IN THE CIRCUIT COURT FOR KNOX COUNTY, TENNESSEE

CHRISTIAN SEUS, PRO SE )

)
Plaintiff )
) No. 1-410-18
v )
)
) Jury Trial Demanded
Knoxville Radical Alliance )
Knoxville Democratic Socialists of America )
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Downtown Wine & Spirits LLC )
Joseph R. Mee, AKA Joseph Cornelius Sutteree )
Caroline and Gary Rowcliffe, Joy Camacho (Photo C) )
DOE's A-E and 1-10 (attached photo description) )
Democratic Socialists of America Inc. )
Travis Donoho, Judy Ears (photo D) )
Derik Druns (photo E), Lucy L. (Photo A) )
National Lawyers Guild Inc. )
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East Tennessee Equality Council, Inc. )

COMPLAINT

1. Public debate on matters of importance is an essential element of a free and democratic society
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and lies at the heart of freedom of expression. Such debate often includes critical and even

offensive commentary, which is best met through engagement and well-reasoned discourse.

2. When the words and actions are used reach the level of genuinely threatening a person’s actual

reputation and safety from unjustified attacks, the law of defamation is available for recourse.

3. Defendants published or spoke mistruths such as “You're a Nazi,” “You kill people,” “You're a
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kidnapper,” “Die you piece of shit,” “You're a Nazi Puppet,” “Hunt them down and fuck them

up,” referring to the Plaintiff in a Nazi Poster, “You straight piece of shit.

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4. These defamatory statements are not along the lines of free speech or first amendment protected

activities.

5. The Defendants are closely affiliated with each other.

6. As a result of defamation, Plaintiff has endured threats, assault and battery, civil rights
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intimidation, great mental anguish, fear, and his reputation has been permanently damaged.

7. Plaintiff brings this case to force Defendants to answer for their malicious, repugnant and
reprehensible conduct.
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Jurisdiction

8. This Court has personal jurisdiction over the Defendants because the allegations were effected in
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Knox County and the majority of the Defendant's reside, have a business or are part of an

organization or group based in Knox County, Tennessee.

9. Plaintiff is requesting damages of $74,999.99 and nothing more.

Parties

10. At all times relevant herein, Plaintiff Pro Se, Christian Seus was a resident of Knox County,
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Tennessee, residing in Knoxville, Tennessee.

11. Defendant Mee, is an administrator of the Knoxville Antifa Facebook group. Defendant Mee

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 Can be served at his last know address of 6926 Duncans Glen Dr Knoxville TN 37919-8585.

12. Defendant Joy Camacho AKA Joy Elliot etc. is also an active member of the Knoxville Antifa

Group. She can be served at her last known address of 6200 Papermill Dr Knoxville, TN

37919-4029 with a previous know address as 4719 Reed Ln. Knoxville, TN 37920-4831

13. Defendant Knoxville Radical Alliance is a local fringe group in Knoxville, and their identity(s)

still needs to be discovered.

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14. Defendant Downtown Wine & Spirits LLC, Owner David J Ewan, is located at 407 S Gay St,

Knoxville, TN 37902 and is also the registered agent located at 411 S GAY ST. KNOXVILLE,

TN 37902 USA. Ewan also owns, Ewan CPA PLLC, and Baker Street Rentals, LLC.

15. Defendant Democratic Socialists of America - Knoxville, also known as KNOX DSA, is a
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local Chapter of the Democratic Socialists of America Inc. Democratic Socialists of America

Maria Svart is their National director and registered aget with an address of 75 Maiden Lane,

Suite 702 New York, NY 10038.

16. Defendant East Tennessee Equality Council, Inc. DBA Knox Pride's is a “nonprofit
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organization founded to provide and conduct educational, cultural, and informational programs

supporting the LGBTQ community throughout East Tennessee, including the annual Knox

Pride.” with a Registered Agent: JEN L GREEN 8321 BLOCK HOUSE WAY APT 613

KNOXVILLE, TN 37923-0923 USA

17. Defendant Gary Rowcliffe is a local protester with contact information

gary@BrandSpinsFoundation.org, 865 567-4619 and his lawyer can be served Bret Bryce 212

S. Peters Road Suite 101 Knoxville, TN 37923- 5217

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18. Defendant Caroline Rowcliffe is a local protester. Her lawyer can be served Bret Bryce 212 S.

