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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF WESTCHESTER
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Date Purchased:
LESLY ZAMOR,
Plaintiff designates

Plaintiff, WESTCHESTER
COUNTY
v. as the place of trial.

"BUTCH"
STEVEN THOMAS, SUMMONS

Defendant. The basis of venue is

Plaintiff's residence
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TO THE ABOVE NAMED DEFENDANT(S):

YOU ARE HEREBY SUMMONED to answer the complaint in this action and
to serve a copy of your answer, or, if the complaint is not served with this summons, to
serve a notice of appearance, on Plaintiff's Attorney with 20 days after the service of this

summons, exclusive of the day of service (or within 30 days after service is complete is
this summons is not personally delivered to you within the State of New York); and in case
of your failure to appear or answer, judgment will be taken against you by default for the
relief demanded in the complaint.

Defendant's name(s) and address(es): GREENBERG FREEMAN LLP

"BUTCH"
STEVEN THOMAS By: /s/ Michael A. Freeman

302 South 1st Avenue Michael A. Freeman

59th 22nd
Mount NY 10550 110 East Street, FlOOr
Vernon,
New York, New York 10022

(212) 838-3121
Attorneys for Plaintiff

Notice: The nature of this action is for defamation and libel per se. The relief sought is

compensatory, punitive and special damages in an amount to be determined at trial but in

no event less than $1,000,000 plus interest.

UPON YOUR FAILURE TO APPEAR, JUDGMENT WILL BE TAKEN

AGAINST YOU BY DEFAULT FOR THE DECLARATORY RELIEF AND THE SUM
DEMANDED IN THE COMPLAINT, WHICH IS NOT LESS THAN $2,000,000 PLUS
INTEREST AND THE COSTS AND DISBURSEMENTS OF THIS ACTION.

Dated: New York, New York

June 29, 2018

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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF WESTCHESTER
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LESLY ZAMOR,

Plaintiff, Index No.

-against-

COMPLAINT
"BUTCH"
STEVEN THOMAS,

Defendant.

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("Plaintiff"
Plaintiff Lesly Zamor or "Zamor"), by his undersigned attorneys, for his

"Butch" (" Defendant"

complaint in this action against defendant Steven Thomas ("Defendant"), alleges as

follows:

PRELIMINARY STATEMENT

1. Plaintiff has served as a trustee and president of the Mount Vernon City School

Board and as a commissioner on the Planning Board for the City of Mount Vernon.

2. Starting in 2017 (and within one year of the date of this complaint), Plaintiff was

the victim of an online smear campaign intended to defame him, damage his reputation in the

community, and undermine his leadership.

3. As detailed below, Plaintiff was the subject of a series of widely distributed,

malicious emails, published and distributed anonymously under the name "MV Citizens for a

Ed,"
Better Board of which falsely accused Plaintiff of fraud, corruption, stealing taxpayer funds,

and other unlawful and abusive actions.

4. Plaintiff subsequently hired an attorney and a private investigator to try to

determine who was responsible for publishing and distributing these anonymous defamatory

statements.

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5. Through these efforts, Plaintiff determined that Defendant, who is the brother of

the current mayor of the City of Mount Vernon, and prior to November 2017, was a candidate for

Mount Vernon City Council (in an election in which he ran against Plaintiff's wife), was

responsible for publishing and distributing the defamatory emails.

6. Plaintiff now brings this action for defamation and libel per se against Defendant

to recover compensatory, special and punitive damages against him.

THE PARTIES

7. Plaintiff resides at 112 Hutchinson Boulevard, Mount Vernon, New York.

8. Upon information and belief, Defendant is a resident of Mount Vernon, New York,

and has a business address at 302 South 1st Avenue, Mount Vernon, New York.

JURISDICTION AND VENUE

9. This Court has personal jurisdiction over Defendant pursuant to CPLR § 301

because he is a resident of the State of New York.

10. Venue is proper in Westchester County pursuant to CPLR 503(a) because Plaintiff

and Defendant reside in Westchester County.

