Shanda Lancaster Provides Inaccurate Suicide Information To Public Shanda Lancaster and a zazillion fake user names Shanda Lancaster Goes On The Record Giving Out False Information On Suicide Dickson, Tennessee

You are fine one to talk about being a coward.  Oh, and, as far as you are concerned... the scales don't exist... you just make up c r a p as you go along.  Get lost, would'ja?

Let's see.  Members of a forum almost made you commit suicide back in January.

Why do you post as if everything is one-sided.  you never mention what you've done.

Can you really come on here and say you're absolutely innocent of all?  You've never done anything to make these people post what they post?

You're the only one being cyber harassed?

Shanda...lol

C'mon.

You keep harping about all the hate sent your way and you jump on Youtube making videos being a hate advocate for people who have been bullied.

This term is used for children.  You are an adult.  It is not bullying when you are an adult.  It is called harassment.

You always do this.  you make it as if all these people are bad bad bad bad bad.  Youve never said "well, I suppose i've thrown in my fair share of crap over the months".

Not once have you ever said youve dealt out as much as youve received.

If you would speak like this, you'd have more respect and possibly a solution a long time ago and no one would be posting anymore.

You do realize that NO ONE, not even myself is innocent.  You speak as if youre a victim and youve never hurt anyone.
I mean, no one believes it but we do wonder why you dont feel it necessary to take even part of the blame for your "stalkers and haters".

Really?  Youve done nothing to deserve this?  You make it sound like one day, people came along and started in on you for absolutely noooo reason.

I double dog dare you to say that.

For once.  claim it.  Say you jumped in there just like the rest of them.  One big happy harassment party...Its takes a man to admit that they have also been wrong.

Cmon shanda.  Be a man.

It doesnt matter if anyone said that or not.  Im sure by that point people were extremely tired of you and the problems you caused.  You started on sss back in 2010.  going on 3 years now shanda.

no one would miss you if you were gone.  seriously.

In my opinion, everyone would be much better off if you werent around anymore. 
as for posts that bother you?

get off the computer.  dont read items anymore.  steer clear.  get a new hobby besides the internet all day and all night long.

no one is forcing you to read anything.  what you put out there, you get back even worse.  no wonder people want you gone.

who cares!!!!  I dont care that youre ill.  I dont care if youre dead.  who cares????

I've been reading this and similar threads. There are a few things that strike me as being perhaps viewed as bullying when that isn't what is actually happening. Bullying has an implied or actual imbalance of power. That is key and central to what makes bullying different from picking on someone or making fun of them or any other form of interaction that is taken as a negative. Additionally, bullying includes the aspect of repetitive behavior. If you get singled out by being treated with disdain repeatedly, then yep, it may be bullying. However, it is not necessarily true if one is treated with disdain over and over that one is being bullied. It very well may be a case of getting as good as you give.  Simply not liking how another person acts towards you does NOT constitute bullying. Remember, it is the imbalance of power that makes it bullying!

Strong opinions that are not in agreement do not equate to bullying. Each person that posts knows their views may or may not be considered valid to all and when someone expresses an opposing view, that is NOT bullying.

It all comes down to CHOICE! If one finds something upsetting, they also have the CHOICE on whether to participate or not. Do not foist someone else's responsibility for THEIR feelings on me. You want to feel badly about how you are treated, then do something about it or don't. Again, personal CHOICE.

No one can control how others behave or interact. The only thing within my power is to control how I respond and how I allow their actions to impact me. The same goes for all. I am not saying that some folks do not find it more difficult than others to brush off unpleasant interactions. Some folks find it very hard to have a "thick skin." Fine. However, if you are unable or unwilling to REFUSE to allow other's actions and reactions to define your emotions, you have a much larger problem than postings on a message board  to worry about.

Bullying does exist and it should be countered. That does not for a nanosecond remove the personal responsibility for one's own response to how one is treated. Nor does addressing the bullying mean that one can play the martyr card when they open that door by stirring s**t in the first place.

nope.  ur once again a dingbat shanda and wrong.  you  must have no idea how much your house (i mean the banks house) is worth.

yur dad sure shelled out wayyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyyy too much money for that dump.

public property assessments are done all the time.  ask ur dad.  hes the one who has the info too.

makin payments on 59k when the dump is only worh 25k.  why mr. neighbor 1525 grab creek road just bout their house for 25 k in 2010.

(see screen shots of public property assessments of the shanda shack)

oh, I think i'll head over there, pay cash for the place across the street and stalk your a** for the rest of your life.

You state that all these people have been bullying you for over a year. What did you do to them to cause this response? A group of people aren't going to just pick your name out of a hat and decide to attack you. You had to have done something to them. Most adults don't attack unless attacked first. Just from what I've seen on here, you are definitely not an innocent victim and you continue to perpetuate the situation, egging them on, threatening them, "exposing" them, etc. You're not smart enough to see that the more you fan the fire the higher the flames and the longer it will burn on. So why do they hate you so much? What have you done to cause it? 

...lololol.... cannot stop giggling here... by going to the lengths of trying to find out how much my house and property are worth you have just shown yourself to be stalkerish.  It certainly doesn't make me look bad but you?  It makes you look extremely creepy.

Oh, and what the hell ever happened to the original topic of this complaint?  It seems people are at a loss as to how to show I've given inaccurate information so they've turned the discussion on me and my personal life.  Next you'll be discussing what I like to have for breakfast.  You'll probably say I nibble on a corn cob.  Ahahahahaha!!!!

ROTFLMAO!!!  I don't know what your 'public records' source is but it is completely inaccurate (probably something you pulled out of your own head!).  I know what my house is worth.  I suspect you are on a fishing trip so just consider me the one that got away.  lolololol  :))))))

you and "hubby" should buy your house right now.  even with crappy low income, you may be able to swing it.

that house has gone so far down in value since its last purchase in june of 2008.

