Federal Lawsuit against Critchlow for Topix Defamation

8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation

1/55

In the Circuit Court of the 3rd Judicial Circuit

f

Missouri at Hillsboro Jefferson County Missouri

S M

FERRY,

RICHARD SIMPSON,

MICHELLE TYLER,

Plaintiffs,

VS

DI NNE CRITCHLOW,

In her individual capacity;

s ~ ~

3040 Strawberry Ridge

Arnold, MO 63010

JAM1E CRITCHLOW,

In his individual capacity;

Serve at:

3040 Strawberry Ridge

Arnold, MO 63010

ANGELA BURNS,

In her individual capacity;

Serve at:

1016 Castlemain Dr.

Imperial, MO 63052

D N

BAKER,


Serve at:

1016 Castlemain Dr.

Impetial, MO 63052

WlLLIA.\1 BRENGLE,


Se1ve at:

3408 Cascade Dr.

Arnold, MO 63010

Cause No. 14JE-CC00092

Jury Trial Demanded

EXHI IT

I

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 1 of 55 PageID #: 127


2/55

Defendants, )

)

P TITION FOR D M GES

VIOLATION

OF

CIVIL RIGHTS PURSUANT TO 42 U.S.C.

§1983 §1985

DEFAMATION

COME NOW

Plaintiffs,

San1

Ferry, Richard Simpson, and Michelle Tyler, by

and through counsel Daniel Hennan

o

Schwartz, H ennan Davidson, and for their

Petition, state

as

follows:

Parties and Venue

I. Venue is proper because all defendants reside in Jefferson County and

the

IP

Address identifiers on the website in question identify the defendants as having

posted within Arnold, Missouri, and the danlage took place primarily in Arnold,

Missouri.

2

The posts relevant to the claims for defamation were made within the (2)

two year Missomi statute oflimilalions for defamation suits.

3. The posts and actions relevant to the claims pursuant to§§

1983 1985

occurred within the (5) five year Missouri statute

o

limitations for civil rights suits.

4

At all times relevant herein, Plaintiff Sam Ferry (hereinafter Ferry )

was a resident

o

Arnold, Missouri.

5

At

all

times relevant herein, Plaintiff Rich Simpson (hereinafter

Simpson ) was a resident

o

Arnold, Missouri.

6 At all times relevant herein, Plaintiff Michelle Tyler (hereinafter

Tyler ) was a resident

o

Arnold, Missouri.

7

At all times relevant herein, the Fox C-6 School District ( Fox C-6 or

the district )

is

a school district, organized and operating under the laws

o

the state

o

Missouri and operating within Jefferson County, State

o

Missouri.

8 At

all times relevant herein, Defendant Dianne Critchlow was the

Superintendent

o

Fox C-6. She

is

named in her individual capacity in the claim for

2



3/55

violation of civil rights pursuant to §1983. She is named n her individual capacity in

the claim for conspiracy to interfere with civil 1ights pursuant to

§

1985. She is named

additionally

as

a defendant to the Missouri common law claim

of

defamation.

9

At all times relevant herein Defendant Jamie Critchlow was the Director

ofBridges at Fox C-6. He is named

in

his individual capacity in the claim for

violation

of

civil rights pursuant to §1983. He is named in his individual capacity in

the claim for conspiracy to interfere with civil rights pursuant to §1985. He is named

additionally as a defendant to the Missouri common law claim of defamation.

I 0. Jamie and Diam1e Critchlow married in 2012 and have lived together at

the same address since that time.

11 At all times relevant herein Defendant Dan Baker was an Assistant

Superintendent

of

Fox C-6. He is named in his individual capacity in the claim for

violation of civil rights pursuant to 1983. e is named in his individual capacity in

the claim for conspiracy to interfere with civil rights pursuant to §1985.

12 At

all

times relevant herein Defendant Angela Bums was an assistant

principal at Fox C-6. She is named in her individual capacity in the claim for

violation

of

civil rights pmsuant

to§

1983. She

is

named in her individual capacity in

the claim for conspiracy to interfere with civil rights pursuant to §1985.

13 Dan Baker and Angela Bums married during the course

of

the events

desctibed herein and have Jived together since that time.

14 At all times relevant herein Defendant Willian1 Brengle was a resident

ofArnold Missouri. I-- e retired as an administrator ofFox C-6 prior to the events

dcsctibed n the complaint. He is named in his individual capacity in the claim for

conspiracy to interfere with civil rights pursum1t

to§

1985. He

is

named additionally

as a defendant to the Missouri common law claim

of

defamation.

3



4/55

Facts Common to ll Counts

·

15

At all times relevant herein, Plaintiffs Ferry, Tyler, and Simpson

publicly commented and criticized the actions

o

the Fox C6 school board and

administration.

16

The subjects

o

plaintiffs complaints were a matter

o

public concern.

17. At all times relevant herein, defendants Dianne Critchlow, Jamie

Critchlow, Dan Baker, and Angela Burns were public officials.

18. At all times relevant herein, defendant William Brengle was acting in

concert with defendants Dianne Critchlow, Jamie Critchlow, Dan Baker, and Angela

Bmns for the purpose

o

retaliating against plaintiffs for plaintiffa public criticism

o

school board and administration actions and policies.

19

Among their criticisms were:

a

Nepotism;

b

The misuse

o

district

funds;

c

Unreasonably high salaries

o

district administrators;

d. The bullying

o

teachers and parents by administrators and other

district staff to punish and silence dissent.

20. Defendants Dianne Critchlow, Jamie Critchlow, Dan Baker and other

administrators were a central subject

o

Plaintiffs complaints.

21. Plaintiff Simpson had a long lasting dispute with the district due to their

seven-year refusal to recognize his daughter s disability claim for a

life

threatening

peanut allergy.

22. Defendant Dan Baker was the director

o

the disttict s 504-disability

program, and directly responsible for the district s lengthy fight against providing

disability benefits

to

Simpson· s daughter.

23. Plaintiffs Feny, Simpson, and Tyler made their criticisms at meetings

o

the Fox C-6 School board and in private conversations.



5/55


6/55


7/55

42. IP Address l 08.235.42.34 is registered to William Brengle for use at his

home address. ee

Ex.

C

43.

IP

address 150.199.176.125

is

registered to the Fox School District.

ee

Ex.H.

44. Defendants posted comments about plaintiffs in the following forums on

Topix.com

a Nepotism on Fox Schoolboru:d.

ee

Ex. D;

b. Fox High School Superintendent.

ee

Ex. D;

c \Vho s the biggest LOCAL LOONEY?

ee

Ex. D;

d

Petition for No Nepotism at foxc6.

ee

Ex.