FACTS

Plaintiff's Background As a Vocal Community Leader

11. Plaintiff is an entrepreneur and businessman, whose businesses include SEED

Design Solutions, an interior design firm that serves clients throughout Westchester County and

the New York tristate area.

12. For many years, Plaintiff has been a vocal advocate on issues pertaining to the

governance and funding of public schools in the City of Mount Vernon, New York.

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13. Since July 2015, Plaintiff has served as a member of the Mount Vernon School

Board, which included a period when he served as President of the Board.

14. Plaintiff has also served as a commissioner on the City of Mount Vernon Planning

Board since October 2011.

15. During his tenure in city government, Plaintiff has taken action that he believed to

be in the best interests of the residents of the City of Mount Vernon, but that, upon information

and belief, were unpopular with certain other officials in the city government.

16. For example, consistent with his advocacy in favor of schools receiving their fair

share of tax revenue from housing developments in the City of Mount Vernon, Plaintiff

spearheaded the Mount Vernon School Board's filing of a lawsuit against the City of Mount

Vernon in 2016 alleging that the Mayor and City Council acted unlawfully in failing to include

school officials in negotiations over tax deals given to housing developers that would lead to an

increase in the number of students without a corresponding increase in school funding, and leaving

existing homeowners to cover the shortfall.

17. In addition, Plaintiff strongly supported the Mount Vernon Board of Education's

decision to file an Article 78 petition against the City of Mount Vernon in June 2017, which sought

nullification of rezoning and revitalization plans for the downtown area of Mount Vernon.

The Anonymous Publication of False Statements About Plaintiff

18. In April 2017, Plaintiff announced his endorsement of various candidates for the

Mount Vernon School Board election to be held in May 2017.

19. The open positions on the School Board were contested, and the candidates that

Plaintiff was supporting were opposed by candidates who were being endorsed by other City of

Mount Vernon officials, including the Mayor of Mount Vernon, who is Defendant's brother, and

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who publicly opposed the lawsuits supported by Plaintiff and had vowed to change the makeup of

the School Board.

20. Defendant, who had already announced that he was running for a seat on the Mount

Vernon City Council in an election in which Plaintiff's wife was also running for a City Council

seat, had also stated his opposition to the School Board candidates that Plaintiff had endorsed.

21. In June 2017, Plaintiff discovered that an anonymous person or persons was

publishing false and defamatory statements about him over the internet through email and public

postings made on a Facebook page.

22. For example, on June 30, 2017, an anonymous person, acting under the name "MV

Ed"
Citizens for a Better Board of sent a widely distributed email from the email address

Zamor" Email"
mvschools@outlook.com entitled "No More (the "June 30 Email").

23. The June 30 email, which included a picture of Plaintiff, falsely states that Plaintiff

"lied" connections"
had to parents, funded his personal ambitions through "covert in neighboring

states, and alleges that changes that Plaintiff was advocating to achieve are part of a secret plot for

him to profit personally.

24. The relevant portion of the June 30 email states as follows:

No More Zamor

Dear Concerned Citizen,

Demagogues lie. They prey on fear. They harbor resentment and generalize discontent.

Lesly Zamor has lied. He preys on (parental) fears. He harbors resentment.

Resentment for the real Mount Vernon. He has allegedly funded his personal ambitions
with covert crony connections in neighboring states, presenting the success of the school
district as his own. He is apparently attempting to take credit for years of hard work by
former and current school board members ... so he can continue his ruthless pursuit for

profitable power.

Now he is taking aim at every single child in the City of Mount Vernon. The claim of
environment,"
"creating a whole new learning is a farce! "What's going on in the inside is

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important," -
also said Zamor's puppet Superintendent Ken Hamilton. Yes he is right.
What is going on inside the schools are important which is why we want you to know more
about Zamor.

Parents just shelled out thousands for graduations, vacations, summer camp... now Lesly
Zamor says pay me more attention by mandating all children to reenroll in the school
district! It is rumored that Zamor may be allegedly involved with a re-enrollment business

portending to falsify documents to help children fake their way into the schools. Is this his
dubious profitable scheme?

