lawsuit: michael g. lenett vs. virginia r. ramsey, et al (complaint)

8/3/2019 LAWSUIT: Michael G. Lenett vs. Virginia R. Ramsey, et al (Complaint)

1/14


2/14

r:::J'N0 .....0ICLu...l(/)a("'..j

. . . IN THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY, MARYLAND

M ICHA EL G . LEN ETTl350 7 R ippling B roo k D riv eS ilver Sp ring, MD 2 090 6

Plaintiff,v .VIRGINIA R. RAMSEY20 1 N orw ood R oadA nnapolis, MD 21 40 1and

JOHN DOE#lAddress UnknownandJOHN DOE #2Address Unknownand

JOHN DOE #3Address UnknownandJOHN DOE #4Address UnknownandJOHN DOE #5Address Unknown

Defendants.

Case No.: a - I I - f L ; ~o1r

1


3/14

:

., COMPLAINT

N COMES NOW, the Plaintiff, Michael G. Lenett, by counsel, and sues the Defendants,Q . Virginia Ramsey and John Does #1 through #5, and for cause states as follows:...0Ic,LI.JV?

Venue and Jurisdiction~ 1. Pursuant to Md. Code, 6-201 of the Courts and Judicial Proceeding Article ("C.J.P."),venue in this Court is proper.

2. This Court has personal jurisdiction over the Defendants pursuant to C.J.P. 6-103.Parties

3. Plaintiff Michael G. Lenett is an adult citizen of the State of Maryland.

4. Defendant Virginia R. Ramsey is an adult citizen of the State of Maryland.5. Defendant Does #1 through #5 are persons who are believed to have conspired with

Defendant Ramsey to further distribute and republish, and did further distribute and republish,the false and defamatory statements alleged herein to members of the public, and upon discoverywill be added as named Defendants for the causes of action alleged herein.

Facts Common to All Counts6. Plaintiff Lenett served in the Maryland General Assembly as a Senator and represented

District 19 in Montgomery County from January 2007 through December 2010.7. "WhenPlaintiff Lenett took office in 2007, he hired Defendant Ramsey as a legislative

aide. Defendant Ramsey had worked for Plaintiff Lenett's predecessor, and he decided tocontinue her employment to offer continuity in the transition.

8. In 2009, Plaintiff Lenett terminated Defendant Ramsey's employment as a result of herpoor work performance. Plaintiff Lenett gave Defendant Ramsey inexcess of 30 days to findnew work.

2


4/14

. . 9. Upon having her employment terminated, Defendant Ramsey stated that she would not

permit Plaintiff Lenett to "fire" her. Defendant Ramsey threatened to "get revenge" againstPlaintiff Lenett and to "ruin" him. She added that there would be "nothing left" of PlaintiffLenett when she was done. She also added that she had the ability to "control" Plaintiff Lenett'spredecessor due to a certain compromising matter she knew about him (and which she had toldPlaintiff Lenett on a previous occasion) and that she would get him to help her ruin PlaintiffLenett.

10. After she received notice of her termination, Defendant Ramsey went to several senateoffices under the pretext of distributing her resume, and made false and derogatory statementsabout Plaintiff Lenett. Defendant Ramsey also refused to perform her job duties prior to hertermination date.

11. In light of her actions and threats, and after consulting the Attorney Generalis Office andthe General Assembly's Human Resources Office, Plaintiff Lenett terminated DefendantRamsey's employment immediately. The Human Resources Office arranged for her keys to beconfiscated, her access to the Senate Office building to be revoked, and the computer accesscodes in Plaintiff Lenett's Senate Office to be changed.

12. Defendant Ramsey engaged in a course of conduct designed to carry out the revenge shehad threatened against Plaintiff Lenett. Among other things, she launched an anonymous smearcampaign against Plaintiff Lenett. Defendant Ramsey sent blast emails to thousands of PlaintiffLenett's constituents asserting false, misleading, and defamatory statements about PlaintiffLenett. Defendant Ramsey also caused others to further distribute and republish such statementsto Plaintiff Lenett's constituents.

3


5/14

13. The emails were sent from one or more email addresses, including

"[email protected]," and were intentionally designed to give the false impressionthat they were news reports originating from a news reporter called "The District 19 Reporter."Defendant Ramsey used the official symbols of the State of Maryland and included a news-typebyline stating: "Real News and Real Facts."

14. Defendant Ramsey also created a website dedicated to smearing Plaintiff Lenett. Thiswebsite's address was www.DistrictI9Reporter.com and may at certain times have had a similaraddress. Defendant Ramsey published her smear blast emails about Plaintiff Lenett on thiswebsite.

