Page 1 FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
NYSCEF DOC. NO.
INDEX NO. 609677/RECEIVED NYSCEF: 04/10/2018Page 2 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
qYSCEF
DOC.
NYSCEF
DOC. NO.
NO.
SUPREME
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
COURT
COUNTY
OF THE
OF NEW
STATE
YORK
OF NASSAU
X
E. FRANK
JAMIE
AMENDED
Plaintiff,
VERIFIED
COMPLAINT
-against-
CARY
WEISS
MICHAEL
and
INDEX
DONNELLY
H.
e endants.
DATE
NUMBER:
609677/
OF OR.IGINAL
FILING:
12/26/
X
CARY
WEISS
and
PERSONNEL
INFINITE
INC.
SERVICES,
Counterclaim
Plaintiffs,
Counterclaim
Defendant
-against-
JAMIE
E. FRANK
X
To
the
above-named
JAMIE
Plaintiff,
CARY
WEISS
Defendants:
E. FRANK,
Pro-se
MICHAEL
and
as and
for
his Amended
H. DONNELLY
hereby
NATURE
1.
This
action
RELIEF
COMPENSATORY
is for
to redress
slander
in this
action
against
Defendants
CLAIMS
DAMAGES
PUNITIVE
DAMAGES,
to wit:
Complaint
as follows:
THE
OF
MONEY
of defamation,
acts
Verified
alleges
and
libel
per se committed
and
by the
INJUNCTIVE
Defendants
against
the
Plaintiff.
2.
Defendants'
to cause,
the
professional
unlawful
conduct
Plaintiff
disgrace,
and
personal
was
knowing,
humiliation
and
shame
and severe
reputations,
willful
malicious,
throughout
mental
4.
This
court
has jurisdiction
over
section
in that
he resides
against
the
Plaintiff
with
This
court
pursuant
were
5.
Venue
6.
The
has jurisdiction
to CPLR
directed
against
is proper
Supreme
jurisdiction
section
in Nassau
Court
trial
and/or
conducts
intent
over
the
damage
he resides
with
County
because
within
in the
MICHAEL
the
and/or
intent
of unlimited
H.
original
permanent
and emotional
(hereinafter
and
State
and
harm
continues
to his
distress.
resides
the
acts
of New
were
to CPLR
directed
York.
within
in the
in the County
jurisdiction
committed
(hereinafter
business
damage
pursuant
"Weiss")
DONNELLY
conducts
of causing
the Plaintiff
has caused,
VENUE
WEISS
business
Defendant
in that
court
CARY
of causing
Plaintiff
is the trial
of the other
Defendant
the
the
the
which
the world,
anguish
AND
JURISDICTION
3.
and wanton,
and
State
"Donnelly")
the
of New
acts
committed
York.
of Nassau.
and the amount
sought
exceeds
the
courts.
PARTIES
7.
Plaintiff
Jan1ie
E. Frank
is a resident
of the County
of Nassau,
an attorney
in good
standing
in the
State
of NevPage 3 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
TYSCEF
DOC.
NYSCEF
DOC. NO.
NO.
York
and
8.
Weiss
9.
Upon
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
resides
and conducts
is a resident
of the
information
and
information
and
and
businesses
of New
State
belief
owns
Weiss
York
at 8 Haven
at 2 West
residing
maintains
Lane,
an office
and
NY
Levittown,
6d'
Apt
Street,
and owns
conducts
1 1756.
1F, New
NY
York,
1001 1.
in the State
businesses
of New
York.
10.
Upon
Surfside,
1 1.
Upon
12.
information
Upon
information
13.
Upon
14.
Donnelly
NY
Aventura,
North
belief,
10538-and
Suite
of the
Miami
is a resident
Beach,
on May
Beginning
of Weiss
for
the
suits
and
sale
of the
is an attorney
Donnelly
and
New
conducts
new
16.
business,
employees
represented
E Frank,
Rita
executor
Maurice
trusts,
In response
to a motion
of Maurice
Paleschuck
Paleschuck
20.
repeats
On December
(yves:.ri
offre
and
said
made
matter
ort.com)
at
residing
at 17 Serpentine
residing
regarding
State
ofNew
State
York,
Inc.
and
Trail,
York.
ofNew
to wit:
York,
the Plaintiff.
and
A copy
CPA
at that
he took
of the Rita
was
the
of
suits
and
with
two
potential
banks,
with
working
for
closing
highest
and
offers
levels
capability
defamatory
an adversarial
of that
F. Paleschuck
disqualified
C. Reilly
1 through
post
of
for
the
position
to Jamie
and Maurice
and
dated
from
representation
December
200¹, 2016.
WEISS
post
the sale
time.
ACTION
in paragraphs
that
15d', 2015.
subsequently
Margaret
and
using
Defendant
December
and
agreement
of the
SE AGAINST
set forth
of a new
conducted
in which
evaluation
negotiations
knowledge
Judge
OF
by and
on behalf
services
against
significant
Trustee
Donnelly
defend
sheets,
were
on or about
Court
a false
term
legal
included:
with
matter
and
various
services
of a purchase
quality,
CAUSE
PER
These
his company
satisfaction
E. Frank,
performed
the hiring
of
of Surrogate
published
ofNew
recommend
commencing
the allegations
Weiss
in the
prepared
F. Paleschuck
by Jamie
by the order
realleges
15d',
York;
of documents
and
level
FIRST
Plaintiff
of Florida,
ofNew
plaintiff
intent
in an estate
LIBEL
19.
State
standing
and the writing
Weiss
of Rita
of
business,
highest
Services,
to the complete
of the estate
F. Paleschuck
for
to the
and all were
conducted;
State
in the County
300',
letters
negotiation
by Plaintiff
performed
conduct,
Donnelly
Avenue,
ALLEGATIONS
review
of the
of lis pendens,
performed
of
vendors,
the valuation
All
June
Personnel
drafting
and
of the business.
tasks
18.
the
review
services
Collins
10016.
and through
Infinite
of the assets
ethical
17.
of
concerning
CPA,
at
residing
33160.
in good
business
NY
York,
25d',
his corporation
by former
analysis
of Florida,
of the
Florida,
is a resident
FACTUAL
15.
State
8.
belief
300,
Weiss
Donnelly
an office
maintains
Avenue,
Defendant
and
information
Park
belief,
and
Boulevard,
Larchmont,
Weiss
33154.
Florida,
Biscayne
is a resident
belief,
18 as if set forth
on "Ripoff
is attached
Report",
hereto
at length.
a website
as Exhibit
A.Page 4 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
TYSCEF
DOC.
NYSCEF
DOC. NO.
NO.
21.
Upon
information
attached
Alternatively,
not
post
24.
as a direct
result
post
have
information
false
and
on
as Exhibit
7,
with
on Ripoff
is still
had
A copy
of that
the post
Report,
responsible
Weiss
Outscam
on
Donnelly
the Plaintiff.
regarding
,
Weiss
published
and
on January
.Ianuary
belief,
post
defamatory
hereto
a false
the Plaintiff.
regarding
is attached
not
for
made
August
A copy
and
post
is
was
the publication
the
initial
of that
as part
and
because
December
post
Weiss
on "Dirty
of Exhibit
is attached
hereto
another
as part
statements
ethics,
capabilities,
knowledge,
and
Weiss
posted
defamatory
statements
knowing
potential
customers
the published
were
these
s family
post
of that
post
on
is attached
both
customers
and
and
defamatory
and
personal
these
false
untrue
is attached
hereto
client
(www.dirtvscam.com)
before
each
in that
they
in his business,
actions
they
as part
of Exhibit
of the Plaintiff,
D.
Weiss
the Plaintiff.
regarding
statements
was
published.
falsely
reported
and
would
to
knew
Weiss
be viewed
of the Plaintiff
in order
acquaintances,
published
maliciously
were
statements
post
a website
also
A copy
injure
that
such
s character,
statements
by the general
and the Plaintiff
the Plaintiff
maligning,
intentionally
the Plaintiff
s various
and
false.
and by clients,
public,
in his business
defaming,
were
morals,
businesses
and
and
personal
life.
the Plaintiff
libeling
in his
business.
Weiss
published
Plaintiff
33.
These
these
statements
in his personal
and
defamatory
personal
and
life
and
libelous
professional
willful
causing
and
deliberate
injury
to the good
had
a devastating
name
and
reputation
of the
business.
statements
reputations
and
described
have
above
caused
have
the
Plaintiff
great
effect
monetary
on the
harm
Plaintiff's
and
emotional
distress.
34.
These
statements
impugn
falsely
abilities
constitute
the Plaintiff
him
charging
with
libel
per se because
s honesty,
improper,
integrity,
unethical
they
falsely
portray
trustworthiness,
conduct
how
the Plaintiff
conducts
and
professional
dependability,
in his trade
or business
as an attorney
his business,
fitness
and
and
business
person.
35.
These
and
false
loss
and
defamatory
of business
revenue.
statements
of
D.
These
Plaintiff
A copy
on "Dirtyscam",
as a dissatisfied
posing
Scam
29.
that
post
of that
150', 2017,
knew
32.
it
150',
published
and defamatory
the Plaintiff.
defamatory
A copy
Weiss
clients,
a false
published
regarding
28.
potential
also
(www.lawyerratingz.com)
Weiss
and
a false
post
Weiss
by Weiss
Plaintiff.
false
C.
information
published
31.
the
Weiss
on Outscam
communicating
on August
a website
.dirt
(www.dirtyscam.com)
30.
post
by Weiss,
re-publication
after
and belief
On November
that
15d',
published
for
posts
defamatory
information
Upon
regarding
identical
B.
hereto
27.
the
26d', 2015.
directly
and belief,
"LawyerRatingZ",
26.
published
Weiss
(www.outscam.com)
.outscam.com)
of the December
available
Defendant
Report.
Upon
Upon
not
B.
on December
was
been
on Ripoff
Exhibit
25.
of Exhibit
by Outscam
a website
as part
If the Outscam
would
on December
"Outscam"
on
hereto
republished
23.
and belief,
post
defamatory
22.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
have
caused
the
Plaintiff
embarrassnient,
humiliation,
emotional
injury
ofPage 5 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
4YSCEF
DOC.
NYSCEF
DOC. NO.
NO.
36.
Upon
information
other
37.
These
38.