I feel for the sap who paid $59,000 for the place and is no doubt making mortgage pymts on nearly sixty grand when the place is now only worth...

well, in 2009 it was assessed at only $24 grand.  say what?????  what a drastic drop.

It is now 2012.  I think its safe to say the value has dropped even more.  pretty soon you'lll  be able to sell the house for the price of a burger.

maybe.


Property Information for 1523 W Grab Creek Rd

Property Features


Financial History

Single Family ResidenceYear Built: 19751 BathroomsApproximately 900 Sq FtStories: 1County: DicksonHeating type: Heating & CoolingRoof type: Composition ShingleParking: Detached Garage
Source: Public Records

Last sold for $59,900 on 6/23/2008

Last assessed at $24,825 on 2009

Previous sales
$59,900 on 6/23/2008
Previous assessments
$24,825 on 2009

$24,825 on 2008

$24,825 on 2007

Source: Public Records

again, it was assessed in 2010 for only
$24,818

look at the neighbors!!!!!

1525 W GRAB CREEK RD
Dickson, TN


$25,000  (sold at this price in 2010)
--
1
1,482
09/29/2011
0.02 mi

I have more then that in my piggy bank.

Ms. Lancaster you can't read or comprehend . The plaintiff is saying that you and Dickerson have accused Ms. Patchen of being the owner of MTSS and have posted it on several sites on the internet one being aboutus.org where it was confirmed that you and Mr. Dickerson shared an account to post this libel.

Ms. Patchen is not saying that MTSS is a fraudulent web site. She is stating you and Dickerson have made fraudulent and illegal statements about her.

So no fairies in Dickersons head. The only fairies are in yours.

Perhaps you should consult with an attorney so they can explain this to you. If you think this to be a silly lawsuit then perhaps you should not have been making silly untrue statements about the plaintiff on more than one level.

This suit as I read it has much more to it then about libel.

I don't know what else to say to you other than you have said about 100 times you were gone, done, finished posting on all these sites yet you do it under fake names daily.

So if you have such full days why is it that you are here and all over the net posting all day long?

Oh and by the way. This lawsuit doesn't involve MTSS at all. So you may want to take that into consideration. Why bring more actions against yourself? Because that is what you are doing by posting incorrect information.

Pro Se may not be the best way to go if you can't understand one sentence and post information which is not true once again.  

...pray tell said that about the 'website' (which you pretend to not realize is MTSS)?  Whose opinion was that in the legal document?  Larry's?  Fairies in a field of daisies?  "I" did not misunderstand anything whatsoever.  YOU simply don't want to believe the truth when it is shown to you.

You people underestimate me on so many levels it is laughable.  I may not be rich, no, but, even if I were rich, I would not sue someone over this stupid mess.  It would be childish of me to sue and lower myself to a level I will never go.

FYI:  if you don't like what I have to say, don't listen/read.  Simple.  I believe many people from MTSS have given me that advice (all the while smearing my name with lies everywhere).

However, when a person said "Shanda, off yourself. You are a waste of cells" I gave that information to the proper people.  That was pretty much the final straw but not in the way it was intended.  It didn't hurt me, no, it made me extremely ANGRY.

BTW:  SHUT UP about my illness.  You would not last a DAY in my shoes.  I have a lot more to deal with than JUST my illness so sod off, the lot of you MTSS people and/or haters.  I have said multiple times, the only reason I ever spoke publicly about my illnesses was to help other people.  You haters perpetuate stigma about mental illness and I'll not stand for it!!!!  This is why I watch sites like this one.

Oh, and the bit about sitting at my computer all day (a lie I've read over and over to infinity)?  I will bet you money I got more accomplished OFF THE COMPUTER today than you could in a week.  Grand total of computer usage today?  Less than an hour.

I'm done speaking with any of you on these sites.  If you are a reasonable and nice person, you know where to find me.  I won't hold my breath waiting to be contacted however.

You have read the Pacer document incorrectly. It states that Mr Dickerson falsely accused Ms Patchen of being involved in a  website (unknown, unnamed) he considered engaged in fraudulent or otherwise illegal activities.  Let me post section #54 where it states this fact.  You are continuing to make incorrect statements in public. You are wrong.

54. In addition to his behavior in connection with the Singsnap Discussion Site, in or about May 2011, on information and belief, with Maddox's assistance,  Dickerson made defamatory comments regarding Ms. Patchen on public websites known as www.ripoffreport.com, aboutus.org and www.pissedconsumer.com, falsely accusing Ms. Patchen of being a partner or owner in a website engaged in fraudulent or otherwise illegal activities.  True and correct copies of some of these defamatory statements are attached hereto as Exhibit "H."  Part of the information forming the basis for the relief is the fact that the owner of the aboutus.org site informed Ms. Patchen that Maddox and Dickerson share the same account on aboutus.org.

shanda, you could not sue if you chose to.  why dont you tell the world HOw you could if you chose to.

you CANT because you are flat broke and dirt poor.  you cant even afford an attorney on the lawsuit currently against you so how pray tell can you come on here and say you COULD of you chose to?

just say you cant afford it.  period.  dont try to embellish your situation.  you are dirt poor.

$400-$500 per hour.  thats how much it costs.  youre into ten grand before much even gets done so please...

then the cost goes up and up and up and up....thousands of dollars..

so your solution?  you expose people?  no shanda.  you guess.  you guess at whos who.  you think "the yard" here on rip off is the plaintiff.

you think this person or that person wrote this post or that post.  while you sit there on your butt and say youre gonna expose people?  the ones that can afford to sue you will

I would think after this first lawsuit, any others dont really want to shell out thousands to shut you up but I have no doubts they will if it comes to that.  Is guessing at whats what and ragging on people online worth a few lawsuits?

