UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA
Filed July 18, 2014- retrieved from PACER- case # 3:15-cv-00467-HLA-PDB.
Olsson’s comment on this case was posted June 4, and her final commentary appeared July 7, 2015 on Facebook , one year after this case began. Scroll through the comments HERE.
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA
First Filing, July 18, 2014.
Additional case filed April 14, 2015, after continued and renewed libel statements by defendant.
PACER # 3:15-cv-00467-HLA-PDB
SUZANNE OLSSON, Plaintiff, Pro Se vs. KATHLEEN HARKEY SMITH COPPENS MCGOWAN, Defendant COMPLAINT The Plaintiff, SUZANNE OLSSON, sues the defendant, KATHLEEN HARKEY SMITH COPPENS MCGOWAN, also known as KATHLEEN MCGOWAN for libel and for loss of revenues, public trust, and reputation, and alleges:
1. Plaintiff has been a resident of Duval County, Florida since 2005. Plaintiff has during all this time enjoyed a good reputation both generally and as a published author. The defendant is a resident of California.
2. Plaintiff is informed and believes, based on information herein, alleges that the Defendant named is legally responsible for the events and happenings referred to in this complaint, and the named Defendant did cause the injuries and damages to the Plaintiff alleged in this complaint.
3. Commencing on or about April 8, 2009, the Defendant published false statements about the Plaintiff, claiming the Plaintiff did make death threats against the Defendant resulting in her publisher, Simon & Schuster, Inc. to cancel book tours and surround the Defendant with police guards. Knowing these statements to be false, the Plaintiff contacted Simon & Schuster to demand a public statement to exonerate the Plaintiff. The Plaintiff also contacted the Defendant and demanded a public statement from the defendant to exonerate the Plaintiff. The Plaintiff initiated a lawsuit against the defendant at that time, but had to discontinue due to lack of funds for legal representation to continue. From 2005 to the present, the Defendant continued to make public statements about alleged death threats and in all of these occurrences, the public presumption has always been that the Defendant was referring to this Plaintiff.
4. ‘Anna’, who is also known publicly as ‘Sasha’, Ram Queen, Bibi Angelo, and numerous aliases, is the Defendant Kathleen Harkey Smith Coppens McGowan, herein referred to as Kathleen McGowan, who has assumed numerous false identities on the Internet for the purpose of continuing libelous attacks against the plaintiff. These fictitious identities eventually become known, and admitted to by the Defendant. Defendant posted on amazon.com as ‘Anna’, falsely identifying herself as a para legal working for the defendant. She stated directly to Suzanne Olsson on April 8, 2009 at 3;04 PM, Pacific Standard time: “Glad you missed me. I have been with you but you just didn’t know it. It has been my job for the past two years to monitor sites posting defamation and liable material about clients of a law firm I work for.” These comments were directed to the Plaintiff by name and alarmed the Plaintiff, raising concerns about Defendant’s stalking behavior and emotional state of mind.
5. On April 19, 2009 at 6; 20 PM, Pacific Standard Time, the Defendant had also been posting on amazon.com. Defendant, continuing to assume the identity of “Anna”, the imaginary para legal, posted the following: “In response to Sue Olsson attacks, we (referring to Simon & Schuster Publishers) feel it necessary to post this message sent to Kathleen McGowan. This message caused Simon & Schuster to cancel (the defendant’s) book release party and book tour. “There’s no evidence for the claims that you (the defendant) are a descendant of Jesus and Mary Magdalene. There’s some sects incrusted in the Catholic Church that will not hesitate in killing you if you ever show up prove (proof) of what you are saying. They have done it for thousands of years and no one has been able to stop them. You are brave or stupid to say things like this.”
6. Plaintiff responded : “I did not say any of those things in your post about Simon & Schuster. Nor was your name ever mentioned in the post about Paul Smith, liars, and delusional people in general.”
7. April 8, 2009, 3;04 PM, Pacific Standard time, the Plaintiff posted a response to ‘Anna’ on amazon.com: “Kathleen, about those so-called ‘death threats’ would you be so kind to tell us what police department you contacted about this matter? Or was it Simon & Schuster who cancelled your book tours because of threats? Please do request they go public with this terrible information. The threats received by myself and my co-author have appeared in the news media in other parts of the world. Threats come to us from fanatic religious groups. My companions suffered a terrible fate including bombing near their homes, kidnapping, torture and rape while held prisoner for two weeks. She nearly died. Only ransom money got her freed. I live in parts of the world where this is no silly publicity gimmick. No one ‘gets’ threats. It is just done to them without preliminaries. For real. This is not a drama game for silly menopausal women trying to gain attention and sell books. You are naive and making terrible mistakes to your public image.”
