01. Vamsidhar Vurimindi
1782 Frankford Ave, Unit #1, Philadelphia, PA
19106
Plaintiff,
Vs.
01. HSFLB Condominium Owners
As...
Page - 2 - of 164
VERIFIED COMPLAINT FOR CIVIL RIGHTS VIOLATIONS, TEMPORARY RESTRAINING ORDER &
PRELIMINARY AND PERMANENT ...
Page - 3 - of 164
violated their constitutional rights. They also seek nominal, actual, and punitive damages
against Defen...
Page - 4 - of 164
1 1 . Since March 2008 and until November 2009, attended MBA course at Fuqua School of
Business, Duke Un...
Page - 5 - of 164
1 9 . Defendant Lauren Westfield Nayerahmadi (“Westfield”) is a bonafied and lawful property
owner of un...
Page - 6 - of 164
3 1 . Since on or after July 2010, Pattinson owns and operates a business entity under the trade
moniker...
Page - 7 - of 164
4 3 . Defendant John Doe-3, An unknown Attorney(s) and/or Police Officer(S) and/or Detective(S)
for Offi...
Page - 8 - of 164
5 5 . Thomas McCracken (“McCracken”) is a bonafied and lawful property owner of unit # 404 at
HSFLB. Sin...
Page - 9 - of 164
6 7 . Since July 2005 and as of today, City Council blocked the approval to purchase City surplus
vacant...
Page - 10 - of 164
Wrongfully and unlawfully denying to reimburse the cost of restoration of damages caused to
Vurimindi’ ...
Page - 11 - of 164
deteriorated in the subsequent years, due to HSFLB residents’ coercive, intimidating,
threatening and p...
Page - 12 - of 164
8 7 . Nevertheless, Duke lodged a police complaint against Vurimindi and begins its investigation
into ...
Page - 13 - of 164
Gallagher stating that he is very much concerned about Vurimindi that he could see Vurimindi
searching ...
Page - 14 - of 164
9 7 . As soon, Duke’ Office of Institutional Equity (“OIE”) refused to take Vurimindi’ harassment
compl...
Page - 15 - of 164
1 0 2 . Nathaniel Hawkins, in order to make a credible claim that Vurimindi is mentally unstable, he
qu...
Page - 16 - of 164
Breach of Contract and Invasion of Privacy; and against Vurimindi’ classmates for tortious
interference...
Page - 17 - of 164
1 1 8 . Upon enquiry and belief, Rosen Shah told to the residents at HSFLB that “Vamsi is a criminal”;
...
Page - 18 - of 164
1 2 4 . On 24th
September 2009, at about 3:30 PM, Vurimindi was vexed with the City Commissioner’
arbit...
Page - 19 - of 164
1 2 9 . It is easier said than done, Vurimindi unable to ignore the verbal attacks, because Vurimindi’
...
Page - 20 - of 164
assign a number to his complaint; and Starbucks assigned a number # 777-4355 to Vurimindi’
complaint.
1...
Page - 21 - of 164
publicized about Vurimindi as “schizophrenic”, “crazy”, “moody”, “paranoid”, “depressed”,
“hallucinate”...
Page - 22 - of 164
1 5 0 . Upon enquiry and belief, since February 2007, Segal is in direct contact with many restaurants
...
Page - 23 - of 164
Fire Station-Engine 8 & Ladder-2 told to residents in and around HSFLB and referring to
Vurimindi as, “...
Page - 24 - of 164
1 6 7 . Nevertheless, between May and June 2010, as and when, Brill passed Vurimindi, as if she is
talk...
Page - 25 - of 164
1 7 5 . Upon enquiry and belief, Brill acted as mouth piece to Borowski to defame Vurimindi in and
arou...
Page - 26 - of 164
Tiefenback, Stanly, Palmer and Elliot via text message, such these defendants can come across
or walk a...
Page - 27 - of 164
1 8 9 . Upon enquiry, belief and observation, since May 2010, HOA, Borowski, Westfield, Pattinson,
and ...
Page - 28 - of 164
1 9 4 . Upon enquiry, belief and observation, between February 2010 and February 2011, when
Vurimindi h...
Page - 29 - of 164
1 9 8 . Upon enquiry, belief and observation, soon after Commonwealth indicted Vurimindi, Old City
Dist...
Page - 30 - of 164
2 0 5 . On or about 15th
January 2012, when Vurimindi contacted a new resident of HSFLB, Kirsten
Sherma...
Page - 31 - of 164
2 1 1 . On 9th
February 2012, at about 9:00 PM, when Vurimindi get out of his condo, Michael
followed V...
Page - 32 - of 164
I. Purposefully lying to Vurimindi about Surveillance against Vurimindi and refusing
to resolve the iss...
Page - 33 - of 164
2 2 4 . In November 2009, Vurimindi, multiple times enquired Tiefenback as to how he know about
Vurimin...
Page - 34 - of 164
2 3 3 . Immediately, Vurimindi shouted across floor, “How do you know, that HealthCore is going fire
me...
Page - 35 - of 164
J. Intrusive enquiry into Vurimindi’ Private Facts:
2 3 6 . In August 2009, Engel prominently sitting i...
Page - 36 - of 164
attorney, told to Judge Sheppard that he heard that Vurimindi is either a ‘Tamil’ or a
‘Muslim’. Immedi...
Page - 37 - of 164
asked “How do you know?” At that time, Baute told to Vurimindi, “Allison is a regular to my
shop and my...
Page - 38 - of 164
against me in support of the defendants in my law suits against Wyeth and Duke. When I
started enquirin...
Page - 39 - of 164
2 5 7 . In the March 2010, Vurimindi contacted Brill and told her that staff in local business
establis...
Page - 40 - of 164
2 6 4 . This is an affirmation to Vurimindi’ belief that his neighbors Borowski, Pattinson and Westfiel...
Page - 41 - of 164
2 7 0 . There are many more Vurimindi’ private conversations were published around HSFLB, to
which Vuri...
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines
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Federal Complaint - Allison Borowski, Rajani Pattinson, Fuqua School of Busines

  1. 1. 01. Vamsidhar Vurimindi 1782 Frankford Ave, Unit #1, Philadelphia, PA 19106 Plaintiff, Vs. 01. HSFLB Condominium Owners Association 2424 E. York St, #217, Philadelphia, PA 19125 02. City of Philadelphia 1515 Arch St, 15th Fl, Philadelphia, PA 19102 03. Commonwealth of Pennsylvania 333 Market Street, 17th Floor Harrisburg, PA 17101 04. Office of the District Attorney, 3 S Penn Square, Philadelphia, PA 19107-3499 05. George J Dilworth Jr, 235 N 11th St, Philadelphia , PA 19107 06. Allison Borowski, 313 Arch St, Unit 608, Philadelphia, PA, 19106 07. Rajani Pattinson, 1822 S 13 th Street, Philadelphia, PA 19148 08. Lauren Westfield, 313 Arch St, Unit 507, Philadelphia, PA, 19106 09. Kendra Brill, 313 Arch St, Unit 501, Philadelphia, PA 19106 10. Nicholas Palmer 313 Arch St, Unit# 601, Philadelphia, PA 19106 11. Michael Borowski, 17 Manly Pl, New Hyde Park, NY 11040 12. Leo Addimando 2424 E. York St, #217, Philadelphia , PA 19125 13. John Doe-1, An unknown Police Officer(S) and/or Detective(S) for the City Of Philadelphia; 14. John Doe-2, An unknown Attorney(s) and/or Police Officer(S) and/or Detective(S) for the City Of Philadelphia; 15. John Doe-3, An unknown Attorney(s) and/or Police Officer(S) and/or Detective(S) for Office of the District Attorney; 16. John Doe-4, An unknown Judge(s) and/or Attorney(s) and/or Police Officer(S) and/or Detective(S) for Commonwealth of Pennsylvania; 17. John Doe-5, An unknown Resident(s) 313 Arch St, Unit 608, Philadelphia, PA, 19106 18. Starbucks, Inc 2401 Utah Ave. South Seattle, WA 98134. Defendants ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) U.S. DISTRICT COURT, EASTERN DISTRICT OF PENNSYLVANIA Civil Action No.______________ Jury Trial Demanded
  2. 2. Page - 2 - of 164 VERIFIED COMPLAINT FOR CIVIL RIGHTS VIOLATIONS, TEMPORARY RESTRAINING ORDER & PRELIMINARY AND PERMANENT INJUNCTION, DECLARATORY JUDGMENT, AND DAMAGES (I) PRELIMINARY STATEMENT: 0 1 . This case arise after condo owners at Hoopskirt Factory Lofts Building (“HSFLB”) and its condo association abused public provisions1 to remove Vamsidhar Vurimindi (“Vurimindi”) involuntarily from his own condo by working with a prior understanding with Philadelphia Police Department, Philadelphia District Attorney’ Office and Commonwealth of Pennsylvania Public Prosecutors to obstruct Vurimindi from enjoying his property right and fundamental rights of personal freedom and liberty. As a result of the abuse of public provisions by the condo owners, Vurimindi was wrongfully arrested by the Philadelphia Police Department and wrongfully incarcerated by the Commonwealth of Pennsylvania and wrongfully issued a restraining order not to enter into his condo, because complaining witnesses lived in the same condo. Prior to Vurimindi was wrongfully removed from his condo, condo owners interfered with Vurimindi’ day-to-day life by snooping and shadowing Vurimindi in and around HSFLB; and eavesdropping into Vurimindi’ condo using electronic devices; and publicizing Vurimindi’ private life facts to many people in and around HSFLB; and in concert repeatedly create psychological terror upon Vurimindi, through their coercive, intimidating, threatening and physical attacks against Vurimindi. 0 2 . This is a civil rights action brought pursuant to 42 U.S. C. $ 1983 that challenges the constitutionality of the actions of Philadelphia Police Department, Philadelphia District Attorney’ Office and Commonwealth of Pennsylvania Public Prosecutors a police and other officials that resulted in the arrest, detention, and incarceration of Vurimindi. Criminal charges of Harassment and Stalking were leveled against Vurimindi and criminal charges are presently pending in the Court of Common Pleas of Philadelphia County. 0 3 . Vurimindi seek temporary, preliminary, and permanent injunctive relief against further prosecution o f the pending criminal charges as well as a declaration that the actions of police 1 Systematically made baseless accusations against Vurimindi with the HSFLB Condo Association, as Vurimindi is intimidating and harassing other condo owners; and made premeditated baseless police complaints against Vurimindi for ‘harassment’; and use those police complaints as basis for filing wholly baseless private criminal complaints of ‘harassment’ and ‘stalking’.
  3. 3. Page - 3 - of 164 violated their constitutional rights. They also seek nominal, actual, and punitive damages against Defendants for the flagrant, willful, and knowing violation of Plaintiffs' First, Fourth, and Fourteenth Amendment rights as well as the costs o f this litigation, including reasonable attorneys' fees. (II) JURISDICTION: 0 4 . This court has jurisdiction of the claims brought in this complaint, because case involving United States Constitution and federal laws or treaties. 28 U.S.C. § 1331. The Court has jurisdiction over the request for declaratory relief pursuant to 23 U.S.C § 2201 and 2202. The Court has supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. § 1367. (III) VENUE: 0 5 . Venue is proper in this United States District Court for the Eastern District of Pennsylvania because Plaintiff’ claims arose in the City and County of Philadelphia and are based on the transactions and occurrences that took place in the city and County of Philadelphia. 28 U.S.C. § 1391(b). (IV) THE PARTIES: 0 6 . Plaintiff Vamsidhar Vurimindi (“Vurimindi”) is a bonafied and lawful property owner of unit # 607 at HSFLB. Vurimindi brings this action in his own right. 0 7 . Vurimindi belongs to protected class, defined Civil Rights Act of 1964, because Vurimindi born and brought up in India and belongs to Hindu religion. 0 8 . Vurimindi is the only male person, born and brought up in India and belongs to Hindu religion lived and owned condo unit at HSFLB. 0 9 . Vurimindi was a lawful resident of unit # 607 at 313 Arch St, Philadelphia, PA 19106 until 10th February 2012. Since, 1st September 2012, Vurimindi was a lawful resident of 1782 Frankford Ave, Unit #1, Philadelphia, PA 19106. 1 0 . Since November 2004 and until March 2009 Vurimindi worked as a consultant at Wyeth Pharmaceuticals, Collegeville, PA.
