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Edward Allan Buck Plaintiff v. Cesar Parra, Michael C. Davis, Kathleen Riley, Stephen Kiront, Barry Kiront, David Schrager, Defendants.

No. 2:13cv00343

U.S. Court District of Utah, Central Division

Plaintiff, Edward Allan Buck, [Herein after referred to as the Plaintift] alleges as follows:

JURISDICTION

1. Jurisdiction is proper in this Court according to: Jurisdiction 28 USC 1337
2. Plaintiff is a resident of the State of Utah and operates a professional horse/rider education
business known as Sympathetic Horsemanship
3. Defendants Cesar Parra and Kathleen Riley are residents of the State of New Jersey
4. Defendant Cesar Parra operates the business known as Piaffe Performance, located at the farm
known Performance Farms, which is also his residence, Performance Farms
Whitehouse Station, NJ 08889
5. Defendant Cesar Parra operates the business known as Piaffe Performance and

(also called Windsong Way) Jupiter, FL 33478
6. Defendants Cesar Parra, Stephen Kiront, Barry Kiront, and David Schrager are officers and
promoters for Defendant Apex Stables International, Inc., which is incorporated in Delaware and
headquartered at Performance Farms 14 Shade Lane Whitehouse Station, N.J. 08889
7. Defendant Michael C. David is a resident of the State of Massachusetts and is the financial backer
of Cesar Parra. Defendant Michael C. Davis is the owner of Panapesca USA with offices

located at 42 Winter St., Ste. 7, and Pembroke, MA 02359, resides in Harwich Port, MA and maintains an
address at 14 Shade Lane Whitehouse Station, N.J. 08889

NATURE OF COMPLAINT

8. Plaintiff mailed on February 7, 2012 to Hunterdon County Sheriff, a complaint against Defendant
Cesar Parra
for “Extreme animal abuse arising from deceptive trade practices and fraud.” Plaintiff
filed complaint against Mr. Cesar Parra for the wanton disregard of the safety of a horse under NJ
Statute 5: 15-1-12 and under NJ Statute Title 4, Chapter 22, Article 2, 22-179 Cruelty in general (a)
torture, unnecessarily abuse, and NJ Title 56, Chapter 8, Section 1 Deceptive trade practices for
misrepresenting services to be rendered.
9. Plaintiff filed the complaint against Defendant Cesar Parra predicted upon the ethical and legal
standards for horse ‘trainers’ under care, custody and control and the legal standards of businesses
practices.
10. Plaintiff filed the complaint against Defendant Cesar Parra in order to protect the health and
welfare of any horses under his care, custody and control.
11. Plaintiff filed the complaint against Defendant Cesar Parra in order to protect the reputation of the
horse ‘trainer’ industry.
12. Plaintiff filed the complaint against Defendant Cesar Parra in order to bring it to the public and
equine industry attention that a horse had been tortured and abused by Defendant Cesar Parra, a
member of the United States Equestrian Federation, the United States Equestrian Team, and a
member of the Federation Equestre lntemationale.
13. Plaintiff filed complaint predicated upon image and video presentations on Facebook that showed
the injuries to a horse owned by Trudy Miranda named William PFF. In the complaint the
Plaintiff stated: “On June 6th, 2009, Mr. Cesar Parra did ‘willfully, intentionally, and knowingly’
cause the near death of a horse named William PFF, owned by Ms. Trudy Miranda, which
resulted in the horse being physically and emotionally handicapped for the rest of his life.”
14. Plaintiff subsequently submitted to Trudy Miranda for her civil complaint against Defendant Cesar
Parra, an Affidavit, wherein, Plaintiff, declared as a professional horseman of over forty years that
the actions and lack of actions by Defendant Cesar Parra constituted gross negligence and violation
of care, custody and control, as we1l as, Defendant Cesar Parra’s fiduciary responsibility under
the animal abuse and business practices laws of the State ofNew Jersey
15. Subsequent investigation by Hunterdon SPCA resulted in criminal charges that, where through
inappropriate and inaccurate investigation by Hunterdon County Prosecutor dropped. Hunterdon
County Sheriff and Hunterdon County Prosecutor ‘failed’to investigate the deceptive trade
practices portion of the complaint. The appearance of impropriety by the County ofHunterdon is
clearly demonstrated by the actually physical evidence provided for the civil case of Miranda v.
Parra.
16. On March 2, 2012, Honorable Judge PeterS. Buchsbam, J.S.C. of the Superior Court of New
Jersey Law Division Hunterdon County, ruled on Defendant Cesar Parra’s Motion for Summary
Judgment, Docket Number HNT·L·000369·11. Judge Buchsbam denied Defendant Cesar Parra’s
Motion for Sununary Judgment and multiple times cited the Affidavit submitted by the Plaintiff.
17. From the ruling, quote: “Under these circumstances, and in light of plaintiff’s motion
to amend her Complaint, there is adequate proof on the record o(de{endant ‘s intentional wrong
doing to withstand a dismissal of plaintiff’s punitive damages claims. After all, punitive damages
are permitted where intentional wrong doing is demonstrated.” [Italicized and underlined for
emphases]
18. Therefore, since that date the Plaintiffhas consistently stated that, according to a Court of Law,
Defendant Cesar Parra had demonstrated wanton disregard of the safety of a horse under NJ
Statute 5: 15·1·12 and under NJ Statute Title 4, Chapter 22, Article 2, 22-179 Cruelty in general (a)
torture, unnecessarily abuse, and that Defendant Cesar Parra in his wanton disregard for William
PFF had also violated NJ Title 56, Chapter 8, Section 1 Deceptive trade practices for
misrepresenting services to be rendered.

