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story category Lawyer Sues dontdatehimgirl.com
Site Contends No Liability
(old news - 08:48AM Friday Jun 30 2006)
tags: legal
Claiming defamation, Todd J. Hollis filed suit yesterday in Allegheny County Common Pleas Court against Tasha C. Joseph, owner and operator of www.dontdatehimgirl.com . The website, a searchable database allowing women to warn others of male philanderers, characterized Mr. Hollis as having a sexually transmitted disease and one who whines about paying child support. Hollis, a Pittsburgh lawyer, contends that Ms. Joseph "conspired with disingenuous people whose only agenda is to attack the character of those individuals who have been identified on her site." Ms Joseph's lawyers assert the site is not liable under 1996 Communications Decency Act.
Story at the Pittsburgh Post-Gazette
More on the habits of dontdatehimgirl.com can be found in this Houston Press article.
Additional legal contentions may be perused at www.classaction-dontdatehimgirl.com

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Forums » Lawyer Sues dontdatehimgirl.com

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Nightfall
My Goal Is To Deny Yours
Premium,MVM
join:2001-08-03
Grand Rapids, MI
clubs:
·AT&T Midwest
·Comcast
·Site5.com

Congrats Mr. Hollis

You have succesfully helped a website that very few people know about get free publicity. I wonder how many new visitors this site will get in the coming weeks/months?
--
My Domain
Nightfall's Hockey and Life Journal
FiL

join:2005-08-16
Silver Spring, MD

Re: Congrats Mr. Hollis

yea, what an idiot. He's done more damage to himself by filing the suit then the few women that were talking about em! Their hit counts gonna crazy, atleast from the 100's/1000's of people that regularly visist BBR. hehe.

tc1uscg

join:2005-03-09
Saint Clair Shores, MI
·Comcast
·WOW Internet and C..
·VoiceEclipse

Re: Congrats Mr. Hollis

said by FiL See Profile :

yea, what an idiot. He's done more damage to himself by filing the suit then the few women that were talking about em! Their hit counts gonna crazy, at least from the 100's/1000's of people that regularly visit BBR. hehe.
Maybe he knows this and while going down with a sinking ship, he's taking a last stab hopping to make her life troublesome to say the least.. You think?

technick
Premium
join:2000-12-16
Loganville, GA

Yea I agree, any publicity is good publicity. Look at the case of Aruba, some young girl disappears down there. Travel goes up two fold to Aruba afterwards.

Anyways, I really think this site is a waste of time. Anybody with a grudge against a guy can defame him on the site without any factual evidence to support the claims.

Lets face it, the truth is guys and girls cheat. The only thing you can do is move on. Holding a grudge does not improve your karma points and will probably shorten your life span. Life is too short to devote your time to trashing someone elses.
--
"Our greatest glory consists not in never falling, but in rising everytime we fall." - Confucius

Bellsouth Free Since 10/05 - To Hell With Bellsouth
Advocatus Diaboli


Streamfire.net
Sofa King

join:2006-06-01
»www.dontdatehimgirl.com/search/c···2Easp%3F

This girl put out my buisness like that.
kdandaoc

join:2003-10-13
608052427

Re: Congrats Mr. Hollis

she ripped you pretty good.....just goes to show todays gangsta's are in no comparison to the real gangsters of yesteryear!

insomniac84

join:2002-01-03
Schererville, IN
That's hilarious.

braynes
Premium
join:2005-03-14
Waterville, ME
I just attempted to read it But i am not aware of the language and Google could not translate it. anybody know what she said?
Bruce

benecewicz
Premium
join:2005-04-08
Parkville, MD

Re: Congrats Mr. Hollis

I used to be quite fluent in jive, but it seems like a regional flavor I am unaccustomed to....

2kmaro
Think
Premium,ExMod 1 BC
join:2000-07-11
ColossalCave
clubs:
Be more careful with that gun next time, and be a man and own up to the fact that you shot yourself with it. The girls will like you better for your honesty.