As
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
other
media,
a result
The
of said
result
40.
libel
acts
and were
thereof
is liable
million
dollars
libel
committed
made
without
to the Plaintiff
five
for
libel
severe
42.
Upon
oral
repeats
information
statements
person
43.
44.
in punitive
and
the allegations
at various
belief,
similar
in nature
and
are currently
unknown
in
to the Plaintiff.
loss
extreme
emotional
distress
were
with
intentional,
the sole
of standing
and
willful,
intent
in the
loss of business.
malicious
wanton,
of injuring
and
the
Plaintiff,
and
but
no less than
as a
damages.
CAUSE
to be determined
OF
Court
by this
five
ACTION
AGAINST
WEISS
in paragraphs
1 through
and to people
places
times,
humiliation,
damages.
set forth
content
the Plaintiff
defaming
to those
41 as if set forth
unknown
he published
online
to Plaintiff,
to one
at length.
Weiss
or more
has repeated
either
individuals
in
or by telephone.
On August
25*,
Weiss
Ripoff
Upon
information
regard
in the
information
those
conversations
46.
Weiss
knew
that
47.
These
statements
capabilities,
information
post
Report
Upon
ethics,
upon
to the truth)
advantage
45.
and realleges
and
of punitive
SLANDER
Plaintiff
and
per se in an amount
dollars
statements
from
by Weiss
to the truth,
SECOND
41.
publications
to suffer
the Plaintiff
regard
libelous
the Plaintiff.
disgrace,
to an award
million
additional
continues
against
is entitled
plus
these
per se against
public
to publish
continues
per se the Plaintiff
Plaintiff
Weiss
Defendant
on paper;
of self-esteem,
per se
oppressive
and
constitute
loss
libel
the
belief,
websites,
publications
community,
39.
and
that
and belief
about
he "would
Court
belief,
Weiss
were
made
both
to speak
that
post
to be able
that
following
with
in order
on Outscam.com
anonymously
the person
to use same
who
to attempt
submitted
this
to get negative
as leverage
oral
false
defamatory
and
untrue
and
similar
statements
were
had one
Weiss
post,
statements
knowledge,
posted
Donnelly
against
below
the
complaint".
information
the Plaintiff
(without
in order
to gain
proceeding.
repeated
the spoken
belief
like
Donnelly
the Plaintiff
Surrogate
and
and
before
in nature
each
in that
in his business,
actions
or more
was
they
and content
to those
and
Donnelly
he published
in
online.
made.
falsely
and
with
conversations
reported
the Plaintiff's
the Defendant
knew
that
character,
such
morals,
were
statements
false.
48.
Defendant
them
to potential
in order
49.
Weiss
personal
50.
Weiss
Plaintiff
51.
made
These
personal
to injure
maliciously
life
made
and
these
these
knowing
customers
clients,
the Plaintiff
made
and
they
potential
in his business
these
would
statements
be heard
intentionally
or more
of the Plaintiff
customers
and personal
by one
and
people
who
could
the Plaintiff's
in turn
various
repeat
businesses
life.
maligning,
defaming,
and
the Plaintiff
slandering
in his
his business.
statements
in his personal
defamatory
statements
and
and professional
life
causing
and
willful
and
deliberate
injury
to the
good
name
and
reputation
of the
business.
slanderous
reputations
statements
and
described
have
caused
above
have
the Plaintiff
had
great
a devastating
monetary
effect
harm
and
on the Plaintiff's
emotional
distress.Page 6 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DOC.
NYSCEF
DOC. NO.
NO.
52.
These
the Plaintiff's
him
charging
These
and
54.
false
Upon
As
with
and
56.
The
oppressive
result
57.
thereof
is liable
million
dollars
the
Plaintiff
public
committed
were
made
is entitled
to the Plaintiff
five
plus
59.
Upon
repeats
60.
Upon
the Plaintiff
regard
million
slander
61.
of that
Upon
and
belief
loss
business
person.
emotional
humiliation,
injury
is attached
and
were
with
Plaintiff
to other
the
and
willful,
intent
in the
standing
distress
intentional,
sole
of
loss
of business.
malicious
wanton,
of injuring
and
the Plaintiff,
and as a
by this
Court
no less than
five
but
ACTION
DONNELLY
in paragraphs
A copy
as a result
1 through
a false
published
Donnelly
"Outscam"
as Exhibit
on August
belief,
OF
the Plaintiff.
on
emotional
extreme
to be determined
set forth
alternatively,
posts
from
SE AGAINST
3rd,
regarding
hereto
the
of that
post
of a conversation
a website
57 as if set forth
and defamatory
is attached
with
Donnelly
(wyvw.outscam.com)
.outscam.com)
as Exhibit
B.
caused
Weiss
the
regarding
"Outscam"
on
posts
hereto
Weiss,
at length.
information
a false
of that
information
2017,
in order
his
and belief,
and
post
Upon
disguise
A
Plaintiff.
B.
3rd,
also
Donnelly
published
the Plaintiff.
regarding
is attached
identity,
the Plaintiff.
64.
Donnelly
knew
65.
These
statements
ethics,
capabilities,
that
hereto
a false
and defamatory
A copy
of that
post
with
Weiss,
Donnelly
post
is attached
retribution
the published
on
hereto
as
of that
post
statements
and
caused
and
actions
Weiss
the Plaintiff.
regarding
being
disqualified
Plaintiff,
and
is attached
untrue
post
defamatory
hereto
false
as part
before
in that
in his business,
Surrogate
as a dissatisfied
posing
a false
were
by the
they
was
falsely
and the
client
on "Dirty
of Exhibit
each
Court
order,
on January
posted
these
defamatory
statements
A
of the Plaintiff
Scam
15*,
in order
1'nowing
they
would
D.
published.
reported
Defendant
be viev
to
.dirtvscam.com
(www.dirtyscam.com)
the Plaintiff's
knew
that
such
character,
statements
morals,
were
false.
Donnelly
to
C.
the
published
defamatory
knowledge,
(www.lawyerratingz.com)
after
against
also
A copy
both
days
of a conversation
"LawyerRatingZ"
as Exhibit
only
Donnelly
were
on
posts
and belief
to seek
as a result
alternatively,
defamatory
regarding
66.
to
C.
publish
63.
humiliation,
and abilities
damages.
CAUSE
PER
on August
defamatory
information
Upon
copy
defaming
falsely
damages.
in an amount
(www.lawyerratingz.com)
62.
statements
and
"LawyerRatingZ"
Exhibit
fitness
and
slanderous
of punitive
the allegations
and belief,
post
as an attorney
embarrassment,
by Weiss
in punitive
dollars
(www.outscam.com)
a false
his business,
professional
Plaintiff
and
to the truth,
to an award
for
realleges
and
information
publish
copy
and
information
a website
or business
to suffer
severe
disgrace,
against
without
to make
continues
THIRD
Plaintiff
and
conducts
Plaintiff.
LIBEL
58.
the Plaintiff
dependability,
the
caused
how
portray
in his trade
continues
to the
of self-esteem,
Plaintiff
Weiss
have
Weiss
belief,
slander
acts
and
conduct
statements
unknown
said
slanderous
falsely
revenue.
and
loss
community,
they
trustworthiness,
unethical
defamatory
currently
of
because
integrity,
improper,
information
a result
slander
honesty,
loss of business
recipients
55.
constitute
statements
impugn
53.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
ed by the general
public,
and
byPage 7 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
qYSCEF
DOC.
NYSCEF
DOC. NO.
NO.
potential
clients,
and
67.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
Plaintiff's
Donnelly
and
family
customers
acquaintances,
in order
and
personal
published
maliciously
potential
customers
clients,
these
statements
of the Plaintiff
to injure
the Plaintiff's
the Plaintiff
maligning,
intentionally
and
various
in his business
and
defaming,
and
libeling
businesses,
personal
life.
the Plaintiff
in
his business.
68.
Plaintiff
69.
in his personal
These
and
These
impugn
abilities
and
libelous
professional
him
charging
libel
described
and
have
deliberate
they
integrity,
injury
have
had
the Plaintiff
to the good
falsely
conduct
a devastating
great
how
portray
monetary
name
and
in his trade
effect
on the
harm
and
the Plaintiff
reputation
of the
or business
Plaintiff's
emotional
conducts
and
dependability,
trustworthiness,
unethical
improper,
above
caused
per se because
honesty,
with
and
business.
statements
the Plaintiff's
willful
causing
reputations
constitute
statements
falsely
statements
life
and
defamatory
personal
70.
these
published
Donnelly
distress.
his business,
professional
fitness
as an attorney
and
and
business
person.
71.
These
and
72.
false
loss
Upon
and
of business
information
other
73.
These
74.
As a result
The
76.
libel
per se acts
oppressive
and were
thereof
dollars
constitute
public
committed
made
per se against
without
regard
for
78.
Upon
oral
million
person
79.
and realleges
information
and belief,
Upon
regard
injury
dollars
similar
at various
and
and
from
by'
by Donnelly
and with
of punitive
unknown
Plaintiff
in
to the Plaintiff.
loss
humiliation,
emotional
of standing
distress
were
intentional,
the sole
intent
and
willful,
in the
loss
of business.
malicious
wanton,
of injuring
the
and
and
Plaintiff,
as a
to be determined
by this
Court
but
no less than
five
damages.
CAUSE
OF
in paragraphs
and to people
places
to those
ACTION
DONNELLY
set forth
content
the
defaming
damages.
AGAINST
times,
are currently
extreme
per se in an amount
the allegations
in nature
severe
in punitive
statements
he published
1 through
unknown
online
76 as if set forth
to Plaintiff,
to one
or more
at length.
Donnelly
individuals
has repeated
either
in
or by telephone.
On August
Weiss
80.
repeats
statements
emotional
humiliation,
the Plaintiff.
to the truth,
libel
libelous
publications
to suffer
the Plaintiff
to an award
to the Plaintiff
five
continues
FOURTH
Plaintiff
embarrassment,
to publish
additional
disgrace,
against
is entitled
plus
libel
SLANDER
77.
the Plaintiff
continues
these
per se the Plaintiff
Plaintiff
is liable
Donnelly
million
on paper;
loss of self-esteem,
libel
result
caused
has and
Donnelly
and
online
publications
community,
75.
belief,
websites,
of said
have
revenue.
and
other
media,
statements
defamatory
post
25d', that
he, Donnelly
information
to the truth)
advantage
in the
upon
and belief
about
Surrogate
information
"would
Donnelly
the Plaintiff
Court
and
like
belief
Donnelly
to speak
made
that
to be able
proceeding.
with
post
posted
the person
in order
to use same
anonymously
who
to attempt
as leverage
submitted
on Outscam.com
this
to get negative
against
complaint?
information
the Plaintiff
in order
below
the
Thank
you".
