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Name:

KANAL V. GASTON

Address: P.O. BOX 4682 PORTLAND. OR 97208 Phone Number: ..... N..!!../"-"A'---_ _ __ E-mail Address:LEGALKAN2012@YAHOO.COM Pro Se UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON, EUGENE DIVISION Kanal V. Gaston

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) Plaintiffl: s), ) ) vs. ) ) (1) Facebook, Inc. ) (2) Maria Raquel Rivas ) (3) Lexis-Nexis Group and/or Reed ) Elsevier, Inc. ) (4) Capitol Information Group. Inc. and/or) Business Management Daily ) (5) Google. Inc. ) (6) Texas Office of the Attorney General ) and/orSmteofTexas ) (7) The PNC Financial Services Group, ) Inc. ) ) DefendanUsl.

Case Number:

-c t.J - /...(J3 S-r

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COMPLAINT

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JURy DEMAND ON ALL COUNTS

COMPLAINT

Plaintiff, Kana! V. Gaston, brings this complaint against the Defendants and states the following: 23 24

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JURISDICTION & VENUE

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1. This Court enJoys subject matter jurisdiction over this action under 28 US.c.
1332(a)(I) because the Plaintiff and Defendants are citizens of different states and th amount in controversy exceeds $75,000.

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2. This Court enjoys venue under 28 US.C. 1331 because this case involves a federa

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question and/or federal laws or treaties under the fourth (4th) and the fourteenth (14th amendments ofthe United States Constitution.

PARTIES

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3. Plaintiff, Kanal V. Gaston, is a private individual and not a public figure, current! residing in Phoenix, Arizona. From October 29, 2007 to January 12, 2011, Plainti worked in the White-Collar Crimes UnitlDivision of the Harris County Distric Attorney's Office in Houston, Texas as Fraud Examiner with the highest level responsibilities of conducting white-collar (financial) criminal investigations fro inception to final adjudication, and testifying as expert in such matters in judicial (cou
& grand jury) proceedings. In that capacity, because of Plaintiff oral and written fluenc
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in English, Spanish, and French, he also served as the sole foreign language translator i these criminal investigations whenever necessary, with an annual salary of about $72 000. After spending more than 18 years in college/university, Plaintiff has managed t obtain four (4) college degrees, which includes a master's degree in business and othe degrees or studies in criminal justice, accounting/finance, and computer engineerin technology. In an effort to enhance his professional reputation and standing in hi profession, plaintiff further sacrificed his own time and money to pursue and study fo additional professional certifications and/or recognitions. In 2006, plaintiff was grant
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the Certified Fraud Examiner (CFE) status by the Association of Certified Frau Examiners (ACFE). In 2010, Plaintiff was granted the Certified Internal Auditor (CIA status by the Institute of Internal Auditor, and that same year also passed the exam t become Certified Information Systems Auditor (CISA) to be granted by ISACA. 4. Defendant 1, Facebook, Inc. is located at One Hacker Way, Menlo Park, CA 94025
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1050 Pagemill Road Palo Alto, CA 94301 or 1601 California Ave, Palo Alto, CA 9430 or 1601 Willow Road, Menlo Park, CA 94025 (Agent). Its listed phone number is 650 543-1300 or 650-543-4800 or 650-543-4801. This Defendant has allowed and/or give Defendant # 2 access to its server or internet web communication system or device social network to spread false or defamatory statements against Plaintiff.
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5. Defendant 2, Maria Raquel Rivas, is an individual and the mother of Plaintiff's chil