Politely,
Miss Manners
--
...then THINK! again!!

calvoiper

join:2003-03-31
Belvedere Tiburon, CA
·Comcast Formerly ..

said by Nightfall See Profile :

...I wonder how many new visitors this site will get in the coming weeks/months?
Enough so that the website is swamped today and response times range from awful to endless....

calvoiper
--
VoIP--the death knell of remaining voice monopolies!
patcat88

join:2002-04-05
Jamaica, NY

edit:
June 30th, @07:26PM

Re: Congrats Mr. Hollis

Here is a new one, BBR-DOTTED!!!!!!!!!
fiberguy
My views are my own.
Premium
join:2005-05-20


edit:
June 30th, @03:24PM

Very few people know about this site? It's been all over the news for months now. I am not sure you're statement is correct. Their stats say something different.

Besides, to each is own in what they want to do and all.. but character assasination is no laughing matter. What would you do if you were posted there and your employer say it? or your family, or other people you have a professional relation with?

These kinda sites would be no different than taking out a billboard, posting a picture and making these same clames.

I say good riddens to bad rubbish.

This is the very thing that makes us as Americans look like spoiled brats. These girls most likely had just as much to do with the failure of the relationship as did the guy. So, she should get out and spread all these unfoudned accusations about the guy? If you are going to say something about someone and not give a chance for rebuttle, then it says alot about your own self.

People who like to air dirty laundry in public have something to be said about their own back yard. No different that the guy who filmed the comcast tech. Just shows the vendictive mentality of some people. I'd avoid the girl that posted on the site.. some of these guys were probably just fine, but did something, pissed off these girls and they are out for spite. I'd avoid these girls at all costs too.

I hope the site does go down - they need to learn a lesson that this behaviour is what kills the Americna spirit.. it's not gays, it's not the church, it's not flag burning - in the end, it's how we treat our fellow man. This site is an embarassment to our own kind.
patcat88

join:2002-04-05
Jamaica, NY

edit:
June 30th, @07:30PM

Re: Congrats Mr. Hollis

Sounds like the site is for disappointed golddiggers.
lawrence171
Evilly Yours - Evilness

join:2001-12-24
Canada
I'm there :-D
FiL

join:2005-08-16
Silver Spring, MD

sheesh...

talk about a woman scorned!

Not that I advocate cheating, but damn. That sites a little too "clingy", wouldnt ya say?


morbo
Complete Your Transaction

join:2002-01-22
00000
clubs:

sounds like

someone's upset that he's been outed as having an STD.

tsu

join:2001-08-17
Wheeling, IL

Re: sounds like

I wonder what verification the site uses to determine factual reporting of such.

TK Junk Mail
Golf season has returned - hurrah
Premium
join:2002-03-03
Margate City, NJ
·Comcast

Re: sounds like

said by tsu See Profile :

I wonder what verification the site uses to determine factual reporting of such.
I am sure they do none at all. They probably claim all liability passes on to the person posting the account. At least that is their plan. I guess if this guy wins his suit, they will go out of business.
--
--
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UHF
Technical Difficulties - Please Stand By
Premium
join:2002-05-24
clubs:

Re: sounds like

The site will be held harmless. As long as they don't edit what the users post, they have no liability. This has been tried in court before and been upheld. The site owner is 100% correct.

Michieru
zzz zzz zzz
Premium
join:2005-01-28
Miami, FL

edit:
June 30th, @02:11PM

The verification process the site uses is called the simple l/p/e.
nonner

join:2005-10-14
Charlotte, NC

Only libel if it's not true?

Correct me if I'm wrong, of course, but is he sueing for libel against the website or the individual poster?

Because to sue for libel, doesn't the statements made need to be false. So, basically he has to prove that he is STD free. If this woman was ranting about him having an STD and it isn't true, then she will pay a penalty. But... the thing is, if he does have an STD, this lawsuit will probably just confirm that for everyone as a fact and not just a woman complaining. So, if he's smart, he wouldn't sue unless he definately doesn't have an STD.
HMS1

join:2006-01-14
Austin, TX


edit:
June 30th, @11:07AM

Re: Only libel if it's not true?

said by nonner See Profile :

to sue for libel, doesn't the statements made need to be false. So, basically he has to prove that he is STD free. If this woman was ranting about him having an STD and it isn't true, then she will pay a penalty. But... the thing is, if he does have an STD, this lawsuit will probably just confirm that for everyone as a fact and not just a woman complaining. So, if he's smart, he wouldn't sue unless he definately doesn't have an STD.