 

MATERIAL FACTS

19. Defamation: An unprivileged false statement of fact which tends to harm the reputation of a person
or company. This is a catch-all term for both libel and slander.
20. Libel: Defiunation which is written such as in any printed publication or written on an Internet web
page, comment, bulletin board post, review, rating or blog post.
21. Slander: Defamation that is spoken to an individual. Such statements may also be filmed and
viewed.
22. Malice: The intentional commission of a wrongful act, absent justification, with the intent to cause
harm to others; conscious violation of the law that injures another individual; a mental state
indicating a disposition in disregard of social duty and a tendency toward malfeasance. Malice is
proven when the person writing and/or speaking the false statements intended to do harm or acted
with reckless disregard of the truth in making the statements.
23. Plaintiff at no time has made false statements to any individual or written any false statement in
any publication or on line regarding the ‘willful, intentional and knowing’ gross negligence
inflicted upon William PFF by Defendant Cesar Parra.
24. Plaintiff at no time, therefore, has demonstrated any malice toward Defendant Cesar Parra.
25. Contrary to the Plaintiff’s efforts to disseminate truthful information regarding the Plaintiff’s
involvement in the Miranda v. Parra civil complaint, Defendant Cesar Parra, Defendant Michael
Davis and Defendant Kathleen Riley have ‘willlfully. intentionally, knowingly. and maliciously’
actually publicly made statements regarding the Plaintiff that are inaccurate, false and misleading.
26. Defendants Cesar Parra, Defendant Michael Davis and Defendant Kathleen Riley have ‘willfully,
intentionallv. knowingly. and maliciously’ made these public statements in the effort to discredit
and malign the reputation of the Plaintiff, especially regarding his knowledge ofhorses and his
effort put forth with the Superior Court of Hunterdon County.
FIRST CAUSE OF ACTION
BUSINESS DEFAMATION, LIBEL, SLANDER

27. On March 22, 2012, Defendant Cesar Parra issued a public statement. Here are excerpts from that
published statement:

A. the unwarranted attacks by self appointed “experts” or fringe players in the horse industry
with questionable motives and possibly even personal agendas

28. This is directed at the Plaintiff and impugns the forty years of experience and knowledge acquired
by the Plaintiff. The statement impugns and falsifies the efforts put forth by the Plaintiff in the
arena of New Jersey law in order to bring justice to a horse and its owner. The statement declares
that the Plaintiff has a personal agenda directed toward Defendant Cesar Parra, when as a material
fact, the Plaintiff has only been seeking criminal and civil justice for the injured horse and its
owner. Plaintiff is receiving no compensation from his efforts and as a material fact, has had to
defend his efforts.
29. B. 1) most readers with horse experience understand that horses are capable of
unpredictable and sometimes self destructive behavior

30. This statement impugns and falsifies the Plaintiff’s Affidavit statements regarding the actions and

lack of actions by Defendant Cesar Parra which endangered the physical well being of the horse
William PFF. This statement actually is placing the blame upon the horse.
31.C. 2) that sometimes horses are injured in the course of being ridden and trained because of
their unpredictable behavior without any inappropriate riding or training method
involved.

