Plaintiff Trout Point Lodge Vaughn Perret Charles Leary and Defendant Douglas K
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Yarmouth No. 411345 Supreme Court of Nova Scotia Between: Plaintiff Trout Point Lodge Vaughn Perret Charles Leary and Defendant Douglas K. Handshoe Brief in opposition to Plaintiff’s request to amend their claims and request for Summary disposal of these proceedings Introduction 1. This is the third proceeding instituted in Nova Scotia by Plaintiffs against Defendant alleging defamation and or Copyright Act Infringement to harass and punish Defendant for exposing Plaintiffs’ roles in the corrupt criminal activities and schemes of a felonious United States politician named Aaron Broussard (Broussard). The record shows Broussard used Plaintiff as his property managers, said property1 being the result of an illegal bribery scheme. The record also shows Plaintiff’s profited from Broussard’s criminal activity and that plaintiff combined with the criminal enterprise identified by the United States Attorney’s Office, on behalf of self-admitted felon Broussard in the no less than three Strategic Lawsuits Against Public Participation (SLAPP suits) filed in Nova Scotia against three media outlets located in Mississippi and Louisiana that covered this sordid tale of corruption in metro New Orleans, including the submission of perjured affidavits in a case to which defendant was not a party that resulted in the invasion of privacy of at least 5 1 Nova Scotia Enterprises, LLC, which owned the River Bend Lodge at Trout Point, which was marketed by Plaintiff Trout Point Lodge indistinguishable from the Lodge itself and for which visitors were charged an 18% gratitude by the Lodge itself. 1 residents of the States of Mississippi and Louisiana.2 Broussard’s co-conspirators, as Plaintiffs in this instant action now seek to duplicate allegations in a SLAPP suit brought in Louisiana by Trout Point Lodge owner Daniel G. “Danny Abel on behalf of “himself and unnamed others” to continue harassing defendant with meritless allegations in fulfillment of their explicit threats to “sue” defendant “into bankruptcy” and inflict a “painful hell of legal entanglement for years to come”. DRAMATIS PERSONAE Douglas K. Handshoe, Defendant CPA and Blogger. Owner, Slabbed New Media, LLC. Primary blogger, Slabbed.org. Daniel G. Abel Plaintiff, Owner of Trout Point Lodge, Cerro Coyote, S.A., La Farme d’Acadie, Chicory Farms, Attorney and associate of Aaron Broussard, Charles Leary, Vaughn Perret and Shane Gates. Charles Leary, Plaintiff Associate and business partner of Abel and Perret. Owner and Manager of Trout Point Lodge. In 2011, sued Handshoe for defamation in Canada including multiple times since. Attempted to execute a default judgment in Mississippi losing that case. Vaughn Perret, Plaintiff Associate and business partner of Abel and Leary. Former Abel paramour. Owner and Manager of Trout Point Lodge. In 2011, sued Handshoe for defamation in Canada including multiple times since. Attempted to execute a default judgment in Mississippi losing that case. Aaron Broussard Former Jefferson Parish President that was arrested and subsequently sentenced to 46 months in prison. Connected to Abel, Leary and Perret through business, politics and partner with Abel in a law practice located at the Super 8 Motel in Metairie Louisiana. He was also involved with marketing investments in Cerro Coyote, S.A., another business venture owned by politically connected Jefferson Parish residents and associates of Brousssard that was managed by Abel, Leary and Perret. At one time Broussard owned property on Trout Point Rd. in Canada, immediately adjacent to the Trout Point Resort. 2 Worth noting is Plaintiff’s only pursued defamation action against defendant only and not the other individuals they identified to this very court as allegedly publishing defamatory statements about them. In that action Plaintiff’s identified Lodge owner Daniel G. “Danny” Abel as their US based attorney. Abel was Broussard’s law partner practicing out of Suite 106 at the Super 8 Motel in Metairie Louisiana. The owner of this facility is currently under indictment for cocaine distribution. State of Louisiana v Desai. 2 Karen Parker Broussard Former wife of Aaron Broussard. Her hiring and resulting payroll ultimately lead to his resignation and indictment on Federal charges. The factual basis of her guilty plea provided the first concrete indications Broussard used his property at the Resort at Trout Point as a bribery scheme. Chief Judge Louis Guirola, Jr. Chief Judge of the U.S. District Court for the Southern District of Mississippi. Denied Leary and Perret’s attempt to execute default judgment from earlier Canadian defamation case. Shane Gates a/k/a Shane D’Antoni Adopted son and reputed current paramour of Daniel Abel. Serves as plaintiff in several of Abel’s lawsuits alleging police brutality. Roy D’Aquila Deceased former member/partner in Nova Scotia Enterprises, L.L.C. which federal authorities identified as a conduit for bribes to Aaron Broussard. D’Aquila