8. After those posts in April 2009, commencing about June 2014, the Defendant again began posting references to death threats allegedly involving the Plaintiff. To the best of Plaintiff’s awareness, these resumed yet again on July 15, 2014 at 7:17 PM at various locations including Facebook and Defendant’s web sites, with links to Huffington Post, Simon & Schuster Publishers, and other web sites to gain the widest possible readership, attention, and exposure. The Defendant published the following on Facebook on July 15, 2014 at 7:17 PM:
9. (a.)”Answering the Controversial Questions. I claim to have had death threats. TRUE. I have had many. My first two national book tours for the EXPECTED ONE were so fraught with controversy that I had armed guards and even police escorts at book stores. The launch party and public appearances for BOOK OF LOVE had to be cancelled due to death threats. (b.) Some of them are scarier than others. There are particular countries I cannot visit because of the serious nature of the threats. I have had to send a fair number of cease and desist letters and pursue restraining orders since the worldwide release of my books in 2006. (c.) I am accused of plagiarizing material to write the EXPECTED ONE. False. False. Fucking false. And this is the one that really infuriates me because I have worked so hard over 20 years, sacrificing my health, my security, my marriage, even risking my life for this work. (d.) So I will expose the source of this right now because it is so utterly insane that it needs to be addressed. When TEO (The Expected One) came out as a record-breaking first-time novel from Simon & Schuster, there was a lot of claims that I had stolen material- coming from people who had never published anything and were all completely bonkers (this kind of material attracts many types). (e.) One of the self-published accusers, part of a famous cult, had to drop her claim when it was proven that my copyright predated hers by years. She later claimed that I had psychically stolen the material by tapping into her brain. You be the judge. (f.) This woman made a career of calling me a plagiarist. She lost her mind when the TEO (The Expected One) was released as well, writing to my publishers to claim plagiarism. When my publisher pointed out that she never published anything to plagiarize, she responded with a letter that said I plagiarized her life. Apparently this delusional character referred to herself on her website- which I had never seen and had no knowledge of- as “Indiana Sue” and because I say in my author’s notes that my life was a surreal cross between Indiana Jones and Little League mom, she took that as proof that I had stolen material from her website. If I made a reference to Indiana Jones in my book, and she called herself Indiana Sue, this was proof that I had stolen her identity. This is what she told my publishers who thankfully have lots of great lawyers to deal with the nut cases. (Plaintiff’s note: ‘The Times of India’ wrote an article about the Plaintiff’s DNA Project, referring to the Plaintiff as “Indiana Sue” in 2002. This was copied by the Defendant after seeing the story on the Plaintiff’s web site. The Defendant then began referring to herself as “Indiana Kate’. The Plaintiff wants to make note to this Court that there are several other examples of the defendant stalking and trying to emulate the Plaintiff. For brevity and clarity these additional behaviors are not included in this complaint, but can be produced if required as additional support of the Defendant’s stalking behavior toward the Plaintiff.) (h.) But this woman has haunted me since 2006, following everything I do, changing my Wikipedia entries, creating countless aliases to give me one-star reviews on amazon.com et cetera. (i.) She has been a full time stalker and apparently still is. The irony is that she is a theorist that Jesus was in India, which is a theory that I detest and think is ridiculous and not even worthy of a moment of consideration, so there is no way I would care about her life or material. (j.) But just to be clear she is the primary and possibly the sole source of the plagiarism claims. If she was as prolific at working on her theories as she is at chasing me, she might have actually published something by now. (k.) My work is my own. I earned it. I have bled for it, sweated for it, suffered for it, and I wouldn’t change a thing about it. I invite you all to judge the work on its own merits and not on these agenda driven ad hominem attacks. I am flawed, brash, outspoken, and I make a lot of people angry. But I am honest and I try to live my life in a way that is devoted to love and service. Sometimes I fail at this as I am human as the next gal. But love me or hate me, I write dam good books. Let the work speak for itself as it continues in over 40 languages of worldwide distribution. “ (note: this statement by the Defendant is blatantly false. Readers Digest is the second widest published book/magazine in the world. It is published in 21 languages. The Watchtower is the widest published in 195 languages. Simon & Schuster does not support Kathleen McGowan claims that her books are published in 40 or 50 languages. This statement is blatantly false. At no time has Simon & Schuster produced any form of proof or acknowledgement that they recieved death threats or in any way attacked or harrassed them or their client Kathleen McGowan, confirming the claims are unsubstantiated falsehoods.)
