RSPCA and DPI conducted a public campaign against Geraldine Robertson designed to hurt her and they did hurt her. Bullying of the worst type.
The media - television, newspapers, internet were filled with RSPCA lies about Geraldine Robertson and her poodles.
(a) Television news, newspapers, internet filled with comments defamatory of Geraldine Robertson and incited violence against her.
(b)
The photographs of the puppies
temporarily
housed in holding pens/kennels together with a commentary that the Plaintiff (Geraldine Robertson) was puppy farming.
a.
This caused the public to believe the Plaintiff permanently housed those puppies in those temporary holding pens.
b.
This caused the public to believe the Plaintiff was breeding them intensively in those temporary holding cages;
(c)
Photographs and video of Plaintiff’s dogs in her back yard holding pens were published in Newspapers and TV with misleading comments.
(d)
Photographs and videos of dogs in both the brick kennels located in different areas of the 5 acres developed kennel property were published in Newspapers and TV with misleading comments
(e)
Photographs and videos of the Plaintiff’s dogs being clipped by members of the Poodle Club of Queensland Inc. at the Second Defendant premises were published in Newspapers and TV with misleading
comments;
(f)
Statements that the Plaintiff’s dogs were packing and eating each other made by the Second Defendant to others, in court and to the medias;
(g)
Statements made, or caused to be made, in court, to the medias and on the Internet by the Second Defendant included:-
a.
that the Plaintiff’s dogs were malnourished and starving;
b.
that the Plaintiff’s dogs were neglected;
c.
that the Plaintiff’s dogs were diseased;
d.
that the Plaintiff’s dogs were worm infested;
e.
that the Plaintiff’s dogs had maggots;
f.
that the Plaintiff’s dogs were full of fleas;
g.
that the Plaintiff’s dogs had infected eyes;
h.
that the Plaintiff’s dogs had infected ears;
i.
that the Plaintiff’s dogs had skin problems;
j.
that the Plaintiff’s dogs had urine burnt paws;
k.
that the Plaintiff was living off the proceeds of sales from her dogs;
l.
that the Plaintiff was funding the Plaintiff’s retirement with her dogs;
m.
that the Plaintiff’s dogs were living on their own urine and faeces;
n.
that the Plaintiff’s kennels had not been cleaned in years;
o.
that the Plaintiff’s dogs were unsociable;
p.
that the Plaintiff’s Plaintiff lived in filth;
q.
that the Plaintiff’s smell “attracted men who liked that sort of thing”;
r.
included
“those poor neglected poodles”;
s.
that the Plaintiff’s dogs were “dogs housed in appalling living conditions”;
t.
that the Plaintiff’s dogs were “dogs infested with wounds and maggots”;
u.
that the Plaintiff’s dogs had
“open wounds”;
v.
that the Plaintiff’s “dogs had fleas”,
w.
that the Plaintiff’s dogs had
“urine burnt paws”,
x.
that the Plaintiff’s dogs were
“matted with feaces and urine”,
y.
that the Plaintiff’s dogs were “ infested with hookworms”
z.
that the Plaintiff’s “dogs not clipped for years”
aa.
that the Plaintiff’s dogs had “untreated infected eyes and ears”
bb.
that the Plaintiff’s dogs were “packing and eating each other”.
(h)
The Second Defendant was stalking the Plaintiff by monitoring, publishing and adding comments to Internet forums about the Plaintiff.
(i)
The Second Defendant published in the media statements that were defamatory to and stalking of the Plaintiff.
(j)
The Second Defendant contacted the Plaintiff’s neighbours and began discussions with them that clearly placed the Plaintiff in a false light.
(k)
The Second Defendant contacted the Plaintiff’s neighbours and persuaded these neighbours to spy on the Plaintiff.
(l)
The Second Defendant stalked the Plaintiff by visiting the Plaintiff in late evening hours like 9:40 pm to serve legal documents,
(m)
The Second Defendant performed service of documents with two cars when the Second Defendant knew the Plaintiff was living alone in fear and terror, receiving death threats, abusive letters, other
threats, assaults, and harm from the public that was incited or done by the Second Defendant.
(n)
The First Defendant had made a movie ready to be released “after the legal actions” by the Plaintiff for television Channel 7 RSPCA Animal Rescue TV show about the Plaintiff and her poodles.
(o)
The RSPCA Animal Rescue TV Show seeks donations from the public for the Second Defendant.
(p)
The RSPCA Animal Rescue TV show would further damnify the Plaintiff.
1.
From the 9th January 2008 the Second Defendant provided to medias videos/films, photographs and defamatory comments about the Plaintiff, that a reasonable person would understand, would cause
hatred of the Plaintiff.
2.
The Second Defendant knew or should have known that pets are an emotional issue in the community and harm to pets can incite hatred by citizens of those seen to cause harm to pets.
3.
Much of the media reporting did, or a reasonable person would expect would, incite others to have a hatred of the Plaintiff and want to punish the Plaintiff and/or see the Plaintiff punished.
4.
The Second Defendant Inspectors told other pet owners and breeders false and nasty stories about the Plaintiff.
