MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT

ROMAN BRICES MOTION FOR SUMMARY JUDGMENT

Introduction
The facts of this two year old and running litigation are well known and the two
allegations against Defendant Roman Brice, essentially political satire and hyperbole
buried on an America On Line political blog at election time should be dismissed.
Hoboken is a mile square city troubled with corruption both in its On the Waterfront
past but very much in the present. Two of Hobokens last four mayors have gone to
federal prison for corruption and their adherents are a present and clear danger to its
health. This litigation is Exhibit A in a SLAPP, the latest Councilwoman Beth Mason
funded political operation, run on this Court from day one to the present spanning more
than two years.1
Defendant Brices website, the Hudson Mile Square View or MSV
(hobokenhorse.com) is approaching 5,000,000 views since its founding five years ago
after the arrest of former Hoboken mayor and convicted felon Peter Cammarano. The
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
1!This!Court!on!April!25th!ordered!the!Plaintiffs!to!produce!to!Defendants!financial,!phone!(wireless!

and!landline)!call!records,!emails!and!related!records!for!the!last!seven!years!to!present!in!20!days.!
Plaintiffs!continued!defiance!at!discoverys!end!to!the!April!25th!Court!order,!restated!in!another!
Court!order!July!11th!reveals!60K!in!deposits!remains!unexplained!among!other!critically!massive!
discovery!,!including!withheld!financials.!Exhibit'A!
!
Separately,!Plaintiffs!are!nonIresponsive!to!a!Court!order!from!Judge!Mary!K.!Costello!July15th.!
account!information!and!bank!records!when!Defendants!discovered!a!Bank!of!America!account.!
Exhibit'C.!

hard news website is on the front lines of a pitted battle against corruption in Hoboken
and often at odds with Councilwoman Beth Mason and her allies (the Russo faction). In
one of its numerous exclusives, the investigative website brought to light a massive voter
fraud scheme using Vote by Mail ballots. That case and confessed affidavits of at least
four voters participating in selling their votes on behalf of the 2010 Tim Occhipinti for
council campaign reached the highest law enforcement office in the state, the Attorney
Generals Office. Further unequivocal evidence uncovered in discovery forced Plaintiff
Mr. Bajardi in his July 16th deposition to admit playing a senior, prominent and
multifaceted insider role on that same Occhipinti 2010 campaign. Exhibit B
In 2014, Defendant Brices hard news website MSV followed up on his years
earlier reports with a new blockbuster of several hundred campaign violations by
Councilwoman Beth Masons 2009 and 2011 campaigns under investigation by NJ ELEC.
When tallied, the potential fines Beth Mason and her treasurer husband, Richard G.
Mason of Wachtell, Lipton, Rosen and Katz runs into seven figures two times over and
would set an all-time State of New Jersey record if finalized. Both Plaintiffs Lane
Bajardi and Kim Cardinal Bajardi acted as senior advisors on these same Beth Mason
campaigns performing dozens of high-level campaign activities each. Since 2007,
Plaintiffs have made strenuous efforts to advance her political career.
Defendant Brices is a voice in the Hoboken reform movement or Hoboken
Reform opposing the Old Guard politics of the Russo faction aligned and financially
supported by Councilwoman Beth Masons family. While theres no allegations against
his website, Plaintiffs and its counsel have at times falsely claimed otherwise and made
efforts in this litigation targeting his website in discovery, repeatedly demanding

information of its readers and subscribers unrelated to their bad faith claims. All those
actions betray a fundamental political operative service on behalf of Beth Mason in this
SLAPP.
In spite of the two years plus in this running litigation, Defendant Brice continues
on his MSV website to uncover and report on Hoboken government and politics with a
focus on corruption. Most recently hes produced the most extensive investigative
coverage two years running revealing serious illicit actions in the Hoboken Housing
Authority. The federal agency is under the stewardship of close Beth Mason ally Carmelo
Garcia and is defended by ethnic cleansing attorney Louis Zayas.2
For the sake of brevity and to ease further imposition on the Court, Defendant
Brice references the June 13th Summary Judgment motion submitted by Defendant Heyer
and its detailed applicable defenses with limited exceptions here. Respectfully, the Court
is asked to reference the March 2013 Summary Judgment motion submitted by Defendant
Nancy Pincus where voluminous background of political operative activities by Plaintiffs
is detailed and Exhibit A of Defendant Mark Heyers Summary Judgment Motion,
Exhibit A Statement of Undisputed Material Facts.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
2!In!2013,!civil!litigation!claiming!Mayor!Dawn!Zimmer!was!exercising!ethnic!

cleansing!of!Hoboken!minorities!and!residents!of!Italian!background!was!thrown!out!of!
Hudson!County!Superior!Court!last!January.!!

THE TWO ALLEGATIONS AGAINST DEFENDANT BRICE ARE

NOT SUPPORTED BY THE FACTS OF THIS LITIGATION AND UNDER
NEW JERSEY LAW
There are but two allegations against Defendant Brice: solely by Plaintiff Lane
Bajardi. One appeared on Hoboken Patch in a political story a day before a Hudson
County Freeholder election, the other on a political blog hosted by the same website. Of
the two, dozens and then hundreds of comments were posted in heated back and forth
political expressions of opinion and commentary, typical to Hudson County and
especially Hoboken. The two allegations clearly fall within clear standards of the NJ
Constitution provision of protected free speech, especially political speech on matters of
public concern as here. Plaintiffs produced no evidence and material facts in discovery
showing the statements are in fact defamatory, merely alleging potential harm.
Plaintiffs have no actionable basis for their claims of defamation or defamation
per se. As stated in the Summary Judgment Motion by Defendant Mark Heyer, (See
Point II), Summary Judgment is the method preferred for disposing of defamation claims
and here where defamation per se is inapplicable. See W.J.A. v. D.A., 210 N.J. 229,
240 (2012).
See also:
Lynch v. New

Jersey

Educ.

Ass'n, 161 N.J. 152, 169

(1999), citing Dairy

Stores, Inc. v. Sentinel Publ'g Co., 104 N.J. 125, 157 (1986); see also
G.D. v. Kenny. 205 N.J. 275, 304-05 (2011) ("[A] timely grant of summary

judgment in a defamation action has the salutary effect of discouraging

frivolous lawsuits that might chill the exercise of free speech on matters of
public concern."); Maressa v. New Jersey Monthly, 89 N.J. 176, 196 (1982)
and Printing Mart-Morristown v. Sharp Electronics Com., 116 N.J. 739, 765
(1989). Slander or libel per se, subcategories of defamation that do not require
proof of special damages, apply only where statements of fact charge the
commission of a crime, contraction of a loathsome disease or the unchastity
of a woman.

