In the complaint filed Thursday. Avodah Farms v. O'Hara-Rusckowski (D. Colorado.):
Avodah was formed in February 2020. We work to restore and reintegrate female survivors of prostitution (“survivors”) through comprehensive, Christ-centered care provided by Catholic nuns and a faith-filled community. Avodah carries out non-profit missionary work throughout the United States…
During the relevant period in which this action occurred, Rusckowski was a member of the Board of Directors of the American Society of Malta and the Representative and Special Advisor on Trafficking in Persons to the Ambassador of the United Nations Command to Malta.
In 2021, Rusckowski connected Avodah and Fitzpatrick to the Oblates (“Lowell Home”), a religious group that was seeking to sell to Avodah a specific property located at 27 Kirk Street, Lowell, Massachusetts. The Lowell Home was intended to be used as a safe home for survivors, their children, and religious nuns who contracted with Avoda to care for survivors.
Despite contributing significant funds to Avodah for the specific purpose of supporting Avodah's mission, the defendants did not possess any legal right or property interest to exercise control or decision-making authority over the Lowell Home development. Nonetheless, Defendants, through their actions, words, and conduct, made significant efforts to unlawfully force Plaintiffs to abandon the Project so that Defendants could implement their new vision…
Rusckowski and the Maltese defendants launched a smear campaign against the plaintiff.
Rusckowski leveraged his influential position in the Catholic community to knowingly make false and defamatory statements to third parties that Avodah was “stealing” and “misusing” donor funds. Rusckowski also revealed to a third party that Avodah was a “labor trafficking” religious sister. The statements were false and/or were made with reckless disregard for their falsehood with the intent to be acted upon, relied upon and disseminated accordingly.
In the winter of 2023, the defendants made oral and/or written statements to representatives of the Archdiocese of Denver that Avodah had “embezzled” donor and investor funds and “labor trafficked” nuns. At the time these statements were made, defendant knew they were false and recklessly disregarded their falsity with the intent to act on, rely on, and disseminate them.
Defendants' actions and statements interfered with Avodah's non-profit activities by causing the Archdiocese of Denver to refuse to recognize Avodah as a Catholic organization. [and also in other ways discussed in the Complaint -EV]This causes Plaintiff to suffer serious and serious injuries, damages and losses.
In February 2023, Rusckowski forwarded the above defamatory statement to influential Catholic leader Kristen Meyer, who then sent the following written correspondence to another third party: [Fitzpatrick] If he has approached you or the steward for money or if he is an intruder in any way, it is best to stay away from him. He has defrauded half a million of our good friends and, ironically and sadly, is trafficking our religious sisters. I would be happy to discuss further.” The statement was either false or recklessly disregarded its falsehood. Rusckowski knew the statement was false when he made it to Ms. Meyer.
On or about February 19, 2023, Rusckowski, along with Fitzpatrick, sent a group text to Avodah's network of potential donors, revealing that Rusckowski and Malta had severed ties with Avodah.[u]Unfortunately, the culprit is still on the “Deb's Friends” list. [Fitzpatrick] Not a friend. There are more demons than friends!! I will make another list for Deb's true friends!” The statement that Fitzpatrick was the devil was false and through reckless disregard of that falsehood, Plaintiff suffered serious and serious injuries, damages and losses.
In the spring of 2023, Rusckowski called Avodah's partners and prominent third-party figures within the Catholic community and national anti-trafficking space, saying, “Avodah and Fitzpatrick misappropriated funds and labor trafficking religious sisters hired by Avodah to care for victims. It was “prostitution”. The statements were false and/or made with reckless disregard for their falsehood. At the time the statement was made, Rusckowski knew it was false…
I cannot speak to the accuracy of either of these claims, and therefore whether a defamation suit can proceed in most cases. But I believe that secular courts “[t]His statement that Fitzpatrick was the devil was false.”
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