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,
In his individual capacity;
Serve at:
1016 Castlemain Dr.
Impetial, MO 63052
WlLLIA.\1 BRENGLE,
In his individual capacity;
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
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 2 of 55 PageID #: 128
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 3 of 55 PageID #: 129
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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.
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 4 of 55 PageID #: 130
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
5/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
6/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 7 of 55 PageID #: 133
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 8 of 55 PageID #: 134
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 9 of 55 PageID #: 135
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 10 of 55 PageID #: 136
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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$$ hammers
You ever wonder why he looks f-d silly? He still has a rodent
that traveled up his digestive system and lodged itself in his
brain. He can't let this tragedy
go
Apparently there
is
a merit
badge for biology when he displays this in his "pack". Lol.
Pardon the pun
You guys are straight up f-sticks. Kinda like middle school and
now
. i
laugh
at
you "
ee
'Nepotism on Fox schoolboard'
post 768; Ex. D. pg. 28.
A. The IP address used to make this post
is
registered
to
the
home
of
Jamie and Dianne Critchlow.
B.
The context
of
the forum makes clear that the 'Sam' in
the above post refers to Sam Feny.
11
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 11 of 55 PageID #: 137
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
12/55
d. On Febrnary 7, 2013 at 2:42 P.M., Dianne and Jamie Critchlow used
the username "Windsor alum" to maliciously publish the following
false and defamatory statement about Ferry to third parties on
topix.com:
i) "Not worried about Sam - disgruntled employee sounds like.
Troop is hilarious. You guys don't get it he making a mockery
of
all
of
you. The crazy on here is the ex Stephanie Thayer."
ee
'Nepotism
on
Fox schoolboard' post 791; Ex. D. pg. 30.
A. The IP address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
e.
On February 14, 2013 at 10:18 P.M., Dianne and Jamie Critchlow
used the usemame "Troop 5 or 6" to maliciously publish the
following false and defamatory statement about
cny
to third parties
on topix.com:
i "Yes I just came on this thread. Had other knowledgable
facts to spread prior
to
this conglomerate
of
brainiacs. So good
to see Melissa has finally shared her secret with
all
of
you.
Now hear this. I have a secret to share too. I have learned that
there
is an
underground group
of
people who like to impose
as
boyscout sponsors. They come
in
all shapes, sizes, mental
capacities and socioeconomic categories. They are known as,
in my opinion,
as
the "a$$ 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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 12 of 55 PageID #: 138
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 13 of 55 PageID #: 139
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
14/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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.
A. The IP address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
Jamie and Dianne Critchlow.
B. The context
of
the forum makes clear that the 'Sam' in
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 15 of 55 PageID #: 141
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 16 of 55 PageID #: 142
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
17/55
headlines. Kids talk ... eventually. ee 'Nepotism on Fox
schoolboard' post 2491; Ex.
D.
pg. 45.
A.
The IP address used
to
make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 17 of 55 PageID #: 143
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 18 of 55 PageID #: 144
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
'Nepotism on Fox schoolboard' post 800; Ex. D. pg. 30.
A. The IP address used to make this post is registered to the
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 19 of 55 PageID #: 145
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 20 of 55 PageID #: 146
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
21/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
22/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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.
A The IP address used to make this post
is
registered to the
Fox C-6 School District.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 23 of 55 PageID #: 149
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
schoolboard' post 459; Ex. D. pg. 61.
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$$.
Your one sick m-fcr. If come near MY daughters you won't
walk away. Please explain this to
us
Sam.'' See 'Nepotism on
Fox schoolboard' post 610; Ex. D. pg. 21.
A. The IP address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
B.
The context of the fornm makes clear that the 'Sam' in
the above pos t refers to Sam Ferry.
24
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 24 of 55 PageID #: 150
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
25/55
J. On Janmuy 24, 2013 at 7:14 P.M., Dianne and Jamie Critchlow used
the username Cant help butt notice to post the following harassing
statement about Tyler to third parties on topix.com:
i I
was at that last board mtng as an innocent bystander hoping
to watch these fools make a mochery
of
themselves, and they
did. That lady who was
up
there looking like an idiot had the
largest hiney think I've ever seen.
think
just one cheek may
have weighed more than her dumba$$ 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
false and defamatory statement about Ferry to third parties on
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
'Nepotism on Fox schoolboard' post 615; Ex. D. pg. 22.