D;

e Fox. ee Ex. D;

f Liars Cheaters and Thieves.

ee

Ex. D;

45. Do Kim, community manager

ofthc

website www.Topix.com, has

identified the IP address used to post each of the below complained ofposts that were

made on www.Topix.com.

ee

Ex. D

46. Defendants Jamie and Dianne Critchlow used their home IP address to

post comments

on

the website www.Topix.com.

ee

Ex. D, Pgs. 15-46, 50-52, 58-59. ·

47. Defendants Dianne Critchlow, Jamie Critchlow, Dan Baker, and Angela

Burns used the Fox School IP address 150.199.176.125 to post comments on the

website www.Topix.com.

ee

Ex. D, Pgs. 46-49, 52-57.

48. Defendant \Villirun Brengle used his home IP address to post comments

on the website www.Topix.com.

ee

Rx D, Pgs. 3-14.

49. Angela Bums and Dan Baker used their home IP address to post

comments on the website www.Topix.com.

ee

Ex.

D,

Pgs. 60-62.

50. Dianne and Jamie C1itchlow individually or jointly used IP address

08.231.66.58 to make posts on Topix using the following incomplete list

of

usernames:

a

RSJ;

7



8/55

b. Newbie;

f were SAM;

c

d. Cant help butt notice;

e.

TROOP

5

or6;

f

I found one;

g Idiots;

h

Go fox;

I. OMG;

j.

Ann·

k. Holy cow;

1. Windsor Alum;

m

RSJ watcher;

n. Troop 11;

0

Green eggs and ham;

p. Well said;

q.

TROOP

12;

r.

TROOP

15;

s oh no;

t TROOP

18;

u.

TROOP

Pi;

v. Quack;

w. Blah;

x

Milk sprayed from nose.

51. Angela

Bums and Dan Baker

individually

or

jointly

used IP address

68.186.163.99 to make posts on Topix using the following incomplete list

of

usernames:

a

Seriously;

b. I-Ialia.

8



9/55

52. Angela Bums and Dan Baker individually or jointly used the

same

unique internet browser on their home IP address o 68.186.163.99 and accessed the

internet

on

that same unique internet browser using various other IP addresses

provided by their cell phone service provider. ee Ex. D.

i]

6

53.

William Brengle used

IP

address 108.235.42.34 to make posts

on

Topix

using the following incomplete list ofusemames;

a.

sam i ain' s infected chode;

b. sam' s infected chode;

54.

Defendants individually or jointly used

IP

address

150. 199. 176.125 to

make posts

on

Topix using the following incomplete list ofuseman1es:

a. Jamie Matthew Critchlow;

b.

Bullwinkle;

c. Friend

o

Parents;

d. TROOP 5 or

6;

e.

baahaaa;

f. who cares.

55. Defondants individually or jointly made posts

on

Topix using the

following incomplete list ofusernames:

a.

stirring the pot;

b. finally the truth;

c. must be drugs.

56.

Di::fendants Dianne Critchlow and Jamie Critchlow, in concert with

defendants Dan Baker, Angela Burns, and William Brengle, jointly and severally

conspired to

accuse Ferry

o

Pedophilia with

the

purpose

o

dissuading Plaintiffs

from

criticizing

t e

Fox School District, its administrators,

ai1d the

Defendants, to wit:

a. On January 15 2013 at 9:44 P.M., Dianne and Jamie Critchlow used

the username Newbie'' to maliciously publish the following false

and

defamatory statement about Ferry

to

third parties

on

topix.com:

9



10/55

i) "Perhaps Sam, the uneducated man, feels he's got a real voice

on hear. It's amazing what recently FIRED petifile buffoons

have to share with us. Sam

..

erase your history, the police will

eventually come knocking for child porn.

People. Complaining in aisle 3

of

Walmart to each other isnt

the same as posting here. Perhaps the naysayers and

uneducated folk posting on here can for form an additional

union. The NEA and MSTA can join forces for barely eligible

teacher members called the NEATMS (never ever attending

things meaning s o/o*). What a flipping due paying bundle ofa

jokes Unions ..another hoax that the ever knowledgable tax

paying citizens of our idiotic society perpetually buy in to.

Humans

..

what a bunch ofslapdicks " See 'Nepotism on Fox

schoolboard' post 461; Ex. D. pg. 19.

A. The IP address used to make this post is registered to the

home

of

Jamie and Dianne Critchlow.

B. The rnntext of the forum makes clear that the 'Sam' in

the above post refers to Sam F

eny.

b.

On

February

2,

2013 at 9:37 P.M., Dianne and

Jan1ie

Critchlow used

the usemame "TROOP 5 or 6 to maliciously publish the following

false and defamatory statement about Feny to third parties on

topix.com:

i) "Dirty ole bastards who oscillate wiili kids?? DO THE

RESEARCH My spouse is in that building. Completely

obscene and unforgivable." ee

'Nepotism on Fox

'

schoolboard' post

718;

Ex. D. pg. 24.

10



11/55

A.

The

IP

address used to make this post

is

registered

to

the

home of Jamie and Dianne Critchlow.

c.

On February 6, 2013 at 10:32 P.M., Dianne and Jamie Critchlow

used the username "TROOP 5 or 6" to maliciously publish the

following false and defamatory statement about Plaintiffs Simpson

and

eny

to third parties on topix.com:

i)

"Yo Petifile Sam. That was addressed over a month ago. Get

off

the bong and up to real time.

Elliot

is

a known hamster packer. Just ask rich Simpson. They

have an undercover tube fest every third Wednesday of the

month. Rumor has it that rich is developing this in his mad

scientist lab; a clawless super hamster that wiggles

exponentially when deprived of air when it's skin

is

exposed to

methane. Richard Gere has nothing on these a$$ hammers

You ever wonder why he looks f-d silly? He still has a rodent

that traveled up his digestive system and lodged itself in his

brain. He can't let this tragedy

go

Apparently there

is

a merit

badge for biology when he displays this in his "pack". Lol.

Pardon the pun

You guys are straight up f-sticks. Kinda like middle school and

now

. i

laugh

at

you "

ee

'Nepotism on Fox schoolboard'

post 768; Ex. D. pg. 28.

A. The IP address used to make this post

is

registered

to

the

home

of


B.

The context

of

the forum makes clear that the 'Sam' in

the above post refers to Sam Feny.

11



12/55

d. On Febrnary 7, 2013 at 2:42 P.M., Dianne and Jamie Critchlow used

the username "Windsor alum" to maliciously publish the following

false and defamatory statement about Ferry to third parties on

topix.com:

i) "Not worried about Sam - disgruntled employee sounds like.

Troop is hilarious. You guys don't get it he making a mockery

of

all

of

you. The crazy on here is the ex Stephanie Thayer."

ee

'Nepotism

on

Fox schoolboard' post 791; Ex. D. pg. 30.


home

of


e.


used the usemame "Troop 5 or 6" to maliciously publish the

following false and defamatory statement about

cny

to third parties

on topix.com:

i "Yes I just came on this thread. Had other knowledgable

facts to spread prior

to

this conglomerate

of

brainiacs. So good

to see Melissa has finally shared her secret with

all

of

you.

