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The following is a facsimile copy of the Complaint filed in Worcester Superior Court against TurtleBoy Sports and Aiden Kearney.
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COMMONWEALTH
OF MASACHUSETTS
WORCESTER, SS SUPERIOR COURT February 11, 2016
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GORDON T. DAVIS, Plaintiff
Vs.
TURTLEBOY SPORTS INC.,
AIDEN KEARNEY,
Defendants
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COMPLAINT
Parties
1. The Plaintiff is Gordon T. Davis who
resides in Worcester MA. The Plaintiff at the time of the violations was self
employed as an Advocate helping people with discrimination cases at the
Massachusetts Commission Against Discrimination and employment cases at the
Department of Unemployment Assistance.
Please see Exhibit 1.
2.
The Defendants are:
Aiden Kearney
Worcester MA 01603
Turtleboy Sports, Inc.
c/o Aiden Kearney
Worcester MA 01603
Counts
3. In November 2015 the Defendants libeled the Plaintiff
by writing in their publication that the Plaintiff, Gordon T. Davis, is
mentally unstable. Please Exhibit 2.
4. In November 2015 the Defendants wrote in their
publication that the Plaintiff, Gordon T. Davis is senile. Please see Exhibit
2.
5. In July 2015 the Defendants wrote in their
publication that the Plaintiff, Gordon T. Davis is crazy.
6. The Plaintiff Advocacy has been severely
adversely affected by the libelous publications of false information about the
health of the Plaintiff.
Demands
7.
Reparation for loss clients and case
income for the year 2015.
8.
The Defendants cease and desist their
libel.
9.
A retraction of the libelous
publications about the Plaintiff health.
10. Compensation for loss clients and case income
for 2016 through the period of time ending one year after the retraction of the
libel.
Signed under the pains and penalties
of perjury
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Gordon T. Davis
Date
Pro Se Plaintiff
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