(without
to gainPage 8 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
NTYSCEF
NYSCEF DOC.
DOC. NO.
NO.
81.
information
those
conversations
published
online.
82.
Donnelly
knew
83.
These
them
Donnelly
made
These
88.
These
90.
These
him
false
As
and
93.
slanderous
acts
and
oppressive
and
million
dollars
belief,
repeats
95.
Existing
and
the
future
96.
Future
causing
were
irreparable
97.
Plaintiff
and
caused
have
such
people
and
to the
had
statements
who
could
the Plaintiff's
and
morals,
were
false.
in turn
various
repeat
businesses
good
the Plaintiff
slandering
name
a devastating
great
how
portray
and
the
harm
the Plaintiff
reputation
on the
and
conducts
professional
and
as an attorney
or business
Plaintiff
effect
monetary
dependability,
in his trade
five
embarrassment,
the Plaintiff
without
regard
is entitled
slander
in
of the
distress.
his business,
falsely
fitness
and
Plaintiff's
emotional
and abilities
business
person.
emotional
humiliation,
and
statements
immeasurable
has no adequate
injury
to other
CAUSE
the allegations
set forth
publications
immeasurable
Donnelly
damage.
at law.
were
with
of
distress
intentional,
the sole
intent
in the
standing
and
loss
willful,
of business.
wanton,
of injuring
malicious
the Plaintiff,
and
damages.
to be determined
by this
Court
but
no less than
five
damages.
AGAINST
remedy
the Plaintiff
defaming
loss
emotional
extreme
and
of punitive
RELIEF
by
statements
humiliation,
by Donnelly
in an amount
in punitive
dollars
from
and
to the truth,
to an award
for
defamatory
slanderous
to suffer
severe
disgrace,
against
million
to make
continues
public
made
irreparable
slanderous
that
defaming,
the Plaintiff
falsely
continues
Plaintiff
committed
and realleges
future
Plaintiff
injury
above
trustworthiness,
FIFTH
Plaintiff
knew
s character,
Plaintiff.
to the
INJUNCTIVE
94.
they
have
Donnelly
to the Plaintiff
plus
in
he and Weiss
the Plaintiff
or more
by one
deliberate
caused
conduct
statements
Plaintiff
is liable
Donnelly
integrity,
of self-esteem,
thereof
because
unethical
slander
The
as a result
reported
maligning,
described
have
and
slander
unknown
said
loss
community,
92.
and
of
and
life.
intentionally
and
to those
Weiss
made.
Donnelly
of the
personal
willful
was
falsely
and
be heard
and content
with
revenue.
currently
a result
they
customers
and
statements
reputations
defamatory
information
potential
statements
slanderous
improper,
in that
each
conversations
business.
honesty,
with
before
would
they
causing
and
constitute
of business
loss
Upon
life
and
the Plaintiff's
recipients
91.
statements
statements
charging
and
these
and professional
impugn
89.
his business.
defamatory
personal
these
and
in his personal
Plaintiff
87.
life
untrue
in his business
made
false
or more
in nature
similar
in his business,
actions
and
had one
Donnelly
statements
were
knowing
the Plaintiff
maliciously
Donnelly
and
post,
and
defamatory
customers
clients,
injure
his personal
86.
both
oral
statements
statements
these
to potential
to
repeated
knowledge,
made
in order
85.
were
that
following
the spoken
that
capabilities,
Donnelly
belief,
Donnelly
statements
ethics,
84.
and
Upon
OF
ACTION
WEISS
AND
in paragraphs
and Weiss
by Donnelly
DONNELLY
1 through
will
93 as if set forth
continue
to injure
the
at length.
Plaintiff
in the
damage.
and Weiss
will
continue
to
injure
the
Plaintiff
in the future
causingPage 9 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
qYSCEF
NYSCEF DOC.
DOC. NO.
NO.
98.
Issuing
99.
Plaintiff
will
an injunction
has a likelihood
100.
It is in the public's
101.
Accordingly,
this
slanderous
statements
102.
Further,
any
should
this
revoke,
enjoin
the
order
in writing
that the statements
an order
Plaintiff
a trial
demands
hereby
Plaintiff
from
search
of all
by jury
CARY
Defendants
A.
WEISS
On
the
but no less than
from
the Court
harm
On the Third
by
the
Court
On the Fourth
by
the
Court
E.
to
prejudgment
interest
On
Cause
the
Fifth
permanently
per
remarks
his
from
at their
future;
revoke,
respective
remarks
at their
Yahoo
others)
to delist
Bing
five
stated
and
herein.
in his
judgment
the following
million
favor
and
against
the
relief:
of damages
to compensate
An
in an amount
the Plaintifffor
dollars
to be determined
plus
damages,
by
and economic
all monetary
in punitive
of damages
award
to compensate
five
in an amount
the Plaintifffor
dollars
million
An
prejudgment
to be determined
all monetary
in punitive
million
and economic
plus
damages,
by
prejudgment
dollars
of the original
and
and
to
to be determined
Plaintiff
all
dollars
in
for
punitive
monetary
and
damages
plus
of damages
five
in an amount
the
million
Plaintiff
dollars
in
for
to be determined
all
punitive
monetary
and
damages,
plus
occurrence.
from
remove
in
injunctive
(1)
in such
engaging
relief
admit
million
to compensate
and Weiss:
injunctive
withdraw
award
plus
reputation,
and Weiss
five
the
in an amount
occurrence.
An
Donnelly
of damages
to compensate
plus
Donnelly:
(2)
award
dollars
of the original
against
costs:
enter
award
reputation,
and
and
An
million
five
Donnelly
for
Donnelly:
against
the time
of Action
in the
rescind,
the time
than
and slanderous
occurrence.
and
business
restraining
se conduct
permanently
less
individually,
RELIEF
Court
dollars,
five
of Action
no
the
plus
business
from
Cause
harm
economic
his
(Google,
damages
and
FOR
Weiss:
against
than
each
occurrence.
reputation,
less
engines
of fact
plus
against
of action
no
but
dollars,
of the original
interest
prejudgment
million
million
five
and
Cause
to
Weiss:
of Action
the time
harm
economic
D.
Cause
but
against
of the original
business
from
that
reputation,
but no less than
to his
interest
C.
and
the time
On the Second
five
and Weiss
DEMAND
H. DONNELLY,
of action
to his business
interest
B.
Cause
or
publications
results.
issues
prays
MICHAEL
and
First
the Court
harm
E. FRANK
JAMIE
further
untrue.
were
PRAYER
WHEREFORE,
from
per se publications
libel
the search
requiring
the Plaintiff
that Donnelly
all such
JURY
.1URY
104.
and Weiss
Donnelly
requiring
and remove
issue
acts be enjoined.
Plaintiff.
withdraw
against
posts
defamatory
Weiss'
and
issue an injunctive
should
Court
the
harm.
matter.
permanently
defame
and to admit
costs
in this
the Donnelly's
should
that
rescind,
permanently
103.
court
that
and Weiss
Donnelly
of success
interest
this Court
Further,
respective
not cause
such
writing
defamatory,
of an order
consisting
all
relief
libel
that
per
the
for
slanderous
Donnelly
se publications
statements
of an order
consisting
were
and
libel
to
and Weiss
and
untrue,
slanderous
and
(3)Page 10 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
SYSCEF
NYSCEF DOC.
DOC. NO.
NO.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
injunctive
to delist
Plus,
under
Dated:
the
costs
and
relief
all defamatory
disbursements
of an order
consisting
posts
of
this
against
action
the search
requiring
Plaintiff
and
any
from
and
all
engines
search
(Google,
Bing,
Levittown,
New
additional
relief
this
Court
deems
York
6, submitted,
Respectfully
By:9Ómie
E Frank
Plaintiff,
Pro-se
8 Haven
Lane,
Levittown,
Phone:
Fax:
Email:
and
others)
and
proper
results.
the circumstances.
July
Yahoo
NY
RECEIVED
: 07/16/RECEIVED NYSCEF
NYSCEF:
04/10/
NYSCEF DOC. NO.
M-
LawyerRating
Find.
rate
and
review
Irf(I'"afe(st~/i"'.r'
drsiceWittj%@'""rts
Attorneys
and
fg"wp 'rp('psych""r"
Lawyers
RRTf4WiffiM192MFAfà55ffEMSXtRM2182282251552352EERR
Jeimie E. Frarik
Altorney
Top
Practice Area: Generai Practice
r ~~
~~ Bied n h
Prosie!ipd
~~"2n
~~
~~~~
~
~~~
~~
~ on
~! v ~s~.
~
!~
~ ~ 1,~
Rating:
!~
~ out
~or 5 based
~ 1 rev~et
~
~~
~~ ra',!
~~~ ~~ Jam!e
~
~ Fra!ok has
E.
a~ ~~
~
~~~1g
a poor overall
Attomcy
g on
~
~~
LawyerRat!ngz.corn.
~~ J~l~
P
Free Consult.
Fees- From $450.
Serving Nassau &
Suffolk Counties.
Theroiiowile post!!!g'1'eve!IOI!de'nSot!Sfef»!die!i
Oj Ld»dyef
Rdi!nfisCOBB
Questions
and
anSWars
abOUt
this
attorney
Post
a
T
Ef:
Date
L
E
D
E
A
T
I
i(
A
C
I
T
v
A
L
I
T
v
V
A
L
u
E
8/3/
Comments
Nothing but disservice, trouble, lies and scams from Jarnie E. Frank
Attorney at Law Levittowrt NY
Registered users can
Best Rated Attorneys in NY
l'
A,"vI1) I~BR FV:
if(4»„ I 4'K l 4 <'l.
Copyright ongo1!LReling Inc. ~ PfivBCV' Con'.BctRBt!BOZ* 'Vt!Bh0 sf n Id Lu!1BGra"hica
I=.XI-IIBI'I
C
g)Page 16 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DOC.
. . NO.
NYSCEF
DOC.
NO.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
hdQi~
I
Reported
» Person
scam
Jamie
Frank
E.