32. This statement impugns and insults the Plaintiffs knowledge and experience regarding appropriate
riding and training methods and once again reiterates the blame upon the horse. However,
Defendant Cesar Parra does not inform the public that the Affidavit of the Plaintiff clearly
stipulates that it was the inappropriate training method used by Defendant Cesar Parra that is the
‘direct and proximate’ cause of the injuries to the horse William PFF.
33.D.3) readers and other horse trainers will not judge each other or Dr. Parra without first
evaluating all the facts
34. This statement impugns the documented visual evidence and written evidence of the actions and
lack of actions [wrongful] by Defendant Cesar Parra, which the Superior Court of Hunterdon
County has ruled is there, of which the Plaintiff presented the Affidavit.
35. E. What he did not tell the readers is that he has found by the Hearing Committee of the
United State Equestrian Federation, after filing a complaint with that Governing Body of
Equestrian Sport, not to be qualified to testifY as an expert on horse training matters. —His
complaint was dismissed by the USEF Hearing Committee at which he was given a
full, unrestricted opportunity to present his case in a due process hearing conducted by
the USEF consistent with its procedural rules.
36. This statement impugns the integrity and reputation of the Plaintiff, as it is a material fact of law,
that NO hearing was held, the evidence was not presented or discussed in any manner. In fact,
the Plaintiff was verbally insulted and rebuked. USEF violated their own procedural rules in order
to prevent evidence being presented that clearly shows the misuse and abuse of bits in the
competitive arenas under the auspices ofUSEF. And furthermore, by the summation of the
Dressage Committee, not one individual sitting there other than the veterinarian would have any
more qualifications then the Plaintiff. As a material fact, the United State Equestrian
Federation Dressage Committed did violate the Plaintiffs due process rights.
37. F. It is now in question what Mr. Buck and Ms. Miranda motivations are in
mounting a campaign to discredit Dr. Parra, interfere with his business
relationships and his potential opportunity to participate on the US National
Team at the 2012 Olympics.
38. Plaintiff’s efforts have nothing to do with a campaign to discredit Defendant Cesar Parra and
interfere with his business relationships or any other efforts. Plaintiff’s efforts have been put
forth the evidence regarding the gross negligence by Defendant Cesar Parra in the infliction of
injuries upon the horse William PFF for the following reasons:
Defendant Cesar Parra is a member of the United States Equestrian Team and represented the
United States at the Pan Am Games. Plaintiff does not believe it is appropriate for any individual
who abuses horses through training and riding methods should be an International representative
for the United States. Plaintiff believes that it is time for the United States Equestrian Federation
to uphold its Mission Statement, Code of Conduct and abuse rules.
39. G. Mr. Buck’s actions which appear to be intended to impugn Dr. Parra’s reputation
40. Plaintiff makes no effort to impugn [challenge or call into question] Defendant Cesar Parra’s
reputation. Plaintiff simply presents the material facts that Defendant Cesar Parra acted with gross
negligence on the day in question with the horse William PFF. The Superior Court of Hunterdon
County has concurred with the position ofthe Plaintiff as demonstrated in the Denial of the Motion
to Dismiss set forth by Defendant Cesar Parra.
41. H. Dr. Parra has no intention to capitulate to such highly suspect behavior and fully
intends to take whatever steps necessary to address the damage that has been
caused by Ms. Miranda’s and Mr. Buck’s reprehensible behavior. The court
filings will soon include his claims against them and his procedurally proper
requests to obtain equitable relief to restrain them from further defamatory and
intentionally tortious conduct.
42. Plaintiff has presented facts and facts cannot be defamatory nor is presenting facts intentional tort
conduct. As a material fact, the “suspect” behavior has been clearly demonstrated by Defendant
Cesar Parra in the inflicted injuries upon the horse William PFF, the efforts put forth to blame the
horse, and the efforts put forth to threaten the owner of William PFF, and the efforts put forth to
threaten any individuals who reference the incident in any manner in any social media upon the
Internet. It is a material fact that Defendant Cesar Parra will make every effort possible to
threaten in any manner and will make every effort in any manner possible to discredit any
individual who speaks up regarding Defendant Cesar Parra in a negative manner.