  4. 4. Page - 4 - of 164 1 1 . Since March 2008 and until November 2009, attended MBA course at Fuqua School of Business, Duke University (“Duke”) and completed the program. 1 2 . Defendant HSFLB Condominium Owners Association (“HOA”) is an association formed by association of condo owners at 309-313 Arch Street, Philadelphia, PA 19106 pursuant to the provisions of Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. § 3101 et seq. 1 3 . HOA manage and maintain public amenities in HSFLB, such as water, sewer, trash collection and removal, cleaning common areas. 1 4 . HOA day to day operations were managed by 806 Capital LLC, having office located at 2424 E. York St, #217, Philadelphia, PA 19125. 1 5 . Defendant City of Philadelphia (“City”), pursuant to Section 1 of Article XV of the Constitution and the Act of the General Assembly of the Commonwealth of Pennsylvania, City have and may exercise all powers and authority of local self-government and have complete powers of legislation and administration in relation to its municipal functions. 1 6 . The City have the power to enact ordinances and to make rules and regulations necessary and proper for carrying into execution its powers; and such ordinances, rules and regulations may be made enforceable by the imposition of fines, forfeitures and penalties not exceeding three hundred dollars and by imprisonment for a period not exceeding ninety days. 1 7 . Defendant Office of the District Attorney (“Philadelphia District Attorney”), pursuant to Commonwealth Attorney's Act of 1850, 71 P.S. §§ 732-101, et seq., Philadelphia District Attorney is chief law enforcement officer for the Philadelphia county. Philadelphia District Attorney is funded by the Philadelphia County; Pursuant to Section 401(a)(11) of the County Code, as amended 16 P.S. § 401(1)(11), District Attorney and his assistants are officers of the Philadelphia county. 1 8 . Defendant Commonwealth of Pennsylvania (“Commonwealth”), pursuant to Article I, Pennsylvania Constitution, Section 8: The people shall be secure in their persons, houses, papers and possessions from unreasonable searches and seizures, and no warrant to search any place or to seize any person or things shall issue without describing them as nearly as may be, nor without probable cause, supported by oath or affirmation subscribed by the affiant.
  5. 5. Page - 5 - of 164 1 9 . Defendant Lauren Westfield Nayerahmadi (“Westfield”) is a bonafied and lawful property owner of unit # 507 at HSFLB. Westfield’ unit # 507 is just bellow Vurimindi’ unit # 607. 2 0 . Since August 2007 Westfield is a resident of unit# 507 at HSFLB and lived along with her husband Kooshan Nayerahmadi. 2 1 . Westfield’ husband Kooshan Nayerahmadi was HOA managing committee member. 2 2 . Westfield works at Hamburg Sud North America, Inc at Curtis Center, Suite#1075, 601 Walnut St, Philadelphia, PA 19106. 2 3 . Vurimindi’ wife Ann Boris and her business associates has three business offices at Curtis Center 601 Walnut St, Philadelphia, PA 19106. 2 4 . Defendant Allison Borowski (“Borowski”) is a bonafied and lawful property owner of unit # 608 at HSFLB. Borowski’ unit # 608 and Vurimindi’ unit # 607 share a common fire wall and both units situated such that Borowski’ bedroom share the wall Vurimindi’ living room; and Borowski’ living room share the wall with Vurimindi’ bedroom; and Borowski’ and Vurimindi’ main entrance doors are separated 10 feet apart; 2 5 . Since June 2009 Borowski is a resident of Unit # 608 at HSFLB and lived alone, but now and then having company with male counterparts. 2 6 . Borowski enrolled into a residency program at Thomas Jefferson University, Department of Radiology. 2 7 . Defendant Michael Borowski (“Michael”) was the biological father to Borowski. Michael now and then visits her daughter in Unit # 608 at HSFLB and sometimes stays overnight. 2 8 . Defendant Rajani Pattinson (“Pattinson”) was a bonafied and lawful property owner of unit # 606 at HSFLB. Pattinson’ unit # 606 and Vurimindi’ unit # 607 share a small portion of the firewall in the living room and Pattinson’ and Vurimindi’ main entrance doors are separated 3 feet apart; 2 9 . Since September 2008 and until March 2011, Pattinson was a resident of unit # 606 at HSFLB and lived alone, but now and then having company with male counterparts. Currently, Pattinson is a resident of 1822 13th Street, Philadelphia, PA 19148. 3 0 . Initially Pattinson worked for Blockbuster Corporation and later begins to work at Nemours Children Hospital, affiliated with Thomas Jefferson University Hospital.
  6. 6. Page - 6 - of 164 3 1 . Since on or after July 2010, Pattinson owns and operates a business entity under the trade moniker “Stanley Cupcakes”, bake and sell cupcakes. 3 2 . Defendant Kendra Brill (“Brill”) is a bonafied and lawful property owner of unit # 501 at HSFLB and lived alone, but now and then having company with male counterparts. Since July 2008 Brill was residing at unit # 501 at HSFLB. Brill was HOA managing committee member. 3 3 . Since on or after January 2011, Brill owns and operates a business entity under the trade moniker “Kendra Designs”, sells woman’s clothes. 3 4 . Defendant Nicholas Palmer (“Palmer”) is a bonafied and lawful property owner of unit # 604 at HSFLB and lived with his girl friend and/or live-in partner until July 2010. After, July 2010 lived alone, but now and then having company with female counterparts. Since March 2008, Palmer resided at unit# 604 at HSFLB. 3 5 . Palmer work in a quasi-pharmaceutical company as a regulatory compliance professional and his live-in partner and/or girl friend Cathy Must, work for Merck Pharmaceuticals. 3 6 . Defendant Leo Addimando (“Addimando”) is the developer of the HSFLB and still didn’t relinquish his control of the condominium association to the members. 3 7 . Addimando is HOA managing committee member and administrator of HOA. Addimando is also a managing partner of the property management company that manages HSFLB. 3 8 . Sarah Rosen Shah (Rosen Shah”) is a bonafied and lawful property owner of unit # 601 at HSFLB. 3 9 . Defendant George Dilworth Jr (“Dilworth”), Law Enforcement Officer, 6th District Philadelphia Police Department, City of Philadelphia. 4 0 . Defendant Starbucks, Inc is in the business of selling coffee, having its Corporate Office located at 2401 Utah Ave. South Seattle, WA 98134. Starbucks, Inc operates a store located at 57-63, N 3rd Street, Philadelphia, PA 19106. Herein after Defendant Starbucks, Inc referred as Starbucks. 4 1 . Defendant John Doe-1, An unknown Police Officer(S) and/or Detective(S) for the City Of Philadelphia; 4 2 . Defendant John Doe-2, An unknown Attorney(s) and/or Police Officer(S) and/or Detective(S) for the City Of Philadelphia;
  7. 7. Page - 7 - of 164 4 3 . Defendant John Doe-3, An unknown Attorney(s) and/or Police Officer(S) and/or Detective(S) for Office of the District Attorney; 4 4 . Defendant John Doe-4, An unknown Judge(s) and/or Attorney(s) and/or Police Officer(S) and/or Detective(S) for Commonwealth of Pennsylvania; 4 5 . Defendant John Doe-5, An unknown Resident(s) 313 Arch St, Unit 608, Philadelphia, PA, 19106 (V) THE FOLLOWING ACTORS WERE DEFENDANTS IN THE CIVIL ACTION CASE CAPTIONED AS VURIMINDI VS. BOROWSKI ET AL AND WERE EITHER DISMISSED AS A PARTY TO THE CIVIL ACTION OR NOT A PARTY IN THIS CIVIL ACTION. 4 6 . Between July 2008 and March 2010, Rosen Shah is a lawful resident of unit# 601 at HSFLB. 4 7 . Rosen Shah worked as a program manager and executive recruiter for Fuqua School of Business, Duke University (“Duke”) Weekend MBA program and recruited Vurimindi into Duke’ MBA Weekend MBA program. 4 8 . Rosen Shah lived in Raleigh, NC along with her husband Tapan Bharat Shah and relocated to Philadelphia, PA. Tapan Bharat Shah studied his MBA at Duke. 4 9 . Jason Tiefenback (“Tiefenback”) is a bonafied and lawful property owner of unit # 402 at HSFLB. Tiefenback was HOA managing committee member. 5 0 . Since April 2007, Tiefenback was residing at unit# 402 at HSFLB. Tiefenback’ unit # 402 spread across three floors (4th , 5th and 6th ) at HSFLB and has direct view of the main corridor of HSFLB three floors. 5 1 . Dena Young (“Young”) is a bonafied and lawful property owner of unit # 304 at HSFLB. 5 2 . Since January 2008, Young was a resident of unit# 304 at HSFLB HOA managing committee member. 5 3 . Daniel Segal (“Segal”) is a bonafied and lawful property owner of unit # 204 at HSFLB. Since February 2007, Segal was a resident of unit# 204 at HSFLB. 5 4 . Anthony Felice (“Felice”) is a bonafied and lawful property owner of unit # 303 at HSFLB. Since January 2008, Felice is a resident of unit# 303 at HSFLB.
  8. 8. Page - 8 - of 164 5 5 . Thomas McCracken (“McCracken”) is a bonafied and lawful property owner of unit # 404 at HSFLB. Since July 2009, McCracken is a resident of unit# 404 at HSFLB. 5 6 . Joseph Vitella (“Vitella”) is a bonafied and lawful property owner of unit # 503 at HSFLB. Since August 2009, Vitella is a resident of unit 503 at HSFLB. 5 7 . Elliot Hodgson (“Hodgson”) is a resident of unit# 609 at HSFLB. Since November 2008 and until March 2012, Hodgson resided at unit# 609 at HSFLB. 5 8 . Jeffery Engel (“Engel”) was a resident of unit# 309 at HSFLB. Defendant Engel work as Senior Property Manager at SSH Management and worked as CFO at Silica Investment & Development. 5 9 . Alex Baute (“Baute”) was the business owner of Old City Cheese Shop at 160 N 3rd St Philadelphia, PA 19106. Defendant Baute’ wife and McCracken work together at Mothers Work, Inc. 6 0 . Michael Ferrarese, C/o. The Papery Store at 57 North 3rd Street, Merchant's Row Old City, Philadelphia, Pennsylvania 19106. Herein after Michael Ferrarese referred as Ferrarese. 6 1 . Charlie Vatori was the business owner of Charlie’s Place at 114 N 3rd Street, Philadelphia, PA 19106. 6 2 . Jed Quinn (“Quinn”) work as Barista at Starbucks Coffee Shop located at 57-63, N 3rd St, Philadelphia, PA 19106. 6 3 . Erin Graves (“Graves”) work as store manager at Starbucks Coffee Shop located at 57-63, N 3rd St, Philadelphia, PA 19106. 6 4 . Charlie’s Place is in the business of food and beverages and operates a pub located at 114 N 3rd Street, Philadelphia, PA 19106. 6 5 . 806 Capital LLC (“806 Capital”) is a real estate developer and operates its business from 2424 E. York St, #217, Philadelphia, PA 19125. (VI) FACTUAL ALLEGATIONS: A. Vurimindi’ issues with City of Philadelphia, directly related to the City’ Harassment in this case: 6 6 . Since July 2005 and as of today, City’ elected and non elected officials obstructed Vurimindi from acquiring City owned surplus vacant lots through its VPRC Program.
