DELAWARE VALLEY AESTHETICS, PLLC v. JOHN DOE 1
Complaint — Document #1
District Court, E.D. Pennsylvania
Description
COMPLAINT against JANE DOE 1, JOHN DOE 1 ( Filing fee $ 400 receipt number PPE210341.), filed by KATHY RUMER, DO, FACOS, DELAWARE VALLEY AESTHETICS, PLLC.(bw, ) (Entered: 01/28/2020)
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I Document 1 Filed 01/23/20 Page 1 of 11
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JS44 (Rev. 02119) CIVIL COVER SHEET
The JS 44 civil cover sheet and the infonnation contained herein neither replace nor supplement the filing and service of pleadin&s or other papers as required by law, except as
provided by local rules of court. This fonn, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
'
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXI' PAGE OF Tf!JSFORM.)
l. (a) PLAINTIFFS DEFENDANTS
Delaware Valley Aesthetics, PLLC d/b/a Rumer Cosmetic Stt gery and John Doe 1 and Jane Doe 1
Kathy Rumer, DO FACOS ~
(b) County of Residence ofFirst Listed Plainti Mont ornery I Counly of Residence of First Listed Defendant _U_n_k_n_o_w_n_ _ _ _ _ __
(EXCEPT IN US. PU/ /FK CASES) (IN US. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE' LOCATION OF
THE TRACT OF LAND INVOLVED.
I
(c) Attorneys (Firm Name, Addr=. and Ttlepl,a,,~nibu) Attorneys (If Kno11m)
Rogers Castor, 26 E. Athens Avenue, Ardmore PA 19003
610-649-1880
II. BASIS OF JURISDICTION (Placcan "X"ln.OneBo.cOnly) III. CITIZENSHIP OF PRINCIPAL PARTIES (Ptacoan "X" ;,, O11e Bo:,far Plaintiff'
(For Divtnity Cases Only) and One Box for Defe,1dant)
0 I U.S. Government 0 l Federal Question PTF DEF PTF DEF
Plaintiff (US. Gover11me111 Not a Party) Cilizcn ofThis State fl/. I O Incorporated or rrincipal rlacc O 4 0 4
ofBusinc,s fn This St:itc
0 2 U.S. Government Diversity Citizc•n or Another Slate 0 2 ~ 2 lncorpomtcd and rnncipal Place 0 s 0 S
Defendant (htdir:ate Citi:e.111/,;p of P(lrtifr in Item· 111). of Business In Another Sl:ltc
Citizen or Subjc<:I ofa 0 3 0 l Foreign Nation 0 6 06
Forci1•n Countrv
IV NATURE OF SUIT (Place a,1 "X" in One Box 011/y) r . Code D escnnt10ns.
C 1ek 1ere or: Nature o fS Utt
t >'·.'··· ·: ·. CONTRACT ·:;,.: ·'····•,·:• , ; ;.;•., .•', .. !TORTS '•: "!.'.· ._, _.. .·.•- •, ·. FORFEITURE/PENALTY . ·: ·BANKRUPTCY>,..., .• ".. ; OTHER STATUTES . "».'. I
0 110.Insurance
0 120 Marine
-•
0 140
' " Negotiable
""~ " ' Instrument t PERSONAL 11'/JURY
~0Airplanc
5 Airplane rroduct
150 Recovery ofOvcrpaym I O' 321 I~~:~~; Libel &
& Enforeemcnt ofJu<lg cnt
0 IS l Medicare Act
Liability
0 JJI ·Fcdcrol Employers'
PERSONAL INJHRY
0 365 Personal Injury •
Product Liability
o 367 Health Care/
Pha.nnat:cudcal
rcrsonal Injury
Product Liability
0 625 Drug Related Seizure
0 820 Copyrights
o g3o·P:11cn1
ofl'ropcrty21 USC881
0 690 0th« Jn9(a))
o 422 Appeal 28 use t58
0 375 False Claims Act
o 376 Qui Tam (J t use
0 423 Withdmwal
28 USC 157
0 400 State Rcapporticmmonl
"·' ·pRoPERTY·RIGI• " ·., ;, ... 0 410 Antitrust
0 430 B•nks and Banking
0 450 Commerce
0 I52 R«ovcry of Dcfaullcq Liability 0 368 Asbestos Pcrsomil 0 835 Patent- Abbrcvio1cd 0 460 Dcporialion