Peters Road Suite 101 Knoxville, TN 37923- 5217

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19. Travis Donoho is the founder of the Democratic Socialists of America - Knoxville and can be

served at 8127 CORNELL LN KNOXVILLE, TN 37938

20. There are Doe defendants that have not been able to be named, but they are on photo (attached)

and video for a description of them.

STATEMENTS OF FACT

21. The Nazi horribly gassed, starved and murdered 6,000,000 Jews. There are also instances of
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hangings and other murders in the USA connected to the Nazi.

22. On or about February, 2018, Defendant Mee, Knoxville Radical Alliance, Downtown Wine &

Spirits LLC, Caroline and Gary Rowcliffe, Joy Camacho and other Defendants published a

Nazi Poster that included Plaintiff Seus.

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23. The Plaintiff has attached a sworn affidavit with numerous facts of proof that he is not a Nazi

nor has he ever been a Nazi or part of any groups aligned with Nazi.

24. There are many Defendants, but the Defendants all work together in Unison, all know each
other and are often in public/private together.
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25. Multiple Defendants are members of the group called Antifa. Antifa activities are reportedly

classified by the U.S. Department of Homeland Security as “domestic terrorist violence.” The

FBI has also blamed Antifa for violent attacks at public events. A Knoxville Antifa

Administrator published, “Don't just abolish ICE, but put every one of its officers to death.”

Defendants wish to abolish Immigration and Customs Enforcement.

26. Plaintiff is in support of the Immigration and Customs Enforcement and law enforcement.
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27. Defendants Mee, Knoxville Radical Alliance, Downtown Wine & Spirits LLC etc. wrongly

defamed Plaintiff by creating, and or publishing his name and photo on a poster that's largely

titled and bolded:“Knox Nazi Watch,” and includes “Identify White Supremacists groups and

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 leaders to keep your family, friends, neigbors[sic], and comrades safe from fascist violence.”

28. Defendant Downtown Wine & Spirits LLC Posted the Nazi poster on the inside of the business

on a window facing Gay Street, one of the busiest foot trafficked streets in Knoxville.

29. Defendant Downtown Wine & Spirits LLC recklessly and with actual malice published the

Poster.

30. In addition, Knoxville Radical Alliance used the hash tag #noNaziInKnox along with the Knox
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Nazi Watch poster.

31. The poster was displayed in many locations in Knoxville, Tn., street posts, as well as many

social media accounts, etc.

32. Defendant's Mee, Knoxville Radical Alliance, Downtown Wine & Spirits LLC, etc. had a
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reckless disregard of the plaintiff's rights by not contacting Plaintiff for facts, publishing,

libeling or slandering Plaintiff as being a Nazi – A completely outrageous and dangerous claim.

33. Plaintiff contacted Defendants with the truth regarding Plaintiff but the Defendants did not

retract the defaming and humiliating slander and defamation.

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34. Defendant published and/or republished the post without regard to the truth or falsity of the

statements it contained.

35. Defendant either knew the falsity of the statements the flier contained or acted in reckless

disregard for the truth.

36. Only Defendant Downtown Wine & Spirits LLC removed the poster from it's busy sidewalk in

downtown Knoxville.
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37. But they did not post a retraction or apology.

38. The Nazi poster and slander were published by the Defendants with a reckless disregard for the

truth.

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39. Each Defendant negligently failed to ascertain the truth of Plaintiff being a Nazi.

40. The Knox Nazi Watch poster was uploaded and seen by at least many thousands of people with

the actual larger amount to be determined in discovery.

