On August 8, 2023, a TikTok creator known as @love.and.justice filed a false Civil Harassment Restraining Order (CHRO) against me in Santa Clara County, California, over 2300 miles from my home in South Carolina. In her second filing, she sought $41,000 in damages. I was compelled to fight a baseless lawsuit and felt silenced by the Temporary Civil Harassment Restraining Order (TCHRO) granted on August 10, 2023. Following her filing, she posted numerous disparaging and unfounded claims about me in a blog, along with hours of YouTube content.
NOTE: This blog is not intended to harass or harm Rachel Ann Depalma. The sole purpose is to tell my side of this horrific experience. Do not interact with, harass, or contact Ms. Depalma via social media, cell, email, text or in person. Do not contact her via her non-profit organization, No Peace No Quiet, Inc. via social media, text, phone or email or in any other manner. This blog is my opinions, experiences and statements made to the court under penalty of perjury.
On Sunday, August 20, 2023, while preparing my son for his first day of school, a process server with flashing lights arrived at my quiet cul-de-sac to serve me with the TCHRO and over 100 pages of false allegations and half-truths. The TCHRO left me defenseless against Rachel Depalma's attempts to destroy my reputation. To say this has been one of the most emotionally trying, mentally exhausting, and financially draining experiences of my life is an understatement.
The truth is not harassment. My opinion is not harassment. As a domestic violence advocate and the founder of a domestic violence non-profit organization, she should recognize that the public has the right to know the truth about one's behavior and voice their opinions. It seems Ms. Depalma did not want me to share the truth, so she tried to silence me with costly litigation, as she has done to many others.
I am silenced no more. I will tell the story of the abuse I have suffered at the hands of this domestic violence advocate. On May 28, 2024, the Santa Clara County Superior Court DENIED Rachel Depalma's request for a Civil Harassment Restraining Order against me. Although, she ask for damages, those can not be granted in a restraining order case. She would have to file another suit for damages, which would be unfounded since she was unsuccessful in proving to the court that I had commited civil harassment. Had I done so, her requested order would have been granted.
There are countless ways I could share my story, but as Rachel Depalma stated in her August 23, 2023 video, "I'm choosing to tell the details of my story in court documents where I am subject to perjury. I have to say, under penalty of perjury, that I agree that this is what happened. So understand that it has more weight in a courtroom than it does on the app." CLICK TO VIEW.
In my final declaration to the court, I told my story under penalty of perjury. I spent many weeks of sleepless nights pouring through evidence and writing my declaration. I addressed her false allegations and half-truths, providing the context she omitted, including her attempts to harass me, get me fired as a volunteer from The Father's Rights Movement, and destroy my reputation. The court listens and DENIED her request. Below you will find a redacted version of my declaration. I am redacting certain names, last names and places to protect the privacy of those involved.
DECLARATION OF TAMMY
NOTE: The unredacted version of this declaration was filed in the Santa Clara County Superior Court Of California on April 19, 2024 in Case #: 23CH011825.
I, TAMMY, declare: I make this declaration in support of this RESPONSE TO REQUEST FOR CIVIL HARASSMENT RESTRAINING ORDERS. I have personal knowledge of the facts set forth herein and, if called to testify, would and could testify under penalty of perjury competently thereto. I, TAMMY, declare that I am the RESPONDENT in this matter. I reside in South Carolina, over 2300 miles from Santa Clara, California, and have not traveled beyond the east coast since January of 2019. As a single mother and survivor of domestic violence, I am dedicated to online content creation, specifically advocating for men's mental health, father's rights, and addressing false allegations. Additionally, my goal is to amplify the voices of overlooked male victims of domestic abuse.
I. INTRODUCTION AND BACKGROUND
1.) I categorically deny the allegations leveled against me. I have not engaged in stalking, harassment, or actions that could endanger the PETITIONER. There is no evidence of me inciting violence, collaborating with others to do so, or committing any unlawful acts of violence. I have not made credible threats, engaged in any conduct without legitimate purpose, or caused emotional distress to any reasonable person. Furthermore, I have not followed or stalked the PETITIONER, made harassing phone calls, or sent any harassing correspondence through any means. I have not participated in gang-stalking or collaborated in any harassment against the PETITIONER. I have never physically contacted the PETITIONER, Rachel A. Depalma, nor have I posed any threat to her safety. There have been no threats, verbal or physical, originating from me or instigated by me against her safety.
2.) I have had no direct contact with the PETITIONER in any form. To the best of my knowledge, I have never been in the same state as the PETITIONER unless she traveled to South Carolina. I have never reached out to her via phone, email, mail, private messenger app, or social media private message. I have never followed any of the PETITIONER's social media accounts. Our only interaction has been thru public social media content. My videos concerning the PETITIONER have been either responses to her ongoing attacks on my reputation or discussions of her nonprofit organization and legal proceedings, always without disclosing personal information about her. Any information I've shared has been sourced from her public social media accounts, websites, or online public court records. I have not initiated contact with individuals in the PETITIONER's offline life, such as family, employers, lawyers, or friends, with the aim of inciting negative behavior towards her.
3.) I have no plans to travel to California now or in the future. In the past decade, I visited California twice in 2017 and 2019, solely for events involving my ex-husband. I have no family, close friends, or property in the state. I am not employed by any California-based company and have no work-related connections there. While I sell merchandise on TeeSpring, which is based in California, all transactions occur online from my residence in South Carolina. Financial limitations and the lack of personal contacts in California make any near-future travel unlikely.
4.) The PETITIONER engaged in extensive public discourse with me, including posting over 5 hours of video content and 2 blogs, not including the content she has posted in January and February of 2024 to harass me further while I am left defenseless due to CHTRO. These interactions often involved malicious attacks on my reputation, insults, and attempts to discredit me. Furthermore, the PETITIONER contributed to the banning of my TikTok accounts, attempted to jeopardize my volunteer position, reported me to multiple agencies and utilized anonymous accounts to stalk and harass me. Additionally, the PETITIONER directed others to target harassment at my TikTok account and has made multiple attempts to connect me falsely to individuals or organizations to tarnish my reputation. Overall, the PETITIONER's actions demonstrate a pattern of harassment aimed at damaging my reputation. PETITIONER's involvement lacks integrity.