10. On July 20, 2014, the Plaintiff sent two emails to the Defendant. These were cease and desist demands sent to the Defendant’s personal email address- email@example.com. The Plaintiff demanded removal of all libelous and false material posted by the Defendant about the Plaintiff. The Defendant did not respond and did not remove the libelous and defamatory material. It remains on public view at the time this complaint is being filed. The Plaintiff filed a lawsuit against the Defendant and her publishers, Simon & Schuster for libel. Because the Defendant did not respond to the Complaint, a default judgement was won against Defendant and against Simon & Schuster in the amount of Two Million dollars. However, after numerous repeated attempts to serve the Defendant, the Court ruled that the attempts at service were not conclusive proof. The default judgement was dismissed for lack of proper service on the Defendant, although numerous attempts had been made to achieve proper service. The Plaintiff agreed to dismiss the Judgement Default against Simon & Schuster without prejudice, which means if a link can be established in the future indicating that Simon & Schuster had knowledge of the libel committed by their author, Kathleen McGowan, and deliberately hid these facts, the case against them can and will be resumed.
11. Regarding 4, 5 (pp. 2,3,) the Plaintiff knows the Defendant to be lying about death threats from the Plaintiff to Simon & Schuster. The Plaintiff contacted the Defendant immediately demanding that Defendant remove all such libelous and false material. When demanded by the Plaintiff, Simon & Schuster had no record or proof of any such action or death threats made by the Plaintiff, nor by anyone else against their client Kathleen McGowan. When the Plaintiff also demanded that the Defendant produce the source of death threats since 2005, neither the Defendant nor Simon & Schuster have provided even one source that made any death threats, or threats of any kind.
12. Regarding 9 (c, d, e, f, g, and j, pp. 4,5) the Defendant made statements falsely, knowing that it was not the Plaintiff who first accused the Defendant of plagiarism, but another author named Bettye Johnson. Ms. Johnson’s accusations against the Defendant appear on the web at –http://www.authorsden.com in which she describes her meeting with the Defendant in early 2005, then realized the Defendant had taken many creative ideas from Ms. Johnson’s own book, already in publication and purchased by the Defendant at a book fair where they met. Ms. Johnson describes in heart breaking detail in her article titled “THE NAUGHTINESS OF PLAGIARISM” her bad experiences with the Defendant.
13. This was followed soon after with another internet web site about the Defendant written by author Theresa Welch, where she also complains about bad experiences and attacks made against her for no reason except the Defendant’s apparent jealousy.
14. Regarding additional accusations of plagiarisms, a review at amazon.com on June 20, 2005, of the Defendant’s book, ‘THE EXPECTED ONE’ describes much of the Defendant’s book as copied from ‘THE ARGUES GOSPEL OF MARY MAGDALENE’, published in French and purchased from little shops in France for the tourist industry. Thus the Defendant knew her statements about the Plaintiff to be false, because she had already been accused by others at least a year previously about Defendant’s alleged plagiarisms. The Defendant’s statements are thus clearly false and made with the intent to make the Plaintiff look bad, and appear as though the Plaintiff was signaling out and stalking the Defendant, which is untrue. The Plaintiff alleges that in fact it is the Plaintiff who feels stalked, with the intent of the Defendant to emulate the life and use the creative ideas of the Plaintiff for Defendant’s personal aggrandizement and financial gain.
15. The Plaintiff had contact with Simon & Schuster Publishers January 19, 2006, to make them aware that the Defendant copied material and acquired creative ideas directly from the Plaintiff’s forums, book, and web site, and this might lead to a potential lawsuit. At the time the Plaintiff only sought to have her name publicly cleared by Simon & Schuster, especially regarding the allegations of death threats claimed by the Defendant and implicating her publishers, Simon & Schuster. The creative and copyright protected ideas taken by the Defendant have included “secret scrolls”- based upon the plaintiff’s first publishing about a (Kashmir) family scroll with a unique family genealogy that the Plaintiff was waiting to gain personal access to. After becoming aware of this through the Plaintiff’s discussion group and forum, the Defendant then made claims in an interview on Beliefnet.com, and elsewhere, that she was the first ever to go public with claims about genealogy scrolls. The Plaintiff had published her genealogy online since 1995, based on the published records of the Des Marets Family Society. In the ‘Beliefnet’ statements and other internet publications and interviews, the Defendant claimed to acquire her genealogy and historical knowledge “psychically” with no basis in reality. Some of these claims appear on the web site- theguardian.com– retrieved August 19, 2006. Defendant knew these claims about her genealogy to be false and unsubstantiated when she made them. The defendant is also involved in a case of fraudulently taking money, not paying her bills, and slandering a competitive tour company in France.
