Aymond Citation Petition Original Complete Served November 2009

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    C I T A T IGREGORY R. AYMOND

    VERSUS NO. 90669

    ED HOOPER

    CITY COURT OF PINEVILIJE

    PARISH OF RAP]DES

    STATE OF I-,OUISIANA

    TO: ED HOOPER270 HOOPER ROADDEVILLE, LOUISIA-I{A7L328TET.,EPHONE (318) 443-90L7

    you ARE HEREBY SUMMONEDo comply with the demand contained in

    the attached certified PETITION AND INTERROGATORIES ND REQUEST FOR

    PRODUCTION, or to file your answer or other pleading to saidpe t i t ion in the off ice of the C1erk of Cour t of PINEVILLE CityCour t wi th in 10 days f rom da te of serv ice hereof . You are a l so

    respons ib le foE lega l in te res t AND ALL FILING FEES. Yourfa i fure

    to compl-y herewith wil-I subject you to the penalty of entry ofDefault ,fudgment against You.

    Witness the Honorable rl . Phillip Terrell- , .Tudge of said Court,on November 5 , 2009.

    SERVICE INFORMATION

    to ra of(DATE) I received the within Citation and on

    (DATE) I made service as folLows:

    PERSONAL SERVICE on the party herein named

    DOMICIIJIARY SERVICE on the party herein nanned by leaving the

    at his domicile in this parish in the hande of, a person apparentJ-y of suitable ag e

    discretion, residing in the domicile of the Person to whom theprocess of court was iesued.

    RETI'RNED WITHOIII SERVICE ONITNABLE TO LOCATE: MOVED

    (DATE)NO SUCH ADDRESS

    OTHER REASON/COMMEMrS

    MII,EAGE FEE:

    sane

    andsaid

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    crvrLurrNUMBER-o ka 9i

    REGORY R. AYMOND PINEVILLE ITYCOURTPARISHOF RAPIDES

    STATE OF LOUISIANA

    SUS

    D HOOPER

    PETITIOI{

    The Petition of GREGORY R. AYMOND. a citizen and resident of Alexandria,

    Rapides Parish, Louisiana, nd of the age of majority,with respect epresents:

    1 .

    ED HOOPER, resident nd domiciliary f Ward 11 of Rapides Parish, ouisiana,

    is made defendant erein.

    2 .

    The defendant s indebted nto your petitioner or sums as are reasonable nd

    propern

    premises,or reasonable ttorney ees;, nd for all costs of court, ogether with

    legal nterest n all sums rom date of udicial ermand ntil paid.

    3 .

    That he defendant s a "blogger" ho has a blog entitled we saw hat..."wherein

    he posts hingswith regard o news and current vents and otherthings which nterest im

    and which he operates rom his home n Ward 11, Rapides Parish, ouisiana.

    4 .

    That on or about March 27, 2009, on tlre "we saw that,. ." blog,

    published he followingdefamatory omments alcout our plaintiff:

    a. "however, an anyone eally elievemr. aymond when he s aknown iar?"

    "lately,mr. aymond as been using is blog o promote nddefend members f hi s criminal etwork."

    "heuses rdiduse mari juana. ."

    "ourexperience ithgreg aymon

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    f. "see also the unethical attorney greg aymond label n thefooter of this post"

    and published t o the general ublic where t s ervailableor reading o anyone who goes

    to his blog and where approximately 00 o 500 people ead his blog on a daily basis.

    5 .

    Thaton or about Apri l , 2009, n he we iawthat . . . " log,ED HOOPER ublished

    the ollowing efamatory omments bout your plaintiff:

    a. "mr.aymond's ttacks re evidence f he growing esperationand pressure hat he and he criminals hat he's workingwithare under o shut wst . . . own."

    b . "he s unethical"

    c. "in eality r.aymond nd hiscriminalriends imply ant o be n control fthe nformation o hat hey an ric;kou nto hinking ilrathe criminalshathe supports re honest nd he criminals n the rival rime angs hat hedogs out are not."

    d. "mr. ymond ndhiscriminalfriendsavewithwst... s hat wearent wned r controlled y anyone"

    e. "mr. ymond n he other andwerrto aw chool nd earnedhow o become professionaliar, ser and con-artist."

    f "we have greg aymond sittingon a shitter n alexandria,louisiana; hinking p ways of ho,w o gyp someone, hilstjacking isdick." t -

    and publishedt o he general ublic here t s availableor eading o anyone ho goes

    to his blogand whereby pproximately00 o 500 people ead hison a daily asls.

    6 .

    That n oraboutMay 0,2009, n he we aw hat. . ." log, D HOOPER ade he

    followingefamatory omments bout ourplaintiffn his blog:'

    "for instance elf-admitted nethical nd mentally defectivelocalattorney nd alleged former lember" f he ku kluxklan,greg aymond when he's

    not busy stealingannetUtown

    alkcontent nd posting t o his blog o mock some black kidswhohave never done anything o him other han o be borrr blackwhich n mr. aymond's orld s he $ame as drivingwhileblack- or moni tor ing st . . . )"

    7 .

    That he untrue tatements ublished n the we saw hat.. . blog by ED HOOPER

    about petitioner onstitute n unwarranted alse, malicious nd liable attack upon his

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    1 4 .

    That all allegations f this petition re made n the alternative r pleaded n the

    alternative here one might be inconsistent ith another.

    1 5 .

    That although D HOOPER s believed o livesomewhere n he Pineville rea, his

    address s unknown nd not isted nywhere nd he cannot e served nd a curatorshould

    be appointed o receive ervice and attemptto ocate ED HOOPER so thatthis matter may

    proceed.

