :/i shesahromewrecker. com/ellen-haddad-allentown-penns ylv anta/

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