Dorota Trec Civil Suit

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index no 4095 3 1/5" DOROTA TREC with SUMMONS WANUS RABBITS (plaintiff) M141 {0/92/15 <SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index no DOROTA TREC with COMPLAIN WANUS RABBITS 9? (plaintiff) "versus-?- NEW YORK POLICE DEPARTMENT . BROOKLYN DISTRICT ATTORNEY THOMPSON NATALIE REEVES ALISSON EELDMAN VIVAN BARNA Captain FRANK DIGIACOMO Officer JERRY GALAN TE Of?cer CHARLES CADIZ PETA ASPCA JOHN DOE JANE DOE (defendants) State ofNew- York County of Kings: %6m see. 56075; @4135; dig/5W4?! (ewe aMda? 1a. 1 am plaintiff (therein plaintiff) in the above entitled action and as such, I am fully familiar with facts and circumstances involved. I live in Brooklyn NY, County of Kings. 11). Subject of this proceeding is Brooklyn District Attorney? and each other defendant? UNLAWFUL, UNCONSTITUTIONAL AND AGGRAVATED INVASION into plaintiff?s life, person, home, property and effects, which continuous, and request is made to this Honorable Court that this intrusion and this IMPRISONMENT, as explained below, will end immediately RESTORING PLAINTIFF T0 HER LIFE, PERSON, HOME, PROPERTYAND EFFECTS IMMEDIA TELY. gamed @addld 2a. Since three years ago petitioner maintains her beloved project that involves large number of domesticated rabbits living outside in the enclosed area on the side and behind the small property in Brooklyn. 2b. The purpose of this project is to provide community and especially children with natural. and interesting view of number of rah with each other, which easily can be seen through the locked gate. Rabbits are highly intelligent animals and they are reach in their personalities. Rabbits are also very strong and resistant, and petitioner simply loves them. 2e. Interacting with rabbits outside for the extended time daily, playing ?ute by the rabbits side, exercising and reading in the garden, was and still is cherished and desired way of living for the petitioner. 2d. In addition, petitioner works with genetic material developing new breeds of rabbits, for example, rabbits that are small, having somewhat big ears. Petitioner also develops number of different colors for rabbits, having special interest in blue and pastel rabbits. This project is advanced now and it is worth millions of dollars. For example, a?er American Blue Rabbit was developed in California biz-Lewis H. Salisbury and recognized by American Breeders Association in I 9] 7, people paid for such breeding doe/ female rabbit 25 dollars in I 920! yam. NATALIE REEVES lSir Cause of Action and CRIMINAL TRESPASS 2? Cause of Aetiou OF PRIVACY BraCause of INFLICTION OF EMOTIONAL 4th Cause of Action SEIZURES 5th Cause of Action ARREST and MALICIOUS PROSECUTION 6th Cause of Action Reeves, Roma and Fetdmott organized, needlessly pursued SMEAR OFF campaign ogaiostpioiott'?ll 3. Large number of times and continuously Natalie Reeves trespassed and criminally trespassed into plaintiff backyard and side alley, as further '1 0? described in this complaint lilf? . .. germission. Backyard and side alley at 466 3rd Avenue, Brooklyn NY are under exclusive possession of plaintiff and, among other things, plaintiff rabbits are living outside on this property. 4. Large number of times Natalie Reeves went on ?subway side? located against left side of backyard and side alley in question (looking from the 31?6 Avenue). From this ?subway side? Reeves :1 1- mod 1 t1 (at least One hour each time) was looking at and I baekyat'd and side alley where Borota Tree? rabbits are running and playing, Reeves also counted rabbits and made photos of backyard and side alley with rabbits running around ?it. :g 0'5 Qegmission. gave photos and the number/ count of to variety ofmedio, like NYPost, NBC News and others. For prolonged period of time Reeves used photos of Trec? rabbits on her web-site ?Big Apple Bunnies? (also to start up and later to renew her lpetitio against plaintiff on the Internet wih a. -.- -. permission. 