43. I. He will vigorously continue with his defense and will take whatever steps
necessary to aggressively pursue counterclaims and cross claims against Ms.
Miranda and Mr. Buck, respectively, to hold them legally accountable for their
reprehensible conduct in intentionally attempting to damage Dr. Parra’s
professional reputation.
44. Plaintiff has not acted in any reprehensible [deserving censure or rebuke] conduct, nor has the
Plaintiff intentionally attempted to damage Defendant Cesar Parra’s professional reputation.
Plaintiff has proceeded to present evidence of the gross negligence by Defendant Cesar Parra, who
acting outside the scope of professional ethics, did cause injury to the horse William PFF.
45. Conduct; behavior in an action or manner of directing or managing through a mode of treatment
during execution of action. Plaintiff’s conduct has been directed at correctly presenting the
evidence to law enforcement, the Court and the public; the unethical, immoral and reprehensible
actions and lack of actions that resulted in the injuries to the horse William PFF.
Defendant Cesar Parra’s conduct has been to blame the horse, threaten the owner, threaten the
Plaintiff and even to threaten individuals in social media.
Defendant Cesar Parra’s conduct has even included making false and inaccurate statements
regarding the owner and the horse and the Plaintiff.
46. May 26, 2012, following dismissal of the criminal charges, Defendant Cesar Parra states to
Horseback Magazine Online quote:
A. “The owner of the horse involved in the 2009 accident and a fellow cohort
filed for severe criminal charges against Parra in the Hunterdon County
Court.”

