justice protection project v. george olivo, et al - complaint

8/11/2019 Justice Protection Project v. George Olivo, Et Al - Complaint

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COMPLAINT

JUSTICE PROTECTION PROJECT v. OLIVO, et al.

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Lenore L Albert, SBN 210876LAW OFFICES OF LENORE L. ALBERT7755 Center Avenue Suite #1100Huntington Beach, CA 92647Telephone (714_372-2264Facsimile (419) 831-3376

Attorney for Plaintiffs, Justice Protection Project, andLenore Albert d/b/a Law Offices of Lenore Albert

THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE

JUSTICE PROTECTION PROJECT, a

California corporation; and LENOREALBERT, as an individual and d/b/a LAWOFFICES OF LENORE ALBERT

Plaintiffs,

vs.

GEORGE OLIVO AKA RALPH OLIVO;MAEGAN NIKOLIC; PAM RAGLAND,

KAREN ROZIER; SHERYLLALEXANDER; XCENTRIC VENTURES,

LLC (aka RIP OFF REPORT); YELP, Inc.;and DOES 1 through 100; inclusive,

Defendants.

CASE NO.

Assigned For All Purposes to:

Hon.

Date Complaint Filed:Trial Date:

COMPLAINT

[JURY TRIAL DEMANDED]

Plaintiff, Justice Protection Project, and Lenore Albert d/b/a Law Offices of Lenore Albert

bring this action against defendants GEORGE OLIVO AKA RALPH OLIVO; MAEGAN

NIKOLIC; PAM RAGLAND, KAREN ROZIER; SHERYLL ALEXANDER; XCENTRIC

VENTURS; YELP; and DOES 1 through 100; inclusive, inclusive (“defendants”) and alleges the

following on information and belief.



COMPLAINT


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I. PARTIES

1. Plaintiff, JUSTICE PROTECTION PROJECT (hereinafter “Justice”), at all times mentioned

herein relevant to the cross-complaint, was a California corporation.

2.

Plaintiff, Lenore Albert, is a resident of Orange County, California and is also d/b/a LawOffices of Lenore Albert.

3. Defendant, George Olivo aka Ralph Olivo, at all times mentioned herein relevant was a

resident of Orange County, California.

4. Defendant, Maegan Nikolic, is a resident of the State of California.

5. Defendant, Pam Ragland, is a resident of the State of California.

6. Defendant, Karen Rozier, is a resident of the State of California.

7. Defendant, Sheryll Alexander, is a resident of the State of California.

8.

Defendant Xcentric Ventures, LLC is a Tempe, Arizona company that owns and operates the

website “Rip Off Report”, and regularly does business in the State of California.

9. Defendant Yelp, Inc. is a Delaware Corporation headquartered in San Francisco, California

and runs the Yelp website, which regularly does business in the State of California.

10. Plaintiff does not know the true names and capacities of the defendants DOES 1 through 100,

inclusive, and, as such, names said defendants by such fictitious names. Plaintiffs will amend

the complaint to state the true name and capacity of the DOE defendant(s) when such

information is ascertained.

11. Plaintiffs are informed and believe, and allege thereon, that each defendant is responsible in

some manner for the occurrences alleged in the cross-complaint, and that plaintiffs’ damages

were proximately caused by the defendants at all times mentioned in the cross-complaint.

12. Plaintiffs are further informed and believe, and allege thereon, that each defendant was the

agent, servant, representative, and/or employee of their co-defendants, and in doing the things

hereinafter alleged were acting in the scope of their authority as agents, servants,

representatives, family members and/or employees, and with the permission and consent of

their co-defendants.

13. Additionally, plaintiffs are informed and believe, and allege thereon, that each defendant

assisted, aided and abetted, adopted, ratified, approved, or condoned the actions of every other



COMPLAINT


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defendant and that each corporate defendant, if any, was acting as the alter ego of the other in

the acts alleged herein.

II. General Factual Allegations

14. Lenore Albert (hereinafter “Albert”) is an attorney at law, licensed to practice in California

and in various federal courts.

