September 18, 2023, ORLANDO, FLORIDA. On September 14, 2023, Plaintiffs Heath Ritenour (“Heath”), John Ritenour (“John”) and Insurance Office of America, Inc. (“IOA”) filed a Notice of Production from Non-Party in a case they filed in Seminole County, Florida in March 2020 (“2020 Case”) against Louis Spagnuolo and others alleged to have damaged their purported “impeccable” reputations.
On September 18, 2023, Spagnuolo filed an Objection to the September 14 Notice of Production (“September 18 Objection”) stating and arguing that the attempt to Subpoena a Third-Party should be denied. Spagnuolo also seeks to recover attorney’s fees and costs associated with this particular dispute as sanctions for “bad faith discovery” conduct. This Objection, which is quoted below from the Court filing, has not been ruled upon or heard at a public hearing as of the time of this announcement and the Court may overrule Spagnuolo’s Objection in whole or in part.
Quoting directly from Spagnuolo’s September 18 Objection where Spagnuolo is making his arguments based upon his legal position: “Plaintiffs Heath, John and IOA’s September 14 Notice of Production to Non-Party LinkedIn Corporation follows their September 1, 2023, Notice of Production from Non-Parties. For purposes of context of Spagnuolo’s Objections which follow, this lawsuit was filed for a number of fraudulent purposes and schemes.”
The September 18 Objection continues stating: “Each one of these malicious intentions were implemented by Heath, John, IOA and others to accomplish their goals of weaponizing this fraudulent lawsuit to, inter alia: (1) white-wash their illegal and wrongful conduct, such as stealing millions of dollars from Spagnuolo through a pattern of regularly conducted activities of mail fraud and wire fraud; (2) intimidate through the use of frivolous retaliatory litigation sending a clear message of the lengths they will go to in order to punish those who sue them; (3) to prevent the lawful investigation as to Heath, John and IOA’s claims in this lawsuit, as well as, the prosecution of Spagnuolo’s claims against Heath, John and IOA; (4) to disseminate the complaint in this case to numerous individuals and entities and engage in private conversations wherein Heath and IOA defame and discredit Spagnolo; and (5) use the “General Allegations” of their lawsuit as a platform to set forth their defenses to their illegal conduct and proverbially rewrite history.”
The September 18 Objection further states that after the Fifth District Court of Appeal substantially overturned an injunction order: “Spagnuolo resumed his lawful right to investigate and obtain information through published announcements seeking information and otherwise his First Amendment Rights to report as to the status of this lawsuit and others in which Spagnuolo is a Plaintiff.”
The Objection continues: “In response, Heath, John and IOA, through the filing of the September 1 Notice of Production and the September 14 Notice of Production, have revealed their latest fraudulent and malicious schemes under the guise discovery requests, those being – to target companies who issue publications for legal counsel, as well as, LinkedIn Corporation to interfere, harass and intimidate not only Spagnuolo, but third parties who have no notice that Heath is going after their LinkedIn Accounts.”
The September 18 Objection argues: “…the discovery was drafted so egregiously and intentionally malignant that, for example, the Request itself states: “Private Messages (ideally all messages, but we can modify the scope if there is pushback).” This is the very definition of bad faith discovery where it is sent out so knowingly overbroad such that “pushback” is anticipated in the actual language of the of Request.”
Spagnuolo’s September 18 Objection further states: “It is sadly ironic that Heath, John and IOA demanded an order preventing Spagnuolo from allegedly “interfering with their relationships,” but now are unapologetically and maliciously seeking to obtain ALL of the third parties’ very personal information including, but not limited to: (1) email addresses, (2) profile photos, (3) billing information (which would include credit card information); (4) personal addresses; (5) personal phone numbers; (6) their LinkedIn search history; (7) all of their “private messages”; (8) list of all followed accounts (meaning who these third parties associate with) and (9) their purchase history.”
Spagnuolo’s Objection also states: “…it should shock the conscience of this Court that Heath, John, IOA and others believe this invasion of individual privacy and seeking unmistakably overbroad discovery would be tolerated, especially, without due process of law for these non-parties. At the same time, unfortunately, it should come as no surprise that Heath, John and IOA believe that this lawsuit’s province is so grand that nothing is off the table where these proceedings have consistently acted as both a shield and a sword.”
If you have any information relative to any of the above allegations in the 2020 Case pending in Seminole County, Florida against Spagnuolo, or as to the character and reputations of John Ritenour, Heath Ritenour or Insurance Office of America, please contact us at email@example.com. You may also contact us at 954-252-9818 and are under no obligation to provide your name or contact information on a confidential basis. All communications will remain confidential unless otherwise permitted by federal or state law, rules of procedure, evidence or Court order.
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