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against whom Plaintiff was forced to call the police and the Texas Child Protectiv Services (CPS) in Houston several times because she had engaged in an abusive an unlawful pattern of stalking and harassing Plaintiff at his home and his place
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employment (job), for calling and emailing Plaintiff's friends, girlfriend, famil members, colleagues and bosses and others to lie and make false or defamato statements against Plaintiff as retaliation or grudge or revenge. This Defendant's addres is: 1977 Western Village Ln., Houston, TX 77043 and place of business is 955 Cambel Rd., Houston, TX 77024-2803. Her last known phone number is 713-251-3665. 6. Defendant 3, Lexis-Nexis Group, a division of Reed Elsevier, Inc. and/or Reed Elsevie PLC and/or Reed Elsevier NY and/or Corporation Services Company (CSC) ha maintained its headquarters at 125 Park Avenue, Suite 2200, New York, NY 10017. It listed phone number is 212-309-8100 and 800-455-3947. Defendant claims to engage i providing computer assisted legal research to the public at large and holds the larges electronic database for legal and public records in the world. This Defendant conspir with the other Defendants to retaliate against Plaintiff, and has published or republishe false & defamatory statements against him.

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7. Defendant 4, Business Management Daily (BMD) and/or Capitol Information Group Inc., a for-profit corporation with principal place of business located at: 7600A Leesbur Pike, West Building, Suite 300, Falls Church. VA 22043 and Mailing Address: P.O. Bo 9070, McLean, VA 22102-0070. According to its stated purpose, this defendant engage in giving business professionals the news, skills, and strategies they need to grow thei businesses, and help these businesses avoid legal pitfalls and advance careers with mor than a dozen HR-related newsletters, webnars, special reports, e-Ietters, podcasts an books. These publications include: The HR-Specialist, Administrative Professiona Today, HR Specialist Employment Law, Executive Leadership, Office Technolog today, and Small Business Tax Services. Founded in 2009, this Defendant boasts to b

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the solutions provider of choice for today's and tomorrow's professionals with a base 0
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130, 000 paid subscribers in 2010 with a mission to expand to one (1) millio subscribers. This Defendant's phone number is 703-905-8000 or 703-394-4931 and Fa number is 703-905-8100 or 703-543-2055. This Defendant conspired with the othe Defendants to retaliate against Plaintiff, and has published or republished false & defamatory statements against him. 8. Defendant 5, Google, Inc., is a corporation with principal place of business located at: 1600 Amphitheatre Parkway, Mountain View, CA 94043. Its listed phone number ther is 650-253-0000 or 650-253-3425 and fax number is 650-253-0001 or 650-649-2939. Google, Inc. also has headquarters office located at 76 ninth Ave, 4th Floor, New Yor
NY 10001. Its listed phone number there is 212-565-0000 and fax number is 212-565

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0001. According to publicly available information, this defendant reaches more than on billion online users (people) worldwide, with annual net income of more than 8 billio dollars and net asset of more than 38 billion dollars as of December 31, 2010. Thi Defendant conspired with the other Defendants to retaliate against Plaintiff, and ha published or republished false & defamatory statements against him.

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9. Defendant 6, Texas Office of the Attorney General, 300 W. 15th Street, Austin, T 78701. Defendant also has a mailing address: PO Box 12548, Austin, TX 78711-2548. Email: greg.abbott@oag.state.tx.us. Its listed phone number: 512-463-2100 or 800-252 8011 and Fax: 512-475-2994. This Defendant falsely published and/or reported tha Plaintiff was 120 days delinquent in child support payment. This Defendant conspired t retaliate, entrap, and torture Plaintiff, and have committed several unlawful acts again him, including publishing and republishing false and defamatory statements again Plaintiff. 10. Defendant 7, The PNC Financial Services Group, Inc. is located at One PNC Plaza, 24

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5th Ave, Pittsburgh, PA 15222. Its listed phone number is: 412-762-2000 and Fax: 412 762-7829. This Defendant falsely published and/or reported that Plaintiff was 120 day delinquent in student loan payments, causing Plaintiff to file for bankruptcy. Thi Defendant conspired with the other Defendants to retaliate against Plaintiff, and ha published or republished false & defamatory statements against him.