Vernon"
Because of Zamor's self-hate, now you have to prove your "Mount status and

possibly expose your child to endless questions about whether or not they are legal. Is
Zamor a secret Donald Trump supporter? Is this a backdoor to deportation that Zamor is
opening? Why is the bankrupt, deadbeat Lesly Zamor forcing everyone to open up their

wallets, submit their personal information to an unsecure school board office... to prove
that their child is legal? Is this part of an identity theft ring that Zamor may be part of?

Will the school board say no more to Lesly Zamor? We doubt it... but we know parents
are frustrated by Zamor's distractions from the real situation he faces. Will the new school
board trustees say no more Zamor? For our children's sake, we believe they must say NO!
to Lesly Zamor.

More to come.

(A copy of the June 30 Email is attached hereto as Exhibit 1 and incorporated by reference.)

come."
25. True to the author's word, there was "more to

26. On August 19, 2017, another anonymous email was distributed under the name

Ed"
"MV Citizens for a Better Board of via the email address mvschools@outlook.com and

Vernon." Email"
entitled "Zamor Sandbagged A Better Mount (the "August 19 Email").

27. The August 19 Email, which included a picture of Plaintiff, falsely states, among

group"
other things, that Plaintiff led a "corrupt intent on damaging the reputation of certain

officials and candidates for office as part of "a conspiracy to enrich himself at the taxpayer's

expense."

28. The relevant portion of the August 19 Email states as follows:

Zamor Sandbagged A Better Mount Vernon

Dear Concerned Citizen,

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Since Lesly Zamor lost his post as School Board President, he has grown desperate for
power. He lost his secret passage to enrich himself at the expense of our children. It is no
surprise that American Express motioned for summary judgment to collect over $80,000
from the deadbeat Zamor.

Following the removal of the slate of candidates for a Better Mount Vernon, Zamor is now

trying to make nice with all the people he attacked... it's obvious desperate people do
desperate things.

Zamor has led a small, angry, corrupt group to mire and maim the reputation of certain
officials and candidates for office as part of a conspiracy to enrich himself at the taxpayer's
expense (again). His thirst for power knows no limit.

Zamor's poorly written open letter in the Mount Vernon Inquirer shows that he is not a
serious thinker. He is a serial schemer. Don't be fooled by Zamor's latest attempt to distract
from his own demons of debt. He will try to get your support, be careful believing in a
known liar. He deceived and sandbagged the slate - them from the September
removing
ballot - and sack you next!
may

Stay tuned to know more on Zamor.

(A copy of the August 19 Email is attached hereto as Exhibit 2 and incorporated by reference.) ~

29. On September 22, 2017, another anonymous email, also published under the name

Ed"
"MV Citizens for a Better Board of was distributed to the public via the email address

mvschools@outlook.com and entitled "Zamor Promised to Fight Pastor in Parking Lot! Zamor

Resign!" Email"
Must (the "September 22 Email").

30. The September 22 Email, which included a picture of Plaintiff, falsely states,

among other things, that Plaintiff was engaged in self-dealing.

31. The relevant portion of the September 29 Email states as follows:

Zamor Promised to Fight Pastor in Parking Lot! Zamor Must Resign!

Dear Concerned Citizen,

The public trusted Lesly Zamor to watch the money said a pastor... however, more and
more sources are saying Zamor was doing more than just watching
it.

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At the past few Board of Education meetings, Zamor's patriotic rhetoric boiled over into

threats, tirades, and when confronted about possible corruption... Zamor followed with a
promise to fight a pastor in the parking lot.

Zamor's daydreams of power received a wake up call when the board this week terminated
his hand-picked architect for reasons allegedly including corruption, negligence, fraud and
abuse. The cult of followers Zamor indoctrinated are now starting to question his motives
and desperate attempts to block the board from the architect. Instead of saving the school
district money, the architect under Zamor's influence served himself by building a
$180,000 secret room at an unknown location in the school district.

Sources at the school board meeting said it was their belief the architect was wrong on
much of his calculations, leading to cost overruns, wasting millions in school tax dollars
unnecessarily. Sources fear that this was part of a broader scheme of self-dealing involving
Zamor. If true, this explains why Zamor was unhinged, threatening the clergy... calling
"terrorists"
them and blaming them for school district woes. Could this be a ploy to cover
his tracks? . . .