THE TWO ALLEGATIONS AND EVIDENCE FROM PLAINTIFFS

ELMINATES THE BASIS FOR ANY DEFAMATION CLAIM
The first allegation from paragraph 35 of the complaint:
Lane Bajardi is back. Still fighting for the corrupt and The Machine for
his Beth Mason paycheck. Yawn. Same ole, same ole.
The second allegation is similar but completely taken out of context by Plaintiffs,
paragraph110:
The boldfaced print is the portion of the post omitted by the Plaintiffs; the italic
print is what is found at Paragraph 110. The judge did not dismiss the case as being
political. He slammed Matt Calicchio for bullying and called his testimony
garbage. Quotes from the judge: There was no
credible testimony by Tania Garcia and Matt Calicchio. This is very

disturbing and uncivilized. This is bullying. Any board member should be

allowed to live their lives without being accosted on the streets. The judge
described the testimony of Matt Calicchio as garbage. No matter what Beth
Masons other paid political operative Lane (prosbus/Madison Monroe/ et al)
Bajardi has to say about his fellow Mason paid political operative Matt
Calicchio, the judges comments speak for themselves even if the prosecutor
lacked the evidence for a conviction. The witness actually testified against the
complainant. The judge called her testimony on behalf of Matt Caliccchio not
credible. So all around a big victory for Beth Mason. Her employees did a
great job! He also said Matt Calicchio is being used.

The quoted statement for paragraph 110 really makes little sense to assign an
allegation of defamation. It is quite a stretch to say that it is defamatory of Mr. Bajardi. It
should be no surprise that this paragraph takes the quoted statement out of its true and full
context. One might reasonably infer that this was done intentionally. In any event, it is
worth placing the full post found on Hoboken Patch on the record. The citation to
Hoboken Patch is found at paragraph 111 of the Complaint.
Whatever one may think is being said in this post, it is not about Lane Bajardi
being involved in criminal activity. It is a satiric rant against Matt Calicchio who works
for Councilwoman Beth Mason even as he was again charged with harassment, this time
against a 70-year-old Hoboken woman with a heart condition. (MSV December 5th, 2013
exclusive: Beth Mason political operative Matt Calicchio charged in alleged threats
against Hoboken senior. http://www.hobokenhorse.com/2013/12/beth-mason-political-

operative-matt.html
It should also be noted that this post was part of a thread of over 700 posts in
response to a political bloggers article on charter schools in Hoboken that was published
on May 21, 2012. The subsequent posted comments continued for weeks afterward. The
alleged defamatory post by Brice came in the midst of a series of posts by others
concerning a Union City judges findings in a criminal harassment complaint brought by
then Board of Education member Theresa Munitillo against Matt Calicchio.
The judge found Calicchio not guilty but, on the record, called him and his
witness liars. A fair reading of the posts on this subject contained in the thread cited at
paragraph 111 shows the two political camps making what they can out of this ruling.
The Mason-Old Guard Russo faction has its spin, i.e. Not Guilty, Not Guilty while the
Reform group has another spin, Liar, Liar. The thread of posts on the Calicchio trial
begins at 1:20 am on June 8, 2011 and continues over days. The post by Brice is at 6:34
am on June 8th and all are contained in the URL citation at paragraph 111 of the
Complaint.
Once again Bajardi claims that calling him a political operative and/or saying that
he was paid for his work is defamatory. Similar in scope to Paragraph 35, it should be
recognized the term political operative has no precise objective definition. What
exactly it means to one person may differ from anothers opinion of the meaning.
Therefore, by its very nature, calling someone a political operative is an expression of
opinion.
Furthermore, saying that someone was paid for his/her work, as noted above,
cannot be considered defamatory. We live in a capitalist society where hard work is

encouraged and valued, normally in the form of financial remuneration. A reasonable

person would presume that a person gets paid for his work. In fact, it is arguable that
saying someone isnt paid for his/her work is more likely defamatory than saying that
someone is being paid. Of course, there are often other motivations for volunteering work
in a given instance. But the bottom line is that in this country there is absolutely nothing
wrong with getting paid for working.
The context in which the statement from paragraph 35 in the complaint was made
can be found in the body of the Complaint and the website which it cites in paragraph 36.
It begins on Monday November 7, 2011 Hoboken Patch, a political news blog, describing
an interview with incumbent Hudson County Freeholder and candidate for re-election,
Anthony Romano. He is described as the candidate of the Hudson County Democratic
Organization (HCDO) (Almost always referred to as The Machine by friends and foes
alike), while his opponent is a favorite of Hoboken Reform. What follows the next day
is an election; its Election Day in Hudson County! If this does not fall within the
political context covered by a First Amendment blanket and the higher bar under New
Jersey law for political speech then nothing is. The complained of statement is one of
about 60 excited posts induced by the article and the imminent election. Needless to say,
Brice with Reform and Bajardi with the Beth Mason underwritten Russo faction are on
different sides of the political fence. Exhibit D (http://patch.com/new-jersey/hoboken/inrunning-for-re-election-freeholder-wants-to-improvb28d1fc3dc)
Further on context, the statement attributed to Brice follows several posts by
other(s) which mention the Plaintiffs, implying that they are political operatives and
supporters of The Machine and are involved in political shenanigans with

Councilwoman Beth Mason.

The Brice post is clearly a satirical statement of political hyperbole and opinion
made in the heat of a political skirmish. What election has ever occurred in Hudson
County without both sides using the term corrupt to describe the opposing team on the
other side?
Further, and most significantly, Defendant Brice did not call Mr. Bajardi corrupt
but only that he is fighting for the corrupt and the (HudCo) Machine. It cant be said
that this is an accusation of a crime. Further, the Plaintiffs own complaint at paragraphs
32 and 33 implicitly admits that he was a supporter of Peter Cammarano and that
Cammarano is a convicted felon for political corruption. Surely that was support for
corruption; but this isnt defamatory of Mr. Bajardi. Many, many people support
candidates who are later found involved in corruption and must listen to their opponents
litany of I told you sos.
Restated, there is nothing illegal or inherently wrong with getting paid by a
candidate for work done on political campaigns. Its done all the time all over the
democratic world. Being a political operative is a worthy profession. It is not a
defamatory remark to state that someone has been paid for efforts on behalf of a
politician.
While Plaintiff Lane Bajardi alleges this could become problematic for his
current media employment as a newsreader for 1010 WINS, he offers no proof against
Defendant Brices it ever did. Mr. Bajaris media work history at Bloomberg actually
revealed in his own email he acted behind the scenes in ghostwriting political operative
activity to influence the Hoboken public and was concerned about its revelation. In his