Yes, truth is a complete defense in a libel or slander case in USA. However, the burden of proof is shared, in effect. The defendant has to show grounds for reasonable belief that the statements were true; the plaintiff may show evidence of falsehood.

said by nonner See Profile :

Correct me if I'm wrong, of course, but is he sueing for libel against the website or the individual poster?

According to the article he's suing the site owner and "several posters". p2pnet.net has been hit with a similar case recently.

It's important for forum operators to be free from blanket liability for whatever posters say - otherwise the threat of lawsuits would shut down any freedom of discussion on the internet.

On the other hand, once the owner/operator is notified, different rules come into play. It becomes a question of whether the challenged writings have to be removed. This situation is less dangerous to freedom of speech.

Of course, *this* site owner is likely to faces suits repeatedly because of the nature of the site: it's inviting this sort of thing.

pb5k
more cowbell
Premium
join:2005-11-16
Tempe, AZ
·Verizon Online DSL

Re: Only libel if it's not true?

It's important for forum operators to be free from blanket liability for whatever posters say - otherwise the threat of lawsuits would shut down any freedom of discussion on the internet.
I agree completely. But while political speech enjoys a tremendous degree of protection (and rightfully so), "gossip column" stuff - e.g. "he doesn't wear a condom and has t3h sex with dozens of da womens!!" - gets considerably less protection under the law and this is understandable.

You see this all the time with the tabloids - every once in a while they will report on something of questionable veracity and get their pantaloons sued off.
--
"It's a recession when your neighbor loses his job; it's a depression when you lose yours." -- Harry S Truman
fiberguy
My views are my own.
Premium
join:2005-05-20

Re: Only libel if it's not true?

The 1st amendment of free speech does give Americans the right to say anything and everything they want as "free speech".. the 1st amendment only protects us when it comes to the government, not each other.

THollis

@comcast.net

Thought you might like to read the complaint. Todd.

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA

TODD J. HOLLIS, ) CIVIL DIVISION
)
Plaintiff, ) No.: GD 06-12677
)
vs. ) Code: 008
)
)
TASHA C. JOSEPH, individually, ) COMPLAINT IN
and as owner and operator of ) CIVIL ACTION
DONTDATEHIMGIRL.COM, )
EMPRESS MOTION PICTURES, )
doing business as THE CAVELLE )
COMPANY, INC., CAROLYN )
MERITT LATTIMORE, ALESIA )
ROSKOV, ANNA DOE, )
BARBARA DOE, CATHERINE DOE, )
DEBORAH DOE, and EMILY DOE, )
)
Defendants. )
) Filed on behalf of Plaintiff:
) Todd J. Hollis
)
) Counsel of Record for
) the Plaintiff:
)
) John R. Orie, Jr., Esquire
) Pa. I.D. #21972
)
) ORIE & ZIVIC
) Firm No. 463
) 25th Floor Lawyers Building
) Pittsburgh PA 15219
) (412) 281-3180
) (412) 232-0813 facsimile
) law@oriezivic.com
)
) A JURY TRIAL DEMANDED

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA

TODD J. HOLLIS, ) CIVIL DIVISION
)
Plaintiff, ) No.: GD 06-12677
)
vs. ) Code: 008
)
TASHA C. JOSEPH, individually, )
and as owner and operator of )
DONTDATEHIMGIRL.COM, )
EMPRESS MOTION PICTURES, )
doing business as THE CAVELLE )
COMPANY, INC., CAROLYN )
MERITT LATTIMORE, ALESIA )
ROSKOV, ANNA DOE, )
BARBARA DOE, CATHERINE DOE, )
DEBORAH DOE, and EMILY DOE, )
)
Defendants. )
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any claim or relief requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERRAL SERVICES
ALLEGHENY COUNTY BAR ASSOCIATION
920 CITY-COUNTY BUILDING
PITTSBURGH, PA 15219
PHONE: 412-261-0518

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA

TODD J. HOLLIS, ) CIVIL DIVISION
)
Plaintiff, ) No.: GD 06-12677
)
vs. ) Code: 008
)
)
TASHA C. JOSEPH, individually, ) COMPLAINT IN
and as owner and operator of ) CIVIL ACTION
DONTDATEHIMGIRL.COM, )
EMPRESS MOTION PICTURES, )
doing business as THE CAVELLE )
COMPANY, INC., CAROLYN )
MERITT LATTIMORE, ALESIA )
ROSKOV, ANNA DOE, )
BARBARA DOE, CATHERINE DOE, )
DEBORAH DOE, and EMILY DOE, )
)
Defendants. )

