Federal Lawsuit Against Critchlow For Topix Defamation

Case: 4:14-cv-02055-HEA Doc.
#: 3 Filed: 12/16/14 Page: 1 of 55 PageID #: 127
In the Circuit Court of the 23rd Judicial Circuit

Of Missouri at Hillsboro, Jefferson County, Missouri
SAM FERRY,
RICHARD SIMPSON,
MICHELLE TYLER,
Plaintiffs,
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VS.
DIANNE CRITCHLOW,
In her individual capacity;
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s~e~
3040 Strawberry Ridge

Arnold, MO 63010
JAM1E CRITCHLOW,
In his individual capacity;
Serve at:
3040 Strawberry Ridge
Arnold, MO 63010
ANGELA BURNS,
In her individual capacity;
Serve at:
1016 Castlemain Dr.
Imperial, MO 63052
DAN BAKER,
Serve at:
1016 Castlemain Dr.
Impetial, MO 63052
WlLLIA.\1 BRENGLE,
Se1ve at:
3408 Cascade Dr.
Arnold, MO 63010
Cause No. 14JE-CC00092

Jury Trial Demanded
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EXHIBIT
Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 2 of 55 PageID #: 128
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Defendants,
PETITION FOR DAMAGES

VIOLATION OF CIVIL RIGHTS PURSUANT TO 42 U.S.C. 1983 & 1985
DEFAMATION
COME NOW Plaintiffs, San1 Ferry, Richard Simpson, and Michelle Tyler, by
and through counsel Daniel Hennan of Schwartz, Hennan & Davidson, and for their
Petition, state as follows:
Parties and Venue
I.
Venue is proper because all defendants reside in Jefferson County and
the IP Address identifiers on the website in question identify the defendants as having
posted within Arnold, Missouri, and the danlage took place primarily in Arnold,
Missouri.
2.
The posts relevant to the claims for defamation were made within the (2)
two year Missomi statute oflimilalions for defamation suits.

3.
The posts and actions relevant to the claims pursuant to 1983 & 1985
occurred within the (5) five year Missouri statute of limitations for civil rights suits.
4.
At all times relevant herein, Plaintiff Sam Ferry (hereinafter "Ferry")
was a resident of Arnold, Missouri.

5.
At all times relevant herein, Plaintiff Rich Simpson (hereinafter
"Simpson") was a resident of Arnold, Missouri.

6.
At all times relevant herein, Plaintiff Michelle Tyler (hereinafter
"Tyler") was a resident of Arnold, Missouri.

7.
At all times relevant herein, the Fox C-6 School District ("Fox C-6" or
"the district") is a school district, organized and operating under the laws of the state
of Missouri and operating within Jefferson County, State of Missouri.
8.
At all times relevant herein, Defendant Dianne Critchlow was the
Superintendent of Fox C-6. She is named in her individual capacity in the claim for
2
violation of civil rights pursuant to 1983. She is named in her individual capacity in
the claim for conspiracy to interfere with civil 1ights pursuant to 1985. She is named
additionally as a defendant to the Missouri common law claim of defamation.
9.
At all times relevant herein, Defendant Jamie Critchlow was the Director
of Bridges at Fox C-6. He is named in his individual capacity in the claim for
violation of civil rights pursuant to 1983. He is named in his individual capacity in
the claim for conspiracy to interfere with civil rights pursuant to 1985. He is named
additionally as a defendant to the Missouri common law claim of defamation.
I 0.
Jamie and Diam1e Critchlow married in 2012 and have lived together at
the same address since that time.
11.
At all times relevant herein, Defendant Dan Baker was an Assistant
Superintendent of Fox C-6. He is named in his individual capacity in the claim for
violation of civil rights pursuant to 1983. He is named in his individual capacity in
the claim for conspiracy to interfere with civil rights pursuant to 1985.
12.
At all times relevant herein, Defendant Angela Bums was an assistant
principal at Fox C-6. She is named in her individual capacity in the claim for
violation of civil rights pmsuant to 1983. She is named in her individual capacity in
the claim for conspiracy to interfere with civil rights pursuant to 1985.
13.
Dan Baker and Angela Bums married during the course of the events
desctibed herein and have Jived together since that time.
14.
At all times relevant herein, Defendant Willian1 Brengle was a resident
of Arnold, Missouri. I--(e retired as an administrator of Fox C-6 prior to the events
dcsctibed in the complaint. He is named in his individual capacity in the claim for
conspiracy to interfere with civil rights pursum1t to 1985. He is named additionally
as a defendant to the Missouri common law claim of defamation.
Facts Common to All Counts
15.
At all times relevant herein, Plaintiffs Ferry, Tyler, and Simpson
publicly commented and criticized the actions of the Fox C6 school board and
administration.
16.
The subjects of plaintiffs' complaints were a matter of public concern.
17.
At all times relevant herein, defendants Dianne Critchlow, Jamie
Critchlow, Dan Baker, and Angela Burns were public officials.

18.
At all times relevant herein, defendant William Brengle was acting in
concert with defendants Dianne Critchlow, Jamie Critchlow, Dan Baker, and Angela
Bmns for the purpose of retaliating against plaintiffs for plaintiffa' public criticism of
school board and administration actions and policies.
19.
Among their criticisms were:

a. Nepotism;
b. The misuse of district funds;
c. Unreasonably high salaries of district administrators;
d. The bullying of teachers and parents by administrators and other
district staff to punish and silence dissent.
20.
Defendants Dianne Critchlow, Jamie Critchlow, Dan Baker and other
administrators were a central subject of Plaintiffs' complaints.

21.
Plaintiff Simpson had a long lasting dispute with the district due to their
seven-year refusal to recognize his daughter's disability claim for a life threatening
peanut allergy.
22.
Defendant Dan Baker was the director of the disttict' s 504-disability
program, and directly responsible for the district's lengthy fight against providing
disability benefits to Simpson s daughter.
23.
Plaintiffs Feny, Simpson, and Tyler made their criticisms at meetings of
the Fox C-6 School board and in private conversations.

m
I
[
"'[
:!!
24.
Plaintiff Tyler attended only one School Board meeting on January 15,
'
2013.
25.
During the January 15 meeting and the following day, Defendants
Dianne Critchlow and Dan Baker individually or jointly ordered Principal Carla Duffy
to question Susan Hedrick ("Hedrick"), the Mother of Michelle Tyler and an
employee of Fox C-6, about Tyler's criticism of the district and the administrators.
26.
On fom separate occasions, including the day after the only board
meeting ever attended by Tyler, Principal Carla Duffy questioned Hedrick at lengtl1
on the orders of Defendants Critchlow and Dan Baker about why her daughter was
criticizing the district and its administrators.
27.
Hedrick and Tyler understood these meetings to be a threat by
Defendants Dianne Critchlow and Dan baker against Hedrick's continued

employment with Fox C-6.
28.
Because of the threat to her mother's employment, Tyler stopped
attending board meetings and refrained from publicly criticizing the district or its
administrator:"
29.
Luann Domek, principal of Lone Dell, asked that Tyler come to the
school lo discuss issues related to Tyler's children.

30.
Domek proceeded to attempt to convince Tyler to discontinue her
criticism of the School board and the administration.

31.
Domek admitted to Tyler that defendant Dianne Critchlow told her to
make Tyler stop.

32.
Defendant Dianne Critchlow set a meeting witli Simpson's father, a
fmmer superintendent.
33.
During tl1e meeting between Dianne Crithclow and Simpson's father,
Diam1c Critchlow voiced her displeasure with Simpson's criticism and attempted to
convince Simpson's father to dissuade Simpson from continuing his c1iticism of the
district, its administrators, and tl1e defendants.
34.
Following the April 2011 board meeting, Defendant Jamie Critchlow
aggressively approached Simpson and ordered him not to speak to the School Board
about issues relating to Jamie Critchlow.
35.
Defendant Jamie Critchlow left angry voicemails and emails for
Simpson.
36.
Defendants Dianne Critchlow and Dan Baker individually or jointly
ordered cease and desist letters to be sent to each Plaintiff, threatening legal action if
they did not discontinue their criticisms of the School Board and the Administrators.
Exs. E, F, G.
37.
Defendants' threat oflitigation caused Simpson to silence or soften his
criticism for several months following his receipt of defendants' cease and desist letter
in August of2012.
38.
Defendants' threat of litigation caused Ferry and Tyler to silence or
soften their criticism for almost a month after their receipt of defendants' cease and
deist letter in February 2013, a period critical to the April 2013 School Board
elections.
39.
On February 7, 2013 at 2:58 P.M., defendants, jointly or severally
cornpired to use the usemame 'TROOP 5 or 6" to publish the following statement on
topix.com:
a. "From what I have beard there will be some sparks flying very soon
for a few of you. Cuc evil monster laugh ... Moohahahahaa.
Hehebeoooooo rahabahaaaaa." See 'Nepotism on Fox scboolboard'
post 792; Ex. D. pg. 30.
40.
IP address 108.231.66.58 is registered to Dianne Critchlow for use at the
home address of Jamie and Dianne Critchlow. See Ex. A.

41.
IP address 68.186.163.99 is registered to Angela Bums for use at the
home address of Angela Bums and Dan Baker. See Ex. B.
42.
IP Address l 08.235.42.34 is registered to William Brengle for use at his
home address. See Ex. C.

