MARYLAND CIRCUIT COURT
BALTIMORE CITY

MITUL R. PATEL, . 
Plaintiff, No. 0243/0003 5 75
VS.

MATHEW CHAN,

Defendants.

 

 

 

QQMELAINT

For his claims for relief against Defendant, Plaintiff Mitul R. Patel
(?Plaintiff?) alleges as follows:
PARTIES, JURISDICTION AND VENUE

l. Plaintiff?maintains a primary residence in Gwinnett County, Georgia.
2. Defendant Mathew Chan (?Defendant?) maintains a primary residence
loCated in Baltimore County, Maiyland.
3. Defendant?s actions, upon which the allegations in this Complaint are based,
were performed in thisjudicial district.
4. Therefore, upon information and belief, jurisdiction and venue are proper

in this Court.

COUNT I
DEFAMATION

5. On 10/01/2015, Defendant posted false and defamatory statements on the
intemet at the following web address?s: 


DrMituLPatelDDS-30366893 
dental-care-suwanee?E 
dentist~dr~mitul-pate  
dr-mitubpatei. (the ?Defamation?).

6. The Defamation was made by Defendant about and concerning Plaintiff. I

7. Without privilege, Defendant communicated the Defamation to third parties
through the Internet to world at large, without limitation.

8. The Defamation made by Defendant impeaches the honesty, integrity and
reputation of Plaintiff by implying that Plaintiff is involved in a fraudulent
scheme.

9. The Defamation is and would be highly offensive to a reasonable person.

10.The Defamation is and will continue to cause harm to Plaintiff?s reputation

unless it? is restrained and enjoined.



Dated, so respectfully, this 8 day of February, 2016


I  ,j

 

Mit?l?rpaxe?r?
276 ?Peachtree Pkwy.
Suwanee, GA 3002

Pro Per Fla-inn)?