15. About July 5, 2014, Defendant George Olivo commandeered Albert’s vehicle, and in an angry

moment, caused her keys to disappear.

16. Defendant, George Olivo, was a former employee of Lenore Albert, and worked in her law

office until about July 11, 2014, when, as a result of his misconduct, in angrily acting out in a

physical rage and improper communications, he ceased employment. Olivo accused Albert of

missing a deadline on a case concerning a friend of his, whereas in fact she had not.

17.

On about July 11, 2014, Olivo, while yelling angrily, raised a heavy plaque/statue in a

threatening manner against Albert, in her presence. He further then communicated to other

employees (knowing the importance of Albert’s dog to her) he had kidnapped her dog, and

wrote her many obscene texts to her, and sent a message that sounded like clicks of a revolver

pistol, and implied he would run over either her or her dog, Marley, by using a threat of “skid

burn”. Thereafter, he commenced posting angry statements against Albert on Facebook on his

wall and on Albert’s wall, and calling mutual friends attempting to force them to say Albert

was a bad attorney.

18. On about July 14, 2014, Olivo posted a photo of a lion, and continued to bash Albert in his

comments and tell untruths about his friend’s legal matter.

19. Since then, Olivo, and his cohorts, have, acted in active participation with each other.

20. Plaintiff obtained a TRO but the slanderous and libelous accusations did not stop.

21. Plaintiff contacted Facebook and Rip Off Report and gave them a copy of the TRO but all of

the slanderous and libelous accusations were not taken down.

22. Yelp allowed a third party to viciously attack Plaintiff and her business and post a “crazy”

note next to her business which she could not take down that read as follows:



COMPLAINT


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26. Defendant Karen Rozier wrote:

27.

28. Karen Rozier posted this to many walls including on the Law Office page and the Justice

Protection Project page.

29. Pam Ragland wrote:



COMPLAINT


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30.



COMPLAINT


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31.

32. Maegan Nikolic wrote:



COMPLAINT


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33.



COMPLAINT


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34.



COMPLAINT


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35.

36.

George Olivo initiated this with a call out for “solidarity” and threatening people who would

not assist him in his revenge:



COMPLAINT


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37.

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39. Over 100 posts were made by these defendants, clearly showing harassment and yet neither

Yelp nor Rip Off Report would take them down in spite of a TRO.



COMPLAINT


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III. Causes of Action

FIRST CAUSE OF ACTION

DEFAMATION

(All Plaintiffs against All Defendants)

40. Plaintiffs incorporate in this claim all of the allegations above, in paragraphs 1 through 19,

inclusive, as though set forth in full herein.

41. On or about July 11, 2014 through August 7, 2014, defendant spoke the following words,

made the following statements and publication, and posted the following images of and

concerning the plaintiff as listed above.

42. Furthermore during this time period George Olivo said:

43.

That he was owed money and was not paid; that the law office was not filing papers in Sheri

Moody’s case in time; and that the law office was hurting homeowners.

44. He left several voicemails concerning plaintiff on another employee’s phone:

a. Voice-mail 11:41am 7/11/14 - Asking my employee to give him a call back and that he

is "kind of flipping the fucking fuck out" and that he has "shit to take care of."

b. Voice-mail 12:29pm 7/11/14 - Complete ager and yelling at my employee that I am so

high with the law and to fuck that, fuck that trucking shit, and for my employee to go get

a new fucking job, because "she fucked us"

c. Voice-mail 1:37pm 7/11/14 - He states that he does not mean to involve my employee

Bianca and have her get in the middle of this but he wants his "fucking check." He said

he will go to my house or to my office, and that he will go to get his check at the office

so that it is legitimate, and that I owe him a "mother fucking check", he mentions that I

owe him hours and that owes me motherfucking money and he wants I now, and then he

will give me back my dog.

d. Voice-mail 2:45pm 7/11/14 - Demanding angrily that he a wants his "fucking money

now."