15. Defendant Ramsey has admitted that she was the "The District 19 Reporter."16. As recently as September 7, 2010, Defendant Ramsey sent emails with false and

defamatory statements, which included links to her smear website against Plaintiff Lenett.17. In the emails and on the website, Defendant Ramsey made the following false and

defamatory statements, among others, about Plaintiff Lenett:a. PlaintiffLenett "denie[d] payment" to an unnamed fired legislative aide;b. PlaintiffLenett "misuse[d] scholarship funds" and "bypassed [his] scholarship

committee and awarded State funds for needy students to the child of a wealthy neighbor";c. Plaintiff Lenett "violat[ed] ethics and elections rules";d. Plaintiff Lenett "bought" union and teacher endorsements with contributions;e. Plaintiff Lenett "excluded [his] wife from home ownership" and that his wife was

pregnant out of wedlock;f. PlaintiffLenett sent out an "illegal mailer" "in violation of at least 4 State Board

of Elections laws";

4
http://www.districti9reporter.com/http://www.districti9reporter.com/


6/14

.,g. "[T]o gain favor with a Proctor & Gamble lobbyist," Plaintiff Lenett "knowingly

and deliberately undermine [d] the work of [his] senate mentor" and "complied" with thelobbyist's request to "help Proctor & Gamble" by sponsoring "legislation that let the companyoff the hook" from an environmental law, and that the Senate President "reward [ed] [PlaintiffLenett] for helping the lobbyist";

h. Plaintiff Lenett was "hiding [his] finances" from the public and the State Board ofElections;

1. Plaintiff Lenett "lied" to his committee Chairwoman and that she "rebuked [him]for lying" to her;

j. Plaintiff Lenett was absent for the vote on a bill of particular importance to theJewish community, causing the bill to fail by one vote;

k. Plaintiff Lenett "did what [he] could to kill [the other District 19 Delegates'] billsfor the sole purpose of preventing a potential rival from achieving success";

L PlaintiffLenett enacted a bill to exclude certain Delegates from serving on a statecommission;

m. The Washington Post had written a story saying that Plaintiff Lenett "was sopower-grabbing, dismissive and abrasive that none of the other senators liked" him;

n. The Gazette had said that Plaintiff Lenett was "maniacal, untrustworthy and hadcolleague problems";

o. Plaintiff Lenett was "disliked by most of the senators";p. Plaintiff Lenett did not get the support of "any of the senators [he] worked most

closely with for four years on the Education, Health &Environmental Affairs Committee";

5


7/14

- . .q. Plaintiff Lenett "spent more of [his] own money on [his] campaign than anymember of the Legislature has spent in the last decade";

r. PlaintiffLenett's legislation to require fire-safe cigarettes in Maryland failed;s.The leaders of the environmental community had announced that they were

"disappointed with [PlaintiffLenett's] lack of follow-through";18. Defendant Ramsey made these false and defamatory statements with actual malice and

the intent and purpose of exacting revenge and retribution against Plaintiff Lenett for terminatingher employment.

Count IDefamation

(Defendants Ramsey and Does #1 through #5)19. Plaintiff hereby adopts and incorporates by reference the allegations contained inall of

the paragraphs of this Complaint as though set forth fully herein.20. The above quoted statements were defamatory and intended and tended to injure Plaintiff

inhis reputation, character, and profession. These statements tended to cast aspersions againstPlaintiffLenett and impugn Plaintiff Lenett as dishonest, a thief, corrupt, and a criminal.

21. Defendant Ramsey knowingly made the false and defamatory statements.22. Defendant Ramsey published these statements through blast and other emails sent to

Plaintiff Lenett's constituents and through a website to the general public as well as PlaintiffLenett's constituents, the recipients of which reasonably understood the publication to bedefamatory .

23. Reasonable recipients of these statements would and did understand them to be assertingstatements of verifiable fact. In fact, Defendant Ramsey claimed that her "facts" could beobjectively verified and represented them to be "real news" and "real facts."

6


8/14

24. Defendant Ramsey's statements accused Plaintiff Lenett of criminal conduct and other

conduct tending to injure him in respect to his office and profession, thereby constitutingdefamation per se.

25. Defendant Ramsey acted with the knowledge that these statements were false and withthe intent to cause emotional harm to Plaintiff Lenett and to harm Plaintiff Lenett's personal and .professional reputation and character and his profession when publishing these false anddefamatory statements about Plaintiff Lenett.

26. In the alternative, Defendant Ramsey made these statements with a reckless disregard forthe truth or falsity of these statements and with the intent to cause emotional harm to PlaintiffLenett and to harm Plaintiff Lenett's personal and professional reputation and character and hisprofession when publishing these false and defamatory statements about Plaintiff Lenett.