5.) I hereby inform the court that, for efficiency, I will resubmit any evidence previously provided. All required evidence for reviewing this declaration and my full argument will be filed simultaneously with this declaration. All video transcriptions have been done using the online service at https://www.veed.io for ease of reviewing this case from the paper documentation submitted.
6.) I notify the court of the PETITIONER's actions, which have disadvantaged me in defending against the allegations. Evidence has been provided in a manner that lacks full accessibility, with many videos not recorded or transcribed fully, requiring additional effort for clarification. Furthermore, the absence of assigned exhibit numbers to videos complicates reference in the allegations. Some videos are hosted on PETITIONER's Google Drive and were inaccessible without violating the CHTRO. Exhibit R-1 shows what I saw when I attempted to access the links provided to the court. PETITIONER was notified via email from my attorney on 1/28/2024.
The PETITIONER rectified the situation 6 days later on 5/3/2024, the fact remains that I should have never had to request access to evidence that was filed against me. Additionally, declaration-style text documents are submitted as Exhibits, containing personal accounts and opinions, which do not qualify as evidence. The referencing of Exhibits within Exhibits adds further complexity to comprehending the filings. I believe that all evidence not accessible via viewable links as well as all non-evidentiary Exhibits should be struck from the record.
7.) To the best of my knowledge, to avoid any further legal issues or provoking the PETITIONER, all content related to or perceived to be about them is private on all my social media platforms.
8.) PETITIONER has many enemies on TikTok (Exhibit R-2). Without my content on TikTok, hashtags associated with PETITIONER, #racheldepalma, #loveandjustice5 and #heifergate have millions of views and a combined 450 videos expressing concerns about Ms. Depalma's actions. PETITIONER's social media activities and non-profit have attracted a lot of negative attention.
9.) PETITIONER has been deemed a limited-purpose public figure by Chief Judge Treadwell, as evidenced in Exhibit R-3, pages 24-30. CLICK TO VIEW. My social media posts, which respond to PETITIONER's content or comments about me as well as focus on expressing truthful information or personal opinions regarding PETITIONER's actions in the domestic violence space, excessive litigation, and concerns regarding her non-profit organization. Notably, my posts coincide with PETITIONER's involvement in a federal lawsuit against TikTokers, Samantha Adamo and Laurinda, whose case documents are publicly accessible. This lawsuit, 5:22-cv-91-MTT - Rachel Depalma Vs Samantha Kern (Adamo), Laurinda & Tracy Korsland, highlights the dangers of litigation abuse and its impact on freedom of speech within the Domestic Violence community.
My concerns about PETITIONER's non-profit organization, No Peace No Quiet, Inc., were raised after its late October 2021 announcement and three months of harassment from PETITIONER. On 11/2/2021, I first expressed my concerns, which were later confirmed by Exhibit R-3, CLICK TO VIEW, the judge's order from the federal lawsuit.
Despite similarities in our content about PETITIONER, I was not initially involved in the federal defamation case filed on 3/2/2022. However, Exhibit R-4, a deposition excerpt from PETITIONER's case, indicates her consideration of involving me in the lawsuit.
The deposition reveals strategies to create content about me while avoiding detection regarding the pending lawsuit, which I perceived as an infringement on freedom of speech, echoing Chief Judge Treadwell's sentiments in Exhibit R-5, page 3. CLICK TO VIEW.
My content primarily focuses on PETITIONER's actions in the domestic violence space and concerns for domestic violence victims and survivors. I personally believe PETITIONER employs litigation or threats thereof to silence critics, a view confirmed by Chief Judge Treadwell's findings in Exhibit R-6, which characterize the federal defamation case as lacking judgment, and resulted in sanctions against PETITIONER.
Notably, PETITIONER's inquiry about her sanctions in her preemptively filed request for depositions indicates disbelief in her own sanctions. However, this information was gleaned from public court records, specifically Chief Judge Treadwell's sanctions detailed in Exhibit R-5, pages 4-5.
10.) PETITIONER EXAGGERATED THE AMOUNT OF CONTENT I MADE. PETITIONER claims there are over 2 hours of videos of me harassing her. The truth about a public figure is not harassment. Additionally, a large percentage of my content was in response to PETITIONER's malicious attacks on myself and the need to defend my reputation against those attacks. Everything I said about the defamation case or non-profit was true to the best of my knowledge. Everything else I said was my opinion of a Public Figure, the federal defamation case or my response to the PETITIONER's attacks on me. I believe the PETITIONER got this 2-hour number from her 2 youtube videos she presented to the court.
a.) The Manicured Mom Harassing Rachel DePalma - 2023 (01:06:56)* https://youtu.be/YxUzbSxrqZ0?si=RUElWzZMEez70l-6,
b.) The Manicured Mom Harassing Rachel DePalma - 2022 (43:11)* https://youtu.be/Y3j8ZKpxZqw?si=bM0TDCC4OiE748t
*NOTE: Upon finding out that the CHRO was DENIED, Rachel Depalma remove this evidence from public view. If was screen recording of my content, some that was about her and some that had nothing to do with her that she submitted as evidence. It was videos of my responding to her harassment and telling the truth about her actions and the defamation case.
When I removed all the videos that had nothing to do with the PETITIONER as well as all the background of her phone screen recordings and the evidence of her mass reporting my accounts, the total time of my videos is 47 minutes and 13 seconds. That is a big leap from the over 2 hours she states in her case documentation repeatedly. Exhibit R-7 is the shortened version of her 2 videos in which I removed all of the excess stuff that was not my content regarding the PETITIONER. CLICK TO VIEW.
11.) THE PETITIONER HAS POSTED OVER 5 HOURS OF CONTENT ABOUT RESPONDENT. The PETITIONER has shared a significantly larger volume of content concerning me. I have compiled a list of every video I have produced as evidence that the PETITIONER has posted, included as Exhibit R-8 in this declaration.
While I did not account for the time spent posting the same video across multiple platforms, I did include instances where the same video was posted repeatedly on a single platform. The total duration of the PETITIONER's videos amounts to 5 hours and 13 minutes. On 02/09/2024, the PETITIONER uploaded a video that I believe truly depicts the events surrounding this filing, as stated in Exhibit R-9. CLICK TO VIEW.
In this video, she remarked, "You know, how they do exactly what they're accusing you of doing and how they abuse you to the point where you lose your shit, and then you look like you are the crazy one, and then they leave out what their part was." Notably, when filing this CHRO against me, the PETITIONER omitted her own involvement in these events just as she says others do in her video.