  9. 9. Page - 9 - of 164 6 7 . Since July 2005 and as of today, City Council blocked the approval to purchase City surplus vacant lots. 6 8 . Since April 2006, City’ elected and non elected officials wrongfully and unlawfully stalled Vurimindi’ construction work at 1782 Frankford Ave and 1510 E Palmer St vacant lots. 6 9 . Since July 2007, City wrongfully and unlawfully attached liens against 1510 E Palmer St vacant lot after vacant lot title transferred to Vurimindi, for the claims against vacant lot owner, prior to the sale of the vacant lot. 7 0 . Since, March 2009, City’ elected and non elected officials wrongfully and unlawfully stalled Vurimindi from obtaining zoning permits for his construction work. 7 1 . Since, March 2009, City’ elected and non elected officials wrongfully and unlawfully stalled the issuance of Certificate of Occupancy for his newly constructed building; 7 2 . Since, October 2010, City’ elected and non elected officials wrongfully and unlawfully blocked Vurimindi from obtaining a 10 year tax abatement for his newly constructed building; 7 3 . Since September 2008, City wrongfully and unlawfully denying to reimburse the damages caused to Vurimindi’ newly constructed building by City’ demolition contractor. 7 4 . As a result, in July 2009 Vurimindi filed a complaint against City executives and employees with Philadelphia Commission on Human Relations (PCHR), for wrongfully and unlawfully stalled Vurimindi’ efforts in establishing his construction business. 7 5 . Without deliberation, PCHR dismissed Vurimindi’ complaint against City executives and employees. 7 6 . As a result, in July 2009, Vurimindi as an untrained Pro Se, commenced a civil action Vurimindi vs. Tax Review Board, bearing Case No 2133, July Term 2009, against City, because Bureau of Revision of Taxes, City of Philadelphia denied Vurimindi’ application for 10 year tax abatement for his newly constructed building at 1782 Frankford Ave. 7 7 . As a result, in July 2009, Vurimindi as an untrained Pro Se, commenced a civil action Vurimindi vs. Li et al, bearing Case No 1874, July Term 2009, against City for wrongfully and unlawfully stalled the issuance of Certificate of Occupancy for his newly constructed building. 7 8 . As a result, in August 2009, Vurimindi as an untrained Pro Se, commenced a civil action Vurimindi Vs Achek et al bearing case number 0908001271, August Term 2009, against City for
  10. 10. Page - 10 - of 164 Wrongfully and unlawfully denying to reimburse the cost of restoration of damages caused to Vurimindi’ newly constructed building by City. B. Vurimindi’ issues with Duke and Wyeth, directly related to the HSFLB Condo Owners Harassment: 7 9 . In January 2008, prior to Vurimindi begins his process of making an application into an MBA program, Vurimindi sought a management consulting psychologist Stanton B. Felzer, PhD professional services, to assist Vurimindi’ thinking about his career options that he must pursue in the short and long-term future. 8 0 . Felzer conducted comprehensive psychological testing on Vurimindi and wrote his recommendation letter to Duke2 about Vurimindi’ natural strengths of his clear thinking ability and his superior intelligence. 8 1 . Vurimindi present this documentary evidence to show the condition of Vurimindi’ mental health in January 2008, and how Vurimindi’ mental health condition severely and drastically 2 Even though I have known Mr. Vurimindi for only a few months I feel that I can give him a strong recommendation for his acceptance into The Fuqua School of Business, Executive MBA program. Mr. Vurimindi sought my professional services, as a management consulting psychologist, in helping him clarify his thinking about career options he might consider for both the short and long-term future. Comprehensive psychological testing was completed and then a series of feedback counseling sessions was held to discuss the results and recommendations. Testing shows that Mr. Vurimindi possesses superior intelligence and his basic skills are consistent with that result. This was evident even recognizing language and cultural factors which affect test results. From a personality perspective Mr. Vurimindi is emotionally stable, positive and optimistic, capable of relating well to people and self confident. He is ambitious, highly motivated to succeed, seeks perfection in his performance and sets a high standard of excellence for himself and for others with whom he interacts. He is highly entrepreneurial and not only talks about this desire but has demonstrated this when in India and also in his years in the United States. In discussing these results the two basic alternatives we considered were for Mr. Vurimindi to seek employment in a financially oriented or Real Estate Development Corporation which would allow him to grow or to pursue an MBA program. We agreed that the latter was the best course to follow and he was enthusiastic about his recommendation. I, therefore, strongly recommend Mr. Vurimindi for your MBA program. I am confident he can successfully complete such a program and will in his future career reflect positively upon your program. If there is any additional information I can give you feel free to call upon me.
  11. 11. Page - 11 - of 164 deteriorated in the subsequent years, due to HSFLB residents’ coercive, intimidating, threatening and physical attacks against Vurimindi. 8 2 . In March 2008, Vurimindi begins his weekend MBA program3 at Duke, Raleigh, NC. 8 3 . Sometime in February / March 2008, prior to Vurimindi begin his weekend MBA program classes at Duke, Vurimindi’ managers at Wyeth Pharmaceuticals purposefully contacted his classmates and made depreciatory statements4 about Vurimindi. 8 4 . Between March 2008 and May 2008, Vurimindi’ classmates quickly turned Duke Campus into a hostile environment to Vurimindi by organizing a smear campaign5 against Vurimindi. 8 5 . In January 2009, Vurimindi’ classmates6 at Duke, maintaining direct contacts with Vurimindi’ managers at Wyeth Pharmaceuticals and at the instigation of Vurimindi’ managers at Wyeth Pharmaceuticals, filed a baseless and utterly false complaint against Vurimindi, that Vurimindi is carrying a gun in the Duke Campus and showed gun to his classmates, for possible gains of social power over his classmates. 8 6 . In January 2009, immediately upon Vurimindi’ classmates files a baseless and utterly false complaint against Vurimindi, Duke interrogated Vurimindi, and Vurimindi denied his classmates allegations as an utterly false complaint, because Vurimindi didn’t have a gun. 3 In order to attend classes, on Thursday evening Vurimindi fly from Philadelphia, PA to Raleigh, NC and return back to Philadelphia, PA on Saturday night. 4 In March 2008, after Vurimindi begins his Weekend MBA classes at Duke, Vurimindi’ managers at Wyeth Pharmaceuticals plotted against Vurimindi with an intention to get Vurimindi expelled from Duke. Vurimindi’ managers covertly established contacts with Vurimindi’ classmates and told them that “Vamsi is not capable to handle managerial responsibilities”, “Wyeth couldn’t able to verify Vamsi’ credentials”, “Vamsi didn’t pass high school” and “Vamsi was a Juvenile delinquent”. In addition, Vurimindi’ managers at Wyeth Pharmaceuticals, through Wyeth Pharmaceuticals third party vendors’ the sales and support staff established contacts with Duke and told that “Wyeth couldn’t able to verify Vamsi’ credentials” and he shouldn’t be admitted into MBA program” 5 Vurimindi’ classmates at Duke quickly turned Duke Campus into a hostile environment to Vurimindi by organizing a smear campaign by projecting Vurimindi as a Juvenile delinquent, having previous criminal record by being implicated in murder case(s) and engaged in money laundering business and not as a person was properly grounded with a decent set of values and permanently and irrevocably damage Vurimindi’ image and reputation among his classmates. In addition, Vurimindi’ classmates made very many baseless and false allegations and accusations against Vurimindi. As a result of Vurimindi’ classmates allegations, Duke harassed Vurimindi under the name of investigation. 6 Upon enquiry and belief, Moira Ringo work for GlaxoSmithKline; and Nathaniel Hawkins worked for Biomet Orthopedics, maintained direct contacts with Vurimindi’ managers at Wyeth Pharmaceuticals.
  12. 12. Page - 12 - of 164 8 7 . Nevertheless, Duke lodged a police complaint against Vurimindi and begins its investigation into the allegations and deployed Duke University Police and private investigators to ascertain the truth in Vurimindi’ statement that “I never carried a gun or had a gun”. 8 8 . Given the severity of the complaints made by Vurimindi’ classmates, during the course of the investigations, Duke contacted Vurimindi’ supervisors at Wyeth Pharmaceuticals and someone at HSFLB in order to ascertain the wellbeing of Vurimindi and truth in Vurimindi’ statement that “I never carried a gun or had a gun”. 8 9 . In January 2009, upon ending the conversation with Duke, Vurimindi’ supervisor at Wyeth Pharmaceuticals with whom Duke spoke, conferred this private and confidential information which at the time were merely allegations to other employees within Vurimindi’ environment at Wyeth Pharmaceuticals, soon the replication of the defamatory statements, quickly eroded Vurimindi’ reputation at Wyeth Pharmaceuticals and ultimately costing Vurimindi’ job. 9 0 . In January 2009, upon ending the conversation with Duke, Vurimindi’ neighbors at HSFLB with whom Duke spoke, conferred this private and confidential information which at the time were merely allegations to other neighbors within HSFLB, soon the replication of the defamatory statements, Vurimindi quickly gained reputation as a violent person. 9 1 . In March 2009, Wyeth Pharmaceuticals terminated Vurimindi’ contractual employment. 9 2 . On 29th April 2009, one of the Vurimindi’ classmates at Duke with personal animosity, hatred7 and anger against Vurimindi wrote an email to Professor Kira Fabrizio and Dean John 7 “Kira, John, I know I am not the only person with this concern (because two separate people have emailed me with their concern) but I may be the only person coming forward with these concerns. I need to further preface this with the fact that I hate writing this email, but ... three things concern me about the remote exams: 1) A minor concern is the large number of people taking two closed book exams away from school. I believe in our Honor Code and I believe in most of my fellow classmates, but we are creating a significant risk of inappropriate or sketchy behavior. Dan Ariely's Behavioral Economics lectures regularly on cheating and how people rationalize it for themselves. "Oh, a little look will not be _that_ bad. ... No one will even know, and I didn't even need to look, it was just to confirm my answer. Yep, that is what I thought it was. I didn't cheat." Then the ball starts rolling down the hill. I'm concerned that a situation is being created where we can probabilistically assume that cheating will occur. - One suggestion is that you check the distribution of the performance of those taking the exams remotely against those taking it on campus and if their is a statistically significant difference, correct for it. - [Disclaimer - last term when I got sick during exams, after offering to come back to campus, I was allowed to take my macroeconomics exam at home. The exam was open book, so the only risk of cheating on my behalf was taking too long or talking to people. I didn't do either one.] 2) Another very minor concern is that some of the people not taking the exam are local. There are enough private spaces in our expanded space that we could provide them a private room. For an administration that
  13. 13. Page - 13 - of 164 Gallagher stating that he is very much concerned about Vurimindi that he could see Vurimindi searching the Internet for answers, using his textbooks, or even having someone help him with the exams. (Note: After the fact, Vurimindi obtained these email conversations as part of discovery from Duke University). 9 3 . 30th April 2009 at about 9:00 PM, when Vurimindi has to take-up his remote examination, next day morning, and his home office internet connection was failed and Vurimindi has to take his remote exam, at his wife’ office where she has the authority of letting Vurimindi to take his examination through her company’ secure firewall to the internet. 9 4 . Upon enquiry and belief, some unidentifiable person(s) purposefully damaged Vurimindi’ home office internet connection, such that Vurimindi must take his remote exam at some other location, other than his home, under the assumption that Vurimindi don’t have privacy to search Internet for answers, and/or use his textbooks, and/or someone help him with the exams. 9 5 . In May 2009, Vurimindi contacted Duke’ Director of Student Services to file a harassment complaint against his classmates, who had been filing baseless allegations against Vurimindi. 9 6 . Unfortunately, in June 2009, Duke’ Office of Institutional Equity (“OIE”) advised Vurimindi that the kind of incidents Vurimindi referring didn’t rise to the level of discrimination or harassment case. suspended a student for missing a mandatory orientation day to allow students living less than 30 minutes from campus to call it in for their exams seems inconsistent. 3) I am very concerned about Vamsi Vurimindi (see reference to others having emailed me with their concerns). He has been on my team the last two terms and he has not demonstrated respect for the honor code. As a team we had to repeatedly warn his about behavior that we felt was border line at best. It went so far in one occasion that an official report was made. However, it was determined that there was insufficient evidence to prove that he had done anything in violation of the honor code. I respect our judicial process, but reality tells me that this will just embolden him to continue doing what he has done before. I could see him searching the Internet for answers, using his textbooks, or even having someone help him with the exam. Out of respect for the challenging jobs that you have in dealing with this awkward situation, I will not be posting anything to public forums about my concerns. It is not my goal to stir up public dissension. However, I respect the integrity of our program and feel that in order to protect it, I must voice my concerns. Humbly submitted, Robert Ross”
  14. 14. Page - 14 - of 164 9 7 . As soon, Duke’ Office of Institutional Equity (“OIE”) refused to take Vurimindi’ harassment complaint, in June 2009 Vurimindi’ classmate Moira Ringo8 made fresh allegations against Vurimindi, which caused, a new another Police investigation against Vurimindi. 9 8 . Duke, didn’t informed Vurimindi about fresh allegations against Vurimindi, but at some point and time during the course of the new investigation, contacted Vurimindi’ neighbors at HSLFB in order to discuss Vurimindi’ situation. 9 9 . Upon ending the conversation with Duke, Vurimindi’ neighbors at HSLFB with whom Duke spoke, conferred this private and confidential information which at the time were merely allegations to other residents within HSFLB, soon the replication of the defamatory statements, quickly eroded Vurimindi’ reputation. 1 0 0 . In July 2009, Duke lead Vurimindi to believe that it was officially withdrawn all its ongoing investigations against Vurimindi. 1 0 1 . While, Duke is investigating into new allegations, another Vurimindi’ classmate Nathaniel Hawkins9 , made fresh allegations against Vurimindi as if he is worried for his life, because he believes Vurimindi is mentally unstable. 8 On 8 th June 2009, Moira Ringo called Duke (John Gallagher, Assistant Dean) and told that, “I spoke with Pete on Monday and he stated explicitly that Vamsi showed him a pistol that he was carrying when both of them were in the Thomas center”. On 11th June 2009, Moira Ringo wrote an email to Duke “My concern is not only that this person brought weapon to the class, although that alone is very disturbing. It is also that his other behavior very closely fits the profile seen in workplace/school violence incidents”. 9 On 29th July 2009, Nathaniel Hawkins sends an email to Duke (John Gallagher, Assistant Dean) stating that, “I think it might be pertinent for someone on your staff with a psychology back ground to keep an eye on Vamsi’ posts and behavior until we finish with Term 5, and graduate out of your hair” …. I forwarded and discussed some of this behavior with my father, who holds a Phd in Psychology. He suggested that these posts are suggestive of a possible “paranoid psychosis” affliction. .. I don’t think anything can actually be “done” about this, but I think we (the class) would feel better if you were keeping an eye on it. … I have considered letting this slide, but after discussion with about half dozen of my most trusted colleagues, we have all suggested that it might be time to drop you a note. … I am copying a few lines below from my father and a line on Thought Disorders that I think pertains”. “Probably an early paranoid psychotic, they can be very dangerous – examples Kool-Aid Jim Jones and David Koresh. They are usually pretty odd and alienated until the age of 40 or so and then flip into complete psychosis when they realize the nature of the plot against them.” “Getting awfully disorganized stay away from him, and let others high on his radar”. This guy is getting more and more decompensated. He is feeling some pressure and he is blaming the school and his classmates – the paranoid illumination has occurred or is about to.” “Tell everybody to be careful and try to disappear of his scope. If you need me send a note to administration let me know.”