Isnt there anything else you could be doing online?  you are dead wrong about what this amended complaint said and you tried to say the plaintiff thru a web site under the bus.  there are no sites mentioned on your lawsuit.
maybe a couple of them are implied, but you completely interpreted the legal documents completely wrong.  you THINK youre right and you mouth off.

there are people smarter then you at work here and youre going to get in a lot of trouble from them. true you already are, but over the last few months and especially the past few days your wild posts and unreadable cryptic messages show a state of mania.

youre wrong.  and no one has ever heard you EVER show remorse for anything.  not one I'm sorry, not one soft moment of regret.  there has been nothing.

you alone have gotten to the point of where youre at right now.  no "web site" did it.  no person did it.  just you.

shanda lancaster.  your own worst enemy.

...or where you got the notion I intend to sue anyone because I am not.  I have stated before that I COULD sue if I so chose but also that I choose not to.  Why?  It is ridiculous!  I do NOT care if people don't like me BUT I will NOT allow them to get away with bullying me without exposing them.  SO!  I exposed them.  That is MY freedom of speech as a life-long resident of The United States of America (God Bless the U.S.A.!).  My father, his brother, and their father all served in the military.  I LOVE MY COUNTRY!

So, now that we are quite clear on my stance regarding freedom of speech... let me tell you something... there is a HUGE difference in saying you don't like someone and telling ENORMOUS lies about them all over the WORLD WIDE WEB!!!!  Put yourself in my shoes, if you have them capability, and decide what you would do, alright? 

is available at this website.

Just type in 814743 at this site and it appears as 'Consumer Comment #19' at Ripoff Report #814743.

Thank You

No Shanda, YOU and Larry were/are accusing the plaintiff Ms. Patchen of committing and engaging in fraudulent or otherwise illegal activities on a web site.

You have read this document incorrectly.  Let me post the section where it states this fact.  You are continuing to make incorrect statements in public.
You are wrong.

54.      
In addition to his behavior in connection with the Singsnap Discussion Site, in or about May 2011, on information and belief, with Maddox's assistance,  Dickerson made defamatory comments regarding Ms. Patchen on public websites known as www.ripoffreport.com,  falsely accusing Ms. Patchen of being a partner or owner in a website engaged in fraudulent or otherwise illegal activities.  True and correct copies of some of these defamatory statements are attached hereto as Exhibit "H."  Part of the information forming the basis for the relief is the fact that the owner of the aboutus.org site informed Ms. Patchen that Maddox and Dickerson share the same account on aboutus.org.

Here is the entire amended complaint for people who can understand a legal document.

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
 
DIANE PATCHEN,                           
         
 
CIVIL ACTION NO.: 
11-5388
791 Midway Lane       
 Blue Bell, PA 19422,                           
           
                        
Plaintiff,                       
           
                        
v.        
                     
 
:
TREVOR MCGUIRE,                        
 
3 Spring Cress Drive                           
Nepean, ON K2R 1A8,               
         

EATSLEEPMUSIC CORP.            
           
300 Moodie Drive, Suite 405                 
Nepean, ON K2H 9C4, Canada,              

SHANDA LANCASTER MADDOX      
1523 Grab Creek Road               
        
       
JURY TRIAL DEMANDED
Dickson, TN 37055,                           
           
LAWRENCE DICKERSON,           
2040 Wheaton Way, Apt. 1A                       
 Bremerton, WA 98310,            
           
                  
and                        
           

CATHERINE           
LOUDON,     
5 Central Avenue         
Motherwell                  
Lanarkshire                 

ML1 4TE                    
 
Scotland,                     
               
          
Defendants.                                         
                             
         
SECOND AMENDED COMPLAINT
 
           
Plaintiff Diane Patchen (hereinafter "Ms. Patchen") says the following by way of a second amended complaint against defendants Trevor McGuire (hereinafter "McGuire"), Eatsleepmusic Corp. ("ESM") , Shanda Lancaster Maddox
(hereinafter "Maddox"), Lawrence Dickerson (hereinafter "Dickerson"), and Catherine Loudon ("C. Loudon").
NATURE OF THE ACTION
1.        
Ms. Patchen brings this action to obtain relief from and redress for the pattern of abusive, harassing and defamatory conduct that defendants have directed in concerted fashion toward Ms. Patchen.
2.        
This conduct has included, inter alia, coordinated defamation of Ms. Patchen on websites and other internet forums, cyberstalking, unauthorized distribution of a video of Ms. Patchen in violation of Ms. Patchen's copyrights, and other acts calculated to inflict severe emotional distress upon Ms. Patchen.

PARTIES AND JURISDICTION
3.                 
Ms. Patchen is an individual residing at 791 Midway Lane,
Blue Bell, PA 19422.
4.           
Defendant McGuire is an individual residing at 3 Spring Cress Drive,
Nepean, ON K2R 1A8, Canada.
           
5.           
Defendant ESM is a corporation organized under the laws of Canada and  having its principal place of business at 300 Moodie Drive, Suite 405, Nepean
ON K2H 9C4, Canada.
6.           
Defendant Maddox is an individual residing at 1523 Grab Creek Road, Dickson, Tennessee 37055.
7.           
Defendant Dickerson is an individual residing at 2040 Wheaton Way Apt.
1A, Washington 98310.
8.           
Defendant C. Loudon is an individual residing at 5 Central Avenue,
Motherwell, Lanarkshire, ML1 4TE, Scotland. 
9.        
This Court has original subject matter jurisdiction over the federal cause of action in this Complaint pursuant to 28 U.S.C. 1338(a), and has supplemental jurisdiction over the state law causes of action in this