41. Other comments included, “Nothing a Cricket bat or Hurly nugget to the head wouldn't fix.”

42. Other comments included, “The time for useless chanting is over” with a photo displaying a

NAZI member in a hood and hanging from a noose, and “Punch them all,” “I wished I wasn't
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swamped today because I've been looking forward to seeing Christian little troll ass.... I do have

bail money though.”

43. Defendant Mee published “Defend your community, hunt them down and fuck them up,”

referring to the Plaintiff in the Knox Nazi Watch poster.

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44. Defendant published the Nazi Poster with the language implying that Plaintiff is “complicit
wi[SIC] the murder of Heather Heyer in Charlottesville.”

45. Plaintiff contacted the Defendants to remove the defamation, but Defendants refused to do so.
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46. Defendant Caroline Rowcliff, shouted in a crowd multiple times, “You're a kidnapper.”

47. Defendant Joy Camacho AKA Alistair Elliott libeled defendant by stating, “Let's talk about that

woman you kidnapped down in Florida.”

48. Defendant Camacho stated this in front of Knox County Commissioner Evelyn Gill, and two

young women Plaintiff was speaking with.

49. Plaintiff has never kidnapped anyone.

50. Plaintiff has never attempted or tried to kidnap anyone.

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51. Plaintiff has never spoken the words that he would kidnap someone or agree to kidnap

someone.

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52. Defendant Gary Rowcliff, also follower of Defendant Knoxville Radical Alliance and other

Defendants, published, “Seus you're a fucking Nazi and you have been doxxed.” along with a

photograph of the Plaintiff.

53. Twitter account Whirled Peas AKA Gary Rowcliff published “This poster depicts local Nazi's”

and posted the “Knox Nazi Watch” poster along with that caption.

54. Defendant with the Twitter handle Whirled Peas “Here ya go. Dox these Nazi Scum” (posted
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with Knox Nazi Watch Poster)

55. During a Women's March event, Plaintiff walked among a large crowd of black bloc protesters

with no problems, until a Defendant National Lawyers Guild Inc. legal observers defamed

Plaintiff and the group became violent towards Plaintiff.

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56. Black Bloc is a group of protesters all dressed almost exactly the same while wearing masks.
They dress in this manner in order to escape law enforcement by blending into the crowd.

57. On video, a National Lawyers Guild member spoke to some in the black bloc group.

58. On video, the group then attempted to mace Plaintiff, attempted hit Plaintiff with a stick,
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humiliated Plaintiff and called him a Nazi in the public square of downtown Knoxville due to

the actions of the National Lawyers Guild.

59. Defendant National Lawyers Guild failed to train or supervise its observers and coordinators.

60. One of the black bloc members did tackle another black bloc member that tried to hit Plaintiff

with a stick.

61. On or about June 23 2018, On video, at the Pride Parade, a member of the Defendant National
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Lawyers Guild told a random person speaking to Plaintiff that Plaintiff was a “Nazi Puppit.”

62. On video, that person then told someone else Plaintiff was talking to the same in order to

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 ridicule, shun, humiliate and cause harm to the Plaintiff.

63. On video, that same person said that he believed the person who told him that Plaintiff was a

Nazi because they were “legal people.”

64. At one of the events with the Defendants, Knoxville law enforcement stated to Plaintiff, We're

leaving here now. You're on your own. And that “it would be a good idea to leave” because the

police could not protect Plaintiff from imminent harm.

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65. Multiple people, including a small business owner, and strangers, contacted both Plaintiff and

other third parties regarding the published Knox Nazi Watch poster.

66. If a client, employer, credit check, etc were to search for Christian Seus on Google, the Knox

Nazi Watch poster, that includes the Plaintiffs name and photo, comes up in the first and second
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position of a world wide web search.

67. Anyone searching for the Plaintiff for a job, credit, etc. on social media creates a grossly
negative and false view of the Plaintiff.

68. Defendant Democratic Socialists of America Inc. member wore masks in violation of the City
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of Knoxville local ordinances, while assaulting Plaintiff.

