Reproduced herein is the entire text of the lawsuit against Dr. Dale Dugas as written by Martin Pedata or, at least written by one of his legal assistants and approved by Pedata. Either way, this is poorly written, self-contradictory, chock full of spelling and grammatical errors, and it should be a source of embarrassment for the writer. It is amateurish, rife with incompetence and, if exemplary of the work product produced by Pedata and his assistants, brings the competence of his entire career into question. The stupidity contained in this document has been faithfully reproduced, to the best of my ability. Images of the original are included for comparison. Now, I'm going to go scold my fingers for typing it all. Filing #117216366 E-Filed 11/24/2020 02:37:02PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR LAKE COUNTY, FLORIDA CASE NO.: DIVISION: STEVEN W. HATFIELD AND BRET GORDON, Plaintiffs, v. DALE DUGAS, a/k/a GERALD GREYSMITH, GG, and LORDES SAPIENS, and TWELVE JOHN DOES, Defendants COMPLAINT The Plaintiffs, Steven W. Hatfield and Bret Gordon, by and through their undersigned attorney, hereby sues the Defendants, Dale Dugas, a/k/a Gerald Greysmith, GG and Lordes Sapiens, and Twelve John Does, who have yet to be determined, and allege: GENERAL ALLEGATIONS 1. At all times material to this complaint, the Plaintiff, Steven W. Hatfield was a resident of the State of Ohio and operated a martial arts business called The Technician Dojo. 2. At all times material to this complaint, the Plaintiff, Bret Gordon was a resident of the Lake County, Florida and operated a martial arts business called Trio Martial Arts. 3. At all times material to this complaint, the Defendant, Dale Dugas, a/k/a/ Gerald Greysmith, GG and Lordes Sapiens, was a resident of Pasco County, Florida. 4. At all times material to this complaint, the Defendant, Dale Dugas, a/k/a/ Gerald Greysmith, GG and Lordes Sapiens, along with twelve other unknown parties, conspired in publishing defamatory statements regarding the Plaintiffs on a facebook page known as “Bullshit Martial Arts”. 5. At all times material to this complaint, the Defendant, Dale Dugas, a/k/a/ Gerald Greysmith and GG, conspired with Lordes Sapiens and others. 6. Plaintiffs have standing to bring this action because he has been directly affected and victimized by the unlawful conduct complained herein which occurred and were widely published in the Circuit and Lake County. They are proximately related to the conduct of Defendants. COUNT I - DEFAMATION 7. This is a cause of action for damages that exceeds $30,000. 8. The Plaintiffs reallege the allegations contained in paragraphs 1 through 6 above as if fully set forth herein. 9. Defendant Dale Dugas, a/k/a Gerald Greysmith GG and Lordes Sapiens, along with twelve other unknown parties published defamatory statements about Plaintiffs contained in Exhibits “A”, “B”, “C” and “D” attached hereto and incorporated by reference herein. The Defendants specifically made the following defamatory statements about Plaintiffs, to wit: they are frauds and liars, that they pretend to be martial arts grandmasters, that they are supporters of rapists and pedophiles, that their businesses and organizations are diploma mills, that their ranks are fake and that they are martial arts frauds and child rape apologists. 10. The aforementioned statements were published on Internet sites and a facebook site called Bullshit Martial Arts, which is controlled by the Defendants. 11. Furthermore, the Defendant, Dale Dugas, a/k/a Gerald Greysmith GG and Lordes Sapiens and GG, and other unknown Defendants, created a facebook page known as Kaiso Krunchdown to publish false and misleading information about Plaintiff Gordon. 12. The social media and Internet postings referred to plaintiffs by name throughout, was made of and concerning plaintiffs, and was so understood by those who read the postings that the defamatory statements were written about plaintiffs. The entire statements about Plaintiffs were false. 13. The Defendants knew or should have known that the defamatory statements were false at the time the statements were made. The statements were published maliciously and recklessly by Defendants with the total disregard as to their truth or falsity and to the utter disregard of the rights of Plaintiffs. 14. The defamatory statements are libelous on its face. They clearly expose Plaintiffs to hatred, contempt, ridicule and obloquy because they wrongfully and maliciously made false statements about Plaintiffs in their professional capacity with the intent to harm plaintiffs in their business and professional capacity. 15. The above-described publications were not privileged because it was published by Defendants with actual malice hatred and ill will toward Plaintiffs and with the desire to injure them in their business and professional capacities. 16. As a direct and proximate cause of the Defendant's conduct, plaintiffs have suffered compensatory damages and injury to their reputation. WHEREFORE, Plaintiffs demand judgment against defendant for damages, plus costs of bringing this action and demands trial by jury. COUNT II – DEFAMATION PER SE 17. This is a cause of action for damages that exceeds $30,000. 18. The Plaintiffs reallege the allegations contained in paragraphs 1 through 6 and 8 through 15 above as if fully set forth herein. 19. Defendants published these malicious, false, misleading and defamatory statements regarding Plaintiffs stating that they are rapists and/or pedophiles and/or support the act of rape and/or pedophilia, participate in fraudulent and dishonest business practices, fraudulently award martial arts rank in their martial arts schools, that they are liars, fraudulently hold martial arts ranks to gain prestige in operating their businesses, and that they operate illegal martial arts businesses. 20. Under Florida law, “it is established. . .that an oral or written communication is actionable per se – that is, without a showing of special damage – if it imputes to another (a) a criminal offense amounting to a felony, or (b) a presently existing venereal or other loathsome and communicable disease, or (c) conduct, characteristics or a condition incompatible with the proper exercise of his lawful business, trade, profession or office, or (d) the other being a woman, acts of unchastity.” Wolfson v. Kirk, 273 So. 2d 774, 777 (Fla. Dist. Ct. App. 1973). 21. These false and misleading statements were published with malice, as Defendants knew that they were false and misleading, or at a minimum acted with a reckless disregard for the truth. 22. This malicious false, misleading and defamatory statements were published on the internet in this Circuit and the County of Lake, domestically and internationally for the entire world to see and hear and specifically Defendants published these malicious false and misleading “facts,” inter alia, that Plaintiffs' conduct, characteristics or a condition is incompatible with the proper exercise of his lawful business, trade, profession or office. 