Complaint pursuant to 28 U.S.C. 1367(a).  This Court also has original jurisdiction over the subject matter of this action pursuant to 28 U.S.C. 1332, in that the action is between citizens of different states and the amount in controversy exceeds the sum or value of $75,000, exclusive of interests and costs.
10.       This Court has personal jurisdiction over defendants, and venue is proper within this District pursuant to 28 U.S.C. 1391(b) because defendants directed their conduct toward plaintiffs, who reside in this district, because ESM does business in this District, and because a substantial part of the acts and omissions giving rise to the claims in this action occurred in this District.   
 FACTUAL BACKGROUND
11. In or about 2006, Ms. Patchen, who is a karaoke enthusiast, began participating in an on-line karaoke web site called singsnap.com (hereinafter "Singsnap").
12. Karaoke refers to an interactive entertainment medium in which the participants sign along to recorded music.
13. ESM owns and operates the Singsnap site.  In 2010, McGuire, who is ESM's President and Chief Executive Officer,
advised Ms. Patchen that over 40% of the approximately 1,000,000 users of the site were United States residents, and that Singsnap had users throughout the United States.  While Ms. Patchen is unaware of the exact number of ESM's customers who reside within Pennsylvania, Ms. Patchen is aware that numerous Singsnap site users resided
and continue to reside within Pennsylvania.
14. The Singsnap site allows users, inter alia, to join the site, create and display videos of themselves performing karaoke versions of songs, and to interact with other members.

15. The Singsnap site also allows users to control the number and types of members and other site users who may view or have access to the videos that they create.
16.           
Beginning in 2006, Ms. Patchen began performing services for the Singsnap site on a "volunteer" basis.  At various times, these services included serving as a chatroom administrator, assistant editor of the Singsnap newsletter, and as a member of the public relations team.  Ms. Patchen performed all of these services for ESM from her residence in
Pennsylvania, and continued providing these services to ESM through February 10, 2010.
17.  ESM provided in-kind compensation to Ms. Patchen for her work, in the form of free services relating to the Singsnap site. 

18.   In connection with her work for ESM, Ms. Patchen became acquainted with McGuire.
19.   From 2007 through February 10, 2010, Ms. Patchen and McGuire engaged in a significant on-line correspondence and personal relationship.  During this time, McGuire directed hundreds of emails and electronic "private messages" to Ms. Patchen in Pennsylvania, and also participated in a "Skype" or "voice over IP" conference call with Ms. Patchen while Ms. Patchen was in Pennsylvania.
20.   These emails and private messages involved a number of subjects, ranging from, inter alia, McGuire's commentary on the users of the Singsnap site, disciplinary actions McGuire was contemplating with respect to Singsnap site users, Ms. Patchen's work on ESM's behalf, and compliments by McGuire on Ms. Patchen's appearance. 

21.  In or about 2007, using the Singsnap site, Ms. Patchen created a video (hereinafter the "Video") showing her performing a karaoke version of a song entitled "Sexy Back" while dancing.
22.       In connection with the creation of the Video in 2007, Ms. Patchen did not agree or consent to any purported "terms of service", "terms of use", or similar terms and conditions purportedly applicable to the creation and use of the
Video. 
23.  Shortly after creating the Video, Ms. Patchen moved the Video to the private portion of her Singsnap site account. 
24.  In or about early 2009, Ms. Patchen deleted the Video from the private portion of her Singsnap site account. 

25. The Video is an original work of authorship that Ms. Patchen created, and contains copyrightable subject matter. 

26.     
Effective as of July 26, 2011, Ms. Patchen obtained a certificate of copyright registration with respect to the Video, a true and correct copy of which is attached hereto as Exhibit "A." 

27.       In connection with the creation of the Video, Ms. Patchen made no assignment of her copyrights in the Video.
28.       At no time did Ms. Patchen give anyone else permission to copy, distribute, post or otherwise display copies of the Video. 
29.       At no time prior to obtaining the certificate of copyright registration with respect to the Video did Ms. Patchen publish the Video within the meaning of the United States Copyright Act.

30.       On or about February 10, 2010, McGuire barred Ms. Patchen from further use of the Singsnap site, falsely accusing Ms. Patchen of intending to share proprietary information relating to the Singsnap site with a competitor.  
31.       Ms. Patchen subsequently became involved with another website (hereinafter, the "Singsnap Discussion Site") used by former users of the Singsnap site, and participated in the discussions about Singsnap that occurred on the Singsnap Discussion Site.
32.       In or about February 2010, McGuire, upon learning of Ms. Patchen's involvement in the Singsnap Discussion Site,
began conspiring with ESM, Maddox, Dickerson, C. Loudon, R. Loudon, and one or more additional conspirators whose identities are as yet unknown to Ms. Patchen, for the purpose of harassing, embarrassing and humiliating Ms.
Patchen, defaming Ms. Patchen, violating Ms. Patchen's copyrights in the Video, and otherwise inflicting severe emotional distress upon Ms. Patchen.
33        At the time, C. Loudon was an ESM employee, and Maddox was a volunteer working for ESM,
providing services in connection with the Singsnap site.  Dickerson was a previous user of the Singsnap site who was acquainted with Maddox and subsequently acted in concert with ESM and Maddox in connection with the distribution and threatened distribution of the Video. 