  15. 15. Page - 15 - of 164 1 0 2 . Nathaniel Hawkins, in order to make a credible claim that Vurimindi is mentally unstable, he quoted his father’ opinion, which holds a PhD in Psychology. 1 0 3 . In August 2009, upon receipt of Nathaniel Hawkins’ email about Vurimindi’ mental health, Duke contacted Vurimindi’ neighbors at HSFLB, and upon ending the conversation with whom Duke spoke, conferred this private and confidential information. 1 0 4 . Duke continued to snoop and shadow Vurimindi by security personnel, from the time he arrives in Raleigh/Durham, NC airport and until he board flight back to Philadelphia, PA, likewise until the end of his Weekend MBA program at Duke University. 1 0 5 . In September 2009, Borowski, and Westfield told to residents at HSFLB that, Vurimindi as “schizophrenic”, “crazy”, “moody”, “paranoid”, “depressed”, “hallucinate”, “violent” and “sexual predator”. 1 0 6 . Simultaneously, in September 2009, Vurimindi’ classmates at Duke imitated in a mocking fashion-way, Vurimindi’ confused facial expressions for the insinuating verbal remarks made by the Starbucks Coffee shop bartenders at his Philadelphia neighborhood, about the rumors that were circulated against Vurimindi at Duke and Wyeth. 1 0 7 . In addition, in September 2009, Vurimindi’ classmates at Duke made direct insinuating verbal remarks in a mocking fashion way about Vurimindi’ private facts, such as his medications, his home internet wireless account details, his online personal bank account details including periodic balances, his construction loan account interest rates and interest rates charged by his credit card companies. 1 0 8 . This is the basis for Vurimindi to believe that there is a real-time communication between Vurimindi’ classmates at Duke and Vurimindi’ neighbors at HSFLB. 1 0 9 . As soon, Vurimindi completed his Weekend MBA program at Duke University, in December 2009, Vurimindi commenced the following civil actions: (i) In December 2009, Vurimindi as a Pro Se commenced a civil action Vurimindi vs. Wyeth Pharmaceuticals et al, bearing Case No 0007 December Term 2009, against Wyeth for promissory estoppel, wrongful termination and slander. (ii) In December 2009, Vurimindi as a Pro Se, commenced a civil action Vurimindi vs. Fuqua School of Business et al, bearing Case No 1704 December Term 2009, against Duke for
  16. 16. Page - 16 - of 164 Breach of Contract and Invasion of Privacy; and against Vurimindi’ classmates for tortious interference with contract and slander. 1 1 0 . After, Vurimindi obtained a partial discovery in Vurimindi vs. Fuqua School of Business et al, bearing case # 10-CV-00234, in USDC EDPA, Vurimindi came to know the his classmates made even more ghastly accusations than those listed here in this pleading. 1 1 1 . Vurimindi, yet to receive discovery documents in from Vurimindi vs. Wyeth Pharmaceuticals et al. C. Rosen Shah purposefully publishing Defamatory information generated out of Vurimindi’ time at Duke to residents of HSFLB: 1 1 2 . Rosen Shah obtained an application for admission into Duke MBA, admission essays, and recommendation letters from Vurimindi. 1 1 3 . Rosen Shaw relocated from Raleigh, NC to Philadelphia, PA and moved into HSFLB is to conduct psychological operation to induce and/or reinforce behavior of other residents in and around HSFLB favorable to Duke professors and Vurimindi’ classmates objectives, to undermine Vurimindi’ professional status and personal standing by way of isolation and destabilization. 1 1 4 . Upon enquiry and belief, Rosen Shah told to Vurimindi’ classmates at Duke and as well as residents at HSFLB, that Vurimindi was a violent person. 1 1 5 . Upon enquiry and belief, Rosen Shah told to Vurimindi’ classmates at Duke and as well as residents at HSFLB, about Vurimindi’ personal information, such as his past record; his current and future career plans embedded in his admission essays; Vurimindi’ own opinions about Vurimindi, which he expressed in his admission essays. 1 1 6 . Upon enquiry and belief, Rosen Shah told about Vurimindi’ personal information that she knew through Vurimindi’ admission application, essays and recommendation letters, to the residents at HSFLB. 1 1 7 . Upon enquiry and belief, Rosen Shah maintained a constant contact with his classmates at Duke and relayed their ongoing and objectionable egregious verbal attacks against Vurimindi at Duke to the residents at HSFLB.
  17. 17. Page - 17 - of 164 1 1 8 . Upon enquiry and belief, Rosen Shah told to the residents at HSFLB that “Vamsi is a criminal”; “Vamsi was implicated in murder cases”; “Vamsi was a Juvenile”; “Vamsi is having rough time at School”, “Vamsi is getting failing grades”, “Vamsi is illegal in this country”, “Vamsi engaged in money laundering business”, “Vamsi plagiarized during the course”, “Vamsi is carrying a gun in the campus”; “Vamsi is a ‘B’ student”; “Vamsi is 3rd class student”, “Vamsi is pimp”; “Vamsi is gay”, “Vamsi, is using psycho stimulants”; D. Ridiculing Vurimindi for his inability to overcome adversarial situation in his dealings with City: 1 1 9 . Upon enquiry and belief, since August 2009, Vitella was in direct contact with City officials to procure information about Vurimindi’ ongoing issues with City, and made disparaging remarks against Vurimindi’ about his ability to overcome adversarial situation in his dealings to many people in and around HSFLB with an intention to undermine Vurimindi’ status and personal standing as a business owner. 1 2 0 . In September 2009, City’ Commissioner for Depart of L & I, asked her staff to refuse to grant a variance without reasonable deliberation for Vurimindi’ project at 1782 Frankford Ave, while City has granted variances for similar projects initiated by other than people of Indian national origin. 1 2 1 . As alleged above, in September 2009, City denied to remove and liens attached against Vurimindi’ 1510 E Palmer St Vacant, to which Vurimindi was compelled by the City to initiate a civil action as an untrained Pro Se, Vurimindi vs. LandAmerica Financial Group et al, bearing Case No 1635, November Term 2008. 1 2 2 . By September 2009, City and its officials had a practice of making arbitrary and bad faith decisions pertaining to projects initiated by people of Indian national origin, by refusing zoning and building permits; and refusing access to City owned surplus vacant lots; 1 2 3 . By September 2009, there are at least seven (7) distinct occasions, City’ Commissioner for Depart of L & I asked her staff to deny Vurimindi’ various applications, without reasonable deliberation.
  18. 18. Page - 18 - of 164 1 2 4 . On 24th September 2009, at about 3:30 PM, Vurimindi was vexed with the City Commissioner’ arbitrary and bad faith decisions, and when Vurimindi asked for an appointment, with a responsible official at Commissioner, Dept of L & I, Commissioner Frans Burns10 personally initiated a police complaint against Vurimindi and was eager to get arrested Vurimindi. 1 2 5 . On 24th September 2009, at about 4:10 PM, while Vurimindi is returning to his home, after the ordeal with Commissioner Frans Burns, and when Vurimindi entering into the HSFLB, Vitella purposefully come across11 in front of HSFLB, in a provocative tone and manner, made a derogatory verbal remark directed towards Vurimindi said that, “construction business is not for woos”. E. Publications of Vurimindi’ Private Conversations by Starbucks Coffee Bartenders: 1 2 6 . In July 2009, as soon Vurimindi commenced his four (4) civil actions against City, the accusations and stories branching out of situations during Vurimindi’ time at Wyeth, Wharton and Duke and his private conversations with Rising Construction LLC; Achek Design and Construction, Co. Inc; Jibe Design; Marks & Rosenzweig, LLC; LandAmerica Title Insurance Company; with his wife and other relatives that he had in his condo, were openly discussed in mocking fashion by Old City local business owners and their support staff, specifically at Starbucks, Café Ole, Old City Cheese Shop, Charlie’ Place, Race Street Café and Moko Hair Salon. 1 2 7 . Right around this time, Vurimindi had frequent arguments with his wife, for not helping him to find as to why Vurimindi is being subjected to harassment simultaneously at five distinct environments. 1 2 8 . Instead helping Vurimindi to find the reason behind the harassment, Vurimindi’ wife asked Vurimindi ignore the verbal attacks and focus on his work. 10 Vurimindi commenced a civil action arbitrary and bad faith decisions of Fran Burns and other City of Philadelphia employees. 11 HSFLB maintenance person informed about arrival time of Vurimindi to Vitella, such that Vitella come across Vurimindi and verbally assault Vurimindi.