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STATEMENT OF FACTS AND CLAIMS

11. In April of 2006 Plaintiff moved to Houston Texas in order to be closer to his son an took a job as Senior Internal Auditor with Stanford Financial Group, now a defun company, where he worked until October of 2007 with an annual salary of abou $70,000. While working at Stanford Financial Group, Plaintiff met and became men with Maria Raquel Rivas who also worked in the accounting department there. I February of 2007, Rivas called and sent Plaintiff an email at work claiming that he younger child had been kidnapped and was missing from school. As any good frien would do, Plaintiff offered to drive to the school and help Rivas deal with this issue. A Plaintiff arrived at the school that afternoon, Rivas claimed that the police had found he son and he was safe and sound. Soon thereafter, Rivas came to Plaintiffs home and th relationship briefly turned intimate.
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12. One night while Plaintiff was sleeping at his home, he woke up at about 3 :00 AM only to find Rivas taking pictures and digging inside of his closet with all of Plaintiff's personal documents on the floor. These documents included a letter and records Plaintiff had obtained from the New Jersey State Police (NJSP) after a state trooper there had fabricated or made false and defamatory statements against Plaintiff causing Plaintiff tc be rejected for a job as state trooper, after Plaintiff was already voted best qualified for the job by the New Jersey State Police themselves. Specifically, these false an defamatory statements included the following: (1) that Plaintiff committed and wa convicted of insurance fraud in Florida and New York (2) that Plaintiff had committe

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and was convicted of social security fraud (3) that Plaintiff committed and was convicte
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of domestic spousal abuse, and (4) that Plaintiff was an illegal alien and trouble maker. 11 12 13
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Immediately thereafter this incident, Plaintiff asked Rivas to leave his home and never t return. However, not more than a few hours later, Rivas returned and refused to leave. Facing no other choice, Plaintiff was forced to call the police and had Rivas remove from his home. Later that day, both the local police and the school where Rivas's so attended informed Plaintiff that they had absolutely no records that Rivas's son was eve kidnapped or missing from his school as Rivas had claimed earlier, and the whol kidnapping claim was made up by Rivas against her own son as a hoax to gain sympathy. Realizing how dangerous a person Rivas was, Plaintiff decided to end or ceased al formed of communications or contacts with Rivas at that point. 13. Weeks later, Rivas was fired from Stanford Financial Group for making false allegation against another co-worker in the accounting department, and later demanded that Plaintif give her $3000 for an abortion because she was pregnant for Plaintiff. When Plaintif refused to give Rivas the money for the abortion, she then launched a massive campaig of stalking, harassment, and defamation of plaintiff. These included several instances
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calling and emailing Plaintiff's boss and other co-workers at Stanford Financial Group t tell them that Plaintiff was a criminal and a fugitive from New York, Florida, and Ne Jersey. As a result, Plaintiff resigned from Stanford Financial Group and took a muc

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lower paying job with the Harris County District Attorney's Office (DA) in October 2007, where he served as Fraud ExaminerlWhite-Collar Crimes Investigator until Janu of2011.

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14. Before the child was born, Rivas contacted Plaintiff and asked him if he could help pa the hospital delivery bill, and Plaintiff paid the entire bill in full. After the child was born, Plaintiff himself decided to go to the Texas Office of the Attorney General's (OAG) t start making child support payment towards the child. However, following the chil support agreement, Rivas began to deny Plaintiff his visitation rights and ofte disappeared when it came time for Plaintiff to pick up the child. She used the child as