23. This false, misleading, and defamatory statements concerning Plaintiffs are defamatory per se and these false and misleading statements, and others which will be uncovered in discovery, severely harmed and damaged Plaintiffs in their profession and business as martial arts instructors, as they concern conduct and characteristics incompatible with being a martial arts instructor and school teaching martial arts to the public at large and specifically, to child, teenagers, young adults and their families. 24. Damage is presumed by law when defamation per se is shown. 25. As a direct and proximate cause of Defendant's conduct, plaintiffs have suffered compensatory damages and injury to their reputation. WHEREFORE, Plaintiffs demand judgment against defendant for damages, plus costs of bringing this action and demands trial by jury. COUNT III – DEFAMATION BY IMPLICATION 26. This is a cause of action for damages that exceeds $30,000. 27. The Plaintiffs reallege the allegations contained in paragraphs 1 through 6, 8 through 15 and 19 through 24 above as if fully set forth herein. 28. Defendants published these malicious, false, misleading and defamatory statements regarding Plaintiffs, creating the implication that Plaintiffs are rapists and/or pedophiles and/or support the act of rape and/or pedophilia, participate in fraudulent and dishonest business practices, fraudulently award martial arts rank in their martial arts schools, that they are liars, fraudulently hold martial arts ranks to gain prestige in operating their businesses, and that they operate illegal martial arts businesses. 29. Defendants published these malicious, false and defamatory statements when taken together as a whole, constitute defamation by implication. 30. These false, misleading and defamatory statements were published with malice, as Defendants knew that they were false and misleading, or at a minimum acted with reckless disregard for the truth. 31. These malicious statements severely harmed and damaged Plaintiffs in their profession and business as martial arts instructors, as they concern conduct and characteristics incompatible with being a martial arts instructor and school teaching martial arts to the public at large and specifically, to child, teenagers, young adults and their families. 32. Plaintiffs have been severely harmed damaged by these published statements because they subjected them to hatred, distrust, ridicule, contempt, and disgrace. 33. Plaintiffs have been damaged by these malicious, false and misleading statements, and others which will be disclosed during discovery, because the statements severely harmed and damaged Plaintiffs in their profession and business as martial arts instructors, as they concern conduct and characteristics incompatible with being a martial arts instructor and school teaching martial arts to the public at large and specifically, to child, teenagers, young adults and their families. 34. Damage is presumed by law when defamation per se is shown. 35. As a direct and proximate cause of Defendant's conduct, plaintiffs have suffered compensatory damages and injury to their reputation. WHEREFORE, Plaintiffs demand judgment against defendant for damages, plus costs of bringing this action and demands trial by jury. IV – CIVIL CONSPIRACY 36. This is a cause of action for damages that exceeds $30,000. 37. The Plaintiffs reallege the allegations contained in paragraphs 1 through 6, 8 through 15 and 19 through 24 above as if fully set forth herein. 38. The Defendants acted together and conspired to publish defamatory statements regarding the Plaintiffs in order to destroy their businesses and to subject them hatred, distrust, ridicule, contempt, and disgrace. 39. The Defendants, acting in concert, did an unlawful act or did a lawful act by unlawful means, by defaming the Plaintiffs in their individual and professional capacity. 40. In furtherance of the conspiracy, one or more of the Defendants, published the defamatory statements on the Internet and/or other social media platforms, including, but not limited to, facebook. 41. As a direct and proximate result of the Defendants' conduct, the Plaintiff suffered damages, including loss profits. WHEREFORE, the plaintiff demands judgment against the defendants for damages, plus costs for bringing this action and demands trial by jury. COUNT V – INJUNCTION 42. This is a cause of action for a temporary and permanent injunction which is within jurisdiction of this court. 43. The Plaintiffs reallege the allegations contained in paragraphs 1 through 6, 0 through 15 and 19 through 24 above as if fully set forth herein. 44. Plaintiffs seek a permanent and preliminary injunction restraining Defendants, during the pendency of this litigation, from continuing their campaign of publishing defamatory statements against Plaintiffs and for Defendants to remove from the Internet all defamatory statements previously made. 45. The Plaintiffs further seek permanent and preliminary injunction from restraining Defendants, during the pendency of this litigation, from continuing their campaign of tortuously interfering with Plaintiffs, contractual and business relationships with their respective students. The Defendants are intentionally and maliciously contacting Plaintiffs' students in an attempt to get each student to terminate their contract and business relationship with Plaintiffs with the goal to shut Plaintiffs' businesses down. 46. Unless enjoined, Defendants will continue, throughout the course of this lawsuit, to take steps toward accomplishing their goal of destroying the Plaintiffs' reputation and ability to conduct their respective ventures. 47. Each additional step that Defendants are permitted to take will cause irreparable harm to Plaintiffs, in that the closer Defendants get to accomplishing their goal, the more difficult, if not impossible it will become for Plaintiffs to conduct their respective businesses in their respective industry. In fact, the public has raised issues regarding the integrity of Plaintiffs and their business practices after reading the Defendants' postings on the Internet. 48. Plaintiffs have no adequate remedy at law. Absent injunctive relief, there is no way to preserve the status quo pending a determination of the issues in this action, nor to effect a return to the status quo after final determination. WHEREFORE, plaintiffs respectfully request that this court enter an order granting its request for injunctive relief. LAW OFFICE OF MARTIN PEDATA
/s/Martin Pedata Martin A. Pedata, Esq. 120 R. Rich Avenue DeLand, Florida 32720 (386) 748-0941 Telephone [email protected] Florida Bar No.: 745790 EXHIBIT A https://martialartsfraudsandfakes.wordpress.com/2020/08/14/open-letter-to-bret-gordon/ EXHIBIT B https://greysmithinvestigations.blogspot.com/2020/10/that-old-song-and-dance-gerald-j.html EXHIBIT C https://martialartsfraudsandfakes.wordpress.com/2020/09/29/bret-gordon-steven-hatfield-and-how-im-making-better-liars-out-of-frauds/ EXHIBIT D https://martialartsfraudsandfakes.wordpress.com/2020/09/29/bret-gordon-steven-hatfield-and-how-im-making-better-liars-out-of-frauds/ (Yes, Pedata really did include the same article as 2 separate “exhibits”, “C” is the comments section, and “D” is the article itself. And this man is an actual bar-licensed attorney.)
