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PLAINTIFF, 09 11403
Case No.
V
COMPLAINT
Plaintiff, Linda Hart Flax, by and through the undersigned attorney, sues Defendant,
DOLLARS ($15,000.00).
2. Plaintiff, Linda Hart Flax and Defendant, Steven Todd Flax, met, became
COUNT I
3. Plaintiff reiterates and adopts paragraphs 1 and 2 above and further avers:
thousand dollars).
systematic and unending psychological and emotional spouse abuse against Plaintiff:
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(a). Very shortly after the marriage, Defendant awakened Plaintiff one
immediate divorce,
alcoholism,
trading stock accounts to cloak the accounts from the view of others,
the past and will in the future, suffer and incur great mental pain and suffering, anguish,
embarrassment, humiliation, a loss of earning and has in the past and will in the future be
compelled to incur expenses for doctors and other related medical care and attention and
has been rendered less able to lead and enj oy a normal life and to provide a home for
herself.
WHEREFORE Plaintiff, Linda Hart Flax hereby sues Defendant, Steven Todd Flax
and demands judgment within the jurisdictional limits of this court to wit: in excess of
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FIFTEEN THOUSAND DOLLARS ($15,000.00), exclusive of interest and costs and
COUNT II
7. Plaintiff reiterates and adopts paragraphs 1, 2 and 6 (a- f) above and further
avers:
engaged in behavior that he intended when he knew or should have known that emotional
distress to Plaintiff, Linda Hart Flax, would likely result which exposed Plaintiff, Linda
Hart Flax to disgust, hatred, contempt, ridicule or obloguy which caused Plaintiff to be
avoided, injured in her occupation, potential employment, church, social engagements and
life and engaging in conduct that was outrageous and beyond the bounds of decency,
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(d). Sending derogatory correspondence a local State's Attorney, State's
Plaintiffs mother.
(g). Sent a very negative Facebook page to individuals and a long known
condominium.
G). Sent email under Plaintiffs former married name to pastoral staff,
(k). Sent Plaintiff email indicating her dog had been run over by a car,
friends.
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9. The above listed conducted by Defendant, Steven Todd Flax, was
outrageous, that goes beyond all bounds of decency, and is regarded as odorous and utterly
10. The conduct by Defendant, Steven Todd Flax, caused severe emotional
distress to Plaintiff, Linda Hart Flax, and the emotional distress is severe and as a direct and
proximate result of the foregoing Plaintiff, has been caused to be seriously and grievously
11. As a further and direct approximate result of the foregoing, Plaintiff has in
the past and will in the future, suffer and incur great mental pain and suffering, anguish,
embarrassment, humiliation, a loss of earning and has in the past and will in the future be
compelled to incur expenses for doctors and other related medical care and attention and
has been rendered less able to lead and enjoy a normal life and to provide a home for
herself, all which conditions are permanent and continuing in their nature.
WHEREFORE Plaintiff, Linda Hart Flax hereby sues Defendant, Steven Todd Flax
and demands judgment within the jurisdictional limits of this court to wit: in excess of
COUNT III
12. Plaintiff reiterates and adopts paragraph 1, 2, 5 (a-f) and 8 (a-I) above and
further avers:
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13. Defendant did so negligently and carelessly engage in the activities listed in
paragraphs 5 and 6 and as a direct and proximate result of such carelessness and
negligence, Plaintiff has in the past and will in the future suffer and incur the following
damages: great mental pain and suffering, anguish, embarrassment, humiliation and a loss
of earnings. Plaintiff has in the past and will in the future be compelled to incur expenses
for doctors and other related medical care and attention. Plaintiff has been rendered less
able to lead and enjoy a normal life and to provide a home for herself.