e. Voice-mail 3:03pm 7/11/14 - In this message George has a sense of robotic repetition

when repeating that he won’t get his money and he doesn't need his money then he goes



COMPLAINT


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silent and there is a notice that sounds similar to an pistol with no rounds being shot six

times. Then he say's tell her (He was asking Bianca to tell me)

f. Voice-mail 3:13pm 7/11/14 - There is a bark of a dog and he says that he has the dog,

then he threatens that if I do not call him, skid-burns.45. Furthermore during this time period Karen Rozier said:

a. 7/12/14 Karen Rozier then joins George’s team and sent out a harassing post full of

lies and then called for a “letter writing campaign to the BAR.” “From what I can

gather, Law Offices of Lenore Albert tanked Sheri Moody’s case.”

b. 7/14/14 George Olivo Lion post accusing me of tanking the Aceves case, and soliciting

to help people file a Bar complaint.

c. 7/15/14 Karen post sitting there thinking of all I had done wrong.

d. 7/17/14 Karen posts her doing karate.

e. 7/18/14 Karen tries to join my While You Were Distracted Web page

f. 7/19/14 Karen comments and suggests that George Olivo remove his case to federal

court (the TRO hearing) “GIVEN THAT YOUR SECOND AMENDMENT RIGHTS

are at stake.”

g. 7/27/14 She said I am doing more to break up social movements and hurt homeowners

and that I perjured myself in the declaration to the TRO.

h. 7/27/14 “One day we will be able to kill all the lawyer, cops and judges..”

i. 7/27/14 stating that lawyers are dumb and went to poor schools that help homeowners

and charge twice as much as bank lawyers after speaking about the Aceves hearing

where the judge went off at the sanctions motion.

j. 7/28/14 “I am preaching nothing but Hate because that is all I have left.”

k. 7/28/14 “Perhaps I can teach a seminar on “Harnessing Hate to Accomplish Your

Goals.”

l. 7/28/14 ‘I HATE EVERYONE WHO HAS CAUSED ME HARM AND I WILL

CONTINUE TO PRAY FOR THEIR PROLONGED AND PAINFUL DEATH.”



COMPLAINT


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m. 7/29/14 “Yes, I am very angry… They had better kill me because this only ends

when both of us are cleared or everyone is dead. Judge RK was absolutely correct.

I will not calm down.”

n.

7/30 “They need to start going after lawyers. ..When you speak out against them,they take out a TRO against you, like L.A. did against George Olivo.”

o. 7/30 “She is a coward and I pray that all of her former clients have filed formal

BAR complaints against her. I also urge you all to form a class and sue her as a

class action. Otherwise, she is going to believe her prestigious award – the one you and

all helped her get – and use it to steal from and harm other homeowners.”

p. 7/31 she called the office and simultaneously posted “Do you know Lenore Albert..

fired several of her clients after she tanked their cases. Now she is posting ugly

things about me…” She posted this on several fb pages including my own, then I

blocked her.

q. 7/31 Karen Rozier posts an email she received from one of my clients on facebook,

destroying client/attorney confidentiality.

r. 7/31 I posted the video on my Law Office FB page after finding Karen wrote an ugly

review that I could not remove there. Karen then trolled that posting accusing me of

stealing from clients.

46. Then on August 1, 2014 Pam Ragland started a post that lasted through Saturday night where

100 people commented. The post include client Cindy Brown asserting that her case was tanked

by this office, too and she was also a victim. Pam Ragland falsely accused plaintiff of lying, and

that she was unstable. The posts go onto to incite others and that plaintiff is dishonest and really

working for the banks.

47. By August 2, 2014 Karen Rozier posted that plaintiff was a “crazy short female lawyer” and

then implied that she tried to tank her case and then thanks three of my clients “for coming

forward” as harmed clients of mine. Then in the comments she called plaintiff a “shill or a

drunk .”



COMPLAINT


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48. On August 3, 2014 Rozier made a “Do you Know Lenore Albert” post and posted it on multiple

business pages and on her page with tags to multiple people and then encouraged them to file

state Bar complaints, complaints to online agencies, and ratings.