7 Comments
It has recently been brought to my attention that I am not really Harold K. Howard, that I am, in reality, Harold C. Howard, former UFC fighter and convicted felon. Imagine my surprise. I thought I was supposed to be Dale Dugas? Or was it Gerald Greysmith? Or was it Carmen Sandiego? Or did I shoot J.R.? Or did I shoot Greedo first? Or was I Ra's al Ghul? Perhaps I am just a glitch in the matrix. The world may never know. At any rate, Gerald J. let me know about a post by none other than one of the most famous frauds in the world of martial arts – Franklin Wanks Ducks, er, Frank W. Dux. I feel honored. In an ashamed, dirty kinda way. This appears to have originated with Arkham escapee #96530, whose name is similar to Dumbass Witless Gelding (or something like that) who, the only crayon he hadn't already eaten in hand, assumed everything he posted without performing a simple internet search, assumed that wikipedia is a reliable source to confirm said assumptions, and tapped out his mental midden heap onto a keyboard. Frank Dux, fool that he is, doesn't care about trivialities like truth, reality, facts, evidence, etc., so he did the only thing fools know how to do, he ran with it. Without considering the source. https://en.wikipedia.org/wiki/Harold_Howard Let's go down the list, shall we? It's H.K., not H.C. Is it Howard, or is it Hayward? I'm an American, not a Canadian (sorry Canuckleheads). I don't have a black belt in jujutsu. I don't have a black belt in goju ryu. I have never competed. Not in mma, and certainly not in the UFC. I have never attempted to murder anyone, family member or otherwise. I have never been sentenced to a term in any prison. Some of the assumptions made in this largely incoherent blog entry: Somehow, after only weeks of membership and spotty participation, I am now the “leader” of the Bullshit Martial Arts facebook group. Fact Check: FALSE I am not even an administrator of the group, nor do I care to be. I wear wife-beaters and sport a mullet. Fact Check: FALSE I do not wear wife-beaters, nor do I sport a mullet. My preferences tend to short-sleeved t-shirts and buzzcuts. I am prohibited by federal law from owning any firearms. Fact Check: FALSE I fully support the Second Amendment and do not object to firearms ownership, even though I do not personally own one. I have been ordered to supply authorities with a DNA sample. Fact Check: FALSE I have never been ordered by any governmental authority to provide anyone with a DNA sample. Nor have I met any female officers attractive enough to be rewarded with one. So, if I'm not Harold C. Howard, then who am I? My true identity is irrelevant to the discussion. I am not the subject, frauds and their false claims are the subject. I am a private American citizen exercising his right to freedom of the press, granted by God and protected (somewhat) by the Constitution. If someone has any evidence that I am Harold C. Howard, or Dale Dugas, or anyone else, I'd like to see it. And that's that. I did have a good laugh about this, though. Thanks, fools. It's been a running bet/joke at Greysmith Investigations as to just how stupid Bret Gordon could really be. Every time someone says that he couldn't be stupid enough to do X – Bret Gordon, without hesitation, quips “Hold my milkshake”, then proceeds to prove them wrong. It seems pretty clear with this evidence that Bret Gordon has committed not one, but two misdemeanors in his misguided attempts to silence his detractors and protect the fiefdom of fraud created by Steven Hatfield and himself. In their desperate attempt to protect, preserve and distract from their other immoral, unethical and criminal activities, Bret Gordon filed two fraudulent police reports, a misdemeanor in the first degree in Florida. The relevant parts of the statutes read: 837.05 False reports to law enforcement authorities. (1)(a) . . . a person who knowingly gives false information to a law enforcement officer concerning the alleged commission of any crime, commits a misdemeanor of the first degree, punishable as provided in s.775.082 or s.775.083. http://www.leg.state.fl.us/Statutes/index.cfm?App_mode=Display_Statute&URL=0800-0899/0837/Sections/0837.05.html A first degree misdemeanor is punishable by: 775.082 Penalties; applicability of sentencing structures; mandatory minimum sentences for certain re-offenders previously released from prison. (4) A person who has been convicted of a designated misdemeanor may be sentenced as follows: (a) For a misdemeanor of the first degree, by a definite term of imprisonment not exceeding 1 year; (5) Any person who has been convicted of a noncriminal violation may not be sentenced to a term of imprisonment nor to any other punishment more severe than a fine, forfeiture, or other civil penalty, except as provided in chapter 316 or by ordinance of any city or county. (7) This section does not deprive the court of any authority conferred by law to decree a forfeiture of property, suspend or cancel a license, remove a person from office, or impose any other civil penalty. Such a judgment or order may be included in the sentence. http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&Search_String=775.082&URL=0700-0799/0775/Sections/0775.082.html If I am reading and interpreting this correctly, Bret Gordon could face up to 2 years in prison (depending upon whether sentences are served consecutively or concurrently), and/or fines, forfeiture of property, loss of business license (if he has one), and/or any other penalty the court chooses to impose should he be brought up on charges. Just for fun, let's revisit the reports, this time with commentary and opinion. According to the official report, #OCPD20OFF004304 (05), officer Valle met with Bret Gordon, who related the information contained in the report, the text of which reads: “On 11/06/2020 at approximately 11:40 hours, I, Ofc. Omar Valle responded to 290 Capitol Court in reference to a harassment. “Prior to my arrival, Winter Garden Dispatch advised that the complainant wanted to file a report against males that came to his business and started to record him without his consent. Complainant also advised that these subjects posted their conversation from the night prior on social media. The complainant informed that they have been harassing him for approximately a year now. [Working backward, this entire escapade began (for Greysmith Investigations) when we read a defamatory article Gordon had written about a verifiably legitimate martial artist in late April or early May 2020. Since Gordon is incapable of correctly interpreting the hieroglyphic inscriptions on that modern contraption referred to as a “calendar”, that would be only 6 or 7 months, not a year. Though, to be somewhat fair, it probably seemed like MUCH longer to ol' Bretty Boop. The only attention Gordon and Hatfield had received prior to our involvement consisted of 3 people and their blogs. Funny how Gordon and Hatfield ignored others (Probably because he showed up in person and frightened Gordon.) and chose to focus on Dr. Dugas, even being stupid enough to claim that Dugas is Gerald Greysmith, which he is not. (And neither am I.) These blog posts are listed as follows in chronological order: 04/06/20: May the Circle (Jerk) be Unbroken: Part 1 by Lordus Sapiens https://martialartsfraudsandfakes.wordpress.com/2020/04/06/may-the-circle-jerk-be-unbroken-part-1/ 04.08.20: Lies in the Martial Arts by Don Roley http://www.coloradospringsninjutsu.com/Ranting_and_Ravings_2016/Entries/2020/4/8_Lies_in_the_Martial_Arts.html 04/09/20: Doughboys and Fat Ninjas by Barron Shepherd