Now hear this. I have a secret to share too. I have learned that

there

is an

underground group

of

people who like to impose

as

boyscout sponsors. They come

in

all shapes, sizes, mental

capacities and socioeconomic categories. They are known as,

in my opinion,

as

the "a$$ hammern". They are constantly

hammering each other with unintelligent, unproved

information so much so that they make an a$$

of

each other.

The AH society commonly gather in small despicable groups

to bitch and moan to one another andmcomplain about being

alive and have to deal with real life issues, etc. You get the

gist. Anyway, news has it that they will be gathering for a late

12



13/55

mardi gras celebration dressed as their favorite petifile/serial

killer to satiate their deep seeded hatred of being alive. They

will take a vote to see

if

they should

be

allowed to exist in this

normal society or move

to

the island of "irna inbred f up".

Rumor has it that this island is waiting there arrival.. News

channel

2

will be there for the after party report. More to

come "

ee

'Nepotism on Fox schoolboard' post 897; Ex. D.

pg. 34.

A The IP address used to make this post is registered

to

the

home

of


f

On

Februaiy 20, 2013 at 9:34 P.M., Diarme and Jamie Critchlow

used the usemame "Troop 11" to maliciously publish the following

false and defamatory statement about Plaintiffs to third parties on

topix.com:

i Tve consolidated my troops ... do the math

..

I 6+5 11 Both

troops have combined.(tired of hitting caps lock to address

these people). I will admit...idiocy outlasts intelligence

..

in

most cases. After heating about portions of last nights meeting.

This sight is like watching an old couple screw .. Kinda like a

car wreck Gotta look but nothing interesting. These odd jobs

on here flaming the fire all have serious mental Jllnesses.

Debatable? Nol at all. Justifiably hard core cases ofpyschot ic

crazies. The online patriots ofRich (f-ud crash victum)

Simpson, Dennis (testosterone deficient) Mueller, Michelle .

(ass and sanity envy loser) Tyler.

..

and Samuel L.(fired district

employee and bonified loser) Ferry all showed to support each

other The parents and students showed up in flocks to show

suppmi. t was rep01ied as awesome Positive remarks and

13



14/55


15/55

following false and defamatory statement about Ferry to third parties

on topix.com:

i)

Sam

I am. I am fired from fox c-6.

Yoda

lay lee hoo "

ee

'Nepot ism on Fox schoolboard' post 986; Ex. D. pg. 36.


home

of


1. On February 23, 2013 at 8:45 P.:\1., Dianne and Jamie Critchlow

used the username "TROOP 5 or 6" to maliciously publish the

following false and defamatory statement about

ferry

to third parties

on

topix.com:

i) "Last checked "live

it"

and others like her, are still

on

my list

of

people who can kiss my a$S. Sam, people don't get fired

because they did nothing wrong. You need to do some soul

searching and understand the real reasons why you think you

were given the shaft. I'm sure you did nothing wrong

for

them

to let you go They just the secret wheel oftennination and it

happened

tp

land on you. Lol It's probably this same idiotic

attitude and personality you display on here tltt helped them

decide you no longer need to be employed with the clistrict ... l'd

imagine." ee 'Nepotism on Fox schoolboard' post 992; Ex.

D pg. 37.

A. The IP address used to make this post is registered

to

the

home

of


B. The context

of


the above post refers to Sam Ferry.

J. On February 27, 2013 at 8:32 P.M., Dianne and Jamie Critchlow

used the usemame "TROOP 11" to maliciously publish the following

15



16/55

false and defamat01y statement about Fen-y

to

third parties on

topix.com:

i) Just to shed some light. It's tax payers delight website, based

on income right? Someone help me here

..

f so, Sam is

receiving no income ( because he was fired for being the same

$hit disturber on here that I'm sure he WAS at work) therefore

paying no taxes

...

thus, has no levity whatsoever. Sam, get a

job

in the district and then I'll listen. I love watching people

try to

make a negative change by whining a bitching. Never

works. Only makes things look worse by your posts. As for

Red, I'll oblige you and state that the odds are that you are a

disgruntled fat bottomed beeotch like a few others on here.

l m sure the sign in name of RED 5 came from the color and

square footage of chaffing you experience between the ham

hocks you refer to as your legs.

ee

'Nepotism

on

Fox

schoolboard' post 1073; Ex.

D.

pg. 38.

A The IP address used to make this post

is

registered to the

home

of


k.

On September 20, 2013

at

9:14 P.M., Dianne and Jamie Critchlow

used the username 'TROOP Pi· to maliciously publish the following

false and defamatory statement about Fen-y

to

third parties on

topix.com:

i) ''Loi.

I again realize

just

dropping in on what is, at best, a site

of

congregating bottom feeders and straight up $&@'/' -ups

who Jive and thrive on BS

(I

cordially apologize for stooping

to this level). Enjoy your world Sam and

5,

no one but you

guys and disgnmtled j ck offs live on here. You'll make

16



17/55

headlines. Kids talk ... eventually. ee 'Nepotism on Fox


D.

pg. 45.

A.

The IP address used

to

make this post is registered to the

home

of


l. On December 8, 2013 at 2:43 P.M., Dianne and Jamie Critchlow

used the usemame 'Quack' to maliciously publish the following false

and defamatory statement about Ferry to third parties on topix.com:

i) Sam and voice of a treachety, I mean a teacher. Sam ..you

are a FIRED district employee. Your whiney and bitchy voice

carries no weight... At all. The only buffoons on here are

as

lowly and d1;Jpressed as you are. Enjoy your company.

Teacher.. .. Go elsewhere. The salary you make is much better

than anywhere else you could go. Reach for

it.

Misery loves

company. I heard saint Louis public is hi1ing. You should go

there and make a difference. You'd be .in the perfect spot.

Crappy results with another crappy teacher. What a positive

contribution you would make. Lol. I don know why I even

look at this post. At hat a bunch

of

negative losers you people

are. Keep feeding off each other because this

is

NOT how the

real world functions. Sam stay away from boys ee

'Nepotism on Fox schoolboard' post 2609; Ex. D. pg. 45.

A. The IP address used to make Uris post is registered to the

home

of


57. Defendants Dianne Critchlow and Jamie Critchlow, in conce11 with

defendants Dan Baker, Angela Bums, and William Brengle, jointly and severally

conspired to accuse Tyler and Simpson of serious sexual misconduct with animals

wit11

the purpose

of

dissuading Plaintiffs from criticizing the Fox School District, its

administrators, and the Defendants, to wit:

17



18/55

a

On

February 6, 2013 at 10:32 P.M., Dianne and Janlie Critchlow

used the usemame "TROOP 5 or 6" to maliciously publish the

following false and defamatory statement about Plaintiffs Simpson

and eny to third parties on topix.com:

i)

"Yo Petifile Sam. That was addressed over a month ago. Get

off the bong and up to real time.