Student Loans I 0 iiOMarinc Injury Product New Drug Application 0 470 Rackclccr Influenced and
(Excludes Vctcr.,.ns) 345 Marine Product Liability 0 840 Trademark Conupt Organiz>tions
0 153 Rccovcry of Ovcrpaym1'til.,.. Liability ;__ ·•'··• ,LAO R· -, .: ·,·"• . - -,~ ... IAL~•- ·•1KJTY " ; '· -~•·: a 480 Consumer Credit
PERSONAL PROPERTY
of Veter.m's Benefits 0 350 Motor Vehicle 0 370 Other Fraud
0 710 Fair Labor Standards 0 861 HIA(IJ95fl) • 485 Telephone Consumer
0 160 Stockholders' Suits 0 355 Motor Vehicle 0 371 Truth in Lcnd.ing
Acl 0 862 Black lung (923) .I>rotc:ction Acl
0 190 Other Contract Product Liability 0 380 Otficr Personal
0 720 labor/Managcmc11t 0 863 DIWCIDIWW (405(g)) 0 490 Cable/Sal TV
0 195 Contract Product Liability 0 360 Other Personal Property Damage
Rclntions 0 864 SS!D Tille XVI 0 8S0 Sccuritics/Commodiiicsl
0 196 Franchise Injury 0 38S Property Damage
0 740. R.1ilw")' labor Act 0 865 RSI (405(g)) Exchange-
0 l62 Personal Injury- Producl liability
0 7Sl Family and Medical 0 890 Other Statulory Actions
Medical Mnlot:1t:ti<:<: Lc.ivcAcl 0 891 Agricultural Acr,
I ·REAL PROPERTY . • ? • ~ ~-
'CIVIL'RIGHTS ' . : . PRISONER PETITIONS : 0 790 Other Labor Litigation ..
FEDERAL·TAX SUITS . 0 893 Environmenl31 Manon
0 210 Land Condcmnntion 0 440 OJhcr Civil Rights Habeas Corpus: 0 791 Employee Relircmcnt 0 870 Ta.xes-(U.S. Plaintiff 0 895 Freedom of lnfonnation
0 220 Foreclosute 0 4.41 Voling 0 463 Alien Detainee Income-Security Act or Defendant) Acf
0 230 Rent Lease·& Ejcctmcnt 0 442 Employment • Sl0 Molions to Vacate 0 871 IRS-Thin! Party 0 896 Arbitmtion
0 140 TMS to Land 0 443 Housing/ Sentence 26 USC 7609 0 .899 Administrative Procedure
O 245 Tort Product Liability Accommodations 0 530 General AcilRcview or Appeal of
0 290 All Other Rcnl Property 0 445 Amor, w/Disabiliti_cs.- 0 SJ5 D02th Penalty '-·· • .. ·. IMMIGRATION,. Agency Decision
Employment Other: a 462 Naturaliu1ion Application 0 950 Cons1in.11ionality of
0 446 Amer.-w/Dis.ibilirics .. 0 540 Mandamus & Other 0 465 Other lmmigrauon State Statutes
Othcr 0 5S0 Civil Rights Actions
0 448 Education O 555 Prison Condition
0 S60 Civil Detainee -
(\ Condidons of
Confinement
V. ~RIGIN (Placoan "X"i11011eBo.t011ly/
~ l ~riginal O 2 Removed from 0 ; Remanded from 04 Reinstated or 0 5 Transferred from 0 6 Multidistrict 0 8. Multidistrict
F ocecding State Court Appellate Court Reopened Another District Litigation- Litigation -
'S
(specify) Transfer Direct File
Cite the U.S. Civil Slam1e under which you are filing (Do 1101 citejttri,diclianal statttlts 1111ks• div,nity):
28 u.s.c. 1322
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AUSE OF ACTION Brief description of cause:
slander
VII. REQUESTED IN 0 CHECK IF THIS IS A CLASS ACT(ON DEMANDS CHECK YES only if d"t_nded in complaint
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND, M Yes •
u
No
VIII. RELATED CASE(S)
(St!e instn1C1io11s):
IF ANY JUDGE DOCKET NUMBER
DATE -~ TURE OF ATTO~Y OF RECORD
01/21/2020
FOR OFFICE USE ONLY
--- ... -r-A. ... .,,, __ A
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-
JAN 23 -?n?
