JOHN RAMSEY and PATSY RAMSEY, )
)
Plaintiffs, )
)
v. )
)
STEVE THOMAS, DON DAVIS, )
ST. MARTIN'S ENTERPRISES, INC., )
SMP (1952), INC., doing business as ) CIVIL ACTION FILE
ST. MARTIN'S PRESS and )
ST. MARTIN'S PAPERBACKS, ) NO. 1:01-CV-0801
and UNKNOWN OFFICIALS OF THE )
CITY OF BOULDER, COLORADO )
POLICE DEPARTMENT, including, )
but not limited to, OFFICER JOHN DOE 1, )
OFFICER JOHN DOE 2, OFFICER )
JOHN DOE 3 and OFFICER JANE DOE, )
)
Defendants. )

COMPLAINT FOR LIBEL, SLANDER,
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AND 42 U.S.C. § 1983 DEPRIVATION OF CONSTITUTIONAL RIGHTS

COME NOW Plaintiffs, John Ramsey and Patsy Ramsey, and state their Complaint for Libel, Slander, Intentional Infliction of Emotional Distress and 42 U.S.C. § 1983 Deprivation of Constitutional Rights against Defendants, Steve Thomas, Don Davis, St. Martin's Enterprises, Inc., SMP (1952), Inc., doing business as St. Martin's Press and St. Martin's Paperbacks, and Unknown Officials of the City of Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, as follows:
JURISDICTIONAL STATEMENT
1.
Plaintiffs John Ramsey and Patsy Ramsey (hereinafter collectively "Plaintiffs John and Patsy Ramsey") are individuals who reside in Atlanta, Georgia.
2.
Plaintiffs John and Patsy Ramsey are citizens of the State of Georgia for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
3.
Defendant Steve Thomas (hereinafter "Defendant Thomas") is an individual who resides at (ADDRESS REMOVED BY WEBMASTER)
4.
Defendant Thomas is a citizen of the State of Colorado for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
5.
Defendant Thomas is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.
6.
Defendant Don Davis (hereinafter "Defendant Davis") is an individual who resides at 6350 Modena Lane, Longmont, Colorado.
7.
Defendant Davis is a citizen of the State of Colorado for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
8.
Defendant Davis is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.
9.
Defendant St. Martin's Enterprises, Inc. is a corporation organized and existing under the laws of the State of Delaware with its principal place of business being located at 175 Fifth Avenue, New York, New York.
10.
Defendant St. Martin's Enterprises, Inc. is a citizen of the State of Delaware for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
11.
Defendant St. Martin's Enterprises, Inc. is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.
12.
Defendant St. Martin's Enterprises, Inc. can be served with summons and complaint by service upon its registered agent, St. Martin's Press, Inc. Attn: General Counsel, at its registered address, 175 Fifth Avenue, New York, New York 10010.
13.
Defendant SMP (1952), Inc. is a corporation organized and existing under the laws of the State of New York with its principal place of business being located at 175 Fifth Avenue, New York, New York.
14.
Defendant SMP (1952), Inc. is a citizen of the State of New York for purposes of diversity jurisdiction under 28 U.S.C. § 1332.

15.
Defendant SMP (1952), Inc. is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.
16.
Defendant SMP (1952), Inc. can be served with summons and complaint by service upon its registered agent, The Corporation Attn: Legal Department, at its registered address, 175 Fifth Avenue, New York, New York 10010.
17.
Among other corporate activities, Defendant St. Martin's Enterprises, Inc. and Defendant SMP (1952), Inc. (hereafter collectively "Defendant St. Martin's Press") own and operate a book publishing company known as St. Martin's Press and St. Martin's Paperbacks.
18.
Defendant St. Martin's Press publishes, distributes and sells hardback books and paperback books throughout the nation on a regular basis, including the State of Georgia.
19.
Defendant St. Martin's Press regularly does or solicits business in the State of Georgia and engages in a persistent course of business conduct in the State of Georgia, deriving revenue from hardback books and paperback books regularly distributed and sold in the State of Georgia.
20.
Defendant Officer John Doe 1, a Boulder, Colorado police officer or official, is a citizen of the State of Colorado for purposes of diversity jurisdiction under 28 U.S.C. § 1332. His identity is presently unknown, but it will be uncovered during discovery in this litigation at which time, service of process can be perfected upon him.
21.
Defendant Officer John Doe 1, is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.
22.
Defendant Officer John Doe 2, a Boulder, Colorado police officer or official, is a citizen of the State of Colorado for purposes of diversity jurisdiction under 28 U.S.C. § 1332. His identity is presently unknown, but it will be uncovered during discovery in this litigation at which time, service of process can be perfected upon him.
23.
Defendant Officer John Doe 2 is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.
24.
Defendant Officer John Doe 3, a Boulder, Colorado police officer or official, is a citizen of the State of Colorado for purposes of diversity jurisdiction under 28 U.S.C. § 1332. His identity is presently unknown, but it will be uncovered during discovery in this litigation at which time, service of process can be perfected upon him.
25.
Defendant Officer John Doe 3 is subject to the jurisdiction of this Court pursuant to O.C.G.A. § 9-10-91 with proper venue pursuant to 28 U.S.C. § 1391.