deposition, Plaintiff Lane Bajardi admitted his plea to Perry Klaussen of Hoboken411 not
to email him at his office as it could be difficult to explain if discovered. In a separate
email November 8, 2007, a panicky Mr. Bajardi responds to Perry Klaussen revealing the
Plaintiffs ghostwriting writing has been discovered:
Seriously though, now I'm concerned that he is going to try to get me fired.
It is imperative that you never admit to anyone that I have written anything for you,
especially if Lenz and Soares are about to drop a dime on me to my bosses. The
person of concern is former Councilman Tony Soares who forwarded an email revealing
he had figured out Mr. Bajardis role at Hoboken411. Klaussen forwards the email to Mr.
Bajardi saying, Ill run him over. Mr. Bajardi greets this idea replying, If you do,
youll just be putting him out of his misery! Exhibit E
In 2011, the two year plus unemployed Mr. Bajardi who had been ghostwriting
the vast majority of political articles on Hoboken411 back to 2007 conspired with its
owner Perry Klaussen to maximize and divide monies from the Russo faction candidates
Councilwoman Beth Mason sponsored including a large Mason banner ad. Klaussen in
an email March 22nd, 2011 offers to split the proceeds saying their expected take
should be in the ballpark of $4,800 or more. Exhibit F
Lane Bajardi requested compensation for a Hoboken City Council preview he
would prepare in June 28th for a July 2011 meeting. Exhibit G
Councilwoman Beth Mason is personally and directly seen offering compensation
to the unemployed Plaintiffs in providing her vacation home via an email between the
parties dated July 12th, 2010. Exhibit H
In his July deposition, Mr. Bajardi reaffirmed the claims on his interrogatories to

have never sought or accepted compensation for his political activities even as he was in
the midst of over two years of unemployment. This fabrication contradicted by his own
emails coincides with Plaintiffs withholding discovery already ordered produced by the
Court in three current orders Plaintiffs defy.

CORRUPTION ISSUES NEW AND OLD ARISE ON PLAINTIFFS

CAMPAIGN EFFORTS FOR BETH MASON IN 2009, 2011 AND TIM
OCCHIPINTI IN 2010

Last March 8th, Politicker NJ covered the open investigation of the massive
violations Beth Mason faces for her 2009 and 2011 campaigns and the millions in
potential fines in an article writing:
ELECs complaint against Hoboken Councilman Beth Mason is a nightmare for
the former mayoral candidate, who could face $2.6 million in fines. When you tally all
the alleged violations of Mason and her team, it adds up to an unbelievable $14.3 million.
See: http://www.politickernj.com/back_room/masons-elec-mess-hoboken On Masons
team acting in multifaceted roles as senior advisors in both her 2009 and 2011
campaign were both Plaintiffs, Lane Bajardi and Kim Cardinal Bajardi. As a husband and
wife political operative team they performed similar starring roles for the controversial
2010 Tim Occhipinti for Council campaign. That one ward in Hoboken generated
approximately 500 Vote by Mail ballots, 575 paid campaign workers mostly out of the
Hoboken Housing Authority for a paltry 1240 votes total.
While it was MSV which blew the whistle and uncovered the illicit VBM

schemes before and after the 2010 fourth ward special election, other media would follow
Defendant Brice covering the vote scandal including but not limited to PolitickerNJ, the
Hudson Reporter, Hoboken Patch and Blue Jersey, a progressive online publication
which wrote: Red flags: How much does it cost to buy an election in Hobokens 4th
ward? Exhibit I
As opinion is never actionable defamation, several categories of opinion, in this
instance combining satire and hyperbole with facts shown in the supporting evidence
provided by the Plaintiffs own words here can never be viewed as actionable defamation.

Political opinions as expressed here occupy the highest rung of protected

speech and are never a basis for a defamation suit. Snyder v. Phelps,
131 S.Ct. 1207, 1215-16 (2011) ("Speech deals with
matters of public concern when it can 'be fairly considered
as relating to any matter of political, social, or other concern
to the community.") "Political discourse depends on the
expression of opinion" and, therefore, New Jersey Courts
will not suppress speech relating to politics, even though
such speech may be emotional, partisan, or self-interested.
Lvnch, 161 N.J. at 168. As shown here, each of the
complained of statements address Hoboken politics, within
articles on a political blog, or within heated political debates
in the comments' sections of another article on the Hoboken
Patch blog.

As expressions of opinion within political

discourse, the Statements are non-actionable.

Further, opinions concerning the beliefs of others are
subjective assertions not sufficiently susceptible to being
proved true or false to constitute defamation. Edelman v.
Croonquist, No. 09-1938, 2010 WL 1816180 (D.N.J. 2010)
(blog entries accusing plaintiffs of being racists were nonactionable opinion).

SLAPP EVIDENCE AND MORE OF PLAINTIFFS POLITICAL

OPERATIVE ACTIVITIES ON BEHALF OF BETH MASON

In the spring Beth Mason for Mayor campaign, Plaintiff Lane Bajardi blasted
campaign manager Jake Stuiver in an email with Kim Cardinal Bajardi, Ricky Mason and
others. The email is referenced in Exhibit A of Mark Heyers Statement of Material Facts,
no. 112 and says:
Weve been at City Council meetings fighting the good fight covering Beths
flank for years. While you were off at Camp Wellstone we were working to get
Beth elected to the 2nd ward seat in the first place so that she could be in this
position today.
Plaintiff Lane Bajardi admitted in his deposition hes been threatening over years
to sue others in the Reform movement going back to 2007. In his February 28, 2014
deposition, former Councilman Tony Soares testified to a threat Mr. Bajardi made