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RECEIPT# AMOUNT APPL YING IFP JUDGE MAG.JUDGE
Case 2:20-cv-00456-CFK
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Document 1 Filed 01/23/20 Page 2 of 11
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;ri UNITED STATES DISTRICT COURT
F ' THE EASTERN DISTRICT OF PENNSYLVANIA
DESIGNATION FORM
· ·•(to be used by counsel or prose plaintiff to indicate the catego1y of the case for the pwpose ofassignment to the appropriate ea/endar)
45 •
Address of Plaintiff: _105Ardmore Avenue, Ardmore PA 19003
Address of Defendant: _ _ _Unknown_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Place of Accident, Incident or Transaction:
...- - - -Pennsylvania- - - - - - - - - - - - - - - - - - - - - - -- - - -
RELATED CASE, TFANY:
Case Number: _ _ _ _ _ _ _ _ _ _ _ __ Judge: _ _ _ _ __ _ _ _ _ _ _ _ __ Date Tenninated:
Civil cases are deemed related when Yes is answered to any of the following questions:
1. ls this case related to property included in an earlier numbered suit pending or within one year
previously terminated action in this court?
YesD No •
2. Does this case involve the same issue of fact or grow out of the same transaction as a prior suit
pending or within one year previously terminated action in this court?
Yes • No •
3. Does this case involve the validity or infringement of a patent already in suit or any earlier
numbered case pending or within one year previously ten inated action of this court?
YesD No •
4. ls this case a second or successive·habeas corpus, so
case filed by the same individual?
YesD No •
l certify that, to my knowledge, the within case is not related to any case now pending or within one year previously terminated action in
this court except as noted above.
DATE: _January 23, 2020_ _ _ _ __ _87546/324891 _ _ _ _ __
Allomey -at-Law I Pro Se Plaintiff Attorney lD. # (if applicable)
CIVIL: (Place a ✓ in one category only)
A. Federal Question Cases: B. Diversity J11risdictio11 Cases:
•• I.
2.
Indemnity Contract, Marine Contract, and All Other Contracts
FELA
Insurance Contract and Other Contracts
Airplane Personal Injury
•• 4. 3. Jones Act-Personal Injury
Antitrust
Assault, Defamation
Marine Personal Injury
B 6. 5. Patent
Labor-Management Relations
Motor Vehicle Personal Injury
Other Personal Injury (Please specify): _ _ _ _ _ _ __ _
• 7. Civil Rights 7. Products Liability
• 9. 8. Habeas Corpus 8. Products Liability - Asbestos
B Securities Act( s) Cases
10. Social Security Review Cases
9. All other Diversity Cases
(Please specify); _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _
• 11. All other Federal Question Cases
(Please specify): _ _ _ _ _ __ __ _ _ _ _ _ _ __
ARBITRATION CERTIFICATION
(Fire effect of this certification is to remove the case from eligibility for arbitration.)
n Newman._ __ _ _ _ _ __ _ __ , counsel of record or prose plaintiff, do hereby certify:
Pursuant to Local Civil Rule 53.2, § 3(o) (2), that to the best ofmy knowledge and belief, the damages recoverable in this civil action case
exceed the sum of $150,000.00 exclusive of interest and costs:
Relief other than monetary damages is sought.. JAN 23 020
: _January 23, 2020_ _ _ _ __ _ _87546/324891 _ _ _ _ _ __
Allorney-at-law I Pro Se Plaintiff Allorney ID. # (if applicable)
NOTE: A trial de novo will be a trial by jury only if there has been compliance with F.R.C.P. .38.
c;•. 609 (J/2 0/8/
Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 3 of 11
f'
_... IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
DELAWARE VALLEY AESTHETICS ,
PLLC d/b/a RUMER COSMETIC
SURGERY
105 Ardmore A venue CIVIL ACTION
Ardmore, PA 19003
and
KA THY RUMER, DO, FACOS
105 Ardmore A venue
Ardmore, PA 19003
Plaintiffs
V.
