More from another file:
“2. Upon information and belief, Kanarek is not a resident of Morris County, New Jersey but, rather, lives a transient lifestyle in which she resides in many locations including, but not limited to , from time to time, Morris County, New Jersey. 3. Kanarek has a criminal history which, upon information and belief, includes a charge and/or conviction for criminal assault. 4. Kanarek has a history of illegal drug use including, upon information and belief, heroin. 5. Kanarek has a history of tortious and/or criminal, antisocial behavior, including but not limited to stalking; bullying; threats of harm, injury, and mayhem against persons she chooses to target; threats against public figures; gaslighting; fraud; false reports; and other behaviors which are harmful, injurious, and destructive to the people she victimizes. 6. Upon information and belief, there is a dozen or more families, persons and businesses in the United States who were victimized by Kanarek through abuse, stalking, crime, and/or other forms of serious abuse, prior to August 2019 when Kanarek turned her sights upon Barisone. 7. At all times relevant hereto, Kanarek was and remains a significant user of various forms of social media including Facebook through which, upon information and belief, Kanarek has more than 10,000 Facebook “Friends,” messenger communication contacts, chats, and like online activities (collective, whether on Facebook and/or other platforms, “Facebook”). 8. For purposes of causing personal injury to Barisone, his business, injury to his good name and reputation, and/or injury to the like interests of Barisone’s girlfriend and other people close to Barisone (collectively, the “Barisone Family”), Kanarek perpetrated a campaign against Barisone and the Barisone Family, which included, without limitation, Kanarek’s utilization of Facebook to publish, promote, and disseminate statements, accusations, and falsehoods that were explicitly threatening; explicitly and/or implicitly threatening injury and violence; causing the subject to be stalked; causing the subject to be bullied; harmful; deceptive; deceitful; false; causing the subject serious and severe emotional pain and distress; harming the subject’s good name and/or reputation; causing the subject to be “destroyed”; harming the subject’s family and friends; and/or that otherwise were grossly inappropriate, harmful, and/or injurious. 9. At all times relevant hereto, Kanarek’s purpose was to cause injury, pain, distress, and upset of a severe and significant nature. 10. At all times relevant hereto, Kanarek’s acts, actions and omissions were perpetrated maliciously, intentionally, recklessly and/or negligently. 11. At all times relevant hereto, Kanarek’s wrongful acts, actions, and omissions included, for example, making false accusation of child abuse, false accusations of animal abuse, false accusation of insurance fraud, false reports to agencies providing child-protective-services, and other falsehoods through which her intention was to cause harm. 12. For example, Kanarek harassed Barisone by utilizing technology to “bug” (i.e., unlawfully eves drop) upon private conversation Barisone was having; and/or, alternatively, harassed Barisone for purposes of causing him severe and significant emotional distress by claiming that she had unlawful eves-dropping of Barisone’s residence and/or business for purposes of stalking him and Barisone Family members. 13. As another example, Kanarek threatened physical violence and harm by and through her internet posting that her “weapons [were] hot” (a phrase indicating that she had a firearm, loaded with ammunition, and its chamber hot) and she was coming for Barisone and/or Barisone Family members. 14. At the time she made that threat, Kanarek was known to be familiar with firearms, to have claimed and/or actual access to a firearm, and to have used a firearm in the past for purposes of shot at her boyfriend and/or his motorcycle while she was in a fit of rage. 15. At all times relevant hereto, Kanarek had a duty to Barisone and the Barisone Family members to refrain from stalking, harming, harassing, threatening, threatening-with-violence, demeaning, injuring, and/or damaging the persons Kanarek was victimizing (including, most notably, Barisone). 16. At all times relevant hereto, Kanarek materially breach her duty(ies) to Barisone and the Barisone Family members, through the acts, actions, and omissions referenced above. 17. As a direct and proximate result and consequence of Kanarek’s wrongful acts, actions, and omissions, Kanarek cause injury to Barisone including but not limited to: (a) placing him in fear for his life and physical wellbeing; (b) placing him in fear for the lives and physical wellbeing of Barisone Family members; © placing him in fear for the lives and physical wellbeing of Barisone’s business staff, clients and the horses owned and/or boarded by Barisone at his dressage farm; (d) emotional distress, including emotional distress with physical manifestations; (f) traumatic stress; (f) emotional breakdown; (g) post-traumatic stress; (h) battered-person-syndrome; (i) psychiatric ailments and eventual breakdown; (j) destruction of his state of mental peace, tranquility, enjoyment and stability; (k) injury to his business; (l) injury mental state; (m) unlawful invasion of his privacy; (n) property damage; (o) irreparable harm; § financial harm; (q) physical harm; and ® other injuries.”
Above from LCV2020428787