(A copy of the September 22 Email is attached hereto as Exhibit 3 and incorporated by reference.)

32. On September 29, 2017, another anonymous email, also published under the name

Ed"
"MV Citizens for a Better Board of was publicly distributed via the email address

District"
mvschools@outlook.com and entitled "Zamor: Lavish Lie$ Lead Investigators to School

Email"
(the "September 29 Email").

33. The September 29 Email, which included a picture of Plaintiff, falsely states,

lies,"
among other things, that Plaintiff told "lavish engaged in abusive behavior, stole taxpayer

money, and that Plaintiff had threatened to fight a local pastor in the parking lot following a School

Board meeting.

34. The relevant portion of the September 29 Email states as follows:

Zamor: Lavish Lie$ Lead Investigators to School District

Dear Concerned Citizen,

Inside sources say Lesly Zamor and his canned architect left behind a trail of lavish lies.
First it was the $180,000 secret room that still remains to be revealed... then it was the
promise to fight a pastor in the parking lot... and now questions are surfacing about

extraordinary amounts of tax dollars blown overbudget on fine materials for auditoriums

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"curb-appeal."
and Meanwhile bathrooms in school buildings are shut and children are

sharing sports equipment and barely have books.

All this has led investigators to ask high level School District Officials about the
extravagant wasteful spending, anonymous sources say out of fear of retribution by Zamor.

Zamor's abusive behavior is catching up with him. Bullies do not belong in our schools or
on the School Board. Zamor must go. Zamor is trouble and his American Express judgment
shows his lying nature.

With the architect gone, we will learn about the lavish lies of Lesly Zamor.

Stay tuned to know more about Zamor...

e(A copy of the September 29 Email is attached hereto as Exhibit 4 and incorporated by

reference.)1 .

35. On October 1, 2017, another anonymous email, also published under the name "MV

Ed"
Citizens for a Better Board of was distributed to the public via the email address

Judgment"
mvschools@outlook.com and entitled "Lavish Life $tyle Sinks New Vision with Amex

Email"
(the "October 1 Email").

36. The October 1 Email, which included a picture of Plaintiff, falsely states, among

children," children"
other things, that Plaintiff had been "accused of stealing from [ ] "attacking [ ]

[Plaintiff]."
and that there are "corruption questions swirling around

37. The relevant portion of the October 1 Email states as follows:

Lavish Life $tyle Sinks New Vision with Amex Judgment

Concerned Citizen,

. . . . With all the clergy confrontation and corruption questions swirling around Zamor,
Party"
maybe the real identity of this "New Vision is the New Villain Party?

We know that Zamor's canned architect left behind a trail of lavish lies. First it was the
$180,000 secret room that still remains to be revealed... then it was the promise to fight a
pastor in the parking lot... and now questions are surfacing about extraordinary amounts of
"curb-appeal."
tax dollars blown over-budget on fine materials for auditoriums and
Meanwhile bathrooms in school buildings are shut and children are sharing sports
equipment and barely have books.

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Out of fear of retribution by Zamor, anonymous sources confirmed that investigators asked
high level School District Officials about the extravagant wasteful spending under Zamor's
presidency. Just how much has Zamor spent without full board knowledge? How much
did Zamor zap our tax payers for without approval? Is this the New Vision? Or is it the era
of the New Villain?

We will dive into this costly question in our next fact-laced note.

For now, Zamor's abusive behavior is catching up with him. Bullies do not belong in our
schools or on the School Board. Zamor must go! Zamor is trouble and his American
Express judgment shows his lying nature.

(A copy of the October 1 Email is attached hereto as Exhibit 5 and incorporated herein by

reference.)

38. On November 2, 2017, another anonymous email, published under the name "MV

Ed"
Citizens for a Better Board of was publicly distributed via the email address

Zamor?"
mvschools@outlook.com and entitled "Did Hamilton cut a dirty deal with (the

Email"
"November 2 Email").