PARTICULARS
a.
that The Plaintiff’s dogs were packing and eating each other.
b.
that The Plaintiff was only interested in the money;
c.
that The Plaintiff would only clip the puppies for sale but let the others go matted;
d.
that The Plaintiff wouldn't let anyone into the Plaintiff’s kennels for fear that the people would see the state of the kennels;
e.
that The Plaintiff used to be an okay breeder years ago but that she now had too many other dogs and wasn't interested in the poodles anymore;
f.
that the Plaintiff’s had too many dogs confined together and they can be mad;
g.
that Mrs Robertson's dogs were killing each other.
5.
The Second Defendant’s campaign caused the Plaintiff to suffer many months of violent verbal, physical, mental assaults, confrontations, harassments and attacks on the Plaintiff and her properties by
members of the public.
PARTICULARS
(q)
Offensive material was dropped and or mailed to the Plaintiff in the Plaintiff’s letterbox.
(r)
When shopping, people came up to her in public places and abused her.
(s)
The Plaintiff had people come to her on her property to abuse and assault her verbally and throw stones, cans and bottles at her.
(t)
The Plaintiff had rubbish dumped onto her property.
(u)
The Plaintiff was physically assaulted by a man with a bottle and was hit on the head with the bottle.
(v)
The Plaintiff suffered many months of continuous abusive and threatening telephone calls which caused the Plaintiff to fear she would be murdered. Statements included:
i.
calling her vile names, offensive racist descriptions;
ii.
telling her they would punish her for her evil acts;
iii.
threatening to treat her “exactly as she had treated those poor dogs”;
iv.
she deserved to be “beaten to death”.
6.
At all times material to this proceeding, the Second Defendant well knew that their behaviour and activities were and or were likely to have an adverse effect on the Plaintiffs health and well being
.
7.
Since the 9th January 2008, and as a consequence of the Second Defendant's continued behaviour and activities, the Plaintiff suffered fear and terror and an emotional breakdown whereupon the
Plaintiff was injured.
8.
The Plaintiff wrote many letter to the Fourth Defendant which were forwarded by the Fourth Defendant to the Second Defendant.
9.
These letters informed the Second Defendant of the consequences upon the Plaintiff of their campaign.
10.
Despite the Plaintiff having suffered injuries, as referred to above hereof, and despite the Second Defendant being aware of such injuries, the Second Defendant's behaviour and activities, as referred
above hereof, continued persistently, whereupon the Plaintiff was further injured.
11.
As a result of the matters aforesaid, the Plaintiff suffered and/or still suffers the following personal injuries:-
(a)
chronic post traumatic stress disorder;
(b)
nauseous spells,
(c)
clumsiness,
(d)
stumbling and falling for no apparent reason,
(e)
difficulties in concentration,
(f)
difficulties in focusing,
(g)
sobbing for little reason,
(h)
nightmares about her beloved poodles ,
(i)
strange aches on different and various parts of her body,
(j)
numbness,
(k)
dizzy spells for no obvious reasons,
(l)
chest pains similar to that of a heart attack,
(m)
extremely high blood pressure on both the lower and upper readings
(n)
fainting spells;
(o)
blackouts;
(p)
sleep disorder;
(q)
nightmares;
(r)
fear and terror;
(s)
fear of being alone;
(t)
high blood pressure;
(u)
panic attacks with uncontrolled sobbing;
(v)
memory loss;
(w)
chest pains;
(x)
distress;
(y)
headaches;
(z)
lethargy;
(aa)
vomiting;
(bb)
loss of appetite;
(cc)
emotional distress;
(dd)
shock, pain and discomfort;
(ee)
Stress related skin rashes and continued itchiness on all parts of her body.
12.
As a result of the Plaintiff’s personal injuries, the Plaintiff has:-
(a)
suffered and will continue to suffer considerable pain, suffering and inconvenience;
(b)
required medical and other similar treatment and will require further such treatment in the future;
(c)
suffered past economic loss and an impairment of her earning capacity, which has and may be productive of financial loss to the Plaintiff;
(d)
received gratuitous assistance and quasi-nursing services from others and may require further such assistance and services in the future;
(e)
received help in maintaining her property;
(f)
incurred special damages and other out of pocket expenses and may incur further such damages and expenses in the future;
(g)
The Plaintiff is fearful of being alone in her own home where she used to enjoy her privacy and solitude. This has caused her further loss of privacy and additional expenses and chores from having
helpers to stay with her;
(h)
lost some of the amenities of life;
(i)
and has been otherwise damnified.
13.
As a result of the Second Defendant’s behaviour the Plaintiff suffered harm to:-
a.
her good reputation;
b.
the good reputation of her world Famous Neiger Poodles;
c.
the good reputation of her business of operating her kennels;
d.
the good reputation of her business breeding and selling her world famous Neiger Poodles;
e.
the Plaintiff’s real, business and personal properties has lost value;
f.
impossible to return to professional employment as an Accountant or a Financial Analyst.
g.
her ability to earn an income from her established businesses;
h.
The total destruction of her businesses;
i.
Loss of the goodwill value of her kennel property;
j.
Loss of the goodwill value of her poodle breeding business;
14. The Defendants made no attempt to mitigate the Plaintiff’s losses. A deliberate personal attack on Geraldine Robertson
was conduct performed in purported exercise of the defendant’s powers as a local government.