https://combatjudo.blogspot.com/2020/04/doughboys-and-fat-ninjas.html However, this is not the first time Gordon's “sensei” has come under scrutiny. People have been questioning the credibility of Steven Hatfield's claims since 2003, at least. These questions specifically concerned Hatfield's association with , and claims of judo credentials under Jack “Papasan” Stern, who was found to be guilty of committing the fraudulent act of stolen valor. http://www.martialtalk.com/threads/korean-yudo-hapkido-association.8086/ So, the first thing Gordon did was lie to the officer. No big surprise there. And, as pointed out by the officer later in the report, Gordon never once asked Dale or either of his two friends not to record, or to stop recording. Nor is posting the video on social media a violation of any Florida criminal statute. Failing to ask them to stop recording, and failing to ask them not to post said recording on the internet, is not a criminal offense. Complaining about it to the police just makes you look like a whiny little manchid, Karen.] “Upon my arrival, I met with the complainant, identified via FL Drivers License as Bret Michael Gordon. Bret advised that a subject, named Dale Dugas, came to his business in a threatening manner with 2 other unnamed subjects last night. Bret advised he invited Dale to show up to his business to talk about their personal issues on 11/12/2020, but Dale decided to show up unannounced on 11/05/2020 instead. Bret informed that Dale has a facebook group called “Bullshit Martial Arts” where he dedicated a substantial amount of time uploading videos and facebook posts talking about Bret's business. Bret advised that when Dale came in with his friends, he felt threatened and intimidated because the unknown 2 males were bigger. [“Bret informed that Dale “has a facebook group”.” This is another lie Gordon told the officer. Gordon does, or at least should, know that BSMA is NOT “Dale's group”, rather that Dale is, or was, nothing more than a member of that group. Here Gordon claims that “he felt threatened” by Dale and his 2 friends (What? Not “bodyguards”?) because they “were bigger”. But . . . but . . . you're KAISO!!! Kaiso ain't afraid uh Nobody!!! Kaiso's an indisputable MASSUH of mahshul ahts, ain't 'e??? Kaiso coulda whooped all dat ass in grand style, couldn't he? He coulda whooped one wit' his indomitable aiki jiujitsu, another wit' his hyperspeed kempo jiujitsu, then laid out the last one wit' his discombobulating Kodoklown judy chop. They'd never know whut hit 'em. Oh, but that's only when he's sitting in the dark spanking his brick, isn't it? The fevered fantasies of a martial arts wannabe who's never matured past the 16-year-old level he was when he first started his fraudulent career. He only became emboldened well after Dale had left and he felt safe once again. It's easy to be brave from a distance, isn't it Gordon? And, no, you didn't invite Dale to “talk about personal issues”. You challenged him to a physical sparring match to settle your dispute. You were just frightened because you didn't expect him to actually show up, and you were eager to seize upon ANY excuse to call off the event.] “Bret advised that he would like to fill out a police report and press charges for harassment. Bret provided me with numerous videos where Dale posted on his own facebook page (Bullshit Martial Arts) in regards to the credibility of Bret's certificates. Bret and Dale exchanged numerous public posts on facebook in passive aggressive demeanor towards each other and the differences they share. Bret then states online “despite you bailing out twice after demanding I name a time and place for us to step on the mat, I'm going to give you a third opportunity to show what a coward you truly are. Thursday, November 12th at 7:30PM, you are invited to my school. I look forward to this opportunity for us to settle our differences.” [Gordon lied to the officer, then provided him with a copy of the video which proves that he lied. Yes, Bret Gordon really is that stupid. Questioning the credibility of your certificates is not illegal, Gordon. Since you've attracted so much attention to yourself over the past several months, there are quite a number of people questioning your claims of legitimacy. And that number is growing. Making those claims in public obligates you to provide proof to the public.] “On Saturday at 9:06PM Bret writes in facebook messenger: “The rules of our match will be simple. One on one, unarmed. To protect each other legally, we need to be able to claim it is sparring. Therefore, mma gloves will be worn by both of us. That's it. Those are my terms.” “Approximately 2 days ago (11/04/2020) Bret posted on facebook: “Dale Dougas AP, On the 12th, if you show up and things get physical, and I win, I want everything you've ever posted about me taken down. All 33 videos (and counting), and all of your derogatory comments. If you win, I will do the same. Agreed?” “Upon researching the facebook group, I discovered that Bret made a facebook post after the 11/05/2020 incident. After Dale and his friends showed up, Bret went on facebook and said “It should also be clear how little I am bothered by standing there alone in front of Dale two of his friends, even with how hostile he has been online.” On a separate video, where Bret claimed to feel intimidated, I heard Bret saying to Dale and his friends “You are always welcome here” and he never told them to stop recording. [Which is it, Gordon? Either you “felt intimidated”, or it “bothered you little”. You lied to the officer about this as well, and he caught you with your own social media. You really are this stupid. Your credibility is in the toilet, Gordon. Your desperation for adulation has led you to committing crimes now. Is this the first? Never mind, you've been caught telling so many lies, you have no credibility left. Nothing you say can be believed. If you will lie to the police in order to damage someone who has, by your own admission, done you no real harm, how much farther will you go to protect your childish fantasies? How much farther will you go to protect Steven Hatfield's childish fantasies? Personally, I hope you have enough sense to go no further. Stop now before you become Ron Collins' cellmate.] “On facebook, Dale took a screeenshot where he is blatantly videotaping the entire incident. After reviewing these facts, I determined that Bret is not intimidated because he continued to invite and contact Dale despite his claims of Dale being hostile. Based on my investigation, this does not meet the criteria for F.S.S784.048 for below since both Bret and Dale exchanged passive aggressive comments to each other. “Both Bret and Dale agreed to meet up and at the time of the incident (11/05/20) Dale came in to bring his waiver (which was provided by Bret) to attend class on November 12th. “Bret, though he stated to Ocoee Police Department he is harassed and threatened by Dale, states multiple times on public posts calling out Dale and stating he is not scared. “Credible threat” means a threat made with the intent to cause the person who is the target of the threat to reasonably fear for his or her safety. The threat must be against the life of, or a threat to cause bodily injury to, a person. “Harass” means to engage in a course of conduct directed at a specific person that causes substantial emotional distress in such person and serves no legitimate purpose “This report is for informational purposes only. “I have an agency issued body camera that was on and activated during this investigation.” [There it is in plain English for everyone to see and determine for themselves. Bret Gordon lied to a police officer, thereby falsifying an official police report. And, in the interest of disclosure, the video in question can be viewed here: https://www.facebook.com/groups/1702944253268681/permalink/2729764210586675/?