ELSON DEBARROS, CASE NO:
YOU FLOWER, ROBYN FONTAINE
DEFENDANT
NOTICE OF ACTION
Elson m DeBarros, am 39 from Cape Verde island, with the address 43 French street Pawtucketri 02860. I have been living in Cape Verde Island for 20 years, with no criminal records, I went to high school in Dorchester and i have been working as a chef for 16 years. Hereby files this COMPLAINT against the Defendant, YOU FLOWER ROBYN FONTAINE, LLC-143 Mill Rock Rd E, Old Saybrook, CT 06475, for DEFAMATION, LIBEL SLANDER, ALSO, NEGLIGENCE, PAIN SUFFERING per C.G.S.A. 52-91 AND 52-572. The wanton actions of the Defendant have damaged the life, reputation, and earning potential of the Plaintiff; and the damage number is 200 and the emotional distress is current and ongoing toward an unforeseeable end. The Plaintiff seeks compensatory and punitive damages in the amount of $100,000. The Statement of Facts is as follows:
On July 4th, 2016, the Plaintiff ordered a bouquet of flowers with an attached private note for one Ms. Susan C. Redmond for delivery to, at: Family Practice Group, 11 Water Street Arlington, MA 02476(See Exhibit A) from fromyouflowers.com, the website of the email, which was acknowledged by the Defendant (See Exhibit B), the Plaintiff expressly requested that no one else was to receive the order except the intended recipient. On the following day, the order was delivered with the private note to a fellow employee of the intended recipient, which caused a legal and reputational backlash upon the Plaintiff. The bouquet and private note were broadcasted to the office and reached the manager, which in turn led to a criminal complaint which has cost the Plaintiff attorney fees, court fees, along with loss of wages and quality of life and reputation. The relationship between the Plaintiff and the intended recipient is forever damaged and the mental anguish and suffering is ongoing, without foreseeable end because of the defamation, libel slander, also, negligence, and pain suffering actions of the Defendant.
De Barros V. From You Flowers, LLC Case No:
WHEREFORE, Plaintiff seeks punitive and compensatory damages totaling $100,000 for the DEFAMATION, LIBEL SLANDER, ALSO, NEGLIGENCE AND PAIN SUFFERING of the Plaintiff of and by the Defendant. The Plaintiff faces criminal charges as a result of the Defendant’s actions, and the costs associated with such; as well as the mental and emotional anguish caused by the Defendant, and the loss of quality of life, wages, and reputation of the Plaintiff caused by the Defendant. The Plaintiff should recover the damages so submitted in this COMPLAINT. It is so prayed.
De Barros V. From You Flowers, LLC Case No:
UNNOTARIZED OATH
I do hereby swear, under oath, that the foregoing COMPLAINT is true and correct and does not seek to duplicate any previously made COMPLAINT. I further swear that I understand the English language.
______________________
Elson De Barros
43 French St
Pawtucket, RI 02860