16. In addition to claiming to have acquired the Plaintiff’s creative material and web site contents “psychically”, the Defendant claims to be a Celtic witch who had psychic contact with another author, Linda Goodman, as retrieved July 18, 2014 from linda-goodman.com/Forum 5. The Defendant also claims to have gotten her material, much of which can be traced to Ms. Goodman’s book and web site, from Mary Magdalene psychically. Those claims appear several places on the Internet including Linda-goodman.com/Forum5. The Defendant claimed Mary Magdalene channeled the secret scrolls to her on several occasions. However, it will be proven that the Defendant’s claims to secret scrolls were based on actual facts copied from the Plaintiff’s book and web site published years earlier.
17. The Plaintiff had edited words from THE KOLBRIN, and these appeared, with permission from the Hope Trust of New Zealand, at the Plaintiff’s book and web site, and nowhere else because at that time the Kolbrin was obscure, hard to get, and virtually unknown. The Plaintiff recognized her own work immediately when the Defendant published the Plaintiff’s uniquely edited quotes from the Kolbrin. The Defendant repeatedly accuses the Plaintiff of stalking her and attacking her when it becomes evident from numerous web pages about the Defendant, that she has issues with many people who may have their own ulterior motives for posting bad reviews and otherwise confronting the Defendant with blatant discrepancies in her claims, and her generally vindictive, jealous, and accusatory behavior with other authors, especially female authors.
18. Theresa Welsh, an author, wrote on her blog that the Defendant has been rude and unpleasant and made false accusations against her, attacking her in most unprofessional and vicious ways as retaliation for a book review the Defendant did not agree with: This was retrieved from theseekerbooks.com on July 11, 2014, first published in 2005. Theresa Welsh fears the Defendant Kathleen McGowan is jealous, mentally unstable, and vindictive.
19. Regarding (8, a-b), the Defendant makes constant reference to death threats she allegedly gets from the Plaintiff, and yet neither the Defendant nor her publishers Simon & Schuster Inc., have produced even one evidence to substantiate such claims. If they had such death threats from the Plaintiff or anyone else, this would have been grounds for legal action years ago.
20. On February 21, 2015 at 2:38 PM, the Defendant did make a long post on Facebook that targeted and specifically named the Plaintiff as someone who harassed, threatened, stalked, defamed, and victimized the Defendant since 2005 (Attachment 1) The Defendant published that the Plaintiff was dangerous liar, delusional, a threat to the Defendant’s family, made false accusations of plagiarisms, filed out-of-State lawsuits against writers and actors to get their attention, and that Plaintiff was a ‘venomous zombie’ and a member of a dangerous cult.