COMPLAINT IN CIVIL ACTION
AND NOW, the Plaintiff, Todd J. Hollis, by his attorneys, John R. Orie, Jr., Esquire and the law firm of Orie & Zivic, files the within Complaint in Civil Action:
The Parties:
1. The Plaintiff is Todd J. Hollis (Hollis), an adult individual residing at 715 N. Negley Avenue, Pittsburgh, Allegheny County, Pennsylvania 15206.
2. The Defendant, Tasha C. Joseph (Joseph), is an adult individual who maintains an address at 771 N.W. 48th Street, Miami, Florida 33127. Joseph is being sued individually and as the owner and operator of a website known as dontdatehimgirl.com located on the worldwide Internet.
3. The Defendant, Empress Motion Pictures, d/b/a the Cavelle Company, Inc. (Cavelle), is a Florida Corporation with offices at 771 N.W. 48th Street, Miami, Florida 33127. Cavelle is the “Registrant” for the domain name of dontdatehimgirl.com.
4. Defendant Joseph is the Registered Agent and an officer and director of Defendant Cavelle.
5. The Defendant, Anna A. Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
6. The Defendant, Barbara Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
7. The Defendant, Catherine Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
8. The Defendant, Deborah Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
9. The Defendant, Emily Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
Background:
10. Defendant Joseph is the founder, owner and operator of dontdatehimgirl.com, a website located on the worldwide Internet.
11. Joseph describes her website as the “most hated cheaters list” for men, and has likened it to the “FBI’s most wanted list.” According to Joseph: “Any woman out there can post a picture and profile of a guy who’s cheated on them and it goes into a massive search engine.”
12. The dontdatehimgirl.com website currently contains “profiles” of more than 1,000 men, and receives more than 100 new submissions per day, according to Joseph. The website averages more than 200,000 visitors per day, and is growing.
13. The dontdatehimgirl.com website permits women to make anonymous postings about men who have allegedly “cheated on them.” Joseph candidly admits that the website does nothing to independently verify the information posted by the anonymous posters.
The defamatory postings:
14. The Plaintiff, Hollis, is a well-known and highly respected criminal defense attorney who practices in the greater Pittsburgh area.
15. Hollis has handled a number of high-profile cases in the local area and has also performed significant work in his local community. Hollis’ good reputation is essential to his occupation.
16. Hollis has an excellent reputation for honesty and integrity in both his business and personal affairs.
17. On or about May 24, 2006, the dontdatehimgirl.com website published an alleged “profile” concerning Hollis.
18. The “profile” was submitted by an anonymous poster, and included a picture of Hollis. Among other things, the “profile” falsely accused Hollis of having multiple children. The “profile” also falsely accused Hollis of having herpes. A true and correct copy of the “profile” is attached hereto as Exhibit “A.”
19. In accordance with its customary practice, the dontdatehimgirl.com website did nothing to independently verify the information contained in the profile, and in fact it was false.
20. Upon learning of the posting, Hollis requested Defendant Joseph to remove it from the website. Joseph refused.
21. On or about _________, 2006, the dontdatehimgirl.com website published a second “profile” concerning Hollis.
22. Again, the “profile” was submitted by an anonymous poster, and included a picture of Hollis. Among other things, the “profile” falsely asserted that Hollis “gave me an STD.” A true and correct copy of the “profile” is attached hereto as Exhibit “B.”
23. In accordance with its customary practice, the dontdatehimgirl.com website did nothing to independently verify the information contained in the profile, and in fact it was false.
Count I
Hollis v. Joseph
24. Plaintiff hereby incorporates paragraphs 1 through 23 above as if set forth in their entirety.
25. As the owner and operator of the dontdatehimgirl.com website, Joseph is responsible for the information contained on her website.
26. As set forth above, Joseph published false and defamatory statements regarding Hollis.
27. Among other things Joseph falsely stated that:
A. Hollis has multiple children;
B. Hollis has herpes; and
C. Hollis had transmitted an STD to an anonymous poster.
28. These statements constituted “defamation per se” under Pennsylvania law.
29. Joseph published the defamatory statements with knowledge of the falsity of the statements and/or with reckless disregard as to the truth of the statements.
30. Joseph failed to properly investigate the subject matter of the defamatory statements prior to publishing them.
31. By publishing defamatory statements with knowledge of their falsity or with reckless disregard as to their truth, Joseph acted with actual malice.
32. Joseph abused any and all conditional privileges which she might have been entitled to assert, by failing to use reasonable care and diligence to ascertain the truth, before publishing the false communications and by acting with actual malice.
33. As a direct and proximate result of Joseph’s conduct, Hollis has suffered embarrassment, humiliation and emotional distress which may be permanent in nature.
34. As a direct and proximate result of Joseph’s conduct, Hollis has suffered damage to his reputation, which may be permanent in nature.
35. As a direct and proximate result of Joseph’s conduct, Hollis’ earning capacity has been impaired and/or may be impaired in the future.
36. Joseph has intentionally and maliciously defamed Hollis. Such conduct was extreme and outrageous in character, entitling Hollis to punitive damages.
WHEREFORE, Plaintiff prays this Honorable Court to enter judgment in favor of the Plaintiff and against Defendant for compensatory damages in excess of $50,000.00, as well as for punitive damages, interest and costs of suit.
Count II
Hollis v. Cavelle
37. Plaintiff hereby incorporates paragraphs 1 through 36 above as if set forth in their entirety.
38. As set forth above, Cavelle is the“Registrant” for the domain name of dontdatehimgirl.com. As such, Cavelle is responsible for the information contained on the website.
39. As set forth above, Cavelle published false and defamatory statements regarding Hollis.
40. Among other things Cavelle falsely stated that:
A. Hollis has multiple children;
B. Hollis has herpes; and
C. Hollis had transmitted an STD to an anonymous poster.
41. These statements constituted “defamation per se” under Pennsylvania law.
42. Cavelle published the defamatory statements with knowledge of the falsity of the statements and/or with reckless disregard as to the truth of the statements.
43. Cavelle failed to properly investigate the subject matter of the defamatory statements prior to publishing them.
44. By publishing defamatory statements with knowledge of their falsity or with reckless disregard as to their truth, Cavelle acted with actual malice.
45. Cavelle abused any and all conditional privileges which it might have been entitled to assert, by failing to use reasonable care and diligence to ascertain the truth, before publishing the false communications and by acting with actual malice.
46. As a direct and proximate result of Cavelle’s conduct, Hollis has suffered embarrassment, humiliation and emotional distress which may be permanent in nature.
47. As a direct and proximate result of Cavelle’s conduct, Hollis has suffered damage to his reputation, which may be permanent in nature.
48. As a direct and proximate result of Cavelle’s conduct, Hollis’ earning capacity has been impaired and/or may be impaired in the future.
49. Cavelle has intentionally and maliciously defamed Hollis. Such conduct was extreme and outrageous in character, entitling Hollis to punitive damages.
WHEREFORE, Plaintiff prays this Honorable Court to enter judgment in favor of the Plaintiff and against Defendant for compensatory damages in excess of $50,000.00, as well as for punitive damages, interest and costs of suit.
Count III
Hollis v. Anna A. Doe
50. Plaintiff hereby incorporates paragraphs 1 through 49 above as if set forth in their entirety.