5. Reeves also compelled other individuals to trespass and criminally trespass into plaintiff?s backyard and side alley at 466 3rd Avenue, and on the ?subway-side?, for her, for Reeves, again, to count rabbits for Reeves, and to make photos for Reeves, and so they didli Individuals directed by Reeves went on the ?subway side? located against left side of the garden (looking from the 3rd Avenue). From this ?subway side? for prolonged period of time [at least one hour each time] individuals were looking at and observing plainth whole backyard and side alley where Doroto Trec? rabbits are running and playing. Individuals, as directed by Reeves, counted rabbits and made photos of backyard and side alley with rabbits running around. Reeves gave these photos and the number count of rabbits to variety of media, like NY Post, NBC News and others. For prolonged period of time Reeves used photos of Trec? rabbits on her web-site ?Big Apple Bunnies?, also to start up and later to renew her Ipetition against plaintiff on the Internet. Directed by Reeves Individuals acted withogt plaintiff or 6. Since Dec 30, 2014 when DNA Info first posted somewhat nice story about plaintiff project with rabbits outside, glad/4e @eaea amp/y seem-we are/e web/? ?ew need/cog; Mde and /meaymea are ?eet gimme I Reeves acted viciously and maliciously disregarding and quashing constitutional rights of plaintiff. Her recent ?success? is that all pet stores in NY are prohibited ?om selling rabbits and . Reeves actively participated in relevant meetings. Reeves however still has her own agency with the BIG ?Big Apple Bunnies and! @airee?a reagents in? @deaat deagy arm! magnet?eaeteia/f?mee. {97/226, are den ?irtech ?awed refined to aez?rwatkegie Q9;er arriaemnenf? (and ram awed/tam wena?e??e die ?ail rum/Wynn it. Reeves wanted iikete that site is the antitority on animais and rabbits and that iterate; rec does not know anything. This exact picture of Tree ?not knowing anything about rabbits and doing everything wrong about the rabbits? Reeves maliciously circulates through media, ASPCA, NYPD and Brooklyn District Att. ?1naking Reeves fully liable for relevant incidents that followed and for all causes of action stated. metres lined in lien Witty weenie/tact enamel eaten die minds We? (lie amaz? (em AW tee/kg; (late, mam/e lie/rad ra??ita (tired 7. As such, Reeves continuously pressured ASPCA, NYPD and Brooklyn District Attorney, preparing and signing letter to Brooklyn District Attorney about Jan 6, 2015, providing photos and information obtained through her criminal trespass/ criminal activity, to investigate Tree, to seize the rabbits, to wrongfully arrest Tree, to malibiOasZy prosecute rec. As snob, Reeves continued to intrude anti invade plaintiffs iife, person, borne, property and effects, in the aggravated manner, also, maliciously defeating piaintiff?s name, as further described in this complaint. 8. ?Backyard and side alley in question are protected from outsiders with heavy, very high gate. This gate is doable locked and two locks are very visible. There is big Sign posted on the front of the gate: PROPERTY. N0 TRESPAS Front gate stands on the left side of the building and only limited part of backyard can be seen] observed by peeple passing by. Extensively looking at the garden horn ?subway side?Von the left side of backyard and side alley is prohibited by law and such behavior is not expected by plaintiff. ?Subway against the left side of the garden is heavy locked, with high fences around, and big signs are posted all around the fences, stating: PRIVATE PROPERTY. NO TRESPASSING. VIOLATERS WILL BE PROSECUTED. 9. true copy of DNAinfo story ?Brooklyn District Attorney Investigates Gawanas Rabbit Colony?, posted on Internet annexed as exhibit and Reeves maliciously stated to DNAinfo, causing false, defamatory statements to be posted: ?local rabbit rescue groups have stepped forward to offer spay and neuter services, vet care and help with ?nding new homes for dozens of rabbits ?These are domesticated rabbits that don ?t have protection from the elements. It?s clearly cruelty ?advocates say apples and carrots are bad for rabbits ?predators such as feral cats ?water could ?eeze ?some of the bunnies live in cages ?some of the bunnies live in cages, which means they can ?s burrow in to the ground for warmth? ?this population is going to increase exponentially very quickly the government, meaning the police or maybe the district attorney is o?ice, need to step in 10. true copies of Ipetition against Dorota rec and relevant document ?ora Sabina Heinlein web-site are annexed as exhibits 2a and 2b, and in Ipetition Reeves maliciously and falsely stated: ?The cruel conditions in which the rabbits lived? ?lived among junk, with