Elliot is a known hamster packer. Just ask 1ich Simpson. They

have an undercover tube fest every third Wednesday of the

month. Rumor has it that rich is developing this in his mad

scientist lab; a claw ess super hamster that wiggles

exponentially when deptived of air when it's skin is exposed to

methane. Richard Gere has nothing on these a$$ hammers

You ever wonder why he looks f-d silly? He still has a rodent

that traveled up his digestive system and lodged itself in his

brain. He can't let this tragedy go Apparently there is a merit

badge for biology when he displays this in

is

"pack". Loi.

Pardon the pun

You guys are straight up f-sticks. Kinda like middle school and

now ... i laugh at you "

ee

'Nepotism on Fox schoolboard'

post 768; Ex. D. pg. 28.

A The IP address used to make this post is registered

to

the


b On February 7, 2013 at 8:31 P.M., Dianne and Jamie Critchlow used

the usernmne "Troop 5 or 6" to maliciously publish the following

false and defamatory statement about Plaintiffs Tyler and Sin1pson to

third parties on topix.com:

18



19/55

i) Dr H, it's so refreshing to see one ofmy kind on here. Silly

aren't they?

Vly troop met this evening. We made signs ..hundreds of them.

We will post these sporadically around the district. Most them

will read some like, but not exactly the same as .... "Rich

Simpson and Michelle Tyler are copulating with livestock.

They must move from the district". Apparently it's quite

interesting from what many of the posters on here have

described to me. Rich is able to take the length

of

a miniature

pony and Michelle's can swallow a donkeys load. That's

disgusting But I have to admit .... ain't surprised." ee




c.

On March 15, 2011, Defendants individually or jointly used the

usemame "Finally the lrntl1" lo maliciously post the following false

and defamatory statements about Simpson to third parties on

topix.com:

i) '"Ohhh forgot to mention Another fact. "fox student comes

first" aka rich Simpson junior flies monthly to Mexico to

engage

in

violent anal sex with miniature horses. My ex best

friends second cousin from college (long story and kinda crazy

in

the l1ead) ran into him at a cantina. He was wasted and spout

off about Nina, the equestrian love of his life." ee 'Fox High

School Superintendent' post 820.

19



20/55

58.

Defendants jointly and severally conspired to make malicious, retaliatory

and harassing accusations and comments with the purpose o dissuading Plaintiffs

from criticizing the Fox School District, its administrators, and the Defendants,

to

wit:

a. On November 16, 2010

at

7:49 A.M., defendant Jamie Critchlow

used the username Jamie Matthew Critchlow to publish

the

following statement

on

Topix.com using

his

own name:

i

Public .. let me introduce myself. 1

am

Jamie Critchlow.

Principal of

the

Bridges program at Fox C-6. have been

made aware o this website and rumors as o late. am on here

to speak

to

you

as

a concerned parent. am trnly apathetic for

anyone who

frnds

comfort

in

these negative words. Dr Brown

and are great friends who have found solitude in each others

friendship through difficult times. The light in which both she

ai1d i have been shed

on

this website is at best ridiculous.

f

you have any questions you would like to ask please call

my

personal cell

at

... ee 'Nepotism on Fox schoolboard' post

127;

Ex.

D.

pg.

55.

A.

The lP address used to make this post is registered to the

Fox C-6 School District.

b. On November

16,

2010

at 8:

l 0 A.M., defendants individually or

jointly used the uscrnamc ''Bullwinkle to

publish

the

following

harassing and retaliato1y statement directed at Simpson on

Topix.com:

i The school board president is a female and has been president

since early last spring you dip stick. Again ..more lies to ham1

others.

Mr Critchlow, I will call you and we can start our own

20



21/55


22/55


23/55

g.

On January

15,

2013 at 2:23 P.M., defendants individually or jointly

used the usemame "Friend

o

Parents" to malicionsly publish the

following false and defamatory statement about plaintiffs to third

parties on topix.com:

i)

"Its such a shame that Rich Simpson Jr spends more time on

stirring up crap with the district than taking care o his very ill

mother. This is obviously an ill man himself with his priorities

clearly out o whack

I know for a fact that the Administration is NOT moving to the

service center and that my children have all the books they

need in school. Apparently some hefty disgruntled woman

was peddling this crap out front o Shnucks tllis weekend. Did

none o you read the letter put on the website this weekend?

Before any o you go out on a limb and attempt to make a

comment at the board meeting, be sure to know the facts

before you open your uneducated pie holes.''

ee

'Nepotism

on Fox schoolboard' post 448; Ex. D. pg. 47.


is

registered to the


h. On Januaty 15, 2013 at 9:30 P.M., Defendants Angela Burns and Dan

Baker, a matTied couple, used the username "Seriously" to

maliciously publish the following false and defamatory statement

about Simpson to third paiiies on topix.com:

i It

is

filllazing how people believe complete nnt jobs Can't

believe people would listen to that one crazy guy with the

weird eye. I mow him from Boy Scouts and he says some

23



24/55

really strange things that do not sound right. I am pretty sure

he has a closet where he hangs up newspaper clippings

of

board members and wears clown make up while cutting up

teddy bears. That guy

is

crazy "

ee

'Nepotism on Fox


A.

The

IP address used to make this post is registered to the

home

of

Defendants Angela Bums and

Dan

Baker.

B. References

to

the Boy Scouts and "weird eye" are clearly

intended to identify Simpson.

1.

On

January 24, 2013 at 4:57 P.M., Dianne and Jamie Critchlow

used

the username Ifl were SAM" to maliciously publish the following

false and defamato1y statement about

Feny

to third pat1ies on

top ix.com:

i " was told about this a f w days ago and took a look. I have

read what

all

have written and hands down Sam takes the

prize. Sam, please do

us

all a favor and explain the EXACT

reason why you were FIRED ?I.

The

very little cyher

credibility must feel that you have secured in your

complaining .... will vanish quicker than a piece

of

cake

around Ms Tylers ginormous a$$.

Your one sick m-fcr. If come near MY daughters you won't

walk away. Please explain this to

us

Sam.'' See 'Nepotism on

Fox schoolboard' post 610; Ex. D. pg. 21.


home

of


B.

The context of the fornm makes clear that the 'Sam' in

the above pos t refers to Sam Ferry.

24



25/55

J. On Janmuy 24, 2013 at 7:14 P.M., Dianne and Jamie Critchlow used

the username Cant help butt notice to post the following harassing

statement about Tyler to third parties on topix.com:

i I

was at that last board mtng as an innocent bystander hoping

to watch these fools make a mochery

of

themselves, and they

did. That lady who was

up

there looking like an idiot had the

largest hiney think I've ever seen.

think

just one cheek may

have weighed more than her dumba$$ husband who was there

to whine

as

well. couldn't stop looking at it...it was like

a

car

wreck happened

in

her pants or something. That thing made

the Hindenburg look like

a

gum ball. Its no wonder shes all

pizzed off. Just saying.

ee

'Nepot ism on Fox schoolboard'

post 614; Ex.

D.

pg. 21.