II. ADDRESSING PETITIONER'S NUMEROUS FILINGS.
1.) PETITIONER'S INITIAL FILING FROM 8/8/2023. Since July of 2021, I have not engaged in harassment of the PETITIONER. Instead, I responded to her malicious attacks, which I will substantiate in this declaration and attempted to protect others from what I have experienced at the hands of the PETITIONER. The PETITIONER publicly engaged in discourse, sometimes knowingly inciting it, attempting to tarnish my reputation with assumptions, half-truths, insults, and lies. In response, I sought to warn domestic violence survivors about her concerning and malicious behavior, a cause that others have also joined due to their unique yet similar experiences with the PETITIONER. Currently, five of us are involved in legal proceedings filed by the PETITIONER. In addressing the PETITIONER's complaint, I will demonstrate the extent of harassment she has directed towards me and show that I am not the one that should be issued a Restraining Order.
1-a.) #2 - The PETITIONER's claim of relating to me through Ashly is false. Ashly was previously friends with Ms. Depalma and later became a witness for the defense in the Federal Defamation Case initiated by the PETITIONER in Georgia Federal Court, upon realizing the inappropriate actions of the PETITIONER. The PETITIONER made a video directed at me in July of 2021, prior to which I had no known connections with her. I did not interact with Ashly until Spring 2022, shortly before she became a witness for the defendants in the Federal Case. Ashly is a TikTok creator whom I have never met in person. I have only communicated with her through phone calls, private messages, and text messages.
1-b.) #5 Venue - The PETITIONER checked that I harassed her in Santa Carla County. I have not been in Santa Carla County since 2019. I have never met the PETITIONER in person. I did not harass her in the county.
1-c.) # 6 Other Court Cases: The PETITIONER checked other, and wrote "GA & CA, See Exhibit C." The PETITIONER may have mentioned my name in these cases, but I am neither a witness nor a listed party in any other case. It is only the PETITIONER that feels the need to involve me in all of her legal endeavors.
1-d.) #7 Description of Harassment: The PETITIONER states that the incident occurred in June/July 2023. I created only 1 video about the PETITIONER in June of 2023 to call attention to a spelling error in her video. However, I had no social media interaction with the PETITIONER and did not create any content about her in July of 2023. The PETITIONER neglects to acknowledge the years of harassment she subjected me to, while simultaneously accusing me of harassment. My actions were not harassment. I would not have been aware of the PETITIONER's existence if she had not initiated a campaign of harassment against me in July of 2021.
d.-i.) In July of 2021, the PETITIONER initiated contact with me for the first time by posting a TikTok video in response to my video about false allegations, accusing me of misinformation. She countered with statistics about Domestic Violence (DV) false allegations, which differed from mine. She demanded the source of my information, to which I explained that I was unable to provide it at the time as I was on vacation with my child and did not have access to my computer.
d.-ii.) On 07/15/2021 the PETITIONER's video claimed I couldn't provide a source, labeled me a liar, and directed viewers to her blog titled "She Is A Liar" (Exhibit R-11), published on 07/15/2021, at https://racheldepalma.blogspot.com/21/07/shes-liar-it-is-socially-irresponsible.html.*
This blog was linked to the PETITIONER's website (liarscheatersandgaslighters.com). As of my court filing on 12/11/2023, this blog remained public. However, the PETITIONER has since deleted the blog.
d.-iii.) On 8/10/21, the PETITIONER posted another video in response to my content (Exhibit R-12). CLICK TO VIEW.
At 1:48, the PETITIONER stated, "When the MeToo movement shows their political agenda, that is when the feminist movement lost all credibility after that." In this case, the PETITIONER utilized my anti-feminism stance to discredit me, despite agreeing that the movement had lost credibility. At 2:37, the PETITIONER mentioned, "So I've seen the early content, at least, some of the content on the Men Going Their Own Way website. And I understand why they've put this together. I don't agree with a lot of it, but I understand the social consequences that brought them to that breaking point." In this instance, the PETITIONER accused me of sympathizing with the MGTOW movement, labeling it a hate group, yet she herself expressed sympathy towards it.
d.-iv.) On 08/21/21, PETITIONER insulted me in her TikTok video (Exhibit R-13). CLICK TO VIEW. She types on the screen beside my video playing, "...your video is socially irresponsible, reckless and endangers the lives of women who are truly in a domestic violence situation by minimizing the actual danger and using cherry picked numbers to push your narrative…"
d.-v.) On 8/30/21, PETITIONER's TikTok video makes vile accusations about me. (Exhibit R-14). CLICK TO VIEW. PETITIONER said, "...your posting is socially irresponsible, because we all know that abusers don't take responsibility for their actions. And when they get arrested for beating that woman within two inches of her life or putting her 6ft under, he's going to blame your content...." Suggesting I bear any responsibility for someone's abuse-related death is a reprehensible accusation. In a bid for peace of mind, I blocked her accounts, hoping to evade further interaction. Unfortunately, luck wasn't on my side.
d.-vi.) In October of 2021, the PETITIONER interacted with TikTok mutuals (Paul of Come One Man Podcast & Retired Goat), involving me in the conversation. A follower informed me, prompting me to unblock her to reply. I commented on the video to tag Paul, alerting him to her mention. In response, the PETITIONER made several insulting videos directed at me.
d.-vii.) On 10/21/21, the PETITIONER's TikTok video (Exhibit R-15, CLICK TO VIEW) response to my comment about Paul was highly condescending and harmful. She labeled me socially irresponsible and once again insinuated that I could be accountable for women's deaths at the hands of abusive men.
d.-viii.) On 10/21/21, the PETITIONER's offensive TikTok video (Exhibit R-16, CLICK TO VIEW) response labeled me a narcissist and wrongly assumed I had previously blocked her because I couldn't provide statistics. She was wrong. I chose not to engage with the PETITIONER after she labeled me a liar in a blog post and created numerous disparaging videos. I protected my piece from her malicious attacks.
d.-ix.) On 10/21/21, the PETITIONER's TikTok video (Exhibit R-17, CLICK TO VIEW) suggests I'm a liar and dismisses my narrative as "bullshit," once more implying I endanger women. It's worth noting she directed these accusations at a domestic violence and attempted rape survivor, information she would have known had she bothered to ask rather than attack. This relentless attack on 10/21 prompted my first direct video response to the PETITIONER on 10/26, following nearly four months of harassment, one blog post, and numerous videos.
