Page 1

IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR INDIAN RIVER COUNTY FLORIDA

THOMAS MIX, Counter-defendant/Plaintiff

Case No 31-2015-CA-00961 REPLY TO COUNTER-DEFENDANT'S AFFIRMATIVE DEFENSES

vs. JEANETTE TYE RUNYON, Counter-claimant/Defendant __________________________/

REPLY TO COUNTER- DEFENDANT’S RESPONSE TO COUNTERCLAIM Comes now counter-claimant/defendant JEANETTE RUNYON hereby files this reply to Counter-defendant/Plaintiff’s THOMAS MIX Affirmative Defenses set forth Counter-defendant/Plaintiff’s THOMAS MIX answer to counterclaimant/defendant JEANETTE RUNYON counter-claim.

-1REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


1. In paragraph 1. Counter-defendant/Plaintiff’s THOMAS MIX through counsel now denies that counter-claimant/defendant JEANETTE RUNYON, embarked on and “electronic campaign to destroy Plaintiff physically, emotionally, and to personally interfere with Plaintiffs’ life, reputation, and personal safety.” This directly contradicts Counterdefendant/Plaintiff’s THOMAS MIX original lawsuit Further counterdefendant/Plaintiff’s THOMAS MIX denies that he tweeted #Runyon liked my cities page on FB. Starting to stalk again” That is false statement; in fact on 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted those exact words. 2. In paragraph 5. Counter-defendant/Plaintiff’s THOMAS MIX through counsel falsely denies that he accused counter-claimant/defendant JEANETTE RUNYON of being a criminal, a human trafficker, mentally ill and a stalker. That is simply not true see following examples: a. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted “She's a criminal and professional stalker.” b. On 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted: “#Conservative Convicted Criminal #JeanetteRunyon having others harass me.” c. On 13 Oct 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted You've know Runyon is a criminal.” d. On 4 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted: “Jeanette is a professional conservative stalker … She's a fake Christian. Only a criminal.” e. On 4 Feb 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE -2REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


RUNYON “That’s right cunt. I use just as much tolerance as you depict in your actions, filthy disgusting criminal." f. On 2 Feb 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "You’re a fucking nut Jeanette. You’re a criminal who pleaded guilty." g. On 17 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted “Jeanette is a criminal stalker.” h. On 2 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted "She is entering my conversations as well. Little baby buying stalker." i. On 16 Apr 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "this lady tried to trafficking an infant and got caught thank god." j. On 16 Apr 2014 Counter-defendant/Plaintiff’s THOMAS MIX also Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Beware #JeanetteVictoriaRunyon #NC. She is a crimal and tried to human traffick a BABY back the US." k. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted; “Its funny that Jeanette Runyon thinks she’s decent after trying to smuggle a baby you into the US....” l. On 15 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted “When the stupid stalking human trafficking criminal should know if she properly searched Google, she'd know what...” m. On 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE -3REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


RUNYON "Gotta love all these fake Christians that break laws, smuggle babies, and all other sorts of vile crimes." n. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted "omfg look at this baby buying freak. Jeanette Runyon release your court documents...." o. On 21 Jan 2014 Counter-defendant/Plaintiff’s THOMAS MIX tweeted on 21 Jan 2014, “She's been admitted to a mental hospital involuntarily…She may be bi-polar or may hear voices.” p. On 1 Feb 2014 Plaintiff THOMAS MIX tweeted “Jeanette T Runyon. You’re a #stalker with severe mental issues.” q. Plaintiff THOMAS MIX tweeted on 11 Oct 2014 posted about “She has been institutionalized.” r. On 6 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "The human trafficker is currently suspended." s. On 8 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Not all Virgo's buy babies and try to smuggle them." t. On 18 Oct 2014 Plaintiff THOMAS MIX Tweeted “Runyon has been diagnosed w/w Borderline Personality Disorder...was institutionalized in a mental health facility... prescribed Risperdal.” u. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "She's a criminal and professional stalker." -4REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


v. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted "This is my stalker Jeanette Runyon." w. On 26 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Psycho conservative stalker is still mentioning me in comments. Still obsessed." x. On 15 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted "As #JeanetteRunyon can see its not about her. Fucking stalker." y. On 1 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "She's evil stalker incarnate" z. On 1 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted "Trying to get me suspended? You’re the stalker. And it is on going, by you Jeanette Runyon." aa. On 18 Jun 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted

"#No1Important00

is

stalker

and

Criminal

#JeanetteRunyon use caution when tweeting to her." bb. On 16 Mar 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to JEANETTE RUNYON "She clearly is a stalker." 3. Further in Paragraph 5. Unbelievably Counter-defendant/Plaintiff’s THOMAS MIX had the audacity to deny that he has a blog devoted to “exposing” the Counter-claimant/defendant JEANETTE RUNYON. Counter-defendant/Plaintiff’s THOMAS MIX has two blogs where he posts

about

Counter-claimant/defendant

JEANETTE

RUNYON

-5REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


“staking” him (according Counter-defendant/Plaintiff’s THOMAS MIX the mere mention of his name is stalking) http://periabo.tumblr.com and http://thomasamix.tumblr.com/ both blogs have dozens of screen shots of Counter-claimant/defendant JEANETTE RUNYON Facebook posts old tweets, and Disqus comments which he claims is harassment. Further Counter-defendant/Plaintiff’s THOMAS MIX falsely denies he has boasted about shutting down Defendants’ Twitter account and Defendants’ Facebook account and has reported Defendant to Defendants’ local District Attorney, local Sheriff’s department, and the FBI in a failed attempt to have Defendant arrested. a. On 10 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "A person may be missing a Facebook." b. On 11 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Yeah she needs to use Disqus cause her Facebook is suspended. Her other two will be down soon hopefully." c. On 11 12 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "You think she misses her Facebook?" d. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Calling her district attorney now to see what can be done about hack attempts." e. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Contacted (336) 242-2100 her local Sheriff." -6REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


f. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Transferring to FBI near Lexington. Calling them now. Referred by Sheriff." 4. In paragraph 7 Counter-defendant/Plaintiff’s THOMAS MIX contradicts his original lawsuit where he alleges Counter-claimant/defendant JEANETTE RUNYON called him a pedophile or a pedophile supporter. He now claims that he no knowledge of the allegations and therefore, denies any and all claims. 5. In paragraph 8 Counter-defendant/Plaintiff’s THOMAS MIX now claims that he has no knowledge that Counter-claimant/defendant JEANETTE RUNYON printed or caused to be or printed false allegations regarding Plaintiff‘s conduct, character, sexual orientation, beliefs, and criminal activity. That directly contradicts what Counter-defendant/Plaintiff’s THOMAS

MIX

states

in

his

lawsuit.

Further

Counter-

defendant/Plaintiff’s THOMAS MIX now claims that he has no knowledge of his outrageous claim that blogger Robert Stacy McCain posted “sealed juvenile records” on his blog. That is another fabrication as Counter-defendant/Plaintiff’s THOMAS MIX tweeted on 17 Apr 2014 “Robert Stacy McCain loves hosting sealed documents on his website of minors.” 6. In paragraph 8 Counter-defendant/Plaintiff’s THOMAS MIX has the audacity to deny what he originally claimed in his defamation lawsuit, that Counter-claimant/defendant JEANETTE RUNYON insinuated or cause -7REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


to be insinuated that the Counter-defendant/Plaintiff’s THOMAS MIX is a criminal, which directly contradicts his suit. 7. In paragraph 9. Counter-defendant/Plaintiff’s THOMAS MIX

now

denies that Counter-claimant/defendant JEANETTE RUNYON called, insinuated or cause to be insinuated that the Plaintiff is a criminal in contradiction to Counter-defendant/Plaintiff’s THOMAS MIX original defamation lawsuit.

Further Counter-defendant/Plaintiff’s THOMAS

MIX denied that he has posted that Counter-claimant/defendant JEANETTE RUNYON is a human trafficker, a baby buying freak, convicted criminal, a professional cyber-stalker, a danger to children, who has her criminal records sealed, a welfare queen and she is severely mentally ill, hears voices may be bi-polar and has been institutionalized, and needs to be committed again. a. See paragraph 2 a-bb for Counter-defendant/Plaintiff’s THOMAS MIX

quotes

where

he

calls

Counter-claimant/defendant

JEANETTE RUNYON a human trafficker, a baby buying freak, convicted criminal, a professional cyber-stalker, a danger to children, and she is severely mentally ill, hears voices may be bipolar and has been institutionalized, and needs to be committed again. b. On 28 Jun 2016 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Thanks for that link with the sealed record. Let's see what it's hiding, shall we?!" -8REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


c. On 14 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "has sealed court documents she knows she had them sealed." d. On 17 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "I keep asking her to release her sealed court docs." e. On 5 Nov 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "I can't believe many #conservatives have criminal records in their adult lives. Stalking, trying to smuggle in babies, defamation." f. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted "omfg look at this baby buying freak. Jeanette Runyon release your court documents...." g. On 7 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "And she won't release her sealed court docs involving the Ukraine incident." h. On 7 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "I keep asking her to release her sealed court docs, cause she says I'm lying. I tell her prove." i. On 6 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "Then release your court documents from the case. You have them sealed Jeanette Runyon." -9REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