34  McGuire and the other co-conspirators committed a number of overt, unlawful acts in furtherance of their conspiracy, as set forth below.  In so acting, McGuire, C. Loudon and Maddox were acting in their personal capacities and for their own personal purposes, with the assistance of ESM, which acted by and through ESM's agents and employees.
35   On  information and belief, at the time McGuire barred Ms. Patchen from further use of the Singsnap site, a copy of the Video remained on the Singsnap site servers, designated as private and non-viewable by other users and members of the site. 
36.   Part of the information forming the basis for this belief is the fact that in 2008, after ESM had at Ms. Patchen's request purportedly deleted Ms. Patchen's account when she temporarily discontinued her use of the Singsnap site, ESM
was able to restore Ms. Patchen's content to the Singsnap site later in 2008, upon Ms. Patchen's resumption of use of the Singsnap site.
37.   On information and belief, on or about May 10, 2011, McGuire, with the assistance of one or more members of ESM's technical staff, retrieved or otherwise restored a copy of the Video from the Singsnap's servers, and provided a copy
of the Video to Maddox, who in or about April, 2011 posted the Video on youtube.com, a public website, along with a number of defamatory comments regarding Ms. Patchen. 
38.  Part of the information forming the basis for this belief is the fact that Maddox has admitted that she had created a youtube account used to comment on the Video.  This account posted the comment "I got you babe" in connection with the Video.  "Babe' was a term that McGuire used repeatedly in addressing Ms. Patchen in his various items of correspondence to her, but otherwise had no relevance to the Video.  Ms. Patchen did not discuss the fact
that McGuire used this term with others, including Maddox.  Maddox could have only learned of the significance of this term to Ms. Patchen from McGuire.  True and correct copies of the texts of Maddox's comments in connection with the posting of the Video on youtube are attached as Exhibit "B."
39.         
McGuire's and ESM's unauthorized distribution of the Video to Maddox infringed Ms. Patchen's copyrights in the Video.
40. Maddox's unauthorized posting and display of the Video on youtube.com, which on information and belief, including but not limited to the information set forth above, occurred at McGuire's direction, infringed Ms. Patchen's copyrights in the Video.
41. Maddox created an account and sent the youtube link of the Video to another public website, manthissitesucks.com, and added comments herself to the Video. 
42.  Subsequently, Maddox distributed or caused to be distributed a copy of the Video to Dickerson.  In an
on-line statement, Dickerson admitted that he has downloaded and has in his possession an infringing copy of the Video and indicated his intention to post a copy of the Video in alt.com, a so-called "alternative lifestyles" adult-oriented web site.  A true and correct copy of Dickerson's statement is attached hereto as Exhibit "C."
43.  On information and belief, beginning in or about February 2010, at McGuire's direction, the other individual defendants began to post numerous anonymous harassing and defamatory comments regarding Ms. Patchen on the Singsnap Discussion Site and elsewhere, each using numerous pseudonyms or aliases, including but not limited to "interesting", "The Banker", "Truthordare", "bugs" and "Mr. Lewis" in the case of C. Loudon, "singin' sam" in the case of
Dickerson, and "meh" in the case of Maddox, to conceal their identities. 
44.  Part of the information that forms this belief is a number of email exchanges between C. Loudon and McGuire, as well as McGuire and a person purporting to be "Ryan Loudon," occurring from June, 2010 through January, 2011.   In one email from C. Loudon to McGuire, C. Loudon references posting content regarding Ms. Patchen to the Singsnap discussion site that McGuire had authored for her.  In other emails McGuire discusses and encourages disrupting the operation of or hacking the Singsnap discussion site with "Ryan Loudon," as well as engaging in an advertising program directed toward Ms. Patchen.  Ms. Patchen obtained copies of these emails from another former user of the Singsnap site
to whom C. Loudon had previously provided the emails.  True and correct copies of the texts of these emails are attached as Exhibit "D." 
45.  In addition, C. Loudon and "Ryan Loudon" admitted to Ms. Patchen in writing that C. Loudon and "Ryan Loudon" had posted these harassing and defamatory comments at McGuire's instigation.  True and correct copies of these writings are attached as Exhibit "E." 
46.  For her part, Maddox admitted to Ms. Patchen in writing that she had also engaged in similar harassing conduct in connection with the Singsnap discussion site under numerous aliases and pseudonyms.  A true and correct copy of the text of this admission is attached hereto as Exhibit "F."
47. These defamatory comments made by defendants C. Loudon, Maddox and Dickerson on the Singsnap Discussion Site included, but were not limited to statements that Ms. Patchen was a prostitute, was dishonest and was mentally unstable, and that Ms. Patchen had threatened to blackmail McGuire.  True and correct copies of some of these statements are attached as Exhibit "G."  Numerous other similar statements have been deleted from the public portions of the Singsnap Discussion Site, but upon information and belief remain on the servers and nonpublic areas of the
Singsnap Discussion Site.
48. A number of these statements contained information about the health condition of another person, Robert Smik, including Mr. Smik's cancer and a serious leg injury, that Ms. Patchen had revealed only to McGuire in private email
exchanges.
49.  Beginning in or about February 2010, these defendants also began directing numerous harassing and offensive emails directly to Ms. Patchen. 
50. Defendants engaged in this pattern of making anonymous defamatory and harassing statements about and to Ms. Patchen for the purpose of annoying, abusing, threatening, and/or harassing Ms. Patchen.
51. In addition to constituting defamation, defendants' behavior constituted cyberstalking within the meaning of 47 U.S.C. 223 et seq.
52.  Maddox's behavior also constituted cyberstalking within the meaning of 39-17-315 of the laws of the State of Tennessee.
53.   Dickerson's behavior also constituted cyberstalking within the meaning of Chapter 9.61 RCW of the laws of the State of Washington. 
54.  In addition to his behavior in connection with the Singsnap Discussion Site, in or about May 2011, on
information and belief, with Maddox's assistance,  Dickerson made defamatory comments regarding Ms. Patchen on public websites known as www.ripoffreport.com,  falsely accusing Ms. Patchen of being a partner or owner in a website engaged in fraudulent or otherwise illegal activities.  True and correct copies of some of these defamatory statements are attached hereto as Exhibit "H."  Part of the information forming the basis for the relief is the fact that the owner of the aboutus.org site informed Ms. Patchen that Maddox and Dickerson share the same account on aboutus.org.
55.       In or about early December, 2011, without Ms. Patchen's permission, McGuire and ESM caused the Video to be displayed publicly on the singsnap site, in willful violation of Ms. Patchen's copyrights in the Video.
56.       In or about January and February, 2012, Lancaster continued making defamatory online statements regarding Ms. Patchen through various online aliases, including but not limited to statements that Ms. Patchen was "demented," "disturbed," had previously engaged in activity "bordering on illegal," was "dangerous," had filed a "frivolous" lawsuit and a "baseless, vindictive claim" as part of a "vendetta", and had engaged in conduct that was "slanderous."
57.        
Defendants engaged in all of this concerted conduct with the purpose and effect of causing Ms. Patchen severe emotional distress, and as of the date of the filing of this Complaint, continue to engage in this course of
conduct.