d.-x.)On 10/26/21, in Exhibit R-18 (CLICK TO VIEW), PETITIONER's TikTok response tried to outshine me with her community non-profit work, unaware of my involvement with The Father's Rights Movement (TFRM) and my charitable history. She proudly stated, "We are not the same." I agree, and I take pride in our differences. In my response video, I voiced concerns about the PETITIONER, her new non-profit, and discussed her recent anti-MGTOW blog.
d.-xi.) On 10/27/21, in Exhibit R-19, pg 1, PETITIONER criticized my parenting, prompting her followers to hurl insults and harassment at me. In her video comment section, she remarked, "...she is raising boys to be men we fear…" despite my having only one son, who was eight years old at the time, with whom I share 50/50 custody. The PETITIONER lacks insight into our son's upbringing. Dragging an innocent child into her online feud is regrettable. Furthermore, PETITIONER's On 10/27/21, in Exhibit R-19, pg 1, PETITIONER criticized my parenting, prompting her followers to hurl insults and harassment at me. In her video comment section, she remarked, "...she is raising boys to be men we fear…" despite my having only one son, who was eight years old at the time, with whom I share 50/50 custody. The PETITIONER lacks insight into our son's upbringing. Dragging an innocent child into her online feud is regrettable. Furthermore, PETITIONER's followers proceeded to disparage me based on her videos, labeling me "childish,""immature," and "someone's narcissistic mother," while asserting that "everyone in her life is sick of her."
d.-xii.) On 10/27/2021, one of the PETITIONER's followers posted a disparaging video in response to her negative comment about my son. The PETITIONER then cheered her on in the comment section, continuing to insult me, as shown in Exhibit R-19, pg 2.
d.-xiii.) On 11/10/2021, in Exhibit R-20 (CLICK TO VIEW), PETITIONER's TikTok questioned my volunteer position with TFRM, suggesting it was a reaction to her non-profit announcement or an attempt to prove something after she labeled me "socially irresponsible." However, she was mistaken. My involvement with TFRM began three months earlier when Walter Richardson approached me, entirely unrelated to the PETITIONER. Despite blocking me, she continued to talk about me.
d.-xiv.) On 11/12/2021, with TFRM's permission, I commented on PETITIONER's 11/10 TFRM video (Exhibit R-21, CLICK TO VIEW) from their TikTok account, urging her not to undermine a valuable organization with personal vendettas. In response, PETITIONER's TikTok video accused me of being the one who would ruin the organization, deemed me unprofessional, and inferred I was connected to an unidentified individual who left a voice message at her non-profit. PETITIONER exaggerated my support of MGTOW. Prior to interacting with Ms. Depalma, I had only posted 1 video regarding MGTOW and then I posted 1 regarding Depalma's Blog about MGTOW. It's worth noting that PETITIONER herself has posted videos speaking positively of MGTOW (Exhibit R-12, CLICK TO VIEW).
d.-xv.) In addition to the above content, 9 additional videos were posted directed at me by the PETITIONER. I do not have the exact dates of the posting, but video evidence of their existence was provided on 02/05/2024 when PETIONERS posted additional YouTube content harassing me. In these videos, she agree with me at times, while others, she attempts to disprove and humiliate me by saying things like, "you're still not taking responsibility for your shitty research, your false narratives, and the fact that your content is harming domestic violence victims," "you're not a rational person and I've known this since day one," "Well, apparently, passive aggressive behavior is also a trait of yours, along with not being able to take responsibility," "Your shitty research and your false narratives," "your video is socially irresponsible, reckless and endangers the lives of women," and "You trying to gaslight victims of abuse, not taking responsibility for your behavior and your content." These can be seen in Exhibit R-24-A. CLICK TO VIEW. CLICK TO VIEW VIDEO TRANSCRIPT.
d.-xvi.) On 11/30/21, PETITIONER attempted to have me fired from my volunteer role at TFRM. She emailed TFRM's Board of Directors and Leaders (Exhibit R-22 pg. 1), falsely accusing me of defaming her non-profit and claiming she reported me to the FBI and Department of Justice. She referenced an unrelated situation involving another individual, Christine, @thetraumalady. At this juncture, to the best of my recollection, I had made one video expressing concerns about her non-profit and one video in response to her attacks and one video calling out the fact that she had gone private after doxing a DV survivor's IP address and bunch of creators voice concerns about her non profit. These 3 videos did not constitute defamation or harassment. The recipients of the defamatory email from TFRM are listed on Exhibit R-22, pg 2, with "Me" referring to Walter Richardson, who provided me with the screenshot. Additionally, PETITIONER attempted to connect with the head of the non-profit organization via LinkedIn, as evidenced by a text exchange between Ashly, Ashley Heaton, and Rachel Depalma (Exhibit R-22, pg 3), provided by Ashly.
Furthermore, in her deposition (Exhibit R-23), Ms. Depalma admitted to reporting me to the FBI for cyber harassment, alleging that I spread false information about her organization and her personally. However, none of my statements regarding her or the non-profit were false.
Moreover, she mentioned in the deposition a conversation with friends discussing whether to include me in a federal lawsuit or just send a cease and desist. She stated (Exhibit R-24), "a cease and desist would be better and sending it to her -- her nonprofit organization that she works for, cc'ing them on it just to freakin' piss her off,' indicating malicious intent. PETITIONER intended to provoke me yet claims to fear me. It is evident that I did not harass the PETITIONER; rather, the opposite occurred.
d.-xvii.) On 12/5/2021, the PETITIONER continued to target me, as evidenced by Exhibit 24-B, which contains screenshots from a text conversation where she jokes with Ashly and Ashley Heaton about taking my property, speculating on what she believed to be my home address. Throughout 2021, I have documented 20 videos, a blog post, an attempt to get me fired, reports to multiple agencies and online stalking to locate my home address while my response consisted of only 3-4 videos. The level of contempt and vindictiveness displayed by the PETITIONER at a stranger on the internet, was unprecedented in my experience. If I had the financial means, I would have pursued a harassment lawsuit against her at that time. After enduring months of her actions, she was now attempting to locate my residence with the intent to take my property, a discovery that was deeply distressing and triggering for me.
NOTE: This is not the correct current information for neither of the people they were looking for or are mentioned in the above screenshots.
