Adam Lynd hired Respondent Kelly to remove online defamatory statements posted by two supposed cooperating defendants named Jesse Wood and Connie Hood.
Neither Respondent Kelly nor any of his staff spoke with defendants Wood and Hood about the substance of the case prior to filing the complaint.
On September 30, 2015, Respondent Aaron Kelly filed a complaint on behalf of client Adam Lynd in Maricopa County Superior Court case Lynd v. Hood, CV 2015-009398. The complaint names Connie Hood and Jesse Wood as defendants and alleges they posted defamatory staements about Adam Lynd on the internet.
Respondent Kelly took no action to determine if the statements were true or false before filing the lawsuit.
Connie Hood and Jesse Wood are not real. Connie Hood and Jesse Wood were fabricated in order to obtain a stipulated order of permanent injunction removing criticism of Adam Lynd from the internet.
Respondent Kelly knew that Connie Hood and Jesse Wood were fabricated defendants or failed to investigate the matter prior to filing the complaint.