__cft__[0]=AZUxnIIiFDpZdDC0SSCNltXstNCWl0BQJemK0tgEMLvapdorzhBBUo03R9hTH6EUWCn5BCbBw_fghj8rVaASQ3l4E3KB7s0D6emEsnAxqMYeNqK24txWhhXyHaARmGUMAbg&__tn__=%2CO%2CP-R That apparently not being enough, another officer had to respond to Bret's butthurt bleating on November 25, 2020, the same day the suit was filed. [According to the narrative supplement to the official report, #OCPD20OFF004304 (05), officer Blake met with Bret Gordon, who related the information contained in the report, the text of which reads: “Information only. “On November 24, 2020, at approximately 1500 hours, I responded to 209 Capitol Court ( TrioMartialArts) in reference to online [threats]. “On arrival, I spoke to the victim, identified as Bret M. Gordon, he stated the following: “since last year, a facebook group called “Bullshit Martial Arts”, which is run by Don Roley out of Colorado has been posting defamatory statements about his business. One member in the group, name Dale Dugas has been posting videos about Gordon's Martial Arts business in Ocoee. Dugas has also posted that he is going to fight Gordon to take his Martial Art title away. [BSMA is not “run by Don Roley”. Roley is an admin on the group page, nothing more. Questioning the validity of Gordon's claims is not defamatory. I don't recall Dr. Dugas ever claiming he was going to take Gordon's “martial art title” away, or what that even means. Perhaps the officer misinterpreted, or perhaps Gordon actually said something this stupid. It's not like this would be unusual.] “Officers completed a report on 11/6, about Dugas coming to Gordon's business in an attempt to intimidate him. Dugas videotpe the whole meeting without Gordon's permission and then posted it on the “Bullshit Martial Arts” grouppage. [An “attempt to intimidate”? Again, is this the officer's misinterpretation, or did Gordon actually say something that stupid?] “On 11/23/2020 Dugas believes Gordon's business partner, Steven Hatfield called Dugas's mother and father and threatened them. I did speak to Steven Hatfield over the phone, he stated he doesn't know Dugas's family's number, and would never call them since they just filed a report to sue Dugas for defamation. [Do I have any evidence that Steven Hatfield, or one of his cronies, called Dr. Dugas' parents and frightened them? No. Do I believe it's possible that he did this, or that one of his cronies did this? Yes. It's only speculation on my part, but if Gordon and/or Hatfield are willing to lie to the police on an official report, it makes me wonder what else they might be capable of doing, especially if they think they're protected somehow. Gordon especially has been known to harass others when it's suited him in the past. His unstable behavior could escalate. We've seen it happen many times with others.] “Dugas called Don Roley and told him about the phone call that Hatfield apparently made to his family. Soon after talking to Dugas, Roley posted a message on the “Bullshit Martial Arts” which states: “Underlying this is how much Steven Hatfield uses Bret Gordon as his bitch. Think about It, Hatfield is in another state when he pulls this type of thing. But he knows that Dale can show up to where Bret teaches and we known where Bret lives. So, he is both depending on Dale not being a monster after his family was threatened and/or he doesn’t care if Bret pats the price for his actions. For that matter, Hatfield brought family into this. His family is obviously not close to Dale, but Bret has to look at his sister and realize that it is only Dale’s restraint that make sure the he won’t have to someday have to identify the body. All of us know Dale won’ t do that, despite what happened to his parents, Dale if you were Bret Gordon, part of you would always wonder if when he looks at his sister if it would be the last time he saw her alive. You just can’t help it in that situation, no matter how the logical part of your brain knows that it would never happen. And Steven Hatfield just doesn’t care if he goes through that fear. Hell, for all we know Hatfield might be considering doing something horrible to Bret Gordon’ s sister Just so he could try to blame us for it. And Bret Gordon has to live with that”. [Was posting this statement unwise? Yes. Bret Gordon will seize upon any opportunity to pervert anything someone says, no matter how innocuous, no matter how obviously non-threatening it should seem, just to make himself look like the victim. His ability to pervert the truth is on par with Bryce Dallas'. And no, that's not a compliment.] “I spoke to Don Roley over the phone about the post. Roley said Dugas told him, Hatfield called Dugas's family, so he made that post. Roley said he did not threaten Gordon's sister with real harm. I told Roley that he was acting like a child and should stop posting “backhanded” threats toward Gordon and his sister. “I then spoke to Dale Duagas, Dugas said he did not tell Roley to make any post directed to Gordon and his sister. Dugas said he doesn't know where Gordon lives. He said Gordon also post mean, and rude things about him, so he would post back. I also told him he needed to grow up and stop acting like a child. I told him Gordon does not want him back at his business again, and if he did show up he would be trespassed. Dugas asked me to tell Gordon not to post mean, or rude things about him. I informed Dugas that Gordon was told to not call or post on their page. He said he will no longer post about Gordon. “Gordon gave me a thumb drive of the post from 11/23 and other video Dugas has posted on his “Bullshit Martial Arts” Page. “I don’t have probable cause for cyber threats or stalking at this time. The thumb drive will be placed into evidence. “I attached a copy of Gordon court filing and a signed paperwork that Dugas dropped off at his business on 11/5/2020. “I have no further information to report.” [This particular officer's tenuous command of the English language, and her unprofessional remarks aside, this report amounted to nothing more than Gordon trying to lay a stronger foundation for the suit he and Hatfield had filed that day. That foundation, however, is laid upon sand. Gordon perjured himself and, since he speaks for Hatfield, he has as well perjured Hatfield by proxy. This does not bode well for your case, boys. Which is probably why you waited until February 4th to serve Dr. Dugas with a summons, isn't it?] Bottom Line: Bret Gordon and Steven Hatfield are frauds. They regularly alter the stories they tell about themselves because they are liars. Their constant lying, obfuscation and concealment have thoroughly destroyed their own credibility. Nothing they claim should be believed. Any martial artist who values their own integrity, who doesn't want their own reputation tarnished by association with these frauds, should distance themselves from these two immediately. Speaking of associates, if any of them want to discuss their association with frauds Steven Hatfield and Bret Gordon, they can email either myself or Gerald Greysmith (neither of which are Dr. Dale Dugas) anytime. How about it, guys? They haven't been “attacked by internet trolls”. Their dubious claims were questioned, and they attacked their critics. They have brought about their downfall with their own words and actions. They have no business being involved in martial arts.