Jamie
E. Frank,
tûÛ
is a con
Attorney-At-Lav~
Û Ù
artist
)
v;.ithout
+
kr:o:.vledge
any
of
law
00 jamieefrank.com
516-908-
Q
Q+
Review
Qw
Favorite
in midst
I was
decision.
what
of selling
my
is when,
I met
That
he does
and
shown
dollar
multimillion
E. Frank
Jamie
some
names
and
company
who
of the
Share
wanted
practices
solely
that
companies
to consult
law.
the
he had
an attorney
before
He assured
me
before
in making
helped
that
making
he was
the
any
great
at
right
selection.
On my
from
penny
business
With
course
of time,
out
of people.
I am
not
life
reason,
have
lost
his
sweet
for
this
because
after
I am
writing
report
You
only
and
have
He will
destroyed
a company
me
off
and
that
and
a contract
myself
then
he does
made
that
he made
not
him
by putting
represented
know
that
in helping
about
the
solution
me
After
three
of my
in-charge
law
at any
and
only
instance.
I have
years,
case.
fof'
for making
to me
company
anything
no effort
sign.
me
sale
how
He even
got
He scammed
my
knows
not
me.
decision.
to make
colluded
a
with
fool
a
me.
ruined
this
back.
and
and
I actually
I discovered
He ripped
to fall
with
away
My
from
in defrauding
at loss
you
of deal.
kind
any
He solicited
broker
an agreement
he build
request,
you
one
leave
hopes
talks.
Most
he expertise
he asked
to help
this
complaint
would
know
chance,
you
of finding
after
of the
his field
me.
here.
what
you
you
sign
right
time
If you
need
any
he speaks
of art,
I should
for
called
have
want
the
problem
about
he got
me
it is fake.
something,
into.
I can
only
He manages
advice
to get
cheating.
done
a thorough
to go with
him
research
for
any
before
of your
legal
him.
hiring
decision,
This
please
is the
read
to do next.
agreement
devastated.
EXHIBIT
D
or pay
him
for
your
service,
you
are
not
going
to get
itPage 17 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
4YSCEF
NYSCEF DOC.
DOC. NO.
NO.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
The reviews,
Law
Consultants
Attorney
complaints
and
scams
posted
.::":.:::
hB2ab'Ldilya0fillMM0lBàYieziatamia±fB10kt
The
reviews,
the content
using
complaints
posted
and scams
about
about
about
E. Frank.
Jamie
Firm
E. Frank
Jamie
Search
for all reviews,
E. Frank
Jamie
is permanant
If you have
is posted
any concern
record
complaints
and scams
by anonymous.
about
Jamie
located
at
We at dirty
E. Frank's
an
about
report,
scam
e
are not liable
you can
contact
for
us by
':.::s '- i3".a'!.
. ..
.:
ChBt tdFfOOgB
Anglyn
Aviles
Tai
Lopez
Reviews
Debra
Smith
Cynthia
742@comcast.net
HANSFQRP
Ra
gsl
Hansford
1 review
Qnet
University
on Jamie
l|ndia
Report
Seam
Carol
horton
E. Frank
"Jamie
E. Frank
is the
on
This
lawyer
Anonymos
worry...
came
not
out
is rudy
to
I got
scammer"
Januar
and
15,
less
of talent.
worry...
not
to
totally
got
foairi)ed
worry
but
up.
he
is harass
at end
of the
you
day
for
his
I mean
fees
when
and
will
the
tell
case
you
verdict
not
toPage 18 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DOC.
NYSCEF
DOC. NO.
NO.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/In first
about
the
he
meeting
it at all..
detaiL
Jamie
in the
what
E. Frank
said
the
the
case
middle
he
helL.
you
are
the
you
is very
started
never
shittttt.
to
easy
blaming
asked
go
and
handle
me why
me you
have
and
dump
good
life
you
you
have
Jamie
of
do
not
had
need
not
to
worry
submitted
all
E. Frank.
my fees.
! 'g
REPLY
Rate
Your
and
write
a review
on Jamie
E. Frank
Review
..
-
one
= two
Your
overall
rating
Title
of
review:
your
Name
*
Emalll
*
O
of this
report:Page 19 FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DO
NYSCEF
DOC. NO.
NO.
Haven
"Get
Lane
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
8, NY US
d!rectior!
Approved
S
Date
Status
Reported
Severity
Location
Reported
Loss
of
Scam
:
November
:
Published
:
:
Extremely
city:
7,
High
Levittown
by:
anonymous
Category
:
Person
Views
:
12 views
Scammer
INDEX NO. 609677/
Images
All
P
photos
'1'
(1)Page 20 FILED: NASSAU COUNTY CLERK 04/10/11:AM
2 : 5 |F ILED
:
NYSCEF DOC. NO. NYSCEF
DOC.
NO.
CLERK
COUNTY
SAU
NAS
/
/
PM|
INDEX NO. 609677/
™¹"^
RECEIVED
*
·
0=
/ / / 2 u1e
RECEIVED NYSCEF: 04/10/NYSCEF:
07/16/
VERIFICATION
State
of New
Jamie
York
E. Frank,
Deponent
},
being
ss:
duly
and
therein
knows
stated
sworn,
the
action.
contents
to be alleged
and says:
deposes
in the within
is the Plaintiff
COMPLAINT
matters
}
of Nassau
County
thereof;
upon
Deponent
has read
and the same
information
and
the foregoing
AMENDED
VERIFIED
to deponent's
own knowledge,
except
and as to those matters
believes
deponent
is true
belief,
be true.
Dated:
Levittown,
July
6™,
New York
P.
an(le
Sworn
Notary
to before
PubliC
me this
6™
day
of July,
T ANDRAKUMAR
otary Public - Stateof New York
NO.01CHQualified in NassauCounty
My CommissionExpiresJan 24,
of
E. Frank
as to the
them
toPage 21 INDEX NO. 609677/
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/04/10/
DOC.
4YSCEF
NYSCEF
DOC. NO.
NO.
COURT
SUPREME
COUNTY
OF THE
STATE
NEW YORK
OF
OF NASSAU
X
JAMIE
E.
FRANK
Plaintiff,
-againSt-
CARY
WEISS
and
INDEX
MICHAEL
H.
NUMBER:
DONNELLY
Defendants.
X
CARY
WEISS
and
INFINITE
PERSONNEL
INC.
SERVICES,
Counterclaim
Plaintiffs,
Counterclaim
Defendant.
-against-
JAMIE
E.
FRANK
X
AMENDED
COMPLAINT
VERIFIED
Filed
JAMIE
by:
E. FRANK
Plaintiff
8 Haven
Levittown,
Tel:
(516)
Fax:(206)
E-mail:mailla
se
Pro
Lane,
NY
908-339-jamieefrank.corn
609677/2016
PDF Page 1
PlainSite Cover Page
PDF Page 2
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
NYSCEF DOC. NO. 78
INDEX NO. 609677/2016
RECEIVED NYSCEF: 04/10/2018
PDF Page 3
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
qYSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
SUPREME
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
COURT
COUNTY
OF THE
OF NEW
STATE
YORK
OF NASSAU
X
E. FRANK
JAMIE
AMENDED
Plaintiff,
VERIFIED
COMPLAINT
-against-
CARY
WEISS
MICHAEL
and
INDEX
DONNELLY
H.
e endants.
DATE
NUMBER:
609677/2016
OF OR.IGINAL
FILING:
12/26/16
X
CARY
WEISS
and
PERSONNEL
INFINITE
INC.
SERVICES,
Counterclaim
Plaintiffs,
Counterclaim
Defendant
-against-
JAMIE
E. FRANK
X
To
the
above-named
JAMIE
Plaintiff,
CARY
WEISS
Defendants:
E. FRANK,
Pro-se
MICHAEL
and
as and
for
his Amended
H. DONNELLY
hereby
NATURE
1.
This
action
RELIEF
COMPENSATORY
is for
to redress
slander
in this
action
against
Defendants
CLAIMS
DAMAGES
PUNITIVE
DAMAGES,
to wit:
Complaint
as follows:
THE
OF
MONEY
of defamation,
acts
Verified
alleges
and
libel
per se committed
and
by the
INJUNCTIVE
Defendants
against
the
Plaintiff.
2.
Defendants'
to cause,
the
professional
unlawful
conduct
Plaintiff
disgrace,
and
personal
was
knowing,
humiliation
and
shame
and severe
reputations,
willful
malicious,
throughout
mental
4.
This
court
has jurisdiction
over
section
301
in that
he resides
against
the
Plaintiff
with
This
court
pursuant
were
5.
Venue
6.
The
has jurisdiction
to CPLR
directed
against
is proper
Supreme
jurisdiction
section
in Nassau
Court
trial
and/or
conducts
intent
over
the
damage
he resides
with
County
because
within
in the
MICHAEL
the
and/or
intent
of unlimited
H.
original
permanent
and emotional
(hereinafter
and
State
and
harm
continues
to his
distress.
resides
the
acts
of New
were
to CPLR
directed
York.
within
in the
in the County
jurisdiction
committed
(hereinafter
business
damage
pursuant
"Weiss")
DONNELLY
conducts
of causing
the Plaintiff
has caused,
VENUE
WEISS
business
Defendant
in that
court
CARY
of causing
Plaintiff
is the trial
of the other
Defendant
the
301
the
the
which
the world,
anguish
AND
JURISDICTION
3.
and wanton,
and
State
"Donnelly")
the
of New
acts
committed
York.
of Nassau.
and the amount
sought
exceeds
the
courts.
PARTIES
7.
Plaintiff
Jan1ie
E. Frank
is a resident
of the County
of Nassau,
an attorney
in good
standing
in the
State
of Nev
PDF Page 4
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
TYSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
York
and
8.
Weiss
9.
Upon
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
resides
and conducts
is a resident
of the
information
and
information
and
and
businesses
of New
State
belief
owns
Weiss
York
at 8 Haven
at 2 West
residing
maintains
Lane,
an office
and
1
NY
Levittown,
6d'
Apt
Street,
and owns
conducts
1 1756.
1F, New
NY
York,
1001 1.
in the State
businesses
of New
York.
10.
Upon
Surfside,
1 1.
Upon
12.
information
Upon
information
13.
Upon
14.