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tool to manipulate Plaintiff and keep Plaintiff's girlfriend away from the baby.
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Meanwhile, the few times Plaintiff was able to reach Rivas and pick up the child, ther 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 appeared noticeable signs of abuse or neglect on the child. In early of 2009, Plainti received both a disturbing phone call and a text message from Rivas, in which sh (herself) claimed to be a danger to the child and needed professional help. Feelin helpless and concerned, Plaintiff had no other choice at this point but to call the polic and CPS to have them go to Rivas's home and check on the child. After this incident, Rivas threatened Plaintiff that she was once again going to Plaintiff's new job (DA' Office) and to the Texas OAG to defame Plaintiff, and then travel to New Jersey, wher she knew Plaintiff was seeking justice in the Courts against the NJSP for defamation, i order to teach Plaintiff a lesson. Not long after Rivas made this threat, all of Plaintiff' co-workers at the District Attorney's Office began to scorn and ridicule him, and hel Plaintiff in complete contempt or categorically refused to associate with Plaintiff as i Plaintiffhad some sort of loathsome disease. 15. In addition, every time Plaintiff would go to the Child Support Office to obtain help i enforcing the visitation agreement, the workers there began to ridicule and scorn Plaintiff, exclaiming among themselves and in Spanish that the "criminal is here, the criminal i outside." Much worse, Plaintiff even hired a lawyer (Sylvia Mintz) there to help hi obtain custody of his child. After Rivas told the lawyer that Plaintiff was a criminal an
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fugitive from New York and Florida who was convicted of fraud and domestic abuse all over the place, the lawyer stole Plaintiff's $1000 deposit and fled with Plaintiff's money, refusing to represent Plaintiff. Although Plaintiff became emotionally and mentall drained and distressed by these abusive and cruel treatments of his colleagues and thes other people towards him, Plaintiff continued to survive and perform or produce qualit work for the Harris County District Attorney's Office. 16. On January 4, 2011, Plaintiff was quietly sitting in his 5th Floor office at the Harri County District Attorney's Office performing his work when First Assistant Distric Attorney, Jim Leitner, sent Plaintiff an email asking Plaintiff to report to his (Leitner

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office in order to interview Plaintiff as part of an internal complaint or investigatio 10 involving wicked, corrupt, prosecutorial bias or favoritism,
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and other pervasive act

committed by his prosecutors and investigators while working for the Harris Count District Attorney's Office. During this interview, Mr. Leitner ordered Plaintiff to revea to him the names of the prosecutors and investigators who were present and gave Plainti a "sex toy" (pENISIDICK) at a prior office party in front of a multitude of other co workers, and forced Plaintiff to hold the PENISIDICK in the air while they took picture and laughed. Facing no other choice, Plaintiff told Mr. Leitner the names prosecutors and investigators who gave him the PENISIDICK at that office party. 17. During this same interview, Mr. Leitner also became aware of another incident of sexua harassment or misconduct, which occurred in September 2010, whereby his prosecutor and investigators unlawfully intercepted one of Plaintiff's text messages and sent graphic sexual act (pENISNAGINA) to Plaintiff's girlfriend in Arizona, as retaliation 0 punishment for Plaintiff's refusal to return the sex toy (pENISIDICK) gift they had give Plaintiff at the office party. These prosecutors and investigators had been asking Plaintif to return the DICKIPENIS since about May of 2009 or about the same time Rivas ha threatened Plaintiff she would go to his new job (DA's Office). But, each time the asked, Plaintiff refused to return the DICKIPENIS. In the meantime, Plaintiff was bein

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scorned, ridiculed, and shown complete contempt by all of the prosecutors an investigators in the office. 18. In addition to these pervasive acts or misconduct listed above, Mr. Leitner also becam aware of two other incidents whereby his prosecutors and investigators burglariz Plaintiff's car and apartment to perform illegal searches for the sex toy (pENISIDICK) and left their DNA (hair) inside of Plaintiff's apartment while Plaintiff was travellin away in Phoenix; and several other incidents whereby his prosecutors and investigator threatened to make life impossible for Plaintiff in Houston because of Plaintiff's refusa to return the DICKIPENIS and because Plaintiff had dissented or refused to participate i

