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IN THE CIRCUIT COURT FOR CHARLES COUNTY, MARYLAND

Elihu Eli El Waldorf, MD Plaintiff, vs. Civil No. ____________________________

Anonymous; Publisher of Maryland Politics Watch AND Google, Inc.; Provider 1600 Amphitheatre Parkway Mountain View, CA 94043 AND Adam Pagnucco; Contributor Chief of Staff for Montgomery County Councilman Hans Riemer AND Heather R. Mizeur; Lobbyist 7200 Maple Ave. Takoma Park, MD 20912 AND Tom Hucker; Delegate 10 Stockton Road Silver Spring, MD 20901 AND Sheila E. Hixson; Lobbyist 1008 Broadmore Circle Silver Spring MD 20904 Defendants. COMPLAINT Elihu E. El (Plaintiff), represented by ___________________ attorney-at-law, does hereby bring the complaint for legal and equitable relief and subpoena against the Defendants Anonymous, Google, Inc., Adam Pagnucco, Heather R. Mizeur, Tom Hucker, & Sheila E. Hixson for the following reasons: JURISDICTION This suit is brought and jurisdiction lies pursuant to Md. Code 6-102(a) because the Plaintiff is a resident of Maryland. This suit is a legal action for subpoena, damages, and relief against the Defendants.

Venue is proper under Md. Code 6-201(a) because the Plaintiff lives in Charles County, Maryland. PARTIES Tom Hucker should be or is aware of the published blog. Tom Hucker competed against the Plaintiff during the 2010 election and was re-elected to the Maryland House of Delegates representing the 20th Legislative District of Maryland. Tom Hucker was re-elected to the Maryland House of Delegates representing the 20th Legislative District of Maryland. Tom Hucker's failure to act was performed knowingly, recklessly, and intentionally, including incitement for other to act, which caused harm to the plaintiff Tom Hucker shows a willful disregard for the "Public Good" in order to advance personal interests. Tom Hucker's failure to act supererogatory is blameworthy and wrong; therefore, lends itself to judicial criticism. Tom Hucker's failure to act as a duty-bound officer of The State of Maryland created an unreasonable risk to the Plaintiff; therefore, lends itself to institutionalized sanction. ^^^^^^^^^^^^ Heather R. Mizeur should be or is aware of the published blog. Heather R. Mizeur competed against the Plaintiff during the 2010 election and was re-elected to the Maryland House of Delegates representing the 20th Legislative District of Maryland. Heather R. Mizeur was re-elected to the Maryland House of Delegates representing the 20th Legislative District of Maryland. Heather R. Mizeur's failure to act was performed knowingly, recklessly, and intentionally, including incitement for other to act, which caused harm to the plaintiff Heather R. Mizeur shows a willful disregard for the "Public Good" in order to advance personal interests. Heather R. Mizeur's failure to act supererogatory is blameworthy and wrong; therefore, lends itself to judicial criticism.

Heather R. Mizeur's failure to act as a duty-bound officer of The State of Maryland created an unreasonable risk to the Plaintiff; therefore, lends itself to institutionalized sanction. ^^^^^^^^^^^^ Sheila E. Hixson should be or is aware of the published blog. Sheila E. Hixson competed against the Plaintiff during the 2010 election and was re-elected to the Maryland House of Delegates representing the 20th Legislative District of Maryland. Sheila E. Hixson was re-elected to the Maryland House of Delegates representing the 20th Legislative District of Maryland. Sheila E. Hixson's failure to act was performed knowingly, recklessly, and intentionally, including incitement for other to act, which caused harm to the plaintiff Sheila E. Hixson shows a willful disregard for the "Public Good" in order to advance personal interests. Sheila E. Hixson's failure to act supererogatory is blameworthy and wrong; therefore, lends itself to judicial criticism. Sheila E. Hixson's failure to act as a duty-bound officer of The State of Maryland created an unreasonable risk to the Plaintiff; therefore, lends itself to institutionalized sanction. ^^^^^^^^^^^^ Anonymous is responsible for process of production and dissemination of literature and/or information in the blog as well as the activity of making information available for public view. Anonymous The contact of the publisher of the blog (article) is unknown. The identities of anonymous internet poster are usually known only by the third party website or internet service provider (ISP), which is Google, Inc through which the statements were made, and Google, Inc declines to disclose the publishers identity in the absence of a court order compelling them to do so. Anonymous has issued the defaming material to the public, or a section of the public. Anonymous is a subscriber of Googles Blogspot and information content provider. ^^^^^^^^^^^^