  19. 19. Page - 19 - of 164 1 2 9 . It is easier said than done, Vurimindi unable to ignore the verbal attacks, because Vurimindi’ reputation is gradually eroding and bogged down with negative publicity and attention that Vurimindi is getting from his classmates and neighbors. 1 3 0 . Vurimindi and his wife developed disagreements about, Vurimindi initiating his long-drawn legal process and associated negativity around the civil actions. 1 3 1 . These personal and private conversations between Vurimindi and his wife on day-to-day basis were prominently discussed in a mocking fashion by the local business owners and their support staff, including Starbucks Coffee Bartenders. 1 3 2 . Between July 2009 and through November 2009, in addition to discussing Vurimindi’ private conversations in mocking fashion, Starbucks Coffee Bartenders uttered various types of provocative comments, which raise doubt and/or suspicion about Vurimindi’ private life, work life along with rumors that were circulated against Vurimindi at Duke. 1 3 3 . Vurimindi was concerned about Starbucks Coffee Bartenders provocative comments and negative publicity or attention that Vurimindi is getting at Starbucks by its bartenders and customers. 1 3 4 . In November 2009, soon after graduating from Duke, Vurimindi asked Starbucks Store Manager to cease and desist her staff from making provocative comments in anyway related to Vurimindi. 1 3 5 . Starbucks Coffee Bartenders continued to make provocative comments and give negative publicity to Vurimindi to its customers. Hence, in 4th week of November 2009, Vurimindi contacted Starbucks Corporate Office by telephone and complained about Starbucks Coffee Bartenders continued negative publicity to Vurimindi to its customers. 1 3 6 . Starbucks Coffee Bartenders continued to make provocative comments and give negative publicity to Vurimindi to its customers. Hence, on 16th December 2009, Vurimindi contacted Starbucks Corporate Office by telephone and enquired about the status of his complaint about Starbucks Coffee Bartenders continued negative publicity to Vurimindi to its customers. 1 3 7 . Starbucks Corporate Office, don’t have any information about Vurimindi’ complaint dated 30th November 2009. In order to track the status of his complaint, Vurimindi asked Starbucks to
  20. 20. Page - 20 - of 164 assign a number to his complaint; and Starbucks assigned a number # 777-4355 to Vurimindi’ complaint. 1 3 8 . In the 4th week of December 2009, Starbucks regional manager contacted Vurimindi to seek more information from Vurimindi about his complaint. At that time, Vurimindi explained the details coffee bartenders provocative comments about Vurimindi’ private facts, private conversations that he had with his wife and his friends in his condo, and negative publicity given to Vurimindi by the coffee bartenders. 1 3 9 . Vurimindi asked Starbucks regional manager, as to how his staff is able to procure Vurimindi’ private facts, private conversations that he had with his wife and his friends in his condo. But, Starbucks regional manager neither denied his staff procuring Vurimindi’ private facts and conversations; nor provide the information as to who is relaying Vurimindi’ private facts and conversations to his staff. 1 4 0 . Nevertheless, Starbucks Coffee bartenders continued to make provocative comments and give negative publicity about Vurimindi to their customers, until Starbucks denied services to Vurimindi in August 2010. 1 4 1 . Upon enquiry, belief and information, Starbucks Coffee bartenders continued to give negative publicity about Vurimindi to their customers about Vurimindi. F. Excessive publication and taunting about Vurimindi’ disabilities in and around HSFLB: 1 4 2 . Upon enquiry, belief and observation, in September 2009, Borowski first label Vurimindi as “schizophrenic”, “crazy”, “moody”, “paranoid”, “depressed”, “hallucinate”, “violent” and “sexual predator” and told to residents of HSFLB and residents around HSFLB. 1 4 3 . In September 2009, Pattinson, told to Vurimindi that, “We don’t believe the stories that they are circulating about you”. At that time, Vurimindi was under severe distress, because there are numerous severe false and baseless accusations against Vurimindi at Duke and didn’t have motivation to seek more information about Pattinson’ assurance about Vurimindi. 1 4 4 . Upon enquiry, belief and observation, since September 2009 and still continuing, Borowski, Westfield, Baute, McCracken, Tiefenback, Stanly, Palmer, Felice and Elliot over and over
  21. 21. Page - 21 - of 164 publicized about Vurimindi as “schizophrenic”, “crazy”, “moody”, “paranoid”, “depressed”, “hallucinate”, “violent” and “sexual predator” to OldCity local business owners such as Café Ole and Old City Cheese Shop, numerous residents in and around HSFLB, and numerous customers of the local business establishments. 1 4 5 . Upon enquiry, belief and observation, since September 2009, and on a regular basis during evening 7:00 to 9:00 PM, Westfield, her husband Kooshan Nayerahmadi, Westfield’ brother- in-law and Borowski, Pattinson, Elliot, Tiefenback, Palmer, and Young and their friends sitting in Westfield’ living room, just below Vurimindi’ living room, taunt Vurimindi as ‘Hey Crazy”, “Hey crazy you are fucked up”, “Wyeth fucked you”, “we will fuck you up”. 1 4 6 . As Vurimindi get irritates and in huff get-out of his unit and comes down and stand in front of HSFLB, Westfield, Pattinson, Borowski, Elliot, Tiefenback, Palmer and Young send their friends and acquaintances to further taunt and verbally assault Vurimindi. 1 4 7 . Occasionally, Vurimindi ignores Westfield, Pattinson, Borowski, Elliot, Tiefenback, Palmer and Young’ taunting and talk to his relatives about the harassment over telephone, Westfield, Pattinson, Borowski, Elliot, Tiefenback, Palmer and Young starts a parallel running commentary, based on Vurimindi’ emotions during his telephone conversation. 1 4 8 . Upon enquiry, belief and observation, since September 2010, soon after, Borowski filed her private criminal complaint against Vurimindi, many City employees, including police periodically visit Cafe’ Ole, when Vurimindi present in the Cafe’ Ole made provocative comments and hand and body gestures indicating to other customers that Vurimindi is “schizophrenic” and “crazy”. G. Ostracizing Vurimindi’ in and around HSFLB: 1 4 9 . Upon enquiry, and belief, since February 2007, Segal was in direct contact with Vurimindi’ managers at Wyeth Pharmaceuticals to procure Vurimindi’ work-life facts and rumors against Vurimindi and published to the residents in and around HSFLB as Vurimindi not capable for managerial responsibilities and undermined Vurimindi’ professional status and personal standing by way of isolating Vurimindi among residents in and around HSFLB.
  22. 22. Page - 22 - of 164 1 5 0 . Upon enquiry and belief, since February 2007, Segal is in direct contact with many restaurants in Old City section of Philadelphia and told to restaurant owners and their workers as Vurimindi is a bad person. 1 5 1 . Upon enquiry, belief and observation, since, September 2009, Westfield, Borowski, Tiefenback, Segal, Felice and McCracken told to residents in and around HSFLB, “don’t talk to Vamsi”, “Stay away from Vamsi”, “Vamsi is a bad person”, “Vamsi isn’t a good person”, “need to be careful with Vamsi”, “Vamsi is a dangerous person”, “Vamsi has criminal history”, “Vamsi is a danger to the people”. 1 5 2 . Upon enquiry, belief and observation, since sometime in October 2009, McCracken, Pattinson and Borowski together organized many social gatherings and parties in McCracken’ condo told to their invitees that “Vamsi is not a good person, stay away from him”. 1 5 3 . Upon observation, since November 2009, after Vurimindi file his complaint with Starbucks corporate office, Westfield yells at Vurimindi as “smelly”, when she passes by Vurimindi. 1 5 4 . Upon observation, since November 2009, Westfield behaves weird with Vurimindi, when Westfield comes across Vurimindi in the elevator, when she walks her dog. Despite her dog is standing quite, a Westfield shout at her dog. In fact, Westfield uses her dog as an excuse, to express her anger at Vurimindi. 1 5 5 . Upon observation, since November 2009, sometimes, when Westfield and Vurimindi come across each other in the elevator, she pick her arm up and smell her forearm; and sometimes when Vurimindi walk past Westfield, she yells at Vurimindi, “today dog is smelling”. 1 5 6 . Upon enquiry, belief and observation, since, March 2010 Young and her boy friend told to bartenders and customers at Charlie’s Place that referring Vurimindi as, “he is an anti-social”, “he is a freak”, “he is crazy” and “he is schizophrenic”. 1 5 7 . Upon enquiry, belief and observation, since February 2010, Stanley, Westfield, McCracken along with bartenders at Charlie’ Place (Dan and Matt) told to their friends attended the party. After half hour, suddenly Defendant told to his friends that, “he is selfish, don’t talk to him”, indicating as a sign of personal weakness. 1 5 8 . Upon enquiry, belief and observation, soon after Commonwealth indicted Vurimindi, Old City District sidewalks cleaning personnel, City’ Parking space patrol inspectors and Staff at City’
  23. 23. Page - 23 - of 164 Fire Station-Engine 8 & Ladder-2 told to residents in and around HSFLB and referring to Vurimindi as, “stay away from him”. 1 5 9 . In March 2010, in order discuss Vurimindi’ ordeal with Borowski, Pattinson, and Westfield, Brill asked Vurimindi to come to her unit sometime around 12:15 AM. Initially, Vurimindi was hesitant to go at that time, but Brill texted Vurimindi that she has some time to talk to Vurimindi at that time. 1 6 0 . As averred somewhere in this complaint, Vurimindi told to Brill about his belief about Borowski, Pattinson, and Westfield eavesdropping into Vurimindi’ affairs and Brill confirmed that she can hear her neighbors conversation. Brill told to Vurimindi that she will get back to Vurimindi after few days. Nevertheless, next day onwards, Brill publicized that Vurimindi as a ‘Gay’ to many people in and around HSFLB. 1 6 1 . In March 2010, when Brill enquired Borowski on behalf of Vurimindi, Borowski told to Brill that Vurimindi is asking sexual favors from Borowski; and she doesn’t want to do that favor. 1 6 2 . Brill was swayed and persuaded with Borowski’ explanation, and becomes hostile to Vurimindi, without revealing Borowski’ explanation; and joined the bandwagon along with Tiefenback and followed Vurimindi to Starbucks. 1 6 3 . In March 2010, when Addimando enquired, Brill, “What is the issue between Vamsi and Allison?” Brill told to Addimando that, “Vamsi is asking sexual favors from Allison and she don’t like to give it to him”. 1 6 4 . In April 2010, Brill asked her acquaintances to take Vurimindi’ pictures. Vurimindi doesn’t know what is going; when Vurimindi enquired Brill’ acquaintances as to why they taking Vurimindi’’ pictures trey refused to answer. 1 6 5 . After few days, Vurimindi enquired a person, who is taking Vurimindi’ picture and he identified himself as, “Paul”, and told to Vurimindi that, “Kendra, told to me that, you threatened someone that you are going to take their pictures”. At that time, Vurimindi told to “Paul, please let Kendra know that she is completely off-base, and I didn’t tell to anyone that, I will take pictures”. 1 6 6 . Immediately, Vurimindi tried to reach Brill, and to ask, why she is attributing false acts or statements to Vurimindi, but she refused to talk to Vurimindi.
  24. 24. Page - 24 - of 164 1 6 7 . Nevertheless, between May and June 2010, as and when, Brill passed Vurimindi, as if she is talking to her dog, say “girl go ahead”. In reality, she is saying to Vurimindi you’re a girl. 1 6 8 . Between May and June 2010, during evenings, when Brill pass Vurimindi say, “we are going to play” and next day morning when she pass Vurimindi, “we had goodtime last night” or “we had wonderful sex”. Vurimindi doesn’t know what to think about it, but just say “good for you”. 1 6 9 . As averred somewhere in this complaint, Brill almost every day followed Vurimindi to Starbucks Coffee shop, and use the Starbucks employees or some other customers as an anchor, and pass comments against Vurimindi. 1 7 0 . In September 2010, while Vurimindi standing in front of HSFLB, the souvenir shop owner approached Vurimindi and asked, “Are you spying”. At that time, Vurimindi felt uncomfortable and told him, “No, I am just watching and taking few minutes break from my work”. 1 7 1 . In November 2010, when Vurimindi discretely enquired through his friends, what exactly is happening and why the people in and around HSFLB don’t interact with him, Vurimindi came to know that, Brill portrayed Vurimindi as “bad person” to the store managers at Roche- Bobois, Dane Decor, Snyder Gallery, souvenir shop owner and residents in the Cherry Street, just right behind HSFLB. 1 7 2 . After that, when, Vurimindi started enquiring, in the neighborhood, several people recognized Brill, and told that, “Kendra, mentioned that you are spying on people in your building”. At that time, Vurimindi clarified to them, that “I am not doing anything, and don’t even think about that at all”; further, told them, that “actually the people in my building are spying on me”. 1 7 3 . Between July 2009 and March 2011, Brill, Rosen Shah, Young, Borowski, Christine, Westfield, and Pattison organized several parties, pot luck dinners and invited several people from the neighborhood; during that time, accusations and stories branching out of the situations during Plaintiff time at Wyeth, Wharton and Duke were openly discussed by Brill in the presence of Rosen Shah; 1 7 4 . Upon enquiry and belief, Brill along with Borowski induced other by organizing private parties to the named defendants and conspired with other named defendants and actors in this complaint to remove Vurimindi from his condo.