47. Plaintiff was the singular person who filed the criminal complaint. Plaintiff and the owner are not,
nor ever have, cohorts as so stipulated by Defendant Cesar Parra. At no time as there been any
effort on the part of either the Plaintiff or the owner of the horse William PFF to act in unison
against Defendant Cesar Parra. The word ‘cohort’ is a synonym for abettor, accessory,
accomplice, or fellow conspirator and that is the context in which it was used by Defendant Cesar
Parra predicated upon all of his previous statements and the statements by Defendants Kathleen
Riley and Michael C. Davis.
48. Defendant Kathleen Riley posted on the social media Barnmice.com the following:
A. Mr. Buck is passing judgement and passing on information from something that
be did not witness, as well as passing on all the predudicial images he can, to as
many outlets as be can to inflame the situation as much as possible; seemingly in
his desire to defame Cesar as much as possible.
49. The Plaintiff did not have to be there in order to observe the constrained and restrained ‘tied’ down
position that the horse William PFF was place in by Defendant Cesar Parra. Plaintiff did not have
to be there in order to observe Defendant Cesar Parra tightening the side reins. Plaintiff did not
have to be there in order to observe Defendant Cesar Parra using a hose to wash William PFF’s
blood off the wall rather than tending to the horse.
50. Plaintiff did not pass on any images that were ‘prejudicial’. [prejudicial: causing prejudices which
is a preconceived opinion] The images used clearly demonstrated the material facts regarding the
physical subjugation of the horse William PFF into a position that physically endangered the horse
William PFF, because the horse William PFF bad no way to protect himself from any actions
caused by Defendant Cesar Parra.
54. Plaintiff at no time used the images as a means of ‘inflaming’ the situation as much as possible.
[inflame; to provoke into a strong feeling especially anger] Plaintiff used the images as a means of
presenting to the public the truth that Defendants Cesar Parra and Kathleen Riley wanted to
remain hidden.
52. Plaintiff at no time used the images to defame Defendant Cesar Parra. Plaintiff used the images in
order to show the truth of the situation that Defendants Cesar Parra and Kathleen Riley wanted to
remain hidden.
53. Plaintiff wishes to inform the Court that Kathleen Riley is Head Trainer for Piaffe Performance
Farms and has a vested interest in any and all publicity.
54. Defendant Michael Davis C. Davis has a vested interest in Defendant Cesar Parra and Piaffe
Performance Farms. Defendant Michael C. Davis made a public statement coming to the
‘defense’ of Defendant Cesar Parra. Here are excerpts from that statement:
A. He cited articles of lawsuits filed by the man against judges, law enforcement
officers, news organizations and officials in the Obama administration.
55. Plaintiff has filed lawsuits Prose in order to seek protection of his civil rights. These law suits
have nothing to do with the Plaintiff’s equine experience and knowledge. Defendant Michael C.
Davis impugns and maligns the Plaintiffs reputation by misrepresenting the Plaintiff as a litigant.
56. B. Accidents happen and as you well know, every trainer, rider, farrier, groom,
veterinarian, transporter associated with handling, riding or care of horses is
subject to attacks from people whose goal is to see all horses released into the
wild and left to their own devices, which I think we can agree would be a
disaster.
57. Plaintiff is not attacking Defendant Cesar Parra. [attacking: vigorously applying oneself to
forcefully hurt someone] Plaintiff has in no manner attacked Defendant Cesar Parra. Plaintiff’s
position on the ownership of horses has been misrepresented as the Plaintiff is NOT one of ‘those
people’ who want all horse released into the wild.
58. C. In my humble opinion our community should set aside any and all personal or
professional differences at a time like this and come together to expose the truth
as to who is behind this, their objectives and their motivation.
59. Plaintiff does NOT have to be exposed, as it is the Plaintiff openly set himself before law
enforcement and the courts of the State of New Jersey in order to expose the truths regarding the
gross negligent injuries inflicted upon the horse William PFF by Defendant Cesar Parra.
60. Plaintiff’s goal is to bring to the forefront of the horse industry that abuse of the horse is rampant
and that any and all individuals must be held accountable Professional differences sets abusive
horse trainers apart from sympathetic horse trainers.
61. Plaintiff’s objective is to see that Defendant Cesar Parra is held legally accountable both civilly
and criminally for the gross negligent injuries inflicted upon the horse William PFF.
62. Plaintiff’s motive is to clearly demonstrate that Defendant Cesar Parra has not abided by the rules
and regulations of USEF/FEI and the abuse laws of the State ofNew Jersey. Therefore and
therein, Defendant should not be allowed to be a member of USEF/FEI or the United States
Equestrian Team pursuant to their own rules and regulations.
63. D. This is a wonderful sport and we should work collectively to preserve its
reputation and keep people whose agenda is driven by self promotion away from
inflicting further damage.
64. Plaintiff has sufficient evidence that the sport of dressage has become abusive in its training and
competition. There is no reputation to preserve as the reputation of competitive dressage has
become an insult to the true classical dressage that the FEIIUSEF dressage rules contain.
65. Plaintiff has no self promotion agenda set before the public. As a material fact, it is quite the
opposite. The Plaintiff’s agenda is simply that there should be no abusive training or riding
methods allowed. The Plaintiff’s agenda is simply that the current definitive descriptive stipulated
rules of dressage and all equine competitive venues are adhered to.
66. E. Yes you can take this as my attempt to protect Cesar and I can appreciate and
understand why, however I am also aware of just how close we are all to being
the ‘next’ victim to outsiders who will stop at nothing to destroy our sport and
promote their own agenda, which I can assure you is different from all of ours.
67. Plaintiff is not creating ‘victims’, the victim is the horse William PFF who had no voice and no
defenses against the infliction of abuse by Defendant Cesar Parra. The VICTIMS are the horses
who are unable to use a voice to express themselves nor to have the physical means to protect and
defend themselves. It is the agenda of Defendant Cesar Parra and Defendant Michael C. Davis is
to conceal from public scrutiny, the abusive and subjugating training and riding methods that they
and others within the horse industry inflict upon the horses every day of every month of every year.
68. Plaintiff has clearly demonstrated that Defendants Cesar Parra, Kathleen Riley and Michael C.
Davis have ‘willfully, intentionally, knowingly and with malice’ made false statements, inaccurate
statements and statements that misrepresent, in order to malign and discredit the Plaintiff in order
to conceal the gross negligent conduct that inflicted injuries upon the horse William PFF and to
conceal that such conduct also clearly demonstrated deceptive trade practices.
69. Statements made by the named Defendants hereby presented above do directly and indirectly refer
to the two parties involved with the Miranda v. Parra Complaint, which are Mrs. Trudy Miranda
and the Plaintiff. Therefore, each of the stipulated statements by the named Defendants do herein
constitute business defamation, slander and libel, as said statements were either or both spoken and
written in publication.