j. On 4 Feb 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "She got someone to seal all her convictions. Probably cried on some conservative Christian forum and got donations." k. On 20 Jan 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "I find it funny that she has gone through the trouble to seal all of her legal troubles. She's got a guilty conscience." l. On 30 Jul 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON "she can't possibly have a life. Welfare queen JR is." 8. In paragraph 13 Counter-defendant/Plaintiff’s THOMAS MIX denies that inserted

himself

into

a

comments

section

of

a

blog

(http://www.crimeandfederalism.com/2015/05/ever-had-the-policecalled-on-you-for-blogging.html)

and

called

the

Counter-

claimant/defendant JEANETTE RUNYON a criminal, falsely claimed that Defendant stalked family members and post addresses of people who disagree with the Defendant. The fact remains the Counterdefendant/Plaintiff’s THOMAS MIX blogged on this incident May 31, 2015, http://thomasamix.tumblr.com/post/120345201591/ever-had-thepolice-called-on-you-for-blogging titled “Ever Had the Police Called on You for Blogging? - Crime & Federalism #mytroll Jeanette Runyon using this site to harass me further with her friends. I commented on this one.” The fact is Counter-defendant/Plaintiff’s THOMAS MIX was never once mentioned by Counter-claimant/defendant JEANETTE RUNYON she simply posted a Google link to his PUBLIC posts about her. - 10 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


9. In paragraph 15 Counter-defendant/Plaintiff’s THOMAS MIX claims that he lacks knowledge and denies that he added his own personal message on the false report about the Defendants Newborn photography on RipOffReport.com repeating his favorite lie that the Defendant is a criminal and a human trafficker. One again Counter-defendant/Plaintiff THOMAS MIX lies; (http://www.ripoffreport.com/r/Jeanette-RunyonStudio-Woolslayer/Lexington-North-Carolina-27293/Jeanette-TyeRunyon-Studio-Woolslayer-Jeanette-Runyon-Studio-Woolslayer-JeanetteRunyon-1131515); Of course you had problems. She's a CRIMINAL AUTHOR: Thomas SUBMITTED: Tuesday, November 04, 2014 I cannot believe this freakshow, Jeanette Runyon, is still out there ripping people off! Many of us in Lexington are very familiar with this woman and her violent outbursts. Google her. She's a convicted criminal. She has decades of trouble with the law, not the least of which being a conviction for lying to federal agents! Her own family acknowledges publicly and under oath that Jeanette has been involuntarily institutionalized. Jeanette's family is currently suing her to end her years of abuse. Just look at the people she has taking up for her here! Paul Lemmen is ALSO A CONVICTED CRIMINAL!! According to Wikipedia, Paul Lemmen is a military impostor and convicted criminal, specializing in fraud. The fact that he and Jeanette are close friends PROVES that she is a shady person to be avoided at all costs!! The business was actually started by Larry Woolslayer. He’s a really nice guy who shacked up with Runyon for a few years. He - 11 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


left her long ago but she still uses his business name & pretends to be in a relationship with him. 10. In paragraph 20 Counter-defendant/Plaintiff’s THOMAS MIX denies that he wants Counter-claimant/defendant JEANETTE RUNYON off the net altogether; another lie by the Counter-defendant/Plaintiff’s THOMAS MIX; a. On 21 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON “hopefully losing net privileges. Court can order that.” b. On 14 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON “please I hope that JR loses access to the net.” 11. In paragraph 20 Counter-defendant/Plaintiff’s THOMAS MIX lies again and denies that he has called the Counter-claimant/defendant JEANETTE RUNYON a professional stalker; a. On 29 Jan 2015 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON “She's a criminal and professional stalker.” b. On 13 Jun 2016 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON “…still stalking my timeline; posting unrelated SS's under its own account. #ProfessionalStalker.” c. 4 Aug 2014 Counter-defendant/Plaintiff’s THOMAS MIX Tweeted referring to Counter-claimant/defendant JEANETTE RUNYON tweeted “Jeanette is a professional conservative stalker.” - 12 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


12. In paragraph 20 Counter-defendant/Plaintiff’s THOMAS MIX contrary to his original lawsuit, now denies that Counter-claimant/defendant JEANETTE RUNYON called or insinuated that Plaintiff is a pedophile, that the Counter-claimant/defendant JEANETTE RUNYON caused false printed materials to be distributed that would cause people to conclude that plaintiff committed criminal acts,