broken glass all over the ground ?and no nog?iozen water to be seen ?rabbits()set out with the trash *Introdaction to {petition also is work of Natalie Reeves as, simply, she directed Sabine Heinlein exactly What to write. Thus, Reeves maliciously caused false and defamatory statements to be posted on Interest: ?animal hoarder Dorota rec more than 70 rabbits seized on Jan 26 were ?jreezing cold rabbits on Jan .26 ?Tree refused to provide adequate shelter for rabbits? ?rabbits were forced to live in deplorable conditions ?photos showed frozen water dishes and a lack of adequate food and shelter ?owner Dorota Tree had been offered assistance to get her multiple animals sterilizes and to provide hatches in which the animals could hide in bad whether ?owner Dorota Tree had been o??red assistance to get her multiple animals sterilizes and to provide hatches in which the animals could hide in bad whether, but she refused?, rec told rabbit advocates that she would sell unwanted animals to be fed to snakes rabbit~breeding operation acted with actual malice; did not act in good faith in the light of all surrounding circumstances; statements were false and defamatory, and had cause plaintiff emotional and reputational harm; Reeves published false statements ?that tends to expose a person (here Dorota Tree) to public contempt, hatred, ridicule, aversion or disgrace, (as such) constitutes defamation?, see Thomas H. Paul B., 18 580, WHEREFORE *requested from Reeves: Plaintiff requests compensation for loss of reputation, shame, mortification, and hurt feelings, temporary loss of rabbits, and for other causes of action, . also 20 million dollars in PUNITIVE DAMAGES. (QZka?/mwg/?/Ww: 1St Cause of Action -TRESPASS and TRESPASS 2'?d Cause of Action OF PRIVACY 3rdCause of TNTENTIONAL OF EMOTIONAL DISTRESS 4th Cause of Action SETZURES 5th Cause of Action 2'2: ST and MALTCTOUS PROSECUTION 6ti3 Cause of Action Reeves, Rama and Feldman organized, needlessly parsned SMEAR GFF campaign against plaintif?l 14. Number of times and continuously (for example on Jan 3, 2015) Feldrnan trespassed and criminally trespassed into plaintiffs backyard and side alley, as ?n'ther described in this complaint ?without plaintiff Backyard and side alley at 466 3rd Avenue, Brooklyn NY, are under exclusive pessession of plaintiff and, among other things, plaintiffs rabbits are living outside on this property. 15. Number of times (for example, on Jan 3, 20.15) Feldrnan tagether with Vivian Berna went on the ?subway side? ?located against left side of the garden (looking from the 33rd Avenue). From this ?subway side? Feldman and Berna for prolonged period of time (at least one hour) were looking at and observing plaintiffs whole backyard and side alley, where Borota Trec? rabbits are running and playing. a lintif ,c Feldman and Barna counted rabbits and made photos of backyard and side alley with rabbits running around g; - bu 1m owner erni Feldman and Berna gav bbits to; variety of media, like NY Post, NBC News and other [also to website Big Apple Bunnies of Natalie Reeves) 16. Since Dec 30, 2014- when DNA Info first posted somewhat nice story about plaintiff project with rabbits outsidefmwma?/Wza . mm swam/gm against plaintiff. Feldtnan acted viciously and maliciously disregarding and quashing constitutional rights of plaintiff. er recent ?success is that all pet stores in are prohibited from selling rabbits, and Feldinan actively participated in relevant meetings. Feldman with her continuously ?ghts against carriage horses in Central Park and 9%25m/ a Mew- aria ev/{mma . @mm err/? dwarf wrMm/Wwale maria/ta (anyway We rammed 456 ??dyyw. Plaintiff seemed to Feldman an easy victim and opportunity for Feldman to make herself famous again. It feels necessary to Feldrnan mim%?wxrw [a sanitary/x MWXW gases Magi/w (?natal/e That plaintiff is keeping rabbits outside and working with rabbits min 4 hours a day, so the community, and especially children, can have beanti?tl View of different rabbits playing and interacting with each other, Mfg/)9 straw area/? ll Just look at the interview Feldman gave to NY Post March 5, 2015. Thus, CONTINUES WITH HER MASQUERADE: ?that she o?ered help to D. Tree andfor her rabbits hat that the plainti?'refaseci never offered any help. Under fake label of ?offering help ?an/amt [ardent dame. . ?an (afghan/7am erg/neat tn animate/6W great @7751; albiIZ?wZW W535. in Feldrnan? opinion, the achievements with rabbits are measured by how many rabbits are sterilized, man/tea meat aft/man? earl/rte an negating darned Mandates in den& ?Visiting? plaintiff on Jan 3, 2015, Feldman needlessly forced plaintiff to listen to all her speeches. wealtl like ts assanee that site is the anthem)! on animals and that Dorota Tree lines not knew anything. This exact picture of Tree ?not knowing anything about rabbits and doing everything wrong about the rabbits Feldntan maliciously circulated through media, ASPCA, NYPD and Brooklyn District Att. wwhich makes her fully liable for all relevant events that followed and for all causes of action stated. giantess lineal" tn lien gig -%nraaf. ctr/Creamery (75(th ale/?at certain/W all am?ma?f in when? mada?atm ?awed, and want/,5? ant/ix any wanna hater/V arm lie/rat saddle} magi (rt/ale 3 Thus, Feldman and Vivian Barns continuously pressured ASPCA, NYPD and Brooklyn District Att, preparing and signing letter to Brooklyn District Att about an 6, 2015, providing photos and information obtained through her criminal treSpass, ta investigate Tree, to seize the rabbits, to wrongfully arrest Tree, to maliciously prosecute Tree. Feldman and Berna continnetl to invade plaintiffs life, person, home, property and effects, in the aggravated manner, also, MALICIOUSLY rlefamed plaintiffs name, as further described in this complaint. l7. Backyard and side. alley in question are protected from outsiders with heaVy, very high gate. This gate is double locked and two locks are very visible. There is big sign posted on the front of the gate: PROPERTY. N0 Front gate stands on the left side of the building and only limited part of backyard can be seen] observed by people passing by. Extensively looking at the garden from ?subway side?/on the left side of backyard and side alley is prohibited by law and such behavior is not expected by plaintiff. ?Subway part??located again-st the left side of the garden is heavy locked, with high fences around, and big signs are posted all around the fences, stating: PRIVATE PROPERTY. NO VIOLATERS WILL BE PROSECUTE 17. true copy of DNAinfo story ?Brooklyn .District Attorney Investigates Gawanns Rabbit Colony?, posted on Interned Jan 6, 2015 is annexed as exhibit 5, and eldman maliciously stated to DNAinfo, causing false defamatory statements to be posted: ?local rabbit rescue groups have stepped forward to o?er spay and neuter services, vet care and help with finding new homes for dozens of rabbits ?These are domesticated rabbits that don ?t have protection from the elements. It ?3 clearly cruelty. . ?advocates say apples and carrots are bad for rabbits? ?predators such as feral cats ?water could ?eeze ?some of the bunnies live in cages ?some of the bunnies live in cages, which means they can ?s burrow in to the ground for warmth ?we ?re trying to prevent a situation that we can already see anfoding . to keep 80 rabbits as pets and to breed them "that ?s not going to end well? ?just because you say you ?re passionate about animals doesn?t mean you are well-suited to take care of them ?Feldman and rabbit rescuer Vivian Barna on Jan 3 offered vet services, spaying and neutering and adoption help ?Feldman and rabbit rescuer Vivian Barna on Jan 3 o?ered vet services, spaying and neutering and adoption help. rec declined the help. 18. true copy of story posted by New York Post on internet on March 5, 2M 5 by the New York Post is annexed as exhibit 6, and Feldman maliciously stated to New York Post, causing false, defamatory statement to be posted: ?it was a bunny house of horrors ?Dorota rec kept her furry ?iends hostage for years but in recent months, it spiraled more and more out Of control ?Her reason for keeping the carry creatures constantly changed(. ..) ?Her reasoning for doing this is always dijj?erent She said, am going to feed the rabbits to lions at the zoo ?The younger rabbits were stn?iad in small cages stacked on top of one another,? and the older ones Were kept in tall wooden hatches locked inside a shed. Approximately 100 more sickly rabbits were allegedly hidden in the basement. 