IN
THE DISTRICT COURT OF DENVER COUNRT, COLORADO
CIVIL
DIVISION
Theatrix USA, a limited liability
company,Torchmark Media, a limited liability company,
2 Corners Enterprises, a limited liability holding company,
and
Mike Broemmel, an individual,
Plaintiffs,
vs. Case No.
_____________________________
Deneale K. Williams,
Defendant.
COMPLAINT
COMES NOW
Theatrix USA, a limited liability company, Torchmark Media, a limited liability
company, 2 Corners Enterprises, a limited liability holding company and Mike
Broemmel, an individual, (hereinafter collectively known as “Plaintiffs”), who
for their Complaint state and allege as follows:
1. Theatrix
USA is a theatrical production company that produces original stage plays in
cities across the United States and is partially owned by Broemmel.
2. Torchmark
Media is a media syndication service providing columnists and feature articles
to publications in the United States and is partially owned by Broemmel
3. 2
Corners Enterprises is a holding company partially owned by Broemmel.
4. In
addition to his ownership interest in the aforementioned enterprises, Broemmel
is an author and lecturer with books published internationally and who speaks
at conferences and conventions across the United States.
5. Deneale
K. Williams (hereinafter Defendant) is an individual who can be served with
Summons and Complaint at Manager’s Unit, King Street Mobile Home Park, Brevard
County, Florida.
Statement of Facts
6. Defendant
has been prosecuted and incarcerated for stalking and harassment.
7. Defendant
has engaged in an ongoing pattern and practice of harassing, defaming and
placing in false light the Plaintiffs herein.
8. In
October 2014, Defendant posted at multiple locations on the Internet false
statements that accused Plaintiff Broemmel of misappropriating money from her,
of accessing her personal bank account, of accessing her PayPal account
multiple times and of accessing her email account(s) multiple times.
9. Defendant
contended that Plaintiff Broemmel undertook these activities as part of his
association with Theatrix USA.
10. One
October 6, 2014, Defendant posted false statements multiple times on the
Internet that accused Plaintiff Broemmel of telephoning her and stating that he
was coming over to her house to rape and murder her.
11. Over
the course of the past 45 days, Defendant has posted other false, defamatory
and statements made in false light on the Internet with the express purpose of
hampering the operations of the business entities named as Plaintiffs herein
and to impair Plaintiff Broemmel’s ability to earn a living.
Count
One – Defamation
12. Plaintiffs
incorporate paragraphs 1 through 11 into this section as if the same were set
forth in their entirety.
13. Plaintiffs
contend that the false statements referenced herein and above constitute
defamation and were knowingly made by Defendant with the express purpose of
harming the reputation of Plaintiffs and causing Plaintiffs financial loss.
WHEREFORE, Plaintiffs
request judgment in their favor and against Defendant in an amount in excess of
$50,000 for defamation.
Count
Two – False Light
14. Plaintiffs
incorporate paragraphs 1 through 11 into this section as if the same were set
forth in their entirety.
15. Plaintiffs
contend that the false statements referenced herein and above constitute false
light and were knowingly made by Defendant with the express purpose of harming
the reputation of Plaintiffs and causing Plaintiffs financial loss.
WHEREFORE, Plaintiffs
request judgment in their favor and against Defendant in an amount in excess of
$50,000 for false light.
Count
Three – Tortious Interference with Business Operations
16. Plaintiffs
incorporate paragraphs 1 through 11 into this section as if the same were set
forth in their entirety.
17. Plaintiffs
contend that the false statements referenced here1in and above constitute
tortious interference with business operations and were knowingly made by
Defendant with the express purpose of harming the reputation of Plaintiffs and
causing Plaintiffs financial loss.
WHEREFORE, Plaintiffs
request judgment in their favor and against Defendant in an amount in excess of
$50,000 for tortious interference.
Count
Four – Harassment
18.
Plaintiffs incorporate paragraphs 1 through 11 into this section as if the same
were set forth in their entirety.
19. Defendant has
engaged in an ongoing pattern and practice of harassment that is designed to
cause Plaintiffs financial loss.
WHEREFORE, Plaintiffs
request judgment in their favor and against Defendant in an amount in excess of
$50,000 for harassment.
Plaintiffs
pray for such other and further relief the Court deems just and equitable in
the premises, including expenses and attorney fees. Plaintiffs further reserve
the right to submit to the Court an appropriate pleading seeking punitive
damages because of the egregious conduct of Defendant in falsely accusing
Plaintiff Broemmel of telephoning her to advise that he was coming to her
residence to rape and murder her.
Plaintiffs
request that this matter be scheduled for a trial by jury. Finally,
Because
Defendant’s inappropriate and illegal conduct is ongoing, Plaintiffs
respectfully reserve the right at amend this Complaint to reflect additional
damages caused by Defendant’s willful and wrongful conduct.
Respectfully
submitted,