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other acts of prosecutorial bias or favoritism for their friends or against innocent people. 10 These incidents include: hacking Plaintiff's computer to steal Plaintiff's personal 11 12 13
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information or private accounts and all ofPlaintiff' s audit work while he was working fo Stanford Financial Group to help them make their case against Stanford, and all
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Plaintiff's personal lawsuits, passport, medical, and citizenship files and documents. The also used these important files & information to sabotage Plaintiff's personal
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professional life. Further, Mr. Leitner also became aware that his prosecutors an investigators, with the help of other law enforcement agencies and private companies, also placed a GPS device in Plaintiff's brakes system causing it to explode in the middl of a Houston Highway costing about $875 to repair, as well as placing another GP device in Plaintiff's key ring allowing them to monitor all of Plaintiff's movements i hope to discover the location of the DICKIPENIS. Plaintiff was forced to call 911 twic and file two POLICE complaints/reports (#10218363 & #16027601O-A) with th HOUSTON POLICE DEPARTMENT (HPD) in Harris County Texas against them an Maria Raquel Rivas. 19. After this interview or upon providing Mr. Leitner with the information he ordere Plaintiff to give him in the presence of Captain Don McWilliams, Mr. Leitner requeste that Plaintiff work from home until January 7, 2011, not only for Plaintiff's own safety 0

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fear of immediate retaliation by these prosecutors and investigators against Plaintiff, bu also to give Mr. Leitner more time to decide what to do with Plaintiff. 20. On January 7,2011, Plaintiff reported to Mr. Leitner's office as requested or ordered. that day, Mr. Leitner and Captain Don McWilliams informed Plaintiff that as a result
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the information they ordered Plaintiff to provide them, it had now become impossible fo Plaintiff to continue to work at the District Attorney's Office. They gave Plaintiff unti January 12, 2011 to return the "Sex Toy" (pENISIDICK) to them, and then to resign
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face termination. After this threat, they made it known to Plaintiff that they had becom aware of all of Plaintiff's past lawsuits, his application for residency in Canada, his personal injury claim to Allstate, his job application to Valero and elsewhere, and hi

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investigators had already been working together with the United States Postal Service
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(USPS) inspectors, the New Jersey State Police (NJSP) investigators, the IRS, and som 12 New York City (NYC) investigators during the past two years to follow plaintiff aroun and intercept all of Plaintiff's emails, personal accounts, postal service mails, and phon communications in order to develop a comprehensive profile on Plaintiff, his family, an friends. In addition, Plaintiff was already surrounded by their spies or crawlers in hi apartment complex where he lived in Houston, and they were ready to send red flags t these companies mentioned above to make sure that all of Plaintiff's applications an claims are denied and that Plaintiff never works again in this country or anywhere else. 21. Further, they made it clear that they already had people working for them inside th Texas Attorney General's Office (OAG) and the major banks around the country wh were ready to make sure that Plaintiff never gets custody of his children, and that Plainti passport and driver's license would get revoked or suspended for being a deadbeat dad 0 for not paying child support; and that they would use their internal database to send fals financial or credit information to the major Credit Bureaus in order to ruin Plaintiff' credit. Therefore, if Plaintiff did not return the DICKIPENIS as requested, they woul unleash all of these investigators, bankers, and federal agents or inspectors to go aft Plaintiff to teach him a lesson and destroy him completely or finish him off.
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22. On January 12, 2011, as Plaintiff returned to Mr. Leitner's office, they handed Plaintiff letter/document outlining if plaintiff did not return the "sex toy" (pENISIDICK), the would unleash the mother ofPlaintiff's Child, Maria Raquel Rivas, so she could release NEWSPAPER article or Publication on Plaintiff along with all of Plaintiff s privat information on Google or the internet in order to paint or show all of Plaintiff s friends,
family members, colleagues and future employers that Plaintiff was crazy and a troubl maker who was convicted of (1) Insurance and driver's license fraud in Florida and Ne York (2) Social Security Fraud (3) domestic spousal abuse, (4) that Plaintiff was a illegal alien, (5) that Plaintiffs never gets along with anyone, (6) that Plaintiff committ