SECOND CAUSE OF ACTION

70. Section 5 of the Federal Trade Commission Act (FTC Act) (15 USC 45) prohibits “unfair or
deceptive acts or practices in or affecting commerce.” The prohibition applies to all persons
engaged in commerce.
71. The legal standards for unfairness and deception are independent of each other; depending on the
facts, an act or practice may be unfair, deceptive, or both.

Unfair Acts or Practices

An act or practice is unfair where it: Causes or is likely to cause substantial injury to consumers,
Cannot be reasonably avoided by consumers, and is not outweighed by countervailing benefits to
consumers or to competition.
Public policy, as established by statute, regulation, or judicial decisions, may be considered with
all other evidence in determining whether an act or practice is unfair.

Deceptive Acts or Practices

An act or practice is deceptive where: A representation, omission, or practice misleads or is likely

to mislead the consumer; A consumer’s interpretation of the representation, omission, or practice is
considered reasonable under the circumstances; and the misleading representation, omission, or
practice is material.
72. Plaintiff contends that the actions and lack of actions by Defendants Cesar Parra and Kathleen
Riley and the subsequent defamation, slander and libel actions taken by Defendants Cesar Parra,
Kathleen Riley and Michael C. Davis, do constitute deceptive trade practices which are
concealing factual activities and practices that are in violation of State ofNew Jersey law, as well
as, the rules and regulations of the USEF/FEL

A. Evidence will prove that the actions and lack of actions did bring substantial
injury to the owner of the horse and to the horse William PFF.
B. Evidence will prove that the actions and lack of actions could not have been
avoided by the owner of the horse William PFF
C. Evidence will prove that the representation, omission and practice did mislead
the owner of the horse William PFF
D. The actions and lack of actions that constitute deceptive trade practices by the
Defendants Cesar Parra and Kathleen Riley do have a direct and proximate
affect upon the Plaintiff’s ability to manifest clients because of the reputation
created for Defendant Cesar Parra that is false and a misrepresentation.
E. The actions and lack of actions that constitute deceptive trade practices by the
Defendants Cesar Parra and Kathleen Riley do have a direct and proximate
affect upon the integrity and reputation of the Plaintiff regarding his equine
experience and knowledge with regards to informing the public of abusive
training methods by professionals throughout the equine industry.

73. Defendant Cesar Parra is a principal in two businesses operating at the 14 Shade Lane
Whitehouse Station, NJ 08889 address. The first is Piaffe Performance which lists only Defendant
Cesar Parra and is registered with the Secretary of State for New Jersey. The second business is

Defendant Cesar Parra is a principal in two businesses operating at the 14 Shade Lane
Whitehouse Station, NJ 08889 address. The first is Piaffe Performance which lists only Defendant
Cesar Parra and is registered with the Secretary of State for New Jersey. The second business is

Apex Stables International, Inc. a Delaware corporation of which Defendant Cesar Parra is an
Executive Officer, Director and Promoter. This business currently is not registered with the
Secretary of State for New Jersey. Defendant Cesar Parra does not inform the public of this
business relationship, which constitutes concealment.

 

A. Concealment of Apex Stables International, Inc. by Defendant Cesar Parra appears to be
of intent. Plaintiff discovered this entity while researching on the Internet and
Defendants Stephen Kiront, Barry Kiront and David Schrager are the other individuals
listed as Executive Officers, Directors and Promoters on the Securities and Exchange
Commission filing located by the Plaintiff.
B. Concealment of Apex Stables International, Inc. by the named Defendants appears to
have a good reason. Evidence acquired on the Internet [not yet verified through legal
sources] shows that Defendants Stephen Kiront and Barry Kiront may have been
previously arrested for stock fraud.
D. Defendants Stephen Kiront, Barry Kiront, and David Schrager are listed with Woodstock
Financial, headquartered in Woodstock, GA as fmancial advisors representing Woodstock
Financial.
E. Defendants Stephen Kiront and Barry Kiront recently {Sept. 12, 2012} established
another company in the State of New York named Jobast Holdings, aka Wood Stock
Financial.