1.-e.) #7 a. (3) The PETITIONER alleges that I have participated in gang stalking with Ashly. Ashly is an acquaintance with whom I have engaged in mutual social media interaction, including commenting on each other's posts and sharing content. While I consider her a friend in the online sphere, we have never met in person which makes her an acquaintance. Ashly has publicly criticized the PETITIONER's actions, litigation, and non-profit organization, but I have neither encouraged her to act nor coordinated our content. This is a baseless assumption by the PETITIONER. Any content we post is of our own volition, without coordination. It's worth noting that the PETITIONER has a restraining order against Ashly, which she frequently mentions in her filings. (Santa Clara County Court Case: 23CH011589 - Rachel Depalma Vs. Ashly.)
This case was filed on 5/2/2023 just days after Ashly has requested the PETITIONER stop harassing her., The restraining order was granted on 6/12/2023, a decision I believe was unjustified as Ashly was unable to defend herself due to financial constraints. The PETITIONER seemingly prompted Ashly's response, then swiftly filed for the restraining order and has since publicly used it to shame her multiple times, leaving Ashly unable to defend her reputation due to the CHRO. I will demonstrate similar behavior towards me. Ashly, an unemployed, single mother and domestic violence survivor residing in Texas, couldn't afford counsel or travel for defense in this litigation. Despite her request for a virtual hearing, Court 4 deemed it impossible. Additionally, PETITIONER accuses me of inciting hate and violence in the federal case, which is untrue. Sharing public court documents, discussing the litigation, supporting a GoFundMe for defendants' legal fees, and expressing my opinion are not incitements of hate or violence. This federal lawsuit, involving a Public Figure, impacts both the domestic violence and TikTok communities and warrants discussion. I didn't create content on behalf of the defendants, but because I believed in their innocence, later confirmed by the judgment in their favor. My content regarding the federal defamation case wasn't harassment nor did it incite hate or violence.
1.-f.) #7 a. (4) PETITIONER's claim that I harassed her for Laurinda is false. Laurinda is a social media acquaintance with whom I first messaged with on 11/21 when the PETITIONER offered her the suicide hotline for asking questions about the non-profit. I had no knowledge of any firearm discussion and was not involved in Laurinda's decisions or alleged threats. Laurinda confirmed she never threatened the PETITIONER. In Exhibit R-25, an excerpt from PETITIONER's federal deposition, this was discussed. Laurinda made a video about a threatening message received via a JotForm, citing she had a gun for self-defense. I spoke publicly about the Federal Defamation Suit against Laurinda, but I did not create content on her behalf. This is an unfounded assumption by the PETITIONER. My content was not harassment and did not incite hate or violence.
NOTE: In the following section, I will be redacting the name of a man that, in my opinion, was falsely accused by Rachel Depalma in 2019, drug across social media, had a book written about him and had to file a defamation suit against her. In a settlement of the suit, he was award $75,000. He had to file for settlement enforcement in 2023 because she continued to defame him and was awarded $41,000 in damages and attorney's fees. She is like a non famous version of Amber Heard. We should just call her Rachel Herd, which fits well with #heifergate and her anonymous cow accounts, more on that later.
1.-g.) #7 a. (5): My content regarding the PETITIONER was not an attack, it was a response to PETITIONER's attacks, the truth and my opinions. As she claimed, it was searchable on google for anyone to find as is all the content that Ms. Depalma makes using her legal name on her many social media accounts including but not limited to TikTok, Instagram, Twitter and YouTube as well as numerous blogs and websites she manages for herself and her non-profit. She refers to her alledged abuser finding this content, but he could just as easily find her content via her postings. Additionally, as per the settlement agreement in Santa Clara Superior Court Case 20CV370750 - Falsely Accused Man vs Rachel Ann Depalma, the PETITIONER is required to use a disclaimer if she mentions she is a victim or survivor of abuse publicly. This can be seen in Exhibit R-26 - 20CV370750 Minute Order, regarding Falsely Accused Man's motion to enforce settlement. If she cannot publicly say that she is a victim of abuse without a disclaimer, how can she possibly say that my content could be found by her abuser? PETITIONER claims that I made unproven allegations.
To the best of my knowledge, everything I have said regarding the PETITIONER has been true, believed to be true or my opinion. She also mentions Ashly posting where to find her protected address. This has nothing to do with me. This is not something that I did and should have no bearing on this case. I have never posted the protected location of the PETITIONER. Additionally, for someone who is so concerned about her protected address not being found, she filed it publicly in Santa Clara County Court Case: 23CH011589 - Rachel DePalma vs Jones Lang LaSalle, Inc. et al as seen in Exhibit R-27 - 20CV366367 Plaintiff's Evidence Packet in part of a deposition of the PETITIONER she gives her current address (Exhibit R-27).
Additionally, the PETITIONER has not done a thorough job of scrubbing herself from the internet prior to posting her legal name and state all over social media. If I search "Rachel Depalma, California" online, I quickly find this link, (REDACTED TO PROTECT PROTECTED ADDRESS) which reveals REDACTED Search which publicly lists her protected address. I also found this link (REDACTED TO PROTECT PROTECTED ADDRESS) which shows her protected address (Exhibit R-28). I have never listed or disclosed Ms. Depalma's public address and only became aware of it when Ashly brought this court document to my attention.
1.-h.) #7 a. (6): PETITIONER alleges police involvement regarding my actions. However, I've spoken with the San Jose Police who confirmed there's no active investigation or reports specifically naming me as the offender. A search of their system didn't yield my name. If a report exists, it wasn't directed at me, and I can't fathom why one would exist. I provided my name and contact details to the police and assured them of my cooperation should an investigation arise.
1.-i.) #7 b. PETITIONER alleges my harassment and incitement of violence led one of my 200K followers to contact her non-profit with vulgar, harassing, and threatening messages. However, it's worth noting that none of my tiktok accounts had 200k followers and at the time, I had less than 150K. The reference made by PETITIONER in her 11/12 (Exhibit R-21, CLICK TO VIEW) video suggests the caller's message related to an issue she addressed in a previous video, unrelated to me. PETITIONER said, "What he's referring to in that message is a video that I posted with regards to the misconduct ticketing system where I threatened to get the law involved because the law was being broken." The unknown caller, made no mention of being associated with MGTOW, another assumption by the PETITIONER. Additionally, PETITIONER omitted her engagement in uncivil discourse with other social media creators in the Red Pill/MGTOW space at the time. Her claim of a connection between me and the caller, who remains unidentified, holds no ground. The blog she references has since been deleted (Exhibit R-29), and I maintain no connection to this call.