43.
IP address 150.199.176.125 is registered to the Fox School District. See
44.
Defendants posted comments about plaintiffs in the following forums on
Ex.H.
Topix.com
a. 'Nepotism on Fox Schoolboru:d.' See Ex. D;
b. 'Fox High School Superintendent.' See Ex. D;
c. '\Vho's the biggest LOCAL LOONEY?' See Ex. D;
d. 'Petition for No Nepotism at foxc6.' See Ex. D;
e. 'Fox.' See Ex. D;
f. 'Liars Cheaters and Thieves.' See Ex. D;
45.
Do Kim, community manager ofthc website www.Topix.com, has
identified the IP address used to post each of the below complained of posts that were
made on www.Topix.com. See Ex. D.
46.
Defendants Jamie and Dianne Critchlow used their home IP address to
post comments on the website www.Topix.com. See Ex. D, Pgs. 15-46, 50-52, 58-59.
47.
Defendants Dianne Critchlow, Jamie Critchlow, Dan Baker, and Angela
Burns used the Fox School IP address 150.199.176.125 to post comments on the
website www.Topix.com. See Ex. D, Pgs. 46-49, 52-57.
48.
Defendant \Villirun Brengle used his home IP address to post comments
on the website www.Topix.com. See Rx. D, Pgs. 3-14.

49.
Angela Bums and Dan Baker used their home IP address to post
comments on the website www.Topix.com. See Ex. D, Pgs. 60-62.

50.
Dianne and Jamie C1itchlow individually or jointly used IP address
I 08.231.66.58 to make posts on Topix using the following incomplete list of

usernames:
a. RSJ;

m
ro
~
:J
'<
::!!
ro
b. Newbie;
0.
'
'ro
c. If I were SAM;
d. Cant help butt notice;
~
01
0
e. TROOP 5 or6;
"'
z
<
ro
f. I found one;
er
~
_,,.
g. Idiots;
.~
N
0
h. Go fox;
I.
.~
"'_,'
OMG;
.~
~
"':;:::
j. Ann,
)>
k. Holy cow;
1. Windsor Alum;
m. RSJ watcher;
n. Troop 11;
0.
Green eggs and ham;
p. Well said;
q. TROOP 12;
r. TROOP 15;
s. oh no;
t. TROOP 18;
u. TROOP Pi;
v. Quack;
w. Blah;
x. Milk sprayed from nose.
51.
Angela Bums and Dan Baker individually or jointly used IP address
68.186.163.99 to make posts on Topix using the following incomplete list of

usernames:
a. Seriously;
b. I-Ialia.
52.
Angela Bums and Dan Baker individually or jointly used the same
unique internet browser on their home IP address of 68.186.163.99 and accessed the
internet on that same unique internet browser using various other IP addresses
provided by their cell phone service provider. See Ex. D. 'i] 6
53.
William Brengle used IP address 108.235.42.34 to make posts on Topix
using the following incomplete list ofusemames;

a. sam i ain' s infected chode;
b. sam' s infected chode;
54.
Defendants individually or jointly used IP address 150. 199. 176.125 to
make posts on Topix using the following incomplete list ofuseman1es:

a. Jamie Matthew Critchlow;
b. Bullwinkle;
c. Friend of Parents;
d. TROOP 5 or 6;
e. baahaaa;
f. who cares.
55.
Defondants individually or jointly made posts on Topix using the
following incomplete list ofusernames:

a. stirring the pot;
b. finally the truth;
c. must be drugs.
56.
Di::fendants Dianne Critchlow and Jamie Critchlow, in concert with
defendants Dan Baker, Angela Burns, and William Brengle, jointly and severally
conspired to accuse Ferry of Pedophilia with the purpose of dissuading Plaintiffs from
criticizing t11e Fox School District, its administrators, ai1d the Defendants, to wit:
a. On January 15, 2013 at 9:44 P.M., Dianne and Jamie Critchlow used
the username "Newbie'' to maliciously publish the following false
and defamatory statement about Ferry to third parties on topix.com:
9
i)
"Perhaps Sam, the uneducated man, feels he's got a real voice
on hear. It's amazing what recently FIRED petifile buffoons
have to share with us. Sam... erase your history, the police will
eventually come knocking for child porn.
People. Complaining in aisle 3 of Walmart to each other isnt

the same as posting here. Perhaps the naysayers and
uneducated folk posting on here can for form an additional
union. The NEA and MSTA can join forces for barely eligible
teacher members called the NEATMS (never ever attending
I
things meaning s#o/o*). What a flipping due paying bundle ofa

jokes! Unions ... another hoax that the ever knowledgable tax
paying citizens of our idiotic society perpetually buy in to.
Humans ... what a bunch ofslapdicks!" See 'Nepotism on Fox
schoolboard' post 461; Ex. D. pg. 19.
A.
The IP address used to make this post is registered to the

home of Jamie and Dianne Critchlow.
B.
The rnntext of the forum makes clear that the 'Sam' in

the above post refers to Sam F eny.
b. On February 2, 2013 at 9:37 P.M., Dianne and Jan1ie Critchlow used

the usemame "TROOP 5 or 6'' to maliciously publish the following
false and defamatory statement about Feny to third parties on
topix.com:
i)
"Dirty ole bastards who oscillate wiili kids?? DO THE

RESEARCH! My spouse is in that building. Completely
obscene and unforgivable." See 'Nepotism on Fox
'
10
A.

c. On February 6, 2013 at 10:32 P.M., Dianne and Jamie Critchlow

used the username "TROOP 5 or 6" to maliciously publish the
following false and defamatory statement about Plaintiffs Simpson
and Feny to third parties on topix.com:
i)
"Yo!!! Petifile Sam. That was addressed over a month ago. Get
off the bong and up to real time.
Elliot is a known hamster packer. Just ask rich Simpson. They

have an undercover tube fest every third Wednesday of the
month. Rumor has it that rich is developing this in his mad
scientist lab; a clawless super hamster that wiggles
exponentially when deprived of air when it's skin is exposed to
methane. Richard Gere has nothing on these a$$ hammers!
You ever wonder why he looks f-d silly? He still has a rodent
that traveled up his digestive system and lodged itself in his
brain. He can't let this tragedy go! Apparently there is a merit
badge for biology when he displays this in his "pack". Lol.
Pardon the pun!
You guys are straight up f-sticks. Kinda like middle school and
now .. .i laugh at you!" See 'Nepotism on Fox schoolboard'
post 768; Ex. D. pg. 28.
A.

B.
The context of the forum makes clear that the 'Sam' in

the above post refers to Sam Feny.
11
d. On Febrnary 7, 2013 at 2:42 P.M., Dianne and Jamie Critchlow used

the username "Windsor alum" to maliciously publish the following
false and defamatory statement about Ferry to third parties on
topix.com:
i)
"Not worried about Sam - disgruntled employee sounds like.

Troop is hilarious. You guys don't get it he making a mockery
of all of you. The crazy on here is the ex Stephanie Thayer."
See 'Nepotism on Fox schoolboard' post 791; Ex. D. pg. 30.
A.

e. On February 14, 2013 at 10:18 P.M., Dianne and Jamie Critchlow

used the usemame "Troop 5 or 6" to maliciously publish the
following false and defamatory statement about Fcny to third parties
on topix.com:
i)
"Yes!!!! I just came on this thread. Had other knowledgable

facts to spread prior to this conglomerate of brainiacs. So good
to see Melissa has finally shared her secret with all of you.
Now hear this. I have a secret to share too. I have learned that
there is an underground group of people who like to impose as
boyscout sponsors. They come in all shapes, sizes, mental
capacities and socioeconomic categories. They are known as,
in my opinion, as the "a$$ hammern". They are constantly
hammering each other with unintelligent, unproved
information so much so that they make an a$$ of each other.
The AH society commonly gather in small despicable groups
to bitch and moan to one another andmcomplain about being
alive and have to deal with real life issues, etc. You get the
gist. Anyway, news has it that they will be gathering for a late
12
mardi gras celebration dressed as their favorite petifile/serial

killer to satiate their deep seeded hatred of being alive. They
will take a vote to see if they should be allowed to exist in this
normal society or move to the island of "irna inbred f up".
Rumor has it that this island is waiting there arrival.. News
channel 2 will be there for the after party report. More to
come!!!" See 'Nepotism on Fox schoolboard' post 897; Ex. D.
pg. 34.
A.

f. On Februaiy 20, 2013 at 9:34 P.M., Diarme and Jamie Critchlow

used the usemame "Troop 11" to maliciously publish the following
false and defamatory statement about Plaintiffs to third parties on
topix.com:
i)
'Tve consolidated my troops ... do the math .. .I 6+5
= 11
Both
troops have combined.(tired of hitting caps lock to address

these people). I will admit...idiocy outlasts intelligence ... in
most cases. After heating about portions of last nights meeting.
This sight is like watching an old couple screw ... Kinda like a
car wreck Gotta look but nothing interesting. These odd jobs
on here flaming the fire all have serious mental Jllnesses.
Debatable? Nol at all. Justifiably hard core cases ofpyschotic
crazies. The online patriots of Rich (f-ud crash victum)
Simpson, Dennis (testosterone deficient) Mueller, Michelle .
(ass and sanity envy loser) Tyler. .. and Samuel L.(fired district
employee and bonified loser) Ferry all showed to support each
other! The parents and students showed up in flocks to show
suppmi. It was rep01ied as awesome! Positive remarks and
13
happy people everywhere. Omg. Heaven forbid the district

ever focuses about positives on this f-up site. On another note.
Reports has it that tthe above mentioned people gathered after
the meeting to plot their next hatred attack on the district.
Reports include unibombers and child kidnapping just to get
Elliot Davis to show .... " See 'Nepotism on Fox schoolboard'
post 966; Ex. D. pg. 35.
A.

g. On February 21, 2013 at 12:58 P.M., Dianne and Jamie Critchlow

used the username "Troop 11" to maliciously publish the following
false and defamatory statement about Ferry to third patties on
topix.com:
i)
"Sam, I guess you've subscribed to the "they're never right"

philosophy. Haha. Thought this tluead about from hiring
people from within. You people are amazing. Truly epitomizes
my remarks all along. Sad, pitiful, whiny humans. Such a
shame sites like this exist for people like you to spew your
toxic mentality. There's a place for your kind. It's called whiny
loserville. Heard all the inhabitants hate each other, fight
constantly and have the lowest school perfo1mance results
ever. lf yo LL move there then you might find some internal
peace." See 'Nepotism on Fox schoolboard' post 978; Ex. D.
pg. 35.
A.

h. On February 21, 2013 at 8:12 P.M., Dianne and Jamie Critchlow

used the uscrnamc "Green eggs and ham" to maliciously publish the
14
following false and defamatory statement about Ferry to third parties

on topix.com:
i)
"Sam I am. I am fired from fox c-6. Yoda lay lee hoo!" See
'Nepotism on Fox schoolboard' post 986; Ex. D. pg. 36.
A.