51. The Defendant, Anna A. Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
52. Hollis intends to learn the identity of Doe during discovery in this case.
53. As set forth above, Doe published false and defamatory statements regarding Hollis.
54. Among other things Doe falsely stated that:
A. Hollis has multiple children; and
B. Hollis has herpes.
55. These statements constituted “defamation per se” under Pennsylvania law.
56. Doe published the defamatory statements with knowledge of the falsity of the statements and/or with reckless disregard as to the truth of the statements.
57. Doe failed to properly investigate the subject matter of the defamatory statements prior to publishing them.
58. By publishing defamatory statements with knowledge of their falsity or with reckless disregard as to their truth, Doe acted with actual malice.
59. Doe abused any and all conditional privileges which she might have been entitled to assert, by failing to use reasonable care and diligence to ascertain the truth, before publishing the false communications and by acting with actual malice.
60. As a direct and proximate result of Doe’s conduct, Hollis has suffered embarrassment, humiliation and emotional distress which may be permanent in nature.
61. As a direct and proximate result of Doe’s conduct, Hollis has suffered damage to his reputation, which may be permanent in nature.
62. As a direct and proximate result of Doe’s conduct, Hollis’ earning capacity has been impaired and/or may be impaired in the future.
63. Doe has intentionally and maliciously defamed Hollis. Such conduct was extreme and outrageous in character, entitling Hollis to punitive damages.
WHEREFORE, Plaintiff prays this Honorable Court to enter judgment in favor of the Plaintiff and against Defendant for compensatory damages in excess of $50,000.00, as well as for punitive damages, interest and costs of suit.
Count IV
Hollis v. Barbara Doe
64. Plaintiff hereby incorporates paragraphs 1 through 63 above as if set forth in their entirety.
65. The Defendant, Barbara Doe (Doe), is an as-yet unknown individual who made anonymous postings on the dontdatehimgirl.com. website.
66. Hollis intends to learn the identity of Doe during discovery in this case.
67. As set forth above, Doe published false and defamatory statements regarding Hollis.
68. Among other things Doe falsely stated that Hollis gave her an STD.
69. These statements constituted “defamation per se” under Pennsylvania law.
70. Doe published the defamatory statements with knowledge of the falsity of the statements.
71. By publishing defamatory statements with knowledge of their falsity or with reckless disregard as to their truth, Doe acted with actual malice.
72. As a direct and proximate result of Doe’s conduct, Hollis has suffered embarrassment, humiliation and emotional distress which may be permanent in nature.
73. As a direct and proximate result of Doe’s conduct, Hollis has suffered damage to his reputation, which may be permanent in nature.
74. As a direct and proximate result of Doe’s conduct, Hollis’ earning capacity has been impaired and/or may be impaired in the future.
75. Doe has intentionally and maliciously defamed Hollis. Such conduct was extreme and outrageous in character, entitling Hollis to punitive damages.
WHEREFORE, Plaintiff prays this Honorable Court to enter judgment in favor of the Plaintiff and against Defendant for compensatory damages in excess of $50,000.00, as well as for punitive damages, interest and costs of suit.
Count V
Hollis v. Catherine Doe, Deborah Doe and Emily Doe
76. Plaintiff hereby incorporates paragraphs 1 through 75 above as if set forth in their entirety.
77. Hollis believes and therefore avers that other unknown individuals may have posted false information about him on the dontdatehimgirl.com website.
78. Accordingly, Hollis reserves the right to amend his Complaint in the event that he learns the identity of any such individuals during discovery.