  25. 25. Page - 25 - of 164 1 7 5 . Upon enquiry and belief, Brill acted as mouth piece to Borowski to defame Vurimindi in and around HSFLB. 1 7 6 . Upon enquiry and belief, Brill and Borowski on day-to-day basis strategize as to how to remove Vurimindi from his condo. 1 7 7 . Upon enquiry and belief, Pattison told too many people in and around HSFLB that Vurimindi either had sexual relations with the woman staff works in the local restaurants or attempted to have sexual relations with woman staff works in the local restaurants. H. Surveillance against Vurimindi’ in and around HSFLB: 1 7 8 . Upon enquiry, belief and observation, since March 2009, everyday Pattinson follow Vurimindi to observe with whom Vurimindi has been interacting on his way to Starbucks to get his early morning coffee, until Vurimindi stopped going out for coffee to go to Starbucks. 1 7 9 . Upon enquiry, belief and observation, since, September 2009 and until February 2012, HSFLB maintenance personnel (Al Cunningham12 and Anthony) conducted surveillance on Vurimindi, by snooping and shadowing Vurimindi in and around HSFLB Building and informed about Vurimindi’ whereabouts to Borowski, Tiefenback, Stanly, Palmer and Elliot. 1 8 0 . Upon enquiry, belief and observation, since December 2009 and up until June 2010, Tiefenback along with Michael (Borowski’ father) followed numerous times to Starbucks Coffee Shop, and made observations about Vurimindi’ interactions with Starbucks Coffee Bartenders. 1 8 1 . Upon enquiry, belief and observation, since September 2009 and until February 2012 Starbucks Coffee bartenders, participated and conducted surveillance on Vurimindi and informed about Vurimindi’ whereabouts within the vicinity of Starbucks store to Borowski, Tiefenback, Stanly, Palmer Elliot and other unknown person(s) to Vurimindi. 1 8 2 . Upon enquiry, belief and observation, since, September 2009 and until February 2012, Westfield track the location of Vurimindi in his unit, based on wooden floor squeaking noise, and as soon Vurimindi stepped out from his unit, Westfield informs to Borowski, Pattinson, 12 Prior to work at 806 Capital LLC, Al Cunningham worked for Redevelopment Authority, City of Philadelphia; and Vurimindi, initiated a civil action against Redevelopment Authority in July 2009.
  26. 26. Page - 26 - of 164 Tiefenback, Stanly, Palmer and Elliot via text message, such these defendants can come across or walk along Vurimindi and make provocative comments about Vurimindi’ private conversations that he had with his wife or his relatives. 1 8 3 . Upon enquiry, belief and observation, since September 2009 and until February 2012, every day evening between 5:30 to 6:30 PM, Tiefenback prominently standing in front of the HSFLB and informs about Vurimindi’ presence in an around HSFLB by sending text messages to Borowski, Pattinson, Brill, Westfield, Stanly, Palmer and Elliot, to either to avoid Vurimindi or to come across or walk along Vurimindi. 1 8 4 . Upon enquiry, belief and observation, since March 2010, Brill almost every day followed Vurimindi to Starbucks Coffee shop, make provocative comments about Vurimindi’ private conversations that he had with his wife or his relatives, using Starbucks Coffee Bartenders or Starbucks customers as her “side kick” to anchor her provocative comments directed towards Vurimindi. 1 8 5 . Upon enquiry, belief and observation, since September 2009 and until February 2012, Baute by foot, snoop and shadow Vurimindi in and around HSFLB and inform Vurimindi’ whereabouts in and around HSFLB to Borowski, Pattinson, Brill, Westfield, Stanly, Palmer and Elliot and other unknown person(s) to Vurimindi. 1 8 6 . Upon enquiry, belief and observation, since September 2009 and until February 2012, Felice, Vitella, McCracken, Brill and Young organized a community-wide surveillance against Vurimindi along with Borowski, Pattinson, Westfield, Stanly, Segal, Palmer, Elliot and HSFLB maintenance personnel and along with and other unknown person(s) to Vurimindi. 1 8 7 . Upon enquiry, belief and observation, since September 2009 and until February 2012, Segal along with other unknown person(s) to Vurimindi, asked owners of the restaurants in and around Old City to participate in community wide surveillance on Vurimindi. 1 8 8 . Upon enquiry, in April 2010, Tiefenback told to Vurimindi, that Starbucks Coffee Bartenders sends text message to him and to some other people about Vurimindi’ presence in the Starbucks coffee shop, and while Vurimindi in the Starbucks Coffee shop, Borowski would leave her unit, such that she can avoid the Vurimindi.
  27. 27. Page - 27 - of 164 1 8 9 . Upon enquiry, belief and observation, since May 2010, HOA, Borowski, Westfield, Pattinson, and Brill caused an overzealous surveillance by “ATF”, “FBI” “Department of Homeland Security (DHS) and “Police” through by snooping and shadowing Vurimindi in and around HSFLB. 1 9 0 . Upon enquiry, belief and observation, since May 2010, when Vurimindi doing his errands in the local neighborhood establishments, Hodgson, Segal, Palmer, Tiefenback, McCracken, Engel, Vitella, and Stanly and acquaintances13 of Borowski, Pattinson, and Brill walk towards Vurimindi along with “ATF”, “FBI” “Department of Homeland Security (DHS) and “Police”, in a provocative manner and in a mocking fashion referring to Vurimindi said, “he is a juvenile delinquent”, “he launders money”, “he is illegal”, and talk about Vurimindi’ internet browsing pattern, type of websites, and what information Vurimindi has been reading lately on his computer. 1 9 1 . Upon enquiry, belief and observation, even after Vurimindi rented a space outside of his condo, and continued his day-to-day activities, and get-out early and come-back very late into his condo, Westfield, Borowski, Pattinson, Tiefenback, Stanly, Palmer and Elliot continue to make provocative comments about Vurimindi’ personal conversations with his friends that he had in his office out-side of his condo. 1 9 2 . Upon enquiry, belief and observation, since May 2010 and until February 2012, City’ Philadelphia Police Department snooping and shadowing Vurimindi in and around HSFLB to terrorize Vurimindi. 1 9 3 . Upon enquiry, belief and observation, sometime after July 2009, City police attached a GPS device to Vurimindi’ vehicle to conduct surveillance on Vurimindi’ movements, because numerous times police cars followed Vurimindi in and around center City, because there was a rumor against Vurimindi that, Vurimindi in his past did some horrible14 act like shooting people or crashing his car. 13 Upon enquiry, belief and observation believe Borowski, Pattinson and Brill enticed their male acquaintances by giving sexual favors and on ‘qui-pro-quo’ basis their male acquaintances are snooping and shadowing Vurimindi. 14 On July 31,2009, Ellen Wilbur, Duke’ Director for Executive MBA Program, writes an email to Duke Dean, referring a comment made by Mark Brown, Duke’ Administrator as follows: John, Libby Webb is the Associate
  28. 28. Page - 28 - of 164 1 9 4 . Upon enquiry, belief and observation, between February 2010 and February 2011, when Vurimindi had an argument with his wife over telephone and for privacy, when Vurimindi quickly get-out of his unit and stand in front of the closed store, and continue his conversation, several times Palmer followed Vurimindi to outside of the building and walk his dog near to Vurimindi and listen to Vurimindi’ conversations. 1 9 5 . Upon observation, between February 2010 and February 2011, several times, Palmer questioned Vurimindi, “Why are you standing here?” when Vurimindi standing outside of HSFLB, and having his telephone conversations. In response, Vurimindi told to Palmer, as “if you tell what you know about the ongoing harassment, then it will be less work for me to get the bottom of this”. In response, Palmer told to Vurimindi, “during my time in this building, I hardly spoke with Borowski and Pattinson not more than five minutes”. 1 9 6 . Upon enquiry, belief and observation, Palmer is in contact with one of the Borowski, and/or Westfield and/or Pattinson, and upon information from one of them, Palmer snoop around Vurimindi. 1 9 7 . Upon enquiry, belief and observation, soon after, Commonwealth indicted Vurimindi based on Borowski’ private criminal complaint for harassment and stalking, sometime, in September 2010, Michael, Borowski, Palmer, Brill, Elliot and Stanley contacted Old City Civic Association, Old City Business Collective, City’ Old City District, City Councilman Frank DiCicco and other City Council members and sought assistance in conducting elaborative surveillance on Vurimindi. Director of Counseling & Psychological Services (CAPS). She will be out of the office for two weeks starting Monday. She can speak with you at 3:45 this afternoon and will be awaiting your call at “REDACTED”. She is someone whom Kathie and I spoke with earlier in the year (mid-January) about our concerns about this same student. Her email address is “REDACTED”. If you want to forward along to her the email that you sent to the Lt which contained Shana's concerns. Also, I did see Mark Brown after lunch when I was in Pam Brown's office. He did a team intervention around March 1 with this student's team as they entered Term 4. Robert Ross was extremely vocal about his team concerns in a variety of emails that has copied “REDACTED” on in preparation for this meeting. Shana too was forthcoming about her concerns. Mark is in a faculty meeting until 4PM, but said he would be happy to update you. He said that he would be on campus tomorrow too if needed as he will be here for the launch of the daytime program. His parting remark to me was that none of us would be surprised if we learned that this student had done some horrible act (like shooting people or crashing his car). That was reason enough to be concerned. Let me know how I can assist. E
  29. 29. Page - 29 - of 164 1 9 8 . Upon enquiry, belief and observation, soon after Commonwealth indicted Vurimindi, Old City District sidewalks cleaning personnel, City’ Parking space patrol inspectors and Staff at City’ Fire Station-Engine 8 & Ladder-2, joined in community surveillance against Vurimindi and inform about Vurimindi’ presence in and around HSFLB to Borowski, Pattinson, Palmer, Brill, Elliot and Stanley. 1 9 9 . Upon enquiry, belief and observation, since July 2009 and until March 2010, Pattinson and Brill, obtain his hair-cut appointment times from Moko Hair Salon and sends their friends at the same-time to hear his casual conversations that he had with his hair stylist; and then make provocative comments at Vurimindi. 2 0 0 . Upon enquiry, belief and observation, since April 2010 and until February 2012, Borowski, Brill, Westfield and Palmer, obtain his hair-cut appointment times from Lakshmi Hair Salon and sends their friends at the same-time to hear his casual conversations that he had with his hair stylist; and then make provocative comments at Vurimindi. 2 0 1 . Upon enquiry, belief and observation, since August 2011 and until February 2012, Brill, Palmer and Elliot contacted many dog owners in and around OldCity and asked to inform Borowski, Palmer, Brill, Elliot and Stanley about Vurimindi’ presence in and around OldCity. 2 0 2 . Upon enquiry, belief and observation, immediately after criminal court issued a restraining order against Vurimindi, since 15th December 2011, Borowski, Brill, Palmer, Stanley, Westfield, Tiefenback, McCracken, Elliot, Felice, Vitella, and HSFLB maintenance personnel Anthony along with Starbucks Coffee bartenders, closely monitor Vurimindi’ location in and around HSFLB, and make Borowski to provoke Vurimindi with her angry gaze at Vurimindi. 2 0 3 . Upon enquiry, belief and observation, on 12th January 2012, at about 6:00 PM, while Vurimindi walking his dog back to his condo Jennifer, Starbucks Coffee Bartender, conducting a surveillance on Vurimindi, and informed Vurimindi’ whereabouts to Borowski. 2 0 4 . Upon enquiry, belief and observation, on 12th January 2012, at about 6:00 PM, as Starbucks Coffee Bartender informing about Vurimindi’ exact timing to arrive near to HSFLB, and Vurimindi about to enter into HSFLB, Borowski suddenly appeared before HSFLB and attempted to provoke Vurimindi through her angry glare at Vurimindi.
  30. 30. Page - 30 - of 164 2 0 5 . On or about 15th January 2012, when Vurimindi contacted a new resident of HSFLB, Kirsten Sherman (“Sherman”) by leaving a note outside of Sherman’ unit and asked her if she had any information regarding Borowski’ allegations in her private criminal complaint against Vurimindi, and specifically told her that would be beneficial to Vurimindi, if she could tip Vurimindi prior to 27th January 2012, the trial date set by the criminal courts. 2 0 6 . Because, Borowski, Westfield, Pattinson, Palmer, Brill, Elliot and Stanley conducting an intense surveillance against Vurimindi, Borowski found that Vurimindi contacted Sherman for information about Borowski’ harassment against Vurimindi, and Borowski took that note from Sherman and give that Vurimindi’ note to Commonwealth’ City District Attorney as a violation to stay away order against Borowski. 2 0 7 . On 4th February 2012, at about 6:10 PM while Vurimindi walking his dog back to condo, Monique Mason (“Mason”), the woman who own “Moko” hair salon, stopped Vurimindi and yelled at Vurimindi “you have problems with the neighborhood” and demanded Vurimindi to withdraw his subpoena to produce documents in the civil action Vurimindi vs. Fuqua School of Business et al and told in an angry tone told to Vurimindi that, “my brother is an attorney and I can cause problems to you” and continued her angry conversation. 2 0 8 . On 4th February 2012, at about 6:15 PM or so, Vurimindi came to the intersection of 3rd and Arch St and at that time, Borowski’ sex partner15 walk past Vurimindi with another woman along with a dog. At that time, he told to Vurimindi “I had a good hump with Allison” and “we are having to night” with an angry gaze at Vurimindi. 2 0 9 . Between 30th January 2012 and 4th February 2012 5:00 PM, Palmer repeatedly followed Vurimindi in the corridors of the HSFLB with an angry glare attempted to provoke Vurimindi to start an argument. 2 1 0 . Between 7:00 AM on 7th February 2012 and until 8:00 AM on 10th February 2012, Palmer repeatedly followed Vurimindi in the corridors of the HSFLB and with an angry glare and sneering look at Vurimindi, and it is certain to Vurimindi that Palmer is provoking Vurimindi to say something to him. 15 An oriental looking person, don’t know the name but, Vurimindi saw him many times entering into 315 Arch St building.