believing Soares had interfered with his desire to bid on a chair at a local Hoboken
function. Beth and I are going to own your condo, is what Soares testified Mr. Bajardi
said to him. Exhibit J
Defendant Brice certified just last month that on his first meeting Plaintff Lane
Bajardi in late October 2009 at a mayoral debate hosted by Stevens Institute, within a
minute he was threatened with being sued and thrown out of the auditorium.
Political consultant Tom Bertoli, a senior advisor to Jersey City Mayor Steven
Fulop testified in a deposition last January. He described Plaintiff Lane Bajardi as a
senior advisor like himself, and conversations with Beth Mason and Mr. Bajardi about
suing bloggers during her spring 2009 mayoral race.
No Defendants had websites but Hoboken bloggers in general were considered
a problem and Bertoli outlined the discussions to file frivolous lawsuits and draining
defendants who were getting in Masons way for higher office. Exhibit K
In a January 4th 2011 email, Plaintiff Lane Bajardi told Hoboken411 owner Perry
Klaussen his desire to sue others was limited by his lack of funds and the lengthy time it
would take to see any outcome.
I obviously do not have unlimited finances to fight a protracted legal battle.
Exhibit L
Enter Beth and Ricky Mason. In an email, one of a series identified in
conversations going back to March 2010, Plaintiff Lane Bajardi complains vociferously
about what he perceives as attacks and threats while lacking coherence to point to

anything in reality. That recurs repeatedly as in this March 2010 email generated from
Beth Mason political operative James Barracato to Plaintiffs Lane Bajardi and Kim
Cardinal Bajardi. Also included is Ricky Mason at his legal office where Mr. Bajardi says
the Masons should pull the trigger and hire a reputable attorney to take on the people
attacking us writing (in his original blue bolded text):
The time has come to hire a reputable attorney who has
experience in these matters to begin to file suit against these
people. The people attacking us count on the fact that legal
action is time consuming and expensive..

Exhibit M

Plaintiff Lane Bajardi then attempts to leverage a quid pro quo for his
soldiering as a political operative attack dog implicitly referencing his work at City
Council meetings and political articles on the censored controlled website Hoboken411.
Its clear he wants to leverage it for legal assistance he wishes the Masons to give me
in the matter.
If I am to continue to be involved here I need legal assistance.
The line has been crossed many times, and it's time to seek damages
and send a message that this activity should not be condoned. Any
assistance you and Ricky can give me in this matter would be welcome
and appreciated. Exhibit M
Bajardi launches into a conspiracy theory urging that Beth and Ricky Mason (at
his law office) to begin to file suit against these people. Plaintiff Bajardi alleges of

having been called a looney leprechaun and unemployable he is being driven out of
Hoboken. Neither of these limp citations however were made by Defendant Brice or on
his MSV website. Plaintiff Kim Cardinal Bajardi earlier chimes in saying, If you want to
teach this guy (Brice) a lesson and get him to stop harassing Beth then there are ways to
do it. One way of course as Tom Bertoli suggested a year earlier is via frivolous lawsuits.
In October September 12, 2011, Councilwoman Beth Mason is sufficiently
motivated instructing her political operative soldiers, senior political operative James
Barracato and Plaintiff Lane Bajardi, I ask you to compile important posts that show
how the dialogue against members of our is ratcheting up in severity. Thanks.
Exhibit N (Included on the email is Beth Masons husband, Ricky Mason at his
Wachtell, Lipton, Rosen and Katz office.)
On March 4th, 2012 Plaintiff Lane Bajardi thanks Ricky Mason for what sounds
like a business meeting and pitched his case again for financial support to sue. His pitch
was sending comments posted by This Means War on Hoboken Patch where his
parenting was criticized and calls it a threat against his son. Mr. Bajardi then proceeds to
discuss an alternative universe pointing to what he deems are his political enemies
saying they are threatening to send their kids in to assault mine. Of the four he accuses,
former Councilman Tony Soares and Defendant Brice have no children whatsoever and
Mr. Bajardi admitted as much in his deposition but here he writes,
The only way to stop the harassment and threats in this alternative
universe created by Nancy Pincus, Roman Brice, Michael Lenz and Tony Soares
is to get a lawyer who will go after those responsible. They are threatening to

send their kids in to assault mine. This cannot stand. I need help to unmask
these horrible people and punish them for their unlawful trespasses.
EXHIBIT O
That summer in the July 2012 Hoboken City Council meeting, Councilwoman
Beth Mason would respond to Defendant Roman Brice in one of his infrequent
appearances where he requested she make available public information on her 501(c)(3)
entity, the Mason Civic League. Mason responded knowingly of the impending SLAPP
saying, Mr. Brice is on the verge of some legal action and if the council would make
sure its appropriately handled. On the latter no one know what it means as its part of
Beth Masons usual broken syntax but this litigation was filed two weeks later.
See: https://www.youtube.com/watch?v=ilrEoAwqnTU
Back in 2010 after a January 10th special City Council meeting Plaintiff Lane
Bajardi expressed concern he had displeased Councilwoman Beth Mason and wrote of
what he deemed attacks against Beth Mason among a small group of speakers at the
sparsely attended event. Even as Mr. Bajardi himself was stopped in the middle of his
attack dog remarks by the Corporation Counsel who interrupted stating concern the
Council was being made witness to slander on live TV, the Plaintiff had an alternative
universe reality in mind writing the same evening:
in contrast I seem to be the only one (besides Perry, who
wasnt there tonight) who defends you and the majority. You need more soldiers
to combat their attacks and lies. Exhibit P

CONCLUSION
The facts at this juncture while incomplete due to Plaintiffs limitless intransigence
to Court orders, completely undermine the two allegations against Defendant Brice and
are derived in New Jersey law and from Plaintiff Lane Bajardis own words. His private
pronouncements obliterate his claims hes not a political operative, paid or not, acting as
a soldier defending the Councilwoman Beth Mason and the Old Guard in numerous
political operations, election campaigns of questionable repute and other activities with
an eye on impacting public opinion on issues of public concern in Hoboken.
As this summary judgment motion is entered before the Court, Plaintiffs continue
to treat the case as a full-fledged political operation on behalf of Councilwoman Beth
Mason. The flouting of Court orders, repeated avoidance of noticed depositions and
refusal to comply with the April 25th Court order plus two July Court orders puts
defendants at a distinct disadvantage filing a complete Summary Judgment motion within
the full deadline. Nevertheless, the facts are sufficiently in.
For all of the reasons herein above, Defendant Roman Walter Brice respectfully
requests this Court to grant the foregoing motion for summary judgment
Respectfully submitted,
Attorney for Roman Brice

s/Alexander W. Booth
ALEXANDER W. BOOTH, ESQ.
August 3rd, 2014

EXHIBIT A

Unexplained*deposits*.*circa*Occhipinti*2010*campaign,*circa*Mason*2009*
&*2011,*and*circa*this*lawsuit.*!
'
Note:'Plaintiffs!various!financial!accounts!show!a!gross!dubious!deposit!
amount!of!over!$63k.!
!