WHEREFORE, Plaintiff prays this Honorable Court to enter judgment in favor of the Plaintiff and against Defendants for compensatory damages in excess of $50,000.00, as well as for punitive damages, interest and costs of suit.

A JURY TRIAL DEMANDED

Respectfully submitted,
ORIE & ZIVIC
By: DRAFT
John R. Orie, Jr., Esquire
Counsel for Plaintiff
PA I.D. No. 21972
2500 Lawyers Building
Pittsburgh PA 15219
(412) 281-3180
(412) 232-0813 facsimile
law@oriezivic.com

PROOF OF SERVICE
I, John R. Orie, Jr., Esquire, of the law firm of Orie & Zivic, hereby certify that the within Complaint in Civil Action was served this day of June, 2006 on all interested parties via U.S. First Class Mail, and addressed as follows:

Robert L. Byer, Esquire
Duane Morris LLP
600 Grant Street, Suite 5010
Pittsburgh, PA 15219

Counsel for Defendants


John R. Orie, Jr., Esquire

thollis

@comcast.net
Your are smart and intelligent. THollis

W8ASA
Tieng gi vay?

join:2000-07-31
Dayton, OH
clubs:
·Vonage
·AT&T Midwest

I visited that site....

and was AMAZED at the ignorance and bad spelling/syntax/thought organization shown by the posters. They come across to me as uneducated women you might find in "clubs" who have been played, and who will believe anything they're told because they are so "clingy", to borrow a word from another poster on here.

One said that she got scammed by the 419 club.... shame on her stupidity.