1.-j.) #11 - PETITIONER alleges I was informed she would seek a TRO in court, which is untrue. While PETITIONER often discusses documenting evidence for potential litigation, she has not validly requested I cease posting about her. Despite having access to my official address and website contact form, PETITIONER has not sent a Cease & Desist Letter via mail, email, or any social media app. In a video posted in 05/22/2022, PETITIONER asked me to stop posting about her, though the context of the post needs clarification as it mocked a stressful and dangerous situation, I was involved in.
j.-i.) Leading up to 05/18/2022, I faced severe online harassment from users 2 social media users. They doxed me, threatened me and my child, and falsely called the police on 05/18/2022. Also, it is suspected they are connected to a Child Protective Services call on 5/20/2022. Authorities deemed both calls false. With the assistance of the police, I filed a cyber harassment complaint with the FBI. At the direction of the Fort Mill Police Department, on 5/21/2022, I posted Public Notices urging the harassers to cease and informing them of further action. These can be seen in Exhibit R-30, pg 1.
j.-ii.) Less than 16 hours later, on 5/22/2022, PETITIONER posted a video on her @loveandjustice5 TikTok page, nearly identical to my previous notice but with the addition of "Watch till the end" in red text. She used the same background music and even thanked me with emojis showing my original post to @redacted feminist creator as seen in Exhibit R-30, pg 2. This mocking gesture occurred despite the seriousness of the situation, with threats made against me and the police called to my home. PETITIONER's actions were not a request to stop but rather another instance of harassment. Petitioner posted this video just 5 days after posting another youtube video harassing me in which I had not responded to. Consequently, I did not consider this mocking video as a valid request. Despite PETITIONER's claims, my videos were not an "obsessive tirade" but an attempt to address her ongoing harassment.
PETITIONER alleges that I deactivated my account briefly and then reactivated it on 01/25/2023, solely to harass her. This is false. My account was banned in 05/03/2022. It was reinstated on 12/7/2023. I deactivated in late December of 2023 due to safety concerns with the intention of coming back. Less than 10 days before filing this CHRO, PETITIONER posted a video mentioning my account name, @stopsilencingmen (Exhibit R-31). If PETITIONER truly wished to avoid interaction, she should not have engaged in it herself. PETITIONER consistently initiated contact by talking about me in videos after long periods of silence and then becomes upset when I respond. My responses are not harassment but rather a defense.
NOTE: Petitioner claimed in her filing from the same date that my account name was @notdyingalonewithcats and was not @stopsilencing men, which is not accurate. For a short time, I changed my profile name from Tammy - The Manicured Mom to Not Dying Alone With Cats but the Stop Silencing Men logo and username has been used in association with that account since I first opened it.
1.-k.) Statement of facts: 1, The PETITIONER alleges that we exchanged a few videos in 2021, which is far from true. During that time, the PETITIONER made at least 20 videos about me, published a blog, reported me to the DOJ and the FBI, and contacted the non-profit I volunteered at in an effort to get me fired and stalked the internet in search of my private residence. In contrast, I made a few video responses. The PETITIONER claims that I engaged in a coordinated effort of harassment that led to her being threatened and harassed. However, I have never coordinated my content with any individual, nor have I asked anyone to harass or threaten Ms. Depalma. My content was intended to shed light on the concerning actions of a public figure in the domestic violence space. The PETITIONER's assumptions about our coordination efforts are untrue.
I believe that Ms. Depalma's fear stems from her clinical diagnosis, not from my actions. Exhibit R-32, which contains Exhibit C of the PETITIONER's publicly filed opposition to an ex-parte application for contempt of court and order to show cause in Case No.: 20CV370750. It's a letter from the PETITIONER's psychologist, Timothy C. Engelmann, discussing her Post Traumatic Stress Disorder and stating, "With this, Ms. Depalma lives in fear of others and remains fairly withdrawn." My actions and content would not cause a reasonable person fear.
The PETITIONER claims that she has repeatedly asked me to stop harassing her. However, she mentioned that she posted only one video directed at me asking me to stop in May of 2022 which I discussed previously was not a valid request due to it's mocking nature. Since that time, the PETITIONER has initiated contact with me on many occasions, as I will evidence throughout this declaration. My content regarding the PETITIONER is not harassment and does not incite violence. The PETITIONER's perception of violence is skewed. In the PETITIONER's federal court deposition (Exhibit R-33), Attorney Nick Pieschel asks Ms. Depalma about me and said, "And what did she state that you perceived to be a threat of violence?" to which she responded, "She said, 'I can't wait to see you in Georgia' with some nasty music playing in the background." I made this statement in a video during the federal case when I thought I was going to be called as a witness or possibly added as a defendant. This is not a threat of violence, nor is it harassment. It simply reflects my expectation of appearing in Federal Court in Georgia with the PETITIONER.
The attorney goes on to ask, "But what threat of violence?" Ms. Depalma responds, "That one, also to her mannerisms. She just comes across like a 'Single White Female,' like she's stalking me. I consider that to be violence." How can my mannerisms be violent? "Like she's stalking me" is a made up assumption in the PETITIONER's head that is not true. I have only ever discussed things regarding the PETITIONER that are publicly available in court records or in her TikTok content. I have never researched her to find her location, unlike she has done to me. I have never contacted were she works, like she has done to me. I would have no reason to be involved with the PETITIONER had she not initiated and perpetuated this discourse. I have never incited violence against or been violent towards the PETITIONER.
1.-l.)Statement of facts: 2, The PETITIONER alleges that I am a men's rights activist and sympathizer of the MGTOW group, this is merely her opinion and not factual. While I do advocate for men, I do not identify as a men's rights activist and am not affiliated with any men's rights groups. I am an egalitarian. Regarding MGTOW, I have no association with the group and do not sympathize with its radical subset. The PETITIONER's claim that I called on MGTOW to harass her is false; I have never made such a video where I addressed members of MGTOW directly. As for the merchandise I sell, it is irrelevant to this case and should not impact the litigation. The PETITIONER's dislike of it does not affect the grounds for this lawsuit.
1.-m.) Statement of facts: 3, PETITIONER alleges that I've created over 2 hours of content about her, citing YouTube videos. As mentioned in I.) 10.), after removing not related content from those videos, I've produced under 48 minutes. However, PETITIONER conveniently omits mentioning her own over 5 hours of content about me, along with 2 blogs.