A The

IP

address used to make this post is registered to the

home

of

Defendants Dianne and Jamie Critchlow.

k.

On

January 24, 2013

at

7:20 P.M., Dianne and Jamie Critchlow used

the usemame

lf

I

were

SAM

to maliciously

p11blish

the following


topix.com:

i)

Sam,

We're all still waiting for you to tell us the trnth.

By

the way

my

name is Ralph Turner

Now spill the trwillful all

of

people tired

of

your lies and

obstinate BS or I will formally request your records through

the proper channels and hand this out at schnucks upon receipt

of

them. Tired

of

the fools on here

...

including

you. ee


25



26/55

A. The IP address used to make

1his

post is registered to the

home

of


B.

The context

of

the forum makes clear

thatthe

'Sam' in


l On January 24, 2013 at 7:43 P.M., Dianne and Jamie Critchlow used

the username 'TROOP 5 or 6 to maliciously publish the following

false and defamatory statement about Simpson to third parties on

topix.com:

i

''Rich, Just remember. Sticks and stones may hurt some bones

but words will never hurt anyone. Your a scout leader you

freak Go get examined for all our sakes. You neeeeeeeeed

help," ee Fox post

4;

Ex. D. pg. 59.

A.

The IP address used to make this post is registered

to

the

home

of

Jamie and Dianne C1itchlow.

m. On Janumy 25, 2013 at 11 :54 A.M., Defendants Dianne and Jamie

Critchlow used the username "Troop 5 or 6" to maliciously publish

the following false and defamat01y statement about Simpson

to

third

pai1ies on topix.com:

i ·'Old school got her very large feelings

hw1.

Its the truth. Its

also the tmth/fact that Rich Simpson Jr has been publicly

reprimanded from the regional director

of

the boyscouts for

using his connections within the r n k ~ to recruit and solicit

additional inbred people such as yourself to spread slanderous

rumors and lies. Thats a fact. He sent emails and letters to

anyone, including yourself, tlmt would listen to him. Now

folks, just look at him Listen to his incesent whining. fyou

had one bit of an IQ and continue to bich about the district,

26



27/55

you too are an idiot. Now f off and go make another sign .. ''

ee 'Nepotism on Fox schoolboard' post 627; Ex. D. pg. 48.



n.

On January 25, 2013 at 5:19 P.M., Dianne and Jamie Critchlow used

the username "TROOP 5 or 6 to maliciously publish the following

false and defamatory statement about Simpson to third parties on

topix.com:

i "Nothing like a dumb fat gossip to keep the onlookers

entertained. Let's do this. Answer me these few questions. 1.

Are you employed at all, and if so for more than 40 hours a

week? 2. Do you have kids that attend school in the district?

3.

Do

you eat when

you

are upset or angry ..preferably

chocolate or Simpsons juniors spunk? You people are irritated

because the above mentioned facts are true

I

get on here for

entertainment. I mow who this group of invalids

are

stoking

this site. You have nothing better to do other than enjoy each

others whiny, negative, miserable company. This is your only

outlet in life. t consumes you. It's your focus. What a sad

bunch oflosers you opponents of fox are. Truly lifeless

humans." ee 'Nepotism on Fox schoolboard' post 635; Ex.

D.

pg. 22.

A The IP address used to make this post is registered to the


o.

On January 25, 2013 at 5:58 P.M., Dianne and Jamie Critchlow used

the uscrnamc "I found one" to publish the following harassing

statement about Simpson and Tyler to third paities on topix.com:

27



28/55


29/55



r

On febrnaiy 2, 2013 at 9:10 P.M., Dianne and Jamie Critchlow used

the usemame Go fox to maliciously publish the following false and

defamat01y statement about

ferry to

third parties on topix.com:

i)

I

think all have their merits. Everyone judging should

carefully exercise their right to choose who is the most

mentally unstable. Keep

in

mind each

of

these candidates all

have issues that may be clinically diagnosed completely

different from one another. Should you know one

of

these

head cases, you can not vote for them. Yes I realize you may

have to endure being their neighbor, relative or better yet part

of their boy scout troop. Choose wisely because the winner

will eventually end up either in an asylum or shot stalking

someone in their home.

ee

'Who's the biggest LOCAL

LOONEY?' post l; Ex. D. pg. 59.

A.

The

IP


is

registered to the

home of Jrnnie and Dianne Critchlow.

s. On February

2,

2013 at 9:21 P.M., Dianne and Jamie Critchlow used

the usemame TROOP 5 or 6' ' to maliciously publish the following


topix.com:

i Sam ferry can tell you how to not keep a job. Just ask him the

trick to getting fired. Has nothing to do with performance.

What options arc left . Hmmmm. Dirty old ba$turd +being

around teenage girls getting fired.

Sam. You should be thankful for getting fired. It's really a

29



30/55

good thing. Had you kept on you probably would have been

brought up on charges. The ttuth shall set you free. Now go

pray to Zeus and hope he does condem you to the nether world

for eternity." ee 'Nepotism on Fox schoolboard' post 714;

Ex. D. pg. 24.

A. The

IP


home

of


t. On February

2,


the usemame "TROOP 5 or 6 to maliciously publish the following

false and defamatory statement about Tyler to third parties on

top ix.com:

i "News flash This jus t in ... It's been reported that Michelle

Ty er

just

unde1went surgery. Apparently her asstronomical

surgery was an amazing success. She is the first human to

successfully receive an a$$ tt·ar1splant from a cow. Reports

say she had conjenitive rump failure due

to

the large arnount of

blood it took to keep the large amount

of

blood flow to her

gigantic hemispheres. She is now recovering nicely in a

Mexico hospital where her new and slightly smaller bovine

a$$ will be ready for return to the states this weekend." ee

'Nepotism on fox schoolboard' post 715; Ex. D. pg. 24.

A The IP adclres:; usecl to make this post

is

registered to the

home

of


u.

On Febrnary

5,


the username "TROOP 5 or 6" to publish the following statement on

top ix.com:

i "Yes .. I did find that quote out

tl1ere

somewhere. Kudos to all

you highly educated sleuths who prowcl all over this site like a

30



31/55


32/55

blood it took to keep the large amount of blood flow to her

gigantic hemispheres. She is now recovering nicely in a

Mexico hospital where her new and slightly smaller bovine

a$$ will be ready for return to the states this weekend." ee



home of Jan1ie and Dianne Critchlow.

w.

On

February

5,


the usemame "TROOP 5 or

6

to publish the following false and

harassing statement about Tyler to third parties

on

topix.com:

i "Loi

Ifit

is, his ex has one gigantic a$$. I heard a long tin1c

ago that the ex is a mean dyke-ish woman as well. Maybe they

were separated at birth. Or maybe they eat the same diet and

use the same hair dresser. Hahahaaa. I love making fon of

idiots.

t

brings me joy. Till later, whiney topix losers ." ee


A. The

IP


home

of


x.