1.
On February 23, 2013 at 8:45 P.:\1., Dianne and Jamie Critchlow

used the username "TROOP 5 or 6" to maliciously publish the
following false and defamatory statement about ferry to third parties
on topix.com:
i)
"Last I checked "live it" and others like her, are still on my list
of people who can kiss my a$S. Sam, people don't get fired
because they did nothing wrong. You need to do some soul
searching and understand the real reasons why you think you
were given the shaft. I'm sure you did nothing wrong for them
to let you go! They just the secret wheel oftennination and it
happened tp land on you. Lol It's probably this same idiotic
attitude and personality you display on here tltt helped them
decide you no longer need to be employed with the clistrict ... l'd
imagine." See 'Nepotism on Fox schoolboard' post 992; Ex.
D. pg. 37.
A.

B.

the above post refers to Sam Ferry.
J. On February 27, 2013 at 8:32 P.M., Dianne and Jamie Critchlow

used the usemame "TROOP 11" to maliciously publish the following
15
false and defamat01y statement about Fen-y to third parties on

topix.com:
i)
"Just to shed some light. It's tax payers delight website, based
on income right? Someone help me here ... If so, Sam is
receiving no income ( because he was fired for being the same
$hit disturber on here that I'm sure he WAS at work) therefore
paying no taxes ... thus, has no levity whatsoever. Sam, get a
job in the district and then I'll listen. I love watching people
try to make a negative change by whining a bitching. Never
works. Only makes things look worse by your posts. As for

Red, I'll oblige you and state that the odds are that you are a
disgruntled fat bottomed beeotch like a few others on here.
l 'm sure the sign in name of "RED 5" came from the color and
square footage of chaffing you experience between the ham
hocks you refer to as your legs." See 'Nepotism on Fox
A.

k. On September 20, 2013 at 9:14 P.M., Dianne and Jamie Critchlow

used the username 'TROOP Pi to maliciously publish the following
false and defamatory statement about Fen-y to third parties on
topix.com:
i)
''Loi. I again realize just dropping in on what is, at best, a site

of congregating bottom feeders and straight up $&@'/' -ups
who Jive and thrive on BS (I cordially apologize for stooping
to this level). Enjoy your world Sam and 5, no one but you
guys and disgnmtled jack offs live on here. You'll make
16
headlines. Kids talk .... eventually." See 'Nepotism on Fox

A.

l. On December 8, 2013 at 2:43 P.M., Dianne and Jamie Critchlow

used the usemame 'Quack' to maliciously publish the following false
and defamatory statement about Ferry to third parties on topix.com:
i)
"Sam and voice of a treachety, I mean a teacher. Sam ... you

are a FIRED district employee. Your whiney and bitchy voice
carries no weight... At all. The only buffoons on here are as
lowly and d1;Jpressed as you are. Enjoy your company.
Teacher.. .. Go elsewhere. The salary you make is much better
than anywhere else you could go. Reach for it. Misery loves
company. I heard saint Louis public is hi1ing. You should go
there and make a difference. You'd be .in the perfect spot.
Crappy results with another crappy teacher. What a positive
contribution you would make. Lol. I don know why I even
look at this post. 'At'hat a bunch of negative losers you people
are. Keep feeding off each other because this is NOT how the
real world functions. Sam stay away from boys" See
A.
The IP address used to make Uris post is registered to the

57.
Defendants Dianne Critchlow and Jamie Critchlow, in conce11 with
defendants Dan Baker, Angela Bums, and William Brengle, jointly and severally
conspired to accuse Tyler and Simpson of serious sexual misconduct with animals
wit11 the purpose of dissuading Plaintiffs from criticizing the Fox School District, its
administrators, and the Defendants, to wit:
17
a. On February 6, 2013 at 10:32 P.M., Dianne and Janlie Critchlow

used the usemame "TROOP 5 or 6" to maliciously publish the
following false and defamatory statement about Plaintiffs Simpson
and Feny to third parties on topix.com:
i)
"Yo!!! Petifile Sam. That was addressed over a month ago. Get
off the bong and up to real time.
Elliot is a known hamster packer. Just ask 1ich Simpson. They

have an undercover tube fest every third Wednesday of the
month. Rumor has it that rich is developing this in his mad
scientist lab; a clawless super hamster that wiggles
exponentially when deptived of air when it's skin is exposed to
methane. Richard Gere has nothing on these a$$ hammers!
You ever wonder why he looks f-d silly? He still has a rodent
that traveled up his digestive system and lodged itself in his
brain. He can't let this tragedy go! Apparently there is a merit
badge for biology when he displays this in his "pack". Loi.
Pardon the pun!
You guys are straight up f-sticks. Kinda like middle school and
now ... i laugh at you!" See 'Nepotism on Fox schoolboard'
post 768; Ex. D. pg. 28.
A.

b. On February 7, 2013 at 8:31 P.M., Dianne and Jamie Critchlow used

the usernmne "Troop 5 or 6" to maliciously publish the following
false and defamatory statement about Plaintiffs Tyler and Sin1pson to
third parties on topix.com:
18
i)
"Dr H, it's so refreshing to see one of my kind on here. Silly

aren't they?
'Vly troop met this evening. We made signs ... hundreds of them.
We will post these sporadically around the district. Most them
will read some like, but not exactly the same as .... "Rich
Simpson and Michelle Tyler are copulating with livestock.
They must move from the district". Apparently it's quite
interesting from what many of the posters on here have
described to me. Rich is able to take the length of a miniature
pony and Michelle's can swallow a donkeys load. That's
disgusting!!! But I have to admit .... ain't surprised." See
A.

c. On March 15, 2011, Defendants individually or jointly used the

usemame "Finally the lrntl1" lo maliciously post the following false
and defamatory statements about Simpson to third parties on
topix.com:
i)
'"Ohhh forgot to mention Another fact. "fox student comes

first" aka rich Simpson junior flies monthly to Mexico to
engage in violent anal sex with miniature horses. My ex best
friends second cousin from college (long story and kinda crazy
in the l1ead) ran into him at a cantina. He was wasted and spout
off about Nina, the equestrian love of his life." See 'Fox High
School Superintendent' post 820.
19
58.
Defendants jointly and severally conspired to make malicious, retaliatory
and harassing accusations and comments with the purpose of dissuading Plaintiffs
from criticizing the Fox School District, its administrators, and the Defendants, to wit:
a. On November 16, 2010 at 7:49 A.M., defendant Jamie Critchlow

used the username "Jamie Matthew Critchlow" to publish the
following statement on Topix.com using his own name:
i)
"Public ... let me introduce myself. 1 am Jamie Critchlow.

Principal of the Bridges program at Fox C-6. I have been
made aware of this website and rumors as of late. I am on here
to speak to you as a concerned parent. I am trnly apathetic for
anyone who frnds comfort in these negative words. Dr Brown
and I are great friends who have found solitude in each others
friendship through difficult times. The light in which both she
ai1d i have been shed on this website is at best ridiculous. If
you have any questions you would like to ask please call my
personal cell at ... " See 'Nepotism on Fox schoolboard' post
127; Ex. D. pg. 55.
A.
The lP address used to make this post is registered to the

Fox C-6 School District.
b. On November 16, 2010 at 8: l 0 A.M., defendants individually or

jointly used the uscrnamc ''Bullwinkle" to publish the following
harassing and retaliato1y statement directed at Simpson on
Topix.com:
i)
"The school board president is a female and has been president

since early last spring you dip stick. Again ... more lies to ham1
others.
Mr Critchlow, I will call you and we can start our own
20
campaign against these crazy parents .. LOL Perhaps we can

find them something to do at your school...hahahaaa" See
A.

c. On November 16, 2010 at 10:03 A.M., Defendants individually or

jointly used the username "Bullwinkle" to publish the following
harassing and retaliatory statement directed at Simpson on
Topix.com:
i)
"Channel person. You must be the disgruntled parents over

the OCR case. get over it! you lost."
"Please"" You are correct in that affairs in the work place are
frowned upon and Im sure Paul wonld agree with you.
However, making accusations without proof is slander and
you, my friend, are crossing the line repetitely. You lose. get
over il!
Put your name out there like Mr Critchlow did. Hes being
ripped on here too and I applaud him for his righteousness."
A.