25
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 25 of 55 PageID #: 151
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
26/55
A. The IP address used to make
1his
post is registered to the
home
of
Jamie and Dianne Critchlow.
B.
The context
of
the forum makes clear
thatthe
'Sam' in
the above post refers to Sam Ferry.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 26 of 55 PageID #: 152
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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.
A. The IP address used to make this post is registered to the
Fox C-6 School District.
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
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 27 of 55 PageID #: 153
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
28/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
29/55
A. The IP address used to make this post is registered to the
home of Jamie and Dianne Critchlow.
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
address used to make this post
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
false and defamatory statement about Ferry to third parties on
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 29 of 55 PageID #: 155
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
t. On February
2,
2013 at 9:30 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
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
Jamie and Dianne Critchlow.
u.
On Febrnary
5,
2013 at 4:44 P.M., Dianne and Jamie Critchlow used
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 30 of 55 PageID #: 156
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
31/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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$$ will be ready for return to the states this weekend." ee
'Nepotism on Fox schoolboard' post 738; Ex. D. pg. 25.
A. The IP address used to make this post is registered to the
home of Jan1ie and Dianne Critchlow.
w.
On
February
5,
2013 at 4:54 P.M., Dianne and Jamie Critchlow used
the usemame "TROOP 5 or
6
to publish the following false and
harassing statement about Tyler to third parties
on
topix.com:
i "Loi
Ifit
is, his ex has one gigantic a$$. 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
'Nepotism on Fox schoolboard' post 739; Ex. D. pg. 25.
A. The
IP
address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
'Nepotism on Fox schoolboard' post 755; Ex. D. pg. 26.
A. The IP address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 32 of 55 PageID #: 158
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 33 of 55 PageID #: 159
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
schoolboard' post 761; Ex. D. pg. 28.
A.
The
IP
address used
to
make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
home of Jamie and Dianne Critchlow.
B. · The context of the forum makes clear that the
Sam
in
the above post refers to Sam Ferry.
34
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 34 of 55 PageID #: 160
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
35/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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.
A. The IP address used to make this post is registered
to
the
home of Jamie and Dianne Critchlow.
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
'Nepotism on Fox schoolboard' post 792; Ex. D. pg. 30.
A. The IP address used to make this post is registered
to
the
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 36 of 55 PageID #: 162
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
schoolboard' post 826; Ex. D. pg. 31.
A. The IP address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 37 of 55 PageID #: 163
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
A. The IP address used to make this post is registered to the
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 38 of 55 PageID #: 164
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
39/55
A The IP address used to make this post
is
registered to the
home of Jamie and Dianne Critchlow.
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
schoolboard' post 882; Ex. D. pg. 33.
39
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 39 of 55 PageID #: 165
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
40/55
A The IP address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
11
On February 12, 2013 at 8:17 P.M., Dianne and Jamie Critchlow
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.
A The IP address used to make this post
is
registered
to
the
home of Jamie and Dianne Critchlow.
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
Fox C-6 School District.
40
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 40 of 55 PageID #: 166
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
41/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
42/55
B. The context
of
the forum makes clear that the 'Sam' in
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.
A. The IP address used to make this post is registered to the
home
of Jamie and Dianne Critchlow.
42
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 42 of 55 PageID #: 168
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
43/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
address used to make this post
is
registered to the
home
of
Jamie and Dianne Critchlow.
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.
A. The IP address used to make this post is registered to the
home of Jamie and Diam1e Critchlow.
44
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 44 of 55 PageID #: 170
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
The IP address used to make this post is registered to the
home of Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 45 of 55 PageID #: 171
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
46/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
'Nepotism on Fox schoolboard' post 1372; Ex. D. pg. 44.
A.
The IP
address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
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.
A The IP address used to make this post is registered to the
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 47 of 55 PageID #: 173
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
address used to make this post
is
registered to the
home of Jamie and Dianne Critchlow.
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
address used to make this post is registered to the
home
of
Jamie and Dianne Critchlow.
48
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 48 of 55 PageID #: 174
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
The IP address used to make this post is registered to the
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
schoolboard' post 2672; Ex.
D.
pg. 46.
A
The IP address used to
make
this post is registered to the
home
of
Jamie and Dianne Critchlow.
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 49 of 55 PageID #: 175
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
50/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
51/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
52/55
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 53 of 55 PageID #: 179
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
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
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 54 of 55 PageID #: 180
8/9/2019 Federal Lawsuit against Critchlow for Topix Defamation
55/55
Top Related