I doubt the veracity of many of those entries. I recognize similar spelling errors across multiple entries, leading me to believe they were written by the same person.
--
Microwave and RF Components at www.ohiomicrowave.com

pnh102
Reptiles Are Cuddly And Pretty
Premium
join:2002-05-02
Mount Airy, MD
·Comcast

Re: I visited that site....

said by W8ASA See Profile :

and was AMAZED at the ignorance and bad spelling/syntax/thought organization shown by the posters.
^ I'm just wondering who clicked on that link! ^
--
Tancredo 2008!

kamm

join:2001-02-14
Brooklyn, NY
·Packet8

said by W8ASA See Profile :

and was AMAZED at the ignorance and bad spelling/syntax/thought organization shown by the posters. They come across to me as uneducated women you might find in "clubs" who have been played, and who will believe anything they're told because they are so "clingy", to borrow a word from another poster on here.

One said that she got scammed by the 419 club.... shame on her stupidity.

I doubt the veracity of many of those entries. I recognize similar spelling errors across multiple entries, leading me to believe they were written by the same person.
I noticed similar patterns too but it could be due to the fact that most of these "girls" are indeed pretty ill-educated, some of them strikingly stupid, moronic so they copy each other's expressions, just like a bunch of kids in elementary...

This whole site is ridiculous, the whole notion is ridiculous: one party can post freely but the other has to send in his rebuttal in email, so it may or may not get posted.

Priceless, seriously.
I bet this Tasha was just another college f*ckup, hence this pathetically distorted system on her site...

PS: BTW she also has the »www.dontdateherman.com - another fucked-up site...

pnh102
Reptiles Are Cuddly And Pretty
Premium
join:2002-05-02
Mount Airy, MD
·Comcast


edit:
June 30th, @02:24PM

Re: I visited that site....

said by kamm See Profile :

This whole site is ridiculous, the whole notion is ridiculous: one party can post freely but the other has to send in his rebuttal in email, so it may or may not get posted.
Anyway, there is one upside to women like these... THEY'RE EASY!
--
Tancredo 2008!
fiberguy
My views are my own.
Premium
join:2005-05-20
Holy crap - we agree on something!

kalphearion
In nomine Patri
Premium
join:2003-11-08
Denver, CO
clubs:
·Comcast

No case

This guy does not have a case. He is mad because he is on a publicly viewed site stating he has an STD and cheated. He just shot himself in the foot, because now a hell of a lot more people know about the site.

On the other hand, if he actually does not have a STD, and the site is saying he does, then he will have somewhat of a case.

See 9 replies to this post

Agent_haito

join:2002-09-20
Winston Salem, NC

wow

So if he "released" tapes/photos of their sexual encounters, would he be in the right? But seriously they should have been a better judge of character, both of them are stupid for all this.....her for being spiteful and petty and starting all this, him for suing and letting even more people know how much of an two timing idiot he is....blah
FiL

join:2005-08-16
Silver Spring, MD

id say

pimp rant on...
hes the liable one for spreading around std's...hahahahaa, dirty ass dude! Its the net, who the hell cares about grammer/spelling. Typing and posting properly formatted replies isnt a test of someones intelligence. I'd say these women are smart for having a forum where they can discuss info on these wannabe "playaz". Learn the game, play it, dont get caught or else your gonna get posterized on that website!

Pimp rant off...

guitarzan
See. Now watch and learn.
Premium
join:2004-05-04
Skytop, PA
·epix

Re: id say

said by FiL See Profile :

I'd say these women are smart for having a forum where they can discuss info on these wannabe "playaz".
I'd say these adulterous women are as bright as an 15 watt appliance bulb, That in addition to what another poster correctly pointed out they are "easy".

What exactly do these easy women think would happen.? Here you have a cheating adulterous husband proving his unfaithfulness.Do these women think or somehow believe these guys will remain faithful to them and not run around on them as they do to their wives.?

I feel so sorry for these "playaz"...NOT. It takes two to tango,yet only one is required to have decency and common sense.

These dimwits act like-Oh my God he cheated on me behind my back. LOL,What comes around goes around.The real victim in this situation is the wives of these cheaters,Who quite possibly can or will end up with HIV, aids or some other STD, All because their other half wanted to knock off a quick and "easy" piece.

Sheesh, they all get what they deserve,except the honest & faithful wife or husband.
--
Bass....the glue of rhythm and harmony...the heartbeat of the band.! Shaking the earth with deep,sonorous vibrations.The dark ominous thunder of an approching storm.