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fraud with the IRS, and (7) that Plaintiff was involved in a ponzi scheme and committ
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fraud while he was working for Stanford Financial Group. Although Plaintiff wa 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 absolutely unaware of what Newspaper article or Internet documents they were talkin about at that particular time, Plaintiff provided Mr. Leitner with a copy of th DICKIPENIS, a copy of the bill ($875) for repairing the damage to his brakes system, and a copy of the SEX ACT that his prosecutors and investigators had sent to Plaintiff girlfriend in Arizona earlier. However, Plaintiff refused to return the actual DICKIPENIS, and was forced or coerced to resign from his $72,OOO/year job as a result. 23. Soon thereafter, Plaintiff received an email from Maria Raquel Rivas accusing Plaintif again of being a criminal, with an attachment, which includes a Newspaper Article post on Google, Inc. and/or the Internet, indexed to the Lexis-Nexis Group, and Published b the Business Management Daily and Titled "Insist on thorou documentation
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background check results." Here, this article clearly makes an example of Plaintiff as convicted criminal and served as a form of advertisement to generate memberships an revenues for the Publisher's business by stating as example or support for its title "recen case: When Kanal Gaston was rejected after applying to join the New Jersey State Police, he thought it had something to do with his ethnicity." However, the letter Gaston go from the State Police made it clear he was rejected because of the totality of th derogatory information collected during the background information, including tw

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incidents of insurance fraud and work history." This Article or publication

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republication also states "when Gaston sued, the State Police introduced a comprehensiv background investigation file. It showed the court exactly why it had concluded Gasto was not trooper material-including extensive interviews that revealed spousal abuse." I was at that point that Plaintiff finally realized for the first time that Maria Raquel Riva has been the original source and cause of all his misery during the past two years. Sh was the only one in Texas who knew of that letter and had stolen it along with othe Plaintiff's documents from Plaintiff's home earlier when Plaintiff had called the police t remove her from his home. At this point, it also became clear that Getting Plaintiff to los

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his job and have his co-workers, friends, and families tum against him, and by Gettin 10 Business Management Daily and Google, Inc. to publish and republish the false an

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defamatory statements both in print and on the internet is, in whole or in part, the lesso that Maria Raquel Rivas and these investigators or prosecutors or agents had threatene to teach Plaintiff. 24. Worse, this article also contains an automatic Link, which allows (Rivas & others) user to share or send an email copy to another email user with just a simple click, therefor facilitating its multiplication and the spreading of the falsehood against Plaintiff muc more quickly. As Rivas and her counterparts in Houston intensified their acts of stalking, hacking, harassment, threats, intimidation, and other crimes against Plaintiff, Rivas als revealed to Plaintiff for the first time that it is indeed the NJSP, the IRS, the NYC, an the USPS investigators or inspectors or other federal agents who forced her to participat in committing these crimes against Plaintiff to teach Plaintiff a lesson, simply because 0 Plaintiff's past lawsuits or legal complaints against all of them or because Plaintiff ha dared to sue them in the past. As a result, Plaintiff finally decided to discretely evade an flee his apartment in Houston at 4:00 AM, fearing for his personal safety. In addition, Plaintiff has been forced to file for bankruptcy, quit law school after one year of study, and spent his last few weeks in Houston living and sleeping in his car and the streets.

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25. Despite the fact that Plaintiff holds four college degrees, is fluent in three differen languages, and hold multiple professional certifications and recognitions, has shown to b best qualified for any job in his profession, has never done any form of illegal drug during his entire life, and has never committed or been convicted of any crime anywher in the world, Plaintiff has not been able to obtain employment anywhere as a direct resul of these defendants false or defamatory statements of facts against him. Every tim Plaintiff has applied for a job or apartment or anything else, these defendant continuously follow or monitor and intercept Plaintiff's phone calls, credit reports, ban accounts information, friendships, and emails or movements through Google or GP

