Respondent Kelly knew that defendant Connie Hood was not the author of the allegedly defamatory statements or failed to investigate the matter prior to filing the complaint.
The complaint alleges Jesse Wood posted an allegedly defamatory statement about Adam Lynd at http://www.ripoffreport.com/r/the-lynd-company-lynd-management/san-antonio-texas-78230-the-lynd-company-lynd-management-michael-lynd-sr-michael-lynd-jr-a-david-lynd-s-435452.
Wood’s allegedly defamatory statement was posted on March 18, 2009, more than a year before the complaint in Lynd v. Hood was filed. The age of the statement exceed the one-year stattute of limitations established by A.R.S. 12-541. Respondent Kelly knew that the claim was barred by the statute of limitations or failed to investigate the matter prior to filign the complaint.
Between December 2 and 14, 2015, the Court docketed four returned mail notices for the plaintiff and the defendants. One of the returned mail notices lists client Adam Lynd’s address as “Connie Hood 122 Roy Smith St San Antonio TX 782-1361.” One of the returned mail notices lists Connie Hood’s address as “122 Roy Smith St San Antonio TX 78212-1361.”