Donnelly
NY
Aventura,
North
belief,
10538-261
and
Suite
of the
Miami
is a resident
Beach,
on May
Beginning
of Weiss
for
the
suits
and
sale
of the
is an attorney
Donnelly
and
New
conducts
new
16.
business,
employees
represented
E Frank,
Rita
executor
Maurice
trusts,
In response
to a motion
of Maurice
Paleschuck
Paleschuck
20.
repeats
On December
(yves:.ri
offre
and
said
made
matter
ort.com)
at 18071
residing
at 17 Serpentine
residing
regarding
State
ofNew
State
York,
Inc.
and
Trail,
York.
ofNew
to wit:
York,
2
the Plaintiff.
and
A copy
CPA
at that
he took
of the Rita
was
the
of
suits
and
with
two
potential
banks,
with
working
for
closing
highest
and
offers
levels
capability
defamatory
an adversarial
of that
F. Paleschuck
disqualified
C. Reilly
1 through
post
of
for
the
position
to Jamie
and Maurice
and
dated
from
representation
December
200¹, 2016.
WEISS
post
the sale
time.
ACTION
in paragraphs
that
15d', 2015.
subsequently
Margaret
and
using
Defendant
December
and
agreement
of the
SE AGAINST
set forth
of a new
conducted
in which
evaluation
negotiations
knowledge
Judge
OF
by and
on behalf
services
against
significant
Trustee
Donnelly
defend
sheets,
were
on or about
Court
a false
term
legal
included:
with
matter
and
various
services
of a purchase
quality,
CAUSE
PER
These
his company
satisfaction
E. Frank,
performed
the hiring
of
of Surrogate
published
ofNew
recommend
commencing
the allegations
Weiss
in the
prepared
F. Paleschuck
by Jamie
by the order
realleges
15d', 2015
York;
of documents
and
level
FIRST
Plaintiff
of Florida,
ofNew
plaintiff
intent
in an estate
LIBEL
19.
State
standing
and the writing
Weiss
of Rita
of
business,
highest
2013
Services,
to the complete
of the estate
F. Paleschuck
for
to the
and all were
conducted;
State
in the County
300',
letters
negotiation
by Plaintiff
performed
conduct,
Donnelly
Avenue,
ALLEGATIONS
review
of the
of lis pendens,
performed
of
vendors,
the valuation
All
June
Personnel
drafting
and
of the business.
tasks
18.
the
review
services
Collins
10016.
and through
Infinite
of the assets
ethical
17.
of
concerning
CPA,
at 9195
residing
33160.
in good
business
NY
York,
25d', 2010
his corporation
by former
analysis
of Florida,
of the
Florida,
is a resident
FACTUAL
15.
State
8.
belief
300,
Weiss
Donnelly
an office
maintains
Avenue,
Defendant
and
information
Park
belief,
and
Boulevard,
Larchmont,
Weiss
33154.
Florida,
Biscayne
is a resident
belief,
18 as if set forth
on "Ripoff
is attached
Report",
hereto
at length.
a website
as Exhibit
A.
PDF Page 5
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
TYSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
21.
Upon
information
attached
Alternatively,
not
post
24.
as a direct
result
post
have
information
false
and
on
as Exhibit
7, 2016
with
on Ripoff
is still
had
A copy
of that
the post
Report,
responsible
Weiss
Outscam
on
Donnelly
the Plaintiff.
regarding
3
, 2016
Weiss
published
and
on January
.Ianuary
belief,
post
defamatory
hereto
a false
the Plaintiff.
regarding
is attached
not
for
made
August
A copy
3
and
post
is
was
the publication
the
initial
2016
of that
as part
and
because
December
post
Weiss
on "Dirty
of Exhibit
is attached
hereto
another
as part
statements
ethics,
capabilities,
knowledge,
and
Weiss
posted
defamatory
statements
knowing
potential
customers
the published
were
these
s family
post
of that
post
on
is attached
both
customers
and
and
defamatory
and
personal
these
false
untrue
is attached
hereto
client
(www.dirtvscam.com)
before
each
in that
they
in his business,
actions
they
as part
of Exhibit
of the Plaintiff,
D.
Weiss
the Plaintiff.
regarding
statements
was
published.
falsely
reported
and
would
to
knew
Weiss
be viewed
of the Plaintiff
in order
acquaintances,
published
maliciously
were
statements
post
a website
also
A copy
injure
that
such
s character,
statements
by the general
and the Plaintiff
the Plaintiff
maligning,
intentionally
the Plaintiff
s various
and
false.
and by clients,
public,
in his business
defaming,
were
morals,
businesses
and
and
personal
life.
the Plaintiff
libeling
in his
business.
Weiss
published
Plaintiff
33.
These
these
statements
in his personal
and
defamatory
personal
and
life
and
libelous
professional
willful
causing
and
deliberate
injury
to the good
had
a devastating
name
and
reputation
of the
business.
statements
reputations
and
described
have
above
caused
have
the
Plaintiff
great
effect
monetary
on the
harm
Plaintiff's
and
emotional
distress.
34.
These
statements
impugn
falsely
abilities
constitute
the Plaintiff
him
charging
with
libel
per se because
s honesty,
improper,
integrity,
unethical
they
falsely
portray
trustworthiness,
conduct
how
the Plaintiff
conducts
and
professional
dependability,
in his trade
or business
as an attorney
his business,
fitness
and
and
business
person.
35.
These
and
false
loss
and
defamatory
of business
revenue.
statements
of
D.
These
Plaintiff
A copy
on "Dirtyscam",
as a dissatisfied
posing
Scam
29.
that
post
of that
150', 2017,
knew
32.
it
150', 2015
published
and defamatory
the Plaintiff.
defamatory
A copy
Weiss
clients,
a false
published
regarding
28.
potential
also
(www.lawyerratingz.com)
Weiss
and
a false
post
Weiss
by Weiss
Plaintiff.
false
C.
information
published
31.
the
Weiss
on Outscam
communicating
on August
a website
.dirt
(www.dirtyscam.com)
30.
post
by Weiss,
re-publication
after
and belief
On November
that
15d', 2015
published
for
posts
defamatory
information
Upon
regarding
identical
B.
hereto
27.
the
26d', 2015.
directly
and belief,
"LawyerRatingZ",
26.
published
Weiss
(www.outscam.com)
.outscam.com)
of the December
available
Defendant
Report.
Upon
Upon
not
2015
B.
on December
was
been
on Ripoff
Exhibit
25.
of Exhibit
by Outscam
26
a website
as part
If the Outscam
would
on December
"Outscam"
on
hereto
republished
23.
and belief,
post
defamatory
22.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
have
caused
the
Plaintiff
embarrassnient,
humiliation,
emotional
injury
of
PDF Page 6
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
4YSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
36.
Upon
information
other
37.
These
38.
As
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2013
04/10/2018
other
media,
a result
The
of said
result
40.
libel
acts
and were
thereof
is liable
million
dollars
libel
committed
made
without
to the Plaintiff
five
for
libel
severe
42.
Upon
oral
repeats
information
statements
person
43.
44.
in punitive
and
the allegations
at various
belief,
similar
in nature
and
are currently
unknown
in
to the Plaintiff.
loss
extreme
emotional
distress
were
with
intentional,
the sole
of standing
and
willful,
intent
in the
loss of business.
malicious
wanton,
of injuring
and
the
Plaintiff,
and
but
no less than
as a
damages.
CAUSE
to be determined
OF
Court
by this
five
ACTION
AGAINST
WEISS
in paragraphs
1 through
and to people
places
times,
humiliation,
damages.
set forth
content
the Plaintiff
defaming
to those
41 as if set forth
unknown
he published
online
to Plaintiff,
to one
at length.
Weiss
or more
has repeated
either
individuals
in
or by telephone.
On August
25*,
Weiss
Ripoff
Upon
information
regard
in the
information
those
conversations
46.
Weiss
knew
that
47.
These
statements
capabilities,
information
post
Report
Upon
ethics,
upon
2016
to the truth)
advantage
45.
and realleges
and
of punitive
SLANDER
Plaintiff
and
per se in an amount
dollars
statements
from
by Weiss
to the truth,
SECOND
41.
publications
to suffer
the Plaintiff
regard
libelous
the Plaintiff.
disgrace,
to an award
million
additional
continues
against
is entitled
plus
these
per se against
public
to publish
continues
per se the Plaintiff
Plaintiff
Weiss
Defendant
on paper;
of self-esteem,
per se
oppressive
and
constitute
loss
libel
the
belief,
websites,
publications
community,
39.
and
that
and belief
about
he "would
Court
belief,
Weiss
were
made
both
to speak
that
post
to be able
that
following
with
in order
on Outscam.com
anonymously
the person
to use same
who
to attempt
submitted
this
to get negative
as leverage
oral
false
defamatory
and
untrue
and
similar
statements
were
had one
Weiss
post,
statements
knowledge,
posted
Donnelly
against
below
the
complaint".
information
the Plaintiff
(without
in order
to gain
proceeding.
repeated
the spoken
belief
like
Donnelly
the Plaintiff
Surrogate
and
and
before
in nature
each
in that
in his business,
actions
or more
was
they
and content
to those
and
Donnelly
he published
in
online.
made.
falsely
and
with
conversations
reported
the Plaintiff's
the Defendant
knew
that
character,
such
morals,
were
statements
false.
48.
Defendant
them
to potential
in order
49.
Weiss
personal
50.
Weiss
Plaintiff
51.
made
These
personal
to injure
maliciously
life
made
and
these
these
knowing
customers
clients,
the Plaintiff
made
and
they
potential
in his business
these
would
statements
be heard
intentionally
or more
of the Plaintiff
customers
and personal
by one
and
people
who
could
the Plaintiff's
in turn
various
repeat
businesses
life.
maligning,
defaming,
and
the Plaintiff
slandering
in his
his business.
statements
in his personal
defamatory
statements
and
and professional
life
causing
and
willful
and
deliberate
injury
to the
good
name
and
reputation
of the
business.
slanderous
reputations
statements
and
described
have
caused
above
have
the Plaintiff
had
great
a devastating
monetary
effect
harm
and
on the Plaintiff's
emotional
distress.
PDF Page 7
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
52.
These
the Plaintiff's
him
charging
These
and
54.
false
Upon
As
with
and
56.
The
oppressive
result
57.
thereof
is liable
million
dollars
the
Plaintiff
public
committed
were
made
is entitled
to the Plaintiff
five
plus
59.
Upon
repeats
60.