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devices, so they can call these companies themselves and tell them to Google Plaintiff' 10 name. They know full well that once these companies or people see the false
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defamatory statements online, which the

themselves

laced on the internet a ains

Plaintiff, he would be denied relationships and anything he has applied for. Worse, the even used this same perverted practice every time Plaintiff has tried to get a lawyer t represent him. Although Plaintiff has contacted more that 100 lawyers in Texas for hel with these matters, not a single one ever returned Plaintiff s call or emails. 26. All of Plaintiff's friends, colleagues, and family members have deserted him and the have bribed and kept everyone from helping Plaintiff. In the meantime, Plaintiff is bein chased, defamed, harassed, intimidated, and followed by Rivas and these investigators 0 agents everywhere he has gone. In a desperate search to recover the DICKIPENIS, the have tried to entrap Plaintiff multiple times before the District Attorney's 2012 Re election campaign gets in full swing.

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COUNT I-DEFAMATION & DEFAMATION PER SE

27. As clearly shown on Plaintiff's FBI criminal background and Texas Department ofPubIi Safety records, Plaintiff has never committed and never been charged and convicted
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any crime in the United States or anywhere else in his entire life. Specifically, when thes
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false or defamatory statements listed above were made, Plaintiff was and still remains United Citizen, Plaintiff has never been charged or convicted of social security fraud; Plaintiff has never been charged and convicted of domestic spousal abuse, Plaintiff ha never been charged and convicted of insurance fraud in New York or Florida, Plainti never committed and has never been convicted of Ponzi-scheme or fraud while he wa working at Stanford Financial Group as claimed or alleged by Rivas, and Plaintiff ha been an exemplary employee in every job he has held and never been fired for any cause, but always serving with the highest level of integrity & ethics. Plaintiff has always pai his child support and has never been charged or convicted of being a "deadbeat dad," an

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Plaintiff has never been charged and convicted of fraud with IRS or anywhere else in hi 10 entire life, as claimed or accused by Rivas and her counterparts. In fact, Plaintiff ha
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even applied for or ever owned or held any insurance policy in Florida, Plainti

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has maintained a clean and the same driver's license record for about 20 years, and ha never been charged and convicted of driver's license fraud in Florida or anywhere el during his entire life. 28. These published and republished Statements referenced in paragraph above (hereinafte "Statements") negligently, recklessly, and intentionally impute or assert or imply th following acts of criminal and moral turpitude: (a) that Plaintiff is or has been foun guilty of domestic spousal abuse, (b) that Plaintiff is or has been found guilty of tw counts of insurance fraud (Florida & New York), (c) that Plaintiff is or has been foun guilty of driver's license fraud in Florida, (d) that Plaintiff is or has been found guilty
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committing social security fraud, (e) that Plaintiff is or has been found guilty of being a illegal alien, (f) that Plaintiff is or has been found guilty of ponzi-scheme or fraud a Stanford Financial Group, (g) that Plaintiff is or has been found guilty of not bein 'trooper material," (h) that Plaintiff is or has been found guilty offraud with the IRS an all over the place, and (i) that Plaintiff is or has been found guilty of "not getting alon with anyone."

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29. These Statements, individually and taken as a whole in context ofthe article and the issu of Business Management Daily and Google. Inc. in which they have appeared, ar defamatory because they falsely impute to Plaintiff corruption, fraud, deceit, as well a the commission of a criminal offense, in a manner ruinous to the reputation and esteem 0 Plaintiff professionally, locally, nationally, and globally. These defamatory Statement directly and proximately caused Plaintiff general and special damages in the form
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injury to his reputation throughout the United States and internationally. These damage include, but are not limited to, Plaintiff's scholarly credibility being compromised, loss 0 prospective economic opportunities and relations, loss of contracts and speakin

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invitations, loss of teaching and book publishing opportunities, loss of book sales, an

