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EFiled: May 11 2016 04:00PM EDT

Transaction ID 58993931
Case No. N16C-05-111 CLS

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE


IN AND FOR NEW CASTLE COUNTY
DAVID GRIMALDI,

)
)
Plaintiff,
)
)
v.
)
)
JANE DOE aka VERONICA
)
HOBSON aka VICTORIA
)
SUMMERS,
)
)
Defendant. )

C.A. No.
JURY TRIAL DEMANDED

COMPLAINT
1.

Plaintiff David Grimaldi is a citizen of the State of Delaware who

resides in New Castle County.


2.

On information and belief, defendant Jane Doe, using the screen names

Veronica Hobson and Victoria Summers, is a citizen of the State of Delaware


who resides in New Castle County. On a Facebook page created by Victoria
Summers at https://www.facebook.com/victoria.summers.7568?fref=ts, she claims
that she is a graduate of the University of Delaware and Harvard Law School, and,
in 2013 at least, was employed with the law firm Stevens & Lee. On information
and belief, those representations are false. The photos used to identify Victoria
Summers on that Facebook page are, in fact, those of Russian model Irina Shayk.
3.

On April 8, 2016, Victoria Summers posted on her Facebook page

that Grimaldi was in a bar fight while driving a county vehicle drunk. He attacked

a 93 year old woman. LAST BUT NOT LEAST, he has a criminal record. She
also stated that The guy [Grimaldi] is a psychopath, he literally doesnt know that
what hes doing is wrong.
4.

On April 23, 2016, an individual identifying himself or herself as

Veronica posted a comment at 11:36 a.m. on www.DelawareLiberal.net, stating


that Grimaldi did time in jail for a violent crime but his friend took the rap for him.
An individual going by the Twitter handle HobsonVeronica has posted continuous
derogatory statements about Grimaldi, hiding behind Internet anonymity.
5.

On or about May 3, 2016, an individual identifying herself as Veronica

Hobson posted an audio recording on YouTube reciting a poem or rap about David
Grimaldi, including the accusation that Grimaldi committed an undescribed violent
crime and allowed another to take the rap for it, and that he is the definition of
a

psychopath

with

an

eating

disorder.

https://www.youtube.com/watch?v=RRcr_i7Cq74. Although the vocal track was


speeded up, when slowed down it appears to Grimaldi that the voice is that of
Jennifer Gordon, daughter of current New Castle County Executive Thomas Gordon,
who is in litigation with Grimaldi in a separate action.
6.

The above-described statements are defamatory as they falsely accuse

Grimaldi of criminal and wrongful conduct, including assault, battery, driving under
the influence, and other unspecified conduct which allegedly resulted in his
2

incarceration.

Defendant also accused Grimaldi of having a dangerous

psychological disorder.

Such false accusations impeach Grimaldis honesty,

integrity and reputation.


7.

The above-described statements are entirely false, the product of

defendants imagination. Defendant posted these statements publicly with


knowledge of their falsity and/or with reckless disregard as to their truth or falsity.
The statements were posted maliciously, to serve no purpose other than to harass
and demean Grimaldi and to injure his reputation, and have done so.
WHEREFORE, for the foregoing reasons, plaintiff respectfully requests that
the Court enter judgment in his favor, and against defendant, for compensatory and
punitive damages, costs, including reasonable attorneys fees, and such other and
further relief as the Court deems just.

/s/ David L. Finger_______________


David L. Finger (ID #2556)
Finger & Slanina, LLC
One Commerce Center
1201 N. Orange St., 7th fl.
Wilmington, DE 19801
(302) 573-2525
Attorney for plaintiff David Grimaldi
Dated: May 11, 2016