    WHEREFORE OURPETITIONER RAYS:

    1. That he defendant e served itha copy of his petition ndcited o appear nd answer ame;

    2. That fter egaldelays ave lapsecl nddue proceedings ad,there e udgment n avor f Gregory .Aymond ndagainstEd Hooper or sums and damages s are reasonable nd

    proper n he premises, easonable ttorneyees o be ixedbythe court and all costs of court;

    3. That a Curator e appointed o receive ervice nd attempt olocate D HOOPER; nd

    4. Forallnecessary rders nd decreres.

    By his etttorney,

    P. O. Box 12424Alexandria LA 71315-2424(318) 42-88eeLa. Bar Roll Number 22,366

    Service nstructions:

    Please erve he Curator ppointed o locateED HOOPER ith this Petition.

    ATTORNEY OR GREGORY .AYMOryD

    I csrtifyhat he oregoings a ruoandcorToctopy fthe orlginal n lloand0frecordn heOfficef hsCltyCourt,rrb{aro otf l fusa- | ' , - - ,n-83a-t --Clerk f heCourt

    SUSANI ORD FISER

    C:\Documents nd Settings\Becka\My Documents\Petition\Aymond.Gregory.wpd

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    INTERROGATORY UMBER4:Please state what facts you relied upon when you published on March 27, 2009 thefollowing, nd also please state each act and circumstance pon which you reliedon,stating members f hiscriminal etwork" nd n crcnnectionherewith lease istthe name,address and elephone number of each person ,vho an estifywith regard o the veracityto same.

    a. "However, an anyone eally believe Mr.Aymond when he isa known liar?"

    b."Lately,Mr. Aymond has been usirrg is blog o promote nddefend members of his criminal etwork."

    ANSWERTO INTERROGATORY UMBER 4:

    INTERROGATORY UMBER5:

    Please istand set orth a detailed escription f each and every exhibitwhichyou ntendto utilize s demonstrative vidence uring he rialon fault n this matter.

    ANSWERTO INTERROGATORY UMBER5:

    INTERROGATORY UMBER6:

    Please tate each act and circumstance ponwl^richou relied n, stating ourexperiencewithgreg aymond has aught us that he s nothing ut a liar and a user. mr. greg aymond

    has no sense of loyalty, onor or integrity. he is not a man of his word and cannot betrusted. mr. aymond's cam s to use people; hen when he has gotten what he;.wantscasts hem aside and criticizes hem. greg aymond s one big phony." nd n connectiontherewith, lease ist he name, address nd elephone umber of each person who ci-ntestifywith regard o veracity o same.

    ANSWERTO INTERROGATORY UMBER6:

    INTERROGATORY UMBER7: IPlease tate each act and circumstance ponwhichyou relied n when on April2,2OAg,you posted hat attorney Greg Aymond is unethical" nd n connection herewith leaselist he name, address nd elephone umber f each person who can estifywithregardto the veracity o same.

    ANSWERTO INTERROGATORY UMBER7:

    | ' .

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    state each act and circumstance pon ruhichou relied n, when you said Mr.desperation ndpressure" nd nconnectionherewith lease isttelephone umber f ear:h ersonwho can estify with egard o

    ymond had a "growingname, address ndveracity o same.

    INTERROGATORY UMBER9:

    Please state each act and circumstance pon which you reliedon, when you said, inrealitymr. aymond and his criminal riends imply want o be in control f the nformationso that hey can rick you nto hinking hat he criminals hat he supports re honest ndthe criminals n he rival rime gangs hat he dogs out are not."and n connection herewithplease ist he name, address nd elephone umber f each person who can estify withregard o the veracity o same.

    ANSWERTO INTERROGATORY UMBER9:

    INTERROGATORYUMBER O:

    Please tateeach act and circumstance ponwhich ou relied n, when you said wehave reg ymond itting n a shitter nAlexandria, ouisiana;hinking pways f how ogyp someone, hilst acking isdick." nd n connection herewith lease ist he name,address nd elephone umber f each person ho can estifywith egard o he veracityto same.

    ANSWERTO INTERROGATORY UMBER1O::

    INTERROGATORY UMBER11

    Please state whether or not Mr. Aymond orward,ed o youMr. Richard Barrett.

    ANSWERTO INTERROGATORY UMBER11:l

    some e-mails oth o a.nd rom

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    lease tate ach act and circumstance ponwlrich ou elied n or about May20 , 2009renyou posted on your blog hat Greg Aymond was a "mentally efective ocalattorney"d in-connectionherewith lease ist he name, address nd elephone umber feach

    n who can testifywith regard o the veracity o same.

    REQUEST OR ADMISSIONNUMBER1:

    Please dmitor deny hat your blog s published n Ward 11 of Rapides Parish.

    RESPONSE O REQUEST FOR ADMISSIONNUMBER1:

    REQUEST OR ADMISSIONNUMBER2:

    Please admit or deny that your blog s read n various parts of the State of Louisianaincluding lexandria, ineville nd other parts ollRapides Parish.

    RESPONSE O REQUEST FOR ADMISSION IIUMBER :

    Respectfu lysubm tted,

    P.O. Box12424

    Alexandria A 71 315-2424(318) 42-88seLa Bar RollNumber 2,366Attorney for GREGORYAYMOND

    {._:-.1

    . j , . - .r '! i l- -

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    N FORD ISER

    C:\Documents nd Settings\Becka\My Documents\Petition\pleading\lnterrogatories\Aymond.Gregory.wpd