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certainly emotional distress and psychological trauma and suffering. 11 12
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30. These defamatory Statements, therefore, severely injured Plaintiff's reputation as scholar and expert in white-collar crimes, auditor, and forensic accounting, especially i certain professional circles. By publishing these Statements in hard copy and on th Internet in the Business Management Daily and Google, Inc., Defendants knew the would be republished and read by the general public throughout the United States an elsewhere. These Statements were in fact republished and read by paid members of th Defendants and the general public throughout the United States and elsewhere as a direct, natural, probable, and foreseeable consequence of Defendants' publication an subsequent republication. 31. Worse, Defendant 6 negligently, recklessly, and wantonly reported and published falsel that Plaintiff was 120 days delinquent in child support payment and falsely published tha Plaintiff's Passport and Driver's license would be suspended or revoked for not payin child support or for being a deadbeat father. 32. By publishing these Statements, Defendants intended to, and did charge Plaintiff with th commission of a crime, and stigmatize Plaintiff as guilty of fraud, domestic abuse, deceit, and injure his professional standing and reputation. The Statements individually an

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collectively are false, and were false when made. The Statements are defamato falsehoods, which Defendants knew or should have known were false when made.

COUNT II-DEFAMATION. DEFAMATION PER SE & PUNITIVE DAMAGES

33. Defendants made the Statements with actual malice and wrongful and willful intent t injure Plaintiff The Statements were made with reckless disregard for their truth
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falsity or with knowledge of their falsity and with wanton and willful disregard of th reputation and rights of the Plaintiff Defendants knew, anticipated, foresaw, an intended that the Statements would be read by persons throughout the United States an the world and would damage the reputation of Plaintiff reasonable grounds for making the Statements. 34. The Statements, individually and collectively, referred to herein have caused, are causing, and will cause Plaintiff to suffer psychological and emotional trauma and suffering, injury to his professional standing and reputation or good name; and they have held an will continue to hold Plaintiff up to public scandal, contempt, and ridicule in his persona or professional life. These published and republished Statements were calculated to caus irreparable damages to Plaintiff and expose him to public scorn, hatred, contempt, an ridicule. Defendants clearly lacke

COUNT ill-CENSORSHIP & INTERFERENCE WITH ECONOMIC OPPORTUNITY

35. More important, in direct response to these crimes committed herein against Plaintiff, h formed a REGISTERED nonprofit company under the name ofWRlP.ORG or th

RETALIATION PROTECTION PROJECT specifically designed to help worker


who have been abused or retaliated against at the work place for reporting abuses b bullies with power or control. However, Because the evidence of all these crime committed against Plaintiff are posted at this company web site, in direct response fro
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Plaintiff outcry to obtain some fonn of help from the outside world, these Defendant have conspired to sabotage & censor or shutdown the company by preventing Plainti from promoting or marketing or obtaining funding or financing for the business. Plainti has sustained irreparable economic, emotional, physical, and psychological injuries as result. PRAYER FOR RELIEF

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33. Plaintiff demands jury judgment against Defendants, jointly and severally as follows: (1 compensatory damages on Count I through Count Count

m; (2) Special damages on Count I throug


both pre-judgment and post

m; (3) punitive damages on Count I through Count m; (4)

judgment interest on Count I through Count

m; (5) Plaintiff prays and demands an immediat

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Restraining Order (RTO) and/or Protective Order and/or Injunction to keep these Defendant away from plaintiff's residence, car, computers and routers or networks, places of employmen or business & enjoyment, friends, families, colleagues, and anything associated with Plaintiff 0 his affairs and documents; and to pennanently bar or prevent Defendants from ever publishing 0 republishing any future statements or records or items with Plaintiff s names and/or associat with Plaintiff, and to permanently remove all such items or records from their databases or file or prints or the internet altogether unless authorized by Plaintiff in writing; and (6) such othe and further reliefas this Court finds just and equitable.

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JURY TRIAL DEMANDED ON ALL COUNTS OR ISSUES

Respectfully submitted,

~~~
Kanal V. Gaston, Pro Se

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