39. The November 2 Email, which included a picture of Plaintiff, falsely states, among

removal"
other things, that Plaintiff "targeted for good teachers did not obey his wishes and,

insinuated that he was responsible for misappropriating $2.4 million during his tenure as School

Board President.

40. The relevant portion of the November 2 Email states as follows:

Did Hamilton cut a dirty deal with Zamor?

Dear Concerned Citizen,

Sources say that the New Vision Party leader Lesly Zamor may have convinced Dr.
Kenneth Hamilton to cut a dirty deal to stay on-board as Mount Vernon's superintendent.

The news reports that Hamilton will stay on to finish the 2020 vision has many parents

asking what is going on, , [sic] especially at Lincoln School and Edward Williams.
Concerned parents fearing retribution by the district are anonymously questioning why
students are often allowed to be unattended, roaming the hallways during class time, and
good teachers that do not obey Zamor's demands are being targeted for removal. Other

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parents are incensed about the $180,000 room Zamor sanctioned, meanwhile there is little
to know [sic] money to fix sinks or hire more security monitors to keep children safe. . . .

Hamilton sat silent when presented with clear evidence that the board under Zamor's
tenure as president more than likely misappropriated $2,400,000 tax dollars. We know that
$180,000 went toward a secret room...

(A copy of the November 2 Email is attached hereto as Exhibit 6 and incorporated herein by

reference.)

41. On May 5, 2018, another anonymous email, also published under the name "MV

Ed"
Citizens for a Better Board of was distributed to the public via the email address

LIE$"
mvschools@outlook.com and entitled "MV SCHOOLS: VOTE AGAINST THEIR (the

Email"
"May 5 Email").

42. The May 5 Email, which included a picture of Plaintiff, falsely states, that Zamor

built a secret $200,000 office for himself at taxpayer expenses and that he has a "history of

thievery."

43. The relevant portion of the November 2 Email states as follows:

MV SCHOOLS: VOTE AGAINST THEIR LIE$

Dear Concerned Citizen,

"sizzle" "sensation"
Don't believe the hype. Since 2014 we were sold and by the zealot

Lesly Zamor.

vision" rise"
At first it was, "vote for a new ... "vote for the schools to ... spend $110
million ... don't question the details. Just do as Zamor screams:

Vote and don't ask about the $200,000 office room [Zamor] built for himself by his cronies.

Vote and don't ask about the contractors or subcontractors eating away at our pockets.

Vote and don't ask about what's really going on because the answers will only anger you.

Did you know that state auditors found that $13 million school tax dollars were misspent
under Zamor's reign?

Did you know that Zamor decided to hide $42 million school tax dollars that were written
off as a loss?

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Did you realize that each school led construction project is behind schedule and OVER
budget??!?!?

Why? Guess who benefits from delays and extra costs. Not our children nor our property
taxes - both get hurt.

Did you know that each expense carries a cost and taxpayers will pay a high cost for
Zamor's slimy schemes?

The latest crop of puppet candidates cannot be trusted to protect your wallet.

It is a SCAM! KD Wilson, Lorna Kirwan, and Meredith Rodriguez are the latest liars and
loud mouths for Zamor's plan to profit off the top.

They are coming to pick your pocket and continue to spin the web of lies for Lesly Zamor.

They will claim to care for the kids, shout loud and act tall... their platform is fake and sets
us up for a great fall.

Zoom in on Lesly Zamor and ask yourself why is he running away?

Zoom in on Lesly Zamor and ask yourself why his neighbors are not talking to him?

Zoom in on Lesly Zamor and ask yourself why numerous School Board Trustees and
staff are not dealing with him?

Zoom in on Zamor and see through the lie. See the history of thievery within his bankrupt
riddled past. See the pattern of the bragger boast about the grandiose... then follow the
trail of the misspent $13 million tax dollars right to his door. . . .

(A copy of the November 2 Email is attached hereto as Exhibit 7 and incorporated herein by

reference.)