!
!

EXHIBIT B

From: Tom Bertoli <tombertoli@yahoo.com>

Sent: Wednesday, October 20, 2010 2:48 PM
To: Lane Bajardi <lbajardi@aol.com>
Cc: james_cryan@yahoo.com; jamesbarracato@gmail.com; davidcruz1962@gmail.com;
alexander.habib@gmail.com; timothy.occhipinti@alliancebernstein.com
Subject: Re: First Email I like lanes whole angle on this issue.
Executed properly will be a homerun. Sent from my iPhone On Oct 20, 2010, at 12:49
PM, Lane Bajardi <lbajardi@aol.com> wrote:
He may miss the Southwest Redevelopment discussion if he gets there at 9pm, but
probably not the open Public Comment portion.
If he needs to be somewhere else meeting voters (which makes perfect sense to me) I
would suggest that I sign him up for the open portion, but that we don't sign him up
for the Southwest Redevelopment resolution until he gets there at 9pm.
He can always comment on the Southwest Redevelopment issue during the public
portion as well. It's not like our comments are going to change the vote on this. It's
just an opportunity to show their inaction on the plan, which we have already done
with the press release, and I will also do so during the resolution discussion.
So, yes... meeting voters and pressing the flesh should be job 1 until 9pm, followed
by the meeting. If it is for some reason moving ridiculously fast I can get in touch
with Tim and let him know if he will be in jeopardy of missing the open portion.
-----Original Message----- From: Jamie Cryan <james_cryan@yahoo.com> To: Lane
Bajardi <lbajardi@aol.com>; jamesbarracato@gmail.com;
davidcruz1962@gmail.com Cc: tombertoli@yahoo.com; alexander.habib@gmail.com;
timothy.occhipinti@alliancebernstein.com Sent: Wed, Oct 20, 2010 12:37 pm Subject:
Re: First Email
Lane, so getting Tim there at 9pm should be ok?
From: Lane Bajardi <lbajardi@aol.com> To: james_cryan@yahoo.com;
jamesbarracato@gmail.com; davidcruz1962@gmail.com Cc: tombertoli@yahoo.com;
alexander.habib@gmail.com; timothy.occhipinti@alliancebernstein.com Sent: Wed,
October 20, 2010 12:26:46 PM Subject: Re: First Email
I like it, too. Nicely done. It's more "Hey, did you know Lenz is Effing us? That's
not cool! Here's what I'm going to do about it." Much more Tim-like, and Cruz's
letter should be the basis for Tim's comments tonight.
Tim should also say something about how so many Hoboken families with parents

who have lost their jobs are suffering to make ends meet and pay COBRA bills for
their health insurance while Lenz pockets a $4600 bonus. This will thwart the
guaranteed Lenz response of "This is an unfair attack because my family has had to
suffer and do without for my choice to step up and bring my skills to Public Service
for the county and the city at a much lower salary than I made in the private
sector..." It is imperative Tim include the comments above to avoid that trap.
I know how Lenz thinks. This will be his response strategy. We need to disarm him
BEFORE he speaks, because Carol Marsh won't give Tim the chance to follow up.
This is crucial.
I will be at the council meeting and can sign Tim up to speak in his absence. What
time would you expect him to be there if he does show? It won't be a super heated
meeting, but I doubt they will get to the Southwest Redevelopment resolution before
8:30, and the Public Portion won't happen before 9pm, if not much later.
-----Original Message----- From: Jamie Cryan <james_cryan@yahoo.com> To: James
Barracato <jamesbarracato@gmail.com>; david cruz <davidcruz1962@gmail.com> Cc:
Lane Bajardi <lbajardi@aol.com>; tombertoli@yahoo.com; alexander.habib@gmail.com
Sent: Wed, Oct 20, 2010 11:39 am Subject: Re: First Email
Perfect. Let's get it out with the "Today, I'm calling for..."
From: James Barracato <jamesbarracato@gmail.com> To: david cruz
<davidcruz1962@gmail.com> Cc: Lane Bajardi <lbajardi@aol.com>;
tombertoli@yahoo.com; james_cryan@yahoo.com; alexander.habib@gmail.com Sent:
Wed, October 20, 2010 10:27:59 AM Subject: Re: First Email
This is very good On Oct 20, 2010 8:45 AM, "david cruz" <davidcruz1962@gmail.com>
wrote:
here's an edit of the e-mail language. It closely resembles the press release we're putting
out on this.
The only problem is that Tim may not make the city council meeting tonite, ehich may
alter the schedule of release somewhat. We'll just have to retouch the language in the email to something like "Today, I'm calling for ..."
cruz

EXHIBIT C

Exhibit D

Exhibit E

Hoboken411@gmail.com> Sent: Thursday, November 8, 2007 7:43 PM!To:

rdhvn@aol.com!Subject: RE: Lane/Prof Pinetop gave you wrong info.
I"hold"my"secrets"TIGHT"and"strong.
The"last"thing"Id"do"is"jeopardize"our"working"rela=onship.
Especially"in"regards"to"those"knuckleheads.
Theres"nothing"anyone"can"see"that"will"reveal"your"iden=ty.
Just"be"sure"you"clear"your"internet"history"and"any"outgoing"messages"that"you"may"
have"on"your"work"PC."Im"not"sure"how"careful"you"are..."But"Im"fairly"certain"you"keep"
things"neat"over"there.
Thanks,
Perry
www.hoboken411.com hoboken411@gmail.com
From: rdhvn@aol.com [mailto:rdhvn@aol.com] Sent: Thursday, November 08,
2007 7:12 PM To: hoboken411@gmail.com Subject: Re: Lane/Prof Pinetop
gave you wrong info.
If you do you'll just put him out of his misery!
Seriously though, now I'm concerned that he is going to try to get me fired. It is
imperative that you never admit to anyone that I have written anything for you,
especially if Lenz and Soares are about to drop a dime on me to my bosses.
As for accuracy, it will all be there on Channel 78 for the world to see.

-----Original Message----- From: hoboken411@gmail.com To: rdhvn@aol.com Sent: Thu,

8 Nov 2007 4:51 pm Subject: Fw: Lane/Prof Pinetop gave you wrong info.
I'm gonna run him over one day
Sent via BlackBerry from T-Mobile
-----Original Message----From: tony soares <tonysoares@optonline.net>
Date: Thu, 08 Nov 2007 16:33:23
To:Hoboken411 <hoboken411@gmail.com>
!