19. *Trne copies of Class two articles prepared by eldman, Where eldman maliciously caused particular false and defamatory statements against plaintiff to be posted: ?rescued Gowanns Rabbits ?hoarder in Gowanns ?Gowanns rabbit hoarder ?animal cruelty abusersto hurt more animals ?this animal hoarding and animal cruelty case seriously What other maliciously statements Feldmaa made: ?rabbits seized ?om boarder in Gowanns, thanks to NYPD, ASPCA, ACC ?So we applaud Brooklyn DA Thompson for taking this animal hoarding and animal cruelty case seriously. We urge the District Attorney to prosecute Dorota Tree to the fullest extent of Ifconvicted, we would urge the court to ban her from owning pets for life so she can no longer abuse any more animals. it? See also East of the 20. As such, Allison Feldman: maliciously invaded the interest of plaintiff in her reputation; intentionally published statements of facts, as set forth in the above, that are false, unprivileged, and have a natural tendency to injure; published matter that is defamatory on its face; knew these statements were false (also published statements in reckless disregard of Whether there were false); falsely charged plaintiff with criminal conduct acted with actual malice did not act in good faith in the light of all surrounding circumstances; statements were false and defamatory, and had cause plaintiff emotional and reputatioaal harm Feldman published false statements ?that tends to expose a person (here Dorota Tree) to public contempt, hatred, ridicule, aversion or disgrace, constitutes defamation?, see Thomas H. Paul B., 18 580, 584(2012) WHEREFORE *requested from Feldman: Plaintiff requests compensation for loss of reputation, shame, mortification, and hurt feelings, temporary loss of rabbits, and all other for causes of action stated also 20 million dollars in IVE DAMAGES. %a/W VIVIAN BA 1St Cause of Action and CRIWAL TRESPASS Cause of Action VASION OF PRIVACY 3"?1Cause of INTENTIONAL OF EMOTIONAL 4th Cause of Action SEIZURES 5% Cause of Action ARREST and Cause of Action Reeves, Berna and Feannan organized, needlessly parsned SMEAR OFF campaign 21. Number of times and continuously (for example on i an 3, 2015') Vivian B?arna trespassed and criminally trespassed into plaintiff backyard and side - alley, as thither described in this complaint, without plaintiff or building owner? 9 emission. Backyard and side alley at 466 3rd Avenue, Brooklyn NY, are under exclusive possession of plaintiff and, among other things, plaintiff" rabbits are living outside on this property. 22. Number of times (for example, on an 3, 2015) Berna together with Allison Feldrnan went on the ?subway side? located against left side of the garden (looking from the 3rd Avenue). From this ?subway side? Berna and Feldman for prolonged period of time (at least one hour) were looking at and observing plaintiffs whole backyard and side alley, where Dorota Trec? rabbits are running and playing. Barna and eldman also counted rabbits and made photos of backyard and side alley with rabbits running around wwit bout glaintiff? . .. - Barna and Feldman gave photos and? the number/ oth of rabbits to variety of media, like NY Post, NBC News and other (also to Big Apple Bunnies wweb-wsite of of Natalie Reeves) 23. Since Dec 30, 2014 when DNAinfo first posted somewhat nice story about plaintiff project with rabbits outside, gimme ?/mewf/y?d/Ma met/MW cared 2'sz against plaintiff. Barns. acted viciously and maliciously disregarding and quashing constitutional rights of plaintiff. Her recent ?success? is that all pet stores in are prohibited ?om selling rabbits and Barna actively participated in relevant meetings. Berna, however, still provides the same Petland Stores in NY (including few stores in plaintiff neighborhood) with her brochures inducing people to continue with rabbits as pets, but that they should now adopt rabbits from ?All About Rabbits which is Berna? adoption agency! true copy of Barna brochure in annexed as exhibit lO. Dorota Tree presents to Barns heavy threat, not just financial threat (she charges min $60 adoption fee). geared de?ned in? {We ?y ?rmed} and re?ned 529 in?ame/edge we'er geese mam-Me (ze/w/?eaWMMJ (new midde marl/tam mews/Wig/ee [be enemas/mtg? (3. ?Visiting? plaintiff on Jan 3, 2015, Berna needlessly forced plaintiff to lissen to her ?lessons about the rabbits?. Barrie waaid like to assame that she is the aatharitfy ea rabbits and that Dorota Tree does not know anything. This exact picture of Tree not knowing anything about rabbits and doing everything wrong about the rabbits Berna maliciously