Upon
the Plaintiff
regard
million
slander
61.
of that
Upon
and
belief
loss
business
person.
emotional
humiliation,
injury
is attached
and
were
with
Plaintiff
to other
the
and
willful,
intent
in the
standing
distress
intentional,
sole
of
loss
of business.
malicious
wanton,
of injuring
and
the Plaintiff,
and as a
by this
Court
no less than
five
but
ACTION
DONNELLY
in paragraphs
A copy
as a result
1 through
a false
published
Donnelly
"Outscam"
as Exhibit
on August
belief,
OF
the Plaintiff.
on
emotional
extreme
to be determined
set forth
alternatively,
posts
from
SE AGAINST
3rd, 2016
regarding
hereto
the
of that
post
of a conversation
a website
57 as if set forth
and defamatory
is attached
with
Donnelly
(wyvw.outscam.com)
.outscam.com)
as Exhibit
B.
caused
Weiss
the
regarding
"Outscam"
on
posts
hereto
Weiss,
at length.
information
a false
of that
information
2017,
in order
his
and belief,
and
post
Upon
disguise
A
Plaintiff.
B.
3rd, 2016
also
Donnelly
published
the Plaintiff.
regarding
is attached
identity,
the Plaintiff.
64.
Donnelly
knew
65.
These
statements
ethics,
capabilities,
that
hereto
a false
and defamatory
A copy
of that
post
with
Weiss,
Donnelly
post
is attached
retribution
the published
on
hereto
as
of that
post
statements
and
caused
and
actions
Weiss
the Plaintiff.
regarding
being
disqualified
Plaintiff,
and
is attached
untrue
post
defamatory
hereto
false
as part
before
in that
in his business,
Surrogate
as a dissatisfied
posing
a false
were
by the
they
was
falsely
and the
client
on "Dirty
of Exhibit
each
Court
order,
on January
posted
these
defamatory
statements
A
of the Plaintiff
Scam
15*,
in order
1'nowing
they
would
D.
published.
reported
Defendant
be viev
to
.dirtvscam.com
(www.dirtyscam.com)
the Plaintiff's
knew
that
such
character,
statements
morals,
were
false.
Donnelly
to
C.
the
published
defamatory
knowledge,
(www.lawyerratingz.com)
after
against
also
A copy
both
days
of a conversation
"LawyerRatingZ"
as Exhibit
only
Donnelly
were
on
posts
and belief
to seek
as a result
alternatively,
defamatory
regarding
66.
to
C.
publish
63.
humiliation,
and abilities
damages.
CAUSE
PER
on August
defamatory
information
Upon
copy
defaming
falsely
damages.
in an amount
(www.lawyerratingz.com)
62.
statements
and
"LawyerRatingZ"
Exhibit
fitness
and
slanderous
of punitive
the allegations
and belief,
post
as an attorney
embarrassment,
by Weiss
in punitive
dollars
(www.outscam.com)
a false
his business,
professional
Plaintiff
and
to the truth,
to an award
for
realleges
and
information
publish
copy
and
information
a website
or business
to suffer
severe
disgrace,
against
without
to make
continues
THIRD
Plaintiff
and
conducts
Plaintiff.
LIBEL
58.
the Plaintiff
dependability,
the
caused
how
portray
in his trade
continues
to the
of self-esteem,
Plaintiff
Weiss
have
Weiss
belief,
slander
acts
and
conduct
statements
unknown
said
slanderous
falsely
revenue.
and
loss
community,
they
trustworthiness,
unethical
defamatory
currently
of
because
integrity,
improper,
information
a result
slander
honesty,
loss of business
recipients
55.
constitute
statements
impugn
53.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2013
04/10/2018
ed by the general
public,
and
by
PDF Page 8
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
qYSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
potential
clients,
and
67.
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2015
04/10/2018
Plaintiff's
Donnelly
and
family
customers
acquaintances,
in order
and
personal
published
maliciously
potential
customers
clients,
these
statements
of the Plaintiff
to injure
the Plaintiff's
the Plaintiff
maligning,
intentionally
and
various
in his business
and
defaming,
and
libeling
businesses,
personal
life.
the Plaintiff
in
his business.
68.
Plaintiff
69.
in his personal
These
and
These
impugn
abilities
and
libelous
professional
him
charging
libel
described
and
have
deliberate
they
integrity,
injury
have
had
the Plaintiff
to the good
falsely
conduct
a devastating
great
how
portray
monetary
name
and
in his trade
effect
on the
harm
and
the Plaintiff
reputation
of the
or business
Plaintiff's
emotional
conducts
and
dependability,
trustworthiness,
unethical
improper,
above
caused
per se because
honesty,
with
and
business.
statements
the Plaintiff's
willful
causing
reputations
constitute
statements
falsely
statements
life
and
defamatory
personal
70.
these
published
Donnelly
distress.
his business,
professional
fitness
as an attorney
and
and
business
person.
71.
These
and
72.
false
loss
Upon
and
of business
information
other
73.
These
74.
As a result
The
76.
libel
per se acts
oppressive
and were
thereof
dollars
constitute
public
committed
made
per se against
without
regard
for
78.
Upon
oral
million
person
79.
and realleges
information
and belief,
Upon
regard
injury
dollars
similar
at various
and
and
from
by'
by Donnelly
and with
of punitive
unknown
Plaintiff
in
to the Plaintiff.
loss
humiliation,
emotional
of standing
distress
were
intentional,
the sole
intent
and
willful,
in the
loss
of business.
malicious
wanton,
of injuring
the
and
and
Plaintiff,
as a
to be determined
by this
Court
but
no less than
five
damages.
CAUSE
OF
in paragraphs
and to people
places
to those
ACTION
DONNELLY
set forth
content
the
defaming
damages.
AGAINST
times,
are currently
extreme
per se in an amount
the allegations
in nature
severe
in punitive
statements
he published
1 through
unknown
online
76 as if set forth
to Plaintiff,
to one
or more
at length.
Donnelly
individuals
has repeated
either
in
or by telephone.
On August
Weiss
80.
repeats
statements
emotional
humiliation,
the Plaintiff.
to the truth,
libel
libelous
publications
to suffer
the Plaintiff
to an award
to the Plaintiff
five
continues
FOURTH
Plaintiff
embarrassment,
to publish
additional
disgrace,
against
is entitled
plus
libel
SLANDER
77.
the Plaintiff
continues
these
per se the Plaintiff
Plaintiff
is liable
Donnelly
million
on paper;
loss of self-esteem,
libel
result
caused
has and
Donnelly
and
online
publications
community,
75.
belief,
websites,
of said
have
revenue.
and
other
media,
statements
defamatory
post
25d', 2016
that
he, Donnelly
information
to the truth)
advantage
in the
upon
and belief
about
Surrogate
information
"would
Donnelly
the Plaintiff
Court
and
like
belief
Donnelly
to speak
made
that
to be able
proceeding.
with
post
posted
the person
in order
to use same
anonymously
who
to attempt
as leverage
submitted
on Outscam.com
this
to get negative
against
complaint?
information
the Plaintiff
in order
below
the
Thank
you".
(without
to gain
PDF Page 9
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
NTYSCEF
NYSCEF DOC.
DOC. NO.
NO. 12
78
81.
information
those
conversations
published
online.
82.
Donnelly
knew
83.
These
them
Donnelly
made
These
88.
These
90.
These
him
false
As
and
93.
slanderous
acts
and
oppressive
and
million
dollars
belief,
repeats
95.
Existing
and
the
future
96.
Future
causing
were
irreparable
97.
Plaintiff
and
caused
have
such
people
and
to the
had
statements
who
could
the Plaintiff's
and
morals,
were
false.
in turn
various
repeat
businesses
good
the Plaintiff
slandering
name
a devastating
great
how
portray
and
the
harm
the Plaintiff
reputation
on the
and
conducts
professional
and
as an attorney
or business
Plaintiff
effect
monetary
dependability,
in his trade
five
embarrassment,
the Plaintiff
without
regard
is entitled
slander
in
of the
distress.
his business,
falsely
fitness
and
Plaintiff's
emotional
and abilities
business
person.
emotional
humiliation,
and
statements
immeasurable
has no adequate
injury
to other
CAUSE
the allegations
set forth
publications
immeasurable
Donnelly
damage.
at law.
were
with
of
distress
intentional,
the sole
intent
in the
standing
and
loss
willful,
of business.
wanton,
of injuring
malicious
the Plaintiff,
and
damages.
to be determined
by this
Court
but
no less than
five
damages.
AGAINST
remedy
the Plaintiff
defaming
loss
emotional
extreme
and
of punitive
RELIEF
by
statements
humiliation,
by Donnelly
in an amount
in punitive
dollars
from
and
to the truth,
to an award
for
defamatory
slanderous
to suffer
severe
disgrace,
against
million
to make
continues
public
made
irreparable
slanderous
that
defaming,
the Plaintiff
falsely
continues
Plaintiff
committed
and realleges
future
Plaintiff
injury
above
trustworthiness,
FIFTH
Plaintiff
knew
s character,
Plaintiff.
to the
INJUNCTIVE
94.
they
have
Donnelly
to the Plaintiff
plus
in
he and Weiss
the Plaintiff
or more
by one
deliberate
caused
conduct
statements
Plaintiff
is liable
Donnelly
integrity,
of self-esteem,
thereof
because
unethical
slander
The
as a result
reported
maligning,
described
have
and
slander
unknown
said
loss
community,
92.
and
of
and
life.
intentionally
and
to those
Weiss
made.
Donnelly
of the
personal
willful
was
falsely
and
be heard
and content
with
revenue.
currently
a result
they
customers
and
statements
reputations
defamatory
information
potential
statements
slanderous
improper,
in that
each
conversations
business.
honesty,
with
before
would
they
causing
and
constitute
of business
loss
Upon
life
and
the Plaintiff's
recipients
91.
statements
statements
charging
and
these
and professional
impugn
89.
his business.
defamatory
personal
these
and
in his personal
Plaintiff
87.
life
untrue
in his business
made
false
or more
in nature
similar
in his business,
actions
and
had one
Donnelly
statements
were
knowing
the Plaintiff
maliciously
Donnelly
and
post,
and
defamatory
customers
clients,
injure
his personal
86.
both
oral
statements
statements
these
to potential
to
repeated
knowledge,
made
in order
85.
were
that
following
the spoken
that
capabilities,
Donnelly
belief,
Donnelly
statements
ethics,
84.
and
Upon
OF
ACTION
WEISS
AND
in paragraphs
and Weiss
by Donnelly
DONNELLY
1 through
will
93 as if set forth
continue
to injure
the
at length.