Subject: Lane/Prof Pinetop gave you wrong info.

Mason was not supported by Councilmembers . Beth looked
like a fool
I would think his ghostwriting by now would have landed
him In Bloomberg News
former employees file but no.
Ths post was true: At yesterdays City Council meeting, Ms.
Mason acknowledged
that she was not aware that this step had been taken. Given
her interest in this
issue, I found that surprising, and somewhat
disappointing.
Email and AIM finally together. You've gotta check out free AOL Mail!

EXHIBIT F

From: Hoboken411 <hoboken411@gmail.com> Sent: Tuesday, March 22, 2011 9:03

PM!To: rdhvn@aol.com!Subject: Ad Rates
Hey"Lane"(between"you"and"I)
What"should"I"charge"the"candidates..."I"figured"we"have"at"least"four"that"will"sign"up""
and"I"want"to"be"able"to"pay"you"too..."Between"now"and"the"first"elec@on""I"was"
considering"charging"between"$1000O1200"for"a"big"banner""and"a"share"of"the"mason"
banner..."That"would"be"$4800"for"four"candidates""which"Id"split"with"you"as"well..."
how"can"I"go"about"geKng"these"idiots"on"board"already?
Oh,"and"Id"have"to"charge"them"$100"a"pop"for"each"banner""my"cost."Cheers,
Perry"Klaussen"Founder"/"Publisher"www.hoboken411.com"
hoboken411@gmail.com"(201)777O0411"(email'is'preferred,'though)'
'
'

'

EXHIBIT G

From: Hoboken411 <hoboken411@gmail.com> Sent: Tuesday, June 28, 2011 12:47

PM To: 'Red Haven' <rdhvn@aol.com> Subject: RE: Holy crap - a council meeting on
7/1?
If I had sales help (Im interviewing two this week) I would be able to. Im 2 months
behind in rent and u=li=es now as it is. And going forward what is reasonable
compensa=on so I can budget it in if sales pick up?
Thanks,
Perry
www.hoboken411.com hoboken411@gmail.com
From: Red Haven [mailto:rdhvn@aol.com] Sent: Tuesday, June 28, 2011 11:47 AM To:
hoboken411@gmail.com Subject: Re: Holy crap - a council meeting on 7/1?
Yes a preview is in order. So is reasonable compensation for the preparer of said preview.
-----Original Message----- From: Hoboken411 <hoboken411@gmail.com> To:
rdhvn@aol.com Sent: Tue, Jun 28, 2011 3:52 am Subject: Holy crap - a council meeting
on 7/1?
I couldnt believe it when I saw it... why would they schedule a council meeting on the
th
July 4 Weekend? Horrible! Is it true? If so I guess a preview is in order?
WTF? Cheers,
Perry Klaussen Founder / Publisher www.hoboken411.com
hoboken411@gmail.com (201)777-0411 (email is preferred, though)

EXHIBIT H

From: nlll@optonline.net
Sent: Monday, July 12, 2010 7:52 AM
To: Kimberly Cardinal & Lane Bajardi & Family <lbajardi@aol.com>; Kimberly
Cardinal & Lane Bajardi & Family <kcardinalmn@yahoo.com>
Subject: Good morning
I wanted to check in with u I have the full agenda. I told someone that its 33 resolutions 7
ordinance and a pea in a shell game. Garage is still topic etc while We spent 7k on bike
racks. Hope all three of you are well and enjoying the summer. I would like to offer our
house upstate if you would like to use it to get away. All the Best. Beth!Sent from my
Verizon Wireless BlackBerry

EXHIBIT I

Red Flags: How much does it cost to buy an election in Hoboken's 4th ward?
by: Rosi Efthim
Tue Dec 21, 2010 at 03:06:24 PM EST
Outgoing Hoboken Councilman Michael Lenz's supporters say it costs about $22,000.
That's how much his opponent Tim Occhipinti spent on "campaign workers" to win Ward 4's Council seat
in November. What's unusual about that? Well, nothing, until you consider that there were about 575 of
them, and that for all that Election Day "field" help there was little Occhipinti campaign presence visible
on 4th Ward streets (say the Lenz folks). And that Occhipinti paid 575 workers for an election in which
only 2,076 people cast ballots (Lenz Election Day paid workers = 17). Most alarming is a spike - a big
one - in vote-by-mail ballots, and who it was who turned them in: overwhelmingly it was Occhipinti's
"campaign workers". Hoboken Ward 4 absentee voting dwarfs that of every other election in Hudson
County, according to the Hudson Clerk's figures. The county prosecutor's office recently referred 190
vote-by-mail ballots to the state Attorney General's office, though it's not known if any investigation
concerns the Lenz campaign's allegations.
Take a gander at this graphic, then tell me you don't see red flags. You're looking a chart of the vote-bymail percentages for the Hudson County general election (data source). Compare Occhipinti's absentee
voter percentages with other Hudson races, and with Len
We wrote about this Oct. 28, when 3 Ward 4 residents swore out affidavits saying they were offered "$40
as an incentive to vote absentee". But this is bigger now. The new information, via ELEC final campaign
spending reports illustrates that the breadth and size of what may be election corruption may be far
greater. Do we know there was corruption? We do not. But where this many red flags are raised, there
should be investigation. And Hoboken's next election should be monitored by credible election protection
experts.
Some of Hoboken's councilmembers are already taking a position: "It looks like he bought the election,"
says Councilman Ravi Bhalla, who is also volunteer legal counsel for the Lenz campaign. Among
Occhipinti donors: Councilmembers Michael Russo and Beth Mason. Among Lenz's: Bhalla, fellow
councilmember Carol Marsh and Mayor Zimmer. Bhalla goes so far to allege forgery. Of 99 ballots
thrown out election night, he says 82 had mismatched signatures. In 2 Ward 4 districts, about 80% of
absentee voters were also employed by the Occhipinti campaign.
For the record, an Occhipinti spokesman denies any wrongdoing, and rejects the suggestion that the
payment to "campaign workers" (most paid $40, some $100) was not for their labor but to buy their voteby-mail. An Occhipinti spokesman:
Campaign workers did everything from wearing t-shirts to making calls to prospective voters, canvassing,
walking with Tim, and distributing signs.
In addition, Occhipinti himself says all campaign staff signed a contract outlining duties, agreeing to
"lawfully promote and encourage the participation of voters," and to "engage in only lawful conduct."
Occhipinti also says it costs more to topple an incumbent, which is why he raised/spent more.
Of Hoboken's 6 wards, only the 4th was in play in November, a special election to Dawn Zimmer's seat,
after she was elected out of Council to become mayor. Lenz was appointed to the seat, but had to run to

keep it last month.