B.
The above referenced 'OCR case is a reference to the

Simpson's seven year battle with the administration to
have a 504 plan implemented for their daughter, who has
a life threatening peanut allergy.
21
C.
Defendant Dan Baker was the assistant superintendent

responsible for the administration of the district's
disability plans.
D.
Defendants Dan Baker and Dianne Critchlow were

actively involved in district's unreasonable denial of a
504 disability plan for the peanut allergy of the
Simpson's daughter.
d. On January 17, 2011, Defendants individually or jointly used the

username "stining the pot" to publish the following retaliatory and
harassing statement directed at Simpson on Topix.com:
i)
"Hope your kids don't like peanuts" See 'Fox High School
Superintendent' post 645.
J\.
The reference to a peanut allergy is a clear reference to

the Simpson s attempt to implement a 504 plan for their
daughter's life threatening peanut allergy.
e. On March 15, 2011, Defendants inclividually or jointly used the

username "must be drugs" to maliciously post the following false and
defamatory statements about Simpson to third parties on topix.com:
i)
"is it heroin? Acid maybe?" See 'Fox High School

Superintendent' post 821.
f. On December 15, 2012 at 7:47 P.M., Dianne and Jamie Critchlow

used the username "RSJ" to harass Simpson on topix.com, posting
that:
i)
"Simpson junior has chameleon vision . .Just look at him." See

A.

home of Defendants Dianne and Jamie Critchlow.
22
g. On January 15, 2013 at 2:23 P.M., defendants individually or jointly

used the usemame "Friend of Parents" to malicionsly publish the
following false and defamatory statement about plaintiffs to third
parties on topix.com:
i)
"Its such a shame that Rich Simpson Jr spends more time on

stirring up crap with the district than taking care of his very ill
mother. This is obviously an ill man himself with his priorities
clearly out of whack!
I know for a fact that the Administration is NOT moving to the

service center and that my children have all the books they
need in school. Apparently some hefty disgruntled woman
was peddling this crap out front of Shnucks tllis weekend. Did
none of you read the letter put on the website this weekend?
Before any of you go out on a limb and attempt to make a

comment at the board meeting, be sure to know the facts
before you open your uneducated pie holes.'' See 'Nepotism
on Fox schoolboard' post 448; Ex. D. pg. 47.
A.

h. On Januaty 15, 2013 at 9:30 P.M., Defendants Angela Burns and Dan
Baker, a matTied couple, used the username "Seriously" to
maliciously publish the following false and defamatory statement
about Simpson to third paiiies on topix.com:
i)
"It is filllazing how people believe complete nnt jobs! Can't

believe people would listen to that one crazy guy with the
weird eye. I !mow him from Boy Scouts and he says some
23
really strange things that do not sound right. I am pretty sure

he has a closet where he hangs up newspaper clippings of
board members and wears clown make up while cutting up
teddy bears. That guy is crazy!" See 'Nepotism on Fox
A.

home of Defendants Angela Bums and Dan Baker.
B.
References to the Boy Scouts and "weird eye" are clearly

intended to identify Simpson.
1.
On January 24, 2013 at 4:57 P.M., Dianne and Jamie Critchlow used
the username "Ifl were SAM" to maliciously publish the following
false and defamato1y statement about Feny to third pat1ies on
top ix.com:
i)
"! was told about this a few days ago and took a look. I have
read what all have written and hands down Sam takes the
prize. Sam, please do us all a favor and explain the EXACT
reason why you were FIRED!?I. The very little cyher
credibility must feel that you have secured in your
complaining .... will vanish quicker than a piece of cake
around Ms Tylers ginormous a$$.
Your one sick m-fcr. If come near MY daughters you won't
walk away. Please explain this to us Sam.'' See 'Nepotism on
Fox schoolboard' post 610; Ex. D. pg. 21.
A.

B.
The context of the fornm makes clear that the 'Sam' in

24
J. On Janmuy 24, 2013 at 7:14 P.M., Dianne and Jamie Critchlow used
'
the username "Cant help butt notice" to post the following harassing
statement about Tyler to third parties on topix.com:
i)
"I was at that last board mtng as an innocent bystander hoping

to watch these fools make a mochery of themselves, and they
did. That lady who was up there looking like an idiot had the
largest hiney I think I've ever seen. I think just one cheek may
have weighed more than her dumba$$ husband who was there
to whine as well. I couldn't stop looking at it...it was like a car
wreck happened in her pants or something. That "thing" made
the Hindenburg look like a gum ball. Its no wonder shes all
pizzed off. Just saying." See 'Nepotism on Fox schoolboard'
post 614; Ex. D. pg. 21.
A.

home of Defendants Dianne and Jamie Critchlow.
k. On January 24, 2013 at 7:20 P.M., Dianne and Jamie Critchlow used
the usemame "lf I were SAM" to maliciously p11blish the following
topix.com:
i)
"Sam,
We're all still waiting for you to tell us the trnth. By the way
my name is Ralph Turner
Now spill the trwillful all of people tired of your lies and
obstinate BS or I will formally request your records through
the proper channels and hand this out at schnucks upon receipt
of them. Tired of the fools on here ... including you." See
25
'-
ro
""';;:
A.
The IP address used to make 1his post is registered to the

B.
The context of the forum makes clear thatthe 'Sam' in

l. On January 24, 2013 at 7:43 P.M., Dianne and Jamie Critchlow used
the username 'TROOP 5 or 6' to maliciously publish the following
false and defamatory statement about Simpson to third parties on
topix.com:
i)
''Rich, Just remember. Sticks and stones may hurt some bones
but words will never hurt anyone. Your a scout leader you
freak! Go get examined for all our sakes. You neeeeeeeeed
help," See 'Fox' post 4; Ex. D. pg. 59.
A.

home of Jamie and Dianne C1itchlow.
m. On Janumy 25, 2013 at 11 :54 A.M., Defendants Dianne and Jamie

Critchlow used the username "Troop 5 or 6" to maliciously publish
the following false and defamat01y statement about Simpson to third
pai1ies on topix.com:
i)
'Old school got her very large feelings hw1. Its the truth. Its
also the tmth/fact that Rich Simpson Jr has been publicly
reprimanded from the regional director of the boyscouts for
using his connections within the
rank~
to recruit and solicit
additional inbred people such as yourself to spread slanderous

rumors and lies. Thats a fact. He sent emails and letters to
anyone, including yourself, tlmt would listen to him. Now
folks, just look at him! Listen to his incesent whining. If you
had one bit of an IQ and continue to bich about the district,
26
you too are an idiot. Now f off and go make another sign ... ''
'
A.

n. On January 25, 2013 at 5:19 P.M., Dianne and Jamie Critchlow used
the username "TROOP 5 or 6" to maliciously publish the following
false and defamatory statement about Simpson to third parties on
topix.com:
i)
"Nothing like a dumb fat gossip to keep the onlookers

entertained. Let's do this. Answer me these few questions. 1.
Are you employed at all, and if so for more than 40 hours a
week? 2. Do you have kids that attend school in the district?
3. Do you eat when you are upset or angry ... preferably
chocolate or Simpsons juniors spunk? You people are irritated
because the above mentioned facts are true! I get on here for
entertainment. I !mow who this group of invalids are stoking
this site. You have nothing better to do other than enjoy each
others whiny, negative, miserable company. This is your only
outlet in life. It consumes you. It's your focus. What a sad
bunch oflosers you opponents of fox are. Truly lifeless
humans." See 'Nepotism on Fox schoolboard' post 635; Ex.
D. pg. 22.
A.

o. On January 25, 2013 at 5:58 P.M., Dianne and Jamie Critchlow used
the uscrnamc "I found one" to publish the following harassing
statement about Simpson and Tyler to third paities on topix.com:
27
i
::J
i)
"I just found a sign that's been talked about on here. It's
located just a few houses down on Glatt road nailed to a pole.
Had to use my bright lites in my 1998 chevy but it read
something like ... !Hey hey ho ho Richard Simpson is a joke!
Impeach his harem of dumb fat boyscout out moms. I Coulda
been a bit off but I swear to god it was there! See for
yourself." See 'Nepotism on Fox schoolboard' post 638; Ex.
D. pg. 23.
A.

p. On January 31, 2013 at 5:11 P.M., Dianne and Jamie Critchlow used
the usemame "Idiots" to maliciously publish the following false and
defamatory statement about Tyler to third parties on topix.com:
i)
"The family doesn't meet the requirements You a11 think you
are so keen. Crazy ms Tyler your jealously is almost
psychotic! I would be worried ifI were any of these admin. or
board. She needs to be banned before someone gets harmed. I
heard she is nuts!!!" See 'Nepotism on Fox schoolboard' post
692; Ex. D. pg. 23.
A.

q. On Januaiy 31, 2013 at 5:12 P.M., Dianne and Jamie Critchlow used
the username ''Go fox" to maliciously publish the following false and
defamatory statement about Ferry to third parties on topix.com:
i)
"They are getting much needed help. I support the district and
board. Not fired employees that lie," See 'Nepotism on Fox
28
A.

r. On febrnaiy 2, 2013 at 9:10 P.M., Dianne and Jamie Critchlow used
the usemame "Go fox" to maliciously publish the following false and
defamat01y statement about ferry to third parties on topix.com:
i)
"I think all have their merits. Everyone judging should

carefully exercise their right to choose who is the most
mentally unstable. Keep in mind each of these candidates all
have issues that may be clinically diagnosed completely
different from one another. Should you know one of these
head cases, you can not vote for them. Yes I realize you may
have to endure being their neighbor, relative or better yet part
of their boy scout troop. Choose wisely because the winner
will eventually end up either in an asylum or shot stalking
someone in their home." See 'Who's the biggest LOCAL
LOONEY?' post l; Ex. D. pg. 59.
A.

