MATTHEW LANDAN
v. COMPLAINT
Electronically Filed
AMANDA DONHOFF
ERIC SNIDER
CHRISTOPHER MAGGIO
DEFENDANTS
2. Plaintiff, Haymarket Whiskey Bar is the assumed name of Derby City Espresso,
Liability Company doing business at 331 East Market St. Louisville, Kentucky
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40202.
4. Plaintiff Matthew Landan is the owner of Plaintiff Haymarket and at all relevant
5. Jane Doe 1 a/k/a Westley Moore (hereinafter Jane Doe Moore), if she exists, is a
RAPIST including a photograph of Mr. Landan. She repeated this and similar
statements to any and all that would listen. These statements are false and
7. Defendant Jane Doe Moore made other false, malicious and defamatory
statements, to include but not limited to claims that other women were contacting
her that they had been raped. These statements are false and malicious and
8. The Face Book page named Westley Moore where the defamatory statements
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Kentucky.
10. On November 15, 2017, Defendant Donhoff stated on Face Book that Matthew
Landan had drugged her drink. This statement is false and malicious and
11. Since November 13, 2017, multiple unknown Jane and John Doe Defendants
(hereinafter Unknown Defaming Jane and John Does), have repeated the
defamatory statements identified above and have also made multiple assertions
that the drinks at the Haymarket Whiskey Bar are spiked with drugs. These
statements are false and malicious and constitute defamation per se as to the
(hereinafter Unknown Stalking Jane and John Does) have, for no legitimate
13. The actions of Unknown Stalking Jane and John Does to include posting Plaintiff
Matthew Landans personal information on the internet were made as explicit and
implicit threats with the intent to place Plaintiff Landan in reasonable fear of
14. Plaintiff Matthew Landan has received threats directly related to the actions of
Kentucky.
Kentucky.
17. Defendants Maggio and Snider were employees of Haymarket Whiskey Bar on
18. Upon the false, malicious and defamatory revelation of Jane Doe Moore or in
concert with that fraud Defendants Maggio and Snider engineered the walkout of
19. Defendants Maggio and Snider then shopped the fact of the walkout to various
media outlets and stated words to the effect that many (8-17) other women had
come forward with similar claims against Plaintiff Matthew Landan. These
attempted a low ball purchase offer to Plaintiff Landan for the Haymarket Whiskey
Bar.
COUNT I
21. The Plaintiffs reaffirm and reiterate each and every allegation set forth above as
22. The actions of Defendants in making false, misleading and defamatory statements
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about Matthew Landan and the Haymarket Whiskey Bar were made with the full
24. Defendants made the statements with the knowledge of their falsity or with
25. Defendants made the statements with the knowledge that they had created a false
26. As a result of the actions identified above Matthew Landan sustained damage to
27. As a result of the actions identified above Haymarket Whiskey Bar sustained
damage is presumed.
28. The actions of all Defendants herein were made in concert and in a civil conspiracy
to cause tortious injury to Plaintiffs, rendering all Defendants jointly and severally
liable.
COUNT II
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29. The Plaintiffs reaffirm and reiterate each and every allegation set forth above as
30. The aforementioned conduct of Defendants gave publicity before the public that
falsity of the publicized matter and the false light in which Plaintiffs would be
placed.
32. Defendants made the statements with the knowledge that they had created a false
33. As a result of the actions identified above Matthew Landan sustained damage to
34. As a result of the actions identified above Haymarket Whiskey Bar sustained
damages.
35. The actions of all Defendants herein were made in concert and in a civil conspiracy
to cause tortious injury to Plaintiffs, rendering all Defendants jointly and severally
liable.
COUNT III
36. The Plaintiffs reaffirm and reiterate each and every allegation set forth above as
37. The aforementioned conduct of Defendants Unknown Stalking Jane and John
Does were in violation of KRS 508.150 rendering these Defendants liable under
KRS 411.220.
38. Liability under KRS 411.220 includes actual damages, punitive damages, court
39. The actions of all Defendants herein were made in concert and in a civil conspiracy
to cause tortious injury to Plaintiffs, rendering all Defendants jointly and severally
liable.
COUNT IV
40. The Plaintiffs reaffirm and reiterate each and every allegation set forth above as
41. Defendants Maggio and Snider actions were made with the intend to intermeddle
Haymarket and to improperly and unlawfully interfere with the ongoing business
with the hopes of devaluing the business and facilitating their purchase.
Whiskey Bar.
43. Defendants Maggio and Snider had no justification or privilege to act in the manner
complained of herein.
44. As a result of the actions identified above Haymarket Whiskey Bar sustained
45. The actions of all Defendants herein were made in concert and in a civil conspiracy
to cause tortious injury to Plaintiffs, rendering all Defendants jointly and severally
liable.
C. Award Plaintiffs their costs and reasonable attorneys' and expert fees;
Respectfully Submitted,
s/Andrew J. Horne
Andrew J. Horne
517 West Ormsby Avenue
Louisville, Kentucky 40203
(502) 637-1222
Counsel for Plaintiffs