But take a look at the figures for vote-by-mail after the jump - the math behind the graph above. Ward 4's
huge absentee spike may indeed be more than good field work, as Occhipinti's campaign suggests. It may
be an attempt - a successful one - to purchase the votes, for not much money, of Hoboken residents who
needed the jingle in their pockets and didn't mind allowing their names to be written in on ballots they
may not have even filled in themselves. There may indeed be more - much more - than a loser's sour
grapes involved in these allegations.
On such things, the direction of a city may turn. Vote-by-mail percentages for Hudson County, after
the jump.
Rosi Efthim :: Red Flags: How much does it cost to buy an election in Hoboken's 4th ward?
Vote by Mail ballots/Total ballots Cast = VBM percentage)
(data source)
House 9th: 1185/20910 5.7% House 10th: 683/10877 6.3% House 13th: 2912/65696 4.4% Assembly
31: 1034/32332 3.2% County Sheriff: 3687/96134 3.8% East Newark Council: 7/224 3.1% Guttenberg
Council: 68/1634 4.2% Harrison Mayor: 103/2612 3.9% Harrison Ward 1 Council: 15/502 3.0%
Harrison Ward 2 Council: 26/625 4.2% Harrison Ward 3 Council: 37/829 4.5% Harrison Ward 4
Council: 25/656 3.8% Hoboken Ward 4 Council: 440/2215 19.9% Jersey City Ward B Council:
143/4551 3.1% Kearny Ward 1 Council: 16/913 1.8% Kearny Ward 2 Council: 19/783 2.4% Kearny
Ward 3 Council: 60/1718 3.5% Kearny Ward 4 Council: 23/1312 1.8% Secaucus Ward 1 Council:
95/1335 7.1% Secaucus Ward 2 Council: 169/1820 9.3% Secaucus Ward 3 Council: 119/1788 6.7%
Public Question #1: 3687/96134 3.8%
Tags: Hoboken, Tim Occhipinti, Mike Lenz, (All Tags)
!

EXHIBIT J

Soares - Direct

Page 24
1

way, the first thing you do is you remove the more

powerful or the more -- the stronger opinion that

can sway opinion so that that other person who

doesn't want you in there can run the show.

So you think that you were excluded

because of how powerful a personality you are?

Stronger personality I would say.

Okay.

We're going to continue on

with paragraph number three.

Now I'm just going

10

to read out the first few sentences and you let me

11

know if I'm reading it correctly.

12

"At a Hoboken Historical Museum

13

Annual Auction around 2006, I was cornered by Lane

14

Bajardi and his wife by the silent auction table.

15

As I waited on line for a drink, Mr. Bajardi

16

stated that: 'Beth and I are going to own your

17

condo.'

18

suspicion that I had commented against his

19

political views and opinions online on nj.com and

20

Hoboken 411."

21

22

I believed he was alluding to his

Did I read that correctly?

Yes.
Q

So let me try to understand this.

23

You were waiting on line for a drink, and your

24

testimony is all of a sudden Lane just walked up

25

to you and said, "Beth and I are going to own your

Veritext/NJ Reporting Company
800-227-8440

973-410-4040

!
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EXHIBIT K

EXHIBIT L

From: Red Haven [mailto:rdhvn@aol.com] Sent: Tuesday, January 04, 2011

7:42 PM To: hoboken411@gmail.com Subject: Re: CC meeting
I have met with an attorney to review my options. The law has not caught up with
the realities of the internets. The only thing for certain is a lawsuit will cost a
shitload of money. It will also probably take years to resolve. I obviously do not
have unlimited finances to fight a protracted legal battle. Did you ever talk to a
lawyer about the lies they were publishing about your business?
-----Original Message-----From: Hoboken411 <hoboken411@gmail.com> To:
rdhvn@aol.comSent: Tue, Jan 4, 2011 7:33 pmSubject: RE: CC meeting
You are in the process of suing them, right?
Thanks,
Perry
www.hoboken411.com hoboken411@gmail.com

EXHIBIT M

From: nlll@optonline.net!Sent: Saturday, March 13, 2010 5:19 PM!To: Kimberly

Cardinal & Lane Bajardi & Family <lbajardi@aol.com> Subject: Re: Roman Brice
I have just read your email. I will be out with ricky tonight with casino night and debaum
and will discuss either tonight or tomorrow. i
Sent from my Verizon Wireless BlackBerry
From: lbajardi@aol.com!Date: Sat, 13 Mar 2010 12:33:42 -0500!To:
<nlll@optonline.net>; <kcardinalmn@yahoo.com>; <RGMason@WLRK.com>
Subject: Re: Roman Brice
Beth,
I appreciate your point of view on this. Before this Tuesday's School
Board meeting my last public comment on the machinations of
Hoboken government was back in October. That didn't stop both
Roman Brice and Kurt Gardiner from continuously attacking me for
calling things as I see them.
Not only have they sought to silence me, they have also sought to
impede my ability to make a living. By putting up blog posts calling me
"unemployable" and referring to me repeatedly as a "looney
leprechaun", they are deliberately trying to make Google searches of
my unique name come up with damaging attacks on my reputation and
character designed to limit my employment opportunities.
It has crossed a line from simply trying to belittle a political foe to an
advanced attempt to drive me out of town and impede the ability to
provide for my family. These attacks have caused emotional distress
and may also cause irreparable damage to my career. The time has
come to hire a reputable attorney who has experience in these matters
to begin to file suit against these people. The people attacking us count
on the fact that legal action is time consuming and expensive, so they
continue their slanderous attacks with a vengeance.
If I am to continue to be involved here I need legal assistance. The line
has been crossed many times, and it's time to seek damages and send
a message that this activity should not be condoned. Any assistance
you and Ricky can give me in this matter would be welcome and
appreciated.
Thank you. Lane