Adam Pagnucco is the contributor, author, or writer of the blog instrumental in the creation of the character defamation in question. Adam Pagnucco essentially worked for the Anonymous blog poster, or publisher. Adam Pagnucco At time of initial posting of the blog, by the publisher, Adam Pagnucco did not hold a chief-of-staff position. Soon after the election results, Adam Pagnucco was awarded the position of Chief of Staff for Montgomery County Councilman Hans Riemer. Councilman Hans Riemer is a longtime resident of the 20th Legislative District of Maryland. No professional politician would admit that he and/or she had promised a blogger a high ranking position within their own district if the blogger could successfully defame and ruin their opponents chance of winning an election. ^^^^^^^^^^^^ Google is the Internet Service Provider (ISP) or "interactive computer service". Name, address, and other information of the anonymous publisher is subject to state and federal laws. In accordance with those laws, it is Google's policy to only provide subscriber information pursuant to a valid third party subpoena or other appropriate legal process. Google is unable to accept service by mail or any form of electronic service. Civil subpoenas to Google may be served at the following address: Attention: Custodian of Records Google, Inc. 1600 Amphitheatre Parkway Mountain View, CA 94043

ASSERTION 1. The Internet is the first thing that humanity has built that humanity doesn't understand, the largest experiment in anarchy that we have ever had. Eric Schmidt, the

executive chairman of Google and a longtime friend and competitor of Steve Jobs.

2. The First Amendment of the United States Constitution guarantees the freedom of expression and the right to express our opinions and ideas. 3. As much as a person has the right to freely express on the Internet or any other forum, nobody has a Constitutional Right to defame the character of another. 4. There are only approximately 100,000 residents living in the 20th Legislative District of Maryland, without request and/or intent, the Defendants article could be accessed by over 6,000,000,000 people. 5. There is NO reason that the Defendants article should be granted to anyone without either implicit or explicit request for such material. 6. For instance, if a ten year old girl living in Australia performs an internet search on El Eli, or anyone living or not living in the United States, the Defendants article and/or article title appears in the search result. 7. The Defendants do not simply refer to the case numbers, only disclose the names of the involved parties limit the scope of the article, avoid misleading phrases and/or words, nor set a time limit that the general public could access the article. 8. The reckless action of the publisher places the Plaintiff at unwarranted harm of hostile engagement by radical & extremist advocates of domestic violence. 9. The Defendants show reckless disregard for the fact that unreasonable citizens and radical extremists would find the article and possibly cause injury to the Plaintiff. This is an extremist form of Cyberbullying. 10. The article is within the realm and purview of common mankind and defames character on the face of it, or prima facie. 11. The Defendants have committed willful and malicious invasion of privacy. 12. The published testimony involving the matter within the article is unfounded and not true.

13. The Defendants is reckless not to express that the testimony is hearsay and has not been proven as true. 14. The Defendants do not have explicit permission to publish and/or re-publish unsubstantiated testimony. 15. The Plaintiff has cause of action, because the published article has a lasting negative impact on the Plaintiffs quality-of-life. 16. A jury would reasonably find for the Plaintiff since there is no expert testimony, nor activity that a common citizen would ever consider abusive or newsworthy. 17. At face value, any common citizen would interpret the blog title or record as criminal record. 18. In the matter expressed with the article, the Plaintiff has NEVER hit, thrown items, cursed, threatened, struck, forced duress upon, nor caused harm to a spouse. 19. There exists no place in the record or the published article that clearly defines the allegations. 20. There exists no place in the record or the published article that states that the Plaintiff has been found guilty of any crime. 21. Due to the original unfairness and injustice, the Plaintiff lived homeless on the streets of Montgomery County. 22. The substance of the article is not newsworthy. 23. The Defendants have never published an article covering a similar circumstance. 24. The Defendants willfully framed this article to defame the Plaintiffs character. 25. The Defendants willfully framed the article in a manner that reflects that the Defendants have shown little regard to the public interests. 26. The Defendants have intentionally and willfully left out testimony in order to mislead the general public. 27. There has never existed a perceived threat to the public. 28. For the last 22 years, the Plaintiff continues to serve his county and state as a soldier, law enforcement officer, grassroots community volunteer/advocate, or government contractor.