On

Febmary 6, 20 l3 at 8: 15 P.M., Dianne and Jamie Critchlow used

the usemame ·'Ann" to publish the statement on topix.com:

i

"Thats all you got Stephanie. Dwi. Talk about slander. Keep

calling Elliot. You

m·e

a scorned ex that has been called out.

Way to

go Jamie and Chris. Kiddos to two great men " ee



home

of


y. On February 6, 2013 at 9:08 P.M., Dianne and Jamie Critchlow used

the uscrnmnc "Troop 5 or 6" to maliciously publish the following

32



33/55

false and defamatory statement about Plaintiffs

to

third parties on

topix.com:

i

"Wow What happened? I heard there

are

soine crazy ex's on

here but this verifies some things. f his site is a venue for that

then guess it truly validates my affonnentioned comments.

This site festers with psychopathic and unruly idiots. If the ex

wife is on here solely to spread hatred and misery then I guess

Sam has

a

chance at finally getting a date. Sloppy seconds of

a

used mule? People ... I hate to tell you this, but

if

you study this

and relish

in

it then you would

be

known as what most

intelligent people would refer

to

as "LOSERS". Yes

. l

hate

to

share this with you but it's who you are. On another note, this

ex wife who seems to be so hateful obviously has a jealousy

issue. Rumor has it that she came in

a

close second to Michelle

Tyler in the fatest ass contest recently held in saint Louis at the

bull dyke festival."

ee

'Nepotism on Fox schoolboard' post

756; Ex. D. pg. 27.

A. The P address used to make this post is registered to the


z.

On Februa1y 6, 2013 at 10:08 P.M., Dianne and Jamie Critchlow

used the usemame "Holy cow" to maliciously publish the following

false and harassing statement about Simpson to third parties on

topix.com:

i

[think Elliot was there for all the wrong reasons. From what l

can gather she was only there for the SAFETY SUMMIT.

Hereyee Hereyee. It's not the superintendent's responsibility to

entertain a liberal negro dip- $hit disturber when the agenda

calls for an entiircly different matter. Whats amazing is that

33



34/55

Simpson junior shows up on tv. What an idiot. Docs this guy

have a job? I swear this country has fallen to $hit when a

mentally deranged fool gets

an

interview. Rich. Good

job

calling yourself out on being the whistle blower. Y oure no

more than a deranged douche bag exposing themselves in the

community by hiding behind boyscouts amongst other

community fellowships. I pity the idiots who listen to you.

Lost sheep t trnly proves there will always be special needs

classrooms in the public schools. Dip$hits .. Keep rproducing

t

only saves jobs. Buy

in

negative media lovers.

Ifit

makes

you happy . Enjoy going to work tomorrow

if

you truly are

qualified for a job .. or even have one." ee 'Nepotism on Fox


A.

The

IP

address used

to

make this post is registered to the

home

of


aa. On Febrnary 6, 2013 10:39 P.M., Diam1e and Jamie Critchlow used

the L1sername "TROOP 5 or 6" to maliciously publish the following

false and defamato1y statement about

Feny

to third parties on

topix.com:

i

"Let's just state one fact You are a fired employee Your

cmmnents are worthless Go get a job Sam. You need to stop,

really. I feel bad for you." ee 'Nepotism on l'ox schoolboard'

post 770; Ex. D. pg. 28.

A. The

IP

address used

to

make this post is registered

to

the


B. · The context of the forum makes clear that the

Sam

in


34



35/55


36/55

and other boyscouts dads lather up with baby oil and cock

choke each other until the loser gags and pukes. It's what I

heard. Not saying its a fact though.

I

don't need help,

I

need

scalps " See 'Nepotism on Fox schoolboard' post 782; Ex. D.

pg. 29.


to

the


dd.On February 7, 2013 at 2:58 P.M., Dianne and Jamie Critchlow used

the uscrnamc "TROOP 5 or 6

to

publish the following statement on

topix.com:

i

Now

Ryan don't be so concerned with me. It's merely things

I have heard. Kinda like all the idiots on here claiming they

actually know something about nepotism, the board, the

administration. Tools. The whole lot of you Now, I will

say this. From what I have heard there will be some sparks

flying ve1y soon for a few of you. Cue evil monster laugh ...

Moohahahahaa. Heheheoooooo rahahahaaaaa."

See



to

the


ee. On February 8, 2013 at 6:29 P.M., Dianne and Jamie Critchlow used

the username

'Troop

5 or 6" to maliciously publish the following

false and defamatory statement about Plaintiffs Tyler and Simpson to

third parties on top ix.com:

i No Time Out.. ..this site will work

just

fine. Now for this

evenings lesson. Of the many but same people who post on

here are none more instigating as concerned parent. Yes you've

guessed it ""concerned parent"" is a fat bottomed ex with

36



37/55

nothing but vengeance on her mind. According to my troop

reports

is

that this mom, Rich Simpson and Michelle Tyler

gather frequently to see who can

stuff

the most Twinkies up

one another's ass. Personal records include, but are not limited

a box a piece. It's also known that fat absorption can occur

rectally hence the exponentially huge hind quarters located on

each

of

these bull dyke women. Till later instigators BTW

Sanely Baker pays for male services since she can't find a man

that finds her f-able Mini dyke in training." ee 'Nepotism on

Fox



home

of


ff

On Febmary

8,

2013 at 9:45 P.M., Diam1e and Jamie Critchlow

used

the usemame "Troop 5 or 6" to maliciously publish the following

false and defamatmy statement about Tyler to third parties on

topix.com:

i I would like to continusouly share one

of

my children's

favorites stories when they were little ones. t goes a bit

something like this:Bitter dyke. Bitter dyke let me in Not by

tl1e hairs on my triple decker chin

Bitter dyke. Bitter dyke why so mad? l been all over topix and

I've been unclad

Bitter dyke. Bitter dyke whos to blame? All of the people with

a critchlow/ baker name

Bitter dyke. Bitter dyke what to do now? Hell

ifI

know, I'm a

psycho fat cow

Bitter dyke. Bitter dyke when will you stop? When I finally

eat so much that my ginormous ass pops.

37



38/55

There's more but tiny Tim

is

usually asleep been this line.

f

you want more you can find some

of

my finest work at

www .gofyourselflosers( dot)corn

I will be sure to share more with you as the days come and

go "

ee

'Nepotism on Fox schoolboard' post 829; Ex. D. pg.

31



gg.On Pebmary 8, 2013 at 10:04 P.M., Dianne and Jamie Critchlow

used the username "RSJ watcher" to maliciously publish the

following false and defanrntory statement about Simpson to third

parties on topix.com:

i

" find

it completely ironic that this boy ended up as part

of

Elliot's report. Rich, let's define nepotism. This goes way

back to your daddy aka. senior, who was an assistant

superintendent while your mother was a teacher and you and

your sister were on the payroll too. You were there working

with the company "minds eye". Your dad hired you and your

sister. Your company was terrible and you were fired. No

wonder you have problems with Fox You are a text book

hippocrit. How in the world can you live with yourself? I was

in

central office back in the 80's. You should be so ashamed of

yourself and the Benedict Arnold person you have become to

the district. I'm old now, but

if

weren't, I'd wash your mouth

out with soap for all the filth and lies you spread. Your parents

are great people. True to their profession and the people in it.