JOHN DOE 1
Unknown Name
Unknown Address
First Defendant
and JURY TRIAL DEMANDED
JANE DOE 1
Unknown Name
Unknown Address
Second Defendant
CIVIL ACTION COMPLAINT
Plaintiffs, Delaware Valley Aesthetics, PLLC, d/b/a Rumer Cosmetic Surgery,
and Kathy Rumer, DO, F AOOS , by and through their counsel, ROGERS CASTOR, hereby
brings this action at law and respectfully aver the following facts :
I. THE PARTIES
1. First Plaintiff, Delaware Valley Aesthetics, PLLC, is a professional
limited liability company, organized and existing under the laws of the Commonwealth of
Pennsylvania, with a registered place of business at 105 Ardmore Avenue, Ardmore,
Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 4 of 11
Montgomery County, Pennsylvania. Delaware Valley Aesthetics, PLLC, is known to the public
and conducts business under the registered fictitious name Rumer Cosmetic Surgery (First
Plaintiff will hereinafter be referred to as "Rumer Cosmetics").
2. Second Plaintiff, Kathy Rumer, DO, F ACOS (hereinafter "Dr. Rumer") is
an adult individual maintaining a principal place of business at 105 Ardmore Avenue, Ardmore,
Montgomery County, Pennsylvania. Kathy Rumer is a Doctor of Osteopathic Medicine ("DO")
and Fellow of the American College of Osteopathic Surgeons ("FACOS"). Dr. Rumer practices
medicine at Rumer Cosmetics.
3. First Defendant, John Doe 1, is believed to be an adult individual, the
identity and address of whom is unknown at this time . Plaintiffs intend to determine John Doe
l's identity and address through further discovery and will amend this Complaint accordingly
upon receiving said information.
4. Second Defendant, Jane Doe 1, is believed to be an adult individual, the
identity and address of whom is unknown at this time . Plaintiffs intend to determine Jane Doe
l's identity and address through further discovery and will amend this Complaint accordingly
upon receiving said information.
II. JURISDICTION
5. Jurisdiction is founded upon diversity of citizenship of the parties and the
amount in controversy pursuant to 28 U.S.C. § 1322, in that Plaintiffs are citizens and residents
of the Commonwealth of Pennsylvania, and Defendants are believed, and therefore averred, to be
citizens of a state other than Pennsylvania; and the amount in controversy exceeds $75 ,000.00 .
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Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 5 of 11
III. FACTS
6. Rumer Cosmetics, through Dr. Rumer, offers a host of cosmetic surgeries
to potential patients, the majority of which focus on altering the body, such as nose surgery,
breast implants, injectable fillers/Botox, hair restoration, etc.
7. Of the services offered by Rumer Cosmetics, Dr. Rumer is most renowned
as a leading aesthetic and reconstructive plastic surgeon specializing in gender reassignment
surgery. This includes both male to female surgeries (of which Dr. Rumer performs 200-250
every year) and female to male surgeries (of which Dr. Rumer performs more than 150 every
year).
8. Patients travel from all across the United States to receive gender
reassignment surgery at Rumer Cosmetics because of Dr. Rumer's stellar track record and
reputation for excellence.
9. Rumer Cosmetics derives a bulk of its annual income from said gender
reassignment surgeries, and the success of its business can be attributed to the reputation of Dr.
Rumer in both the medical and lay-person communities.
10. In or around 2019, Dr. Rumer discovered a website known as "Kathy
Rumer's Anonymous" a blog dedicated to "Chasing the #ButcherofArdmore." The URL of said
website is: rumersanonymous.blogspot.com (hereinafter the "Website").
11. The Website is maintained and edited by John Doe 1 and/or Jane Doe 1
with the goal of tarnishing Dr. Rumer and Rumer Cosmetic's reputation in the medical
community as well as her reputation amongst potential clients.
12. John Doe 1 and/or Jane Doe 1, have updated the Website making claims
such as, inter alia :
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Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 6 of 11
(a) That a quote in an advertisement for Dr. Rumer's service was not
real. John Doe 1 and/or Jane Doe 1 attributed said quote to a fake client, thus implying
Dr. Rumer I Rumer Cosmetics lied in an advertisement.