  31. 31. Page - 31 - of 164 2 1 1 . On 9th February 2012, at about 9:00 PM, when Vurimindi get out of his condo, Michael followed Vurimindi in the corridors of the HSFLB and with an angry glare and sneering look at Vurimindi, and it is certain to Vurimindi that Michael is provoking Vurimindi to get agitated. 2 1 2 . On 9th February 2012, at about 9:10 PM, Vurimindi called police and at about 9:30 PM police came to HSFLB and at that time, Brill preempted Vurimindi and gets down ahead of Vurimindi and begins to say to the Police that Michael don’t live here and with an angry glare and sneering look at Vurimindi, and it is certain to Vurimindi that Brill is provoking Vurimindi to get agitated. 2 1 3 . On 10th February 2012, at about 8:30 AM, when Vurimindi coming out of HSFLB to attend a hearing in the criminal courts, Stanley16 along with his girl friend, Rebecca Platt, made provocative comments directed at by looking at Vurimindi and said that, “he is going for a picnic”, referring to the incarceration that to be happened at few hours later at about 10:30 AM. 2 1 4 . On 11th April 2012, when Vurimindi attend the criminal court, City’ Police and Commonwealth’ law enforcement personnel continued to conduct surveillance on Vurimindi. 2 1 5 . Between, 15th April 2012 and 31st August 2012, City’ Police and Commonwealth’ law enforcement personnel conducted surveillance on Vurimindi at his temporary transitory accommodation. 2 1 6 . On 31st August 2012, after movers dropped all his belongings from the truck and Vurimindi went to a nearby bank, City’ probationary officer followed Vurimindi into the bank, despite Vurimindi wasn’t under any surveillance, City’ law enforcement personnel abusing their authority to create psychological terror upon Vurimindi. 2 1 7 . Upon enquiry and belief, since, September 2010 and until February 2012, Starbucks employees participated in the communitywide surveillance against Vurimindi and informed his whereabouts in and around HSFLB to Defendants Stanly, Tiefenback, Palmer, Hodgson, and Borowski. 16 Who had threatened Vurimindi, earlier in February 2011 as “If you have guts stay at the same place, where you are, I will come after you, when I come back from my Iraq trip”
  32. 32. Page - 32 - of 164 I. Purposefully lying to Vurimindi about Surveillance against Vurimindi and refusing to resolve the issue: 2 1 8 . In February 2010 Vurimindi enquired Palmer, “what is going on? How my personal conversations reaching several people in the community?” but Palmer told to Vurimindi as, “I don’t know anything about it” 2 1 9 . In March 2010, Vurimindi enquired Addimando by email as, “It is just only for your information and requesting a quite action. It came to my attention that Al and Anthony have been making insinuating comments against my personal business and further, that these two people along with some other neighborhood store employees are actively involved in spreading rumors and ostracize me among the neighbors. Is it possible to restrain Al and Anthony from engaging in such activity? I am actively pursuing other remedies against other neighborhood stores to protect my dignity and rights. In response, I appreciate any help in this regard”. In response Addimando replied as, “I have spoken to Al for you. He has denied making any comments. Also, please be advised that 806 Capital does not have any employees.” 2 2 0 . In May 2010, Vurimindi enquired Palmer, “what do you know about my personal conversations are being rumored across the neighborhood”, but Palmer told to Vurimindi as “I don’t know anything about it” 2 2 1 . In July 2009, Vurimindi enquired Pattinson as to how Vurimindi’ private marital facts become talking point to vendors at local business establishments and to the Vurimindi’ classmates at Duke, but Pattinson told to Vurimindi that, she doesn’t know what Vurimindi is talking about. 2 2 2 . In October 2009, Vurimindi enquired Pattinson, whether she has any concern regarding noise from the Vurimindi’ unit, but Pattinson told to Vurimindi that she didn’t hear anything from the Vurimindi’ unit. 2 2 3 . In November 2009, Vurimindi enquired Borowski, whether she has any concern regarding noise from the Vurimindi’ unit, and as to how his private facts and personal conversations that he had in his condo with his wife and others are being published to people in and around HSFLB. But Borowski didn’t respond to Vurimindi’ enquiry.
  33. 33. Page - 33 - of 164 2 2 4 . In November 2009, Vurimindi, multiple times enquired Tiefenback as to how he know about Vurimindi’ private and intimate conversations, but Tiefenback responded as “I don’t know what you are talking about”. 2 2 5 . In the 2nd week December 2009, Vurimindi in-person enquired Borowski, whether she heard Vurimindi’ loud conversations, but Borowski told to Vurimindi that she didn’t hear anything. 2 2 6 . In December 2009, Vurimindi enquired Brill, Pattinson, Westfield, Hodgson, Tiefenback, and Palmer as to how his private life facts and conversations that he had in his condo being published to staff at Starbucks, Charlie’s Place, Race Street Café, and Café Ole and in response they told “We don’t know what you are talking about”. 2 2 7 . In June 2010, Vurimindi, again enquired Defendant Pattinson and requested her help to find how, Vurimindi’ personal conversations are reaching people in the community, but Pattinson told to Vurimindi that, she don’t know nothing about it. 2 2 8 . In 1st week of August 2010, Vurimindi left a note for Borowski enquiring, “Did you recently try to get in touch with me? Do you feel threatened by me? Did you inform to anyone that I have threatened you? Did you inform anyone in this building about this? Did you informed to anyone about this in the neighborhood? When it would be convenient for you to talk about this? I prefer to have one-on one conversation with you, however, if you aren’t comfortable to have a face-to-face dialogue with me, please send me an email”. Nonetheless, Borowski didn’t reply to Vurimindi. 2 2 9 . Immediately, Vurimindi contacted Michael (Borowski’ father) to intervene and put an end to surveillance on Vurimindi, but Michael didn’t respond. 2 3 0 . In September 2010, some-time after Borowski filed a private criminal complaint against Vurimindi, yelled across the wall, referring to Vurimindi, “Dad, mom didn’t do anything to you, you did to yourself”. Immediately, Vurimindi shouted back, “what are you talking?” and “What did I do to be treated like this?” and asked her “Please tell me what is going on?”But Pattinson didn’t respond to Vurimindi. 2 3 1 . Between September and October 2010, Vurimindi enquired Pattinson, “why do you think that I hurt myself”, but Pattinson responded “I don’t know what you are talking about” and asked Vurimindi not to talk to her, because, it is a harassment to her. 2 3 2 . In December 2010, a day before, HealthCore terminate Vurimindi’ contract, Westfield shouted across the floor “hey crazy, they are going to fire you”.
  34. 34. Page - 34 - of 164 2 3 3 . Immediately, Vurimindi shouted across floor, “How do you know, that HealthCore is going fire me?” But, Westfield didn’t respond to Vurimindi. 2 3 4 . In December 2010, Vurimindi enquired Addimando as, “Gianna Spatoulas, It came to my notice today that the trash removal person hired by 806 Capital is monitoring my activity in and out of my condo. Several times, I have requested you to urge your employees / contractors and residents in the building restrain from monitoring my movements, however it is continuing and interfering with my privacy.” In response Addimando replied as, “Vamsi, Your continued emailed, written and in person harassment of other owners at 313 Arch, employees of 806 related entities, and vendors contracted by the Hoopskirt Lofts Condo Association, has to cease and desist immediately. Nobody cares enough about your whereabouts and other personal or business matters to be spying on you, or slandering you, as you have alleged. I suggest that rather than filing frivolous claims against my company, Starbucks and your fellow condo owners, that you seek psychiatric help. You are obviously disturbed in some way and you have made many of the other owners in your building very uncomfortable. Numerous complaints have been filed against you with the police. This is not a conspiracy against you but rather a reasonable response by reasonable people to the irrational behavior that you have and continue to display. If you continue to behave in this manner, I suspect that you will soon face legal and potentially criminal consequences. There is no need for this. Go about your own business, stop harassing your neighbors, stop sending emails like the one below and stop wasting everyone’s time. This is the last email that you will receive from me or any member of the Condo Association’s assigned property manager in response to any of your deranged complaints.” 2 3 5 . In February 2011, after, Vurimindi realized Palmer is lying to Vurimindi and said to Palmer that, “don’t think that if you didn’t reveal, I don’t get the bottom of this nonsense”. Next day after this conversation Palmer retaliate Vurimindi, by wearing a T-Shirt prominently printed as “You are dumb” and specifically waited near Vurimindi’ office until Vurimindi comes out of his office and read his t-shirt. At that time, Vurimindi asked Palmer, “is that you are trying to make a statement?” In response, Palmer simply smiled and walk past Vurimindi’ office.