Plaintiff
in the
damage.
and Weiss
will
continue
to
injure
the
Plaintiff
in the future
causing
PDF Page 10
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
qYSCEF
NYSCEF DOC.
DOC. NO.
NO. 12
78
98.
Issuing
99.
Plaintiff
will
an injunction
has a likelihood
100.
It is in the public's
101.
Accordingly,
this
slanderous
statements
102.
Further,
any
should
this
revoke,
enjoin
the
order
in writing
that the statements
an order
Plaintiff
a trial
demands
hereby
Plaintiff
from
search
of all
by jury
CARY
Defendants
A.
WEISS
On
the
but no less than
from
the Court
harm
On the Third
by
the
Court
On the Fourth
by
the
Court
E.
to
prejudgment
interest
On
Cause
the
Fifth
permanently
per
remarks
his
from
at their
future;
revoke,
respective
remarks
at their
Yahoo
others)
to delist
Bing
five
stated
and
herein.
in his
judgment
the following
million
favor
and
against
the
relief:
of damages
to compensate
An
in an amount
the Plaintifffor
dollars
to be determined
plus
damages,
by
and economic
all monetary
in punitive
of damages
award
to compensate
five
in an amount
the Plaintifffor
dollars
million
An
prejudgment
to be determined
all monetary
in punitive
million
and economic
plus
damages,
by
prejudgment
dollars
of the original
and
and
to
to be determined
Plaintiff
all
dollars
in
for
punitive
monetary
and
damages
plus
of damages
five
in an amount
the
million
Plaintiff
dollars
in
for
to be determined
all
punitive
monetary
and
damages,
plus
occurrence.
from
remove
in
injunctive
(1)
in such
engaging
relief
admit
million
to compensate
and Weiss:
injunctive
withdraw
award
plus
reputation,
and Weiss
five
the
in an amount
occurrence.
An
Donnelly
of damages
to compensate
plus
Donnelly:
(2)
award
dollars
of the original
against
costs:
enter
award
reputation,
and
and
An
million
five
Donnelly
for
Donnelly:
against
the time
of Action
in the
rescind,
the time
than
and slanderous
occurrence.
and
business
restraining
se conduct
permanently
less
individually,
RELIEF
Court
dollars,
five
of Action
no
the
plus
business
from
Cause
harm
economic
his
(Google,
damages
and
FOR
Weiss:
against
than
each
occurrence.
reputation,
less
engines
of fact
plus
against
of action
no
but
dollars,
of the original
interest
prejudgment
million
million
five
and
Cause
to
Weiss:
of Action
the time
harm
economic
D.
Cause
but
against
of the original
business
from
that
reputation,
but no less than
to his
interest
C.
and
the time
On the Second
five
and Weiss
DEMAND
H. DONNELLY,
of action
to his business
interest
B.
Cause
or
publications
results.
issues
prays
MICHAEL
and
First
the Court
harm
E. FRANK
JAMIE
further
untrue.
were
PRAYER
WHEREFORE,
from
per se publications
libel
the search
requiring
the Plaintiff
that Donnelly
all such
JURY
.1URY
104.
and Weiss
Donnelly
requiring
and remove
issue
acts be enjoined.
Plaintiff.
withdraw
against
posts
defamatory
Weiss'
and
issue an injunctive
should
Court
the
harm.
matter.
permanently
defame
and to admit
costs
in this
the Donnelly's
should
that
rescind,
permanently
103.
court
that
and Weiss
Donnelly
of success
interest
this Court
Further,
respective
not cause
such
writing
defamatory,
of an order
consisting
all
relief
libel
that
per
the
for
slanderous
Donnelly
se publications
statements
of an order
consisting
were
and
libel
to
and Weiss
and
untrue,
slanderous
and
(3)
PDF Page 11
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
SYSCEF
NYSCEF DOC.
DOC. NO.
NO. 12
78
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2015
04/10/2018
injunctive
to delist
Plus,
under
Dated:
the
costs
and
relief
all defamatory
disbursements
of an order
consisting
posts
of
this
against
action
the search
requiring
Plaintiff
and
any
from
and
all
engines
search
(Google,
Bing,
Levittown,
New
additional
relief
this
Court
deems
York
6, 2017
submitted,
Respectfully
By:9Ómie
E Frank
Plaintiff,
Pro-se
8 Haven
Lane,
Levittown,
Phone:
Fax:
Email:
and
others)
and
proper
results.
the circumstances.
July
Yahoo
NY
11756
(516) 908-6658
(206) 339-7091
paai l 's ieLF rgnJ'.cond
just
PDF Page 12
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2013
04/10/2018
TYSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
Ripoff Report [ Complaints Reviews Scams Lawsuits Frauds Reported. File your review. Consumers educating consumers.™
By consumers, for consumers...
ERR~~'
Report.
'
taReview Latest Reports a Advanced Search a Browse Categories
Don't let them get away with it!® Let the truth be known!w
e/ea
filed' 2,040,562
a TotalVisitssince 1998:8,820,000,000 a EstimatedmoneyConsumerssavedsince 1998:$15,449,000,000.68 a Reportsfiled:
Update
a Report
Programs&
Services
Help&
FAQs
VenfiedBusiness Legal
Consumer
Resources
Directory
Consumers
Say
Thank You
Directory
Inthe
Media
RipoffReport
Investigates
Repairyourreputation
therightway
ni
% unn Advm :x y
Registeror
et
a Ripoff Report protects consumers first amendment right to free speech
aa'
tfa
"-'
if a
COMING
fnv/st at Sifvcr Today
t
8 ".4
s4
SOON
Oetvaarr~ fat
.
A new investigative Series uncovering Consumer Fraud at its worst.
Real-estate Fraud. Homes and property across Amertica being stolen doors locked so you cannot get back in!
/'
8tefnfiggIlo
aggagamagamaggaggage
yldese
Report: #1276203
LAFERIA
Review:
Complaint
RelatedReports
wmbe
i
ca
as
Jamie
Frank
Law
at
Attorney
Verified
taSubmitted: Fri, December25. 2015 a Updated: Fri, December25. 2015
taReported By: Lost lawyer sold me up the river - surfside Florida USA
t @ttsaff Report
verified
a JamieFrankAttomey at Law 0 Phone:
a Web: www. amiefranklaw.corn
e iÎtownN w York
a Category: LawVers
USA
I GAN
Business
Directory
lf ' I ee/
AR T
" ii
SEVEN DAYS
A WEEK
"
&'a
JBme/&
r'vBPk
/
GtO
SB~'-"
tJIfiiS
BngBG6
nOt
Of
/OUI'
Bt
Af,torAGy
LB'
s~"",.f'iOrrt6e'j
PJUSIr'~""--"~
JBÃyteira
rO
:,'F'"Vi''r'0'pZr
l"
a
rBv'tk
hBVtdI8
thB
t f2tpeV~ YOrk
i""'-',"'if
a /e
REBUTTAL BOX™ | Respond to this Reportl
Add Rebuttal to this Report:,~f::,
F le New Report
Ripoff Reports
„'(7'1 .
Aribitrate & Set Record Straight
Repair Your Reputation
'Attorney'
g I used this sole practice 'Attomey for the Sale of my multi
million dollar business. Three years later I have not seen
a penny. He created an Agreement and Contract that I
actually paid him to create that destroyed my entire life.
He solicited business from the Company he represented
me to sell to. He has no experience, no knowledgeand
absolutely ripped me off. He offered no help, nothing but
bad advice. coerced me into horrible decisions, colluded
with a Broker to cheat me.lf you come across Jamie
Frank Attorney at Law excuse yourself from this con man,
t""""" Is this
Ripoff
Mod
Report
yoW
Ripoff
Report
business'
A busjDBSS first
IfllB Of CIBfellSB
w)
.
fft
PDF Page 13
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2011
04/10/2018
4YSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
do yourself a favor and walk away. I ruined my life
engaging him, plese do not allow this to happento you...
on the
Internet.
g
If your business is
willing to make a
commitment to
customer satisfaction
a d
Doesyourbusiness
havea bad
reputation?
Fixittherightway.
ram'R
Corporate
AdvocacyProgram™
d,
C,
SEOReputation
Managementat its best!
We
!
Rip¤ffReporti.asanexclusive
of
iicensetoths report.it maynotbecopiedwithoutthewrittenpermission
RipoffReport.
y
Click Here to read other Ripoff Reports on Jamie Frank Attorney at Law
Search for additional reports
If youwouldliketo seemoreRip-offReportsonthiscompany/individual
searchhere
JamieFrankAttorneyatLaw
Report
Respond
report!
.i.0ai..a
u.Cscammea
19 e.iass
I ~
i
G„'
SearchTips
& Rebuttal
to this
.t",,'>:
File a Rebuttal .,",,'>:
asidili.masilfas
earch
Also a victim?
Repair Your
Reputation!
File a Report
Get Started
Arbitrate
Remove Reports?
eti Arbitrate to set the record strai hti
No! Better etl
ttsl5R~
550~
I egos
I gOg
e
s
yv
2 yx
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
TY
EF DOC.
NYSCEF
DOC. NO.
NO. 12
78
RECEIVED
17
RECEIVED NYSCEF:
NYSCEF: 07/16/
04/10/2018
vios
Dec 26, 2015
I used
this
later
I have
create
to
sole
not
that
sell
He
but
come
you
favor
bad
walk
He
entire
my
no
life.
Sale
an
into
life
million
Agreement
and
and
excuse
business.
yourself
me
con
this
to
him
to
me
represented
offered
He
to
happen
no
help,
me.If
cheat
do
man,
yourself
to
a
you...
as Useful
Marked
Reply
years
paid
a Broker
this
allow
not
off.
with
from
do
he
Company
ripped
Three
I actually
that
colluded
plese
him,
engaging
the
absolutely
decisions,
Law
dollar
Contract
from
business
horrible
at
multi
my
solicited
Attorney
my
of
knowledge
me
Frank
I ruined
away.
He
no
coerced
Jamie
the
created
experience,
advice,
across
and
Post
has
for
a penny.
seen
destroyed
to.
nothing
'Attorney'
practice
fuicommed
[6votes]
Aug 25, 2016
would
I
submitted
I would
speak
liketo
to
speak
with
who
person
the
complaint?
this
like
with
the
who
person
submitted
this
compliant.