home of Jrnnie and Dianne Critchlow.
s. On February 2, 2013 at 9:21 P.M., Dianne and Jamie Critchlow used

the usemame "TROOP 5 or 6'' to maliciously publish the following
topix.com:
i)
"Sam ferry can tell you how to not keep a job. Just ask him the
trick to getting fired. Has nothing to do with performance.
What options arc left . Hmmmm. Dirty old ba$turd +being
around teenage girls = getting fired.
Sam. You should be thankful for getting fired. It's really a

29
good thing. Had you kept on you probably would have been
brought up on charges. The ttuth shall set you free. Now go
pray to Zeus and hope he does condem you to the nether world
for eternity." See 'Nepotism on Fox schoolboard' post 714;
Ex. D. pg. 24.
A.

t. On February 2, 2013 at 9:30 P.M., Dianne and Jamie Critchlow used

the usemame "TROOP 5 or 6" to maliciously publish the following
false and defamatory statement about Tyler to third parties on
top ix.com:
i)
"News flash! This just in ... It's been reported that Michelle
Ty !er just unde1went surgery. Apparently her asstronomical
surgery was an amazing success. She is the first human to
successfully receive an a$$ ttar1splant from a cow. Reports
say she had conjenitive rump failure due to the large arnount of
blood it took to keep the large amount of blood flow to her
gigantic hemispheres. She is now recovering nicely in a
Mexico hospital where her new and slightly smaller bovine
a$$ will be ready for return to the states this weekend." See
'Nepotism on fox schoolboard' post 715; Ex. D. pg. 24.
A.
The IP adclres:; usecl to make this post is registered to the

u. On Febrnary 5, 2013 at 4:44 P.M., Dianne and Jamie Critchlow used

the username "TROOP 5 or 6" to publish the following statement on
top ix.com:
i)
"Yes ... I did find that quote out tl1ere somewhere. Kudos to all
you highly educated sleuths who prowcl all over this site like a
30
fat mom on cake. You should be proud. Okay let's move on

kids. I will make another observation ... The people on here or
all on for the same reasons, including me. My goal on here
has been to enlighten as well as defend the district. I know
people who know people, you get the jist. My knowledge of
some of the people I have berated on here are from what I have
heard (rnmor) and know (fact). I am not a gambling person
but i would guess the majority of people whining also arc
claiming to know factual comments made on here as well. The
bottom line is that none of you whiners know the tmth. The
ttuth about the board, the administration, etc. I would bet none
of you have never been behind closed doors during a meeting
that addressed hiring practices including what faculty, staff
and board members were in attendance and contributing to
these practices. I will also presume that no one on here has the
credentials to rnn a food service much less a huge school
district." See 'Nepotism on Fox schoolboard' post 737; Ex. D.
pg. 25.
A.

v. On February 5, 2013 at 4:45 P.M., Dianne and Jamie Critchlow used

the username "OMG" to publish the following false and harassing
statement about Tyler to third parties on topix.com:
i)
"'\icws flash! This just in ... It's been reported that Michelle
Tyler just underwent surgery. Apparently her asstronomical
surge1y was an amazing success. She is the first humm1 to
successfully receive an a$S transplant from a cow. Reports
say she had conjenitive rump failure due to the large amount of
31
blood it took to keep the large amount of blood flow to her

'
gigantic hemispheres. She is now recovering nicely in a

Mexico hospital where her new and slightly smaller bovine
a$$ will be ready for return to the states this weekend." See
A.

home of Jan1ie and Dianne Critchlow.
w. On February 5, 2013 at 4:54 P.M., Dianne and Jamie Critchlow used

the usemame "TROOP 5 or 6" to publish the following false and
harassing statement about Tyler to third parties on topix.com:
i)
"Loi! Ifit is, his ex has one gigantic a$$. I heard a long tin1c
ago that the ex is a mean dyke-ish woman as well. Maybe they
were separated at birth. Or maybe they eat the same diet and
use the same hair dresser. Hahahaaa. I love making fon of
idiots. It brings me joy. Till later, whiney topix losers .. " See
A.

x. On Febmary 6, 20 l3 at 8: 15 P.M., Dianne and Jamie Critchlow used

the usemame 'Ann" to publish the statement on topix.com:
i)
"Thats all you got Stephanie. Dwi. Talk about slander. Keep
calling Elliot. You me a scorned ex that has been called out.
Way to go Jamie and Chris. Kiddos to two great men!!!" See
A.

y. On February 6, 2013 at 9:08 P.M., Dianne and Jamie Critchlow used

the uscrnmnc "Troop 5 or 6" to maliciously publish the following
32
<...
~
Ol
"'
false and defamatory statement about Plaintiffs to third parties on

topix.com:
i)
"Wow! What happened? I heard there are soine crazy ex's on

here but this verifies some things. If this site is a venue for that
then I guess it truly validates my affonnentioned comments.
This site festers with psychopathic and unruly idiots. If the ex
wife is on here solely to spread hatred and misery then I guess
Sam has a chance at finally getting a date. Sloppy seconds of a
used mule? People ... I hate to tell you this, but if you study this
and relish in it then you would be known as what most
intelligent people would refer to as "LOSERS". Yes .. l hate to
share this with you but it's who you are. On another note, this
ex wife who seems to be so hateful obviously has a jealousy
issue. Rumor has it that she came in a close second to Michelle
Tyler in the fatest ass contest recently held in saint Louis at the
bull dyke festival." See 'Nepotism on Fox schoolboard' post
756; Ex. D. pg. 27.
A.

z. On Februa1y 6, 2013 at 10:08 P.M., Dianne and Jamie Critchlow

used the usemame "Holy cow" to maliciously publish the following
false and harassing statement about Simpson to third parties on
topix.com:
i)
"[think Elliot was there for all the wrong reasons. From what l
can gather she was only there for the SAFETY SUMMIT.
Hereyee Hereyee. It's not the superintendent's responsibility to
entertain a liberal negro dip- $hit disturber when the agenda
calls for an entiircly different matter. Whats amazing is that
33
Simpson junior shows up on tv. What an idiot. Docs this guy

have a job? I swear this country has fallen to $hit when a
mentally deranged fool gets an interview. Rich. Good job
calling yourself out on being the whistle blower. Y oure no
more than a deranged douche bag exposing themselves in the
community by hiding behind boyscouts amongst other
community fellowships. I pity the idiots who listen to you.
Lost sheep! It trnly proves there will always be special needs
classrooms in the public schools. Dip$hits ... Keep rproducing!
It only saves jobs. Buy in negative media lovers. Ifit makes
you happy!. Enjoy going to work tomorrow if you truly are

qualified for a job ... or even have one." See 'Nepotism on Fox
A.

aa. On Febrnary 6, 2013 10:39 P.M., Diam1e and Jamie Critchlow used
the L1sername "TROOP 5 or 6" to maliciously publish the following
false and defamato1y statement about Feny to third parties on
topix.com:
i)
"Let's just state one fact! You are a fired employee! Your
cmmnents are worthless! Go get a job Sam. You need to stop,
really. I feel bad for you." See 'Nepotism on l'ox schoolboard'
post 770; Ex. D. pg. 28.
A.

B. The context of the forum makes clear that the 'Sam' in

34
bb.On February 6, 2013 at 10:57 P.M., Dianne and Jamie Critchlow

used the usemame "TROOP 5 or 6" to maliciously publish the
following false and defamatory statement about F eny to third parties
on topix.com:
i)
"Sony Sam. I would love to stay up all night and debate with
you but 1 must digress. I have work in the morning. A
rewarding job that I must prepare myself for. One that
requires forethought and planning. You understand ... but not
really. Night d-bag! PS go apply for work. The school district
beeds your tax dollars." See 'Nepotism on Fox schoolboard'
post 772; Ex. D. pg. 29.
A.

home of Jan1ie and Dianne Critchlow.
B.

the above post refers to San1 Ferry.
cc. On February 7, 2013 at 9:10 A.M., Dianne and Jamie Critchlow used
the username 'TROOP 5 or 6" to maliciously publish the following
false and ddamato1y statement about Sin1pson to third parties on
topix.com:
i)
"Wait, stop, don't! The intelligence is so prevalent in recent

comments. I can't handle it. The local nut cases are
collectively rearing their retarded heads. Please don't. You're
such and impressive force of anonymous posters. I fear the
Internet will come riding into my living room and slay my
family and I. Your imposing posts arc threatening and
powerful. Factual and trne. Hell I believe all the hearsay now
because of you f-sticks. I'm a changed man. I want to attend
rich Simpsons next sacrificial Loser meeting. I hear that he
35
and other boyscouts dads lather up with baby oil and cock
choke each other until the loser gags and pukes. It's what I
heard. Not saying its a fact though. I don't need help, I need
scalps!" See 'Nepotism on Fox schoolboard' post 782; Ex. D.
<
ro
pg. 29.
A.
;;;:
g
~

dd.On February 7, 2013 at 2:58 P.M., Dianne and Jamie Critchlow used
the uscrnamc "TROOP 5 or 6" to publish the following statement on
topix.com:
i)
"Now Ryan don't be so concerned with me. It's merely things

I have heard. Kinda like all the idiots on here claiming they
actually know something about nepotism, the board, the
administration. Tools. The whole lot of you!!! Now, I will
say this. From what I have heard there will be some sparks
flying ve1y soon for a few of you. Cue evil monster laugh ...
Moohahahahaa. Heheheoooooo rahahahaaaaa." See
A.