Counter-claimant/defendant

JEANETTE RUNYON stalked Counter-defendant/Plaintiff’s THOMAS MIX family and posted their home address, Counter-claimant/defendant JEANETTE

RUNYON

intentionally

threatened

Counter-

defendant/Plaintiff’s THOMAS MIX personal safety; all these statements are

in

direct

contradiction

to

the

claims

made

in

Counter-

defendant/Plaintiff’s THOMAS MIX original lawsuit. 13. In paragraph 23 Counter-defendant/Plaintiff’s THOMAS MIX, contrary to his original lawsuit, now denies that Counter-claimant/defendant JEANETTE RUNYON threatened Plaintiffs personal safety. 14. In paragraph 25 Counter-defendant/Plaintiff’s THOMAS MIX, claims no knowledge

of

calling

Counter-claimant/defendant

JEANETTE

RUNYON a lesbian which contradicts his public Tweet he made on 14 Feb

2014

referring

to

Counter-claimant/defendant

JEANETTE

RUNYON “She is a bigot, stalker, and is obsessed with gay people. Maybe she's a lesbian??” 15. In paragraph 27 Counter-defendant/Plaintiff’s THOMAS MIX, country to his admissions now denies and claims he has no knowledge that he publically boasted that he “did not care if {his false allegations of Counter- 13 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


claimant/defendant JEANETTE RUNYON criminal activity} …were true or not.”

REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES Florida's statute of limitations for defamation is two (2) years. See Fla. Stat. § 95.11(4)(g), Therefore Counter-defendant/Plaintiff’s THOMAS MIX claim that his defamatory statements are past the Florida statute of limitations is without merit. Thomas Arzi aka @_ThomasArzi @_Lazarus___ Twitter account was created on January 2014 that means his entire account is within the Florida's statute of limitations for defamation as his lawsuit was brought on December 2015. PLEA FOR RELIEF One again Counter-defendant/Plaintiff’s THOMAS MIX has either lied outright or denied the claims he made in his original lawsuit. It is becoming clear that Counter-defendant/Plaintiff’s THOMAS MIX can’t support his allegations against Defendant JEANETTE RUNYON; Counter-defendant/Plaintiff’s THOMAS MIX has lied in discovery and lied and contradicted himself in his response to Counter-claimant/Defendant JEANETTE RUNYON’S counter-suit. Quite frankly his original lawsuit is nothing but a work of fiction which Counterdefendant/Plaintiff’s THOMAS MIX will be unable to prove to this court his false allegation of defamation. Further in his response to Counter-claimant/Defendant JEANETTE RUNYON’S counter-suit Counter-defendant/Plaintiff’s THOMAS MIX now denies all allegations made in his original defamation lawsuit. Either - 14 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


something is true or not, truth is not what the Counter-defendant/Plaintiff’s THOMAS MIX may find useful. It should also be noted that Counter-defendant/Plaintiff’s THOMAS MIX answer to Counter-claimant/Defendant JEANETTE RUNYON’S counter-suit was filed WEEKS after the due date set by this court. This frivolous and malicious lawsuit has always been aimed at denying Counterclaimant/Defendant JEANETTE RUNYON’S First Amendment rights to freedom of speech. Counter-claimant/defendant JEANETTE RUNYON asks for sanctions on the Plaintiff and she prays that the Court dismiss the Plaintiff’s complaint with prejudice in its entirety and any other actions this Court feels is proper.

Respectfully submitted,

Jeanette Tye Runyon – Pro Se

- 15 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES


This is to certify that a true and correct copy of Counter-claimant/Defendant JEANETTE RUNYON'S REPLY TO COUNTER-DEFENDANT'S AFFIRMATIVE DEFENSES have been furnished to Counterdefendant/Plaintiff THOMAS MIX’S counsel electronically and by United States Post Office, First Class Mail, postage prepaid this 11 day of July 2016. To:

Matthew Randell Groom Rooney & Rooney P.A. 2145 14th Ave. Suite 20 Vero Beach, FL 32960

Jeanette Runyon – Pro Se 686 Happy Hill Road Lexington, NC 27295 (336)-236-9390

- 16 REPLY TO COUNTER- DEFENDANT'S AFFIRMATIVE DEFENSES

Runyon reply to thomas a mix affirmative defenses  

Runyon reaction to Thomas A Mix caned responses to her counter suit claiming defamation

Runyon reply to thomas a mix affirmative defenses  

Runyon reaction to Thomas A Mix caned responses to her counter suit claiming defamation

Advertisement