swore several affidavits in support of the SLAPP suits filed by Leary, Perret and Trout Point Lodge in Canada. Carl J. Eberts Investor in the Cerro Coyote scheme, who wrote Aaron Broussard in 2007 asking him to help sell his stake in the venture as Broussard has originally sold him his original stake.. LOCALE Trout Point Lodge A Nova Scotia, Canada, hotel on the Trout Point Resort. Owned by Abel, Perret and Leary along with a bevy of contractors for the Parish of Jefferson and other individuals associated with Broussard. Cerro Coyote, S.A. A Costa Rican resort owned by Abel, Perret and Leary along with a bevy of contractors for the Parish of Jefferson and other individuals associated with Broussard Chicory Farms A defunct goat farm in Washington Parish Louisiana which received grants from the U.S. Department of Agriculture. Owned by Abel, Perret and Leary. Identified itself in USDA grant filings as a woman owned business enterprise. La Ferme d’Acadie A defunct cheesemaking business in Canada that received a loan and later was sued by the Atlantic Canada Opportunity Agency. Also owned by Abel, Perret and Leary along with a bevy of contractors for the Parish of Jefferson and other individuals closely associated with Broussard. 3 Nova Scotia Enterprises, LLC A Louisiana Limited Liability Company which owned property in Trout Point Road in Nova Scotia. Owned by Broussard, the late Roy D’Aquila along with John Does 1-13. Later identified as a conduit for bribes to Aaron Broussard. Kempt Wilderness Lodge Services A Canadian Partnership which owned property on Trout Point Road. Owned by Broussard, the late Roy D’Aquila along certain John Does. Parties 2. Plaintiff Trout Point Lodge Limited is a Nova Scotia company owned by several Louisianans connected to the disgraced former Parish President of Jefferson Parish, Aaron Broussard, a self-admitted felon currently incarcerated in the US Penitentiary at Butner North Carolina for crimes involving his corrupt tenure as President of the Parish of Jefferson, Louisiana including identification by United States Attorney of Broussard’s property at the Resort at Trout Point as a corrupt bribery scheme.3 3. Plaintiffs Vaughn Perret and Charles Leary managed several Broussard connected business entities including Nova Scotia Enterprises, LLC, one company identified by United States Prosecutors as Broussard’s conduit for an illegal bribery scheme. The only connection Nova Scotia has to the scheme is it is the foreign land where the ill-gotten gains from Broussard’s various corrupt business schemes were hidden, out of sight of the American public 4. Defendant Douglas Handshoe is a nationally recognized investigative journalist whose 3 United States of America v Aaron F Broussard et al. Case No. 2:11-cr-00299, Document 146, Filed 08/31/12. This document can be accessed free of charge via the New Orleans Times Picayune at http://media.nola.com/crime_impact/other/Other%20crimes%20Broussard.pdf. Mr. Broussard subsequently pleaded guilty to two counts of his superseding indictment and is now serving a 46 month prison sentence. 4 media company, Slabbed New Media LLC, publishes a blog that is targeted to a specific American audience in the southern United States.4 Salient Factual Background 5. Plaintiffs, along with their business partner Daniel G. “Danny” Abel has been associated in public,5 in Court filings,6 and in Court opinions7 with Trout Point Lodge Limited, a Limited Company organized under the laws of Nova Scotia, Canada. Two of Abel’s business partners in Trout Point Lodge include Charles Leary and Vaughn Perret. Broussard owned two cabins immediately adjacent to Trout Point Lodge along with Nova Scotia Enterprises, LLC, (which owned Riverbend Lodge) that were marketed on the Trout Point Lodge website as if they were part of Trout Point Lodge’s operations. The Trout Point Lodge’s website confirmed that Broussard owned two cottages, called “Black Bear” and “Cub.”8 Trout Point Lodge “managed rentals of his property.”9 The case records in Plaintiff’s suit against Louisiana Media Company also clearly indicate Riverbend Lodge was owned by Nova Scotia Enterprises, LLC, which was identified by United States 4 Slabbed has been cited as an authoritative news source numerous times in the US Media including the New Orleans Times Picayune as an authority on Jefferson Parish Louisiana politics and corruption, the Biloxi Sun Herald for coverage of the 2010 Gulf Oil Drill moratorium litigation and coverage of the corruption scandal at the Mississippi Department of Marine Resources among other topics and a book, Delay Deny Defend, Why Insurance Companies Don't Pay Claims And What You Can Do About It by Rutgers University Law Professor Jay Feinman. Additionally, Slabbed is listed by consumer interest group United Policyholders as a nationally recognized policyholder resource at http://www.uphelp.org/library/resources for our work covering the post Hurricane Katrina Wind-Water litigation. 5 Abel is an author of the “Trout Point Lodge Cookbook,” available at: http://www.troutpoint.com/cookbook.htm.