69. Defendant East Tennessee Equality Council, Inc. failed to supervise and train it's parade

attendants/groups and these negligent actions allowed Defendants to wear masks while

defaming and assaulting others.

70. Defendant Democratic Socialists of America Inc. failed to train or supervise its members.

71. Plaintiffs and Plaintiffs best friend cannot go out to public events without fearing for their
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safety.

72. Plaintiffs best friend will not or will be hesitant to go into public with Plaintiff, including basics

such as shopping.

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73. Plaintiffs has gone out in public and has been harassed and humiliated due to the negligents of

Defendants and the posting of the Knox Nazi Watch poster.

74. Plaintiff cannot go out in public without experiencing a tremendous amount of anxiety.

75. A known strategy and goal of Antifa and other Defendants is to doxx, or give personal

information out on anyone they do not get along with in order to harass, ridicule, harm or

attempt to get fired from a job.

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76. Plaintiffs vehicle has been followed, so Plaintiff has to take different routes home in order to

not be followed.

77. Plaintiff must check under his vehicle for illegally placed GPS each time he has contact with

the group, so that the Defendants cannot doxx the Plaintiff even further than they have.
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78. Plaintiff suffers mentally by having the feeling of being followed due to the published and

verbal threats of the Defendants.

79. Plaintiff has not attended many public events, as Plaintiff normally would, due to each of the
Defendants actions, and has cause stress and great anxiety on the Plaintiff.
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80. Plaintiff has had to hire a security guard for protection from bodily harm due to the Defendants

unlawful actions in this complaint.

81. Law enforcement had to also approached Druns and Ears in order to stop the imminent and

intentional harm.

82. Defendant Democratic Socialists of America Duns and told multiple Knoxville Police
Department officers that Plaintiff was an “Actual Nazi.”
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83. Defendant Druns of the Democratic Socialists of American shouted in public and to the

Plaintiff “Go kill yourself.” “Your a straight piece of shit. Get the fuck out”

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84. Defendant Druns of the Democratic Socialists of American shouted at multiple people “Watch

out for him, seriously.”

85. Defendant Druns of the Democratic Socialists of American shouted in public and to the

Plaintiff that he has “killed people.”

86. Defendant Druns of the Democratic Socialists of American shouted in public and to the

Plaintiff “Get out of here” “Go. We aren't playing games.” “Go Home.” “Get the F _ _ _ out of
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here you Nazi piece of S_ _ _ _, “You're a F _ _ _ _ _ _ Nazi.”

87. Defendant Druns of the Democratic Socialists of American shouted in public and to the

Plaintiff, “You got people killed.”

88. Defendant's Druns, Ears and the Democratic Socialists of America and were able to get the
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entire group to chant “Nazi Go Home” at the Plaintiff, while bystanders pointed at Plaintiff.

89. Defendant Ears of the Democratic Socialists of American shouted in public and to the Plaintiff,

“That's a fucking Nazi over there.”

90. Defendant Druns of the Democratic Socialists of American shouted to the Plaintiff, “Get the F
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_ _ _ out. Pride is not for you”

91. Defendant Druns of the Democratic Socialists of American shouted at the crowd and pointed to
Plaintiff and stated that he was a Nazi.

92. Plaintiff was on the Public Sidewalk during the majority of the ridicule, and the Defendants

crossed one side of the street to get closer to Plaintiff's.

93. Plaintiff was wearing neutral clothing with no words or affiliations.

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94. Plaintiff did not provoke the Defendants.

95. Defendants Druns and Ears moved closer and closer to Plaintiff and continued to defame and

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 humiliate him as he was walking on the public side walk.

96. As the parade paused, Plaintiff ultimately moved to the other side of the street via a crosswalk

in order to escape Defendant's Democratic Socialists of America humiliation and slander.

97. Defendants Druns and Ears followed Plaintiff and escalated things even further.

98. Defendant Druns and Ears violently and aggressively came at the Plaintiff and purposefully

made unlawful contact with the camera that Plaintiff was holding.
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99. Defendant Druns and Ears committed assault and or battery on Plaintiff by aggressively and

unlawfully confronting Plaintiff and punching at his camera.

