IN THE DISTRICT COURT FOR THE COUNTY OF BEXAR
STATE OF TEXAS
Civil Action No. 2020 CI 21633
ALISON MA YNARD and RICHARD CARLISLE,
WILLIAM R. LUCERO, JACOB VOS, JACOB ZIMMERMAN, MARK BANKSTON, LEONARD POZNER, DOUG MAGUIRE, and ELIZABETH WILLIAMSON,
This case originally sought an injunction against the interception and disclosure of
Plaintiffs’ private emails in violation of 18 U.S.C. Sec. 2520, along with their use in evidence in
violation of 18 U.S.C. Sec. 2515. Because the activities sought to be enjoined were not, severe
injury has been visited on the plaintiffs. This amended complaint now seeks damages in excess
of $1,000,000 for these injuries, stemming from the violations of federal law as well as the torts
of defamation, invasion of privacy, intentional infliction of emotional distress, and conspiracy by
the original defendants, as well as new defendants Doug Maguire and Elizabeth Williamson. It
also still seeks injunctive relief against the Defendants’ torts. The harm is continuing and severe.
JURISDICTION AND VENUE
1. Plaintiffs seek statutory, actual, and punitive damages, along with costs, including interest and attorney fees. The damages sought are within the jurisdictional limits of this court.
2. Jurisdiction is conferred on this court pursuant to Art. V, Sec. 8, of the Texas Constitution; and Sections 24.007(a) and (b), 24.008, and 17.042(2), Tex. Rev. Civ. Stat. (2021). The amount in controversy is over $500.
3. Defendants are subject to the court’s personal jurisdiction by having transacted business in Texas by initiating, personally serving, and proceeding against Texas resident Maynard in an administrative matter in Colorado; by intercepting, disclosing, and using private emails belonging to both plaintiffs; or by committing the torts of defamation and invasion of privacy against Maynard.
4. Venue is appropriate in this district, pursuant to Tex. Rev. Civ. Stat. 15.002(a)(1), because a substantial part of the events giving rise to the claim occurred in Bexar County, where Maynard resides. Sec. 15.004 also provides that, when there are multiple claims and defendants and one of the claims (in this case, the Sixth through Ninth Claims for Relief, for defamation and invasion of privacy) is governed by a mandatory venue provision (Sec. 15.017), suit is required to be brought in Bexar County.
5. Venue is appropriate for Plaintiff Carlisle’s claims pursuant to Tex. Rev. Civ. Stat. 15.003 and joinder of him in the suit is proper under Texas Rules of Civil Procedure. There is an essential need to have Carlisle’s claims tried in the county where the suit is pending since his emails were intercepted likely from Plaintiff Maynard’s email account and used in a proceeding brought against Maynard. Maintaining venue in Bexar County does not unfairly prejudice any other party to the suit and Bexar County is a fair and convenient venue for Carlisle and all
persons against whom the suit is brought.
6. Alison Maynard (in the first person henceforth) is a resident of Bexar County in the State of Texas and a citizen of the United States. My address is 7642 Hummingbird Hill Ln, San Antonio, TX 78255. My email address is: [email protected].
7. RichardCarlisleisaresidentoftheStateofMissouriandcitizenoftheUnited States. His address is: 2310 N. Grace Ave., Springfield, Missouri 65803, tel: 417-848-4985; email: [email protected].
8. William Lucero is a resident of the State of Colorado employed until May 31, 2022
as presiding disciplinary judge of the Colorado Supreme Court. His business address was 1300
Broadway, Suite 250, Denver, CO 80203; tel: 303-457-5999; email: [email protected]. His
residence is believed to be at 488 I W 102
9. Jacob V os is a resident of the State of Colorado. His address is c/o the Colorado
Supreme Court’s Office of Attorney Regulation Counsel, 1300 Broadway, Suite 500, Denver, CO 80203. His email address is: [email protected] and telephone number is 303-928-7858.
10. Jacob Zimmerman is a resident of the State of Minnesota. His business address is: 800 LaSalle Ave., #2800, Minneapolis, MN 55402, tel: 612-349-8500. His email address is: [email protected].
11 . Mark Bankston is a resident of Texas. His business address is c/o Kaster Lynch Farrar & Ball, LLP, 1117 Herkimer, Houston, TX 77008, tel: 713-221-8300. His email address is: [email protected].
Pl, Westminster, CO 80031 , tel: (303) 469-4676.
12. Leonard Pozner’s address is unknown. Upon information and belief he lives in Florida. One of his numerous email addresses is: lenpoz.com.
13. Doug Maguire works at the direction of Leonard Pozner. Maguire’s last-known address was 10061 Riverside Dr., North Hollywood, CA 91602.
14. Elizabeth Williamson is a reporter for the New York Times and author of a book entitled Sandy Hook: An American Tragedy and the Battle for Truth (“Williamson’s book”). Her address is believed to be 4411 Connecticut Ave., NW, Apt. #311 , Washington, D.C. 20008.