21. On February 21, 2015, several hours after publishing the above posts, the Defendant then began editing, denying, and deleting her own posts, especially those containing references to alleged death threats made by the Plaintiff. These actions were apparently in response to someone warning the defendant that such comments could result in additional lawsuits. The Plaintiff received private emails from the Defendant’s readers who had copied the libel comments that were posted, then changed. Defendant perjured herself by changing her story and claiming that the Plaintiff in fact did NOT make death threats to the Defendant, claiming the Plaintiff was ‘delusional’ to suggest such an idea. On Facebook on February 21, 2015 at 4:58 PM (attachment 2) the Defendant wrote: “Suzanne Olsson appears to believe that most statements I (Defendant) make about stalking and threats are about HER (Plaintiff). They aren’t. Many bad things have happened to me-including the very real death threats that required armed guards at my national book tours- these had nothing to do with her and I never claimed that they did. She posts that I accused her of death threats but I never did. That is totally false. It is her delusion that when I state publicly or write about the fact that I had death threats, she then turns and says “Kathleen McGowan is accusing me of death threats.” This is part of her obsession and pathology that everything I say or do is about her. So for the record, Suzanne Olsson has never threatened my life that I am aware of. It does not mean that I do not feel I am in any physical danger because of her. I do. But they are totally different circumstances. My many death threats over the years have come from all over the world. I do not know of any that have come directly from her. Suzanne Olsson (plaintiff) and those who side with her in attacking me so viciously and so constantly have a very different spiritual belief system than I do. ….The Zombie faction who believe that Jesus survived the crucifixion and went on to a life where ever they believe- Europe, India, Disneyland (which is about as likely as the other two) need to deny that all that is miraculous and redemptive about the resurrection in order to make their own theories work. …So for me ultimately that is the view of the dark side at work: they destroy what defends the miracle of love and resurrection. And THAT is why I will not stop, as long as there is breath in my body. And who knows-maybe even beyond.” It is obvious from her statements that the Defendant has committed perjury for the purpose of gaining public attention and promoting her own public image. Defendant has contradicted herself repeatedly and engaged in efforts to hide or alter her defamatory statements after publishing them where they could be seen by the widest possible readership on Facebook, on amazon.com, and elsewhere. Despite publishing contradictory claims that the Plaintiff never actually threatened her, the Defendant has not removed the numerous remaining public statements accusing the Plaintiff of making death threats, and numerous other untrue statements that appear throughout the Internet, regardless that the Plaintiff sent her cease and desist orders to remove same from the internet and all other published sources. Other than making the changes to the wording of the above mentioned posts, thereby committing perjury, the Defendant has made no effort to remove the numerous other sources where she has published these damaging and untrue comments since 2005.
22. The Defendant published statements that the Plaintiff has multiple personality disorders, posted multiple one-star reviews at amazon.com, failed to publish before the Defendant, that Defendant was unaware of the Plaintiff or of her own published works, that Plaintiff has been the sole source of allegations against the Defendant of plagiarisms, that Plaintiff did stalk the Defendant, did make changes to the Defendant’s Wikipedia pages, that Plaintiff was member of dangerous cults, that Plaintiff was lying and threatening and did threaten to harm or kill the Defendant, did send threatening letters to the Defendant’s publishers necessitating police protection and cancellation of book tours and parties, all these statements are made with the intent of the Defendant to gain public attention and sympathy, to deceive the public and to cast the Plaintiff in a shameful and abnormal public status, thereby adversely affecting the Plaintiff’s ability to sell more books or to obtain an independent publisher.
23. The Defendant has maliciously and deliberately caused the Plaintiff shame and distress, resulting in the Plaintiff’s financial hardship and loss of revenue from book sales and DNA research projects that require the Plaintiff to apply for grant money. The Defendant, fully aware that the Plaintiff desires to return to dangerous war-torn regions including Afghanistan, Pakistan, and Kashmir, to continue DNA research projects, has put these endeavors in jeopardy and failure by attacking the integrity of the Plaintiff, and causing her credibility to be cast in doubt in such regions, putting the life of the Plaintiff in imminent danger at times because personal integrity is integral to the success of such religiously associated projects and endeavors.
24. The comments printed by the Defendant and allowed to continue by the Defendant are libelous and clearly exposes the Plaintiff to hatred, contempt, ridicule, and obloquy.
25. As a proximate result of the above-described publications, Plaintiff has suffered loss of reputation, shame, mortification, and injury to feelings, all to damages in the amount of $250,000.00 (two hundred fifty thousand dollars) or as determined fair and equitable by a Judge and jury.
26. The above-described publications were not privileged because they were published or allowed to remain published by the Defendant with malice, hatred, and ill-will in ways that would be viewed by the largest public audiences, with malice and ill will toward the plaintiff. Because of the Defendant’s malice in publishing or allowing to remain published the libelous and inflammatory and deceitful remarks, The Plaintiff continues to fear the Defendant because no legal protections have been brought to bear upon the Defendant. There is no legal or punitive incentive for Defendant to cease and desist her illegal behaviors. Plaintiff seeks punitive damages in the amount of $250,000.00 (two hundred fifty thousand dollars). WHEREFORE, the Plaintiff demands judgement against the Defendant for:
1. Removal of all libelous and false statements wherever published:
2. Compensatory damages according to proof:
3. Punitive damages:
4. Interest as allowed by law;
5. Cost of suit, including prior suit legal expenses of ten thousand dollars;
6. Such other and further relief as this Court may deem just and proper.
Suzanne Olsson , Plaintiff, Pro Se