(b) Claiming that Dr. Rumer stormed out of a surgery room
demanding her staff to "deal with it" because her patient was having an anxiety attack.
(c) Claiming that Dr. Rumer instructed a patient to cut off a portion of
her own labia with scissors.
(d) Labeling Dr. Rumer the Butcher of Ardmore, thereby implying she
repeatedly fails surgeries and "butchers" clients.
(e) Posting Dr. Rumer's home address, when she does not disclose
such information to her patients.
(f) Labeling surgeries as "botched" without supporting facts .
(g) Many other claims that are made with either knowledge of their
falsity and/or recklessness as to their veracity with the intention of injuring Plaintiffs'
reputation.
13 . In addition to the above, John Doe 1 and/or Jane Doe 1 have sent
threatening emails to Dr. Rumer and Rumer Cosmetics. For example, on January 5, 2020, Dr.
Rumer received an email from "rualooker555@gmail.com" that provided as follows:
Please allow me to introduce myself, I am the bringer of bad news and taste.
The trans community is about to have its own #metoo movement. I'm the one who
has been running the Rumer's Anonymous blog. Do you like it? I know you read
it, I know you scan reddit for the horror stories people post about you. I know you
are slowly going insane from watching your reputation slowly on the decline. Do
you know how many submissions I get from people that you hurt? It's all going to
come to light soon enough.
Enjoy the inevitable.
4
Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 7 of 11
Pleased to meet you, I hope you try to guess my name.
This is one of many threats, often referencing The Rolling Stones' lyrics, made by John Doe 1
and/or Jane Doe 1 to tarnish Plaintiffs' reputations.
14. It is believed, and therefore averred, that the Website is hosted at IP
Address 162.158.63.49. From said IP Address, it appears the Website is maintained by the
Internet Service Provider CloudFlare, Inc.
15. Based on the present state of the Website, and the repeated threats made
by John Doe 1 and/or Jane Doe 1, the injury to Plaintiffs' reputation will continue until the
Website's creator is held accountable in a Court of Law.
COUNT I
Libel Per Se
Plaintiffs v. John Doe 1 and/or Jane Doe 1
16. Plaintiffs incorporate paragraphs "1" through "15" by reference as though
the same were set forth herein in extenso.
17. The statements posted by John Doe 1 and/or Jane Doe 1 on the Website,
as more fully described in Paragraph 11 above herein, disparages Plaintiffs' competence and
integrity in its trade and business, thus constitution libel per se.
18. The libelous statements were authored and posted online by John Doe 1
and/or Jane Doe 1.
19. The Website is accessible to anyone with internet access. John Doe 1
and/or Jane Doe 1 has gone out of his/her way to promote the website by posting links to it on
other social media websites such as Reddit.com. This conduct made the libelous statements
contained on the Website highly visible.
5
Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 8 of 11
20. John Doe 1 and/or Jane Doe l's defamatory blog was readily understood
by its readers to be about Plaintiffs, and as a direct result thereof, Plaintiffs have suffered a
permanent false taint and substantial professional harm to their business reputations.
WHEREFORE, Plaintiffs demand judgment against John Doe 1 and/or Jane doe 1 (the
identity of which will be determined through further discovery), individually and/or jointly and
severally, in an amount in excess of $75,000.00, together with all applicable interest, costs, and
fees, as well as any other available relief.
COUNT II
Commercial Disparagement
Plaintiffs v. John Doe 1 and/or Jane Doe 1
21. Plaintiffs incorporate paragraphs "l" through "20" by reference as though
the same were set forth herein in extenso.
22 . Dr. Rumer and the staff of Rumer Cosmetics have been approached by
existing and/or prospective customers who have seen the defamatory statements posted on the
Website by John Doe 1 and/or Jane Doe 1. Said customers commented and/or question Dr.
Rumer and Rumer Cosmetics' staff about the statements.
23. Internet post, such as the Website blog published by John Doe 1 and/or
Jane 2, are permanently archived on the Website' s host served, and can still be accessed even if
removed or deleted.
24. Additionally, a "screenshot" and/or other permanent replications of the
Website can be easily created and readily available to anyone reading the Website, which is still
online as of the filing of this Complaint.