1.-n.)Statement of facts: 4, PETITIONER brings up Ashly again whom I covered in previously.
1.-o.) Statement of facts: 5, PETITIONER alleges that I escalated harassment regarding the defamation case. However, discussing public court documents, supporting legal funds, and expressing opinions on the case do not incite hate or violence. This federal lawsuit impacts both the domestic violence and TikTok communities. Regarding the claim of planning to stalk PETITIONER at her recent hearing, it was a public court proceeding in the Santa Clara Superior Court which I intended to watch online from home. My social media often addresses false allegations, like in the Falsely Accused Man case, where defamatory claims were made against him. It's important to remember that accusations don't equate to guilt, and Falsely Accused Man was never charged or proven guilty, hence the reason for his defamation case against the PETITIONER.
1.-p.) Statement of facts: 6, I will address the alleged harassment as I discuss each exhibit. Regarding the mentioned TikTok video, I do want to clarify, here and now, that I did not mentioned Ms. Depalma's name in the referenced video, nor was she the reason I reactivated my account. The PETITIONER's assumptions and out of context misinterpretations will be addressed in detail as we examine the exhibits.
1.-q.) 8/8/2023 - PETITIONER's Exhibit C - Exhibit C represents the PETITIONER's subjective interpretation of events and should not be considered as evidence. Exhibits are meant to offer additional information or proof of facts, not to tell a narrative. Nonetheless, I will address the PETITIONER's claims as this is my only chance to defend myself. She alleges that I am friends with the restrained party, Ashly, and the defendants in the defamation case. However, it's important to note that our association stemmed from the PETITIONER's behavior towards us. Regarding her assertion that I engaged in vile conduct despite her requests to stop. My conduct was never vile and she never validly requested I stop. In neither of the mentioned videos did the PETITIONER say she was in fear for her safety. Furthermore, PETITIONER's request on 5/21/2022 was mocking a very serious situation, as detailed in previously. Additionally, PETITIONER overlooks her own malicious behaviors between November of 2021 and now, as she continues her path of reputation destruction against me and I can not respond due to the CHTRO.
q.-i.) During Feburary thru April of 2022, PETITIONER was involved in a TikTok controversy dubbed "Heifergate". Along with a group of online acquaintances, including Ashly, Ashley Heaton and others, PETITIONER and friends created anonymous accounts which they referred to as the "Heifers", identifiable by cow-themed profile pictures. These accounts were used for stalking, harassment, mass reporting, and posting inflammatory content targeting various individuals, including myself. PETITIONER admitted to her involvement with these accounts in her federal case deposition (Exhibit R-34).
Furthermore, in a text conversation (Exhibit 35, pg 1), PETITIONER directed her associates to target top accounts, including mine, for harassment. The screenshot (Exhibit 35, pg 2) reveals eight anonymous accounts involved in this campaign, there may have been more. Being targeted by multiple anonymous accounts was distressing, especially given the unknown potential dangers. It's noteworthy that those harassed were predominantly survivors of domestic violence. PETITIONER's involvement went beyond mere participation; she actively directed the targeting of individuals, including myself, as evidenced by her messages. PETITIONER's 2/16/2024 exhibit submission provided some of the, at least 15 harassing videos, she posted on her "heifer" account in PETITIONER's Exhibit 10, PAGE 1 filed on 3/1/2024 at 9:39 AM.
q.-ii.) From December of 2021 to April of 2022, I refrained from creating any content specifically about the PETITIONER. During this time period, she only received one mention at the end of a video regarding Emma Bois. Despite this, she persisted in harassing me through comments on TikTok, Anonymous "Heifer" accounts and on her personal @loveandjustice5 Tiktok account. On 01/09/2022, another creator, Emma Bois, who I was actively engaging in discourse with, posted a negative video about me. The PETITIONER joined in, leaving disparaging comments about me as seen in Exhibit R-19, pg 3. It's worth noting that my relationship with Emma had soured in December of 2021, and the PETITIONER's interaction with her only arose after our conflict began.
q.-iii.) On 01/09/2022, PETITIONER left insulting comments on another disparaging video from Emma Bois, mocking my emotional maturity as seen in Exhibit R-19, pg 4. It seems Ms. Depalma tends to align with anyone who shares animosity towards her target.
q.-iv.) On 01/09/2022, I posted a video addressing harmful statements made by Emma Bois sympathizing with and justifying abuse against women. I highlighted the dangers of such narratives and noted the Petitioner's apparent support for Ms. Bois by engaging with her content, albeit not necessarily in direct response to that specific video. The video in question, as provide by the PETITIONER as the first video referenced on PETITIONER's Exhibit 11, PAGE 1 filed on 3/1/2024 at 9:39 AM. Despite any potential claims of ignorance, Ms. Depalma, given her involvement with domestic violence victims and survivors, bears a responsibility to ensure the safety of those she associates with. Emma Bois is not the sole concerning individual with whom the Petitioner has aligned herself. Petitioner's public connections on TikTok with convicted felons Izzy White and Rikki Cornelisse, alleged abuser Mike Leal, as well as a man with a domestic violence harassment conviction, Brian Carlsen, raise significant alarms for victims and survivors.
q.-v.) On 01/10/2022, in a video by Emma Bois, PETITIONER once again left negative comments, criticizing my research as seen in Exhibit R-19, pg 5. Emma Bois has openly admitted to being a pathological liar, recovering porn addict, recovering alcoholic, and husband abuser who lives with Borderline Personality Disorder. It's concerning that the head of a non-profit publicly associates with individuals like Ms. Bois. PETITIONER further supported Emma by featuring her in multiple videos on her TikTok account and engaging with her in the comments section.
q.-vi.) On 01/22/2022, the PETITIONER posted a video in support of Emma Bois, as evidenced by additional exhibits provided on 02/16/2022 and seen as the second video referenced on PETITIONER's Exhibit 11, PAGE 1 filed on 3/1/2024 at 9:39 AM. Emma Bois engaged in ongoing harassment towards me from 12/3/2021, until her TikTok account was banned in September 2023. This harassment culminated in Emma weaponizing the death of my father to brain cancer against me, causing significant mental health distress for me and my family, particularly as these actions coincided with what would have been my parents' 50th wedding anniversary. Despite attempts to address the situation with tributes to my father, responses to Emma's false claims, and even extending an apology to Emma for any part I may have played in the conflict, she persisted in justifying her behavior and engaging in arguments with others on TikTok, resulting in the eventual banning of her account due to her hostile demeanor. PETITIONER's Exhibit 11, PAGE 3 filed on 3/1/2024 at 9:39 AM shows my heartfelt apology to Emma Bois.