Maybe they can go build some solar panels and contribute something useful to society for a change. That's my opinion, anyway. Bret Gordon and Steven Hatfield have gone to great lengths to construct a network of fraud and deceit for over a decade. They have created a number of shell organizations and sold worthless memberships and certifications. They have lied about their own experience and qualifications in several different styles of martial arts. And they have lied about having received authority for one of their arts, American Jidokwan (americanjidokwan.com), from a fictional Japanese master allegedly named Hasaka Yutashi which, according to input we have received from people who actually speak the language, is not a real Japanese name. One might wonder why so much effort is being put into the construction of such an elaborate, fraudulent scheme. One might wonder why they haven't just put in the effort to be legitimate martial artists, thus eliminating the necessity of lying to everyone every day. One could only speculate that they wanted the immediate gratification of proclaiming themselves authorities, without experiencing the effort that is necessary to actually become an authority. Their latest effort to continue the charade has been to file suit against Dr. Dale Dugas, alleging defamation of their persons and monetary damages to their businesses. In his video testimony, Steven Hatfield stated: “. . . with the help of Martin Pedata, this is something that has been, we've been working on for awhile.” This suit was filed on November 25, 2020. Gordon and Hatfield had the Summons, dated January 21, 2021, yet they waited a little more than 2 weeks to have Dr. Dugas served. Why? What was the delay? If they've got such a good case, and they've retained an attorney, and they've filed suit, why not get this ball rolling right away so they can silence their detractors and collect some cash? At any rate, the Summons has been served, and now we wait to see other events unfold. On 11.06.2020 at 12:47:12PM Eastern time, Ocoee, Florida police officer Omar Valle, ID#1721, paid a visit to Richard Hackworth's American Dragon Martial Arts located at 209 Capitol Court in response to a complaint from Bret Gordon. The alleged incident Bret Gordon wanted to complain about occurred the previous day, 11.05.20 at approximately 6:00PM. According to the official report, #OCPD20OFF004304 (05), officer Valle met with Bret Gordon, who related the information contained in the report, the text of which reads: “On 11/06/2020 at approximately 11:40 hours, I, Ofc. Omar Valle responded to 290 Capitol Court in reference to a harassment. “Prior to my arrival, Winter Garden Dispatch advised that the complainant wanted to file a report against males that came to his business and started to record him without his consent. Complainant also advised that these subjects posted their conversation from the night prior on social media. The complainant informed that they have been harassing him for approximately a year now. "Upon my arrival, I met with the complainant, identified via FL Drivers License as Bret Michael Gordon. Bret advised that a subject, named Dale Dugas, came to his business in a threatening manner with 2 other unnamed subjects last night. Bret advised he invited Dale to show up to his business to talk about their personal issues on 11/12/2020, but Dale decided to show up unannounced on 11/05/2020 instead. Bret informed that Dale has a facebook group called “Bullshit Martial Arts” where he dedicated a substantial amount of time uploading videos and facebook posts talking about Bret's business. Bret advised that when Dale came in with his friends, he felt threatened and intimidated because the unknown 2 males were bigger. “Bret advised that he would like to fill out a police report and press charges for harassment. Bret provided me with numerous videos where Dale posted on his own facebook page (Bullshit Martial Arts) in regards to the credibility of Bret's certificates. Bret and Dale exchanged numerous public posts on facebook in passive aggressive demeanor towards each other and the differences they share. Bret then states online “despite you bailing out twice after demanding I name a time and place for us to step on the mat, I'm going to give you a third opportunity to show what a coward you truly are. Thursday, November 12th at 7:30PM, you are invited to my school. I look forward to this opportunity for us to settle our differences.” “On Saturday at 9:06PM Bret writes in facebook messenger: “The rules of our match will be simple. One on one, unarmed. To protect each other legally, we need to be able to claim it is sparring. Therefore, mma gloves will be worn by both of us. That's it. Those are my terms.” “Approximately 2 days ago (11/04/2020) Bret posted on facebook: “Dale Dougas AP, On the 12th, if you show up and things get physical, and I win, I want everything you've ever posted about me taken down. All 33 videos (and counting), and all of your derogatory comments. If you win, I will do the same. Agreed?” “Upon researching the facebook group, I discovered that Bret made a facebook post after the 11/05/2020 incident. After Dale and his friends showed up, Bret went on facebook and said “It should also be clear how little I am bothered by standing there alone in front of Dale two of his friends, even with how hostile he has been online.” On a separate video, where Bret claimed to feel intimidated, I heard Bret saying to Dale and his friends “You are always welcome here” and he never told them to stop recording. “On facebook, Dale took a screeenshot where he is blatantly videotaping the entire incident. After reviewing these facts, I determined that Bret is not intimidated because he continued to invite and contact Dale despite his claims of Dale being hostile. Based on my investigation, this does not meet the criteria for F.S.S784.048 for below since both Bret and Dale exchanged passive aggressive comments to each other. “Both Bret and Dale agreed to meet up and at the time of the incident (11/05/20) Dale came in to bring his waiver (which was provided by Bret) to attend class on November 12th. “Bret, though he stated to Ocoee Police Department he is harassed and threatened by Dale, states multiple times on public posts calling out Dale and stating he is not scared. “Credible threat” means a threat made with the intent to cause the person who is the target of the threat to reasonably fear for his or her safety. The threat must be against the life of, or a threat to cause bodily injury to, a person. “Harass” means to engage in a course of conduct directed at a specific person that causes substantial emotional distress in such person and serves no legitimate purpose “This report is for informational purposes only. “I have an agency issued body camera that was on and activated during this investigation.” That apparently not being enough, another officer had to respond to Bret's butthurt bleating on November 24, 2020, the same day the suit was filed. On 11.24.2020 at approximately 3:00PM Eastern time, Ocoee, Florida police officer Trista Blake, ID#1163, paid a visit to Trio Martial Arts located at 209 Capitol Court in response to a complaint of online threats from Bret Gordon. The alleged incident Bret Gordon wanted to complain about occurred the previous day, 11.05.20 at approximately 6:00PM.