49.

These posts reached literally thousands of people.50. The group of individual defendants then created a master review which said that plaintiff

steals from her clients and tanks their cases. It even implied plaintiff was a racist.

51. Although plaintiff sent the Rip Off Report a copy of the TRO, the Rip Off report ignored the

communication and left the posting up there.

52. The words and images were heard and seen by the Law Office employees, colleagues and

several other persons whose names are not known to plaintiff.

53. These words uttered were slanderous per se because they accused plaintiff of committing the

crime of being a thief.

54. This is also libelous on its face because it charges plaintiff with committing the crime of being

a theif.

55. This has a tendency to injure the plaintiff in his/her occupation because it impugnes plaintiff

as being unethical or immoral.

56. This is libelous on its face because it charges plaintiff with improper and immoral conduct.

57. This is libelous on its face because it charges plaintiff with dishonesty.

58.

This is libelous on its face because it subjects the plaintiff to contempt and ridicule.

59. The words uttered and words and images posted and published, were a false statement because

plaintiff is not intentionally tanking her clients cases, she was not late in filing Ms. Moody’s

complaint, her window was blown out, she is not stealing her client’s money, she is not

unstable or crazy.

60. At all times herein mentioned, plaintiff was, and now is, an attorney at law and resides in the

County of Orange, State of California.

61. Plaintiff has resided here for over a decade and at all times has enjoyed a good reputation both

generally and in his/her occupation.

62. The “reviews” and facebook postings are libelous on its face. It clearly exposes plaintiff to

hatred, contempt, ridicule, and obloquy for the reasons alleged above.



COMPLAINT


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63. As a proximate result of the above-described publications, plaintiff has suffered loss of his/her

reputation, shame, mortification, and hurt feelings all to her general damage.

64. As a further proximate result of the above-described publication, plaintiff has suffered the

following special damages: loss of business, loss of billable hours trying defend herself and to

contain the deliberate campaign to smear plaintiff ’s business and shut it down, and to mitigate

damages all to her injury.

65. Plaintiff does not at this time know the exact extent of pecuniary loss resulting from the

foregoing, but is informed and believes, and thereon alleges, that the loss is a continuing one,

to her injury according to proof.

66. The above-described publications, statements, and images, were made, posted, uttered,and

published by the defendant(s) with malice and/or oppression and/or fraud in that it was started

as a deliberate campaign invited by defendant George Olivo, and thus plaintiff seeks an award

of punitive damages.

The above-described publications were not privileged because defendant published it/them

with personal animosity, hatred, and ill will toward plaintiff and with either the knowledge

that it was false or without any reasonable grounds for believing that it was true in that George

Olivo knew the Sheri Moody papers were filed on July 10, 2014; Karen Rozier knew that

plaintiff did not steal her work product; Pam Ragland and Maegan Nikolic knew that plaintiff

was honest and not a thief.

67. At all times herein mentioned, the defendant corporation Yelp, Inc. and Xcentric Ventures,

LLC was, and now is, doing business as an internet service provider and network and was and

now is providing those services and broadcasting in the County of Orange, State of

California. The publications it makes are seen by a great number of persons and citizens of the

area in which it is broadcast.

68. The publications were read, heard, and/or seen by those accessing sites concerning that topic

throughout the State of California.

69.

Defendant(s) were negligent in so publishing. With ordinary and reasonable care defendant(s)

would have realized or could have discovered that the material and photos were obviously

false and grossly slanderous as it applied to this plaintiff.

70. Furthermore, defendant(s) posted the information either knowing that it was false as it applied

to plaintiff or with reckless disregard for whether or not it was true.



COMPLAINT


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71. After the post was made, plaintiff served on defendant broadcaster a demand for correction or

retraction as required by Section 48a of the Civil Code, or due to the nature of the website, not

such demand was required.