74. Plaintiff contends that the preliminary evidence of improprieties and the concealment of Apex
Stables International, Inc. by Defendants Cesar Parra, Stephen Kiront, Barry Kiront and David
Schrager does constitute deceptive trade practices in order to hide the business relationships of the
named Defendants, which may or may not involve the movement of monies received by Defendant
Cesar Parra, as Defendant Cesar Parra has apparently claimed in the Miranda civil case
that he has no money.
CONCLUSION

75. Plaintiff has shown a direct effort being put forth by Defendants Cesar Parra, Kathleen Riley and
Michael C. Davis to publicly humiliate and discredit the Plaintiff, as well as, Mrs. Trudy Miranda
the owner of the horse victim William PFF. Such efforts constitute defamation, slander and libel
through their published false, inaccurate and misrepresenting statements.
76. Plaintiff has shown that the physical evidence does exist clearly showing the gross negligence
inflicted upon the horse William PFFand that such gross negligence violates business trade
practices.
77. Plaintiff has shown there appears to be concealment and improprieties regarding business
operations by named Defendants Cesar Parra, Stephen Kiront, Barry Kiront and David Schrager.
Such concealment and improprieties would demonstrate a propensity for ‘willfully, knowingly and
intentionally’ operating businesses using deceptive trade practices.

PRAYER FOR RELIEF

78. Whereas, Defendants Cesar Parra, Michael C. Davis and Kathleen Riley have clearly demonstrated
a propensity for the defamation of the Plaintiff through slander and libel, the Plaintiff moves this
Court for an Order to Cease and Desist any and all forms of defamation against the Plaintiff by the
named Defendants. Said Order should provide for this Court to impose fines and jail time for
violation of said Order.
79. Whereas, Defendants Cesar Parra, Kathleen Riley and Michael C. Davis did directly make and
publish false, inaccurate and misrepresenting statements the Plaintiff moves the Court for damages
in the amount of $1,000,000.00 per each named Defendant. Total amount $3,000,000.00
80. Whereas, Defendants Cesar Parra, Kathleen Riley and Michael C. Davis did directly make and
publish false, inaccurate and misrepresenting statements the Plaintiff moves the Court for punitive
damages in the amount of $2,000,000.00 per each named Defendant. Total amount $6,000,000.00
81. Whereas, Defendants Cesar Parra, Stephen Kiront, Barry Kiront and David Schrager are engaging
in deceptive trade practices which are protecting Defendant Cesar Parra and have a direct bearing
upon the public perception of Defendant Cesar Parra, thus an impact upon the public’s perception
of the efforts put forth by the Plaintiff; the Plaintiff moves the Court for damages in the amount of
$1,000,000.00 per each named Defendant. Total amount $4,000,000.00
82. Whereas, Defendants Cesar Parra, Stephen Kiront, Barry Kiront and David Schrager are engaging
in deceptive trade practices which are protecting Defendant Cesar Parra and have a direct bearing
upon the public perception of Defendant Cesar Parra, thus an impact upon the public’s perception
of the efforts put forth by the Plaintiff; the Plaintiff moves the Court for punitive damages in the
amount of $2,000,000.00 per each named Defendant. Total amount $8,000,000.00

 

Dated this 15th day of May 2013

 

Edward Allan Buck

 

View Complaint 

Defendant Michael Davis’ Motion to Dismiss

Response to Defendant Davis

Defendants’ Cesar Parra & Katie Riley Motion to Dismiss

Response to Defendants Parra & Riley

Defendants’ Stephen Kiront, Barry Kiront, and David Schrager Motion to Dismiss

Defendant Davis Reply Memorandum to Support Motion to Dismiss

Plaintiff’s Memorandum Support of Complaint   

Request to Submit for Decision        

Request to Submit for Decision     

Request to Submit for Decision 

 

Suit dismissed by court for lack of jurisdiction