circulated through media, ASPCA, NYPD and Brooklyn District Att. mrnaking her fully liable for all relevant event that followed and for causes of action stated {tam ire hers 95mm}, dream/hay that Me has wttm/ ate/16 Manda We?? the (and wart/tea (my (W, emw hermit gim??tta newt/I 24. As such, Barna and Allison Feldman continuously pressured ASPCA, NYPD and Brooklyn District Att, preparing and signing letter to Brooklyn District Att about 3 an 5, 2015, providing photos and information obtained through their criminal trespass, to investigate Tree, to seize the rabbits, to wrongfaiiy arrest Tree, to prosecate Tree. as, Barrett and Fehimaa coatiaaed to inradepiaiatiffs iife, person, home, property and effects, ire the'aggravateti mariner, also, maliciously defamirtg plaintiff?s name, as further described in this complaint. 25. Backyard and side alley in question are protected from outsiders with heavy, very high gate. This gate is double locked and two locks are very Visible. There is big Sign posted on the front of the gate: PROPERTY. N0 Front gate stands on the left side of the building and only limited. part of backyard can be seen/ observed by people passing by. Extensively looking at the garden from ?subway side?/on the left side of backyard and side alley is prohibited by law and such behavior is not expected by plaintiff. ?Subway part??located against the left side of the garden is heavy locked, with high fences around, and big signs are posted all around the fences, stating: PRIVATE PROPERTY. N0 TRESPASSING. VIOLATERS WILL BE PROSECUTED. 26. On Jan 3, 2015 Barns. left, in public place, in plain View, easy to notice and easy for anybody passing by to read, attached to the front gate of the rabbit garden, *t?Bama ?s ietter topiaiatiff Furthermore, Berna knew that different media were coming to this location to make story about rabbits, weamt that they will her ietter in their stories. Media indeed included Barna? letter in stories about the rabbits. in her letter Barns self-?calls herself rabbit expert and she maliciously presumes that plaintiff does not know anything about the rabbits. @qume (it 69ng easier/lowed wait/ax doe omen ate/2y 2754325 We (ken not feed/tee mean Barna?s letter to plaintiff maliciously and falsely states that Tree does not feed any hay to her rabbits, and that "free feeds too much carrots to rabbits. Furthermore, Barna? letter clearly suggests that pteintz?aeglects tier rabbits. true copy of photo showing Zetter?om Berna to plaint? letter indeed included in DNAinfo story posted on Jan 6, 2015, is annexed as exhibit 8. 27. Similar false and defamatory statements that plaintiff neglected her rabbits and that plaintiff does not feed her rabbits properly, Berna maliciously posted on Internet ?as comments? tender DNAinfo somewhat nice story about Gowamss Rabht?ts posted on Internet Dec 30, 20M (and Berna immediately posted her comments). ?it See also Part of complaint 28. As such, Vivian Berna: maliciously invaded the interest of plaintiff in her reputation; intentionally published statements of facts, as set forth in the above, that are false, unprivileged, and have a natural tendency to injure; published matter that is defamatory on its face; knew these statements were false (also published statements in reckless disregard of whether there were false); falsely charged plaintiff with criminal conduct; acted with actual malice; did not act in good faith in the light of all surrounding circumstances; statements were false and defamatory, and had cause plaintiff emotional and reputational harm; Berna published false statements ?that tends to expose a person (Dorota Tree) topublt'c contempt, hatred, ridicule, aversion or disgrace, constitutes defamation?, see Thomas H. Paul 3., l8 580, 584(2012) WHEREFORE *reqnested from Berna: Plaintiff requests compensation for loss of reputation, shame, morti?ea?tion, and hurt feelings, temporary loss of rabbits, and for other causes of action also, 18 million dollars in PUNITIVE DAMAGES. PETA People for the Ethical Treatment of Animals I3t Cause of Action -TRESPASS and CRIMINAL TRESPASS 2ma Cause of Action OF PRIVACY 3rdCause of Action- :2 SSMENT, INTENTIONAL INF LICTION 0F EMOTIONAL DISTRESS Cause of Action SEIZURES 5m Cause of Action ARREST and MALICIOUS PROSECUTION 6th Cause of Action 29. About Jan 6, 2015, together with Natalie Reeves and Allison Feldman, PETA maliciously prepared and signed letter to Brooklyn District Attorney. In letter PETA requested that plaintiff Gowanus Rabbits ?be investigated?. Letter falsely and defamatory states that Gowanus Rabbits are neglected and that plaintiff is committing with these rabbits animal cruelty. In letter PETA requests that rabbits be taken away ??orn plaintiff, that plaintiff be arrested and prosecuted for animal cruelty. 