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
David
2/25/2021 11:46:48 am
Really seems like this is a witch hunt. No attorney worth their salt would allow the 12 "John Does" who are yet to be determined. If they are yet to be determined common sense tells you Gordon and Hatfield haven't picked them yet. Please, please, please let the Judge dismiss this while he rips the "plantiffs" a new one
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Jonn Lilyea
3/17/2023 05:47:35 pm
Hmmm ? I haven't seen anybody filling in anybody pertaining to the old-time kung fu bearded mantis Dale Dugas and his legal beagle accomplices hereon.
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Purple Heart Parachutist
3/24/2023 05:42:34 am
SORRY DAVID, Nothing is thrown out by the Judge, but the Defendant Dugas (et.al. John Does) has admitted to destroying the victim Plaintiffs' evidences of the alleged civil conspiracy from the Courts scrutiny in Americas most important (relevant) mixed martial arts lawsuit. Mixed Martial Arts personalities across the board are about to be affected in the iron palm hands of Dale Dugas' mouth-boxing. PAY CLOSE ATTENTION DAVID.
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7/29/2023 03:26:42 pm
David, David, David, NO DISMISSING SHIT or anybody. Here is how this (these) "John Does' bull shit really works. Ccheck with a real lawyer and NOT martial arts trolls on the internet.
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3/17/2023 05:44:28 pm
Hmmm ? I haven't seen anybody filling in anybody pertaining to the old-time kung fu bearded mantis Dale Dugas and his legal beagle accomplices hereon.
Reply
5/25/2023 04:28:41 pm
Dale Dugas is nothing but a cowardly fake martial artist who never backs up his words.
Reply
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AuthorHarold (HK) Hayward, retired, enjoying life Archives
February 2021
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