According to the narrative supplement to the official report, #OCPD20OFF004304 (05), officer Blake met with Bret Gordon, who related the information contained in the report, the text of which reads: "Information only. “On November 24, 2020, at approximately 1500 hours, I responded to 209 Capitol Court ( TrioMartialArts) in reference to online [threats]. “On arrival, I spoke to the victim, identified as Bret M. Gordon, he stated the following: “since last year, a facebook group called “Bullshit Martial Arts”, which is run by Don Roley out of Colorado has been posting defamatory statements about his business. One member in the group, name Dale Dugas has been posting videos about Gordon's Martial Arts business in Ocoee. Dugas has also posted that he is going to fight Gordon to take his Martial Art title away. “Officers completed a report on 11/6, about Dugas coming to Gordon's business in an attempt to intimidate him. Dugas videotaped the whole meeting without Gordon's permission and then posted it on the “Bullshit Martial Arts” grouppage. “On 11/23/2020 Dugas believes Gordon's business partner, Steven Hatfield called Dugas's mother and father and threatened them. I did speak to Steven Hatfield over the phone, he stated he doesn't know Dugas's family's number, and would never call them since they just filed a report to sue Dugas for defamation. “Dugas called Don Roley and told him about the phone call that Hatfield apparently made to his family. Soon after talking to Dugas, Roley posted a message on the “Bullshit Martial Arts” which states: “Underlying this is how much Steven Hatfield uses Bret Gordon as his bitch. Think about It, Hatfield is in another state when he pulls this type of thing. But he knows that Dale can show up to where Bret teaches and we known where Bret lives. So, he is both depending on Dale not being a monster after his family was threatened and/or he doesn’t care if Bret pats the price for his actions. For that matter, Hatfield brought family into this. His family is obviously not close to Dale, but Bret has to look at his sister and realize that it is only Dale’s restraint that make sure the he won’t have to someday have to identify the body. All of us know Dale won’ t do that, despite what happened to his parents, Dale if you were Bret Gordon, part of you would always wonder if when he looks at his sister if it would be the last time he saw her alive. You just can’t help it in that situation, no matter how the logical part of your brain knows that it would never happen. And Steven Hatfield just doesn’t care if he goes through that fear. Hell, for all we know Hatfield might be considering doing something horrible to Bret Gordon’ s sister Just so he could try to blame us for it. And Bret Gordon has to live with that”. “I spoke to Don Roley over the phone about the post. Roley said Dugas told him, Hatfield called Dugas's family, so he made that post. Roley said he did not threaten Gordon's sister with real harm. I told Roley that he was acting like a child and should stop posting “backhanded” threats toward Gordon and his sister. “I then spoke to Dale Duagas, Dugas said he did not tell Roley to make any post directed to Gordon and his sister. Dugas said he doesn't know where Gordon lives. He said Gordon also post mean, and rude things about him, so he would post back. I also tole him he needed to grow up and stop acting like a child. I told him Gordon does not want him back at his business again, and if he did show up he would be trespassed. Dugas asked me to tell Gordon not to post mean, or rude things about him. I informed Dugas that Gordon was told to not call or post on their page. He said he will no longer post about Gordon. “Gordon gave me a thumb drive of the post from 11/23 and other video Dugas has posted on his “BullshitMartial Arts” Page. “I don’t have probable cause for cyber threats or stalking at this time. The thumb drive will be placed into evidence. “I attached a copy of Gordon court filing and a signed paperwork that Dugas dropped off at his business on 11/5/2020. “I have no further information to report.” Here we have evidence of Bret Gordon making not one, but two false police reports which, according to Florida statute, is a misdemeanor. The relevant part of the statute reads: 837.05 False reports to law enforcement authorities. (1)(a) . . . a person who knowingly gives false information to a law enforcement officer concerning the alleged commission of any crime, commits a misdemeanor of the first degree, punishable as provided in s.775.082 or s.775.083. In Part Two, opinion and commentary. Why are attorneys so despised? In part, because of actions like this. Recently, a complaint against attorney Martin Pedata, Florida bar #745790, was filed by Dr. Dale Dugas with the Florida Bar Association. The nature of the complaint was in regard to Martin Pedata's unethical actions as representative for the plaintiffs in the case of Gordon and Hatfield v Dugas. https://www.facebook.com/martin.pedata On November 24, 2010, Bret Gordon and Steven Hatfield, represented by attorney Martin Pedata, filed suit against Dr. Dale Dugas, alleging defamation against themselves and their businesses. According to Steven Hatfield, Martin Pedata advised him to post a video on social media to announce and discuss the suit. This was also posted on a blog run by Bret Gordon. The relevant part of the transcript, in which Hatfield states that Pedata had recommended that he post a video, reads: “It's 2020-CA-001851, and the Complaint was actually provided and written by our attorney, who is Martin Pedata, and he has provided us with more than enough help to get everything taken care of that needs to be taken care of and addressed. “I normally don't even speak out on this crap, but my attorney did suggest that I make a video and kind of let everybody know what's going on . . . “. . . I just wanted to be clear that, y'know, luckily, with the help of Martin Pedata, this is something that has been, we've been working on for awhile.” You can read the entire transcript here. According to the Florida Bar Association's website, the General Principles of their Guidelines for Professional Conduct state that an attorney should (in relevant part): 1) strive to uphold the honor and dignity of the profession. 