30. Letter to Brooklyn District Attorney clearly indicates that PETA participated in masquerade and witch hunt against plaintiff, as further described in this complaint. PETA with its founder and president Ingrid Newkirk are fully responsible for relevant events that followed, restilting from preparing and signing said letter, and for all causes of action stated. PETA used the authority and power of its name without thinking first, not examining situation with rabbits, not getting any facts and Without first investigating. Also, PETA was not acting in Based on Nathan J. Winograd research and according to Virginia Department of Agriculture consumer Services, in 2014 PETA took in 1605 cats and killed 1536 -a kill rate of 96 percent; as to dogs: PETA took 1021 dogs and killed 788 -a kill 77 percent. Iso . WHEREEORE *requested from PETA: Plaintiff requests compensation for loss of reputation, shame, mortification, and hart feelings, temporary loss of rabbits and for other causes of action also, 24 million dollars in PUNITIVE DAMAGES JOHN DOE JANE DOE Cause of Action and CRIMINAL TRESPASS 2? Cause of Action OF PRIVACY 3rdCause of INTENTIONAL INELICTION OE EMOTIONAL DISTRESS Cause of Action SEIZURES 5th Cause of Action ARREST and NIALICIOUS PROSECUTION 6* Cause of Action 31. John Doe Jane Doe are two ?civilians? who assisted NYPD and maliciously participated on Jan 26, 2015 in criminal trespass, needless raid and stealing of plaintiff?s rabbits. Plaintiff made photos of these two persons on that day *and a true copy of this photo is amnexed as exhibit I 0. 32. Plaintiff recognize now that the same person John Doe ?occupied? outside of subject premises at 466 3rd Avenue almost every day (especially in the mornings) since Jan 6, 2015 making numerous photos of rabbits from the front gate; also waiting for the right moment to trespass from the ?subway?site? on the left side of yard and side alley and ready with his camera to make more photos. Stitlyet it most be discovered who sent John Poe oa sock mission. 33. John Doe maliciously made large number of complaints to the authorities incorrectly, maliciously describing situation with plaintiff? rabbits. After on Jan 26, 2015 John and Jane Doe maliciously made large number of 911 calls/ complaints, Captain Digiaconio admitted to plaintiff that he felt too much pressure and had to seize the rabbits. John Doe and Jane Doe maliciously did not say that rabbits looked all right and happy were jumping on the snow, that not even one rabbit looked in distress, and that some shelters clearly were visible and provided. 34. It is clear that John Doe and Jane Doe MALICIOUSLY participated in masquerade and Witch hunt against plaintiff, as further described within this complaint. John and Jane Doe are fully responsible for relevant events that follovved as a result of their actions needlessly taken, and are liable for all causes of action stated. John and Jane Doe maliciously especially With. their false, defamatory and distorted complaints. John and Jane Doe 9 rd plaintiff neglects her rabbits and that she is committing with these rabbits animal cruelty. 35. Backyard and side alley in question are protected from outsiders with heavy, very high gate. This gate is double locked and two locks are very visible. There is big Sign posted on the front of the gate: PROPERTY. N0 TRESPAS SIN-G. Front gate Stands on the left side of the building and only limited part of backyard can be seen} observed by people passing by. Extensively looking at the garden from ?subway side?