100. Once Defendant was on the opposite side of the street and on the sidewalk, Defendants

continued to abuse, defame and humiliate the Plaintiff.

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101. Police Officer J. Schettler, and others witnessed the defamation.

102. Officer H. Cochran said that the matter was civil.

103. Private Security had to intervene, and physically stop one of the defendants by holding out his
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arm, and deescalating the situation with John Doe.

104. Knoxville Police Department also saw the intimidation and stepped in.

105. Each Defendant purposeful and recklessly avoided the truth and acted with actual malice in

the aforementioned statements published or said about the Plaintiff.

COUNT I:
DEFAMATION (LIBEL AND SLANDER)
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106. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 103 of this Complaint

as if fully set forth herein.

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107. Defendants wrote, published and/or spoke that Plaintiff is a Nazi.

108. Defendant published or spoke the defamation without privilege and without Plaintiff's

consent.

109. The extremely serious nature of the allegations that Plaintiff is a Nazi, a kidnapper, that

Plaintiff has killed people should have heightened Defendant's due diligence in confirming the

veracity of the claim before publishing and or speaking the defamation.

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110. Defendants acted with actual malice when they published the caption with actual knowledge

that the caption was not true or with reckless disregard as to its truth.

111. Defendants failed to exercise reasonable care when they published such a serious allegation

against the Plaintiff.

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112. By falsely claiming that the Plaintiff is a Nazi, the Defendant insinuated that the Plaintiff held

anti Jewish beliefs, supports nazism, and this defamation has proximately caused injury to

Plaintiff's reputation and credibility. Specifically, the caption has caused Plaintiff to suffer in the

following manner: a. Damage to his personal and professional reputation; b. Damage his
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business opportunities c. Damage to job opportunities. d. caused serious mental anguish. e. fears

being followed, has great anxiety in public or attending public events as well as personal

humiliation.

113. A false implication and innuendo attached to Plaintiffs reputation that he holds Nazi beliefs is
defaming, has impaired Plaintiffs of reputation by having his name and photo on the first page

of google as a Zazi and causes Plaintiff to have personal humiliation, harassment and assault out
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in public is not acceptable in society.

114. "The more customary types of actual harm inflicted by defamatory falsehood include and

standing in the community, personal humiliation, and mental anguish and suffering.

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 COUNT II
ASSAULT/ INTENTIONAL ASSAULT

115. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 112 of this Complaint

as if fully set forth herein.

116. Defendant Druns and Ears of the Democratic Socialists of America Intentionally, recklessly or
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knowingly caused Plaintiff to reasonably fear imminent bodily injury;

117. Defendant's goal was to forcefully remove Plaintiff from viewing a protest as well as remove
Plaintiffs constitutional and Civil rights to be at a public location.
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118. Plaintiff reasonably believed he was in danger due to the violent behavior of masked

Defendants, their verbal and their highly aggressive and unordinary body language.

119. Police and Private security saw the assault and had to physically step in to prevent additional

harm and remove the Defendant aggressors.

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120. There were hundreds of people present and the embarrassment was extreme.

COUNT III
BATTERY/INTENTIONAL BATTERY

121. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 118 of this Complaint

as if fully set forth herein.

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122. Defendant Ears Intentionally or recklessly caused Plaintiff to fear for his safety by trying to

violently, without shouting, threats and defamation by trying to expel Plaintiff from a public

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 event.

123. Defendant Ears Intentionally, recklessness or knowingly caused physical contact with

Plaintiff, and the contact was non consensual.

124. Plaintiff did not want or invite the unlawful contact by the Defendants.

125. A reasonable person would regard the actions of the Defendant's contact as extremely

offensive, provocative or violent.

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126. There were hundreds of people present and the embarrassment was extreme.

COUNT IV:
FALSE LIGHT INVASION OF PRIVACY
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127. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 124 of this Complaint

as if fully set forth herein.