WHEREFORE Plaintiff, Linda Hart Flax hereby sues Defendant, Steven Todd Flax
and demands judgment within the jurisdictional limits of this court to wit: in excess of
COUNT IV
14. Plaintiff reiterates and adopts paragraphs 1, 2 and 8 (a-I) above and further
avers:
15. Defendant, Steven Todd Flax, did conspire with another individual (whose
present name is not known at present) to engage in the actions of creating and sending false
emails, facebooks and blogs as indicated in paragraphs above and as a direct and proximate
result of the foregoing, Plaintiff has in the past and will in the future, suffer and incur the
following damages: great mental pain and suffering, anguish, embarrassment, humiliation,
a loss of earning and a permanent diminishment of overall earning capacity, that she has in
the past and will in the future be compelled to incur expenses for doctors, and other related
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medical care, that she has been rendered less able to lead and enjoy a normal life and to
WHEREFORE Plaintiff, Linda Hart Flax hereby sues Defendant, Steven Todd Flax
and (Individual presently not known co-conspirator) and demands judgment within the
($15,000.00), exclusive of interest and costs and demands a trial by jury of all issues triable
as of right by ajury.
COUNT V
INVASION OF PruvACY
16. Plaintiff reiterates and adopts paragraphs 1 and 2 above and further avers:
17. Defendant by his own sworn testimony placed in Plaintiffs and Defendant's
marital residence a secret audio recording device in all rooms of the residence, including
but not limited to the marital bedroom, bathrooms, living rooms, guest rooms, children's
room, basically all rooms and locations in the house. Such audio recording device,
recorded conversations, marital relations, bathroom activities, etc ... , all without the
knowledge of Plaintiff, until she learned of same during the sworn testimony by Defendant
on August 29,2008.
marriage, during the marriage and after the parties were separated but still living at the
marital residence.
19. During the marriage, Defendant secretly recorded intimate marital relations
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20. The audio recordings were intentional and unlawful intercepts pursuant to
Fla. Stat. 934.03. and were for a torturous purpose and have been used for torturous
purpose.
21. As a direct and proximate result of the foregoing, Plaintiff has in the past
and will in the future, suffer and incur the following damages: great mental pain and
diminishment of overall earning capacity, that she has in the past and will in the future be
compelled to incur expenses for doctors, and other related medical care, that she has been
rendered less able to lead and enjoy a normal life and to provide a home for herself.
WHEREFORE Plaintiff, Linda Hart Flax hereby sues Defendant, Steven Todd Flax
and demands judgment within the jurisdictional limits of this court to wit: in excess of
COUNT VI
further avers:
upon the solitude or seclusion of Plaintiff, Linda Hart Flax, by the highly offensive to a
reasonable person intrusion of placing listening devices in the marital bedroom, bathrooms
and other private areas of the residence Plaintiff expected to be alone in.
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24. Defendant, Steven Todd Flax, confirmed the intentional nature of his
25. The intrusion upon Plaintiffs seclusion would be highly offensive to any
reasonable person having been placed in locations where any reasonable person would
expect the utmost privacy, Defendant's action unreasonable and knowingly assaulted
privacy and the wrongfulness of the conduct springs from the fact Plaintiffs activities were
recorded without her knowledge and consent at a time and place and under the
26. As a direct and proximate result of the foregoing, Plaintiff has in the past
and will in the future, suffer and incur the following damages: great mental pain and
diminishment of overall earning capacity, that she has in the past and will in the future be
compelled to incur expenses for doctors, and other related medical care, that she has been
rendered less able to lead and enjoy a normal life and to provide a home for herself.
WHEREFORE Plaintiff, Linda Hart Flax hereby sues Defendant, Steven Todd Flax
and demands judgment within the jurisdictional limits of this court to wit: in excess of
~ ~,.,
Dated at St. Petersburg, FL, ~/v\.~ooJ
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Thomas M. Woo ff, Esq .
Woodruff Injury Law
4055 Central Avenue
St Petersburg, FL 33713
(727) 327-3111 Phone
(727) 327-1776 Fax
FL Bar No. 121693
Attorney for Plaintiff
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cc: Plaintiff
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