/on the left side of backyard and side alley is prohibited by law and such behavior is not expected by plaintiff. ?Subway part??located against the left side of the garden is heavy locked, with high fences around, and big signs are posted all around the fences, stating: PRIVATE PROPERTY. N0 TRESPASSING. VIOLATERS WILL BE PROSECUTED. ?See also Part of Complaint WHEREFORE *requested from John Doe and Jane Doe, from each: Plaintiff requests compensation for loss of reputation, shame, mortificatioa, and hurt feelings, temporary loss of rabbits and for other causes of action also, 20 million dollars in PUNITIVE DAMAGES '15: ?American Society for Prevention of Cruelty to Animals ist Cause. of Action -TRESPASS and CRIMINAL TRESPASS 2"?3 Cause of Action OF PRIVACY 3rdCanse of INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 4th Cause of Action UL SEIZURES 5151? Cause of Action ARREST and MALICIOUS PROSECUTION 6th Cause of Action 36. After DNAinfo posted on Internet ?rst and somewhat nice story about Gowanus Rabbits on Dec 30, 2014, ASPCA MALICIOUSLY started with its harassment and unlawful, unconstitutional invasion into plaintif'f?s life, person, borne, property and effects, starting Jan 3, 2015. Allison and other persons from ASPCA called plaintiff and building? owner few times a day demanding that ASPCA enter inside the property and inspect rahhi'ts. Persons from ASPCA used word ?help? in its conversation. However, no actual help was ever offered by ASPCA to plaintiff regarding her herds efrahhits. Number of times, for example, on lan 14, ASPCA maliciously ?occupied? outside rabbit garden at 466 3?rd Avenue for prolonged period of time [each time two hours at least], at such time calling and demanding from plaintiff that she leaves her work and came "because ASPCA would like to meet her?. Presence of ASPCA with its cars standing in front of the property full of jumping rabbits, clearly suggested to everyone passing ?animal cruelty?. 37. Number of times {for example on Jan 14, 2015) ASPCA trespass and criminally trespassed into backyard and side alley where rabbits are kept 'ASPCA trespassed through the back door of the the shop, and as a result, this emergency door had to be locked from outside to prevent further trespassing. 38. On 5 an 26, 2015 ASPCA together with Captain Digiacomo and number of policemen from 78 Precinct viciously and violently out two locks on the front gate and criminally trespassed, STEALING RABBITS. ASPCA committed animal cruelty that day by running like crazy with 20 big policemen on the snow after over- 100 free-range rabbits, stepping on rabbits, injuring rabbits and giving them heart attacks. Then, ASPCA clearly was hot coheertted' when ?it? rabbits were thrown into small var: iota 5,6 mediates dog cages and when rabbits? bodies were thrown one on top of another, when rabbits could not move and they were . getting heart attacks. More facts, issues is described in Part of Complaint. 39. it is clear that ASPCA MAUCIOUSLY participated in this needless masquerade and Witch hunt against plaintiff, as further described Within this complaint. ASPCA with its president Matthew Bershadker are fully responsible for relevant events that followed as a result of ASPCA unlawful and unconstitutional intervention into plaintiff?s life, person, home, property and effects, and are liable for all causes of actions are stated). For example, ASPCA .. .. . .. .. .. NYPD that plaintiff is neglects her rabbits and that she commits with these rabbits animal cruelty. ASPCA, offering to the authorities that it would take rabbits raider their camel, ed YD .. .. .. 40. ASPCA need the authority and power of its name Without thinking ?rst, not examining situation with rabbits, not getting any facts and - Without first investigating. ASPCA Was not acting in good faith. Backde and side alley in question are protected from outsiders with heavy, very high gate. This gate is double locked and two locks are very visible. There is big sign posted on the front of the gate: PROPERTY. N0 TRESPAS Front gate stands on the le? side of the building and only limited part of backyard can be seen/ observed by people passing by. Extensively looking at the garden from ?subway side?/on the left side of backyard and side alley is prohibited by law and such behavior is not expected by plaintiff. ?Subway part??loeated against the left side of the garden is heavy locked, with high fences around, and big signs are posted all around the fences, stating: PRIVATE PROPERTY. NO TRESPAS SING. VIOLATERS WILL BE PROSECUTED. WHEREFORE *requested from ASPCA: Plaintiff requests compensation for loss of reputation, shame, mortifieation, and hurt feelings, temporary loss of rabbits and for other causes of action also, 32 million dollars in PUNITIVE DAMAGES.