What happened to you?" ee 'Nepotism on Fox schoolboard'

post 831; Ex. D. pg. 32.

38



39/55


is

registered to the


hh.On Febrnary

12,

2013 at 7:51 P.M., Dianne and Jamie Critchlow

used the usemame Troop 5 or 6 to maliciously publish the

following false and defamatory statement about Tyler to third parties

on topix.com:

i You inbred, unknowingly, racist f-sticks have no idea what a

dream is. Your dreams beyond being

ad bag

within the

district may include:

your house has no wheels

that you stayed

in

high school and went to Jeffco

...

,and are

now qualified to actually work in the district...maybe

that you shouldnt

have

gone to da movies wit yo babies daddy

that you are constantly

in

denial of who you would be without

a site to be a loser on

that you wish grannys distillaty didn't catch the families best

trailer on fire

that a life without topix would focus you on doing something

you've been neglecting to do in your house . .like clean it

There are sting operations that many

of

you would fall into.

Beware of 90% coupons

off

at pizza and chineses buffets.

PS. I'm still amazed that Michelle Tyler's hind quarters aren't

a mutant tmaformation. ln a movie she could drop from 1000

feet and crnsh a small city with that thing. Impressive in a

genetic facet. You must admit.

ee

'Nepotism on Fox


39



40/55


home

of


11


used the username 'TROOP 5 or 6 to maliciously publish the

following false and defamatory statement about Tyler to third parties

on topix.com:

i

Tim, I will petition for you to insert your fist up your dogs

rectum before I would sign anything in opposition

of

our

district. Btw d· bag a petition requires signatures. Expose

yourself on the steps

of

a local business and see what

responses youll get. You have no balls, therefore you won't do

this. Know why? Because, unlike Michelle Tyler, who has

learned that she's a bonificd psycho in the eyes of thousands,

that stating the truth in your own minds eye, equals being an

uneducated and uniformed loser. Just stating facts by most

peoples standm·ds.,.

ee

'Petition for

No

Nepotism

at

foxc6'

post 3;

Ex. D.

pg. 59.


is

registered

to

the


JJ.

On Febrnaiy 27, 2013 at 11 :52 A.M., defendants jointly or

individually used the username baahaaa

to

publish the following

harassing and retaliatmy statement about Ferry

to

third parties

on

topix.com:

i Sam, you need help and a better hobby. ee 'l\epotism on

Fox schoolboard' post 1063; Ex.

D.

pg. 48.

A

The IP address used to make this post is registered to the


40



41/55


42/55

B. The context

of


the above

post

refers to

Sam

Feny.

mm.

On

March 2

2013

at

8:42

P.M., Dianne and Jamie Ctitchlow used

the username 'TROOP 11" to maliciously publish the following false

and defamatory statement about Plaintiffs

to

third parties on

topix.com:

i) Ahhh ms Tyler ....Bravo to 2

of

the 5 nototious $hit

disturbing nimrods on here. Only if Junior will confess will we

get the trifecta. What's sad is the sanctity that you find in one

another's negative agenda and each others opinion. What's

even sadder is that your multiple posts amongst different

names constitutes the voice

of

nothingness

.

.including

Sam

the

fired man. This site has spent

itself

past all possible

worthiness.

As

I mentioned before, I am an avid defender of

the district

(because

it's good) and have found the mentally

challenged on here ( who are evil,

but

rather not able to fully

comprehend real lifo agendas

and

reality) to

be

ratherly

bming

over

time. Michelle. I'll leave a donation for your next cut and

die if i see you. At least you can look presentable the next

time you try to hand out flyers and paint patheological psycho

signs ... \Vait...that was

nut

job mueller and Simpson at a

boyscouts meeting. HENCE

my

name. You people are

F

up " ee

'Nepotism

on Fox schoolboard' post 1122; Ex. D.

pg. 40.


home

of Jamie and Dianne Critchlow.

42



43/55


44/55

i "Ruth Anne [School Board presidentat time of post]

is

the

mother/ grandmother all of us never had. For anyone to

berate, belittle or demean anything she supports

is

a true attack

on human kind and the

district. She is

the

epitome of what's

ritght

in

the world, much less the district . For the people on

here trying to belittle the district, it's board

or it's

administration are what the troopsters would reter to

as

""a$$wipes""l. I hold no concern

as

to what the whiners

portray. The more Sam the ""fired man"" claims, the more the

truth

of

mankind

says. man

who chastises

his

former

employer

will

never

find

on again ...

Sam. You lost lost once in your annoying voice. You will

lose again.

go

back

to

the west coast where Arnold will

snuggle witb you" ee 'Nepotism on

Fox

scboolboard' post

1186;

Ex.

D.

pg.

42.

A.

The

IP


is

registered to the

home

of


qq.On March

6,

2013 at 9:21 P.M., Dianne and Jamie Critchlow used the

username 'TROOP

l 5

to maliciously publish the following false and

defamatory statement about Simpson to third parties on topix.com:

i "Simpson junior

is

a demented reject lamb that fondles lost

sheep such

as

Dennis mueller. ..times are tough for closet

homos." ee 'Nepotism on Fox schoolboard' post

1187;

Ex.

D.

pg.

42.


home of Jamie and Diam1e Critchlow.

44



45/55

rr.

On

March 6, 2013 at 9:46 P.M. , Dianne and Jamie Critchlow used

the usemame

'oh

no' to publish the following harassing statement

directed to Ferry and his family on topix.com:

i

Sam ... find a job. You are officially a website stalker. So pity

you in more ways than one. Your employed wife must be

sooooo embarrassed. Don't do that to her

her."

ee 'fox High

School Superintendent' post

1150;

Ex. D. pg. 51.

A



ss. On March

6,

2013

at

10:

10 P.M., Dianne and Jamie Ctitchlow used

the usemarne

'Oh

no' to maliciously publish the following false and

defaniatory statement about Simpson to third parties on topix.com:

i "Sam. You are bright beyond your years, but yet you are still

a

fired janitor. What do you want these people

to

believe?

Accordance? Mayhem? Unloylaty? No These are the

standards from which you erupt from Your followers (who

are are minimal in and ofthemeselves) are what makes the

district stronger. They have always been abou helping each

other. (which is why the district prevails).

You

are what the

majority call a nuisance. rat that needs tending. An online

nuisance who has an obvious axe to grind because you were

fired ,. It's you and your kind that only make the board scoff

at you for every unemployed you post you make You were an

employee. Now you've become a joke. I'm

sony

your only

endeavor has become this site. Im a lady but I've had enough

with you and your kind." ee 'Nepotism on Fox schoolboard'

post 1189; Ex. D. pg. 42.