COUNT I - CIVIL CONSPIRACY
Ms. Patchen v. All Defendants
 
58.    Ms. Patchen incorporates the allegations of paragraphs 1 through 57 as though set forth fully herein.
59.          
Through and as part of their conduct as alleged above, defendants engaged in a conspiracy to commit numerous unlawful acts, all with the purpose of violating Ms. Patchen's rights, harassing, humiliating and embarrassing Ms.
Patchen, and causing Ms. Patchen to suffer severe emotional distress.    

60.           
Defendants committed numerous overt, unlawful acts in furtherance of their conspiracy, including but not limited to the acts alleged above.    

61.   As a direct and proximate result of defendants' conduct, Ms. Patchen has suffered damages.
62.          
Defendants' conduct was intentional, wanton, malicious, outrageous and of the sort warranting the imposition of punitive damages.  
 
WHEREFORE, plaintiff Diane Patchen demands judgment in her favor and against defendants:
          
(a)        
awarding Ms. Patchen compensatory damages in an amount to be proven at trial; 
           
(b)           
awarding Ms. Patchen punitive damages;
           
(c)            
awarding Ms. Patchen prejudgment interest and their costs of suit; 
           
(d)           
awarding Ms. Patchen reasonable attorneys' fees; and
           
(e)       
granting such other and further relief as the Court may deem just.COUNT II - INTENTIONAL INFLICTION OF EMOTIONAL
DISTRESS

Ms. Patchen v. All Defendants
63.           
Plaintiffs incorporate the allegations of paragraphs 1 through 62 as though set forth fully herein.
64.           
Defendants' conduct as described above was atrocious, intolerable, and so extreme and outrageous as to exceed the bounds of decency.
65.           
Defendants acted with the intent to inflict emotional distress, and/or acted recklessly when it was certain or substantially certain emotional distress would result from defendants' conduct.
66.           
Defendants' actions caused Ms. Patchen to suffer emotional distress that was so severe that no reasonable person could be expected to endure it.
67.   As a result of this emotional distress, Ms. Patchen suffered weight loss, post-traumatic distress, and other physical manifestations of the emotional distress.
68.           
Defendants' conduct was willful, outrageous and of the sort warranting the imposition of punitive damages.

WHEREFORE, plaintiff Diane Patchen demands judgment in her favor and against defendants:
           
(a)           
awarding Ms. Patchen compensatory damages in an amount to be proven at trial; 
           
(b)           
awarding Ms. Patchen punitive damages;
           
(c)            
awarding Ms. Patchen prejudgment interest and her costs of suit;                 

           
(d)           
awarding Ms. Patchen reasonable attorneys' fees; and
           
(e)       
granting such other and further relief as the Court may deem just.
COUNT III - DEFAMATION
Ms. Patchen v. McGuire, C. Loudon, Maddox and Dickerson

69.    Ms. Patchen incorporates the allegations of paragraphs 1 through 68 as though set forth fully herein.
70.       As alleged above, defendants made numerous false and defamatory statements regarding Ms. Patchen, including statements that accused Ms. Patchen of criminal misconduct and ascribed to her conduct, character and condition that
would adversely affect her fitness for the proper conduct of her proper business, trade or profession. 

71.           
Defendants knew that these statements were false when they made them. 
72.  These statements were not privileged and were made with malice.
73.  These statements were defamatory per se, and were also otherwise of a nature tending
to harm Ms. Patchen's reputation, lower them in the estimation of the community and/or deter third persons from associating or dealing with Ms. Patchen. 

74.  As a direct and proximate cause of these statements, Ms. Patchen has suffered damages.
75.           
Defendants' conduct was willful, outrageous and of the sort warranting the imposition of punitive damages.
       
WHEREFORE, plaintiff Diane Patchen demands judgment in her favor and against defendants McGuire, C. Loudon, Maddox and Dickerson:
           
(a)           
awarding Ms. Patchen compensatory damages in an amount to be proven at
trial; 
           
(b)           
awarding Ms. Patchen punitive damages;
           
(c)            
awarding Ms. Patchen prejudgment interest and her costs of suit;                 

           
(d)           
awarding Ms. Patchen reasonable attorneys' fees; and
           
(e)       
granting such other and further relief as the Court may deem just.
           
(e)       
granting such other and further relief as the Court may deem just.
COUNT V - COPYRIGHT INFRINGEMENT
Ms. Patchen v. McGuire, ESM, Maddox and Dickerson

76.   Ms. Patchen incorporates the allegations of paragraphs 1 through 75 as though set forth fully herein.
77.    By defendants' conduct as described above, defendants have infringed Ms. Patchen's copyrights in the Video.  

78.        
Defendants' infringement was willful.
79.  As a direct and proximate result of defendants' conduct, Ms. Patchen has suffered damages.
80.  Prior to obtaining a certificate of copyright registration with respect to the Video, Ms. Patchen did not publish the Video within the meaning of the United States Copyright Act, 17 U.S.C. 101 et seq.
81.  Upon information and belief, defendants are continuing to infringe Ms. Patchen's copyrights in the Video by, inter alia, copying, displaying, distributing and/or selling copies of the Video without Ms. Patchen's authorization, and in
the absence of an injunction prohibiting defendants from doing so, intend to and will continue to do so in the future. 