72. Up to and including the date of the filing of this complaint, defendant(s) have failed and

refused, and still fail and refuse, to broadcast a correction or retraction as required by law.

73. As a direct and proximate result plaintiff has been specially and generally damaged as alleged

above.

74. Plaintiff is also entitled to punitive damages.

SECOND CAUSE OF ACTION

INTERFERENCE WITH ECONOMIC ADVANTAGE


75.

Plaintiffs incorporate in this claim paragraphs 1 through 70 as though set forth in full herein.

76. Plaintiff had an economic relationship with various groups and individuals pertaining to

Plaintiff’s legal representation of clients in wrongful foreclosure litigation, and other civil

litigation matters, which was economically advantageous to Plaintiff.

77. Defendants intentionally interfered with this economic relationship contacting existing clients

and prospective clients and individuals, by making utterances, statements, postings, and publications

to them or which in all likelihood they knew would reach them, for the purpose of disrupting the

relationship or prospective relationship.

78. Defendants’ wrongful conduct was a substantial factor in proximately causing damages and

loss to Plaintiff.

79. Plaintiff was proximately damaged by the loss of the existing clients, according to proof, the

loss of the prospective clients, according to proof, the loss of her time in having to defend

herself and mitigate damages, according to proof.

THIRD CAUSE OF ACTION

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS


https://www.lexis.com/research/buttonTFLink?_m=fb660812b8f984589e2347e489c80322&_xfercite=%3ccite%20cc%3d%22USA%22%3e%3c%21%5bCDATA%5b30-340%20California%20Forms%20of%20Pleading%20and%20Practice--Annotated%20%a7%20340.244%5d%5d%3e%3c%2fcite%3e&_butType=4&_butStat=0&_butNum=8&_butInline=1&_butinfo=CAL.%20CIV.%20CODE%2048A&_fmtstr=FULL&docnum=1&_startdoc=1&wchp=dGLzVzt-zSkAz&_md5=8c4fd56dc0b96f8bd9b0a3660cdc3c63

https://www.lexis.com/research/buttonTFLink?_m=fb660812b8f984589e2347e489c80322&_xfercite=%3ccite%20cc%3d%22USA%22%3e%3c%21%5bCDATA%5b30-340%20California%20Forms%20of%20Pleading%20and%20Practice--Annotated%20%a7%20340.244%5d%5d%3e%3c%2fcite%3e&_butType=4&_butStat=0&_butNum=8&_butInline=1&_butinfo=CAL.%20CIV.%20CODE%2048A&_fmtstr=FULL&docnum=1&_startdoc=1&wchp=dGLzVzt-zSkAz&_md5=8c4fd56dc0b96f8bd9b0a3660cdc3c63



COMPLAINT


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80. Plaintiffs incorporate in this claim all of the allegations in paragraphs 1 through 75 above as

though set forth in full herein.

81. The Defendant engaged in extreme and outrageous conduct with the intent to cause, or with

reckless disregard for the probability of causing, emotional distress by making all of these

scurrilous accusations to other colleagues, clients and friends and to the public at large.

82. Defendants knew that Sheri Moody’s papers were filed on July 10, 2014 and that George Olivo

was not having his pay withheld from him. Despite knowing Plaintiffs set out on a smear

campaign to cover up Olivo’s rate and physical threats he made on July 11, 2014.

83. This campaign from threatening to kidnap plaintiff ’s dog, skidburn, and gun shots to the

smear campaign of plaintiff ’s profession became so stressful Plaintiff suffered severe

emotional distress.

84.

As a direct and proximate consequence of Defendants’ actions and/or failure to act, the

Plaintiffs suffered extreme or severe emotional distress, including but not limited to, headaches,

loss of sleep, anxiety, depression, stomach aches, worry.

85. The defendant’s extreme and outrageous conduct what the actual and proximate cause of the

plaintiffs’ extreme or severe emotional distress in that Defendants’ conduct was so extreme that

it exceeded all bounds of decency in a civilized community.