-----Original Message-----From: nlll@optonline.netTo: Kimberly Cardinal & Lane

Bajardi & Family <kcardinalmn@yahoo.com>; Kimberly Cardinal & Lane Bajardi
& Family <lbajardi@aol.com>; James A. Barracato
<jamesbarracato@gmail.com>; Richard Mason <RGMason@WLRK.com> Sent:
Fri, Mar 12, 2010 11:09 amSubject: Re: Roman Brice
I do. I do not shy away from bullies. I especially cannot stand hypocracy. As a
mother of two daughters who is teaching them to stand up for themselves, I
cannot stand by permit hatred to silence those who seek to expose those who
seek to
silence those who seek the truth and justice on behalf of the people. If we let this
go it becomes the acceptable norm. I would like to know what you think we
should do. Thanks for asking and glad to have you back. Beth :)Sent from my
Verizon Wireless BlackBerry
From: Kim Cardinal <kcardinalmn@yahoo.com>Date: Fri, 12 Mar 2010 07:41:37
-0800 (PST)To: Beth Mason<nlll@optonline.net>; <lbajardi@aol.com>; James
Barracato<jamesbarracato@gmail.com> Subject: Re: Roman Brice
I had been advised not to go to this site and now I know why. Roman is a bully.
He's afraid of being in the spotlight. If you want to teach this guy a lesson and get
him to stop harassing Beth, then there are ways to do it.Let me know if you want
to pursue more aggressive tactics than just walking past him.
Thanks. Kim
--- On Thu, 3/11/10, James Barracato <jamesbarracato@gmail.com> wrote:
From: James Barracato <jamesbarracato@gmail.com>Subject: Roman BriceTo:
"Beth Mason" <NLLL@optonline.net>, lbajardi@aol.com,
kcardinalmn@yahoo.com Date: Thursday, March 11, 2010, 11:49 PM
Beth,
I know Roman Brice aggressively approaches you at City Council meetings but
you really need to ignore this guy. He is a hateful human being who is only out to
hurt and embarrass you. Attached is just one of the many images he has put on
his website of you. This is a clipped image meant to insinuate that you own
Maureen Sullivan. The full image includes you dressed that way as a pimp and
Lane and Perry from 411 dressed as prostitutes. Another photo shows Perry
fishing with a Nazi flag after he took umbrage with Zimmer's using the Holocaust
as a comparison for the Police Audit. Needless to say there is no reason for you
to ever talk to this guy. If you tell him you do not want to speak to him and he
continues to harass you we will just have him arrested.

--James Barracato (201)-920-2124

EXHIBIT N

From: Beth Mason <beth@fourmasons.com>!Sent: Monday, September 12, 2011 9:20

AM!To: lbajardi@aol.com; jamesbarracato@gmail.com; RGMason@WLRK.com
Subject: Please compile most important posts from bloggers
I ask you to compile important posts that show how the dialogue against members of our
is ratcheting up in severity. Thanks.

EXHIBIT O

From: Lane Bajardi <lbajardi@aol.com>!Sent: Sunday, March 4, 2012 10:05 PM!To:

RGMason@wlrk.com; nlll@optonline.net!Cc: jamesbarracato@gmail.com;
kcardinalmn@yahoo.com Subject: Some of the latest threats
Thanks for meeting with me last week. It was good to see you. I thought you
should see a small sample of the invective directed at my family this weekend by
Nancy and her ilk on Patch. The poster "ThisMeansWar" continues to threaten
Benjamin, and harass Kim and I even though we do not post anything on the site.
ThisMeansWar
8:02 pm on Sunday, March 4, 2012
Nice to see you back up the wife for a change Lane. Now what about your child?
Have either of you two losers EVER thought about the damage you are doing to
him? It's not just that he is growing up in a toxic atmosphere of LYING and
DECEIT. But he will be the kid who is KNOWN the second he walks through the
doors of ANY school as the progeny of you two hateful people. Children are
cruel. You are digging an awful hole for that child. Fairly or not he will be
punished for the sins of the father. And mother. Stop thinking about how badly
you want to hurt everyone associated with Zimmer and reform, and start thinking
about how badly you ARE hurting your own child.
ThisMeansWar
5:07 pm on Sunday, March 4, 2012
You're a PAID LIAR. This is not debatable. Public Service Announcement. Lane
Prosbus-HQ and Kim Curiousgal are PAID LIARS. Their sole motivation is to be
paid for POLITICAL DIRTY TRICKS and CHARACTER ASSASSINAITION.
Pages and pages of rants designed to incite violence against my family and
yours by this poster can be seen by clicking here:
http://hoboken.patch.com/users/thismeanswar/comments
The only way the police will pay attention is if I show up with a lawyer to make
them. The only way to stop the harassment and threats in this alternative
universe created by Nancy Pincus, Roman Brice, Michael Lenz and Tony Soares
is to get a lawyer who will go after those responsible. They are threatening to
send their kids in to assault mine. This cannot stand. I need help to unmask
these horrible people and punish them for their unlawful trespasses.
I don't need a million dollar attorney who needs $20k to write a letter, but I do
need help to take action before one of these crazies really loses control. The time
to take legal action is long overdue. History shows us lies left unchallenged
become perceived truth, and repeated public threats left unchallenged become
violence. I cannot let that happen.
-- Lane
!

EXHIBIT P

From: Beth Mason <beth@fourmasons.com> Sent: Monday, January 10, 2011 11:41
PM To: lbajardi@aol.com!Subject: Re: Ugh
Ps I am definitely NOT annoyed. I am trying to discern how to address this I have some
ideas.
----- Original Message -----!From: lbajardi@aol.com <lbajardi@aol.com> To: Beth
Mason!Sent: Mon Jan 10 20:38:38 2011!Subject: Ugh
Beth,!I thought it best to leave the meeting without speaking with you in public. I was also
concerned you might be annoyed with me.
Meetings can't continue like this. All they have left are their most vicious attack dogs, but
in contrast I seem to be the only one (besides Perry, who wasn't there tonight) who
defends you and the majority. You need more soldiers to combat their attacks and lies.
Just FYI that Lenz told several lies tonight. Kim is not Red Haven and I am not Professor
Pinetop. Though I purposely did not say it at the mic, Melissa is Katie_Scarlett and has
no business lecturing you about civility. She recently posted that I am such an asshole
that it would be a good idea if somebody called DYFS on us to look into Benjamin's well
being. This is the kind of person she is.
Kim is beside herself after Lenz's attack. She wants to file charges against him.
But the thing that takes the cake is Arch calling me a liar. Nothing I said was a lie and I
got none of that info about the memo from you, so I can say so if need be. Too many
people saw it today, by the way, and I was even urged to do what I can do to get it widely
distributed. I didn't want to go that far without consulting with you first.
-- L
Sent from my Verizon Wireless BlackBerry