    WHEREFORE, plaintiff Diane Patchen demands judgment in their favor and against defendants McGuire, ESM, Maddox and Dickerson:
           
(a)           
awarding Ms. Patchen an amount equal to Ms. Patchen's actual damages and any additional profits of defendants, or in the alternative, statutory damages pursuant to 17 U.S.C. 504;
           
(b)           
awarding Ms. Patchen prejudgment interest and her costs of suit;                 
           
(c)           
awarding Ms. Patchen reasonable attorneys' fees;
           
(d)           
preliminarily and permanently enjoining defendants from infringing Ms. Patchen's copyrights in the Video;
           
(e)           
requiring the impounding and destruction of all infringing copies of the Video and of all articles by means of which infringing copies of the Video may be reproduced, pursuant to 17 U.S.C. 503; and
           
(f)        
granting such other and further relief as the Court may deem just.

Unless the United States Constitution was wiped out overnight, it is still the basic right of Americans to publicly express their thoughts and opinions about anything or anyone they choose.  There is nothing fraudulent nor illegal about it! You can't sue people just because they don't like you or your activities and say so. Oh, you can try but it will be laughed out of court.

...Kit.  You tell me not to trust other people?  I think you should take you own advice.  Yes, some people have pretended to be me and have said foul things to make me look bad.  I think if you listened to your own heart you would realize I am not a bad person.  Meet me on SingSnap.  Ask people on my faves list about me.  Hell, ask people who have flagged me!  You are not going to get negative feedback about me from those people.  This whole mess started because I DID THE RIGHT THING.  The one's who hate me and say negative things about me have listened to hearsay from one person with a huge grudge.  I see people who hate me say I've 'been sued numerous times'.  NO.  One time and THAT is frivolous litigation.  If you are the person I contacted on SingSnap, come forth and tell me the truth.

Read the document.  It is the last on the docket and you will see MTSS referenced  in #54 of the second amended complaint.  "a website engaged in fraudulent or otherwise illegal activities".  This is how you all are thought of, not only by me, but also by the plaintiff in this case.

@Sue/Kit:

A smear campaign has been run against me, SingSnap, and Mr. McGuire by the website Man This Site Sucks.  When the person/people who launched these complaints used the name Man This Site Sucks it was ALL INCLUSIVE.  So, like it or not, you, as a member, are included.  If you don't like it, I suggest you speak with the owner of MTSS; it is that person who should be held accountable, not me.

If you are honestly a good person, Kit, I highly recommend you break ties with MTSS.  I appreciate the fact you spoke out in your own name and respect you for defending yourself (I know what that is like!).  The company you are keeping IS DANGEROUS.

Shanda

Shanda,

This is Kit.  Legal name is Susan but everyone in my family and all  my friend call me Kit.  I go by karaokesue on mtss and several other sites online.

I have pretty much read to date all that has been going on but I would say I'm sure I've missed chunks here and there.

To be honest, I do not appreciate you referring to me as a disposable person.  I dont know you.  I've never interacted with you while I was on singsnap.  I left singsnap because my husband said we had to choose one singing site only so we went to the Kc, but there were other reasons too. I joined manthissitesucks because I can exercise my freedom of speech.  I'm an independent person and would never allow myself to be stifled in any way.

the facts as I know them are you were banned from the forum more then a year ago.  youre on some mission to post all over the net about the forum and you group ME in there with everyone else.  completely unfair.

please stop.

first of all you cannot sue someone within someone elses lawsuit.  you also cannot sue this forum.  It is not a business.
five people worked to start it back in 2010 from what I remember.  I was gonna help but cant because I work too many hours. I also dont see any member that has singled you out and has cause you to lose a job nor to my understanding no member has ever trumped up anything at all for you to gather up enough for any type of personal civil lawsuit.
If you have a beef with one person or two, you need to sue them and not continue to insult me and the other members.  I know that the members list cannot be seen by non members but there are cached pages that show up from the bots and my user name appears associated with posts here and there.

I have never done nothing to you and Im sorry, but if you act like an a*s, I am entitled by my rights to discuss it on an open forum in public and so is everyone else.  there is nothing legally you can do about it. If people want, they can call you every name in the book from now until doomsday and theres nothing you can do about it.  im sorry but that is the way it works.

Now you can as well, but youre not someone like me right now.  You HAVE been sued and its an ongoing open case right now.  Why are you hurting yourself like this?  and please dont come back on here just to insult or yell at me or accuse me of this or that ok? Im asking a fair question.

I wont say you specifically, but one or more of the defendants actually posted comments about the judge in the case having homosexual relations with one of the plaintiffs.  I cant even print exactly what was said because it was so filthy and disgusting. I was shocked.  No other way to describe it.

Since I dont run in your circle I dont know whats going on on your end as far as conversations, pms and emails but even though you dont know me from Adam, please consider trusting no one.

Please dont count on anyone else but yourself, ok?

Don't trust anyone and try to understand my meaning.  Just take care of your own legal things and dont listen to anyone except if you get your own legal counsel. I fear for you.  I really do. You can tell me to go to hell or whatever but at the very least please consider what I said about trust.  Think about it.  Maybe ask your parents or someone in your family you know wouldnt let you down or use you for help or advice.And please dont lump me or the rest of the members in with everyone else.  Its a dumb forum but that dumb forum IS allowed to post opinions and thoughts about what they view online or on tv or in the movies.

A lot of members have commented on your posts over the last year.  If you put it out there, no one is allowed to say anything?  If you trespass with proxies, no one is allowed to be po'd because of it?  If you say that person is ugly or whatever else, you should expect a comment back?