45



46/55


47/55

Dear

quintet

of

opponents ... the threat

of

physical violence

isn't tolerated nor even funny. . The fact that you are now all

clearly visable and completely exposed does not favor you.

The employees

of

this district have

had

enough and will

faithfully defend their administration and board. (employed

and loyal). f you want to go redneck Hoosier on this ... all loyal

employees will gladly find a place and time. Trust me, there

are hundreds of us. Talk is cheap. As is your posts . ee


A.

The IP


home

of


vv.

On September 20, 2013 at 7 :58 P .M. , Dianne and Jamie Critchlow

used the username

TROOP

Pi' to publish the following harassing

statement directed to Ferry on topix.com:

i) [quoted text from post

by Sam Ferry removed

as

irrelevant]

This certifies that you are officially a certified slap dick.

Thanks for confirming. 100%

of our

founding fathers who

wrote the first amendment would have lynched you by now.

ee Fox High School Superintendent' post 1227; Ex. D. pg.

51.


borne of Jan1ie and Dianne Critchlow.

ww. On September 20, 2013 at 8:33 P.:1\1. Dianne and Jamie Critchlow

used the username

TROOP

Pi to maliciously publish the following

false and defamatory statement about

Feny

to third parties on

topix.com:

47



48/55

i) "Sam we all love you. Only because your special. Your

lucky it's 2013 ""dude"'"' ee 'Nepotism

on

Fox schoolboard'

post 2489; Ex. D. pg. 45.

A. The

IP


is

registered to the


xx On December

8

2013 at 2:58 P.M., Dianne and Jamie Critchlow

used the username 'Quack' to publish the following statement on

topix.com:

i) "[QUOTE who=""Addit""]No moving on or

getting over it

m1til

the old board has been replaced and

Administration makes better decisions. enjoy Sam's reposts;

am in the trenches and living it. T ove my job and the students

T

teach, but some things need to change and

it

needs to start at

the top. Keep up the good work Sam, and thanks for being at

the forefront for us. [/QUOTE]

Enjoy your paycheck. Loyalty

is

a characteristic that's rarely

known amongst people anymore. f you feel you're in a

position to complain. Take it to your principal rather than blast

those who have employed you. Times are tough ... money is

tight. We all know that. But to verbally slash the throat

of

your own employer is not ok. You need to check your mind set

addit. The 1st amendment only stretches

so

far. Keep that in

mind mole " ee 'Nepotism on Fox schoolboard' post 2610;

Ex. D pg.

45.

A.

The

IP


home

of


48



49/55

yy.On

Januaiy 28, 2014 at 6:21 P.M., Dianne and Jamie Critchlow used

the username

'Blah'

to maliciously publish the following false and

defamatory statement about Ferry to third parties

on

topix.com:

i) "Sam. Get a life.

Your

truly obsessed with things out

of

your

control. Even

as

a terminated fox employee. Go get a

job ee

'Fox

High School Superintendent'

post

1311; Ex. D. pg. 52.

A


home

of

Jamie

and

Dianne Critchlow.

zz.

On

January 28, 2014 at 7:02 P.M., Dianne and Jamie Critchlow used

the username

'Milk

sprayed from

nose'

to maliciously publish the

following false and defamatoty statement about Simpson to third

parties

on

topix.com:

i) [QUOTE who=""Ssdd""]Richard Simpson should run. Or how

about an upstanding community member. Do

we

have

any?[/QUOTE]

What? That guy is jacked.

I

wouldn't be surprised

if

he

eats

used

band aids. Way out there. f he if the rain

man

and

Hellen Keller reproduced this guy would

be

the result.

Special '' ee 'Nepotism

on Fox


D.

pg. 46.

A

The IP address used to

make

this post is registered to the

home

of


59.

The

damage suffered

by

plaintiffs due to the harassing and malicious

statements of defendants often caused plaintiffs to remain silent

or

soften their

criticism for long periods.

9



50/55


51/55


52/55


53/55

73. The maliciously defamatory statements made by Defendants Dianne and

Jamie Critchlow have damaged Ferry, Tyler, and Simpson in the following ways:

a

Humiliation;

b Damage to reputation;

c Exposure to public hatred, contempt, ridicule and shame;

d

Mental anguish;

e Loss of sleep;

f

Strained marital relations;

g eny

and Tyler suffered from unpredictable episodes

of

uncontrollable c1ying;

h. Tyler suffered from and was diagnosed with depression;

1

Tyler suffered from and was diagnosed with anxiety;

J

The

arLxiety

and depression suffered by Tyler was so severe that it

caused her to suffer chest pains;

k

Tyler experienced weight gain;

I Ferry s ex-daughter in law has restricted Ferry s ability to spend time

with his grandson because she wmries about Ferry being near his

grandson due to the malicious accusations written above;

m

eny is unable

to

appear

in

public without concern that those around

him have heard

ar1d

believe the accusations made by the Critchlows,

and have hanned his ability

to

interact nom1ally

witl1

other members

of the public regardless of whether they are actually aware of the

accusations made about him;

n. Falsely stating that Ferry s employment was terminated because of

inappropriate behavior towards underage girls and asse11ing insider

knowledge

of

the truth

of

these false statements.

53



54/55

74. Punitive damages are appropriate against both Jamie and Dianne

Critchlow because the defamatory statements were malicious and they intended to

cause

ham1

to Plaintiffs.

WHEREFORE

Plaintiffs pray for judgment against defendants for damages

for pain and suffering, psychological and emotional injury, humiliation, damage to

reputation, costs, and expenses; and for punitive damages to punish Defendants

outrageous conduct; and for such other and further relief

as

to this Court seems just

and proper.

Count ll

Tyler v. Dianne Critchlow and .Jamie Critchlow for damages for the Intentional

Infliction of Emotional Distress

COMES NO\V

Plaintiff Michelle Tyler and for her cause o action for

damages against Defendants Dianne Critchlow, Jamie Critchlow, states to the Court

as

follows:

75. The conduct o Dianne Critchlow and Jamie Critchlow was so extreme

in degree and outrageous in character that it

is

outside the bounds o civilized decency

and utterly intolerable in a civilized community.

76. The actions taken by defendants Dianne and Jamie Critchlow were taken

with the intent to cause extreme emotional distress to Tyler.

77. The conduct o Dianne and Jamie Crtichlow caused Tyler to experience

severe and medically diagnosed depression, anxiety, chest pains, and weight gain.

78. The conduct ofDialll1e and Jamie Critchlow caused Tyler to suffer the

following damage:

a

Tyler suffered from and was diagnosed with severe depression;

b. Tyler suffered from and was diagnosed with severe anxiety;

c

The anxiety and depression suffered by Tyler was so severe that it

caused her

lo

suffer chest pains;

54



55/55

Federal Lawsuit against Critchlow for Topix Defamation

Documents

Transcript of Federal Lawsuit against Critchlow for Topix Defamation