29. Out of continued humble service to God and fellow members of the community, the Plaintiff ran for public office based on a sincere calling and apparent societal need. 30. The Plaintiff has NEVER done anything to violate the public trust nor shame his family. 31. The Plaintiff would NEVER do anything to violate the public trust nor shame his family. 32. The Plaintiffs 15 year-old daughter has been told by her step-father that the Plaintiff is an abuser. 33. Although the Plaintiff has called his daughter just about every day for the last two months, the daughter refuses to answer the telephone, the voicemails are full not allowing the Plaintiff to leave her a message, and daughter refuses to call the Plaintiff. 34. Destroying people lives just to win an election is immoral, shameful, and disgraceful. 35. The Plaintiff does not know who to blame worse; the unconscionable politicians or the voters who keep them in office. 36. As a result of the Defendants publication, the Plaintiffs daughter, relatives, friends, co-workers, and colleagues in the Plaintiffs field of employment have read the maliciously misleading blog that is causing them to scorn and abandon the Plaintiff. 37. Many prospective employers use the internet searching tool Google to perform searches on perspective employees. 38. No prospective employer would ever openly state for record that they would not hire the Plaintiff due to the content of the Defendants article. 39. By the maliciously misleading article remaining on the Defendants blog, this greatly impedes the Plaintiffs ability for greater career opportunities and/or future employment. 40. By conceding the total truth of facts of the matter, the public disclosure of the private and unfounded statements humiliates the Plaintiff and exposes him to continuous contempt and ridicule and the subject matter of the article is neither noteworthy nor newsworthy. 41. Therefore, there is a conflict between the right to privacy and the freedom of the press.

42. Although the matter is available for public record upon explicit requests, the Defendants disseminates the information in a manner that maliciously and purposefully defames the Plaintiffs character and causes harm to the Plaintiff. 43. The incident is not newsworthy based on the lack of social value of the actual facts, allegations, and lack of public interests. 44. The method that most professional politicians use to win elections is to run Cyberbullying campaigns against their opponents. The reason why we do have comprehensive Cyberbullying laws is because it is impossible to make laws that limit the wrong doing to K through 12. It's like saying that stealing is wrong when committed against a minor, but is OK when stealing from an adult. 45. Stealing is WRONG when being committed against people of all age groups. Cyberbullying is WRONG when being committed against people of all age groups. 46. Politicians often use Cyberbullying and character defamation as a means of winning elections. Allowing politicians to write Cyberbullying, slander, and defamation laws is just like allowing a career criminal thief to write burglary and robbery laws. 47. The article is full of lies, falsehood, and embellishment in the form of hearsay. 48. Currently there exist certain marginalized groups of people who lack a unified grassroots voice that would sustain adequate media representation. This is why certain American demographics continuously lead in every negative statistic. Those of us who understand Social Theory understand the true cause of our recession. The shameful actions of the professional politicians are NOT readily disclosed to the public and are the true causes of misfortune, untraditional crime waves, school-aged children living in fear, grief in local communities, and the list continues on and on. Unaccountable political framing by professional politicians, of people who look like me, is the root cause of misguided youth flash mobbing our local convenient stores, desperate people stealing our copper and air conditioning units directly from our homes, brazen home break-ins that are occurring in our

neighborhoods, , just so professional politicians {with help from their apparent cronies} could continue to hurt those less fortunate in order to stay in office. 49. No human-being of any religion, gender identity, race, age, disability, ethnic background, skin color, socio-economic status, genetic makeup, health condition, level of education, veteran status, nationality, marital status, language, or sexual orientation deserve what these Defendants are doing.

PRAYER FOR DECLARATORY RELIEF Plaintiff prays that the Court declare that Defendants did act in malice and bad faith, did cause harm to the Plaintiff, and did tortuously violate the rights of the Plaintiff.

JURY DEMAND Pursuant to Rule 2-325 of the Maryland Rules of Civil Procedures, Plaintiff hereby makes a demand for trial by jury of all issues so triable.

_________________________________ Attorney Last, First Attorney contact information

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