ee. On February 8, 2013 at 6:29 P.M., Dianne and Jamie Critchlow used
the username 'Troop 5 or 6" to maliciously publish the following
false and defamatory statement about Plaintiffs Tyler and Simpson to
third parties on top ix.com:
i)
"No Time Out.. .. this site will work just fine. Now for this
evenings lesson. Of the many but same people who post on
here are none more instigating as concerned parent. Yes you've
guessed it ""concerned parent"" is a fat bottomed ex with
36
N
0
"'
nothing but vengeance on her mind. According to my troop

reports is that this mom, Rich Simpson and Michelle Tyler
gather frequently to see who can stuff the most Twinkies up
one another's ass. Personal records include, but are not limited
a box a piece. It's also known that fat absorption can occur
rectally hence the exponentially huge hind quarters located on
each of these bull dyke women. Till later instigators! BTW
Sanely Baker pays for male services since she can't find a man
that finds her f-able! Mini dyke in training." See 'Nepotism on
A.

ff On Febmary 8, 2013 at 9:45 P.M., Diam1e and Jamie Critchlow used

the usemame "Troop 5 or 6" to maliciously publish the following
false and defamatmy statement about Tyler to third parties on
topix.com:
i)
"I would like to continusouly share one of my children's

favorites stories when they were little ones. It goes a bit
something like this:Bitter dyke. Bitter dyke let me in! Not by
tl1e hairs on my triple decker chin!
Bitter dyke. Bitter dyke why so mad? l been all over topix and
I've been unclad
Bitter dyke. Bitter dyke whos to blame? All of the people with
a critchlow/ baker name!
Bitter dyke. Bitter dyke what to do now? Hell ifI know, I'm a
psycho fat cow!
Bitter dyke. Bitter dyke when will you stop? When I finally
eat so much that my ginormous ass pops.
37
There's more but tiny Tim is usually asleep been this line. If
you want more you can find some of my finest work at
www .gofyourselflosers( dot)corn
I will be sure to share more with you as the days come and
go!" See 'Nepotism on Fox schoolboard' post 829; Ex. D. pg.
31.
A.

gg.On Pebmary 8, 2013 at 10:04 P.M., Dianne and Jamie Critchlow

used the username "RSJ watcher" to maliciously publish the
following false and defanrntory statement about Simpson to third
i)
"!find it completely ironic that this boy ended up as part of

Elliot's report. Rich, let's define nepotism. This goes way
back to your daddy aka. senior, who was an assistant
superintendent while your mother was a teacher and you and
your sister were on the payroll too. You were there working
with the company "minds eye". Your dad hired you and your
sister. Your company was terrible and you were fired. No
wonder you have problems with Fox! You are a text book
hippocrit. How in the world can you live with yourself? I was
in central office back in the 80's. You should be so ashamed of
yourself and the Benedict Arnold person you have become to
the district. I'm old now, but if weren't, I'd wash your mouth
out with soap for all the filth and lies you spread. Your parents
are great people. True to their profession and the people in it.
What happened to you?" See 'Nepotism on Fox schoolboard'
post 831; Ex. D. pg. 32.
38
A.

hh.On Febrnary 12, 2013 at 7:51 P.M., Dianne and Jamie Critchlow
used the usemame "Troop 5 or 6" to maliciously publish the
following false and defamatory statement about Tyler to third parties
on topix.com:
i)
"You inbred, unknowingly, racist f-sticks have no idea what a

dream is. Your dreams beyond being ad-bag within the
district may include:
your house has no wheels
that you stayed in high school and went to Jeffco ... ,and are
now qualified to actually work in the district...maybe
that you shouldnt have gone to da movies wit yo babies daddy
that you are constantly in denial of who you would be without
a site to be a loser on
that you wish grannys distillaty didn't catch the families best
trailer on fire
that a life without topix would focus you on doing something
you've been neglecting to do in your house .. .like clean it
There are sting operations that many of you would fall into.
Beware of 90% coupons off at pizza and chineses buffets.
PS. I'm still amazed that Michelle Tyler's hind quarters aren't
a mutant tmaformation. ln a movie she could drop from 1000
feet and crnsh a small city with that thing. Impressive in a
genetic facet. You must admit." See 'Nepotism on Fox
39
A.

11.
On February 12, 2013 at 8:17 P.M., Dianne and Jamie Critchlow

used the username 'TROOP 5 or 6' to maliciously publish the
following false and defamatory statement about Tyler to third parties
(I)
on topix.com:
i)
"Tim, I will petition for you to insert your fist up your dogs
rectum before I would sign anything in opposition of our
district. Btw d bag a petition requires signatures. Expose
yourself on the steps of a local business and see what
responses youll get. You have no balls, therefore you won't do
this. Know why? Because, unlike Michelle Tyler, who has
learned that she's a bonificd psycho in the eyes of thousands,
that stating the truth in your own minds eye, equals being an
uneducated and uniformed loser. Just stating facts by most
peoples standmds.,. See 'Petition for No Nepotism at foxc6'
post 3; Ex. D. pg. 59.
A.

JJ. On Febrnaiy 27, 2013 at 11 :52 A.M., defendants jointly or

individually used the username "baahaaa" to publish the following
harassing and retaliatmy statement about Ferry to third parties on
topix.com:
i)
"Sam, you need help and a better hobby." See 'l\epotism on

A.

40
kk. On Februa1y 28, 2013 at 11 :50 A.M., defendants jointly or

individually used the username "who cares" to publish on topix.com
the following threat of physical violence against plaintiffs:
i)
"Attacks are random. you may be next???" See 'Nepotism on

A.

11. On Februa1y 28, 2013 at 6:40 P.M., Dianne and Jamie Critchlow
used the username "TROOP 11" to maliciously publish the following
false and defamato1y statement about Plaintiffs to third parties on
topix.com:
i)
"True, I am now told she has even more butchy purple hair
that highlights her already evil face. Nothing like praising a
fired district employee, a purple headed, oil changing dyke,
and the mentally unstable son of a superintendent. Sam, find a
way to get out tomorrow ... go job searching. Go for a walk. For
the other disgruntled hags on here. Follow Sam. He will be
walking. You can pick up his offal as you epitomize the blind
leading the blind.
The district is strong and improving daily. Things just seem to

keep improving as the whiners on 11ere keep whining.
I've found another site that interests me more. I'll let you crabs
in the bucket carry on for a while .. .lol" See 'Nepotism on Fox
A.

41
B.

the above post refers to Sam Feny.
mm.
On March 2, 2013 at 8:42 P.M., Dianne and Jamie Ctitchlow used
the username 'TROOP 11" to maliciously publish the following false

and defamatory statement about Plaintiffs to third parties on
topix.com:
i)
"Ahhh ms Tyler ..... Bravo to 2 of the 5 nototious $hit

disturbing nimrods on here. Only if Junior will confess will we
get the trifecta. What's sad is the sanctity that you find in one
another's negative agenda and each others opinion. What's
even sadder is that your multiple posts amongst different
names constitutes the voice of nothingness .. .including Sam the
fired man. This site has spent itself past all possible
worthiness. As I mentioned before, I am an avid defender of
the district (because it's good) and have found the mentally
challenged on here ( who are evil, but rather not able to fully
comprehend real lifo agendas and reality) to be ratherly bming
over time. Michelle. I'll leave a donation for your next cut and
die if i see you. At least you can look presentable the next
time you try to hand out flyers and paint patheological psycho
signs ... \Vait...that was nut job mueller and Simpson at a
boyscouts meeting. HENCE my name. You people are Fup! !!" See 'Nepotism on Fox schoolboard' post 1122; Ex. D.
pg. 40.
A.

42
mi.On March2, 2013 at 8:49 P.M., Dianne and Jamie Critchlow used the
username "Well said" to maliciously publish the following false and
defamatory statement about Tyler to third patiies on topix.com:
i)
"Ifl were you I would also harass your hair stylist. :). By the
way. Your ""coming out"" exemplified what the consensus is
about you and your sort. GO READ, then write." See
A.

oo.On March 3, 2013 at 10:24 P.M., Dianne and Jamie Critchlow used
the Ltsemarne 'TROOP 12' lo publish the following haiassing
statement directed to Feny and his family on topix.com:
i)
"I've grown. One more poster to our group. Gotta love the
polmity of goodness, honesty and real trnth of kids. Isn't It
reality a hooger? Boyscouts are good kids. Don't pollute them
at this age. Sam is a transplant. At best an Arnold
Swrazzrengger poser! A transplant at best... This homer
wants to be a voice for our cornnmnity as a fired janitor?
Lollololllllolooooollloloooo! You people must tmderstand.
Sam came from a different world. Hes a poser/loser from the
west coast" See 'Nepotism on Fox schoolboard' post 1144: Ex.
D. pg. 40.
A.

pp.On March 6, 2013 at 9:12 P.M., Dial11le and Jamie Critchlow used the
uscmamc 'TROOP 15' to publish the following harassing statement
directed to Ferry on topix.corn:
43
i)
"Ruth Anne [School Board president at time of post] is the

mother/ grandmother all of us never had. For anyone to
berate, belittle or demean anything she supports is a true attack
on human kind and the district. She is the epitome of what's
ritght in the world, much less the district!. For the people on
here trying to belittle the district, it's board or it's
administration are what the troopsters would reter to as
""a$$wipes""l. I hold no concern as to what the whiners
portray. The more Sam the ""fired man"" claims, the more the
truth of mankind says. A man who chastises his former
employer will never find on again ....
Sam. You lost lost once in your annoying voice. You will
lose again. go back to the west coast where Arnold will
snuggle witb you" See 'Nepotism on Fox scboolboard' post
1186; Ex. D. pg. 42.
A.

qq.On March 6, 2013 at 9:21 P.M., Dianne and Jamie Critchlow used the
username 'TROOP l 5' to maliciously publish the following false and
defamatory statement about Simpson to third parties on topix.com:
i)
"Simpson junior is a demented reject lamb that fondles lost

sheep such as Dennis mueller. .. times are tough for closet
homos." See 'Nepotism on Fox schoolboard' post 1187; Ex.
D. pg. 42.
A.

home of Jamie and Diam1e Critchlow.
44
rr. On March 6, 2013 at 9:46 P.M. , Dianne and Jamie Critchlow used
the usemame 'oh no' to publish the following harassing statement
directed to Ferry and his family on topix.com:
i)
"Sam .... find a job. You are officially a website stalker. So pity
you in more ways than one. Your employed wife must be
sooooo embarrassed. Don't do that to her her." See 'fox High
School Superintendent' post 1150; Ex. D. pg. 51.
A.

ss. On March 6, 2013 at 10: 10 P.M., Dianne and Jamie Ctitchlow used
the usemarne 'Oh no' to maliciously publish the following false and
defaniatory statement about Simpson to third parties on topix.com:
i)
"Sam. You are bright beyond your years, but yet you are still
a fired janitor. What do you want these people to believe?

