LAW OFFICES
OF
DELLI CAT
Cattorney for
Plaintiffs
IN THE
SUPERIOR COURT OF THE STATE OF CATDOM
IN AND
FOR THE COUNTY OF CATFUSION
ELIZABETH
QE2, )
QUEEN BITSY, )
PEPPER LE
MILLE’, ) No.
0237258
BAMBI, )
) VERIFIED COMPLAINT
Plaintiffs, ) FOR DAMAGES FOR
) LIBEL, DEFAMATION
vs. ) OF CHARACTER,
) SLANDER
NOSEY PARKER, )
CATERWAUL
CHRONICLE, )
THE AGENCY, )
MAC T.
McTAVISH, AGENT 0001 )
MOKE THE
MAGNIFICENT, AGENT 0007 )
KEEKEE, AN
ORANGE TOM )
Defendants.
Plaintiffs
allege:
1. Defendant NOSEY PARKER, an individual, is a
tomcat who as sole purrprietor, operates a boys only club called tomzrule®
privut boyz klubb.
2. Defendant CATERWAUL CHRONICLE is an entity
which publishes a monthly mewspaper which falls under the jurisdiction and
control of NOSEY PARKER and tomzrule® privut boyz klubb.
3. Defendant THE AGENCY is a private
investigator firm that is associated with the tomzrule® privut boyz klubb and
specializes in spying on girls.
4. Defendant MAC T. McTAVISH aka Agent 0001, is
an individual who acts as Chief Investigator for THE AGENCY and as such is in
charge of operations of THE AGENCY and is directly responsible for the actions
of the Agents.
5. MOKE THE MAGNIFICENT aka Agent 0007, is an
individual who works in the capacity of assigning Agents in THE AGENCY to
special assignments, which can include disguising themselves as girls in order
to spy on them better.
6. KEEKEE, a renowned turkeymeat thief, is an
individual who specializes in causing trouble at any activity where girls are
gathered, and quite often appears in disguise.
7. The corporation, tomzrule®, acts as the
umbrella under which the CATERWAUL CHRONICLE and NOSEY PARKER conduct their nefarious
operations.
8. Named Defendants, both individually and in
behalf of tomzrule® privut boyz klubb did willfully and with malice
aforethought post numerous demeaning messages and photographs of said
Plaintiffs on the “Brofur Clubs Meows” message board, thus subjecting the
Plaintiffs to public humiliation and loss of respect in the community.
9. Named Defendants, both individually and in
behalf of tomzrule® privut boyz klubb, did disseminate numerous emails of an
inflammatory nature across the Internet, thereby reaching millions of readers
in every country of the world. These
communications were defamatory in nature, with specific mention of each of the
named Plaintiffs, thereby causing undue grief, embarrassment, humiliation and
suffering by each of the named Plaintiffs.
10. Defendants believe their positions entitle
them to engage in lies, misrepresentations, and bad behavior.
11. At all
relevant times, each Defendant conspired with each other Defendant to engage in
the acts as alleged in this complaint.
FIRST
CAUSE OF ACTION
(Libel)
12. On or about the beginning of time,
Defendants began distributing false, defamatory, and disparaging messages about
Plaintiffs. These messages, authored
and published by Defendants, were e-mailed to mailing lists, posted on Internet
message boards and news groups, posted on the tomzrule® website and printed in
the CATERWAUL CHRONICLE.
13. Defendants have actively and aggressively
distributed false and defamatory information about Plaintiffs to millions of individuals
both in the United States and all over the world. The object of these activities is to destroy the Plaintiffs’ good
reputation and to make them objects of ridicule.
14. At various times, in various combinations,
the Defendants conspired with each other to engage in the acts as alleged in
this complaint.
15. The Defendants did deliberately, and with
actual malice, disseminate false, defamatory, and malicious statements and
photographs to the effect that:
(a) ELIZABETH QE2, an aging Queen, was publicly
embarrassed, humiliated, and suffered great mental anguish and pain and
suffering as a result of nude photos widely circulated on the Internet by said
Defendants.
(b) QUEEN BITSY has suffered immeasurable
humiliation, loss of dignity, and has also suffered intense mental anguish and
pain and suffering as a result of enhanced photographs widely circulated by
said Defendants which depict her in numerous outlandish, outrageous, false
situations.
(d) PEPPER LE MILLE’ has suffered severe mental
anguish, public humiliation, and pain and suffering as a result of the flagrant
postings of photographs of her which were intended to be kept private. In addition, numerous Internet postings have
been made by said Defendants which were designed to maliciously misrepresent
her true nature and slander her good name and standing in the community.
(e) BAMBI, a sweet, defenseless gurl, has
suffered greatly at the paws of her notorious brother, KEEKEE, who continually
posts messages and pictures on the “Brofur Clubs Meows” message board which
make BAMBI appear to be fat and selfish.
He ceaselessly continues to make false accusations against her that she
steals his turkeymeat. As a result of
her brother’s maligning, the other tomcats laugh at her and say ugly things
which cause her intense mental anguish and pain and suffering.
16. The above-mentioned statements were
published and republished maliciously with the specific intent to harm the
Plaintiffs and to advance the commercial activities of Defendants.
17. The above-referenced conduct of said
Defendants is willful, malicious, fraudulent, outrageous and in conscious
disregard and indifference to Plaintiffs’ rights. Plaintiffs, for the sake of example and by way of punishing said
Defendants, seek punitive damages.
WHEREFORE,
Plaintiffs pray judgment against Defendants as hereinafter set forth.
SECOND
CAUSE OF ACTION
(Defamation
of Character)
18. Paragraphs 1-17 are re-alleged and
incorporated herein by reference.
19. That the said statements made by Defendants
are defamatory in nature and designed to ridicule and humiliate Plaintiffs and
to destroy their good standing in the community.
20. As a direct and proximate result thereof,
Plaintiffs have suffered the injuries and damages previously alleged.
WHEREFORE,
Plaintiffs pray judgment against Defendants as hereinafter set forth.
THIRD
CAUSE OF ACTION
(Slander)
21. Paragraphs 1-20 are re-alleged and
incorporated herein by reference.
22. At various times, in various combinations,
the Defendants conspired with each other to engage in the acts as alleged in
this complaint. The purposes of this
conspiracy have been to:
a. Subject named Plaintiffs to public ridicule,
embarrassment, and humiliation;
b. Destroy the fine reputations said Plaintiffs
used to enjoy;
c. Undermine and assassinate the character of
named Plaintiffs;
d. Promote the reputations of each of the
Defendants;
e. Share information with each other in
furtherance of these goals.
WHEREFORE,
Plaintiffs pray judgment against Defendants and each of them as follows:
1. For Plaintiffs’ general damages in the
amount of 500,000 samoleons;
2. For Plaintiffs’ cost of suit herein;
3. For exemplary or punitive damages in the
amount of 20,000,000 samoleons; and
4. For such other and further relief as the
Court may deem just and proper.
DATED: May 21, 2002
By Delli
Cat
Delli Cat
Cattorney for
Plaintiff(s)