44. Based on Plaintiff's own investigation of who had been receiving the false and

defamatory emails, it appeared that many of the email recipients had also signed up to receive

emails from the City of Vernon, which led Plaintiff to suspect that the person(s) behind the

anonymous online smear campaign had access to the City of Mount Vernon's official email list.

Plaintiff's Successful Efforts To Identify the Anonymous Author(s)

45. After these false and defamatory statements about Plaintiff began circulating

online, Plaintiff retained an investigator specializing in cyber-investigations to try to determine the

11

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identity of the person(s) responsible for publishing and distributing the false and defamatory

statements about Plaintiff.

46. With the assistance of an attorney, Plaintiff commenced a special proceeding to

take pre-action discovery, and subsequently served subpoenas executed by the court on Microsoft

Corporation, which administers email addresses with the <outlook.com> domain name, and The

Rocket Science Group LLC, d/b/a, MailChimp, which offers a service used to distribute group

emails, which was utilized to distribute one or more of the emails that defamed and contained false

statements about Plaintiff.

47. Through the subpoenas that were served, Plaintiff identified Defendant as the

person who had established and is financially responsible for the MailChimp account used to

distribute one or more of the defamatory emails.

48. Upon information and belief, Defendant is responsible for drafting, publishing and

distributing all defamatory and false statements about Plaintiff, either alone or in concert with

others who have yet to be identified.

AS AND FOR A FIRST CAUSE OF ACTION

(Defamation and Libel Per Se)

49. Plaintiff repeats and realleges each and every allegation contained in the foregoing

paragraphs of the complaint as if fully set forth herein.

50. On various dates on or after June 29, 2017, Defendant caused the June 30 Email,

the August 19 Email, the September 22 Email, the September 29 Email, the October 1 Email, the

Statements"
November 2 Email and the May 5 Email (collectively, the "Defamatory Statements") to be

delivered and published to members of the public, including residents and registered voters

residing in Mount Vernon, New York, as well as, upon information and belief, current and

potential clients and customers for Plaintiff's business.

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51. The Defamatory Statements contained false, untrue and misleading information

about Plaintiff, that disparaged Plaintiff's character and damaged his personal and business

reputation in the community.

52. The Defamatory Statements published and distributed by Defendant were false,

untrue, and misleading.

53. The Defamatory Statements published and distributed by Defendant were known

by Defendant to be false at the time they were published and distributed.

54. Defendant published and distributed the false statements contained in the

Defamatory Statements with the intent and expectation that the recipients of Defamatory

Statements would think negatively of Plaintiff and act upon on those statements by opposing

Plaintiff's agenda, by not supporting or voting for candidates endorsed by Plaintiff, and to cause

members of the community to avoid or terminate any business dealings that they had with Plaintiff.

55. Prior to Defendant's publication and distribution of the Defamatory Statements,

Plaintiff enjoyed a reputation for honesty, integrity, trustworthiness, dependability, and

competence.

56. Defendant's false statements about Plaintiff caused injury and harm to Plaintiff with

respect to his standing in the community.

57. Defendant's false statements about Plaintiff caused injury and harm to Plaintiff in

his trade, business and/or profession, and thereby constitute defamation and libel per se.

58. Defendant is liable to Plaintiff for compensatory damages in an amount to be

proven at trial, but not less than $1 million.

59. In addition, because Defendant knowingly, intentionally and maliciously caused

injury and harm to Plaintiff's personal and professional reputation, Defendant is also liable to

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Plaintiff for special and/or punitive damages in an amount to be proven at trial, but not less than

$1 million.

WHEREFORE, Plaintiff Lesly Zamor demands judgment against Defendant Steven

"Butch"
Thomas as follows:

a. On the first cause of action, awarding compensatory, special and punitive

damages against Defendant in an amount not less than $2 million;

b. The costs of suit and prejudgment interest; and

c. such other and further relief as the Court deems just and proper.

Dated: New York, New York

June 29, 2018

GREENBERG FREEMAN LLP

By: /s/ Michael A. Freeman

Michael A. Freeman
59th
110 East Street, 22nd Floor
New York, New York 10022

(212) 838-3121

Attorneys for Plaintiff

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