Accordance? Mayhem? Unloylaty? No! These are the
standards from which you erupt from! Your followers (who
are are minimal in and ofthemeselves) are what makes the
district stronger. They have always been abou helping each
other. (which is why the district prevails). You are what the
majority call a nuisance. A rat that needs tending. An online
nuisance who has an obvious axe to grind because you were
fired!,. It's you and your kind that only make the board scoff
at you for every unemployed you post you make! You were an
employee. Now you've become a joke. I'm sony your only
endeavor has become this site. Im a lady but I've had enough
with you and your kind." See 'Nepotism on Fox schoolboard'
post 1189; Ex. D. pg. 42.
45
A.

tt. On May 13, 2013, William Brengle posted under the usemames
"sam's infected chode" and ''sam i am's infected chode." A chode is
slang 1 for a penis that is wider than it is long, and saying that it is
infected is an accusation that a person suffers from a venereal
disease. See 'Nepotism on Fox Schoolboard' Posts 1933, 1935,
1939, 1940, 1941; Ex. D. pgs. 8-9.
i)
The above usemamcs are the complained of defamato1y

statements.
A.
The context of the f01um makes clear that 'Sam' in the

above posts refers to Sam Feny.
B.
Brengle admits that he was "defending the district" when

he posted on Topix.com.
uu.On March 23, 2013 al 11 :21 P.M., Dianne and Jamie Critchlow used
the uscrname 'TROOP 18' to publish the following harassing and
retaliatory statement about plaintiffs to third parties on topix.com:
i)
''[QUOTE who='"'Common Sense""]I would agree. For an

education institution that the Fox District is and one that
should praise higher education, the administration thinks the
general conununity is stupid for thinking this decision is okay.
The district gets an F-- on this metro adve1tised blunder. And
then goes out and hires a deficient admin from DeSoto. The
voters will remember tbis. All the admins should be shaking in
their boots and consider other career paths. April elections will
prove that.<quoted text>[/QUOTE]
y.-1,.v\v.urb:indi~tioQi!D:'.:-g~fil
defines 'Chocte as ''A penis wider than it is long.'" See

(accessed 08/02/2013 at 4: l4 pm).
]l\)11://w\\~v.urbundictiona_ry.co111/define.php''tenn=cl1ode
46
Dear quintet of opponents ... the threat of physical violence

isn't tolerated nor even funny .. The fact that you are now all
clearly visable and completely exposed does not favor you.
The employees of this district have had enough and will
faithfully defend their administration and board. (employed
and loyal). If you want to go redneck Hoosier on this ... all loyal
employees will gladly find a place and time. Trust me, there
are hundreds of us. Talk is cheap. As is your posts". See
A.

vv. On September 20, 2013 at 7 :58 P .M. , Dianne and Jamie Critchlow
used the username 'TROOP Pi' to publish the following harassing
statement directed to Ferry on topix.com:
i)
"[quoted text from post by Sam Ferry removed as irrelevant]
"This certifies that you are officially a certified slap dick.

Thanks for confirming. 100% of our founding fathers who
wrote the first amendment would have lynched you by now."
See 'Fox High School Superintendent' post 1227; Ex. D. pg.

51.
A.

borne of Jan1ie and Dianne Critchlow.
ww.
On September 20, 2013 at 8:33 P.:1\1., Dianne and Jamie Critchlow
used the username 'TROOP Pi' to maliciously publish the following

false and defamatory statement about Feny to third parties on
topix.com:
47
i)
"Sam we all love you. Only because your special. Your

lucky it's 2013 ""dude"'"' See 'Nepotism on Fox schoolboard'
post 2489; Ex. D. pg. 45.
A.

xx.On December 8, 2013 at 2:58 P.M., Dianne and Jamie Critchlow

used the username 'Quack' to publish the following statement on
topix.com:
i)
"[QUOTE who=""Addit""]<quoted text>No moving on or

getting over it m1til the old board has been replaced and
Administration makes better decisions. I enjoy Sam's reposts; I
am in the trenches and living it. Tlove my job and the students
T teach, but some things need to change and it needs to start at
the top. Keep up the good work Sam, and thanks for being at
the forefront for us. [/QUOTE]
Enjoy your paycheck. Loyalty is a characteristic that's rarely

known amongst people anymore. If you feel you're in a
position to complain. Take it to your principal rather than blast
those who have employed you. Times are tough .... money is
tight. We all know that. But to verbally slash the throat of
your own employer is not ok. You need to check your mind set
addit. The 1st amendment only stretches so far. Keep that in
mind mole!" See 'Nepotism on Fox schoolboard' post 2610;
Ex. D. pg. 45.
A.

48
yy.On Januaiy 28, 2014 at 6:21 P.M., Dianne and Jamie Critchlow used
the username 'Blah' to maliciously publish the following false and
defamatory statement about Ferry to third parties on topix.com:
i)
"Sam. Get a life. Your truly obsessed with things out of your
control. Even as a terminated fox employee. Go get a job" See
'Fox High School Superintendent' post 1311; Ex. D. pg. 52.
A.

zz. On January 28, 2014 at 7:02 P.M., Dianne and Jamie Critchlow used
the username 'Milk sprayed from nose' to maliciously publish the
following false and defamatoty statement about Simpson to third
i)
[QUOTE who=""Ssdd""]Richard Simpson should run. Or how

about an upstanding community member. Do we have
any?[/QUOTE]
What? That guy is jacked. I wouldn't be surprised if he eats

used band aids. Way out there. If the if the rain man and
Hellen Keller reproduced this guy would be the result.
Special!'' See 'Nepotism on Fox schoolboard' post 2672; Ex.
D. pg. 46.
A.

59.
The damage suffered by plaintiffs due to the harassing and malicious
statements of defendants often caused plaintiffs to remain silent or soften their

criticism for long periods.
49
COUNT I
Ferry, Tyler & Simpson v. Dianne Critchlow, Jamie Critchlow, Dan Baker,
Angela Burns, and William Brengle in their individual capacity for actual and
punitive damages pursuant to 42 U.S.C. 1983 & 1988 and the First and
Fourteenth Amendments
COMES NOW Plaintiffs Sam Fe1Ty, Michelle Tyler, and Rich Simpson and
for their cause of action for damages against Defendants Dianne Critchlow, Jamie
Critchlow, Dan Baker, Angela Bums, and William Brengle in their individual
capacity, and state to the Court as follows:
60.
Plaintiffs exercised their constitutional rights to criticize the government
and public officials regarding a matter of public interest and importance.

61.
During the five years prior to filing suit, Defendants punished Plaintiffs
speech in retaliation for Plaintiffs' criticism of the District, the administrators, and the
defendants themselves.
62.
Defendants' actions were motivated by a desire to dissuade citizens from
criticizing the district, its administrators, and the defendants themselves.

63.
Plaintiffs suffered the following damages as a result of Defendants'
actions:
a. Humiliation;
b. Embarrassment;
c. Damage to reputation;
d. Exposure to public hatred, contempt, ridicule and shame;
e. Mental anguish;
f. Loss of sleep;
g. Strained family and marital relations;
h. Ferry and Tyler suffered from unpredictable episodes of
uncontrollabk crying;
1.
Chilling of Plaintiffs' speech;
50
J. Tyler suffered from and was diagnosed with depression;

k. Tyler suffered from and was diagnosed with anxiety;
1. The an,xicty and depression suffered by Tyler was so severe that it

caused her to suffer chest pains;
<
CD
m. Tyler experienced weight gain;
cr
9'
n. Feny's ex-daughter in law has restricted Ferry's ability to spend time

with his grandson because she is concerned that Feny is a pedophile
as a result of the malicious accusations of the defendants;
o. Feny is unable to appear in public without concern that those around
him have heard and believe the accusations made by the Critchlows,
and have haimed his ability to interact nonnally with other members
of the public regardless of whether they are actually aware of the
accusations made about him;
p. Falsely stating that Ferry's employment was terminated because of
inappropriate behavior towards underage girls and asse11ing insider
knowledge of the truth of these false statements.
q. Simpson suffered strained relations with his father, a fmmer
superintendent, because Defendants communicated their displeasure
with Simpson's complaints through Simpson's father.
r. Some people in the conununity refused to speak to plaintiffs for long

periods of time out of fear of retaliation at the hands of the district, its
administrators, and the defendants.
64.
Defendant \Villiam Brengle is joined in this count under 42 U.S.C.
1985.
65.
The retaliatory actions taken by the defendants against plaintiffs would
and did chill persons of ordinary finnness from criticizing the district and its
administrators.
51
66.
Defendants violated plaintiffs constitutional rights to be free from