A forum is not involved in your lawsuit.  your lawsuit is because of something that was done to one person.  just because that person has posted on the forum before doesnt mean you can attach the forum into your mess.  Youre completely unfair, so please stop.

Kit, is not disposable.

Very interesting. Especially since MTSS and its members are not and never have been a part of the lawsuit against you. Nor is there any such mention on the latest Pacer documents. Sounds to me like someone is feeding you a line of b.s.

I do want to make you all aware that you should visit pacer to view the attached exhibits for the most current document.  Just as I figured, MTSS and its members are 'disposable'.  It may take you awhile to read everything but it's there and you've all been thrown under the bus.  Don't say I didn't warn you. 

uh!  dont you just HATE it when someone doesnt give you the link to sumthing???

anywho, you shouldnt make a 14 min long video. snoreeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeee fest!

oh and black and white are so not your colors, but moving right along.  you said your iq is 127?

lol

but youre stupid enough to call this acct on youtube all haters suck, just like the title of the acct that uploaded the video youre being sued for right now. lol

now, darlin, how smart was that???

lordy, if youre so d**n genious why dont you go sit at a piano and write some music???

Shanda, I just watched your latest video. Are you out of your mind?! Have you ever taken a good look in the mirror or examined your own behavior?? Your actions fit every single one of the categories listed in that article. All of which has also been documented by many. You really need to practice what you preach, lady!

I have a brand new video recorded.  YouTube username ALLhatersSUCK  Enjoy.

The information in my videos is 100% accurate and I stand behind it 100%.  Expect more videos from me in the future.  I'm taking off my training wheels and my next videos will be scripted.  I may be inclined to use screenshots in some of them as well.  There is nothing more telling about a hate site that a screenshot (or a hundred of them).  If you want accuracy and truth you are about to get it.  Be careful what you ask for!

I have made NAMI and ADL aware of your site so we will see over the course of time how well your smear campaign against me pans out.  From here on out I suggest you tread very carefully when you sit down to your computer keyboard.

The site you speak of at no where at any time even remotely puts "bullycide" blame on another individual.

You mention in your video that "too many people hide behind fake names".  ARE YOU KIDDING ME MS LANCASTER?

That's ALL you do. 

If you continue to post videos and or make comments giving out false information I will post every single fake user name you have used right here on this report along side copies of posts made by you using those names, followed by copies of YOU as yourself Shanda Lancaster being outed as to using all those numerous fake user names, followed by all current locations and links where you can be found using your OWN name to harass others.

If it takes an entire day, or two, or three or a month, I will post all of it here.

Do NOT EVER tell anyone that the result of a suicide is because of another person. 

That report Ms. Lancaster isn't even referring to suicide, not is that entire web site about adults.  It is about children.  Children who are young and underage.  They even renamed the word suicide to "bullyside" to reflect the difference.
Your video seriously bleeds the childs world with the adult world and you are using this CRAP to further your own agenda about your own sorry life.  Do you care?  No.  You started this anti-hate, anti-bully campaign only after you were sued for the very same thing in a federal court.  (Case is ongoing and currently active.  Please Google Shanda Lancaster for all information)

Anyone will agree that children should not be bullied but it has gone on since the beginning of time.  There are childhood bullies in all our lives.

This site talks about children ONLY.

They say the act of bullying can lead to a child taking his own life.  You're making statements and should not be.  You have no authority, no degree and you're mentally ill.  You should not be handing out information.  "rippedoff" from auburn is correct.  What you did could be dangerous.

Your sad adult life is not part of this anti bullycide world.  Ms. Lancaster, you ARE one of these people.  You're just a grown up bully.  A full grown adult bully that has done exactly the very things you list in your recording.  The numerous fake names.  The harassing posts.  The mindless jealous filled ridiculous insults that go nowhere.

The adult world is different from underage children.  You have zero rights speaking "out" about this very thing when you are currently engaging in the act itself.

Keep it up and you will be dogged for the rest of your miserable life.  Every hate filled post by you and your endless fake nicknames will be posted in public numerous times and often.

I doubt your children know the extent of what you do.  If they did, they would be humiliated and horribly ashamed.  Do not come back and threaten me or anyone else posting here or anywhere else.  Nothing you say matters.

Just so we're crystal clear.

I would suggest that anyone reading this Google Shanda, read the hundreds of posts to, from and about her, and then decide for yourselves if she's mentally stable enough or credible enough or educated enough to be making pronouncements about others and their motives.

So sue me...:o)

Blaming others for a person's suicide IS false information. The only one to "blame" is the person themselves......killing themselves is THEIR decision. Any psychiatrist will tell you that blaming others is unacceptable doctrine. For you to try to lay a guilt trip on someone who knows a suicide victim and/or may have had a disagreement with them or a loving friend/family member who would do anything they could to have stopped them, is despicable on your part. You aren't a psychologist or psychiatrist and certainly not qualified to make such statements. Your alleged "almost drove me to suicide" remarks are nothing but narcissistic, attention-seeking comments. When you don't know what you're talking about, you really should shut up...... these comments are dangerous to others.

Are you saying, REALLY, that a site dedicated to studying hate, bullying, and cyberbullying is FALSE information?  I read straight from their website.  Go their yourself, maybe you will learn a thing or two.  I clearly stated at the beginning of my video where I got my statistic information from and that I would be adding my own 'thoughts and opinions' to the content.

As for being 'high as a kite'?  NO.  If you think you can prove otherwise, please, do so.  Until then, shut up with the LIBEL.

For anyone interested in viewing all my videos, you can find them on YouTube under the name ALLhatersSUCK.  If you hear false information, please, leave a comment or send me a message and I will make corrections.

Mrs. Shanda Lancaster
Dickson, TN