  35. 35. Page - 35 - of 164 J. Intrusive enquiry into Vurimindi’ Private Facts: 2 3 6 . In August 2009, Engel prominently sitting in front of HSFLB strike a conversation with Vurimindi and asked Vurimindi, “why don’t you be humble and mingle with people”; In response, Vurimindi told to Engle, “I like to mingle with all of the residents and for some reason, they don’t invite me to their homes or respond to me when I express my interest to be as their friend”. 2 3 7 . In October 2009, when Vurimindi entering into the building, Tiefenback strike a conversation with Vurimindi and during that conversation, Tiefenback asked the Vurimindi, “Where did you attend your undergraduate program?” Vurimindi thought that Tiefenback might be referring a job opportunity and asked him, “Do you have an employment opportunity? I will give you my resume”. In response, Tiefenback replied, that, “No I don’t have”. In response, Vurimindi told Tiefenback that he went to undergraduate course in India. 2 3 8 . In October 2009, in continuation to the just above said conversation, Tiefenback asked Vurimindi about rumors that were circulating among Vurimindi’ classmates at Duke. Immediately, Vurimindi asked Tiefenback, “How do you about such rumors?” Tiefenback didn’t respond to Vurimindi. 2 3 9 . In October 2009, Tiefenback asked Vurimindi, “Is that your wife work as a paralegal?” In response, Vurimindi asked Tiefenback, “Why do you ask?” Tiefenback didn’t respond to Vurimindi. 2 4 0 . Since November 2009, Anthony Barreca, City of Philadelphia, Law Department personnel was frequent to the business establishments, specifically to the Starbucks coffee shop and using sale and support staff, in an indirect and unpleasant mocking fashion way, suggest to the audiences that Vurimindi would soon lose his house and he knows this information, because he work for the City Law Department. 2 4 1 . The residents in and around HSFLB, speculated that Vurimindi belongs to either a ‘Tamil’ or a ‘Muslim’ militant group. As an example to the wide spread publication of these false information about Vurimindi, sometime in May 2010, when Vurimindi attended a conference meeting with other attorneys before Judge Sheppard in a civil case Vurimindi vs. Li et al, one
  36. 36. Page - 36 - of 164 attorney, told to Judge Sheppard that he heard that Vurimindi is either a ‘Tamil’ or a ‘Muslim’. Immediately, Judge Sheppard casually asked Vurimindi “Are you a ‘Tamil’ or a ‘Muslim’? Vurimindi told to Judge Sheppard, “I am neither a ‘Tamil’ nor a ‘Muslim’.”. 2 4 2 . In March 2010, when Vurimindi is walking into the HSFLB, Defendant Felice wished Vurimindi and had small talk. After few minutes, Defendant Felice asked the Vurimindi, “Where he did you go to your undergraduate school?” At that time, Vurimindi asked him, “Do you have an employment opportunity? So I can give my resume”. At that time, Defendant Felice replied, that, “I am just asking”. At that time, Vurimindi told him that he went to school in India. 2 4 3 . Right after that, Defendant Felice asked the Vurimindi, “What happened, in your undergraduate school”. At that time, Vurimindi asked the Defendant Felice, “Why do you ask”. At that time, Defendant Felice told to the Vurimindi, that “Tapan and Sarah told us that you had rough time at Duke, and we all know the total story. 2 4 4 . After that, Defendant Felice told to Vurimindi that “I am also unemployed, but I don’t talk like you”. At that time, Vurimindi asked him, “What are you talking about?” At that time, Defendant Felice told to the Vurimindi, “about your loud voice”. At that time, Vurimindi asked him, “Did anyone complained to you?” At that time, Defendant Felice responded, “You are bothering your neighbor”. At that time, Vurimindi asked “Who is that neighbor?” “Is that the neighbor that you play with?” 2 4 5 . In June 2010, when Vurimindi is just standing outside of the building and waiting to receive a delivery, Engels approached Vurimindi and started telling that he is just coming from rescuing a Mexican immigrant, who has been arrested by immigration enforcement. At that time Engels directly looked into the eyes of Vurimindi and asked whether Vurimindi had any issues with the immigration? At that time, Vurimindi asked Engels, “What made you to ask this question?” At that time, Engels told to Vurimindi that, “because, you are an immigrant, that is why I am asking”. At that time, Vurimindi responded to Engels, “Because, I am an immigrant, you can’t ask that question”. 2 4 6 . In July 2010 after, Borowski, filed a police complaint against Vurimindi, Baute asked Vurimindi, “What is going on?” At that time, Vurimindi responded “same old, same old”. At that time, Baute asked Vurimindi, “What about Police complaint by Allison?” At that time, Vurimindi
  37. 37. Page - 37 - of 164 asked “How do you know?” At that time, Baute told to Vurimindi, “Allison is a regular to my shop and my wife work with Thomas McCracken”. At that time, Vurimindi asked Baute “What is her issue?” At that time, Baute responded to Vurimindi, that “Allison doesn’t like Indians and her friends are mostly Whites, which is why Allison is not interested to talk to you”. 2 4 7 . On 30th September 2010, when Vurimindi is going to airport to catch the flight for his job interview, Young and McCracken stopped Vurimindi “why don’t you let it go?”. At that time, Vurimindi asked them “What are you talking about?” At that time Young and McCracken replied as, “It’s about the issue between you and Allison”. In response, Vurimindi asked Young and McCracken, “Why would I deserve a less than a civilized response from Allison?” and enquired Young and McCracken as “What’s your interest in this?” But, Young and McCracken didn’t respond to Vurimindi. 2 4 8 . On 30th September 2010, on evening, when Vurimindi returns back to his residence and found a certified letter from Commonwealth summoning Vurimindi to attend a court hearing, which duly acknowledged by the mailman17 on behalf of Vurimindi. 2 4 9 . Between March 2010 and September 2010, when Vurimindi stands in front of the building, and far away from the entrance of the building and having his personal telephone conversations, at that time, when Vitella walk past the Vurimindi, he use his friend as an anchor and pass comment against Vurimindi “he is living on his credit cards”; At that time, Vurimindi asked Defendant Vitella, “how did you know about my credit card bills?” At that time, Defendant Vitella didn’t respond to the Vurimindi. 2 5 0 . On March 24th 2011 morning, when Vurimindi going to his work, at about 8:05 AM, City’ police asked Vurimindi as “Are you crazy?”. Vurimindi responded as “No”; City’ police asked “Do you carry any weapons?” and Vurimindi responded as “No”; City’ police asked “Do you have any mental problems?” and Vurimindi responded “Yes, I am experiencing severe distress chronic worrying, chronic fatigue, anxiety, inability to sleep, inability to relax, irritability, restlessness, moodiness, and increase in defensiveness”; City’ police asked “Do you hear any voices or experience hallucinations?” Vurimindi responded “No”; City’ police asked, “What is happening with your neighbors?”; Vurimindi responded as “Initially neighbors ganged up 17 This same mailman acknowledged all certified letters mailed by Borowski, on behalf of Vurimindi, which is against
  38. 38. Page - 38 - of 164 against me in support of the defendants in my law suits against Wyeth and Duke. When I started enquiring why they would engage in an activity of supporting defendants in my law suits and work against me, they started telling to other people that they are afraid about me, because they believe that I am crazy and schizophrenic.” In addition, Vurimindi responded as, “Also, these neighbors and some other woman in the building having sexual and intimate relationships with men living in this building, in the OldCity neighborhood and in and around Philadelphia and use those males, to intimidate me, while I am going to my work; So I filed a lawsuit against them and now they are retaliating me by filing frivolous police complaints”. K. Eavesdropping into Vurimindi’ Private affairs: 2 5 1 . Upon enquiry, belief and observation, since August 2007, Westfield obtained Vurimindi’ private conversations between Vurimindi and his wife, by eavesdrop into Vurimindi’ unit, and published private conversations to residents in and around HSFLB. 2 5 2 . Upon enquiry, belief and observation, since September 2008, Pattinson surreptitiously eavesdrop into Vurimindi’ private affairs using mechanical and/or electronic devices and publish such private conversations to residents in and around HSFLB. 2 5 3 . Upon enquiry, belief and observation, since July 2009, Borowski surreptitiously eavesdrop into Vurimindi’ private affairs using mechanical and/or electronic devices and publish such private facts to residents in and around HSFLB. 2 5 4 . On 24th September 2009, Vurimindi contacted Addimando (as Executive member of HOA) and told him that his immediate neighbors (Westfield, Borowski, and Pattinson) using mechanical and/or electronic devices, surreptitiously eavesdropping into Vurimindi’ private affairs and publishing such private facts to other residents in and around HSFLB. 2 5 5 . In addition, on 24th September 2009, Vurimindi asked Addimando to demand Westfield, Borowski, and Pattinson to cease and desist from eavesdropping using mechanical and/or electronic devices into Vurimindi’ private affairs and publishing such private facts to others. 2 5 6 . Nevertheless, Addimando (as Executive member of HOA) didn’t enquire Westfield, Borowski, and Pattinson about Vurimindi’ allegations about eavesdropping into Vurimindi’ private affairs.
  39. 39. Page - 39 - of 164 2 5 7 . In the March 2010, Vurimindi contacted Brill and told her that staff in local business establishments told him that residents of HSFLB are relaying Vurimindi’ private life facts and his private conversations that he had in his condo and asked Brill to help him to find what exactly is going-on with Borowski, Pattinson and Westfield. 2 5 8 . In response, Brill told to Vurimindi as, “I can hear everything that my neighbor Vitella and his new girl friend’ conversations”. In continuation, Brill told to Vurimindi as, “Based on those conversations between Vitella and his new girl friend, she can tell that Vitella met a nice girl”. 2 5 9 . This is an affirmation to Vurimindi’ belief that his neighbors Borowski, Pattinson and Westfield could hear Vurimindi’ private affairs. 2 6 0 . In the March 2010, few days after Vurimindi contacted Brill, and having a telephone conversation with his friend, Vurimindi said to his friend as, “Why these people are so inquisitive about my private information and relay such information to wider audiences?” In response, Vurimindi’ fried replied, “May be someone else is asking them to procure your private information?” In response, Vurimindi said to his friend as, “if some ask them to eat shit, would they eat?” and “People eat normal food don’t do this to me”. 2 6 1 . In the March 2010, immediately next day, at about 1:00 AM, when Vurimindi was sleeping in his bedroom, Vurimindi heard a scream across the wall from Borowski’ living room; and Vurimindi jumped and not knowing what happened, shouted “What happened?”. “What happened?” 2 6 2 . In response, Borowski, yelled at Vurimindi, “Are you eating my shit?”, “Why are you listening?” This Borowski’ retaliation is an affirmation to Vurimindi’ belief that Borowski is eavesdropping into Vurimindi’ private affairs. 2 6 3 . Few days later, in March 2010, around 11:00 PM, Vurimindi had a telephone conversation with his cousin regarding an admission into London School of Economics. Few days later, when Vurimindi met with Rachel Wood and her boy friend Elliot, to enquire about what is going on with Borowski, Rachel Wood talked about Vurimindi’ conversation about an admission into London School of Economics. Immediately, Vurimindi asked Rachel Wood how she came to know about his private conversation. But, Rachel Wood didn’t respond to Vurimindi.
  40. 40. Page - 40 - of 164 2 6 4 . This is an affirmation to Vurimindi’ belief that his neighbors Borowski, Pattinson and Westfield could hear Vurimindi’ private affairs. 2 6 5 . In the March 2010, after Borowski opposed the installation of motion detection switches, and accused Vurimindi take advantage of darkness and might attack her, Vurimindi had a telephone conversation with his friend about Borowski’ accusatory style, opposition to install motion detection switches. In repose, Vurimindi’ friend responded, “Perhaps she can’t see clearly?”. In repose, Vurimindi told to his friend that, “I never see her wearing eyeglasses, and in-fact she has beautiful blue/green eyes”. 2 6 6 . In the March 2010, few days later, when Vurimindi is walking around HSFLB, Baute stopped Vurimindi and strike a conversation with Vurimindi; and during that conversation Baute repeated Vurimindi’ classification of Borowski’ eyes as “beautiful blue/green eyes”. Immediately, Vurimindi asked Baute how you know my private conversation. But, Baute didn’t respond to Vurimindi. 2 6 7 . In May 2010, when Vurimindi waiting in line to pick his coffee at Starbucks Coffee Shop, Coffee bartender Quinn, talking to another customer who is standing in front of Vurimindi, about Vurimindi’ prior night conversation with his friend in his unit, about Borowski’ association with Harvard. 2 6 8 . Based on the conversation between Coffee bartender Quinn and Starbucks customer, Vurimindi realized that, Borowski / Westfield misunderstood that, Vurimindi is talking about Borowski’ association with “Hardwood”, probably due to Vurimindi’ pronunciation. 2 6 9 . As a test immediately next day, Vurimindi purposefully had the same conversation with his friend, but very slowly and clearly such that Borowski / Westfield must understand Vurimindi’ is talking about ‘Harvard University’ and not about ‘Hardwood’. Next morning at the same time, when Vurimindi is waiting to pick his coffee, Coffee bartender Quinn talking to the same customer and acting like as if he is asking the other customer to clarify Vurimindi’ question. In response to Coffee bartender Quinn’ question, the same customer as if she is talking to Vurimindi, said that, “oh, she just like that university and don’t have any association”.
  41. 41. Page - 41 - of 164 2 7 0 . There are many more Vurimindi’ private conversations were published around HSFLB, to which Vurimindi is embarrassed to bring to the attention of the court. Vurimindi would be more comfortable to bring to courts attention as confidential / in camera proceedings. 2 7 1 . To just to give some idea as to what type of private conversations were being published: which direction , few weeks before Vurimindi confronted with his wife to leave him, Vurimindi become afraid to sleep with her in the bed-room, because his intimate conversations with his wife is publicized in the neighborhood. In February 2010, when Vurimindi in the Café Ole shop, Borowski along with her friend Mora, passed a comment at Vurimindi, “We need to help him to sleep with his wife”. L. Publication of Private facts: 2 7 2 . Upon enquiry, belief and observation, since July 2009, Borowski eavesdropped into Vurimindi’ private conversations with his wife and told to residents in and around HSFLB, as Vurimindi and his wife quarreling over money issues. 2 7 3 . Upon enquiry, belief and observation, since July 2008, Westfield eavesdropped into Vurimindi’ private conversations about Vurimindi’ reactions to his classmates’ verbal assaults and relayed to Rosen Shah. In turn Rosen Shah relayed Vurimindi’ reactions to his classmates’ verbal assaults to Vurimindi’ classmates at Duke. 2 7 4 . Upon enquiry, belief and observation, since February 2007, periodically Vurimindi’ USPS mail has been placed into mailing slots belongs to Borowski, Pattinson, Westfield, Tiefenback, Palmer, Felice, Hodgson, Young, Segal, and McCracken and were never returned that mail back to Vurimindi. 2 7 5 . Upon enquiry, belief and observation, since February 2007, Borowski, Pattinson, Westfield, Tiefenback, Palmer, Felice, Hodgson, Young, Segal, and McCracken opened Vurimindi’ USPS mail without Vurimindi’ permission, and read the contents of the mail and relayed brief bits and pieces of the contents of the mail to residents in and around HSFLB. Importantly, Borowski, Pattinson, Westfield, Tiefenback, Palmer, Felice, Hodgson, Young, Segal, and McCracken found ending balances in his bank accounts; interest charged by his bank on his

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