2) be courteous and civil in all professional dealings with other persons. Whether orally or in writing, lawyers should avoid vulgar language, disparaging personal remarks, or acrimony toward other counsel, parties, or witnesses. [acrimony meaning bitterness or sharpness of manner, speech, temper, etc. https://www.thefreedictionary.com/acrimony] In brief, attorneys are supposed to conduct themselves in a dignified and professional manner, and refrain from making unprofessional and disparaging remarks, at least while representing their clients. Martin Pedata seems to have skipped over this section. On Steven Hatfield and Bret Gordon's website, Gordon wrote the previously referenced blog entry featuring the video posted by Steven Hatfield, which Martin Pedata responded to by posting a comment. [Note that comments must be approved by Bret Gordon in order to appear on the blog.] The part of the comment relevant to Dr. Dugas reads: “Martin 11/25/2020 12:51:15 pm “Dale Dugas is a coward. Him showing up to your school unannounced with bodyguards was a ploy to avoid fighting. He knew by doing that he would screw up the set upon time to spar. All he had to do was wait a few more days and the fight would have happened.” I don't know how you might interpret this, but referring to someone as “a coward” on a publicly available forum, someone who is the opposing party to the clients you are representing in a suit, doesn't seem to be adhering very well to the Professional Guidelines set forth by the Florida Bar Association. Nor did it seem very ethical or professional to Dr. Dugas, and the complaint was filed for this reason. This is not the only ethically questionable behavior that Martin Pedata has seen fit to indulge. Looking into Steven Hatfield and Bret Gordon's numerous websites and organizations reveals a relationship that goes far beyond an average client-attorney association. Martin Pedata is featured as the “Director of Operations” for Hatfield and Gordon's USAMA organization. http://www.join-usama.com/martin-pedata.html
Among the many, many, many, many, MANY martial arts that Hatfield and Gordon claim to have mastered well enough to become not only instructors, but high-ranking instructors at that, neither one has ever mentioned having any proficiency whatsoever in Krav Maga. This begs the question – If you have no experience in a specific martial art, certainly not the level necessary to competently evaluate anyone's proficiency, how could you possibly recognize someone's rank in said art, issue them a certificate stating as much, and include them in your organization? Sounds pretty dishonest, almost like something a fraud would do, doesn't it? And, if you're an attorney (or anyone else for that matter), why would you accept, or even seek out, rank recognition from someone who has a history of making dubious claims about their own background, who can't honestly evaluate your skill or proficiency, someone with no experience in your art, someone whose “rank recognition” holds no authority whatsoever? Sounds pretty dishonest, almost like something a fraud would do, doesn't it? But then, we are talking about an attorney, aren't we? It would seem that Pedata has a vested fiduciary, and even a personal interest in the favorable outcome of this case, would it not? Wouldn't an ethical, moral attorney (I know, I know!) recuse himself from involvement due to the conflict of interest? This doesn't seem like the type of behavior someone who touts himself as a “Follower of Christ, Pastor”, should engage in, does it? I wonder what the Bible has to say about lying?
Proverbs 19:5 - A false witness shall not be unpunished, and [he that] speaketh lies shall not escape. Proverbs 19:9 - A false witness shall not be unpunished, and [he that] speaketh lies shall perish. Exodus 20:16 - Thou shalt not bear false witness against thy neighbour. Ephesians 4:25 - Wherefore putting away lying, speak every man truth with his neighbour: for we are members one of another. In light of Martin Pedata's past conduct, conduct that could be considered questionable, unethical, immoral and possibly even criminal, what was the result of the complaint filed against him by Dr. Dale Dugas? Predictably, they circled the wagons to defend their scumrade. On December 15, 2020, the Florida Bar Association responded to Dr. Dugas after conducting their own review of the complaint. Their conclusion was: “Your inquiry concerning [Martin Pedata] has been referred to me for my review. “Your complaint raises issues which are civil in nature and must be addressed to the appropriate tribunal, not the Bar. “After careful consideration, I conclude that the matters referenced in your inquiry do not constitute violations of the Rules of Professional Conduct, and accordingly, your inquiry does not fall within the purview of the grievance system framework. Consequently, I have closed our record in this matter effective December 14, 2020. Please be advised that my action does not preclude you from consulting with private counsel, nor does it preclude you from exercising any legal remedy which may be available to you. “Pursuant to the Bar's records retention schedule, the computer record and file will be disposed of one year from the date of closing.” Sincerely William W. Wilhelm Attorney Consumer Assistance Program ACAP Hotline 866-352-0707” To summarize – scumbag attorneys (Triple Dub in particular) decided not to reprimand another scumbag attorney for violation of their Professional Guidelines because their Professional Guidelines don't apply to scumbag attorneys if other scumbag attorneys don't want them to. (That's my interpretation, anyway.) Pursuant to Under the Gi – with H.K.'s records retention schedule, this information will remain available to the public indefinitely. On Thursday, February 4, 2021, Steven Hatfield, Bret Gordon and Martin Pedata proved the depths of their stupidity by providing evidence in the form of public record. A Summons was served upon Dr. Dale Dugas at his clinic. Next will probably come the Answer and Counterclaim as Dr. Dugas defends himself from the asinine allegations of defamation and civil conspiracy.
More details as they become available. |
AuthorHarold (HK) Hayward, retired, enjoying life Archives
February 2021
Categories |