128. Defendants designed and or published the Nazi Poster on Twitter, Facebook, and other
locations and the defamatory captions with the Plaintiff’s photo falsely accusing Plaintiff of
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being a Nazi.

129. The Nazi Poster caption contains a false and defamatory allegation about the plaintiff that

insinuates that the Plaintiff holds beliefs he does not hold and that has the effect of placing

plaintiff in a false light, specifically, that he is a Nazi. Such false light is highly offensive to a

reasonable person.

130. As soon as Defendant published the caption it immediately became accessible to the entire
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Internet, and was re-shared by other social media users.

131. Defendant published the caption without privilege and without Plaintiff’s consent.

132. The serious nature of the allegation that Plaintiff is a Nazi should have heightened

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 Defendant’s due diligence in confirming the veracity of the claim before publishing the caption.

133. Defendant acted with actual malice when publishing the caption either with actual knowledge

that the caption was not true or with reckless disregard as to its truth.

134. Defendant failed to exercise reasonable care when they published such a serious allegation

against the Plaintiff.

135. Even after the Plaintiff informed the Defendants in writing that he is not a Nazi, the
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Defendants failed to retract the poster, never posted an apology, or continued to call Plaintiff a

Nazi.

COUNT V:
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INTENTIONAL/WRECKLESS INFLICTION OF EMOTIONAL DISTRESS

136. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 133 of this Complaint

as if fully set forth herein.

137. Defendant’s choice to write and publish on their social media pages and inside their business
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defamatory captions along with Plaintiff’s photo falsely accusing Plaintiff of being a Nazi

occurred intentionally and with a desire to harm Plaintiff.

138. How Defendant sought to harm Plaintiff, including the publication of a false and defamatory

statement about Plaintiff to a worldwide audience, was extreme and outrageous.

139. Because of the actions of Defendant, including the resulting mass harassment campaign

experienced by Plaintiff, Plaintiff has experienced extreme emotional distress.

140. Because of the actions of Defendant, the character and reputation of Plaintiff were harmed,
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his standing and reputation among the community were impaired, and he experienced and

continues to experience undue and unnecessary stress, anxiety and extreme ridicule.

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141. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in her favor and

against the Defendant, issue injunctive relief, including that Defendant issue a retraction, issue

declaratory relief, that the Defendant declare that their statement was in fact defamation,

monetary relief in an amount not to exceed $74,999.99 for all counts, and grant such other

further relief that the Court deems appropriate.

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COUNT VI: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

142. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 139 of this Complaint

as if fully set forth herein.

143. Defendant’s choice to write and publish on their social media pages the defamatory caption
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over Plaintiff’s photo falsely accusing Plaintiff of making a white power hand gesture and

falsely insinuating that Plaintiff held white supremacist beliefs occurred as result of Defendant’s

negligence.

144. The manner by which all Defendants sought to harm Plaintiff, including the publication of a
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false and defamatory statement about Plaintiff to a worldwide and public audience, was extreme

and outrageous.

145. Because of the actions of Defendants, including the resulting mass harassment campaign

experienced by the Plaintiff, Plaintiff has experienced extreme emotional distress and

humiliation.

146. Because of the actions of each of the Defendants, the character and reputation of Plaintiff
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were harmed, his standing and reputation among the community were impaired, and he suffered

mental anguish and personal humiliation

147. WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in her favor and

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 against the Defendant, issue injunctive relief, including that Defendant issue a retraction, issue

declaratory relief, that the Defendant declare that her statement was in fact defamation,

monetary relief in an amount to be determined at trial, pre-judgment interest, and grant such

other further relief that the Court deems appropriate.

Count VII
Negligence
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148. Plaintiff realleges and incorporates herein the allegations contained in paragraphs 1 through

145 as though fully alleged herein.

149. Each Defendants owed a duty of due care to Plaintiff.

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150. Defendants knew or should have known that their conduct would cause personal and

emotional injuries to Plaintiff.