27. The character and reputation of Plaintiff Lenett were harmed as a result of the false ormisleading, and defamatory statements published by Defendant Ramsey. Moreover, PlaintiffLenett's standing and reputation in the community were impaired, and he suffered mentalanguish and personal humiliation.

WHEREFORE, Plaintiff Lenett demands Two Hundred Thousand Dollars ($200,000.00)in compensatory damages and Eight Hundred Thousand Dollars ($800,000.00) in punitivedamages, plus attorneys' fees, interest, and costs, in addition to appropriate injunctive anddeclaratory relief.

7


9/14

Count IIFalse Light(Defendants Ramsey and Does #1 through #5)

28. Plaintiff hereby adopts and incorporates by reference the allegations contained in all ofthe paragraphs of this Complaint as though set forth fully herein.

29. Defendant Ramsey improperly publicized facts about Plaintiff Lenett, which placedPlaintiff Lenett in a false light by attributing to him conduct and characteristics that were false.

30. Defendant Ramsey knew that the facts she publicized about the Plaintiff were false or shemade the assertions with a reckless disregard for the truth or falsity of those facts.

31. The publication of these facts was highly offensive to any reasonable person.32. Plaintiff Lenett suffered damages as a result of Defendant Ramsey's tortious conduct.

WHEREFORE, Plaintiff Lenett demands Two Hundred Thousand Dollars ($200,000.00)in compensatory damages and Eight Hundred Thousand Dollars ($800,000.00) inpunitivedamages, plus attorneys' fees, interest, and costs, in addition to appropriate injunctive anddeclaratory relief.

Jury DemandPlaintiff demands a jury trial as to all claims so triable.

Respectfully submitted,JOSEPH, GREENWALD &LAAKE, P.A.

Matthew M. Bryant6404 Ivy Lane, Suite 400Greenbelt, Maryland 20770(301) 220-2200Counsel for Plaintiff

8


10/14


11/14

CIRCUIT COURT FOR BALTIMORE COUNTY

o Expedited(Trial Date-90 days)o Standard(Trial Date-240 days)o Extended Standard(Trial Date-345 days)o Complex(Trial Date-450 days)

Attachment Before Judgment, Declaratory Judgment (Simple), Administrative Appeals, DistrictCourt Appeals and Jury Trial Prayers, Guardianship, Injunction, Mandamus.Condemnation, Confessed Judgments (Vacated), Contract, Employment Related Cases, Fraud andMisrepresentation, International Tort, Motor Tort, Other Personal Injury, Workers' CompensationCases.Asbestos, Lender Liability, Professional Malpractice, Serious Motor Tort or Personal Injury Cases(medical expenses and wage loss of $100,000, expert and out-of-state witnesses (parties), and trialof five or more days), State Insolvency.Class Actions, Designated Toxic Tort, Major Construction Contracts, Major Product Liabilities,Other Complex Cases.

CCIDCM 002 (Rev. 2/2010) Page3 on


12/14

- LINEPlease issue a summons to the above-named Defendants and return to counsel for

Plaintiff for service by private process server.

Respectfully submitted,JOSEPH, GREENWALD &LAAKE, P.A.t v < : /t/ _____ -JITimothy F. MaloneyMatthew M. Bryant6404 Ivy Lane, Suite 400Greenbelt, Maryland 20770(301) 220-2200Counsel for Plaintiff

10


13/14

IN THE CIRCUIT COURT FOR ANNE ARUNDEL COUNTY, MARYLAND

MICHAEL G. LENETT13507 Rippling Brook DriveSilver Spring, MD 20906

Plaintiff,v.VIRGINIA R. RAMSEY201 Norwood RoadAnnapolis, MD 21401andJOHN DOE #1Address UnknownandJOHN DOE #2Address UnknownandJOHN DOE #3Address UnknownandJOHN DOE #4Address UnknownandJOHN DOE #5Address Unknown

Defendants.


14/14

,. . .LINE ENTERING APPEARANCESIRIMADAM CLERK:

Please enter the appearance of Timothy F. Maloney, Matthew M. Bryant, and the lawr-finn of Joseph, Greenwald, and Laake, P.A. as counsel for Plaintiff in the above referenced::tNmatter.Q.

Respectfully submitted,JOSEPH, GREENWALD &LAAKE, P.A.

By: - - - jf- I~ ~ __tiIl1OthYF.MaiOIey, Esq.Matthew M. Bryant, Esq.6404 Ivy Lane, Suite 400Greenbelt, MD 207703011220 - 2200Counsel for Plaintiff

lawsuit: michael g. lenett vs. virginia r. ramsey, et al (complaint)

Documents