86. As a proximate result, defendants conduct was malicious, reckless, willful, and despicable, of

depraved heart warranting punitive damages.

87. Defendants’ acts are malicious, oppressive, and fraudulent in that Defendants have acted with

conscious disregard of the rights and welfare of the Plaintiffs for their own personal motives and

corporate greed.

88. Defendants conduct was malicious, fraudulent, despicable, Plaintiff is therefore entitled to

punitive damages.

89. As a proximate result of defendants’ conduct, plaintiffs have been financially injured in an

amount to be proven at trial, including attorney fees and his reputation has been damaged.

90.

The aforementioned conduct of defendant(s) was an intentional misrepresentation, deceit, or

concealment of a material fact known to the defendant(s) with the intention on the part of the

defendant(s) of thereby depriving plaintiff of property or legal rights or otherwise causing injury,

and was despicable conduct that subjected plaintiff to a cruel and unjust hardship in conscious

disregard of plaintiff’s rights, so as to justify an award of exemplary and punitive damages.



COMPLAINT


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a. Wherefore plaintiff demands judgment against defendants as set forth below.

FOURTH CAUSE OF ACTION

VIOLATION OF 18 USC §1030


91. Plaintiffs incorporate in this claim all of the allegations in paragraphs 1 through 87 above as

though set forth in full herein.

92. Plain is informed and believes and alleges thereon that on or about, Defendants Olivo, Rozier,

Ragland, Nikolic, and Alexander gained unauthorized access to Plaintiff’s facebook postings

that were set to private for friends only.

93.

Defendants were not friends with plaintiff on facebook at the time of access which occurred

from July 11, 2014 to present.

94. Plaintiff did not authorize defendants access to her Facebook wall.

95. In obtaining information from and access to plaintiff’s wall, Olivo and said defendants engaged

in unauthorized access to a computer system or access to plaintiff ’s computer system, by use of

their computer.

96. As a result, said defendants obtained information from a protected computer involving interstate

commerce in violation of 18 USC §1030.

97. By so intentionally plaintiff’s wall without plaintiff ’s authorization or permission or exceeding

authorized access, said defendants obtained information from a protected computer involving

interstate communications.

98. As a result of said defendant’s conduct, as herein alleged, they interfered with plaintiff ’s

prospective economic advantage, possible profits, and required plaintiff to expend time and

energy, to her damage, as a result of said defendant’s acts, in a sum according to proof, and as

may be determined by a jury.

99.

As a further result of defendant’s conduct, plaintiff has been injured in her health in a sum to be

determined by a jury.

100. Said defendant’s conduct was wanton, willful, malicious, oppressive and/or fraudulent

justifying punitive and exemplary damages in a sum to be determined by a jury.



COMPLAINT


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PRAYER

WHEREFORE, Plaintiffs pray for judgment against defendants, and each of them, as

follows:

A. First Cause of Action

1. General Damages

2. Special Damages

3. Injunctive Relief

4. Attorney Fees

5. Costs

6. Punitive Damages

7. Such other and further relief as this Court finds necessary and proper.

B.

Second Cause of Action

1.

General Damages

2. Special Damages

3. Injunctive relief

4. Attorney Fees

5. Costs

6. Interest

7. Specific performance


C. Third Cause of Action

1. General Damages

2. Special Damages


4. Attorney Fees

5. Costs

6.

Punitive Damages


D. Fourth Cause of Action

1. General Damages

2. Special Damages



COMPLAINT


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4. Attorney Fees

5. Costs


Dated: August 8, 2014 Respectfully Submitted,

LAW OFFICES OF LENORE ALBERT

/s/ Lenore Albert___________________________

LENORE L. ALBERT, ESQ.



COMPLAINT

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DEMAND FOR JURY TRIAL

Plaintiffs hereby demand a jury trial.

Dated: August 8, 2014 Respectfully Submitted,

LAW OFFICES OF LENORE ALBERT

/s/ Lenore Albert___________________________LENORE L. ALBERT, ESQ.

justice protection project v. george olivo, et al - complaint

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