151. Defendants breached their duty to Plaintiff.

152. As a direct and proximate result of Defendants' wrongful conduct, Plaintiff is entitled to
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recover special and general damages in such amounts as shall be shown at a trial or hearing

hereof.

153. Defendant's have a lack of training.

COUNT VIII
Gross Negligence
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154. Plaintiff realleges and incorporates herein the allegations contained in paragraphs 1 through
151 as though fully alleged herein.

155. Defendants acted with reckless disregard of the need to use reasonable care, which was likely

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 to cause foreseeable injury or harm to Plaintiffs.

156. Defendant's gross negligence caused Plaintiff to suffer injury or harm.

157. As a direct and proximate result of each Defendant's wrongful conduct, Plaintiff is entitled to

recover special, general, and punitive damages in such amounts as shall be shown at a trial or

hearing hereof.

COUNT IX
Negligent Training and/ or Supervision
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158. Plaintiff realleges and incorporates herein the allegations contained in paragraphs 1 through

155 as though fully alleged herein.

159. Defendants Knoxville Radical alliance, Democratic Socialists of America Inc,/Knoxville

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local, and National Lawyers Guild Inc. failed, neglected, and/or refused to train and/or

supervise group or observer members who unlawfully assaulted, battered and defamed Plaintiff.

160. Defendants knew or should have known that their members were unfit, violent, and masked

with no reason for masking.

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161. Downtown Wine & Spirits LLC failed to supervise, and train it staff and allowed the
defamation.

162. As a direct and proximate result of Defendant's wrongful conduct, Plaintiff is entitled to
recover special and general damages in such amounts as shall be shown at a trial or hearing

hereof.

COUNT X
Respondeat Superior and/ or Vicarious Liability and or Imputed Negligence
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163. Plaintiff realleges and incorporates herein the allegations contained in paragraphs l through

159 as though fully alleged herein.

164. Defendants Knoxville Radical alliance, Democratic Socialists of America Inc,/Knoxville

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 local, Downtown Wine & Spirits LLC, and National Lawyers Guild Inc. are liable for all of the

wrongful acts and/or omissions of its agents, members or representatives under doctrine of

respondeat superior liability, agency liability, and/or vicarious liability.

165. As a direct and proximate result of Defendants' wrongful and unlawful conduct, Plaintiff is

entitled to recover special, general, and punitive damages in amounts as shall be shown at a trial

or hearing hereof.
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166. WHEREFORE, Plaintiff prays for Judgment in his favor and against Defendants, jointly and

severally, as follows:

A. Special damages in an amount to be determined at a trial or hearing hereof;

B. General damages in an amount to be determined at a trial or hearing hereof;

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C. Punitive, exemplary, and/or treble damages in an amount to be determined at a trial or hearing

hereof;

D. Reasonable attorneys' fees and costs;

E. Pre-judgment and post-judgment interest; and

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F. Any and all other relief as may be deemed just and equitable by the Court.

PRAYER FOR RELIEF

167. Wherefore, Plaintiff Christian Seus respectfully prays for judgment as follows:

a. For injunctive relief requiring Defendants to publish retractions stating that Plaintiff is not a Nazi etc.

b. For declaratory relief requiring Defendant declare that their statements claiming Plaintiff is c. c. Nazi

is in fact defamation;
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d. For costs of suit incurred herein;

e. For reasonable attorney's fees; and

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f. For total monetary relief in an amount of no more than $74,999.99;

g. For such other and further relief as this Court deems just and proper. WHEREFORE, Plaintiff

respectfully requests that this Court enter judgment in favor of the Plaintiff and against the Defendants,

issue injunctive relief, including that Defendants issue a retraction, issue declaratory relief, that the

Defendant declare that their statements/published statements were in fact defamation, and grant such

other further relief that the Court deems appropriate.

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Respectfully submitted, with Interrogatories and photos, this 19th day of 2018

By:__________________________________
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Plaintiff
Christian Seus, Plaintiff Pro Se
4434 Sutherland Ave. #10471
Knoxville, Tennessee 37919
chris112@rocketmail.com
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