Hodges v. McGough Enterprises LLC

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK penne eee eee eee eee K JAMIE HODGES, Plaintiff, -againstMCGOUGH ENTERPRISES LLC, individually and d/b/a MCGOUGH ACADEMY, and MEAGAN MCGOUGH, individually, Defendants. penne eee ence K Index No.: 23 CIV 05016 (NSR) URGENT MOTION FOR INJUNCTIVE RELIEF AND GAG ORDER Plaintiff, Jamie Hodges, respectfully moves this Court for an order granting an immediate injunction against the defendant, Meagan McGough, to prevent her from engaging in any direct or indirect contact with the plaintiff, the plaintiff's family members, or third parties regarding the ongoing litigation in this matter. In support of this motion, Plaintiff states as follows: 1. On October 9, 2023, the defendant, Meagan McGough, sent a message to Plaintiff's mother, which was insulting, harassing, and personally degrading to both the Plaintiff and his mother. This communication constitutes harassment under New York law. The court in People v. Shack ( 86 N.Y.2d 529, 1995 ) held that repeated, unwanted communications with the intent to harass or annoy can be sufficient to justify injunctive relief. Defendant's actions clearly demonstrate an intent to intimidate and cause emotional distress. This is found at Exhibit 1 below. 2. Defendant has engaged in a pattern of defamatory conduct. Through her ‘anonymous’ Instagram account under the handle 'tattle_trebles,’, McGough has made false and defamatory statements about the Plaintiff and other individuals, specifically with the intent to damage Plaintiff's reputation. This included posting of an email from previous counsel of which only her and plaintiff were in receipt of. This private (and privileged) email was SDNY UMENT FILED posted with the defendant knowing the judgement was overturned on appeal. They were also aware that this same woman was found guilty of defamation, with it also deliberately misconstruing how counsel was outlining the worst case scenario in this, and was posted to make it appear that it was a fact. Under Rosenberg v. MetLife, Inc. ( 8 N.Y.3d 359, 2007 ), New York courts have held that defamatory statements made in bad faith and with malicious intent can support claims for injunctive relief. This post is found in Exhibit 2 below. 3. The ongoing harassment through both direct messages and defamatory public statements constitutes an abuse of process and an attempt to interfere with the legal proceedings in this matter. In Murry v. Gelber ( 870 N.Y.S.2d 378 , 2008), the court granted an injunction to prevent further harassment and public defamation, recognizing that such actions have the potential to significantly prejudice court proceedings. 4. Plaintiff further requests that the Court issue an immediate order enjoining the Defendant from contacting Plaintiff, Plaintiff's family members, or third parties regarding the case, directly or indirectly, and from making any public statements, including on social media, which are intended to defame, harass, or otherwise damage the Plaintiff. 5. Courts have routinely granted injunctive relief in cases where there is a clear pattern of harassing or defamatory behavior, particularly where the conduct is intended to disrupt court proceedings or cause emotional harm. In People v. Louis ( 9 A.D.3d 725, 2004 ), the court acknowledged the need for injunctions to prevent ongoing harassment and protect the integrity of the legal process. WHEREFORE, Plaintiff respectfully requests this Court immediately grant: A. An immediate injunction against Defendant, prohibiting all forms of direct or indirect contact with Plaintiff, Plaintiffs family, or third parties regarding the litigation; B. A gag order preventing Defendant from making public or private statements regarding this case on any platform; C. Such other and further relief as the Court deems just and proper. Respectfully submitted, Pro se Plaintiff's application for a Temporary-Restraining Ord , is denied without prejudice to renew due to pro se Plaintiff's failure to comply with Federal Rules of Civil Procedure Rule 6 fry The Clerk of Court is kindly directed to maila copy of this Endorsement to the pro se Plaintiff at the address listed on EC to show service on the docket, and to terminate the motion at Dated: October 10, 2023 ECF No. 54. #C401, 42 Sirirat Rd Dated: October 11, 2024 nay Phuket, Thailand 83150 White Plains, NY KO pdb LAAMTITIQLOALE —— < Meagan McGough @ https:// lapps.courts.state.ny.us/ nyscet/ViewDocument? doclIndex=yNXGwkwaaEE pbH6Jv4smmNw== Page 9 of the document Is particularly informative on the now confirmed affidavit claiming deceit from your son from his ty own legal counsel in NY. Outright lies, false claims, gaslighting, and extortion with no remorse on how it would affect others or my family. I'm sure you're a very proud Mum. If you accept, Meagan will be able to call you and may see info such as your Active Status and whan vorr\ya raad maccanac TATTLETREBLE < Posts Follow tattletreble eee Oper tor our 2 pm Can today, | ask that you The German judge has please read the highlighted written a devastatingly bad : decision, portions of the newly minted attached German court decision from April 2020, RAEN Nwnnae EOOSIOM his elon ECCI will make Jamie very unsympathetic to any jury, One of the many dead! even if we survived the y y motions to dismiss and conclusions by the German aliies summary judgment that will juage: LECCCON be filed. Jamie will be seen as a player, and as admittedly going out for drinks with younger female students. LOCC Jamie is extraordinarily ROCCE handsome, and the jury will hate him. The beautiful white male predator. LECCEEEEEEC OY What matters is that Jamie is dead in front of a New York Ree, ae QV ° 56 likes tattletreble Jamie Hodges - Part 1.» 9 hours ago