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Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 9 of 11
25. Plaintiffs have suffered financial loss as a direct result of the damage to
their business reputation resulting from the defamatory online statements published by John Doe
1 and/or Jane Doe 1.
WHEREFORE, Plaintiffs demand judgment against John Doe 1 and/or Jane doe 1 (the
identity of which will be determined through further discovery), individually and/or jointly and
severally, in an amount in excess of $75,000.00, together with all applicable interest, costs, and
fees, as well as any other available relief.
COUNT III
Intentional Interference with Business Relationships
Plaintiffs v. John Doe 1 and/or Jane Doe 1
26 . Plaintiffs incorporate paragraphs "l" through "25" by reference as though
the same were set forth herein in extenso.
27 . The conduct described in Paragraphs 11 and 12 above herein constitutes a
concerted effort by John Doe 1 and/or Jane Doe 1 to interfere with Plaintiffs' existing and
prospective business relationships. In fact, interfering with said relationships is John Doe 1
and/or Jane Doe l's stated intentions in creating the Website.
28. John Doe 1 and/or Jane Doe l's conduct as described herein was wrongful
and without justification or privilege.
29. John Doe 1 and/or Jane Doe l's conduct as described herein was
intentional and was deliberately designed to cause harm to Plaintiffs.
30. Plaintiffs have suffered, and will continue to suffer, financial loss as a
direct result of John Doe 1 and/or Jane Doe l's wrongful interference with Plaintiffs' existing
and/or prospective business relationships.
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Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 10 of 11
WHEREFORE, Plaintiffs demand judgment against John Doe 1 and/or Jane doe 1 (the
identity of which will be determined through further discovery), individually and/or jointly and
severally, in an amount in excess of $75,000.00, together with all applicable interest, costs, and
fees, as well as any other available relief.
COUNT IV
Invasion of Privacy: Public Disclosure of Private Fact
Dr. Rumer v. John Doe 1 and/or Jane Doe 1
31. Plaintiffs incorporate paragraphs "1" through "30" by reference as though
the same were set forth herein in extenso.
32. As stated above, John Doe 1 and/or Jane Doe 1 published Dr. Rumer's
personal address and financial information on the Website.
33. The information on the Website was accessible, and still is accessible, to
anyone with internet access.
34. Information regarding Dr. Rumer's personal address and finances is
private and never disclosed to the average patient.
35. John Doe 1 and/or Jane Doe 1's publicity of Dr. Rumer's personal address
and financial information is highly offensive to a reasonable person, and further is highly offense
to Dr. Rumer.
36. Dr. Rumer's personal address and financial information is not a matter of
legitimate concern to the public and evidences John Doe 1 and/or Jane Doe 1's ongoing motive
to repeatedly harass, discredit, smear, tarnish the reputation of, and annoy Dr. Rumer.
37. John Doe 1 and/or Jane Doe 1's repeated, continual, and substantial
publicity of Dr. Rumer's private information was outrageous, willful, malicious, and
intentionally designed to and actually did cause economic and professional harm to Dr. Rumer.
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Case 2:20-cv-00456-CFK Document 1 Filed 01/23/20 Page 11 of 11
38. Dr. Rumer suffered substantial monetaiy and non-economic harm from the
Website's publication.
39. John Doe 1 and/or Jane Doe 1's conduct was reckless and/or intentional
and/or wanton and/or outrageous and he/she is, therefore, liable to Dr. Rumer for punitive
damages.
WHEREFORE, Plaintiffs demand judgment against John Doe 1 and/or Jane doe 1 (the
identity of which will be determined through further discovery), individually and/or jointly and
severally, in an amount in excess of $75,000.00, together with all applicable interest, costs, and
fees, as well as any other available relief.
Respectfully submitted,
ROGERS CASTOR
Dated: 1/23/2020
/C~-~
B: V
_ ~--
Lance Rogers, Esq.
Brian T. Newman, Esq.
ROGERS CASTOR
Attorney I.D. No. 87,546 / 324,891
26 East Athens A venue
Ardmore, PA 19003
610-649-1880 / 877-649-1880 (fiL'I'.)
Attorneys for Plaintiffs
9