'
retaliation for the exercise of First Amendment protected speech, which is a

constitutional right clearly established at the time of defendants' conduct.
67.
Punitive damages are appropriate because Defendants violated Plaintiffs'
constitutional rights willfully and with full legal malice in an attempt to suppress
Plaintiffs' rights to speech, and the chilling of Plaintiffs' speech was a substantial and
motivating factor for Defendants' actions, and was in gross disregard for Plaintiffs'
constitutional rights.
WHEREFORI<:, Plaintiffs pray for damages against all defendants; for

p1mitive damages against all defendants to punish their willful and malicious violation
of Plaintiffs' constitutional rights; for attorney fees and costs pursuant to 42 U.S.C.
I 988; and for such other and farther relief as to this Court seems just and proper.
COUNT II
Ferry, Tyler, and Simpson v. Dianne Critchlow and Jamie Critchlow for
Defamation
CO:WES NO\\' Plaintiffs Sam fcny, Michelle Tyler, and Rich Simpson and
for their cause of action for damages against Defendants Diam1e Critchlow, Jamie
Critchlow, and state to the Cami as follows:
68.
Defendants Dianne and Jamie Ctitchlow were at fault for publishing
many of the defamatory statements complained of in ilil 56-58

69.
Such statements in ilil 56-58 tended to expose plaintiffs to humiliation,
exposme to public hatred, contempt, ridicule and shame.

70.
Such statements in ilil 56-58 tended to deprive plaintiffs of the benefit of
public confidence, and other social associations.

7 J.
The statements in iii: 56-58 were posted on Topix in forums lmique to the
Arnold, Missouri community and were read by numerous third parties.

72.
Plaintiffs' reputations have been damaged by defendants posts.
52
<...
in
0
"'
73.
The maliciously defamatory statements made by Defendants Dianne and
Jamie Critchlow have damaged Ferry, Tyler, and Simpson in the following ways:
a. Humiliation;
b. Damage to reputation;
c. Exposure to public hatred, contempt, ridicule and shame;
d. Mental anguish;
e. Loss of sleep;
f. Strained marital relations;
g. Feny and Tyler suffered from unpredictable episodes of
uncontrollable c1ying;
h. Tyler suffered from and was diagnosed with depression;
1.
Tyler suffered from and was diagnosed with anxiety;
J. The arLxiety and depression suffered by Tyler was so severe that it
caused her to suffer chest pains;

k. Tyler experienced weight gain;
I. Ferry's ex-daughter in law has restricted Ferry's ability to spend time

with his grandson because she wmries about Ferry being near his
grandson due to the malicious accusations written above;
m. Feny is unable to appear in public without concern that those around
him have heard ar1d believe the accusations made by the Critchlows,
and have hanned his ability to interact nom1ally witl1 other members
of the public regardless of whether they are actually aware of the
accusations made about him;
n. Falsely stating that Ferry's employment was terminated because of
inappropriate behavior towards underage girls and asse11ing insider
knowledge of the truth of these false statements.
53
74.
Punitive damages are appropriate against both Jamie and Dianne
Critchlow because the defamatory statements were malicious and they intended to
cause ham1 to Plaintiffs.
WHEREFORE, Plaintiffs pray for judgment against defendants for damages
for pain and suffering, psychological and emotional injury, humiliation, damage to
reputation, costs, and expenses; and for punitive damages to punish Defendants'
outrageous conduct; and for such other and further relief as to this Court seems just
and proper.
Count Ill
Tyler v. Dianne Critchlow and .Jamie Critchlow for damages for the Intentional
Infliction of Emotional Distress
COMES NO\V Plaintiff Michelle Tyler and for her cause of action for
damages against Defendants Dianne Critchlow, Jamie Critchlow, states to the Court
as follows:
75.
The conduct of Dianne Critchlow and Jamie Critchlow was so extreme
in degree and outrageous in character that it is outside the bounds of civilized decency
and utterly intolerable in a civilized community.
76.
The actions taken by defendants Dianne and Jamie Critchlow were taken
with the intent to cause extreme emotional distress to Tyler.

77.
The conduct of Dianne and Jamie Crtichlow caused Tyler to experience
severe and medically diagnosed depression, anxiety, chest pains, and weight gain.
78.
The conduct ofDialll1e and Jamie Critchlow caused Tyler to suffer the
following damage:
a. Tyler suffered from and was diagnosed with severe depression;
b. Tyler suffered from and was diagnosed with severe anxiety;
c. The anxiety and depression suffered by Tyler was so severe that it
caused her lo suffer chest pains;
54
~
ro
3
d. Tyler suffered from and was diagnosed with weight gain directly
caused by her stress, anxiety, and depression;
e. Unpredictable episodes of uncontrollable crying;
f. Humiliation;
g. Damage to reputation;
h. Exposure to public hatred, contempt, ridicule and shame;
i.
Mental anguish;
J. Loss of sleep;
k. Strained marital relations;
79.
Punitive damages are appropriate against both Jamie and Dianne
Critchlow because the defamatory statements were malicious and they were made
with the full intentions of causing severe emotional harm to Plaintiff.
WHEREFORE, Plaintiff prays for judgment against defendants for damages

for pain and suffering, psychological and emotional injury, humiliation, damage to
reputation, costs, and expenses; and for punitive damages to punish Defendants'
outrageous conduct; and for such other and further relief as to this Comt seems just
and proper.
Respectfully submitted,
SCHWARTZ, HERMAN & DAVIDSON
By:
Dan Herman, Bar No. 65466
8820 Ladue Road, Suite 20 I
St. Louis, Missouri 63124
Ph: (314) 862-0200
Fx: (314) 862-3050
dhermanCailaduelaw.com
Attorney for Plaintiffs
55

Federal Lawsuit Against Critchlow For Topix Defamation

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Federal Lawsuit Against Critchlow For Topix Defamation

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Case: 4:14-cv-02055-HEA Doc.

#: 3 Filed: 12/16/14 Page: 1 of 55 PageID #: 127

In the Circuit Court of the 23rd Judicial Circuit

3040 Strawberry Ridge

Cause No. 14JE-CC00092

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 2 of 55 PageID #: 128

PETITION FOR DAMAGES

Venue is proper because all defendants reside in Jefferson County and

two year Missomi statute oflimilalions for defamation suits.

At all times relevant herein, Plaintiff Sam Ferry (hereinafter "Ferry")

was a resident of Arnold, Missouri.

At all times relevant herein, Plaintiff Rich Simpson (hereinafter

"Simpson") was a resident of Arnold, Missouri.

At all times relevant herein, Plaintiff Michelle Tyler (hereinafter

"Tyler") was a resident of Arnold, Missouri.

At all times relevant herein, Defendant Dianne Critchlow was the

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 3 of 55 PageID #: 129

the same address since that time.

At all times relevant herein, Defendant Dan Baker was an Assistant

At all times relevant herein, Defendant Angela Bums was an assistant

desctibed herein and have Jived together since that time.

At all times relevant herein, Defendant Willian1 Brengle was a resident

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 4 of 55 PageID #: 130

Facts Common to All Counts

At all times relevant herein, Plaintiffs Ferry, Tyler, and Simpson

The subjects of plaintiffs' complaints were a matter of public concern.

At all times relevant herein, defendants Dianne Critchlow, Jamie

Critchlow, Dan Baker, and Angela Burns were public officials.

At all times relevant herein, defendant William Brengle was acting in

Among their criticisms were:

Defendants Dianne Critchlow, Jamie Critchlow, Dan Baker and other

administrators were a central subject of Plaintiffs' complaints.

Defendant Dan Baker was the director of the disttict' s 504-disability

Plaintiffs Feny, Simpson, and Tyler made their criticisms at meetings of

the Fox C-6 School board and in private conversations.

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 5 of 55 PageID #: 131

During the January 15 meeting and the following day, Defendants

Hedrick and Tyler understood these meetings to be a threat by

Defendants Dianne Critchlow and Dan baker against Hedrick's continued

Because of the threat to her mother's employment, Tyler stopped

school lo discuss issues related to Tyler's children.

Domek proceeded to attempt to convince Tyler to discontinue her

criticism of the School board and the administration.

Domek admitted to Tyler that defendant Dianne Critchlow told her to

make Tyler stop.

Defendant Dianne Critchlow set a meeting witli Simpson's father, a

During tl1e meeting between Dianne Crithclow and Simpson's father,

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 6 of 55 PageID #: 132

Following the April 2011 board meeting, Defendant Jamie Critchlow

Defendant Jamie Critchlow left angry voicemails and emails for

Defendants Dianne Critchlow and Dan Baker individually or jointly

Defendants' threat oflitigation caused Simpson to silence or soften his

Defendants' threat of litigation caused Ferry and Tyler to silence or

On February 7, 2013 at 2:58 P.M., defendants, jointly or severally

IP address 108.231.66.58 is registered to Dianne Critchlow for use at the

home address of Jamie and Dianne Critchlow. See Ex. A.

IP address 68.186.163.99 is registered to Angela Bums for use at the

home address of Angela Bums and Dan Baker. See Ex. B.

Case: 4:14-cv-02055-HEA Doc. #: 3 Filed: 12/16/14 Page: 7 of 55 PageID #: 133

IP Address l 08.235.42.34 is registered to William Brengle for use at his

home address. See Ex. C.

IP address 150.199.176.125 is registered to the Fox School District. See

Defendants posted comments about plaintiffs in the following forums on