ArchAngel21x
Obama 2008
Premium
join:2001-10-28
Lincoln, NE

Now We Just Need

Something along the lines of dontdateherboy.com to even playing field.

mr sean
Professional Infidel
Premium,ExMod 2001-07
join:2001-04-03
N. Absentia
clubs:

Re: Now We Just Need

»www.classaction-dontdatehimgirl.com/

PhoenixDown
-- Ron Paul 2008 --
Premium
join:2003-06-08
Fresh Meadows, NY
clubs:

I found a similiar site a while back...

and they actually charge people to have the rant/post removed. They just seemed so open to a lawsuit it wasn't funny and now I read this about a very similiar site.
--
NYC Pagans | NYC Pagan Resource

La Luna
Surviving Ashraful
Premium
join:2001-07-12
Hewitt, NJ
clubs:

WHEEEEE!!!

HAHAHAHA!! This is awesome!!

Derch
Premium
join:2004-10-16
Tulsa, OK

edit:
June 30th, @11:22AM

You have got to be kidding me.

For someone to create a website like this is just plain stupid. "Scornful women unite against Men!", that's a better website title.

mr sean
Professional Infidel
Premium,ExMod 2001-07
join:2001-04-03
N. Absentia
clubs:

Re: You have got to be kidding me.

said by Derch See Profile :

For someone to create a website like this is just plain stupid. "Scornful women untie against Men!", that's a better website title.
Untie?
It's a bondage website too?
--
How you can make the world a Better Place

Derch
Premium
join:2004-10-16
Tulsa, OK

Re: You have got to be kidding me.

No, but I have a feeling it could be introduced

(Sorry for typo)
TheGhost
Premium
join:2003-01-03
Lake Forest, IL
clubs:

said by mr sean See Profile :

said by Derch See Profile :

For someone to create a website like this is just plain stupid. "Scornful women untie against Men!", that's a better website title.
Untie?
It's a bondage website too?
No, site is actually for Dyslexic scornful women.

mr sean
Professional Infidel
Premium,ExMod 2001-07
join:2001-04-03
N. Absentia
clubs:

Re: You have got to be kidding me.

oh.
that's very different.
never mind.

braynes
Premium
join:2005-03-14
Waterville, ME

funny web site

We thought it would be interesting to apply this concept to the cheating, lying men of the world and save women the heartache."

Not a chip on her shoulder but the whole tree.
Bruce
FiL

join:2005-08-16
Silver Spring, MD

Re: funny web site

have yall ever had girlfriends?

Or even touched any part of the female race? lol.
I saw this typa stuff coming from a mile away 10 years ago.

anonpisser

@optonline.net

heh

Crazy broad

izy
Premium,MVM
join:2000-09-21
Naples, FL

Can't wait for the....

...sh*t to fly here!

»www.dontdateherman.com
XtremepH

join:2003-10-19
Fort Lauderdale, FL

Re: Can't wait for the....

lol This sh*t is crazy.
RandallFlagg
The Last Gunslinger Of Rational Thought

join:2002-06-09
Renton, WA

Has anyone looked for the Taylor Troll's profile there?

Then we'll finally know the truth!:

"Cheating pirate left me with brain-wasting STD from salad tossin' and donwloading gangsta rap MP3z and programz and Microsoft appz and picturez and shiz from P2P and then doing P on me. Found solace on RIAA. Though RIAA don't really care for me. Now I hate all pirates and say they should meet Bubba in jail because I want to know Bubba as well but I am too chicken to download the latest Backstreet Boyz MP3z and then put my own ass in jail because if I did that then I'd hate my own ass and I'd have to pop it like a pimple on the face of copyright."

I wonder if this will finally get him out of hiding and make him the fun loving troll we all now and hate.

David
Last man standing
Premium,VIP
join:2002-05-30
Granite City, IL
clubs:

I am suprised...

They don't have a

www.dontdateherdude.com

Then again they might have one!!
russotto

join:2000-10-05
Collegeville, PA

CDA protects the website...

But the CDA doesn't protect the person who wrote the actual comment. Hollis ought to sue that person... maybe the libel judgement will offset his child support payments...

braynes
Premium
join:2005-03-14
Waterville, ME

Re: CDA protects the website...

How the fX