Thank
you.
Mark
as Useful
[2votes]
Aug 3, 2016
JAMlE
Jamie
FRANK
E
E Frank,
accomplishments
contempt
or
your
Post
Write
of
local
court
Law
Law
At
Attorney
that
are
and
criminal
Bar
and
At
(attorney
is a total
false
totally
or
behavior.
make
fraud.
at
His
least
Stay
website
half
away
true.
from
makes
He's
this
claims
being
brought
- or
con-artist
and
states
up
for
better
Mark
Review
about
review
yet,
call
for
the
BBB
a complaint.
Reply
a
MAN
A CON
IS
Law)
Jamie
E.
Frank
PC
as Useful
[2votes]
PDF Page 16
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
4YSCEF
DOC.
NO.
12
RECEIVED
: 07/16/201
RECEIVED NYSCEF
NYSCEF:
04/10/2018
NYSCEF DOC. NO. 78
M-
LawyerRating
Find.
rate
and
review
4
Irf(I'"afe(st~/i"'.r'
drsiceWittj%@'""rts
Attorneys
and
fg"wp 'rp('psych""r"
Lawyers
RRTf4WiffiM192MFAfà55ffEMSXtRM2182282251552352EERR
Jeimie E. Frarik
Altorney
Top
Practice Area: Generai Practice
r ~~
~~ Bied 3
n h
Prosie!ipd
~~"2n
3
~~
~~~~
~
~~~
~~
~ on
~! v ~s~.
~
!~
~ ~ 1,0
~
Rating:
!~
~ out
~or 5 based
~ 1 rev~et
~
~~
~~ ra',!
~~~ ~~ Jam!e
~
~ Fra!ok has
E.
a~ ~~
~
~~~1g
a poor overall
Attomcy
g on
~
~~
LawyerRat!ngz.corn.
~~ J~l~
P
4
Free Consult.
Fees- From $450.
Serving Nassau &
Suffolk Counties.
Theroiiowile post!!!g'1'eve!IOI!de'nSot!Sfef»!die!i
Oj Ld»dyef
Rdi!nfisCOBB
Questions
and
anSWars
abOUt
this
attorney
Post
a
T
Ef:2
Date
L
E
D
6
E
A
T
I
0
i(
A
C
I
T
v
A
L
I
T
v
V
A
L
u
E
8/3/16
1
1
1
1
1
Comments
Nothing but disservice, trouble, lies and scams from Jarnie E. Frank
Attorney at Law Levittowrt NY
Registered users can
Best Rated Attorneys in NY
l'
A,"vI1) I~BR FV:
if(4»„ I 4'K l 4 <1
'l.
Copyright ongo1!LReling Inc. ~ PfivBCV' Con'.BctRBt!BOZ* 'Vt!Bh0 sf n Id Lu!1BGra"hica
I=.XI-IIBI'I
C
g)
PDF Page 17
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DOC.
. 12
. NO.
NYSCEF
DOC.
NO.
78
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
hdQi~
I
Reported
» Person
scam
Jamie
Frank
E.
Jamie
E. Frank,
tûÛ
is a con
Attorney-At-Lav~
Û Ù
artist
4
)
v;.ithout
+1
kr:o:.vledge
any
of
law
00 jamieefrank.com
516-908-6658
Q
Q+
Review
Qw
Favorite
in midst
I was
decision.
what
of selling
my
is when,
I met
That
he does
and
shown
dollar
multimillion
E. Frank
Jamie
some
names
and
company
who
of the
Share
wanted
practices
solely
that
companies
to consult
law.
the
he had
an attorney
before
He assured
me
before
in making
helped
that
making
he was
the
any
great
at
right
selection.
On my
from
penny
business
With
course
of time,
out
of people.
I am
not
life
reason,
have
lost
his
sweet
for
this
because
after
I am
writing
report
You
only
and
have
He will
destroyed
a company
me
off
and
that
and
a contract
myself
then
he does
made
that
he made
not
him
by putting
represented
know
that
in helping
about
the
solution
me
After
three
of my
in-charge
law
at any
and
only
instance.
I have
years,
case.
fof'
for making
to me
company
anything
no effort
sign.
me
sale
how
He even
got
He scammed
my
knows
not
me.
decision.
to make
colluded
a
with
fool
a
me.
ruined
this
back.
and
and
I actually
I discovered
He ripped
to fall
with
away
My
from
in defrauding
at loss
you
of deal.
kind
any
He solicited
broker
an agreement
he build
request,
you
one
leave
hopes
talks.
Most
he expertise
he asked
to help
this
complaint
would
know
chance,
you
of finding
after
of the
his field
me.
here.
what
you
you
sign
right
time
If you
need
any
he speaks
of art,
I should
for
called
have
want
the
problem
about
he got
me
it is fake.
something,
into.
I can
only
He manages
advice
to get
cheating.
done
a thorough
to go with
him
research
for
any
before
of your
legal
him.
hiring
decision,
This
please
is the
read
to do next.
agreement
devastated.
EXHIBIT
D
or pay
him
for
your
service,
you
are
not
going
to get
it
PDF Page 18
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
4YSCEF
NYSCEF DOC.
DOC. NO.
NO. 12
78
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/2013
04/10/2018
The reviews,
Law
Consultants
Attorney
complaints
and
scams
posted
.::":.:::
hB2ab'Ldilya0fillMM0lBàYieziatamia±fB10kt
The
reviews,
the content
using
complaints
posted
and scams
about
about
about
E. Frank.
Jamie
Firm
E. Frank
Jamie
Search
for all reviews,
E. Frank
Jamie
is permanant
If you have
is posted
any concern
record
complaints
and scams
by anonymous.
about
Jamie
located
at
We at dirty
E. Frank's
an
about
report,
scam
e
are not liable
you can
contact
for
us by
':.::s '- i3".a'!.
. ..
.:
ChBt tdFfOOgB
Anglyn
Aviles
Tai
Lopez
Reviews
Debra
Smith
Cynthia
742@comcast.net
HANSFQRP
Ra
gsl
Hansford
1 review
Qnet
University
on Jamie
l|ndia
Report
Seam
Carol
horton
E. Frank
"Jamie
E. Frank
is the
on
This
lawyer
Anonymos
worry...
came
not
out
is rudy
to
I got
scammer"
Januar
and
15,
less
20
7
of talent.
worry...
not
to
totally
got
foairi)ed
worry
but
up.
he
is harass
at end
of the
you
day
for
his
I mean
fees
when
and
will
the
tell
case
you
verdict
not
to
PDF Page 19
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DOC.
NYSCEF
DOC. NO.
NO. 12
78
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
In first
about
the
he
meeting
it at all..
detaiL
Jamie
in the
what
E. Frank
said
the
the
case
middle
he
helL.
you
are
the
you
is very
started
never
shittttt.
to
easy
blaming
asked
go
and
handle
me why
me you
have
and
dump
good
life
you
you
have
Jamie
of
do
not
had
need
not
to
worry
submitted
all
E. Frank.
my fees.
! 'g
REPLY
Rate
Your
and
write
a review
on Jamie
E. Frank
Review
..
-
one
= two
Your
overall
rating
Title
of
review:
your
Name
*
Emalll
*
O
of this
report:
PDF Page 20
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
YSCEF
DO
NYSCEF
DOC. NO.
NO. 12
78
Haven
"Get
Lane
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
8, NY US
d!rectior!
Approved
S
Date
Status
Reported
Severity
Location
Reported
Loss
of
Scam
:
November
:
Published
:
2897
:
Extremely
city:
7, 2016
8
High
Levittown
by:
anonymous
Category
:
Person
Views
:
12 views
Scammer
INDEX NO. 609677/2016
Images
All
P
photos
'1'
(1)
PDF Page 21
FILED: NASSAU COUNTY CLERK 04/10/2018
11:47
AM
16
2 : 5 8
|F ILED
:
NYSCEF DOC. NO. 78
NYSCEF
DOC.
NO.
CLERK
COUNTY
SAU
NAS
07
/ 2017
/
0
PM|
INDEX NO. 609677/2016
™¹"^
RECEIVED
12
*
·
0=
/ / / 2 u1e
RECEIVED NYSCEF: 04/10/2018
NYSCEF:
07/16/2017
VERIFICATION
State
of New
Jamie
York
E. Frank,
Deponent
},
being
ss:
duly
and
therein
knows
stated
sworn,
the
action.
contents
to be alleged
and says:
deposes
in the within
is the Plaintiff
COMPLAINT
matters
}
of Nassau
County
thereof;
upon
Deponent
has read
and the same
information
and
the foregoing
AMENDED
VERIFIED
to deponent's
own knowledge,
except
and as to those matters
believes
deponent
is true
belief,
be true.
Dated:
Levittown,
July
6™,
New York
P.
2017
an(le
Sworn
Notary
to before
PubliC
me this
6™
day
of July,
2017
T ANDRAKUMAR
otary Public - Stateof New York
NO.01CH6121641
Qualified in NassauCounty
My CommissionExpiresJan 24,2021
19
of
20
E. Frank
as to the
them
to
PDF Page 22
INDEX NO. 609677/2016
FILED: NASSAU COUNTY CLERK 04/10/2018 11:47 AM
RECEIVED
RECEIVED NYSCEF:
NYSCEF: 07/16/201
04/10/2018
DOC.
4YSCEF
NYSCEF
DOC. NO.
NO. 12
78
COURT
SUPREME
COUNTY
OF THE
STATE
NEW YORK
OF
OF NASSAU
X
JAMIE
E.
FRANK
Plaintiff,
-againSt-
CARY
WEISS
and
INDEX
MICHAEL
H.
NUMBER:
DONNELLY
Defendants.
X
CARY
WEISS
and
INFINITE
PERSONNEL
INC.
SERVICES,
Counterclaim
Plaintiffs,
Counterclaim
Defendant.
-against-
JAMIE
E.
FRANK
X
AMENDED
COMPLAINT
VERIFIED
Filed
JAMIE
by:
E. FRANK
Plaintiff
8 Haven
Levittown,
Tel:
(516)
Fax:(206)
E-mail:mailla
se
Pro
Lane,
NY
11756
908-6658
339-7091
jamieefrank.corn
609677/2016