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q.-vii.) On 01/22/2022, the PETITIONER commented on a video disparaging me by Brian Carlsen, whose TikTok account "brettstars06" has since been banned (Exhibit R-19, pg 6). At the time, Brian faced public accusations of domestic violence and had multiple pending charges against him related to domestic violence. It is concerning that the head of a domestic violence non-profit would engage in the comment section of an alleged abuser's video, just another reason for our concern. The PETITIONER's comment suggests collaboration with Brian against me, indicating a troubling level of vengeance and a willingness to associate with an alleged domestic violence abuser while leading a domestic violence non-profit. Upon being provided evidence that one of his alleged victims lied, I befriended Brian, for a short period, to find out the truth. PETITIONER provided an exhibit from a Tiktok Live I did with Brian Carlsen during this time period. Subsequently, upon learning more about Brian's actions and the truth behind the allegations, I chose to disassociate myself from him entirely in June of 2022.
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q.-viii.) On 2/11/2022, the PETITIONER employed her anonymous "heifer" account to harass me. The post featured a screenshot of my content, accompanied by audio saying, "FUCK OFF." and concluded with a message criticizing my work and character that said, 'The content you create is dangerous to society as a whole. You can't re-search due to your inability to see beyond your own hypocrisy and hate. You have no business helping others until you learn to help yourself and heal from your own bullshit." I am grateful for the petitioner's inclusion of this additional evidence of her harassment in her 02/16/2024 exhibit submission of PETITIONER's Exhibit 10, PAGE 1, item #2, filed on 3/1/2024 at 9:39 AM.
q.-ix.) On 2/11/2022, the petitioner used her anonymous "heifer" account to harass me again. She named the file provided, "Restored content that Sullivan had taken down." This is an assumption. Until this evidence was provided on 02/16/2024, I had never seen this video before and most certainly did not report it. When there are 8 or more anonymous "heifer" accounts harassing you, you don't see everything. The video also reveals harassing content aimed at other creators, with at least 15 videos on the page and 3 drafts ready for posting. PETITIONER's Exhibit 10, PAGE 1, item #5, filed on 3/1/2024 at 9:39 AM.
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q.-x.) Between February 22nd and 24th of 2022, an account named @mrbodycam posted five aggressive videos about me, making false accusations including claims about me pocketing money I solicitated for non-profits. He commented on one of his videos (Exhibit R-19, pg 7)"basically all proceeds go straight to her pocket unless she feels like donating parts of it." Despite my clarification and warning of hearing from my lawyer, he persisted, even spreading falsehoods on Twitter. He blamed me for his videos getting violations and made the same untrue allegations about me pocketing money as seen in Exhibit R-19, pg 8.
While I reported the harassing videos, I did not mass report his account. However, PETITIONER swiftly supported his lies on TikTok, calling me derogatory names without verifying the claims. PETITIONER ends her support video with "To that large content creator who did this to this guy, you're a real piece of shit," as seen in Exhibit R-36. PETITIONER's habit of siding with those against me is evident.
Despite @mrbodycam's mental health struggles not being disclosed on TikTok, PETITIONER exploited this information to discredit me in her video. @mrbodycam thanked the PETITIONER on his twitter account for supporting him as seen in Exhibit R-19, pg 9. PETITIONER further misrepresented my actions in her blog as seen in Exhibit R-37 pg. 6. Her malicious portrayal of the situation aims to tarnish my reputation. Contrary to her claims, I never threatened legal action against @mrbodycam, I said if he did not cease, he would be hearing from my attorney. I intended to send an official cease and desist if I could locate him.
q.-xi.) Around February 2022, PETITIONER sent a disturbing voice message to Ashly and others, discussing targeting the non-profit I work with as heard in Exhibit R-36-A. LISTEN TO AUDIO. She knowingly attempted to provoke me as she said, "that's the way you piss her off and get her to get back in line is through that organization," while attempting to shift blame onto me. Despite my silence about her for months, she continued to pursue me, even making derogatory remarks calling me a "a single, white, crazy ass female." It's worth noting that prior to this voice message, I did not engage in actions such as searching for her home, creating 20 plus videos, or writing blogs – those were carried out by the PETITIONER.
q.-xii.) On 03/02/2022, PETITIONER initiated a federal defamation lawsuit against Ms. Adamo, Laurinda, and Ms. Korslund. Prior to defendants being served on 03/03/2022, convicted felon Rikki Cornelisse publicly disclosed the lawsuit on TikTok. It is evident that Mr. Cornelisse could only have obtained this information so promptly if provided by the PETITIONER. Consequently, the PETITIONER knowingly disclosed the home addresses of three domestic violence survivors to a convicted felon, enabling him to harass them on social media, which he did. A voice message exists of the PETITIONER boasting and laughing to a friend about her ability to release the defendants' home addresses while protecting her own under the California Safe At Home program. This instance exemplifies the PETITIONER's malicious conduct, endangering domestic violence survivors.
OFFICIAL COURT DECLARATION WILL CONTINUE IN PART 2.
We are only 21 pages into my 75 page declaration and as you can see, Rachel Depalma has thus far initiated and perpetuated the harassment against me. I had no idea just how bad it was going to get, but wait till you read what is coming next in PART 2. When I tell you, I was not expecting the response that I received from posting one video supporting Sam and Laurinda and their GoFundMe to help defray the costs of fighting a Federal Defamation Case against her, it is a ginormous understatement. I have never experience this level of contempt and harassment. Video upon video across multiple platforms, and multiple Tiktok accounts all posted by the women who filed for a Civil Harassment Restraining Order against me.
This was one of the most insane things I have endured. The level of malice in which she attempt to erode my credibility far surpassed anything I thought possible, but I was determined that the truth would be told and that I would continue to support Sam and Laurinda in having their voices heard as Rachel Depalma was attempting to silence them in Federal Court. So stay tune for more of this wild ride. And please rememeber, in the midst of chaos sparkle, don't let life dull your shine.
Much Love,
The Manicured Mom.
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